11 



restricting bag limit. As Jack pointed out, that is the kind of tools 

 we are looking for to re-write the management plan. 



I am not aware of any effort to evaluate the effects of increased 

 predation or changes in water currents or water temperatures on 

 the distribution and abundance of bluefish. However, there is one 

 study underway to assess the possibility that the greatly increased 

 abundance of striped bass could have displaced bluefish offshore. 



Since most recreational landings of bluefish are attributed to 

 fishermen fishing close to shore, such a displacement might also ac- 

 count for the decline in recreational landings in recent years. 



I might also add, sir, that our watermen in the Chesapeake Bay 

 have been telling us for years that there is some correlation be- 

 tween bluefish abundance and striped bass abundance at least in 

 the Bay. 



You asked what effect the proposed withdrawal of the Bluefish 

 Management Plan might have on bluefish management, on the re- 

 source and on public input. The amount of work required to prop- 

 erly manage bluefish will not be reduced by withdrawing the exist- 

 ing plan. 



The effort to amend the plan will be the same. The amount of 

 effort required to implement the plan will be the same. Scientists, 

 plan developers and fishery managers will still need as much data 

 collection support and updated stock assessments as ever. How- 

 ever, the personnel and resources to accomplish all of this will be 

 significantly reduced by withdrawal of the plan and eliminating 

 Council participation at least at the working level. 



The amendment process will be prolonged and yet the oppor- 

 tunity for public input during the amendment process and imple- 

 mentation of the amended plan will be greatly reduced. I believe 

 the Atlantic States Marine Fisheries Commission is every bit as 

 concerned as the Council about the condition of bluefish stocks. 



Nevertheless, assigning sole responsibility for bluefish manage- 

 ment to ASMFC or to any other management entity in itself ig- 

 nores as a matter of expediency the resources needed to amend the 

 plan, to implement it and to monitor its effectiveness so as to main- 

 tain the well being of the resource while responding to the needs 

 and desires of recreational/commercial users. 



The proposal to withdraw the Bluefish plan also deprives the 

 user community of a fair and meaningful participation in a man- 

 agement process assured it by the National Standards and other 

 provisions of the Magnuson Act. I see no benefit to the resource or 

 to the fishing community in the proposal to withdraw the Bluefish 

 Management Plan that now exists. 



A management strategy similar to that which is working for 

 summer flounder appears to be adaptable to managing bluefish 

 stocks for growth. The strategy involves setting a target fishing 

 mortality rate consistent with achieving an increase in stock bio- 

 mass using that target rate in a stock assessment to calculate a 

 total allowable catch and allocating that total allowable catch to 

 the recreational commercial fisheries based on some agreed-upon 

 formula such as in the case of bluefish, the 80/20 allocation speci- 

 fied in the current management plan. 



Given that the Bluefish Plan includes both recreational and com- 

 mercial users and that it will extend along the entire Atlantic 



