Mid-Atlantic Fishery Management Council
Federal Building, Room 200
300 New Street
Dover, DE 19904

RE: Comments on the Bluefish Management Plan - Amendment 1

After reviewing the Amendment 1 document, the Jersey Coast Anglers Association and New Jersey Federation of Sportsmen's Clubs enter the following comments on behalf of our associations representing 150,000 members. 

1) We find the methods used to assess bluefish stocks to be highly speculative and based on extremely limited sea sampling data. The current stock assessment bears little resemblance to the fishery we see today, even considering the most recent work done by the S & S and Monitoring committees which determined the stocks are in better shape than previous assessments indicated. 

Bluefish are an extremely wide-ranging species both in their north-south migrations and their ability to move well offshore in search of forage. The use of bottom trawl surveys as an assessment tool is a highly questionable way to estimate stock size. First, bottom trawls are an extremely inefficient method of catching bluefish. Second, the swept area of the typical bottom trawl survey covers only a fraction of the known migratory range of the species in western Atlantic waters. The bottom trawl survey
does not provide enough hard information to be used as even a rough indicator of bluefish stock health. 

Depending to such a high degree upon recreational catch statistics developed from MRFSS data is speculative, at best. There is the potential for wide-ranging statistical error when relying on such data and the implications of using it as the single most important indicator of stock size is not very reassuring. As an example, when bluefish are concentrated in areas of high angler participation, catches, and hence stock abundance, appear high. When forage or other factors makes availability low in just
two key states (New Jersey and New York) that are responsible for a major portion of the coastwide recreational catch, the assessment appears low and hence stock abundance appears to have declined. The methodology becomes even less dependable when you consider the recreational community has, in most recent years, been releasing the majority of its catch. This brings into question the use of recreational "landings" and recreational "catch" in the assessment. It almost appears the two are interchangeable in places when, in actuality, the figures are different by orders of magnitude. This needs to be closely reviewed.

Therefore, we strongly recommend revising the stock assessment methodology for bluefish to provide a more accurate and representative sampling biomass to better judge the merits and benefits of different management tools. Without a more accurate stock assessment, much of the FMP's assumptions are simply hard to support.

2) Concerning the rebuilding objectives of this plan, JCAA questions the ability of any plan to result in a biomass of 107,500 metric tons except under the most ideal environmental conditions and with the highest availability of forage species. This biomass goal becomes even harder to fathom when you take into consideration the fact that commercial landings of squid and butterfish have increased tenfold in the last decade and the menhaden population is in decline and commercially harvested at grossly unsustainable levels. The harvest of herring has become the latest commercial "gold rush" and smaller forage species such as sand eels have not been in abundance in recent years. Without an enormous forage base to support such a massive increase in biomass of a voracious predator like bluefish, a plan objective of 107,500 metric tons of biomass is doomed to
failure without a wider "ecosystem based" assessment of the possibilities.

3) While the recreational/commercial split of 83/17 is not totally unreasonable, it is most definitely not representative of the true historic nature of this fishery. The actual historic "shares" were in the range of 90/10. And, in reality, an 83/17 split will result in a commercial share of almost 6 million pounds of the 35 million pound TAL. Since recreational landings are presently running about 14 million pounds, the actual result is about a 70/30 split. For this reason, we do not support the proposed transfer of 4.5 million pounds of recreational quota to the commercial quota in year one of the plan.

A transfer would provide no conservation benefit and is nothing more than a strategy to give the commercial sector one more year to maintain its harvest level without having to conserve. Such a transfer would set a highly questionable precedent.

4) We request an immediate moratorium on the entry of new participants into the commercial bluefish fishery. With the pending quota reductions on two other overfished species, specifically monkfish and dogfish which are traditional target species for coastal gill-netters, it is likely that a dramatic increase in commercial effort will be directed on bluefish. The proposed plan does not provide for a moratorium on entry. Such an effort shift will only hurt recovery and those commercial fishermen who have been traditional participants in the fishery have the landing records to prove it.

5) We do not support the imposition of a 12" size limit. The current stock assessment and the most recent landing trends in the recreational fishery clearly show no reason to institute a size limit at this time. A 12" size limit might not impact ocean fishermen and those anglers who patronize party and charter boats, but it does represent an unfair exclusion of estuary and shore-based fishermen from the fishery. Anglers limited to fishing bay waters and children who participate in the seasonal snapper fishery do not deserve to be arbitrarily shut out of another fishery, especially at a time when recreational fishermen are landing only about
one-half of the proposed quota.

6) We do not support the transfer of commercial quota between states. It can cause undue pressure in localized fisheries which penalize both recreational fishermen in those areas by decreasing local availability, and commercial fishermen in other areas who have been traditional participants in the fishery.

Sincerely,

Thomas P. Fote
Legislative Chairman
22 Cruiser Court
Toms River NJ, 08753
732-270-9102 Fax 732-506-6409
Email tfote@jcaa.org


Release For Tomorrow
Tom Fote

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