I copied this from a Charles Witek post on another website. Clear message to ASMFC is ACT NOW to save stripers.
Let's see how NJ & MD dance around these data...
The ASMFC has released both a summary of the public comments made on Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass, and copies of every individual comment, each of which were tabulated. For folks who wondered, in earlier threads, whether the ASMFC reads each comment, the answer is clearly yes.
A total of 4,689 comments were received, from individuals (1,149), organizations (51, plus 92 organizations and businesses that were additional signatories to the American Saltwater Guides Association comment letter), and as form letters (3,397). The comments overwhelmingly supported striped bass conservation.
Just to hit some of the high points:
With respect to the time to reduce fishing mortality to target, 4,124 supported keeping the current 1-year deadline, 25 supported extending the deadline to 2 years
4,093 supported the current requirement that management action be taken as soon as overfishing occurs, 17 preferred that a 2-year average exceed the threshold before action is taken
4,101 comments supported a new requirement that, if a biomass trigger is tripped, rebuilding must begin within 2 years; 13 opposed such requirement
14 comments supported the current recruitment trigger, which wasn't tripped by recent low recruitment; 4,077 supported a new, more sensitive recruitment trigger
4,068 comments supported a new requirement that managers must act if a recruitment trigger was tripped; 16 would retain the Board's current option not to act; 2 would add qualifications
4,080 comments opposed giving the Management Board authority to delay taking action; 23 supported delays under some circumstances
4,052 supported basing the rebuilding plan on a low recruitment assumption; 12 disagreed
4,047 felt that the Management Board should fast-track rebuilding; 14 disagreed
4,104 felt that conservation equivalency should not be used when the stock is distressed; 52 opposed any restrictions on the use of CE
4,101 if stock overfished, 6 if spawning stock biomass is below target, 426 if overfishing is occurring
1,563 felt that there should be a minimum standard for data accurace (NOTE: for this and following items, many people failed to comment on the issue)
1,558 would limit the percent standard error to 30, 2 would limit the PSE to 40, 1 would limit PSE to 50
1,568 felt that states using conservation equivalency should have to incorporate a buffer to address management uncertainty
225 supported a 10% uncertainty buffer, 1,144 supported a 25% buffer, and 169 supported a 50% buffer
1,332 felt that "conservation equivalency" should be defined
1,328 believed that a state must achieve the same reduction as the coastwide measures would achieve in that state, 4 supported a state only meeting the overall coastal reduction
That's a good distribution for the striped bass. Hopefully, the Management Board will get the message.
The letters themselves were interesting, at least on the organizational level.
The attorney generals for three states, Connecticut, Rhode Island, and Massachusetts, sent in a letter strongly supporting striped bass conservation
Three conservation groups, the Chesapeake Bay Foundation, The Nature Conservancy, and Wild Oceans, also wrote good pro-striped bass letters
The Recreational Fishing Alliance, supported by a few charter boat groups, supported delay, continued conservation equivalency, lowering the biomass target, and maintaining rec harvest
The Center for Sportfishing Poilicy claimed to speak for 7.5 million striped bass anglers, and was on target with most options, but well off the vast majority on others
The American Saltwater Guides Association letter was supported by 94 fishing industry members, and groups including RISSA, Connecticut Surfcasters, etc.
JCAA did not submit comments
With respect to the form letters:
The form letter that garnered the greatest response, by far, was from the Chesapeake Bay Foundation, with 2,461
Of sportsmen's groups, Backcountry Hunters and Anglers had the best response, 251. The American Sportfishing Association was runner-up in the sportsmen's category, with 217. Another form letter of uncertain provenance, but seemingly sent by Massachusetts surfcasters, had 141 responses; no other letter had the report of more than 100 persons
I'm going to pull all of the numbers together, try to figure out patters and what it all means, and write it up in the blog that I'll write tomorrow. In the meantime, thanks go out to everyone who sent in comments. They will hopefully help to get the job done.
If you want to read the comments yourself, you can find them here http://www.asmfc.org/files/Meetings...anticStripedBassBoardSupplemental_May2022.pdf
And, while I'm at it, thanks to Emile Franke, ASMFC';s Fishery Management Plan Coordinator for striped bass. She was brand-new when the PID came out in February 2021, and has done an exceptionally good job reaching out to stakeholders, coordinating the Plan Development Team, reading and tabulating comments, and generally trying to get this right. Now it's up to the Management Board, and even if they screw things up, Ms. Franke deserves nothing but thanks and appreciation.
Let's see how NJ & MD dance around these data...
The ASMFC has released both a summary of the public comments made on Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass, and copies of every individual comment, each of which were tabulated. For folks who wondered, in earlier threads, whether the ASMFC reads each comment, the answer is clearly yes.
A total of 4,689 comments were received, from individuals (1,149), organizations (51, plus 92 organizations and businesses that were additional signatories to the American Saltwater Guides Association comment letter), and as form letters (3,397). The comments overwhelmingly supported striped bass conservation.
Just to hit some of the high points:
With respect to the time to reduce fishing mortality to target, 4,124 supported keeping the current 1-year deadline, 25 supported extending the deadline to 2 years
4,093 supported the current requirement that management action be taken as soon as overfishing occurs, 17 preferred that a 2-year average exceed the threshold before action is taken
4,101 comments supported a new requirement that, if a biomass trigger is tripped, rebuilding must begin within 2 years; 13 opposed such requirement
14 comments supported the current recruitment trigger, which wasn't tripped by recent low recruitment; 4,077 supported a new, more sensitive recruitment trigger
4,068 comments supported a new requirement that managers must act if a recruitment trigger was tripped; 16 would retain the Board's current option not to act; 2 would add qualifications
4,080 comments opposed giving the Management Board authority to delay taking action; 23 supported delays under some circumstances
4,052 supported basing the rebuilding plan on a low recruitment assumption; 12 disagreed
4,047 felt that the Management Board should fast-track rebuilding; 14 disagreed
4,104 felt that conservation equivalency should not be used when the stock is distressed; 52 opposed any restrictions on the use of CE
4,101 if stock overfished, 6 if spawning stock biomass is below target, 426 if overfishing is occurring
1,563 felt that there should be a minimum standard for data accurace (NOTE: for this and following items, many people failed to comment on the issue)
1,558 would limit the percent standard error to 30, 2 would limit the PSE to 40, 1 would limit PSE to 50
1,568 felt that states using conservation equivalency should have to incorporate a buffer to address management uncertainty
225 supported a 10% uncertainty buffer, 1,144 supported a 25% buffer, and 169 supported a 50% buffer
1,332 felt that "conservation equivalency" should be defined
1,328 believed that a state must achieve the same reduction as the coastwide measures would achieve in that state, 4 supported a state only meeting the overall coastal reduction
That's a good distribution for the striped bass. Hopefully, the Management Board will get the message.
The letters themselves were interesting, at least on the organizational level.
The attorney generals for three states, Connecticut, Rhode Island, and Massachusetts, sent in a letter strongly supporting striped bass conservation
Three conservation groups, the Chesapeake Bay Foundation, The Nature Conservancy, and Wild Oceans, also wrote good pro-striped bass letters
The Recreational Fishing Alliance, supported by a few charter boat groups, supported delay, continued conservation equivalency, lowering the biomass target, and maintaining rec harvest
The Center for Sportfishing Poilicy claimed to speak for 7.5 million striped bass anglers, and was on target with most options, but well off the vast majority on others
The American Saltwater Guides Association letter was supported by 94 fishing industry members, and groups including RISSA, Connecticut Surfcasters, etc.
JCAA did not submit comments
With respect to the form letters:
The form letter that garnered the greatest response, by far, was from the Chesapeake Bay Foundation, with 2,461
Of sportsmen's groups, Backcountry Hunters and Anglers had the best response, 251. The American Sportfishing Association was runner-up in the sportsmen's category, with 217. Another form letter of uncertain provenance, but seemingly sent by Massachusetts surfcasters, had 141 responses; no other letter had the report of more than 100 persons
I'm going to pull all of the numbers together, try to figure out patters and what it all means, and write it up in the blog that I'll write tomorrow. In the meantime, thanks go out to everyone who sent in comments. They will hopefully help to get the job done.
If you want to read the comments yourself, you can find them here http://www.asmfc.org/files/Meetings...anticStripedBassBoardSupplemental_May2022.pdf
And, while I'm at it, thanks to Emile Franke, ASMFC';s Fishery Management Plan Coordinator for striped bass. She was brand-new when the PID came out in February 2021, and has done an exceptionally good job reaching out to stakeholders, coordinating the Plan Development Team, reading and tabulating comments, and generally trying to get this right. Now it's up to the Management Board, and even if they screw things up, Ms. Franke deserves nothing but thanks and appreciation.
