When the Atlantic States Marine Fisheries Commission’s
Atlantic Striped Bass Management Board met on the afternoon of May 6, the big
question was what they were going to do with the first draft of Addendum III to Amendment 7 to the Interstate Fishery Management
Plan for Atlantic Striped Bass.
As the meeting began, the Management Board faced three possible actions: It could decide that a 7 percent reduction in fishing mortality was too trivial to worry about and, recognizing that the stock had a 48.5 percent probability of rebuilding if no action was taken, halt work on the addendum; it could accept the draft prepared by the Plan Development Team and, perhaps after making some minor revisions, approve the draft addendum for public comment; or it could decide that some major revisions were needed, and send the draft back to the Plan Development Team for additional work.
In the end, the Management Board chose the latter option.
While some observers expected that outcome, it certainly
wasn’t a foregone conclusion. Although
the Management Board never seriously debated abandoning the entire Addendum,
John Clark, the Delaware fishery manager, made a motion to strip out the entire
section that dealt with harvest reductions, leaving an Addendum that would deal
with some odds and ends such as commercial tagging and guidelines on how to
measure a bass, but would do nothing to better ensure that the stock would
rebuild by the 2029 deadline.
The motion, which was seconded by New Jersey fishery manager
Joseph Cimino, had substantial support, and failed to pass by the narrowest of
margins, with seven jurisdictions voting in favor, seven voting against, and
the two abstaining. So at least for now,
the seven percent reduction in striped bass removals will move forward,
although the wisdom of moving forward with the Addendum might be challenged
again at the Management Board’s August meeting.
With that vote concluded, the Management Board began to edit the draft
presented by the Plan Development Team, and the possibility of approving the
edited draft for public comment remained a real possibility.
Chris Batsavage, a North Carolina fisheries manager, made
the initial amendment:
“Move to remove Option 4 from Section 3.3 (0.8% commercial
reductions.”
That motion, which was seconded by Delaware’s Clark, passed
by consensus, and removed what I have always believed was the single most illogical and indefensible provision in the draft Addendum III, as well as in previous draft
documents where similar provisions have appeared.
It arose out of the fact that the commercial fishery accounts for about 11 percent of striped bass fishing mortality.
After the Technical Committee determined that removals would have to be reduced by seven percent if the spawning stock was to have a 60 percent probability of rebuilding by 2029, someone suggested that instead of both recreational fishing mortality and the commercial quota being reduced by seven percent, the seven percent commercial reduction should instead be multiplied by the commercial fishery’s 11 percent contribution to fishing mortality, resulting in a commercial quota reduction of only 0.77 percent, which was rounded up to 0.8 in the draft Addendum.
Proponents of that approach argued that cutting the commercial quota by
a full seven percent would be unfair, given the commercial fishery’s small
contribution to fishing mortality.
It is, of course, an absurd argument, that shows either a
pathetic ignorance of basic mathematics or an intentional effort to misdirect
management efforts. If both recreational
fishing mortality and commercial quota are cut by seven percent, then—assuming
that the contributions to overall fishing mortality remain constant at recent
levels—the recreational fishery will be expected to make 89 percent of the cuts
while the commercial fishery is responsible for 11 percent—exactly in accord
with their contributions to striped bass removals.
On the other hand, if the commercial quota is only cut back
by 0.8 percent, and the rest of the needed reductions are placed on the
shoulders of the recreational fishery, then the recreational removals would
have to be reduced by an additional percentage point—by eight percent instead of
seven—to compensate. No, it wouldn’t
have been a large increase in the recreational reduction, and was small enough to get lost amid the uncertainty in the recreational catch and landings data, but it
is nonetheless based on a flawed and inherently inequitable concept, and has no
place in Addendum III.
We can easily predict how the commercial fishery would have
reacted had someone proposed multiplying the seven percent recreational
reduction by 89 percent—the recreational contribution for fishing mortality—and
having the commercial fishery shoulder the remainder of any needed cuts. Yet the logic for such an approach would be the same as the logic supporting the 0.8 percent proposal.
Of course, removing the 0.8 percent commercial reduction
from the document still leaves an even more inequitable option in place—an option that would force the recreational fishery to cut back its landings, and so shoulder the
entire burden of rebuilding, while the commercial
quota remains unchanged. Fortunately, the option for equal, seven percent reductions also remains in
the draft Addendum, so we can only hope that true equity, in the form of equal
percentage reductions, prevails in any final version of Addendum III that the Board might approve.
Sadly, the commercial fishery isn’t the only fishery that seeks
to benefit at the expense of the great majority of recreational fishermen. The for-hire fleet wants to use Addendum
III as a vehicle to take bass away from private and shore-based anglers, too.
The notion of “mode splits”—that is, gifting anglers on for-hire boats with more generous regulations, and relegating private-boat and shore-based anglers to a sort of second-class status—is not new. It was raised in the draft Addendum II to Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass that was approved in January 2024 (where it was overwhelmingly rejected in stakeholder comments, by a margin of 2,314 to 160), and ultimately in Addendum II as well, and has also been an ongoing theme in other fisheries.
Just last Wednesday, multiple for-hire
operators attending a meeting of the National Marine Fisheries Service’s Highly
Migratory Species Advisory Panel asked NMFS to take an unspecified number of bluefin
tuna away from private-boat fishermen and give them to the party and charter
boat sector, while at
the Mid-Atlantic Fishery Management Council, there is an amendment under
consideration that would favor the for-hire boats over private boat and
shore-based anglers with respect to bluefish, summer flounder, scup, and black
sea bass.
It's not clear that the "greatest overall benefit to the Nation," supposedly the standard to be used when chosing between possible federal fishery management measures, would be served by such actions.
Perhaps surprisingly, the first draft of Addendum III addressed the mode split
issue in a unique and far more equitable way.
While it included options that would allow the for-hire boats a somewhat
wider slot limit, and so let them kill the larger female bass that the generally-applicable 8- to
31-inch slot denies to everyone else, it also included options that attached a
price to that wider slot. Those options
invoked the principles of conservation equivalency, and required for-hire anglers to reduce their landings by the same seven percent required of everyone else; in exchange for the wider slot limit, such for-hire anglers would have to accept a longer closed season, which would help ensure that all anglers did
their fair share to rebuild the striped bass stock.
Unfortunately, Massachusetts fisheries manager Nichola
Meserve rose to
“Move to remove all the split separate equal mode reduction
options.”
David Sikorsky, the Legislative Proxy from Maryland,
seconded, and that motion, too, was passed by consent.
Thus, the only option that could have brought some equity to the mode
split issue was removed from the draft Addendum, although options that elevate for-hire anglers above the rest of the recreational fishery remain.
The third edit to the draft Addendum came when Dr. Jason
McNamee, the Rhode Island fisheries manager, moved
“to remove the ocean size limit options of 37-40” and
38-41”.”
New York fisheries manager Martin Gary seconded, and
unanimous consent again settled the issue.
Given that such size limits barely achieved the seven percent reduction,
while targeting the larger, more fecund females that the current slot limit is
intended to protect, the universal support for removing such larger slots should have come
as no surprise.
If the proposed changes stopped there, draft Addendum III
would probably have already been released for public comment. However, one more big issue was put on the
table, which made it necessary to send the draft Addendum back for more work.
Over the years, Maryland has sought special, state-specific
management measures that, in theory, had the same conservation impact as the measures adopted by the
Management Board. There were
times when the state placed greater restrictions on its recreational landings,
so that it could have a larger commercial quota. There were times when it shut down its entire
recreational fishery for a few weeks, not even allowing catch-and-release, so that
its for-hire anglers could retain two fish, compared to the single striped bass that every other recreational fisherman might take home. There were times when it convinced
the Management Board that requiring the use of circle hooks by anglers fishing
with bait reduced release mortality enough to justify higher landings.
But in time, the Maryland regulatory structure, with all of the special bits and pieces added on, became too clunky and difficult for state managers to work with, particularly as each new addendum required new management measures in addition to those already in place.
Things finally got to the point where Maryland believed it necessary to rationalize its recreational striped bass seasons, so that any new measures required by Addendum III, should it finally be adopted, could be more easily applied.
Thus, at the May 6 Management Board meeting, Maryland’s Sikorski was called upon to
“Move to add the Maryland baseline season option to Draft
Addendum III.”
Delaware’s Clark
seconded, but it was clear that the Management Board wasn’t going to blindly
follow along. While Maryland made a
convincing presentation, which suggested that the new “baseline season” would
not increase fishing mortality, many Board members wanted
independent confirmation. So Doug Grout,
New Hampshire’s Governor’s Appointee, moved to amend the initial motion to add
the words
“contingent upon final review by the [Technical Committee]
and [Stock Assessment Subcommittee] of the modifications that were made.”
Raymond Kane, the Governor’s Appointee from Massachusetts,
seconded the motion to amend, which then passed easily, with 15 in favor, and 1
abstention.
With that change, the main motion also passed, by a vote of 13 in favor, 2 abstentions, and 1 null vote (which occurs when a majority of a state delegation cannot agree on a position).
But the Management Board wasn’t yet done.
The Maryland “baseline season” was arguably a form of
conservation equivalency, and Amendment
7 to the Interstate Fishery Management Plan for Atlantic Striped Bass provides
that
“Proposed [conservation equivalency] programs for non-quota
managed fisheries are required to include an uncertainty buffer of 10%.”
While Maryland might be able to make a case that its
“reset” baseline season wasn’t exactly conservation equivalency, the
proposal came close enough that Ms. Meserve moved
“to task the [Plan Development Team] with developing a
sub-option for the MD season option that would add an uncertainty buffer.”
The motion was seconded by Cheri Patterson, New Hampshire’s
Legislative Appointee, and appealed to enough Management Board members that it
passed on a vote of 9 in favor, 5 opposed, and 2 abstentions.
The additional work required before the Maryland
baseline might be included in the draft Addendum—work that had to be done by the Technical Committee, the Stock Assessment Subcommittee, and the Plan Development Team—meant that a draft
Addendum III could not yet be released for public comment.
A new draft will be prepared in time for the Management
Board’s August meeting. If the Board is
satisfied with that version, and if the Management Board still believes it
worthwhile to move forward with the Addendum, a draft Addendum III should be
released for public comment soon after the August meeting, with public hearings held in late
August and September. Assuming that
schedule holds, the final decision on Addendum III would be made at the Management
Board’s October meeting.
Right now, I’m not sure how I would like to see the Amendment III story
end.
I wanted to see the Management Board adopt additional
management measures last December, to protect the 2018 year class and reduce 2025 landings. That didn’t happen.
In December, such reductions didn't appear necessary to rebuild the stock by 2029. However, in the short term, they would probably have increased the size of the spawning stock biomass, and put it in a better position once
the six years of poor spawns—which began in 2019—begin
to impact the SSB. More restrictive
regulations in 2025 would also have protected the 2018 year class—the last
above-average year class that the stock has produced—which will be moving
into the 28- to 31-inch slot this year.
If Addendum III is finally adopted, its management provisions won’t go into effect until 2026. By then, the 2018 year class will have been targeted by recreational fishermen for a full season, and about half of the 2018s that survived will have already grown out of the 28- to 31-inch slot. Both factors will limit the impact of Addendum III.
So the question that needs to be answered is whether any benefits provided by Addendum III will justify the bad precedents
that the Addendum may very well create.
By “bad precedents,” I mean elevating both the commercial
and for-hire fisheries above the mainstream recreational fishery to which the
great majority of striped bass fishermen belong, and perhaps introducing the concept of no-target closed seasons, when even catch-and-release is illegal, to the entire coast.
Should the Management Board ultimately decide that the
commercial quota should not be cut, and should it adopt a mode split proposal,
it will have effectively placed the private-boat and shore-based anglers at the
bottom of the striped bass pecking order, forcing such recreational fishermen
to bear the brunt of the conservation effort, while also forcing them to give
up the most in terms of striped bass landings.
Given that the private-boat and shore-based anglers are
responsible for more than 98 percent of all recreational trips, and so generate
a substantial majority of the social and economic benefits gleaned from the
striped bass resource, placing them in such a position seems the wrong thing to
do.
And given that no-target seasons are just about impossible to enforce, as it is pretty well impossible to prove beyond a reasonable doubt that an angler is fishing for striped bass and not weakfish, bluefish, red drum, white perch, or some other species of fish, the adoption of such seasons would provide the illusion of reducing harvest, while in fact accomplishing little.
For as one honest fisherman noted in a comment sent in to the Management Board,
"I continue to discuss proposed changes for striped bass management with many fellow anglers. When I ask them about the no targeting proposal for striped bass they all invariably reply by saying that they will be fishing for blue fish."
And no one will be able to prove otherwise.
Everyone who benefits from the striped bass
resource—commercial or recreational, private or for-hire—has a stake in the
species’ future health, and should be paying a proportionate price to help
ensure that such future is a good one.
If Addendum III doesn’t do that, and skews striped bass
management against the most important user group, or imposes unenforceable regulations that will do little to rebuild the stock, an argument can easily be made that Addendum III would do more harm than good, and shouldn’t be adopted
at all.
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