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The Mid-Atlantic Unmanaged Forage Omnibus Amendment

A landmark forage fish protection action takes shape

In August of 2016, the Mid-Atlantic Fishery Management Council put forward what may be one of the most forward-thinking ecosystem protection actions we’ve seen on the East Coast.

To put it simply, the Council’s Unmanaged Forage Omnibus Amendment would put a full stop on any new/potential industrial-scale fishery in the region’s federal waters for forage fish (sandeels, silversides, bay anchovies, halfbeaks, sardines, krill, currently unmanaged mackerels, herrings and squids, and a bunch of other things the Council determined to be important forage, and/or subject to large-scale extraction), at least until any such fishery could be scientifically proven to be sustainable. Not just sustainable from a harvest perspective, but sustainable from an ecosystem one. That means ensuring enough remain in the water to satisfy the needs of predators like striped bass, bluefish, tunas, billfish, whales, etc.

This is an enormously significant action because it protects all these species — the lower levels of the food-chain — from low-value/high-volume fisheries (i.e. those fisheries that are worth pennies on the pound, and thus need to be caught in extremely high volume for them to be profitable).

Given the dynamics of current directed fisheries, a lot of which are either declining or facing increasingly constraining regulations, it is very likely that industry was eyeing new low-value/high-volume fisheries for things like sandeel, etc. In fact, there were rumors abound of commercial fishermen in New England gearing up for such fisheries.

Such unmanaged, directed, high-volume/low-value fisheries on bait fish would be devastating to so many recreational fisheries. Anyone who’s spent more than a few days on the water knows, if you want to find striped bass, bluefish, etc., or tuna, mahi and bill fish, you’ve got to first find the bait concentrations. It is unequivocally true that spatial and temporal forage fish aggregations drive angling opportunity. Removing concentrations from any given area would kill such opportunity.

So this is a critical action, not just for the sustainability of the recreational fishing industry but to the sustainability of entire marine ecosystems.

Chub Mackerel Discovery

The intent of the Council all along, when developing the Unmanaged Forage Omnibus Amendment, was to “freeze the footprint.” In other words, prevent new large-scale fisheries on critically important bait-fish from developing without science.

When staff was trying to determine what fisheries currently existed, the Council discovered a new, unmanaged, large-scale fishery on chub mackerel – a small pelagic that is an important forage component for large pelagics (tunas, sharks and billfish).

Large chub mackerel aggregations, at least in the numbers we’ve seen them in recent years, is a relatively new occurrence in the mid-Atlantic region. And so, the squid and mackerel fleet had been fishing on them pretty hard.

Once the landing records were reviewed, the Council saw that industry went from catching almost none in 2008 to catching over 5 million pounds in 2013. This is an extraordinary escalation in a very short amount of time. Essentially, a 5-million-pound large-scale fishery for a forage species, with no science or management in place, had developed right under the Council’s nose, with hardly anyone knowing about it. This alone is a good case for the need for the Council’s Unmanaged Forage action.

While the Council’s original intent was to include chub mackerel in the list of protected unmanaged forage, because a fishery had already existed, it instead voted to cap the chub fishery at a 3-year landing average (2.86 million pounds a year) for three years (from 2018 until 2021), as part of the Unmanaged Forage Amendment. The intent was for the Council to develop a management strategy in the meantime.

And so, the Council is currently developing an amendment to the Squid, Mackerel, Butterfish Fishery Management Plan to add chub as a stock in that fishery, as it is generally the mackerel and squid fisheries that have targeted chub recently.

Read more on this here: (Link coming).

Where we are now

In March of 2017, NOAA Fisheries submitted the Unmanaged Forage Omnibus Amendment to the Secretary of Commerce for review and approval. The proposed rule was published late in April.

While It makes clear that they will likely approve of all the Council’s recommendations, it is also clear it will likely reject the inclusion of bullet mackerel and frigate mackerel in the amendment noting that these species don’t quite qualify as “forage” due their large size, high trophic level, and the lack of a link between frigate mackerel and the Council managed species.

It would be a shame to lose these species, as they are important bait-fish, particularly for tuna and billfish, and we should support their inclusion in our comments. But if we do lose them, this is still a huge win for ecosystems and recreational fisheries.

NOAA fisheries is currently requesting comments

Anglers should be letting NOAA Fisheries know they support the Council’s Unmanaged Forage Action, but we should also mention that frigate and bullet mackerel warrant inclusion, because they are indeed “bait” for a variety of specie, and are in need of protection from large-scale/low-value fisheries.

Comments must be received on or before May 30, 2017.

They can be submitted via the Federal e-Rulemaking Portal: Mid-Atlantic Forage Species Omnibus Amendment. Click the “Comment Now!” icon. You can also mail: John K. Bullard, Regional Administrator, NMFS, Greater Atlantic Regional Fisheries Office, 55 Great Republic Drive, Gloucester, MA 01930. Mark the outside of the envelope, “Comments on Mid-Atlantic Forage NOA.”

Prior Unmanaged Forage Amendment Blogs:

http://conservefish.org/2016/08/12/epic-win-marine-ecosystems

http://conservefish.org/2016/08/05/false-albacore-chub-bullets-everything-else

http://conservefish.org/2016/05/12/because-its-all-about-the-bait

http://conservefish.org/2016/04/05/false-albacore-is-bait

http://conservefish.org/2015/11/04/holy-mackerel

http://conservefish.org/2015/09/11/of-sandeels-and-tuna-we-need-your-help-getting-ahead-of-the-curve

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2 Comments

  1. Pingback/Trackback
    Apr 26, 2017 at 11:50 am

    The Mid-Atlantic Unmanaged Forage Omnibus Amendment | Fly Life Magazine

  2. Pingback/Trackback
    Apr 28, 2017 at 6:08 pm

    Chub Mackerel – Fissues