CHESAPEAKE BAY ECOLOGICAL FOUNDATION, INC.
P.O. BOX 1538
EASTON MD 21601
April 3, 2012
Fishery Management Plan Coordinator
Arlington, VA 22201
Atlantic States Marine Fisheries Commission
1050 N. Highland Street, Suite 200 A-N
Dear Mr. Waine:
The Chesapeake Bay Ecological Foundation (CBEF) has been providing biological and ecological data concerning the decline of Atlantic Menhaden to the Atlantic States Marine Fisheries Commission's (ASMFC) Atlantic Menhaden Management Board (AMMB) since June 8, 1998, initially at the request of the Maryland Department of Natural Resources.
As a result of CBEF's testimony to the AMMB the ASMFC decided to conduct Atlantic Menhaden's first external peer review June 11, 1998. The peer review was completed in November 1998. Upon receiving the report of the Peer Review Panel in January 1999 the Board recommended that a full amendment to the current Fishery Management Plan (FMP) be developed. In 2001, following the peer review, Amendment 1 was passed, providing specific biological, social, economic, ecological, and management objectives for the fishery.
Revisions to Amendment 1 were made during the decade that followed which included Addendum 1 through Addendum 1V. These Addendums addressed changes in biological reference points, a cap on the Atlantic menhaden harvest and a research program for Atlantic menhaden in Chesapeake Bay. During this period the fundamental problem of ecological depletion of menhaden (insufficient numbers to provide adequate prey for dependent predators) remained unresolved and the population continued to decline while the goals and objectives of the new and revised FMP were not achieved.
Since 2004, CBEF, with initial assistance from East Carolina University, has examined over 8,000 striped bass from the Chesapeake Bay and Atlantic Ocean along the Virginia and North Carolina coast. This ongoing study that includes a Predator/Prey Monitoring Program has focused on collecting data to help determine the size and numbers of Atlantic menhaden that are consumed by Atlantic coast striped bass. CBEF is currently working toward the goal of providing ASMFC with additional peer reviewed published papers on this study. This type of information is vital in determining predation mortality of menhaden in ASMFC's Multi-Species VPA Model. In fact, according to ASMFC fisheries scientists: "Model results demonstrate that, for menhaden in particular, and forage fish in general, quantifying predation mortality is an important part of effective assessments of forage fish, their predators, and the fisheries of both."
In November 2011, the AMMB approved Addendum V which establishes a new interim fishing mortality threshold and target. In February 2012 the AMMB approved the Public Information Document (PID) for Draft Amendment 2 which is intended to initiate discussion on the new biological reference points recently adopted through Addendum V. In the PID ASMFC stated that the primary question on which the Commission is seeking public comment is: "How would you like the Atlantic menhaden fisheries to look in the future?" CBEF would like to see Atlantic menhaden managed as a forage fish in which the ecological services they provide take preference over its exploitation as an industrial commodity. The purse seine reduction fishery should not be allowed to harvest immature ages 0&1 menhaden (nutritionally critical to non-migratory Chesapeake Bay striped bass) or harvest the spawning stock in the Exclusive Economic Zone. The ASMFC should manage the menhaden purse seine fisheries and require the states to submit management plans for the small bait fisheries that operate in their local waters.
In October 2012 the AMMB is scheduled to approve Amendment 2. After fifteen years of testimony, debate, research and written comments the Board has not resolved the fundamental problem of ecological depletion of menhaden. According to the PID under Issue 1: The new F reference points adopted by the Board are intended to be interim reference points. The ASMFC has not collected adequate up-to-date diet information necessary to quantify predation mortality on menhaden; therefore, the Multispecies Technical Committee has been unable to provide the Menhaden Technical Committee and the AMMB with the information needed to help determine the ecological-based reference points in time for inclusion into Amendment 2.
The PID addresses the problem of overfishing but fails to acknowledge the issue of ecological depletion and without additional information concerning the number of menhaden being removed by predators, the Board will be unable to determine if too many menhaden are being harvested. Therefore, substantial reductions in harvest should be taken immediately to achieve F target. In addition, the Board hasn't addressed the issue of what size menhaden to protect or when they should be protected to provide critical forage for Chesapeake Bay striped bass. ASMFC's claim, that overfishing is not occurring, doesn't mean there is adequate prey for dependent predators.
Although most of the public concern appears to be focused on the lack of forage for menhaden predators, the ASMFC hasn't provided any information concerning the health of the predators that prey on Atlantic menhaden. Also, the ASMFC hasn't provided the public with any information concerning the numbers of menhaden consumed by predators or the size and number of menhaden that need to be protected for ecological services. The ASMFC needs to develop a Predator/Prey Monitoring Program similar to CBEF's program to monitor the diet, health and migration of top marine predators to ensure self-sustaining populations of fish species along the Atlantic coast.
Attached is a CBEF report and additional comments relevant to the PID.
James E. Price, President
Chesapeake Bay Ecological Foundation