Monday, April 03, 2023

Fish Report 4/3/23 - On Correcting MRIP's Effort Estimates With Video..

Fish Report 4/3/23 
On Correcting MRIP's Effort Estimates With Video..

Yes, my tale here is a long read for these times. I thought any associated with, or participating in fisheries would want to know a good part of the story.. 

Over and over this last decade NOAA has kicked this issue to statisticians at the National Academy of Sciences (NAS) for review. NAS has absolutely no way of knowing about fishing - but they love statistics  ..so MRIP keeps going unabated. 
Repair has to come from our DC representatives. Ask yours to put enough video cameras up to get an excellent angler effort estimate around the coast. Then tell Congress to fix MRIP's crazy effort estimates so we can go fishing! 

Write Your DC Reps (Senators & Congressman - see addresses far below). Email will get read but if you snail mail a regional office they'll reply in writing. 

Here's the crux of it. A difference of 2,464 anglers fishing on Private Boats every day.. With video evidence we'd see hundreds of estimates like this. Pretty easy to over estimate catch like that..
1) In July/Aug 2020 (wave 4) MRIP's total effort estimate for all ocean-only Private Boat effort is 185,341 angler trips. Divide by 4 per boat and again by 60 days and you'll see 772 Private Boat trips a day leaving Ocean City MD's inlet. (Oyyyy.. Nonsense! Even the White Marlin Open would have just over 300 boats if they all went, and that's the biggest billfish tournament in the world!) So: MRIP has 772 boats a day.. Video boat count for the same period, judging centerpoint by bar graph, is 37,500 angler trips during the wave or 156 boats per day using the same parameters of 4 anglers and 60 days.  That's 616 less boats & 2,464 fewer anglers per day. Per Day! 
(I'll note MRIP's July/Aug ocean-only high for Maryland in the last decade is 311,675 angler trips for 1,298 boats exiting OC Inlet daily or 5,192 anglers trips a day. Marinas would have been so profitable. Ahhh, actually? I expect we'd have to build a big new marina, huge, to have that many boats fishing every day..) 

Time after time after time I've reported catch estimates that could only be fantasy - that had no possible path to reality. 
"Its peer reviewed" would be the retort.. 
Well, I suppose these are peer reviewed too. Except here you can plainly see they're dead wrong. Not with logic or a fisherman's memory - but video. 
A hard count.. 
We've never had the advantage of video evidence before. We must write. 

Greetings All, 
This is my most important essay ever. 
After long decades we now have proof, conclusive proof, that NOAA's recreational fishing effort & catch estimates for Private Boat are far too high. Their use in science and management required by law; Marine Recreational Information Program (MRIP) recreational catch estimates are, I guarantee, the source of bad recreational regulation.
Seriously, every time you're stunned by news of tighter regulation, it's because managers were shown how recreational fishers had taken more fish than they were allowed the year before. That information is from MRIP.  Commercial catch has nothing to do with it. Party/Charter catch either. Private Boat (and occasionally Shore) MRIP catch estimates are why regulations are seemingly never tight enough - they're why recreational access to our marine fisheries lessens. Despite managers, scientists; even recreational & commercial fishers seeing ample evidence a fish population is doing far beyond management's expectation; MRIP keeps inventing more recreational anglers - increasing recreational 'effort' via statistics so we appear to be "overfishing." When a catch every fisheries professional realizes is impossible shows up on their computer screen? Voila! "Overfishing!" 
Truthfully? There's no joy in it. Managers don't like tightening regulations; but the law is the law. Going over-quota always has regulatory consequences. 

US East Coast and Gulf recreational catch estimates have always upset fishery science's accuracy; management's fairness of regulation, and indeed; poor recreational catch estimates today threaten the continued success of fisheries restorations for which we've already claimed victory. 
If you've ever wondered how in the Billy Blue Blazes recreational anglers can possibly "overfish" when only allowed a handful of 16 inch sea bass in a short season - MRIP's catch estimates are why. 
Recreational fishers from Maine to Texas need to see what Maryland's video boat counts showed compared to MRIP's effort estimates - save one small instance video counts are incredibly lower. There are tables below from 5 two-month periods of data. The value of video records is clear. 

I first laid eyes on a 'recreational catch estimate' in 1998 - 25 years ago. In 1997 recreational partyboats in NJ were said to have increased their catch to over 3 million sea bass -- a million (a million!) more sea bass than the year before. That statistical overfishing caused a closure for two weeks during August of 1998. Although I'd begun self regulation in 1992, federal and state sea bass regulation was only in its second year. Our region's sea bass population was growing incredibly. We sure didn't need a closure based on statistics with only a stopped-clock's chance of being correct. Those very statistics would upend my industry with nonsense time & time again though. 
Three million sea bass is a lot of fish.. Thirty one very large party boats catching 100,000 sea bass each? In NJ? The land of fluke fishing?
NJ's Private Boats, however, didn't get the memo sea bass were on fire. They 'caught' a hundred ten thousand less than the previous year at 262,000.. Hmmm.. Not how fishing plays out. When one sector is catching outrageously - all are..
I wrote letters. Others must have too. Using paper VTRs (Vessel Trip Reports we had to fill out daily & send in weekly back when. VTRs are now electronic for every trip) we showed Congress how bad these catch estimates were & demanded their repair.. Congressman Gilchrest, Chair House Fisheries, was my representative then. He & staff were really helpful. 
In 2003 For Hire catch estimates were given the repair we still use today. It sure isn't perfect - and they STILL don't use our VTRs! - but these estimates are survivable at least. 
A major overhaul of recreational catch estimates, then called MRFFS, was written in to the 2007 rewrite of the Magnuson-Stevens Act. 
Everything looked like it would be peachy..
For-Hire estimate's new found statistical stability, however, didn't prevent accusations of recreational overfishing for long. In 2004 Private Boat landings began a rise that has never abated. In fact, with the new system beginning in 2012, called MRIP, Private Boat catch estimates from just one state(!) would sometimes be greater than all Recreational Party/Charter and even all Commercial catch above Cape Hatteras all combined. I will note that when I've boiled it down, MRIP's Catch Per Unit of Effort {CPUE} or "catch per person per trip" seems logical/believable -- it is absolutely Effort, the NUMBER of anglers and how many trips they make, that skews catch sky high. 

Many complaints were made against MRIP's estimates. NOAA has submitted MRIP to the National Academy of Sciences (NAS) for review three times. Statisticians there found no major faults - suggested minor fixes. 
When we write to Congress, Dept of Commerce or NOAA these days, they reply back with a bunch of statistical-speak. Used to listen to us. Now they listen to the agency with NAS backing. During these NAS reviews scientists wanted no parts of fisherman's knowledge - no "anecdotal evidence" was allowed. I wanted to be included. Told them I didn't understand statistics but I sure understood fishing effort & catch. It wasn't going to happen. 
In fact, crickets is all I expect anymore. 
 
If we are to garner DC House and Senate's attention, many anglers must write and demand MRIP's catch/effort estimates be repaired with Real World Effort Estimates - use the video percentages as a guide until other states can get up and running. (Now, now.. Catch more flies with sugar than vinegar! Write Nice!)

On a windy day at local tackle shop, Ake Marine (now Atlantic Tackle) back in 2013 or 14, I met Dr. Van Vorhees. He'd been in charge of MRIP from inception. He told me if complaints continued estimates would only grow worse.  
"How could they possibly grow worse?" I wondered. Well.. Wish I'd recorded that conversation. He was certainly a man of his word. 
MRIP was 'recalibrated' twice that I know of. Both recalibrations created increases in already high Private Boat catch estimates and no increase in For-Hire landings. MRIP's second recalibration was especially huge. 
In 2017 this newly recalibrated 'best available science' was forced into NOAA fisheries science 'stock analysis' (where live fish populations are estimated) and, importantly, from where all commercial/recreational quotas originate. 
In 2018 Commercial quotas were raised to match now astronomical recreational catch estimates. (Gosh, says Mr NOAA Stock Analyst, if recreational anglers are catching THAT many fish, there must be a lot more fish in the ocean than we'd previously thought. With fish populations up sharply, management had no option but to raise quotas.) Especially of note, the second recalibration resulted in a 49% commercial increase for summer flounder (fluke) quota & a 69% increase for sea bass. 
(Holy Mega-Landings Batman! Shades of Conspiracy Theories! Those are, by far, the largest quota jumps ever. Honestly, I think the worst owed to Bill Hogarth, in charge of NOAA Fisheries from 2000 to 2007. He'd give a speech and make shore fishing seem more destructive than foreign pair trawling of the 1960s! It wasn't accidental.) 
Recreational fishers got an increase too. On a computer screen at least. But MRIP still had us catching more than we're allowed.  It's all ghost catch. We're catching fabulously on a computer but doing little damage at sea. Commercial landings, however, are real. No estimates - fish are weighed and sold. 
Since 2019 the full commercial quotas for sea bass & fluke have not been met. 
They can't catch what they're allowed. 
Something's wrong..

As I've mentioned; in the early years of regulation we lobbied successfully to repair For-Hire estimates. I believe that was because we could prove a close approximation from our catch reports. Professional skippers have to inform NOAA what our clients caught. 
But Private Boat? No logical argument gained traction. Their catch is a complete unknown. MRIP's big repair was switching to snail mail from telephone. Not that NOAA's top brass didn't see exactly what I and others were getting at, that's why the National Academy of Sciences (NAS) reviewed MRIP - they were told to. 
But NAS's statisticians preferred their formulas over fishermen's logic & observations. Not only would anecdotal accounts not count, they weren't allowed. I was told by attendees there were no fishermen at the meetings. 
We were supposed to have 'proof' of Private Boat and Shore effort from salt water registries - the state fishing licenses required by the 2007 Magnuson rewrite. But MRIP staff 'knew' many anglers were so dialed-in to fisheries science & management that they could fool the system by not registering or, instead of bragging about their fishing, underreport their days fishing and thus get less regulation and higher quotas. (I'm being sarcastic. Fishermen cannot guess how data will be used..) 
MRIP's top statisticians also 'knew' that because there are many more Private Boats than For Hire boats "Of course Private Boats catch more!" (Yes, that is a quote.) 
Well, what about all the folks who either have better sense; not quite the level of interest; or simply cannot afford a boat but can afford an occasional charter or partyboat ticket? Aren't there a lot more of non-boat owners than boat owners? 
Promise - yes there are. Incredibly many more. A bunch of them like to fish too. 
Regardless, MRIP staff believed lots of anglers were underreporting their trips or not getting a license at all. 
An assumption fishers lie and cheat? 
Yup. You could put it that way. 
Promise. That's why MRIP's Private Boat (& sometimes Shore) estimates are so high. They add "Effort" - they add people and increase the number of trips reported to fill in for those cheating the system.
Neat trick. 

Proof. 
We needed proof. 
I argued for video cameras - even just one camera please - to cover Ocean City, MD's one access point to the ocean - our inlet. If we had a count of the boats, we'd have proof of effort where Maryland's 'ocean only' catch estimates are concerned. 
The Mid-Atlantic Fishery Management Council actually did it. 

On March 31, 2023 the first inlet boat count video data was published. 
And, as I've argued for so very long, it's plain to see MRIP's effort estimates for Maryland's 'ocean only' Private Boats are way too high. 
We now have PROOF the effort estimates are wrong. If this doesn't get fixed now, fisheries science will be forever damned with today's effort estimate models and crazy high catch numbers. If this inlet boat count data gets squashed? Recreational fishers will continue to see tighter and tighter restriction. 

The well written work on inlet video camera boat counts concludes that video work is 'probably not worth it' -- "..but staff does not immediately see a path to how a relatively simple video system could be used to reliably estimate ocean recreational fishing effort in Maryland.
Dern sure looks a lot better than MRIP's lunacy to me - and this is just the very first stab at it. 
My sense of it, especially after the National Saltwater Recreational Summit in April 2022 - where from the very first speaker to the last comment, MRIP catch estimates were bashed at every turn ..it sure seems as though every angler from Texas to Maine and everyone in fisheries science & management has had enough of MRIP's baloney. 
NOAA should use MD boat counts as a rough guide to how far off MRIP's 'Effort' estimates are - apply the math everywhere. 
In time MRIP should have cameras in enough places to make far firmer effort estimates for all states using its estimates.. 

Here are the 5 MAFMC video comparisons that have been published in sentence form. MAFMC's bar graphs are below. In the bar graphs, unfortunately, they chose to use the full "PSE" spread. For regulation's purpose no one is allowed that convenience - the only number that counts in a catch estimate is the centerpoint. I interpolated the centerpoint from the video counts and used the MRIP website centerpoint for that number: 

1) In July/Aug 2020 MRIP's total effort estimate for all ocean-only Private Boat effort is 185,341 angler trips. Divide by 4 per boat and again by 60 days and you'll see 772 Private Boat trips a day leaving Ocean City MD's inlet. (Oyyyy.. Nonsense!) Video boat count for the same period, judging centerpoint by bar graph, is 37,500 angler trips or 156 boats per day using the same parameters of 4 anglers and 60 days.  That's 616 less boats & 2,464 fewer anglers per day. Per Day! ..and video counts are of no use? 
(I'll note MRIP's July/Aug ocean only high in the last decade is 311,675 angler trips for 1,298 boats exiting OC Inlet daily or 5,192 anglers trips a day. Marinas would have been so profitable. Ahhh, I expect we'd have to build a big new marina somewhere to have that many boats fishing a day..) 

2) In Sept/Oct 2020 MRIP has the lowest Effort estimate of this examination at 5,468 angler boat trips or a quite believable 30 boats a day average across 45 days (weather being an issue in early fall) - Video count, however, shows more at roughly 13,500 or 75 boats a day fishing the ocean. (I'm not convinced we have the counting just so, but it's far better than MRIP's current guesses which, yes, sometimes shoot too low.) 

3) In Nov/Dec 2020 MRIP has 6,682 angler trips or 37 boats a day average for 45 days. Video count is somewhat lower at 4850 or 27 boats per day. 

4) The camera got water in it and all was lost until Sept/Oct 2021. Here MRIP shows 60,447 individual angler boat trips or 336 boats exiting OC Inlet daily with four anglers per boat and across 45 days. Video boat count here is dramatically lower than MRIP's estimate at 15,500 anglers on 86 boats per day over 45 days. That's 250 fewer boats or 1,000 less anglers a day. 

5) And finally for this data set we have 
Nov/Dec 2021 where MRIP shows 10,477 anglers or 58 boats a day across 45 days. Here again the video count shows a much lower number at about 3,000 angler trips or just 17 a day which makes sense over Thanksgiving and Christmas. 

Maryland's estimates are small potatoes. We're NOT the problem. Consider - in Nov/Dec 2016 MRIP shows 3,565 New York Private Boats going daily (Daily!) on each of 45 days. Among those boats, anglers 'caught' 2,680,000 lbs of sea bass in a few weeks of fishable weather. That's two million more pounds than all Party/Charter caught from Hatteras to Maine - All Year. 
Do you see we have a problem with effort estimation? 
 
I'd never felt so certain MRIP would change as at the National Saltwater Summit last April. Every fisherman there was hammering MRIP. Likely half the folks were from the science and management community. Top brass especially had no misunderstanding - MRIP is delivering up codswallop and fishermen wanted it fixed for good. My final comment to the 175 attendees at conference's conclusion was: "If you're using MRIP, you're just pretending you have data.

Now we have proof. 
We need to tell our representatives in Congress that we're no longer guessing - we're sure MRIP's no good and can prove it. 
We Have The Video. 
Regards, 
Monty

Yes, my tale is a long read. I thought readers affected by bad data would want to know. 
Your Congressman and Senators' Staffers won't likely read this much. 
Over and over NOAA has kicked this issue to statisticians at the National Academy of Sciences (NAS) for review. Wrong or not, NAS has absolutley no way of knowing about fishing - but they love the statistics. MRIP keeps going unabated. 
Repair has to come from DC. Tell your representatives to put enough video cameras up to get an excellent effort estimate around the coast. Tell Congress to fix MRIP's crazy way high Effort estimates so we can go fishing! 

Write Your DC Reps (Senators & Congressman) Email will get read but if you snail mail a regional office they'll reply in writing. 


NOAA is under Commerce, Secretary of Commerce, thesec@doc.gov Gina M. Raimondo 
U.S. Department of Commerce 
1401 Constitution Ave NW 
Washington, DC 20230 

Dr. Rick Spinrad PhD rick.spinrad@noaa.gov NOAA's big boss - not just fisheries - the whole shebang. 
NOAA/National Oceanic and Atmospheric Administration 
1401 Constitution Avenue NW, Room 5128 
Washington, DC 20230 

Janet Coit, Esq. NOAA Fisheries 
janet.coit@noaa.gov 
(Fisheries Boss from Rhode Island with LOTS of fisheries and enviro experience) 
U.S. Department of Commerce 
1401 Constitution Ave NW 
Washington, DC 20230 

Evan Howell PhD. Director of MRIP (New! Willing to take a hard look at it!)
NOAA Fisheries 
1315 East-West Highway 
Silver Spring, MD 20910 

Michael Pentony NOAA's Regional Administrator GARFO 

Bob Beal 
Executive Director ASMFC 
 
Dr. Chris Moore 
Executive Director MAFMC 

If reading this far you probably already know your state's fisheries people.. Keep them informed. 
If not, they're pretty easy to look up. 

We can crack this egg. In fact, we'll never have a better chance. 
Write! 



For management and regulation's purpose, only the exact center of the MRIP statistical spread can be used. Any suggestion otherwise is rubbish. MRIP centers are listed in the sentence descriptions. 




Regards, 
Monty

Capt Monty Hawkins 
Mhawkins@morningstarfishing.com 
Info@ocreefs.org