Dear Secretary Lutnick,

On behalf of The Jersey Coast Anglers Association, representing more than 30 saltwater fishing clubs, Hudson River Fishermen’s Association, Hi-Mar Striped Bass Club, Tackle Box Fishing Company, Karen Ann Charters, My Joyce Fishing Charters, Captain Ron’s Fishermen, and Moran’s Dockside, the enclosed petition filed pursuant to the First Amendment to the U.S. Constitution,1 Administrative Procedure Act (“APA”),2 and Magnuson Stevens Fisheries Management and Conservation Act (“Magnuson-Stevens Act”)3 requests emergency action to immediately prohibit industrial “reduction fishing” for Atlantic menhaden in the New York / New Jersey Bight (“Bight”). The Bight is a unique and highly productive ocean area off New York and New Jersey formed by the generally north-south Atlantic coast and the generally east-west southern Long Island coast. From this roughly triangular section of coast stretching from the Cape May Inlet to Montauk Point it extends out to the continental shelf break, including Hudson Canyon. Its waters are directly influenced by the Gulf Stream, and from spring through fall is home to massive schools of Atlantic menhaden that drive recreational and commercial fisheries worth billions of dollars and tens of thousands of jobs to regional and national economies.

Emergency regulations are required to protect the Bight from destructive and wasteful industrial reduction fishing4 that is having devasting ecological and economic impacts on the Bight and the recreational and commercial fisheries that depend on it. Specifically, we request that you:

1. Promulgate emergency regulations under the Emergency Action and Interim Measures provisions of Magnuson-Stevens Act5 to establish an immediate seasonal closure to reduction fishing for Atlantic menhaden in the New York / New Jersey Bight, as described in the enclosed rulemaking petition.

2. Immediately initiate informal (notice-and-comment) rulemaking under the APA6 and Magnuson-Stevens Act7 to be completed during the one-year period in which the emergency regulations are in effect to make the emergency seasonal closure permanent, ensuring the Bight is protected at minimum from May 1st to December 31st annually.

The proposed reduction fishing closure is designed to provide protection to the New York / New Jersey Bight area during the times of year when it is most important to American fishermen, and most vulnerable to being ruined by the reduction fishery. The annual “fall migration” of Atlantic menhaden south through the Bight is beginning and is threatened by the reduction fleet, which is having unprecedented difficulty finding and catching menhaden near their base of operations on the Chesepeake Bay and is facing new restrictions there due to its prolonged negative impacts.

Menhaden are commonly referred to as “the most important fish in the sea”8 – American recreational and commercial fishermen rely on them because they are the food in the water (“forage fish”) that feeds the fish they catch, like striped bass, bluefin tuna, summer founder, and bluefish, or because they are caught and sold by small boat fishermen as bait to supply our iconic American lobster and blue crab fisheries and recreational anglers all along the Atlantic Coast. Menhaden are

also a critical part of the larger marine ecosystem, converting planktons into biomass that can be eaten by not only larger fish but also humpback whales, dolphins, sharks, osprey and bald eagles.

The threat to the Bight and regional fishermen is now amplified by an ongoing, broader Atlantic Coast forage fish crisis. This crisis has resulted from both the decline in Atlantic menhaden’s population and the collapse in recent years of the other keystone forage species including Atlantic herring, Atlantic mackerel, river herring, and shad. When these fish populations are healthy, they are all important parts of the diet for Bight predators. For example, striped bass, the single most important species to the recreational fishing industry at both the regional and U.S. scales,9 is now classified as overfished due to its population declines. The most recent stock assessment science concluded Atlantic menhaden are so critical to the striped bass diet that to rebuild striped bass populations, significant reductions in the catch of menhaden are required so more are left in the water as food for striped bass growth, survival, and reproduction.10 In addition Osprey, another important menhaden-dependent predator, are having their worst nesting success rates along the all along the eastern seaboard since the U.S. banned DDT in the 1970s.11 Striped bass, osprey, and other fish, bird, and mammal populations in the Bight suffer and cannot rebuild and sustain themselves when reduction fishing occurs.

The Atlantic reduction fishery is carried out by a single foreign-controlled company operating out of Reedville, Virginia. As the fishery has experienced increasing difficulty finding menhaden to catch near its U.S. base of operations on Chesapeake Bay and faces further restrictions there due to its impacts on Bay resources, it is increasingly looking to the north for menhaden in the federal waters of the Bight. The company uses spotter planes, chase-boats, and industrial-scale purse-seine nets to find and rapidly remove the Bight’s schools of Atlantic menhaden. These fish are then taken to a factory in Reedville aboard a “mother ship” or carrier ships where they are ground into fish meal and oil for pet food, livestock feed, and other low value products (thus the term “reduction fishing”). Many of these products are sent overseas or fed to animals here at the expense of American fishermen, who are left with an empty ocean, lost fishing opportunities, and heavy economic losses as the predator fish they seek to catch starve or leave the Bight in search of food.

* * * * * * *

Reduction fishing in the New York / New Jersey Bight is causing substantial ecological, economic, and social impacts to the marine resources, fisheries, and communities of the Bight area. To address this emergency and ensure compliance with the Magnuson-Stevens Act’s National Standards,12 we request that you use your authority to immediately promulgate emergency regulations to halt reduction fishing in the Bight. Emergency action is necessary to protect the Bight and the fishermen and coastal communities that depend on a healthy marine ecosystem supported by robust menhaden populations. To address this problem on a permanent basis, we also request that you exercise your authority under the APA and Magnuson-Stevens Act to initiate informal (notice-and-comment) rulemaking to make the petitioned-for emergency seasonal closure to reduction fishing permanent. When considering this permanent rule, one alternative considered should be to prohibit reduction fishing in all Atlantic Coast waters.

Federal law requires that the Department of Commerce respond to this Petition promptly to “proceed to conclude a matter presented to it,”22 and “fully and promptly consider” the Petition’s merits.23 We have enclosed a letter signed by over 6,200 fishermen and other Americans sent to your office in October 2025 supporting immediate action to protect Atlantic menhaden in the New York / New Jersey Bight. In addition, Executive Order 14276 Restoring American Seafood Competitiveness solicited input from our fishing industry on ways to revitalize American fisheries. The letter from the International Game Fish Association and the Bonefish Tarpon Trust recommending an end to industrial reduction fishing for bait fish is also enclosed.

This Petition presents an opportunity for President Trump and you to demonstrate your leadership by protecting American fishermen and thousands of fishing related businesses. Atlantic menhaden are vital fisheries resources and a linchpin driving Atlantic and national economies. The Bight and the American fisheries the Bight supports require emergency action to protect them from destructive and wasteful industrial reduction fishing during the spring through fall fishing seasons.

Thank you for considering this urgent matter.

Sincerely,

Roger Fleming, Director and Attorney

Blue Planet Strategies

On behalf of

Jersey Coast Anglers Association and Hudson River Fishermen’s Association Hudson River Fishermen’s Association

Hi-Mar Striped Bass Club

Tackle Box Fishing Company

Karen Ann Charters

My Joyce Fishing Charters

Captain Ron’s Fishermen

Moran’s Dockside

Mark Taylor - President, Jersey Coast Anglers Association

Joe Albanese - President, Hudson River Fishermen's Assoc.

Stephan Machalaba - Board Member, Hi-Mar Striped Bass Club

Phil Sciortino - Tackle Box Fishing Company

Vincent Calabro - Karen Ann Charters

Ken Hejducek -My Joyce Fishing Charters

Ron Santee - Captain Ron’s Fishermen

Jim Moran - Moran’s Dockside

1 U.S. Const., amend. I (Congress shall make no law … abridging the … right of people … to petition the  Government for redress of grievances). 

2 5 U.S.C. § 553(e). 3 Magnuson Stevens Fisheries Management and Conservation Act,16 U.S.C. §§ 1801-1884. 4 Reduction fishing is “the practice of harvesting fish, primarily for non-direct human consumption, to be processed  into products such as fish meal, fish oil, and/or fish solubles used in livestock feeds, pet food, oils, and other  industrial products. This contrasts with "bait fishing," where fish are caught for use as bait in other fisheries.” See Atlantic States Marine Fisheries Commission, Atlantic Menhaden Amendment 3, at pp. ii, 10-12 (Nov. 2017). 5 16 U.S.C. 5 U.S.C. § 553(e); 62 Fed. Reg. 44421-42 (Aug. 21, 1997).

6 5 U.S.C. § 553(e). 7 16 U.S.C. § 1855(d). 

8 Franklin, H.B. 2007. The Most Important Fish in the Sea. Island Press/ Shearwater Books. 762 Washington, DC.  268 p. 

9 Striped bass fishing contributes more than $13 billion annually to the U.S. economy and supports more than  100,000 jobs. American Sportfishing Association citing The Economic Contributions of Recreational and  Commercial Striped Bass Fishing, Southwick Associates (2019). 10 2025 Ecological Reference Point (ERP) Benchmark Assessment and Peer Review Report. Atlantic States Marine  Fisheries Commission (ASMFC) and Southeast Data, Assessment and Review (SEDAR) (2025). 11 Watts, B.D., et. al., “Widespread reproductive Deficits in Chesapeake Bay Ospreys” Frontiers in Marine Science (2026); see also Watts, B.D., et. al., “Demographic response of osprey within the lower Chesapeake Bay to  fluctuations in menhaden stock.” Frontiers in Marine Science (2024); Watts, B.D., and C. Hines, “Response:  Commentary: Demographic response of osprey within the lower Chesapeake Bay to fluctuations in menhaden stock.” Frontiers in Marine Science, (2025); Audubon Magazine, Ospreys in the Chesapeake Bay Are Starving to  Death at Disastrous Rates. What Will It Take to Save Them?, (Summer 2026). 12 As explained in the Petition, reduction fishing in the Bight is inconsistent with National Standards,1, 2, 8, and 9.  16 U.S.C. § 1851(a)(1), (2), (4), (8), (9). Addressing this issue would ensure compliance with these Standards and be  consistent with the Act’s emergency action provisions and National Standard 4. Id. at § 1851(a)(4).