Annual Catch Limits - Omnibus Amendment

The Mid Atlantic Fishery Management Council has a proposed an Omnibus Amendment to address the requirement for annual catch limits (ACLs) and accountability measures (AMs) for all target stocks. The Council is considering amending all its FMPs through this Omnibus Amendment. Exempt from the requirements are annual life cycle species not subject to overfishing, and the New England Fishery Management Council will develop measures for the monkfish (which is jointly managed between the New England and Mid-Atlantic Fishery Management Councils). The Science and Statistical Committee will be responsible for application of control rules to set acceptable biological catch for target species stocks.

The Council recently held public meetings on the ACL Omnibus Amendment throughout the Mid-Atlantic region. The Marine Fish Conservation Network delivered testimony at the May 2010 meeting in Alexandria, VA, and submitted written comments to the Council.

The Network is encouraged by the Council’s initial efforts to develop a system of ACLs and AMs for stocks in its fisheries and the public hearing document and the proposed alternatives contain a number of the features of a system of ACLs and AMs that we recommended in our earlier national report Implementing Annual Catch Limits: A Blueprint for Ending Overfishing in U.S. Fisheries. While the public hearing document contains many promising features and represents a good start, the Network believes that much work remains to be done. Specifically:

• The Draft Omnibus public hearing document simply assumes that those stocks already listed in the FMPs are the only stocks in the fishery requiring ACLs and AMs; the document lacks any evaluation of other, non-target stocks caught incidentally as bycatch that may qualify as stocks in the fishery.
• The proposed system of ABC control rules appears to be designed in such a way that substantial sources of scientific uncertainty would not be considered and uncertainty buffers would not be adequate.
• The proposed alternative risk policies do not provide an adequate margin of safety against the risk of overfishing and should be more conservative.
• The proposed system of accountability measures relies primarily on reactive measures that would not enable managers to close a fishery upon attainment of its ACL, and fails to address the shortcomings of the catch monitoring system.
• The document lacks any adequate consideration of procedures for achieving OY, including measures addressing ecosystem considerations in the setting of ACLs in order to achieve OY.

Timeline