Fish Report 4/22/19 DC Continued
Another Sample Letter (more simple)
Names & Addresses - even some email addresses
How can You look at MRIP estimates?
This is a simple letter I thought might be useful to fishers who want
to sound off about MRIP's recreational catch estimates - Personalize
it a bit, perhaps adding an example of bad data you find most
egregious - print & sign - send..
Dear Fishery Manager/DC Congressperson/Secretary of Commerce etc,
Recreational fishers have always had serious trouble with NOAA's
recreational catch estimating program. Issues began as soon as marine
fisheries management began. Today, under MRIP, those troubles are
worse than ever. Already terrible at it's 2012 release, since MRIP's
recent "recalibrations" our situation has become untenable.
Along the Gulf of Mexico, all States have given MRIP the boot and are
doing their own catch estimates.
Indeed, it seems there is no remaining support for MRIP's estimates in
the fisheries science & management communities at the
State/Council/Commission levels.
NOAA needs a test—a way to check recreational catch estimates.
Currently there is no amount of recreational catch that isn't possible
in statistician's eyes ..while at sea we see the estimates for what
they are - a fraud.
It is not true that 1.6 M lbs of cod crossed New York's recreational
docks from Private Boats in hearty winter weather, and their Partyboat
fleet didn't get in on it. There's no chance that happened.
It is not true the "Average Size" of shore-caught stripers in CT were
19.6 lbs - MA 33.4 lbs - RI 33.8 lbs.. And the grand prize for
"Average" Shore caught stripers is RI in 2018 at 45.1 lbs!
It is not true Maryland's Shore anglers caught more than 3 years worth
of MD Party/Charter sea bass, and they "Averaged" 1.4 lbs apiece -
Impossible!
It is not true that in Delaware last year sea bass caught from Shore
'averaged' 1.9 lbs..
All in all? There's virtually no truth at all in MRIP's catch estimates.
Don't let NOAA's MRIP tell you "these estimates are fine in coastwide
collection" as they always have in years past. This claim is
disingenuous in the extreme. Management uses MRIP in its smallest
pieces - Wave, State, & Mode - and never simply at the Coastwide
annual level - to create recreational regulation.
Please assist us in having MRIP corrected. We need catch estimates
that represent real catch values - not this worsening fraud.
Regards,
Voter Constituent
9900 Voter Lane,
Votertown, USA
Readers are from many states. Here's a great site to look up and get
in contact with your Congressman & Senators:
https://www.senate.gov/reference/reference_index_subjects/Directories_vrd.htm
For your state's Fisheries - do the Google..
Because NOAA is part of Dept of Commerce - Secretary Ross is the
big-big cheese in all this.. He bought MRIP's line about how "the
estimates are just fine in 'coastwide collection' a couple years ago.
Now to see if we can change his mind.
thesec@doc.gov
Secretary W. Ross
Dept Of Commerce
1401 Constitution Ave
Washington DC 20230
RDML Tim Gallaudet is one smart dude - really impressive. He's
undersecretary for NOAA (the boss) and graduated Annapolis & Scripps
Institute. Guarantee he listens. And he fishes. Convince him MRIP's a
shell game and change will come swiftly.
Timothy.Gallaudet@noaa.gov
RDML Tim Gallaudet
Dept Of Commerce - NOAA
1401 Constitution Ave
Washington DC 20230
These men at the top of NOAA Fisheries have all heard this before.
They too believed MRIP's "we have this" baloney..
Their address is:
(Name) NOAA Fisheries
1315 East-West Highway
Silver Spring, MD 20910
Chris Oliver came up through the ranks of Fisheries. Over on the West
Coast they took care of recreational catch data long ago - it's right.
He's "Assistant Administrator" for NOAA Fisheries. That means he's the
big boss at Fisheries. He's heard every kind of fisheries problem
imaginable - including our beef with MRIP. Now is different though. I
guarantee he's heard about it in-house recently too.
chris.w.oliver@noaa.gov ,
Dr. Werner is in charge of NOAA Fisheries Science. May not have time
for this. But he is NOAA Fisheries' chief science advisor. Once MRIP
is exposed, NOAA will have appeared a fool - maybe they'd like to
repair this program now instead.
cisco.werner@noaa.gov
Sam Rauch is in charge of regulatory programs for NOAA Fisheries.
Maybe he'd like to know our regs are based on catch info that's 100%
codswallop.. I've never heard a peep back from him, but it can't hurt
to try.
samuel.rauch@noaa.gov
If you do write, please CC a snail mail to my Congressman's guy too.
Please.
Congressman Dr. Andy Harris
C/O Adm. Tim Daniels
100 East Main St - Suite 702
Salisbury, MD 21801
You may not get a reply, but it will indicate to him sincere interest
of recreational fishers..
Greetings All,
I've been encouraging folks to write about fisheries issues for many
years. Almost all of these letter campaigns were focused on NOAA's
recreational catch estimates - a program today called MRIP. We've
brought about change in this fashion - promise. Unfortunately, it's
done nothing but get worse! Today our need of getting MRIP's
recreational catch estimates right has never been greater, nor has our
case ever been stronger. It's so strong today that even regulators
have great difficulty swallowing some estimates—managers can no longer
pass "The Red Face Test."
Statistics are a highly complex study. One aspect of such study is
'probability theory'. The catch estimates I've been writing about have
a probability rating of zero - these catches, often represented by
enormous numbers, could not have happened. That's not really so
different than from the last 20 years of complaining. Todays worst
estimates, however, are more blatantly ridiculous than we've ever
seen—and there's a lot more of them..
My first bout with Catch Estimates was in 1998 when the Mid-Atlantic
Fishery Management Council (MAFMC) closed sea bass for two weeks in
August based on a 1997 NJ Party/Charter assessment where their catch
tallied 4.7 million sea bass. The size limit had been brand new - NJ
ignored it.. NOAA made us all pay. (Imagine if you will - had NJ's sea
bass production, alone, been capable of a 4.7 million Party/Charter
sea bass catch in the dawning of regulation--before there'd ever been
any protection whatever, why in the Billy Blue Blazes are they
cracking our eggs today when from Maine to Virginia all Party/Charter
doesn't catch a half-million sea bass.. Their catch estimates tell
them, "It's because we've been unable to reign in Private Boat
catch--now they catch 5 million sea bass! What a bunch of horse
feathers.. I've written time and again, this fancy statistical fog
lays blindingly across all our fisheries. They honestly have no idea
what works because they have no real sense of what we catch.)
NOAA has always held, & NOAA has always told Congress: 'Our
recreational catch estimates 'blend in' the bad portions and create a
quite accurate coastwide estimate.'
In truth, however, wildly inaccurate estimates from different states &
different modes (eg Shore, Private Boat, & For-Hire) are so far
removed from reality they cannot be included in a broader 'coastwide'
estimate in any fashion and still offer an accurate representation of
our catch.
Regardless, if you write to your Congressional reps, NOAA will, again,
tell them their "Coastwide Accuracy" fairy tale.
Here's the thing, while true that these catch estimates were designed
to create an accurate picture of coastwide catch (& failed,)
management almost never uses the broader coastwide estimate in
regulation. Instead, Managers use catch estimates down to their lowest
levels: one state, one two-month 'wave,' and one mode, are frequently
used to create regulation.
For example, consider the 2017 NY Wave 6(Nov/Dec) Private Boat sea
bass estimate of about 3 million lbs.. Here MRIP asserts NY's Private
Boaters landed quite nearly the entire Recreational sea bass quota in
less than 25 fishable days in November/December.. The other components
of NY's sea bass Wave 6 estimate are Shore with zero & Party/Charter
with 25,000 lbs.
(I have detailed instruction below on how you too can slide down this
rabbit hole and nose around in the Estimates yourself.)
Take a look at any state's summer flounder regulation. That states can
even have different regs--not coastwide--was decided by dividing
recreational quota (called RHL or Recreational Harvest Limit) among
states - these "state by state" recreational divisions are based
solely on NOAA's state by state catch estimates. Then, when seasons
are set (& must be approved by NOAA) those dates are made by delving
into so-called 'wave estimates' - the 6 two-month periods such as wave
2, March/April.
Say a state needs to reduce catch by 30% to remain in compliance with
recreational quota. Managers will then look around in wave data and
see where they can cut catch. Maybe they'll cut a month of season
based on Sept/Oct (Wave 5) data. Maybe they'll increase the size limit
or reduce the bag limit across the entire season. All these decisions
of how to cut (or increase) catch are based on MRIP's catch
estimates..
Some states have even given more lenient regulation to Shore or
Party/Charter fishers. These would be 100% based on 'mode' estimates
where a wave estimate is divided by 'shore, private boat, &
party/charter.'
Because of a repair to Recreational For-Hire (Party and Charter Boat)
in 2003, (a repair that came about because of letters!) it's with rare
exception when some other mode than Private Boat shows most of the
catch. This is how Private Boat regs can be more stringent, & other
modes can be liberalized. (For instance when Massachusetts For-Hire
was allowed 8 sea bass & Private Boats allowed 4..)
Bottom line? When NOAA tells your Congressional reps "MRIP catch
estimates are just fine in coastwide format and therefore the whole
program is sound," they're either being disingenuous in the extreme,
or are sorely uninformed.
For numerous specific examples of bad MRIP catch estimates please go
to morningstarfishing.com and click 'fish reports' up top. My previous
4 reports detail numerous violations of a statistical pillar -
Probability. I list estimate after estimate that could not possibly be
true.
Have done so for years..
In statistics if a very low or no probability field is found, then
that data-set should not be given/added to an estimate. With MRIP's
estimates we often/always see where the wildly incorrect aspects of a
set actually drive regulation. The wild fliers are what's used against
us.
I do not have a PhD in statistics. I do, however, have a lifetime of
counting recreationally caught fish at sea. I have to know how much
pressure is being put on our reefs so that my clients will catch—every
skipper who is reef fishing with success must have a pretty good idea.
Folks doing the estimates are PhDs in statistics ..but have never
counted fish at sea. They have no idea, no means of conceptualizing
what might be true in recreational catch. So far as I can tell, there
is absolutely no level of catch that, to them, isn't perfectly
feasible.
To give them a basis for rejection NOAA must create a test.
Statisticians need grounding in reality in order to create "Bayesian
Stops." Here grand complexity in statistical formulation is made most
simple by saying: a Bayesian stop is the number which an estimate
cannot surpass or be lower than.
It is my belief these stops are best created by my "Percentage of the
Catch Theory."
Say NOAA's MRIP statisticians have a table to work from showing NY's
recreational Atlantic cod catch should never show Private Boat
catching more than 20% of NY's total recreational cod catch. (It's a
winter fishery comprised mostly of party & some charter boats.) With
zero shore-caught NY cod, it's cleanly 80% For-Hire & 20% Private Boat
..probably generous in the extreme to Private Boat at 20% who may
actually land less than 5% of NY's cod.
These are actual MRIP catch numbers - currently NOAA has NY Private
Boat cod at 1.7 million pounds in 2016 and 1.6 mil in 2017. Total
Party/Charter is less than 55,000 lbs in '16, & even less in 2017..
Bayesian stops would have cut these Private Boat estimates to under
10,000 lbs — & never allowed over 1,500,000 lbs!
Sakes. It's pretty simple.
Truthfully, in any fishery where there's a large For-Hire component
these "percentage of the catch" calculations would offer management
much more accurate information than they've ever had before.
Ever.
Complain! Send some letters! Put some emails out.. Forward this and
other emails of mine. 'Share' them on Facebook...
Instructions on how to access MRIP estimates below.
Good Luck!
Regards,
Monty
Capt. Monty Hawkins
Partyboat Morning Star
Ocean City, MD.
mhawkins@morningstarfishing.com
*********
How to do you own estimates investigating:
A) Google search "MRIP query"
B) select "run a data query"
C) in blue small print select "open our query tool"
D) a box will pop up - I am an experienced user.. select 'experienced'
(You're not, But I am! You could, alternately, look at all their
reasons MRIP is so great..)
E) beneath top rt select bar 'select a catch query' - click "go to
query" (it'll come up 'Time Series.')
F) select the data you want - I always select "all areas combined" -
though it can be broken down to Bay/Ocean etc, it gets depressingly
inaccurate.
Chose - Years you want to see - whether by two-month wave or annual -
region or state (for MAFMC-wide regs select North & Mid Atlantic -
here you can chose by each state or all those states combined) - then
species - then 'mode' - here is where you can break out shore/All For
Hire/ Private Boat etc..
Type of catch! Oh Boy! The third one is "Harvest"
You may also want to look at releases because THAT's where release
mortality is coming from...
And finally, Table or Graph. I will generally select table. The graph
however shows the entirety of PSE (as in margin of error from a
political poll - but vastly larger spreads..)
Be Careful! Double check your selections! You'll swiftly see Estimates
that couldn't possibly be true - make sure you've chosen fields
correctly and start complaining!
Regards,
Monty
