74 



accessible to the public. 



My second objection to a responsibility shift focuses on 

 the removal of a fishery from Magnuson and National 

 Standards overview. To what extent will Magnuson and 

 National Standards continue to guide bluefish management? 

 And what authority will "hold the ASMFC feet" to that 

 fire? It appears that a responsibility shift will have 

 bluefish managed solely by the Atlantic Coastal Fisheries 

 Cooperative Act, which, if I may risk being presumptuous, 

 wasn't the intent of Congress. 



My final concern centers on scientific data use. Under 

 ASMFC management, NMFS scientific information would 

 presumably be interpreted only by ASMFC scientists, 

 thereby losing valuable peer participation. But if NMFS 

 scientific personnel were to play an active role in 

 technical and monitoring committee functions, one would 

 rightly question the inconsistency of shouldering aside 

 just the Council. 



ISSUE 3 



With respect to improvements to bluefish management, I 

 offer the following thoughts which are in no way complete 

 but which represent my analysis up to this point and which 

 served as my input to the recent ASMFC/Council meeting to 

 launch Amendment 1 to the bluefish plan. 



1. Young-of -year protection 



I don't quarrel with the idea of protecting young fish, 

 but I'm troubled by the lack of data concerning angler 

 participation, numbers of fish caught, mortality, and 

 other factors as they relate to catches of small bluefish. 

 Without more precise data, we are quite likely to set a 

 minimum fish size which totally excludes effort on smaller 

 bluefish without really knowing that a meaningful 

 reduction will ensue. When one considers the scup plan, 

 sea bass plan, tautog plan and the potential in the 

 bluefish plan amendment, it's obvious we're slowly 

 leveraging out of the fishery an entire segment of 

 recreational angler: those who fish bays, docks, jetties, 

 backwater shorelines and rivers. I caution against that 

 direction and suggest it's unfair. It also opens the 

 management process to criticism that recreationally, the 

 process favors anglers who can afford to own boats or pay 

 the party/charter boat fare. 



