Commenter:
Phil Zalesak, Southern Maryland Recreational Fishing Organization
Petition for Rule Making regarding the Management of the Atlantic Menhaden Reduction Fishery
I fully support the petition for the following reasons:
There is no science supporting the allocation to Virginia of over 75% of the total allowable catch of Atlantic menhaden for the entire Atlantic Coast.
There is science documenting the direct relationship of Striped Bass mortality rate and Atlantic menhaden mortality rate (overharvesting) in a localized area. Localized depletion of Atlantic menhaden has been an issue with the ASMFC for over 20 years, explicitly defined in 2009, and quantified in 2019.
There is empirical data documenting the poor performance for six consecutive years of Striped Bass juvenile young-of-year index in the Maryland Chesapeake Bay. The recent index has been running from 1.0 to 2.0 compared to long time average index of 11.0.
The commercial value of Striped Bass is 2 to 3 times the commercial value of Atlantic menhaden. In 2023 the Potomac Rive Striped Bass dock revenue was $1.25 million dollars and the Atlantic menhaden revenue was $0.43 million dollars. Further, the per pound revenue value of Striped Bass was $3.36 versus $.21 per pound for Atlantic menhaden. Striped Bass was 16 times more valuable than Atlantic menhaden on a per pound basis.
There is NOAA empirical data documenting an 80% decline in the recreational harvest of Striped Bass in Maryland waters since 2016. In 2016, the GDP associated with the recreational harvest was over $800 million dollars and over 10,000 jobs. An 80% decline in recreational harvest of Striped Bass has cost the State of Maryland millions of dollars annually as well as thousands of jobs since 2016,
Finally, decades of science and empirical data document the decline of osprey which nest in the main stem of the Chesapeake Bay. Their reproductive rate needs to be 1.15. It's currently 0.6. The osprey species is currently not sustainable in the main stem of the Chesapeake Bay.