Fishery Management Plan Coordinator
Atlantic States Marine Fisheries Commission
1050 North Highland Street, Suite 200A-N
Arlington, Virginia 22201
Subject: Menhaden PID
January 4, 2017
Dear Ms. Ware,
I am writing in response to the Atlantic States Marine Fisheries Commission Public Information Document (PID), for Amendment 3 to the Interstate Fisheries Management Plan for Atlantic Menhaden. The following comments comprise the considered opinion of the Board of Directors of Save the Great South Bay, Inc (STGSB). We are a registered 501c(3) organization that is dedicated to the bay’s restoration for the benefit of all. We have nearly 11,000 in our facebook group as of Jan 1, 2017. Our members are Long Islanders past and present: scientists, baymen, fishermen, organic gardeners, lawn care advocates, politicians, and public officials, teachers and professors, local civic leaders and board members from numerous environmental and educational organizations, and concerned citizens from all walks of life. As an organization we advocate for the return of a healthy Great South Bay for the benefit of future generations.
STGSB is a member organization of the Citizen Advisory Committee to the South Shore Estuary Reserve Council (LISSER). LISSER is one of the several legislatively created state and regional estuary reserves that stretch from the Hudson/Raritan Bay Estuary to the Long Island Sound and beyond. All of the Reserves face similar challenges to those besetting the Great South Bay. We believe that the return of large menhaden populations are key to attaining our ends. Our views on the above proposed amendment are:
- Opposition to any near-term increases in menhaden catch limits.
- Support for the continued use of Ecosystem Based Fishery Management (Pikitch et al, 2004, “Ecosystem Based Fishery Management”), using ecological reference points (ERP), to inform the management of menhaden stocks.
- Endorsement the findings and recommendations of the Lenfest Forage Fish Task Force (Pikitch et. al., 2012 “Little Fish Big Impact”).
Our reasons for holding these views, and for writing to you today, are:
- Increases in menhaden populations have been observed throughout Long Island’s waters. We see these increases as the combination of natural population fluctuations and reduced harvest limits set by the Commission We understand that Commission policy derives from the recommendations of the Lenfest Forage Fish Task Force.
- Although largely anecdotal at this early juncture, the increase in menhaden numbers has been a positive for fisheries, tourism and the environment. We believe that as time passes and people begin to register and understand the changes being wrought, the efficacy of the policy direction will become clear, and public support for commission policy will grow. More time and data is needed to come to a general understanding of the impact of the new policy.
- The dramatic increase in sightings of whales to our near-shore ocean waters (we’ve all seen the photos and videos of these massive creatures feasting on menhaden) is spectacular. In our opinion, this resurgence is enough of a benefit to justify the continuation of the policy direction taken by the Commission. The long-term impact of the increased population of menhaden is difficult to quantify, but it is having a positive effect on tourism and the quality of life for Long Islanders.
- Predator/prey relationships: Menhaden’s importance as food for predators such as striped bass, bluefish, weakfish, dolphins, seals, baleen whales and various shore birds cannot be overstated. The policy of using ERPs and the findings of the Lenfest-forage-fish-task-force to manage the fishery takes these relationships into account. We support this course of action.
- Lenfest Forage Fish Task Force: The economic value of the fishery is enormous, and its sustainability is fragile. This value must be protected. As explained by the work of Lenfest Forage Fish Task Force, the forage fish populations are subject to unique population dynamics, including predation by a wide range of predators, large natural population fluctuations and easy catch-ability. This makes forage fish especially vulnerable to a population crash if not managed with a margin of safety in mind. We have confidence in these findings.
- We also believe that it will take some considerable time to see a restoration of healthy and sustainable menhaden populations across the broadest possible range.
- Menhaden are important for water quality. Their filter feeding is an important mechanism for removing algae and improving the general clarity and quality of waters. Decimated menhaden populations contribute nothing to water quality, clarity, and productivity, and it may take some time to fully appreciate the impact that larger numbers of menhaden will have on water quality.
- The use of menhaden as bait is a traditional and ongoing activity. Fewer menhaden being harvested by the Omega Protein Corporation, for example, leaves more menhaden for the rest of the fishing community. Forage fish are a common resource that should be managed for the enjoyment and use of the widest range of interested parties.
- The use of menhaden as fertilizer and feed for gardening and farming can serve to reduce the use of chemical fertilizers, which contaminate the bays and sources of drinking water. This practice has not been common due to the small available population of menhaden as well as the availability of cheap, quick-release petroleum based fertilizers. Ample science demonstrates that the use of chemical fertilizers needs to be curtailed for the sake of water quality. Tthe use of menhaden in gardens as fertilizer is one of a range of beneficial substitutes.
Too often have we seen entire populations of animals decimated because of reckless harvesting by humans. With menhaden, there is still an opportunity to manage the resource correctly for the benefit of humans, other predators and the ecosystem in which they exist. In advocating for the sensible management of menhaden, we are seek to protect ecosystems and waterways, which impact quality-of-life. This is a key forage fish species, the mismanagement of which can lead to a disaster for water quality, the fishing industry, tourism, and all other ecosystem services throughout the South Shore Estuary and beyond.
A generation or more of Long Islanders have grown up without the knowledge of what clean bay water looks like, what a real bluefish blitz on a menhaden school looks like or how a gull or osprey captures its food. Too few Islanders have seen a whale breaching, or a school of dolphins hunting, from the beach. Fewer still have buried menhaden next to the plants as fertilizer. Gone are the days of oysters and of oystermen, clammers and clams, winter flounder and eels, as well as much of the herring run. Weakfish and striped bass populations waver on the brink, and Atlantic cod populations are still recovering from overfishing. We’re losing our maritime ways, and our connection to the waters. Let’s change that. We ask that you continue to protect the menhaden, in understanding of the critical inter-dependency of which these fish play a vital role.
John J. Hall
Director, for the Board of Directors,
Save the Great South Bay
132 Clyde Street
W. Sayville NY 11796
Pikitch, Ellen K, C. Santora, E. A. Babcock, A. Bakun, R. Bonfil, D. O. Conover, P, and others Dayton et al. “Ecosystem-based fishery management.” Science 305, no. 5682 (2004): 346-347. Retrieved from: http://www.nmfs.noaa.gov/pr/sars/improvement/pdfs/science.pdf
Pikitch, Ellen, Patricia Dee Boersma, I. L. Boyd, D. O. Conover, Philippe Cury, Timothy Essington, S. S. Heppell et al. “Little fish, big impact: managing a crucial link in ocean food webs.” Lenfest Ocean Program, Washington, DC 108 (2012). Retrieved from: