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

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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)