National Marine Fisheries Service Policy

The National Marine Fishery Service has published the public comment draft (link) of many months of work by NMFS to formulate a recreational fishing policy that will guide the department’s future actions regarding saltwater recreational fishing including regulation making. There are further links on the page that will take you to the pdf draft policy [recfish_policy_public_comment_draft] and also that enable you to send in any comments that you may have. The comments sent in by Stripers Forever’s appear at the end of this broadcast. We urge you to read the draft policy as well as SF’s comments, then to submit your own comments. The more recreational anglers and industry people they hear from the more motivated they assume our constituency is, and that can only help us down the road.
In general we agree with what they say. NMFS states that they “recognize the important social, cultural, and economic benefits associated with saltwater recreational fishing, and are committed to pursuing a collaborative stewardship approach promoting public access, fishery accountability, and regulatory enforcement.” The question is just how this philosophy will be transferred into NMFS actions in how they treat areas like exploitation versus conservation, resource allocation, and regulations that do affect recreational fishing opportunities such as seasons, closed areas etc. The record in the past has had mixed reviews as have the agency’s votes from their seat on the Atlantic States Marine Fisheries Commission.
NMFS defines in this document the recreational fishing community as containing “the businesses and industries, such as the for-hire fleet and tournaments, which support them.” This an important statement since SF believes that the guiding and charter boat industry is an important part of public recreational fishing and not a separate category to be lumped in with commercial fishing. Those desiring to continue past commercial sovereignty over the ocean regulatory process have tried to weaken the recreational fishing constituency by driving a regulatory wedge between for hire boats and anglers fishing on their own. SF has fought to stop this from happening. We believe that guides, head boats and charter boats exist to enable individual members of the public to access and enjoy the public fishery resources.
Brad Burns President, Stripers Forever and Ken Hastings ASMFC Policy Coordinator, Stripers Forever
*********
Stripers Forever Comments on the draft NMFS Recreational Fishing Policy
We have read the draft NMFS recreational fishing policy statement, and we applaud the formal recognition by NMFS of the socio economic value of recreational fishing, the rights of the public to access this resource, and the fact that the guiding and charter industry are not elements of commercial fishing, but rather enablers of recreational fishing access.
Our concern is that we do not see any evidence of commitment on the part of NMFS to make sure that these declared values are given the appropriate weight in management decisions that NMFS may participate in.  Mr. Sam Rauch of NMFS moderated a workshop at the Summer 2014 Atlantic States Marine Fisheries Commission meeting where he candidly discussed some perceived inadequacies in fisheries management that would be addressed by the new policy. In particular, he singled out the subject of allocation between stakeholder groups as an example of a policy “rusted in place” and in need of updating. The website announcing the policy update process promised direction in making the hard decisions that appears to be absent from the draft document.
The challenges regarding allocation described in the National Standards section of the Magnuson Act suffer from the lack of direction more than some other aspects of the Act. For example, consider the statement regarding allocation that says: “If it becomes necessary to allocate or assign fishing privileges among various United States fishermen, such allocation shall be (A) fair and equitable to all such fishermen; (B) reasonably calculated to promote conservation; and (C) carried out in such manner that no particular individual, corporation, or other entity acquires an excessive share of such privileges.”
Instead of addressing these obviously subjective descriptions of lofty goals, NOAA has concentrated on technical reports describing how economics theory might provide the guidance for maximizing the socio-economic “value” of our fisheries. Between 1990 and 2012 there have been repeated attempts to get traction with this approach, all of which have failed because these concepts have never been developed into a clear policy that is applied to fishery management decisions.
The Executive Order signed by President Clinton in 1993 directed fisheries managers to rely on economic “Net National Benefits” to drive management decisions. Twenty-two years later, a decade-long debate over decreasing striped bass abundance has terminated in a new addendum to the Fisheries Management Plan without ever mentioning “Net National Benefits” or any of the goals established by the National Standards. In fact the debate and decision process degenerated into the age old struggle pitting the financial desires of the current harvesters against what would truly provide the greatest benefit to the most people.
If the job of NOAA is to help ensure that fisheries managers adhere to Magnuson, then we need stronger, clearer policy documents to bridge the gap between lofty goals in the Act and the real world.

Category: News Updates · Tags:

ASMFC Regulations Released: What Does It All Mean?

On October 29, the Atlantic States Marine Fisheries Commission (ASMFC) approved new striped bass regulations which lower both commercial and recreational fishing mortality to conform to new lower reference points recommended by the ASMFC Technical Committee and adopted at this meeting. The ASMFC Management Board also clarified that uncaught commercial quotas cannot be transferred to other states. All of this comes as a result of last year’s stock assessment which showed that the striped bass spawning stock biomass has been below the desired target levels for years. The ASMFC technical committee gives the new changes only a 50 percent chance of rebuilding the spawning stock.

Some of us have been following this process for many years, and while the names of the fishery managers have changed, the basic positions they take are quite similar. The Chesapeake Bay area commercial fishermen want no changes in their catch quotas, claiming that they fish on a stock of non-migratory and plentiful male fish. This argument is hard to buy since the recreational catch in the Bay has declined from about 6.7 million fish in 2006 to 3.2 million in 2013. Further, striped bass spawning success in the bay has been drastically lower in recent years than it was during the glorious 1990s before all the catch quotas of striped bass were liberalized. (For more information on striped bass spawning success, see the recently posted 2014 young-of-the-year report on our website). It stands to reason that with fewer young stripers being born, there are also fewer fish to catch, and that is why the catch is less than half of what it was in 2003.

Bay area commercial fishermen also argue that a striped bass population as robust as it was a few years ago is not desirable or sustainable. The watermen claim that stripers are eating too many young blue claw crabs that the fishermen depend on for the rest of their living. The other argument heard repeatedly during the hearing was that a large spawning stock is not necessary for producing a large year class. The truth is that stripers have been coexisting with the crabs in the Chesapeake Bay forever, and many people feel that over-harvest and environmental conditions within the bay are the real culprits in the low crab population. While a reduced striper spawning stock can produce a large young-of-the-year class, the large spawning stock in the 90s produced many big year classes, not just an occasional outlier. Many scientists believe that the chances of a successful year class are much better if more adults spawn over a longer period of time and are therefore more likely to hit the jackpot for ideal spawning conditions.

It was heartening to hear some fishery managers from the northern states argue that the recreational fishery for striped bass has created more than 90 percent of the jobs and economic value tied to the species. Paul Diodati, the Director of Marine Fisheries in Massachusetts, made the point that the coastal states had already lost a great deal of money with the striped bass population downturn, and that many anglers have been deprived of highly valued recreational opportunities. Listening to ASMFC fishery debates over the years, I have never heard anyone stand up for the value of recreational fishing and the need for a robust fish population to the extent that I did during this meeting. That may be a good sign for the future of fishery management.

So where will the striped bass situation go from here? Will the lower quotas work? And what will happen if they don’t? It is impossible to predict the future spawning success of striped bass.

Certainly the more big stripers that come in to spawn, the better the chances that a big year class will result. The new coastal size and bag limit is one fish at 28 inches, rather than two fish. Will that change really reduce pressure and mortality on big stripers? Not very much, I fear. Most fishermen don’t catch two legal keepers anyway, and the new ruling will encourage the illegal practice of hi-grading – releasing smaller, dead keepers already in possession to keep a larger fish.

While we can’t say for sure what next year’s striped bass young-of-the-year number will be, we can look at the production that has already taken place to see just how many fish are in the biomass. It is the fish that are already born that we will have to work with for years to come. Nothing can change that, which means we will not have generally improving fishing for striped bass for many years. The reportedly large 2011 year class is in the pipeline. Those fish are now 17 inches or so in size and should be filling every nook and cranny along the coastline as is normal for three year old stripers from a giant year class. But very few fish of this size have been reported by anglers up and down the coast; nor were those 2011 fish seen in abundance last year as 11-inch, two-year-old stripers. There is no denying that the number of small stripers available over the past 10 years is much smaller than it was in the previous decade. That means there will be many fewer big fish in the coast-wide striped bass population down the road than there are now.

So while the vote this week mandating regulatory changes for 2015 is a step in the right direction, we would be surprised if those changes will substantially improve the striped bass population, or even make any difference. The battle is a very long way from being over. Although we feel that game fish status is the logical and inevitable future of striped bass management, any move away from the long-standing commercial bias is frustratingly slow in coming. So there is an even greater need for Stripers Forever and its members to remain involved in the fishery management process. In a few weeks we will launch our 12th consecutive annual fishing survey. Each year we have supplied fishery managers with the results of this coast-wide survey, and it is an important reason why the needs of the recreational fishing community are being taken more seriously in the fishery management process.

Thanks to everyone from Stripers Forever and from other conservation organizations whose members took the time to tell the ASMFC that stripers must be managed more conservatively. The ASMFC heard us and responded favorably. We must continue to keep the pressure on the ASMFC while we advocate for striped bass game fish. We need your help, so please stay involved.

Brad Burns
President, Stripers Forever

Category: Featured, News Updates · Tags:

MD DNR 2014 YOY Figures

MD has just released the 2014 young of the year figures for striped bass. The graph below shows the arithmetic mean numbers:

SB YOY 2014 GRAPH AM

The 2014 number is 11.02. This is sure to be a great number for the spin doctors. Looking at it positively this may be the best of the last three years, but in reality this is another very mediocre number and certainly not one that will allow continuing harvesting striped bass at current levels. One of our SF board members once said that a classic sign of a species in trouble is when both the lows and the highs of spawning success are in decline. The average of the last 3 years is now about 5.9 which is only slightly better than the levels experienced during the crash of the late 70s and 80s and just half of the long term average of 11.8 taken from 1957 through 2014.

In the graph above you will note that the large years happened quite regularly throughout the 1990s; these big years were needed to produce the great fishing that encouraged angler participation, tackle sales, and sustained the guiding industry. In fact there were five years within the 15 year period of 1989 to 2003 that had a young of the year counts above 20. In the 11 years from 2004 through 2014, there has been only 1.

Of extra concern is that while that one year class – 2011- was very large those fish should be about 17 or 18 inches this fall and they should be everywhere, but no one seems to be finding that to be the case. In fact the entire summer of 2014 was very spotty for school bass fishing. Some locations along the coast reported quite a few while many normally good spots had almost none or only a few good days. However many there will be as three year olds there will surely be many fewer in the future as they are harvested first in the Chesapeake Bay and later the coastal fisheries. So in summary we feel that while the 2014 year class is not bad news, it provides no reason to abandon the major reductions in harvest the ASMFC will be contemplating on Wed. 10/29.

Click here to view the MD DNR young of the year page. Click on either geometric or arithmetic mean to download the excel document. (If the pages opens up and asks for a password, but just X that window out and the document will open up anyway.)

Category: Featured, News Updates · Tags:

SF Full Comments to ASMFC Draft Addendum IV to Amendment 6

STRIPERS FOREVER COMMENTS TO DRAFT ADDENDUM IV TO AMENDMENT 6 TO THE ATLANTIC STRIPED BASS INTERSTATE MANAGEMENT PLAN FOR PUBLIC COMMENT

Stripers Forever is a not for profit organization that advocates for the conservation and responsible stewardship of striped bass.

Stripers Forever (SF) believes that the Atlantic States Marine Fisheries Commission (ASMFC) has given too much consideration to reducing potential social and economic impacts on the commercial striped bass fishery, and too little on managing the striped bass fishery as a public resource for the greatest user of this resource, the recreational angling community and the industry it supports. The signs of diminishing abundance have been ignored for years and have finally resulted in yet another attempt to follow the failed policies of the past instead of actually doing something proactive to improve fish abundance. The draft addendum for public comment at best proposes measures that fit the “too little, too late” model that has plunged this resource toward pre-moratorium abundances and now proposes measures that have a 50% probability of failure.

We believe that ASMFC should take as large a bite out of this apple as it can and we support the following options:

Proposed Fishing Mortality Reference Points (2.5.1) While the Technical Committee has been candid in their assessment of risks associated with the proposed new reference points, managing under the old reference points (Option A) has failed to stabilize SSB. We support the 2013 Benchmark Stock Assessment F Reference Points (Option B) for both coastwide and Chesapeake Bay fisheries because they represent the most

conservative approach to the problem.

Proposed Fishing Mortality Reference Points (2.5.2) We support Option B since the Technical Committee does not have the needed information to set up separate reference points for separate Chesapeake Bay management.

Albemarle Sound Reference Points (2.5.3)  We have no comment on this question.

Timeline to Reduce F to the Target (2.6). Since the one year time frame represents the most aggressive approach to reaching the stated goals, we support Option A.

Proposed Management Scenarios (3.0). It seems redundant and confusing to select Option A under section 2.6 and then to have to select Option B in this section to support taking the largest possible reduction (25% of the 2013 harvest) in one year. We support Option B.

Proposed Recreational Fishery Management Options, Coastal Recreational Fishery.

Stripers Forever supports option B1 which is a one fish bag limit with a minimum size of 28-inches.  We would prefer to see an option for a 28-34” slot but with a total bag limit of one fish, but it is not offered.

Proposed Recreational Fishery Management Options, Chesapeake Bay.

Since the objective is to increase the SSB, it doesn’t make sense to kill the largest, most productive spawners we already have while we wait for the 2011 year class to provide a greater number of smaller fish to make up for trophy fishing. Option B12 would effectively end the spring trophy season where the Bay jurisdictions get to kill large spawners that don’t count toward their coastwide quota. We support Option B12.

Proposed Commercial Fishery Management Options. The statement, “It is important to note none of the management options presented in the tables achieve a 25%

reduction from 2013 harvest” reveals an apparent inconsistency regarding the commitment to treat all stakeholders equitably. For the Coastal Commercial Fishery, it appears that Option B16 (taking a reduction of 25% from the Amendment 6 quota) is the only choice provided. It isn’t clear why this fishery isn’t held to the 2013 harvest baseline like the others.

The consideration of alternate options for the Chesapeake Bay Management Area Commercial Fishery seems unwarranted. The Bay jurisdictions claim they had a lower quota in 2013 so they would like to have their cut come from the 2012 harvest. Missing from this discussion was the fact that the Bay jurisdictions increased their quota (and probably harvest) for 2014 when the exploitable biomass increased due to the 2011 year class reaching 18” in length. We support Option B17 to take the 25% from the 2013 commercial quota. The Bay commercial fishermen have already been repaid for whatever happened in 2013.

SB is opposed to commercial quota transfers. If a state can’t catch their quota, it may be because they don’t have enough fish. It doesn’t make sense to transfer that quota to another state that does have fish and maintain the coastwide harvest to help ensure that more states won’t have enough fish next year. We support Option A – no commercial quota transfers.

All stakeholders should be fishing on the same size limits. We support Option A to constrain the commercial fishery in each jurisdiction by the same size limits established for that jurisdiction’s recreational fishery.

Compliance Schedule (4.0).  The schedule has been compressed by the protracted debate over Chesapeake Bay reference points but the end point seems firm – no later than January 1, 2015, as it should be.

Sincerely;

Ken Hastings

Atlantic States Marine Fishery Commission Policy Coordinator for Stripers Forever

——————————————————————————

Send written comments to :

Mail: Mike Waine, Fishery Management Plan Coordinator

Atlantic States Marine Fisheries Commission (Subject: Draft Addendum IV)

1050 North Highland Street Suite 200A-N

Arlington, VA 22201

Phone: (703) 842-0740

Fax: (703) 842-0741

Email: mwaine@asmfc.org; (Subject: Draft Addendum IV)

Category: Featured, News Updates · Tags:

CONTACT INFO

Stripers Forever
57 Boston Rd
Newbury, MA 01951
stripers@stripersforever.org

close
Facebook IconTwitter IconVisit Us On Instagram