“If we do not put the heat on the ASMFC to do the right thing, Omega Protein will prevent any meaningful protection, the menhaden population will continue to crash, and species after species of the valued fish dependent on menhaden will crash with them.”
— H. Bruce Franklin, author of The Most Important Fish in the Sea: Menhaden and America
The October New Moon is here and while I’ve pretended like I was waiting for it to start the fall run, in truth I’ve been adjusting to domesticated life and all of the now-doubled family obligations that come with it. September was a complete wash of out of town weddings and birthdays, but it was 90 degrees for almost the entire month so perhaps I didn’t miss much. I moved at the end of August and the apartment is still a mess and full of boxes and I can’t find anything when I look for it, but there are more important fishing matters now with a window opening of an unknown, but always shrinking, length.
More immediately though, the Atlantic States Marine Fisheries Commission held its meetings regarding Atlantic menhaden (aka bunker) management over the past six weeks and today is the last day to send in public comments to the ASMFC. The Commission is considering what’s called Amendment 3, which will lay out a management plan for menhaden based on their role in an ecosystem—meaning it will be managed as a prey species and will consider factors such its role as a food source for predatory species like striped bass, birds, and mammals like whales and dolphins. It will not continue to be managed like a single species independent of environmental impacts, factors, but rather by its importance in the food chain. The bottom line of how many millions of pounds Omega Protein is allowed to take from the Chesapeake Bay is ostensibly no longer the primary factor in menhaden management, but more on that later because Omega’s take in the Chesapeake is also an important consideration.
We should support Amendment 3 and push for a “75% Target; 40% Threshold” interim rule while the Commission figures out the final details of implementing Amendment 3. This interim rule refers to maintaining a 75 percent unfished stock, and the Commission would be forced to take action if the stock falls below 40 percent. We should also push to revamp the allowable catch in the Chesapeake Bay—the headquarters of Omega and the reduction industry. The available option in Amendment 3 caps the Bay catch at 51,000 metric tons, reduced from over 85,000 metric tons. The argument here is that Omega never comes close to the 85K cap and can in turn take as much as it wants—there is no real regulation on how much they can take. I’ll have a sample letter that you can copy and paste at the bottom of this post.
So far, at least in the New York meetings, it looks like most people are on board with better menhaden management. That includes recreational fishermen (and women), commercial fishing captains, scientists, tackle shop owners, conservationists, bay watchers, and whale watchers. [Speaking of which, during a time of particularly high abundance of peanut bunker out in the Rockaways last Spring, I casted fruitlessly in the dawn hours into a gorgeous morning. Out in the distance I watched birds making great wide circles, as if they were slowly looping an oval race track. More birds appeared, seemingly out of the air, moving in the same direction, making those great circles. It was not the kind of bird action I’m accustomed to seeing—I’m more interested in the chaotic diving into the water variety. But this looked almost ritualistic, a conjuring even. And it was—seconds later a humpback blasted out of the water like something crashing out from the surface of a mirror. I didn’t catch any fish that day, but it was one of the most awesome things I’ve seen in NYC waters.] But while consensus among citizens may be near universal—according to John McMurray, the ASMFC received over 25,000 comments in 2016 in favor of ecosystem-based management, and only 11 comments favoring the current, single-species management—agreement among states is far from certain.
Obviously Virginia, home to Omega Protein who still controls 85 percent of the total allowable catch, and New Jersey, which has a smaller stake in the bait industry (11 percent), probably won’t support an ecosystem approach. The problem with the current single-species management these industries favor is there isn’t any consideration for predator/prey relationships. The increased number of whale sightings, the healthier birds, the more bunker we’ve seen pooled up in places like the Harlem River and even Newtown Creek (ugh!)—a lot of this is likely due to the 20 percent harvest reduction back in 2012. The menhaden industry believes it was solely environmental factors and not the reduction that impacted the increased numbers of bunker. However, they also believe their harvest has no impact on the population, which is just intellectually dishonest at best—the fishing industry once thought they could never out fish the cod population either and you know how that story ends.
So here’s the letter you can send to the ASMFC (should be sent to Megan Ware, email@example.com, Subject line: Draft Amendment 3). It’s short and to the point and takes less than five minutes.
Hello ASMFC Commissioners!
I am writing on behalf of the Brooklyn Urban Anglers Association. You have a unique opportunity on November 13 to make a huge impact on the quality of marine life in the Atlantic Ocean. The importance of menhaden in our ocean ecosystems is well documented and cannot be overstated. This is not a resource that should be managed based on the short-term desires of a single industry. More menhaden in the water has more potential to have positive results across the spectrum of marine life resulting in benefits for both the recreational and commercial communities. We believe we are just seeing the beginnings of potential long-term benefits of menhaden management.
In the interim, we support ISSUE 2.6 REFERENCE POINTS – OPTION E: “BERP Workgroup Continues to Develop Menhaden-Specific ERPs with Interim use of 75% Target, 40% Threshold.” Menhaden from this point forward should not be managed as a single-species, even before full implementation of Amendment 3.
We also support a cap on the Chesapeake Bay allotment. We support Option B which sets the cap at 51,000 metric tons, an approximation of the five-year average of reduction harvest from the Chesapeake Bay between 2012 and 2016. It’s important to close the loophole which allows Omega a virtually unlimited take of an essential resource in a critical area.
The Brooklyn Urban Anglers Association is a group of dedicated citizens who fish all of New York City’s waters, from Prospect Park and the East River, to the Rockaways and the upper Hudson. We were established in 2009 with the vision of expanding awareness of New York City’s fishing history, the life found in its waterways, and the benefits of responsible conservation and clean rivers. Please consider the impacts of your decisions regarding Amendment 3.
Brooklyn Urban Anglers Association