“to develop a white paper that could inform a future
management document. The Work Group
should include representation from all sectors in addition to scientists and
managers. The goal of this Work Group is
to consider how to update the [fishery management plan’s] goals, objectives,
and management of striped bass beyond 2029, in consideration of severely
reduced reproductive success in the Chesapeake Bay. The Work Group should utilize public comment,
including that received during the Addendum III process to inform its research
and management recommendations and work with the Benchmark [Stock Assessment
Subcommittee] to incorporate ideas and deliver necessary data products. Work group discussions should include the
following topics:
·
Review [biological reference points] and
consider recruitment-sensitive, model-based approaches.
·
Formally review hatchery stocking as both a
research tool and a management tool for striped bass w/cost analysis.
·
Evaluate the potential for other river systems
to contribute to the coastal stock.
·
Explore drivers of recruitment success/failure
in Chesapeake Bay, Delaware, and the Hudson in light of changing climatic and
environmental conditions, including potential impacts from invasive species.
·
Explore the reproductive contribution of large
and small female fish and the implications of various size-based management
tools.
·
Methods to address the discard mortality in the
catch-and-release fishery.”
That gives the Work Group a very broad mandate to
investigate, and provide recommendations on, striped bass management issues,
and creates the potential for the Work Group to have a very positive or a very
negative impact on striped bass management, and the long-term health,
sustainability, and structure of the striped bass stock. As is so often the case, it will all depend
on how the Management Board decides to structure and constitute the Work Group,
an issue that it will discuss when it meets at 8:30 next Wednesday morning
(February 5).
One of the most important questions is who will be included among
the Work Group’s members. The
ASMFC has adopted guidelines, titled the “Work Group Meeting Standard Operating
Practices and Procedures,” which sets the outer limits for membership, saying
“Membership should be a limited subset of Board members
approved by the Chair of the Board or the Board itself. Ideally, members will represent diverse
perspectives on the issue at hand. WGs
can request non-Board members to provide information to the WG but will not be
members of the WG itself.”
That last sentence could create some problems. As a recreational striped bass fisherman, I’m
particularly sensitive to that possibility, for while the motion creating the Work
Group stated that “The Work Group should include representation from all
sectors in addition to scientists and managers,” the unfortunate truth is that,
apart from a few people from New England and perhaps one more from Pennsylvania,
I don’t believe that there are any independent recreational fishermen on the
Management Board.
There are plenty of commercial fishermen, and
representatives of the for-hire fishing industry, as well as representatives of
recreational industry-affiliated organizations such as the Coastal Conservation
Association sitting on the Board, but finding even one recreational fisherman who
isn’t beholden to the for-hire or tackle or boating industries in one way or
another, and is willing to represent the shore-based and private-boat anglers’
point of view, might not be an easy job.
Some of the state fisheries managers do a pretty good job of
representing such anglers’ concerns, but while it’s nice that others might be
willing to speak on your behalf, it’s always better to be able to speak for
yourself. But given the composition of the
Management Board, that might be hard for anglers to do.
The fact that the motion directed the Work Group to update
the fishery management plan’s goals and objectives is also something of a red
flag. Right
now, Amendment 7 to the Interstate Fishery Management Plan for Atlantic
Striped Bass states that
“The goal of Amendment 7 to the FMP is to perpetuate, through
cooperative interstate fishery management, migratory stocks of striped bass; to
allow commercial and recreational fisheries consistent with the long-term
maintenance of a broad age structure, a self-sustaining spawning stock; and
also to provide for the restoration and maintenance of their essential habitat.”
It's not particularly clear what in that goal would need to
change, even in view of the recent poor recruitment in the Chesapeake Bay and
elsewhere on the coast. Goals, after
all, are aspirational, representing an end that one hopes to achieve, despite
whatever obstacles lie in the way.
Continued poor recruitment might, for example, make it more difficult to
maintain a “broad age structure” in the population. Yet managing for some other goal—say,
sacrificing the larger, older females in order to maintain a higher fishing
mortality rate—would only make the stock more vulnerable to unexpected changes
in fishing mortality or environmental conditions, something that would be
patently unwise at low recruitment levels.
Similar arguments could be made for keeping the objectives
unchanged. According to Amendment 7
“In support of [the] goal, the following objectives are
specified:
1. Manage striped bass fisheries under a control
rule designed to maintain stock size at or above the target female spawning
stock biomass level and a level of fishing mortality at or below the target
exploitation rate.
2.
Manage fishing mortality to maintain an age structure that provides
adequate spawning potential to sustain long-term abundance of striped bass
populations.
3.
Provide a management plan that strives, to the extent practical, to
maintain coastwide consistency of implemented measures, while allowing the states
defined flexibility to implement alternative strategies that accomplish the
objectives of the FMP.
4.
Foster quality and economically-viable recreational, for-hire, and
commercial fisheries.
5.
Maximize cost-effectiveness of current information gathering and
prioritize state obligations in order to minimize costs of monitoring and management.
6.
Adopt a long-term management regime that minimizes or eliminates the
need to make annual changes or modifications to management measures.
7.
Establish a fishing mortality target that will result in a net increase
in abundance (pounds) of age 15 and older striped bass in the population,
relative to the 2000 estimate.”
While it might be difficult, and even practically impossible,
to maintain female spawning stock biomass at the target level in the face of
continued poor recruitment in the Chesapeake Bay, such poor recruitment would make
it even more important that fishing mortality remain at or below the target, to
keep spawning stock biomass from falling even further. And striving to maintain an age structure
adequate to support the greatest possible abundance becomes an even more
important objective under such circumstances, for with a
dearth of young bass entering the population, the remaining older fish might be
needed to jump-start a recovery when favorable spawning conditions finally
occur, as they were needed to initiate the recovery of the late 1980s.
The
Board also addressed the “goals and objectives” issue when Amendment 7 was
being drafted five years ago. At that
time, public comment was solicited on the question, and 1,719 of those comments
(98.4%) supported the goals and objectives that are currently in the plan,
while only 28 supported change. Given
such lopsided opinion, it seems unreasonable to open up that discussion again.
Those issues aside, the bullet points included in the motion
raise some interesting issues which, when answered, could well assist future
management efforts.
The issue of biological reference points might be the most
interesting of all.
Right
now, the reference points used to manage the striped bass stock aren’t truly “biological,”
in the sense that they weren’t developed from the model used to assess the
stock. Instead, they have been termed “empirical”
reference points, based on the estimated spawning stock biomass in 1995, the
year that the once-collapsed striped bass stock was deemed to be fully recovered. Such reference points are based on
observation, as the reference points calculated by the model during the last
benchmark stock assessment were deemed to be “unrealistic.”
It is possible that, when the 2027 benchmark stock
assessment is conducted, the model used—which might or might not be the same
model used the last time—will produce calculated biological reference
points. If that occurs, such calculated
reference points should certainly be adopted to manage the stock. However, if the model again returns “unrealistic”
reference points, then reference points based on 1995 spawning stock biomass
ought, again, to be used.
Regardless of how the reference points are calculated, we
should all understand that they are going to change from those
now in effect. It is virtually certain
that the spawning stock biomass reference points will be lowered, and that the
fishing mortality reference points will be amended to match that change. That’s because
the Marine Recreational Information Program’s estimates of recreational effort,
catch, and landings are going to be revised ahead of the 2027 benchmark
assessment, to correct for a previous overestimation of recreational effort,
which inflated catch and landings data.
Since the estimate of spawning stock biomass is, in part, dependent on
the estimate of recreational catch and landings, once the MRIP estimates are
reduced, the estimate of biomass is going to go down, too.
That’s not a bad thing, but rather a natural step in
biologists’ quest for the most accurate data.
But what we do need to look out for is one or more members
of the Work Group trying to influence that group to lower the biomass target and
threshold in an effort to increase commercial and/or recreational
landings. In
the past, we’ve seen some Management Board members, in particular Michael Luisi
of Maryland and John Clark of Delaware, try to do so, arguing that the current
reference points are too high because the biomass target has only been reached
for a few brief years in all the past few decades.
The
flaw in their argument is that, during much of the time since 1995, and in 11
of the 14 years between 2004 and 2017, the striped bass stock was experiencing
overfishing; there were few if any years since the stock was first declared to
be recovered when fishing mortality was at or below the target level. With fishing mortality at such high and
unsustainable levels, it was near-miraculous that the biomass ever rose to a
level even close to the target, even for just a few years. But with fishing mortality kept to or below
the target level, and assuming that recruitment also returns to historical
patterns, a biomass target of 125% of 1995 levels isn’t unrealistic at all.
Of course, there is also a real chance that recruitment
might remain at lower levels, due to changing environmental conditions in the
Chesapeake Bay. But should that prove to
be the case, raising the fishing mortality target would be an even riskier, and
even more foolish, thing to do.
Even before the Work Group is organized, the
Board will have the opportunity to suggest “alternative” reference points that could
be be included in the upcoming benchmark stock assessment, probably as soon as
the February 5 meeting. So the issue
of reference points may be one of the most urgent items that the Worg Group will
consider.
The remainder of the bullet points in the motion raise
equally legitimate questions, which have either emerged in the public
discussions—such as the
popular, if patently incorrect argument that the decline in recruitment in the
Chesapeake Bay isn’t too important, because the Chesapeake bass are just moving
north and spawning in some yet-unidentified northern rivers—or are going to
be key issues of striped bass management discussions going forward.
In the end, the output of the Work Group may depend largely
upon the input given by its members, and those members are yet to be
chosen. Despite the clear language of
the “Work Group Meeting Standard
Practices and Procedures” document, there
is at least a suggestion that non-Board members may be included in the Group,
as a Work Group related document provided ahead of the February 5 meeting asks
the questions
“1. What is the
maximum size of the WG to ensure the group will function effectively?
2. Will each WG seat
be allocated by category type to ensure representation of the full management
range and diversity of stakeholder interests?
3. Will there be a
specific nomination process, e.g. each state can nominate x number of
participants?
4. How will
individuals be chosen?”
Such language neither limits Work Group participation to
Board members nor clearly includes non-Board as Work Group members,
but seems to at least suggest that non-Board members might be considered.
If that proves to be the case, we can only hope that independent
anglers will be adequately represented.
After all,
in 2024, the recreational sector accounted for about 85% of all striped bass fishing
mortality, and within
the sector, shore-based and private boat anglers accounted for about 98.5% of
all recreational trips. Such anglers
are, by far, the largest group of stakeholders, both in numbers and in impact,
in the overall striped bass fishery. They
have their own views and concerns, which are not the same of the industry
organizations who might seek—and even claim—to represent them.
In any equitable process, independent shore-based and
private-boat anglers must be allowed to speak with their own voice.
They do not seek to dominate the conversation, or to have every
issue decided in their favor. But as the
largest of all of the stakeholder groups in the striped bass fishery, they have
the right to a seat at the table, and to have their voice carry at least as
much weight as those of the for-hire, tackle, and boating industries, who in
the end depend on individual anglers for their very survival.
It is up to the Board to ensure that the right things are done.
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