To put the American eel plight in perspective. If the coast wide rec limit on striped bass was 6" minimum 50 fish per day, if the coast wide comm limit was 6" as many as you can catch, how many striped bass would we have today?

If there had been a unregulated coast wide young of the year striper fishery for several years, and if these fish fetched better than one hundred dollars a pound at market, how many stripers would we have today?

If striped bass lost access to 80 % percent of their historic upstream habitat, how many would we have today?

If a significant number of adult female stripers migrating to their spawning grounds were diced up in hydro dam turbines how many would we have today?

If all of the above mortality to striped bass was pre spawn (American eels only spawn once and die), how many would we have today?

The American eel faces all of the above. Pick any diadromous or inshore species, how many would we have today if they had to run the above gauntlet?

I begin my comments with the above questions because there appears to be no biological basis for current and past eel harvest regulations. The current regulations appear to be based more on tradition than science. How many other fish species can be caught by recreational fisherman in fish traps (eel pots)? How many other fish species are specifically targeted and harvested as young of the year?

Before continuing with my comments I would like to complement those who prepared this Public Information Document. Having followed the ASMFC response to the eel decline over the past few years there appeared to be a couple schools of thought forming on the subject. One being that the decline of the St. Lawrence and Northern eels were not an indication of an overall, coastwide stock decline. The other being, there is something going on, eels are declining, we know very little about the dynamics of it, but we should take action sooner rather than later. The information put forth in this PID appears to embrace the latter of the two schools of thought, that action should be taken sooner rather than later.

To answer the last question of the PID first.

"Does the public feel that a coast wide reduction of or prohibition on the take of American eel will be helpful in re-building the American eel resource?"

Ideally we would like to see a prohibition on the targeted harvest of eels until some sense can be made of their decline. If the board does not consider this a viable or palatable option at this point, we would like to see the recommendations of the technical committee followed.

The first step should be to bring eel harvest more in line with other main stream fishes like the striped bass. While there are many pressures being exerted on the eel, and many factors contributing to their decline the ones we have most immediate control over is their harvest, upstream passage and downstream hydro dam mortality. To have so many unanswered questions about a species in decline and to allow such liberal harvest limits does not make any sense.

 

"The American Eel Technical Committee recommends a closure of all directed silver eel fisheries."

"The American Eel Technical Committee recommends a seasonal closure for fishing of American eel."

As pointed out in the PID these two recommendations if followed would go a long way towards reducing harvest and protecting eels during their spawning runs. If these actions were coupled with annual quotas of x number of pounds as is the case for striped bass a positive step toward eel conservation would be taken.

In addition to the above we recommend the following.

Prohibition of the use of fish traps (eel pots) by recreational fisherman.

This in itself would greatly reduce the recreational catch. If recreational fishermen want eels let them use hook and line the same as they do for other fish. Why are fish traps allowed for eels? Is there a biological justification for why they are allowed for eels when they are not allowed for other species?

Closure of the elver fishery in those states which still allow it (Maine, South Carolina, Florida).

Given the current state of the eel stock and the fact that all other states have ended elver fishing the remaining states which allow elver fishing should be required to follow suit. What other species is allowed to be harvested as young of the year? Furthermore poaching of elvers still appears to be a problem. If prices paid for elvers rise in the future to something even close to what they once were poaching will become more of a problem. By eliminating all elver fishing it would be much easier to eliminate poaching problems now and in the future because there would be no legal source for delivery and distribution.

As an example there are many dams throughout this region where elvers and glass eels gather each spring. Two, which I have personal experience on are the Weweantic River in Wareham Ma, and Sebasticook River in Winslow Maine. It would not have been difficult in years past for a person to scoop up ten or twenty pounds of elvers beneath either the Fort Halifax dam on the Sebasticook or the Horseshoe pond dam on the Weweantic. In fact my brother and I have done it on several occasions to put them over the dams. In less time than it took us to put them over the dams we could have just as well loaded them into coolers and been gone in no more than twenty minutes time. Even at a price of twenty five or fifty dollars per pound a good bit of money could be made by the unscrupulous type.

Reporting requirements.

This seems to be a real problem with eels. One gets the sense after reading the minutes and other various documents of the Eel Board that the Technical Committee has been frustrated by a lack of reliable reporting data and an unwillingness of the Board and member States to require better documentation of the catch. Here again we support the recommendations of the Technical Committee as outlined on page 8/9 under Issue 4. Catch and effort data.

If the Committee is going to continue to allow eel to be harvested then both the Committee, States, and fisherman must partner to maximize and use the harvest as the valuable stock assessment tool that it can and must be. Given the current state of affairs if I depended on eels for my livelihood I would be in immediate contact with my fellow eel fishermen and distributors to establish a system to collect accurate data as well as collect eels. At this point one is dependant on the other, or certainly should be. If member states and their respective user groups do not comply their privilege to fish should be immediately revoked.

Habitat.

ASMFC (2000) states: "By region, the potential habitat loss [for American eel] is greatest (91 percent) in the North Atlantic region (Maine to Connecticut) where stream access is estimated to have been reduced from 111,482 kilometers to 10,349 kilometers of stream length. Stream habitat in the Mid Atlantic region (New York through Virginia) is estimated to have been reduced from 199,312 km to 24,534 km of unobstructed stream length (88 percent loss). The stream habitat in the South Atlantic region (North Carolina to Florida) is estimated to have decreased from 246,007 km to 55,872 km of unobstructed stream access, a 77 percent loss."

The Maryland Department of Natural Resources, MBSS Newsletter March 1999, Volume 6, Number 1 states:

"The most dramatic example of the decline of American eel abundance is dam construction on the Susquehanna River. Prior to the completion of Conowingo and three other mainstem dams in the 1920's, eels were common throughout the Susquehanna basin and were popular with anglers. To estimate the number of eels lost as a result of construction of Conowingo Dam, we used MBSS data on American eels from the Lower Susquehanna basin and extrapolated it to the rest of the basin above the dam. Our best conservative guess is that there are on the order of 11 million fewer eels in the Susquehanna basin today than in the 1920s.

"The magnitude of this loss is corroborated by the decline in the eel weir fishery in the Pennsylvania portion of the Susquehanna River. Before the mainstem dams were constructed, the annual harvest of eels in the river was nearly 1 million pounds. Since then, the annual harvest has been zero. Given the longevity of eels in streams (up to 20 years or more) and their large size, the loss of this species from streams above Conowingo Dam represents a significant ecosystem-level impact. Because adult eels migrate to the Sargasso Sea to spawn and die -- transporting their accumulated biomass and nutrient load out of Chesapeake Bay -- the loss of eels has increased nutrient loads in the basin and reduced them in the open ocean where they are more appreciated."

If similar loses have resulted on other large coastal rivers with multiple dams on their mainstems, Connecticut, Kennebec, Penobscot, and if ASMFC estimate that American eel once comprised 25 to 50 percent of the total fish biomass in the streams is accurate, it seems likely that the eel populations we have had in the past while stable represent a remnant population. If indeed this is the case it makes the current decline all that more alarming.

In the eels once unaltered ecosystem there would have been millions of more eels of wide ranging age groups in the system. This would be a valuable survival mechanism for the species as a whole. If, as has recently been theorized, ocean currents changed so that glass eels are no longer reaching our shores there would again be millions of eels in an unaltered system. It seems conceivable that in the eels unaltered ecosystem glass eels could disappear from our coast for ten years or more and there would still be plenty of adults in the system to produce another year class. Because of the loss of habitat todayís remnant eel population could be very vulnerable to such a change in ocean conditions.

The point of all the above theorizing and blabbering is, that if our American eel is going to remain a viable species we have to take the habitat and hydro dam mortality seriously. Meaning, itís no longer good enough to talk about it in concerned voices, and declare it in policy statements, itís time to fix it. This requires a focused, combined commitment and effort from top to bottom, at the federal, regional, state and local level.

Closing comments.

 

On March 10, 2004 the American Eel Management Board of the Atlantic States Marine Fisheries Commission (ASMFC) issued a press release recommending the protection of American eel under the United States Endangered Species Act. The statement reads in part:

"Canadian and US data show 2003 commercial landings are the lowest on record since 1945 and there are indications of localized recruitment failure in the Lake Ontario/St. Lawrence River system. The International Eel Symposium at the 2003 American Fisheries Society Annual Meeting reported a worldwide decline of eel populations, including the Atlantic coast stock of American eel ... The Commission also recommended that the US Fish and Wildlife Service (USFWS) and the National Marine Fisheries Service (NMFS) consider American eel in the Lake Ontario/St. Lawrence River/Lake Champlain/Richelieu River system as a candidate for listing as a Distinct Population Segment under the Endangered Species Act. The Board also recommended that the USFWS and NMFS consider designating the entire coastwide stock as a candidate for listing under the ESA."

Despite this statement in March 2004, the Atlantic States Marine Fisheries Commission has not reduced or prohibited the ongoing harvest of all life stages of American eel from the waters of the Atlantic seaboard of the United States of America.

 

On November 12, 2004 my brother and I filed a petition to have our American eel listed and protected under the Endangered Species Act. This action serves three fundamental purpose.

First and most importantly, to protect what appears to be a dwindling species. Despite all the talk little has been done over the past several years to protect this species. Furthermore, there has been a serious lack of commitment from upper level management at both the federal, regional and state levels.

The second purpose is to get people to stop talking and start acting.

The third purpose is accountability. If adequate steps are not taken now and ten years from now the remainder of our coastal eel population goes the way of the Saint Lawrence there will be no excuses. The documentation will be there for all to see, there will be no talk of surprise or mystery. Someone will ask the question "WHY", and someone will have to answer WHY?. I wouldnít want to be the person to have to answer that question.

Gone Forever -- September 1, 1914

Original Essay, "PASSENGER PIGEON:Ectopistses Migratorius (Linnaeus)" by Edward Howe Forbush in "Game Birds, Wild-Fowl and Shore Birds". Massachusetts Board of Agriculture, Reprinted in Birds of America. T. Gilbert Pearson, Editor-in-chief, Copyright 1917, by The University Society Inc....

"No adequate attempt to protect them was made until they practically had disappeared. Whenever a law looking toward the conservation of these birds was proposed in any State, its opponents argued before the legislative committees that the Pigeons "needed no protection"; that their numbers were so vast, and that they ranged over such a great extent of country, that they were simply able to take care of themselves. This argument defeated all measures that might have given adequate protection to this species. That is why extinction finally came quickly. We did our best to exterminate both old and young, and we succeeded. The explanation is so simple that all talk of "mystery" seems sadly out of place here...."

 

Sincerely,

Timothy A. Watts

Underpaid Executive Director

Glooskap and the Frog