James Boyle
Fishery Management Plan Coordinator
Atlantic States Marine Fisheries Commission
1050 N. Highland St. Suite 200
Arlington, VA 22201
Dear Mr. Boyle and Members of the Menhaden Management Board,
As organizations representing hundreds of thousands of constituents from the recreational fishing, boating, and conservation community along the Atlantic, we urge you to adhere to the ecosystem-based framework that represents the cutting-edge of sustainable fisheries management and:
- Accept the 2025 benchmark ERP F target (0.151), ERP F threshold (0.458), FEC target (1,758,288), and FEC threshold (1,184,339); and
- Set the 2026-2028 TAC at the level projected to have a less than 50% probability of exceeding the ERP F target (108,450 mt).
These values represent the best available science based on the latest single-species and ERP stock assessment updates. These values would maintain the integrity of the ERP framework for Atlantic menhaden management, which accounts for menhaden’s role as a forage in the diets of key predators, in particular, striped bass.
The Best Available Science Indicates That ERP Values Must Be Lowered
The 2025 single-species and ERP stock assessment updates utilize the best available science, including the latest suite of species’ life history data and updated ecosystem models which incorporate complex predator-prey dynamics, and have undergone rigorous peer review to be ready for adoption in management. The ERPs, which are an output of these assessments, explicitly evaluate tradeoffs between menhaden harvest and predator population outcomes, particularly for striped bass. The single-species and ecosystem models underwent independent peer review by external experts and were endorsed as scientifically credible for use in management. The 2025 ERP values derived from the stock assessment updates represent the amalgamation of this effort and demonstrate a firm grounding in the best available science. It is imperative that the Board accept these values to maintain the integrity of the ERP framework itself and to continue the sustainable management of the Atlantic menhaden stock, or its role as a key forage species in the Atlantic ecosystem could be at stake.
To Rebuild Striped Bass, We Must Manage Menhaden Below the ERP F Target
Fishing Atlantic menhaden below their ERP F target is necessary to support striped bass rebuilding. The ERP framework explicitly links menhaden harvest levels to striped bass population outcomes. Striped bass are the dominant predator influencing the ERP models, and they are currently overfished with spawning stock biomass below target levels. Allowing menhaden harvest to exceed the ERP F Target risks constraining menhaden availability at a time when striped bass require sufficient forage to rebuild. By reducing menhaden fishing mortality below the ERP F Target, additional forage is left in the system, lowering the probability of prey limitation on striped bass growth, survival, and recruitment. This precautionary strategy also accounts for uncertainty in stock assessments, predator-prey interactions, and environmental variability, thereby increasing the likelihood that striped bass can rebuild to their biomass target within the mandated time frame under the ASMFC’s rebuilding requirements.
The ASMFC has two primary levers to support striped bass rebuilding: controlling striped bass fishing mortality and menhaden fishing mortality. The Atlantic Striped Bass Board has already demonstrated leadership by implementing multiple years of regulatory changes that reduced fishing pressure to a 30-year low, with striped bass fishing mortality now well below the target and threshold. This means that striped bass fishing mortality is no longer the limiting factor for rebuilding. Because striped bass are heavily dependent on menhaden, managing menhaden at or below the ERP F Target is essential to ensure sufficient prey biomass for striped bass. If the ASMFC also wants to rebuild the striped bass stock, then it needs to manage equally across both species. A TAC set at a level with no more than a 50% probability of exceeding the ERP F Target reflects best practice for managing a key forage species, reflects the peer-reviewed science underlying the ERP framework, and provides an appropriate buffer against uncertainty in predator–prey interactions and ecosystem variability. If the Menhaden Management Board fails to manage menhaden at the ERP F Target, it is effectively undermining striped bass rebuilding and disregarding the ecosystem-based approach the ASMFC has committed to uphold.
In closing, we urge the Menhaden Management Board to adopt the 2025 ERP values and establish a TAC for 2026–2028 that ensures no greater than a 50% probability of exceeding the ERP F Target. Doing so will safeguard the ecological role of menhaden, provide the forage base necessary for striped bass rebuilding, and maintain the credibility of the ERP framework as the best available science for ecosystem-based management. The decisions before the Board are not only about managing menhaden but about sustaining the health of the Atlantic coast’s fisheries, coastal economies, and the communities who depend on them. We ask the Board to act decisively and uphold its commitment to science-based, precautionary management.
Sincerely,
American Bird Conservancy
Angler Action Foundation
Boat Owners of The United States, BoatU.S.
Bonefish & Tarpon Trust
Coastal Conservation Association
Guy Harvey Foundation
International Game Fish Association
Marine Retailers Association of the Americas
National Audubon Society
Rhode Island Saltwater Anglers Association
Theodore Roosevelt Conservation Partnership
Virginia Saltwater Sportfishing Association
