Sunday, November 26, 2023



Striped bass anglers have less than a month left to comment on Draft Addendum II to Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass, a document that represents the last remaining hope for rebuilding the striped bass spawning stock biomass by the 2029 deadline.

The bad news is that, so far, anglers have not been showing up at scheduled hearings in the hoped-for numbers, and in some cases are having their voices all but drowned out by those of the for-hire fleet which, even in this time of spawning failure and a threatened stock, is still trying to convince the Atlantic Striped Bass Management Board to grant its customers special privileges not enjoyed by the rest of the recreational fishing community.

The good news is that the angling organizations which have opined on the Addendum II options all seem to be headed in the same direction, and agree on the major issues, and thus are placing the health of the resource ahead of their parochial interests.

So far, four unaffiliated organizations—the American Saltwater Guides Association, Stripers Forever, Theodore Roosevelt Conservation Partnership, and Jersey Coast Anglers Association—which have frequently been at odds over other fisheries issues, have published their positions on Addendum II, and there is virtually; no difference between them.  A fifth organization, the American Sportfishing Association, the largest fishing tackle trades association, has released a more limited position addressing only two of the Addendum II issues, but to the extent that it takes a position at all, ASA is also in accord with the general consensus.

I discussed the Addendum II options in detail in an earlier post, along with my own views on their merits, but now that a number of major angling organizations have also provided their views, it’s probably worthwhile to review the options one more time, along with such organizations’ comments.

The first set of options, designated Section 3.1.1 of the Draft Addendum, addresses the ocean recreational fishery which, despite the “ocean” designation, deals with all recreational fisheries except for those in the Chesapeake Bay—and even there, Maryland’s so-called “trophy fishery” is governed by the ocean fishery rules.  The key choice to be made is whether Addendum II should perpetuate the current 28- to 31-inch “emergency” slot that the Management Board adopted last May, or whether it should instead adopt a larger, 30- to 33-inch slot with would make some portion of the big 2015 year class—the same year class the emergency measure was adopted to protect—vulnerable to recreational landings.

All four organizations that took a position on the issue agree that the Management Board should adopt Option B, which would keep the current 28- to 31-inch slot limit in place, and minimize the number of 2015s that are landed by anglers.  The American Saltwater Guides Association explained its position, saying that

“ASGA supported the Emergency Action measure, and we still do.  It is critical that managers continue efforts to protect the 2015 year class and maintaining the 28-31” slot achieves that goal, while providing some consistency for anglers and the stock assessment scientists.”

Section 3.1.1 also addresses the contentious issue of “sector separation,” that is, allowing one sector—in this case, anglers patronizing the for-hire fleet—to enjoy special privileges not extended to any other anglers.  With respect to such proposals it’s probably significant to note that the Guides’ Association—the only one of the organizations created specifically to represent the owners and operators of for-hire vessels along the entire Atlantic coast—has come out in clear opposition to the concept of sector separation, noting

“We do not support mode splits.  The Recreational sector (private and charter/for-hire) should continue to be managed under the same regulations.”

Stripers Forever provided more detailed comments on the issue, saying

“There are three goals here; the greatest overall reduction, protecting the 2015 year class and making sure it’s done in a fair and equitable way…Option C and D [sic] introduce mode splits.  Essentially, recreational anglers are split into ‘private vessel/shore’ and ‘for-hire’, it is not the right thing to do now or ever.  Since the inception of Amendment 7, we have heard from the board and law enforcement that no harvest and no target closures would be too difficult to enforce, the same applies here.  All recreational anglers should make an equitable effort to reduce harvest and restore the Striped Bass stock to abundance.”

The Jersey Coast Anglers Association, put an interesting spin on the sector separation question in the set of model comments they released on November 23, suggesting that anglers comment that

“I don’t like options C or E [the sector separation options] as they give a wider ranged slot to the for-hire sector.  I’m adamantly opposed to sector separation but if anything, more lenient regulations should be for shore-based anglers who fish for sustenance and can’t afford to go on a boat.”

If fairness is a consideration, it’s difficult to argue with the JCAA’s position.  Even with today’s narrow slot limit, it’s still far easier to bring home a legal fish from a for-hire vessel than it is to catch one from shore—or, given the relative knowledge and skill of the captains, even from the typical private boat—which casts the equity of the two sector-separation options into serious question.  Even though the American Sportfishing Association’s members sell tackle to both private and for-hire anglers, the ASA stated that

“To rebuild the striped bass population—let alone maintain a rebuilt condition—the entire striped bass fishery must participate in conservation and continued poor recruitment reinforces that point.  ASA urges managers to…set equal limits for all recreational fishing modes as it finalizes Addendum II to the Fishery Management Plan this winter.  [emphasis added]”

The Theodore Roosevelt Conservation Partnership also opposed the concept of sector separation, observing,

“Often called mode split or sector separation, a request for these options was made by participants in the for-hire realm of recreational fisheries and was supported by some managers in various states.  The request for these options is often due to a concern that other regulations being considered would have an impact on certain businesses that are part of the recreational fishing industry.  Unfortunately, these types of splits mean that some portions of recreational fisheries receive a pass on important conservation measures, and others do not, inequitably impacting the recreational fishing economy.”

Section 3.1.2 of the Draft Addendum addresses the options for the recreational Chesapeake Bay fishery.  It is similar to Section 3.1.1, in that it offers alternative size limits and also includes sector separation options, although Section 3.1.2 also addresses the question of whether there should be a uniform set of size and bag limits throughout the Bay, or whether the Bay jurisdictions should each be allowed to adopt unique regulations.  Unfortunately, many of the options provided in this section would not achieve the 14.5% reduction which, when all management measures across all fisheries are considered, is needed to provide even a mere 50% probability that the stock will be rebuilt by the 2029 deadline.

Faced with such choices, the four organizations commenting on the issue agreed that Option B1, which would impose a 1-fish bag limit and a 19- to 23-inch bag limit Bay-wide, and so achieve a theoretical 22.4% reduction with no sector separation provision, was the preferred choice, although the Theodore Roosevelt Conservation Partnership also opined that Option B-2, which proposes the same 1-fish bag, but with a 19- to 24-inch slot, and would supposedly achieve a 15.9% slot, would also be acceptable.

In explaining its choice, the Partnership said that

Options B1 & B2 are the only options estimated to achieve more than the goal of reducing fishery removals by 14.5% or more, and apply reductions over all components of recreational fishery.”

Jersey Coast Anglers Association and Stripers Forever concurred, with the latter stating that

“After 5 years of very poor spawns in the Chesapeake Bay, it is time for some simplification and a narrow slot.  Option B1, with consistent minimum size, maximum size, and bag limit creates more uniform regulations across the bay.  Again, as previously discussed in the ocean recreational options, mode splits are not something we can support in any way.”

Specifically addressing the sector separation question, the American Saltwater Guides Association opined, despite the fact that it represents some Maryland and Virginia charter boat owners, advising anglers that

“Mode splits in the Bay should be fiercely opposed”.

With respect to the other two recreational issues, the four organizations which commented were in complete agreement.  

In the case of Section 3.1.3, all selected Option B which, in the event that a sector separation option was chosen, would nonetheless require the captain and crew of a for-hire vessel to adhere to the regulations imposed on the majority of the angling community, and not to those providing special privileges to their customers.  In the case of Section 3.1.4, Option B was also preferred by all four commenters, which would require that if a striped bass was filleted at sea or at a shoreside location, that the rack be retained by the angler and the skin be left attached to such fillets (which may not number more than two per retained rack) so that enforcement personnel could easily determine both the length and the species of the harvested fish.

Things get both simpler and a little more complicated when the organizations discussed the commercial options, Section 3.2.1.  Simpler, because there are only two options, Option A, status quo, and Option B, reducing the commercial quota by “up to” 14.5%, but more complicated both because the wording of the option, which includes that qualifying “up to,” means that even if Option B is chosen, the commercial quota might be reduced by far less than the needed 14.5%, and also because such reduction is to the quota, and not to actual landings, which means that in some states, a 14.5% quota reduction might mean no reduction in landings at all.

Stripers Forever put it this way:

“First off, it is important to understand that the reduction is to the allowable total harvest number, not to the actual harvest.  So, states that do not max out their quota may not see any actual reduction in mortality.  Let’s say a state only harvests 80% of its total allowable quota.  In that case a 14.5% reduction in quota would not save a single fish.  For example, in the past we have reported on Massachusetts struggling to fill its commercial quota.  To us its [sic] a clear sign that there are just not enough fish around but the troubling part is that if history repeats itself, then the best case scenario of a 14.5% reduction could mean no actual change in commercial harvest.  As we have always said, to rebuild this stock we need equitable reductions in mortality.  We all need to give something to get something in return.”

The Theordore Roosevelt Conservation Partnership offered a similar explanation:

“The Board is considering reducing the quota by between 0% and 14.5%...Option B includes a range from 0-14.5% reductions.  Unfortunately, a reduction in a state’s commercial quota may not reduce the actual number of fish landed next year by the desired percentage, because quotas vary from actual harvest numbers.

“For example, the Chesapeake Bay commercial fisheries, which account for approximately 80% of all coastwide commercial striped bass catch, when considering the number of fish caught, landed approximately 15% less than their quotas allowed in 2022.  This indicates that a reduction in quota in 2024 will not guarantee increased fish survival.”

Yet, even though Option B is flawed, all five organizations commenting on the issue recognized that it offered a better option than the status quo, and most of those organizations explicitly stated that quotas should be cut by the full 14.5%.

Finally, the four organizations providing a full set of comments addressed Section 3.3, which considered giving the Management Board authority to fast-track management measures that they deemed to be needed if future stock assessments and assessment updates, including the update scheduled for October 2024, indicate that such action is needed to achieve rebuilding by the 2029 deadline.  All four organizations supported Option B, which would grant such authority to the Management Board.  As noted by Stripers Forever,

“As we mentioned in our summary of this past ASMFC board meeting, there is a really good chance that Addendum II will only be in effect for a one year period.  The next stock assessment results are expected in the fall of 2024.  Given the 5 years of very poor recruitment in the Chesapeake, there is a good chance that stronger management changes will be needed to ensure a greater than 50% chance of rebuilding by 2029.  If the board is required to do so via another Addendum, that process could take close to a year to finalize.  The Striped Bass stock does not have that kind of time right now.  Option B would allow the board to react by voting by a simple majority.  While we prefer to have a public comment period, it just becomes a cumbersome and time consuming process which puts us further behind in terms of rebuilding.  This is unfortunate, the writing has been on the wall for years and as you are probably already aware, Stripers Forever has been calling for the most conservative measures since the beginning of the Amendment 7 process.”

When all of the angling organizations focused on the striped bass issue are in lockstep with respect to what must be done, and individual anglers largely support the same options, it is very difficult for the Management Board to endorse a very different course of action.

The organizations have already spoken, but as noted at the beginning of this post, angler comments still lag.  It is critical to the success of Addendum II that anglers turn out in numbers to state their preferences.  If too many remain silent, the for-hire fleet and commercial fishery will drown out the calls of those who do choose to speak, and the striped bass will suffer as a result, perhaps for more than a decade.

Anglers have until December 22 to make their voices heard.  Comments may be emailed to, with a subject line that reads “Striped Bass Draft Addendum II,” or snail-mailed to Emilie Franke, Fishery Management Plan Coordinator, Atlantic States Marine Fisheries Commission, 1050 N. Highland St., Suite 200 A-N, Arlington, VA 22201.

Since the Amendment 7 process began, those who support striped bass conservation have turned out in numbers to make their opinions heard, and the Management Board has, on the whole, responded well.  With 2029 just a few years away, and rebuilding still possible, it would be a shame if conservation advocates gave up the fight now.

No comments:

Post a Comment