Striped Bass Amendment 7: Public Comment Guide

 

Get Involved: Public Comment Deadline is April 15, 2022

By Tony Friedrich

Vice President/Policy Director

This blog will detail everything you need to know about commenting on draft Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass. We cannot emphasize enough that this your last chance and biggest opportunity to make a difference. Look to the recent victories in the Pebble Mine, the Boundary Waters, and Captains for Clean Water/Everglades Restoration. The conservation-minded public spoke and overwhelmed the opposition. You must do that now.

There isn’t a way to make it easier. We can only try our best to distill the information in an honest way to get all of you to comment. If we don’t include everything, we aren’t doing any favors to striped bass. However, if you only comment on a single issue, then please focus on 4.6.2 Management Program Equivalency, better known as Conservation Equivalency (CE).

We have several podcasts detailing the four major topics. Episodes 35 through 38 focus on Amendment 7. Please listen to these for more clarity.

The state-by-state public hearing schedule can be found here, which includes a mix of in-person and virtual events. We posted the most up to date schedule below. Some of these meetings have changed from virtual to in person. Check the link for the most up to date information. If something changes, we will do our best to make you aware. If you can’t attend a hearing, the public comment period ends on April 15, 2022. Individual emails are what counts the most. Form letters count the least. Send your comment to comments@asmfc.org with the subject line “Draft Amendment 7.” We will be running a raffle again this time. There will be awesome prizes from our best sponsors. Just copy stripercomments@gmail.com in your email to ASMFC and you are entered. It does not matter if you agree with our positions or not. We just want folks to participate in this process.

ASGA has also produced an infographic detailing our positions for easy distribution. It can be found here. We have between now and April 15 to do everything in our power to recover striped bass. It will take all of you, but it can be done. Let’s all pull together and restore striped bass.

Below are the formal positions of the American Saltwater Guides Association on each of the four options in the draft amendment:

4.1 Management Triggers

Tier 1: Fishing Mortality (F) Triggers

Option A: Timeline to Reduce F to the Target

ASGA Supports Sub-option A1 (status quo): Reduce F to a level that is at or below the target within one year.

Option B: F Threshold Triggers

ASGA Supports Sub-option B1 (status quo): If F exceeds the F threshold, the striped bass management program must be adjusted to reduce F to a level that is at or below the target within the timeframe selected under Option A.

Option C: F Target Triggers

ASGA Supports Sub-option C1 (status quo): If F exceeds the F target for two consecutive years and female SSB falls below the SSB target in either of those years, the striped bass management program must be adjusted to reduce F to a level that is at or below the target within the timeframe selected under sub-option A.

Tier 2: Spawning Stock Biomass (SSB) Triggers

Option A: Deadline to Implement a Rebuilding Plan

ASGA Supports Sub-option A2: Two-Year Deadline to Implement a Rebuilding Plan. The Board must implement a rebuilding plan within two years from when an SSB-based management trigger is tripped.

Option B: SSB Threshold Trigger

ASGA Supports Sub-option B1 (status quo): If female SSB falls below the SSB threshold, the striped bass management program must be adjusted to rebuild the biomass to the target level within an established timeframe [not to exceed 10-years].

Option C: SSB Target Trigger

ASGA Supports Sub-option C1 (status quo): If female SSB falls below the target for two consecutive years and the fishing mortality rate exceeds the target in either of those years, the striped bass management program must be adjusted to rebuild the biomass to a level that is at or above the target within an established timeframe [not to exceed 10-years].

Tier 3: Recruitment Triggers

Option A: Recruitment Trigger Definition

ASGA Supports Sub-option A2: The recruitment trigger is tripped when any of the four Juvenile Abundance Indices (JAIs) used in the stock assessment model to estimate recruitment (NY, NJ, MD, VA)11 shows an index value that is below 75% of all values (i.e., below the 25th percentile) in the respective JAI from 1992-2006, which represents a period of high recruitment, for three consecutive years.

Option B: Management Response to Recruitment Trigger

ASGA Supports Sub-option B2. If the recruitment trigger is tripped, an interim F target calculated using the low recruitment assumption is implemented, and if F from the terminal year of the most recent stock assessment is above the interim F target, the striped bass management program must be adjusted to reduce F to the interim F target within one year.

Tier 4: Deferred Management Action

ASGA Supports Option A (status quo): No Deferred Management Action.

If any (or all) of the management triggers are tripped following a benchmark stock assessment or assessment update, the Board is required to respond to that trigger regardless of when the last management action was implemented in response to any management trigger.

4.2.2 Measures to Address Recreational Release Mortality

Option C. Additional Gear Restrictions

ASGA Supports Sub-option C1: Recreational anglers would be prohibited from using any device other than a nonlethal device to remove a striped bass from the water or assist in the releasing of a striped bass.

ASGA Supports Sub-option C2: Striped bass caught on any unapproved method of take would be returned to the water immediately without unnecessary injury.

Option D. Outreach and Education

ASGA Supports Sub-option D2: It is recommended states continue to promote best striped bass handling and release practices by developing public education and outreach campaigns. States should provide updates on public education and outreach efforts in annual state compliance reports. Best practices could include those listed in sub-option D1.

4.4 Rebuilding Plan

4.4.1 Recruitment Assumption for Rebuilding Calculation

ASGA Supports Option B: Rebuild female SSB to the SSB target level by no later than 2029. F rebuild is calculated to achieve the SSB target by no later than 2029 using the low recruitment regime assumption as identified by the change point analysis.

4.4.2 Rebuilding Plan Framework

ASGA Supports Option B: If the 2022 stock assessment results indicate the Amendment 7 measures have less than a 50% probability of rebuilding the stock by 2029 (as calculated using the recruitment assumption specified in Amendment 7) and if the stock assessment indicates at least a 5% reduction in removals is needed to achieve F rebuild, the Board may adjust measures to achieve F rebuild via Board action.

4.6.2 Management Program Equivalency (Conservation Equivalency)

Option B. Restrict the Use of Conservation Equivalency (CE) Based on Stock Status

ASGA Supports Sub-option B1-a: CE programs would not be approved when the stock is at or below the biomass threshold (i.e., overfished). CE programs would not be considered until a subsequent stock assessment indicates stock biomass is above the threshold level.

Option C. Precision Standards for MRIP Estimates Used in Conservation Equivalency Proposals

ASGA Supports Sub-option C3: CE proposals would not be able to use Marine Recreational Information Program (MRIP) estimates associated with a percent standard error (PSE) exceeding 30%.

Option D. Conservation Equivalency Uncertainty Buffer for Non-Quota Managed Fisheries

ASGA Supports Sub-option D2: Proposed CE programs for non-quota managed fisheries would be required to include an uncertainty buffer of 25%.

Option E. Definition of Equivalency for CE Proposals with Non-Quota Managed Fisheries

ASGA Supports Sub-option E2: the percent reduction/liberalization projected for the FMP standard at the state-specific level.

There it is! Please be on the lookout for a follow-up blog in the next twenty-four hours that explains our rationale for each of these positions. Thanks for reading!