JCAA Statement for the NMFS November 18 Hearing to open the EEZ for Striped Bass Fishing.
Remember the Hearing is at the Quality Inn on Route 37 West in Toms River at 6:00PM. If you want a copy of this as a MS Word File please let me know and I will send it to you.
JERSEY COAST ANGLERS ASSOCIATION
Working For Saltwater Resource & Marine Anglers
1201 Route 37 East, Toms River, NJ 08753
Web Site www.JCAA.org
JCAA STATEMENT REGARDING NMFS PROPOSAL TO OPEN THE EEZ TO STRIPED BASS FISHING
JCAA has historically been and is presently opposed to the opening of the EEZ to recreational and commercial fishing.
It is interesting that when the motion to open the EEZ was discussed under Amendment 6 at the ASMFC, a majority of the states did not vote for the opening. It was the two federal agencies (NMFS and USF&WS) that cast the deciding votes. Only 4 out of 13 states and jurisdictions that have voting privileges voted to open it. That does not demonstrate widespread support from the states or the public for the proposed opening.
New JerseyÃ¢â‚¬â„¢s waters have been closed for to the commercial harvesting of striped bass since 1995 because PCB testing placed these fish above the FDA levels for the sale of striped bass. New York also has areas closed due to the same PCB contamination problem. Once the EEZ is open there will be no enforcement of those closed PCB areas since state jurisdiction does not extend there. This could allow for the harvesting and sale of contaminated striped bass. This is a potentially serious problem with possible legal and health consequences that the management boards MUST address. This could affect the whole striped bass commercial fishery since no one could guarantee the source of the commercial landings. The Public would lose confidence in the quality of the product.
When we talk about increasing commercial fisheries, one of the reasons given is that it allows them to use fish they are already harvesting and allows them to use that bycatch of dead striped bass. Many fisheries have demonstrated that increasing the commercial quota or harvesting opportunities increases bycatch. So, you are not just utilizing dead bass that would have been killed but instead increasing the number because of the increased effort. This was clearly demonstrated this year when the increased quota was in place in North Carolina. In order to keep the harvest open for a longer period of time and retain the price, there was an implementation of trip limits. We understand the reasons for trip limits but trip limits promote higrading (culling out the biggest fish) and increase discard. This fact is always lost in the discussion.
It will create new fisheries in areas that are presently closed. Striped bass in the EEZ will be targeted since many other fisheries will be closed at that time. If trip limits are in effect, bycatch will only increase. Depending on regulations, small fish may have to be discarded, which will only increase the discard mortality.
While striped bass stocks appear to be in a healthy condition, the population structure of age/size has not expanded to historical ranges. The reduced population of the larger and older fish is primarily concentrated in the 3-12 mile range. To place additional pressure on these fish could well jeopardize the goal of having an expanded age/size distribution in the stock.
Amendment 6 restored the coastal commercial fishery to the average landings during 1972-1979 (3.8 million lbs), provided jurisdictions implemented a 28-inch minimum size limit. They are now fishing at 100% or more. Some states have not changed the recreational regulations to allow for a greater harvest by the recreational sector under Amendment 6 and are considering doing so or could in the immediate future. We do not know what impact this would have on the overall mortality. We should not open the EEZ until all states are allowed to fully implement Amendment 6 and we know what the increased mortality is.
What we are talking about is opening the EEZ at the same time that NY, NJ, PA and DE recreational fishermen are restricted in their quotas and size limits.
Why is it necessary to open an area that is a refuge for the larger (best breeders) striped bass, when it appears we are currently fishing at 100% both recreationally and commercially?
The preferred option here is to remain status quo and keep the EEZ closed to the possession of striped bass. This option helps to maintain conservation of striped bass and allow states to manage striped bass within state waters.
Point by Point Comment on Scoping Document made by ASMFC to open the EEZ:
In support of ASMFC recommendation: Opening the EEZ:
Ã‚Â· Will not increase pressure on the resource, it will just spread it out.
This is not a fact, but merely supposition, and in contrast to reality, the more big fish that are available the greater the participation. It happens in every fishery. There will be greater participation from both the commercial and recreational sectors.
Ã‚Â· Will relieve congestion within state waters, improving safety.
More speculation. It may; in fact, lead to people fishing offshore farther than they would normally, in the coldest and most dangerous months.
Ã‚Â· Will not lead to an increase in boat purchases.
This is only speculation and an absolutely specious argument!
Ã‚Â· Will allow legal size discarded bycatch to be landed within commercial quota, which will make more efficient use of the stock without affecting mortality rates.
Opening the EEZ will increase the bycatch, will lead to trip limits, higrading, and the mortality rates will go up because the fishing will be on a large portion of the 10+ year old fish, the very fish Amendment 6 was supposed to protect.
Ã¢â‚¬Â¢ The EEZ is an historical striped bass fishing ground.
The only documented commercial fishery in the EEZ was the New Jersey Commercial catch. 98% of the official documentation of all other commercial catches came from within state waters. (At those times many different gear types were used in contrast to what is allowed today) This is another attempt at transference of a documented noncommercial fishery to the commercial sector.
Ã¢â‚¬Â¢ Controls are in place within the states, under Amendment 6, to effectively manage the striped bass stock.
Are management boards absolutely sure that no loopholes exist in any plan? How can we take the risk of opening up this fishery when loopholes may exist that can be exploited to a repeated destruction of this stock?
Ã¢â‚¬Â¢ If the EEZ isnÃ¢â‚¬â„¢t opened, then enforce the closure.
Why not make the penalties so severe that no one could even think of fishing in the EEZ? This would have to be implemented with a massive education effort and improved law enforcement.
Ã¢â‚¬Â¢ The reasons to keep EEZ closed are political, not biological.
We do not agree with this statement since we are positive there are biological consequences in opening the EEZ, but many of the decisions made in fisheries management are made for political reasons.
Ã¢â‚¬Â¢ Striped bass mortality is below the threshold level.
Increased fishing pressure on the larger fish in the EEZ will lead to higher mortality levels on older fish and possible overfishing. If this occurs we will have to increase size limits or shorten the seasons thereby impacting the historical inshore and land-based fisheries. This will affect the poor and subsistence fisheries the most.
Ã¢â‚¬Â¢ Any overages in commercial quota will be taken off the following yearÃ¢â‚¬â„¢s quota.
Yes, we understand that legal commercial overages will be taken off the following year, but the opening of the EEZ will increase commercial participation where no participation existed before. It will also greatly increase the illegal commercial fishery. Law enforcement does not have the resources to catch all the illegal landings. Fisheries managers know this is happening both at the state and federal level but presently do not have the resources to apprehend the entire illegal landings. They do not even want to discuss this issue.
This also causes serious enforcement problems because in the multi-jurisdictional areas in the EEZ it will not allow for unified enforcement. Example: when the Coast Guard boards a vessel in the EEZ, which state regulations do they enforce? Right now it is easy, no one can possess striped bass in the EEZ.
Ã¢â‚¬Â¢ Monitoring requirements and management triggers contained in Amendment 6 would allow for quick action if needed for additional stock conservation.
States and the Federal government at this time do not have the resources to attempt real-time management of the recreational striped bass fishery. They cannot do this with most of the species they are presently monitoring for commercial fisheries and this would strain the existent programÃ¢â‚¬â„¢s management programs. There would have to be a large increase in federal funding to put in place a program to do this.
Ã¢â‚¬Â¢ State control at point of landing works, regardless of where the fish are caught.
States will be given the burden of enforcement and may not have the proper resources to fully implement the procedures that are required. Again, a huge influx of federal funds would be necessary
In opposition to ASMFC recommendation: Opening the EZ will:
Ã‚Â· Create conflict between state and federal jurisdictions for states with game fish status (ME, NH, CT, NJ, PA, DC, SC).
We agree. In New Jersey there is no commercial fishery, nor is the sale of wild striped bass permitted. All commercial efforts off the coast of New Jersey would have to be landed in other states. Commercial interests from within and outside of New Jersey would fish a currently un-fished resource and will be jeopardizing our recreational inshore fishery.
Ã‚Â· Disrupt statesÃ¢â‚¬â„¢ ability to manage the striped bass population.
We agree. Nor does the proposal outline any management alternatives for the states, nor have the states provided any management alternatives. Without knowing what the effects of opening the EEZ will be, it would be unwise to proceed with any opening of the EEZ to exploitation.
States will be given the burden of enforcement, and may not have the proper resources to fully implement the procedures that are required. There would be difficulty in enforcing striped bass regulations beyond 3 miles and controlling loopholes in individual statesÃ¢â‚¬â„¢ landing laws. How do we handle vessels fishing off of one state and landing the catch in another state or country? Beyond this, where does the funding and manpower come from?
Ã‚Â· Result in an increase in commercial catch.
We agree. It will encourage greater participation in a new directed fishery where none previously existed. Commercial seasons would have to be adjusted with the increased catches and mortality associated with the increased proportion of larger fish in the commercial landings, again leading to more complicated, convoluted regulations.
Ã‚Â· Result in an increase in mortality rate.
We agree. The mortality would increase on the larger older fish found in the EEZ.
Ã‚Â· Result in greater harvest of larger, older breeders (the EEZ is a refuge for large fish)
We agree. These are the very fish Amendment 6 was supposed to protect and did not. Just the opposite happened.
Ã‚Â· Result in directed fishing for larger, older striped bass, which is counter to the intent of Amendment 6 to increase the number of these fish.
Ã‚Â· Result in landings in excess of target mortality rate set in Amendment 6.
Ã‚Â· Create a new fishery in the EEZ.
We agree. With both sectors apparently fishing at maximum, why is it necessary to open a new fishery to people who are not now involved? It can only lead to higher mortality rates and over fishing. In New Jersey and other states this was mainly an inshore recreational fishery and not an EEZ fishery. This will create one and transfer landings from one sector in the recreational fishery thereby impacting the shore and inshore angler.
In opposition to ASMFC recommendation:
Prior to opening the EEZ, issues that should be addressed include:
Ã‚Â· Bycatch problems.
Ã‚Â· Higrading in both commercial and recreational fisheries.
Ã‚Â· Questionable population estimates-despite some highly questionable population estimates from ASMFC-the near shore population has declined.
We agree. The Chesapeake Bay area must be re-evaluated with real science and the inshore problems of the most northern states seems not to be addressed.
Ã‚Â· The effect of trans shipped catches.
This can be an issue of major importance, and the lack of good information here can ultimately have a devastating effect on the fishery.
Ã‚Â· The impact of the relaxing of both recreational and commercial regulations as allowed for in Amendment 6.
Some states are considering relaxing recreational regulations that have been in place for a long time. There are also periods during the fishing season when recreational anglers have not been able to harvest legal striped bass in state waters because the largest fish seem to be in the EEZ. This reduces the recreational harvest. Once the EEZ is open these areas will become fair game all year long and will no longer provide a sanctuary for the migrating striped bass
Ã‚Â· The EEZ should not be opened unless it can be determined that such actions would not disrupt management of striped bass by the states.
Ã‚Â· The recommendation to open the EEZ was not supported by a majority of the states.
Only 4 states voted to consider the recommendation. Five states opposed, 3 null and 1 abstention, only the 2 votes cast by the two federal agencies decided the issue.
Ã‚Â· Recreational fishing is worth more and recreational fishermen release fish, dead fish only benefit commercial fishermen.
The socio-economic value of the recreational striped bass to the states far outweighs that of the commercial sector. A large proportion of this participation is from shores and bridges and bays. This economic benefit to the shore communities is vital to their existence. We simply cannot take a chance of overfishing this resource by opening the EEZ
The preferred option here is to remain at status quo and KEEP THE EEZ CLOSED to the possession of striped bass. This option helps to maintain conservation of striped bass and allow states to manage striped bass within state waters.
JCAA Striped Bass Committee Chairman