Angler Paul
01-11-2014, 10:50 PM
JERSEY COAST ANGLERS ASSOCIATION ALERT HEARING on FLUKE ADDENDUM XXV
Please support Options 1 and 2
The public is encouraged to submit comments regarding addendum XXV at any time during the public comment period. The final date comments will be accepted is January 24, 2014 at 5:00 p.m. You may submit public comment in one or more of the following ways:
1. Attend public hearings in your state or jurisdiction.
2. Refer comments to your state’s members on the Summer Flounder, Scup, and
Black Sea Bass Management Board or Advisory Panel, if applicable.
3. Mail, fax or email written comment to the following address:
Mail: Kirby Rootes-Murdy Email: krootes-murdy@asmfc.org
Atlantic States Marine Fisheries Commission Phone: (703) 842-0740
1050 North Highland Street, Suite 200A-N Fax: (703) 842-0741
Arlington, VA 22201
A public hearing will be held on the addendum as listed below:
New Jersey Division of Fish and Wildlife
January 13, 2014 at 7 PM
Ocean County Administration Building
Public Hearing Room 119
101 Hooper Avenue
Toms River, New Jersey
Contact: Tom Baum at 609.748.2020
The Jersey Coast Anglers Association represents approximately 75 clubs throughout our state. We appreciate this opportunity to comment on Draft Addendum XXV to the summer flounder, scup and black sea bass fishery management plan.
Regarding summer flounder in section 3.1 we support option 1: Status Quo: Coastwide or Conservation Equivalency. We believe that the state-by-state measures under the conservation equivalency are the fairest way to divide the quota. While quotas are, in fact, based on harvest estimates for a single year (1998), there was sound reasoning for this. When the Management Board first considered how to equitably allocate the quota, and, thus, the conservation burden among its member states, it spent considerable time in analyzing various time periods. After much discussion it was agreed by the states that the single year of 1998 was the most representative and fairest.
Additionally, state-by-state measures allow our state to be flexible in setting regulations. Our state is often divided between back bays and southern New Jersey fishermen preferring an earlier shorter season with a smaller size limit and central and northern New Jersey fishermen preferring a later and longer season with a higher size limit. State-by-state measures allow the public to have input and the New Jersey Marine Fisheries Council considers all of this before voting on the compromise they feel meets the needs of the majority of our fishermen. We would lose this flexibility under any regional plan.
We also support Option 2: Utilization of Additional RHL. This option would allow New Jersey and other states facing a reduction to not to have as severe a cut. This worked out well last year in that it allowed New Jersey to extend its season and allowed New York to lower their size limit. Though New Jersey was granted an extra 88,000 fish which should have been more than ample to extend our season by 11 days, the New Jersey Marine Fisheries Council chose to only extend the season by 8 days. That was because the Council justifiably does not trust the numbers generated by the Marine Recreational Fisheries Statistical Survey (MRFSS) or Marine Recreational Information Program (MRIP). The Council's concerns were confirmed again in 2013 by the distorted MRIP numbers that were changed several times.
We are strongly opposed to any mandatory regionalization plan as described in option 3. The existing FMP allows for states to voluntarily combine their quotas with neighboring states, i.e., regionalize, yet none have done so. While we sympathize with the tougher regulations that our fellow fishermen in New York have, we are concerned that regionalization may result in some of New Jersey's target quota being reallocated to New York. Most likely, any regionalized plan would result in New York's regulations being liberalized at the expense of New Jersey's regulations being made more stringent. Further, under the adaptive regional approach outlined in option 3, if a region was to over fish, that region would be penalized the following year. If we opted to go back to conservation equivalency the following year “the technical committee will use the harvest from 2014 to predict the harvest in 2015 and compare that to the 2015 state harvest target (derived from the state’s 1998 based portion of the 2015 RHL). If a state’s predicted harvest is higher than the target, the state must adjust their regulations to constrain harvest to the 2015 target.” It is almost a certainty that with relaxed regulations, New York would harvest far more fish in 2014 than in 2013. Then New York would be forced to make draconian cuts in 2015.
We also suggest that New York or anyone else develop a plan that shows how each state would benefit from a regional plan and then it could be considered. More specifically, pertaining to the stated problem in section 2.1., we would like to see studies showing how the distribution, abundance, and size composition of fluke as well as the abundance and distribution of fluke anglers along the coast have changed over the years.
Addendum XXV suggests that under a regional approach we might have an 18" size limit with a 4 fish bag limit and a season from May 1st - September 30th. However, that is based on the current MRIP numbers that might change yet again. We also believe that these potential regulations would cause New York to significantly overfish their target quota which would negatively impact the entire region the following year. Consider the fact that in 2013, New York overfished its quota with a 19" size limit. For a regionalized plan to work, any region with New York in it would have to receive a substantially higher quota than the sum of what each state in that region would receive under state-by-state measures. Again, any regionalization plan should be voluntary and it should be mutually beneficial to all the states within a particular region.
We also question why you would consider making a small state like Massachusetts its own region. They should be in a region with other states. If any state should be its own region, it should be New Jersey because we account for the most fluke. There are also vast differences in the times and sizes of fluke that are available in different parts of our state.
NJ has the most fluke and the most fluke fishermen. A higher percentage of our fishing trips target fluke than any other state. Still we are forced to have a shorter season than almost all the other states. In many of the more recent years our traditional early spring and late fall fishing has been taken away from us while other states are open year round. How is that fair?
We would also like to point out that the commercial quota is divided up on a state-by-state basis. It is simply the fairest way to do things whether it applies to commercial or recreational fishermen.
Regarding sea bass, we believe that they should be managed on a state-by-state basis through conservation equivalency as well. Since that is not an option, regarding section 3.2, we reluctantly support option 1: Status Quo We are aware that over fishing has occurred in many years but believe this is due to an unrealistically low RHL. We also do not agree with the fact that the overall coastal quota is being reduced due to over fishing that occurred in Massachusetts state waters.
Please support Options 1 and 2
The public is encouraged to submit comments regarding addendum XXV at any time during the public comment period. The final date comments will be accepted is January 24, 2014 at 5:00 p.m. You may submit public comment in one or more of the following ways:
1. Attend public hearings in your state or jurisdiction.
2. Refer comments to your state’s members on the Summer Flounder, Scup, and
Black Sea Bass Management Board or Advisory Panel, if applicable.
3. Mail, fax or email written comment to the following address:
Mail: Kirby Rootes-Murdy Email: krootes-murdy@asmfc.org
Atlantic States Marine Fisheries Commission Phone: (703) 842-0740
1050 North Highland Street, Suite 200A-N Fax: (703) 842-0741
Arlington, VA 22201
A public hearing will be held on the addendum as listed below:
New Jersey Division of Fish and Wildlife
January 13, 2014 at 7 PM
Ocean County Administration Building
Public Hearing Room 119
101 Hooper Avenue
Toms River, New Jersey
Contact: Tom Baum at 609.748.2020
The Jersey Coast Anglers Association represents approximately 75 clubs throughout our state. We appreciate this opportunity to comment on Draft Addendum XXV to the summer flounder, scup and black sea bass fishery management plan.
Regarding summer flounder in section 3.1 we support option 1: Status Quo: Coastwide or Conservation Equivalency. We believe that the state-by-state measures under the conservation equivalency are the fairest way to divide the quota. While quotas are, in fact, based on harvest estimates for a single year (1998), there was sound reasoning for this. When the Management Board first considered how to equitably allocate the quota, and, thus, the conservation burden among its member states, it spent considerable time in analyzing various time periods. After much discussion it was agreed by the states that the single year of 1998 was the most representative and fairest.
Additionally, state-by-state measures allow our state to be flexible in setting regulations. Our state is often divided between back bays and southern New Jersey fishermen preferring an earlier shorter season with a smaller size limit and central and northern New Jersey fishermen preferring a later and longer season with a higher size limit. State-by-state measures allow the public to have input and the New Jersey Marine Fisheries Council considers all of this before voting on the compromise they feel meets the needs of the majority of our fishermen. We would lose this flexibility under any regional plan.
We also support Option 2: Utilization of Additional RHL. This option would allow New Jersey and other states facing a reduction to not to have as severe a cut. This worked out well last year in that it allowed New Jersey to extend its season and allowed New York to lower their size limit. Though New Jersey was granted an extra 88,000 fish which should have been more than ample to extend our season by 11 days, the New Jersey Marine Fisheries Council chose to only extend the season by 8 days. That was because the Council justifiably does not trust the numbers generated by the Marine Recreational Fisheries Statistical Survey (MRFSS) or Marine Recreational Information Program (MRIP). The Council's concerns were confirmed again in 2013 by the distorted MRIP numbers that were changed several times.
We are strongly opposed to any mandatory regionalization plan as described in option 3. The existing FMP allows for states to voluntarily combine their quotas with neighboring states, i.e., regionalize, yet none have done so. While we sympathize with the tougher regulations that our fellow fishermen in New York have, we are concerned that regionalization may result in some of New Jersey's target quota being reallocated to New York. Most likely, any regionalized plan would result in New York's regulations being liberalized at the expense of New Jersey's regulations being made more stringent. Further, under the adaptive regional approach outlined in option 3, if a region was to over fish, that region would be penalized the following year. If we opted to go back to conservation equivalency the following year “the technical committee will use the harvest from 2014 to predict the harvest in 2015 and compare that to the 2015 state harvest target (derived from the state’s 1998 based portion of the 2015 RHL). If a state’s predicted harvest is higher than the target, the state must adjust their regulations to constrain harvest to the 2015 target.” It is almost a certainty that with relaxed regulations, New York would harvest far more fish in 2014 than in 2013. Then New York would be forced to make draconian cuts in 2015.
We also suggest that New York or anyone else develop a plan that shows how each state would benefit from a regional plan and then it could be considered. More specifically, pertaining to the stated problem in section 2.1., we would like to see studies showing how the distribution, abundance, and size composition of fluke as well as the abundance and distribution of fluke anglers along the coast have changed over the years.
Addendum XXV suggests that under a regional approach we might have an 18" size limit with a 4 fish bag limit and a season from May 1st - September 30th. However, that is based on the current MRIP numbers that might change yet again. We also believe that these potential regulations would cause New York to significantly overfish their target quota which would negatively impact the entire region the following year. Consider the fact that in 2013, New York overfished its quota with a 19" size limit. For a regionalized plan to work, any region with New York in it would have to receive a substantially higher quota than the sum of what each state in that region would receive under state-by-state measures. Again, any regionalization plan should be voluntary and it should be mutually beneficial to all the states within a particular region.
We also question why you would consider making a small state like Massachusetts its own region. They should be in a region with other states. If any state should be its own region, it should be New Jersey because we account for the most fluke. There are also vast differences in the times and sizes of fluke that are available in different parts of our state.
NJ has the most fluke and the most fluke fishermen. A higher percentage of our fishing trips target fluke than any other state. Still we are forced to have a shorter season than almost all the other states. In many of the more recent years our traditional early spring and late fall fishing has been taken away from us while other states are open year round. How is that fair?
We would also like to point out that the commercial quota is divided up on a state-by-state basis. It is simply the fairest way to do things whether it applies to commercial or recreational fishermen.
Regarding sea bass, we believe that they should be managed on a state-by-state basis through conservation equivalency as well. Since that is not an option, regarding section 3.2, we reluctantly support option 1: Status Quo We are aware that over fishing has occurred in many years but believe this is due to an unrealistically low RHL. We also do not agree with the fact that the overall coastal quota is being reduced due to over fishing that occurred in Massachusetts state waters.