Fishery Management Plan Coordinator
Atlantic States Marine Fisheries Commission
1050 North Highland Street, Suite 200A-N
Arlington, Virginia 22201
RE: Comments on Atlantic Striped Bass Amendment 7 Public Information Document
Dear Ms. Franke and Atlantic Striped Bass Management Board:
I am the owner of the Saltwater Edge a fishing tackle shop in Middletown, RI. I am also Chairman of the American Saltwater Guides Association an organization that believes healthy sustainable fisheries drive angler participation and therefore sales. I also serve on the Legislative Committee of The Rhode Island Saltwater Anglers Association (RISAA) which represents over 7,500 recreational anglers.
A healthy striped bass population is the linch pin to sustaining mine and other tackle shops along the striper coast. Striped bass are everyman’s fish in that you can catch it from the beach, a kayak or a boat with bait, or lures, or flies and they are in our waters from April to November. Many of my customers were introduced to saltwater fishing by the striped bass.
According to data collected by the National Oceanic and Atmospheric Administration (NOAA) for the most recent year available, 2016, recreational fishing supported over 4,000 jobs and contributed over $412 million to the Rhode Island economy. That's in comparison to a value of $332 million for commercial fisheries.The economic contribution of striped bass to my shop and the recreational fishing economy in Rhode Island is difficult to understate.
I am very concerned for the ASMFC’s ability as currently configured to manage the striped bass population in a sustainable manner. Being old enough to have fished through the last decline I also witnessed the subsequent rebound brought about by effective mamanagemnt. It was the shining star of fisheries management. I believe the current decline is largely because managers have yielded to political pressures by ignoring there own management triggers rather than looking out for the best interest of rebuilding fish stocks. The striped bass recovery from the last moratorium demonstrates if we take care of the fish the fish will take care of us. ASMFC needs to look in the mirror and learn from the past.
As a small business owner reliant on healthy striped bass population. I can’t see past the ridiculous and unchecked use of conservation equivelece by ASMFC. These proposals and resulting impacts rarely seem to be on target. Most recently, the reduction target was 18% once the CE proposals were factored in the actual reduction was 15%. I have wracked my brain and read a fair amount and don’t recall or find a time when the CE impacts proposals actually exceeded the target. Raised the bar. Protected the striper. Most catastrophically, Marylands CE proposal a few years back resulted in overfishing their quota and the 2011 year class by 217%! The striped bass resource (and associated businesses) would have been on the road to recovery by now instead of being force to double down on the 2015 year class. Be aware there is considerable and growing public distrust in the ability of ASMFC to deliver on their mission of “ leaving healthy and abundant marine fisheries for the next generation to enjoy”
Issue 1: Fishery Goals and Objectives:
Remove from consideration as the ‘Goals and Objectives” are appropriate. I am not in favor of regulatory flexibility as stated above I believe that such flexibility has contributed to overfishing of striped bass in the past 10 years
Issue 2. Biological Reference Points:
I support of continuing to use the 1995 estimate of female SSB as stated above. I think that the Target level of 125% of the estimated 1995 SSB is still attainable and is still appropriate. I feel strongly that a diverse age structure is critical to a sustainable striped bass population
Issue 3. Management Triggers and Issue 4. Stock Rebuilding Targets and Schedule:
I believe the current triggers are adequate.
Issue 4. Stock Rebuilding Targets and Schedule:
I feel strongly the the 10 year rebuilding timeline needs to stay in place and that the Board is two years late in developing a Rebuilding Plan.
Issue 5. Regional Management:
Remove form consideration as the science needed is not available.
Issue 6. Conservation Equivalency:
As stated above I support eliminating CE in fisheries where over fishing is occurring.
Issue 7. Recreational Release Mortality:
At present outreach and education should be utilized until science becomes available to better inform next steps
Issue 8. Recreational Accountability:
Remove from consideration. Complex issue that applies to all ASMFC species. We need of answers but it is to big to include in this Ammendment.
Issue 9. Coastal Commercial Allocation:
The landing period used for allocation is 50 years old and should be revisited by the Technical Committee.
I appreciate the opportunity to provide comments. I hope the Board seizes this opportunity to restore public trust and realize their mission of “ leaving healthy and abundant marine fisheries for the next generation to enjoy”