75 



2. Recreational catches 



Heretofore the bluefish plan has measured recreational 

 catch, not landings (fish killed and brought to the dock). 

 Thus, calculations of recreational harvest were overstated 

 in that credit for released fish was not given. I suggest 

 landings plus release mortality are more realistic 

 measurements. This will produce an equal comparison to 

 commercial catch measurements which, although usually 

 expressed in pounds, are nevertheless statements of 

 landings . 



3. Bag limits and minimum size 



These can't be adequately addressed until the stock 

 assessment scheduled for this summer, but to implement 

 either or both recreationally without adequate controls on 

 commercial multi-species, multi-gear and non-selective 

 gear simply begs the issue. 



I would suggest that all bluefish caught commercially be 

 considered legal for sale and counted against the overall 

 commercial quota. This would limit regulatory discards. 

 However, let's not overlook the possibility of gear quotas 

 (which I acknowledge could conflict with the discard 

 point ) . 



Also, as was accomplished in the scup plan, commercial 

 discards should be accounted for as is recreational 

 release mortality. 



4. Quota calculation 



I suggest the recreational and commercial quota setting 

 process follow the model of other fishery plans such as 

 summer flounder and no longer be linked to each other. 

 Further, while I won't quibble over whether the split 

 should be 90-10 or 80-20, I believe the percentage should 

 be set and not a function of a moving average. Otherwise, 

 underfishing on the recreational side could eventually 

 erode quota allocation unjustly. 



Commercial overages should be subtracted in the following 

 year (and/or season should such measures be implemented). 

 Recreational overages should be considered along the same 

 multi-year average which I recently proposed with summer 

 flounder. Thus, a one-year spike in recreational catches 

 would not trigger a bag limit cut unless the average for 

 the period exceeded the quota. 



