ADDENDUM III: THE STRIPED BASS COULD LOSE THIS ROUND

 

The Atlantic States Marine Fisheries Commission’s Atlantic Striped Bass Management Board will meet all day next Wednesday—October 29—to debate Addendum III to Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass, and there’s probably at least a 50-50 chance that its decision won’t bode well for the resource.

I say that for a number of reasons.

The issue of closed seasons—something never imposed on the coastwide striped bass fishery before—has clouded the conservation debate, with many anglers seemingly more concerned with when and if they will be able to fish than whether they will have anything to fish for when they do.  The possibility of a “no-target” season, when even catch-and-release would be illegal, has proven to be a particular distraction.  Many of the comments sent in respect off Addendum III emphasize opposition to no-target closures over support for a reduction in striped bass landings.

And, at least in the second and third “waves” (March through June), both angler effort and catch has been far lower than expected.  In preparing the draft Addendum III, both the Striped Bass Technical Committee and the Plan Development Team assumed that recreational removals—the combination of landings and fish that died after release—would increase by 17% this year, due to the above-average 2018 year class growing into the coastwide 28- to 31-inch slot limit.  Instead, preliminary Marine Recreational Information Program data indicates that angler effort was down about 25% compared to 2024, while recreational catch fell even more, by about 48%.  It’s not hard to predict that some Management Board members are going to use those figures to argue that additional management measures will not be needed to get fishing mortality down enough to rebuild the stock by 2029, as the management plan requires.

Finally, the majority of the public comments received by the ASMFC support maintaining current regulations, and oppose the proposed 12% reduction.  That was somewhat surprising, given that in the case of other, recent management actions, most notably Amendment 7 to the Interstate Management Plan for Atlantic Striped Bass, which was adopted in May 2022, and Addendum II to Amendment 7 to the Interstate Management Plan for Atlantic Striped Bass, which was adopted in January 2024, more than 90% of all comments supported more restrictive management measures.

In total, 2,722 comments urged the Management Board to maintain the current management measures, while 1,775 asked that it impose a 12% reduction in both commercial quota and recreational removals.  Another 28 people felt that the commercial quota should not be reduced, but seemingly had no issues with imposing a reduction on the recreational fishery.

But those overall numbers are somewhat misleading.

When it came to individual comments, 330 people appeared at public hearings to oppose the 12% reduction; except in New Jersey, where angler opposition to the proposed conservation measures was high, most of those arguing for status quo were either commercial fishermen or members of the party and charter boat industry.  Only 81 hearing attendees supported the 12% cut.  However, individual letters were skewed in the other direction, with 1,175 individual letters opposing the 12% reduction, and 1,423 supporting it.

Adding all of the individual comments together, the public’s sentiments were almost perfectly split, with 1,505 individuals supporting the status quo, and 1,504 supporting the conservation measures.

However, members of the various sectors of the fishery responded in very different ways.  The summary prepared by Emilie Franke, the ASMFC’s Fishery Management Plan Coordinator for striped bass, notes that

“When possible, staff tracked individual comments on the reduction by sector/mode as self-identified by the commenter:  private recreational angler, for-hire, commercial.  Some commenters (19%) were part of other stakeholder groups or did not indicate their sector/mode.  Of those other/unidentified comments, 54% were in favor of status quo 46% in favor of a reduction.

“Of the identified private recreational anglers, 39% were in favor of status quo and 61% were in favor of a reduction.

“Of the identified for-hire, 73% were in favor of status quo and 27% were in favor of a reduction.

“Of the identified commercial, 97% were in favor of status quo and 3% were in favor of a reduction.”

However, when it came to form letters, petitions, and similar documents, 1,187 persons appear to be in opposition to any reduction in commercial quota or recreational removals, while just 249 were in support, and it were these form letters and multi-signature documents that skewed public comment so heavily toward the status quo side.

And it was just two such documents, a form letter prepared by the American Sportfishing Association and a somewhat mysterious—it’s hard to know what to call it—petition or set of sign-on sheets only identified by the ASMFC as “South Shore of Long Island Form Letter,” and by its originator(s) as “Striped Bass Status Quo Management Support Sheet (Addendum III), but identifying no preparator or originating organization, together accounting for 1,145 of the 1,187 form letter comments in favor of status quo.

The significant divergence of opinion, particularly within the recreational sector, along with the nature off the form letters, raises an interesting issue, of whether every comment should be given equal weight, or whether some consideration should be given to not only the level of thought and effort underlying the comments, but also to the contribution, in terms of effort expended and the social and economic benefits derived from the striped bass fishery.

As an example of the latter, for-hire vessels—party and charter boats combined—were responsible for about 1.42% of all directed striped bass trips in 2024.  Yet, at most of the public hearings, and certainly the hearing in New York, the for-hire industry accounted for most of the people in the room, even though, in New York, they represent an even smaller proportion of the fishery, making only 0.94% of all directed striped bass trips in 2024.  Despite their very small role in the recreational striped bass fishery (although it should be noted that for-hire landings, at more than 9% of all recreational harvest, are vastly disproportionate to for-hire effort), the various for-hire organizations did a very good job turning out their members at public hearings and inspiring their members to submit written comments; although no for-hire organization seems to have circulated a form letter for its members to use, the similarity of wording of many letters sent by for-hire operators (particularly in Massachusetts) makes it clear that the for-hire opposition to the proposed 12% reduction was well-coordinated.

The opposite is true of private recreational fishermen.  Although they were responsible for over 98% of all directed striped bass trips in 2024, and thus undoubtedly generated the lion’s share of the social and economic benefits accruing from the recreational striped bass fishery, private anglers were underrepresented at both the public hearings and in the written comments.

Thus, members of the Atlantic Striped Bass Management Board should give real thought to the question of whether the comments of for-hire operators should be given the same weight as those of private anglers, or whether some consideration should also be given to the importance of each mode within the recreational sector, and the weight given each comment balanced accordingly.

We face the same question with regard to form letters. 

At the December 16, 2024 Management Board meeting, Michael Waine, who speaks for the American Sportfishing Association with respect to East Coast matters, made depreciating comments with respect to the private anglers who had repeatedly supported needed conservation measures, saying

“…And 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.”

He promised,

“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…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.”

Waine was true to his word, using contacts in the tackle industry and the angling press to find recreational fishermen opposed to striped bass conservation measures, feed them a load of misleading, one-sided information, and direct them to a website that would allow them to send a form letter opposing the 12% reduction in removals to the ASMFC, which received 660 such form letters (with another 269 ASA form letters being tabulated as individual comments, because the senders didn’t settle for the original form, but enhance it with their own comments).

There was no organization with the reach and resources of the American Sportfishing Association that worked to gather comments of anglers who supported striped bass conservation measures.  Backcountry Hunters and Anglers, an organization of conservation-minded sportsmen with most of its membership in inland states, did its best, gathering 239 form letter comments. 

However, the only organization with both the capacity and the resources to mount a coastwide effort—and the one that, at one time, probably would have done so—the Coastal Conservation Association—long ago abandoned its former role as an advocate of striped bass conservation, and instead sided with the members of the tackle and boating industries that buy ads in its magazine and donate product to its fundraising auctions, joining in a letter with the American Sportfishing Association, Boat U.S., the Center for Sportfishing Policy, the National Marine Manufacturers Association, and the Marine Retailers Association of the Americas to oppose the 12% reduction and support the status quo (it’s probably notable that the only state CCA chapter to comment on the issue, CCA New Hampshire, split with the national organization and called for the 12% reduction in removals to be adopted; given the position of the national CCA office on striped bass, the most important recreational species in New England and the mid-Atlantic states, it’s difficult to understand why anyone living between Maine and Virginia would continue to keep paying membership dues).

So, again, a question arises for the Management Board.  How much weight ought it give the American Sportfishing Association form letter, when it knows that such letter was the product of a directed campaign, and that there was no similar campaign to support needed conservation measures.

The other big form letter—really, more like a petition or sign-on letter—raises questions of a very different sort.

The biggest ones are:  Who put the form together and distributed it?  Who are the people who signed it?  And, what are the signatories’ connections to the striped bass fishery.

There is no indication on the form as to who put it together.  As noted above, it is called a “Striped Bass Status Quo Management Support Sheet.”  It contains a list of four assertions which sound a lot like those made by the American Sportfishing Association, such as

“Status quo management is the most equitable option.  It will minimize further economic harm to businesses…”

“Anglers that prefer to harvest fish should not bear the overwhelming conservation burden when catch-and-release practices contribute to a significant portion of total mortality.”

And

“No-Target and No-Harvest options unnecessarily put anglers against each other creating a lose-lose scenario.”

So maybe the petition, sign-on letter, or whatever one wants to call it was an extension of the American Sportfishing Association campaign, promoted by one or more Long Island businesses.  But looking at the way the sheets were signed, and the number of individuals who identified themselves as coming not from the South Shore of Long Island, or anywhere else in New York, but instead from the neighboring states of Connecticut and New Jersey and, in a few cases, from states as far away as Georgia and Florida, my guess is that the signatures were gathered by one or more party boats that solicited their customers at some point during a trip.

And that’s fine, although the Management Board really ought to understand who those signatories are before taking the sign-on sheets at face value.  A lot of the signatures are completely illegible, and there is no indication that the folks who signed have any connection to the striped bass fishery.  After all, the deadline for submitting comments was October 3, and on one of the signature sheets, the first people to sign thought the column that read “STATE” said “DATE” instead, and wrote in dates of 9/19/25 and 9/20/25.  At that time, South Shore party boats were fishing for fluke (summer flounder) and black sea bass, not striped bass, which raises the question of whether the signatories were participants in the striped bass fishery at all, or whether they just signed the sheets because they were asked to, and had no well-considered opinions about the striped bass fishery, and Addendum III, at all.

Again, those are things that the Management Board ought to consider when looking at the public comment on Addendum III.

But just how many Management Board members will consider such things is impossible to predict.

The Management Board members who understand the plight of the stock, who are trying to minimize the chances that the stock will collapse once again, are going to vote their consciences, and vote for conservative management that will give the stock the best chance to rebuild, and even if rebuilding doesn’t occur, to maximize striped bass abundance until such time as more favorable spawning conditions occur.

And the Management Board members who serve as the voice of the commercial and for-hire fisheries, and perhaps or the tackle and boating industries as well, are going to oppose any additional management measures, in an effort to maximize the short-term profits of the commercial and recreational striped bass fisheries, even if the data and the scientific advice recommend a far different course.  Such individuals will sympathize with the charter boat captain who commented,

“I was concerned, as I listened to some members of the [Advisory] panel make their arguments, that they were under the impression that the board’s directive is to save the Striped Bass.  We are dealing with a species that has its own path regardless of human interaction.  Species will increase and decline, and also become extinct if they can’t adapt to changes in the environment.  Unfortunately, human interaction, both direct and indirect, has had an effect on the Striped Bass population.  It is the job of the ASMFC and the Mid Atlantic Council to be management boards.  It is their job to MANAGE the striped bass stock in order to give the greatest access, while balancing the health of the SSB with the socio economic impact of reducing mortality.  We are managing, not saving!”

 

Thus, the outcome of Addendum III is going to depend on the Management Board members who sit somewhere in the middle, those inconsistent advocates who sometimes support conservation measures and sometimes oppose them out of concern for their impacts on the recreational and/or commercial fishing industries.

How they consider the debate over the timing of seasons and the question of no-target versus no-harvest closures, how much they are concerned about the future of the striped bass in the face of continuing low recruitment, how willing they are to believe that lower recreational catch and effort will lessen the need for management action, and how they value the public comment will ultimately decide whether the centerpiece of the draft Addendum III, the 12% reduction in removals, is adopted by the Management Board.

Right now, as I consider past debates and look at the positions that have been previously taken by members of the Management Board, I believe that the question of whether fishing mortality will be reduced, or whether current management measures will remain in place, will be decided by a very narrow vote.

And as I consider the outcome of that vote, I find that I can’t predict whether the Management Board will rise to the occasion, and take action to conserve the striped bass resource, or whether it will take shelter in the current uncertainty, and maintain the status quo.

The striped bass may very well lose, and find themselves on an increasingly perilous road, where stock collapse becomes an ever more likely destination.

And at this point, there is little that anyone can do to change the outcome.  We can only wait until next Wednesday, and see whether wisdom or mindless profligacy prevails.