The Honorable Wilbur Ross
U.S. Department of Commerce
1401 Constitution Avenue, NW
Washington, DC 20230
Dear Secretary Ross,
As members of the recreational fishing and boating industry, we ask that you affirm the October 31, 2019, decision by the Atlantic States Marine Fisheries Commission (ASMFC), which found the Commonwealth of Virginia out of compliance with Amendment 3 of the Interstate Fishery Management Plan (FMP) for Atlantic Menhaden for failing to fully and effectively implement and enforce the Chesapeake Bay Reduction Fishery Cap (Bay Cap). Furthermore, we ask that you take such action as deemed necessary and consistent with the Atlantic Coastal Fisheries Cooperative Management Act to compel the Commonwealth of Virginia to come into compliance with the FMP.
As ASMFC describes in their letter to you dated November 15, 2019, the Bay Cap is a management solution that conserves menhaden as critical forage for the Chesapeake Bay ecosystem, while reducing conflicts between an industrial fishing fleet and the sportfishing and boating communities. The Bay Cap is particularly important as of late because menhaden’s top predator, Atlantic striped bass, is currently in poor condition and the Chesapeake Bay is the primary spawning and nursery area for the species. Additionally, recent science suggests that the industrial harvest of menhaden contributes to the decline in striped bass biomass1. Therefore, the intent of the Bay Cap is to ensure adequate forage for striped bass and other important predator species (e.g., bluefish, summer flounder, black sea bass, weakfish) that have significant recreational fisheries within the Bay and along the Atlantic coast.
These valuable recreational fisheries are major contributors to America’s economy and support many fishing-dependent businesses across our industry. A Department of Commerce report, “Fisheries Economics of the United States 2016”, details the economic contributions of these menhaden-dependent fisheries to the various regions along the Atlantic coast2. Saltwater recreational fishing along the Atlantic is enjoyed by 6 million anglers annually, contributing $11.3 billion to the economy and supporting 120,236 jobs. The jobs created by these fisheries are the lifeblood of our Atlantic coastal communities as more than 90% of the sportfishing and boating industry is made up of small businesses.
Furthermore, the sportfishing and boating industry consistently plays an integral role in stewardship of our fisheries by directly funding conservation and habitat restoration efforts through licensing fees and excise taxes set up through the Sport Fish Restoration and Boating Trust Fund. In 2019 alone, $365.4 million was apportioned to the states to fund fishery conservation programs with the money generated from excise taxes on fishing equipment and motorboat fuel. Our industry is proud to be a partner in this cooperative approach to fisheries management because we know that fisheries conservation and fishing access afforded by these funds directly supports outdoor recreation and the American
economy. As stewards of our shared public resources, we respect the laws that govern our fisheries which ensure the sustainability of the resource and our industry. We simply cannot tolerate the recent actions of Omega Protein which willfully exceeded the Bay Cap and forced the Commonwealth of Virginia out of compliance with ASMFC.
Interstate fishery management only succeeds when each state fully and effectively implements and enforces the requirements of ASMFC and its FMPs. Your affirmation of the finding of non-compliance will hold Omega Protein accountable for their actions; demonstrate clear leadership to the millions of Atlantic coast anglers and the thousands of businesses they support; and ensure the ASMFC process continues to bring cooperative management solutions to our shared fishery resources.
American Sportfishing Association
Center for Sportfishing Policy
Baton Rouge, LA
Coastal Conservation Association
Congressional Sportsmen’s Foundation
Acting President & Conservation Director
International Game Fish Association
Dania Beach, FL
Marine Retailers Association of the Americas
National Marine Manufacturers Association
Recreational Fishing Alliance
New Gretna, NJ
President and CEO
Theodore Roosevelt Conservation Partnership
1 ) www.tandfonline.com/doi/full/10.1080/19425120.2017.1360420
2 ) www.fisheries.noaa.gov/webdam/download/97729452