As I noted in last Thursday’s edition of One Angler’s Voyage, 2021 was a half-decent year for marine fisheries management. Some things that happened were good, some weren’t bad, and none were truly awful.
But 2021 is now history.
Looking forward to 2022, there are a number of pending issues that can do real good for fish stocks if we get them right; a number
of those also have the potential to do real harm if the powers that be get them
wrong.
Over the next week, I will discuss a few of those
issues. Today, the focus is on striped
bass.
Getting Amendment 7
right
Unless something completely unexpected happens, the Atlantic
States Marine Fisheries Commission will finalize Amendment 7 to the Interstate
Fishery Management Plan for Atlantic Striped Bass sometime in 2022.
The most likely timeline would see a draft of the amendment approved
by the Atlantic Striped Bass Management Board at its next meeting, which will
be held on January 26. After approval,
the draft amendment will be released for public comment. Hearings will be held, likely in webinar
format, during February and/or March.
Once the comment period closes, all comments received will be assembled
and tabulated by ASMFC staff, and presented to the Management Board before its
May meeting, where a final version of Amendment 7 will be approved and
adopted. The management measures
contained in the amendment will then become effective on January 1, 2023.
That schedule isn’t cast in stone. An issue could arise at the January meeting
that causes the Management Board to again remand the draft amendment to the
Plan Development Team for additional work. If that happens, all subsequent events would
be pushed back a few months. However, final approval and adoption
of Amendment 7 should still occur in plenty of time for implementation by January
2023.
Whenever the draft amendment is released, stakeholders
concerned about the future of the striped bass should be ready to provide their
comments.
The good news, as I mentioned last Thursday, is that the biggest threats to the bass have already been
stripped out of the draft amendment. The
only really problematic options that remain are some changes to
the management triggers that determine when the Management Board must respond
when threats to the striped bass stock arise.
Currently, if a stock assessment or assessment update
reveals that the stock is overfished or experiencing overfishing, a management
response is immediately triggered.
Some of the options in the draft amendment would only require the Management Board to act if two, or possibly three, years of data confirm that a such threats exist, while another, particularly bad option would completely eliminate the spawning stock biomass trigger, and place all of the focus on managing fishing mortality.
A propensity to delay taking action is already the
Management Board’s defining flaw. While
such delay might cause relatively little harm when the biomass falls a little
below, or fishing mortality rises above, the relevant target, as the Board will still have some time
to avert a crisis, allowing delay once biomass falls below, or fishing mortality rises above, the threshold, meaning that the stock is overfished and/or experiencing overfishing, is a very different matter. At that point, the crisis has already
occurred, and further delay can only make the situation worse.
To put it another way, biomass slipping below or fishing
mortality rising above their respective target levels ought to be seen as a
yellow flag for fishery managers; it’s a time to figure out what’s going wrong,
and prevent things from getting worse, but it isn’t a sign of immediate
danger. If things take a couple of years
to figure things out, no lasting harm will be done.
But when a threshold level is breached, that’s a clear red
flag that signals imminent peril. At
that point, it’s time for managers to immediately stop what they’ve been doing
and take action to keep the stock from crashing.
Those who support building additional delay into the
management triggers point to the uncertainty in estimates of both fishing
mortality and biomass. While stock
assessments provide a single point estimate for both, they also include a
“confidence interval,” a range of values above and below the point estimate,
that represents the likely uncertainty in managers’ calculations. Given such uncertainty, it is always possible
that the point estimate overestimates fishing mortality and/or underestimates
spawning stock biomass, and that threshold-based triggers haven’t really been
tripped.
Thus, the argument goes, by averaging the point estimates
over two or more years, managers will be better able to determine whether a
threshold has actually been exceeded.
While such argument isn’t wrong, it also reveals the
Management Board’s bias against taking action.
While the Board worries that a single year’s point estimate might be
overestimating fishing mortality or
underestimating biomass, and so might lead them to take management action when
no such action was strictly required, it never seems too concerned that the
point estimate might be underestimating fishing mortality or overestimating
biomass, and that it failed to take management actions that were, in fact,
needed, because a threshold had, in reality, been crossed.
One could grow very old waiting for someone on the Management Board to argue “the fishing mortality (or biomass) value hasn’t crossed the threshold yet, but it’s so close that we probably ought to do something now, because if we consider the uncertainty, the trigger might have already been tripped.”
Instead, the Management
Board seems to always prefer the option that provides for more delay.
In that respect, the option that completely eliminates the
spawning stock biomass trigger is particularly bad. Not surprisingly, it is an option favored by
Maryland fishery manager Michael Luisi who, over the past five or so years, has
stood as an implacable opponent of many management measures favored in
stakeholder comment, including the current spawning stock biomass target and
threshold. At the October 2021
Management Board meeting, he argued that since fishing mortality was the only
thing that the Board could truly control, management triggers should be focused
on such mortality; achieving target fishing mortality should, in theory,
also eventually rebuild the spawning stock biomass.
That sounds good in theory.
It was the
same argument that Michael Waine, then the ASMFC’s Fishery Management Plan
Coordinator for striped bass, made to the Management Board in August 2014, when
he advised them to ignore Amendment 6’s mandate to initiate a 10-year
rebuilding plan. But looking at
where we stand today, it’s pretty clear that ignoring the spawning stock
trigger back then didn’t do any good for the bass.
In fact, there are badly overfished stocks that are not
suffering from overfishing, yet are also not being successfully rebuilt. Winter
flounder are a good example. They have
all but disappeared from the southern New England/mid-Atlantic region, but the latest stock assessment found that while
the stock is overfished, overfishing is not occurring. That has been the case for at least the last
decade, and probably longer (the assessment data only goes back to 2010) yet,
not only is the flounder stock showing little sign of recovery, but spawning
stock biomass is actually shrinking; SSB in 2019 was 35% smaller
than it had been ten years before.
Clearly, maintaining fishing mortality at or below target is
not necessarily enough to guarantee the health of a stock.
That’s why it will be important for stakeholders to turn out
in big numbers to oppose any management triggers that will encourage Management
Board delay.
Stakeholders may also want to express their feelings about
proposed measures aimed at reducing recreational fishing effort in an effort to
reduce recreational release mortality.
While reducing release mortality is, in itself, a good thing, some
Management Board members, including the aforementioned Michael Luisi, have
built it into a sort of red herring, singling it out as a major threat to the striped bass stock.
“The source of mortality does not matter to the health
of the stock, as long as the overall fishing mortality is below the
threshold. [emphasis added]”
Instead of trying to limit recreational striped bass
releases, and in doing so limit some of the social and economic benefits
derived from the resource, it probably makes more sense to admit that in a fishery in which
anglers are responsible for 90% of the fishing mortality, and release 90% of
their catch, release mortality is always going to be a substantial, and
that managers should control fishing mortality by restricting recreational
harvest, rather than recreational effort.
But once some management trigger and recreational release mortality
options are
addressed, the rest of the draft Amendment 7 can only benefit the striped bass
stock.
Stakeholders will have an opportunity to comment on options
that will amend the current recruitment trigger, that is tripped when poor
spawning occurs. The current trigger
only addresses true recruitment failure, defined as recruitment indices that
fall into the lower quarter of all historical data—including those from the
stock collapse years of the late 1970s and 1980s—for three consecutive
years. It’s a standard so stringent
that, for Chesapeake-spawned bass, it would have only been tripped once or
twice in the past 60 years. Proposed options,
if adopted, would eliminate older data, including those for the collapse years,
from the time series used to gauge recruitment failure, calculate the values
needed to trip the trigger differently, and require the Management Board to
reduce fishing mortality if the trigger is tripped.
Such changes would better assure a prompt response to
spawning problems.
Other options would limit states’ ability to use
“conservation equivalency” to adopt regulations that allow them to escape their
full share of the conservation burden.
Some would limit when conservation equivalent measures could be used,
and prohibit them when the stock is overfished, experiencing overfishing, or in
a rebuilding stage. Others would impose
a cost on states that opted for conservation equivalent regulations, in the form of larger harvest reductions, to account for the greater uncertainty that is unavoidable when managers use
state-level, rather than coastwide, catch and landings estimates. The worst of the options would maintain the
status quo; while it ought to be rejected, even if adopted, it would not make
things any worse.
That option deserves support.
Once the Management Board meets in January, we’ll know what
the draft Amendment 7 will look like, and have a better idea of the comments
that need to be made. The comment period
is likely to begin five or six weeks from now, and stakeholders ought to be
prepared.
And rebuilding the stock
Amendment 7 will probably contain language that requires
striped bass to be rebuild by 2029. What it will not contain is a clear rebuilding plan.
As things stand right now, the Management Board will wait for a stock assessment update to be released this fall. Based on the information provided in that
update—in particular, the spawning stock biomass, fishing mortality rate, and
projected stock trajectory at the end of 2020—managers will be able to craft
management measures likely to rebuild the stock by the 2029 deadline.
From a biological perspective, that approach makes a lot of
sense. From a management perspective, it
has one major flaw: It adds delay to the
rebuilding process. There is a good
chance that, while Amendment 7 will become effective on January 1, 2023, the
rebuilding plan, which will take the form of a new Addendum, won’t take effect
until a year later. Rebuilding the stock
in just 5 years will not be an easy thing to do.
That being the case, it will be important to keep the
Management Board focused not only on the need to rebuild, but on the need to
rebuild by the 2029 deadline. There will
certainly be plenty of loud objections that such deadline is unrealistic and
that draconian harvest cuts will be needed to achieve rebuilding by then.
That may be so.
But all of those problems could have been avoided if the
Management Board had chosen to initiate a rebuilding plan back in 2019, when
the stock was declared overfished.
Delay, in the end, has its costs, and the bill may be coming
due.
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