Amendment 31 to the Coastal Migratory Pelagics Fishery Management Plan
Thank you for the opportunity to comment on cobia management in Draft amendment 31, we sincerely appreciate the opportunity. The Coastal Conservation Association is the largest marine resource conservation group of its kind in the nation and at this time we are in favor of Preferred Alternative 2: Remove Atlantic cobia from the Coastal Migratory Pelagics Fishery Management Plan.
Despite all the uncertainties surrounding this popular species, the one factor that is indisputable is that the majority of harvest takes place in state waters. This action, if taken, would move management of cobia to the Atlantic States Marine Fisheries Commission (ASMFC) for the Georgia to New York portion of the fishery.
We are aware there is a stock identification workshop this spring, with results anticipated in 2019, and a new stock assessment is also about to get underway. Hopefully there will be new information on which to base a final decision on the management of this important species. New information may lead us to change our current position.
We must note it is extremely difficult to make an informed decision on the management of an important recreational species when the most current information on stock status is at least eight years old. The Council and NOAA Fisheries must strive to have more current information on which to make management decisions. It is possible, and even highly likely, that the current high catches are due to a recruitment spike at some point in the last eight years.
As is well documented, recreational fisheries respond to the population of fish that exists in the water today. If the recreational fishery is catching a lot of fish, as is the case currently with cobia in the South Atlantic, it is most likely because there are a lot of fish in the water, as a result of a large year class entering the fishery. That could be considered a good thing, but the current federal management paradigm forces managers to react as if something bad has happened because the recreational fishery is exceeding an outdated annual catch limit.
We appreciate the opportunity to comment on Amendment 31 and will stay engaged on these issues as additional necessary science on this species is developed.