Sunday, February 5, 2017


Last Thursday, the Atlantic States Marine Fisheries Commission again demonstrated why it has been unable to restore even a single fish stock over the past twenty years.

In November 2014, ASMFC’ Atlantic Striped Bass Management Board adopted Addendum IV to Amendment 6 to the Atlantic Striped Bass Interstate Management Plan, which has the stated purpose of

“reducing [fishing mortality] to a level at or below the target beginning in 2015…conservation of the strong 2011 year class and conservation of spawning fish to enhance the long-term sustainability of the striped bass resource and the fisheries that it supports.  [emphasis added]”
The Addendum was adopted in response to a benchmark stock assessment released in late 2013, which showed that the striped bass stock had experienced repeated episodes of overfishing over the previous 10 years, and that there was a substantial chance that the stock would become overfished if no remedial action was taken.

Addendum IV established a fishing mortality target of 0.180, and a fishing mortality threshold of 0.219, both substantially lower than previous fishing mortality reference points.  In order to reduce fishing mortality to the target level, coastal striped bass harvest was reduced by 25%, compared to harvest in 2013, while harvest in Chesapeake Bay was reduced by 20.5%, compared to harvest in 2012.

The Addendum seemed to have been achieving at least two of its three goals.  A 2016 Striped Bass Stock Assessment Update revealed that fishing mortality in 2015 had been 0.16, marginally below Addendum IV’s target.  A separate analysis performed by ASMFC’s Atlantic Striped Bass Technical Committee found that coastal harvest, which for the most part targets spawning-sized fish, showed significant decreases of 24.9% in the commercial fishery and 47.0% in the recreational fishery. 

However, efforts to protect the 2011 year class fell short, as the Chesapeake Bay jurisdictions failed to protect those fish from excessive recreational harvest.  Instead of reducing landings by 20.5%, as explicitly required by Addendum IV, the Chesapeake Bay states allowed recreational harvest to spike up by 58.4%.  According to the 2016 Update,
“Coast-wide recreational harvest was dominated by the 2011 (age 4) and 2010 (age 5) year-classes in 2015…Recreational harvest from the ocean states (includes Delaware Bay) was comprised mostly (70%)  of ages 5-10, while harvest in Chesapeake Bay (MD and VA) was dominated by age 4-8 (70%).”

So if the 2011s, which Addendum IV was supposed to conserve, was one of two year classes that dominated the 2015 harvest, if such 2011s were only an important part of the recreational landings in Chesapeake Bay and if Chesapeake Bay anglers increased their harvest by 58%, instead of reducing it by 20.5%, it’s pretty clear what changes, if any, ought to be made in the striped bass management program.

But if you believed that ASMFC would really try to live up to the conservation goals set out in its management plan, or hold a state accountably for flagrantly ignoring its obligation to a public resource, you haven’t been paying much attention to how things are done at the Commission.

Instead of taking actions that might help to insure the stock’s recovery, the Management Board has moved toward relaxing the restrictions imposed by Addendum IV, even though the 2016 Update let everyone know that spawning stock biomass stands at an estimated 58,853 metric tons, well below the 72,032 metric ton target but just slightly above the 57,626 metric ton threshold that defines an overfished stock.

“The Commission’s Atlantic Striped Bass Management Board initiated the development of Draft Addendum V to Amendment 6 to the Atlantic Striped Bass Fishery Management Plan (FMP) to consider liberalizing coastwide commercial and recreational regulations.  The Board’s action responds to concerns raised by Chesapeake Bay jurisdictions regarding continued economic hardship endured by its stakeholders since the implementation of Addendum IV and information from the 2016 assessment update indicating fishing mortality is below the target.”
It’s hard to even discuss such a foolish action.

The Chesapeake Bay jurisdictions, and particularly Maryland, did not want to see the Management Board adopt Addendum IV in the first place.  At the October 2014 Management Board meeting, all four—Maryland, the District of Columbia, Virginia and the Potomac River Fisheries Commission—voted against using the best available science, in the form of the fishing mortality and spawning stock biomass reference points determined by the benchmark stock assessment, to manage striped bass.

They then fought doggedly to prevent a 25% harvest reduction, based on that good science, from being imposed in 2015.  First, they tried to stretch the reduction out over three years, then over two and finally asked for and received special treatment in the form of a 20.5% reduction, instead of the full 25% reduction imposed on all other states.

But no good or thoughtful deed goes unpunished, and despite the Management Board's concession on the size of the harvest reduction, at the November 2015 Management Board meeting, Maryland’s marine fisheries director, Michael Luisi, was already complaining about how

“The charter, the recreational and the commercial industry are suffering greatly as a result of the reduction’s we’ve taken,”
and trying to undo the science-based measures of Addendum IV.

We now know that, at least with respect to the recreational fishery, Mr. Luisi's statement was patently false, given that recreational fishermen suffered no reduction at all, but actually substantially increased their landings in 2015.  Even so his tales of hardship have survived all confrontations they have had with the truth, and formed the basis for last Thursday’s motion to begin relaxing striped bass rules.

However, the motion also relied on a memo from the Technical Committee, which found that regulations could be relaxed to allow a harvest about 10% above 2015 levels, without exceeding the F=0.180 target.  With that memo in hand, the Management Board moved forward, to initiate a new Addendum V.

I have to admit that I have read the Technical Committee’s memo a few times, trying to find anything in it which supports such action. 

To begin, without any change in regulations at all, striped bass fishing mortality for 2016 seems likely to fall somewhere between 0.190 and 0.194, depending on how it’s calculated, which is already above the fishing mortality target.

Based on that, alone, Mr. Luisi already has the 10% increase in landings that he’s been looking for.

The Technical Committee calculated that, in order to bring 2015 landings levels up to a 0.180 fishing mortality rate, between 303,800 and 341,186 additional fish could be killed.  However, it appears that anglers landed more than 500,00 more fish in 2016 than they did in 2015, so based on 2016 landings, harvest would have to be reduced by 6% to keep fishing mortality from exceeding its target.

So, somehow, the Technical Committee decided to effectively ignore 2016’s reality in favor of two theoretical calculations.  One of those assumed that the fishing mortality rate would equal 0.18 in both 2016 and 2017; we already know that fishing mortality was at least 0.19 in 2016, so that calculation already rests on a faulty foundation. 

The other calculation assumes actual F for 2015 and 2016, but again assumes that fishing mortality in 2017 will return to the target level.  Why that assumption was made, rather than an assumption that 2016’s rate of 0.19 would prevail, was never explained.

A look at fishing effort data, as estimated by the National Marine Fisheries Service, suggests that just the opposite would be true.

For the five years between 2010 and 2014, the states between Massachusetts and New Jersey, which account for most of the coastal striped bass harvest, averaged about 4.6 million striped bass trips per year (for the purposes of this discussion, a “striped bass trip” is a trip on which striped bass are the primary target). 

In 2015, that number dropped to less than 3.4 million trips.  

However, for just the first ten months of 2016, anglers in those states had already taken about 3.3 million trips; during the period 2010-2016 (excluding 2012, when Hurricane Sandy disrupted late-season angling activity), New York and New Jersey alone averaged more than 500,000 striped bass trips in November and December, suggesting that the actual number of trips made in 2016 was somewhere in excess of 3.8 million.  (It should be noted that the Technical Committee did try to estimate November/December 2016 landings when calculating 2016 fishing mortality.)

Thus, it is likely that 2015 effort and landings estimates were well below average, and that as a result, 2015 provides a poor baseline to use in predicting future recreational striped bass landings.  The coast will not always make up for the excesses in Chesapeake Bay.  If Addendum 5 is ultimately adopted, such landings could well approach or exceed the threshold, and cause overfishing to occur.

That is particularly true because, as the Technical Committee noted in its recent memo to the Management Board,

“although the assessment is very good, it may not be able to distinguish between fishing mortality point estimates of 0.16 and 0.18.  In other words, the upper and lower bounds of the confidence intervals for both F estimates would essentially overlap.”
Which means that the fishing mortality rate in 2015 may already have been 0.18, and that no underage ever occurred.

And that demonstrates the essential weakness of the ASMFC system.  

Unlike federal fisheries managers, which are required by law to employ the best available science, avoid overfishing and rebuild overfished stocks in a timely fashion, state managers, acting through ASMFC, know no such constraints.

If a manger down in Maryland wants to live a lie, and insist that his recreational fishermen have “suffered” as a result of reductions that never occurred, and if he chooses to halt the recovery of the striped bass stock, and risk pushing that stock down to “overfished” status merely to gain a transient economic advantage for a handful of watermen in his state, he’s free to do so, if he can convince the rest of the Management Board to go along.

Hopefully, the Management Board will, in the end, not be convinced, and will stop the Addendum V process.

However, hope rarely accomplishes much without people working to turn such hopes into reality.  

Right now, there is little to do but stay informed, and let fellow anglers know that this problem has arisen.  But at some point before the May ASMFC meeting, we should get a look at the draft Addendum V.

When we do, we will have to do just what we did when Addendum IV came out—let our state representatives to ASMFC know how we feel.  

We’ll have to go to the hearings, make our thoughts known, and make it clear that we are not willing to let the progress already wrought by Addendum IV be squandered.

The public is entitled to a healthy and fully recovered striped bass stock.

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