Ladies and Gentlemen,
The deadline for making official public comment to the MFC that will be included in each commissioner's briefing book is fast approaching. Please take the time to write a letter asking the commission to take action at the May meeting on behalf of the CSMA striped bass. Below is the letter that I sent this morning. Please use any information you'd like that will assist you in your letter.
Here is a link to 11 files containing pertinent research-
http://onedrive.live.com/redir?resid=6A19FBB1D4C5EFB1!199&authkey=!ABUMrZC1zSHfgQw&ithint=folder%2c
Please do this. We clearly saw that public support and action helped during the southern flounder supplement process.
The squeaky wheel gets the grease.
This issue is a no-brainer from both biological and economic standpoints. The new Director just needs to understand the issue, which will not happen internally given that old staff is still piloting the ship with the purpose of self-preservation. Some influential members of senior staff need the problems of competing user groups, overfished stocks, ESA gill net issues and management of unsustainable gears that are depleting our resources and destroying our habitats...it's called job security.
Here is an easy list of email addresses that you can just cut&paste-
samjcorbett3@gmail.com; captgorgesmfc@gmail.com; captjoemfc@yahoo.com; sobxl1@gmail.com; rds.mfc@gmail.com; janetrosemfc@gmail.com; amikewicker@gmail.com; awillis.mfc@gmail.com; donald.vandervaart@ncdenr.gov; john.c.evans@ncdenr.gov; John.Bell@ncleg.net; Jimmy.Dixon@ncleg.net; braxton.davis@ncdenr.gov; nancy.fish@ncdenr.gov
May 5th, 2016
North Carolina Marine Fisheries Commission
3441 Arendell Street
Morehead City, NC 28557
Subject: Public Comment on behalf of CSMA Striped Bass for the May-2016 MFC Meeting
Dear Commissioners,
The attempt to re-establish a spawning stock biomass of striped bass in the Central Southern Management Area (CSMA) is failing. Long-term data supported by recent genetics work shows that failure has been caused by commercial overfishing. The North Carolina Wildlife Resources Commission in partnership with the USFWS and academia understands this fishery quite well and has been diligently working towards restoration goals. Interagency communications show that the NCDMF has not come to the table in good-faith to discuss much needed and urgent management changes.
Recruitment overfishing by the commercial fishing sector has led to a truncated age structure preventing the establishment of a spawning stock biomass that can produce dominant year-classes. Mature dominant year classes are needed to increase egg deposition on the spawning grounds. Increasing the spawning stock biomass and advancing the female age-structure to older fecund individuals should lead to improved wild recruitment, which is the goal of Amendment 1 to the North Carolina Estuarine Striped Bass Fishery Management Plan as stated on page 1.
The goals of Amendment 1 to the North Carolina Estuarine Striped Bass FMP are to achieve sustainable harvest through science based decision-making processes that conserve adequate spawning stock, provide and maintain a broad age structure, and protect the integrity of critical habitats.
Exploitation in this fishery exceeds the CSMA management target and threshold mandated by the FMP. The commercial fishing sector is harvesting 70% of all striped bass in the CSMA. It is estimated that when mortality from unreported landings, illegal harvest, dead discards from active fishing gears, and mortality from ghost commercial fishing gears are included along with reported commercial trip ticket landings that the commercial fishing sector is responsible for 85% or more of all striped bass mortality in the CSMA.
Genetic sampling studies show that at least 93% of the river stocks are from hatchery origin. There is a high probability that the remaining 7% of the stock is of hatchery origin that was stocked prior to 2010 when genetic parentage based marking begun. If true, then the CSMA has become almost entirely a "put-grow-take" fishery. Stocking was never intended to enable a fishery in which the commercial sector takes 85% of the fish.
The original purpose of stocking the CSMA can be found on page 301 of the FMP.
Specific objectives for stocking striped bass into coastal river systems include attempts to increase spawning stock abundance while promoting self-sustaining population levels appropriate for various habitats and ecosystems.
Also on page 301 of the FMP, you can see that stocking was not thought to be of significant importance.
Results suggested striped bass stocked in the Neuse and Tar rivers appeared to contribute little to the spawning stocks in these systems.
Through genetic Parentage Based Sampling, we now know that the importance of stocking the CSMA has changed significantly. Genetic sampling has proven that stocking is not supplementing an existing wild stock, but is the stock. Biologists believe that this fishery is close to 100% stocked origin. Stocking is crucial. If stocking stops, this fishery will completely disappear within five to six years with a striped bass in the CSMA becoming a rarity.
I, along with others, have been requesting for over a year that the NCMFC/NCDMF address the glaring mortality level that violates the management goals of the FMP. It is now clear that the importance of hatchery stocked fish is a complete paradigm shift undermining the tenets of Amendment 1 to the North Carolina Estuarine Striped Bass Fishery Management Plan.
Action on behalf of the resource is urgently needed.
The FMP gives proclamation authority to the DMF Director to address the urgent biological needs of this fishery. On page 9, this authority is clearly detailed.
“It should also be noted that under the provisions of this FMP the NCDMF Director and the NCWRC Chief of Inland Fisheries will maintain the ability to establish seasons, authorize or restrict fishing methods and gear, limit quantities taken or possessed, and restrict fishing areas as deemed necessary to maintain a sustainable harvest.”
The WRC voted to take action in Inland waters. I ask that this commission by motion and vote require the DMF Director to take similar action in Joint and Coastal waters including closing the commercial fishery and requiring full time attendance in other gill net fisheries in order to reduce mortality from regulatory discards. These actions should remain in effect until completion of the next amendment process.
The above request is based solely on the biological needs of this important fishery. The economic need is just as compelling. State and federal agencies have been spending in excess of $600,000 annually to stock the Neuse and Tar River systems. The commercial harvest of these stocked fish has an annual value of approximately $60,000. It’s hard to make a profit on 10-cents of income for every $1 spent, unless it's not your dollar! Commercial harvest is about subsidized short-term financial gain for a few that is preventing long-term recovery of this important public trust resource for all of the citizens of North Carolina.
I have included as attachments files in my possession related to this matter. A review of these documents will clearly show the need for immediate action. I ask that you take such action at your May meeting. As esteemed biologist and highly respected research professor Dr. Roger Rulifson clearly stated in his February 17th, 2016 communications with NCDMF staff -
“We cannot wait 3 years. In that period of time the wild Tar and Neuse striped bass populations will be extinct. This is clearly confirmed independently by both otolith and genetics studies. What you are suggesting will be a put-and-removal fishery, with no recruitment. This will cost the fisheries agencies hundreds of thousands of dollars in revenue. If stocking stops, so does the fishery. I ask that NCDMF reconsider their position, as this is an emergency situation and we still have a small window in which to act.”
Please do not be the commission that allowed our CSMA striped bass to go extinct.
Sincerely