STRIPED BASS AMENDMENT 7--NAVIGATING THE PID: PART III, MANAGEMENT TRIGGERS AND REBUILDING TIMELINES

In the last two editions of One Angler’s Voyage, I discussed a couple of issues raised by the Public Information Document for Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass (PID), the proper Goals and Objectives for the striped bass management plan, and the biological reference points needed to achieve them.

In today’s blog, we’ll look at the third face of that issue:  When fishing mortality begins rising too high, and/or the spawning stock biomass falls too low, how should managers respond?

I’m going to begin that inquiry with an observation:  Fish can do well without fishermen, but fishermen, and fishing industries, can’t survive without fish.  

Maintaining the long-term health and sustainability of the striped bass stock ought to be the first priority of the Atlantic States Marine Fisheries Committee’s Atlantic Striped Bass Management Board.  While the Management Board can reasonably try to avoid unnecessarily inconveniencing the recreational and commercial fishing industries, it should never compromise the needs of the striped bass stock in its efforts to do so.

Fishery managers must always remember that Mother Nature doesn’t—and can’t—compromise.  The striped bass’ biological needs are just that—needs—and the stock cannot thrive if those needs aren’t met.

A management strategy that slows, but does not halt, the decline of the stock, in order to accommodate the short-term economic concerns of stakeholders, is a strategy that is destined to fail in the long term.  Stocks can’t be overfished back to health.  The failure to rebuild a stock when rebuilding is called for, in order to placate the fishing industry, only sets up both the stock and the stock-dependent industry for hard times the next time the bass faces adverse conditions on the spawning grounds and/or in the sea.

With that in mind, let’s look at the management triggers.  The current triggers, contained in Amendment 6 to the Interstate Management Plan for Atlantic Striped Bass, address three different issues:  fishing mortality, female spawning stock biomass, and the recruitment of new fish into the population. 

Of the three, fishing mortality is by far the most important, in part because controlling fishing mortality is directly related to maintaining the spawning stock biomass at acceptable levels, and in part because it is the only one of the three factors that the Management Board can directly control.

The last benchmark stock assessment notes that if female spawning stock biomass is to be maintained at its target level, fishing mortality must be constrained to its target level as well.  Yet, while fishing at or below the target fishing mortality level might be necessary to achieve the biomass target, that’s not the whole story.  Striped bass abundance is dependent upon two completely unrelated factors.  One is the number of fish being removed from the stock; that’s where fishing mortality comes in.  The other is the number of new fishing recruited into the stock, and fishing mortality doesn't affect that at all.

Many anglers think that if the spawning stock biomass is high, the number of juvenile bass produced by those females each year will be high, too.  That’s not how things work.  There is no clear relationship between the size of the spawning stock and spawning success.  

Biologists measure such stock-recruit relationship with a parameter they call “steepness,” which is

“a ratio of 2 recruitment levels:  the recruitment obtained when the spawning stock is at 20% of its [unfished] level, and the recruitment at the [unfished] level.”

The higher the number obtained by dividing the number of fish recruited into a stock fished down to just 20 percent of its unfished level by the number of fish recruited into an unfished stock, the less that spawning success is dependent upon the size of the spawning stock.

The model used to produce the most recent benchmark stock assessment for bass used a steepness value of 1, which assumes that there is no stock-recruitment relationship at all.

Normally, that would be good news, because it would mean that striped bass were a very resilient species, that could be quickly rebuilt even if spawning stock biomass fell to very low numbers.  Unfortunately, in the case of striped bass, that resilience is tempered, and even controlled, by another, external factor:  Weather.

In my last blog, I quoted Dr. Michael Armstrong, Assistant Director of the Massachusetts Division of Marine Fisheries, who noted during an American Sportfishing Association-sponsored webinar last July, that

“Recruitment is striped bass is highly variable…When you have a series of lows…we start seeing spawning stock biomass eroding, and that’s exactly what has caused the [current] erosion of spawning stock biomass, it’s these poor year classes.  It’s primarily not fishing, it’s primarily environmental causes.  And the primary cause is…the water regime in Chesapeake Bay.  When you have flood springs, you get bad recruitment.  When you get really dry springs, you get bad recruitment.  When you get nice cool, wettish springs, you get big year classes…”

Then he uttered the words that ought to control the entire management trigger discussion:

“We have to husband the big year classes along the best we can.  The only way to do that is to keep [fishing mortality] low.  [emphasis added]”

And the best way to do that is to adopt more restrictive management measures as soon as fishing mortality gets too high.

Two of the current management triggers attempt to do just that.  Management trigger 1, which kicks in when the stock becomes subject to overfishing, says

“If the Management Board determines that the fishing mortality threshold is exceeded in any year, the Board must adjust the striped bass management program to reduce the fishing mortality rate to a level that is at or below the target within one year.”

Taking quick action to avoid overfishing makes sense, because fishing above the threshold target level doesn’t only mean that it will be difficult, if not impossible, to maintain the biomass at or below the target level.  It means that the stock is likely to fall below the biomass threshold, and become overfished at some point in the future, if no action is taken.

And the Management Board should never allow the stock to become overfished again.

But if it is doing its job diligently and well, the Management Board should never allow overfishing to occur. 

Sometimes, inevitably, some combination of factors—perhaps a strong year class of fish, perhaps unexpectedly good weather, perhaps something different—will result in more people fishing, or the bass being easier to catch, and cause fishing mortality to rise above the target over the course of a season.  That should be expected, and not be a cause for concern.

But if fishing mortality doesn’t drop back to or below the target in the following year, there could be something inherently wrong with the management process.  That’s where management trigger 3 kicks in:

“If the Management Board determines that the fishing mortality target is exceeded in two consecutive years and the female spawning stock biomass falls below the target within either of those years, the Management Board must adjust the striped bass management program to reduce the fishing mortality rate to a level that is at or below the target within one year.”

Again, it’s a prudent measure.

If fishing mortality gets a little too high when the stock is above the biomass target, no real harm is done, and the Management Board can safely defer action.  But if fishing mortality is still too high after the biomass falls below target, then that fishing mortality is driving down abundance, and needs to be addressed before the biomass declines to the point where the Management Board, perhaps hampered by adverse conditions on the spawning grounds, will have real difficulty rebuilding it without resorting to very restrictive measures.

It’s always easier to fix a problem when it first appears, rather than waiting until things approach crisis levels before taking action.

Of course, not every Management Board member agrees.  The “Work Group” report that preceded the creation of the PID noted that

“Some stakeholders support the 1-year requirement for change while others believe that it promotes ‘knee-jerk’ reactions that might not always be necessary.  [emphasis added]”

That’s interesting language, which says a lot about why the Management Board, and more generally, the ASMFC, has such a poor record of maintaining fish stocks at healthy and sustainable levels. 

It inherently admits that imposing additional management measures are often needed, but also reflects the views, held by too many Management Board members, that it is worse to impose restrictions that “might not always be necessary” than it is to fail to adopt restrictions that are needed to maintain the health of the striped bass stock.  In their view, it is better to delay action in order to avoid the occasional, unnecessary restriction, even if that increases the risk to the fish that they are obligated to manage and conserve.

That bias, which favors continued harvest in the face of uncertainty, and underlies the PID’s emphasis on “management stability” and “flexibility,” has hampered fisheries management at the ASMFC for many years.

Board delay, continued overfishing, and a few years of poor recruitment could leave the striped bass stock in a pretty bad place.  A quick response to excessive fishing mortality is the only way to help assure the abundance of the stock—even if it doesn’t provide for “management stability.”  Thus, management triggers 1 and 2 should remain unchanged.

Things get a little trickier when we start talking about spawning stock biomass.  

Amendment 6 contains two management triggers that deal with that, too, and both are similar to the triggers that address fishing mortality.  One requires a rebuilding plan, not to exceed ten years in duration, if the stock becomes overfished; the other requires that the same rebuilding plan be put in place if spawning stock biomass falls below target for two consecutive years, and fishing mortality rises above target in either year.

Here’s the problem:  While the Management Board clearly should intervene when spawning stock biomass declines, its ability to rebuild that biomass will always be limited by the number of young bass recruiting into the stock.  A mason can’t rebuild a wall without bricks; a fishery manager can’t rebuld a stock without fish.

The farther the stock declines, the harder it will be to rebuild if, due to adverse conditions in the spawning rivers, recruitment remains low (if spawning conditions are good, on the other hand, the lack of a stock-recruitment relationship should allow for a quick and successful recovery).

That means that the Management Board ought to do everything in its power to keep the stock from becoming overfished.  If the stock does become overfished, as it is right now, it is only because the Management Board failed to intervene in time, and didn’t adequately reduce fishing mortality while there was still a chance to effectively do so.  Management stability would have prevailed over management success.

Even in a period of poor recruitment, the striped bass stock can be rebuilt within ten years, if the Management Board summons the will to do so.  Amendment 3 to the Interstate Fishery Management Plan for Atlantic Striped Bass was adopted in late 1985, in the depths of the striped bass collapse, when recruitment was at or near historic lows.  In 1995—just 10 years later—the stock was declared completely rebuilt, although it’s worth noting that such rebuilding was only to what we’d now consider the biomass threshold, not the target.

Yet it’s important to note that even to get there, the Management Board had to resort to very restrictive measures, which gave near-full protection to the “large” (today, we’d deem it below average) 1982 year class, and every year class that came after.  Amendment 3 contemplated removing no more than 5 percent of the protected year classes from the population each year, a fishing mortality rate of just 0.051; the current fishing mortality rate target of 0.197 allows more than three times as many—roughly 17 percent—of striped bass to be removed from the stock each year.

So nipping a stock decline when it first manifests itself, rather than letting things get worse for a few years, can help stakeholders avoid a lot of future pain.

That’s why management trigger 4, which requires rebuilding when spawning stock biomass falls below target in consecutive years, and fishing mortality rises above target as well, makes sense.  It provides for an early, easier fix, instead of a long, difficult, and painful slog back from an overfished condition.

So when talking about current management triggers 2 and 4, both make sense, and both ought to remain as they are.

That gets us to the most difficult issue, management trigger 5, which addresses recruitment failure.  It reads

“The Management Board shall annually examine trends in all required Juvenile Abundance Index surveys.  If any JAI shows recruitment failure (i.e., JAI is lower than 75% of all other values in the dataset) for three consecutive years, then the Management Board will review the cause of the recruitment failure (i.e., fishing mortality, environmental conditions, disease, etc.) and determine the appropriate management action.  The Management Board shall be the final arbiter in all management decisions.”

Here, in management trigger 5, we find someting that probably does need to change.  If we look at the Maryland striped bass juvenile abundance index, we find that such index would have to be below 4.24 for three consecutive years before the trigger is tripped.  That only happened once in the 64-year history of the index, during the years 1983-1986, when the stock was just beginning to claw itself out of its prior collapse.

And that shows the weakness of management trigger 5; it would only have been tripped in 1985, after Amendment 3 had been adopted.  If it had been in place back in the 1970s, it would not have prevented the stock collapse, just as it didn’t prevent the stock from becoming overfished today.  The question is, what would make it better? 

Perhaps if it triggered when a three-year rolling average, rather than three consecutive years’ indices, fell below the twenty-fifth percentile, it would be more effective. 

If that were the case, the trigger would have been tripped (again, if it had been in effect) in 1981, when a three-year average of just 2.40 might have started rebuilding just a little earlier, and perhaps protected more of the critical 1982 year class.  It’s far from impossible that, if such rolling average was in effect, management trigger 5 would also be tripped at the end of this year, as the Maryland JAI was dismal enough in 2019 and 2020—3.37 and 2.48, respectively—than anything lower than a still sub-par 6.8 for 2021 would be low enough to require action.

And requiring action, of course, should be another change.  As currently written, management trigger 5 does not require management action, even if recruitment failure occurs.  Allowing a Management Board that is wedded to the concept of “management stability” to be “be the final arbiter in all management decisions” virtually guarantees that nothing will be done.

Thus, with respect to management trigger 5, change is needed.  A rolling average that falls below the 25^th percentile of the relevant juvenile abundance index would be a step in the right direction, as would language that requires Management Board action.  I’ll leave the precise wording of the needed changes to the scientists and statistical experts, who actually know how to calculate such things. 

But change, of some sort, is required, the sort of change that forces managers to respond to declining recruitment trends, and compels them to act before declining recruitment translates itself into a depleted spawning stock.

That leaves only one issue:  How long should the Management Board have to rebuild the spawning stock?

Management triggers 2 and 4 both say that if either one is tripped,

“the Management Board must adjust the striped bass management program to rebuild the biomass that is at or above the target within the timeframe established in Section 2.6.2 [of Amendment 6]”

That section says that if rebuilding is required

“the Management Board will determine the rebuilding schedule at that time.  The only limitation imposed under Amendment 6 is that the rebuilding schedule is not to exceed 10 years.”

So is 10 years an appropriate rebuilding period?  The PID asks

“What is more important, rebuilding the stock quickly, or mitigating the impact to fisheries?  In other words, do you prefer significant changes to rebuild the stock quickly, or smaller incremental over time to gradually rebuild the stock.”

Those questions were inadvertently answered by MichaelWaine, the ASMFC’s former Fishery Management Plan Coordinator for striped bass,in August 2014, when he (in my opinion, very wrongly) sought to convince theManagement Board to ignore their clear obligation under management trigger 4,and not initiate a rebuilding plan for the striped bass stock.

The bass are suffering the consequences of that advice today.  But what Waine said still remains relevant.  It was

“Management trigger 2 [sic] in Amendment 6 says that you need to rebuild the [spawning stock biomass] back to its target over a specified timeframe that should not exceed ten years.  I think that there is sort of a combination of things happening.  The board is acting to reduce [fishing mortality].  Through that action we see the projections showing that [spawning stock biomass] will start increasing towards 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 that is involved.  [emphasis added]” 

In some ways, Waine wasn’t wrong.  The degree of uncertainty does increase over time, and it’s much more difficult to predict where the spawning stock biomass is going to be ten years from now than it is to predict where it will be in just two or three years.  That’s why “management stability” is such a dangerous concept—if the Management Board sets regulations that don’t seem to work, it should be willing to make course corrections when and as needed, to counter the effects of past uncertainty, and not maintain ineffective measures in the name of stability.

But where Waine went wrong was first, and most obviously, in assuming that the actions taken in 2014 would initiate rebuilding—in fact, the stock continued downhill—and then in using uncertainty as an excuse for ignoring the 10-year rebuilding deadline in Amendment 6, instead of as a reason for setting a goal, and then making mid-course corrections to assure that such goal was achieved.

As mentioned earlier, history has demonstrated that even a collapsed striped bass stock can be rebuilt within 10 years.  Yes, there is uncertainty about how to get it done by that deadline, but assuming that the Management Board is willing to elevate the needs of the bass above its desire for ineffective, but stable, regulations, there's nothing that new regulations can't cure.

Think about it.  If uncertainty m akes it difficult to develop a 10-year rebuilding plan, why should anyone believe that it would be easier to rebuild the stock in 15 or even 20 years, when uncertainty would be further compounded by time?

Human nature also needs to be considered.  When presented with a firm deadline, people can usually figure out how to get a job done, even if it might be unpleasant to do so.  But when faced with a choice of making a decision to rebuild a stock, and in doing so, suffer the vitriol spouted by temporarily inconvenienced stakeholders, or putting off the hard and unpleasant decisions off for another day, fisheries managers—particularly at the ASMFC—will almost always choose the latter course.

Consider the actions of the ASMFC's Tautog Management Board.  It knew that tautog were overfished in 1996, and had a pretty good idea how to fix the problem back then.  But because doing so would cause a lot of political pushback, it hemmed and hawed and tried to find a way to put off needed measures for more than 20 years.  Nothing resembling an effective tautog management plan was adopted until 2017—fully 21 years after the problem was first recognized—and even that plan will allow for overfishing in Long Island Sound until 2029.  No rebuilding timeline has yet been established.

It would take an optimist—or a fool—to believe that striped bass would fare any better if the 10-year rebuilding deadline was replaced with a longer rebuilding timeline—or with no deadline at all.

Thus, with respect to rebuilding, the 10-year deadline must be retained.

In the end, the right answer to all of the issues—both the management triggers and the rebuilding timeline—boil down to the needs of the fish, and to the foibles of fishery managers.  Prompt responses to problems with the stock will keep small issues from evolving into crises; taking away mangers’ ability to delay taking action will better assure that meaningful actions are taken.

And actions that help maintain striped bass abundance will, in the end, be best not only for the fish, but for fishermen and the fishing industry.

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On Thursday, One Angler’s Voyage will move on to the next important issues in the PID—conservation equivalency and accountability.  Unlike the topics discussed so far, those are issues where significant changes to the management plans are not only justified, but sorely needed.

STRIPED BASS AMENDMENT 7--NAVIGATING THE PID: PART II, BIOLOGICAL REFERENCE POINTS

 

In the last edition of One Angler’s Voyage, I provided a brief overview of the Public Information Document for Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass (PID), along with a discussion of the Goal and Objectives that ought to guide the new amendment.

In today’s blog, we’ll look at biological reference points, and why choosing the right reference points is critically important to the long-term health of the striped bass stock.

Let’s start by addressing one statement that occurs on page 7 of the PID, which never should have made it into the document.  It says

“the current reference points may be unattainable given the current objectives for fishery performance.”

You need to understand, before reading any farther, that such statement was made without any scientific or other factual support; it is merely an editorial comment that made its way into the PID at the behest of John Clark, a Delaware fishery manager, who is doing everything that he can to increase Delaware’s commercial striped bass quota. 

The reference points used to manage the striped bass fishery are “empirical” reference points derived from observations of the striped bass stock at different points of time; for whatever reason, the stock assessment model has been unable to calculate appropriate biological reference points for the striped bass.  

The most recent benchmark stock assessment reveals that

“The reference points currently used for management are based on the 1995 estimate of female [spawning stock biomass].  The 1995 female [spawning stock biomass] is used as the SSB threshold because many stock characteristics (such as an expanded age structure) were reached by this year and the stock was declared recovered.”

That benchmark assessment, which represents the best available scientific information about the striped bass stock, also says that

“To estimate the [fishing mortality] threshold, population projections were made using a constant [fishing mortality rate] and changing the value until the [spawning stock biomass] threshold value was achieved…

“For this assessment…[the spawning stock biomass] threshold was estimated at 91,436 [metric tons] (202 million pounds), with [a spawning stock biomass] target of 114,295 [metric tons] (252 million pounds).  The [fishing mortality] threshold was estimated at 0.240, and the [fishing mortality] target was estimated at 0.197.”

In other words, what the science tells us—contrary to the language in the PID—is that the current reference points are obtainable.  But to rebuild female spawning stock biomass to the biomass target, the Management Board must first reduce fishing mortality to the fishing mortality target and keep it there long enough for the stock to rebuild.

That’s something that the Management Board has never been willing to do.

But never doubt that the only reason that the current reference points might appear to be “unattainable” is because the Management Board has, to date, lacked the moral courage and political will to do what’s required pursuant to the explicit language of the striped bass management plan.

Language in the PID that talks about “management stability” and “flexibility” is merely an effort to condone the Management Board’s failure to maintain the health of the striped bass stock.

That observation is very relevant to the PID’s Issue 2, Biological Reference Points, as there are number of Management Board members who are seeking to escape the burdens of rebuilding the stock by reducing the biomass target; they want to increase landings in the short term, even if such landings would place the long-term health of the stock in greater jeopardy.  To accommodate such Management Board members, the PID says that

“other empirical-based reference points could be considered, such as the estimate of [spawning stock biomass] in a year other than 1995 as the [spawning stock biomass] threshold…For example, the [Atlantic Striped Bass Technical Committee] discussed 1993 as a possible alternative proxy year because the [spawning stock biomass] was lower than in 1995 but still produced a strong year class.”

Citing 1993 as an alternative proxy year “because the SSB was lower than in 1995 but still produced a strong year class” is a red herring of the first order.  Striped bass spawning success isn’t directly linked to the size of the female spawning stock biomass.  That biomass peaked in 2003, when the Maryland striped bass juvenile abundance survey returned a young-of-the-year index of 25.75, which was well above average, but not much different from the 1989 index of 25.20, despite the fact that, in 1989, a much smaller striped bass stock was still clawing its way back from its collapse in the decade before.  1993 did produce a strong year class—the Maryland index was 39.76 that year--that was more than four times larger than the below-average 9.27 produced by the fully-recovered spawning stock in 1995.

Trying to correlate the size of any given year class of striped bass with the size of the spawning stock at the time is an exercise in futility.  Unless the spawning stock biomass has fallen so low that it is physically incapable of producing a large year class, spawning stock size does not predict spawning success.  A small spawning stock can still produce a large year class, as it did in 1989.  And a large spawning stock can, and often does, produce below-average spawns, as was the case in 2006—just three years after the biomass peaked—when the Maryland index was a dismal 4.25.

What really matters are the environmental conditions in the spawning rivers, which are dictated by the weather each year.  Cold winters and wet springs tend to produce successful spawns and large year classes of juvenile striped bass, while warm winters and dry springs lead to poor spawning success and small year classes of juvenile fish.

As Dr. Michael Armstrong, Assistant Director of the Massachusetts Division of Marine Fisheries, noted during an American Sportfishing Association-sponsored webinar last July,

“Recruitment is striped bass is highly variable…When you have a series of lows…we start seeing spawning stock biomass eroding, and that’s exactly what has caused the [current] erosion of spawning stock biomass, it’s these poor year classes.  It’s primarily not fishing, it’s primarily environmental causes.  And the primary cause is…the water regime in Chesapeake Bay.  When you have flood springs, you get bad recruitment.  When you get really dry springs, you get bad recruitment.  When you get nice cool, wettish springs, you get big year classes…”

The problem, of course, is that no one can predict, a year or even years in advance, what the environmental conditions in the Chesapeake’s tributaries will be when it’s time for the striped bass to spawn.  If the conditions are good for an extended period of years, striped bass abundance can remain high for a while.  But if the conditions are poor for a number of years in a row, as they were for most of the years between 2004 and 2010, striped bass abundance can plummet; the fact that striped bass spawning stock biomass peaked in 2003 didn’t prevent it from declining sharply in later years.  There is always uncertainty about when the next strong year class will be produced.

Thus, there is only one way to maintain a healthy striped bass stock.  As Dr. Armstrong also noted,

“We have to husband the big year classes along the best we can.  The only way to do that is to keep [fishing mortality] low.”

That being the case, it only makes sense to maintain the current biological reference points.  Lowering the biomass threshold to 1993 levels, as suggested in the PID, is contrary to that goal, and the fishing mortality reference point associated with such a 1993 threshold and target would be higher than the fishing mortality reference point being used today.

There is also another reason for maintaining the current reference points.  A higher fishing mortality target that would be associated with a lower spawning stock biomass target would tend to truncate the age and size structure of the spawning stock, and that, in turn, increases the risk to the striped bass. 

That’s something people often don’t think about; it’s somewhat intuitive to assume that if fishing mortality is increased, that increase will have an equal impact on every year class in the population, but that’s not how things actually work.  Higher fishing mortality rates have their greatest impact on the older age classes; when such rates increase, the population tends to lose its fish, and reduce the number of year classes in the spawning stock.

That’s not a good thing.

Twenty years ago, biologist David H. Secor, who is well-known for his work with striped bass, published a paper in the ICES Journal of Marine Science that addressed the issue.  In that paper, Dr. Secor noted that

“reduction in year-class diversity renders a population more vulnerable to recruitment failures.”

He also observed that, with respect to striped bass spawned in the Chesapeake Bay,

“Lowest year-class strengths were observed during periods when age structure [of the spawning stock] was severely truncated.”

That’s apparently due to the fact that female striped bass of different ages spawn at different times, with the older, larger fish generally being the first to spawn.  When there are many different year classes of bass represented in the spawning stock, it makes it more likely that, even in years with generally unfavorable spawning conditions, at least some striped bass will time their spawn to coincide with a period when spawning conditions are somewhat better, and thus prevent spawning failure.

When the age structure of the spawning stock is truncated, the stock loses much of its spawning time diversity; the fish are all about the same age, spawn at about the same time, and fail to produce many juveniles if, at that time, they encounter hostile spawning conditions.

Finally, having older fish in the population provides a buffer against long periods of below-average spawns.  Dr. Secor points out that, even after the striped bass stock collapsed in the late 1970s, it managed to produce a fairly successful spawn in 1982; that 1982 year class later become the foundation for the  stock’s recovery. He notes that

“most egg production in 1982 was attributable to striped bass >10 years in age.  Old remnant females produced during the 1960s were a hedge against a long period of recruitment overfishing that occurred during the 1970s.  Striped bass epitomize periodic strategists, spreading risk of failed replacement through variability in spawning behavior over many spawning seasons.  This life history tactic indicates that a truncated age distribution would result in stock abundance being more closely linked to annual changes in year-class strength.  [emphasis added]”

To put that in a PID context, if the reference points are changed, and a lower spawning stock target and higher fishing mortality target are adopted, and the age structure of the spawning stock becomes more truncated as a result, the stock will become more vulnerable to extended periods of below-average recruitment such as we saw throughout most of the 1970s and 1980s, and saw again, just a few years ago, in the period 2004-2010.

Thus, maintaining the current biological reference points is the best way to avoid truncating the age and size structure of the spawning stock, and by doing so, ensure the continued resiliency of the striped bass stock, and minimize its vulnerability to periods of low recruitment.

In response to Issue 2 of the PID, the current biological reference points should not be changed.

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In the next edition of One Angler’s Voyage, we’ll look at the issues of management triggers, intended to compel the Management Board to act when spawning stock biomass falls too low or fishing mortality rises too high, and how to rebuild the spawning stock.

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.

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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.

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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.