STRIPED BASS AMENDMENT 7--NAVIGATING THE PID: PART 1, GOALS AND OBJECTIVES

 

As most readers already know, the Atlantic States Marine Fisheries Commission’s Atlantic Striped Bass Management Board has voted to move forward with a new Amendment 7 to its striped bass management plan.  Earlier this month, as its first formal step toward adopting the new amendment, the Management Board approved the Public Information Document For Amendment 7 to the Interstate Fishery Management Plan For Atlantic Striped Bass, and released it for public comment.

This is a big deal, for the new amendment has the potential to radically alter the course of striped bass management. 

As I’ve mentioned in previous posts, there are members of the Management Board who are seeking to increase striped bass landings in the short term by reducing the female spawning stock biomass target and the threshold for determining when the stock is deemed to be overfished.  If they succeed, they will permanently reduce striped bass abundance, and will threaten the long-term health of the stock.

There are also Management Board members who see the new amendment as a way to improve the striped bass management process, perhaps by providing a better scientific footing, and make it less likely that, should the stock be restored, it will ever become overfished again.

The Public Information Document doesn’t champion either of those different visions of the striper’s future (although, as I’ll describe in this and future posts on the topic, it does reflect some unfortunate biases).  Instead, it is similar to a scoping document in the federal fisheries management process, allowing all stakeholders to weigh in and provide their views on how the resource should be managed. 

Because of that, the Public Information Document is the public’s last, best chance to get Amendment 7 headed in the right direction, and to hamper efforts that might significantly impair the long-term health and stability of the striped bass stock.

Right now, everything is on the table.  

Once public comment on Amendment 7 has been made, and the preliminary draft of the amendment is put together, Amendment 7 will begin to acquire a sort of institutional inertia; after that, it will be ever more difficult to divert it from the Management Board's chosen course.  Now, before everyone’s views hardened and various Management Board members’ personal prestige has become wrapped up in provisions of the draft amendment, the public has its last, best opportunity to influence the drafting process.

The problem is that, because the Public Information Document contemplates many different aspects of striped bass management, it is a very dense document that asks many questions, but provides very little background information; it’s very difficult for an angler who doesn’t stay on top of striped bass issues on a near-daily basis to understand just what they’re being asked to comment on, or what the implications of the various options might be. 

Thus, today’s edition of One Angler’s Voyage, and the next two or three that follow, will attempt to break down the Public Information Document into its key sections, and explain how those sections might affect the health, and so the future, of the striped bass stock.

It’s always best to start at the beginning, and it just so happens that the first issue raised by the Public Information Document, “Fishery Goals and Objectives,” provides a very good place to start, for such goals and objectives should guide all of the other management decisions included in Amendment 7, as the remaining provisions ought to be crafted to achieve the Objectives, and so attain the Goal.

The current Goal for striped bass management, as set forth in Amendment 6 to the Interstate Fishery Management Plan for Atlantic Striped Bass, is

“To perpetuate, through cooperative interstate fishery management, migratory stocks of striped bass; to allow commercial and recreational fisheries consistent with the long-term maintenance of a broad age structure, a self-sustaining spawning stock, and also to provide for the restoration and management of their essential habitat.”

That is already a worthwhile Goal.  It seeks sustainable fisheries, a sustainable striped bass stock, and the protection of essential fish habitat.  As a mission statement for the ASMFC’s Atlantic Striped Bass Management Board—which is what the Goal, in essence, is—it would be tough to come up with improvements.

Amendment 6 also contains seven Objectives, which might be deemed the strategies devised by the Management Board to carry out its stated mission.  Those Objectives include

“Manage striped bass fisheries under a control rule designed to maintain stock size at or above the target female spawning stock biomass level and a level of fishing mortality at or below the target exploitation rate.”

“Manage fishing mortality to maintain an age structure that provides adequate spawning potential to sustain long-term abundance of striped bass populations.”

“Provide a management plan that strives, to the extent practical, to maintain coastwide consistency of implemented measures, while allowing the States defined flexibility to implement alternative strategies that accomplish the objectives of the [fishery management plan].”

“Foster quality and economically viable recreational, for-hire, and commercial fisheries.”

“Maximize the cost effectiveness of current information gathering and prioritize state obligations in order to minimize costs of monitoring and management.”

“Adopt a long-term management regime that minimizes or eliminates the need to make annual changes or modifications to management measures.”

“Establish a fishing mortality target that will result in a net increase in the abundance (pounds) of age 15 and older striped bass in the population, relative to the 2000 estimate.”

On the whole, those are also reasonable Objectives, although some are more worthy than others.  

It wouldn’t be hard to argue that the striped got into trouble because the Management Board failed to diligently seek to perform some of the most substantively important Objectives over the past decade, while slavishly adhering to others that were of a more procedural sort.

The Public Information Document, in seeking comment on the Goals and Objectives, says

“The status and understanding of the striped bass stock and fishery has changed considerably since the implementation of Amendment 6 in 2003.  As a result, both managers and stakeholders have expressed concern that the existing goals and objectives of this management program may be outdated, and no longer fully reflect current fishery needs and priorities.  Some of the objectives may need to be refined, while other priorities may be missing entirely.  The Board identified management stability, flexibility, and regulatory consistency as guiding themes for future striped bass management, and discussed the desire to balance these principles to the extent practical.  [emphasis added]”

That paragraph raises what may be the single most important issue of the Amendment 7 process.

Remember that the striped bass stock is currently overfished, and as of the last stock assessment, was experiencing overfishing.  Addendum VI to Amendment 6 to the Atlantic Striped Bass Interstate Fishery Management Plan was intended to end fishing overfishing and reduce fishing mortality to or below the target level; however, because COVID-19-related concerns severely crippled the recreational data gathering process last year, no one knows how close Addendum VI came to achieving its goals.

Under such circumstances, one might think that the biological needs of the stock—rebuilding it back to the spawning stock biomass target, so that, in accord with the current Goal, commercial and recreational fisheries are managed in a manner “consistent with the long-term maintenance of a broad age structure,” and also in accord with the Objective to manage “fishing mortality to maintain an age structure that provides adequate spawning potential to sustain long-term abundance of striped bass populations.”

After all, maintaining a healthy and sustainable stock should always be the first priority of striped bass managers.

But that’s not what we’re seeing.  Instead of concerning themselves with the biological needs of the striped bass stock, we see in the Public Information Document that the Management Board is prioritizing the bureaucratic convenience of striped bass managers, “identifying management stability [and] flexibility…as guiding themes for future striped bass management.”  (I left “regulatory consistency” out of the previous sentence, as that can would actually be good for the bass.)

Never forget that “management stability” and “flexibility” are, once you strip away that bureaucrat-speak, just nice-sounding language designed to let managers off the hook for doing nothing when decisive action is called for.  “Management stability” and “flexibility,” even if not expressly condoned in a management plan, are already hallmarks of how the ASMFC typically does business, and are a big part of the reason that striped bass became overfished once again.

Let’s look at how that actually played out.

We’ll look at “management stability” first.  That’s the notion that it’s better to keep regulations consistent from year to year, rather than to change them in response to every vacillation in fishing mortality or striped bass abundance.

That notion isn’t completely wrong.  Stable regulations do allow fishing-related businesses to plan farther ahead.  They also improve regulatory compliance, because fishermen don’t have to constantly stay on top of frequently changing rules.  And they can help scientists, for when regulations are consistent, biologists can better calculate whether changes in stock abundance are due to fishing or to naturally-occurring conditions.

But a mindless devotion to regulatory stability also leads to management inaction when action is clearly called for, and does real harm to the striped bass.  Consider what happened in November 2011, after an update to the striped bass stock assessment warned that, if regulations went unchanged, the stock would become overfished by 2017.

According to what was then the best available science, the Management Board had six years to act, and prevent the stock from becoming overfished.  That was plenty of warning, and had the Managtement Board acted right then, the striped bass stock probably wouldn’t be as bad off as it is today (although no one, including the Management Board, knew that recreational fishermen were killing as many fish as they were back then, and that the situation was even worse than the science had, to that point, revealed).  

But instead of acting, the Management Board sat on their hands.

It declared that striped bass remained a “green light” fishery, and decided that acting in accord with the scientific advice would constitute “overmanaging.”  It elevated the concerns of the fishing industry above the needs of the fish.  Tnat was demonstrated in the comments of one Management Board member, Vito Calomo, the legislative proxy from Massachusetts, who said,

“in this economy, we have real big problems, and allowing people to fish, whether commercial or recreational, doesn’t mean anything to me.  I just look at the jobs.  The jobs are needed real bad in the history of my lifetime as they are today.  [sic]  The green light, red light, yellow light, right now fishing is still good.  They’re seeing plenty of fish…

“Erring on the side of caution in times that are good and the economy, I would say maybe that’s the way to go.  At this time I think we need to continue fishing…

“I don’t believe the Atlantic States Marine Fisheries Commission should lose sight of their position.  They should revert back to where they came from, their history of making decisions that were good for the fishing and the fishermen.  [emphasis added]”

In the end, the Management Board focused on the fact that, “right now fishing is still good,” that fishermen were, “right now…seeing plenty of fish,” and that the striped bass hadn’t fallen on hard times yet, and elected for “management stability,” rather than for meaningful action to prevent the stock from declining further.

We’re still living with, and trying to undo, the consequences of their inaction today.

The same can be said about “flexibility.”

When the 2013 benchmark stock assessment effectively confirmed that the striped bass stock was in decline and that management actions were needed, the Management Board dithered.  Two “management triggers” contained in Amendment 6 required the Board to reduce fishing mortality to the target level within one year, and to initiate a rebuilding plan to restore the stock to target in 10 years or less.

The Management Board adopted Addendum IV to Amendment 6 tothe Atlantic Striped Bass Interstate Management Plan in 2014, but ignored Amendment 6’s clear direction that the Board “must” initiate a rebuilding plan, too.  And when the 2019 benchmark assessment that found the stock overfished and triggered another provision of Amendment 6 which said that the Board  “must” rebuild the stock, the Management Board ignored that provision, too.

The Management Board has already ignored two separate provisions of the management plan, both saying that it “must” take action to rebuild the stock, within a mere 5-year period. One can only sit back and wonder how much worse it would treat the striped bass resource if it was given even more “flexibility” to do nothing when the stock was in need, and such inaction was specifically condoned in the management plan.

So, getting back to the Goal and Objectives, striped bass anglers would do well to reject the notion that “management stability” and “flexibility” ought to govern Amendment 7’s outcome.  Instead, they ought to insist that Amendment 7’s Goal and Objectives—and all of Amendment 7, for that matter—emphasize restoring and maintaining the long-term health of the striped bass stock.

And the best way to do that may be to leave the goals and objectives largely the same as they are in Amendment 6, particularly that part of the Goal which talks about “the long-term maintenance of a broad age structure,” and the Objectives that seek “to maintain an age structure that provides adequate spawning potential to sustain long-term abundance of striped bass populations” and “a fishing mortality target that will result in a net increase in the abundance (pounds) of age 15 and older striped bass in the population.”

Here’s why that’s important.

Striped bass spawning success is dependent upon environmental conditions in the spawning rivers.  Cold winters followed by wet springs lead to successful spawns and usually, one year later, by strong recruitment of young fish into the populations; warm winters and dry springs, on the other hand, lead to less successful spawns and below-average recruitment.

A look at Maryland’s annual juvenile striped bass survey will show that, in most years, striped bass spawns fall into the below-average range, but that in about one-third of the years, the survey index rises well above the 11.7 average.  It’s those strongly above-average spawns that keep the striped bass stock healthy and able to support commercial and recreational fisheries.

No one can predict, years in advance, when the above-average spawns will occur.  Sometimes, as occurred during the years 1993-2003, very strong recruitment can occur every few years (in that case, in 1993, 1996, 2001, and 2003).  But sometimes, just the opposite happens, and striped bass recruitment stays low for a very long time.

Back in the 1970s and ‘80s—the years which include the last collapse of the striped bass stock—the Maryland juvenile index remained below 11 from 1973 through 1988, and only rose above even half that level—5.5—in just five of those sixteen years.

Back then, there was no effective striped bass management at all, and the fishing mortality rate was far too high to maintain an appreciable number of older, larger fish in the population.  With few large, fecund fish remaining in the spawning stock, and few younger females entering the striped bass population to eventually bolster the younger end of the spawning stock biomass, the collapse, in retrospect, was inevitable.

Managers should never allow the striped bass stock to find itself in such a situation again.

That is why the current Goal and Objectives, which recognize the need for an abundance of fish, for broad age structure, and for maintaining an adequate number of older, larger fish in the population, should remain largely unchanged.

The only exception to that recommendation is the sixth Objective which, as currently written, could be read to elevate “management stability” and “flexibility” above the health of the striped bass stock.  That one should be amended to read:

Adopt a long-term management regime that minimizes or eliminates the need to make annual changes or modifications to management measures; provided, however, that the Board shall act quickly and decisively when the best available scientific information indicates that the current management regime is inadequate to prevent a decline in the striped bass stock.

Other than that, the response to the Public Information Document’s “Issue 1” should be “No change is needed; the current Goal and Objectives are needed to adequately protect the long-term health and sustainability of the striped bass.”  

Then explain why.

-----

On Thursday, One Angler’s Voyage will look at another important issue in the Public Information Document, Issue 2:  Biological Reference Points.  That issue is intimately related to the goals and objectives, for the reference points finally adopted by the Management Board could determine the fate of the striped bass stock for the next twenty years.

 

 

 

FLY FISHING INDUSTRY CALLS FOR IMPROVED FISHERIES MANAGEMENT

 

Fish and the recreational fishing industry have long had a strange relationship.

The industry can’t survive without fish.  And not only without fish, but without enough fish to allow the average weekend warrior, with moderate to negligible skills and an aversion to fishing in inclement weather or getting out of bed before 9:00 a.m. on a Saturday morning, to still manage to catch enough of them to stay interested and buying bait, tackle, boats, and the like.

Yet any time fisheries managers propose regulations that might increase fish abundance or rebuild an overfished stock, members of the fishing industry, ranging from local tackle shop owners and representatives of the for-hire fleet to, if the fishery has been politicized enough (think Gulf of Mexico red snapper), tackle manufacturers and boatbuilders, all doing their best to oppose needed restrictions on harvest.

Probably the best—or the worst—example of that was the tackle and boatbuilding industry-sponsored report, “A Vision for Managing America’s Saltwater Recreational Fisheries,” which was issued under the aegis of the Theodore Roosevelt Conservation Partnership in 2014.

Stripped of its weasel words, emotional appeal, and pretty pictures, the Vision report made a handful of modest requests on behalf of the tackle and boatbuilding industries:

·         Take the fish away from commercial fishermen and give them to anglers, so that they can take more fish home and we can make more money;

·         Don’t set annual catch limits for anglers, so that they can take more fish home and we can make more money;

·         If anglers overfish, don’t hold them accountable, so that they can take more fish home and we can make more money;

·         Anglers should be given more time to rebuild recreationally-important stocks of fish, so that they can take more fish home and we can make more money;

and, sort of as an afterthought,

·         Protect forage fish, because anglers don’t want to take them home, and it won’t cost us money, and the bigger fish do like to eat them.

You might say that it took a one-sided view.

Although the Vision report gave lip service to fisheries conservation, every time the long-term health of fish stocks clashed with the short-term goals of increasing recreational landings and recreational industry profits, the interests of the fish were subordinated to those of the industry.  Which, in the end, was a strange way to go about things, because the Marine Recreational Information Program’s angler effort data shows that angler participation—and, undoubtedly, angler spending on tackle and such—is closely linked to fish abundance.

Yesterday, the American Fly Fishing Trades Association issued its report, “Recommendations to Improve the Health and Sustainability of America’s Marine Resources,” which illustrates that the fly fishing industry, at least, understands the connection between healthy fishing businesses and healthy fish stocks.  As noted in the introduction to the report,

“Saltwater fly fishing is the fastest growing segment of the fly fishing industry.  It is responsible for attracting new entrants to the sport, and it offers a compelling growth opportunity for our industry, and for job creation in coastal communities.

“At the same time, threats to healthy marine fisheries and their habitats are numerous and deserve our concern and attention…Without dramatic action, our marine fisheries and habitats—and saltwater fly fishing—have a tough road ahead.  As the voice of the fly fishing industry, AFFTA believes that it our responsibility to advocate for the solutions that will allow ocean fisheries—and our members—to thrive over the long term…

“AFFTA undertook a rigorous process to identify and better understand the primary threats to healthy marine fisheries and habitats, and to determine policy solutions capable of addressing these threats head-on…

“As we worked through this process, it became clear that the continued growth of the fly fishing industry will require bold federal fisheries management and marine conservation efforts guided by the best available science…” 

“Responsibility.”  “”Long term.”  “Bold federal fisheries management.”  “Conservation efforts guided by the best available science.”

When have you ever heard a recreational fishing industry group use words and phrases like those before?

We’re so used to hearing industry babble about federal fisheries management “disenfranchising America’s recreational anglers,” protecting “the rights of recreational fishermen,” and similar tripe, that seeing someone actually talk about taking responsibility for making things better, and taking a long-term view, is almost shocking.  It’s something like being in a roomful of kindergarten kids all day, and then finally escaping into the company of rational adults.

And rational adults are exactly what we need if we’re going to have sustainable fisheries for the foreseeable future, because the other folks are still out there, trying to take what they can get for themselves before everything falls apart.

Fortunately, there are also folks like those at AFFTA, who are trying to hold a good fisheries management system together and even—dare I say it—make it better.

Thus, we see them calling on fisheries managers to rebuild imperiled and overfished species.  At the federal level, they want to

“Uphold the science-based measures that end and prevent overfishing and ensure prompt rebuilding of federal fisheries.”

Unfortunately, not every fishery is managed under the federal management system.  Many are managed by state agencies, which are generally under no legal obligation to manage stocks in a sustainable manner; at the state level, management often has more to do with politics than with science.  That’s particularly true at the Atlantic States Marine Fisheries Commission, an organization that has not managed to rebuild a single overfished stock, and then maintain such stock at sustainable levels, since it was formed in 1942.

It has even allowed the striped bass, once its sole success story, to become overfished and subject to overfishing again.

Thus, it’s heartening to see that AFFTA seeks to

“Extend proven conservation requirements to fisheries managed by the Atlantic States Marine Fisheries Commission,”

make the ASMFC legally obligated to

“Require an immediate end to overfishing, establish annual catch limits for all stocks, and impose accountability measures when catch limits are exceeded,”

and

“Require within two years a rebuilding plan intended to fully rebuild the stock within a specific time period for any stock designated as overfished.”

If that latter rule had already been in effect, we’d have a striped bass rebuilding plan in place by this coming May, instead of the “never” that seems to be the scheduled-in deadline on the ASMFC’s current agenda.

Of course, there is more to the U.S. than the Atlantic Coast, so AFTTA also wants to

“Improve recovery efforts for wild salmon and steelhead in the Pacific Northwest.”

In case anyone was wondering, that means an effort to

“Significantly reduce reliance on hatcheries to recover and maintain genetically diverse wild salmon and steelhead populations.”

That’s a very different stand from that taken by the “Vision” crowd, which is trying to expand hatchery use, euphemized as “stock enhancement,” into saltwater fisheries as an alternative to science-based regulations adequate to preserve native fish stocks.

The AFFTA report then goes beyond merely rebuilding overfished stocks, to reach the essence of what recreational fishermen really need:  stocks managed for an abundance of fish in the water, not merely a load of dead fish on the dock.  To that end, it would like to see fisheries managers required to

“Account for the economic and social importance of abundance to recreational fisheries when setting optimum yield for fisheries,”

and

“include goals and objectives in a fishery management plan that address the value of having an abundance of fish in the water.”

Because fishing in a largely empty ocean isn’t much fun, and gives little reason to spend money on fishing gear.

Yet if there are a lot of fish out there, they need something to eat, so AFFTA also would also require managers to

“Promote abundance by ensuring forage fish are managed in a way that acknowledges their role as a food source,”

which may be the only place where their views and that of the Vision crowd coincides.

Other issues are discussed in the AFFTA report.  The above comments barely scratch the surface of the well-thought-out, 36 page document.  But they give you a taste of what happens when people actually think, and come to the realization that fisheries conservation isn’t a threat to the fishing industry but, in the end, is the only thing that will keep the industry alive.

Healthy, sustainable fish stocks are a prerequisite to a healthy, sustainable fishing industry.

AFFTA has figured that out, and presented that truth in a report that will, hopefully, have a real impact on fisheries policy.

We should all be glad that they did.

-----

Full disclosure:  I was one of the many people who contributed to the AFFTA report, and am proud to have been a part of the team.

UNDERSTANDING STRIPED BASS RELEASE MORTALITY, AND ITS IMPACT ON THE STOCK

Ever since the latest benchmark assessment of the striped bass stock, released in 2019, revealed that nearly half of all fishing mortality resulted from fish that didn’t survive after being returned to the water by anglers, striped bass release mortality has been a hot topic for East Coast fishery managers.

A Work Group assembled by the Atlantic States Marine Fisheries Commission’s Atlantic Striped Bass Management Board, in order to provide some direction on issues that should be addressed in the proposed Amendment 7 to the ASMFC’s striped bass management plan, noted last August that

“Multiple members of the [Work Group] indicted that recreational dead discards may be the single most important issue at this time, and addressing (or reducing discards) is the most important action that can be taken going forward.  Many [Work Group] members pointed to the fact that recreational discards accounted for just under 50% of the fishing mortality as basis for the critical need to address this issue…”

A desire to reduce striped bass fishing mortality was also the impetus behind the provision in Addendum VI to Amendment 6 to the Atlantic Striped Bass Interstate Fishery Management Plan that requires all states to adopt regulations requiring striped bass fishermen to use non-offset fishing hooks when fishing with bait.

Given the impact of recreational release mortality on the striped bass stock, the Management Board asked the ASMFC’s Atlantic Striped Bass Technical Committee to run the striped bass stock assessment model again, using different assumptions for the release mortality rate, to determine whether such mortality rates would materially impact the conclusions reached in the benchmark assessment.

The short answer is no.  

Whether the release mortality rate was the best-case 3%, the worst-case 26%, or the 9% used in the original benchmark assessment (all of which come from a Massachusetts study and a subsequent paper authored by Paul J. Deodati and R. Anne Richards in 1996), or a blended mortality rate that takes differing seasonal or regional mortality rates into consideration, the conclusions would have been the same:  the striped bass stock is overfished, and experiencing overfishing.

Since the results of the Technical Committee’s research were reported at last week’s Management Board meeting, it seems that some individuals in the angling community might have misinterpreted exactly what the report itself says about the importance of release mortality.  Some appear to believe that the Techincial Committee concluded that release mortality isn't very important.

That's not true.

What the Technical Committee did, and later reported on, was to perform a “sensitivity analysis” to determine how sensitive the population model used for the benchmark assessment would be to differing rates of release mortality.  In performing such analysis, the Technical Committee looked backwards, to see how using different fishing mortality rates would have affected the outcome of the benchmark stock assessment.

They concluded that the impacts would be minimal.

That’s not surprising.   The benchmark assessment was based, in part, on a number of fishery-dependent and fishery-independent surveys that, when run through a population model, allow biologists to estimate the size of the current striped bass population, along with the size of each individual year class of fish as they make their way through the stock.  

To come up with that estimate, scientists must know, among other things, how many fish are removed from the stock each year, whether such removals are a result of natural mortality, harvest, or fish that die after being released.  Knowing how the stock responds to such removals, in light of the current population size, estimated recruitment of new fish into the stock, and similar factors, allows biologists to calculate the target fishing mortality rate, the fishing mortality rate where overfishing begins to occur, the target biomass or spawning stock biomass, and the point at which biomass drops so low that a stock becomes overfished.

All of the parameters are interconnected.  Thus, if fishing mortality was higher than the scientists originally believed—perhaps because the release mortality rate was 26% instead of 9%--the initial population had to be larger than scientists originally believed, too.  Otherwise, it would be impossible for there to be as many striped bass around as there are today. 

Similarly, if the release mortality rate was lower than believed—for example, 3% instead of 9%--then the stock was probably a little smaller than believed, as well, because even at the lower mortality rate, the stock is no bigger than it is at this time. 

Unfortunately, some anglers are looking at the fact that differing estimates of past release mortality didn't materially change the current status of the stock, and coming to the conclusion that, looking forward, the rate of release mortality will not materially affect the fishing mortality rate in the future, nor the size of the spawning stock biomass.

That conclusion is wrong.

In 2017, the terminal year of the benchmark stock assessment, recreational release mortality constituted 48% of all striped bass fishing mortality.  Every fish that dies after being released by an angler contributes to overall fishing mortality, as does every fish that is retained by an angler, harvested by a commercial fisherman, or is shoveled over the side and dies after ending up in a trawl.

It doesn't matter how a fish dies; all are removed from the spawning stock biomass.

Thus, if recreational fishing mortality could be cut in half, we could see an approximately 24% reduction in overall striped bass fishing mortality—one-third more than the reduction that Addendum VI was hoped to achieve—without making any reduction at all in the number of fish actually landed by recreational or commercial fishermen.

Thus, reducing release mortality, to the extent reasonably possible, is a worthwhile goal for fisheries managers, but only when viewed in the context of reducing overall fishing mortality.  For it’s overall mortality that matters.

Striped bass won’t be rebuilt unless the overall fishing mortality rate is low enough to allow that to happen.  So managers should try to eliminate unnecessary release mortality; requiring circle hooks to be used when fishing for bait is one important step toward that goal.

But managers would be wrong to focus merely on release mortality.  If they were able to reduce overall mortality enough to allow the stock to rebuild, even if that meant that release mortality increased to some degree, the bass would be in a better place than they are today.

 

 

 

 

 

STRIPED BASS AMENDMENT 7: IT'S NOW UP TO YOU

 

Yesterday, as expected, the Atlantic States Marine Fisheries Commission’s Atlantic Striped Bass Management Board hastily agreed to approve the Public Information Document for Amendment 7 to its striped bass management plan, and send it out for public comment.

Releasing the Public Information Document is the first step toward drafting and adopting a new amendment to the ASMFC’s Interstate Fishery Management Plan for Atlantic Striped Bass, and could result in real and significant changes in the way striped bass are managed for the next couple of decades.  If Amendment 7 gets things wrong, and the bass population goes into steep decline, those of us who lived through the first stock collapse probably won’t live long enough to see them recover from the next one—assuming that recovery is on the table.

Now that the Public Information Document has been approved for release, the ASMFC will soon make it available on its website, and begin seeking public comment on the issues raised in the PID.  The public comment that results will go a long way toward shaping the rest of the Amendment 7 debate.

Thus, it would make sense for the Management Board to get everything right, and make sure that the PID provides the public with all of the information that it needs to make rational, fully informed comments on striped bass management when they get their chance to do so.  Last week, I suggested—without much hope that it would actually happen—that the Management Board ought to slow down for a while, and not take any more action until the ASMFC can hold in-person meetings on the PID; get reliable data on how Addendum VI to Amendment 6 to the management plank, adopted last October, was impacting fishing mortality; and perhaps even see the results of two important new studies being conducted by the Commonwealth of Massachusetts, which could provide information that will be very relevant to the Amendment 7 process.

But getting the PID right didn’t seem to be as important to the Management Board as getting a flawed document out to the public as quickly as possible.

And the PID is certainly flawed. 

Capt. John McMurray, the legislative proxy from New York, did his best to put it on the right track, but found himself fighting alone.  Thus, when the average angler, who doesn’t follow fisheries issues very closely, reads the PID, that angler will be presented with the statement that

“the 2007 and 2013 benchmark assessments, indicated female [spawning stock biomass] was above the [spawning stock biomass] was above the target for a period of time during the early 2000s.  This fits our understanding of striped bass population dynamics, as the population was considered to be at a historically high level during that time period…Given the 2018 benchmark assessment found overfishing was occurring and the [spawning stock biomass] was below the target even during those years that the spawning stock biomass was at a historically high level, the current reference points may be unattainable.  [emphasis added]”

Go back and re-read that section, and maybe go back and read it a third time, and let its full meaning set in. 

Wade through the words long enough, and you realize that they’re arguing that, because fishery managers at the ASMFC knowingly allowed too many bass to be removed from the population under Amendment 6, the failure of the overfished stock to achieve the target spawning stock biomass proves that such biomass could be “unattainable.”

What the PID doesn’t say is that there is not a shred of science to support the statement; the latest benchmark stock assessment, which was peer reviewed by a panel of recognized experts, suggests that if fishing mortality was reduced to target, target spawning stock biomass could be achieved. 

Yet the Management Board had no problem sending that sort of biased language out to stakeholders, at least some of whom are likely to believe that it’s true.

Worse, because the language in question says that the “current reference points,” and not merely the current biomass reference points, are unattainable, it’s also suggesting that it may be impossible to reduce fishing mortality to the target level, something that is patently untrue.  The only reason that fishing mortality is too high today (I can give the Management Board some benefit of the doubt for it being too high 15 years ago, because back then, no one realized how many bass recreational fishermen were really removing from the stock) is because every time it is given a chance to reduce fishing mortality to the science-based target, the Management Board fails to summon the political courage to impose the needed harvest restrictions. 

Instead, it repeatedly caves in to New Jersey and Maryland and anyone else who wants to kill too many striped bass.

Yet when Capt. McMurray pointed out that the PID shouldn’t include statements that were unsupported by science, not a single Management Board member stood with him to support that seemingly obvious truth. 

Meagan Ware, a fisheries scientist from Maine and one of the co-chairs of the Work Group that provided recommendations on the scope of the PID, did admit that she was “uncomfortable” with the PID’s statement about the reference points, and added the following qualifying words to the section:

“given current objectives for fishery performance.”

I’m not sure whether that made it better or worse, since the qualification essentially admits that the only reason that the reference points might be “unattainable” is that at least some states’ “current objectives for fishery performance” is simply to harvest as many bass as possible, without regard for the health of the stock.   

On the other hand, the current “objectives for fishery performance” spelled out in the management plan include

“Manage striped bass fisheries under a control rule designed to maintain stock size at or above the target female spawning stock biomass level and a level of fishing mortality at or below the target exploitation rate, [emphasis added]”

“Maintain fishing mortality to maintain an age structure that provides adequate spawning potential to sustain long-term abundance of striped bass populations [emphasis added]”

and

“Establish a fishing mortality target that will result in a net increase in abundance (pounds) of age 15 and older striped bass in the population, relative to the 2000 estimate.”

There’s certainly nothing in any of those current objectives—which were all formally approved and adopted by the ASMFC—that would render the current reference points “unattainable.”  All would takes is summoning the courage to follow through with what the Management Board had promised the public it would do when Amendment 6 was adopted in 2003.

So far that sort of moral courage has been in notably short supply at the Management Board. 

It was definitely lacking yesterday, when no one other than Ms. Ware and Capt. McMurray was willing to admit that there might be something wrong with foisting a scientifically unproven statement off on an unsuspecting striped bass fishing public (and there were more such statements included in the PID but not discussed, including one warning that “management measures focusing on reducing discards could discourage participation from anglers that value food fish and negatively impact the industry that caters to those anglers”), and then seeking their comments in response.

I couldn’t help but notice that those who typically champion “conservation” in the abstract were notably absent from the discussion of that particular topic.

Yet, when you look at the history of the ASMFC, there’s nothing new about a handful of Management Board members wanting to kill too many bass, and the rest of the Management Board letting them do it.

I can still recall the fight over Amendment 6 to the striped bass management plan that took place twenty years ago.  There was one contingent who wanted to focus on yield, and set the target fishing mortality rate at 0.41, which was thought, at the time, to approximate maximum sustainable yield.  I was part of another contingent who, armed with data developed by the Northeast Fisheries Science Center, recommended setting the target somewhere between 0.20 and 0.25, which would have allowed more large spawning females to survive, and so increase the number of larger, older fish in the spawning stock. 

The Management Board ended up cutting the baby in half, setting a compromise fishing mortality target of 0.30 that supposedly

“provides a higher long-term yield from the fishery and adequate protection to ensure that the striped bass population is not reduced to a level where the spawning potential is adversely affected.”

But cutting the baby in half, while perhaps a fair compromise, doesn’t do the baby much good, and the current state of the striped bass population pretty well shows us how such compromises typically work out for the bass.  The latest benchmark stock assessment informs us that the appropriate fishing mortality rate is about 0.20—at the low end of the range that we were arguing for back in 2001.

So yes, the Management Board had reason to know that they were allowing too many bass to be killed back in 2003, and so also has reason to know, today, that if proper regulations were put in place, the current reference points would probably not be “unattainable.”  But they also know that it could be politically unpopular among some constituencies and in some states to adopt such rules, and maybe that’s why they had no problem letting the bad language stand.

Now that the PID has been approved for release, it’s up to you—up to us—to shepherd a reluctant Management Board down the right path, and keep them from exposing the already-depleted striped bass stock to additional hazard.

It’s not going to be easy. 

Maryland seems to have a lot of sway with the Management Board, and Michael Luisi, the Maryland fisheries manager, has already begun his push for a bigger kill.  John Clark, his counterpart from Delaware, is just as avidly looking to reduce the biomass target and increase Delaware’s commercial landings—at yesterday’s meeting, he took full credit for putting the “unattainable” language in the PID.  And New Jersey, well, you know where they always stand.

To steal a line from President George W. Bush, those three states constitute an “axis of evil” on the Management Board, that will continue to threaten the long-term sustainability of the striped bass stock unless they are decisively defeated.

Twenty years ago, when Amendment 7 was being drafted, we faced the same sort of opponents of striped bass conservation—in one or two cases, it’s still the same people who are calling for a bigger kill.  Back then, we didn’t get the fishing mortality target that we wanted, but we also prevented the target from being set at 0.41, which in itself was a sort of win.  And we convinced the Management Board to adopt the objectives of maintaining the age structure of the spawning stock and increasing the number of older, larger fish in the population.  Those were wins, too, even if they were smaller wins than we were hoping for.

Today, when I look at the PID that was approved yesterday, it feels like we’re back where we were two decades ago, making the same arguments, for the same reasons, that we did back then.  Although then we were dealing with a healthy and, we thought, fully restored stock, while today we’re dealing with a stock that is overfished and in need of recovery.

It’s a stock that needs a real win even more than we do.

So now, with the PID approved and being released to the public soon, it’s time to forget about the times that the Management Board didn’t listen to public comments, and shake off the disappointments of past defeats that might make us want to throw up our hands in frustration.  For make no mistake—if you’re anywhere close to might age, this is the big fight that could decide how striped bass are managed for the rest of your lifetime. 

I’m gearing up for the fight, and you should be getting ready, too.  You can’t afford to sit on the sidelines.

Having said that, I do think that yesterday’s meeting should have been rescheduled for February 2^nd, instead of the 3^rd.

Because after being part of the fight over Amendment 6, which was bitter and lasted three years. when I heard the Management Board push through the flawed PID, containing all the same issues we debated back then, it sure as Hell felt just like Groundhog Day.

CAN MAGNUSON-STEVENS STOCK REBUILDING PROVISIONS BE IMPROVED?

The Magnuson-Stevens Fishery Conservation and Management Act (Magnuson-Stevens) is probably the most comprehensive, and most successful, marine fishery conservation law in the world. Since the year 2000, it has been responsible for rebuilding 47 once-overfished stocks; other overfished stocks are well on their way to recovery.

Much of that success can be attributed to the fact that Magnuson-Stevens doesn’t merely give federal fishery managers the option of rebuilding overfished stocks; instead, it requires them to do so, and sets a firm deadline for achieving that goal. If a stock is found to be overfished or approaching an overfished condition, the National Marine Fisheries Service (NMFS) must put a rebuilding plan into effect within two years. Once such a plan is in place, it must rebuild the stock in no more than 10 years, unless it is biologically impossible to do so, or the stock is managed pursuant to an international agreement. In any event, rebuilding must be completed in as short a time as possible, given the prevailing circumstances.

Yet Magnuson-Stevens hasn’t met with success in every fishery. Some remain stubbornly unwilling to rebuild. Many of those are located in New England, where the New England Fishery Management Council often adopts rebuilding plans that are insufficiently risk averse. While such management plans successfully limit the short-term hardships that fishermen would experience under more restrictive management regimes, they do long-term harm to the health of fish stocks.

As a result, historically important stocks such as Georges Bank cod, Gulf of Maine cod and Southern New England/Mid-Atlantic winter flounder have remained overfished for many years, and show few signs of recovery. As such fish remain scarce, it is clear that the less risk averse plans didn’t avoid causing hardship to fishermen; by failing to rebuild badly depleted stocks, they instead forced fishermen to endure hardship over a much longer period of time, which has yet to come to an end.

But there is now hope that an end to such hardship might, just possibly, be in sight.

In late December 2020, Rep. Jared Huffman (D-CA), chair of the House Natural Resources Water, Oceans, and Wildlife Subcommittee, and Ed Case (D-HI), a subcommittee member, released the discussion draft of a Magnuson-Stevens reauthorization bill. That draft contained a number of provisions that would strengthen the stock rebuilding provisions of Magnuson-Stevens.

One of the provisions would make it easier for fisheries managers to determine whether a stock has, in fact, become overfished.

Currently, Magnuson-Stevens requires that all federal fishery management plans “specify objective and measurable criteria for identifying when the fishery to which the plan applies is overfished.” To satisfy that requirement, management plans will typically deem a stock to be overfished when its spawning stock biomass falls beneath a specified threshold, which is most often 50% of the biomass needed to produce maximum sustainable yield. Problems arise when scientists lack the data to calculate whether the criteria specified in the management plan have been met.

When that happens, scientists may not declare a stock overfished, even when they know that spawning stock biomass has declined sharply. Instead, as recently occurred in a stock assessment for Gulf of Maine winter flounder, they may only declare that “biomass based reference points cannot be determined and overfished status is unknown,” while also noting that both recreational and commercial landings have fallen sharply in recent decades, a long-term trend that could reflect declining abundance.

The discussion draft’s proposed language would allow fishery managers greater discretion, allowing them to declare a stock to be “overfished” if “the best available scientific information” suggests that is the case, even if clear criteria identifying when such stock is overfished is not available.

Yet the mere facts that a stock has been deemed to be overfished, and a rebuilding plan has been put in place, does not mean that such rebuilding plan will be successful. Gulf of Maine cod have been overfished since at least 2001, and probably for long before that, if the current criteria for gauging stock status had been applied in earlier assessments. The first rebuilding plan for Gulf of Maine cod was unsuccessful; the stock remained overfished. A second rebuilding plan, initiated in 2014, is supposed to rebuild the stock by 2024. But with the spawning stock biomass totaling only 3,838 metric tons, which is only somewhere between 6% and 9% of the rebuilding target, in 2018, it is very likely that the second rebuilding plan is going to fail as well.

If that happens, the NMFS will undoubtedly initiate a third rebuilding plan, which will probably look much like the two previous, unsuccessful rebuilding plans. It will undoubtedly try to balance mitigating the burdens placed on fishermen with the legal requirement that the rebuilding plan have at least a 50% probability of achieving its goals. If, under such new rebuilding plan, the stock didn’t make “adequate progress” toward its rebuilding goal, the NMFS would have to “immediately make revisions to achieve adequate progress,” but the rebuilding plan wouldn’t have to define what such “adequate progress” might look like.

The language proposed in the discussion draft would address those issues as well.

First, it would require every fishery management plan to “contain objective and measurable criteria for evaluating rebuilding progress.” Then, it would establish clear criteria that would signal to the NMFS that adequate progress was not being made.

The discussion draft’s proposed language states that

The Secretary [of Commerce] shall find a lack of adequate progress toward ending overfishing and rebuilding an affected fish stock if (i) the status of the stock is not improving sufficiently such that it becomes unlikely that the stock will be rebuilt during the rebuilding time period; (ii) the applicable fishing mortality rate or annual catch limits are exceeded, and the causes and rebuilding consequences of such exceedances have not been corrected; (iii) the rebuilding expectations are fundamentally changed due to new scientific information about the stock, and the new information indicates that the current rebuilding plan is inadequate to address the stock’s rebuilding needs; or (iv) for other reasons, as appropriate. [internal formatting deleted]

If such language was added to Magnuson-Stevens, the NMFS would not be able to let an overfished stock languish, or see overfishing occur, without taking the action needed to put such stock back on the path to rebuilding by the scheduled date.

If, despite the agency’s efforts, a stock still remains overfished on the scheduled rebuilding date, a new rebuilding plan would have to be prepared. But given the failure of the original rebuilding plan, any such new rebuilding plan would be required to have at least a 75% probability of successfully rebuilding the overfished stock.

Such a provision would make any successor rebuilding plan more restrictive than the original, failed plan. It would make it more likely that other fish stocks will not share the fate of the Gulf of Maine cod, which will almost certainly have to undergo a third consecutive rebuilding plan before it has any realistic chance of being restored.

Magnuson-Stevens is already a very good fisheries conservation and management law. But changes to its stock rebuilding provisions, as provided in the discussion draft, would make it even better. If such changes are made, species such as Atlantic cod and winter flounder, which have so far fallen through the cracks of then management system, would finally have a reasonable chance of being rebuilt.

Fishermen across the nation would do well to see those changes become law.

-----

This essay first appeared in “From the Waterfront,” the blog of the Marine Fish Conservation Network, which can be found at http://conservefish.org/blog/

 

 

STRIPED BASS AMENDMENT 7: ASMFC SHOULD TAKE THE TIME TO GET IT RIGHT

 

On Wednesday, February 3, the Atlantic States Marine Fisheries Commission’s Atlantic Striped Bass Management Board will review the draft Public Information Document For Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass.  It is very likely, although not absolutely certain, that after such review, the Management Board will approve the Public Information Document for public comment, thus formally kicking off the process that will eventually lead to changes—perhaps very significant changes—in the way striped bass will be managed.

Those changes could have a very serious impact on the future health of the striped bass stock.

Right now, it’s very hard to predict what that impact will be, as there are two competing factions on the Management Board, and the future of the striped bass stock, and the striped bass fishery, will depend on which of those factions prevails.

One faction is composed of Management Board members who want to better assure the long-term health of the striped bass fishery.  They recognize that the current management approach failed to prevent the striped bass stock from becoming overfished, and experiencing overfishing, once again, after being rebuilt following its collapse in the late 1970s and early 1980s.  In general, they support science-based management, more effective regulation of striped bass fisheries, and ending some of the current abuses that exist in the management process.

The other faction, which is centered in the three states of New Jersey, Maryland, and Delaware, is less concerned with the long-term health of the striped bass stock, and far more concerned with the short-term economic well-being of their fishing industries.  It generally seeks laxer regulations and higher landings, while shunning any accountability for excessive recreational harvest.  Members of the faction have expressed a willingness to change the reference points used to gauge stock health, even though doing so would permanently reduce striped bass abundance and increase the risk that the stock could decline to dangerously low levels.

So far, it seems like the wrong folks are winning.

Late last July, a “work group” created by the Management Board issued a report suggesting what the new amendment ought to address.  The work group was reasonably balanced, with three members from the usually conservation-minded New England states and three from New Jersey, Maryland, and the Potomac River fisheries commissions, jurisdictions that have historically prioritized harvest over the health of the stock.  

Given that the striped bass stock is overfished, and that the recent management action taken to reduce landings had only a 41 percent probability of reducing fishing mortality to the target level, it would have been reasonable to expect that the work group would have prioritized rebuilding the stock, and adopting measures to prevent overfishing and prevent the stock from being overfished once again (assuming that the stock is successfully rebuilt this time).

But that’s not what happened.

Instead, the work group emphasized three factors—management stability, flexibility, and regulatory consistency—as “themes” that should guide the Amendment 7 drafting process.

“Management stability” would promote maintaining consistent regulations over a period of years, which sounds nice on its face.  However, the Management Board’s history shows that it is already far too willing to promote such stability at the cost of the striped bass stock; perhaps the best example of that is when it sat on its hands in 2011, maintaining “management stability” even after a stock assessment update warned that, under any foreseeable recruitment scenario, the stock would become overfished by 2017 if fishing mortality wasn’t reduced.  As it turned out, the stock became overfished even more quickly than the assessment update predicted, as fishing mortality had been higher than managers believed at the time.

It’s hard to imagine building even more opportunity for inaction into Amendment 7, but that’s where the work group would seem to be headed.

A similar comment could be made about “flexibility” which, in the fisheries management context, is merely a euphemism for taking no action, even when the management plan requires that something be done. 

But the Management Board is already experienced at doing that, too.

Amendment 6 to the Interstate Fishery Management Plan for Atlantic Striped Bass explicitly states that

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

Amendment 6 also states that

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

Both of those passages are pretty clear about what the Management Board “must” do if the specified triggers are tripped.  Yet, when the 2013 benchmark stock assessment revealed that the biomass had fallen below target for two consecutive years, and that the fishing mortality had risen above target as well, the Management Board did absolutely nothing to rebuild the stock within the specified time.

Instead, it took comfort in the advice of Michael Waine, then the Fishery Management Plan Coordinator, who advised

“Management Trigger 2 [sic] in Amendment 6 says that you need to rebuild the SSB back to its target over a specified timeframe that should not exceed 10 years.  I think that there is sort of a combination of things happening.  The board is acting to reduce F.  Through that action we see the projection showing that SSB will start increasing toward its target, but we’re uncomfortable with projecting out far enough to tell you when it will reach its target because the further on the projections we go the more uncertainty is involved.  Therefore, I think the trend is to go back towards the target, but we can’t tell you that exactly how quickly that’s going to happen.”

As a practical matter, Waine advised the Management Board to ignore an explicit requirement of the management plan, advice that the Board was happy to follow.

Five years later, after the latest stock assessment found that the striped bass stock was overfished, the second provision kicked in.  This time, Max Appelman, who had replaced Waine as Fishery Management Plan Coordinator, did what he was supposed to do and reminded the Management Board of its rebuilding obligation, saying that

“the ten year clock began in May when the information [that the stock was overfished] was presented to the Board.”

But the Management Board roundly ignored him, deciding to move forward with Amendment 7 instead of a rebuilding plan.

Given that the Management Board knowingly flouted two supposedly mandatory provisions of the management plan over the course of only five years, it’s frightening to think that the work group believes that giving the Board even more “flexibility” to do nothing is a good idea.

Fortunately, the work group only advises the Management Board, which will make the final decisions on Amendment 7.  ‘

And perhaps the first, and one of the most important, decisions that the Management Board ought to make is to slow down.

If the Public Information Document is approved for public comment next week, the odds are that the public comment period will end sometime before the Management Board’s May meeting.  That means  either that public hearings will have to be held, putting people at risk of contracting COVID-19 before they have a reasonable expectation of being vaccinated against the disease, or comments will have to be taken in webinars that, given the number of responses striped bass amendments normally generate, will probably severely limit the opportunities for anglers to be heard.

Neither of those is a good alternative.

Delay will also provide time for some very important information to be provided to the Management Board, which would inform the Amendment 7 process.

One of those would be an update to the stock assessment.  Such an update was originally scheduled for 2021, so that managers could get some idea of how the striped bass stock has reacted to the regulations imposed, for the first time, in 2020.  But because of COVID-19, and its impacts on the Marine Recreational Information Program’s in-person angler intercepts, there are still no estimates of recreational landings and discards for 2020, and the stock assessment update has been delayed until 2022, when 2021 data will hopefully be available.

In addition, there are two studies currently being conducted by Massachusetts which are very relevant to Amendment 7.  One is probably going to provide a lot of important new information about striped bass release mortality.  The other is a genetic study that will help managers understand where the bass that migrate into New England are spawned.

Drafting a document that is as important to the striped bass’ future as Amendment 7, in a time when COVID-19 has not yet abated, with no recent recreational catch data, no updated assessment, and without the results of the two Massachusetts studies, seems foolish.

Better to wait a year or so, and so have the information needed to get everything right.

Dr. Michael Armstrong, a top fisheries manager for the state of Massachusetts, supported delay at last August’s Management Board meeting.  He said

“We have a lot to talk about, particularly reference points and rebuilding, and all that.  We need an enormous amount of public input.  I’m looking at us having two or three Board meeting, one or two public hearings, through this kind of [webinar] venue.

“Having recently gone through it at home, here for the public hearing, I wouldn’t call it a success.  It is very, very difficult to present a serious subject and get feedback.  I do think this Amendment needs to be postponed…

“Boy, I think it is irresponsible for us to try and get public input while under this [pandemic] condition.  We’re looking at maybe next May meeting in person, maybe.  I would say the better bet is a year from now.  I would vote to postpone this indefinitely, and not do any serious work, in terms of public hearing…

“I think we ought to get a look at what is going on with the assessment next year, before we really move forward with an amendment.  We’re flying blind at this point, and we’re flying without appropriate public input…  [emphasis added]” 

It was a very rational argument.  Dr. Justin Davis, Connecticut’s fishery manager, concurred, as did John McMurray, New York’s legislative proxy, Dennis Abbott, the legislative proxy from New Hampshire, and even Tom Fote, New Jersey’s governor’s appointee.  But it failed to convince a majority of the Management Board, so the Amendment process moved forward.

Thus, on Wednesday, the Management Board will review the Public Information Document for a second time.  And then it needs to make a choice.

Does it send the Public Information Document out for public hearing, knowing full well that, in the age of COVID-19, the public response will likely be muted and haphazard, and also knowing that it lacks current information on the state of the stock, recreational landings, and discard mortality?

Does it decide, as Dr. Armstrong characterized things, to fly blind?

Or does it act responsibly, recognize that it is better to do things right than to do things quickly, and delay work on Amendment 7 until the pandemic abates and needed information is finally available?

Given the ASMFC’s penchant for doing the wrong thing for the wrong reasons, I suspect it will choose a quick shot in the dark over waiting to be enlightened by new information.

I hope that I’m wrong.