Last May the Atlantic States Marine Fisheries Commission (ASMFC) initiated the development of Addendum II to Amendment 7 to the Interstate Fishery Management Plan (FMP) for Atlantic Striped Bass. In the same meeting, ASMFC’s Striped Bass Management Board also implemented an Emergency Action that restricted recreational anglers to a 31-inch maximum size limit to temporarily reduce fishing mortality until Amendment II was completed. In late October Draft Addendum II was released for public comments, and earlier this month a series of public hearings were scheduled throughout November and December. Written public comments will be accepted until midnight on Friday, December 22, 2023.

Throughout BHA’s involvement in striped bass management the principles that guide our engagement have remained constant -  and they are to advocate for policies that recover the Atlantic striped bass stock to target levels as soon as reasonably possible, and that ensure target levels are maintained long-term.

According to ASMFC’s records the striped bass population was declared overfished in 2019 and remains overfished as of ASMFC’s most recent Stock Assessment Update in November 2022, which accounted for data through the 2021 fishing season. Earlier this year, ASMFC reported that an ‘unprecedented magnitude’ of recreational harvest had occurred in 2022, reducing the odds of successfully recovering the fishery before the deadline under current management parameters from 97% previously projected to an unacceptable 15%.

With our guiding principles in mind, BHA’s priorities and rationale on each of the options we would like to see included from Draft Addendum II are outlined below:

As an additional “guiding” principle, ASMFC has projected that a fishery-wide reduction of 14.5% is needed to achieve the fishing mortality target in 2024. (pg. 11, Draft Addendum II). We believe that all sectors of the fishery should contribute to its recovery, and as a result BHA will not support options for inclusion in Addendum II that are not projected to achieve at least a reduction in fishing mortality of approximately 14.5%.

3.1.1 Ocean Recreational Fishery Options

            Priority for inclusion – Option B – 1 fish at 28”-31” (all modes)

Only options B and C are projected to achieve the necessary reduction in fishing mortality, and as a result we oppose the inclusion of options A, D and E.

Mode splits (ex. different size limits for “private” anglers and “for-hire” vessels) are proposed in several sections of Draft Addendum II, including in Option C and E of this section. BHA urges the Board to remain focused on recovery as a primary objective, rather than providing enhanced harvest opportunities to any sub-segment of the fishery, and as a result we oppose the inclusion of Options C and E, leaving Option B as the only supportable choice.

3.1.2 Chesapeake Bay Recreational Fishery Options

            Priority for inclusion – Option B1 – 1 fish at 19”-23” (all modes)

Only options B1, B2 and C1 are projected to achieve the necessary reduction in fishing mortality, and as a result we oppose the inclusion of all other options. Additionally, we oppose the inclusion of option C1 because it proposes a mode split between the “private” and “for-hire” recreational fishery (see our note on mode splits in 3.1.1.).

While both options B1 and B2 are projected to achieve more than the necessary 14.5% reduction in fishing mortality, we believe that the current state of the Chesapeake Bay fishery warrants exceptional protection. The tributaries of the Chesapeake Bay, especially those in Maryland, are collectively regarded as the most productive of the major spawning areas that contribute to the migratory striped bass population (66^th SAW Assessment Report, pg. 476) and they have experienced sustained sub-average juvenile recruitment (for example, 2023 was the 5th concurrent year of sub-average juvenile recruitment in Maryland tributaries). Striped bass spawning success relies primarily upon favorable environmental conditions, and until the Chesapeake population experiences successful juvenile recruitment such that it is likely to ‘maintain an age structure that provides adequate spawning potential to sustain long-term abundance’ (Amendment 7 – 2.4 Objectives) BHA urges the Striped Bass Board to extend special care towards the fish we’ll be relying upon when favorable conditions do finally occur in the Chesapeake Bay tributaries by including Option B1.

3.1.3 For-Hire Management Clarification

As noted in our comments on 3.1.1., BHA does not support mode splits anywhere they are proposed in Draft Addendum II. If the Board does choose to include mode splits, we urge the inclusion of Option B, which would ensure that benefit of enhanced harvest opportunities is only extended to patrons on for-hire boats rather than captains and crew.

3.1.4 Recreational Filleting Allowance Requirements

Priority for Inclusion – Option B – minimum requirements for at-sea/shore-side filleting

According to Appendix I in Draft Addendum II many states already employ standards that would fulfill the requirements of Option B, so it does not seem as though its inclusion would constitute an undue burden upon anglers. BHA supports including Option B, which would require that states establish minimum requirements for at-sea/shore-side filleting, and would subsequently increase coastwide compliance with the FMP standards and aid in recovery of the fishery.

3.2.1 Commercial Quota Reduction Options

            Priority for Inclusion – Option B – 14.5% Reduction of Commercial Quotas

We feel that all segments of the fishery should participate in its recovery. As a result, BHA supports Option B, which would require that the Commercial sector contributes to recovery by reducing fishing mortality.

3.3 Response to Stock Assessment Updates

            Priority for Inclusion – Option B – Response via Board Action

BHA supported a similar option in Draft Amendment 7, granting the Striped Bass Board authority to act quickly in response to changing conditions that warranted amending the FMP standards. BHA supports Option B, which would allow the Board to implement corrective measures as quickly as possible if they are clearly needed, rather than allowing insufficient measures to persist and subsequently needing to take more drastic action closer to the recovery deadline to achieve a similar result.

BHA will be preparing our formal comments on Draft Addendum II in the coming weeks, and will continue to provide resources for those interested in advocating for the recovery and protection of Atlantic striped bass as we approach the public comment deadline on December 22, 2023.