Well, after an almost two-year-long process, it’s here. The public comment period for Draft Amendment 7 to the Atlantic Striped Bass Management Plan began in late February and will remain open until April 15th. If you’ve followed this subject and love striped bass, you understand the importance of this document for much of the east coast. The striped bass stock is overfished and in a period of poor recruitment. It’s a grim outlook but makes this opportunity to improve striped bass management all the more important. Right now, the American Saltwater Guides Association is leading the charge for the responsible management and conservation of striped bass.
The Bare Bones of Striped Bass Management
Striped bass are anadromous fish that are mostly found from North Carolina to Maine. The Atlantic States Marine Fisheries Commission (ASMFC), which manages striped bass, declared the stock to be overfished and subject to overfishing in 2019. The ASMFC Striped Bass Board took quick action to curb fishing mortality (the overfishing component) through Addendum 6, which was designed to achieve an 18 percent reduction in coastwide removals. Towards the end of 2020, the Board initiated Amendment 7 to address “longstanding fishery management issues.” Throughout last spring in 2021, stakeholders provided public comment on a Public Information Document regarding potential issues to include in the Draft Amendment. In January 2022, the Striped Bass Board approved Draft Amendment 7 with four primary issues (management triggers, recreational release mortality, rebuilding plan, and conservation equivalency), and began the public comment period—this is where we are today. The Board will meet in May to review all the public comment and select final alternatives for the Amendment.
Draft Amendment 7 is a beefy and complex document. Heck, there are 18 decision points. But it’s all important, and these decisions will impact striped bass management for years to come. We all have a great opportunity to positively influence striped bass management and, hopefully, restore this iconic fishery to its past glory and enjoy all that follows. Keep reading for the ins and outs of Draft Amendment 7 and how to provide effective, informed public comments.
- ASMFC Quick Reference Guide for Striped Bass Draft Amendment 7
- ASMFC Public Comment Instructions and Hearing Schedule
- ASGA Public Comment Guide and In-Depth Blog
What’s in Draft Amendment 7
Draft Amendment 7 considers four primary topics: management triggers, recreational release mortality, rebuilding plan and conservation equivalency. Each of these issues have their specific complexities, so this article will try to stay at a high level. Listed below are brief summaries of these issues and themes ASGA is voicing.
If you have read any of Flylords’ striped bass coverage or followed management in recent years, you probably have an understanding for how CE can be abused to the striped bass stock’s detriment. CE is a program fishery managers use to allow states flexibility in setting regulations (bag/size/season limits) as long as the same levels of conservation are achieved—or at least that’s how it’s supposed to work. This section provides several options to bring accountability to the program and reduce the inherent uncertainty that CE injects into management.
If there is one issue in Draft Amendment which can fundamentally improve striped bass management, it is the reform of CE. So, if you must prioritize these issues, focus on this section and encourage the Board to place responsible guardrails on its CE program. Draft Amendment 7 includes options to restrict CE based on stock status, set minimum data precision standards, add an uncertainty buffer (luxury tax), and hold states responsible for their share of fishing mortality.
“Conservation Equivalency has been systematically abused by several states resulting in missed conservation goals,” said ASGA’s VP and Policy Director Tony Friedrich. “New Jersey and Maryland have used CE to continue an unsustainable level of harvest. In 2020, NJ and MD accounted for over 73% of the total number of recreationally harvested striped bass. CE cannot continue in its current form.”
This section deals with how, when, and why striped bass management reacts to new information. For the most part, the biomass and mortality triggers in the current Fishery Management Plan are effective—when they’re followed—and thus should remain status quo. For example, the overfishing trigger that directed management action in 2020 through Amendment 6 successfully reduced fishing mortality by the prescribed amount. However, CE almost jeopardized that success. Here are a couple of instances where the triggers could be improved.
Recruitment—or how many juvenile striped fish are entering the key nursery areas—is an essential component in striped bass management, yet its outcome is largely out of our hands. The current recruitment trigger has only tripped once despite a long period of below average recruitment, prompting the Striped Bass Board to question its design and efficacy.
Tony offers more insight: “If a trigger never trips, is it really a trigger? The Maryland portion of the Chesapeake Bay has seen the worst three consecutive years of recruitment since 1979-81, and the trigger was not tripped. That is all we need to know about the need for updating this management tool.”
New options for the recruitment trigger would improve its design by tweaking the sensitivity so that it actually trips when recruitment is poor. The thinking behind this is to modify the trigger to act more like an early warning sign. Additionally, there are options that would compel the Board to react to the recruitment trigger tripping.
Taken in conjunction, improving the sensitivity of the recruitment trigger and requiring the Board to adequately respond to the trigger seem like common-sense improvements to striped bass management and should better prepare management for future periods of poor recruitment.
Recreational Release Mortality
The striped bass fishery is overwhelmingly a recreational, catch-and-release fishery. This is even more true in the booming striped bass fly fishing community—most anglers just want to go out and get on a great bite, and filling coolers is not a strong motivator (not that there is anything wrong with legally harvesting a striper to feed friends and family).
For more than 30 years, the vast majority of striped bass caught by recreational anglers have been released, hovering around 90 percent or 50 million fish annually. While this shows that there is inherent value in abundance and the opportunity to reencounter a striper, it also presents a management challenge as some fish don’t survive following catch-and-release fishing. Stock assessments tell us that roughly half of all recreational removals (dead fish) are the result of release mortality. Currently, managers assume nine percent of all striped bass that are released die. While this is an averaged assumption, there are times when mortality is much less (think cold, salty, oxygen-rich waters of New England) and when it is far greater (think lukewarm water with low oxygen levels such as the Chesapeake Bay in mid-late summer).
The alternatives in this section seek to limit the impact of catch and release mortality through varying mechanisms, including seasonal closures, gear restrictions, and educational outreach. There are some difficult, possibly painful topics in this section, notably options which would institute “no-targeting closures.” Such closures would prohibit anglers from trying to catch a striped bass (even if you planned to safely release them or environmental conditions would not contribute to increased mortality) over specified time periods.
ASGA contends that because no-targeting closures are not enforceable and any conservation benefit is not quantifiable, such closures, which would punitively harm conservation-minded light tackle and fly fishing guides, should not be implemented at this time. Coming from the world of fly fishing, this might seem foreign. What about the steelhead closures in the PNW or hoot owl closures on western trout rivers? Coastal fisheries are an entirely different beast. For example, in the Northeast if you are fishing for bluefish, you are de facto also fishing for striped bass. There’s just no way around it. However, this is undoubtedly a difficult issue, because there really aren’t that many tools managers have for recreational fisheries management. This issue will definitely be the topic of intense debate at the May meeting. Further discussions on spawning closures will likely occur then too.
Striped bass were declared overfished in 2019, but the Board has not developed or implemented a rebuilding plan yet. According to its own rules, the Board must rebuild the stock by 2029. Draft Amendment 7 will address this and, given the recent period of poor recruitment, provides an option to attack rebuilding with more conservative assumptions regarding striped bass spawning success. Additionally, Draft Amendment 7 includes an option to allow the Striped Bass Board to respond quickly to the upcoming stock assessment update should it require additional restrictions. Simply put, if the October 2022 updates indicates that additional measures are needed to rebuild striped bass by 2029, the Board can quickly implement measures, instead of using the traditional year-long addendum process.
ASGA supports using a low recruitment assumption to rebuild striped bass and allowing the Board to adjust measures through Board action (simple majority vote).
“Without this option, we would lose another year and be backed further into a rebuilding corner. None of this would be necessary if the Board had acted in 2018. But, here we are again,” said Friedrich. “An additional year could make a lot of difference in the pain we all will face through rebuilding. The only downside to this option is that public comment is limited since time is of the essence. We will still be able to comment in some capacity, but it would be limited.”
Once approved, Amendment 7 will guide management long into the future (Amendment 6 was developed in 2003, and it’s not inconceivable that this document guides striped bass management for another 20 years). So, read the Draft Amendment 7 (or the more digestible quick reference guide), check out ASGA’s materials, talk to your fishing buddies, think about what type of fishery you want to see in five or ten years, and then submit a well thought out comment! The striped bass could really use your help right now.
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How to Comment
So, by now, you probably have a solid footing for what is in this document and how management could be impacted. If you want to help improve striped bass management and restore this amazing fishery, it’s time to develop and submit a public comment. You can do so in person or at a webinar at one of the remaining state hearings. Or you can simply write an email and send it to ASMFC staff. It’s important to stay focused on the issues because that is what staff will be tracking. Put another way, comments on issues not in Draft Amendment 7 will not be nearly as constructive.
If you can’t make it to a state hearing or just want to take your time to develop a well-reasoned comment, written comments over email are a great option. However, ASMFC has a policy in place that weights ‘form letters’ or identical comments less than individual comments. So, it’ll be important to make sure you add some level of personalization on top of whichever options you decide to support. Also, to further motivate public comment and engagement around Draft Amendment 7, ASGA is putting on a raffle for folks who send in a comment. Email your comment to email@example.com with “Draft Amendment 7” in the subject line and cc firstname.lastname@example.org in the email to be entered—no matter which positions you decide on.
Striped bass are a special and iconic fish. Some call schoolie stripers the perfect fly rod fish–they put a great bend in an 8wt, will eat all sorts of flies, are usually with other willing takers, and you can catch them on the flats, in the surf, or way up in a brackish tributary. Fly fishing aside, striped bass also every man’s fish and the most popular sportfish on the east coast. When striped bass are abundant, like they were in the early 2000s, coastal towns from Maine to Virginia felt the impact. Hotels were full, guides were booked, fly shops couldn’t keep up with demand, all because of the fact that there was a healthy, abundant biomass.
It’s time ASMFC turns it around and restores this iconic fish, but it’ll take a big push from conservation-minded anglers and the larger fly fishing community to nudge the Striped Bass Board in the right direction. And by now, I think we all know just how powerful the fly fishing community can be.
Cover picture by Flylords’ Dan Zazworsy and Zak Robinson of Rising Tide Anglers
Organization of the Month: American Saltwater Guides Association
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