The Jersey Coast Anglers Association represents approximately 75 clubs throughout our state. We appreciate this opportunity to comment on the public information document for Amendment 1 to the Interstate Fishery Management Plan for Tautog.
It is very disheartening to be told that tautog are overfished and that overfishing is occurring in most areas of the east coast. In fact from the perspective of most tautog fishermen in New Jersey, it is unbelievable. They report stellar fishing with some truly monster tog to over 20 lbs being caught as well as good representation of tog of all sizes. Most of us believe that our regulations are already far too restrictive.
Regarding the PID, JCAA supports Option 1, status quo with the fishery being managed as one stock from Massachusetts to Virginia. However, we would support the fishery being managed on a regional basis provided it could be done correctly. We urge you to further develop science to better determine the boundaries of the various stocks. By your own admission, options 2, 3 and 4 all present problems of some sort. Let’s hold off on regionalization for now until you can get it right.
Many New Jersey fishermen are very skeptical of any regionalization plan for good reason. We were forced into a region against our will for fluke in 2014. The plan was supposed to alleviate the problem of neighboring states fishing essentially the same waters but having vastly different regulations. This was done to appease New York fishermen who had a higher size limit than New Jersey fishermen both of whom were fishing the NY bight area. However, in reality all the regionalization plan did was to transfer the problem to the Delaware Bay area. Now fishermen from Delaware fishing essentially the same waters as fishermen from NJ have only a 16" size limit and a much longer season, while NJ fishermen have an 18" size limit. How is that fair?
Regarding tautog, options 2 and 3 are unacceptable primarily because there is little biological connectivity between New Jersey and Connecticut and we would be fishing on different stocks.
As previously stated, we prefer option one but of the current regionalized plans, option 4 is the only one that makes some sense. However, at this time complete data is missing for this option which makes it hard to endorse. Additionally, if we were to endorse this option, it would be on a conditional basis. New York's regulations are far more restrictive than New Jersey's and we vehemently oppose our regulations being made more restrictive so that theirs can be relaxed. While it is nice to have compatible regulations between bordering states it is more important for each state to have the right to choose the regulations that are best for their fishermen. We suggest that if we do have regionalization it should be with State-by-State measures. Each region would be given a quota and within that region each state would be given a target quota. Target quotas would be set and then adjusted accordingly when necessary to ensure that each state would continue to be allowed to harvest its traditional percentage share of the harvest. If the regional quota was exceeded, the state most responsible for causing it would have borne the brunt of it having more restrictive regulations the following year. However, states would be encouraged to work together on this so that perhaps a longer term agreement could be reached.
Regarding other parts of the PID most of New Jersey's fishermen would be happy if the tautog fishery in the future remains as good as it is now. Of course we would like it to be even better. We are opposed to more restrictive regulations but urge that the environment and habitat be improved. For example we strongly support the creation, maintenance and expansion of artificial reefs. This is particularly important at this time as our government is destroying the marine environment. They are replenishing our beaches and in doing so are burying sand and calico crabs while at the same time they are also burying, notching or completely removing many of our jetties that were prime habitat for blackfish and other species. Worse still, they are using sand from many of our inshore lumps which are designated as "prime fishing areas" and are of crucial importance to forage and game fish alike.
We agree with most if not all of the listed goals and objectives. It is difficult to determine exactly which are the most important. However, Objectives A, B, E and I are near the top of the list. We are aware that there is a very significant problem with the illegal sale of live tautog primarily in Asian markets in large cities like New York. There is insufficient law enforcement there and we urge that more officers be hired and/or a special task force be created to combat this illegal activity. We also urge that harsher penalties should be created for all illegal fishing activity. For example a fish market that is selling illegal tautog should be shut down for a period of time rather than just being fined. To many of those who break our fisheries laws, fines are accepted just as a cost of doing business. This needs to change.
We disagree with your statement that law enforcement noted a significant number of hook and line fishermen using undersized tautog as live bait for striped bass. Statements like that hurt your credibility. Striper fishermen who use live bait prefer menhaden, mackerel, herring and eels. Tautog are rarely used and the amount that are used is miniscule. We suggest that this statement be removed from the Amendment or that proof be provided if you still believe it is a problem.
There are many other factors that are impacting the tautog population far more than striper fishermen using them for bait. Probably the most significant is the explosion and expansion of our sea bass populations. They are not only competing with tautog for food such as crabs but they are eating juvenile tautog. I have noted this in the sea bass I clean. Perhaps, a study should be done to see just how prevalent this problem is. Sea bass are negatively impacting our fluke fishery as well. Spiny dogfish have been "restored" and are negatively impacting the populations of more desirable species as well. We can't have all the desirable species at peak periods of abundance at the same time as there is simply not enough food for all of them. We favor a more sensible eco-system approach to fisheries management.
Thank you for your consideration in this matter.
