NOAA has proposed a rule that would allow fishing for striped bass in a portion of the Exclusive Economic Zone (EEZ) in the area of Block Island. JCAA is opposed to this for reasons stated in our letter below. However, we need your help to stop this proposed rule from going into effect. Please take a few minutes to comment on this issue by going to: https://www.regulations.gov/docket?D=NOAA-NMFS-2018-0106 A simple statement saying that you are opposed to this rule is sufficient or you can use our letter as a guideline and elaborate further if your wish. Written comments may also be mailed to: Kelly Denit, Division Chief, Office of Sustainable Fisheries, 1315 East-West Highway, SSMC3, Silver Spring, MD. 20910 or faxed to Kelly at 301-713-1193. All comments must be received by 11/19/18

Dear Chief Denit,
           
            The Jersey Coast Anglers Association (JCAA) appreciates this opportunity to comment on the proposed rule that would open a portion of the Exclusive Economic Zone (EEZ), more specifically the Block Island Transit Zone (BITZ), to striped bass fishing. The JCAA represents approximately 75 fishing clubs throughout our state. Many of our clubs' individual members enjoy fishing for stripers. This includes all types of striper fishermen, ranging from those who like to keep all the fish they can legally take for consumption to those who prefer to release every striped bass they catch. Many of these anglers are very passionate about their sport. When it comes to regulations pertaining to striped bass, if you put ten striper fishermen in a room you might have ten different opinions as to how they should be managed. However, one thing they all agree on is that they want a healthy striped bass fishery with good representation from various year classes.      
 
            The JCAA has always fought hard to protect the stocks of striped bass, especially when the stocks of this fishery were decimated during the 1970's and early 1980's. Back then, we were the driving force that pushed through legislation that prohibited striped bass from being commercially caught or sold in our state. This designation helped the coastal stocks of striped bass to recover significantly. We realized back then as we do now that having a viable recreational striped bass fishery is of extreme economic value to our state. In recent years, the spawning stock biomass (SSB) of striped bass has been declining. The quality of striped bass fishing along our coast, particularly for those fishing from shore, has declined significantly. Since many of the stripers that are caught in states to our north are the same ones that migrate through New Jersey, we certainly don't want to see regulations that would allow stripers to be harvested in any portion of the EEZ. In 2015, both commercial and recreational anglers were forced by the Atlantic States Marine Fisheries Commission (ASMFC) to reduce their harvest by 25%. Therefore, it does not make sense that while the ASMFC is trying to keep the stocks of striped bass healthy, a portion of the EEZ would be opened to allow more striped bass to be harvested.

We fear that opening a portion of the EEZ to striper fishing could be the equivalent of opening Pandora's box. We understand that the current proposed rule would open the BITZ only to recreational fishermen. However, if that were to happen the next proposal might be to open it to commercial fishing as well. Further, we understand that this proposal is being considered because it is in a "unique area." Well, there are other "unique areas" along the east coast as well. We fear that other states might request "unique areas" near them be opened too. The next thing you know, there might be a proposal to open the EEZ in its entirety to striped bass fishing. We are adamantly opposed to that!
Stripers often winter over and are concentrated in the EEZ particularly off the coast of North Carolina and Virginia. They are very vulnerable at that time and would be decimated if the fishing there was reopened. The EEZ is a sanctuary for striped bass to help ensure that the stocks attain and remain at healthy levels. Further, the BITZ already allows for the transportation of stripers through the EEZ. We are not enthralled with that rule either as we understand that this has led to quite a few poachers fishing in that area. We find it appalling to hear that one of the arguments for opening this area is that people are fishing for stripers there anyway. We would like to see more enforcement in the area if this is the case.

Therefore, in conclusion, we strongly urge NOAA to nip this potential problem in the bud by denying any request to open any portion of the EEZ to fishing for striped bass!

Sincerely,

Mark Taylor, President

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