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PO Box
1118 • West Babylon, NY 11704 |
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September 24, 2009 Nichola
Meserve Washington, DC 20005 Dear Mr. Meserve: Coastal Conservation Association New York (“CCA NY”) is taking this opportunity to comment on the Draft Addendum II to Amendment 6 to the Atlantic Striped Bass Interstate Fishery Management Plan for Public Comment (“Addendum II”). With respect to the first issue, Treatment of Unused Coastal Commercial Quota, CCA NY supports Option 1, status quo, which would not permit the rollover of unused commercial quota. Managers must remember that the commercial striped bass quota is a hard ceiling that should not be exceeded, not a target to be achieved. Addendum II explicitly recognizes that fact, stating that “avoiding a quota overage signifies managerial success.”[1] While it is true that a state’s failure to fill its entire quota does diminish commercial fishers’ opportunities to profit from the public striped bass resource, it is also true that it is a practical impossibility to set regulations in a manner that assures that a quota will be met but not exceeded. Given the choice between underage and overage, the public interest is better served by assuring that the striped bass resource is not overfished, and that the underage is “reinvested” in the spawning stock to better assure abundance in future years.[2] The failure of a state to harvest its full commercial quota in any year could result from a number of causes. The fish may be locally unavailable, or the weather might curtail fishing activity. Other fisheries, or even non-fishing activities, might offer greater opportunities for profit. Slot limits or other management measures might limit the ability to harvest what fish are locally available. Such are the arguments that are made in favor of the proposed rollover, but one comment is seldom heard: That the failure to harvest a state’s full quota could be due to a contraction of the striped bass population. To be clear, CCA NY is not claiming that the striped bass population is under imminent threat, or that the population is declining from unhealthy levels. CCA NY understands that, while the population has declined from its 2004 high, it remains well above both the spawning stock biomass target and threshold. Fishing mortality is believed to be well below the target, and the number of older fish (age 8+) in the population has fallen, but seems to have stabilized. Still, there are reasons to approach striped bass management with some caution, and a clear recognition of the fact that the best time to resolve a problem is before it actually occurs. There are constant anecdotal reports that striped bass abundance at the northern end of its range has decreased sharply.[3] Mycobacteriosis is potentially a serious threat, particularly in Chesapeake Bay, where it has its greatest impact on the older females[4] that spawn in the largest striped bass nursery area on the coast.[5] Recruitment in 2006 and 2007 was some of the worst in recent years, while the 2008 Maryland young of the year index, traditionally a reliable measure of future striped bass abundance, was merely 3.2, compared to a long-term average of 11.7.[6] The winter tagging cruise that takes place off Virginia and North Carolina in January caught the fewest striped bass in its 22-year history.[7] Anecdotal evidence from anglers, both in New York and throughout the coast, suggest that striped bass are less available than in recent years, and that with the exception of a handful of very large fish that may have been spawned during the moratorium years of the 1980s, the average size of the fish caught by anglers is declining. Any one of those factors, taken on its own, is probably not significant. Striped bass typically experience very irregular spawning success, in which dominant, average and below-average year classes follow one another without discernable pattern. Weather can affect fishing success, whether by anglers or by research vessels, in any given year, and changes in water temperature and/or forage abundance may affect the annual distribution of striped bass. However, when viewed as a whole, particularly considering the potential impact of mycobacteriosis, there is more than adequate reason to approach any increase in the actual striped bass harvest with caution. CCA NY believes that, to date, the Atlantic States Marine Fisheries Commission’s Striped Bass Management Board (the “Board”) has not taken an adequately precautionary approach to the striped bass fishery. Instead, it has incrementally increased harvest not by a single coordinated action, but rather by a series of measures that one Board member has likened to “death by a thousand cuts.”[8] In a single session, the Board created fisheries in Delaware and Pennsylvania for striped bass smaller than the 28-inch coastal minimum, eliminated the quota on the Chesapeake Bay spring “trophy” fishery and permitted Maryland to extend its December season by more than two weeks.[9] Addendum II would comprise yet another small but very real drain on striped bass abundance by authorizing a de facto increase in commercial harvest.[10] CCA NY believes that, until the uncertainties relating to striped bass abundance, including both trends in recruitment and future abundance and the effects of mycobacteriosis on the overall health of the stock, are determined in the next baseline stock assessment, consideration of a rollover of uncaught commercial quota is both premature and irresponsible. As representatives of the public interest and as stewards of the public striped bass resource, the Board is obligated to take a risk-averse approach to striped bass management, and to maintain the status quo as to the rollover of unused quota. As CCA NY believes that a rollover of unused quota is not appropriate, and that status quo is the only responsible response to the rollover issue, it refrains from any additional comment as to the dimensions that any such rollover should take. Thank you for considering CCA NY’s views on this matter.
[1] Atlantic States Marine Fisheries Commission, Draft Addendum II to Amendment 6 to the Atlantic Striped Bass Interstate Fishery Management Plan for Public Comment, August 2009, p. 3. [2] It is worth noting that, in the event that a state’s commercial harvest exceeds its quota, that state is required to do nothing more than apply such overage, on a pound-to-pound basis, to its quota in the following year. The public is not compensated for the loss of spawning potential suffered by the striped bass stock as a result of the excess removals. Although this is not a matter to be contemplated in Addendum II, the Striped Bass Management Board would do well to consider action which, in the event of an overage, would require the following year’s quota to be reduced not only by the weight of the excess landings, but also by an amount which represents lost future production attributable to the overharvest. [3] See, for example, the comments of Matt Boutet in Proceedings of the Atlantic States Marine Fisheries Commission’s Atlantic Striped Bass Management Board, October 20, 2008, p. 1. [4] Atlantic States Marine Fisheries Commission, Striped Bass Technical Committee, March 31, 2009, Baltimore, Maryland, Meeting Report, p. 4. [5] CCA NY understands that the relative contribution of the Chesapeake Bay nursery area to the overall coastal migratory stock has declined when compared to the contributions from the Delaware River estuary and the Hudson River, due largely to reduced production from the Chesapeake, although it not yet able to document such assertion. [6] Source for Maryland young of the year index: Maryland Department of Natural Resources press release [7] Comments of Dr. William Laney in Proceedings of the Atlantic States Marine Fisheries Commission’s Atlantic Striped Bass Management Board, May 24, 2009, pp. 19-20. [8] Comments of Representative Dennis Abbot in Proceedings of the Atlantic States Marine Fisheries Commission’s Atlantic Striped Bass Management Board, August 18, 2009, p.18. [9] Proceedings, October 20, 2008, pp. 4-17. [10] While it can be argued that no increase is taking place, since even if 100% rollover was permitted, over a period of years the average harvest would not exceed the average commercial quota, viewed in real terms, the absolute number of striped bass killed would increase, and thus constitute yet another of Rep. Abbot’s “thousand cuts.”
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