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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