Your comments on an emerging large-scale fishery on a forage source for large pelagics are important.
By Capt. John McMurray
If you fish offshore of 20 fathoms at all, you’ve probably seen them. Schools of smallish “chub” mackerel blitzing rain bait. Throw a small metal lure at them, and you’ll likely catch one. But wait around long enough and you might see them suddenly spray out of the water as some large predator comes up from the deep to crash their party. I’ve been there. It’s pretty darn cool.
Chub have been inexplicably ubiquitous during the last eight years or so. As such they’ve driven and continue to drive time and area bites, primary for bluefin tuna, but also for yellowfin, mahi and billfish.
Yet, with their recent abundance, a large-scale high-volume/low-value commercial fishery for them sprang up rather quickly. A handful of squid boats went from catching close to none in 2008 to catching over 5-million pounds in 2013. That’s an extraordinary escalation in a very short amount of time.
A few years ago, during the development of the Mid Atlantic Fishery Management Council’s Unmanaged Forage Amendment, the Council recognized the rapidly escalating fishery and eventually capped it at the most recent 3-year average (2.86 million-pound annual landings limit).
The intent was to prevent further escalation until the Council could figure out how to manage it. That cap will expire December 31, 2020.
Last year the Mid Atlantic Fishery Management Council initiated a Chub Mackerel Amendment, a first step to manage the fishery when the current cap expires.
The purpose of this amendment is to “consider” adding Atlantic chub mackerel to the Atlantic Mackerel, Squids, and Butterfish Fishery Management Plan. The amendment will take into account potential catch limits and other conservation and management measures to achieve “optimum yield” for the fishery. The Council recently voted out a public hearing document.
While we struggle to understand exactly why, the Council’s Science and Statistical Committee recommended an “Acceptable Biological Catch” of 5.07 million pounds based on nothing more than the fact that was the max amount industry has yet to harvest in a year. That’s a 77% increase from the 2.86 million-pound cap that exists now.
The intent seems to be to let industry fish at that level, so the Council can collect the data and develop the science to manage the fishery. Industry seemed to be arguing for 10-million pounds, so they could fish hard on chub mackerel when they are available, throwing out the usual arguments such as “there are plenty of fish around”, “fishing has very little if any impact”, “very little predator/prey data exists, so chub aren’t really important to tuna/billfish etc.”.
It is true the Council has very little data on chub, but those of us who spend time offshore of 20 fathoms know that these fish are indeed forage for valuable commercial and recreational species. With an absence of perfect information, and chub mackerel’s important role as forage, the Council should move forward with a precautionary approach.
The public information document actually includes an alternative for doing just that—Alternative 3.B: OY is less than ABC—puts the Council on the scientifically supported, precautionary approach to manage chub mackerel.
ALL of us should be advocating for that alternative.
Without a doubt, offshore anglers have benefited from an abundance of chub mackerel, particularly the economically valuable recreational, charter, and tournament fisheries. Because of its ecological and economic value, any significant increase in commercial fishing for chub mackerel would NOT be good for the sport fishing community. Here’s what you can do:
Attend a public hearing to make your voice heard:
- Virginia Beach, VA. December 3, 2018, 6:00 – 7:30 pm. Hilton Garden Inn Virginia Beach Oceanfront. 3315 Atlantic Avenue, Virginia Beach, VA 23451.
- Berlin, MD. December 4, 2018, 6:00 – 7:30 pm. Worcester County Library – Ocean Pines Branch. 11107 Cathell Road, Berlin, MD 21811.
- Narragansett, RI. December 17, 2018, 6:00 – 7:30 pm. URI Bay Campus Corless Auditorium. 215 South Ferry Road, Narragansett, RI 02882.
- Cape May, NJ. December 18, 2018, 6:00 – 7:30 pm. Congress Hall Hotel. 200 Congress Place, Cape May, NJ 08204.
- Webinar. January 14, 2019, 6:00 – 7:30 pm. Connection information is available at http://www.mafmc.org/council-events/2019/chub-mackerel-amendment-public-hearing-5-webinar.
Submit written comments by January 18, 2019 using the subject line “Chub Mackerel Comments”:
- Email to Julia Beaty, Fishery Management Specialist, at firstname.lastname@example.org.
- Online at: http://www.mafmc.org/comments/chub-mackerel-amendment.
- Mail to Dr. Chris Moore, Executive Director, Mid-Atlantic Fishery Management Council, 800 North State Street, Suite 201, Dover, DE, 19901.
Contact your Council Members (http://www.mafmc.org/members) using the below talking points and urge them to consider chub mackerel’s role in the ecosystem, the multiple users of this resource and their economic contributions.
- I/We support the Mid-Atlantic Fishery Management Council managing Atlantic chub mackerel as a stock in the Atlantic Mackerel, Squids, and Butterfish Fishery Management Plan (MSB FMP).
- Until sufficient scientific information is available to provide a full understanding of the role chub mackerel play in the ecosystem, I/We do not support increasing catch on chub mackerel.
- I urge the Council to consider the multiple users, particularly offshore anglers, and manage chub mackerel to maintain its role as forage for large pelagics. To ensure sustainability, we need to leave enough fish in the water to maintain healthy populations of chub mackerel and their predators.
- Current data limitations do not forgo the responsibility of managers to consider the role of chub mackerel as forage, and the economic, social and ecosystem impacts when setting catch limits.
- In the absence of clear data, setting lower catch limits to maintain a healthy and abundant population is critical to our shared marine ecosystems.
- The Council should require that optimum yield be set less than the Acceptable Biological Catch for all forage species including chub mackerel.
- The Council should select “Alternative Set 3.B: OY Is Less Than ABC” and adopt a value for Optimum Yield that is less than the ABC recommended by the SSC for 2021-2023.
- Set 3.B is the only alternative that accounts for chub mackerel’s role in the ecosystem.
- Setting Optimum Yield less than the Acceptable Biological Catch provides managers the flexibility to consider additional biological, ecological and economic factors when setting catch limits for chub mackerel.
- With an absence of perfect information, setting Optimum Yield less than the ABC— Set 3.B—puts MAFMC on the scientifically supported, precautionary approach to management of chub mackerel.
- For all forage species, setting Optimum Yield less than Acceptable Biological Catch is just common sense.
- Managing chub mackerel where Optimum Yield is less than the recommended Acceptable Biological Catch allows for fair access to a public resource for commercial fishing, sportfishing, gamefish and other predators, as well as the structure and function of the marine ecosystem at-large.
Atlantic Chub Mackerel template letter | winter 2018
Please use the following template to help you craft your letter and/or email. The text below is to inspire you to share your own story. Where possible, please adjust this language to reflect your own voice, perspective, and experience—personal, compelling stories make the most effective letters and/or emails.
How to Submit Your Letter
1) email your letter to Julia Beaty at email@example.com using the subject line “Chub Mackerel Comments”; or, 2) submit your letter by copying/pasting it into the online comment portal here: http://www.mafmc.org/comments/chub-mackerel-amendment.
Subject Line: Chub Mackerel Comments
Dr. Chris Moore, Executive Director
Mid-Atlantic Fishery Management Council
800 North State Street, Suite 201
Dover, DE, 19901
Dear Dr. Moore,
As a [Insert fisherman/woman, ocean enthusiast, seafood consumer; or on behalf of XYZ organization, etc.], I am writing to ask you to support protections for chub mackerel, specifically managing them as a stock in the MSB FMP, adopting the SSC’s recommended ABC of 2,300 mt for 2021-2023, and setting OY less than the SSC’s recommended ABC per Alternative Set 3.B.
Chub mackerel are an essential part of the ocean ecosystem, providing food for recreationally and commercially important fish like marlins, tunas, billfish, mahi-mahi and sharks.
Industrial demand has increased— risking commercial and recreational fisheries, whose target species prey on chub mackerel. To ensure a healthy and abundant chub mackerel population in the future, enough fish need to be left in the water so that they can fulfill their ecological role.
The Council has an opportunity to get chub mackerel management right from the beginning.
While data limitations exist, this does not forgo the responsibility of managers to consider the role chub mackerel play as forage, and the economic, social and ecosystem impacts when setting catch limits.
In the absence of clear data, setting lower catch limits to maintain a healthy and abundant population is critical to the longevity of our shared marine resources and the coastal economies that depend on them.
Adopting the SSC’s recommended ABC and setting OY less than the ABC to better account for chub mackerel’s role as forage puts the Council on the right path to managing this public resource.
Thank you for the opportunity to comment on this important issue.
Sincerely,[Insert Name] [Insert Affiliation if appropriate] [Insert City, State] [Insert Email Address and Phone Number]