October 7, 2019
Via email only to: firstname.lastname@example.org
Dear Mr. Appelman,
Thank you for the opportunity to comment on Addendum 6 to the Atlantic States Marine Fisheries Commission’s Striped Bass Fishery Management Plan. The Coastal Conservation Association(CCA) is the largest marine resource conservation organization of its kind in the nation, with more than 130,000 members in state chapters on all three coasts. As a state chapter with a long history of focusing on multiple Chesapeake Bay fisheries, CCA Maryland has a keen interest in ensuring the health and abundance of striped bass stocks.
As the state fish of Maryland and held in high regard throughout the coast, striped bass are an iconic species for legions of saltwater recreational fishermen here on the Bay, and up and down the Atlantic coast. The fishery is conducted 12 months of the year as they migrate along the most heavily populated coastline in the country, with the waters of the Exclusive Economic Zone acting as a refuge for the breeding population. Given this large and complex range of the fishery, it is a remarkable achievement that the ASMFC’s management of this fishery has maintained the striped bass population as well as it has since the recovery in 1995.
Under proper conservation measures for both size and bag limits, fishing for the decade after the recovery was exceptional, seemingly everywhere from Maine in the summer to North Carolina in the winter. This period was also marked by a period of above-average recruitment. Predictably, however, recruitment went through a below-average period and the population started to decline. In hindsight, the ASMFC should have acted to reduce the fishing mortality during the low recruitment period to slow that decline. The Striped Bass Technical Committee advised the Board that spawning stock biomass (SSB) was declining and that unless recruitment changed, the stock would become overfished. The SSB declined below the target level in 2012 and finally declined below the threshold in the 2018 stock assessment report.
The Striped Bass Management Board of the ASMFC should be applauded for acting to end overfishing as soon as they received this stock status last year. However, given the importance of striped bass to the Atlantic recreational fishery, and the inherent critical importance of abundance to the recreational fishery, the ASMFC should have heeded their Technical Committee’s advice and stopped the steady slide of SSB. As we have argued since the inception of Amendment 6, fishing mortality was too high for the stock to remain abundant and indeed the population has declined to the great concern of the angling community. A reduction in fishing mortality, greater than the currently proposed 18 percent, would pay dividends for the future abundance of striped bass and help guard against the inevitable downward variations in recruitment success in the future.
With regard to the options that are available in Addendum 6 CCA Maryland offers the following comments:
CCA Maryland supports Option 2 – Equal percent reductions for all sectors
- All sectors should take equal percent reductions as a matter of fairness.
- By reducing removals at an even percentage (18%), this option decreases recreational catch at a much higher volume, which is the correct action given the proportion of coast-wide removals that the recreational sector accounts for.
- This option reduces the commercial catch at the same percentage (18%), but at much a lower volume given the smaller proportion of coast-wide catch by the commercial sector
- Because each state may have a different balance of recreational and commercial catch over time, this option presents the most straight forward approach to reducing removals in each state without reallocating overall catch from one sector to another.
CCA Maryland strongly opposes Option 3 – The Commercial Sector Takes a Smaller Percent Reduction
- Option 3 reflects a reallocation of allowed harvest between sectors based on the estimated proportion of coast-wide catch that occurred in a single year.
- Option 3 allows for a potential increase in catch for the commercial sector in Maryland which primarily operates in the largest and most valuable nursery for striped bass.
- Any re-allocation should consider multiple factors which recognize the many differences between recreational and commercial fishing, and include a thorough process which clearly defines reallocation as a goal, not to use an action which requires a reduction in removals based on one year as an opportunity to change the allocation between sectors.
CCA Maryland supports the use of Conservation Equivalency(CE) as a valuable management tool that can be used to provide a balance of conservation and angler access, and give states an opportunity to use regionally specific data to make the best decisions possible for fishery participants and the resource in a specific state or region. CE plans are an important part of managing the striped bass fishery in Maryland’s portion of the Chesapeake Bay. CCA Maryland believes:
- CE proposals should be crafted to improve the likelihood that any measure approved on paper, as part of a management plan, will meet the necessary goals of such plans on the water.
- CE plans should not be used as a way to benefit one stakeholder group or sector over another within a specific state, or to wildly shift plans from one year to another, therefore increasing uncertainty in the impacts that management changes may have.
Circle Hooks & Discard Mortality
- CCA Maryland supports the mandatory use of circle hooks when using natural bait as a matter of principle.
- We encourage all states to develop monitoring programs so that the conservation gains realized by the use of circle hooks translate into lower discard mortality and greater abundance.
- We stand committed to working with managers and state leaders to continue to promote sound handling techniques, and studies necessary to ensure that recreational anglers participate in fisheries in a responsible manner, and by the letter of the law.
- We support and encourage future efforts to clearly communicate best practices for angling and fish handling to ensure that the assumed coast-wide and year-long survival rate of recreational live releases of 91% is maintained, or improved upon.
- We look forward to working with Maryland DNR and other stakeholders in the region on future efforts to better understand, and limit discard mortality for all sectors in the striped bass fishery.
CCA Maryland respectfully recognizes the challenges that come with any action to reduce fishing mortality, and the challenges inherent with managing any fishery. We stand committed to working within the spirit of the multi state/federal partnership which has worked to conserve and manage Atlantic coast fisheries for 78 years.
Thank you again for the opportunity to provide input on Draft Addendum VI, and the Striped Bass Management Board’s efforts to fairly and equitably return the striped bass fishing mortality to target levels, and begin rebuilding the stock to higher levels of abundance for the benefit of all.
Frank Bonanno David Sikorski
Chairman Executive Director