REBUILDING STRIPED BASS--WITHIN 10 YEARS

One of the most frustrating aspects of the Atlantic States Marine Fisheries Commission’s striped bass management program is the Atlantic Striped Bass Management Board’s repeated failures to put a 10-year rebuilding plan in place, even when it’s called for in the management plan.

Amendment 6 to the Interstate Fishery Management Plan for Atlantic Striped Bass contains two “management triggers” that supposedly require the Management Board to put such rebuilding plan in place.  The first is Management Trigger 2, which reads

“If the Management Board determines that the biomass has fallen below the threshold in any given year, the Board must adjust the striped bass management program to rebuild the biomass to the target level within [no more than 10 years.]”

That trigger is tripped when the stock becomes overfished. 

It has now been over two years since the last benchmark stock assessment, which found striped bass to be overfished, was formally released, but there is not yet a rebuilding plan in place, despite the fact that Max Appelman, ASMFC’s former Fishery Management Plan Coordinator for striped bass, clearly advised the Management Board, at it’s August 2019 meeting, that

“the clock is sort of ticking, and the ten year clock began in May when the information [in the benchmark assessment] was presented to the Board,”

and then later reinforced that message, saying

“The ten-year timeframe, the clock is ticking on that yes.”

The other rebuilding-related trigger, Management Trigger 4, comes into play when the stock is declining in the face of increasing fishing mortality, but has not yet become overfished.  That trigger reads,

“If the Management Board determines that the female spawning stock biomass falls below the target for two consecutive years and the fishing mortality rate exceeds the target in either of those years, the Management Board must adjust the striped bass management program to rebuild the biomass to a level that is at or above the target within [no more than 10 years].”

That trigger was tripped in 2013, after a benchmark stock assessment revealed that the parameters specified in Management Trigger 4 had been met.

But in 2014, as in 2019, no 10-year rebuilding plan was initiated.

In the latter case, ASMFC staff was complicit in the Management Board’s inaction.  Michael Waine, then the Fishery Management Plan Coordinator, advised the Management Board, at its August 2014 meeting, that

“Management Trigger 2 [sic] in Amendment 6 says that you need to rebuild the [spawning stock biomass] back to its target over a specified timeframe that should not exceed ten years.  I think that there is sort of a combination of things happening.  The board is acting to reduce [fishing mortality].  Through that action we see the projections showing that [spawning stock biomass] will start increasing towards its target, but we’re uncomfortable with projecting out far enough to tell you when it will reach its target because the further on the projections we go the more uncertainty that is involved.  Therefore, I think the trend is to get back towards the target, but we can’t tell you just how quickly that will happen.”

Waine’s comment explain why it is so difficult for the ASMFC to rebuild the striped bass resource. 

Both in 2014 and in 2019, the rebuilding triggers were not the only management triggers that were tripped; triggers requiring reduced fishing mortality also came into play, and on both occasions, the Management Board did take action to reduce fishing mortality to or below the target. 

The prevailing attitude seems to be that, if fishing mortality is reduced to target, rebuilding will eventually take care of itself. 

At one of the Plan Development Team meetings held earlier this summer, to put together some options for the draft Amendment 7, we saw the same kind of thinking when one of the Technical Committee members somewhat condescendingly said (I may get the precise words wrong, but I know I’ve captured the spirit)

“What a lot of people don’t understand is that when we reduce fishing mortality to target, rebuilding is going to occur.”

We actually understand that fact just fine.  But what the Management Board, maybe some Council staff, and perhaps even some Technical Committee members don’t understand is that when Amendment 6 sets a 10-year deadline to rebuild the stock, and says that the stock “must” be rebuilt during that timeline, then rebuilding the stock in some longer timeframe, whether it's 13 years, 15 years, or some enigmatic “eventually” isn’t good enough.  Stakeholders want to see the stock rebuilt more quickly than that.

It’s not unreasonable to expect the Management Board to do what it said it would do in its own amendment.

Certainly, stakeholders would celebrate if they did.  When the Management Board solicited public comment on what the draft Amendment 7 should address, changing the 10 year timeline—except, perhaps, to make it shorter—didn’t seem to be atop anyone’s agenda.  There were 529 comments, made in writing and at public hearings, to keep the current 10-year rebuilding timeline, 45 to make it shorter, and none explicitly calling for stretching things out; even it we made the assumption that all of the comments to change the fishing mortality and spawning stock biomass triggers supported a longer rebuilding period, they would constitute just 18 out of 592 comments made, or about 3% of the total.

Emilie Franke, the current Fishery Management Coordinator, noted in her report to the Management Board that

“A majority of comments support maintaining the 10-year rebuilding timeline with a few comments supporting a faster rebuilding timeline.  Many comments noted concern there is not yet a rebuilding plan in place to the address the current overfished status of the stock.  Commenters noted that the Board should adhere to this rebuilding requirement as specified in Amendment 6 and should act quickly to implement a rebuilding plan to address the overall status tock [sic] by 2029 (10 years after the last benchmark stock assessment results were adopted for management use).  Many commenters expressed a need for urgency to implement a rebuilding plan and take action in response to triggers more quickly.”

So delaying rebuilding beyond 10 years certainly isn’t doing the stakeholders any favors.

But what about the comments that Waine made back in 2014, that there is too much uncertainty to put a 10-year rebuilding plan in place?

Frankly, they just don’t fly.

While uncertainty certainly increases the farther out in time one goes, federal fisheries managers, bound to the rebuilding timelines set by the Magnuson-Stevens Fishery Conservation and Management Act, have been able to work with 10-year rebuilding timelines since 1996. 

Initiating a 10-year rebuilding plan is, in practice, a good way to combat uncertainty, because with a plan in place, the stock’s rebuilding progress can be compared to pre-existing benchmarks for its recovery, and the rebuilding plan amended if needed to get the job done.  Waine reassured the Management Board that “The board is acting to reduce [fishing mortality].  Through that action we see the projections showing that [spawning stock biomass] will start increasing towards its target…the trend is to get back towards the target, but we can’t tell you just how quickly that will happen,” but, in the end, the stock didn’t increase at all.

Instead, it continued to decline, in what may have been the clearest possible example of uncertainty causing real harm.

If there had been a rebuilding plan in place, the ongoing decline probably could have been detected, and the matter addressed, much sooner than it was.

Of course, amending a rebuilding plan in mid-course goes against the ASMFC’s predilection for letting even unsuccessful management actions continue on for half a decade or so before trying to fix things, and certainly offends the Management Board’s desire for “management stability” and “flexibility.”

But bureaucratic concerns should never get in the way of rebuilding a fish stock.  After all, keeping fish stocks healthy and sustainable in the long term are the bureaucrat’s primary duties, even if accomplishing such goals might make them work a little harder along the way.

So it’s past time for the Management Board to start taking striped bass rebuilding seriously.  Instead of merely reducing fishing mortality to the target level, andt hoping that the spawning stock biomass will grow as a result, it should also be calculating the reduction in fishing mortality needed to rebuild the stock within the 10-year deadline, and then draft management measures that implement whichever reduction is greater.

And if the Management Board could do that with a 60 or 65 percent probability of rebuilding the stock within 10 years, instead of its usual 50% probability of failure, that would be a good idea, too.