87 



* The number of juvenile fish being produced has declined 



substantially since 1984 and has been below average smce 1989; and, 



* Recmitment of juvenile fish to the spawning stock has been poor. 



Whether we continue to delay and wait for a new stock assessment or not, these facts 

 shout out that bluefish stocks are experiencing substantial declines and we must take action now 

 to avoid pushing them even lower through excessive fishing. The July 1995 MAFMC Bluefish 

 fishery management plan (FMP) review indicated that exploitation must be reduced by 50% to 

 achieve the target fishing mortality rate, and we must start down the road to achieve that end. 

 The only dynamic affecting bluefish stock size that can be manipulated is fishing mortality and 

 pushing the stocks to exceedingly low levels may jeopardize or gready diminish the chances for 

 a fiill recovery. There is just too much we don't know about bluefish, therefore management 

 measures must be extremely conservative. It would be foolhardy to pin our future hopes on 

 anecdotal information that claims the ocean is fiill of big bluefish just over the horizon. 



Next, the question of who should manage the bluefish fishery. That question has been brought 

 to the fore with the recent proposed action of the Secretary of Commerce to deactivate the 

 current Bluefish FMP. There is no doubt that the current co-management by the MAFMC and 

 the Atiantic States Marine Fisheries Commission (ASMFC) is cumbersome and gives credence to 

 the public's lack of confidence in government's ability to run their business smoothly, 

 eflFectively and eflScientiy. One only has to attend a joint meeting of the MAFMC's Coastal 

 Migratory Committee and the ASMFC's Bluefish Board to see why the fishing public questions 

 government ability to manage the bluefish stocks. From that perspective, I think it is appropriate 

 for Congress to assess the proper role of the federal government in the management of bluefish. 

 The Bluefish FMP was adopted by the MAFMC in October, 1989 and NOAA approval came in 

 1990. The MAFMC heaped praise upon itself for launching an FMP for a "healthy" fishery. 

 However, the FMP was fatally flawed fi-om its inception. The plan may not be the reason for the 

 decline of bluefish stocks but it certainly tarnished the luster of the MAFMC in the eyes of the 

 recreational fishing industry and recreational fishermen. Among the plans shortcomings were 

 the lack of management options built into the plan (the antithesis of firamework flexibility), 

 linking commercial allocation to recreational catch, punishing recreational fishermen for 

 practicing catch and release, and giving the commercial fishing sector a higher proportion of the 

 catch than was historically demonstrable. The historic recreational/commercial ratio of bluefish 

 harvest was 85/15 fi-om 1979 to 1989, tiie Council's FMP targeted tiie ratio at 80/20. The 

 Council exacerbated their standing with the recreational fishing community when they devised a 

 grossly unfair methodology for predicting the next years recreational catch in setting the bluefish 

 commercial quota when the plummeting bluefish stocks triggered an FMP mandated commercial 

 quota. [NOTE: The commercial harvest did not rise, rather the severe decline of recreational 

 harvest greatiy changed the recreational/commercial ratio in excess of 20% triggering the 

 commercial quota setting process.] The methodology knowingly overestimated the recreational 

 catch which rewarded the commercial sector with higher quotas than which were realistic, 

 leading to increased over fishing. Since 1990 the split has been of the magnitude of 70/30 when 

 using the Council's unbelievable mandate of measuring the commercial catch by landings (fish 

 brought to the dock and sold) while the recreational measure was their catch (including fish 



