Dear Acting Administrator Sullivan and Director Ashe:
We are writing to express our opposition to recently adopted measures that unfairly reduce the fishing quota for fluke in New Jersey.
As you know, on February 4, 2014, the Atlantic States Marine Fisheries Commission (ASMFC) voted for new regionalization measures for the 2014 fluke fishing season. We were disappointed in the 7-4 vote to oppose the current system, which included votes from representatives on the ASMFC from the National Fish and Wildlife Services (NFWS) and the National Oceanic and Atmospheric Administration (NOAA).
While we appreciate the ASMFC's efforts to address fluke management, this measure replaces the current summer flounder management plan with a misguided approach that has the effect of suddenly reallocating some of New Jersey's fluke quota to New York. The ASMFC allegedly wanted to have similar size regulations between bordering states but all they did was shift the problem at the expense of New Jersey anglers, who are projected to lose approximately 20 percent of their fluke catch in 2014.
Additionally, the ASMFC disregarded the input of the public and the tremendous opposition when considering this measure. A public comment period was held, along with a number of public hearings, and the vast majority of the input provided was in opposition to the regionalized plans. Furthermore, there has not been enough time for constituent groups and interested parties to analyze the consequences of such a radical departure from current management measures or for voting members of the ASMFC to make fully informed decisions.
As such, we are troubled that NFWS and NOAA would support the adoption of these new measures. We request that both of your agencies provide our offices with the rationale for your support and explain what consideration your agency gave to the adverse impacts these measures would have on New Jersey's anglers. In addition, we believe that the NFWS and the NOAA should take the lead and commit to a careful evaluation of the economic and management impacts of these new measures. During the course of this evaluation, your agencies should review the best options for future management of fluke within the jurisdiction of ASMFC.
In light of the concerns we have laid out above, we hope you give careful consideration and take appropriate action to ensure that further public input and evaluation of alternative management plans is carried out before any further action towards regionalization of the fluke quota is pursued.
Thank you for your attention to this matter and look forward to your response.