FWIW, here's my letter that has been sent to ASMFC, all the Maine Striped Bass Board Members, who are proxies and all the Maine State officials who have proxies...
December 7, 2024
Emile Franke, Atlantic States Marine Fisheries Commission via Email
via Email to Emile Franke
[email protected]
RE: Striped Bass Comments regarding Proposed Striped Bass Management Measures
Dear ASMFC Striped Bass Management Board:
My name is XXXXXXXXXXXX and I’m a recreational fisherman that lives in Maine, having been an avid Striped Bass angler for over 60 years, with the last 15 years up in Maine. I keep copious records of my catch and since the inception of a spreadsheet version of the Maine Volunteer Angler’s Log I have shared my logs with Maine. Over the past 4 years my logs have shown a precipitous decrease in smaller striped bass, fish that previously made up the bulk of my catches. In previous years I have caught striped bass as small as 8 inches, in 2024 I didn’t catch a single fish less than 22 inches, 2 inches longer than my median fish size in 2018! These data irrefutably confirm what the Maryland Young of the Year studies have been showing the past six years; striped bass are in a dire spawning situation and measures need to be taken to ensure that the Spawning Stock Biomass, the only variable ASFMC can control, is brought back up to the minimum target levels by 2029. There’s no doubt that the Board must take management measures in time for the 2025 season to meet the 2029 deadline. Any Board action MUST provide a 14% reduction in fish mortality from both the Recreational and Commercial sectors.
After hearing the different proposals that the Technical Committee has provided the Management Board in regarding how to protect the 2018 fish, our last “decent” spawn, I’m extremely disillusioned and disappointed; the TC’s work has provided no viable path forward for the 14% reduction. They seemed to focus the majority of their efforts on No Targeting Closures for Striped Bass scenarios, which confuses me, as the Enforcement Side of the Striped Bass Board has consistently stated that No Targeting Closures are “very difficult, if not impossible to enforce”. This enforcement evaluation has resulted in the Management Board shying away from them. It’s critical that any fishery regulations need to be considered reasonable to the fishing public. Regulations that are deemed unenforceable by undermanned and underfunded Enforcement Groups will just invite normally well-meaning anglers to ignore them. I realize that the TC was tasked with answering specific Management Board questions, but spending virtually all their time on something that is probably DOA seems a very poor use of their limited time. It almost seems that the Commissioners who asked these questions were looking for an end run of not having adequate time to get things in place for the 2025, propagating the opinion that the ASFMC Striped Bass Board’s favorite management tool is kicking the can down the road.
Another aspect of the No Targeting Closures was the assumption that many folks would still take the same amount of fishing trips, but look towards other species as the trips’ targets. In Maine, where we have ZERO other inshore game fish like tautog, scup, weakfish, fluke, and only an occasional bluefish, this idea of redirected trips is totally wrong. Any trip that would have targeted striped bass in Maine is a trip that won’t happen during a No Targeting Striped Bass Closure! The average duration of the proposed No Targeting Closure scenarios for Maine presented by the TC was 30 days, which represents over 22% of Maine’s historical time that striped bass are in our waters. Therefore, no Targeting Striped Bass Closures would result in ALL the businesses dependent on Striped Bass Fishing losing at least 22% of their income over this closure. That is not an insignificant number, as it will directly impact Charter Boat Operations, Tackle Shops, the Hospitality Industry, Marinas,
etc.
A second disappointment with the TC’s analyses was the quick and very incomplete analysis of a different slot. Once again, they stuck with the Management Board’s question about lowering the slot to 26 or 27” to 28” which was deemed inadequate to reduce fish retention enough. That makes sense, but when asking the ASMFC person associated with the analysis the obvious question if slots with high ends at 26” or less were appropriate, the response was “We didn’t have enough time”. More troubling was the fact that the population distribution of fish sizes used in this model were based on the 2018 population assessment! This is totally inappropriate as the population of 2018 had that very strong 2015-year class fish of migratory size in it. If they used a properly modeled population size distribution for 2025, it would have fewer smaller fish in it than the 2018 model, and very few fish in the lower sizes. When looking at this population a slot of 24-26” might provide fewer retained fish by anglers than the current 28-31” slot, enough to get the desired reductions on retention. On a personal note, in 2018, my keeper to catch ratio was 1:300, in 2024, when there were far fewer small fish, it dropped to 1:27. Therefore, using a 2018 population size distribution for forecasting 2025 verges on being statistically disingenuous. When this was brought up at the informational meeting, the answer of “You’re correct, but we didn’t have enough time” raised its head again. Therefore, the statistical folks basically admitted that they couldn’t spend enough time on this potentially critical retention reduction tool for the Board to consider.
Being perfectly blunt, the two tasks the Board asked the TC for provided no feasible, real-world solutions for the Management Board. Unfortunately, getting additional, viable solutions would probably negate the possibility of having enough time to place emergency measures in place for the 2025 season. Sadly, this will just perpetuate ASMFC’s Striped Bass Management Board’s reputation of inaction by a kicking the can down the road.
Yours truly,
Pemaquid, Maine
via Email
cc: Representative Alison Hepler
Director Patrick Keliher, DMR via email
Governor Janet Mills via email
Senator Cameron Reny via email
Stephen Train via email
Megan Ware via email
