Wednesday, March 01, 2017

MRIP - Where's the Filter? 3/1/17

Hello NOAA? We have a problem! 
..it's the same problem we've had all along. Looks exactly like so many years past.
Private Boats north of Cape Hatteras in 2016 - All Mid-Atlantic & North Atlantic Private Boats Caught More Sea Bass--4,247,354 Pounds--than every Trawler/Trapper/Partyboat/Charter Boat - All Combined = 2,833,111 Pounds. 
All 2016 For-Hire plus the average of the last ten years annual Commercial catch north of Cape Hatteras becomes dwarfed next to Private Boat catch.  
Your "Best Available Scientific Information" asserts small, privately owned boats, used by a fraction of recreational fishers, caught nearly twice as many sea bass as every commercial & professional recreational fisher--all combined. 
Our regulatory troubles comes when, instead of saying "Oh, that's codswallop," NOAA simply grinds every bit of bad data through their catch-restriction only based restoration system. There is no filter to trap the bad.. 

What an astounding amount of biological & economic waste loyalty to these statistical catch estimates has created..

Greetings All,  
Monty Hawkins here, a party boat skipper from Ocean City, MD. that specializes in reef/wreck fishing. Doing just that 37 years now. 
I work on fisheries restorations all the time. A gargantuan task with thousands of players, I prefer to focus on the biological & ecological aspects of our restoration efforts. Our federal fisheries management system is primarily centered on catch restriction. Managers have told me their task is not restoration, but management. This seems to belie "Rebuilding Target" seen so often in their work, but it is what I've been told.
 
Managers, these Council Members & Commissioners--everyone at NOAA, they are forever & perpetually busy with recreational regulation despite incredibly many other fisheries. I've long held recreational catch data's use creates an incurable curse upon management. So many years gone by & to this day; catch estimate data's terrible affects on the management community's rational conclusion/action/regulation owes only to NOAA's staunch: "It's the best scientific information available." No matter everyone's sincere desire to create good & fair regulation --often incredible effort from individual players & in every administration--and no matter who the appointees are-- recreational catch estimates gum this important effort up terribly.  

There is no way, at least not that I've found, to make this a fun read. Bad Catch Data is how we're being robbed though. Promise. 

I've written about recreational catch estimates many times. Been looking at them since 1998/99 when I was forced to take unnecessary risks with clients owing a two week cbass closure in August. That regulation stemmed entirely from a bogus NJ For-Hire statistical catch estimate. 
Maryland was the only state to follow the Fed's closure guidance. Other states rightly ignored it, having not been published in the Federal Register in time. 

Some Acronyms: 
MRFSS = Marine Recreational Fishing Statistics Survey - fishers say MuRFSS, most managers say MurFiss..
MRIP = Marine Recreational Information Program (MuRFSS Rest In Peace?)
VTR = Vessel Trip Report - a NOAA federal form in quadruplicate, loaded with catch info, that MUST be submitted to NOAA for each & every fishing trip. Any error or failure to fill in required boxes results in a return to the permittee for correction. 
NOAA = National Oceanic & Atmospheric Administration (most of our pain actually comes from NMFS = National Marine Fisheries Service, a part of NOAA which, not too long ago, was the Bureau of Commercial Fisheries. NMFS is part of NOAA.)
For-Hire = Party/Charter = all partyboats and charter boats combined.  
PSE (seen in every table) is something I'll not go into here. It's essentially the same as "plus or minus 3 points" in a political poll -- the "Margin of Error"--  except ours sometimes go over 100, are all MRIP's PSEs would be laugh out loud stupid to a professional political pollster...

Back to that early closure, my first run-in with bad catch data; in that early regulatory period, the late 1990s/early 2000s, For-Hire fishers had proof, or close to it, the Marine Recreational Fishing Statistics Survey was badly wrong -- and we were writing Congress. My Congressman, Wayne Gilchrest, chaired House Fisheries back then and knew baloney when he saw it. We Party/Charter sea bass guys could show MuRFSS was inflating For-Hire estimates--exaggerating them many-fold. That's because NOAA requires professional recreational fishers to submit a "VTR" daily. A Vessel Trip Report  ..and boy does NOAA get nasty quick if you fail to send them in. 

Recreational catch estimates are basically split into Shore - Private Boat - and For-Hire. A repair was made to MuRFSS in 2003 that began to give more & more 'catching power' to Private Boats, while also lowering, continuously, For-Hire catches. 
For instance, this year, again, Maryland currently shows ZERO sea bass caught by Party Boats. Though this "preliminary" number will likely change in the year to come, (and this particular estimate has no true bearing on regulation,) the fact remains regulations are already decided long before any correction occurs.  
I tell NOAA every single trip a nearly precise number of sea bass my clients caught in these VTRs we Party/Charter skippers fill out daily. It's a fair-many sea bass--Not Zero. 

This MRIP table shows every Maryland party boat threw all their sea bass back. 
I promise - many a client's kitchen smelled of fresh sea bass cooking. Or, sometimes, their sea bass were served ice cold with wasabi & soy.. Delicious. 

MD Party Boat Only All of 2016
Estimate StatusYearCommon NameTotal Catch PSEHarvest - Total Weight (lb)

PRELIMINARY2016BLACK SEA BASS10,52225.30.

Even though we surrender catch data on VTR sheets daily, NOAA.gov says we tossed all our sea bass back. In 2015 they did the same thing. On one 2015 fall trip I'd invited a bunch of policy wonks who were in town anyway for an Ocean Policy meeting. A senior NOAA administrator (yes, he bought a ticket) and some family caught sea bass every drop. Some were keepers. 
NOAA's MRIP catch estimates then said we'd caught 56 pounds of sea bass all year -- and none of those aboard a Party Boat. That estimate left my upper-echelon NOAA.gov paycheck recipient--this very successful angler who truly enjoyed his fresh fish--scratching his head.. 

Our troubles are not in under-estimates however. 
It's in Private Boat over-estimates. 

Yes, sometimes a shore estimate can catch a statistical moon-shot too. Here's a table showing all NJ Shore Tautog Landings in early spring. Missing in this table are 2011, 2014, & 2015.. These years would also be a zero as shown in 2016. 
In 2010 the old MuRFSS estimating program had shown 73,000 tog caught & boxed on New Jersey's jetties that March & April. I had railed against the estimate - it was nuts.
Two years later the new & improved MRIP estimate took that screw-up, one of the most blatant errors in my findings, and raised it up 100,000 fish. I knew our troubles were far from over in the New & Improved MRIP..

NJ Shore Tautog
Estimate StatusYearWaveCommon NameTotal Harvest (A+B1)PSEHarvest (A+B1) Total Weight (lb)PSE
FINAL2009MARCH/APRIL TAUTOG5,0019613,96696
FINAL2010MARCH/APRIL TAUTOG173,09286.4469,36786.4
FINAL2012MARCH/APRIL TAUTOG3,701101.711,557101.7
FINAL2013MARCH/APRIL TAUTOG9,775112.431,662112.4
PRELIMINARY2016MARCH/APRIL TAUTOG0.0.
New Jersey's Jetty Anglers were catching tog like crazy while tog ain't biting? (though they sure might this year, warm as it's been) Freezing their butts while sitting atop 5 gallon buckets, they caught more computer-tog than all U.S. commercial effort for the entire year. They also caught more tog than all U.S. Party/Charter for the year too. 
A neat trick only achievable with statistics - it remains in the data. 

Another: You'll remember Maryland has zero Party Boat sea bass in 2016. Here's MD shore sea bass..

Maryland Shore-Only All of 2016
Estimate StatusYearCommon NameTotal Harvest (A+B1)PSEHarvest (A+B1) Total Weight (lb)PSE
PRELIMINARY2016BLACK SEA BASS36,83486.156,74787.3
12.5 inch sea bass from MD's jetties? It's a dern wonder I can sell a ticket at all. In the official MRIP data all my clients were cbass-skunked, while shore anglers had to buy more freezers..

NOAA's worries with an occasional crazy Shore estimate, or with a Party/Charter spike, are not what cause our troubles. It's the continuous increase in Private Boat.
Today, even after MRFSS's Congressionally mandated replacement with the MRIP program, & even after two supposedly hard looks from the National Academy of Sciences; it's rare to find a set of Private Boat estimates that make sense. 

Since 2009 our new and supposedly "improved" rec catch estimates from the Marine Recreational Information Program, MRIP, have portrayed recreational sea bass catch as wildly out of control  ..despite far and away the most draconian regulation in the fishery's history. 

For instance: Recreational Private Boat fishers in New York, in 2016, are said to have caught 1,846,000 pounds of sea bass. Not the whole coast's Private Boats - just New York.
Management truly fears this powerful force & has factually reacted to it in regulation. It was only hard fighting at Council/Commission that prevented a further restriction in sea bass regs this year. 

NY Private Boats All Year
Estimate StatusYearCommon NameHarvest (A+B1) Total Weight (lb)PSE
PRELIMINARY2016BLACK SEA BASS1,846,12220.5

Then New York's Private Boats, catching when most Private Boats boats had long since been put away until next spring; NY's recreational Private Boats even caught 718,000 pounds of sea bass from just after Halloween to New Year's Eve in 2016. 
NY Private Boats Nov/Dec
Estimate StatusYearWaveCommon NameHarvest (A+B1) Total Weight (lb)PSE
PRELIMINARY2016NOVEMBER/DECEMBERBLACK SEA BASS718,70241.9

To put that 1,846,122 pounds of Private Boat sea bass catch by one state's Private Boats in perspective: the 10 year average for all Commercial Trawl & Trap from Cape Hatteras to the Canadian border is 1,612,000 pounds.. (They do not publish commercial data w/o a year's delay, but 1.6 million is going to be pretty close.) Therefore NY's private boats outcaught commercial fishers from North Carolina to Maine by 234,000 pounds. Why do we become concerned when we see pictures of thousands & thousands of pounds in one tow by a trawler? It's obvious, in NOAA's "best" data that small private boats are the real problem..

But Wait! 
It could also be said that these die hard anglers also outfished All Party/Charter from Hatteras north all year.. 
All Mid-Atlantic & North Atlantic For-Hire
Estimate StatusYearCommon NameHarvest (A+B1) Total Weight (lb)PSE
PRELIMINARY2016BLACK SEA BASS1,221,11115.8

A manager would have to conclude - and I do mean "Have To" - that NY's Private Boats outfished every Party & Charter Boat north of Hatteras by 625,000 pounds in 2016. That information is, after all, straight out of NOAA.guv's "Best Available Scientific Information." 
They would also Have To conclude these small boats outfished the trawl fleets & trap boats from Hatteras north. 

Going back to MuRFSS's early estimates; from 1981 to 1990 Party/Charter Boats north of Hatteras landed an average of 6.4 million sea bass-- 6.4 million individual fish, not pounds. That's all pre-regulation catch. Though also fuzzy as heck, we could--and did--try to catch every sea bass possible. 
In the MRIP estimates from 2007 to 2016, however, we For-Hire skippers and our clients landed 0.58 million sea bass - a precipitous drop of 5,820,000 individual fish per year that are not being caught by For-Hire. Regulation ought surely curtail our catch -- and indeed it has. 

In the Private Boat side of catch estimates though, we see an altogether different result. From 1981 to 1990 Private Boats from Hatteras north are said to have landed 1.6 million sea bass annually - as an average number of fish. The average from 2007 to 2016 in Private Boat catch is only marginally lower at 1.2 million sea bass. Their average annual catch has only declined by 400,000 individual fish..
In For-Hire we see regulation take it's toll on catch--where Catch Restriction is doing what it should and everyone who paid to go fishing on a daily rate sees their catch fall & feels it like a sharp knife; yet the average from 2007 to 2016 in Private Boat catch is only marginally lower at 1.2 million sea bass..

Lower, but not lower like their sea bass catch should be..

Still, even these averages are as nothing in our troubles. It's big spikes in the data that cause our real regulatory pain. In 2016, for instance, Private Boats north of Cape Hatteras, (belonging to those citizens fortunate enough to have a boat with offshore capability; some time off from work; & inclined to go after sea bass instead of trolling for tuna/marlin/blues/striper, or drifting for fluke) - those fortunate few anglers "caught" more sea bass than all commercial trawl/trap & party/charter combined.
Really. 
Private Boat 2016 - All Mid-Atlantic & North Atlantic Sea Bass = 4,247,354 Pounds 
All 2016 For-Hire & the average annual Commercial catch = 2,833,111 Pounds. 
Ummm? Hello? NOAA? Is anyone home?

Yup. That makes Grady Whites & Boston Whalers almost twice as deadly as Party/Charter/Trap/Trawl all combined.. 
I somehow doubt any fisherman would agree with that assessment. 
Yet it is the exact "Best Available Scientific Data" NOAA will use--is using--to keep our sea bass fishery restricted with the tightest regulations ever   ..even though the latest cbass population assessment, a stock assessment thought better than any they've ever had before, a population assessment showing sea bass at 2.5 times their intended restoration target. 
And regulation will not loosen because of MRIP's private boat landings statistical estimates. 

Bad data makes for bad regulation. 

I've been trying to get NOAA interested in essential reef habitat--even coral habitat--off DelMarVa since 2000. 
No joy. Not yet. 
Trying to show NOAA & everyone in the science community how size limits affect sea bass reproduction since 2006 or so. 
No joy. Not yet. 
Trying to show them their catch estimates are nuts--just dumb crazy, since 1998 or so. 
No joy. Nope. Not yet. 
Trying to show them we can build all the coral reef we want just by rolling rocks off a barge - and build anywhere we want if we use enough. Fifty fathoms, five fathoms - a hundred fathoms. It all works. I want NOAA to know any real increase in habitat necessarily increases fish populations. I want NOAA to know whether we're building intentional restoration of reef lost in the early industrial commercial fisheries (which has never happened yet in the ocean,) or some small bit of reef building funded by a raffle & bake sale (what I do mostly) -- some progress is better than no progress. 

Instead of seeing other methods of restoration in our young endeavor--any other means to focus on aside from catch restriction in marine fisheries restoration; NOAA is forever chasing their tail, forever finding overfishing by Private Boats as big & wicked as any by foreign trawlers of yore -- the early industrial period before the Magnuson Act in 1976 when US trawlers were FREQUENTLY outnumbered by foreign boats - big ones..
Overfishing, these days, is always ---ALWAYS--- by private boats with a few anglers aboard enjoying their day..

I am certain a simple method of testing MRIP's veracity can be fashioned from "Percentage of VTR Catch." 
Say a collection of NY skippers assert the only time Private Boats catch even 50% of that state's sea bass is on Saturday in summer. Other summer days it's more like 30% - and in late fall not even 5%.. This would have to be looked into deeply - but it can be checked. Were Private Boat percentages of VTR-reported catch exceeded by, or undershot, then closer examination would be warranted. 
Here is an actual table from NY containing VTR (Vessel Trip Report) landings. You can plainly see how MRIP varies widely from reported landings. 

NY Sea Bass Catch June to December From NY Fisheries -- VTR is self-surrendered data. 
Look at the Wave 6 Column. If professional skippers believe NY Private Boats catch 10% or less of that state's sea bass in Nov/Dec, then Wave 6 above would be shown as somewhat reasonable. (and it's NOT 718,702 pounds like this year's estimate!)
MRIP's Party & Charter estimates, however, would be grossly undershot and in need of correction. 

NY All Party/Charter 
Estimate StatusYearWaveCommon NameTotal Harvest (A+B1)PSEHarvest (A+B1) Total Weight (lb)PSE
PRELIMINARY2016NOVEMBER/DECEMBERBLACK SEA BASS82,37639.1168,47638.3
If we applied 10% to this year's Wave 6 estimate, we'd anticipate a Private Boat catch somewhere around 17,000 pounds.
Instead, there is regulatory turmoil because it's nearly 3/4 of a million pounds. 

We might also consider species effort. Also in NY & points north, there is considerable effort on scup. Any For-Hire deckhand could approximate the ratio of sea bass to scup. Lets say it's 15 to 1 scup -- that any regular angler would catch 1 sea bass to 15 scup. 
NY Summer For-Hire Sea Bass 
Estimate StatusYearWaveCommon NameTotal Harvest (A+B1)PSEHarvest (A+B1) Total Weight (lb)PSE
PRELIMINARY2016JULY/AUGUST BLACK SEA BASS79,55133.9143,27532

NY Summer For-Hire Scup 
Estimate StatusYearWaveCommon NameTotal Harvest (A+B1)PSEHarvest (A+B1) Total Weight (lb)PSE
PRELIMINARY2016JULY/AUGUST SCUP73,42035.563,65632.3
Here NOAA sees a nearly 50/50 split in the sea bass/scup fishery. It's the same, but incredibly higher, for Private Boats. Is that right? I doubt it, but certainly don't know. NOAA could hammer it into an accurate test by interviewing many participants. Be a lot cheaper than lots & lots of new dockside intercepts/interviews with anglers. 

Our troubles are amplified this year like few others. In a quadruple whammy, RI, CT, NY, & MA all have very high private boat estimates this year. Each is vastly higher than their state's commercial landings. All but Rhode Island's are also higher than the average North Atlantic commercial trawl/trap annual landings - some substantially. 

MRIP's Private Boat estimates..  That's why we're forever over-quota & cannot enjoy our sea bass restoration. Nor can managers, locked into using bad data, explore for means to achieve better result in a real restoration..

Every port has guys on the water who have a feel for what's being caught. It's what we do. 
This "Percentage of VTR Catch" would never be the estimate - it's just a test to see if MRIP is in the right solar system. 
Here are NY & NJ's For-Hire/Private Boat numbers in tables I've adapted. 
If For-Hire fishers with any sense of it might think NY's Private Boats catch 40 to 60 percent of their state's sea bass, the For-Hire "Percentage of VTR Catch" would surely shoot a flare quickly at these wild divergences. Virtually every time these separations grow too broad, there's big trouble in sea bass regulation..
 
NY BSB
Estimate StatusYearWaveCommon NameTotal Harvest 
NY For-Hire
# of Fish
PSETotal Harvest 
NY Private Boat
# of Fish
PSEFor-Hire 
Catch Percentage


FINAL2001JULY/AUGUSTBLACK SEA BASS10,18247.065,82842.113%

FINAL2002JULY/AUGUSTBLACK SEA BASS3,01653.1 12,00337.220%
FINAL2003JULY/AUGUSTBLACK SEA BASS13,57626.445,33031.423%

FINAL2004JULY/AUGUSTBLACK SEA BASS9,85557.115,38655.140%
FINAL2005JULY/AUGUSTBLACK SEA BASS5,42636.350,73260.010%
FINAL2006JULY/AUGUSTBLACK SEA BASS41,09964.938,50843.852%

FINAL2007JULY/AUGUSTBLACK SEA BASS91,16814.837,68655.871%
FINAL2008JULY/AUGUSTBLACK SEA BASS18,07040.339,83455.831%

FINAL2009JULY/AUGUSTBLACK SEA BASS23,52634.4 183,77559.111%
FINAL2010JULY/AUGUSTBLACK SEA BASS53,77032.783,51348.739%

FINAL2011JULY/AUGUSTBLACK SEA BASS11,32653.153,74052.517%

FINAL2012JULY/AUGUSTBLACK SEA BASS73,31136.9127,87159.127%

PRELIMINARY2013JULY/AUGUSTBLACK SEA BASS11,89629.6 236,77933.15%

Estimate StatusYear Wave          Common Name   Total Harvest 
NY For-Hire

Party/Charter   
PSETotal Harvest 
NY Private Boat
# of Fish
PSEFor-Hire 
Catch Percentage






FINAL2014JULY/AUGUST BLACK SEA BASS9,48741.4225,26729.74.0%




FINAL2015JULY/AUGUST BLACK SEA BASS29,30836.3259,63422.410.1%





PRELIMINARY2016JULY/AUGUST BLACK SEA BASS79,55133.9424,5332415.8%





Last set again key; this table has been modified so New Jersey For-Hire & Private Boat can be compared. 
Here you should note carefully the Private Boat see-saw starting in 2005, but especially the percentage value in 2013.
Estimate StatusYear WaveCommon NameNJ For-Hire 
Total Harvest
PSENJ Private Boat 
Total

PSEFor-Hire
Catch %


FINAL2001JULY/AUGUSTBLACK SEA BASS 461,14019.8223,91228.067%

FINAL2002JULY/AUGUSTBLACK SEA BASS22,37723.999,01323.118.3

FINAL2003JULY/AUGUSTBLACK SEA BASS85,38514.8115,13224.643%

FINAL2004JULY/AUGUSTBLACK SEA BASS40,22569.3137,95035.623%

FINAL2005JULY/AUGUSTBLACK SEA BASS48,59130.7216,83338.018%

FINAL2006JULY/AUGUSTBLACK SEA BASS7,03938.224,14848.129%

FINAL2007JULY/AUGUSTBLACK SEA BASS74,70830.1151,35345.533%

FINAL2008JULY/AUGUSTBLACK SEA BASS33,41127.414,33052.870%

FINAL2009JULY/AUGUSTBLACK SEA BASS97,02333.2194,79042.033%

FINAL2010JULY/AUGUSTBLACK SEA BASS31,52226.282,52136.928%

FINAL2011JULY/AUGUSTBLACK SEA BASS17,29134.117,43540.832%

FINAL2012JULY/AUGUSTBLACK SEA BASS63,69932.2117,98240.935%

PRELIMINARY2013JULY/AUGUSTBLACK SEA BASS5,05245.0 162,53851.43%

Estimate StatusYearWaveCommon NameNJ For-Hire 
Total Harvest
# of Fish
PSENJ Private Boat Total 
Harvest # of Fish
For-Hire 
Catch 

FINAL2014JULY/AUGUST BLACK SEA BASS84,23535.255,59960.2%
FINAL2015JULY/AUGUST BLACK SEA BASS9,65447.527,67525.9%
PRELIMINARY2016JULY/AUGUST BLACK SEA BASS12,2442162,37716.4%

In case you've not had enough, below is a piece I wrote a few years back. Maybe come back to it later? 
A Short Regulatory History of the Recreational Sea Bass Fishery .. 
NOAA is, absolutely, positively, stealing our fisheries with bad data. 
Guarantee it. 
This really needs fixing or we'll never move on to what is truly important in marine fisheries restorations.

Regards,
Monty 

Capt. Monty Hawkins 
capt.montyhawkins@gmail.com 
Partyboat Morning Star
Ocean City, MD

****************************************************
Just The Estimates – Monty Hawkins, 3/14/14
MRFSS/MRIP Catch Estimates: A Short Regulatory History of the Recreational Sea Bass Fishery:

With the permission & blessing of the Nichols Family, I began self-regulation on sea bass & tautog in 1992 aboard the party boat O.C. Princess, Ocean City, MD. 
For sea bass, a nine inch size limit was chosen because I'd been told by a biologist, "All sea bass have spawned by 9 inches, some twice." Within months I knew regulation was going to work, that we could undo the damage done by industrial overfishing. Sea bass fishing became better - Instantly. By August, 1992, we could see healed hook wounds from Kahle (wide-gap) hooks in numerous sea bass from nearshore reefs, especially reefs less-known or unknown to others. 

1) Fed/state sea bass management in the Mid-Atlantic began in 1996 when the Joint ASMFC/MAFMC Black Sea Bass Plan was adopted. 

2) 1997: Published too late in the Federal Register for '96, management is actually begun in '97 with a 9 inch limit. Listed as a goal is increasing the size limit to 10 inches.

3) 1998, Size limit up 1 inch for a 10 inch size limit, plus a late-summer closure because an increase of 1,220,000 fish is estimated in New Jersey's 1997 For-Hire estimate. This takes the New Jersey For-Hire Estimate to 3,100,000 sea bass. No other state or mode varies from previous years by a noticeable amount. It's Extremely Important To Consider & Remember The Assertion That JUST New Jersey For-Hire Caught Three Million Sea Bass In 1997. The Recreational Total That Year Was 4,721,000 Cbass Caught. This Estimate Is, Of Course, Junk. I argued against it and especially the August closure, yet failed to gain traction. I was told, in the Federal Register, to take my clients striped bass fishing – quite impossible along the coast in high-summer.. While exact numbers in the estimates are nearly worthless; we did, however, catch a lot of sea bass back then; just one year into management; just one year after wholly-unregulated sea bass fishing had ended. 

4) 2001, Size increase to 11 inches and a spring closure. Regulation in this early period tightened when New Jersey's Y2K For-Hire estimate Alone & Again put coastwide recreational fishers over-quota. 
2002, increase to 11.5 inches & no closed season. A twenty-five fish bag limit is begun. Tighter regulation sources, as ever, from New Jersey For-Hire "catching" over half the 2001 recreational quota and that's that.
Prior to this first bag limit, anglers could keep as many legal sized fish as they caught. In late fall, for instance, this could easily exceed 100 fish per person ..Still, from 1997 to 2003 the sea bass population grew fantastically. One could say 'exponentially' in very precise definition; Exponential population growth despite incredibly higher recreational removals than today. 

5) 2003, increase to 12 inches with a short fall closure. For once, New Jersey actually declines slightly in 2002 while Delaware increase from about 110,000 in 2001 to 560,000 sea bass in 2002.. MD's up 200,000 year over year from '01 to '02.. In the estimate MD For-Hire 'catches' 311,000 sea bass, but I'm absolutely positive this number is at least 100,000 too high. Fishing was awesome.

6) 2009 – Size limit increased to 12.5 inches, but I don't remember exactly why and can't find it. Note: 2008 is the first year Private Boats are estimated to have caught more sea bass than the For-Hire fleet in the Mid-Atlantic with 63% of total landings. A Tumultuous Year; in early fall, 2009, an Emergency 180 Day Closure is declared based on estimated 2009 coastwide landings of 1,769,000 sea bass, or about half what the New Jersey For-Hire fleet alone had been catching previously. Estimates credit Private Boats with another percentage of the fishery increase in 2009, catching 74% of the coast's sea bass. This is several times the percentage of the fishery they'd held earlier, and a much greater percentage of the fishery than professional skippers believe Private Boats capture. 

7) There was a regulatory peace beginning in 2004. That peace was shattered when our smallest quota ever was exceeded in 2009. . .
The 2009 emergency sea bass closure bases primarily from Massachusetts wave 4 July/Aug Private Boat catch being up 340,000 pounds from 2008's 33,000 or 2007's 9,000 pounds.. (see table immediately below) There were also increases in Virginia's private boat, up 115,000 pounds from just 10,000 the year before – New York's private boats were up 160,000 pounds in wave 3 from just 30,000 & New Jersey's private boats were up 145,000 in wave 3 plus another 220,000 pounds in wave 4.. 

Since 2009 Sea Bass management has come completely unglued. 
Its not as though outboards are a new invention. Their catch sure is though..

Even allowing a million fish here and there, the downward catch trend from regulatory tightening is plainly seen in party/charter estimates. For-Hire catch is factually reduced when regulations tighten; Regulation's Effect Is Real. 
Catch on the private boat side, however, is reported by the estimates to erupt wildly & uncontrollably, then subside swiftly. There is no apparent regulatory control over the Private Boat mode. That, of course, is not at all true. Private Boat Catch Is Increasingly Restricted, it's just not seen in the estimates. 

Massachusetts Private Boat  —  Note Percentage of the Fishery
Estimate StatusYearWaveCommon NameTotal Harvest (A+B1)PSEHarvest (A+B1) Total
Weight (lb)
PSEPrivate Boat %
FINAL2007JULY/AUGUSTBLACK SEA BASS9,00668.78,76070.538%
FINAL2008JULY/AUGUSTBLACK SEA BASS21,21376.432,85874.058%
FINAL2009JULY/AUGUSTBLACK SEA BASS270,46034.7372,32134.292% 

Massachusetts For-Hire
Estimate StatusYearWaveCommon NameTotal Harvest (A+B1)PSEHarvest (A+B1) Total
Weight (lb)
PSE
For Hire % 
FINAL2007JULY/AUGUSTBLACK SEA BASS14,58660.018,62162.562%
FINAL2008JULY/AUGUSTBLACK SEA BASS15,23948.517,87146.042%
FINAL2009JULY/AUGUSTBLACK SEA BASS22,38433.930,21739.58%

The regulatory history is driven by estimate spikes. Only rarely are broader multi-state/multi-mode/multi-wave increases a factor. 
In the early years, estimate spikes were seen primarily on the For-Hire side. Now it's virtually always on the Private Boat side, and never both. Catch increases are rarely seen across time, across recreational sectors & across state lines as in real life. Estimate spikes never resemble real biological fish production.
In the estimates, fishing doesn't get better over time, it's all of a sudden. 'Statistically' these catch increases happen swiftly, inside a two month period, and then melt away.. 

8) In 2010 we had a "gunshot start" for the first time ever; a race-like opening for sea bass in late May because of the 2009 emergency closure. The season closed October 5th. In the lower Mid-Atlantic there was a four month open season with a 12.5 inch size limit and 25 fish bag. 

9) 2011 – Season Closed From Jan 1st to May 22nd--And All of October. Gunshot Start Again. 

10) 2012 — Overages in the Private Boat estimates threaten to close sea bass for all of 2014. The worst two catch estimate sets in 2012 were in New Jersey & Massachusetts. 

This table offers a May/June\ July/Aug Comparison of Massachusetts Private Boat Catch. Their bag limit, for instance, doubled to twenty fish in July/Aug 2012, Yet Catch Declined By 600,000 lbs.. Compare especially the summer estimates & Bag Limits Shown In Last Column. Note also the 2010 spring estimate.. Only In MRIP Could Such Things Occur.. 
Massachusetts' May/June, 2012, spike represents how half of the recreational quota can be made to suffer a regulatory seizure owing only to a single spike in the estimates. Massachusetts' 2012 estimates were a huge component in the Accountability Measures struggle. 
Estimate StatusYearWaveCommon NameTotal Harvest (A+B1)PSEHarvest (A+B1) Total
Weight (lb)
PSEBag Limit 
FINAL2009MAY/JUNEBLACK SEA BASS34,49351.372,68252.120
FINAL2009JULY/AUGUSTBLACK SEA BASS270,46034.7372,32134.220









FINAL2010MAY/JUNEBLACK SEA BASS448,18168.6610,38069.220
FINAL2010JULY/AUGUSTBLACK SEA BASS121,48156.2202,68354.920





45.0


FINAL2011MAY/JUNEBLACK SEA BASS77,39742.9124,30945.420
FINAL2011JULY/AUGUSTBLACK SEA BASS36,70439.464,79238.620









FINAL2012MAY/JUNEBLACK SEA BASS276,31534.3616,51233.310
FINAL2012JULY/AUGUSTBLACK SEA BASS7,77468.316,37265.820

















PRELIMINARY2013MAY/JUNEBLACK SEA BASS65,58532.1168,05632.84
PRELIMINARY2013JULY/AUGUSTBLACK SEA BASS48,46035.5101,77033.54





















New Jersey – Private Boat – No Special Regs In 2007.. Just Random Numbers. 
Estimate StatusYearWaveCommon NameTotal Harvest (A+B1)PSEHarvest (A+B1) Total
Weight (lb)
PSE
FINAL2006SEPTEMBER/OCTOBERBLACK SEA BASS69,44457.089,66756.7
FINAL2007SEPTEMBER/OCTOBERBLACK SEA BASS7,23983.99,21181.6
FINAL2008SEPTEMBER/OCTOBERBLACK SEA BASS288,40956.9344,79856.4
FINAL2009SEPTEMBER/OCTOBERBLACK SEA BASS37,26937.446,27137.7
FINAL2010SEPTEMBER/OCTOBERBLACK SEA BASS392,43247.6423,11648.4
FINAL2011SEPTEMBER/OCTOBERBLACK SEA BASS1,119104.8247104.8
FINAL2012SEPTEMBER/OCTOBERBLACK SEA BASS236,21541.5305,11942.5
PRELIMINARY2013SEPTEMBER/OCTOBERBLACK SEA BASS81,70530.2117,18732.9


11) Owing to foresight by an ASMFC Commission member, the winter period from Jan 1st to Feb 29th, 2013 is reopened & the October Closure is reduced to 2 weeks. May, however, is still nearly lost to southern Mid-Atlantic sea bass fishers. A year-long 2014 closure is defeated owing to an incredible effort on the part of management.

Recreational sea bass fishers in the lower Mid-Atlantic may yet lose 15 more days of season & 5 fish off their bag limit in 2014 because NY Private Boats are estimated to have caught more sea bass in two late-summer months of 2013 than the entire Atlantic Coast's recreational for-hire fleet caught ALL YEAR! New York's Private Boats are said to have made their all-time record high catch when New York's own party/charter For-Hire operators were; owing to Hurricane Sandy's destruction, factually having their second-worst summer of sea bass fishing in a decade. 

This assertion of New York private boat catch flies in the face of reality—no one in industry or management believes it -- Yet the estimate stands firm & has sopped-up fully a quarter of the MAFMC's recreational 2013 sea bass quota: While New Jersey also has a spike, this one New York estimate is why we're accused of being over-quota; This estimate is why our season's under pressure again.  

Some Tables..

Last Set Key; this table has been modified so New York For-Hire & Private Boat can be compared. I was unable to change the colors in the PSE boxes for Private Boat, but did change the PSE values exactly as MRIP shows. An estimate is said to be inaccurate if it could be more than 100% off in the 95% confidence level (50 PSE.) 

Personally, I often see estimates I believe are several orders of magnitude too high; and, in an abject display of foundational knowledge's absence, I also commonly see estimates that are impossibly low.  

Note spikes & percentage inconsistency, especially for 2013. The 2013 New York, summer, Private Boat estimate represented here is Greater Than All For-Hire Catch, Along The Entire Coast, All Year. 

Readers Should Also Be Made Aware That The 2013 NY Private Boat Estimate Is Based Upon Finding Thirty-Three Sea Bass In Intercept Sampling. Not 3,300 – or 33,000 - Just 33.. I was recently advised there was an error on the website where this information was gathered; that the true number of sea bass was more than 100% higher at 78 individual sea bass.. Whether 33 or 78, how so few fish become 240,000 & then half-a-million pounds is beyond my comprehension. 
Repairing only this estimate would lower the recreational estimate below MAFMC's 2013 recreational quota. 
Estimate StatusYearWaveCommon NameTotal Harvest 
NY For-Hire
PSETotal Harvest 
NY Private Boat
PSEFor-Hire 
Catch Ratio


FINAL2001JULY/AUGUSTBLACK SEA BASS10,18247.065,82842.113%

FINAL2002JULY/AUGUSTBLACK SEA BASS3,01653.1 12,00337.220%
FINAL2003JULY/AUGUSTBLACK SEA BASS13,57626.445,33031.423%

FINAL2004JULY/AUGUSTBLACK SEA BASS9,85557.115,38655.140%
FINAL2005JULY/AUGUSTBLACK SEA BASS5,42636.350,73260.010%
FINAL2006JULY/AUGUSTBLACK SEA BASS41,09964.938,50843.852%

FINAL2007JULY/AUGUSTBLACK SEA BASS91,16814.837,68655.871%
FINAL2008JULY/AUGUSTBLACK SEA BASS18,07040.339,83455.831%

FINAL2009JULY/AUGUSTBLACK SEA BASS23,52634.4 183,77559.111%
FINAL2010JULY/AUGUSTBLACK SEA BASS53,77032.783,51348.739%

FINAL2011JULY/AUGUSTBLACK SEA BASS11,32653.153,74052.517%

FINAL2012JULY/AUGUSTBLACK SEA BASS73,31136.9127,87159.127%

PRELIMINARY2013JULY/AUGUSTBLACK SEA BASS11,89629.6 236,77933.15%



Last set again key; this table has been modified so New Jersey For-Hire & Private Boat can be compared. 
Here you should note carefully the Private Boat see-saw starting in 2005, but especially the percentage value in 2013.
Estimate StatusYear WaveCommon NameNJ For-Hire 
Total Harvest
PSENJ Private Boat 
Total

PSEFor-Hire %

FINAL2001JULY/AUGUSTBLACK SEA BASS 461,14019.8223,91228.067%

FINAL2002JULY/AUGUSTBLACK SEA BASS22,37723.999,01323.118.3

FINAL2003JULY/AUGUSTBLACK SEA BASS85,38514.8115,13224.643%

FINAL2004JULY/AUGUSTBLACK SEA BASS40,22569.3137,95035.623%

FINAL2005JULY/AUGUSTBLACK SEA BASS48,59130.7216,83338.018%

FINAL2006JULY/AUGUSTBLACK SEA BASS7,03938.224,14848.129%

FINAL2007JULY/AUGUSTBLACK SEA BASS74,70830.1151,35345.533%

FINAL2008JULY/AUGUSTBLACK SEA BASS33,41127.414,33052.870%

FINAL2009JULY/AUGUSTBLACK SEA BASS97,02333.2194,79042.033%

FINAL2010JULY/AUGUSTBLACK SEA BASS31,52226.282,52136.928%

FINAL2011JULY/AUGUSTBLACK SEA BASS17,29134.117,43540.832%

FINAL2012JULY/AUGUSTBLACK SEA BASS63,69932.2117,98240.935%

PRELIMINARY2013JULY/AUGUSTBLACK SEA BASS5,05245.0 162,53851.43%



Below you can see from a broader, multi-state perspective, how the gap has grown between For-Hire & Private Boat. These two tables show how after Hurricane Sandy sea bass fishing was tough for professionals – yet MRIP has the private boat guys filling their freezers to bursting. 
All Mid-Atlantic For-Hire BSB Landings – New York to Cape Hatteras
Estimate StatusYearWaveCommon NameTotal Harvest (A+B1)PSEHarvest Total
Weight (lb)
PSEFor-Hire %
FINAL2011JULY/AUGUSTBLACK SEA BASS52,72919.357,73319.641%
FINAL2012JULY/AUGUSTBLACK SEA BASS149,28222.8199,57722.437%
PRELIMINARY2013JULY/AUGUSTBLACK SEA BASS18,63623.933,79721.04%


All Mid-Atlantic Private Boat BSB Landings (mostly NY & NJ) 
Estimate StatusYearWaveCommon NameTotal Harvest PSEHarvest Total
Weight (lb)
PSEPrivate Boat %
FINAL2011JULY/AUGUSTBLACK SEA BASS75,92238.7107,28238.659%
FINAL2012JULY/AUGUSTBLACK SEA BASS254,48534.8453,61037.563%
PRELIMINARY2013JULY/AUGUSTBLACK SEA BASS420,61127.1786,67827.9  96%

Below is representative of pre/mid 2000s percentages. Note For-Hire & Private Boat Percentages In Last Column – An Amazing Switch. 

Mid-Atlantic For-Hire Annual Landings  Historical 
Estimate StatusYearCommon NameTotal Harvest 
For-Hire
PSEHarvest Total
Weight (lb)
PSEFor Hire %
FINAL1993BLACK SEA BASS4,529,97525.33,645,09328.677%
FINAL1994BLACK SEA BASS1,950,91115.01,752,21515.662%
FINAL1995BLACK SEA BASS5,103,31418.24,859,58018.680%

Mid-Atlantic Private Boat Annual Landings  Historical 
Estimate StatusYearCommon NameTotal Harvest 
Private Boat
PSEHarvest Total
Weight (lb)
PSEPrivate Boat %
FINAL1993BLACK SEA BASS1,355,97010.91,104,87113.923%
FINAL1994BLACK SEA BASS1,207,03020.81,063,51225.138%
FINAL1995BLACK SEA BASS1,305,04920.11,168,81828.7    20%

A "true believer," if there were one, would have to think Private Boats have increased their share of the fishery from about 25% in the 1990s to 96% in 2013.. 
Professionals Do Not Believe Private Boats Catch Above 50% Of Coastal Sea Bass..

After the 2009 Emergency Closure, I & others had high hopes MRIP would be an actual repair, that the new estimating system would offer an improvement. 
Instead, below are several of the first estimates I found when MRIP was "revealed" to the public in January, 2012 (four years late). I was made instantly aware the long-awaited cure for bad estimates had not been found, that MRIP would offer no repair to our recreational catch estimates. 

Where present-day management is wholly-dependent on catch restriction, we must find a method of actual improvement to our recreational estimates, we must discover the truth of recreational catch.
We must also steer management toward other means of fisheries improvement. 

Massachusetts Wave 4 (July/Aug) For-Hire Party/Charter  See Any "Improvement" on the MRIP side? Any at all?

Estimate StatusYearWaveSpecies  New MRIP  {Old MRFSS}PSE  or MRIP's Margin of Error Spread
FINAL2004JULY/AUGUSTSCUP752,942        {19,547}48.9    or      20,000 to 1,450,000
FINAL2005JULY/AUGUSTSCUP     1,382       {12,557}   67.3    or        Zero to 3,200
FINAL2006JULY/AUGUSTSCUP  76,908        {49,624}46.2   or       6,000 to 140,000


Here's another: 
This MRIP table starts in 2001 - should have 13 years. Where the year is omitted the estimate is zero. New Jersey Shore Tautog, Wave 2, Just March/April – Just Tautog Caught From Shore Along New Jersey. 
Estimate StatusYearWaveCommon NameTotal Harvest (A+B1)PSE
FINAL2005MARCH/APRILTAUTOG0.
FINAL2009MARCH/APRILTAUTOG5,00196.0
FINAL2010MARCH/APRILTAUTOG173,09286.4
FINAL2012MARCH/APRILTAUTOG3,701101.7
PRELIMINARY2013MARCH/APRILTAUTOG9,730112.4

And its MRFSS counterpart.  
Note carefully how the "new & improved" MRIP estimates dealt with MRFSS's 2010 inconsistency – They added 100,000 fish!!!
Species: TAUTOG - 2007 to 2011 -- NJ -- Shore -- '07 = zero -- '08 = zero -- '11 = zero  
YearHARVEST (TYPE A + B1)PSE
20096,835100   
201071,75670.2

I believe Congress thought the old catch-estimating formula's failing was MRFSS' dependance on a scatter-shot telephone survey to calculate private boat & shore effort. 
That's why Congress created the very unpopular salt-water fishing license law. I supported the fishing license because I can plainly see how it could tighten up our catch estimates. 
Now I understand the MRIP team plans on experimenting with salt-water license data beginning in 2015. 
That's what was supposed to sharpen the estimates. An IMPROVED PHONE SURVEY was THE REPAIR offered by MRIP. That's what was supposed to take place by 2009!!! 

These estimates are a mess. A hundred thousand more fish added to the dumbest estimate ever.. Estimates that make no sense to industry at all.. 
I believe a true repair can be fashioned by using federally mandated fishing licenses to determine phone survey/mailing targets & by using For-Hire "Vessel Trip Reports" (VTRs are catch reports filled out daily) to double check For-Hire estimates. Then, with as firm a number as possible from the For-Hire side, do a "Percentage of the Fishery" comparison to look for red-flags in the estimate fields. 

If regulators were made to reconsider each specific spike in the MRFSS/MRIP catch estimates that forced the sea bass fishery's regulatory tightenings, they'd soon discover recreational overfishing only an artifact of their data and not at all real. That would allow experimentation with the sciences of Population Biology & Habitat Ecology.

Fish Do Not Fall From The Sky. 
We must learn how to make fish. 
Surplus-production is the true backbone of fishery management. It begins with fertilized eggs – more fertilized eggs. 
Guided Skillfully By Management, Fishing Pressure CREATES Surplus Production. Sadly, right now management's enveloped in an enormous smoke-screen of bad estimates. I believe history will recognize this period as precisely how NOT to manage a fishery.  
Thankfully, however, we've already witnessed surplus production  
..now to do it on purpose. 

Note 1998 to 2004 in the graph below by Dr. Gary Shepherd. 
Churchill: "However beautiful the strategy, you should occasionally look at the results."

 

When management has discovered habitat & begun to manage fishery production, when we've unbuckled them from the ludicrous; Then we'll enter a period of boundless increase. 
I just hope I can hold on to my boat until then. 

Regards,
Monty 

Capt. Monty Hawkins 
Partyboat Morning Star
Ocean City, MD

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