CCA Recommendations for 2021 Striped Bass Season

CCA Maryland Comments to Striped Bass Regulatory Actions for 2021 Season 

Via email to: fisheriespubliccomment.dnr@maryland.gov

RE: Proposed striped bass fishery closure dates & targeting definition

Coastal Conservation Association Maryland (CCA Maryland), is a state chapter of Coastal Conservation Association (CCA), a nationwide non-profit, and the largest saltwater recreational fishing organization in the country. As anglers, and avid users of our natural resources, CCA Maryland members work hard to promote sensible science-based management measures to support sustainable fisheries for the benefit of the general public, and the long-term health of the Chesapeake Bay.
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We believe the department’s choice to divide the recreational fishing sector into two groups, and place the majority of the conservation burden on the private recreational fishery undermines the likely success of actions taken to reduce fishing mortality and disregards intent of Maryland natural resource law.

Maria Meinke

 

NR- 4-215 states:*

(c) (1) Conservation and management measures adopted under a fishery management plan, to the extent possible:

(i) Shall prevent overfishing while attempting to achieve the best and most efficient utilization of the State’s fishery resources;

(ii) Shall be based on the best information available;

(iii) May not discriminate unfairly among groups of fishermen or have economic allocation as its sole purpose;

(2) If it becomes necessary to allocate or assign fishing privileges among various groups of individuals under paragraph (1)(iii) of this subsection, or under any fishery management plan, that allocation shall be:

(i) Fair and equitable to all individuals;

(ii) Reasonably calculated to promote conservation; and

(iii) Carried out in such a manner that no particular individual, corporation, or other entity acquires an excessive share of such privileges.

Sara Salt

Lofty goals, not easily defined. Leaves the coms and recs plenty to squabble over.

Existing & Proposed Season Closures

Summary: CCA Maryland continues to support a one-fish @ 18” limit for the full recreational fishery with no seasonal changes. Based on the 2017 season and guidance from the Technical Committee and Law Enforcement Committee of ASMFC. Based on anecdotal evidence from the 2020 closure and air temperature and water temperature data, the proposed closure of July 16-31 is the most likely to achieve any conservation gains or reductions in striped bass mortality.
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CCA Maryland has concerns over the enforceability of the current summer closure provision. Anecdotal accounts from the 2020 closed period directly reflect the concerns shared by the Law Enforcement Committee(LEC) of the ASMFC.

The following language is copied from the LEC memo to the Striped Bass Management Board during the addendum VI implementation process:

“In general, voluntary compliance for the casual or infrequent angler (the most common type) is tied to regulatory simplicity; more complex regulations become more difficult to enforce and increases the likelihood of violations.

Happy Payne

The limit was one fish 19" this year, and I expect that to continue.

Absent a definition of “targeting,” including provisions for gear type, tackle and bait) it is impossible to enforce this measure. This may be particularly difficult to define when anglers use the same (or similar) fishing methods to target species other than striped bass (e.g., bluefish). Officers may not prioritize enforcement of certain FMP regulations if they know it is not enforceable and will not stand in court.

When there are multiple closures within a fishing year, fishermen are often caught off guard which can lead to unintentional violations. When establishing season closures, have them in place for several years. If closures change year-to-year, the likelihood of unintentional violations increases. Education takes time to set in.

Enforcement is not an issue, but compliance in closely adjoining states would be greatly enhanced if the regulations are consistent. Different regulations between two neighboring states (e.g., NY and CT) presents special enforcement challenges, and are often confusing to anglers. Inconsistent seasons poses a problem between neighboring states (e.g. NY and NJ), especially when fishermen unintentionally pass into another states waters. Consistency of regulations for shared water bodies is important for enforcement, e.g. consistency within the Chesapeake Bay among the jurisdictions of MD, VA, PRFC and DC would greatly enhance enforceability and compliance.”

For the reasons noted by the LEC, CCA Maryland supports the current proposal to better define targeting, but has concerns that a simple change in definition will have any measurable conservation benefits or support meaningful changes in angler behavior. Without broad communications done in partnership with fishing and boating industry stakeholders and partners, and in multiple languages, future regulatory closures may continue to fail to meet the on-water conservation goals and continue to create enforcement challenges for Maryland’s Natural Resources Police.

Targeting is tough to enforce. We catch Stripers, Blues, Speckled Trout, Redfish and White Perch all on similar tackle in overlapping places. 

Over all, it seems reasonable to me.