Fish Report 10/24/12 - Storm Waves

Fish Report 10/24/12 - Storm Waves

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Readers, Clients,

I know this email is too big -- but its a HUGE problem.

Closing sea bass is very bad problem.

I really think there's enough evidence here to assert MRIP does not qualify as science - any science.

I would far prefer to work with NOAA & NMFS to create real restoration instead of their paper-pretend..

Write!

Thank You.

Cheers,

Monty

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Sea Bass are now officially closed for the remainder of 2012..

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I had single days in 1991 where we caught 7000+ sea bass. There were no regulations. Everything that came over the rail went in a pail.

Its absolutely likely that just my boat landed more fish in a week of 1991 than MRIP claims All Maryland For-Hire caught in May & June of 2011..

I'm POSITIVE I once caught more sea bass in two days than MRIP says we caught in ALL of 2012 -- Now Overfishing; Season Closed!

We caught those fish at the very bottom, after decades of unlimited commercial and recreational pressure, after huge foreign factory trawlers had vacuumed our coast.

From the early 1990s to 2003 Del-Mar-Va anglers and commercial fishers alike would see the miracle of Fishery Management, of Surplus Production.

We Believed.

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Where are those Fish? Where are the hundreds & hundreds of thousands of sea bass we have not taken but once did? Why isn't our region absolutely chock full of sea bass given the incredible reduction in effort and fantastic increase in regulation?

Catch Restriction does not offer stand alone management policy!

We see our sea bass fishery squandered by management, stolen by bad data -- A Coastwide Plan That Can Never Really Work Until Divided Into Habitat Based Eco-Regional Spawning Sub-Populations.

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MRIP has Failed.

Now Accountability Measures are going to destroy whole fisheries if swift action is not taken.
Ecology, Philopatry & Biology -- NMFS can go line a bird cage with their estimates.

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Greetings All,

Today's concern is whether NMFS can justify its emergency closure of black sea bass based on MRIP's assertions of overfishing.

I believe the new recreational catch estimating system, MRIP, is worse than MRFSS. (Marine Recreational Fishing Statistics Survey) I believe if management holds course it will completely destroy some existing recreational reef-fishing businesses, my own included.

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Because the single most vital element of "Science" is testability -- provability -- here science is as the Missourian's "Show Me" writ large -- It is simple to assert our catch data, even the latest & greatest, is not science at all. It is merely a loose guide for management.

Among far too many data sets available for measure of absurdity, the Wave 2 NJ Tautog Shore Mode of 2010 is among the easiest.

Fact: Where MRFSS asserts there were 44,700 tautog caught from NJ's shore in Mar/Apr (wave 2) in all the years from 1981 to 2009 combined --and that includes the then outlandish spike of 20,000 from 1987-- MRFSS then asserts these same anglers who caught 45,000 tog over 28 years then caught 72,000 tautog just in Mar/Apr 2010 followed immediately by zero catch in 2011.

This is only 5000 less fish in one two-month period than Party/Charter (aka For-Hire) caught over the species entire range for the entire year.

Incredibly, it represents 2X as many pounds of tautog as All Atlantic Coast For-Hire Caught - those jetty fish were JUMBOS compared to our offshore fish - It also means these shore fishers (who honestly were pushing the season & praying for a bite--any bite--in March & early April) It means these shore fishers caught more pounds in two late winter months than New Jersey's commercial fishers caught in all of the previous FIVE YEARS -- This shore-side catch represented to be "Our Best Available Science" proves they had 75,000 more pounds than all Mid-Atlantic Commercial Effort For All Of 2010..

Who In Billy Blue Blazes Would Ever Believe This Absurd Assertion?
How Did This Slip Through??

Overestimates like this are why Congress mandated a new recreational catch estimating system be ready by 2009..

But Wait!
MRIP - Our "New & Improved" Recreational Catch Estimating System is now here to steady our Coast's Fishery Restoration Philosophy with firmer guidance.

MRIP claims to know these shore-bound anglers caught, not 72,000 tautog, but instead caught One Hundred Seventy Three Thousand -- 173,000 tautog.

That's more than Party/Charter caught in all of 2010, 2011 & 2012 combined. That's more pounds of tog, at 483,000 lbs, than the NJ commercial harvest for the last decade--Combined.

Who, exactly, is calling this "science."

Is this why the National Academy of Sciences blasted the MRFSS? To make it WORSE?

Is this what Congress intended with the 2006 Magnusson re-write?

I hope not.
MRIP's recreational catch estimates stink to high-heaven

and are about to be used to destroy what's left of the Mid-Atlantic's recreational sea bass fishery.

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Fact: It is a simple matter to identify 2 or 3 separate two-month spikes in catch (almost always occurring in the private boat mode) that have driven sea bass regulations since 1998 - That in these individual sets of wave data are the cause of management's finding recreational fishers "over quota."

The for-hire data appears to be better, perhaps owing to professionals filling out VTRs (vessel trip reports) although there remain fantastic allegations of catch & also inexplicable omissions where catch is asserted to be zero--yet VTRs were submitted showing accurate catch amounts. (see MD For-Hire Wave 3, 2010 & Wave 4, 2012.. VTRs were submitted showing catch - fair amounts of catch. Official MRIP Estimate of MD For-Hire Catch = Zero)

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I believe the entire period beginning with Dr. Kurkul's closure on October 5th, 2009 is a result of bad data.

I believe catch estimate data has so run away from reality that genuine science has no voice. Biology, especially regarding age at maturity; Philopatry's study of spawning site fidelity, and Ecology--where even the perfectly obvious need of reef fish to require reef has yet to enter management's consideration: None are included in today sea bass management plan.

A student of even our most modern data--our MRIP data--must conclude "recreational effort is difficult to predict" otherwise no possible sense can be made of it.

Here, for example, is NJ's Private Boat, Wave 4, (July & August) from 2006 to present: George & Lucy had their kids down for 3 weekends; Pat & Donald were more serious..

CAUTION: Readers susceptible to seasickness should take a Dramamine and wait one hour before reading this data set.

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NJ Private Boat - Wave 4 - Sea Bass Kept - MRIP

Estimate Status	Year	Wave	Common Name	Total Harvest (A+B1)	PSE
FINAL	2006	JULY/AUGUST	BLACK SEA BASS	24,148	51.0
FINAL	2007	JULY/AUGUST	BLACK SEA BASS	151,353	42.1
FINAL	2008	JULY/AUGUST	BLACK SEA BASS	14,330	52.3
FINAL	2009	JULY/AUGUST	BLACK SEA BASS	194,790	41.6
FINAL	2010	JULY/AUGUST	BLACK SEA BASS	82,521	37.7
FINAL	2011	JULY/AUGUST	BLACK SEA BASS	17,435	45.4
PRELIMINARY	2012	JULY/AUGUST	BLACK SEA BASS	120,295	39.0

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Wow. That's some highly suspicious "science."

Looks an awful lot like the NJ tog WAGuesstimate.

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Here again with fantastic increases in catch are Massachusetts's Private Boat Estimates.

Massachusetts - Wave 3 - Sea Bass Kept - Private Boat

Estimate Status	Year	Wave	Common Name	Total Harvest (A+B1)	PSE
FINAL	2007	MAY/JUNE	BLACK SEA BASS	30,335	79.2
FINAL	2008	MAY/JUNE	BLACK SEA BASS	54,678	65.6
FINAL	2009	MAY/JUNE	BLACK SEA BASS	34,493	51.3
FINAL	2010	MAY/JUNE	BLACK SEA BASS	448,181	68.6
FINAL	2011	MAY/JUNE	BLACK SEA BASS	77,397	42.9
PRELIMINARY	2012	MAY/JUNE	BLACK SEA BASS	275,657	34.5

Interesting. These guys aren't really sure if they want to keep pounding on sea bass..

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Every once in a while a For-Hire estimate gets a flyer - like in 2012 here.

Notice also that MA's private boats outfished the professionals by 400,000 cbass in 2010 - a large part of that year's "Overfishing" - that while scarcely keeping pace the year before..

Massachusetts, Wave 3, For-Hire, BSB Kept

Estimate Status	Year	Wave	Common Name	Total Harvest (A+B1)	PSE
FINAL	2006	MAY/JUNE	BLACK SEA BASS	25,692	66.5
FINAL	2007	MAY/JUNE	BLACK SEA BASS	12,594	60.0
FINAL	2008	MAY/JUNE	BLACK SEA BASS	62,529	84.7
FINAL	2009	MAY/JUNE	BLACK SEA BASS	39,291	38.0
FINAL	2010	MAY/JUNE	BLACK SEA BASS	41,088	31.2
FINAL	2011	MAY/JUNE	BLACK SEA BASS	15,503	35.4
PRELIMINARY	2012	MAY/JUNE	BLACK SEA BASS	119,828	34.7

At 2.1 pounds apiece, MA Private Boat sea bass accounted 566,000 pounds. Now, if we remove MA For Hire's spike, that's almost exactly 180,000 more pounds of sea bass than the entire Atlantic Coast's For-Hire catch. These Grady Whites & Boston Whalers -- primarily below Cape Cod -- have managed to outfish the entire East Coast's Party/Charter Fleet..

That strikes me as a fantastic assertion.

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Then, after a truly unbelievable spring, MA private boaters seem to have so-filled themselves of sea bass that, even though 2012 state regs doubled their creel limit in July & August, they appear to have nearly quit altogether.

Pretty amazing considering For-Hire catch in this wave is shown as their highest ever. At 106,000 cbass - its more than any previous 4 year period combined..

Here "Angler Effort Is Difficult To Predict" theorists are shown to be absolutely right - who could guess these anglers would just run out of gas; Or is this actually a good estimate and 2010 is fantasy?

What science can we turn to? Where is the truth here?

Will NMFS bankrupt my industry with NJ tog estimates?

MA - Private Boat - Wave 4 - BSB Kept

Estimate Status	Year	Wave	Common Name	Total Harvest (A+B1)	PSE
FINAL	2006	JULY/AUGUST	BLACK SEA BASS	29,425	47.3
FINAL	2007	JULY/AUGUST	BLACK SEA BASS	9,006	68.7
FINAL	2008	JULY/AUGUST	BLACK SEA BASS	21,213	76.4
FINAL	2009	JULY/AUGUST	BLACK SEA BASS	270,460	34.7
FINAL	2010	JULY/AUGUST	BLACK SEA BASS	121,481	56.2
FINAL	2011	JULY/AUGUST	BLACK SEA BASS	36,704	39.4
PRELIMINARY	2012	JULY/AUGUST	BLACK SEA BASS	7,594	68.2

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Rhode Island - Wave 4 - Private Boat - BSB Kept (Dramamine still working?)

Estimate Status	Year	Wave	Common Name	Total Harvest (A+B1)	PSE
FINAL	2006	JULY/AUGUST	BLACK SEA BASS	11,026	43.4
FINAL	2007	JULY/AUGUST	BLACK SEA BASS	3,184	54.4
FINAL	2008	JULY/AUGUST	BLACK SEA BASS	7,199	68.6
FINAL	2009	JULY/AUGUST	BLACK SEA BASS	17,869	46.5
FINAL	2010	JULY/AUGUST	BLACK SEA BASS	96,932	34.6
FINAL	2011	JULY/AUGUST	BLACK SEA BASS	8,871	57.7
PRELIMINARY	2012	JULY/AUGUST	BLACK SEA BASS	42,430	27.9

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And CT's For-Hire Party/Charter estimate in wave 4 -- LI Sound not so hot?

Estimate Status	Year	Wave	Common Name	Total Harvest (A+B1)	PSE
FINAL	2007	JULY/AUGUST	BLACK SEA BASS	226	104.3
FINAL	2009	JULY/AUGUST	BLACK SEA BASS	0	.
FINAL	2010	JULY/AUGUST	BLACK SEA BASS	1,058	76.0
FINAL	2011	JULY/AUGUST	BLACK SEA BASS	21	95.3
PRELIMINARY	2012	JULY/AUGUST	BLACK SEA BASS	0	.

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Yet CT's private boaters smoked 'em this year - Really?

Estimate Status	Year	Wave	Common Name	Total Harvest (A+B1)	PSE
FINAL	2006	JULY/AUGUST	BLACK SEA BASS	3,392	100.9
FINAL	2007	JULY/AUGUST	BLACK SEA BASS	1,150	101.4
FINAL	2008	JULY/AUGUST	BLACK SEA BASS	57,983	80.8
FINAL	2009	JULY/AUGUST	BLACK SEA BASS	0	.
FINAL	2010	JULY/AUGUST	BLACK SEA BASS	9,884	47.4
FINAL	2011	JULY/AUGUST	BLACK SEA BASS	3,092	75.1
PRELIMINARY	2012	JULY/AUGUST	BLACK SEA BASS	86,582	65.9

At 2.25 pounds apiece, these Connecticut private boats caught 200,000 pounds of sea bass in 2012 while their For-Hire fleet never had a sniff -- Zero CT For-Hire Catch..

Similarly, RI's For-Hire guys eked out about 10,000 pounds while their Private Boats were pushing 6 digits.

Below you'll see NY's Private Boats with 130,000 cbass @ 1.9 pounds each for 242,000 pounds of catch while their For-Hire fleet had 49,000 cbass with a weight of 63,000 pounds @ 1.3 pounds per fish.

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New York - Wave 4 - Private Boat - Another Sharp Increase while their fishery is reported as constant in May/June..

Estimate Status	Year	Wave	Common Name	Total Harvest (A+B1)	PSE
FINAL	2006	JULY/AUGUST	BLACK SEA BASS	38,508	43.8
FINAL	2007	JULY/AUGUST	BLACK SEA BASS	37,686	55.8
FINAL	2008	JULY/AUGUST	BLACK SEA BASS	39,834	51.2
FINAL	2009	JULY/AUGUST	BLACK SEA BASS	183,775	59.7
FINAL	2010	JULY/AUGUST	BLACK SEA BASS	83,513	48.7
FINAL	2011	JULY/AUGUST	BLACK SEA BASS	53,740	52.5
PRELIMINARY	2012	JULY/AUGUST	BLACK SEA BASS	129,441	57.7

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Different View: Here's NY's For Hire - All Wave/Annual Catch (if you're sweating and have excess saliva quit reading, look out at the horizon, and have a ginger candy)

Estimate Status	Year	Common Name	Total Harvest (A+B1)	PSE
FINAL	2006	BLACK SEA BASS	73,056	38.3
FINAL	2007	BLACK SEA BASS	294,287	11.8
FINAL	2008	BLACK SEA BASS	61,507	30.8
FINAL	2009	BLACK SEA BASS	104,620	23.9
FINAL	2010	BLACK SEA BASS	133,142	36.9
FINAL	2011	BLACK SEA BASS	64,820	34.4
PRELIMINARY	2012	BLACK SEA BASS	74,076	27.7

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And NY's Annual Private Boat Catch -- Note the guys who go every day caught incredibly in 2007 while private boats caught fewer. Then, from 2008 on, private boats managed to keep the bite a secret catching 3 to 4X more..

Estimate Status	Year	Common Name	Total Harvest (A+B1)	PSE
FINAL	2006	BLACK SEA BASS	148,765	27.9
FINAL	2007	BLACK SEA BASS	115,410	29.1
FINAL	2008	BLACK SEA BASS	191,862	36.2
FINAL	2009	BLACK SEA BASS	455,680	32.8
FINAL	2010	BLACK SEA BASS	405,479	29.6
FINAL	2011	BLACK SEA BASS	209,653	32.4
PRELIMINARY	2012	BLACK SEA BASS	160,759	48.1

No Really - This data set demonstrates what we actually got by waiting an extra 3 years for MRIP's "New & Improved" catch estimates. Just New Jersey..

Estimate Status	Year	Wave	Common Name	Fishing Mode	Total Harvest (A+B1)	PSE
FINAL	2010	SEPTEMBER/OCTOBER	BLACK SEA BASS	SHORE	0	.
FINAL	2010	SEPTEMBER/OCTOBER	BLACK SEA BASS	PARTY BOAT	16,910	43.6
FINAL	2010	SEPTEMBER/OCTOBER	BLACK SEA BASS	CHARTER BOAT	4,248	50.6
FINAL	2010	SEPTEMBER/OCTOBER	BLACK SEA BASS	PRIVATE/RENTAL BOAT	392,432	47.6

Awful nice of those Party/Charter skippers up there to be kind to sea bass while private boats were raining lead on the reefs...

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For those still reading - Thank You.

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Some History

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Below is a data set that almost encompasses my black sea bass career in MD's party boat trade.

In it, viewed with great skepticism as to absolute accuracy, one can see the result of early regulation compared to later regulation. Yes, the 1991 number is somewhat off. I carried thousands of clients aboard a brand-new, very fast party boat that year. The official estimate is 413 sea bass for May/June. I'm sure I had numerous clients catch 100 a-piece: That four hundred fish total is grossly underreported.

The following year, 1992, I was allowed by the Nichols Family to put a 9 inch size limit on their boat. While some applauded, many clients left for other boats.

Again, if you take the data at face value there's little to go by, but fishing was getting a lot better for us with just that 1992 nine inch limit.

In 1996 the nine inch limit became federal policy too. But, as I recall, because of a loophole in announcing new regulations in the Federal Register, no one worried with it until 1997.

The MRFSS survey that year, 1997, had NJ's Party/Charter catch at an astronomical amount of 1.8 million sea bass in Sept/Oct -- Overfishing By Statistic Was Begun.

A "Coastwide" management plan, we paid for it with an increased size limit--10 inches--in 1998 and a two week closure in August.

Encumbered only by a 1 inch size limit increase, NJ's Party/Charter fleet catch was estimated to have decreased from 1.8 million to 0.0068 million in 1998.

Looked like Bad Statistics to me.

When I complained about the data & the closure (but not the size increase, that was OK by me) I was told--in the federal register--to take my clients striped bass fishing.. (still can't do that because of the EEZ MPA)

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Despite MRFSS assertions of declining MD For-Hire catch, in 2001 I wrote I had "never seen fishing so good" -- this in a paper titled "On the Recent Improvements of Live Bottom Habitats in the DelMarVa Region of the Mid-Atlantic Bight" from January, 2001.

I really couldn't fathom why places I fished for sea bass were getting bigger -- Even one of NOAA's best ecologists hadn't envisioned sea whip as 'habitat' - he laughed at my claim this was new habitat.

With trawl pressure on summer flounder at an all time low and surf-clam pressure moving north, some bottoms expanded -- especially in the Old Grounds off DE/MD.

I had never dreamed sea bass fishing could be so good.

With only a ten inch limit and no creel, It would get better.

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In 2001 there was another closure, another overestimate: In 1999 NJ's combined sea bass landings were about 450K fish. In 2000 NJ was estimated to have caught 1.9 million, not the 0.45 million of the year before. Based on 2000's data, management again declared an overfishing situation in 2001 and raised the size limit coastwide to 11 inches with a closure from March 1st to May 10th -- And, for the first time, a 25 fish creel limit.

I applauded the creel limit, but those first 10 days of May cost us dearly.

That, unfortunately, would get much worse.

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Sea bass were again officially estimated to have been caught in too-great a number during 2001. It was the first year Massachusetts ever crossed the 100K mark. Their private boat catch now increased by 10X; in July & August 2001 Massachusetts' private boats "caught" more sea bass than they'd previously been estimated to catch from 1991 to 2001 combined -- more than a decade's catch added together..

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Estimates alone were always used to "prove" recreational effort remained unrestrained. Increased by one million fish from their 1999 estimate, NJ's Party/Charter catch of 1.4 million 'proved' we were "overfishing our quota" - the size limit was again raised in 2002, this time to 11.5 inches and the 25 fish creel limit kept in place.

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You should know management still believes the creel limit has no real effect. When they average the entire fishery; half day & inshore flounder boats as well as more dedicated full day sea bass party/charter, the average catch is somewhere below 1 fish per person, they believe that 0.4% of anglers catch more than 10 fish.

So far as they're concerned the creel limit is ineffective

..but in 2002 we were often counting client's fish. In 2003 we often had to count every single client's fish -- every day.

We'd get in early.

Fishing was incredible.

I had clients who threw back everything under 16 inches and would still catch a limit.

It was so incredible that sometimes even 4 hour boats would have clients limit-out..

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Management should ponder how the DelMarVa Region's sea bass exploded in population back then; How now--with far more restrictive regulation--we see a fantastically lower Catch Per Unit of Effort. (CPUE)

That we are accused of overfishing our region's stock is an assertion that can bear no scrutiny.

That this is a false assertion of misguided management, misguided only by bad data, is a case I hope I have made.

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Now The Fix. But first readers must accept basic tenets about the behavior & biology of Black Sea Bass.

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My crew & I have, over the years but especially in the mid-90s, tagged about 6 to 7 thousand sea bass with ALS. Our returns are the same as VIMS -- NJ's -- & two of Woods Hole's programs -- All these tag studies reveal homing/site fidelity in black sea bass.

The tag-return data is conclusive: Despite wintering sometimes far offshore, Black Sea Bass will return to the same summer spawning grounds come spring.

This is not questionable - its hard. That is how sea bass behave in the Mid-Atlantic.

No Virginia Cape cbass will wander to the MD/VA line nor a southern NJ fish ever stray to RI.
I've even had double headers of tagged fish that were marked a year earlier recaptured at exactly the same reef.

Not only is site fidelity regional, it comes down to reef by reef..

With thousands of tag returns to examine, its plain to see that if every single sea bass were caught and cooked above NY -- all of them-- we would see no variance in the DelMarVa population.

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Age at maturity too is crucial. When looked at in length each study shows sub-9 inch fish as having matured--as being actively engaged in spawning. I began a 9 inch limit in 1992 because I was told this was the best size: "All sea bass have spawned, some twice, by 9 inches."

From the 1996 Chesapeake Bay & Atlantic Coast Black Sea Bass Fishery Management Plan: Fifty percent of black sea bass are sexually mature at 7.7 inches Available at NSCEP by searching title.

From NOAA Technical Memorandum NMFS-NE-143, BSB EFH Source Document: 50% are mature at about 19 cm SL (7.5 inches) and 2-3 years of age (O'Brien et al. 1993).

Also from the EFH Source Document: In the South Atlantic Bight, Cupka et al. (1973) reported that both sexes mature at smaller sizes (14-18 cm SL) (5.5 to 7.1 inches).

Able & Fahay "The First Year in the Life of Estuarine Fishes" Pub 1998, citing Lavenda 1949, Mercer 1978 & Werner et al 1986: ..that matures first as female, then changes to a male at ages of 1 to 8 years:

In these and other works citing these studies, the confusion of age at maturity is evident. Where before we were shown " 50% are mature at about 19 cm SL (7.5 inches) and 2-3 years of age " we now know beyond any question that these already-matured fish would are barely age one. (See Gary Shepherd's "Probability of Age Key") In no way are 7.5 inch sea bass ever age two or three as often quoted - They are age one.

Where early FMPs (Fishery Management Plan) were focused somewhat on length; modern works look instead at ages quoted from the same studies thus skewing management's sense of Spawning Stock Biomass.

Where once we had incredibly numerous sea bass already transitioned by 9 inches - often 7.5 inches; Where once every single cbass outside the estuaries in summer was engaged in spawning: In 2012 we caught fewer than 12 sea bass exhibiting male coloration at 9 inches or less.

Any single client could have easily had that many from 1992 to 2000..

I have no doubt: Age At Maturity In The MAB Has Shifted From Age Zero/One to Age Three. Where once virtually every single sea bass in this marine region was actively engaged in spawning, now only a fraction of the population is.

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Habitat: I believe Reef Restoration Makes Fishery Restoration Simple. There would be no need to manage reef fisheries were there no reef.

I believe black sea bass production is primarily a function of habitat-cubed and SSB (Spawning Stock Biomass) but that is not an emergency for today..

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Back to landings..

In the chart below of Maryland For-Hire catch in May/June you can see the trend UP in the 90s. While you can't really see the peak (although its clear in VTRs) the first 25 fish creel limit and increasing size limits to 12 inches created a huge bulge in the stock.

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In hindsight, by 2003 it was apparent that age at maturity was shifting. There were fewer small male sea bass. I thought this was because we had to be very close to holding capacity -- That Our Reefs Simply Couldn't Hold Many More Sea Bass -- and this was a natural reaction on the fishes part to SLOW DOWN spawning production and not overpopulate their reefs. (many, many species exhibit shifting age at maturity - see especially T.Targett's work on sea trout)

After numerous fluke trawl bycatch incidents in late winter 2004, our spring catch contracted by half. (Gosh Sakes - It looks even worse in the data)

Miserable as it was, I had faith production would swiftly return as small sea bass must soon re-enter the spawning stock.

To this day that has not happened.
There must be visual cues or chemical pheromones which drive age at maturity..

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Management, not fishing pressure, has decelerated production to a minimum in this region. We need to lower size limits, and not too slowly. Management could force ALL sea bass into the spawning stock as once they were. But, with single-focus on catch estimate data, have instead allowed the black sea bass spawning stock to contract to just 3 year olds. Where once even many age-zero fish were spawning, now only fish legal for recreational catch are; Where once the entire marine population of sea bass was actively spawning, now only a fraction are.

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Based on a life-time of sea bass fishing, were I given 5 bargeloads of granite to deploy as artificial reef I would absolutely expect a large increase in our local sea bass population in under 3 years as new habitat was first colonized, then began to create its own natural production. How much of an increase would be based on age at maturity of fish present & habitat measured in cubic yard complexity. Habitat combined with spawning productivity should define the measure of management's expectation of sea bass population .

Of the many habitat ecologists at NOAA sidelined by current catch restriction-only fishery restoration theory: Perhaps NOAA should consider if these now-warming surface waters have done what I can only dream of: Not 5 bargeloads of boulder, but thousands upon thousands of newly available reef-acres to sea bass. Is an expanded Southern New England BSB habitat allowing Population Expansion? Is This Habitat Expansion Factored Into Management's Extraction Controls?

Or is NMFS billing us for fish never counted as inventory..

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With thousands of tag returns to consider, its plain that no amount of real or imagined overfishing in Southern New England could cause a decline in the DelMarVa stock..

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I had single days in 1991 where we caught 7000 sea bass. There were no regulations. Everything that came over the rail went in a pail.

Its absolutely likely that just my boat landed more fish in a week of 1991 than MRIP claims All Maryland For-Hire caught in May & June of 2011..

I'm POSITIVE I once caught more sea bass in two days than MRIP says we caught in ALL of 2012 -- Now Overfishing; Season Closed!

We caught those fish at the very bottom, after decades of unlimited commercial and recreational pressure, after huge foreign factory trawlers had vacuumed our coast.

From the early 1990s to 2003 Del-Mar-Va anglers and commercial fishers alike would see the miracle of Fishery Management, of Surplus Production.

We Believed.

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Where are those fish now? Where are the hundreds & hundreds of thousands of sea bass we have not taken but once did? Why isn't our region absolutely chock full of sea bass given the incredible reduction in effort and fantastic increase in regulation?

We see our sea bass fishery squandered by management, stolen by bad data -- A Coastwide Plan That Can Never Really Work Until Divided Into Habitat Based Eco-Regional Spawning Sub-Populations.

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MRIP has Failed.

Now Accountability Measures are going to destroy whole fisheries if swift action is not taken.
Ecology, Philopatry & Biology -- NMFS can go line a bird cage with their estimates.

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Last table below.

Thank You Again For Reading.

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Regards,

Monty

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Capt. Monty Hawkins
mhawkins@siteone.net
Party Boat "Morning Star"
Reservation Line 410 520 2076
http://www.morningstarfishing.com/

MD BSB For-Hire

Estimate Status	Year	Wave	Common Name	Total Harvest (A+B1)	PSE
FINAL	1981	MAY/JUNE	BLACK SEA BASS	79,037	49.8
FINAL	1983	MAY/JUNE	BLACK SEA BASS	19,539	33.5
FINAL	1984	MAY/JUNE	BLACK SEA BASS	38,607	41.5
FINAL	1985	MAY/JUNE	BLACK SEA BASS	14,427	48.0
FINAL	1986	MAY/JUNE	BLACK SEA BASS	41,259	53.5
FINAL	1987	MAY/JUNE	BLACK SEA BASS	55,722	28.6
FINAL	1988	MAY/JUNE	BLACK SEA BASS	116,444	46.2
FINAL	1989	MAY/JUNE	BLACK SEA BASS	2,429	57.2
FINAL	1990	MAY/JUNE	BLACK SEA BASS	72,729	31.2
FINAL	1991	MAY/JUNE	BLACK SEA BASS	413	100.0
FINAL	1992	MAY/JUNE	BLACK SEA BASS	81,166	35.7
FINAL	1993	MAY/JUNE	BLACK SEA BASS	137,318	34.4
FINAL	1994	MAY/JUNE	BLACK SEA BASS	123,173	31.3
FINAL	1995	MAY/JUNE	BLACK SEA BASS	174,986	30.0
FINAL	1996	MAY/JUNE	BLACK SEA BASS	87,723	34.1
FINAL	1997	MAY/JUNE	BLACK SEA BASS	149,806	30.2
FINAL	1998	MAY/JUNE	BLACK SEA BASS	254,096	33.9
FINAL	1999	MAY/JUNE	BLACK SEA BASS	3,763	71.6
FINAL	2001	MAY/JUNE	BLACK SEA BASS	20,355	31.1
FINAL	2002	MAY/JUNE	BLACK SEA BASS	50,905	47.1
FINAL	2003	MAY/JUNE	BLACK SEA BASS	100,869	25.6
FINAL	2004	MAY/JUNE	BLACK SEA BASS	6,156	80.3
FINAL	2005	MAY/JUNE	BLACK SEA BASS	30,637	37.8
FINAL	2006	MAY/JUNE	BLACK SEA BASS	67,521	23.5
FINAL	2007	MAY/JUNE	BLACK SEA BASS	25,525	30.8
FINAL	2008	MAY/JUNE	BLACK SEA BASS	16,652	21.7
FINAL	2009	MAY/JUNE	BLACK SEA BASS	19,170	37.3
FINAL	2010	MAY/JUNE	BLACK SEA BASS	0	.
FINAL	2011	MAY/JUNE	BLACK SEA BASS	14,521	42.4
PRELIMINARY	2012	MAY/JUNE	BLACK SEA BASS	8,943	63.1