[ZuluHotel]

FYI, fellas, here's a letter that was distributed at the Tuesday ASMFC meeting down in VA. I think the big point that the dogfish situation highlights is that species-by-species management fails to adequately recognize any species' place in the overall ecosystem. As a few guys pointed out, doggies are filling a gap left by all the other predators that are being fished down to low levels. Simply assuming that if you remove man from the ecosytem (by eliminating fishing effort) that it will return to some utopian state is asinine. Sometimes, at least once man is involved as THE apex predator, man needs to do some "pruning" to restore the balance. The problem is that much of what managers know about dogs is based on a very limited pool of science--primarily spring and fall two-week trawl surveys. Was the "problem" that led to the end of comm. fishery really a problem, or was it a perceived problem that existed mainly on paper? I dunno.

Anyway, here's the letter. Would be curious to hear some more perspectives on this (not the letter, the fisheries issue).

13 August 2006

Ruth Christiansen
Spiny Dogfish FMP Coordinator
Atlantic States Marine Fisheries Commission
1444 Eye Street, NW
Washington, DC 20005

To The Members Of The Spiny Dogfish Management Board:

(To be read at the August 15 ASMFC Meeting by Capt. Tom DePersia or Rich Ruais)

I regret that scheduling issues prevented me from attending this hearing, but hope these comments will be taken seriously nonetheless. It has unfortunately been the trend with dogfish—more so than with any other species—that managers have out-and-out ignored any and all input from the public while crafting regulations, and I know I’m not alone when I say I have little faith ASMFC will view this as anything more than some additional “anecdotal” information.

In my capacity as Editor of The Fisherman, New England Edition, I have ample opportunity to sample public sentiments about all regulations affecting recreational, and to a large extent, commercial, fishing. The overwhelming view on dogfish at this point is that they are becoming a very serious threat to local marine ecosystems. Yes, dogfish are a “nuisance” to those targeting fluke, striped bass, bluefish, bluefin tuna, winter flounder, cod, pollock, haddock, scup, sea bass and a variety of other “important” recreational species. But our concern runs much deeper than squawking about inconvenience (as all recreational comment about dogfish has been characterized by managers to date).

Realizing that this is anecdotal, please consider the following (I have heard it from countless hundreds of party and charter boat skippers, many of whom have spent the last 20 to 30 years earning a living on the water): Since the enormous cuts in commercial fishing effort, dogfish are appearing in unbelievable numbers in many areas where they’ve never been encountered before. During the same timeframe, many important historical fishing grounds have been rendered unfishable by massive bodies of dogfish. Once dogfish infiltrate a piece of bottom, there’s no room, literally, for other species to gain a foothold. This has been documented in hundreds of historically important fishing areas.

The situation has gone well past mere “interaction problems,” a phrase that numerous managers have used, rather smugly, to sum up recreational and commercial concerns about dogfish. Whether or not the science has caught up to the reality at this point, take it from those on the water: Dogfish are a major threat to rebuilding efforts for every other commercially and recreationally important species. It appears NOAA and ASMFC are hell-bent on rebuilding a species with no current economic value at the expense of all other fish and all fishermen.

To that end, on behalf of 100,000 weekly readers of this magazine, as well as hundreds of charter and party boat captains (who cannot sacrifice their livelihoods to attend a daytime meeting 500 miles from where the issue is most immediate), I support Paul Diodati’s emergency proposal to establish a limited directed fishery for spiny dogfish (with the possible caveat that we believe the current, real-world biomass of dogfish could support more than the modest 6,000,000-pound quota Mr. Diodati has proposed). The recreational and commercial communities are in full agreement that something must be done immediately to curb the impending dogfish disaster.

This situation is a prime opportunity for ASMFC to pick up the ball on ecosystem-based fisheries management. A vote for status quo dogfish management is a vote for the old-model species-in-the-void management that has led us to this sorry chapter in the history of our fisheries. I hope the Commission will have the forward vision to endorse Diodati’s proposal and, by implication, a more ecologically sensible management approach.

Sincerely,





Zach Harvey,
Managing Editor,
The Fisherman Magazine, New England Edition