Coastal Conservation Association Comments On Bluefish Allocation Amendment To The Bluefish Management Plan

The following comments were provided by CCA on the current Bluefish Allocation Amendment being considered by the Mid-Atlantic Council.  Full details of this action can be found HERE

The following information is from the document regarding public input:

The public is encouraged to submit comments regarding the range of potential issues to be addressed in the amendment. In addition to providing comments at any of the scheduled scoping hearings listed below, you may submit written comments by 11:59 p.m., Eastern Daylight Time, on July 30, 2018 

CCA’s Comments:

June 20th, 2018

To most anglers, bluefish are not a highly prized species like striped bass or even summer flounder. They are a cosmopolitan fish that have saved many a trip with their vicious strikes and strong fight. They are the third most important recreational species in pounds landed according to NOAA’s latest information (2016), yet many more are released than kept. While they may not be a target species, they are an important component of the Atlantic coast recreational fishery.

As with all species managed primarily for the recreational sector, they should be managed for maximum practicable abundance. Yet according to the last stock assessment, as noted in Figure 2 of the scoping document, bluefish have been undergoing overfishing every year since 1985. This is no way to manage bluefish as a primarily recreational species.

Central to this tenet is the notion that fish in the water have value to recreational fisheries, and a lot of fish in the water have a lot of value. Yet managers persist in believing only landed fish have value. One of the goals of the FMP should be to manage for maximum economic value.

The MAFMC is correct in managing this species primarily for the recreational sector, defined as the commercial fishery not exceeding 20% 0f the total catch, and that should remain as a central goal in the FMP. Yet as a practical matter the MAFMC and ASMFC have likely violated this goal by routinely transferring quota from the recreational to the commercial sector every year since 2001. The original allocation was set in the early 1990’s using previous catches by sector as the primary metric.

If the Council truly wishes to manage bluefish as primarily a recreational species and uses past catch history as the primary means of setting allocations percentages, then transfers between sectors should be abandoned.

It is time to use a different metric. Managing to an allocation set in past history makes little sense for today’s fishery. The bluefish population has changed, the climate has changed and the number of fishermen pursuing bluefish has changed. In our view one of the better metrics to guide allocation decisions is maximum economic value. The council should be encouraged to take a step back and develop an allocation policy consistent with the NMFS national allocation policy that sets a series of triggers to start a reallocation process and sets a group of factors that will be used to set allocations. Currently, the only trigger that the council is using is that the recreational sector didn’t harvest all they could. This is not fair nor is it in keeping with the national policy on allocation.

To manage for maximum economic value, one would have to compare the total value of fish in the commercial sector to the total value in the recreational sector. Total value on the recreational side is the sum of the value of caught fish, the value of a released fish and the value of access to take the fishing trip, summed across all anglers. As stated above, recreational anglers value abundance. One way to maintain the abundance they seek is by voluntarily releasing fish they catch to grow larger and be caught again. Allocating those uncaught fish to the commercial sectors robs the nation of that value and punishes the conservation decisions made by thousands of anglers. Setting allocations using just catch histories ignores the value being generated by a released fish. The current scoping document makes no mention of any other allocation factor other than catch histories.