37 



"Added to these changing recreational fishing patterns, a first 

 time bluefish bag limit was imposed in this same period. Consider- 

 ing all of this, it is hard to imagine how recreational landings 

 wouldn't show a significant decline regardless of the number of 

 bluefish in the ocean. 



"More than anything else the bluefish situation emphasizes the 

 flaws in our system of estimating the size and health of fish stocks. 

 This system has become much too dependent on what recreational 

 and commercial fisherman are catching or on what the statisticians 

 estimate we are catching and much too separated from any actual 

 sampling of the number offish in the ocean. 



"What fishermen catch isn't always the best indicator of the 

 health of a fishery. Landings are too often dependent on fishery- 

 independent factors. The bluefish not being where they usually are 

 or as thick as they used to be doesn't necessarily mean there are 

 too few of them out there and shouldn't be used to justify further 

 management restrictions. 



"All of us that are seriously involved in fisheries management 

 are becoming increasingly aware of the increasing use of pressure 

 to force the management system to allocate fisheries resources be- 

 tween user groups, often to the detriment of a particular group of 

 users and with no benefit to the fisheries being managed. 



"I hope that this won't be the case with bluefish. Meetings that 

 I have participated in lead me to believe that it won't be. One of 

 the major problems with bluefish management up until now has 

 been the indexing of the allowable commercial harvest to the rec- 

 reational harvest. 



"We appear to be moving away from that, considering independ- 

 ent recreational and commercial 'total allowable catches' for each 

 sector instead and this is a step away from an allocation driven 

 system. 



"If, as many of us suppose, the bluefish stocks are healthy it is 

 possible to manage them to allow for greater utilization. Particu- 

 larly considering the pressure on many of our other fisheries, if this 

 could be done without threatening the sustainability of the fishery 

 it should be seriously considered. 



"Finally, I would like to address the proposal to have all bluefish 

 management authority taken from the Mid-Atlantic Council. 

 Speaking for myself and this is a feeling that is shared by the ma- 

 jority of recreational and commercial fishermen that I deal with, 

 one of the greatest strengths of the Regional Council system is the 

 public accessibility that is designed into it. 



"Taking the Council out of bluefish management will effectively 

 bar many of the users, both recreational and commercial, from par- 

 ticipating in bluefish management. By holding this hearing today 

 you are showing us how important you think public participation 

 is. Please help us to maintain this level of participation by keeping 

 the Mid-Atlantic Council actively involved in bluefish management. 



"In support of the idea that the bluefish stocks are not being de- 

 pleted, I have included a page of charts prepared from MRFSS data 

 looking at the age distribution of recreationally landed bluefish 

 from 1982 to 1994. These charts indicate a population surprisingly 

 constant in age composition, something that doesn't seem consist- 

 ent with any kind of excessive fishing mortality. 



