Chub Mackerel Comments
Dr. Chris Moore, Executive Director
Mid-Atlantic Fishery Management Council
800 N. State Street, Suite 201
Dover, DE, 19901
Dear Dr. Moore:
[Your optional comment]
Thank you for the opportunity to comment on this important issue. I support the Mid-Atlantic Fishery Management Council managing Atlantic chub mackerel as a stock in the Atlantic Mackerel, Squids, and Butterfish Fishery Management Plan (MSB FMP) and encourage the Council to adhere to the science and statistical committee’s (SSC’s) recommended acceptable biological catch (ABC) of 2,300 metric tons (5.07 million pounds) for 2021-2023. Furthermore, until sufficient scientific information is available to provide a comprehensive understanding of the role of chub mackerel in the ecosystem and allow for the necessary management adjustments to consider the needs of predators, I do not support increasing catch limits on chub mackerel.
When the Council passed the Unmanaged Forage Amendment, it committed to taking a proactive approach to conserving unmanaged forage species and the ecosystem services they provide. It’s in that spirit that I commend the Council on this effort to formally manage chub mackerel under the MSB FMP. As forage, chub mackerel are vital to supporting an array of ecologically and economically important species, including highly migratory species such as tunas, billfish, marlin, and striped bass, as well as other species like monkfish, summer flounder, and a variety of marine mammals and sharks.
While the Council must follow the SSC’s recommended ABC of 2,300 metric tons for upcoming fishing years, it’s the responsibility of managers to consider the ecosystem role of chub mackerel, and the economic, social, and ecosystem impacts when setting catch limits. For forage species like chub mackerel, the Council can in fact set catch limits less than the recommended ABC. By keeping more fish in the water, managers can invest in the future of the resource as well as other fisheries that depend on healthy and abundant populations of chub mackerel. This precautionary approach to management is supported by the Magnuson-Stevens Fishery Conservation and Management Act and the National Standard guidelines, where attention should be given to managing forage stocks for higher biomass to enhance and protect the marine ecosystem.
Lastly, the Council should adhere to its own policy and recommendations for managers when setting catch limits for forage species like chub mackerel—as outlined in the Council’s Ecosystem Approach to Fisheries Management Guidance Document, which details the importance of supporting an adequate forage base to ensure ecosystem health, and gives clear guidance on how to set catch limits that consider a species’ role as forage.
Thank you again for this opportunity to comment, as well as to Council and staff for embarking on this long-term commitment to managing chub mackerel for its role as forage under the MSB FMP to the benefit of its many predators, fishing and coastal communities, and the marine ecosystem underlying many of the public resources on which we all depend.
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