Monday, April 15, 2019

Fish Report 4/15/19

Fish Report 4/15/19 
Follow Up From DC Report 
Write A Letter or Two! 
Good Science Step Aside, Bad Statistics Own The Process..

I smell blood.. No one in fisheries management has faith in NOAA's recreational catch estimates anymore. 
It's time to write! 
(Alright, I'll mention the Reef Dinner too! It's May 5th at Seacrets in OC from 4:30 to 8 - Tix at the door $25. Come join us!) 

Greetings All, 
Am beginning yet another campaign to have recreational fishers write their Fisheries & DC Representatives. We must, yet again, seek relief from NOAA's recreational catch estimates. NOAA has to pursue truth in these estimates. 
How bad are they? I've recently discovered a New York Sept/Oct sea bass estimate from 2010 - a time when NY's sea bass season was only open 12 days - where NY's Private Boats "landed" over a million pounds of sea bass during just those 12 days of September. Pretty neat trick.. Our entire recreational quota that year was barely 3 million pounds. 
While recreational quotas might falsely dissipate on a computer screen without harm to a fish population; increased commercial quota will most assuredly be sold across a dock. 
Our recreational catch estimates have grown so bad, they're causing increased commercial quotas -- while at the same time these sky-high overestimates of recreational catch leave us falsely accused of "overfishing." 

I think it's high time we brought NOAA's recreational catch estimates under control. Whether you'd like to help - and it will take many voices - or are simply interested in what I've recently uncovered with the "Marine Recreational Information Program" (MRIP, NOAA Fisheries' marine recreational catch estimating program that began in 2012,) please read on. I have a sample letter readers can personalize below to send to their reps in DC & State Fisheries. 
MRIP was no good right out of the gate. Now it has now undergone two "Recalibration" events that have increased recreational catch/landings by astronomical amounts. 

MRFSS - the Marine Recreational Fishing Statistics Survey - was the program that estimated marine recreational catch (not freshwater) from Maine to Texas beginning in the early 1980s. Many of us (some anyway) fought MRFSS data year after year as an unrealistic view of recreational catch. We were especially successful in 2003 with the redoing of MRFSS's For-Hire Party/Charter recreational landings by having statistical spikes removed--a 'statistical spike' in a rec catch estimate can & does fill an entire coastwide quota without ever having truly been fish in coolers.

What did we see back then that made us fight MRFSS For-Hire Party/Charter estimates? One of the largest For-Hire mis-estimates ever (the largest?) was MD's 1982 Sept/Oct Sea Bass estimate of 4,183,000 lbs of sea bass (MD Private Boat pulled a zero, and rightly so as you'll soon learn.) Sakes.. In those days every Party/Charter boat was seatrout fishing in the fall. So were Private Boats. The wrecks were completely fished down. There were no regulations on sea bass or tautog. Trout (weakfish) started in mid August with spike trout (small weakfish) leaving the bays above us and coming south. No one was fishing for sea bass in Sept/Oct. Clients back then would have raised a ruckus if we'd tried to go sea bassing during trout season  
..therefore this 1982 For-Hire estimate is 4,183,000 lbs too high! - in just two months - from just one state, Maryland, with a single ocean access inlet.. (Private Boat estimates have gone on to be much worse than Party/Charter ever were. Back then these statistical spikes were almost always in For-Hire. That MD example is just one of the worst from before the repair to For-Hire catch estimates..)

It has become paramount that we understand & repair MRIP's wild overestimates. You see, "Catch," whether Commercial or Recreational--& especially combined--is a truly important value for scientists assessing a fish population, or "stock assessment" as they say in fisheries science/management. 
Commercial catch is sold by the pound and thus offers fairly solid catch data, save what small percentage is back-doored.. Because recreational catch is 'estimated' & now shown as crazy-high on computers, it's nowhere near as firm as Commercial landings data. With MRIP's sudden meteoric rise in recreational catch, fisheries scientists think now-huge recreational "catch" from many species of fish must be supported by higher populations of those fish.
I'm talking about millions & millions of pounds of recreational catch that never happened. Scientists' previous "Stock Assessments" would not support recreational catches as shown in MRIP's current recreational catch data. 

For instance, we've just witnessed our summer flounder (fluke) stock assessment climb. That is, scientists say the flounder population must be much higher than previously thought, mostly owing MRIP's recent recreational catch estimates. We could not possibly have taken as many flounder as MRIP claims had the original population assessment been correct. Fisheries personnel from management and science must accept MRIP's catch estimates as "the best available science." If our catch is no longer X, but now XX, then the live population we "took" those fish from at sea  must also no longer be XX, but now XXX.. 
And, because "recreational fishers are already catching more," commercial fishers were given a 49% increase in fluke/flounder while we got nada. 

Recreational catch ghosts-away on computer screens. Only a small percentage of MRIP's asserted recreational landings are factual. However, any new quota given commercial fishers will, I promise, become fish sold across a dock. 
Fisheries science stock assessments are now so mislead by poor MRIP data, we have no idea how much damage is being done by raising stock/population estimates--and increasing quotas--based on untrue recreational catch values. 
Administrators of these catch estimating programs, and their bosses above them at NOAA, have always held, "Sure, there can be a couple bad mode/state/wave estimates - but when they're all blended together coastwide, they become accurate. And besides, Mr/Mrs Congressperson/Senator, we only use these estimates in coastwide form as they were designed to be used." 
Oh heck no.. That's Pure Phooey. 
I probably have a dozen letters to my Congressional Reps from various NOAA administrations over the years explaining to my Congressman/Senators how MRFSS and then MRIP are "Coastwide" estimates and just fine for what they're doing. "Capt. Hawkins doesn't understand..."
That "coastwide estimates" are fine was never true, not since the beginning of management. 
For instance, when recreational summer flounder quotas were first devised, a more accurate assessment may well have led to different divisions between Commercial & Rec. It's a certainty that when state by state quotas were divided, MRFSS estimates played a singular role. From 10 year, 5 year, 3 year, & a single year's estimates - one single year gave every state but NY their best summer flounder split. Here "tyranny by democracy" raised its head and NY caught the short straw for fluke. It's been a huge pain in their backside ever since. 
The reason there's so much variance in recreational regulation from state to state is because there's so much variance in MRIP's estimates. 

As I've mentioned, by 2003 we'd raised so much stink about MRFSS's For-Hire estimates - we were, after all, telling NOAA what we caught everyday in "Vessel Trip Reports" (VTRs) - Party/Charter estimates were formally corrected. NOAA promised my Congressman back then, Wayne Gilchrest & Chair of House Fisheries, that they'd use VTR data in their For-Hire estimates. I see no evidence of that today. Never have. Still, it's much more rare to have a statistical spike in the For-Hire mode of MRIP's estimates. (BTW - other MRIP modes are Private Boat & Shore. Waves are two month periods. "Wave 3 RI Private Boat" would be what Private Boats caught in Rhode Island during May/June of a given year.)
The year after For-Hire's repair; in 2004 Private Boat catch estimates began a steady march upward. Today Private Boats from one state, in one two month period, might have outfished All Commercial landings from Virginia north. Or, as in NY's 2017 sea bass estimate, NY's Private Boats alone (and especially in harsh early winter weather) outfished ALL Commercial Trawl/Trap & Party/Charter by 200,000 lbs.. 
Gulf of Mexico states have now given MRIP the boot. They are all doing their own catch estimates. 
It's high time we brought MRIP back to earth along our coast too. 
Not just sea bass & flounder. Every marine species is subject to MRIP's under/over estimating. 

As evidenced by this recent summer flounder stock assessment and liberalization of commercial quota by 49%, MRIP's statistical sepsis is getting serious. 

Here are some Striped Bass (aka 'Rockfish' in Maryland) Total Catch numbers (including all throwbacks) to illustrate the rise in MRIP's numbers. This data is from where NOAA still has MRFSS/early MRIP comparisons available--MRFSS was all done in 2012. 
MRIP has since had two 'recalibrations' sending catch sky high. These numbers are for ALL stripers caught from Virginia north, whether released or not.  
In 2004 we were first told the total was 10,048,000 striper/rockfish by MRFSS. In 2012 MRIP replaced MRFSS. That same 2004 estimate rose to 11,055,000 at MRIP's launch. After MRIP's two recent "Recalibration" events of the last 3 years, that catch has moon-shot to 24,766,000.. way more than double - That's a 147% increase. 
In 2006 MRFSS was at 11,505,000 and fell to a slightly lower 11,255,000 at MRIP's launch in 2012.. Today's MRIP value is 24,906,000 striped bass total. More than double the original MRFSS estimate - That's a 116% increase. 

We fought MRFSS in the early/mid 2000s because we thought their estimates far too high. In the 2007 re-write of the Magnuson Stevens Act Congress ordered MRFSS repaired by 2009 -- we got today's MRIP ever-increasing madness beginning in 2012. 
MRIP recalibrations have our Total Recreational striper catch at 27 million both in 2016/17, & 25 million in 2018. Now, because NOAA's fishery scientists assign a 9% "recreational discard mortality" (fish that die on release - a number I think too high) with MRFSS estimates the total discard mortality might have been pushing 800,000 - but with current MRIP estimates those fish that died w/o ever swimming in hot oil are above 2 million.. 
Everyone in management wildly arm-waving: "Oh No!! The discard mortality!!" 
Gosh, I bet MRIP's recent recalibrations have something to do with that. 
Take a hard look at how striped bass recovered in the 1980s & 90s. How in blazes is there any difference between release mortality then & now? 
Mycobacteriosis? Yup, now that's different. Chesapeake rockfish are sick. They're dying.. 

A curious development: because For-Hire estimates are done as agreed back in 2003, they've not budged at all in MRIP's recalibrations. Party/Charter offer the best recreational data we have, except for straight VTR reports. 
I've been trying to get NOAA/Council/Commission to look at my "Percentage of the Catch" theory for years. 
Consider: Why did I spend a good chunk of a recent afternoon filling out permit applications when Party/Charter has such a LOW percentage of the catch in MRIP's portrayals? 
If Party/Charter only catches 5% of our coastwide summer flounder & less than 10% of our sea bass--and that's exactly what MRIP portrays; why such higher levels of scrutiny for Party/Charter? Why these permits? 
The answer, of course, is that MRIP is dead wrong. For-Hire does catch a significant portion of recreational landings. 
Yet MRIP's For-Hire numbers--still not tight--are a dern-sight more accurate than Private Boat & Shore modes. That increased accuracy, and a closer-still examination from VTRs alone, can be used to illustrate MRIP's infectious inaccuracies. "Infectious" in that they're affecting all of fisheries management & science. 

Let me show you what I mean by "Percentage of the Catch Theory" in Summer Flounder (SFL). Everything here is computed from North & Mid-Atlantic combined MRIP landings. 

The Party/Charter (For-Hire) recreational sector is strongly focused on SFL. They're a crowd pleaser. In some areas For-Hire landings likely exceed 50% or even 60% of that region - around Montauk, for instance. In other areas For-Hire might only be 35% or so. (To hear some local guys fishing our back bays along coastal Maryland, partyboats catch ALL the flounder!) 
To properly create percentage values NOAA Fisheries/Councils/& Commission would be required to truly have a deep look around. 
Although only illustrative here, I have written/spoken with many in my trade. I believe my For-Hire percentage numbers are low - on purpose. 
MRIP has For-Hire fluke/summer flounder landings in 2018 at 383,000 lbs. (VTRs would show a lower number still.) So: 383,000 lbs For-Hire flounder becomes a total Recreational Boat Fisheries Landings (not Shore) of 1,094,000 lbs when computed as if Party/Charter had just 35% of that fishery. (I'm using - Query: "383,000 is 35% of What Number" ) 
Giving For-Hire less credit, it increases to 1,915,000 lbs total Rec Boat Landings if computed at a lower 20% For-Hire Percentage of the Catch.. 
MRIP, although they valued For-Hire more greatly in 2018 than usual, has For-Hire at just 6% of coastal SFL Rec Boat Landings. 
MRIP's Private Boat estimate is 5,975,000 lbs. 
If MRIP's For-Hire estimate of 383,000 lbs is ballparkish, then with For-Hire at 20% the total, Private Boat would be substantially lower at 1,532,000 lbs & MRIP is 4,443,000 lbs too high. 
With For-Hire landing 35% of the total recreational boat landings, Private Boat harvest would be just 711,000 lbs & MRIP is 5,264,000 lbs too high. 

In 2017 MRIP has For-Hire at 385,000 lbs of summer flounder. 
Private Boat is shown at 8,537,000 lbs. 
With MRIP's current values, For-Hire landed just 4.3% of all Recreational Boat catch. 
With For-Hire at just 20% of Rec Boat Landings, the Private Boat estimate becomes 1,540,000 lbs - not 8,540,000 lbs.. 
With For-Hire at a still-stingy value of 35% total fluke recreational boat harvest, Private Boat landings become 715,000 lbs - a difference where MRIP is 7,822,000 lbs too high.. 

In 2016 it's worse. MRIP's Private Boat estimate is an astounding 10,757,000 lbs too high with For-Hire at 35% & 9,683,000 lbs too high at just 20%... 

My results were essentially the same for sea bass. Those numbers are in Fish Report 3/27/19 if you'd like to have a look. 

"Recalibration" indeed. 
I've asked for years & years to have "Bayesian Stops" put on MRIP's values. A Bayesian stop is most simply where a statistical value cannot exceed a certain number. As it stands, there appears to be no catch considered impossible by MRIP.

I wonder what happens to a fluke stock assessment when you back 11 million pounds of catch out? Probably makes that population appear a lot smaller. 
It's very likely the sea bass catch from 2017 is over 10 million pounds too high--always at least 5 million lbs too high.  
Wonder what happens to a smaller-than-they-thought population when commercial catch is jacked-up? 
Hmmmm... I think we've been there before. 
It was in the 1980s.  

Everywhere I look I see bad recreational catch estimates throwing up so much smoke, the truth of our many tasks in fisheries restorations cannot be seen. Seafloor habitat restoration/creation, means of manipulating spawning production for best result -- shoot, we've yet to even (officially) figure out the ocean's turned green. 
There's always a battle over recreational regulation. Always. 
It's a heck of a distraction. Good science step aside - bad statistics own the process. 

High time we had clarity where rec catch is concerned. There has to be a way to test MRIP. If NOAA's going to call it "Scientific Information" then it must be testable. I think "Percentage of the Catch" would work fine; would swiftly push NOAA to a repair.. 
NOAA needs to fix MRIP or be done with it. 
(See sample letter below) 


Capt. Monty Hawkins 
Partyboat Morning Star 

A letter you can use as is - or rewrite to suit. Shorter is better. I'm awful at "short" letters..
For addresses look up Secretary of Commerce - Undersecretary of NOAA (this one's important. He used to be NOAA's General Counsel.) - Your State's Natural Resources & Fisheries - And, of course, Senators & Congressman...  

Please also CC your letter (regardless if you're a constituent) to: 
Congressman Dr. Andy Harris
C/O Adm. Tim Daniels 
100 East Main St - Suite 702 
Salisbury, MD 21801 

For your DC reps, LEAVE A STREET ADDRESS THAT SHOWS YOU ARE A CONSTITUENT! It's best to write a field office. Less letter traffic..

Dear Congressperson/Senator State Fisheries Director Such & So -- OR, better still, a staffer you've established coms with.. 
In 2007 Congress ordered NOAA to repair/replace their MRFSS recreational catch estimating program for marine recreational fisheries from Maine to Texas by 2009. When finally finished in 2012, the result, MRIP, offered far worse estimates than we'd previously had. 
NOAA's going to tell you, as they always have for 20-some years, "A few bad estimates from one state or two-month period smooth out & become quite accurate as a 'Coastwide' representation."
This is disingenuous in the extreme. 
For one thing, modern fisheries management breaks down MRIP estimates to create State by State and seasonal regulation. All state & regional closures, size limits, & bag limits are based primarily on MRIP's catch estimates. It matters a great deal that they be accurate at every level. 
For another thing, there is no cap on MRIP's estimates. The 2010 estimate for NJ Shore Tautog in just March/April, for instance, (a time when quite nearly none are caught) shows nearly a million pounds of catch. This is far more than ALL Commercial Trap/Trawl & Recreational Party/Charter caught, all combined, all year. 
MRIP's catch estimates are riddled with such examples. Take NY's Private Boat black sea bass from 2017; here we see one state's Private Boats catching more sea bass than all the trawlers, trappers, partyboats, & charter boats from Maine to Virginia - and most of that impossible catch came in Nov/Dec when even 100+ foot partyboats often have a hard time getting out.
We must create a test for NOAA's Private Boat & Shore catch estimates. Such a test could be created by comparing Party/Charter reported landings against MRIP's estimates via "Percentage of the Catch." 
An example: In the above sea bass estimate, NY Partyboats do indeed fish for sea bass far offshore in Nov/Dec, often in harsh conditions. Some of those skippers have reported it would be extremely unlikely NY's Private Boats would even land 5% of the sea bass they do. Most private boats are either put up for winter then or engaged in the striped bass or tautog fisheries. 
Because Party/Charter is shown at 25,000 lbs of sea bass in just the Nov/Dec period, managers could safely assume Private Boats landed 1,250 lbs or so - and NOT 3 million!
Were NOAA to sit down with knowledgable recreational fishers of any & all stripes, they could soon develop Bayesian Stops for Private Boat & even Shore to some extent. 
Having now undergone two recent "Recalibrations," virtually every single MRIP estimate these days is a statistical spike. 
Recreational catch estimates have now grown so bad they're creating havoc in fishery scientists' population assessments: "After all," reasons a fishery scientist, "if recreational fishers caught THAT many, then the population must be much larger than we'd thought." 
For 2019 managers have raised commercial summer flounder (fluke) quota by 49% while recreational fishers see no increase whatever.. We're "already catching" ours.
The point here is not to deny commercial fishers an increase if it's sustainable, but because the increase stems solely from MRIP's illusion of huge recreational catch, managers may well be doing serious harm to the summer flounder stock - they cannot know. 
On & on & on it goes.. 
MRIP has nice cod being caught from shore in Massachusetts; jumbo sea bass being caught from shore in MD, DE, NY, CT, RI, & MA -- in 2016 MD Shore sea bass catch was shown to be 178,000 lbs & averaging 1.4 lbs apiece (we can  only find one angler who claims to have caught a barely legal keeper and it didn't weigh a pound..)   
MRIP shows nearly 3/4 of a million pounds of striped bass from shore in Massachusetts that AVERAGED 42 lbs apiece! The average size shore-caught fluke in NY in 2016 was 4.8 lbs - In Virginia Private Boats caught nearly 500,000 pounds of cobia in May/June 2015 that averaged 47.8 lbs apiece. . . . 
None of that happened. There's plenty more too. 

Even Scientists & Managers Have Lost Faith In MRIP.

Always & Forever Over-Quota, this is why: MRIP's estimates are loaded with impossible catches--mostly in Private Boat.   
MRIP was a mess when it began in 2012. Now, after its two "recalibrations," MRIP has completely lost credibility in the science & management communities. 
Recreational fishers need to be treated fairly. That's not possible with catch estimates no one believes. 
Your loving constituents,
John & Jane Doe

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