Saving Stripers

Stripers Forever members - recently the ASMFC - the interstate fishery commission responsible for managing striped bass - invited public comments on its next 5 year strategic plan. We submitted the following comments.

Brad Burns

The board of directors of Stripers Forever, a nonprofit corporation with approximately 14,000 members largely concentrated within the Atlantic coast north of the Carolinas, offers the following comments regarding the Strategic Plan of the Atlantic States Marine Fisheries Commission.

1. We think the Commission is too liberal regarding allowable harvest parameters. And as a direct consequence, many managed species are in poor condition. Therefore we strongly urge the Commission to take a more proactive stance regarding harvest restrictions. Pressure, largely from commercial harvesters, has caused both the NEFMC and ASMFC to rationalize overharvest until the realities of low stocks finally mandate a lower fishing effort. The disastrous state of northeast ground fish stocks is one clear example. The ASMFC's handling of shad is another one. The persistent downward trend of shad stocks has been evident for many years, but large scale harvesting of the species was not stopped.

2. This risk-averse conservative behavior needs to start with the management plans. The harvest models for striped bass have undergone several complete overhauls with greatly differing results and now we know that even the latest peer-reviewed version is being questioned by the very scientists who wrote it. This is not meant to be a slam at the scientists; all stock assessment science is complex, theoretical and thus suspect. Every bit of anecdotal evidence that Stripers Forever has gathered shows that striped bass stocks are far less robust than those reflected in the Commission's official statements. Given the tremendous importance of this fish to the recreational fishing industry and the fishing public, the consequences of incorrect assessments are far worse than any social or financial benefit gained by higher levels of harvest. It would seem when reading the ASFMC "Vision" statement, that to adopt proactively lower levels of allowed mortality and harvest would be more consistent with the expressed goals of protecting our marine resources than the actions that the Commission typically takes. When there is legitimate concern about the accuracy of a stock assessment, the ASMFC should follow the path of caution and should reduce harvest, not simply continue on whatever the present course might be.

3. The ASMFC needs to recognize how difficult it is for interested parties to understand the Commission's process. We urge the Commission, therefore, to seek better ways to inform the public. Video taping the meetings or streaming them live on the website would be excellent means for people everywhere to watch and understand the management process. In addition, transcripts of the meetings can be posted as soon as they are received to allow interested parties to know exactly what was said by every participant. Currently these are not available until after the next meeting when the results of the prior meeting may have already been acted on. This is an unacceptable public process. The rationale that these transcripts must be reviewed and officially accepted into the minutes is an unacceptable excuse for not making them public on a timely basis. We certainly are far more likely to believe that the transcriber's comments are accurate than to trust in the memory of the speaker some months down the road.