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							Letter from Paul Diodati Director of the Massachusetts Division of Marine Fisheries
and Response in bold blue text by Stripers Forever’s directors
 Dear:

 I appreciate your comments and concerns about the future of our fishery resources.
 Representatives of the Massachusetts Division of Marine Fisheries have been at the
 forefront of technical and policy issues related to Atlantic striped bass since 1982. We
 continue our leadership position today, as I chair the Atlantic States Marine Fisheries
 Commission’s Striped Bass Policy Board and a number of my staff serves in chief
 technical roles. These stocks were fully restored in 1995, and today, their recovery and
 sustainability is considered the most triumphant program in the history of fisheries
 management.

 We can all be happy that striped bass have recovered. Whether or not the
 recovery is being sustained, however, and just how much credit the Atlantic
 States Marine Fisheries Commission (ASMFC) deserves to take for the recovery –
 after allowing the striper to be fished into near oblivion to begin with - is a matter
 of considerable debate.

 In the past, advocates for striped bass game-fish status have not represented the
opinions of the hundreds of thousands of “main-stream” saltwater anglers that are
residents of Massachusetts.

Has Mr. Diodati conducted some sort of survey? We think he is confusing “main-
stream” with old school. While we know of no means to survey all anglers, we are
very confident that striped bass fishermen who support making this species a
game fish are very definitely in the main stream.

Prohibiting commercial harvest of striped bass in our state has been broached by three
public petitions and one attempt to make it a ballot question over the past 15 years.
None of these actions ever came close to being achieved.

 It took more than 100 years and a war to abolish slavery in the U.S. Not
 everything worth doing is quickly attainable. The Migratory Bird Treaty Act that
 prohibits the commercial harvest of our wild waterfowl is another good example
 of an important conservation law that required years of hard work before being
 enacted into law. Some states fought it to the last, including suing the federal
 government over the curtailment of market hunting, but they lost in court. The
 Massachusetts Division of Marine Fisheries (DMF) has for years fought the
 striped bass petitions and proposals referred to above, and Mr. Diodati continues
 to do so today.

 The Massachusetts fishery was established in colonial times and throughout its history
 managers have struggled to conscientiously sustain and sensibly allocate the
 resource. In 1945, Massachusetts passed a law banning net-harvest of stripers by
 making “hook and line” the only allowable gear type. By doing so, differences between
 commercial and recreational striped bass fishermen became blurred; although not all
 recreational fishermen were commercial fishermen, all commercial striper fishermen
 were recreational fishermen too. Conventional “party lines” cannot straightforwardly be
 drawn in our fishery.

 The distinction between recreational and commercial fishermen is like night and
 day. Recreational anglers are personal-use fishermen, which means they


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Letter from Paul Diodati Director of the Massachusetts Division of Marine Fisheries
and Response in bold blue text by Stripers Forever’s directors
 consume what they catch and/or practice catch-and-release angling;
 commercials fish for the market. It’s plain and simple -- nothing blurred here,
 except in Mr. Diodati’s view.

 “Sensibly allocating” the striped bass resource today means to some that the
 500,000-plus MA recreational anglers who fish for stripers take about 80 percent
 of the bass harvested in Commonwealth waters, while some 1,250 “commercial”
 fishermen have a quota that amounts to the other 20 percent. One quarter of one
 percent of the users getting 20 percent of the resource is anything but a sensible
 or fair allocation.

 Perhaps the number one factor defeating past attempts to ban commercial fishing here
 is that both commercial and recreational fisheries co-exist while striper populations
 continue to thrive.

 We think the number one factor in the defeat of past attempts to make striped
 bass a game fish in MA has been the fierce advocacy by the DMF to preserve the
 commercial striped bass fishery. The commercial fishery was continued in MA
 even during the moratorium years in Chesapeake Bay when some wondered if
 striped bass were going to become extinct. The DMF has consistently been pro-
 commercial on this issue and has never given fair consideration to game fish
 status for stripers.


     On this last point, current “poor” health of striped bass stocks has been cited by
 some as a reason to suspend commercial fishing, but there is no evidence that
 eliminating the commercial fishery would improve resource or recreational fishery
 conditions. While game-fish status for striped bass may result in some benefits, it’s
 difficult to argue that any such benefits would be biological given recreational fisheries
 are attributed the vast proportion of total fishing mortality; even without national game-
 fish status, recreational striped bass fisheries continue to expand, as evidenced by
 seasonal landings in Chesapeake Bay and off North Carolina. Nevertheless, today’s
 stock status under current fishing conditions show not only has adult stock size
 stabilized at very high levels of abundance, but major spawning areas persist in
 producing dominant year classes every few years pushing juvenile recruitment to
 spectacular levels.

 There is a lot to discuss here. By the measures used just last year by the
 ASMFC, large striped bass would now be considered dangerously overfished,
 and the spawning stock biomass far below the threshold level. But this year, by
 completely revamping the data used in their analyses, the ASMFC numbers have
 miraculously changed, and we are now “officially” only on the very verge of over
 fishing large stripers. Not all of Mr. Diodati’s counterparts on the ASMFC are as
 confident of the rosy scenario he paints. Read the report on the SF website
 regarding the November meeting of the ASMFC in NJ:
            http://www.stripersforever.org/Home/S006F4899
 006F48D5.0/2005%20stock%20status.doc.
  It is important also to realize that according to the government’s Marine
 Recreational Fishing Survey (MRFS), angler success coast wide for striped bass
 has declined by about 50 percent in the last six years.



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Letter from Paul Diodati Director of the Massachusetts Division of Marine Fisheries
and Response in bold blue text by Stripers Forever’s directors
Juvenile recruitment has been high, but research out of Chesapeake Bay indicates
that unprecedented numbers of these fish are not living to become part of the
coastal fishery. Additionally, the idea of bringing in large numbers of small fish
and then cutting down the population of larger ones like a field of wheat is a
tenant of the old maximum sustainable yield philosophy that has brought many
wild fish populations to their knees, so to speak. Unfortunately the DMF appears
to be mired in this philosophy. Check out this sentence from the DMF’s own
recent press release issued on December 30, 2005:
 “ TO ALL INTERESTED IN STATE WATERS MANAGEMENT OF GULF OF MAINE
COD: The Massachusetts Division of Marine Fisheries has provided greater
protection for what it considers the last vestige of the Gulf of Maine cod stock…”

 In fact, striped bass stocks have become so robust over the past decade that many
 Atlantic coast scientists fear the abundance of stripers (as apex predators) has
 significantly altered trophic levels and reduces our ability to ecologically succeed at
 multispecies management. I’ve attached the link to the most recent press release from
 the Atlantic States Marine Fisheries Commission that details current stock status.
 http://www.asmfc.org/press_releases/2005/pr27StripedBassStockAssmt.pdf

 Rather than blame the true culprits of over fishing and environmental
 degradation for decreased fish populations, it is very convenient to point to one
 of the few species not in serious trouble, especially if it is one that has a (very)
 small commercial fishing component to protect. Are we expected to believe that
 today’s striped bass population (which according to the Stripers Forever annual
 fishing survey is no where near as abundant as some would claim) is any
 replacement for the huge bluefish populations of 20 years ago, or the now
 virtually extinct inshore stocks of cod, pollock, whiting, tuna and black back
 flounder?

 One of the effects of the ASMFC’s self-serving fishery propaganda is to dumb
 down newer anglers. No veteran striper fisherman would compare today’s
 population of large fish to that of 40 years ago. Soon there will be few fishermen
 remaining who remember this, and we can’t help but wonder if that isn’t part of
 the strategy.

     Some people have tried to formulate an economic argument by comparing the
 economic valuation of our recreational fishery to that of our commercial fishery, but their
 work is flawed and not informative. For instance, comparing harvest values between
 fisheries, when one is regulated only by daily creel limits and the other by quotas and
 closed seasons, makes no sense. Likewise to suggest that value of a commercial
 fishery and public policy to conduct one is based on the amount earned by those
 permitted to commercially fish without consideration given to the retail, restaurant and
 other market and cultural opportunities afforded the non-fishing public, is short-sighted.

 It seems very clear that Mr. Diodati either hasn’t read or simply wants to discredit
 the factually important findings of the Southwick Report. Rob Southwick is a
 highly respected professional expert in his field. He regularly does this kind of
 work for the federal and state governments, and for a wide variety of equally
 sophisticated clients. Nor is this the first time that Rob has written about striped
 bass; he has authored a similar but less comprehensive study for the American
 Sportfishing Institute in the mid 1990’s. Anyone who reads the current Southwick


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Letter from Paul Diodati Director of the Massachusetts Division of Marine Fisheries
and Response in bold blue text by Stripers Forever’s directors
 Report will see that Rob carefully documents marketing and cultural
 considerations in his research. Frankly, Mr. Diodati’s comments above are
 nothing short of irresponsible.

 The Southwick Report even breaks down the value of the commercial vs.
 recreational fishery in Massachusetts on a per pound basis as opposed to a total
 fishery basis. With all commercial multipliers taken into account – and these
 generally favor commercial fishing statistics – striped bass are worth $236.86 per
 pound if allocated to the recreational fishery and only $22.97 a pound, or one
 tenth as much, if given to the commercial fishery. So giving a greater share to
 commercial fishermen would not help anything; it would, in fact, only hurt us
 more economically.

 One area that Mr. Diodati fails to discuss is the need for aquaculture to provide
 seafood for an expanding populace on a year-round basis. The production of
 hybrid striped bass raised through aquaculture, while already larger than the wild
 fishery, could be even more significant, were it not for the disincentive of
 seasonally cheap wild fish. And as Southwick reports, those are savings that
 never get passed on to the consumer.

 Does Mr. Diodati think that providing a few meals of wild striped bass is more
 culturally valuable than letting recreational fishermen harvest fish for their own
 consumption? The 28-inch minimum size for anglers in MA effectively prohibits
 a very large segment of the recreational community who fish near shore from
 ever keeping a prime size eating fish for dinner. This was historically a public
 fishery, and it has been virtually eliminated in MA in order to give a comparative
 handful of pinhookers a five-week season to beat the devil out of the breeding
 size fish summering here. It is a ridiculous policy economically, socially, and in
 terms of its conservation ramifications.



     Lastly, recreational trade journals and magazines, bait and tackle shops, guide and
 charter services, small-boat sales, and numerous other industry sectors have all
 flourished over the past decade and continue to do well because of striped bass, while
 a small but tightly managed commercial fishery has been allowed. In closing, I’m
 available to answer any questions you may have about managing striped bass or any of
 our other fisheries, but please understand that I don’t speak (or listen) as a citizen, I do
 so as a natural resource manager. This means I listen to all sides of public debate,
 review and evaluate all the science, and consider the true economic factors to base my
 decisions.

 If that is the case Mr. Diodati, how about undertaking an open-minded evaluation
 of a proposal to make striped bass a game fish in MA?

 Best Regards,



 Paul Diodati,
 Director............................................................................................................


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Letter from Paul Diodati Director of the Massachusetts Division of Marine Fisheries
and Response in bold blue text by Stripers Forever’s directors




                                      Paul Diodati

                                        Director

                       Massachusetts Division of Marine Fisheries

                             251 Causeway Street, Suite 400

                             Boston, Massachusetts 02114

                                     617.626.1530

                                  617.626.1509 FAX




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