|October 11, 1999
Dr. Joseph Desfosse|
Atlantic Menhaden FMP Coordinator
Atlantic States Marine Fisheries Commission
1444 Eye Street NW, 6th Floor
Washington, DC 20005
Dear Dr. Desfosse,
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, we also support Option 4 in the Supplement to the Atlantic Menhaden PID. The CBARF agrees with the peer review panel's recommendation, "that the current mixed advisory-scientific committee (AMAC) be dissolved and reconstituted into separate technical and advisory committees". The technical committee should be composed of biologists from states with a declared interest, the National Marine Fisheries Service and the U.S. Fish and Wildlife Service. The advisory committee should be composed of recreational fisherman, commercial fisherman and representatives from the environmental community.
The Advisory Report published in February 1999 by the ASMFC, Stock Assessment Report No. 99-01, and the PID, contain contradictory and inaccurate statements, for example, the reports claim, "The panel did not receive any direct evidence of local depletion of menhaden in the Chesapeake Bay and Florida waters. 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 VPA for these regions. These local depletions may or may not be subsidized in subsequent years by menhaden from other less exploited regions". Enclosed I have included a copy of my reply to Dr. Lisa Kline that gives a detailed explanation why I state the Advisory Report and the PID contain inaccurate remarks concerning local depletions of menhaden in the Chesapeake Bay.
The Juvenile Finfish Seining Survey conducted by the Maryland Department of Natural Resources indicates 1999 was the eighth consecutive year of poor recruitment of age-0 Atlantic menhaden in Maryland's portion of the Chesapeake Bay. The NMFS reported Atlantic menhaden purse seine landings through September 30th 1999 are 25.7% below 1998 landings for the same time period. Currently, 86% of the landings are composed of immature age-1 and age-2 fish. The harvest of these immature fish should be reduced in the Chesapeake Bay and along the Atlantic coast, until the stock demonstrates its ability to recover by producing several good or above average year classes.
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 ASMFC needs to coordinate the management of this valuable species with the Chesapeake Bay Program officials who are working toward the restoration of the Chesapeake Bay and management of it's living resources.
Numerous research projects have been recommended by the Atlantic Menhaden Advisory Committee to the Atlantic Menhaden Management Board, but no funding has been made available to carry out the recommendations, and no research projects are currently being conducted. The CBARF is 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 funds 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 CBARF recommends that an environmental assessment be conducted by the NMFS to determine the impact Atlantic Menhaden have on the ecology of the Chesapeake Bay.
The current amendment process is moving forward, however, it could be several years before any actions are approved and implemented through the adoption of an amendment to the Atlantic Menhaden FMP by the ASMFC. The Atlantic menhaden population has been declining for the past 17 years, decreasing 79% from 17.4 billion in 1981 to 3.8 billion in 1998. The CBARF recommends that the ASMFC take the necessary steps immediately to reduce fishing pressure on the remaining Atlantic menhaden stock.
James E. Price
cc: Sarah Taylor-Rogers, Secretary, MD DNR
Eric Schwaab, Fisheries Director, MD DNR
John Dunnigan, Executive Director, ASMFC
Jamie Geiger, Asst. Regional Director - Fisheries, USFWS
Judith Freeman, Director, NOAA Chesapeake Bay Office
Penelope Dalton, Asst. Admin., NMFS
Bill Matuszeski, Director, Chesapeake Bay Program
Congressman Wayne Gilchrest
Bill Goldsborough, MD Gov. Appointee, ASMFC
Delegate Ron Guns, MD Legislative Representative, ASMFC