Striped bass have been and continue to be a major focal point for us at Tightlined, and the recent finalization of Amendment 7 marked an important step forward in how the species is managed moving forward. With overwhelming public comment and strong efforts from the industry and other conservation groups, the resulting Amendment that was finalized represented a step forward in regulations that we believe improve chances for the stock to stabilize and recover. There is still a long way to go, and an addendum process and specific regulation changes are likely to be implemented as soon as this fall when the new striped bass stock assessment is released, however we are thankful for the public comment and results we got from the ASMFC this time around.
To read more about the process and the results, please check out the American Saltwater Guides Association’s write-up from May, 2022.
https://saltwaterguidesassociation.com/striped-bass-amendment-7-finalized/
Our Amendment 7 Public Comment Letter to the AMSFC
Our Amendment 7 Public Information Document Letter to the AMSFC
The Public Information Document (PID)
The initial step in the Amendment 7 process is for the ASMFC to take input from the public to the PID. This document outlines items that could be included in the final Amendment 7, which will determine the manner in which Striped Bass are managed moving forward. Accordingly, providing feedback on what is included in the PID, and therefor what may be included in Amendment 7, is critical in making sure the right topics are discussed and considered by the AMSFC moving forward.
To give more color on what is included in the PID, the entirety of which may be found here, the American Saltwater Guides Associate posted a Guide to the PID and their views on what should and should not be included in the Amendment language. We have also included a link below to the ASGA’s most recent podcast, which highlights how important it is to focus any comments during hearings and in letters or calls to the ASMFC on what is outlined in the PID and the two pager below. It’s pretty quick, but very informative, so please take a listen.
Submitting Comments / PID State Hearings
The ASMFC has scheduled state hearings to discuss the PID and receive feedback from anglers and constituents up and down the coast. The schedule is pasted here. Please register for your (or other) state's meeting here and speak up for striped bass.
PLEASE, when submitting comments, keep them focused on the items outlined above, and not on alternative ideas or other thoughts about striped bass. They are all important, however given how this process is laid out and where we stand in it, we need to make sure that comments are as effective as possible, enabling us to shape the information included in the Amendment itself.
In addition to state hearings, the AMSFC is receiving comments on the PID from stakeholders until 5 PM (EST) on April 9, 2021. We urge you to write a letter to the ASMFC ahead of April 9, 2021 and send to Emilie Franke, Fishery Management Plan Coordinator, 1050 N. Highland St, Suite 200A-N, Arlington, VA 22201; 703.842.0741 (FAX) or at comments@asmfc.org (Subject line: Striped Bass PID).
PID State Hearing recaps
Connecticut - March 23
Yikes… I might be taking this a bit harder than I should because I’m proud to have grown up and fished in Connecticut my entire life, but tonight’s hearing did not go the way I expected / hoped it would. While once again, the majority of comments supported conservative management and rebuilding and maintaining a healthy population, there were more pro-harvest comments than we had heard at other hearings.
We are not against harvest, and understand and recognize the need and desire to keep striped bass and other fish. That said, we are staunchly pro-science, and believe that management of striped bass should be based on the best available science and designed to maintain healthy and abundant stocks, and not for maximum harvest. The concerns I had with several comments from the Connecticut hearing had to do with pushback on current science, ranging from studies around release mortality and the efficacy of circle hooks to the stock assessment being from 2018 being biased.
The science isn’t perfect by any means, and there are ways that things can improve (better recreational reporting, more frequent stock assessments, updated studies on catch and release mortality, education around proper fish handling and catch & release, to name a few things), but it’s important that we support the science and use it to make informed decisions to rebuild the stock and manage it for abundance moving forward. Unfortunately, the science paints a pretty bleak picture for striped bass at the moment - an overfished stock with an unbalanced age breakdown. There aren’t many good classes coming to save the species, and the stronger classes we do have are now entering the slot right at the time they begin to spawn.
With all this in mind, we come back the points we’ve heard from the majority of comments - including the majority of comments tonight - that a rebuilding plan needs to be implemented, and implemented yesterday, that the reference points need to stay where they are and the goal posts cannot be lowered, that conservation equivalency should not be allowed until the stock is rebuilt, and even then, it should only be allowed with strict accountability measures associated with it.
Tomorrow is the last state hearing - New Jersey. After that, we have until April 9 to submit comments to the ASMFC about what we want to see in the Amendment document. Please take the time to write a letter or call / email your commissioners (links above) to voice your thoughts on this process and the management of the species.
New York - March 22
New York is a key state when it comes to how votes go coast-wide, and the comments we heard at tonights PID hearing were encouraging.
Nearly every comment supported more conservative management, but beyond that, they were largely focused and targeted on the specific aspects of the PID. The key takeaways we heard were that this is not the time for biological reference points to be changed, and that we can get back to the ‘95 target levels. Participants were against Conservation Equivalency without accountability or while the stock is overfished, recognizing the impact that accepted CE proposals in certain states have had on the stock stock. As for recreational release mortality, which continues to be brought up time and time again, educating the public on proper catch and release tactics continues to be the most recommended path forward, however barbless or single hook requirements were also mentioned.
Once again, there was tangible frustration with the way the ASMFC has managed striped bass, and commenters were not shy to point it out during the Q&A and comments section. There is a real need for accountability here, not only in terms of striped bass mortality, but also from the ASMFC to heed to their own bylaws. The lack of a viable rebuilding plan despite the trigger of stripers being overfished being tripped during the 2018 stock assessment was brought up multiple times, with no adequate response from the ASMFC to those questions and comments. To recap, the ASMFC is required to initiate a plan to rebuild striped bass within 10 years of the stock being declared overfished. We are now almost three years into the that 10-year window and nothing has been put in place.
Judging from the hearings over the past week, it feels like there is a lot of momentum building for stronger management and a more conservative approach to the striped bass management plan. With that in mind, following up on these public hearings with written commentary and/or individual outreach and conversations with commissioners will be needed to reinforce what people have said. Please, after making comments and listening into these public hearings, look up your state commissioners here and reach out to them directly.
Hopefully we can build on this momentum through today’s CT hearing and maintain the sentiment through the last hearing, New Jersey, on Thursday.
Maryland - March 22
Another PID hearing pushing 100 people, and I have to say that this one was a pleasant surprise. There are a few states that have gained reputations for being problem states when it comes to striped bass conservation, and Maryland is at the top of that list. Tonight, however, the commentary from participants (there were nearly 100 at one point or another) was strongly conservation-focused.
Comments focused on the importance of doing more to help rebuild the stock - as the ASMFC is required to do - and to maintain the SSB threshold / target. There were calls for legitimate accountability for any state that uses Conservation Equivalency, and calls to get rid of Conservation Equivalency all-together - especially while the stock is overfished. Anglers from Maryland understood the responsibility the state has, as the birthplace of the majority of striped bass on the coast, to take care of the fishery.
Like in previous hearings, there was real frustration towards the ASMFC and the way striped bass have been managed, and it sounded like the commissioners from MD heard and felt that frustration. This was an encouraging discussion, but there are a lot of Maryland anglers and constituents who did not speak up today, but will offline, who feel differently than the voices that were heard on tonight’s call. For those who attended, and for those who did not, PLEASE follow-up and build off tonight’s comments by sending in written comments or arranging a one-on-one call with your commissioners to make sure they know what needs to be done to protect striped bass.
After listening to a number of these now, we wanted to comment quickly on the presentation and Q&A portion of these PID hearings. The information in the presentation at the beginning of each hearing does not match up directly with what is in the PID, and the questions that are posed in that presentation can, understandably, lead participants to focus on topics that are not in the PID, and therefor not relevant for where we are in the process with the ASMFC. It is important to review the PID itself (and the ASGA document, which breaks down the points clearly) ahead of making any commentary, to make sure you are speaking out on the points at hand, and not points and ideas that will not move the needle with Commissioners heading into the drafting of Amendment 7.
Massachusetts - March 18
There was great turnout to the Mass public hearing, with nearly 150 participants at one point, and well north of 100 for the entire 2 hours and 20 minutes of commentary. During that time, we didn’t hear any support for increased harvest or for the lowering of the SSB thresholds and targets, but instead universal support for more conservative management and a focus on managing towards abundance - with strong and vocal support for a 10-year moratorium (which is not going to happen).
There were two main takeaways that we heard from this hearing. First, this is the wrong time to take the time needed to implement a comprehensive review and restructuring of striped bass management. What we know right now comes from the 2018 stock assessment that determined striped bass are overfished and overfishing is occurring. As a result, the ASMFC implemented new regulations (what we believe was an ill-advised slot limit with likely detrimental CE proposals from a number of states) that were intended to end overfishing from occurring. With that in mind, there was no rebuilding plan put in place, despite the fact that when the tripwires that were tripped with that stock assessment are tripped, the AMSFC is required, under its own bylaws, to implement a plan to rebuild the stock within ten years. Two years later, we still have no rebuilding plan, and the data collection that fishery managers rely on to determine effectiveness of regulations was prevented due to the pandemic last year.
So where do we stand today? As far as we know, exactly where we stood a year ago before the new regulations went in place, and potentially in a worse place. Importantly, we don’t have a rebuilding plan in place either. Instead of focusing on quickly implementing a plan to rebuild the stock, we are now moving down what could be a two year path before anything new is put in place. Further, part of that process will be examining and evaluating whether the SSB thresholds and targets should be lowered - essentially lowering the goal posts, and the number of striped bass in the water, forever. We agree with the ASGA and other participants who voiced concern over the timing of this Amendment process, and urge the ASMFC to keep the SSB thresholds and targets where they are while focusing their efforts on implementing a quick and effective rebuilding plan now.
The second main takeaway is not a surprise - anglers up and down the coast are fed up and tired of the mismanagement of the ASMFC. Multiple commenters called out the ASMFC’s use of the word ‘proactive’ when describing efforts around Addendum 6 in 2019. We agree with this. There have been no proactive measures taken by the ASMFC to protect striped bass since 2000 (21 years ago!), and the stock has suffered accordingly. While it has been extraordinarily discouraging over the past several iterations of regulations to watch the ASFMC seemingly ignore public comments, we have to keep moving forward and make sure that the future PID hearings go the way that Massachusetts did tonight. Unified support of MORE conservative regulations, MORE protections for the fish, and management for the abundance of the resource.
Rhode Island - March 17
We listened in to much of this hearing, and were encouraged by the general tenor of comments from those who spoke up. Importantly, keeping the biomass threshold / targets in place was recommended, as was a more aggressive rebuilding plan. As we discussed last year around the Addendum, the ASMFC’s own bylaws state that when a fishery is overfished, the Commission is required to implement a 10-year rebuilding plan. 2-years after striped bass were determined to be overfished, no rebuilding plan has been started at this point, so this needs to be a big-time focus of any regulations ASAP.
Another key topic that was brought up was that there needs to be coast-wide regulations and accountability for states that exceed harvest targets. This point bleeds into Conservation Equivalency, which has resulted in some states grossly exceeding harvest targets and contributing to overfishing coast-wide, with no repercussions or consequence of any kind. With a species that migrates like striped bass, Conservation Equivalency does not work, especially without any accountability.
We did also want to note that a couple commercial participants spoke up as well, one of which warned against catering entirely to the recreational community. We could not agree more, and believe that any successful management accounts for the fishery as a whole rather than to a specific constituent. That said, we are all fishing for the same fish, so it is the burden of all striped bass anglers to encourage responsible management of the fish, so we believe in an equal percentage of reduction in harvest across the community when regulations are put in place.
Overall, people are disappointed in how management has seemed to bend to political pressure rather than doing what is right for the fish and the fishery as a whole. With that in mind, it is CRITICAL that we all speak up in the next few weeks to ensure that the right things are included in the Amendment, and that the goalposts remain where they are. Please register for your state’s PID hearing today and send in your comments to your representatives before the April 9 deadline.
While other topics did not focus on specific pieces of the PID, the discussion was largely pro-conservation rather than pro-harvest, and included:
- managing for abundance rather than yield
- educating the community on proper Catch & Release practices
- Implementing a winter season closure
- Protect the fish entering the slot limit now. 32-36 inch slot
- Requiring single inline hooks stock on plugs from factory
- Increasing enforcement, especially at high-pressure targets like the Cape Cod Canal