Comments Of James E. Price To The Atlantic States Marine Fisheries Commission Atlantic Menhaden FMP Amendment Process

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Chesapeake Bay Ecological Foundation, Inc. Founded 1984, Easton, MD

Comments Of James E. Price To The Atlantic States Marine Fisheries Commission Atlantic Menhaden FMP Amendment Process

The Chesapeake Bay acid rain foundation supports the recommendations from the Atlantic Menhaden peer review panel and the management objectives outlined in the public information document, also we support option 4 in the supplement to the Atlantic Menhaden PID. The CBARF agrees with the peer review panels recommendation, “That the current mixed advisory-scientific committee (AMAC) be dissolved and reconstituted into separate technical and advisory committees”.

The Atlantic Menhaden population has been in a state of decline for the past 17 years, decreasing 79% from 17.4 billion in 1981 to 3.8 billion in 1998; Atlantic Menhaden landings for 1999 through august 31st are 40% below the previous five-year average. Currently, 86% of the landings are composed of immature age-1 and age-2 fish. Until the stock demonstrates some sign of recovery, the harvest of these immature fish should be reduced in the Chesapeake Bay and along the Atlantic coast.

The advisory report published in February 1999 by the ASMFC, “Stock Assessment Report No 99-01”, and the public information document, are incorrect and somewhat contradictory. The report claims the panel “did not receive any direct evidence of local depletion of Menhaden in the Chesapeake Bay and Florida waters”. The report states: “However, most effort is directed on components of the stock which utilize the Chesapeake Bay and North Carolina waters . . . Therefore, on a seasonal basis, local exploitation rates are expected to exceed those estimated from the CPA for these regions. These local depletions may or may not be subsidized in subsequent years by Menhaden from other less exploited regions”.

The CBARF is submitting, for the record, copies of several recent letters sent to and received from William Pruitt, Chairman of the Atlantic Menhaden Management Board and a letter sent to William Matuszeski, Director of the Chesapeake Bay Program. The ASMCF needs to coordinate the management of this valuable species with the CBP officials who are working toward the restoration of the Chesapeake Bay and management of its living resources. The harvest of age-1 and age-2 Atlantic Menhaden should be restricted in the Chesapeake Bay until after an environmental impact assessment, concerning the effect Atlantic Menhaden have on the ecology of the Chesapeake Bay, is competed.

Various research projects have been recommended by the Atlantic Menhaden advisory committee annually to the Atlantic Menhaden management board; no funding has been made available to carry out the recommendations and no research projects are currently being conducted. Due to lack of commitment by the ASMFC in conducting research projects, the CBARF began working with the Maryland DNR, the interstate commission on the Potomac River Basin, and the U.S. Fish and Wildlife Service to submit proposals to Congressman Wayne Gilchrest in hopes of obtaining funding necessary to proceed with increased water quality monitoring and various research projects involving the declining Atlantic Menhaden population. Also, for the record, the CBARF is submitting copies of these proposals along with other charts and reports to the ASMFC.

The current amendment process is moving forward, however, it could be years before any actions are approved and implemented through the adoption of an amendment to the Atlantic Menhaden FMP by the ASMFC. The CBARF recommends that the ASMFC take the necessary steps immediately to reduce fishing pressure on the remaining Atlantic Menhaden stock.

If the ASMFC continues to take no action to restrict the harvest of Atlantic Menhaden, the CBARF is prepared to proceed with the process that will require the NMFS to review the status of the stock under section ……………………………of the federal code.