Monday, March 16, 2015

Fish Report 3/16/15

Fish Report 3/16/15 
Going Looooong Toggin (and, um, long on the report too)
NOAA's Pout Regulations
Reviewing Formative Science 
Please Write The Secretary Of Commerce

Skunks are always possible while tog fishing. 
Really. It's a frequent occurrence, even with a good bite. Not an easy fishery; the very best toggers sometimes get their head handed to them despite folks all around having done well. 
Then too, sometimes the whole boat can do very poorly. 
If you can't take the heat, and there ain't much of that either, stay out of the kitchen. 

But If That Sounds Like Your Kind Of Fishing, Good! Cause We're Going Toggin Anyway! Tog Only, Sea Bass Closed. 

(still) Have (some) White Crabs For Sale AT THE DOCK for the low, low price of just $5.00 per generous exact dozen. (they're small & most have died) There Is No Guarantee We'll Have Whites For Any Trip. Sometimes they all die. That shrinkage is why I prefer greens. We will not be bringing whites with us in the ocean. Green Crabs Remain Provided As Boat Bait And Are Included.   

Yes, it feels like spring on land and I'm glad of it. The ocean, however, has only grown colder as ice melts in our bays & estuaries. To catch a tog right now I must take a very long ride - very. Even that may not work! 
In three more weeks, a month, we'll see nearshore waters warm & the traditional tog bite begin. This trip is not that - not at all. Get it? 

Going Toggin - Thursday, March 19th - 5am to 5pm - Calm Before The Storm - Tog Only - Sea Bass Closed - $175.00 - 12 Anglers Sells Out. Expect A Very, Very Long Ride. 

Reservations Required for All Trips. 
Reservations at 410 - 520 - 2076 — They Answer 24/7. 
LEAVE YOUR BEST POSSIBLE CONTACT NUMBER - Weather Cancelations Are Common - I Make Every Attempt To Let Clients Sleep In If The Weather's Not Going Our Way.. 

We provide green crabs. You're welcome to bring any kind of crab you like – even lobster, even plastic. 


No Live Tog Leave The Boat - Dead & Bled - Period. (I Believe The Live Tog Black Market Has Hurt This Fishery ..But Nowhere Near As Much As Bad Sea Bass Regulations)
Agreed With Or Not, All Regulations Observed – Maryland: 4 Tog @ 16 Inches – Sea Bass Closed On Jan 1st Because Of Rotten MRIP Catch Estimates. 
If You Won't Measure & Count Your Fish The State Will Provide A Man With A Gun To Do It For You. We Measure & Count — ALWAYS — No Exceptions! 

It's Still Winter Out There!! Wear Boots, Not Sneakers! Fingerless Wool Or Thin Fleece-Lined Waterproof Gloves With Handwarmers Tucked Into The Palms Make For A Comfortable Day.. 

Dramamine Is Cheap Insurance! Crystalized Ginger Works Great Too. It's Simple To Prevent Motion Sickness, Difficult To Cure.  

Bring A (not terribly big) Fish Cooler With ICE (or fresh snow if you can find any) For Your Party.. A 48 QT Cooler Is Good For 2 Guys. Even Now You Should ICE Fresh Fish.. 
Be A Half Hour Early - We Like To Leave Early.
Clients Arriving Late Will See The West End Of An East Bound Boat.. 

Please believe Sue Foster's contribution to our fishing community will be remembered in a memorial reef. Help Make That Happen. 

Very Good Things Are Happening With OCRF Reef Building. Our Largest Concrete Project Ever In Coming Weeks. (and even that's been pushed back by ice! We start rolling trucks - stockpiling precast concrete - Wednesday for April deployments.)

Now 10,976 Reef Blocks by the stern rail – 2,146 at Doug Ake's – 1,218 at Saint Ann's – 558 at Eagle Scout Reef - 557 at Lindsey's Isle of Wight Reef and 304 at the Brian Sauerzopf Memorial Reef.. 
Our Reef Block pile was reloaded with monster 90 pound blocks courtesy of Potomac Valley Brick, Inc. of Salisbury. 

New 2015 Reef Raffle for a bronze Turner Sculpture of a pair of spadefish. About 16 inches high, it's an awesome piece. Maybe I'll keep it in my office this summer for safe-keeping.. 
Nearly $3,000.00 value, only $10.00 a ticket! Turner's work is, quite literally, around the world. It's true sculpture.. 
Send an email w/your address and I'll snail-mail you some tickets. Just return the stubs & money. We'll pull a winner Thanksgiving week. 
Greetings All, 
Got a call from NOAA the other day. Seems I reported myself for illegally landing ocean pout. 
The good news is someone at NOAA is actually looking at VTR Catch Reports. These are not broad two-month Catch Estimates. We report, on a NOAA form, what we land everyday. Be nice if management were told what those reports say instead of MRIP's nonsense. 

Sad news is now I'm one of the bad guys. Maybe they'll pull my permits.. Maybe, "Oh, that permit application must have fallen off my desk" is coming. 
When & who in blazes made it illegal to land a dagoned big-mouthed yellow eel? 
I mean really, sometimes it's difficult to keep the wheelhouse vernacular from these written words.. 
(See pics at Google Images ocean pout )

Never very common, I like eating pout fried.. 'Liked' I suppose. I certainly won't violate a regulation I know about. 
Because the now-protected (for who knows what reason) ocean pout eel lives on REEF BOTTOM, maybe NOAA will HAVE TO investigate our reefs! 
Our very own spotted owl?  
Yeah no. They're worried about these things up in Maine or somewhere.
Maybe they're 'moving north' too. 

Fishery management began as a way to save the fishing industry. At least that's how I saw it. Save the fish & create self-sufficient coastal communities. 
Create Bio-Economic Resilience In Coastal Communities By Increasing Fish Populations.  
Initially fishing got better & better. The very best sea bass fishing I ever saw was just a few years into the regulated period--and I spent nearly two-decades working in the last of the unregulated period. 
I could never have ever imagined a time would come when the recreational For-Hire sea bass fishery would go from catching perhaps nearly 5 million sea bass annually to less than a million ..yet be under constant attack for being 'over-quota.' Where in the world are the 4 million sea bass we're NOT CATCHING EVERY YEAR?
Commercial catch too is much more tightly controlled, they catch far-far fewer individual fish than they did both in pre-regulatory & the early regulatory period. 

I would never have dreamed the regulatory & scientific community would respond robot-like to 'scientific data' they do not even believe; catch estimates no one should ever believe.. Then I saw it in 1998. In 1997 the recreational catch estimate for New Jersey Party/Charter sea bass catch jumped up a million fish to 3 million. That increase in catch caused the MAFMC to raise the sea bass size limit to 10 inches, something they had very clearly intended from management's inception just a year earlier. 
I supported the 10 inch limit. I could see sea bass populations climbing straight up. Management was really working! 

But they also wanted to close two weeks in August. WHAT??? They did just that too. I put my crew, my boat & my clients in danger trying to get way-offshore to catch red hake (ling) during that 1st sea bass closure - a closure based on a single state/single sector/single period spike in the estimates. A spike exactly as has happened so many times since..  

In 2014 New Jersey's Party/Charter boats landed 312,000 sea bass. That's fully an order of magnitude lower than their 1997 catch estimate - and again MAFMC is about to further restrain New Jersey's recreational sea bass season for 2015. 
Where are the fish? Where's the savings? How in the world could we possibly have been at the bottom of the worst overfishing period this planet's ever experienced and yet still have 3 million sea bass available to New Jersey For-Hire vessels in 1997; but today, after nearly two decades of regulation, have management even a tiny bit concerned over landings fully an order of magnitude lower than in the dawn of regulation. 

That's just bizarre. Something's very, very wrong here. 

It's absolutely because spawning production has tapered. Collapsed actually. I've been trying & trying to show management what went wrong. They may come to it, but for now they're deep in a real-life witch hunt for small Private Boats as their main suspect in an uncontrolled, under-regulated, over-quota theft of our nation's public resources. 
They can see it plain as day in MRIP's estimates. 
Management: "If We Could Only Control these Wicked Overfishers!!"

The most powerful tools in reef-fish management are:  
1) catch restriction that recognizes habitat fidelity, (even today's hot-button issue, blueline tile, is being swept-up in our old stupidity. Will we really expect the people who manage Florida's east coast fisheries to be better able to gauge our blueline fishery above Cape Hatteras?'s never worked yet. Not once. Quota management MUST recognize spawning site habitat fidelity or fail again & again.)
2) habitat expansion (Here's a tough one: if the stand of oak where Uncle Jed used to shoot 20 squirrels every winter is now instead a fallow field that gets bushogged every few months except for one tiny corner of trees, why can't we shoot as many squirrels there today as Uncle Jed did? If reefs once measured in square miles have only been replaced by reefs measured in square yards, why is it so difficult to restore reef-fish populations that lived upon those huge multi-square-mile historical reefs with our multi-square-yard reefs of today?)
& 3) using the natural instinct of fish to spawn young when they perceive 'room to grow' or, in converse view, fish spawn more and earlier when 'put under pressure.'  

The "Iron-Clad Rule" (Murawski) of fish populations becoming far more numerous, if fished at the appropriate level, relies heavily on several simple assumptions that no scientist or manager should make when dealing with reef fisheries: To be true --for fish to become far more numerous-- Spawning age must either remain constant or its changes factored into management; and the base area, the footprint, The Size, of reef habitat must either remain unchanged or be increasing

But here in the Mid-Atlantic we still "don't have" reef habitat. Really. Management's not going to worry over something that's not on their NOAA issued to-do list. 
This was in a document put out for public comment in March of 2002:  Essential Fish Habitat (EFH) Alternative 1, the "No Action" alternative, states that  ".. Additionally, the majority of (benthic) habitat in the Mid-Atlantic region is sandy bottom. Current research shows that bottom tending mobile gear has a short-term impact on this type of habitat. As such, further EFH regulations may not be necessary at this time." 
And so it remains.. 

I copied this off a government website in 2003. You might think this must have been forgotten; but, even today--a decade later--they remain blissfully ignorant of our reef habitats: "NOAA Fisheries and the Regional Fishery Management Councils have three roles. First, they describe and identify essential habitat for all fish and shellfish stocks managed under federal fishery management plans. Most of this work has already been completed.* Second, they must identify measures to conserve, restore, or enhance essential fish habitat in fishery management plans and amendments. And third, they recommend actions that will minimize the adverse effects of fishing on habitat."
So here's where this "EFH No Action Alternative" from 2002 comes in: 
Additionally, the majority of (benthic) habitat in the Mid-Atlantic region is sandy bottom. Current research shows that bottom tending mobile gear has a short-term impact on this type of habitat. As such, further EFH regulations may not be necessary at this time." 

*completed? describe and identify? Really? I've yet to see but one heroic start by Vince Guida up in Sandy Hook & that was exactly a decade after this document was written. Truthfully, habitat impacts are growing increasingly rare. That's mostly because habitat that could be scraped away - has been. I think too trawl skippers are more dialed into it. Regardless, todays task is not so much in preventing impacts; we need to find out what's gone missing over the last 8 decades & put it back.

I've been digging around, looking for evidence that will finally convince someone in authority we must more-closely examine every facet of the sea bass fishery. 
I see methods using biology & ecology to manage populations for accelerated growth, to repopulate reef-fish quickly. I see new methods of management we need to master in order to move this endeavor forward. I absolutely believe we could engineer any population of sea bass we'd like - from today's minimally productive but rather large fish, to a population greater than existed in 1950. To do that we have to examine aspects of regulation other than cyber-ghost Private Boats MRIP claims are able to kill with greater efficiency than the very-real foreign fleets of yesteryear.
Instead of biology & ecology, management's only out to kill overfishing. 
They're good at "Closed." 
More & More Closed.

You can smoke a joint in DC cause a bunch of guys wrote letters. 
Recently a cheap rifle ammunition was about to be banned (gun talk for Closed). Over 80,000 comments later, BATF withdrew their ban.

Close cod to recreational harvest in the Gulf of Maine? 
NOAA "Allows" a two day red snapper season? 
New Jersey & all points north hammered again on sea bass regulations? 
Fishing's Closer & Closer To Closed.  
We're witnessing the end of marine recreational fisheries based on the worst possible data. Yet even people in the trade, people who own a boat or earn a paycheck from the deck or wheelhouse, won't write. 
We need everyone to write.

I suppose it's really no different than any struggle, and fishing's very low on people's radar to begin with. 
Fishing ought to be. 
The ocean should be blue & full of fish. 
The reason it isn't, at least from "The Best Available Science" right now, is because regulators just cannot control small plastic boats piloted by ruthless slayers of untold fish. 

That's just pathetic. With all the work we need to do to set the ocean right, NOAA's pitchforks are pointed at Private Boats. 

In the early 1970s commercial fishermen wanted Spain's fishing fleet OUTGET OUT OF OUR WATERS. 
Spain said, "Sure, we can accommodate you on that. But these military bases you have here? They have to go too.
So the State Department not only allowed Spain's boats to stay, they gave them coordinates where to fish. 
That's just one country's fleet. There would often be dozens of foreign trawlers, trans-Atlantic fishing ships really, for every US fishing boat. 
That was what Magnuson was originally written to cure. The law was passed in 1976. 

Now, with the strictest recreational regulations ever in history, with Councils & Commissions convened to control US Fisheries and prevent foreign theft; these regulators see on their computer screens MRIP's statistical representations of rapidly increasing catch in the Private Boat sector. Every other sector's catch DROPS when regulations tighten. MRIP says: Oh No, these guys in their Private Boats are killing off entire previous successes in management! The more you regulate, the more they take! 

Now managers want recreational guys OUT - Stay In Your Marina! Don't you dare TOUCH a sea bass, red snapper, or cod. 

When some crazy bug-eyed loon hears voices in his head, that's just him being nuts. When he takes an AR to the school yard; that's a tragedy. 

MRIP is making regulators crazy. The tragedy is unfolding before our eyes as recreational fisheries are closed. 

I'm digging - looking. Re-reading old works. What on earth can I possibly use to show management how utterly bizarre their belief in MRIP's catch estimates seems to us? This stuff is just NUTS to anyone working in the recreational fishing trade. There's just No Way Private Boats from one state can outfish all US Party/Charter. It's doubtful any one state's Private Boats catch more sea bass than just their own state's Party/Charter fleet. 
But NOAA believes the estimates. After all, they paid for them  ..and then get paid to use them. 

Found this. Here's something interesting management used to 'know' from page 55 in the "1995 Review Of The Development of A Joint ASMFC/MAFMC plan For Black Sea Bass" by John Carmichael: "A large proportion of the recreational landings are taken on party and charter boats." 

Wow. That's rather different than when NY For-Hire was recently shown to have caught 5% of their state's sea bass; or when NJ's For-Hire fishers were shown to catch just 3% of their summer sea bass. I'm certain the nature of the fishery has not changed that much, the balance has not shifted so far toward Private Boat removals - nowhere near so. 
Fishing seems the same out there on the water, at least when season's open, if a little heavier on the Private Boat side. 

Fishing's Amazingly different in the MRIP catch-estimate data though. 
Funny. If the estimates were true we would factually see an incredible increase in boats over our reefs - the reefs we know by heart because that's how we make our livelihood. Those enormous fleets MUST EXIST for MRIP's catch estimates to be true. 

That's why Party/Charter operators don't believe the estimates. Where are these fleets of Private Boats? 
No one's catching the fish NOAA's catch estimates claim are being taken. Not for tautog, not for sea bass, not red snapper, not red grouper, not cod or haddock either. Ghost fleets on a computer screen do not create true landings.
While reported catch factually falls through the cracks; estimated catch from sectors where no one physically counts actual catch climbs higher & higher, showing catches far beyond what's seen on the water while we're out fishing. 

Digging around in management's formative work starts getting more intriguing for me in Kendall's 1977 Sandy Hook Technical Series, "Biological & Fisheries data on Black Sea Bass.
On page 8, section 2.2: (writing in 1977) "Over the past 70 years it appears, from catch records, {would have been commercial sales by the pound - no estimates} that the center of abundance of black sea bass in the Mid-Atlantic Bight has shifted south from New York/Delaware region to the Chesapeake region." (underlines mine of course..)
Yup. Kendall actually wrote that in 1977. 
Now -Today- NOAA's quite certain, based mostly on MRIP's numbers, that sea bass are fleeing the lower Mid-Atlantic because of warming waters. 
The 'species flight' theory not only ignores the South Atlantic's "restored" status of sea bass, but clearly our NOAA Administrators have no idea sea bass populations are climbing in the Gulf of Mexico.. 
I promise: water's plenty cold enough for even Boston mackerel. Ain't no way this ocean's "too hot" for sea bass.. 

I really wonder about that. Who picks our 'best available science'? Why is MRIP a 'best available science' - why is everything in Magnuson that edges management toward CLOSED FISHERIES embraced as "best"?? 
Yet the Essential Fish Habitat section of Magnuson is of no concern whatever. We haven't any reef habitat to excite the EFH section of the law. There just isn't any habitat. Turn the data inside-out. I have. My videos--first one sent to NOAA & Congress in 2001, are just about all there is for sea bass habitat off the DelMarVa coast. & & then Nick Caloyianis's work - all those hard star corals & soft whip corals are sunlight dependent - there are managed species of fish which require reef habitat - Nothing. 

According to the actions of people at NOAA in charge of enforcing the Magnuson Act's EFH provisions; habitat does not exist where we fish for sea bass. 
It's important to note there are people at NOAA who would love to research our corals - it's the people in charge do not see the wisdom in it. 

This fishery was an easy one. They shot straight up to a 50 year high early-on (if still nowhere near a post-WWII population) yet have been in decline since.  

Overfishing is now history. It's over. Foreign fleets are gone. Quotas are in place. 
Management's catch-estimate illusions/delusions have them behaving like those poor Japanese soldiers holed-up in caves & tunnels still fighting long after Nagasaki. 
Really. Overfishing is history. The little plastic private boats are not coming to take management's island. 
Overfishing now past; today we're in an un-named era when management ignored fish & fishers in favor of a government definition of science - the "best available science" - and allowed their most rapid & successful restoration, their first restoration, to falter & fail with its associated businesses' following in suit. 

I think that failing is because sea bass spawn years later than they used to. Kendall's 1977 work illustrates precisely what I mean.  
On page 15, section 4.11, Kendall wrote: "Since black sea bass are protogynous hermaphrodites*, sex ratio varies with age and size of the fish. Larger fish are all males. Nearly all fish 25 cm (9.84 inches) are males. Thus catches of large fish will consist of males. 
(*Like many reef species, sea bass begin life as females. Because a reef may be isolated in the extreme, reef-fish are able to switch sex to keep the spawning population of any given reef in balance.) 
Kendall also wrote, "Generally, males tissue is first seen in fish 3 years old at about 18cm." (7.1 inches - what we today are certain is age 1) 

Using his 'best available science,' Mr. Kendall believed a ten inch sea bass was 6 years old. Today we know that's an age 2 sea bass. As above, he also thought a 7 inch fish was 3 years old. While what he believed about "age at length" was a fault of science, we can not doubt the man knew how to measure---an aging table might have been wrong, but not his ruler. 

I doubt any recreational fisher has measured more sea bass than I have. I had boat regulations long before there was any actual law. When I was told in 1991 that sea bass had all spawned by 9 inches, I began looking to see if I could confirm that by measuring fish I believed were spawning. In 1992 I made 9 inches my boat regulation - self regulation. Over the next 6 years we would often throw back thousands of under-nine inch sea bass every day - without the force of law. Among them it was quite a simple matter to see the males. Even small; newly switched males have a blue hump on their head.  
When management finally began in 1997 they too chose a 9 inch limit. In 1998 it went to 10 inches. 

What I've been trying to tell management for 6 or 7 years now--and have suspected longer still--is made plain as day in Kendall's work ..but only if you're familiar with sea basses' modern-day response.
Where Kendall thought it quite likely a catch of over-10 inch sea bass would be all male, today we could easily catch 5,000 ten inch sea bass and not a single one would be male. That's a perfectly possible scenario. Yet Kendall tells us in 1977 a catch of large (10 inch) sea bass would all be males. They did not have the aging right - not then. But they surely knew how to measure.  
We've gone from innumerable age-one males (<9 inches) in pre & early management, to virtually no age-two males at all today. Spawning production has declined sharply in precise match with this shift. 

Instead of a huge spawning population, it's quite likely our spawning biomass today is nearly the smallest in history. Moreover, the nature of sea bass in the lower Mid-Atlantic carries these larger spawners further offshore, further from the estuaries so vital to juvenile success... 

Management's had BOFF pounded into 'em. 
Closed & BOFF are good. (but habitat & population biology are bad?)
Big Old Fecund Females - BOFF. Managers believe by protecting older females they can increase a species' spawning capacity. This is probably quite true in, say, striped bass. 

Here's what management should plainly see with sea bass switching to male years later than they used to.  

For black sea bass at least, BOFF is dead. 

Mr. Kendall wrote in his time, "The largest females are about 34 cm and 8 years old.." A 14 inch female would have been enormous. He certainly implies just that with his 10 inch males quote.. Such females, actually about 4 years old, are commonplace today. In fact, the size limit in Massachusetts is 14 inches and they certainly do not take all males. 
We now have 2 entire age classes that are nearly entirely female, but were once nearly all male ..yet the population is in decline. Our sea bass population is unquestionably shrinking  ..but there are more females, and females represent a far greater percentage of the population than ever in the history of sea bass science - we have BOFF big-time. Today's sea bass couldn't be more BOFFy  ..yet the population wanes. 

If BOFF were at all true for sea bass it wouldn't be safe to walk a beach - you'd get spined.. 
When sea bass on nearshore reef habitats felt pressured by the absence of larger sea bass on their reef, males transitioned from female even as early as a few months of age. With every reef possessing the needed percentage of males by age one, this provided a spawning population even in the worst of overfishing. Spawning productivity was accelerated as management began because all these youthful spawners were then newly size-limit protected by law for the first time in history.

Regulation, in concert with biology, created exponential population growth. The real driver of this 1998 to 2002 population explosion of sea bass was as far from BOFF & Marine Protected Area theory as could possibly be imagined. It was the nearshore reefs with the heaviest pressure that drove an 'all hands on deck' spawning response. Just a little further out, a tad outside 12 miles, there were a lot of big sea bass. 

The first year of a recreational bag limit was 2002 - the size limit was moved from 11 to 12 inches in 2002 as well. 
From that day to this - population decline. 
(This graph only goes to 2011. When updated in will not spring miraculously upward.)

I've only gotten through a couple old documents from early in sea bass management's history. I'll keep digging.  
Here, however, is something else that's entirely slipped away from us -- in the Executive Summary of the 1998 Summer Flounder/Scup/Black Sea Bass Plan it says, from among several Fishery Management Plan objectives:  Improve Yield -- Minimize Regulation .. 
Would make perfect sense if it was removed in 2002. That's when management of sea bass turned sour.
When the size limit crossed 12 inches it 'tricked' sea bass into behaving as though their habitat were full. Indeed, in 2003 I thought our sea bass were at habitat capacity. Today's size limit makes them behave as though they still were - they delay spawning accordingly. 

I believe age at maturity shift has had a huge negative affect on production. 
I believe today's spawning age-shift, and accompanying spawning production decline, stem soley from recreational size-limit regulation. 
I also believe today's recreational regulations are solely the result of catch estimates so rotten that no other industry would suffer them for any other purpose. 

From those estimates management has unknowingly orchestrated the decline of sea bass in the Mid-Atlantic. . .

Overfishing is dead, but so too is management's promise. 

Please See Comment Information Below. 


Capt. Monty Hawkins 
Partyboat Morning Star
Ocean City, MD 

If you only write the Secretary of Commerce, that may have been the most important letter. It's very simple to contact your Senators & Congressional Reps online.

Please write to the Secretary of Commerce, your Senators & your Congressional Representatives. (search at )
The Secretary is hearing from red snapper fishers right now about catch estimates too. She also ought to be hearing from cod & haddock guys if they've not given up. Please tell Mrs. Pritzker the reef fish recreational For-Hire industry from Maine to Texas may well collapse under the weight of bad catch estimates. Tell her too that Private Boat owners deserve fair consideration in the estimates The situation requires her immediate attention. 

I believe the best course of action is to relieve NOAA of catch estimates all together & hand that duty to US Fish & Wildlife. They've been estimating fishing effort a lot longer, they're better at it. I can scarcely imagine anything worse.. 
Personally, I also think if NOAA cannot find & manage the closest reef ecologies to Washington DC, then maybe they ought to just stick to weather. Weather forecasting's much better than ever before, but maybe USFWS should have responsibility for all US fish habitat if NOAA hasn't time for it. 

Whether a couple sentences or a couple paragraphs - we need Commerce to know we're getting hurt bad by MRIP's false accusations. This is NOAA's third attempt at recreational estimates, their second in a decade. 
They just don't get it. 

We need tell Government: Create Bio-Economic Resilience In Coastal Communities By Increasing Fish Populations. 

Mrs. Penny Pritzker - Secretary of Commerce
U.S. Department of Commerce
1401 Constitution Ave., NW
Washington, D.C. 20230

You might try an email - - but I'm sure snail-mail carries a bigger stick. I'm not at all sure email gets in. 
You have a state Fisheries Dept. and representatives to the MAFMC & ASMFC - tell them too. Believe me - They'd like solid estimates also. 

As for NOAA's upper echelons? I give up. 

I am absolutely convinced if NOAA does not hear Mrs. Pritzker's high-heels coming down the hall, we're toast. They'll just keep doing what they know how to do - CLOSED.
Yes, sea bass are not under immediate threat in the DelMarVa region, but we are next. 
We need to get Marine Fisheries Restoration headed in the right direction. With an ocean of potential, we're still fighting overfishing from the pre-regulatory era; now from tiny boats, not foreign factory trawlers. 

Want more? If that's not enough work, here's another task; a "request for comments" from the Highly Migratory Species folks.. 
Below is my submission. 
Comment:HMS are typically thought outside the borders of nearshore & estuarine hardbottom losses' affect. Given a deeper examination of changes to HMS recreational landings since the 1920s from OC MD; loss of oyster filtration in our major estuaries has caused an-ever increasing 'greening' of the Mid-Atlantic's once-blue marine waters. 
The white marlin fishery can be traced from even just 3 to 5 miles out pre-WWII, then 8 to 20, then 20 to 30 - to today's canyons fishery. Because the Gulf Stream dams outflows, reduced flushing in the Mid-Atlantic Bight creates a far different situation than in, say, Stuart Florida where billfish are still caught where they were 60 & more years ago. 
The Mid-Atlantic has grown far greener, not remained blue. 
Then too, we can be certain squid once spawned on nearshore hardbottoms as they do worldwide. Given our certain knowledge heavy stern-towed gears can reduce or destroy a hardbottom's reef-growth; and given what should-be certain knowledge by now that soft sandstones & clays can be lost permanently, especially over decades of gear impacts, one can imagine how deep research into past reef fish landings and catch locations would illuminate a need for habitat restoration preceding prey-base restoration. 
If oyster restorationists are successful, a true HMS restoration to these many species' full habitat range--including the nearshore--will indeed require more than a pelagic mind-set. 
Monty Hawkins 
Ocean City, Maryland

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