CCA Letter to ASMFC Urges Commission to Keep Commitment to Managing Menhaden
Next week the Atlantic Menhaden Management Board will set specifications for the 2017 fishery and provide further guidance to its Plan Development Team on Draft Amendment 3. These two issues are of the utmost importance to the Coastal Conservation Association. We urge you to keep your commitment to managing menhaden for predators, allow conservation to continue working, and avoid the impacts of regulatory whiplash. Be cautious and measured in your setting of the specifications and stay on the schedule previously established for the approval and implementation of Amendment 3.
Any increase in quota in 2017 without an understanding of the impacts to the ecosystem is contrary to the Commission’s now long-standing commitment to manage menhaden based on its role as forage through Amendment 3. Furthermore, an increase will go primarily to Virginia and New Jersey, will not address shortages in the other states and in the bait market, and will not sufficiently help those states that are exceeding their allocations.
Any attempt to alter the current allocation formula through an addendum for 2017 presupposes that such a formula could be easily agreed to. Its development and consideration would further delay implementation of Amendment 3, which already considers new allocation schemes, but only after the much anticipated socio-economic study is completed. States already have the ability to share quota to address their bait needs. Amendment 3 is the right vehicle to address allocation, together with developing ecological reference points, not through an addendum now.
During next week’s discussions, we ask that you consider that all of the Technical Committee’s projections are based on a single-species model and assessment and the impacts of any increase in catch on predators like striped bass and weakfish in the system are unknown. Since no one has identified what a TAC would look like under ecological reference points, significant regulatory whiplash could result. There simply is no new science to justify a catch increase and there are good reasons to be cautious. You have no new data since the 2015 benchmark assessment and the troubling signs of low abundance and recruitment remain. In fact, the Technical Committee continues to inform that recruitment and fecundity are not expected to increase in 2017. But, a new assessment is coming in 2017 and that should inform Amendment 3.
We urge you to stay the course with Amendment 3 and let menhaden fully recover to their historic range.