Comments Needed for Unmanaged Fisheries! A Rare Opportunity!

Note my epic measuring technique, useful for getting that extra 1/8

Note my epic measuring technique, useful for getting that extra 1/8″ for the win. Oh, and also the silversides this blue spit up.

Spearing on the deck! Coughed up by a bluefish on that spot I used to fish all the damn time.

Spearing on the deck! Coughed up by a bluefish on that spot I used to fish all the damn time.


The Mid-Atlantic Fishery Management Council is actually taking a proactive step and looking into the sustainability of currently-unmanaged fisheries, like sandeels, silversides, bay anchovies and several other species of anchovy, Spanish sardine, and round herring. These are all important food sources for fish like albies, tunas, bluefish, weakfish, and of course striped bass; and we already know what happens when commercial/corporate interests come first in our fishery: think menhaden and cod. Captain John McMurray has a good column regarding the importance of these forage species and some general outlook and information on what the MAMFC is looking for in its series of scoping hearings it’s holding during the next few weeks. It’s a good read on why we need to take advantage of this rare opportunity to effect change in the fishery before it starts, instead of scrambling and baling water when it’s already too late like we usually find ourselves.

The MAFMC is accepting comments and letters until 23:59 Eastern Standard Time on Friday October 2, 2015.

Written comments may be sent by any of the following methods:

1) Online at

2) Email to the following address:

3) Mail or Fax to:
Dr. Chris Moore, Executive Director
Mid-Atlantic Fishery Management Council
800 North State Street, Suite 201
Dover, DE 19901
FAX: 302-674-5399

Please include “Unmanaged Forage Scoping Comments” in the subject line if using email or fax or on the outside of the envelope if submitting written comments.

I wrote up a letter to Julia Beaty, Fishery Plan Coordinator at the MAFMC (the, which, while somewhat personal, you are all welcome to copy/edit/paste as you see fit.

Dear Julia,

First off, bravo for the Council’s initial forward-thinking move to study and consider the regulation of unmanaged fisheries. We’ve been down this road so many times when it seemed a constant uphill battle against corporate and commercial interests, at which point the best we could hope for was to mitigate the damage and pray for a stock recovery. Thanks to you and the MAFMC for devoting time toward species like sand eels, silversides, and bay anchovies—fish that are so important to the survival of striped bass, among others, that we at the Brooklyn Urban Anglers Association have advocated for many times in the past.

We are aware that NOAA has looked into some of these fisheries as potentially viable commercial sources before, so we feel it’s very important the MAFMC take careful and deliberate steps to studying these unmanaged populations before the rendering plants determine the courses of action for us. You (the MAFMC) have asked that we consider eight questions in our comments. By now, you’re probably familiar with Captain John McMurray’s response to these eight considerations. In general, we at the BKUAA agree with McMurray’s assessments.

1. What is the most appropriate type of action?
We believe amending a current management plan and adapting it to forage species is the best of the three options, out of consideration for time, effectiveness, and deliberate action. Waiting to address new fisheries for forage species as they arise (the third option) would only put us in a difficult, albeit familiar, position.

2. What type of management provisions would be most effective?
We believe adding forage species to the management plan as an “ecosystem component species” is obvious because of their importance to the vitality of other fisheries, and would initially give the unmanaged fisheries the attention they need before possibly opening these fisheries to commercial sources.

3. Which forage species should be included in this action?
Sand Eels. Chub Mackerel. Spearing. Silversides. Bay anchovy. Striped anchovy. Silver anchovy. Round herring. Thread herring. Spanish sardine.

4. What types of fishing should be addressed?
The commercial (especially) trawler fleets. See Omega Protein.

5. What is the most appropriate geographic scope of the action?
What areas the Council has under its jurisdiction would be an appropriate start.

6. What are the most effective ways to prohibit the expansion of existing fisheries?
Scientific studies and research with allowances for proper evaluation before opening the fisheries to the rendering plant. Not bowing to pressure from corporations or people from New Jersey.

7. What is an appropriate process for allowing new fisheries to develop?
McMurray suggested “exempted fishing permits,” which have had documented success on the West Coast fisheries in both data collection and exploring the vitality and sustainability of a controlled fishery.

8. What is the ability of current scientific data and models to inform action?
That’s more of a question for you to answer for us. There’s plenty of examples of poorly managed fisheries that teeter on collapse or have already collapsed (cod, menhaden, striped bass). There’s also examples of properly managed fisheries (Florida comes to mind) that worked and allowed the species to recover. We hope you make the right decisions with regards to the overall health and sustainability of the Atlantic fishery.


Brooklyn Urban Anglers Association


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