UPDATE: Click here for a complete guide on how you can take action and protect the future of striped bass! 

In early May the Atlantic States Marine Fisheries Commission (ASMFC) will convene for their spring meeting, at which time we’re expected to see their Atlantic Striped Bass Board finalize Amendment 7 to the Striped Bass Fishery Management Plan (FMP). This would conclude a regulatory process that’s been ongoing for almost two years and will set the trajectory of the fishery for decades to come. Under the current FMP, which was approved in 2003, we’ve observed a historically abundant stock degrade to overfished levels, and little has been done to curb overfishing or reverse this declining trend. To put it simply – management changes are needed, and the stakes for the future of the Northeast’s most iconic recreational fishery couldn’t be higher.

The principles that have guided BHA’s engagement in this process, which began over a year ago when the New York and New England Chapters weighed in on the Amendment 7 PID, have remained constant – and they are to recover the Atlantic Striped Bass stock to target levels as soon as reasonably possible and to implement policies that ensure target levels are maintained long-term after the stocks have recovered.

In early 2022 when the ASMFC’s Striped Bass Board approved Draft Amendment 7 for public comment the scope of potential changes was narrowed to four specific areas – Management Triggers, Recreational Release Mortality, Rebuilding Plan, and Management Program Equivalency. Within each of these focus areas a very complex range of technical options has been presented for the public to comment on, and BHA’s volunteers and staff have been working over the last month to understand how each of the potential changes would affect management of the fishery moving forward. In the coming days we will be sharing our recommendations for how you can engage with ASMFC’s staff and the Striped Bass Management Board to protect the fishery – so keep an eye out for that.

With our guiding principles in mind, BHA’s priorities and rationale on each of the potential changes that we would like to see included in Amendment 7 are outlined below:

4.1 – Management Triggers

Tier 1 Options – Fishing Mortality (F) Triggers

Priorities for Inclusion:

• Sub-Option A1
• Sub-Option B1
• Sub-Option C1

Because fishing mortality (F) is a direct result of angler effort and behavior, and subsequently can be controlled by management action more readily than any other trigger, rapid response should be a top priority for F triggers. Given that the intention of managing the fishery to target and threshold levels is to provide some buffer for fluctuations, both F_Target and F_Threshold triggers should be included in Amendment 7, and the primary objective of the Striped Bass Board should be to maintain F below F_Target. The buffer between F_Target and F_Threshold allows a degree of management consistency with both options C1 (preferred) and C2 providing multi-year scenarios before action must be taken if F exceeds F_Target. Further, if F exceeds F_Threshold and overfishing is occurring, then the need to quickly correct this scenario outweighs the convenience of management consistency and therefore, we support sub-options A1 and B1.

Tier 2 Options – Female Spawning Stock Biomass (SSB) Management Triggers

Priorities for Inclusion:

• Sub-Option A2
• Sub-Option B1
• Sub-Option C2

Female Spawning Stock Biomass (SSB) is the gauge by which the fishery’s abundance is measured, and as a result any decrease in abundance should be addressed appropriately by the Board. Given the intention of managing to target and threshold levels, both C2 (preferred) and C1 provide multi-year options if SSB falls below SSB_Target to allow for a degree of management consistency. We favor sub-option C2 because it does not rely on excessive fishing mortality, which is one of many causes that could lead to a decline in SSB requiring correction. If SSB falls below SSB_Threshold and the stock is declared overfished stronger action is needed, which would be accomplished through sub-option B1. While Amendment 6 required a 10-year timeline for rebuilding if SSB falls below SSB_Threshold it did not require the Board implement a rebuilding plan within a specified timeline. We feel that when any SSB trigger is tripped, implementing a rebuilding plan in a timely manner should be required. The 2-year timeline proposed in sub-option A2 would ensure the best possible chances to rebuild the stock within the 10-year requirement.

Tier 3 Options – Recruitment Triggers

Priorities for Inclusion:

• Sub-Option A2
• Sub-Option B2

Juvenile recruitment relies on factors other than female SSB and fishing mortality and thus, even a well-managed fishery can suffer from low recruitment during periods when several years of sub-optimal conditions occur in a row. The need for a more sensitive recruitment trigger was highlighted during the Board’s Fall 2021 meeting when the Technical Committee recommended that measures to protect the remaining strong juvenile recruitment classes be removed because the time when action would result in appreciable protection had already passed. Both sub-options A2 (preferred) and A3 are more sensitive than the status-quo.

The point of implementing a stronger juvenile recruitment trigger is to protect the remaining fish if recruitment suffers for a prolonged period so they can assist in recovering the stock. Thus, we support sub-option B2, which requires the Board to reduce F to a low-recruitment assumption within one year and determine appropriate action at the next stock assessment if the recruitment trigger is tripped.

Tier 4 Options – Deferred Management Action

Priorities for Inclusion:

• Option A

We do not support any of the deferred management options that would allow response to triggers to be ignored or delayed.

4.2.2 Measures to Address Recreational Release Mortality

Priorities for Inclusion:

• Sub-Option C1
• Sub-Option C2
• Sub-Option D2

We prioritize recovering the stock as quickly as reasonably possible as a guiding principle, and while the intent of Option B and its sub-options appears to be decreasing fishing mortality by reducing recreational effort, we oppose the proposed measures for inclusion in Amendment 7. BHA’s members are primarily recreational anglers who occupy all segments of the fishery, including without limitation shore-based wading, personal watercraft, and utilizing for-hire charter fishing services, and therefore measures taken to reduce recreational effort directly affects our opportunities to pursue fish. A primary concern with Option B relates to the note on Page 60 of the draft document, which states that the success of no-targeting closures is highly uncertain. Further, the Technical Committee has not established a method for estimating reduction in removals. Without an understanding of the anticipated benefit or the likelihood that a benefit to the fishery would even occur, the Board cannot proceed with an informed assessment on the merits of the proposal. We also share the concerns of the Law Enforcement Committee, that any restrictions on targeting striped bass would be practically unenforceable. 

While we support efforts to share information regarding best handling and release practices, as well as general education on the state of Striped Bass, we also recognize that state agencies operate with limited resources and personnel. As a result, we prefer sub-option D2, which recommends states engage in educational efforts while balancing resources appropriately across their range of responsibilities rather than requiring public education related to Striped Bass.

4.4 Rebuilding Plan 

4.4.1 Recruitment Assumption for Rebuilding Calculation

Priorities for Inclusion:

• Option B

A formal rebuilding plan to recover the stock by 2029 remains nonexistent. Further, we continue to be concerned about the declining trend of the stocks. We emphasize that the Board take measures to protect the fish that remain in the water by including option B.

4.4.2 Rebuilding Plan Framework

Priorities for Inclusion:

• Option B

We are concerned that the 2022 stock assessment could indicate measures included in Amendment 7 are unlikely to achieve recovery by 2029.  Thus, the benefit of option B is that such action could be taken almost immediately, rather than requiring a year-long addendum process. Recognizing that this option would be a one-time allowance and is contingent on a very dire outlook for the future of the fishery we support Option B, which would allow the Board to implement needed recovery measures as quickly as possible should the measures included in Amendment 7 be unlikely to achieve recovery by 2029.    

4.6.2 Management Program Equivalency

Priorities for Inclusion:

• Sub-option B1-a
• Sub-option C3
• Sub-option D2
• Sub-option E2

To paraphrase ASMFC’s Guidelines, the concept of Conservation Equivalency (CE) is intended to allow states flexibility to develop alternative regulations that better accommodate local conditions while still achieving the overall conservation goals of the Fishery Management Plan. However, introducing alternative regulations makes it more difficult to determine the effectiveness of the coastwide management plan or such alternative measures. As a result, we support sub-options B1-a (preferred) and B1-b, which restrict the use of CE during times when the stock is declared overfished. In conjunction with a female SSB trigger related to SSB_Threshold, sub-option B1-a option would ensure the management focus is on rebuilding the stock for the benefit of the entire Atlantic Coast if the SSB_Threshold trigger is tripped, as opposed to accommodating situations in specific states during times when recovery should be the priority.

As outlined by the National Marine Fisheries Service, “PSEs of 30 percent of greater are not considered sufficiently reliably for most purposes and should be treated with caution”. CE proposals should rely on data that is sufficiently accurate to make informed management decisions so we support sub-option C3.

Unlike quota-managed fisheries, the Board has not utilized its discretion over CE programs to ensure that non-quota fisheries are held accountable for exceeding their respective intended impact. We understand that sub-options outlined in option D seek to decrease the chances that CE proposals exceed their intended impact by proactively imposing an uncertainty buffer and support sub-option D2. If sub-option B1-a or similar is not selected and CE continues to be allowed during rebuilding, then requiring a higher uncertainty buffer sub-option would be appropriate, in which case we would support sub-option D3. 

Recognizing that a multitude of factors, e.g., total angler effort and accessibility of fish in the area, result in each state having a different total impact on the fishery. Some states will have a greater impact than others so we support sub-option E2.