Remember, Comments are due by 5 PM, this Sunday.
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Here is my submission:
Dear Commission,
My comments on the Striped Bass Draft Addendum VI are as follows:
I believe that striped bass regulations should remain status quo. This is based on the fact the ASMFC has just changed the models they’ve used to estimate abundance, and in doing so has manipulated the “science” to manufacture a problem.
In 1995, when the stock was declared to be rebuilt, SSB was estimated to about 14,000 mt. This was the threshold level that was set, with a target of 17,500 mt. The fisheries management models used these numbers to continue to grow the entire stock to an all time high of more than 100,000 mt, and the fishery remained strong, and healthy for the next 15 years. Until you decided to start changing your models.
Now, 24 years later, you preposterously propose that you now know that the SSB level in 1995 was actually 6.5x higher than it was estimated by the scientists at the time, ~91,000 mt, and that’s what it should be now. You should all be embarrassed and ashamed at yourselves for proposing that you and your fellow “scientists” were ever so incompetent that their estimates were so far off. However, I don’t believe that the science at the time was so wrong. Management under that model was successful at rebuilding and maintaining a healthy stock and fishery for more than 15 years. It’s only since you started manipulating the models, in 2010, 2014 and now again, in 2018, that a “problem” has developed. Each time you “played” with your “science” you increased the SSB thresholds and targets, exasperating a declining trend in the stock, until finally, in 2018, you achieved your apparent goal of demonstrating overfishing is occurring and the stock is over fished.
There is no way that any management decisions should be based on this new model, which has only just been implemented, and so wildly differs in number from the successful management model used from 1995 to 2010. You all decided to create this model, and in doing so, created this problem. Just as you chose to use the current model, you could go back and use the prior model from 1995. Don’t tell us this is the “best available science” and use that a poor excuse for why you are proposing cuts. You just created the science yourselves. Fix it. Only in Govt, would this level of incompetence ever be tolerated. It’s shameful.
What is even more shameful, is that your “science model” shows that 48% of striped bass are killed due to recreational dead discards. To fix that problem, you suggest further restricting regulations to the size and season of the fishery, which will only serve to increase the number of fish that have to be released, therefore, further increasing the dead discard mortality. Only a “scientist” with his/her face planted squarely into a Bunsen burner could see that as an effective or ethical solution to a such a problem. If a reduction is needed, and about half of the fish being killed, are simply being wasted because they are being caught and thrown back to die, that is where the reduction needs to come from.
No reductions to harvest should be made at this time. Any changes to seasons or size limits, will only serve to further increase discard mortality. Instead, studies should be done on how to reduce discard mortality, and measures should only be implemented there. The use of circle hooks have been proposed. However, the ASMFC doesn’t recognize any reduction in mortality from using them because there aren’t any studies to demonstrate the efficacy of their use. So do those studies. Study the use of circle hooks and other release mechanisms. Stop wasting your time, and ours, manipulating management models, and do some actual science that will be beneficial to all stakeholders and the fish themselves (so that half of the fish being killed are not just being thrown back into the ocean to rot).
Study the use of circle hooks
Study the use of various dehooking devices
Study the efficacy of outreach to anglers on how to better fight, handle and release fish
Additionally, further study release mortality and apply it to different size fish, different methods of fishing (surf, boat, bait, lure, fly fishing) and across all the various conditions found in the areas these fish migrate through. The cool, rushing waters found around Cape Cod and the east end of Long Island are vastly different then the warm embayments found in the Chesapeake and Delaware Bay areas and release mortality is likely very different too.
Bigger fish fight harder, and are fought longer and therefore, experience more stress, increasing the likelihood of dying after being released. A slot limit, prohibiting keeping larger fish, is just going to kill more big fish through release mortality. Raising the minimum size limit is just going to increase discard mortality while people fish to catch a fish to keep. Reducing the season length will just increase the number of fish that are caught out of season, and have to be released, increasing release mortality. Reductions in harvest is not the answer. Reductions in release mortality is the only logical and ethical answer to the current problem with the fishery.