Editor’s Log: Public (Comment) Indecency - The Fisherman

Editor’s Log: Public (Comment) Indecency

The Atlantic States Marine Fisheries Commission (ASMFC) is a panel of officials hailing from each state along the Eastern Seaboard. There are 45 commissioners (three per state) and there are additional committee members that sit on boards dedicated to each species. The ASMFC oversees 27 fisheries, from lobster and Jonah crab to many species of concern for recreational anglers: weakfish, tautog, menhaden, American eel and striped bass, among them.

Whenever a proposal is considered, they release documentation that details these changes and the options for making them. The press release usually closes with the announcement of a public comment period, through which concerned anglers can voice their opinions using various channels. These public comments are gathered to gauge the leanings of the public, and (we assume) that they somehow factor into the decision, especially since recreational fishermen often make up the largest user-group, as they do with striped bass.

Most of us have lived through enough of these meetings to know that the impact of public comment on the ASMFC is about as reliable as the wind, but in their most recent meeting their disregard for the public was especially egregious. The decision on the table concerned quota transfers between states with a commercial striped bass fishery, put simply, if State A was unable to reach their commercial quota, they could hand their remaining quota over to State B. It should be pretty obvious that this is not a good idea, I mean the 2022 stock assessment found that striped bass are still overfished! Secondly, the only reason why this proposal is even on the table is because reaching commercial striped bass quotas has become increasingly difficult over the past decade. And why might that suddenly begin happening? I’ll refer you back to the 2022 stock assessment. It would seem obvious that the failure to reach a quota, that used to be opened and closed in about a month, would raise red flags about its sustainability. But we’re supposed believe that sending that unmet quota to another state that’s further ahead of the migration is a good idea?!

Somehow the concept made it through the ASMFC’s vetting process and was opened up for public comment. An overwhelming majority of the public, to the tune of 98%, said they would prefer ‘status quo’ meaning “no quota transfers”. In the meeting at the end of January, the ‘status quo’ option was not even discussed! Option D (board discretion on quota transfers) began to gain some steam before the board decided to postpone the motion until after the technical committee completed a series of population projections.

While it is important for the Board to understand the impacts of maximizing commercial quota utilization on fishing mortality and rebuilding, the Board should already be concerned based on the unrealistically low mortality estimate and what we already understand happened in 2022. The Board admitted that the numbers were affected by COVID, but added that they had to use them because of the implementation of the slot limit and how that changed their models. It makes sense, but, look at these numbers!

The table below represents striped bass that were harvested or died after release…

Period 2020 2021 2022
March/April 233,995 123,082 522,614
May/June 440,138 453,353 710,188
July/August 293,154 295,373 698,815
Sept/October 366,159 332,215 604,510
TOTAL 1,333,446 1,204,023 2,536,127

The 2022 harvest and mortality estimate is almost exactly equal to 2020 and 2021 combined! You would think that someone on the ASMFC would have checked these numbers and had the good mind to mention it! Additionally, the numbers of striped bass ‘released alive’ has fallen precipitously over the past three seasons, 2020 saw over 31 million striped bass released alive, 2021; 29 million, in 2022 that number fell to 20 million. When the numbers of harvested or dead-released fish double and the numbers of caught and released fish falls by a third over that same time period, something isn’t right. It’s pretty scary that I can figure that out after 20 minutes of playing around with the MRIP Query site and no member of the ASMFC even seems to know these facts… that were derived from THEIR OWN DATA!

If there’s anything we can know right away, simply by looking at these numbers, it’s that the mortality rate definitely did not stay at 0.14%, I’m no Archimedes, but I can see that without even opening the calculator app on my iPhone. The ASMFC assumes that 9% of all released striped bass die as a result, the very idea that two years with roughly one-third more fish caught and released would have such a low mortality rate is preposterous. If the ASMFC knows those numbers are inaccurate then they should hold themselves accountable and everything should remain status quo for at least one more year before considering any regulation changes, commercial or recreational. Where do we go from here? I guess we have to make our voices even louder.


Editor’s Log: Chevron Deference Overturned

Editor’s Log: Looking Back At Civilization

Editor’s Log: A Tagging Reoccurance