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1. Al Albano's Dedication to Conservation
2. Fred Schwab's Opposing reopening of EEZ
"There is a window in time, and that is now, when we could forever lose a precious ocean heritage, or we could develop the foundation for an enduring legacy, an ocean ethic...an inspired gift from the 20th century to all who follow us." -- Dr. Sylvia Earle
As leaders in fish conservation, the High Hill Striper Club has historically been and continues to be actively involved in campaigns which seek to maintain a sustainable and abundant population of recreational species of fish. As most obviously evidenced by the decimation of striped bass prior to the 1980s, sound fisheries management is imperative to the future our sport and as a result, has long been an important goal of High Hill. Over the course of the existence of the club, several members have taken active roles in the development of recreational and commercial fishing legislation to prohibit the exploitation of striped bass and other gamefish.
Our members have been involved with several committees, lobbied legislators and have written countless letters which have helped keep fish populations from a seemingly certain demise. These committees include the Marine Resources Advisory Council, the Atlantic States Marine Fishery Commission and the Friends of the Striper Committee, to name just a few. These passionate gentlemen include, but are certainly not limited to, such surf fishing legends as Fred Schwab, Bob Rance and Bill “Doc” Muller. In recent years, my mentor, Ed Messina has carried the torch lit by Fred Schwab. Moving forward, Ed has instilled the High Hill Striper Club’s conservation ethic in me, and has made me proud and excited to carry that ethic to future generations of High Hill Members.
On the beach, High Hill members continue to pride themselves on their conservation-minded ethic by practicing “Catch and Release.” In 2002, the club captured first place in the New York Surf Fishing Contest “Release Points” category (with 10,381 points); over 3 times the total of the club which placed second with 3,275 points. Furthermore, members utilize the utmost care when handling fish to be released and refrain from the use of equipment which may be detrimental to fish survival. It is without a doubt that this behavior is exemplary for other surf fisherman to observe, respect and adopt as their own.
Fred Schwab, Mattituck, NY September 11, 2003
Anne Lange, Chief
State/Federal Fisheries Division
Office of Sustainable Fisheries
National Marine Fisheries Service
1315 East West Highway, Room 13317
Silver Spring, MD 20910RE: Proposed Rulemaking-Striped Bass Regulations for Exclusive Economic Zone (EEZ)
Dear Ms. Lange;
The undersigned has never mastered the art of brevity, particularly when a proposed action is inadvisable. Having said that I and those whom I speak for are opposed to any form of a reopening of a striped bass fishery in the EEZ.
The NOTICE of PROPOSED RULE MAKING for the EEZ states that it is “…..in response to recommendations from the Atlantic STATES Marine Fisheries Commission…”. Please note the emphasis placed on the word STATES. The fact of the matter is that the States did not vote in favor of change, 5 opposed, 4 favored, 3 null votes and 1 abstention. Thus the Notice conveys inaccurate information inasmuch as the votes cast by the 2 Federal agencies, the NMFS and the Fish and Wildlife Service, altered the outcome and thus the position taken by the voting States.
In the process of adopting Amendment 6 to the Striped Bass Management Plan the ASMFC’s Striped Bass Board had to take action on a number of specific issues contained therein. Relative to fishing mortality the more, if not most significant of theses were Allocation, Fishing Mortality Target and the question of the EEZ.
Because fishing effort and the availability and therefore likelihood of catching striped bass is both unpredictable and largely uncontrollable the “collective impact of those three factors on fishing mortality is unknown. But the Board chose to increase allocation, not implement a significantly conservative fishing mortality target and with the two votes cast by the services, to seek a reopening of the EEZ. In addition, the Board approved increases in the commercial allocation for Massachusetts and the recreational bag limits for that state and New Hampshire. From a collective standpoint those five actions were glaringly unwise choices.
The Board’s actions were taken despite the fact that there is not and, for at least several more years, will not be hard or even moderately soft data on the magnitude of commercial discard mortalities within state or federal waters, and of course what would occur were targeting of striped bass in part or all of the EEZ legitimized. On that last point, to state the obvious, advanced data pertaining to the EEZ would not and could not be reliable since the degree of targeting effort on striped bass would be subject to unknown shifts in fishing effort and user behavior by both user groups.
Whatsmore, eliminating or even easing the prohibition on the possession of striped bass in the EEZ will increase discard mortality as a result of the known practice of “high grading” and in all likelihood result in an increase in unrecorded landings and the black marketing of striped bass flesh. Those practices are not controlled through specific quotas!
A partial or even total reopening of the EEZ rises, as the NMFS 2/1/02 letter to the ASMFC points out, a very complex problem in terms of enforcement and it’s impact on effective management.
Another factor which must not be overlooked and which the NMFS speaks of under issue 3 of that 2/1/02 letter is the question of mortality on older/larger fish were the EEZ reopened. Expanding the age/size distribution of striped bass was an often-repeated topic of discussion prior to and throughout the development of Amendment 6. In fact, under the heading of Goals and Objectives Amendment 6 contains the following objective, “Establish a Fishing Mortality Target that will result in a net increase in the abundance (#) of age 15 and older striped bass in the population…..”.
In adopting Amendment 6 the ASMFC implements a Fishing Mortality Target of F=0.30 which is essentially status quo it having been F=0.31. The Board felt that over time at F=0.30 the abundance of age 15 and older fish in the population would increase. Over time that “might” have been the case but in the opinion of many the increasing pressure on this fishery resource and a reopening of part or all of the EEZ places that viewpoint under the category of extremely unsound reasoning.
A reopening of the EEZ will result in a totally unknown increase in fishing mortality on older/larger striped bass.
With respect to the age/size structure having not expanded to that seen in the past one might argue that growth takes time that the catch of some large striped bass, most notably from New York waters several weeks ago, its contradictory. A local fisherman publication has stated as much. (During the development of the original management plan (1978-1981) claims of there not being a problem were voiced whenever a notable catch occurred). Of course such events hardly qualify as being scientific evidence.
In this year’s case one must take into consideration the northeast cold and wet spring and early summer which probably did delay and alter the northward migration of some and perhaps many large fish which summer-over in New England waters. Colder than normal and fluctuating water temperatures and currents would also effect the abundance, movement and disbursement of prey species.
An analysis of public comment focused ion the EEZ question cannot and should not be ignored. Attachment number #1 is based on the ASMFC Summary Report distributed during the Board’s 12/19/02 meeting while Attachment #2 is the result of an exhaustive review of the well over 200 copies of letters and emails, also furnished during that meeting.
Regardless of which listing one chooses to review it is obvious that the votes for reopening of the EEZ by the two Board members states (NY &RI) dismissed the overwhelming opinion expressed by their constituency. With respect to the two (2) remain states which voted for a reopening (MA &NC) neither state could claim overwhelming public support for their vote and in this case of the Attachment (2) both states received public support by the very slimmest of margins.
Public input, whether voiced verbally or in written form, varies in terms of both detail and eloquence for that is the nature of human beings; we are not all the same. How one expresses their thoughts should not be the yardstick by which their opinion is measured. What is significant is that they have an opinion and are concerned enough to take time to attend and speak at a hearing or express their position in written form.
This July/August 2003 issue of the ASMFC’s by-montly publication “Fisheries Focus” states that “Public comment is a key part of the Commission’s fishery management process”. It also points out, and understandably so, that ASMFC Commissioner’s must reach decisions based on number of factors. One of those, which is, or should be, the most important is that Commissioner’s must act in the best interest of the resource.
That is as it should be, but reopening EEZ in part or totally does not translate into being “in the best interest of the resource”. On the contrary. Such change in the management of this resource, now or for several years to come, may and probably would jeopardize the process of building a healthy age structure and consequently the future well being of the coastal migratory stock.
Two final points relative to the input to the Striped Bass Board. During it’s 12/18/02 meeting the ASMFC’s Striped Bass Advisory Panel restated, for at least the third time through the years, strong opposition to a reopening of EEZ.Whatsmore, the ASMFC’s Law Enforcement Committee in reviewing both a partial and total reopening has expresses objection to such actions.
Having used and observed the use of this fishery for over 50 years it is my belief that is being more heavily exploited than ever before. During the years leading up to the collapse of the coastal migratory stock there were no commercial quotas, no recreational bag limits and no meaningful minimum size limits. Today those measures are in place along with “somewhat” more significant area and seasonal restrictions.
But we also have more fishermen and targeted fishing efforts on striped bass and in the case of Chesapeake Bay jurisdiction the maximum size limits of the past have been eliminated. Both user groups use more effective gear and techniques. Have the means to fish in areas rarely fished before, have fish finders and depth recorders and so on.
While it is understood that Amendment 6 allows for adjustments in management measures should stock assessments raise a red flag, such assessments are understandably not based on real time. Furthermore, the Board must evaluate the data and struggle to agree on what actions to take before the many involved jurisdictions go through their process of implementation. These various steps take time and it is not a stretch to say that close to 2 years can pass from the time that a problem began to the time full implementation of corrective or more conservative measures by all jurisdictions are in place. Add or include the time needed for the process of once again closing the EEZ should it be determined that it’s reopening had been a mistake.
The undersigned has served as a New York representative on the ASMFC’s Striped Bass Advisory Panel since it’s inception during 1994. And to the best of my knowledge, with the exception of just one Board member, I am the only present participant who can claim direct involvement; start to finish, in the development of the original Striped Bass Management Plan (1978-81). So I was on board at a time when species specific marine finfish management on a regional basis began and when this fishery was in steady decline and on the verge of total collapse.
The closure of the EEZ has been and continues to be a major contributor to the striped bass becoming, once again, a viable fishery and that closure should be continued to achieve the goal of full and hopefully sustained restoration.
Sincerely,
Fred Schwab
Member-ASMFC Striped Bass
Advisory panel