Striped Bass Public Comments are in: Here’s What They Say

Tony Friedrich, Vice President/Policy Director

We would like to thank everyone for submitting their comments on the Public Information Document (PID) for Amendment 7 to the Striped Bass Fishery Management Plan (for a refresher on the process and our priorities, click here). The staff at ASMFC did a great job of breaking down all the comments as well as communicating the outcomes of the process. It would be an understatement to say that conservation won in a landslide.

Let’s take a look at feedback on some of the key issues.

A total of 3063 comments were received. 2397 came from form letters. 616 individual comments came in as well as comments from 50 different organizations.

Issue 1: Goals and Objectives

There were a total of 1672 comments on this issue. Only 22 of those suggested changing the Goals and Objectives. A total of 295 comments wanted the species managed for abundance. There was also little interest in regulatory consistency vs. stability/flexibility not overriding a goal. Only 43 comments came in for flexibility while 1292 came in for consistent coastwide regulations. The flexibility message does not resonate with the public. The overwhelming majority of anglers don’t want some perceived notion of flexibility that can override a management goal. It was also interesting to note that many anglers commented on the timing of the amendment:

“Regarding the timing of Amendment 7, some commenters noted concern about developing a new amendment before a rebuilding plan is put in place to address the overfished stock and before there is information available on the effectiveness of Addendum VI measures put in place to reduce fishing mortality.”

Issue 2: Reference Points

There are some unhappy folks sitting in their offices today. A few key members of the Atlantic States Marine Fisheries Commission’s Striped Bass Board initiated this amendment in the hopes that they could lower the reference points in order to continue unsustainable harvest. Their plan failed and now resembles something akin to a dumpster fire. This is a devastating blow to the forces of darkness. It is one that will most likely tank their efforts to deny the rest of the coast a healthy stock of striped bass.

This issue received the most comments. There was a total of 2678 written comments regarding changing the BRPs, and 2668—99.6%—of those recommended maintaining 1995 as the base year. Furthermore, many of the comments suggested removing BRPs from the amendment altogether. 100% of the form letters rejected changing BRPs. Never in my life have I seen 100% agreement on any fisheries issue.

Issues 3-4: Management Triggers and Rebuilding Timelines

There was not a single comment against conservation on these two issues. 209 comments wanted no change in the five management triggers, while 185 wanted the triggers adjusted to react more quickly and more specifically. Every single comment regarding the rebuilding timeline wanted 10 years or less. Think about that for a second. Every person who commented wants the stock rebuilt promptly, and many believe that this should be the focus of the Striped Bass Management Board:

“A majority of comments support maintaining the 10-year rebuilding timeline with a few comments supporting a faster rebuilding timeline. Many comments noted concern there is not yet a rebuilding plan in place to address the current overfished status of the stock. Commenters noted the Board should adhere to this rebuilding requirement as specified in Amendment 6 and should act quickly to implement a rebuilding plan to address the overfished status tock by 2029 (10 years after the last benchmark stock assessment results were adopted for management use). Many commenters expressed a need for urgency to implement a rebuilding plan and take action in response to triggers more quickly.”

Issue 5 Regional Management

ASGA supports science. There is currently no science that supports regional management. This was another attempt by the producer areas to carve out a separate management system that would help them continue to overharvest. You can see these results in the public hearings. Of the 14 comments supporting regional management at public hearings, 6 were from VA and the remaining were from NY, NJ, MD, and PRFC—all producer areas. There wasn’t a single individual in the remaining public hearings that spoke for this issue. Most comments said that this is a migratory stock that needs consistent coastwide management. Only a little over 5% of the comments supported regional management:

“A majority of commenters do not support pursuing regional management measures at this time either because the science (i.e., the two-stock assessment model) is not yet available or because they are opposed to regional management in general. Those opposed to regional management noted that striped bass as a migratory fish should be managed as one unit along the coast. Some comments also expressed concern about making the shift to regional management at a time when the stock is in poor condition. Many comments specifically stated this issue should be removed from consideration for Draft Amendment 7.”

Issue 6: Conservation Equivalency (CE)

By now, everyone knows that CE is being used for nefarious purposes. ASGA has been banging this drum since the first day we started. It is difficult to explain to the angling public what CE is and why it is bad. The bad guys were counting on this and hoping that the public wouldn’t understand the issue enough to comment. They failed yet again.

All told, there were 3758 comments on CE. Of that, a measly 1.22% said the use of CE should remain status-quo. 1527 said is should not be used while overfishing is occurring. 1463 said that if it is used, the states employing CE must be held accountable. 612 comments stated it should be eliminated completely. If that isn’t consensus, then I don’t know what is.

Conclusions

Thank you all for commenting. That needs to be said. Be proud of yourselves for taking the time to send in your thoughts. There has never been this level of consensus on a fisheries issue. Never, not even close and not by a long shot…

Let’s review some of the top-level numbers.

1.31% of comments wanted to alter the Goals and Objectives.

0.651% wanted to change the BRPs.

5.7% wanted regional management.

1.22% wanted Conservation Equivalency to remain unchanged in the fisheries management plan.

So, here we sit. We will hear many things at the meeting on May 5th that will attempt to discredit our efforts. We will hear that people couldn’t comment or didn’t know how to use Zoom. We will hear that the document was too complicated. We will hear just about every single excuse you can imagine.

Guess what? The conservation community faced all the same hurdles. The one exception is that individuals weren’t taunted and intimidated at in-person public hearings. No one was in the room yelling and screaming at people trying to participate in a public process. Yes, that probably worked in our favor.

Here is our message to the Striped Bass Board. Much unlike the PID, it is simple and straightforward. The striped bass world is watching. Don’t let a few members of this Board derail striped bass recovery. Take a stand and do what is right for this resource.