 |
 |
 |
 |
 |
|||
 |
PO Box
1118 • West Babylon, NY 11704 |
||
|
January 4, 2010 Kathryn A. Hattala, Senior Fisheries Biologist New York State Department of Environmental Conservation Hudson River Fisheries Unit,
Bureau of Marine Resources Dear Ms. Hattala: Coastal Conservation Association New York (“CCA NY”) is taking this opportunity to support the proposed closure of the shad fishery in the Hudson River and in the Marine District. There is little doubt that the Hudson River stock of American shad are in serious trouble. The stock is at an historic low.[1] As noted by the New York State Department of Environmental Conservation (“DEC”) in its shad recovery plan, “[T]he spawning stock is experiencing excessive and unacceptably high mortality and that mortality has seriously reduced production of young in the estuary.”[2] There is little doubt about the cause of such problems. “The excessive mortality of the last 20 years perpetuates almost a century of successive periods of overfishing on the Hudson River stock of American shad”[3] and that “[a]ll declines [in the size of the Hudson River stock] are attributable to overfishing,”[4] there is also little question that immediate action is needed, since DEC biologists have stated that even if recovery measures are implemented, “there is a high uncertainty regarding [the American shad’s] recovery” in the Hudson River.[5] In addition, Hudson River shad represent one of the longest-lived stocks, with adults able to reach an age of at least 13 years (and very probably more in an unfished stock).[6] When the stock was healthy, repeat spawners comprised as much as 78% of the shad returning to the river, with some shad having spawned as many as eight times.[7] Such information suggests that older shad may be of particular importance to the health of the Hudson River stock, and any stock that is dependent on having older fish in the population is particularly vulnerable to overfishing. The relatively modest measures put in place in 2008 have not helped spur a recovery.[8] Hope for such a recovery depends on shad spawned between 2002 and 2008, which represent the remaining adult population.[9] Thus, the need for rapid and meaningful action is manifest. CCA NY has long advocated enhanced measures to recover the Hudson River stock of American shad, and has suggested in earlier correspondence with the DEC that it would support a complete closure of the shad fishery in the Hudson.[10] Given the dire state of the American shad fishery in the Hudson River, and the clear connection between overfishing and the shad’s decline, CCA NY strongly supports the proposed closure, and asks that the DEC act quickly to enact the closure before the first American shad enter the Hudson River in March. Thank you for considering CCA NY’s views on this matter. Sincerely, Scott Emslie State Chair [1] New York State Department of Environmental Conservation, Regulatory Impact Statement, Proposed regulation amending 6 NYCRR parts 10, 11, 35, 38 and 40 with respect to American shad, November 18, 2009. [2] New York State Department of Environmental Conservation Hudson River Fisheries Unit, Hudson River American Shad, An Ecosystem-Based Plan for Recovery, May 2008, p. 1. [3] Hattala, Kathryn A. and Andrew W. Kahnle, “State of the Hudson River, New York American Shad Stock,” in Stock Assessment Report No. 07-01 (Supplement) of the Atlantic States Marine Fisheries Commission American Shad Stock Assessment Report for Peer Review, Volume II, Atlantic States Marine Fisheries Commission, August, 2007, p. 227. [4] Ibid., p. 217. [5] Ibid., p. 227 [6] Ibid., pp. 212, 216 [7] Ibid., p. 214 [8] NYSDEC, Regulatory Impact Statement [9] Ibid. [10] Letter from William Emslie to Kathryn A. Hattala, dated January 15, 2008
|
|
|
|
||
