positiontautog

The New York Fishing Tackle Trade Association is an organization consisting
of retailers, wholesalers and manufacturers involved in the fishing tackle trade throughout New York State, with additional members in New Jersey and
Connecticut.

Comments regarding the ASMFC Tautog Management Plan

The members of the New York Fishing Tackle Trade Association realize that
the current decline of the tautog fishery is due to overfishing pressure. We feel the potential economic impact on the recreational fishing industry must be taken into consideration when formulating any fisheries restoration plan.

We commend the efforts of the ASMFC in devising a plan for the recovery of
this popular fishery. However, we request that all current proposals be reevaluated, taking into consideration the following positions and concerns
derived from the ASMFC Management Plan.

In order to accomplish the 63% recreational mortality reduction specified
by the ASMFC, we must first establish the credibility of any data from which reduction estimates have been derived.

The findings of the Atlantic States Marine Fisheries Commission are tempered by a statement made in the Fishery Management Plan for Tautog: "(1.12) Commercial Fisheries: Problem Statement: The commercial fisheries reductions listed in the FMP are outdated in that they do not incorporate the latest catch data."

Once again, we feel it would prove beneficial to survey the members of this
association as to the perceived increase in recreational targeting efforts for tautog for the years 1996-1999. Our bait wholesalers have indicated a decrease in tautog bait sales over the past four years. The use of bait products (i.e., green crabs, fiddler crabs, etc) is the primary method used in targeting tautog; no known artificial lures have proven effective in catching blackfish.

We do not presume to have a "scientific" percentage that can translate to a
decreased tautog mortality. However, the economic indicators conservatively imply at least a 25% decrease in recreational participation. We believe this to be a clear reduction; credit needs to be calculated toward reaching the goal of a 63% recreational mortality reduction.

Options to compliance with the ASMFC guidelines

Apparently, much time and effort was placed into the option plans proposed
by the ASMFC. However, the plan neglects to address the financial needs of the recreational fishing industry.

To restate, the original ASMFC guidelines are questionable at best. Since
the fisheries data are unreliable, compliance with the ASMFC guidelines needs to be reevaluated.

We request that fisheries managers consider the needs of the recreational fishing industry when developing fisheries management plans, as the health of the industry is important to the overall health of the economy.

This association's concerns lie in how restrictions, seasons, possession limits, etc. would impact the ability of the recreational fishing industry to conduct business on an even playing field.

Fisheries managers must realize how important it is to the recreational fishing industry that a bottom fishery be available in the fall season. Fall blackfishing is a transition fishery; the blackfishery is crucial to the recreational fishing industry, considering the absence of winter flounder during the conclusion of fluke (summer flounder) season and after the departure of scup (porgy.) Please note: this is the consensus of the NYFTTA membership throughout the entire New York Marine District.

Commercial restrictions

Although we have made some suggestions regarding the absence of accurate
data collection and the commission's concerns with the increased tautog markets emerging, it is the opinion of this association that a possible method in determining tautog commercial landings is through a tag distribution system, similar to the one already in place for the striped bass fishery. This method would support general compliance and bring forth a more accurate landing total. Not withstanding is the possibility of a "black market" disposal of this fishery (illegal sale of fish to the live markets) , which needs to be factored into any fisheries management plan.

Enforcement

Any implementation of a fisheries restoration plan for tautog is rendered moot if enforcement is inadequate. Arbitrary size and/or possession limits should be made reasonable and practical, to facilitate general compliance.

It is the position of the NYFTTA that the current size limit of 14", along with the current possession limit of 10 fish per person per day be maintained until the aformentioned concernes are addressed.

I and my association's directors are available to elaborate on the positions stated in this document. We thank you for your time in allowing us to express our concerns.

Sincerely,

John Mantione, President
New York Fishing Tackle Trade Association