The Jersey Coast Anglers Association represents 65 recreational fishing clubs and over 30,000 anglers who fish the waters off New Jersey. Our member clubs have reviewed and discussed the draft addendum and provide the following comments.
We are pleased that the MAFMC voted to request that the Scientific and Statistical Committee reconsider their recommendation for the 2013 allowable biological catch (ABC) limit in light of the most recent black sea bass landings and stock information. We are confident that this action will result in more reasonable harvest levels. We believe that this anticipated increase should be large enough to allow all of the affected States to have the same regulations that they had in 2012. Regulations were tough last year and negatively affected many fishermen and the various businesses that they support. Restricting us further from a healthy fishery particularly in these economic times while our coast is trying to recover from Hurricane Sandy is just wrong. Further leaving the regulations the same for two or more years would result in much more accurate data being acquired.
Additionally, we are aware that the FMP does not allow for conservation equivalency. However, we are in favor of an amendment to the plan that would make the necessary changes consistent with those proposed in the document
In recent years the options that have been best for New Jersey and some of the other states have not been the ones chosen by the majority. In the past, JCAA has favored State by State measures. We are confident that the New Jersey Marine Fisheries Council will make more prudent decisions than other states and therefore we are opposed to most regional management proposals. The regional approach tends to favor States that far exceed their target. Further regulations that are good for the northern part of a region might be far different than what is best for the southern part of the region. Last year there was a proposal for regional management where New Jersey would have been its own region. Since there were no public hearings on the development of proposals this year, we suggest that you add a proposal where the States to the South of NJ would be one region and the States to the north of NJ be another region. New Jersey would be its own region because the fishery we have here differs from that of the States north of us as well as the States south of us.
This year the proposed State by State measure is one of the least favorable options as it would force our State to have either a 52.8% or 53.2% reduction. Yet it seems to be the option that will favor the majority of the other States. Whether this is the option that is chosen or not, you need to be fair and follow the same procedure for 2014 Therefore in regard to Addendum XXIII, section 4.2 we support option 2 which would extend the addendum by one year. These reductions would most likely be the same if New Jersey were to become its own region. All of the options being considered under section 4.1 are unacceptable. We are hopeful that you will consider our suggested alternatives. If not, we reluctantly support option 2 provided it is implemented for two years.
Additionally, we would like to comment further on the addendum as follows:
The Statement of the Problem has not presented a cogent case that there is indeed a problem. In fact it is obvious that the problem lies with an unrealistic harvest limit that is inconsistent with the historical information provided and the continued reliance on the fatally flawed MRFS data which has not been significantly improved by the introduction of the new MRIP system.
1. In the Stock Status section it is stated that “Based on the June 2012 update, the stock is not overfished and overfishing is not occurring, relative to the biological reference points. Spawning stock biomass (SSB) in 2011 is 24.6 million pounds.”
Therefore the projected 2012 catch of 2.99 million pounds represents a catch rate of 12.15% of the SSB. It is not logical that removing 12.15% of the available fish will have a negative impact on the fishery.
2. A close examination of Table 5 shows a dramatic inconsistency between the harvest limit and the actual harvest. When the size limit was increased from 9” to 10” for the 1998 season the harvest limit dropped from 4 million pounds to 1.2 million pounds. As the fish had an opportunity to grow from 9” to 10” the harvest increased to 1.7 million pounds in 1999 and then 4.0 million pounds in 2000. In 2001 the size limit was again increased, this time to 11” and the season shortened. This resulted in a decrease in the harvest to 3.4 million pounds. This occurred while the harvest limit remained at 3.15 million pounds. In 2002 the size limit was raised to 11.5” and the season opened all year. This resulted in a harvest of 4.3 million pounds. For 2003 the size was raised yet again, this time to 12” and the season shortened. As expected the harvest dropped to 3.3 million pounds. The size limit remained at 12” for 2004 – 2008 and the harvest varied from a low of 1.56 million pounds in 2008 to a high of 2.25 million pounds in 2007. During this period the Harvest limit set dropped from 4.13 million pounds in 2005 to 2.11 million pounds in 2008. What we had for five years is a relatively consistent harvest and each year was below the harvest limit set. There was no apparent reason to increase the size limit and decrease the harvest limit almost in half for 2009. It was certainly no surprise to anglers who are actually out fishing that the harvest limit would be exceeded in 2009. The only thing that changed was the harvest limit. Simple common sense indicates that the problem was the harvest limit was set incorrectly. This pattern of changing the harvest limit and changing the seasons is the problem that we face today. The trends shown by the MRFS and MRIP data indicate that the fishery is healthy and that there is season to season variability in the catch levels. Additionally as protogenous hermaphrodites, most sea bass change to males by the time they reach 13”. With a size limit of 12 ½”, the vast majority of females are protected. This is the reason that there are far more sea bass in our waters than assessments and surveys have shown. It is also why their size and range has been increasing. It seems to have been forgotten that MRFS and MRIP are designed to show trends in fishery abundance. They are in no way indicative of what is actually being caught. Until the sample size for the surveys is dramatically increased they will continue to be suspect.