PUBLIC INFORMATION DOCUMENT

FOR THE MANAGEMENT OF

ATLANTIC MENHADEN

Prepared by the

Atlantic States Marine Fisheries Commission’s

Atlantic Menhaden Plan Development Team (PDT)

July 20, 1999

Acknowledgments

This document was prepared by the Atlantic Menhaden Plan Development Team (PDT) under the guidance of the Atlantic Menhaden Management Board. Members of the Menhaden PDT include: Dr. Michael P. Armstrong, Massachusetts Division of Marine Fisheries; Ellen Cosby, Virginia Marine Resources Commission; Peter Himchak, New Jersey Division of Fish, Game and Wildlife; Dr. John Merriner, National Marine Fisheries Service; Dr. Alexei Sharov, Maryland Department of Natural Resources; Michael W. Street, North Carolina Division of Marine Fisheries; and Dr. Joseph C. Desfosse, Chair, Atlantic States Marine Fisheries Commission. The PDT wishes to express its thanks to the following individuals who contributed to the development of this document: Niels Moore, National Fisheries Institute; Joe Smith, National Marine Fisheries Service; Charles Williams; Dr. Douglas Vaughan, National Marine Fisheries Service.

Public Information Document for Atlantic Menhaden

Introduction

The Atlantic States Marine Fisheries Commission (Commission), is developing an amendment to its Atlantic Menhaden Fishery Management Plan (FMP) under the authority of the Atlantic Coastal Fisheries Cooperative Management Act (ACFCMA). Responsibility for managing the Atlantic menhaden fishery lies with the Commission through the coastal states. Responsibility for complementary management action in the Exclusive Economic Zone (EEZ) from 3-200 miles from shore lies with the Secretary of Commerce through the ACFCMA in the absence of a federal FMP.

Purpose of the Public Information Document

The purpose of this document is to inform the public of the Commission’s intent to gather information concerning the Atlantic menhaden fishery and to provide an opportunity for the public to identify major issues and alternatives relative to the management of Atlantic menhaden in compliance with the ACFCMA, through the Commission’s Interstate Fisheries Management Program (ISFMP).

The input of fishermen, the public and other interested parties is being sought by the Commission to help produce responsive management plans. Input received at the start of the fishery management plan development process has great impact in meeting the needs of all concerned parties. The purpose of this document is to draw out observations and suggestions from these groups, as well as any supporting documentation and additional data sources. To facilitate public input, this document provides a broad overview of the extent of the issues facing the Atlantic menhaden population and fishing industry, as well as a wide range of potential management measures which may impact the stock and its dependent fisheries.

The Process

The publication of this document and announcement of the Commission’s intent to amend the existing Atlantic menhaden FMP is the first part of the formal amendment process. Following the initial phase of information-gathering and public comment, the Commission will evaluate potential management alternatives and the impacts of those alternatives. The Commission will then develop a draft amendment to the FMP with preferred management measures identified for public review. Following that review and public comment, the Commission will specify the management measures to be included in the new amendment.

This is your chance to tell the Commission about changes observed in the fishery, things you feel should or should not be done in terms of management, regulation, enforcement, research, development, enhancement, and any other concerns you have about the resource or the fishery as well as the reasons for your concerns.

Problem Statement

Atlantic menhaden are currently managed through the Commission’s 1992 Atlantic Menhaden Fishery Management Plan (FMP) (ASMFC 1992). The menhaden program functions under the Commission’s Interstate Fisheries Management Program (ISFMP), with immediate oversight provided by the Atlantic Menhaden Management Board. The Board is composed of up to five state directors, five industry representatives, and one representative from the National Marine Fisheries Service and one from the National Fish Meal and Oil Association (the industry trade association). In 1997, the ISFMP Policy Board approved the addition of one Legislator, one Governor’s Appointee and two public representatives to the Menhaden Board. The Board in turn, appoints members to the Atlantic Menhaden Advisory Committee (AMAC), which serves as both the technical and advisory body for the Board. One of the reasons the Commission is initiating the amendment process is to examine the current structure of the menhaden management process. Concerns have been raised recently over the mixed composition of both the management board and the technical/advisory committee because they differ from the traditional board/technical committee structure followed in all other Commission fishery management programs.

Recent concern over declines in the Atlantic menhaden population led the Menhaden Board to recommend that the Commission conduct an external peer review of the menhaden stock assessment which is conducted annually through AMAC. This peer review was completed in November 1998 and provided some major recommendations for improving the assessment and management of menhaden (ASMFC 1999). Upon receiving the report of the Peer Review Panel in January 1999, the Board recommended that a full amendment to the current FMP be developed and that the recommendations of the Peer Review Panel be addressed through the development of this amendment. Concerns over apparent reductions in the forage fish base in Chesapeake Bay and northeastern Florida have also been expressed by members of the public and state fisheries personnel.

In 1998, AMAC also suggested that changes to the menhaden management process be addressed through an addendum to the current FMP (AMAC 1998). The addendum would address: 1) updating the FMP in accordance with changes to the Commission’s ISFMP FMP outline; 2) updating the data with particular attention to the 1998 reduction of the Virginia fleet; 3) strengthening the Habitat section of the FMP; and 4) examining the trigger levels based on recent data and analysis.

The Atlantic menhaden spawning stock is currently considered to be healthy, although there has been a decline in recruitment over the last ten years (Fig. 1) (AMAC 1999). The overall spawning stock biomass is currently high, but is expected to decline over the next few years unless the trend in recruitment is reversed. There has also been a general decline in the stock size (numbers and biomass), concurrent with the decline in recruitment. The most recent estimate of maximum sustainable yield (MSY) for Atlantic menhaden is 480,000 metric tons (mt). Natural environmental conditions, as well as overall stock status, may influence the distribution of the menhaden population. Recent poor recruitment of menhaden is dependent on natural environmental conditions and appears to be unrelated to fishing effort (AMAC 1999).

The main source of stock assessment data is the reduction fishery. A coastwide sampling program for the reduction fishery conducted by NMFS has been in effect since 1955. A limited bait fishery sampling program has been in effect since 1994. There is no sport fishery to sample. Other potential sources of information regarding menhaden stock status include fishery-independent surveys such as the Virginia and Maryland juvenile seine surveys and juvenile surveys conducted by the states of Rhode Island, Connecticut and North Carolina. The Menhaden Peer Review Panel agreed that the current reduction fishery sampling program was adequate both spatially and temporally and that the stock assessment methodology and analysis were reasonable given the available data (ASMFC 1999).

The primary concern over management of the stock appears to be the allocation of fish between fisheries and ecological functions. Recreational fishing and environmental groups have emphasized the forage role of menhaden for piscivorous fishes and its ecological role in filtering phytoplankton. Commercial fisheries interests advocate maintenance of the traditional reduction and bait fisheries. In recent years there have been allegations that sport fishing may be negatively affected by menhaden purse seine fishing in the same general areas; data are not presently available to evaluate this issue.

Background Information

Atlantic menhaden are distributed along the Atlantic coast from Florida to Nova Scotia. Spawning occurs over much of the species’ range, with a peak off North Carolina during late fall and winter. Menhaden are estuarine-dependent, utilizing coastal estuaries from Florida through southern New England as nursery areas. Young fish join the coastal migration late in their first year of life. After their first year, menhaden migrate along the Atlantic coast, with older, larger fish moving farthest north each spring and summer. Most menhaden migrate to the North Carolina area each fall and early winter.

Menhaden serve as a vital link in the ecology of the estuarine and marine environments. Adults are primary consumers, transforming phytoplankton into animal protein. Both adults and juveniles, in turn, serve as prey for many fish-eating fish, sea birds, and marine mammals, as do many other species of fish, including anchovies, herring, sardines, sand lance, and the young of most other fishes.

Commercial Fisheries

Atlantic menhaden have been harvested since colonial times, when they were used mostly as fertilizer. Oil recovery began in the early 1800s. Large-scale fisheries for menhaden were established in the 1850s following the development of the purse seine (Frye 1999). Menhaden oil was used for industrial purposes, and Ascrap@ or dried fish, was used for fertilizer. By World War II, the primary product of the reduction industry had changed from scrap to the production of high protein fish meal for poultry and swine feeds, the major contemporary uses. In recent years, there has been a growing use of menhaden in aquaculture feeds, and for direct human consumption in the manufacture of margarine products (omega-3 fatty acids).

Atlantic menhaden make up the majority of all Atlantic coast finfish and shellfish landings (Fig. 2; NMFS Beaufort). Landings from the reduction fishery remained fairly consistent during 1982-91, averaging about 341,000 mt (751.9 million pounds). The catch has averaged 295,000 mt (650.5 million pounds) since 1992. Landings have been considerably less than during the peak years of the reduction fishery because of changes in the areas where fishing occurs (most fishing is concentrated in Chesapeake Bay now rather than the entire Mid-Atlantic region), reduced fleet size, fewer processing facilities, increased regulatory restrictions, and possibly other factors.

Information on the harvest and use of menhaden for bait is difficult to obtain because of the nature of the bait fisheries and current data collection systems. Reported bait landings have contributed approximately 30,000 mt annually in recent years. Harvest comes from directed fisheries, primarily small purse seines, pound nets, and gill nets, and as bycatch in various food-fish fisheries. Menhaden are taken as bait in almost all Atlantic coast states (both reported and unreported) and are used for bait in crab and lobster pots, and hook and line fisheries (both sport and commercial). Menhaden are used as chum and as cut or live bait for sportfish such as king mackerel, red drum, sharks, and tunas.

Bycatch (or incidental catch) of other species, including sea turtles and marine mammals, in menhaden purse seines has been examined repeatedly since the late 1800s. The capture of non-target species is a relatively rare event, and the overall bycatch is insignificant in comparison to the overall catch of menhaden. Menhaden are also a common bycatch in many Atlantic coast fisheries using gillnets, seines, trawls, and other gear. Data have not been compiled on the overall magnitude of this bycatch.

Recreational Fisheries

No significant directed recreational fisheries exist for menhaden. However, menhaden are an important bait in many recreational fisheries; some recreational fishermen employ cast nets to capture menhaden or snag them with hook and line for use as bait, both dead and live.

Ecological Considerations

Menhaden are typically an extremely abundant species in nearshore coastal waters. They have the ability as juveniles and adults to directly utilize phytoplankton and microzooplankton, the bases of the aquatic food chain. Other marine and estuarine finfish are not equipped to filter such small organisms from the water. Another dominant pelagic species, bay anchovy, feed on larger zooplankton. Because menhaden are so abundant in nearshore coastal and estuarine waters, they are an important forage component for a variety of predators including larger piscivorous fishes, birds, and marine mammals. In ecological terms, menhaden represent an important link in the coastal aquatic food chain, transferring planktonic material or energy into higher trophic levels/biomass within the coastal ecosystem. Consequently, Atlantic menhaden abundance can influence and be influenced by predator abundance.

Management History

The original Atlantic Menhaden Fishery Management Plan (FMP) was prepared during 1976-81 and approved by the ASMFC in October 1981. This plan did not recommend any specific management measures, but instead, provided a discussion of regulatory options, should they be needed. In 1982, the Atlantic Menhaden Management Board (AMMB) recommended seasonal limits as a means to provide long-term benefits to the fishery. This recommendation was approved by the ASMFC and referred to the states for implementation. Full implementation of the recommendation was never achieved. Changes in the operation of the Commission’s Interstate Fisheries Management Program in the mid-1980s resulted in disbanding the AMMB, with oversight of menhaden management transferred to the ISFMP Policy Board. A number of developments in the late 1980s greatly affected the Atlantic menhaden fishery, resulting in the need to amend the 1981 FMP. The most important of these items included:

In light of these and other social and economic developments, the Commission determined in 1988 that the 1981 menhaden FMP was no longer sufficient to guide management of the fishery and authorized the preparation of a revision to the plan. The current FMP was adopted by the Commission in 1992. In addition to identifying a new management structure consisting of the AMMB and AMAC, the 1992 FMP established an annual review process focusing on three topics: 1) the condition of the stock and fishery as determined by analysis of data for the six (6) triggers in the FMP and ancillary information; 2) allocation of menhaden for harvest under Internal Waters Processing (IWP) requests; and 3) implementation of the FMP relative to other areas of concern, including state management actions which may affect the fishery.

The variables that were selected to act as triggers were: 1) the reduction fishery landings in weight; 2) the proportion of age-0 menhaden in reduction fishery landings; 3) the proportion of adults in reduction fishery landings; 4) recruits to age-1; 5) spawning stock biomass; and 6) percent maximum spawning potential (%MSP). The first three triggers are estimated directly from the reduction fishery landings, while estimates of the latter three are obtained from virtual population analysis (VPA) on estimated catch-at-age data. The latter three estimates are subject to false "firings" because there is large uncertainty in the most recent years of a VPA, i.e., estimates for the most recent year or two are the least reliable.

Peer Review Panel Results

Twice annually, the Commission’s ISFMP Policy Board prioritizes all Commission managed species based on species Management Board advice and other prioritization criteria. The species with the highest priorities are assigned to a review process to be conducted in a timely manner. In June 1998, the Atlantic menhaden stock assessment was prioritized for an external peer review. An external peer review panel was formed, including four stock assessment biologists with expertise in menhaden life history, stock assessment techniques, and multispecies interactions. The external peer review for the Atlantic Menhaden stock assessment was conducted November 16-18, 1998, in Baltimore, Maryland.

The Menhaden Peer Review Panel convened to review the stock assessment methodology and other issues including: 1) the type of model and data sources used in the assessment; 2) evaluate the extent of any statistical bias; 3) identify and evaluate other potential sources of mortality; 4) review the trigger mechanisms used to monitor the stock and fishery; 5) evaluate the status of the stock as a whole and locally; 6) evaluate the ecological significance of menhaden and suggest other trigger mechanisms which may reflect this role; and 7) review existing management and research needs and identify any new needs.

The Panel concluded that the model used to assess the menhaden population was reasonable given the available data, and sampling was comprehensive with sufficient temporal and spatial resolution. The "triggers" were not triggers because firings do not lead to specific management actions. Recruitment has declined during the 1990's, and fisheries-dependent data strongly suggest that the stock has contracted from the northern and southern extent of its range in the last few years. The Panel did not receive any direct evidence of local depletion of menhaden in Chesapeake Bay and Florida waters. A comprehensive analysis of the ecological significance of menhaden was not presented to the Panel. A further examination of this issue should be addressed through a Commission workshop on multispecies interactions tentatively scheduled for later in 1999. Finally, the Panel concluded that the trigger-based management system has not served the function of guiding regulatory actions in the menhaden fishery.

The Panel made a number of recommendations to improve the stock assessment including evaluation of the sampling methodology, estimates of natural mortality, sensitivity analyses of spawning stock biomass (SSB) estimates and recruitment, evaluation of fishery-independent and -dependent measures of abundance and evaluation of current reproductive parameters of the population. The Panel recommended renaming the triggers as biological reference points or variables used to evaluate stock status since they do not trigger any specific management action. The Panel recommended replacing certain variables with those based on fishery-independent data to reflect the condition of the stock and not the fishery. The Panel also recommended that a reference point responsive to menhaden as a forage species be developed to take into account the allocation of fish between fishing and natural mortality (predator-prey interactions). Specific management recommendations made by the Panel included: developing a quota-based management system allocated by season and area; development of biological reference points based on recruitment and spawning stock biomass; and inclusion of a greater diversity of scientific and public participation in the technical and advisory process.

Copies of the Advisory Report and the Stock Assessment Report for Peer Review are available from the Commission.

References

AMAC. 1998. Atlantic Menhaden Management Review, 1998. Report to the Atlantic Menhaden Board, April, 1998. 18 p.

AMAC. 1999. Atlantic Menhaden Management Review, 1999. Report to the Atlantic Menhaden Board, May, 1999. 27 p.

ASMFC. 1992. Fishery Management Plan for Atlantic Menhaden - 1992 Revision. Fishery Management Report No. 22, ASMFC, Wash., DC. 159 p.

ASMFC. 1999. Terms of Reference and Advisory Report for the Atlantic Menhaden Stock Assessment Peer Review. Stock Assessment Report No. 99-01, ASMFC, 16 p.

Frye, J. 1999. The Men All Singing - the story of menhaden fishing. 2nd. ed., The Donning Co., 242 p.

USDOC. 1998. Fisheries of the United States, 1997. United States Dept. of Commerce, Current Fish. Stat. No. 9700. 156 p.

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Contents of the Fishery Management Plan

At this point, the following items and management alternatives have been identified for consideration in the Commission’s Amendment 1 to the Atlantic Menhaden FMP.

I. Management Goal(s) - The Commission is considering the following management goal for Amendment 1 to the Atlantic Menhaden FMP.

"To manage the Atlantic menhaden fishery in a manner that is biologically, economically, and socially sound while protecting the resource and its users. (from 1992 FMP)"

II. Management Objectives - The Commission is considering the following management objectives for Amendment 1 to the Atlantic Menhaden FMP and is seeking input on these and any others that may be raised.

A. Protect and maintain the Atlantic menhaden stock at levels to maintain viable fisheries and forage base with sufficient spawning stock biomass to prevent stock depletion and guard against recruitment failure.

B. Insure adequate accessibility to fishing grounds.

C. Protect fishery habitats and water quality in the nursery grounds to insure recruitment levels are adequate to support and maintain a healthy menhaden population.

D. Maintain uniform data collection system for the reduction fishery and develop new protocols for other harvesting sectors, including biological, economic, and sociological data (ACCSP protocols as a minimum; NMFS reduction fishery monitoring system continued).

E. Improve understanding of menhaden biology, food web ecology and multispecies interactions that may bear upon predator-prey and recruitment dynamics.

F. Evaluate, develop, and improve approaches or methodologies for stock assessment including fishery-independent surveys and variable natural mortality at age or area.

G. Maintain existing social and cultural features of the fishery to the extent possible.

H. Develop a public information program for Atlantic menhaden: fishery, biology, estuarine ecology and role of menhaden in the ecosystem.

I. Develop options or programs to control or limit effort, or regulate fishing mortality by time or area.

J. Optimize utilization of the resource within the constraints imposed by distribution of the resource, available fishing areas, and harvest capacity.

K. Base regulatory measures upon the best available scientific information and coordinate management efforts among the various political entities having jurisdiction over the fisheries.

L. Protect and maintain the important ecological role Atlantic menhaden play along the coast.

III. Overfishing, optimal yield, and corresponding stock size levels - To achieve the management objectives, the amendment may contain any or all of the following components:

A. An overfishing definition

B. The development and evaluation of biological reference points including but not limited to F0.1, Fmax, Fmsy, SPR, MSP and MSY

C. Stock status determination criteria and a process which would allow the Commission to determine the health of the menhaden resource

D. A specification of optimum yield

E. A re-examination of natural mortality (to address predator-prey dynamics - allows for increasing biomass of managed piscivores and marine mammals; in order to provide a precautionary approach)

F. Total Allowable Catch (TAC) levels for appropriate fishing areas and or seasons

G. Evaluation of fishery sector allocations including reduction fishery, bait fishery, IWP and other uses

H. Estimates of U.S. harvesting and processing capacity

I. Data reporting requirements per Atlantic Coastal Cooperative Statistics Program (ACCSP) protocols

IV. Management Unit - The management unit for this amendment is defined as the Atlantic menhaden resource throughout the range of the species within U.S. waters of the northwest Atlantic Ocean from the shoreline to the seaward boundary of the EEZ. This definition is consistent with recent stock assessments which treat the entire resource in U.S. waters of the northwest Atlantic as a single stock. It is also recognized that the menhaden resource, as defined here, is interstate and state-federal in nature, and that effective assessment and management can be enhanced through cooperative efforts with all Atlantic coast state and federal scientists and fisheries managers. Comments are encouraged on the following issues:

A. Possible delineation of separate management areas

B. Definition of stocks or stock components

V. The Management Process - the current management process involves state and federal fisheries personnel and industry representatives in a mixed management board/technical committee structure unlike other Commission-managed species. The public is invited to comment on this structure and the annual review process and trigger mechanisms.

A. Management body structure

B. Technical and advisory committee

C. Annual review process

D. Trigger variables/reference points

VI. Catch and Effort Control Measures - To ensure the achievement of optimum yield and to prevent overfishing, the amendment will consider a range of alternatives for managing the potential harvest of menhaden for all gear types. Though its desirable to have consistent management measures throughout the range of a species, different measures by region may be considered if they increase the likelihood of achieving management goals.

A. Effort Measures - The amendment could restrict fishing levels through the following measures to achieve a specified fishing mortality level:

1. Limited entry

2. Closed seasons

3. Closed areas

4. Limits on the amount of fishing time (days-at-sea limits)

5. Gear controls

- vessel size limits

- vessel horsepower restrictions

- allowable gear

6. Trip limits

7. Minimum mesh size limits

B. Catch quotas - the amendment could close the fishery when target TACs are reached through the following types of quotas:

1. Fleet or sector quotas

a. annually

b. seasonally

c. by vessel category

d. area

e. other

2. Vessel catch limits

3. Management area quotas

C. No action - fishery remains at status quo and no additional measures are implemented

VII. Habitat Protection - the public is invited to comment on the following issues in regards to menhaden:

A. Spawning area closures (probably infeasible - spawning mainly occurs offshore in Gulf Stream waters)

B. Juvenile protection area closures (nursery areas)

C. Identification, description and distribution of habitat and essential habitats

D. Gear impact assessments

VIII. Bycatch minimization measures - refers to both the minimization of menhaden bycatch in other fisheries as well as the bycatch of other species in the menhaden fishery. The input from fishermen and the public is particularly sought concerning the potential effectiveness of various methods in reducing unwanted bycatch in the fishery, and the impacts of such methods on fishing practices and the resource itself. (Bycatch is defined as fish harvested in a fishery, but which are not sold or kept for personal use. It includes economic and regulatory discards of menhaden and other species.)

A. Gear modifications

B. Area closures

C. Discards

IX. Recommendations for future research - a complete list of research recommendations for Atlantic menhaden has been reviewed and prioritized (AMAC 1999). The following is a brief list of those needs:

A. Re-evaluate natural mortality estimate (current stock assessment uses a 0.45 instantaneous natural mortality rate for menhaden based on historical studies; includes predation by other species, as well as other causes of death).

B. Evaluate effects of environmental factors on growth, survival and abundance of menhaden.

C. Develop fishery-independent indices of abundance of menhaden.

D. Evaluate effects of habitat loss/degradation on menhaden.

E. Monitor landings, size, age, gear and harvest area of menhaden fisheries, and enhance biostatistical sampling of menhaden bait fisheries.

F. Study the ecological role of menhaden including predator/prey, nutrient flow dynamics, oxygen depletion, etc.

G. Evaluate precision of the assessment (VPA) results.

H. Evaluate alternative measures of effort in the commercial fishery.

I. Determine the effects of fish diseases on the menhaden stock.

J. Determine the effects of regulations on the fishery, the participants and the resource.

K. Evaluate long-term trends in growth rates of menhaden.

L. Monitor fish kills along the Atlantic coast.

M. Develop bycatch studies of menhaden on other fisheries.

N. Periodically monitor the economic structure and sociological characteristics of the menhaden reduction fishery.

X. Fishing community considerations - the public is invited to comment on the following issues in regards to menhaden:

A. Protection of traditional uses

B. Description and analysis of impacts on fishing communities

XI. Administrative provisions - the public is invited to comment on the following issues in regards to menhaden:

A. A requirement for vessel fishing licenses or permits

B. A requirement for fishing vessel operator licenses or permits

C. Dealer licenses or permits

XII. Data needs - a comprehensive coastwide fisheries data collection program (Atlantic Coastal Cooperative Statistics Program - ACCSP) is being developed and implemented. Menhaden fisheries will be subject to the reporting requirements of ACCSP. The public is invited to comment on the following issues in regards to menhaden data collection:

A. Reporting of landings from stock components

B. Observer coverage

C. Data on end-products and uses

 

 

Proposed Schedule for Development of Atlantic Menhaden Amendment 1

 

 

Stage

Tentative Date*

Approval of Draft Public Information Document (PID) May 1999
Public Information Hearings August 1999
Approval of Initial Draft of Amendment 1 Late winter/early spring 2000
Draft Amendment 1 Hearings Summer 2000
Approval of Amendment 1 Annual Meeting 2000
ASMFC Adoption Annual Meeting 2000

* This schedule is tentative and subject to change.

 

The Commission invites comment on this public information document. You may do so in one or more of the following ways:

1) attend public hearings held in your state or jurisdiction;

2) refer comments to your state’s Atlantic Menhaden Board, or Atlantic Menhaden Advisory Committee member, if applicable;

3) send or fax written comments to the following address:

Dr. Joseph C. Desfosse

Atlantic Menhaden FMP Coordinator

Atlantic States Marine Fisheries Commission

1444 Eye Street NW, 6th Floor

Washington, D.C. 20005

phone: (202) 289-6400, ext. 329

fax: (202) 289-6051

If you have any questions please call the Commission at (202) 289-6400.