NEW STUDY CONFIRMS DOMINANT ROLE OF CHESAPEAKE STOCK STRIPED BASS

 

Fishermen are often optimists who, despite poor fishing conditions and a shortage of fish, still venture out on the water believing that they're going to catch, even if their experience on previous trips would seem to suggest otherwise.  That optimism often spills over into the fishery management arena where, despite all evidence pointing to a declining stock, they believe that all is well, and that next trip, next month, or maybe next season, the fish will be just abundant as they were years ago.

Of course, sometimes that’s not just unalloyed optimism speaking.  Sometimes, it’s a matter of what fishermen want to believe, or need to believe, because their job involves catching fish, either as a commercial fisherman or for-hire operator, and if the fish population isn’t as healthy and abundant as they hope it to be, they’re going to have to be facing more restrictive regulations that are likely to impact their incomes.

Right now, we’re seeing that scenario play out with striped bass.

For many, many years, it has been pretty well accepted that the Chesapeake Bay is the primary striped bass spawning area, which contributes somewhere between 70 and 90 percent of all of the fish in the coastal migratory population.  And the most recent benchmark stock assessment tells us that abouttwo-thirds of the Chesapeake fish are produced in Maryland waters. 

The Hudson and Delaware rivers provide smaller contributions, as does North Carolina’s fish from the Albemarle/Roanoke River complex.  But the North Carolina stock has effectively collapsed, and genetic studies suggestthat the Delaware River has now been colonized by Chesapeake bass, perhapsafter past episodes of hypoxia in the Delaware prevented the river’s original bass from reaching their spawning grounds.  So the Chesapeake stock remains the most important component of the coastal population.

Recently, that has proven to be a problem, as Maryland is now experiencing spawning failure, with itsaverage juvenile abundance index for the past five years the lowest in thehistory of a survey that dates back about 65 years.  While Virginia spawns have arguably been alittle more successful, the last three years there have still seen very lowjuvenile abundance.  While we won’t know how successful the Maryland and Virginia spawns were until sometime in mid-October, I’m getting enough signals—in the form of rumors, in the way people try to change the subject when it comes up, and in what people in the know just will not say—to make me believe that Maryland might well see its 6^th consecutive year of below-average spawns this year, although the juvenile abundance index will hopefully be a little higher than it was in the recent past.

However, even if the 2024 juvenile abundance indices for the major spawning grounds turn out to be near, or even above, average, there will be five year classes of fish missing from the population, and a big hole in the age structure of the stock that we will probably begin to feel in 2026, when the largely-absent 2019 year class would normally be expected to exceed the current 28-inch minimum size.

That would normally be problem enough, but the striped bass stock is in even worse straits, as it remainsoverfished, and there is some question as to whether managers will be able to rebuild spawning stock biomass to its target level by 2029, the deadlinecreated by the Atlantic States Marine Fisheries Commission’s striped bassmanagement plan.

Put all of those issues together, and it becomes clear that, if fisheries managers do what needs to be done to rebuild the striped bass population, some very onerous management measujres are going to have to be put in place when the ASMFC’s Atlantic Striped Bass Management Board meets on October 23^rd.

Those management measures won’t be welcomed by those who kill bass for a living, and thus tend to focus on short-term harvest rather than the long-term health of the stock.  Such folks already expressed their objections to the more restrictive management measures contained in Addendum II to Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass.  One of the most common arguments was that as the climate changes and waters warm, striped bass spawning is shifting from the Chesapeake to spawning grounds farther north, including the Hudson River and various New England streams.  

Thus, we saw comments submitted like those of the Stellwagen Bank Charter Boat Association, which wrote,

“Change in environmental conditions are impacting the Chesapeake Bay striped bass spawning ground and climatic shift is impacting the distribution and productivity of spawning grounds further north.  Proactive measures to address detrimental impacts to the Chesapeake Bay and further assessment of other striped bass spawning grounds including the Delaware and Hudson Rivers needs to be conducted to further assess the status of the fishery.  Proactive measures are recommended such as what was conducted to address Atlantic Salmon and spawning forage species that need to be considered with the potential removal of dams located on the Raritan River, Connecticut River and Merrimack River where spawning is evident and/or elsewhere to promote and protect spawning grounds.”

Tom Fote, a New Jersey angler who frequently opposed striped bass conservation measures when he served as a Governor’s Appointee on the Management Board, argued that

“Because of climate change and other conditions in the Chesapeake Bay, I think other areas are producing a greater percentage of the striped bass.  Because of the warming of the water, this may continue to increase.  I have been waiting to see what happens to the stocks in the Kenneback [sic] River since that has always been considered a producing area.  It is also interesting to see if Connecticut’s waters are becoming producing areas.  We know that Canada is having a problem with wild Atlantic Salmon being eaten by striped bass and that may indicate more production further north.  We need to do the necessary research to find out what is happening with the coastal migratory stocks and not just continue to see the Chesapeake Bay as the only producing area…”

Paul Haertel, another New Jersey angler, made similar comments, claiming that

“in the NY Bight area we now have some of the best striper fishing I have ever seen in my life.  This is due to the fact that the Hudson River stock is in great shape.  However, we are being denied access to them because of the declining Chesapeake Bay stock.  I believe that as the population of the Hudson River stock increases so does their range.  They are heading further North, South and East and providing great sport in areas where they never used to travel to.  I suggest you conduct a study to see for yourselves…”

And another fisherman named James Leone, who appears to belong to the commercial sector, commented

“As someone who derives 100% of my income from fishing industry [sic] it would be a devastating blow to be further regulated or shut down a fishery as important as stripedbass [sic].  My concern is that the science needs to be updated because of rising ocean temps in the Atlantic, changes in migration and breeding patterns.  Therefore the science that has been used for many years specifically as pertains to the Chesapeake does not accurately reflect the total population that has moved further north.  I believe that there has to be new research that takes into account obvious climate change before we start further restricting a fishery our industry and coastal communities are dependent on.”

A number of other individuals, many of whom were connected with the for-hire fishing industry, made similar comments, many at in-person hearings held by the ASMFC.  However, no one provided any reliable data in support of their claims of a northward shift, but merely assumed that it was taking place; their requests for additional studies seemed to presuppose that any such research would support their beliefs.

I have written about striped bass many times on this blog, and one of my more recent posts, published last August, addressed the hard decisions that the Management Board is going to have to make at its October meeting.  It received a response from Montauk, New York charter boat captain Rick Etzel, who wasn’t particularly pleased with what I had written, and chose to challenge my statements, saying

“If you think the striped bass stock is in decline, you should step out of your cubicle and witness a spring and fall run.  For someone who claims to be on the water for fifty years your knowledge appears minimal.  The YOY in the Chesapeake and Maryland is down because the fish don’t just spawn there and nowhere else.  They MUST be spawning further north and east in every estuary along the coast.  How else could we be seeing all these different Year classes that you and the scientific community say don’t exist.  You spew as if you’re out there every day but you’re not.  In fact you’re probably nothing more than a weekend warrior professing to save the species.  Do is [sic] all a favor and convince Dr Drew [of the ASMFC’s Atlantic Striped Bass Technical Committee] to go out and observe the fish stock instead of swallowing what she is fed from the scientific community.”

Stripped of all the insults and disdain for fisheries science that characterize the majority of comments emanating from somewhere within the for-hire industry, that particular comment was merely made by someone who is afraid that regulations needed to rebuild the striped bass stock are going to damage his business, and so is striking out against the science, and anyone who supports it, not because he has any data contradicting what the biologists are saying, but instead because he badly needs to believe that the stock is healthy and that the spawning failure in Maryland won’t seriously impact his income.

Thus, the comment “They MUST be spawning further north and east in every estuary along the coast.”

After all, he seems to argue, we can assume that striped bass are successfully spawning somewhere, because they don’t exactly have labels on them specifying their waters of origin.

Except that, in fact, such labels exist.

Every striped bass swimming in our coastal sea, in our rivers, our bays, our estuaries and sounds carries a very clear and distinct label that declares where they were spawned, included in their genetic code.  Biologists can readily read those labels, and newly released genetic research—the very sort of research that many people called for in their comments to Addendum II—conducted by biologists working under the aegis of the University of New Hampshire and New Hampshire Sea Grant, has provided new insights into the origins of the striped bass migrating along the East Coast of the United States.

As scientists have always believed, the overwhelming majority of those striped bass were spawned in the Chesapeake Bay.

The description of the research project reads:

“The migratory striped bass stocks support one of the most popular recreational fisheries on the Atlantic coast.  Identifying the contribution of different spawning populations (or stocks) to the fishery would provide a more thorough understanding of stock dynamics and could enable more targeted, informed management.  Here, we used a genetic approach to determine the proportional contribution of spawning stocks to the striped bass mixed fishery in the Northwest Atlantic between Long Island, NY and Portland, ME.”

The initial research was conducted in 2018 and 2019, when biologists worked with 36 fishermen located along four sections of coast, including the waters surrounding New York's Long Island, the Rhode Island shoreline, the Buzzards Bay/Martha’s Vineyard/Nantucket region of Massachusetts, and the waters between the New Hampshire side of the Merrimack River and Portland, Maine.  Fin clips were taken from 5,400 different striped bass, which

“eventually allowed for a detailed description of when and where striped bass of different sizes and populations are migrating northward and then southward throughout the region.”

With respect to the origins of the striped bass sampled, the researchers determined that

“The Chesapeake Bay and Delaware River fish were too genetically similar to differentiate using our panel [a differentstudy conducted by Massachusetts fisheries managers came to the sameconclusion]; together they contribute 80-88% of the striped bass to the fishery,”

“The Hudson river system contributes 10-18% of the fish,”

and

“1-2% of the fish originated from the Roanoke River or could not be assigned to any of the reference populations.”

The results were remarkably consistent across both years and all four sampling regions, with the contribution of Chesapeake Bay/Delaware River fish ranging from a high of 88.8% in Rhode Island in 2019 to a low of 75.4% in New York in 2018 (it should be noted that the next-lowest Chesapeake contribution was 80.6% in Maine/New Hampshire in 2018; the Chesapeake contribution to New York samples in 2019 was 86.5%).

As might be expected, the Hudson River was the next-highest contributor, with contributions ranging from a high of 19.6% in New York in 2018 to a low of 10.3% in Rhode Island in 2019 (the Hudson’s contribution to New York in 2019 was 11.6%, the second-lowest contribution made to any of the four regions that year).

But it might be the smallest contributions that were the most intriguing.  Although North Carolina’s Albemarle/Roanoke stock never contributed more than 0.4% of the fish to any of the sub-samples (New York 2018), and made no contribution at all in three of the eight sub-samples, the fact that it appeared in any measurable quantities, given the very badly depleted state ofthe stock, suggests that, at one time when the stock was healthy, it might have been a more significant component of the coastal migratory population.

And the fact that New York enjoyed the two highest contributions of fish of unknown origin—4.6% in 2018 and 1.7% in 2019, compared to contributions ranging from 0.9-1.6% for the other six sub-samples—leaves some room to argue that, perhaps, some nearby, as-yet uncredited spawning ground or grounds, perhaps the Connecticut and/or Raritan rivers, might be contributing a very small fraction of the fish to the coastal population, although it’s just as likely that contamination or other problems with some of the samples led to the “unknown” determination.

But the important takeaway from the study isn’t speculation about where a very small fraction of the bass might have originated, but the fact that the Chesapeake Bay/ Delaware River stock is proven to be the predominant source of striped bass for the entire coast, providing over 80% of the bass being caught.

So if the Chesapeake stock collapses, fishermen will not be able to look to the Hudson, or some yet-unnamed rivers in New England to save them from the consequences of a stock collapse that could look very much like the one of forty-some years ago.

If the Chesapeake stock collapses, the fishermen can expect no salvation to come from anywhere else.

The future abundance of juvenile striped bass in the Chesapeake is going to depend on environmental conditions in the spawning reaches, and on the availability of zooplankton for the juvenile bass to feed on when and where they hatch.  No one can predict when favorable spawning conditions will recur, and if and when they do, whether such conditions will coincide with a sufficiency of food for the juvenile bass.

Thus, those who depend on striped bass, whether for food, for recreation, or for their livelihood, would do well to set aside false hopes and unsupported beliefs, and instead support managers’ efforts to rebuild and then conserve the overall striped b ass stock.

For if we get behind conservative, science-based management efforts, there may still be a chance to maintain some sort of fishery until conditions in the Chesapeake eventually improve.

If we don’t, and instead stake the future on the fantasy of new spawning grounds taking the place of the Chesapeake Bay, then we're doing nothing more than setting the stock up for collapse.

I aleady saw the stock collapse once, and have no desire to sit through that show for a second time.  And I can assure you that if you missed the last collapse, and particularly if bass help to pay for your meals and your mortgage, you really, really do not want to see that scenario played out again.

COURT REJECTS CHALLENGE TO MID-ATLANTIC RECREATIONALMANAGEMENT MEASURES

 

On September 5, the United States District Court for the District of Columbia issued a decision upholding the use of the so-called “Percent Change Approach” to manage summer flounder, scup, black sea bass and, eventually, bluefish.  The decision was a victory for supporters of “alternative” approaches to recreational fisheries management, that would allow anglers to regularly exceed hard-poundage catch limits, and a rebuke to conservation advocates who believed in the disciplined management approach that has arguably made the Magnuson-Stevens Fishery Conservation and Management Act the most successful fishery conservation and management law in the world.

I freely admit to being a member of the latter group; in fact, when I learned that the Natural Resources Defense Council was planning to initiate the lawsuit, I agreed to let them list me as a member and as an injured party in order to assure that they had standing to bring the action.  I was particularly aggrieved by what I saw as the Mid-Atlantic Fishery Management Council’s and the National Marine Fisheries Service’s lax management of the black sea bass resource; while black sea bass biomass remains very high and the fish are extremely abundant, over the last decade or so I have been observing a steady decline in the size of the sea bass available to fishermen, an indication that the older and larger fish may be being removed from the population more quickly than before, and a possible precursor to future problems.

In the 10 years between 2014 and 2023, the Mid-Atlantic Council only managed to keep recreational landings at or below the recreational annual catch limit once, in 2019, when such landings were 14 percent below the ACL.  In the other nine years, recreational landings ranged from one percent to 96 percent above such limit, and exceeded the limit by more than 20 percent in seven of the nine years.

Part of the problem was that the black sea bass population was expanding, and so attracting more and more angling effort.  Part of the problem was that the Council never really tried to constrain landings; it knew that there was significant uncertainty in the recreational catch, landings, and effort data, which translated into significant management uncertainty when setting the annual management measures, yet it ignored NMFS’ guidelines which state that

“[Annual Catch Targets], or the functional equivalent, are recommended in the system of [Accountability Measures] so that [the Annual Catch Limit] is not exceeded.  An [Annual Catch Target] is an amount of annual catch of a stock or stock complex that is the management target of the fishery, and accounts for the management uncertainty in controlling the catch at or below the [Annual Catch Limit]…”

Instead of recognizing the substantial management uncertainty that existed in the recreational black sea bass fishery, and setting an annual catch target to account for it, the Council proceeded as if there was no uncertainty at all, setting the Recreational Harvest Limit equal to the sector Annual Catch Limit minus the estimated release mortality.  The result was a chronic pattern of recreational landings exceeding the Recreational Harvest Limit, which led to recreational management measures being constantly tightened at a time when the black sea bass biomass seemed to be steadily increasing. 

The recreational fishing industry constantly hammered the Council and NMFS for steadily tightening restrictions in the face of growing abundance, and the Council and NMFS eventually grew weary of the incessant criticism.  By 2019, they effectively stopped trying to control recreational overages, unless action was clearly required by law, and even then they were heavily criticized.  

At about the same time, the Council began work on a new management approach intended to

“Allow for more regulatory stability and flexibility in the recreational management programs for summer flounder, scup, black sea bass, and bluefish by revisiting the current annual timeframe for evaluating fishery performance and setting recreational specifications to a new multi-year process.”

A memo describing the possible new approach noted

“In recent years, status quo recreational measures despite projected harvest exceeding the recreational harvest limit (RHL) have been justified on an ad hoc basis.  The steering committee is exploring the development of pre-determined guidelines that could be followed to determine if measures could remain status quo in the future.  [emphasis added].”

Thus, the Council’s priority shifted from preventing overfishing and ensuring the long-term sustainability of fish stocks to preventing disruptions to the recreational fishing industry, even if that meant that Annual Catch Limits might be exceeded, and that overfishing might occur from time to time.  

The result was Framework 17 to the Summer Flounder, Scup, and Black Sea Bass Fishery Management Plan and Framework 6 to the Bluefish Fishery Management Plan, which completely changed the way those four species are managed, replacing efforts to constrain recreational landings to a Recreational Harvest Limit with the so-called “Precent Change Approach,” a matrix that mandated the adoption of pre-determined management actions depending on both the status of the stock and a calculation of whether recreational landings, if management measures were unchanged in upcoming years, would be likely exceed, approximate, or fall below such Recreational Harvest Limit.

The new approach introduced some worthwhile innovations. 

It provided that management measures would be adopted for two-year intervals which coincided with biennial stock assessments, so that any changes in management would be based on the most recent relevant science.  And it introduced something called a “recreational demand model,” which predicted how anglers were likely to respond to changes in regulations, and didn’t merely assume that angler behavior would remain constant from year to year.

However, particularly in the case of very abundant fish stocks, the Percent Change Approach allowed recreational landings to exceed not only the Recreational Harvest Limit, but also the sector Annual Catch Limit, and set up situations where the combined commercial and recreational landings permitted by the annual fishery specifications could exceed not only the overall Annual Catch Limit, but also the Acceptable Biological Catch established by the Council’s Scientific and Statistical Committee, and perhaps lead to overfishing.

That seemed to be a step too far, which violated a section of Magnuson-Stevens which provides that each regional fishery management council, including the Mid-Atlantic, must

“develop annual catch limits for each of its managed fisheries that may not exceed the fishing level recommendations if its scientific and statistical committee.”

On April 10, 2023, the Natural Resources Defense Council filed its complaint in Natural Resources Defense Council v. Raimondo, in which it challenged the validity of Framework 17 and alleged, among other things, that

“Instead of the recreational ACL, the harvest target is used as the constraining factor for setting recreational management measures.  This harvest target may be above the recreational ACL, sometimes by a significant amount, depending on circumstances in the fishery.  Furthermore, Framework 17 contains no other safeguards to constrain recreational catch to the recreational [Annual Catch Limit.]

“Framework 17 additionally contains no safeguard against exceeding the overall [Annual Catch Limit] for the fisheries.  Because the specifications fully allocate the available catch for each stock between the commercial and recreational sectors, NMFS’ approval of an overage of the recreational sector’s ACL pursuant to Framework 17 amounts to approval of an overage for that stock’s total ACL, risking exceedances of other specifications (such as [Acceptable Biological Catch] and [Overfishing Limit]) as well…

“The function and effect of Framework 17 are to remove the [Annual Catch Limit] as an actual constraint on management decisions in these recreational fisheries.  The Council and NMFS published a final environmental assessment in November 2022, which acknowledged that Framework 17’s percent change approach would ‘allow for some level of [Recreational Harvest Limit] overages in some circumstances,’ which ‘carry a risk of [Annual Catch Limit] overages, which in turn risk [Acceptable Biological Catch] and [Overfishing Limit] overages and therefore risk resulting in overfishing.  Therefore, [Framework 17] cannot be demonstrated to proactively prevent overfishing every year in all circumstances.  The [Recreational Harvest Limit] accounts for the best available scientific information on stock status.  Therefore, even at high biomass levels, [Recreational Harvest Limit] overages can result in overfishing…’  The environmental assessment further acknowledged that when [Recreational Harvest Limit] overages occur, the Framework 17 approach, ‘is expected to have negative impacts on the stock status of summer flounder, scup, and black sea bass.’  [paragraph numbering omitted]”

It seemed like a convincing argument, but challenging an agency action is always a difficult proceeding, with the court giving substantial deference to the agency’s findings of fact and policy positions.  I hoped that the Natural Resources Defense Council’s arguments would prevail, and believed that they should, but after the oral arguments were made, time began to drag out, with no movement from the Court.

Since it would have been relatively easy to draft an opinion that supported the plaintiff’s arguments, relying on little more than the plain language of Magnuson-Stevens, the more time that passed after the arguments were made, the more I began to fear that the Court was drafting an opinion that tried to get around what seemed to be the clear language of the statute, and instead interpreted the law in a way that favored the agency and Framework 17.

And, as we now know, that is precisely what happened.

Some of the Court's reasoning arose out of the fact that, although Magnuson-Stevens said that regional fishery management councils had to develop “annual catch limits,” it never offers a definition of that term, nor did it state how such annual catch limits must function.  The Court, looking at that failure, came to the somewhat surprising conclusion that an “annual catch limit” wasn’t really a “limit” at all, at least as that word is generally understood.

The only definition of “annual catch limit” is found in NMFS’ guidelines—the same guidelines that both NMFS and the Council ignored when they failed to establish a buffer accounting for management uncertainty when they set previous black sea bass specifications—and it states that an ACL is

“a limit on the total annual catch of a stock or stock complex…that serves as the basis for invoking [Accountability Measures].”

Nothing in the statute or the guidelines explicitly states that recreational management measures must keep catch below the Annual Catch Limit.

Thus, the Court noted that the Council was acting in accordance with the law, as it still sets an Annual Catch Limit, along with an Overfishing Limit and Acceptable Biological Catch.  However,

“The [Harvest Control Rule in Framework 17] simply adds consideration of a new value, calculated independently of the Specifications Framework, called the ‘recreational harvest target’ (“RHT”).  Whereas, under the status quo approach, recreational management measures were calibrated to result in an estimated recreational harvest at or below the ‘recreational harvest limit’ (“RHL”), the [Harvest Control Rule] sets management measures to target an estimated recreational harvest at or below the ‘recreational harvest target’ (or RHT).”

The fact that such Recreational Harvest Target might be higher than the Annual Catch Limit didn’t concern the Court at all, although its reasoning is a little difficult to follow.  The decision concedes that

“plaintiff initially argues that management measures need only ‘manage’ to the [Annual Catch Limit], which is an uncontroversial position.  [citation omitted, emphasis added]”

But it then goes on to say that

“Plaintiff, however, then criticizes the [Harvest Control Rule] for ‘severing’ the development of recreational management measures from and ‘ignor[ing]’ the [Annual Catch Limit] in violation of the MSA.  The [Harvest Control Rule], however, does no such thing.  Accountability measures, or AMs, are still triggered only when the ACL is exceeded, and the lynchpin in the decision is the decision whether to liberalize or restrict management measures remains the recreational harvest limit, or RHL…The [Harvest Control Rule] merely introduces the RHT, an additional reference point that has newly accounted for data uncertainty and a stock’s biomass, in an effort to temper the degree of change in management measures from year-to-year—not to prevent a change in expected harvest in the direction of the RHL.  [citations omitted]”

Thus, the Court seems to be saying that if catch exceeds the Annual Catch Limit, Accountability Measures will still be imposed, but nothing stops the Council or NMFS from setting a Recreational Harvest Target that exceeds the Annual Catch Limit and triggers Accountability Measures—even though the very nature of AMs is to penalize a sector that lands too many fish, and that triggering AMs ought to be avoided.

In rejecting the plaintiff’s arguments, the Court goes on to say that

“Plaintiff’s principal argument is that the MSA’s Section 1853 means what it says:  providing for ‘annual catch limits’ means setting ‘caps not to be exceeded.’  By focusing primarily on the definition of ‘annual catch limit,’ plaintiff ignores that the question in dispute concerns not the ACL itself, but the means that NMFS and the Mid-Atlantic Council must adopt to achieve the ACL; specifically, whether recreational management measures must be calibrated exclusively to the ACL.  The three words ‘annual catch limits’ do not answer the question.  [citation omitted]”

 At that point, the Court writes that Magnuson-Stevens requires a fishery management plan to “establish a mechanism for specifying annual catch limits…at a level that overfishing does not occur,” then correctly states that, in the case of the species affected by Framework 17, such mechanism exists.  But it next elevates form over substance, making the remarkable statement that so long as the mechanism for specifying annual catch limits exists, the Council and NMFS have satisfied the requirements of Magnuson-Stevens, regardless of the relationship between the ACL and the recreational management measures.

Instead, the Court referenced National Standard 1, which requires that

“conservation and management measures shall prevent overfishing while achieving, on a continuing basis, the optimum yield from each fishery for the United States fishing industry,”

and argues that while the ACL is relevant to preventing overfishing, other considerations may bear on the adequacy of management measures.  Once again, it makes an effort to set the Recreational Harvest Target outside of the ACL framework, stating

“First, as explained, recreational management measures do not have to be calibrated exclusively to the ACL, or the corollary [Recreational Harvest Limit].  Second, the [Recreational Harvest Target] is used to determine management measures—not as a substitute for the RHL, which is a limit on the year’s catch.  The [Harvest Control Rule] still looks to the RHL whether and to what extent management measures need to be liberalized or restricted, the HCR merely imposes limits to cap the percent change from year-to-year, resulting in the [Recreational Harvest Target], which reflects an effort to make more methodological and iterative the process of reaching the RHL.  Importantly, when the [Recreational Harvest Target] is exceeded, nothing happens, given the RHT is simply an estimated harvest, used to develop management measures.  In contrast, when the RHL is exceeded, the HCR imposes consequences, and when a year’s recreational harvest is greater than the recreational ACL, recreational [Accountability Measures] are triggered.”

So what the Court seems to be saying is that there are consequences for exceeding a Recreational Harvest Limit or Annual Catch Limit, but despite that, it is perfectly fine for Framework 17 to establish a Recreational Harvest Target above either of those values, and use such RHT to set management measures that are likely to lead to landings so high that such consequences will be imposed.

That might not seem consistent with a rational management system, but it is now, nonetheless, the law.  Perhaps understanding the seeming inconsistency, the Court then wrote,

“Having established that the MSA does not require the ACL to be the exclusive target of management measures, review of what the MSA requires of management measures is helpful to avoid any implication that management measures may be set willy-nilly.”

Because the Court’s analysis up to that point could easily give that impression.

The Court shifted its focus from Annual Catch Limits to National Standard 1, and particularly on its requirement that management measures achieve optimum yield, which Magnuson-Stevens defines as

“the amount of fish which will provide the greatest overall benefit to the Nation, particularly with respect to food production and recreational opportunities, and taking into account the protection of marine ecosystems; is prescribed as such on the basis of the maximum sustainable yield from the fishery, as reduced by any relevant economic, social, or ecological factor; and in the case of an overfished fishery, provides for rebuilding to a level consistent with producing the maximum sustainable yield from such fishery.  [formatting omitted]”

The Court stated that

“[optimum yield] must be achieved ‘on a continuing basis’ and a stock is not deemed overfished unless its fishing mortality rate risks the species capacity ‘to produce the [maximum sustainable yield] on a continuing basis.’  Read together, these provisions indicate that the setting of management measures should consider sustainability and longevity, as well as results.  The [Harvest Control Rule] attempts to strike this balance, by eliminating extreme fluctuations in management measures and adopting an incremental approach in conforming harvest to the RHL, which remains the goal of the [Harvest Control Rule].”

It then builds on that argument by stating, in the case of a stock with a very high biomass,

“When the RHL is equal to the estimated harvest, the [Harvest Control Rule] recommends a 10 percent liberalization, and when the RHL is less than the estimated harvest, the [Harvest Control Rule] recommends a 10-percent reduction.  In these two circumstances, the [Harvest Control Rule] could set management measures that, alone, result in a harvest that is greater than the RHL,  In permitting such outcome, however, the [Harvest Control Rule] heeds [National Standard 1’s] guidance that preventing overfishing must be balanced with achieving [Optimum Yield] on a continuing basis and decides that, for species in more abundance, the balance is best struck as such…

“NMFS struck a different balance under the status quo approach—one that tilted more in favor of preventing overfishing, but with less regard for producing [Optimum Yield] on a continuing basis, even for fish with very high biomass…”

Such language implies that, at least in the case of a very abundant stock, it is permissible to increase the likelihood of overfishing occurring, in order to also increase the likelihood that Optimum Yield will be attained.  Arguably, it condones the adoption of management measures likely to lead to a temporary fishing mortality rate higher than that which would produce maximum sustainable yield, provided that such rate did not continue for so long that it threatened the stock’s ability to produce maximum sustainable yield “on a continuing basis.”

Such an interpretation would significantly weaken Magnuson-Stevens’ conservation mandates.

Thus, the Court’s decision in Natural Resources Defense Council v. Raimondo can be seen as a step backward with regard to sustainable fisheries management.  Yet, not surprisingly, it is being hailed by the recreational fishing industry, which undoubtedly believes that it will open the door to a better business environment.  In a press release dated September 25, 2024, the American Sportfishing Association, the primary trade organization of the recreational fishing industry, which also intervened as a defendant in the action, expressed its approval of the decision, saying

“…The overall goal of the Percent Change Approach is to provide more stability for the recreational sector by iteratively adjusting management measures to achieve the Recreational Harvest Limit, while minimizing potential overreaction (overcorrection) to annual variability in the harvest estimates.

“’This ruling reinforces the progress made in developing alternative recreational fisheries management that still adheres to the conservation ethic of the MSA and highlights the significance of innovative strategies like Framework 17,’ said Mike Waine, ASA’s Atlantic Fisheries Policy Director.  ‘Such measures are essential for addressing inherent imprecision in recreational fisheries data, providing predictability for anglers, and supporting a robust recreational fisheries sector.”

It’s probably important to note that maintaining healthy and sustainable fish stocks was not one of the benefits listed in Waine’s statement.

But that’s to be expected.  The decision in Natural Resources Defense Council v. Raimondo represents an important win for the angling industry and the “anglers’ rights” organizations that have long been trying to undermine Magnuson-Stevens in order to put more dead fish on the dock and more profits in industry coffers.

We will undoubtedly see more “innovative strategies” and “alternative recreational fisheries management” measures proposed and, most likely, adopted in regional fishery management councils on every coast as, emboldened by the recent court decision, council members seek ways for anglers to evade all or part of their conservation duties, and further undercut effective fisheries conservation measures.

And, given the decision in Natural Resources Defense Council v. Raimondo, such efforts will most likely succeed.

 

 

 

 

 

 

 

 

WINDFARMS AND FISH STOCKS: WHAT WILL THE FUTURE HOLD?

 

The impact of windfarms on fish, other living marine resources, and on recreational and commercial fisheries has been the subject of an ongoing debate along the Atlantic coast.

Windfarm advocates argue that the pylons supporting the turbines, as well as the rock deposited around the bases of the pylons to prevent marine currents from scouring sand, mud and/or gravel away from such structures, will provide needed hard bottom habitat on an otherwise featureless bottom, providing new places for sessile marine organisms to inhabit, which will in turn attract structure oriented marine fish.  Comparisons to the supposed habitat created by oil rigs in the Gulf of Mexico have often been made.

Such advocates point to seemingly improved fishing taking place around small wind projects built off Virginia and Rhode Island to support their positions.

Not everyone agrees.  Windfarms have their detractors, as well as advocates.  

Fishermen’s experiences off Rhode Island suggest that the noise created during the construction of the structures can temporarily chase fish out of the area, although the fish return once construction activities cease.  Commercial fishermen have sued, so far unsuccessfully, to prevent the federal government from leasing areas of the ocean bottom for windfarm development, claiming that such development will cause them to lose access to traditional fishing areas.  And there have been many claims, unsupported by scientific data of any kind, that wind development has resulted in the deaths of a number of marine mammals.

So what are the potential positive and/or negative impacts of windfarm development on the ecosystems of the Atlantic coast?  While we will only know for certain after the development occurs and observations can be made, a recently published paper provides some structure for the inquiry.  Titled “Anticipating the winds of change:  A baseline assessment of the Northeastern US continental shelf surficial substrates,” it appeared in the July 24, 2024 edition of Fisheries Oceanography.

The purpose of the paper was to describe the current bottom habitats off the upper Atlantic coast (roughly, from the southern Gulf of Maine and Georges Bank south to the continental shelf off the Delmarva Peninsula), a necessary first step toward predicting how windfarm development, and the resulting hard, high-profile structure, might change the status quo.

Early in the paper, its authors address the seemingly analogous changes that offshore oil development brought to the Gulf of Mexico, noting that about 7,000 oil rigs have been constructed in the Gulf since 1942, about half of which are currently still standing.  With respect to those rigs, the paper notes,

“Within weeks of constructions, plants and invertebrates begin to attach to these platforms, and in the following months and years, a highly complex food chain was created with each platform seasonally serving as habitat for fish densities 20 to 50 times high [sic] than the surrounding open water.”

However, such platforms were not an unalloyed benefit, as

“Invasive species also colonize these platforms very successfully, providing a steppingstone for their spread.”

The authors, rather than accepting the common wisdom that the rigs were entirely beneficial for marine life in the Gulf, raise important questions, noting

“Rigs-to-Reef program encourages the reuse of obsolete offshore oil rigs as artificial reefs, benefitting recreational fishers in the Gulf of Mexico.  This suggests a significant change in the Gulf of Mexico ecosystem, but was it?  What were the components of the original Gulf of Mexico ecosystem and did their makeup change?  Was there a significant increase in hard substrate?  Did these platforms create new complex food chains, enhance existing food chains, or only serve to concentrate and spatially reallocate existing food chains?  Finally, and perhaps most importantly, did the installation of platforms cause a regime shift?  Did they abruptly and persistently change the structure and function of the original ecosystem creating new essential fish habitat resulting in ecosystem reorganization, as the implementation of the Rigs-to-Reef program strongly suggests?  [references omitted]”

We may never know, for

“With no baseline data collected in a scientifically rigorous design prior to 1942, these questions will remain unanswered.”

The paper's authors created a baseline survey of bottom habitats on the upper Atlantic coast, so that the impact of windfarm development might be better gauged.  The authors use over a quarter-million observations of the bottom composition throughout that region, with the intention

“to (1) provide insights regarding how the areas selected for wind energy development compare with other locations, (2) motivate the development of a priori expectations for ecosystem changes to inform monitoring and research efforts, and finally (3) to provide a base-line characterization of the Northeastern US continental shelf surficial substrates to support robust examination of the changes observed in areas impacted by these installations.”

As was already recognized, soft bottom dominates the continental shelf off the upper East Coast.  Sand (defined as particle sizes between 0.07 and 2 millimeters) is the most common substrate, covering 59 percent of the region’s bottom.  The smaller particles of mud/silt, most common in deeper waters, account for 34 percent of the bottom, while gravel, found primarily off river mouths, in the area of canyons and sea mounts, and along the northern edge of Georges Bank, makes up another 6 percent, while cobble and rock outcroppings are the least common bottom types, making up about 0.1 percent each.

Soft bottom is particularly prevalent in the mid-Atlantic region, where cobble and rock are less abundant than they are off New England.

In addition, the various bottom types are generally overlain with pieces of broken clam and scallop shells, which are present on well over 90 percent of the region’s continental shelf.

However, it should be noted that regions of bottom are not homogeneous; patches of different bottom types can appear adjacent to one another.  Thus, when the bottom is broken down into a grid of 250-meter squares sand, which makes up 59 percent of the bottom, appears in 94 percent of such squares, while mud appears in 72 percent of them; among harder substrates, gravel appears in 27 percent of the grid squares, while cobble and rock appear in 4 and 3 percent, respectively.

The historical prevalence of soft bottom, particularly in the mid-Atlantic region, raise the question of whether the added hard structure provided by the windfarms will be as beneficial as people believe.  As the authors of the paper note,

“Large tracks of open uniform sand with shell debris accumulated over centuries and the fish and invertebrate communities of the Mid-Atlantic continental shelf have evolved in this homogeneous habitat.  This area supports many fisheries including Atlantic sea scallop, summer flounder, scup, Atlantic mackerel, long and short finned squid, butterfish, blue fish [sic], surfclam and ocean quahog, Golden and Blueline tilefish, and monkfish with a combined biomass of about 800,000 metric tons (excluding sea scallops)…The richness of this resource contradicts the generally held assumption that soft sediment habitat has a low value from a biological standpoint and that increasing the biodiversity by introducing hard substrate is ecologically beneficial.  What the creation of a windfarm will do is change the ecosystem by adding hard substrate as well as intertidal and subtidal zones that support new and possibly invasive species, instead of the original continental shelf ecosystem.”

It is still too soon to know with any certainty whether the windfarms will cause beneficial or detrimental change to the ecosystem of the upper Atlantic coast continental shelf.  Arguments can be, and are being, made on both sides of the debate.  

By presenting a baseline description of the region’s bottom today, before extensive energy development has begun, the paper’s authors have provided a way to measure any changes, and perhaps to determine whether such changes are causing significant harm while there is still time to amend development plans and moderate the extent of any likely damage.

 

 

 

 

 

 

FISHERIES MANAGEMENT, AND WHAT FISHERMEN FAIL TO PERCEIVE

 

Fishermen, by their nature, spend a lot of time on the water.  If they fish commercially, or run a for-hire boat, they’re out just about every day that weather and business considerations allow; if they fish recreationally, other factors, such as jobs, spare cash, and family obligations enter the picture.  But whether recreational, commercial, or for-hire, fishermen put in enough time to observe changes in environmental conditions, fish movements, and the health of fish stocks.

Such observations are essential to a fisherman’s success, as they provide a matrix of information that reveals where fish will most likely be at a particular juncture of season, water temperature, wind, and tide.  They also inform a fisherman’s views on the health of fish stocks and the value of particular management measures.  

But in such cases, fishermen can easily be led astray, in part because their observations are usually limited in space and time, and also because of the very human tendency to succumb to confirmation bias, which leads people to remember and give higher value to observations that support their existing beliefs and interests, while discounting those that challenge such preexisting values.

Thus, we often hear for-hire captains in the northeastern striped bass fishery argue that bass are shifting their spawning grounds north, even though there are no scientific data to support such claims, rather than admit that years of extremely poor recruitment in the Chesapeake Bay is going to require managers to adopt more restrictive regulations.  

Similarly, after a stock assessment update found that the bluefish stock had become overfished, we heard members of the recreational fishing industry argue that the population hadn’t actually declined, but merely moved offshore where managers can’t find them, based on a handful of offshore encounters between bluefish and commercial and recreational fishermen (the interesting thing about such comments, from my perspective, is that I fish offshore throughout the summer, spending a substantial amount of time chumming for sharks, and am now encountering far, far fewer bluefish in my offshore chum slicks than I did in the 1980s and 1990s—even than I did in the early 2000s—which would seem to contradict the claim that the bluefish stock is healthy, but merely remaining in deeper waters).  Once again, such comments were offered in the hope of avoiding more restrictive regulations.

Right now, we’re seeing the same phenomenon play out in the gag grouper fishery in the Gulf of Mexico.  Because the State of Florida has been doing quite a bit of research on gag grouper, the current controversy surrounding that fishery illustrates why fishermen’s objections to management measures can be based on misconceptions arising out of incomplete, and perhaps biased, understanding of the relevant facts.

This year, the Gulf of Mexico Fishery Management Council agreed to open the recreational gag grouper season on September 1.  However, that season is already over, as it was only scheduled to run for two weeks, due to problems with the gag grouper stock.

The short season led to many unhappy anglers, with one reportedly saying,

“What a joke this has become,”

while another, probably unaware of the irony in his comment, said,

“What an unfortunate situation we find ourselves in.  Resources being governed on emotion, you know, under the guise of poor science.  It’s a shame.”

A writer for the Bradenton [FL] Herald wrote,

“After studies and quotas and all sorts of angler/government/legal interaction, this is what we’ve been left with.  A short two-week window in the middle of hurricane season when the water is the warmest.  It is almost a slap in the face to anglers.”

Yet the same writer concedes,

“I will admit that gag grouper landings have been more sparse in my recent fishing experiences than years past,”

and that

“Anglers pre-fishing [ahead of the season] have caught legal-sized fish, but they haven’t been in extreme abundance,”

although he tries to explain away his own lower catches by saying,

“much of that is because I actively try to avoid them.”

Another angler quoted in the article complains about the number of undersized fish, or fish caught out of season, which end up being eaten by sharks or Goliath grouper sometime after being hooked and/or released.

But the one group of people that the writer does not quote are the scientists who study gag grouper, the same group of folks who could provide plenty of reason for the short recreational season.  For, contrary to the claims of the angler who said that gag grouper were “governed on emotion…under the guise of poor science,” there are good reasons to engage in precautionary management.

Biologically, gag grouper are what is known as a protogynous hermaphrodite; that is, a fish that begins life as a female, but eventually transitions into a male.  Biologists previously believed that the health of the stock depended upon the number of breeding-aged females, and the last stock assessment, which was reliant on female abundance, found the stock to be neither overfished nor experiencing overfishing.  However, commercial fishermen were having trouble filling their quotas and, as the Bradenton Herald writer noted, anglers weren’t finding overwhelming numbers of adult fish.

Concerned by such signs of declining abundance, Florida scientists decided to take another, deeper look at the resource.  It turned out that males matter more than people once thought.

The most recent stock assessment found that males only make up two to three percent of the overall gag population, as opposed to their historic level of 17 percent.  Such males spend the entire year in deep water, typically at depths of more than 165 feet, on or near the spawning grounds.  Some, but not all, of the spawning areas have been designated as marine protected areas in order to help conserve the gag grouper stock.

Immature females, which typically means fish between one and four years of age, remain in relatively shallow (average of 70 to 75 feet) inshore waters, while mature females form pre-spawning aggregations during the late fall and early winter (November-February) in 50 to 400 feet of water, before joining the males on the spawning grounds.

When a team of researchers examined the gag grouper stock, they discovered that “overall gag grouper abundance is low.”  They also found that the relatively few males that remain in the population are unevenly distributed on the spawning grounds.  About five percent of the fish within the marine protected areas are males, well below the 15 percent that the researchers expected to find in such places; in spawning areas outside the marine protected areas, the researchers found almost no males at all.

In the paper reporting their findings, the researchers

“propose[d] that shallow-water pre-spawning aggregations are a key spatio-temporal bottleneck to gag productivity.  They appear to be an important source of [female to male] transitionals and are heavily fished, which may negatively impact male recruitment to the spawning grounds.”

They also found that current regulations were not sufficiently restrictive to rebuild the proportion of males in the spawning stock to the historical 17 percent.

Thus, the anglers quoted in the Bradenton Herald article had it all backwards.  It was not the fishery managers, but the anglers, who were basing their views on “on emotion…under the guise of poor science.”  They saw—and targeted—the abundance of females, including fish in transition from female to male and, by doing so, drove the level of males below the level needed to maintain a healthy stock.

As the researchers noted,

“the male population in the [Madison Swanson marine protected area] may be aging with limited recent recruitment of younger males rather than indicating a recovering stock, highlighting our need to better assess male recruitment and the processes driving it.  The mating function (relationship between sex ratio and fertilization success) plays an important role in the productivity of protogynous species…but is poorly understood.  Males displayed low milt (sperm) reserves during the spawning season which is a pattern associated with pair spawners.  Because gag are pair spawners and female gag are multiple batch spawners (meaning they produce multiple batches of eggs throughout the spawning season), males would have to spawn with multiple females per day, every day of the [approximately] 78-day spawning season.  Although make spawning frequencies are unknown, given the low milt reserve gag displayed this seems unlikely to be accomplished.

“With the current low observed sex ratios being close to those seen in the 1990s when gag were considered overfished and undergoing overfishing, the above evidence suggests that male abundance is well below what would be expected in a healthy stock.”

Anglers saw a lot of gag, and based on the apparent abundance, assumed that the stock was healthy and the short season unnecessary, but they were completely unaware of the skewed sex composition of the stock, and the implications of the shortage of males on the stock’s long-term sustainability.

They didn’t realize that far from being “a slap in the face,” the two-week season was really a helping hand, both to the gag grouper and to those who plan to be fishing for them a few years from now.

The story of the gag grouper is just one more example of why fishermen’s comments on the health of fish stocks need to be taken with a very large grain of salt.  While fishermen know what they see—or at least think they see—when out on the water, they rarely have a complete picture of all of the factors that bear on the status, and long-term prospects, of a fish stock.

And, as is so true in many facets of life, it’s what one doesn't know that can often cause the most harm.

 

FALSE ALBACORE: GETTING AHEAD OF THE PROBLEMS

 

Far too often, fisheries management is a reactive process, which only sees managers act to conserve a stock after it is already in some kind of trouble.  And even then, managers are often reluctant to take the sort of decisive action needed to halt a stock’s decline and begin rebuilding.

We saw that happen with striped bass in the late 1970s, when managers kept reassuring us that a declining stock would turn itself around, took no remedial action, and allowed that stock to collapse instead.  We saw it with Atlantic cod, with thesouthern New England stock of winter flounder, and with striped bass again adecade ago, when the Atlantic States Marine Fisheries Commission’s AtlanticStriped Bass Management Board ignored a tripped trigger in their managementplan that required them to initiate a 10-year rebuilding plan, and allowed the striped bass stock to become overfished once more.

Earlier this month, we saw the ASMFC’s Summer Flounder, Scup, and Black Sea Bass Management Board ignore the findings of the most recent stock assessment, and set black sea bass catch limits over 20 percent above the overfishing limit, rather than irk stakeholders with a round of harvest reductions.

So when we see fisheries managers considering proactive management measures with respect to any fish stock, and making efforts to provide needed protections while the stock is still healthy, it’s always good news.

And right now, it looks like that’s happening with respect to little tunny—the fish that we know as “false albacore” in the north, and “bonita” well below the Mason-Dixon line.

False albacore might seem like an unlikely candidate for such protections.  They remain abundant, appearing anywhere between the beaches and the edge of the continental shelf, from southern New England around Florida, and into the Gulf as far as the Texas/Mexico border.  

Because they’re not a popular food fish—most people are turned off by the strong-tasting, bloody meat, although if the fish is bled properly, immediately iced down, and eaten within 24 hours or so, it makes a very good sashimi—commercial landings are relatively low, with a little over 500,000 pounds landed in 2022, a figure somewhat less than the 20-year average.  However, because false albacore aren’t governed by any sort of fishery management plan, there are real questions about how much of the catch is being reported, particularly because one of the primary uses for the fish is as bait for grouper, swordfish, and other, more popular species.

But even if false albacore don’t support an important commercial fishery, they do support a vital recreational fishery, particularly in southern New England and the mid-Atlantic region, which over the past decade has seen between 2 million and 3.5 million fish caught by anglers each year.  While most anglers, aware of the species’ dubious reputation as food, think that catch-and-release anglers dominate the recreational fishery, that is not necessarily true; roughly two decades ago—the five-year period between 2004 and 2008—the recreational harvest averaged a little over 450,000 per year, about 21  percent of overall recreational landings.  But in the most recent five-year period, 2019-2023, recreational landings more than doubled to an average of almost 950,000 fish per year, just about 40 percent of anglers’ total catch.

At the same time, given the depleted state of both striped bass and bluefish populations, false albacore are becoming a more important recreational target, often proving to be “season savers” for for-hire captains who cater to fly and light-tackle fishermen.

Thus, it makes sense to consider managing false albacore now, while the stock is still perfectly healthy and has not felt the effects of steadily increasing fishing pressure.

The effort to manage the species began slowly.

The South Atlantic Fishery Management Council once included little tunny in its Coastal Migratory Pelagics Fishery Management Plan, but deleted them from that plan in 2012.

More than a decade later, when the Mid-Atlantic Fishery Management Council was drafting its Unmanaged Forage Omnibus Amendment, some council members, as well as some members of the public, suggested including false albacore as an unmanaged forage species.  However, because the predators that fed on the fish—things like blue marlin and shortfin mako sharks—were not among the species managed by the Council, such suggestion was ultimately rejected when the amendment was finalized in 2017.

After that, false albacore were largely ignored by fishery managers.  Federal managers didn’t believe that the false albacore stock “requires of conservation and management,” the Magnuson-Stevens Fishery Conservation and Management Act’s criterion for initiating a management plan, and the Atlantic States Marine Fisheries Commission never thought to pay the fish any attention.

Finally, in December 2022, the South Atlantic Council took a tentative step toward conserving false albacore when it directed its Mackerel and Cobia Advisory Panel to prepare fishery performance reports for little tunny, which will track catch and landings, at regular, three-year intervals.

At that point, it became clear that if any management action was going to happen, it was going to be taken by the states.  Such action wasn’t likely to be prescriptive, and it didn’t have to be.  It merely had to set triggers that, if tripped, would lead to some sort of management measures being put in place.

North Carolina was the first state to consider false albacore management.  There, the North Carolina Marine Fisheries Commission, encouraged by 170 written comments sent in by concerned anglers, voted 5 to 4 to move forward with what the American Saltwater Guides Association calls “guardrail management,” which provides that if, in any year, false albacore landings exceed 200 percent of the five-year average, the state would impose a 3,500 pound trip limit on the commercial fishery, and establish a 10-fish bag limit for individuals and a 30-fish bag limit for recreational vessels.

Later, at its August meeting, the same Marine Fisheries Commission voted 9-0 to approve the financial analysis associated with the proposed management measure, and to continue to move toward “guardrail management.”  A final vote on the issue will occur later this year, and it is expected to approve the management process.

Now, the focus is shifting to Massachusetts where, on Tuesday, September 17, the state’s fisheries managers will be taking public comments with respect to possible management measures for false albacore and Atlantic bonito.  The meeting will be the very first step in what could easily be a long process of adopting management measures, but the very fact that Massachusetts is considering such measures is a step in the right direction.

It should be noted that the steps being taken toward false albacore management are not happening in a vacuum, but are instead the results of a lot of hard work being done by the American Saltwater Guides Association which, understanding the importance of the species to its members’ businesses, is putting in a lot of effort to sponsor research on what is very much a data-poor species, and to get precautionary management measures in place before the fish runs into any sort of problems.

If the rest of the recreational fishing industry understood the connection between healthy fish stocks and healthy fishing businesses, everyone—including the fish—would be far better off than we are today,.