Earlier this week, the American Sportfishing Association,
the fishing tackle industry’s largest trade association, came out in opposition
to the primary conservation measures included in the Draft Addendum III toAmendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bassfor Public Comment. The purpose of
Addendum III is to rebuild the currently overfished striped bass stock to its
target level by the end of 2029, as explicitly required by the Atlantic States
Marine Fisheries Commissions striped bass management plan.
Rebuilding the stock will require a 12 percent reduction in the
current fishing mortality rate, a reduction that, in the recreational ocean
fishery--which encompasses all recreational striped bass fishing outside of the
Chesapeake Bay--can only be achieved by adopting a some sort of closed season,
as the current one-fish bag limit and narrow, 28- to 31-inch slot size limit
cannot, as a practical matter, be made more restrictive.
“Speak Up for Striped Bass—Tell ASMFC to Reject Seasonal
Closures
“The Atlantic States Marine Fisheries Commission (ASMFC) is
considering new restrictions for striped bass for 2026, proposing a 12%
reduction for the recreational sector, which would require additional
seasonal closures to achieve the reduction.
The closures even consider “no targeting”, which prohibits anglers from
fishing for striped bass, whether harvesting fish or practicing catch-and-release.
“Additional seasonal closures are being proposed even though
the current striped bass fishing mortality is at a 30-year low, well
below both the fishing mortality target and threshold. ASMFC is reacting to short-term swings in
recreational catch estimates from the Marine Recreational Information Program,
a survey that NOAA Fisheries admitted overestimates fishing effort due to
design flaws.
Click the link below to tell the ASMFC to reject new seasonal
closures and support status quo management.
[emphasis in original]”
It was the sort of thing that one has come to expect from the American Sportfishing Association, which has frequently demonstrated that it is more interested in exploiting fish stocks in a manner that maximizes short-term sales and the resultant short-term profit, without regard for the long-term health of fish stocks.
The ASA had already telegraphed its intentions to hamper
striped bass recovery efforts, the first time probably being when Michael
Waine, its East Coast spokesman, appeared on a podcast to say,
“We’re in a rebuilding period for the striped bass
population. The trajectory is good right
now, the rebuilding trajectory.
(Remember that you’ve got to take all this with a grain of salt. I think it’s better to talk about
trajectories rather than talk in absolutes given the uncertainties.)
“So we have an increasing trend in the striped bass, but we
know on the horizon there’s been poor recruitment in the Chesapeake Bay, which
is a major spawning area for striped bass and that’s been a good indicator of
future, or what the fishery will look like in the future, right. You cannot catch an adult striped bass
without starting with a lot of babies.
We know these, what we call ‘poor year classes,’ that have been spawned
over the past five years are coming down the road, meaning when the fish get large
enough to be a part of our fishery, that we’re catching, there are going to be
fewer of them, and so the question becomes, like what do we do in the meantime,
to plan for that?
“And so that coupled with very ambitious conservation goals, very
ambitious, like we’re trying to rebuild the striped bass population to a level
that it has rarely ever been to in the history of striped bass, that we’ve been
measuring. And so the question becomes
like how far are we willing to go from a management and policy side to
meet these very ambitious conservation goals, and you can see the byproduct of
that, we have a very narrow slot limit…We want to make sure…that
management is aware of the headwinds but also allows for access for anglers to
go out and catch a fish, and so how do we balance these values? How do we balance building back a population
to a conservation level that we call all agree on, which we never likely will,
with fishing access, with the ability to actually go out and catch these fish,
and what worries me, worries me specifically is like we’ll go too far, meaning
we’ll actually tell people to stop fishing for striped bass, which is
where I think everyone loses…”
While those comments left at least some room to give ASA the
benefit of the doubt as to their intentions, Waine’s
comments at the December 2024 meeting of the ASMFC’s Atlantic Striped Bass
Management Board, when he argued against the Management Board adopting measures
to protect the above-average 2018 year class--which managers are depending on
to help rebuild the striped bass spawning stock--made it clear that the
American Sportfishing Association had decided to oppose additional conservation
measures:
“I think giving the [then-proposed] addendum the opportunity
to consider this more thoroughly [rather than adopting regulations that would
go into effect in 2025 to protect the important 2018 year class, which will
otherwise be very vulnerable to recreational fishermen], really develop options
that the public can consume and provide input on is the best way best path
forward [sic]. You know, I think about you guys know I am a part of a
lot of these fisheries management discussions, and this is probably the most
unique fishery that ASMFC manages, especially recreationally.
“I look at the public comments, and I know that there’s
millions of striped bass anglers out there.
Millions. And I’m only seeing
twenty-five hundred comments from a lot of the same people that we know have
been commenting. And so, as an
organization, we’re going to work with our members to try to get more people
integrated into this process. We know that
the recreational fishery is very diverse, and I don’t feel the public comments
really are a good reflection of that diversity.
And so, where is the opportunity to get those individuals into the
process?
“Where is the opportunity to give folks the chance to
get involved and engaged?...Don’t talk to the same folks that you’ve been
talking to all the time. Find the people
who care about this resource, and value it in a way that their voices should be
heard too. And that’s what we’ll do as
an organization ourselves.
[emphasis added]”
It’s interesting to note, in retrospect, that Waine’s
justification for not taking immediate action to conserve the 2018s was based
on his—and so ASA’s—support for initiating the management action that we now
know as Draft Addendum III-- the same management action that the
American Sportfishing Association currently opposes.
Looking back, the real message in Waine’s December comments
was his promise to “to work with our members to try to get more people
integrated into this process,” a promise that we now see coming to fruition in
the ASA’s recent call, expressed in Policy Watch, for people to oppose
new striped bass conservation measures.
With that in mind, it’s also interesting to see the message that
the American Sportfishing Association is providing to people who click on the “Take
Action” link provided in Policy Watch, to see just how the ASA is trying
to recruit supporters to its anti-conservation campaign:
“Protect Recreational Access to Striped Bass: Oppose Unnecessary Fishing Closures…
“Additional seasonal closures are not needed. Strict recreational fishery management using
a narrow slot limit has effectively lowered fishing mortality to a 30-year low
which is well below the target and threshold needed for rebuilding.
“So why push new restrictions? ASMFC is reacting to short-term swings in
recreational catch estimates from MRIP, a survey NOAA Fisheries has already acknowledged
overestimates fishing effort due to design flaws. In fact, the entire case for the proposed 12%
reduction is based on a difference of 0.01 in fishing mortality—well within the
margin of error and scientifically indistinguishable from the current management
approach.
“Instead of acknowledging this uncertainty, ASMFC is
proposing a lose-lose choice: accept closures that ban fishing completely
or unfairly burden anglers who prefer to legally harvest fish. These measures create unnecessary division in
the angling community.
“The recreational striped bass fishery drives billions of
dollars in economic activity, supports tens of thousands of jobs, and sustains
countless small businesses up and down the Atlantic coast. An additional 12% reduction would devastate
the recreational fishing economy while doing very little to improve the health
of the fishery.
“The message is clear:
New restrictions based on unreliable data, that are not scientifically
distinguishable from status quo, threaten both angler access and the economy.
“Tell ASMFC to reject new closures and maintain status quo
management. Comments are due no later than
October 3. [emphasis in original]”
It’s a remarkable collection of half-truths—and it’s easy to
argue, some “untruths,” too—so it’s worth taking the time to go through the
comments line by line to see just where they fall short.
Let’s start with the biggest “untruth” of all—OK, let’s be honest
and just call it a blatant lie—"Additional seasonal closures are not
needed.”
That’s just plain wrong.
That memorandum begins, in relevant part,
“Draft Addendum III projections were initially developed and
discussed by the [Technical Committee] in March 2025…The projections were
updated in May 2025 to incorporate final MRIP estimates for 2024 and initial
commercial harvest estimates for 2024 provided by the states. This resulted in a 7% increase in 2024
removals driven by the 7% increase in final MRIP estimates…
“Even though 7% is a relatively small increase, with the
preliminary MRIP estimates falling within the 95% confidence interval of the
final estimate, this resulted in a higher estimate of [the fishing mortality
rate in 2024] which propagated through to the estimates of [the fishing
mortality rate for 2025] and [the fishing mortality rate for the years
2026-2029] due to the assumptions of those years relative to F2024… [internal references omitted]”
After looking at the final recreational data, the scientists
making up the Technical Committee concluded that, when the 7% increase in
removals is carried forward through 2029—which it must be, because the removal
estimates for the years 2025-2029 are based on removals in 2024—the likelihood
of rebuilding the stock by the end of 2029 falls from an dubiously adequate 49
percent to a clearly unacceptable 30 percent.
Of course, when confronted with those figures, the American
Sportfishing Association might ask why it is so important to rebuild the stock
by 2029, and perhaps the best answer to that question would be, “Because the
management plan says so.”
Amendment
7 to the Interstate Fishery Management Plan for Atlantic Striped Bass clearly states,
“If female [spawning stock biomass] falls below the
threshold, the striped bass management program must be adjusted to
rebuild the biomass to a level that is at or above the target within an
established timeframe [not to exceed 10 years].
[emphasis added]”
Since the last benchmark stock assessment, accepted by the
Management Board in 2019, found that the female spawning stock biomass had fallen
below the threshold by 2017, the stock “must” now be rebuilt by
2029.
It’s entirely possible that the ASA wouldn’t consider that a
particularly convincing argument, given that Waine
told the Management Board, at its August 2014 meeting, that it didn’t have to
initiate a 10-year rebuilding plan even after a similar trigger in Amendment
6 to the Interstate Fishery Management Plan had been tripped because, with
the fishing mortality rate reduced to the target level,
“the trend is to get back toward the target, but we can’t
tell you exactly how quickly that will happen.”
Of course, we now know that Waine was far too optimistic, the “trend” was not “to get back toward the target” at all, and the next stock assessment found that striped bass were badly overfished.
It’s not hard to believe that if Waine, who
was the Fishery Management Plan Coordinator for striped bass at the time, had
instead upheld the clear language of the management plan, and reminded the
Management Board of its duty to initiate a rebuilding plan when the management
trigger was tripped, the bass would be in a far better place than they are
today.
But, apparently, being burned once was not enough to impart
the needed lesson, for we again find Waine—or, at least, Waine’s employer, the
American Sportfishing Association—opposing the actions needed to best ensure
timely rebuilding.
It should be noted at this point that adhering to the provisions of the management plan isn’t an arbitrary action. When, after hearing public comment—which, in the case of Amendment 7, supported the management triggers—the Management Board includes a provision in the management plan, it is entering into a moral covenant with the public, promising them that they will manage the striped bass according to the plan’s terms.
By asking the
Management Board not to adopt the harvest reduction needed to rebuild the
striped bass stock by the 2029 deadline, the American Sportfishing Association
is asking the Management Board to renege on that promise, and violate the trust
that the public may have in the management process.
It would thus be an ethically fraught action. Should the
Management Board comply with the ASA’s request, it could only
undercut the public’s already shaky confidence in the current management
process, and in the ASMFC itself.
The ASA’s next statement, that “Strict recreational fishery
management using a narrow slot limit has effectively lowered fishing mortality
to a 30-year low which is well below the target and threshold needed for
rebuilding,” achieves the dubious distinction of including a two half-truths—one
of which comes close to a complete falsehood—in a single sentence.
The near-falsehood is that the current fishing mortality
target and threshold is all that is “needed for rebuilding.” The
current fishing mortality threshold is 0.21, and the fishing mortality target
is 0.17. However, to
rebuild the stock by the end of 2029, the Technical Committee informs us that
fishing mortality must be reduced to 0.122, and to achieve that fishing mortality rate in the years
2025-2029, the 12 percent reduction is needed.
Again, the American Sportfishing Association could, if it
chose, play word games, and point out that it said that the current target and
threshold are all that’s “needed for rebuilding,” not
“needed for rebuilding by 2029.”
But that’s where the half-truth comes in. For while
it may be true that fishing mortality is the lowest that it has been in 30 years,
what the ASA doesn’t say is that in those 30 years, fishing mortality has been
well over target, and often over threshold, and should never have been
allowed to get so high.
Viewed in that context, getting fishing mortality down to
the lowest level in 30 years doesn’t seem like such an impressive achievement.
The other thing that the ASA doesn’t mention is that, while
fishing mortality may be the lowest in 30 years, the
recruitment of new striped bass into the population has been extremely low,
with recruitment in the Maryland portion of the Chesapeake Bay, the single most
important spawning area on the entire coast, over the past six years the worst
six-year period in the 68-year history of the Maryland juvenile abundance survey.
So no, current fishing mortality is not low enough to ensure
rebuilding. Further landings reductions
are needed.
At this point, the American Sportfishing Association’s
arguments against additional conservation measures start getting a little more
technical, although they still veer away from the full and accurate story.
Take the claim that “ASMFC is reacting to short-term swings
in recreational catch estimates.” That
is, on the whole, true. But what the ASA
doesn’t say is that, for the most part, those short-term swings have shown fishing
mortality headed downwards.
Thus,
total striped bass removals fell from about 6.8 million fish in 2022 to 5.6
million fish in 2023 to 4.1
million fish in 2024, with the declines largely driven by declining
recreational catch and landings.
So if the American Sportfishing Association is trying to impeach
the current recreational data because it only reflects “short-term swings,”
what it’s really questioning—whether the ASA realizes it or not—is whether recreational
removals are really declining substantially, as the MRIP data
shows.
They probably ought to have second thoughts about that line
of argument, because it clearly doesn’t support their premise that no further
landing cuts are needed.
The
only significant short-term increase in the 2024 MRIP data—which made a
substantial contribution to the 7% increase in estimated recreational removals
in the final MRIP data compared to the preliminary estimates—wasn’t, in
substance, an increase at all. It came
about after preliminary MRIP data, which showed that New York anglers made only
442,911 trips primarily targeting striped bass in November and December of
2024, was revised upward in the final MRIP data, to 845,711 trips. ASA might want to throw that change into
question and pass it off as just an artifact of an uncertain data-gathering process, but given that the 2022 estimate
for the same two-month “wave” was about 1.09 million trips, and the 2023 estimate
was 867,384, simple logic would argue that the final 2024 estimate of
845,711 trips, which is close to the estimate for the two previous years, is probably
much closer to the actual figure than the preliminary estimate of a mere
442,911.
And as to ASA’s claim that MRIP is “a survey NOAA Fisheries has already acknowledged overestimates fishing effort due to design flaws,” the whole truth again lies in the things that ASA failed to say.
For yes, NOAA Fisheries has found that MRIP appears to overstate recreational effort, and so also recreational catch and landings (although, according to comments made by NOAA Fisheries personnel at the Highly Migratory Species Advisory Panel meeting on September 3, the magnitude of the overages is substantially less than the 30 to 40 percent originally estimated, the greatest level of error occurred in the winter when effort was substantially less, with far less error during the busiest part of the fishing season, and the degree of error was less in the case of boat fishermen than it was in the case of surfcasters).
However, because
the MRIP data is one of the inputs used in the stock assessment to determine
the size of the striped bass biomass, if recreational catch and landings are
actually less than the current MRIP estimates, than the size of the striped
bass biomass is actually smaller than calculated in the most recent stock
assessment.
We can see how that works in the two most recent benchmark
stock assessments.
The
2012 assessment, used the now obsolete Marine Recreational Fisheries
Statistical Survey data, which tended to underestimate recreational catch, effort,
and landings, as one of its inputs. It advised that the female spawning stock
biomass was 61,500 metric tons, between the biomass target of 73,380 metric
tons and the biomass threshold of 57,904 metric tons. However, the
2018 benchmark stock assessment, which replaced the old MRFSS data with data
derived from MRIP, which returned substantially higher estimates (now believed
to be overestimates) of recreational catch, effort, and landings, estimated female
spawning stock biomass to be slightly higher, at 68,476 metric tons, but also
found the stock to be badly overfished, since the new, higher estimates of
recreational removals caused the biomass threshold to be recalculated, and it increased from
57,904 metric tons to 91,436.
So, if recent recreational landings were actually lower than
the MRIP estimates, as the ASA claims (and they probably were), that means that
the striped bass spawning stock is also lower than the latest stock assessment
suggests, and that reference points will need to be changed as well.
The bottom line is that lower recreational removals do not
justify the ASA’s call to maintain such removals at their current level.
The American Sportfishing Association’s assertion that “ASMFC
is proposing a lose-lose choice: accept closures that ban fishing completely or
unfairly burden anglers who prefer to legally harvest fish. These measures create unnecessary division in
the angling community” may be its most bizarre claims of all. While “no target” closures would ban all
striped bass fishing during the term of such closure, it’s not clear why “no
harvest” closures, which permit catch-and-release during the closed season, “unfairly
burden” anglers who might want to keep a bass.
Such no-harvest closures are generally accepted in the
fishing management and the angling communities.
Here in New York, we have had such no harvest closures in our striped
bass fishery since at least the 1990s. In
federal waters off New York’s coast, they exist for shortfin mako sharks and
other prohibited shark species, and for bluefin tuna during the closed season. In New York’s fresh waters, no harvest
seasons that allow catch-and-release fishing exist in the recreational
fisheries for trout and both largemouth and smallmouth bass.
Other states have adopted similar rules.
To date, few if any anglers have complained that such
seasons “unfairly burden” anglers who might want to harvest fish. They just require all anglers—and
most anglers do harvest fish from time to time—to wait for the season to open
before taking fish home. That is, after
all, how closed seasons are supposed to work.
For ASA to grasp at straws and claim that a traditional tool
of fisheries management has some how become “unfair” when applied to striped
bass does little but demonstrate the weakness of its overall position.
And to claim that closed seasons somehow cause division in
the angling community is just downright strange. If anything might cause outrage and division,
it is the American Sportfishing Association’s opposition to needed striped bass
conservation efforts, for most dedicated striped bass anglers care deeply about
their favorite species’ future.
For the true losing proposition is being presented by the
ASA: Maintaining status quo regulations
in the face of an overfished stock and historically low levels of recruitment,
and so exposing the striped bass stock, and striped bass anglers, to the very
real risk of a stock collapse at least as severe as the one that we experienced
half a century ago.
Which, finally, gets us to the American Sportfishing
Association’s motivation for opposing conservation measures, a motivation that
exposes just how foolish its opposition really is.
It all comes down to money.
The ASA notes that “the recreational striped bass fishery
drives billions of dollars in economic activity, supports tens of thousands of jobs,
and sustains countless small businesses up and down the Atlantic coast.”
And yes, that’s true.
The recreational striped bass fishery is the single most important salt
water recreational fishery to be found anywhere in the United States which,
given that no other nation hosts as large a recreational fishery as the U.S.
does, means that it’s the most important salt water recreational fishery in the
entire world.
And from the vehement, if deceptive, arguments that its
making, it’s pretty clear that the ASA isn’t willing to see even one of those
billion dollars generated by the fishery lost, even temporarily, to
conservation efforts.
Which is short-sighted and, to be frank, remarkably stupid.
Because MRIP data clearly demonstrates that striped bass
fishing activity is generated not by the number of dead bass that anglers can
put on the dock, but by the number of live fish they can find in the
water. Abundance generates effort, and
effort generates revenues.
From 1995 through 2014, the recreational ocean fishery was
generally governed by the same set of regulations—a two-fish bag limit, 28-inch
minimum size, and no closed season. Some
states veered away from that, but even in those states, regulations generally
stated the same through the years. Yet
if we look at the effort data compiled by MRIP, we see directed striped bass
trips increase steadily from 1995 through 2006 or 2007, then begin a long
decline; the number of trips taken corresponds almost perfectly with the
changes in striped bass biomass, as regulations went unchanged.
Thus, we—and the Management Board—would do well to
completely ignore the ASA’s ludicrous claim that “An additional 12% reduction
would devastate the recreational fishing economy.” The ASMFC acknowledges
that
“The recreational fishery is primarily prosecuted as catch
and release, meaning the majority of striped bass caught are released alive
either due to angler preference or regulation…Since 1990, roughly 90% of total
annual striped bass catch is released alive.”
To suggest that a 12 percent reduction in landings is going
to “devastate the recreational fishing economy” in a fishery where 90 percent
of the fish caught are already released is to stretch credibility to, and then
well beyond, the breaking point.
To put it as politely as I can, the American Sportfishing Association’s
arguments against the 12 percent reduction called for in Addendum III are a
towering sculpture composed solely of bullsh*t and greed, authored by a trade
organization so desperate to preserve short-term profits that it would risk a
stock collapse that really would devastate the salt water sportfishing
industry.
Because no one goes fishing if there aren’t any fish.
And if people don’t fish, they don’t buy fishing gear.
That seems to be a point that the ASA is forgetting.
But I don’t forget the last stock collapse, when bass were
nearly as scarce as unicorns, and I could fish for a week and only catch one or
two.
The other thing that I can remember—and the ASA ought to
remember, too—was that back when there were no bass, you could spend a day on the
water and never deal with crowds.
The fishermen all stayed home.
Not surprising from a business-focused organization with short-term business impact concerns...maybe the move here is to boycott those companies represented by the ASA's Board: TackleDirect, AFTCO and Z-MAN
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