Sent October 3, 2025 via electronic mail to: comments@asmfc.org
Emilie Franke – FMP Coordinator
Atlantic States Marine Fisheries Commission
1050 N. Highland St. Suite 200A-N
Arlington, VA 22201
Ms. Franke,
Save The Bay, on behalf of our members and supporters, is writing to submit comments regarding the Atlantic States Marine Fisheries Commission (ASMFC) Draft Addendum III to Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass.
Save The Bay – Narragansett Bay is a member-supported environmental advocacy non-profit 501(c)(3) in Rhode Island. Our mission of protecting and improving Narragansett Bay is accomplished through many aspects of our work including advocacy, habitat restoration and adaptation, and on-the-water experiential education. Our work helps to ensure that Narragansett Bay and all Rhode Island waters are clean, fishable, and swimmable for everyone to access in a safe way. One way that many citizens choose to access the waters of Rhode Island is through recreational and commercial fishing, especially for Rhode Island’s state fish, the Atlantic striped bass (Morone saxatilis). It is with the goals of attaining a better than 50% likelihood of rebuilding the stock by 2029, the long-term maintenance of a thriving striped bass population, and the continued ability for individuals to access this fishery that Save The Bay offers the following comments.
3.1 Method to Measure Total Length of a Striped Bass
As it pertains to proposed management change 3.1 “Method to Measure Total Length of a Striped Bass,” Save The Bay recommends to the Atlantic Striped Bass Management Board the adoption of Option B – Mandatory Elements for Total Length Definition.
As stated in the draft addendum, in the absence of clearly defined coastwide regulations defining methods for total length (TL) measurement, states, and often anglers, are left to make the decision as to how to measure a fish. This inconsistency in the regulation of method often leaves discretion to anglers as to whether to forcefully fan the tail to make the fish shorter, or pinch the tail to make it longer, can effectively allow harvest of striped bass that are either under or over the slot size limit, as defined by ASMFC, and adds unnecessary confusion and burden on enforcement.
For this reason, Save The Bay, in agreement with ASMFC’s Law Enforcement Committee, recommends the adoption of Option B, establishing mandatory and consistent coastwide elements to each state’s regulatory definition of striped bass total length measurement.
3.2 Commercial Tagging: Point of Tagging
As it pertains to proposed management change 3.2 “Commercial Tagging: Point of Tagging,” Save The Bay recommends to the Atlantic Striped Bass Management Board the adoption of Option B – Commercial Tagging At the Point of Harvest (POH).
As stated in Draft Addendum III, currently, only three states utilize a tagging program other than POH tagging (although North Carolina does not currently have a commercial striped bass fishery). Implementation of a coastwide program of POH tagging would therefore result in the fewest coastwide changes to tagging programs. Additionally, Save The Bay affirms that the commercial angler should be responsible for both tagging a removed fish and returning any unused tags at the end of the season/year. As noted in the minutes from the Law Enforcement Committee (LEC) March meeting, the LEC considers POH tagging to be more effective in resource protection also minimizes effort for law enforcement while increasing their ability to improve enforcement of possession from the total time the species is in possession, reduce the ability to high-grade, and increase accountability.
3.3 Maryland Chesapeake Bay Recreational Season Baseline
While Save The Bay represents users of the striped bass fishery in Rhode Island waters, we must acknowledge the migratory nature of the striped bass. For a species and fishery of this nature, which does not abide by state boundaries, and especially given the importance of the Chesapeake Bay to striped bass production, we consider it important to provide a recommendation for this proposed management change, despite it not pertaining directly to how our citizens use the fishery. Therefore, as it pertains to proposed management change 3.3 “Maryland Chesapeake Bay Recreational Season Baseline,” Save The Bay recommends to the Atlantic Striped Bass Management Board the adoption of Option C – New Chesapeake Bay Recreational Season Baseline Plus 10% Uncertainty Buffer.
Save The Bay supports the Chesapeake fishery’s ability to determine and restructure their baseline season, especially in this case which would reduce fishing effort during the warmest time of year with the highest level of catch and release mortality. However, given that all data to this point used to determine the likelihood of rebuilding by 2029 has included data from the Chesapeake’s current baseline season, Save The Bay recommends the inclusion of an uncertainty buffer with this new baseline, to provide a window of time to determine if the new baseline is indeed resulting in the desired effect. If the board were in the position to consider an uncertainty buffer of greater than 10%, this would be something Save The Bay would support, to provide strong protections for the fishery during a period of regulatory change.
3.4 Reduction in Fishery Removals to Support Stock Rebuilding
As it pertains to proposed management change 3.4 “Reduction in Fishery Removals to Support Stock Rebuilding,” Save The Bay recommends to the Atlantic Striped Bass Management Board the adoption of Option B – Even Sector Reductions: Commercial -12% and Recreational -12%.
As included in Draft Addendum III, “With the estimate of 2024 fishing mortality, the above assumptions about 2025-2029 fishing mortality under status quo management, and the same low recruitment assumption as the assessment, the projections estimate a 30% probability of being at or above the SSB target in 2029. This would require a 12% reduction in 2026 removals to achieve the level of fishing mortality that would result in a 50% probability of SSB being at or above the SSB target in 2029.” This means that the bare minimum considered necessary to reach just a 50% probability of rebuilding by 2029 would be a 12% reduction in
removals. For this reason, Save The Bay supports Option B, would be in opposition to a proposal of any less than 12% reductions, and would be in favor of reductions greater than 12% if the board were in a position to recommend such.
Regarding how the recreational reductions would be achieved, Save the Bay opposes O2 and CB2, which would each create exemptions for the for-hire sector. Save The Bay feels that the burden of reductions should be felt equally across all sectors which would also equally feel the benefits of these reductions should they prove successful. Save The Bay is then in support of O1 for the ocean fishery to attain a 12% reduction, and would defer to the recommendations of others in the fishery regarding the choice between CB1 and CB3 to attain a 12% reduction in the Chesapeake Bay fishery. Finally, Save The Bay would oppose any “No Targeting” closures as a method to meet the 12% reduction, as no targeting closures are difficult to enforce and unlikely to result in the desired reductions.
In conclusion, Save The Bay remains concerned regarding the striped bass fishery and its ability to recover to a greater than 50% likelihood of rebuilding by 2029, and will continue to be concerned beyond such time, given the decreased spawning success over the last seven years. While we believe that the options we have recommended above from those provided by ASMFC provide the greatest likelihood of recovery, we will continue to push for stronger regulations and enforcement of those regulations as it pertains to this fishery to ensure that it is a viable fishery across the coast and to anglers in Rhode Island, and this population is part of a thriving coastwide ecosystem for generations to come.
Sincerely,
Capt. Chris Dodge
Narragansett Baykeeper – Save The Bay
100 Save the Bay Dr.
Providence, RI 02905
(401) 272-3540 x116
cdodge@savebay.org
cc:
Jason McNamee PhD – ASMFC Striped Bass Board: RI Commissioner
David V.D. Borden – ASMFC Striped Bass Board: RI Commissioner
Senator Susan Sosnowski – ASMFC Striped Bass Board: RI Commissioner
Eric Reid – ASMFC Striped Bass Board: RI Commissioner (Proxy)