THE FIRST, SMALL STEPS TOWARD STRIPED BASS REBUILDING

Last Tuesday, the Atlantic States Marine Fisheries Commission’s Atlantic Striped Bass Plan Development Team met to discuss the next iteration of the Draft Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass, which draft is likely to be reviewed, and very possibly released for public comment, when the Atlantic Striped Bass Management Board next meets during the week of January 24, 2022.

Due to a conflicting conference call, I was unable to listen in on most of the PDT meeting.

I wasn’t able to hear the discussions, if any were held, about the management triggers, or protecting the 2015 year class, nor did I hear how the PDT might have addressed conservation equivalency or reducing recreational release mortality.

But I was able to catch the final, and to my way of thinking, most important discussion:  How to rebuild the striped bass stock.  While that discussion was very preliminary, and merely erected the sparsest skeleton of a plan that will have to be fleshed out over the next couple of months, what little was said makes me believe that the PDT is trying to move things in the right direction.

The discussion began with a slide that laid out the options, as discussed at last month’s Management Board meeting.  It read

“Rebuilding Plan Options

·        “Option A status quo: Implement management measures designed to achieve F target as calculated in the 2022 assessment update.  F target is calculated to achieve the SSB target in the long term.

·        “Requirement (implied status quo): Achieve SSB target by 2029.

·        “Option B: Implement management measures designed to achieve F rebuild under the low recruitment assumption as calculated in the 2022 assessment update.  F rebuild is calculated to achieve the SSB target by 2029 using the low recruitment regime assumption.

·        “Other options?

“--F rebuild under average recruitment (typical assessment assumption)

“Others?

“Note: F rebuild may or may not be lower than F target”

Given the Management Board instructions to the PDT, that’s about what I had expected to see.  Options A and B reflected specific scenarios described in the Board’s motion to initiate the rebuilding plan, and since that motion didn’t limit possible options to just the two that it mentioned, the “Other options” line was not out of place.

If that initial slide formed the framework for the rebuilding plan, and the foundation for the PDT’s later work, I would not have been displeased, even though it clearly set the stage for a long and probably difficult effort on the part of rebuilding advocates, to keep the Management Board from backsliding.

But as things turned out, the initial slide led to a productive discussion, in which Max Appelman, who now represents the National Marine Fisheries Service on the Management Board, but was formerly the ASMFC’s Fishery Management Plan Coordinator for Atlantic Striped Bass, expressed a view of the status quo different from what the slide portrayed.

Mr. Appleman stated that, in his view, the status quo included the Management Board’s obligation to rebuild the currently overfished female spawning stock biomass to its target level by 2029, as required by Amendment 6 to the Interstate Fishery Management Plan for Atlantic Striped Bass.  He went on to state that the fishing mortality target, referred to as “F target” in the slide’s “Option A,” doesn’t form a part of the contemplated rebuilding plan, which is all about restoring the spawning stock biomass to its target within the specified timeline.

Such comment probably didn’t come as a surprise to anyone familiar with Mr. Appelman’s work as Fishery Management Plan Coordinator.  Unlike his predecessor, Michael Waine, who actively and successfully tried to convince the Management Board not to initiate a 10-year rebuilding plan back in 2014, despite Amendment 6’s clear requirement that it do so, Mr. Appelman properly and repeatedly reminded the Board of its rebuilding obligation after the 2019 stock assessment revealed that the striped bass was overfished.

Still, it was good to hear him remind everyone of that obligation.

It was also good to see that, as a result of his comments, the slide’s Option A was changed to read

“Option A: Requirement (implied status quo):  Achieve SSB target by 2029.  F rebuild is calculated to achieve the SSB target by 2029 using the average recruitment assumption.  [emphasis added]”

That’s a significant change.  Instead of merely trying to hold  fishing mortality to the target level—something that the Management Board has historically failed to do, largely because it repeatedly adopted management measures that, at best, were as likely to fail as succeed—and hope that the spawning stock biomass would, at some uncertain point in the future, return to its target as a result, the new Option A language recognizes the Management Board’s clear duty to rebuild the stock by 2029.

Given the recent spate of below-average recruitment, it’s easy to criticize the “average recruitment assumption” part of Option A, but every management plan must contain a status quo option.  In any event, by the time the rebuilding plan goes into effect, the Management Board will have had yet another year of recruitment figures to consider, and if the Marylandjuvenile abundance index is as bad in 2022 as it was in 2019, 2020, and 2021(and in 2012, 2013, and 2016 as well), we can only hope that it will see the wisdom of assuming low recruitment during the rebuilding years, too.

The problem, of course, is that no one can predict what the Management Board will ultimately do.  Based on its past performance, it’s not unreasonable to expect it to try to find some way to wiggle out of some or all of its rebuilding obligations, particularly if faced with extremely onerous rebuilding requirements.

And that's probably what it will face.

While the Plan Development Team went out of its way to note that “F rebuild may or may not be lower than F target," it is very likely that, in order to rebuild the stock in only six years—Amendment 7’s management measures are expected to take effect in 2023 so, despite the Mr. Appelman warning, back in 2019, that “the clock is ticking,” the Management Board chose to squander at least 3 years of rebuilding time—the measures needed to get the job done will be very restrictive, particularly under the assumption that current low recruitment will continue through the rebuilding years. 

Simon Brown, a PDT representative from Maryland commented that rebuilding the stock by the 2029 deadline, under a low recruitment scenario, could very well require a negative fishing mortality rate, which is obviously impossible to achieve.  Even assuming that Mr. Brown’s comment was an intentional exaggeration, it nonetheless expressed a core truth:  Achieving rebuilding by 2029 is going to be very, very hard.

It is probably going to be so hard, and will probably require such stringent restrictions, that I expect the usual conservation skeptics on the Management Board—representatives from New Jersey, Maryland, Delaware, and the Potomac River Fisheries Commission—to make every effort to defeat, or at least water down, the rebuilding plan.

And I expect it to be so hard that some, and perhaps many, Management Board members who have so far supported rebuilding to have second thoughts not about the need to rebuild, but about the 2029 deadline and/or the low recruitment assumptions.

The Plan Development Team has already designated a rebuilding plan that includes the 2029 deadline, but assumes average recruitment, as “Option A,” so we know that will be part of the draft amendment that the PDT presents to the Management Board.  I’m certain that some Board members, trying to seek a middle ground, will support that option over Option B’s low recruitment scenario, argue that no one can be certain that low recruitment will continue throughout the rebuilding years, and also raise the point that assuming average recruitment is the norm in most stock assessments and management plans.

I’ll also be very surprised if we don’t hear at least a few Management Board members contend that the ten-year rebuilding period should begin in 2023, when the management measures are implemented, and not in 2019, when the stock was declared overfished. 

But for those are debates for another day.

What matters right now is that the Plan Development Team seems to be making a good faith effort to craft a rebuilding plan that will get the job done by 2029.  For that effort, they deserve thanks and support, even though we all know that the real fight looms early next year, when the Management Board has its say.