caught and released alive! - see Figure 3). If a more realistic method is used of equating 

 recreational fishing harvest (MRFSS A + B 1 fish) with commercial landings the split exceeded 

 70/30 and actually approached 60/40! (see Figure 1) 



What has the MAFMC done to correct the badly flawed Bluefish FMP? Nothing! During my 

 three year tenure (1992-95) the Council toyed (used advisedly) with drafting Amendment One to 

 the Bluefish FMP. They are still toying with it... Some would say that the ASMFC shares 

 culpability for the faulty Bluefish FMP since it was developed as a joint plan. I would answer 

 that with the observation that the ASMFC of 1996 is far different than the ASMFC of 1989. Of 

 singular difference is the passage of the Atlantic Coastal Fisheries Cooperative Management Act 

 (ACFCMA) of 1994. The ASFMC's standing in the management of Atlantic coast fisheries was 

 significantly enhanced with passage of that legislation. In addition to standing, the Act 

 increased ASMFC's resources to carry out greater responsibilities. 



In my opinion it is entirely appropriate for the Secretary of Commerce to withdraw the 

 Bluefish FMP, notwithstimding the rationale of reducing federal regulations. If carried out the 

 withdrawal of the Bluefish FMP will gready reduce the duplication of effort between the 

 ASMFC and the MAFMC. Mr. Chairman, in your letter of invitation to testify you asked if such 

 a move would help the resource. That is problematical, but it certainly will help the public in 

 focusing their efforts to participate in bluefish fishery management while reducing government 

 duplication. From the recreational fishing community's standpoint it makes sense because a 

 great preponderance of bluefish fishing occurs in the territorial sea (see Figure 2). Such a move 

 will not exclude federal participation in bluefish management it will merely change the lead for 

 the Bluefish FMP to the ASMFC. The Secretary will continue to have responsibility for bluefish 

 in the Exclusive Economic Zone (F.F.Z) and the National Marine Fisheries Service will have a 

 place at the ASMFC's bluefish management deliberations. In fact, as with other coastal fisheries 

 it is imperative that ASMFC and the National Marine Fisheries Service work to avoid creating 

 enforcement loopholes due to inconsistencies in state and federal regulations. It has been said 

 that the ASMFC does not provide for adequate public participation in the management process. 

 It may not be exactly like the Magnuson Act's public participation process but I believe it is 

 adequate. Each ASMFC member state has its own public participation process for public input. 

 I would add that endorsement of an ASMFC lead for bluefish is not summarily extended to all 

 fishery management plans. That must be done on a plan by plan basis. It would behoove the 

 ASMFC and the MAFMC, the New England Fishery Management Council and the South 

 Atlantic Fishery Management to get together and develop a protocol for inteijusidirtional fishery 

 management in the light of passage of the ACFCMA. That is not a novel idea. Congress implied 

 such action in the Findings and Purposes [Section 5101 (a) and (b)]of the ACFCMA. 



The final area of concern of this hearing is what kind of management is needed to rebuild the 

 stocks. The simple answer to that question is to minimize fishing mortality and wait for natural 

 condition that are conducive to bluefish spawning and recruitment. That seems crass, but 

 identifies the range of options. With regard to specific recommended changes in the Bluefish 

 FMP, it must be amended to be more flexible in regard to management options to reduce fishing 

 mortality. The states should be given a great deal of latitude to reach management objectives. It 

 is time to use conservation equivalencies in management as well identifying and quantifying all 



