Thursday, April 21, 2022

STRIPED BASS AMENDMENT 7: WHERE WE ARE, AND WHAT STILL NEEDS TO BE DONE

We’re less than two weeks away from the next meeting of the Atlantic States Marine Fisheries Commission’s Atlantic Striped Bass Management Board, when the fate of Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass will almost certainly be decided.  The meeting will begin at 11:30 a.m. on Wednesday, May 4, and is scjheduled to run until 5:15 p.m., although the smart money is on the meeting running lasting longer than that.

The comment period closed last Friday, April 15.  As of Monday, April 11, 493 individuals attended hearings held all along the striper coast, and something like 1,500 written comments had been received by the ASMFC.  

That’s a slower pace than we saw a year ago, when the ASMFC received over 3,000 comments on the Public Information Document for Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass.  Hopefully, a lot of last-minute comments were filed during the final week.

It's impossible to know what was said in the written comments, which will be made available next week, but if they track the comments made at the various hearings, we can be cautiously optimistic about how the final amendment will turn out.  A summary of such comments, provided among the materials for the upcoming meeting, reveals a generally strong sentiment for striped bass conservation and a desire to see the Management Board take prompt and decisive action when threats to the stock arise. 

Such summary notes that in Maine, there were

“General comments on the need for conservative, aggressive triggers that require [Management Board] action immediately, proactively, and without delay,”

and an expressed stakeholder

“Desire to rebuild as quickly as possible and maintain abundance.  Public is frustrated at the slow speed of the Commission process.”

The same sentiments were echoed elsewhere on the coast.  In New Hampshire, the summary reports

“General comments on the need for the most aggressive, conservative triggers to rebuild the stock and limiting flexibility,”

and

“Support for acting urgently to improve the stock and maintain abundance in the future after years of past mismanagement, and managing for the best interest of the species.”

Similar comments were reported from Rhode Island, Connecticut, and New Jersey.

However, there were also dissenting voices.  A commenter from Rhode Island bewailed the

“Disturbing trend  of managing for abundance and how that does not align with ecosystem management; also notes concern about declining trend of harvested fish and increased release mortality when striped bass is a valuable source of food…”

At the New Jersey/Pennsylvania hearing, a representative of the Recreational Fishing Alliance

“noted the importance of flexibility when responding to management triggers and that we should not be as reactive as some other fisheries.”

The Recreational Fishing Alliance has historically close ties with the fishing industry, and its comments were typical of many made by representatives of the for-hire fishing fleet. 

In Rhode Island, the Rhode Island Party and Charter Boat Association took a number of positions that were at odds with comments made by the rest of the state’s angling community; they often provided the sole Rhode Island support for measures that promoted Management Board delay or otherwise increased the potential risk to the striped bass stock.

In Connecticut, the

“For-hire fleet wants to keep the measures at the current slot and keep everything else status quo; we already exceeded the expectations of the percent reduction from the Amendment VI slot,”

while in New York, comments were made to the effect that

“The charter industry has already taken reductions and cannot go any lower than 1 fish bag limit; the charter industry is not discarding and emphasizes the value in keeping the fish.”

Still, the entire for-hire industry should not be tarred with the same brush.  The American Saltwater Guides Association, which describes itself as

“a coalition of forward-thinking guides, small business owners and like-minded anglers who…realize that abundance equals opportunity, and that such opportunity is quite a bit more important to the future of fishing than low size limits and full coolers,”

has taken a very strong pro-conservation position on Amendment 7, as have other for-hire operators.  At New York’s Long Island hearing, one charter boat captain correctly observed that

“It’s the fish that’s most important,”

and warned,

“You keep kicking the can down the road, the fish will have no opportunity to recover.”

With respect to the various options contained in the Draft Amendment 7, there was clear stakeholder opposition to proposals that would allow the Management Board to “keep kicking the can down the road.”  226 out of the 308 persons who commented on the issue (73%) want to retain the current requirement that, if fishing mortality rises too high, the Management Board must return it to the target level within one year; 56 out of 57 who commented on a related option (98%) believe that a single year of overfishing should trigger management action, while only the Rhode Island Party and Charter Boat Association supported amending the trigger to delay management action until a two-year average of fishing mortality exceeded the fishing mortality threshold. 

All 49 comments made supported a new requirement that, if a spawning stock biomass trigger was tripped, the Management Board would have to put a rebuilding plan in place within no more than two years.  203 out of 270 commenters (75%) felt that, if a management trigger was tripped, the Management Board should be required to take immediate action, and should not be allowed to defer action under any circumstances.

If those percentages hold up in the written comments, there is reason to hope that the “Management Triggers” section of Amendment 7 will come out in pretty good shape.

With respect to efforts to reduce recreational release mortality, there was some support for an option that would require all states to prohibit all directed recreational striped bass fishing, including catch-and-release, for a two-week period during the height of each state’s striped bass season.  

Because of the wording of the recreational release mortality section, opposition to such closures was difficult to judge, since stakeholders were asked to either select Option A, status quo, which would eliminate all efforts to further reduce release mortality, or explicitly support one or more of the other options; opposition to specific options was not directly solicited.  Nonetheless, 61 of the 493 people attending the hearings (12%) explicitly supported such closures.

That is significantly less than the 172 hearing attendees (35%) who supported  a prohibition on harvest in spawning areas during the spawning season, or the 121 attendees (25%) who supported a two-week spawning area targeting prohibition.  

Of course, given that most states don’t host spawning striped bass, it’s understandable why restrictions on fishing in spawning areas were so much more popular than mandatory closures in every state for, as I’ve noted before, it’s always easier to conserve the other guy’s fish.

The one release mortality issue on which just about everyone agreed was the proposal to ban the use of gaffs or other lethal devices to land striped bass.  It garnered the support of 306 out of 307 who commented on the issue (99.67%), with the Rhode Island Party and Charter Boat Association again being the lone dissenting voice.

The comments related to the rebuilding plan were somewhat surprising.  Two issues were presented in the Draft Amendment 7.  One was whether, in drafting the rebuilding plan, scientists should use the “standard” recruitment model, based on average recruitment, or whether they should assume a low recruitment regime that more closely matched recent recruitment levels.  The other was whether the rebuilding plan should follow the typical course for an addendum to the management plan, a process that usually takes about a year, and would see the plan’s measures adopted for the 2024 season, or whether the plan should be fast-tracked by the Management Board, in which case it would probably be in effect early in 2023.

Given the general support for fast and effective rebuilding, one might think that the low recruitment scenario would have been strongly favored, but that wasn’t the case.  Instead, only 165 of the 276 people who commented, not quite 60%, supported such scenario.  Having said that, it’s probably important to note that 36 of the 111 stakeholders supporting the standard recruitment model (32%), attended a single hearing held in upstate New York, where anglers who fish the Hudson River were strongly opposed to any harvest or targeting closures in spawning areas, and strongly supported the status quo across the board.

A similar pattern emerged with respect to fast-tracking the rebuilding plan, another issue that might be expected to see strong stakeholder support, but was viewed favorably in only 164 of 268 comments (61%).  In that case, 37 of the 104 comments supporting the longer addendum process (36%) were made at the same upstate New York hearing.

It’s likely that the written comments, which originatied from all along the striper coast, will see a marked increase in the percentage of stakeholders supporting both proposals.

Conservation equivalency also had greater than expected support, with 91 out of 227 people who commented (40%) supporting the status quo, which gives the Management Board unlimited discretion to approve conservation equivalency measures.  Once again, upstate New York generated the greatest opposition to change, with 32 of the 91 comments in support of the status quo (35%) coming from that hearing.

Of the comments calling for some sort of restrictions on the use of conservation equivalency, 136 (65%) would prohibit its use when the stock is overfished.  86 comments supported establishing a minimum level of precision for the data underlying state conservation equivalency proposals; of those 31 (36%) supported restricting the percent standard error of such data to 30 or less, 1 (1%) supported restricting the PSE to 50 or less, and the rest expressed no opinion on what PSE should apply.  96 stakeholders supported a related provision, which would establish an uncertainty buffer intended to account for the lower precision of state fisheries data, when compared to coastwide estimates.  Of those, 5 (5%) supported a 10% buffer, 29 (30%) supported a 25% buffer, and 5 (5%) supported a 50% buffer.  Backcountry Hunters and Anglers’ New England Chapter supported a 25% buffer if the data was limited to a maximum PSE of 30, but supported the higher, 50% buffer if a PSE of 50 was allowed.

Finally, stakeholders addressed the question of whether Amendment 7 should include a clear definition of how conservation equivalency should be calculated.  Of the 76 comments, 29 (38%) stated that a state's conservation equivalency measures should achieve the same level of conservation as the standard management measures would achieve in that particular state; no one explicitly supported the option that would only require states to achieve the reduction (or liberalization) that such standard management measures would achieve on a coastwide basis.

Support for the conservation equivalency status quo will probably wane as written comments dilute the comments from the upstate New York hearing, but it is impossible to predict what sort of support the other conservation equivalency-related options will receive.

Now, even though the comment period is over, the job is not done for those concerned with the health of the striped bass resource.  Even if the number of public comments is lagging last year’s pace, it is highly unlikely that many management board members will read every one of the comments received.  Because each state’s delegation will be particularly concerned with the opinions of stakeholders living within such state, it is important for everyone to go to the ASMFC webpage and find thecontact information for their own state’s delegation, and send each member ofsuch delegation a copy of their comments.

While the ASMFC is no longer accepting comments on Amendment 7, there is no reason why a stakeholder shouldn’t contact their state delegates to the Management Board and share their views.  Even those who have already submitted comments can augment those comments when providing them to their state’s representatives.

Based on the comments made--and not made--at the hearings, it might be particularly important to stress the need to include a low-recruitment assumption in the rebuilding plan, to support fast-tracking such rebuilding plan, and to support reform of the conservation equivalency process.  

In states where the for-hire industry has an influential political presence, and opposes needed conservation measures, it might also be important to note that along theentire coast, over the past three years (2019-2021) for-hire trips primarily targetingstriped bass constituted well under 2% of all directed striped bass trips; thus, by far the greatest economic and social benefits gleaned from the recreational striped bass fishery come from shore and private boat anglers.  Given that fact, it makes sense to manage striped bass for the benefit of the vast majority, rather than a small minority, of stakeholders.

Amendment 7 should be finalized in less than two weeks.  If conservation advocates can continue to make their case to the Management Board, and convince it to place the interests of the striped bass resource ahead of the interests of narrow stakeholder groups, there is a good chance that the Board will produce a document that benefits the bass stock.

But if conservation supporters ease up now, and let others have the last word, Amendment 7 could still turn out badly.

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