On May 4th the Atlantic States Marine Fisheries Commission (ASMFC) is adopting Amendment 7, new guidelines to the Striped Bass Management plan. We have an historic opportunity to rein in misuse of management tools and force more responsive and responsible action from the Striped Bass Board for the next 10 to 20 years.
A majority of the ASMFC Board is finally listening to us. We’re 4th and goal from the 2 yard line with seconds to go in the game. A field goal to tie would be a disappointment. Public comments on the draft of Amendment 7 are due by April 15.
The 149-page draft of Amendment 7 is a bear. The length and complexity of this document is a significant barrier to public participation. You can find it and more info at the ASMFC website linked here: ASMFC website
I suggest you focus on these most significant and contentious opportunities and pitfalls, with an emphasis on Conservation Equivalency:
- Conservation Equivalency (CE) has been the most misused management tool in this fishery. It allows states to enact different regulations with the goal of achieving equivalent mortality reductions or increases. There’s no accountability for states using CE’s: the data limitations often can’t support the use of CE’s; and the track record for many CE’s is appalling. [Sec. 4.6] We need the following guardrails:
- No CE’s permitted when striped bass are overfished.
- Data used in CE proposals must meet the federal standard of 30 Percent Standard Error or less.
- We need a 25% Uncertainty Buffer (front-end margin of error) built into any CE.
- Equivalency for CE proposals must meet the state-specific level.
- We can’t afford to weaken any existing Management Triggers nor delay implementation of action as the result of a Trigger. Allowing Deferred Management Action would be a setback. [Sec. 4.1]
- We need the most conservative recruitment triggers and fastest timeline for any required rebuilding plan. [Sec. 4.1]
- Seasonal Closures, as outlined in this draft, are not a reliable way to reduce striper mortality. Any new steps must be science-based, quantifiable, and enforceable. [Sec. 4.2]
- We must use the more recent, more conservative spawning success measures in calculations known as Low Recruitment Assumption. [Sec. 4.4]
Here are some tips on how to make effective comment:
- Start with who you are, why you care about striped bass, where you fish.
- If you belong to or follow a conservation organization, name that group and express support for their position. I’m aligned with the American Saltwater Guides Association [saltwaterguidesassociation.com]
- Highlight a couple of the most critical options in the Draft Amendment, as outlined above.
- Focus comments on options contained in the draft.
- Let fisheries managers know that you will be tracking their decisions.
Please join me in making a difference in the future of this fishery. Visit saltwaterguidesassociation.org to learn more or contact me at my email above. I’m happy to help.
Email your input to email@example.com by April 15 with subject “Draft Amendment 7.”
Send a copy of your comments to firstname.lastname@example.org to be entered into a great raffle sponsored by the American Saltwater Guides Association.