BLUEFISH REBUILDING PLAN CREEPS FORWARD

The Mid-Atlantic Fishery Management Council and the Atlantic States Marine Fisheries Commission’s Bluefish Management Board held a joint meeting on June 16, when they spent more than three hours discussing possible alternatives for the Bluefish Allocation and Rebuilding Amendment. 

Progress was painfully slow.  The Fishery Management Action Team charged with analyzing the data, managers’ concerns and public comment, and then crafting alternative measures for the Council’s and Management Board’s consideration, had provided a discussion document to both management bodies prior to the meeting.  In presenting that document, the Action Team explained that it was crafted after a meeting

“to further refine draft alternatives, including identifying alternatives that should not be further pursued in this action due to feasibility or timing concerns.  The [Fishery Management Action Team] discussed the implications of each draft approach and worked to identify any additional analyses needed to guide the Council and Board during their next discussion of this action in mid-June.”

It was a comprehensive document, that was responsive to public comment, the needs of the bluefish resource and the limitations of the available data.  Unfortunately, the Council and Management Board chose to ignore some of the Action Team’s recommendations and, at least for the time being, missed out on an opportunity to adopt measures that would have broken new ground by managing the fishery as what it is:  a predominantly recreational fishery that supports a high level of catch-and-release angling. 

Instead, they chose to bog themselves down with unnecessary and, in some cases, arguably unwise alternatives; rather than take decisive action on some important issues, they merely deferred decisions until August, when action will probably have to be taken in order to meet deadlines imposed by the Magnuson-Stevens Fishery Conservation and Management Act. 

From the moment discussions began, it was clear that some people sitting around the table weren’t particularly keen on moving forward, illustrating why Magnuson-Stevens, and its legally-enforceable requirement that overfished stocks be rebuilt, is so important to the health of our fisheries. 

As soon as the Action Team completed its initial presentation, Tom Fote, the Governor’s Appointee from New Jersey, tried to cast doubt on their projections of bluefish recovery under various management scenarios by asking whether the Action Team had considered the “history” of bluefish when preparing the document.  

He followed up with his view that the bluefish stock only “started collapsing” after a recreational bag limit was imposed in the 1980s, and that the decline in bluefish abundance since then had “nothing to do with fishing,” despite the fact that the operational stock assessment released less than a year ago demonstrated that the bluefish stock had been experiencing overfishing in every year between 1985 and 2017.

Fote ended by saying that

“I have no confidence at all”

that the proposed management measures would rebuild the bluefish stock, and took great comfort in the fact that Tony Wood, a biologist from the Northeast Fisheries Science Center, stated that bluefish didn’t show a strong stock/recruitment relationship; that is, the strength of any given year class of juvenile bluefish is not heavily dependent upon the size of the spawning stock.

However, that’s true of most fish, other than those such as sharks which take a many years to mature and produce relatively few young during their lifetimes.  One of the reference books that I keep on my shelf is Fisheries Ecology and Management, by Carl J. Walters and Steven J.D. Martell, which is a standard text used to teach fisheries issues.  It notes that

“most fish populations show recruitment relationships that are flat across a wide range of parental stock sizes (i.e., recruitment is independent of the parental stock size)”

and goes on to explain that

“Beverton and Holt [two noted biologists who, among other things, developed a stock assessment model that is still widely used today] (1957) examined early data on the relationship between parental spawning stock and subsequent recruitment, and data on the early mortality rates of juvenile fish.  They noted that the spawning stock is generally a very poor predictor of recruitment (recruitment being independent of parental abundance)…”

Thus, the lack of a strong stock/recruitment relationship in bluefish does not make bluefish exceptional in that regard, and does not suggest that regulating bluefish landings is will be any less likely to increase abundance than would regulating the landings of summer flounder or striped bass, both species that have historically benefitted from management efforts—and, in the case of striped bass, have suffered when managers failed to step in when they should have acted decisively to reduce fishing mortality.

To argue that management measures won’t help to restore the bluefish population is to contradict managers’ successes with a host of other species, and seems a completely fatuous approach to the issue, but Fote wasn’t, unfortunately, the only person at the table to voice such thoughts.

Even so, most of those in the room, and in particular the professionals on the Action Team and on Council and ASMFC staff, tried to keep everyone headed in the right direction.

The first topic addressed were the Goals and Objectives of the management plan, which the Action Team had completely reorganized and rewritten to reflect the state of today’s fishery and today’s fisheries science, which have changed substantially since the original Goals and Objectives were drafted back in the 1980s.  No one had any substantive comment on those, and they will probably appear in the draft Addendum, which will go out to the public at some point in the late summer or early fall, in the same form as they were presented at the meeting.

The next topic was the recreational vs. commercial allocation, and it was here that things went a bit sideways.

The Action Team had presented four basic approaches to setting the allocation between the commercial and recreational sectors.  The first, as must always be the case, was the no-action alternative, in which anglers would continue to receive 83 percent of the landings, while commercial fishermen received 17 percent.  After that, things got a bit complicated, largely due to the discards issue.

Discards are always a difficult thing to calculate.  Currently, for purposes of setting each year’s recreational harvest limit, managers assume that the size range of the fish released is identical to the size range of the fish taken home by anglers and measured as part of the Marine Recreational Information Program.  However, that is merely an assumption, which is completely unsupported by any data derived directly from the released fish.

In fact, there is data suggesting that released fish average larger than those that people take home.  

That finding shouldn’t seem strange to any recreational fishermen, as anglers are often quite vocal about preferring to eat smaller bluefish, which are generally thought to be less oily and “fishy” than larger individuals.  The biologists at the Northeast Fisheries Science Center believe that such data is the best scientific information available, and used it when preparing the operational stock assessment last year.

That data comes from American Littoral Society tagging records, and voluntary angler reporting in Rhode Island, Connecticut and New Jersey.  Unfortunately, it is limited in regional coverage, and doesn’t include areas where most of the releases take place, so it may or may not accurately reflect the size range of released bluefish along the entire coast.  It also failed to distinguish between fish released by surf and private boat anglers and those released by anglers fishing from for-hire vessels.

The Council and Management Board were thus asked to chose between a discard estimate based on an assumption, which was completely unsupported by any hard data, and a higher discard estimate that while based on data, was based on data that was incomplete and did not cover the entire coast.

In the end, they decided to adopt the former estimate, even though, by doing so, they may be substantially underestimating the volume of dead discards in the recreational fishery.

The managers were also asked to decide whether to base allocation on landings, as is currently done, or on catch (landings plus dead discards), which would have been some acknowledgement of the predominance of catch-and-release in the recreational fishery.  

The Action Team recommended that the Council and Management Board abandon the practice of basing the allocation on landings, noting that

“Basing allocation on catch between sectors using landings ignores the catch-and-release aspect of the fishery.”

For a while, it looked as if that would happen.  Steven Heins, who holds the obligatory Council seat from New York, and Hannah Hart, who I believe is a state fisheries manager for Florida and sits on the Management Board, included it in a motion listing alternatives to be removed from the Amendment.  

However, Adam Nowalsky, the Legislative Proxy from New Jersey and also a Council member, made a motion to amend that list of deletions to keep the landings option in the Amendment, arguing that landings might still be used to allocate bluefish between surf and private boat fishermen and the for-hire sector, and saying that

“Consistency in the use of data is extremely important.”

Both the Council and the Management Board went along.

It’s impossible not to note that “consistency in the use of data” could also have been maintained by deleting both the alternative that would use landings to determine the recreational/commercial allocation, and the alternative that would use landings to calculate any private angler/for-hire split, should that ever occur.  Such dual deletion would have been a win-win, that addressed the consistency issue while also recognizing “the catch and release aspect of the fishery.”

But things didn’t happen that way.

Fortunately, the issue is not dead.  The decision is merely delayed, so anyone with strong feelings about the issue ought to contact their Council and Management Board representatives prior to the August meeting.

A related issue, discussed later in the session, was that of transferring unlanded recreational quota to the commercial sector.  

While some anglers speaking at the scoping hearings, including myself, called for managing for maximized abundance rather than maximized landings, and so asked that such transfers no longer occur, the Action Team did not include that suggestion among the possible alternatives.  Managers will only choose between maintaining the status quo, creating a cap on such transfers that is expressed as a percentage of the allowable biological catch (and notably not of the significantly lower recreational harvest limit or annual catch target), or so-called “bi-directional” transfers, in which unused commercial quota could be shifted to the recreational sector.

Interstate transfer of commercial quota also got some attention, as a proposal for regional management, suggested earlier by Florida’s representatives on the Management Board, garnered debate.  A motion to delete it, in favor of establishing minimum quota allocations for every state on the coast, was made by Massachusetts fishery manager Nicola Meserve and Earl Gwin, who holds the obligatory Council seat from Maryland.  However, a substitute motion to retain both the Florida proposal and the minimum quota was made and ultimately adopted by both management bodies.

The assembled managers also had to decide on alternatives establishing the rebuilding timelines.  

Possible alternatives ranged from a “constant harvest” strategy that set a low annual catch limit and would theoretically rebuild the stock within four years, a “constant fishing mortality” strategy that should rebuild the stock within the required ten years, and another constant harvest strategy that seemed to set an unrealistically high annual catch limit, but would still supposedly rebuild the stock within ten years. 

Both the Council and Management Board voted to remove both constant harvest strategies, leaving alternatives that would rebuild the stock, depending on the option ultimately chosen, in between five and ten years.

Finally, the Council and Management Board addressed the issue of sector separation; that is, setting up separate annual catch limits, sub-annual catch limits or recreational harvest limits for the surf/private boat and for-hire sectors.

The Action Team recommended that the sector separation proposals be removed from the Amendment, saying

“The [Fishery Management Action Team] reached consensus that for-hire sector separation should be removed from the amendment.  The FMAT expressed several concerns with pursuing this issue further.  Foremost, the FMAT thought that developing for-hire sector allocations is such a large task that it could significantly delay the amendment timeline.  FMAT members were concerned about the reliability of MRIP data at the mode level when generating allocations.  MRIP data with high PSE values poses additional issues for catch accounting and accountability.  There is also the difficulty of determining how accountability measures are implemented between modes.  Lastly, according to MRIP data, the for-hire sector is a relatively small portion of the recreational fishery and for-hire fishermen may draw issue with the resultant small allocation.”

Despite such recommendation, Management Board representatives from southern New England, as well as the National Marine Fisheries Service, seemed interested in developing sector separation alternatives.  Other representatives from elsewhere on the coast were adamantly opposed to the idea.  In the end, sector separation alternatives were retained for the time being, although the issue will be reconsidered in August.

And that’s about where the Bluefish Reallocation and Rebuilding Amendment stands today.  There were a few other issues discussed, which I didn’t mention as they would have little to no impact on the resource itself but would take quite a few words to explain. 

While this week’s meeting moved the process forward just a little, most issues remain up in the air. 

Unfortunately, we’ve already lost the most important point; the Council and Management Board have effectively vetoed the concept of managing bluefish for abundance instead of landings; inter-sector quotas transfers will remain alive in some form, assuring that bluefish will continue to be managed for dead fish on the dock, as opposed to live fish in the water. 

At the same time, the first step in the right direction, allocation by catch, rather than by landings, to better acknowledge the catch-and-release fishery, remains alive.  It was the preferred position of the Action Team, and can still be adopted in the final Amendment, provided that concerned anglers keep pressure on their representatives and convince them to do the right thing.

Perhaps that best defines where we really are right now:  Still early in the debate, with real opportunities to influence and improve bluefish management before the draft Amendment is finalized, during the public comment period for that draft, and even as part of the final debate, when public comment is again considered, and the Council and Management Board vote on the ultimate shape of the Amendment that is forwarded to the National Marine Fisheries Service for approval, something that will probably happen in September 2021.