CCA Striped Bass Comments - Draft Addendum IV
Coastal Conservation Association
Comments on the ASMFC
DRAFT ADDENDUM IV TO AMENDMENT 6
TO THE ATLANTIC STRIPED BASS
INTERSTATE FISHERY MANAGEMENT PLAN
As our members have been painfully aware, striped bass abundance has declined steadily since the mid-2000s. In fact, recreational releases plummeted from a high of 23.4 million fish in 2006 to a low of 5.4 million fish in 2012. Anglers were simply encountering fewer striped bass which, in our view, indicates a significant decline in abundance.
Striped bass are one the most sought-after game fish on the Atlantic coast. The keys to managing any primarily recreational fishery are access and abundance. Clearly abundance has declined and must be addressed as soon possible. The stock is not in danger of being significantly harmed in the classic fishery management measure of Maximum Sustainable Yield (MSY), but that style of management is antithetical to managing a primary recreational species. In the eyes of the angling public, it has already been significantly harmed due to the decrease in abundance.
Anglers desire abundance and respond readily to changes in abundance. Often, the dominant fish in the recreational catch are the dominant year classes in the stock. Simply put, the most abundant ages are the ones most often caught. There is currently a very strong 2011 year class, with poor year classes surrounding it, in the population. It could suffer disproportionate harvest levels if left unprotected. However, this strong year class, if protected, could help jump-start the recovery of striped bass abundance. We believe the Board should consider further management measures that protect that year class until they can enter spawning size.
Our comments on each option are below:
2.5.1 Coastwide Population Reference Point Options
CCA supports Option B:
Option B: 2013 Benchmark Stock Assessment F Reference Points
The fishing mortality reference points will be adjusted to be internally consistent with the SSB target and threshold, consistent with the recommendations in the 2013 benchmark assessment:
Rationale: This is the option recommended by the Technical Committee, and makes the Fishing Mortality Reference points internally consistent with the Spawning Stock Biomass reference points. They are more conservative and should allow for increased abundance (under average recruitment regimes) than previous reference points and should help to expand the age structure of the striped bass population.
2.5.2 Chesapeake Bay Stock Reference Point Options
CCA supports Option B:
Option B: Use coastwide population F reference points as established in section 2.5.1.
Due to data and model limitations, the Technical Committee cannot reach consensus on separate reference points for the Chesapeake Bay management area at this time (see TC memorandum; Appendix 2). Previously, the intent of establishing a lower F target in the Chesapeake Bay was to account for the impacts of harvesting a smaller sized fish (i.e., 18 inch minimum) in the Chesapeake Bay. The new coastwide reference points coming from the 2013 benchmark stock assessment (and considered in section 2.5.1) include the effects of the Chesapeake Bay’s harvest of smaller fish on the coastwide SSB, but do not incorporate data on the sex ratio that exists in the Bay. Therefore, the coastwide population reference points represent the best available scientific advice to manage total fishing mortality on both the coastwide population and the Chesapeake Bay stock component because the Technical Committee is unable to calculate Chesapeake Bay stock specific reference points at this time.
Rationale: Until such time as we receive better guidance from the Technical Committee, the coastwide reference points represent the best available advice for management.
2.5.3 Albemarle Sound/Roanoke River Stock Reference Point Options
CCA supports Option B:
Option B: The State of North Carolina will manage the Albemarle Sound/Roanoke River (A/R) stock using reference points from the latest North Carolina A/R stock assessment accepted by the Striped Bass Technical Committee and approved for management use by the Board. If this option is selected, the recreational and commercial fisheries in the Albemarle Sound and Roanoke River will operate under North Carolina’s Fishery Management Plan while the recreational and commercial fisheries in the Atlantic Ocean will continue to operate under the same management measures as the rest of the coastal fisheries.
Rationale: Since the AR stock contributes little to the coastwide striped bass stock, it makes sense to allow for management under an approved North Carolina Striped Bass Fishery Management Plan.
2.6 Timeline to Reduce F to the Target
CCA supports Option A:
Option A: Status quo: One year time frame
Management Trigger 3 requires reducing F to a level at or below the target within one year.
Rationale: The sooner fishing mortality can be reduced, the sooner abundance can begin to be restored. One of the enduring lessons from the last 30 years of fishery management is that delayed management often has little or no management effect. Taking the necessary reductions as early as possible is usually the best solution.
3.0 Proposed Management Program
CCA supports Option B:
Option B: Reduce F to a level that is at or below the target within one year. This represents a 25% reduction from 2013 total harvest. The desired reduction would be achieved by
approximately equal relative reductions to both the commercial and recreational fisheries. Rationale: We see no reason to delay reducing fishing mortality. As stated previously, the sooner fishing mortality can be reduced the sooner abundance may begin to rebound.
Proposed Recreational Fishery Management Options
Recreational fishing accounts for the majority of the fishing mortality on striped bass. Therefore it is critical that managers institute measures that meet or exceed the required amount for the recreational fishery. Every option for reducing harvest in the recreational fishery meets or exceeds the necessary amount.
Proposed Commercial Fishery Management Options
The projections to achieve the necessary 25% reductions are based on 2013, so the commercial reductions must be taken from that year’s harvest level to be effective. We are dismayed there are no options presented for achieving the 25% reduction in the coastal commercial fishery from any harvest level. We believe it is disingenuous to base the reductions on an as yet unachieved quota rather than actual harvest.
For the commercial fishery, many different scenarios are presented. Our basic position is to achieve the necessary 25% reduction in 1 year. However, we understand the Chesapeake Bay’s rationale with the 14% reduction in 2013, and can support taking a 25% reduction from the 2012 harvest levels.