The Mid Atlantic Council is currently accepting comments until Oct 2 on a proposed action that will hopefully prevent new fisheries for currently unmanaged forage such as silversides, sand eels & krill from developed before sustainability is proven.

http://www.mafmc.org/comments/unmanaged-forage

Interestingly both the Menhaden Reduction Industry & the Atlantic Herring Mid Water Trawl Fleets are opposed to these protections. MSBA urges all anglers to submit comments via the link below. We offer the following set of positions for you to consider when making your personal comments. RE: Unmanaged Forage Scoping comments:

Dear Dr. Moore;

I am a recreational angler from New England that fishes for multiple species that are managed by the MAFMC (bluefish, black sea bass, mackerel etc.). I am concerned that reductions of quota in existing commercial fisheries will lead to development of new commercial fisheries that target currently unmanaged forage species. Fishing down the food chain is a very real threat to ecosystems world wide. I support the MAFMC effort to be proactive and address the issue of protecting unmanaged forage species.

Additionally, I feel this action is a logical next step in the multiple year process of moving away from single species management and beginning the transition to ecosystem based management.

The following are my comments based on the 8 questions contained in the scoping document:

A: I support Action A (amend one or more of the Council’s existing FMPs to include provisions for unmanaged forage species.)

B: I support Provision A (identify forage species as ecosystem component species and prohibit their directed harvest)

C: I agree with the 8 unmanaged forage species included in the document (sandeel/sand lance, bay anchovy, striped anchovy, silver anchovy, round herring, thread herring and silverside). Additionally, I would like to see half beaks, all species of krill & all species of cinder worms also included.

D: This action should include all harvest of currently unmanaged forage species in federal waters. Existing state waters small-scale fisheries such as the raking by hand of sand lance on New England beaches should not be included.

E: Although I feel this action should be a national regulation, I do not think that is a realistic option at this time. I support the MAFMC adopting this action in all waters under MAFMC jurisdiction.


F: The MAFMC should include within this action some language that prevents expansion of any ongoing fishery for the species covered that may not be known at this time. In todays world no fishery in federal waters should be allowed without a management plan that ensures sustainability.

G: New forage fisheries should be allowed if proven to be sustainable and only when enough information is available to promote ecosystem sustainability. The MAFMC should use the “EFP” permit system already being used by the Pacific Council to deal with a similar situation.

H: I am not a scientist, but I know that if there is enough information for a fishery to develop then NMFS science centers should be able to model and provide management advice to ensure sustainability of the target species. If the species cannot be modeled then the fishery should not be allowed due to a lack of information. Sustainable ecosystems are a key to all of our fisheries and without abundant forage all fisheries collapse.

Thank You for the opportunity to proved these comments.

Sincerely,