STRIPED BASS: THE RECREATIONAL FISHING INDUSTRY VERSUS THE RECREATIONAL FISHERMEN

 

The recent discussions impacting striped bass conservation, and the need to rebuild the spawning stock biomass by the 2029 deadline imposed in the management plan, have been disappointing in many respects.

The data on which any management measures must be based is, at best uncertain, with biologists forced to make projections of 2024 landings, future fishing mortality rates, and so the trajectory of the spawning stock biomass based on information that is not really sufficient for the scientists’ needs.  So it’s probably not surprising that the Technical Committee came up with a disappointing set of no-harvest (and no-target) options that would impose punitive closures on some states, particularly in northern New England, where seasons are already short, while allowing anglers in long-season states such as New Jersey to escape the same sort of consequences.  And, given that the coastwide size limit hasn’t fallen below 28 inches since the mid-1980s, it’s understandable, yet also disappointing, that the Technical Committee lacked the data to adequately analyze the impact that reducing the slot limit below 28 inches would have on striped bass landings in 2025 and beyond.

But perhaps the most disappointing thing about the debate is how the recreational fishing industry has come together to oppose conservative management measures, in order to  maintain their short-term profits and the status quo, while recreational fishermen, who have generally shown concern for the health of the striped bass resource, have failed to find common ground and instead have broken up into myriad factions, making it much more likely that the industry will win the stasis that it is seeking, and that the striped bass will lose.

Historically, the recreational fishing industry, by which I mean both the for-hire fleet and at least the retail side of the fishing tackle business, has opposed striped bass conservation.  Here in New York, that opposition dates back to at least 1995, when the striped bass stock was first declared “fully rebuilt” after it had collapsed a decade and a half before.

Amendment 5 to the Interstate Fishery Management Plan for Atlantic Striped Bass had just been released.  It allowed states to drop their size limit from the 34 inches permitted by the previous Amendment 4 to just 28 inches, while allowing the bag limit to increase from one bass to two.  While the comments received from most striped bass fishermen and just about all of the striped bass fishing clubs asked that New York maintain its 1-fish bag limit and 36-inch minimum size (because of overwhelming angler sentiment expressed subsequent to Amendment 4’s adoption, New York, like most other northeastern states, had never reduced its bag limit from 36 to 34 inches, even though Amendment 4 allowed it to do so), just about all of the tackle shops and for-hire boats were demanding the most relaxed regulations that Amendment 5 would allow, thinking that a relaxed regulatory scheme would be better for business.

A long and very intense debate ensued, in which tempers frequently frayed and voices were frequently raised, the umbrella organization that supposedly represented both anglers and the angling industry took the industry’s side against its member clubs (at the time, the organization’s president took me aside and tried to explain that they had to make the industry happy, as industry members made the contributions to the organization’s auction that raised the funds that the organization depended to fund it for the entire year) and as a result was almost put out of business, friends were made as people came together, enmities festered as disagreements deepened, and I somehow ended up as one of the spokesmen for the angling conservation community,  a post I have yet to successfully escape.

In the end, the New York State Department of Environmental Conservation, trying to give everyone what they wanted, split the baby in half—or maybe in thirds—dropping the size limit to 28 inches and giving the for-hire boats a two-fish bag limit, while keeping the bag limit at one for everyone else.

Throughout much of the northeast, the story was the same, if without the baby-splitting, with a 28-inch bag limit becoming the standard from New Hampshire to North Carolina (except, at times, in New Jersey, who was finding a way to finesse a few more dead bass for everyone).

It is probably no coincidence that the 2018 benchmark stock assessment found that striped bass suffered from overfishing in 1996, and experienced overfishing in most of the years between then and 2017.  Such overfishing, which didn’t abate until 2020, is undoubtedly the main reason that the striped bass stock remains overfished today.

We have since learned that, even with striped bass recruitment reaching some of the highest levels ever recorded in the late 1990s and early 2000s, a 28-inch minimum size and a two-fish bag limit was just not sustainable in the long term.

In the very early 2000s, the Atlantic States Marine Fisheries Commission’s Atlantic Striped Bass Management Board was developing Amendment 6 to the Interstate Fishery Management Plan for Atlantic Striped Bass, and a similar split between the recreational fishing industry and the recreational fishermen occurred, which became particularly nasty here in New York.

This time, the cause of the controversy wasn’t a single proposed regulation, but the overall philosophy of striped bass management.  On one side stood those in the commercial and recreational fishing industries who believed that striped bass should be managed for yield, with a lower spawning stock biomass target and a higher permissible fishing mortality, a situation which would lead to higher landings of smaller bass, while removing most of the older, larger, and most fecund females from the population.

On the other side stood anglers concerned with the long-term health of the striped bass stock, who argued that the fishing mortality rate, and resultant landings, should be low enough to permit older, larger striped bass to form a significant portion of the spawning stock biomass.  They found support in a report jointly issued by the National Marine Fisheries Service and the United States Fish and Wildlife Service, which noted

“The distribution of age classes in a population has important implications for stock productivity and stability.  Studies on striped bass have shown that larger fish produce larger eggs and larvae, and larger individuals of these life stages have a greater chance of survival.  [references omitted]’

Some of the concerned anglers banded together in a coalition they called “Friends of the Striper” and, adopting the slogan,

“The job’s not done until we BRING BACK THE BIG BASS,”

began a grassroots campaign to highlight the issue.

The campaign was contrary to local industry hopes that, at a time when summer flounder regulations were becoming more restrictive and winter flounder were disappearing, striped bass regulations might be lenient enough to convert what had historically been a sport fish targeted by a relatively small group of anglers into a panfish that might replace some of the disappearing flounder, tautog and similar species in their customers’ buckets.

The ASMFC scheduled an Amendment 6 hearing here in New York.  Ahead of that hearing, the local publisher of a now-defunct weekly fishing newspaper, which was then available both in hard copy and on line, conducted an online poll of his readers, to see which option they preferred.  The response overwhelmingly favored the more conservative, “bring back the big bass” position, and he testified to that result at the hearing.

The industry response was both immediate and extreme.  The morning after the ASMFC hearing, the publication was beset by calls from its advertisers, as for-hire boats, tackle shops and marinas sought to punish the publisher for representing his readers at the hearing, and not hewing to the industry’s party line.  Thousands of dollars of advertising was pulled, enough to force the publisher to partially recant in print by supporting the for-hire’s privileged two-bass bag limit, and causing him to withdraw from the conservation arena, where he had previously served as a valuable and articulate spokesman.

But the bass and the anglers who argued their case won that round, with Amendment 6 stating as its goal,

“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 maintenance of their essential habitat.  [emphasis added]”

Amendment 6 also included, as one of its objectives, to

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

When the Management Board adopted Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass in 2022, that goal and that objective remained intact.

Now, as the December 16 Management Board meeting looms, and the possibility of rebuilding the spawning stock remains in doubt, the recreational fishing industry is again setting itself in opposition to concerned, conservation-minded anglers and the long-term health of the striped bass population.

And this time, it’s pulling out some of its biggest guns.

Last Friday, the ASMFC released the public comments submitted on the rebuilding issue.  The very first comment in to appear was written by the American Sportfishing Association, the national trade organization for the fishing tackle industry and an imposing lobbying force; the letter opposes any additional management measures that might make rebuilding more likely.

The ASA’s position wasn’t surprising, as one of its spokesmen, Michael Waine (who once was the Fishery Management Plan Coordinator for striped bass at the ASMFC) had already suggested that the striped bass biomass target was too high, and that the ASMFC ought to seek some kind of “balance” between rebuilding and allowing the public to access—that is, catch and kill—striped bass in a podcast a few months ago.

In its comments, the ASA argues that

“New stock projections show that the current management measures are working to control fishing mortality and achieve rebuilding by the 2029 deadline.  The new projections include lower recruitment assumptions to account for the ongoing scenario of poor recruitment coming out of the Chesapeake Bay.

“The technical committee estimates that the striped bass population is not currently experiencing overfishing and is below F rebuild of 0.13 which is a fishing mortality target that accounts for achieving rebuilding by 2029…

“…This demonstrates that the current management plan is effective without requiring additional restrictions…”

It’s one of those examples where telling a half-truth may be more effective than telling a lie, for everything that the ASA alleged in the above statements—except for the last sentence—is undoubtedly correct.  But it’s what the ASA doesn’t say that really matters.

For yes, one stock projection does say that the stock has a 57 percent chance of rebuilding if no further management measures are adopted.  However, two other stock projections project that the stock is unlikely to recover unless additional management measures are imposed.  And, in its report to the Management Board, the Striped Bass Technical Committee clearly stated that

“all three primary scenarios represent a credible range of what might happen.”

With respect to the projection cited by the ASA, which included an extra two-month “wave” of data, the Technical Committee warned,

“While including additional data (i.e., adding Wave 4) is generally informative, the [Technical Committee and Stock Assessment Subcommittee] notes that using Waves 2-4 to predict removals does not always result in a more accurate estimate of final removals than using only Waves 2-3.”

In other words, while the ASA cites only one of three possible scenarios in support of its position, there are two other scenarios, both just as likely to reflect reality, which contradict the ASA’s claims.

Of course, the ASA didn’t mention those two scenarios at all…

But that doesn’t mean that the ASA doesn’t include an outright falsehood or two among its comments.  Consider its statement that

“The narrow [28- to 31-inch] slot limit protected the strong 2015-year class and is similarly expected to protect the 2018 above-average year class in 2025.”

That assertion is just plain wrong.

The 28- to 31-inch slot limit wasadopted in 2023, when the 2015 year class was eight years old.  The mean size of an eight year old bass is 31.8 inches, meaning that less than half of the 2015s were still in the narrowed slot when it was adopted.  However, the 2018 year class will only be seven years old in 2025.  The mean size of a seven year old bass is 28.7 inches, meaning that more than half of the 2018s will be in the slot, and so targeted by the catch-and-kill fishery in 2025, and just under half will still be in the slot, and targeted again, in 2026.  

Those two years of focused catch-and-kill will result in a lot of the 2018s being removed from the population before they can grow out of the slot.

It's what the ASA might call “increasing angler access.”  It’s what the rest of us think of as reducing the size of the spawning stock.  In fact, the American Sportfishing Association wants to go farther and increase the striped bass kill, as its comments make clear when it suggests that

“the ASMFC should consider adding additional days to the recreational fishery to improve equity across regions for both anglers who prefer to take a fish home for dinner or practice catch and release.  [emphasis added]”

The reason for that position is clear as well:

“We urge you to avoid season closures that would have unnecessary economic impacts on both anglers and the sportfishing industry.”

Other industry organizations made similar arguments.  For example, the New York Fishing Tackle Trade Association, which represents the state’s bait and tackle dealers and wholesalers, argued that

“Conserving resources for the future is not just managing the fishery from a conservation or regulatory approach, but also accounting for the socioeconomic impact of such regulations and maintaining fair and equitable access.”

While saying that conserving resources for the future is not just about conservation seems like a dubious and self-contradictory claim, and while NYFTTA, like ASA, is seeking to leave striped bass regulations unchanged, the NYFTTA comments are actually a little more rational, conceding that there might be a place for regulations that appeared to be a little more equitable and a little better thought-out.

Still, NYFTTA, like the rest of the industry, is supporting the most risk-prone position, although its position is at least based in some semblance of reality, unlike that of the Marine Trades Association of New Jersey, which was somehow able to write, with a completely straight face, that

“the spawning stock biomass is robust,”

and

“the numbers and range of fish is astounding.”

Predictably, most of the for-hire fleet also opposed any change in striped bass management measures.  Their comments differed in detail, but were all some variation on the theme of, “We’ll lose money if we can’t kill as many fish.”

Thus, the Cape Cod Charter Boat Association talked about “a healthy striped bass population with great fishing,” even if a peer-reviewed stock assessment update found the stock to still be overfished, while the Captree [New York] Boatmen’s Association completely disregarded the health of the stock and simply maintained that a proposed closure sometime during the November/December period would be “devastating” to their business.

The Connecticut Charter and Party Boat Association calls the stock “robust” and whines that

“Every Striped Bass reduction has been on the backs of those who need and want to harvest striped bass and 0 reductions from the catch-n-release shareholders [sic],”

sentiments echoed by a group of for-hire operators that calls itself the East Coast Fishing Coalition, which also made the remarkable statement that

“It is unconventional to factor the 2018 year class as harvested fish prior to a season even beginning, on the basis that they ‘may’ enter the current 28”-31” slot.  Without that factor there would be a 50-57% chance of being rebuilt by 2029.”

Which is something like saying, “If we could ignore the fact that small fish are going to grow larger, we could stop worrying about the 2018 year class growing big enough to be caught next year…”

And then they complain that

“There just isn’t any room left to cut the For Hire sector.  There is nothing left to fish for.  Paying customers want to harvest fish and eat them for dinner plain and simple.  This has been built into the industry for generations.  Perhaps one day catch-n-release will become mainstream, but present day is just a small fraction of the customer base that find this acceptable.”

In making the statement, they miss the irony that, if the striped bass isn’t rebuilt, and perhaps falls into deeper decline in the near future, there will be even less to fish for, and less for paying customers to harvest, while they also completely ignore the fact that the ASMFC has already admitted that

“The recreational [striped bass] fishery is predominantly prosecuted as catch-and-release, meaning the majority of striped bass caught are released alive either due to angler preference or regulation…Since 1990, roughly 90% of total annual striped bass catch is released alive…”

Given those facts, the striped bass wouldn’t be one of, if not the, most important recreational species in the northeast and mid-Atlantic if “just a small fraction” of anglers were willing to participate in the catch-and-release fishery.

Yet the for-hire fleet keeps making such assertions.

The spokesperson for the East Hampton [New York] Town Fisheries Commission alleged that

“The implementation of the 2023 emergency action restricted the taking of striped bass and reduced income for all the small businesses dependent on this one fish.  Reports of up to a forty-percent loss in income within the For-Hire fleet were made.”

And in truth, there was a big drop in the number of for-hire trips made in New York, but a quick look at the effort data provided by the National Marine Fisheries Service will quickly show that the drop occurred well before the emergency regulations were put in place in 2023.   New York for-hire trips dropped from nearly 400,000 to just over 270,000—about a 32% reduction—between 2021 and 2022, a full year before the emergency regulations were adopted.  However, between 2022 and 2023, the year the emergency regulation went into effect, the number of for-hire trips taken in the state only dropped by 3.15%, fairly persuasive evidence that the emergency regulations did not have a significant impact on the for-hire industry as a whole.

Other incredible claims were made by the Montauk Boatmen and Captains Association, which operates out of East Hampton, and made the impossible argument that

“Following the striped bass emergency action that was implemented in 2022, which introduced a 28” to 35” slot striped bass, we began to see a downturn in business.”

Such statement is completely contrary to a couple of facts, first that the 28- to 35-inch slot was introduced in 2020, not 2022, as part of Addendum VI to Amendment 6 to the Interstate Fishery Management Plan for Atlantic Striped Bass, and second that the emergency action the MBCA complained about was introduced in 2023, not 2022.

An organization incapable of getting such basic facts straight, and which tried to tie supposed declines in business to a completely and demonstrably false timeline, should be granted no credibility at all.

I could go on quoting the various comments made by the various for-hire groups, but whether we are talking about the North Fork [of Long Island, New York] Captains Association, or the Rhode Island Party and Charter Boat Association, or the Stellwagen Bank [Massachusetts] Charter Boat Association, they are all variations on the same theme:  There are plenty of bass in the ocean, we need to kill fish to make money, and that the bass will do fine without any additional management (and if they don’t do too well, it’s not our fault).

In other words, it’s about the same argument being made by the fishing tackle and marine trades organizations, all of which are in vehement opposition to any meaningful striped bass conservation effforts.

Which puts them in sharp opposition to the majority of anglers, who understand that the bass is at risk and are urging the ASMFC to do something about it.

While the anglers aren’t all on the same page about what needs to be done, at least most understand the need for action, making comments such as

“I remember the days when the striped bass stock was severely depleted and do not want to see those days again,”

“[I]f effective and enforceable measures are not taken now to reduce harvest and protect 2015 and 2018 spawners, it is almost certain that fishing mortality will increase not just next season but possibly for years to come, putting at further risk the most valuable sport fish on the East Coast.  That is a risk not worth taking.”

And

“Taking immediate, conservative, and risk-averse actions at this point is required.  That means hard choices and real action, not milquetoast measures or business as usual.”

The positions taken by the majority of the recreational fishing industry and by the majority of recreational fishermen could not be more different, and stand in complete opposition.  There is little to no room for compromise.

If the industry wins, the anglers, and the bass, will lose, and the consequences of that loss could echo for years.  And the industry, left with a less vital ocean that is far less attractive to anglers, will lose in the end as well.

Ironically, if the industry loses this current fight that they’re trying so hard to win, they prevail in the battle that matters, as a restored striped bass population encourages anglers to fish, and to fish more often, and in so doing makes them more likely to patronize the very businesses that are trying to throttle needed conservation efforts.

The benefits of conservation, and a restored striped bass stock, would be easy to see, if only the industry wasn’t blind.

TO DESTROY THE COD FISHERY--OR MAYBE TO SAVE IT

 

Last October, the New England Fishery Management Council approved Amendment 25 to the Northeast Multispecies Fishery Management Plan, which promises big changes to the way Atlantic cod are managed.

The new amendment is an outgrowth of the 2023 Atlantic Cod Research Track Stock Assessment, which for the first time divided the Atlantic cod population into four separate stocks.  Previous assessments only divided the population into two stocks, one on Georges Bank and one in the Gulf of Maine, but recent research provided reason to question that approach.  As the 2023 stock assessment noted,

“The [Working Group] recommended that the cod research track process proceeds with four spatial units for assessment:  1) eastern Gulf of Maine, 2) western Gulf of Maine (winter and spring spawners combined), 3) Georges Bank, and 4) southern New England (including the Mid Atlantic Bight).  The rationale for a 4-unit structure, relative to the historic 2-unit model, is better alignment between the scale of cod stock assessment units and biological stock structure that can be supported with available information.”

Because federal law requires that fishery management measures must track the best scientific information available, which in this case means the recent assessment, Amendment 25 will establish four management units for Atlantic cod, each one conforming to one of the newly-defined stocks (biologists believe that there are actually five distinct stocks, but are combining the western Gulf of Maine/Cape Cod winter spawners and western Gulf of Maine spring spawners because they currently lack the information needed to manage them as separate stocks).

Because the 2023 research track assessment has established a new paradigm for Atlantic cod management, the New England Council created an Atlantic Cod Management Transition Plan, which calls for a two-step phase-in of the new management approach.  Phase One would implement Amendment 25 by May 1, 2025, and also implement a new Framework 69 that would set the criteria for determining stock status, and also set catch limits for the 2025 through 2027 fishing years.

Phase Two is not as clearly defined, but contemplates additional frameworks, or perhaps an amendment, that would focus on the long term, may adopt different management units, and could shift allocations or add additional protections for spawning fish.

Last June, a new management track stock assessment, which addressed each of the four newly defined cod stocks, was released after passing peer review, and was submitted to the New England Council’s Scientific and Statistical Committee, which then set the Overfishing Limit and Acceptable Biological Catch (which is calculated by adjusting the Overfishing Limit downward to account for scientific uncertainty) for each stock.

All of the stocks are still severely overfished, but the research track assessment and SSC advice still contain some hopeful notes.

While the western Gulf of Maine stock is not only overfished, but also experiencing overfishing, the SSC projects both the Overfishing Limit and Acceptable Biological Catch to increase over the next three years, with the OFL rising from 507 metric tons (1,118,000 pounds) in 2025 to 769 mt (1,695,000 pounds) in 2027, and the ABC also increasing from 387 mt (853,000 pounds) to 586 mt (1,292,000 pounds) over the same period.

In making those projections, the SSC expressed some concerns about the stock’s management.  While the recommended Overfishing Limit and Acceptable Biological Catch will lead to lower landings in the immediate future, making overfishing less likely, the SSC is nonetheless concerned that such projections are overly optimistic; at the same time, it is also concerned about the socioeconomic impacts of the reduced ABCs on participants in the fishery.

In the case of eastern Gulf of Maine cod, the SSC’s projects a declining Overfishing Limit and Acceptable Biological Catch during the period 2025-2027, with the OFL falling from 63 to 39 mt (139,000 to 86,000 pounds) and the ABC dropping from 48 to 30 mt (106,000 to 66,000 pounds).  Cod bycatch in the lobster fishery is thought to be a significant source of removals, but has not been fully quantified nor included in the population models, and so adds uncertainty to the projections.

The southern New England cod stock provided some unique challenges for the Scientific and Statistical Committee.  It is both overfished and experiencing overfishing, but it is the only one of the four stocks that sees the majority of fishing mortality generated by the recreational rather than the commercial sector.  That adds an additional level of uncertainty to the data, as recreational landings areestimated through the Marine Recreational Information Program, and not directly reported by recreational fishermen, so the recreational data is not as precise as that generated by the commercial fishery, which comes from near real-time reporting generated by weigh-out reports.

Other sources of uncertainty include a lack of biological sampling in recent years, concerns about the indices of abundance used in the population model, the level of recreational release mortality, and similar issues.  The Scientific and Statistical Committee’s projections would substantially reduce southern New England stock landings, although such landings would theoretically increase over the 2025-2027 period, with an Overfishing Limit that begins at 29 mt (64,000 pounds) and increases to 65 (143,300 pounds), and an Acceptable Biological Catch that rises from 22 mt (48,500 pounds) to 36 (79,000 pounds).  The 2025 ABC is so small that, assuming that Framework 69 is approved by the National Marine Fisheries Service, recreational fishermen will not be allowed to harvest any southern New England cod from federal waters next year.

The fourth stock, Georges Bank cod, is not experiencing overfishing, but is very badly overfished.  Its spawning stock biomass is the lowest ever recorded, at the same time that low recruitment is preventing the stock from rebuilding.  Scientists attempting to rebuild the stock have also been hampered by insufficient port sampling and difficulties in determining the stock’s age composition.  The Scientific and Statistical committee reduced Georges Bank cod landings for the period 2025-2027, while projecting that the size of the stock will continue to decline.  The Overfishing Limit will fall from 518 mt (1,142,000 pounds) to 420 mt (926,000 pounds), with the Acceptable Biological Catch dropping from 397 mt (875,000 pounds) to 321 (708,000 pounds).

Across all stocks, the Annual Catch Limit for Atlantic cod will be cut by 43 percent, from 667.4 mt (1,471,517 pounds) in 2024 to 382.9 mt (844,150 pounds) in 2005.

Right now, because the four-stock structure is new, neither rebuilding times nor the fishing mortality rates needed to rebuild the stocks have been calculated, although such calculations will be made at some point in early 2025.

It seems like a worthwhile way to approach Atlantic cod management.  For the first time, the stocks established for management purposes will roughly accord with the biological stocks, which should provide a more effective management structure.  Managing multiple stocks with a one-size-fits-all management approach rarely works very well.

I used to do quite a bit of codfishing, most of it near Block Island and out on Rhode Island’s Cox’s Ledge, areas that would now be considered within the southern New England stock’s range.  Back in the late 1960s, 1970s, and early 1980s, when most of my codfishing took place, fish were abundant on those grounds, and it wasn’t necessary to venture out on the coldest and most hostile seas of the year; anglers caught plenty of cod, some of them in excess of 50 pounds, while fishing in their shirtsleeves on a flat midsummer ocean.

Those memories stirred a bit of excitement 15 or 20 years ago when, after years of near-complete absence, a relatively strong run of cod appeared, seemingly out of nowhere, on my old fishing grounds.  If Amendment 25 and Framework 69 had been in place back then, the southern New England cod stock might have been given a chance to rebuild, and fishing could be even better today.  Instead, recreational and commercial fishing boats pounded the fish incessantly, with boats from everywhere between New York Harbor and Cape Cod renting winter dock space in Montauk, New York and in various Rhode Island ports, so that they could be closer to the fishing grounds.

It wasn’t very long until the newly-abundant  cod had disappeared again.  As one writer from East Hampton, New York noted a few years ago,

“From a fishing perspective, it was as quiet a season as I could ever recall…The quietness also marked the first time that I never went out for codfish, which are usually most prevalent during the winter in our local waters…But not this winter.  It just never happened.

“While my enthusiasm for fishing never waned, there was an acute problem that was fundamentally impossible to rectify.  With little to no codfish around, there were no boats willing to sail.  It was depressing.”

But if fishermen don’t let fish stocks rebuild, and instead do their best to wipe out the first strong year class to appear in a couple of decades, that’s what results.

Atlantic cod are the poster child for an overfished, mismanaged stock, that saw U.S. landings fall from around 117,775,000 pounds in 1980 to a little under 1,095,000 pounds in 2023.  And Framework 69 is going to force that total even lower, to a bit under 845,000 pounds.

While there’s no doubt that 1980 Atlantic cod landings were far too high to be sustainable, and helped to assure the population’s demise, the fact that cod landings fell by more than 99 percent over the course of 43 years is a pretty good indication that something was very, very wrong with the way the fishery was managed for a very long time.

Amendment 25, and any subsequent frameworks, promise to bring a meaningful change to the way cod are managed, and perhaps provide a ray of hope that cod stocks might rebuild.

So, in a move that comes as no surprise to anyone familiar with the New England approach to fisheries management, commercial fishermen in the northeast are objecting to the new Amendment, claiming that it will destroy what remains of the Atlantic cod fishery.

The website Seafood Source quotes Jerry Leeman, the CEO of the New England Fishermen’s Stewardship Association as saying,

“These restrictions are going to be the end of the trawlers and anyone else buying fish.  Everyone in the fisheries expects Amendment 25 to torpedo their businesses.”

He claims that Amendment 25 will

“permanently destroy the centuries-old cod fishing business.”

As a result of such sentiments, fishermen protested ahead of the New England Council’s December meeting, hoping to prevent Amendment 25’s passage, but their efforts were to no avail.

That’s probably a good thing, because while many fishermen blame restrictive regulations for destroying their businesses, they tend to ignore the role played by the decades they spent overfishing the stock, driving it down to levels that make such regulations necessary.  

Yet no matter how far stocks decline, it is still the rare fisherman—or, at least the rare fisherman who makes his or her living off the backs of dead fish—who will ever acknowledge that strict, effective regulation remains the only thing that might, with a good helping of luck, bring their moribund fishery back from to some semblance of life.

It's an ever rarer fisherman who is willing to admit to the need for regulations that will keep a fishery from collapsing in the first place.

That’s not just true for cod, but for a host of fisheries ranging from winter flounder to—sadly—striped bass.  But cod, due to their historic importance, their former abundance, and their cultural value in the northeast, will probably always remain as the foremost example of how much can go wrong when needed management measures are not put in place.

 

STRIIPED BASS: "SUCH A SOLID FALL RUN"

For last Thursday’s edition of this blog, I put up a post describing the issues that the Atlantic States Marine Fisheries Commission’s Atlantic Striped Bass Management Board will be considering when it meets on December 16, and suggested some themes for comments that stakeholders might wish to submit to the Management Board ahead of next Tuesday’s deadline.

The post drew a few comments, the majority of which seemed to question whether any further management action was needed, because from what the commenters saw, the bass stock appeared to be healthy.  One commenter wrote

“The past fall run has proved to me that the fishery is strong and robust…Countless bass gorging on sand eels and bunkers.  Acres and acres of fish.  Last year I did not land one school nor one slot fish.  Something is going right.”

Another wrote,

“I as many on LongIsland [sic] have experienced a very strong fall run of striped bass…I am a true believer that the slot law is working.”

A third noted that

“It was a terrific year for striped bass fishing.  Contrary to the last couple of years, I was able to land more than my share of slot sized fish this year, with leads me to believe that the limits that have been imposed have worked to help revive the striped bass population,”

while a fourth simply said,

“Such a solid fall run…It was a great fishing run with my family.  What a great season.”

The truth is that those anglers are right:  There was a great fall run of striped bass off western Long Island this year.  And the truth is that those anglers are wrong, when they try to extrapolate from their very successful fall season off Long Island, to reach the conclusion that there were plenty of bass everywhere.

That’s just not the case.  The striped bass stock remains overfished, and is facing some serious challenges.

It turned out that one of the anglers who commented on the post is a friend, who runs his boat out of Fire Island Inlet, New York, just as I do.  He had a great fall season, and is having a hard time believing that the striped bass stock is not doing well.  

In response to his comments, I referenced an old fable that I had learned as a child, which spoke of six elderly blind men who were extremely curious about elephants, but were never able to see one because of their blindness.

According to the fable, the blind men were eventually led to the palace of the Rajah, where they would be able to approach an elephant and, because they could not see the creature, touch it to determine its nature.  When the opportunity finally arose,

“The first blind man reached out and touched the side of the huge animal.  ‘An elephant is smooth and solid like a wall,’ he declared.  ‘It must be very powerful.’

“The second blind man put his hand on the elephant’s limber trunk.  ‘An elephant is like a giant snake,’ he announced.

“The third blind man felt the elephant’s pointed tusk.  ‘I was right,’ he decided.  ‘This creature is as sharp and deadly as a spear.’

“The fourth blind man touched one of the elephant’s four legs.  ‘What we have here,’ he said, ‘is an extremely large cow.’

“The fifth blind man felt the elephant’s giant ear.  ‘I believe an elephant is like a huge fan or maybe a magic carpet that can fly over mountains and treetops,’ he said.

“The sixth blind man gave a tug on the elephant’s coarse tail.  ‘Why, this is nothing more than a piece of old rope.  Dangerous, indeed,’ he scoffed.”

Each of the blind men having perceived one part of the elephant, and certain that their perception disclosed the elephant’s true nature, they each began to argue about what an elephant was really like, rejecting the views of the others.  Their argument grew quite clamorous, until finally,

“’Stop shouting!’ came a very angry voice.

“It was the Rajah, awakened from his nap by the noisy argument.

“’How can each of you be so certain that you are right?’ asked the ruler.

“The six blind men considered the question.  And then, knowing the Rajah to be a very wise man, they decided to say nothing at all.

“’The elephant is a very large animal,’ said the Rajah kindly.  ‘Each man touched only one part.  Perhaps if you put the parts together, you will see the truth.  Now, let me finish my nap in peace.’”

That fable’s teachings are applicable to many situations, including perceptions of the striped bass stock, which is very large—even overfished, its spawning stock biomass at the end of 2023 was estimated to be 86,536 metric tons, or slightly over 190 million pounds—and ranges from North Carolina to Maine, with a handful of fish even straggling up into Canadian waters.

So while fishermen off Long Island undoubtedly experienced very good fishing this fall, their perceptions were very limited in time and place.  The popular striped bass website Stripers Online hosts a series of chat boards, including one dedicated to Connecticut anglers which features a thread titled “stripers in CT this year….” which sees Connecticut anglers reporting their very different perceptions of the fishery.  The leadoff post reads,

“this was without question the worst season I’ve ever had fishing for bass…talking to others seems to reinforce my experience.”

I grew up in Greenwich, Connecticut, and still go back to my old home waters to fish with a friend every year.  One of my favorite times is late summer, which typically sees a short but intense pencil popper bite occur right at first light.  But this year, that bite didn’t happen, and it really wasn’t worth my time to drive up to Connecticut at all.  Thus, I wasn’t surprised to see others who fish there make comments such as

“Same here.  Bass fishing sucked for me this year,”

“I wish this were a fluke but the steady deterioration is in its 5^th yr at least.  Each yr is a little worse,”

“It has been the worst year I’ve had in several years…The fall was the Nail in the coffin for me with only one good week in early October…Since then it has been skunk city with a few rats under the birds here and there,”

and

“The locations that I would normally fish this time of year that would be stacked up thick with schoolies are empty…It has been going downhill for years and this year is worse.”

Clearly, those Connecticut anglers didn’t touch the same part of the elephant as folks fishing off western Long Island, even though the two areas are not all that far away from one another.  Anglers fishing other areas of the coast also have divergent perceptions of the health of the striped bass stock.

So how do we—all “blind men” in that we only see a piece of the overall whole—gain a full picture of the striped bass stock?

The answer, of course, is by using science and analyzing data, to create a factually unbiased view of the entire striped bass population, throughout its various peregrinations between nursery grounds and summering areas, and between coastal rivers and the waters of the continental shelf. 

When it comes to the health of the striped bass stock, the primary scientific documents are the benchmark stock assessment and the periodic updates thereto.  In preparing the assessment, biologists employ no less than 15 different state surveys and monitoring programs, which gather data from coastal and estuarine waters between New England and Virginia.  All are fishery-independent, meaning that they are not derived from catch or landings by either commercial or recreational fishermen, although fishery-dependent data, such as that developed through the Marine Recreational Information Program and commercial landings data, are also used to inform the stock assessments.

Because of the wide array of data included in a stock assessment, gathered over most of the striper coast, a benchmark stock assessment or subsequent update necessarily provides a far more comprehensive and far more accurate picture of the striped bass stock than do the limited experiences of anglers fishing along a small section of coast.

To assess the future, as well as the current status, of the striped bass stock, biologists can rely on juvenile abundance indices, which provide an estimate of spawning success in the four most important spawning regions, the Maryland and Virginia sections of the Chesapeake Bay, the Delaware River, and the Hudson River.  

The Chesapeake Bay is, by far, the most important spawning area, providing about eighty percent of the migratory striped bass found along the Atlantic Coast, and Maryland Is the most important portion of the Chesapeake Bay, producing about two-thirds of the Bay’s juvenile bass

Thus, to learn that the 2024 Maryland striped bass juvenile abundance index revealed that the bass experienced recruitment failure for the sixth consecutive year, and that the Virginia index signaled the fourth straight year of recruitment failure was particularly bad news.  2024 data is not yet available for the Delaware and Hudson rivers, but the fact that the New Jersey juvenile abundance index, marking the success of the Delaware River spawn, was below the 25^th percentile of the juvenile survey’s time series in 2021 through 2023, and that the Hudson River index for 2023 was the worst since 1985 provides reason to worry about the bass’ immediate future.

Contrary to some Long Island anglers’ beliefs, the conclusions of the stock assessment and assessment updates, combined with the recent juvenile abundance surveys, provide no objective evidence that “the stock is strong and robust,” nor that “something is going right.”

Good fishing that occurs within a limited area, particularly good fishing for bass that fit within the recreational slot limit, can give the impression that the stock is healthier than it actually is.  But a simple test can reveal whether abundance is improving, or whether the health of the stock is getting worse:  calculating the number of bass caught on an average trip.  When striped bass abundance is increasing coastwide, the average number of bass caught per trip will increase; when abundance declines, the number of bass caught per trip declines, too.

And over the past few years, the number of bass caught per trip has steadily headed in the wrong direction, with the rate of decline increasing in recent years.  In 2019, the average trip taken in New England/mid-Atlantic region, primarily targeting striped bass, saw 1.960 bass caught.  That number ticked up slightly, to 2.032 fish per trip, in 2020, then declined, at an ever-increasing rate, to 1.947 bass/trip in 2021, 1.814 bass/trip in 2022, and 1.611 bass/trip in 2023.  

For the first eight months of 2024, the average number of bass caught per trip was just 1.059, although that figure might be deceiving, as it leaves out the last four months of the year, when bass fishermen are often very active.  Still, it's not  unreasonable to expect the 2024 average to fall below that of 2023.

A vast preponderance of the objective evidence indicates that the coastwide health of the striped bass stock is not good, which again illustrates why relying on personal experience to gauge stock status, instead of depending on objective information, can easily lead someone astray.

I wish that wasn’t the case.  I wish that the fishing we saw off Long Island this fall accurately represented the health of the stock.

But when it comes to striped bass, subjective impressions must yield to objective fact, and the fact is that the immediate prospects of the striped bass stock are worrying.

Hopefully, when it meets on December 16, the Management Board will have the courage, wisdom, and collective will to put the stock back on the track to long-term health and sustainability.

 

 

 

 

 

 

 

 

  

STRIPED BASS: THE TIME HAS COME TO PROVIDE YOUR COMMENTS

 

On December 16, the Atlantic States Marine Fisheries Commission’s Atlantic Striped Bass Management Board will meet to discuss possible changes in management measures, for the 2025 season.  The Management Board is seeking public comment ahead of that meeting, which comment must be emailed to comments@asmfc.org by 11:59 p.m. on December 10.

The question for stakeholders is precisely what they’ll be asked to comment on.

Because the Management Board will be fast-tracking any measures that might be adopted, and adopting such measures outside the usual addendum process, it did not produce the typical draft addendum for public comment, not did it schedule public hearings.  Instead, the only document available for stakeholder review is the memo that the Striped Bass Technical Committee and Stock Assessment Subcommittee produced for the Management Board, which is included in the meeting materials.  It’s not the easiest document to navigate if someone isn’t familiar with management jargon, as it doesn’t include clearly labeled options.  However, the topics for comment are clearly presented.  In the remainder of this post, I’ll try to lay out the key points, along with some thoughts on what might best benefit the striped bass resource in this difficult time.

Uncertainty still clouds the data

One of the tasks that the Management Board assigned the Technical Committee, when the Board last met in October, was to include data from Wave 4—July and August—into its calculations of the fishing mortality reductions needed to rebuild the stock by 2029.  

Unfortunately, that additional data may have only increased the uncertainty.

At the October Management Board meeting, a Technical Committee presentation suggested that, based on data from Waves 2 and 3—March through June 2024—and depending upon how much 2025 landings increased after the above-average 2018 year class entered the coastal slot limit, a reduction in the 14.5 percent to 26.8 percent range would be needed to rebuild the stock by 2029, assuming that fishing mortality fell back to 2024 levels in the years 2026-2029.  A 14.5 percent reduction seemed the most likely outcome.

But when the Technical Committee included the Wave 4 catch and landings in its calculations, things changed—a lot.  Because catch and landings were relatively low during Wave 4, it now appeared that, assuming that the fishing mortality rate for the rest of the year was no higher than it was for Waves 2-4, that the fishing mortality rate for 2025 was no more than 17 percent higher than the 2024 rate, and that the fishing mortality rate in 2026 through 2029 fell back to a level no higher than it was in 2024, there was a 57 percent probability that the stock would fully rebuild by 2029 even if management measures remained unchanged.

Of course, that was a lot of assumptions, and there was no guarantee that all—or any—of them would prove true.  The Technical Committee cautioned that

“While including additional data (i.e., adding Wave 4) is generally informative, the [Technical Committee-Stock Assessment Subcommittee] notes that using Waves 2-4 to predict removals does not always result in a more accurate estimate of final removals than using only Waves 2-3.”

Warnings like that should be heeded, particularly when, after providing two other scenarios, including 1) the scenario based on Waves 2 and 3, which calls for a 14 percent reduction and 2) another scenario that includes Wave 4 data but assumes higher landings in 2025 and a fishing mortality rate for 2026-2029 slightly higher than the 2024 rate, which would require an eight percent reduction to achieve rebuilding.  With respect to all three scenarios, the Technical Committee advised

“The probability of achieving rebuilding by 2029 range from 57% to 43% across the three primary scenarios which equate to reductions ranging from 0% to 14%.  The [Technical Committee-Stock Assessment Subcommittee] notes that all three primary scenarios represent a credible range of what might happen.  As such, the Board should consider its risk tolerance when considering possible management response for 2025 and beyond.  The level of risk the Board is willing to accept (with respect to resource status, economic loss, and persistent modeling uncertainty due to annual management changes) is a management decision.”

Thus, the Technical Committee acknowledges the uncertainty inherent in its recommendations, does not  attempt to predict which scenario is most likely, and further warns that

“Although these projections aim to capture some component of changing effort and fish availability (i.e., increased [fishing mortality] when strong year classes are available), angler behavior and fish availability are still sources of uncertainty.  Additionally, there is high uncertainty in the exact [fishing mortality] values that will occur over this period even with constant regulations.  The estimated F₂₀₂₄ and F__rebuild values for all scenarios would be the lowest values since 1994, which is possible given both the extremely narrow slot limit and the lack of a strong year class in that slot.  The low year-classes following the 2018 year-class will result in lower availability of harvestable fish after 2025, which may result in a decline in effort and a lower F for 2026-2029; however, if removals remain constant on these weaker year-classes, F may not decrease as much as expected.  Finally, the ability to maintain a constant F for consecutive years is difficult even with regulation changes.  While the projections assume a constant F for 2026-2029, the [Technical Committee-Stock Assessment Subcommittee] cannot predict how F will vary from year to year.”

So it is clear that even the best estimates of the Technical Committee might not be very precise.

A risk-averse approach is needed

The Technical Committee’s projections unavoidably include a high level of uncertainty, and when considering fishery management measures, a high degree of uncertainty calls for an equally high degree of precaution.

That is particularly true in the case of the striped bass.

Last October, the ASMFC released an update to the benchmark striped bass stock assessment, which revealed that the striped bass stock remains overfished, although spawning stock biomass is slowly increasing.    

In addition, recruitment of young striped bass into the population has been very low in recent years.  Maryland, the most important spawning ground on the coast, has experienced six consecutive years of recruitment failure, with the average juvenile abundance index for those six years the lowest of any six-year period on the coast—including those years in the late 1970s and 1980s when the striped bass stock experienced a collapse.  Virginia recruitment has also been poor for the past four years, and Delaware River recruitment for three (although we don’t have the 2024 data yet; 2024 could conceivably mark the fourth poor year there, too).  The only relatively successful recruitment has been in the Hudson River, where it has vacillated wildly from year to year, with 2020 producing one of the strongest year classes on record and 2023 producing the worst recruitment since 1985.  We don’t yet know what Hudson River recruitment looked like this year, although there are some rumors floating around suggesting that it wasn’t very good.  The Hudson figures should be released later this year.

Because of the low recruitment, the current effort to rebuild the stock by 2029 is about more than merely increasing the number of striped bass available to the commercial and recreational fisheries; it is about shoring up the spawning stock biomass, so that if recruitment stays low for an extended period due to unfavorable environmental factors, as it did in the 70s and ‘80s, and biomass crashes again, there will still be sufficient spawning stock available to begin a recovery once more favorable spawning conditions recur.

Given the overfished status of the striped bass stock, and the impossibility of predicting when recruitment will again return to more typical levels, the Management Board should be urged to exercise caution and assume that a 14% overall reduction in landings will be needed to rebuild the spawning stock biomass by the 2029 deadline.

The issues that must be considered

Once the size of the reduction has been determined, the next question is just who must reduce their landings.  Here, the Technical Committee offers three possible choices:  1) the commercial and recreational sectors could both take an equal reduction, 2) the commercial quota could remain unchanged, and the recreational sector made responsible for the entire reduction, or 3) the commercial sector could take what the Technical Committee describes as a reduction “based on sector contribution to total removals.”

The first two choices are self-explanatory, while the third is strange enough to require a little discussion.  It was first proposed during the debate over Addendum VI to Amendment 6 to the Interstate Fishery Management Plan for Atlantic Striped Bass, which was adopted in 2019, although it never gained too much traction back then.  The idea was that the commercial sector was only responsible for about 10 percent of striped bass landings, so instead of being reduced by (in the current case) 14 percent, the commercial quota should only be reduced by 10 percent of 14 percent, or 1.4 percent, while the recreational sector is held responsible for the rest of the cuts.

It’s clearly inequitable, making the recreational sector assume a disproportionate share of any landings reduction, but it is an approach revived by commercial fishing advocates every time that the subject of landings reductions is raised.

Requiring both the commercial and recreational sectors to accept an equal percentage reduction is the only equitable option, and should be the option adopted by the Management Board.  

Making no change to the commercial quota would require the recreational sector to shoulder the entire conservation burden, and take a 16 percent reduction, while the third approach would reduce the commercial quota by only about 1.5 percent, while still imposing a 16 percent cut on recreational fishermen.

The question of who must reduce their harvest being resolved, the next question is how that reduction ll be achieved.

Of the six different size limit options for the ocean fishery, which range from a narrower, 28- to 30-inch slot limit to a 40-inch minimum size, none offered more than a 6 percent reduction.  So, even if a size limit was adopted, it would have to be paired with some sort of season, along with a reduction of the recreational size limit in the Chesapeake Bay to achieve a meaningful reduction in landings.

The need to combine size limits with a closed season will probably militate against new size limits being adopted.

Instead, it is very likely that any recreational reductions imposed by the Management Board will be achieved through some sort of closed season.  The Technical Committee put together two pages of suggested season closures for the coastal fishery.  All but one of them broke the coast into regions, with different seasons for northern New England (Maine to either Massachusetts or Rhode Island, depending on the option) and the rest of the coast. 

If the Management Board adopts a closed season, it can do one of two things.  It can close the season to harvest, but allow catch-and-release fishing to continue, or it can prohibit even targeting striped bass, prohibiting the release fishery as well.  While the latter approach results in a season closure only about half as long as a no-harvest closure, it has one very big disadvantage:  No-target closures are virtually impossible to enforce. 

The National Marine Fisheries Service has maintained a no-target closure in federal waters for the past 40 years, and when asked, NMFS representatives could not recall a single instance in all that time when a fisherman was convicted for merely targeting striped bass, unless that fisherman also had a dead bass in the cooler.  State law enforcement personnel told the ASMFC about the same thing:  Unless someone is in possession of a striped bass, it is extremely difficult to convict them for merely targeting the species.

It's just too easy for an angler to target striped bass, but say that they’re fishing for bluefish, white perch, weakfish or anything else, and was just catching striped bass by accident.  In such cases, it is very, very difficult to prove to a judge, beyond a reasonable doubt, that striped bass was the actual target.

Thus, as a practical matter, a no-target closure is little more than a no-harvest closure that is only half as long as it needs to be to accomplish its goal.  The Management Board should be encouraged to adopt a no-harvest closure, which allows catch-and-release to continue, to achieve the needed recreational reduction.

Unfortunately, in constructing the possible season closures, the Technical Committee focused on all states reducing their season by the same number of days, even though that leads to the very inequitable result of Maine and New Hampshire, which has the shortest seasons on the coast, giving up a far larger proportion of its season than, for example, New Jersey, where anglers can catch bass for at least ten months of the year.

The Technical Committee also chose to break the coast into only two regions, and in all cases, the southern region is just too big.  There are few similarities between the striped bass fisheries off southern New England and those in the ocean off Virginia, and it would have served the bass better to break the coast up into at least one more region, perhaps with Delaware Bay as the dividing line.

The current division allows the more northerly southern states too much opportunity to play games with any closure that might be adopted.  For example, should the Management Board decide on an option that provides for a 23-day no-target closure in Wave 6, a state like New Jersey, which has a reputation for abiding by the letter of the rules while doing its best to apply them in the way most likely to negate their effect, could close its bass fishery for the last three weeks of December, when most boats are already out of the water, be in technical compliance, but not achieve anything close to the intended harvest reduction.

However, this late in the game, there is no time for the Technical Committee to investigate other possible seasons.  We can only hope that the Management Board picks the best of the choices available, and live with the results of their choice until the 2026 assessment update tells us whether additional modifications are required to meet the rebuilding deadline.

What will the Management Board do?

Hopefully, quite a few anglers will provide comments ahead of the December 16 meeting, but we still have to wonder what, regardless of the comments made, the Management Board might decide to do.

It might well do nothing.  

The Technical Committee did calculate, after all, that if fishing mortality rate for the first eight months of 2024 is maintained throughout the rest of the year, there is a 57 percent chance that the stock will recover under current regulations.  That finding will probably tempt quite a few Management Board members to take the easy way out, forego any new management measures, and hope that the basws work things out on their own.

It's a risky strategy, with a 43 percent chance of failure, and the poor recruitment in recent years makes going into 2030 with a spawning stock biomass that remains below the target level more hazardous than it would otherwise be.

The high level of uncertainty could also lead the Management Board to defer action until they can get the recreational catch and landings data for Waves 5 and 6.  

That could mean deferring any action until February 2026 or, perhaps, even until May, or it could mean that the Board will decide that, instead of fast-tracking new management measures, it should initiate an addendum through the normal addendum process.  Doing so would allow the Management Board to put concrete options on the table and send them out for public comment, and would make it possible to hold public hearings to maximize stakeholder input.  

Any measures included in such an addendum wouldn’t be effective until 2026, but given the advice that additional measures might not be needed at all, initiating an addendum might be an easier sell than it was two months ago, when a motion to do so was rejected by the Management Board.

But there are also quite a few responsible members of the Management Board, who understand the perils now facing the striped bass stock, and who will want to take immediate, decisive action.  We can only hope that there are enough of such people, holding the majority of the seats in enough states, that their views will prevail.  

If they do, we can probably expect some sort of closed season, and probably some sort of commercial quota reduction as well, although I’m hesitant to predict anything beyond those two things.

What we need to do

Whether or not the Management Board decides to take action, and what sort of action it decides to take, may well depend on the volume and content of public comment.  

If the Management Board gets a couple of thousand emails—not an unreasonable volume, as they received more than that many comments on both Amendment 7 and Addendum II—and a substantial majority of those letters call for a 14 percent reduction, there’s a pretty good chance that the Board will comply.

That’s not a certain outcome, because one or more Management Board members might make an argument compelling enough to yield a different result, or there might be enough disagreement between Board members that it becomes impossible for any proposal to attract a majority of the votes.  Nonetheless, a strong outpouring of public comment calling for a particular outcome is likely to have a real impact.

Thus, it’s important that stakeholders comment on the issues.

Comments must be emailed and, as noted at the start of this post, must be received no later than 11:59 p.m. on December 10.  Emails should be addressed to comments@asmfc.org, with a subject line clearly indicating that they are “Striped Bass Comments.”  Emilie Franke, the Fishery Management Plan Coordinator, asks that if an organization is planning to solicit form emails from members or from the general public, it contact her at efranke@asmfc.org, or call her at 703-842-0716, to arrange for a special subject line that will make such emails easier to identify and sort.

Ms. Franke has done a masterful job in the past, sorting, compiling, and reporting on the public comment received, and anything that we can do to make her job easier, given the short time she has to get it done, is something we ought to do.

And that’s it for now.

I only ask that readers of this blog do what they can to make their views known.  In return, two weeks from now, I’ll let you know how it all turned out.