Striped Bass Addendum II – Public Comment Guide

Feature Photo: Luyen Chou, Founder of the GotOne App

WRITTEN COMMENT DEADLINE: FRIDAY, DECEMBER 22, 2023
SUBMIT EMAILS TO COMMENTS@ASMFC.ORG
SUBJECT LINE: “STRIPED BASS DRAFT ADDENDUM II“

After a brief break from the politics of fish and a full season chasing epic bites, the time to don our advocacy hats and protect our saltwater resources has returned. ASMFC just released the final version of Draft Addendum II for Striped Bass for public comment. The goal of this document is to reduce fishing mortality by adjusting recreational measures and commercial quotas in the ocean and Chesapeake Bay regions. While we strongly supported the initiation of Addendum II, we believe that the potential outcomes of this action are not enough to ensure long-term striped bass sustainability and abundance. These measures may only be in effect for the 2024 fishing year, assuming a 2024 stock assessment warrants another management action. Five consecutive years of poor spawns out of the Chesapeake Bay should be on everyone’s minds as we consider Draft Addendum II and the future of this fishery. 

After the Striped Bass Board approved this document at the ASMFC Annual Meeting, ASGA began reviewing notes, talking with partners up and down the coast, and drafting positions for Draft Addendum II. In the coming weeks, ASMFC will be holding virtual and in-person hearings from New England down through Virginia to collect public comment on this document. The deadline for public input is December 22^nd, 2023, so be sure to look into the options within Draft Addendum II and share your perspectives before the clock runs out. The following provides a summary of our positions and a template to guide your public comments.

Draft Addendum II—How to Comment

• ASMFC Draft Addendum II Web Page
• Meeting Schedule: Remember, you can attend any of the virtual or in-person meetings, regardless of where you actually reside.
• November 15^th, New Jersey, virtual.
• November 16^th, Connecticut, in-person.
• November 28^th, Delaware, hybrid.
• November 30^th, Rhode Island, hyrbid.
• November 30^th, Connecticut, in-person.
• December 4^th, New York, in-person.
• December 5th, New Jersey, in-person.
• December 5^th, Massachusetts, in-person.
• December 6^th, Maryland, in-person.
• December 7^th, Virginia, in person/listen only live stream. 
• December 11^th, New Hampshire, hybrid.
• December 12^th, Potomac River and DC, virtual.
• December 14^th, Maine, hybrid.
• December 18^th, New York, in-person.
• December 19th, Massachusetts, in-person. 

Public Comment Guide on The Guide Post Podcast – Listen in Audio Format

ASGA Draft Addendum II Positions

3.1.1 Ocean Recreational Options: Option B—1-fish at 28-31″ with 2022 seasons (all modes).

• Let’s face it, recreational anglers harvested way too many fish in 2022, as the strong 2015 year-class recruited into the then 28-35” slot limit. ASGA supported the Emergency Action measure, and we still do. It is critical that managers continue efforts to protect the 2015 year-class and maintaining the 28-31” slot achieves that goal, while providing some consistency for anglers and the stock assessment scientists. 

• We do not support mode splits. The Recreational sector (private and charter/for-hire) should continue to be managed under the same regulations. 

• These measures will likely only be in place for just next year; the 2024 Striped Bass Stock Assessment Update is scheduled for late-2024, and another management action is probable. In other words, there is a good chance that the assessment shows us that additional actions will be required in order to successfully rebuild striped bass SSB by the 2029 deadline.

3.1.2 Chesapeake Bay Recreational Options: Option B1—1 fish at 19-23” across all CBAY jurisdictions with the same 2022 seasons. 

• After five consecutive years of poor spawning success, the Chesapeake Bay region is in desperate need for conservation and precautionary fisheries management. ASGA supports Option B1 for many of the same reasons applicable to the ocean, but now the Bay’s recreational fisheries need to contribute to conservation. If the Ocean fishery can have a 3” slot, then the Chesapeake can deal with a 4” slot. 

• Mode splits in the Bay should be fiercely opposed. Through previous conservation equivalency proposals, Maryland implemented a program to allow Charter/For-Hire passengers the ability to harvest two striped bass compared to one fish for the rest of the recreational sector. Maryland’s Chesapeake Bay for-hire fleet harvested 142,098 stripers; the coastwide total for the for-hire fleet was 281,289 fish. By giving Maryland’s charter fleet two fish, they harvested more than the rest of the Bay and the ocean combined. This is what happens when a state agency picks favorites.  

• Option B1 would place all of the Chesapeake’s jurisdictions under the same size and creel limit, achieving far greater consistency across the region. 

• Also, the 23” max will add a layer of protection for the average 2017- and 2018-year classes which will still have some presence in the bay. The current maximum size in MD would still allow harvest of these valuable fish. The proposed 19-23” slot would avoid these fish. 

3.2.1 Commercial Quota Reduction Options: Option B with a 14.5% reduction to both the Ocean and Chesapeake Bay Quotas.

• Before we go any further, understand that this option may be entirely meaningless—unless states take matters into their own hands. For one, due to quota underutilization, a reduction in quota does not guarantee an actual reduction in fishing mortality—the ocean region has been using most of its quota in recent years and will see a reduction in fishing mortality; the Chesapeake Bay will not see much of any reduction with a 14.5% quota cut. Second, there are huge question marks around when states would even implement these changes. Doesn’t it seem disingenuous when certain states wait until the last minute to claim that implementing these commercial changes in 2024 would not be possible? We have a hard time buying this. Yes, commercial landings accounting is far more robust than in the recreational sector. But, if Maryland really wanted to take part in meaningful conservation, they would work through the challenges and issue new tags and IFQs for 2024. Don’t hold your breath.  

• Another piece of context is to distinguish the Ocean and Chesapeake commercial fisheries, because in general, ASGA is not opposed to commercial fishing. The Ocean commercial fishery has taken all the reductions placed on the recreational sector, with the Emergency Action being the only outlier.  

• The Chesapeake Bay has not taken a meaningful reduction since 2015. The Chesapeake commercial quota has taken a whopping 1.8% reduction (see below).

• Since 2020, Chesapeake Bay quota utilization hovered around 80%. This is concerning on multiple fronts: there are clearly not enough fish in the system AND quota reductions less than 20% will have zero impact. 

• The 14.5% reduction is off the quota, not landings (the amount of fish harvested commercially). That means once again the Chesapeake Bay commercial fishery will not do their part to restore striped bass, as landings could be the same as last year.  

• ASGA is supporting Option B with a 14.5% reduction to both fisheries. 

• Do we think the Bay’s cut should be greater or specifically target landings? Of course we do, but that is not an option in this document. Remember, to be an effective advocate you need to support options that are being considered. 

• We will be reaching out to each state to determine whether they can implement these commercial management changes in 2024. 

3.3 Response to Stock Assessment: Option B—Board Action. 

• Remember, the above options will likely only be effective for 2024 (and if at all on the commercial side), so this option may have the greatest impact on striped bass management. Next fall (likely at the 2024 Annual ASMFC Meeting), the Striped Bass Board will see the results of a new stock assessment update. We won’t speculate much other than by saying this string of poor recruitment is going to have a significant impact on the rebuilding projections, and additional management changes are needed to improve the odds of rebuilding by 2029. This option would allow the Board to move quickly to implement those new management measures through a simple majority. Without the Board action provision, the management process could take up to a year to respond. 

• Public input, while not formalized through a management action, is not precluded by this option. ASGA regularly communicates with SB Board Members to share our perspectives on management. You can too. Get to know your respective Board Member, ask them questions, share with them how you want this fishery to look like in 12 years. It is Important. In this day and age, public involvement is as easy as ever. 

There you have it. The ASGA team thoughtfully considered every dynamic possible when examining options for Addendum II. Our final positions reflect our grave concern for this fishery and a strong desire to do what is needed in the short-term in order to have an abundant stock and sustainable fisheries in the long-term.

Stay tuned for podcasts, more infographics and future information on social media channels about Draft Addendum II. Also, be sure to check the public hearing schedule and pick out a hearing that best fits your schedule. Finally, if you have any questions about this document or process, please reach out. You can direct message us any time on social media or email info@saltwaterguidesassociation.org. Who knows – we may just answer your question on a podcast and award you with a brand new pair of Costa Sunglasses.