Thursday, February 26, 2015

Regulatory Death Of Our Fisheries

Regulatory Death Of Our Fisheries - 2/26/15

Greetings All, 
We're experiencing the death of the sea bass fishery. It's happening now. 
We're also witness to the death of the red snapper fishery. 
Haddock, tautog, red grouper & even blueline tile: All will suffer a similar fate caused only by bad data. 

What I've written is true. Since 2009 we have been continuously robbed of more & more sea bass season. Today, and now with NOAA's brand-new catch estimating repair in place, MRIP's constant accusations of recreational Private Boats landing far-over quota is finishing our fisheries off piece by piece. 
Not just sea bass & red snapper, other fishery's catch-estimates run in mirror-like fashion. 
Shorter & shorter seasons, larger size limits with smaller bag limits; these are a result of management's firm belief recreational fishers have over-shot quota numerous times of late. 
In fact, based entirely on MRIP catch estimates, the federal red snapper season may only run for two days in 2015 - perhaps even just one day.

Is that NOAA's way of thanking red snapper fishers for building all that reef? 

Make no mistake, MRIP isn't just a little bit wrong; our new & fabulously expensive catch estimating program is incredibly wrong. Management uses MRIP's catch estimates, and those estimates alone, to determine whether the recreational sea bass & red snapper fisheries have "behaved" - have remained within quota. 

I absolutely guarantee and here intend to prove - The sea bass bass & red snapper fisheries, others too, are being stolen from recreational participants by bad MRIP estimates. 

I've asked many clients aboard my Maryland Atlantic Coast partyboat, the Morning Star, about their experience with the Massachusetts sea bass fishery, specifically: "How many private boats did you see while you were catching sea bass on a charter or partyboat in Massachusetts?" 
The answer is always - always - clients either saw very few Private Boats or none

But if MRIP's catch estimates are even remotely close to true there would have to be huge fleets of Private Boats catching sea bass. 
Consider the 2014 May/June MRIP catch-estimate of 207,800 sea bass caught by Massachusetts Private Boats in May/June vs 19,200 sea bass landed by Charters during the same period. As always of late, the private boat estimate represents a huge chunk of recreational quota. Whatever species MRIP claims has been "overfished," a little research will reveal insane levels of increasing Private Boat catch regardless of regulatory tightening ..while For-Hire catch factually declines under greater restriction. 

All Massachusetts Recreational Sea Bass Catch MRIP
Estimate StatusYearWaveCommon NameFishing ModeTotal Harvest (A+B1)PSEHarvest (A+B1) Total
Weight (lb)


I've asked & asked; even on Memorial Day Weekend no one I've spoken with, or corresponded with, has reported vast fleets of Private Boats fishing over Massachusetts's reefs. 
There's just no way around it, if MRIP estimates were even remotely correct then there would have be about 18 MA Private Boats fishing (& catching like crazy) for each MA Charter Boat fishing a reef. One charter boat, eighteen private boats. That's irrevocably how MRIP paints it. Only real boats can catch real fish. If the estimates are real---real enough to cripple the economic & biological vitality of the sea bass fishery---then where are these real fleets? 
Because weekends are the true pressure point for Private Boats, we should actually expect to see several hundred Private Boats wherever a small fleet of 3 or 4 Charters were fishing on a Saturday. 

Captain Willy Hatch of Falmouth, MA -- a skipper who knows where to find sea bass, writes: 
"I would say on the weekends here in Massachusetts the ratio of Private Boats to For-Hire boats is 50/50. On a really busy weekend might be more Private Boats bottom fishing. During the week For-Hire boats definitely outnumber Private Boats. Two other points is that often some of the Private Boats try to follow around the For-Hire boats because they might not know where to fish or where the bite is and might not be fishing on as productive bottom. Also generally on average, the number of anglers on a For-Hire boat outnumbers the Private Boats. I feel confident saying on average For-Hire boats are much more productive and efficient at catching fish than the average Private Boat. There are some extremely good private anglers, however, and an intercept of them at the dock might spike the numbers if not enough data is gathered." 

By testing an MRIP estimate against Party/Charter landings, we can see that in order to have REAL Private Boat catch that is truly far in excess of For-Hire catch, there must be, has to be, incredibly many more Private Boats out over their reefs. 
I'll write it again: Because weekends are the true pressure point for Private Boats, we should actually expect to see several hundred Private Boats wherever a small fleet of 3 or 4 Charters were fishing on a Saturday. 

NOAA says we can't prove the estimates are bad. They LIKE the estimates. "Gosh, we did a swell job!" 
Yet there's no way around it. For the above estimates to be plausible--in any way remotely close to accurate--there would have to be huge fleets of Private Boats every Saturday & sometimes even on weekdays. 
But, according to all witnesses, that's not what happened. 
It's much more likely that Massachusetts Party/Charter caught more sea bass than Private Boats. 
It's much more likely that MRIP's estimate is wildly incorrect.   

The Math. Take 19,200 bsb/5 anglers/8 fish = 480 Charter Trips -- Then take 207,800 bsb/3 anglers/8 fish = 8,658 Private Trips. 8,658 divided by 480 = 18 Private Boat trips {if they all limited out} per Charter trip. Since all those Private Boat trips do not happen regularly--because effort spikes on weekends while remaining more consistent for well-established charters, there would be roughly triple the Private Boat effort on any Saturday while Charter remained constant. So: 18 Private Boats as an average X 3.4 greater effort on Saturday = 61.2 private boats per-Charter. If just 3 Charters were on a Massachusetts reef, in order for MRIP to be correct there would have to be 180+ private boats catching there as well. 
If some guys are not limiting out, the number of Private Boats climbs much higher.  

If MA Party/Charter doubt their Private Boats even outfished them, then the idea that MA Private boats caught more sea bass than the whole US Party/Charter fleet in May & June of 2014 is laugh out loud silly.  
Except NOAA believes it. 
That's not so funny. 

MA Private Boats 
Estimate StatusYearWaveCommon NameTotal Harvest (A+B1)PSEHarvest (A+B1) Total
Weight (lb)
PSELandings (no.) without
Size Information
PRELIMINARY2014MAY/JUNEBLACK SEA BASS207,83642.3603,44244.20
All US Party/Charter
Estimate StatusYearWaveCommon NameTotal Harvest (A+B1)PSEHarvest (A+B1) Total
Weight (lb)
PSELandings (no.) without
Size Information
PRELIMINARY2014MAY/JUNEBLACK SEA BASS236,44727.6340,56026.20

Real regulation from catch estimates that aren't real creates really bad regulation. 
Plenty of really bad regulation lately. 
It's killing an industry.

In Connecticut over a period of 32 years, most with no regulations at all; between 1981 & 2013 Connecticut anglers landed about 127,000 sea bass total in Sept/Oct. 
That's 127,000 sea bass all combined & all added together over thirty-one fall periods. 
Now for 2014:
Estimate StatusYearWaveCommon NameFishing ModeTotal Harvest (A+B1)PSEHarvest (A+B1) Total
Weight (lb)
PSELandings (no.) without
Size Information

With an 8 fish limit in 2014, their tightest regulations in history, they catch 66,000 more fish than they have, all together, in all those September & Octobers combined. 
Regulations just do not matter. MRIP has Connecticut anglers catching at incredible new highs. 

In NY's 2014 summer catch-estimate we see a similar pattern as in MA's spring sea bass estimate & CT's fall estimate. 
Here in summer---the very period when professionals have more difficulty catching sea bass---MRIP has NY's Private Boats catching phenomenally well. 
New York
Estimate StatusYearWaveCommon NameFishing ModeTotal Harvest (A+B1)PSEHarvest (A+B1) Total
Weight (lb)
PSELandings (no.) without
Size Information
Odd that such huge sea bass catches occur lately, especially given that NY now has their strictest regulations ever. 
New York's Private Boat July/Aug catch-estimates for 1982, 83, 84, 85, 86, 87, 88, 89, 91, 92, 93, 94, 95, 96, 97, 99, 01, 02, 03, 04, 06, 07, 08 & 2011, All Added Up & All Together, are thought to have been 958,706 pounds---that's less than 2013 & 2014's July/August total. 
Today: Tight Regulation - Eight Fish - 13 Inches ..but record shattering catches.  
Unless you're out with a professional who knows where they live, what they're biting & how to anchor just so or drift....

The Mid-Atlantic sea bass population factually climbed to a 50 year high in 2003 just a few years into management. There was virtually no closed season & no bag limit at all until 2002. Quite nearly all of the sea bass that formed that wonderful resurgence has been spawned with no bag limit and size limits of 9 to 11 inches. 
The effect bad catch estimates has had, even from 1998, is cumulative. Once management accepts bad data, they do not back off. 
The best regulation for sea bass happened over a decade ago. With the sea bass population doubling annually, it's plain in NMFS's population assessments that maintaining a young spawning population is vital to stock growth.
But they weren't watching the fish, just the landings - just the catch estimates. 

The idea that Southern New England now catches more sea bass than the Mid-Atlantic ever did is wrong by any measure. Even with today's grossly inflated catch estimates, SNE only comes within 25% of historical Mid-Atlantic landings once - This Past Year. 

What is true is that regulatory "age at maturity" shift is pushing the Mid-Atlantic spawning stock further & further from shore; further from the estuaries so vital to successful sea bass production. 

Here's what is true: Statistical Estimates Own Management. Science Has Left The Room. 

Further South: 
All US Waters
Estimate StatusYearCommon NameFishing ModeTotal Harvest (A+B1)PSEHarvest (A+B1) Total
Weight (lb)

Estimate StatusYearCommon NameFishing ModeTotal Harvest (A+B1)PSEHarvest (A+B1) Total
Weight (lb)

It's the same thing. Some Private Boat owners are indeed very skilled, but red snapper & red grouper catch is much more equally divided between Private Boat & Charter/Party than is presently represented by MRIP. No One believes Private Boats catch 10X as many of any of these reef fish.. 
Believe me, Alabama's head of fisheries crucified MRIP in Congressional testimony. A lot of Congressional Representatives, including Senators, know quite well something's wrong with MRIP. 

Management says: "Just look at the PSEs.. These estimates are so accurate!" (their statistical PSE "percentage standard error" is similar to "margin of error" in a political poll) 
All fantasy. Their measures of PSE are as worthless as the estimates themselves. 
Even if NOAA were persuaded to allow managers the use of PSE, which they have steadfastly denied, the estimates are too far wrong for adjustments within PSE to fix. 

Maryland, for instance, is officially estimated by MRIP to have landed 348 sea bass all last year - 348 sea bass for all of 2014. A calculation for the high side of PSE (which NOAA has never allowed management to use) takes the Maryland total to about 800 sea bass. 
That's for all of 2014 & all of Maryland's anglers. 
My little 55 foot partyboat caught more sea bass than that in three trips. 

MRIP can be be stone-cold provably false on the low side. In fact, I may have taken more sea bass home for my family in 2014 than they say all Maryland anglers caught all year. 

On the low-side MRIP's dumb stuff stops at zero. They can't go lower than zero.  
However, an estimate can go upward forever. On the high side there is no stop   ...well, yes there is. When they've finally closed our fisheries with innumerable false accusations of having gone over-quota, there will be no catch to report from closed waters. 
When there's no catch at all, then we'll be able to absolutely prove high estimates were wrong. Except.. It's the same anecdotal argument falling from scientists' lips today: "Sure! Those estimates could be correct. There are a lot of fish & there are a lot of boats.
That is the extent of necessary proof needed to destroy a fishery. 

Perhaps one day soon Management will grapple the question: "Do we need to examine anything besides catch?" 
For now, MRIP's catch estimates suite NOAA's need just fine. 
No spawning age confusion; No needless ponderings: "Is coral really fish habitat? Should we go look?"

Only a handful of men on Council & Commission have kept these fisheries from complete regulatory collapse. 
Only a handful of Party/Charter owners & their crews can be troubled to write their representatives in DC & in their State. 
It's amazing that more clients write to their State & Federal Reps than party/charterboat crews. 
That's just astounding. 
With so few complaining it's no wonder NOAA keeps getting away with this.. 

While large recreational.orgs are busy with 'important' fish like stripers, "less important" fish like sea bass, blueline tile, red snapper, red grouper - even haddock; those fisheries are all being stolen by bad data. 

Management should be embarrassed, truly ashamed, to have ever used MRIP estimates as though they were science. 
Recreational anglers & boat crews should be mad, angry enough to write. 
You should write. 

Congress has heard about bad recreational catch estimates for decades. Congress has even tried twice to fix it ..and twice NOAA has made our catch estimates worse than before. 
In fact, now NOAA's plan to repair MRIP (again) is to switch from blind phone calling to a mail survey. 
Snail mail. 
That's their brand new idea. The reason we have a "saltwater registration" now was to allow a better count of catch - by phone. 

Capt. Rick Bellavance of RI has already developed and tested an iPhone app. NOAA could know how many fish we caught instantly. 
I don't think they want to know. 

Botched & then botched again, the authority to estimate recreational catch should now be handed to the US Fish & Wildlife Service. They've been estimating recreational catch a lot longer and will do a better job. 
Have to. I cannot image worse. 

Perhaps too USFWS should be put in charge of seafloor habitat inside 100 fathoms. I see no evidence at all NOAA has any interest in the remaining Essential Fish Habitat today or what existed in the past. 

We must write. Tell Your Congressional Representatives - Tell Your State Reps & Fisheries Department - Tell Them We Want Our Sea Bass Back. Tell Them We Want Red Snapper Back, We Want ALL OUR FISHERIES BACK. 
Tell Them We DEMAND A More Thorough Examination Of MRIP Estimates Using A "Percentage of the Fishery" from VTR Party/Charter Daily Reports. 
Tell Congress USFWS would do a much better job.

NOAA is stealing our fisheries with bad data. 

Tell your Representatives you want it fixed! 

My Regards,

Capt. Monty Hawkins 
Partyboat Morning Star
Ocean City, MD

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