Monday, April 02, 2018

Fish Report 4/2/18 - A Call To Arms

Fish Report 4/2/18 
A Call To Arms (well, keyboards/printers/pens)
We're About To Go WAY Over Quota In Almost Every Fishery (according to soon-worsening catch data) 
I Anticipate Many Recreational Fisheries Will See Closures.

I Promise: An EMERGENCY is brewing in our recreational catch estimates. NOAA's MRIP recreational catch estimates are about to increase manyfold. They call it a "Recalibration."

If you are a For-Hire operator anywhere from Maine to Texas, I believe your business model is about to implode. 
If you own or work at a saltwater-oriented tackle shop or marina, sales may get mighty slim. 
If you own a salt-water capable boat, you may soon question the wisdom of all those maintenance, insurance, license, & marina fees -- all the monies paid regardless whether you ever go fishing. 
If you are simply a recreational angler, I believe your seasons & bag limits are about to become incredibly smaller, your size limits larger: You May Not Be Allowed To Fish AT ALL For Some Species. 

The ONLY WAY to prevent this upcoming, fully configured & ready to implement "MRIP Recalibration" from wreaking havoc on recreational regulation is to WRITE!

Greetings All,  
Was up to DC last week for NOAA's 3rd Saltwater Fishing Summit. Gathered every 4 years or so, anglers from Guam, Hawaii, Alaska, & every region where oceans touch the lower 48 were there. I estimate fishers were outnumbered, however, by Council/Commission & NOAA/NMFS staff. 
Secretary of Commerce Wilbur Ross came to address this event, as did Rear Admiral (Ret) Gallaudet (CINC NOAA, the Undersecretary).. That's some heavy horsepower for a bunch of rec fishers. (see especially who said, and I quote: "We're going to get more anglers on the water & hooking up!") 
I care deeply about honor & integrity, even in governance, & am happy to report both of these higher-ups impressed me with their concern for recreational fishing; both in business & health of our marine ecosystems. 
Another new position-holder at NOAA, and present throughout the conference, was our new chief of National Marine Fisheries, (NMFS,) Chris Oliver, who, though new to fishers on the East Coast, is hardly new to fisheries - he has a lifetime in marine management. 

I Promise: An EMERGENCY is brewing in recreational catch estimates. That's why I'm writing. As most readers know, recreational catch estimates determine how much we've gone under/over quota. These statistical estimates are the single most important aspect of how new regulation will be determined for any species in a following year. With "Accountability Measures" (AMs) now in place many years--a 'pay-back' when either recreational or commercial fishers are accused of going overquota, of catching more than allowed; we are already seeing many recreational fisheries tighten to truly disturbing levels - even closure. 

If "Recalibration" takes effect, these last few years of regulatory battles will seem a cakewalk. 

We must now harness Secretary Ross's obvious 'No Horse Feathers Suffered' attitude; the uber-Ph.D. smarts of RDML Galluedet, and utilize the West Coast's long-since-cured-of Recreational Fisheries Catch Data Vagaries as lived by NMFS new chief, Chris Oliver.

You see, during lunch on day two of this major conference there was an "MRIP Recalibration" talk given by our numerical arch-nemesis, Dave Van Voorhees, (the big-boss at MRIP. Please recall MRIP stands for Marine Recreational Information Program; the system designed to replace & make better the old MuRFSS system of guessing how many fish Party/Charter, Shore, & Private/Rental Boat anglers take every year. These statistics measure more than catch, a lot more; but where regulation is concerned, "How Many Fish Did They Catch?" is management's main concern and primary need from among all data MRIP produces.) 
So, with MRIP having recently done away with a landline telephone survey & gone to a mail-in form; (during the smartphone revolution?) from these mail-ins they now believe their old Private Boat catch estimates to be 3.3X too low; and their Shore landings recreational catch estimates to be 6X too low. 
They are about to INCREASE Private Boat & Shore estimates, all the way back to 1981, to several times higher values. 
We'll soon be so overquota, in every fishery, that our rod-racks will become wall-mounted spider farms long before we're allowed to fish again. 

Now, it's also possible that these massive increases in catch could also result in far higher quotas for rec fishers. You can bet some of our commercial brethren will cheer overquota driven tightening & closures, yet fight like cornered dogs where they might lose percentages of quota. 

An ugly time's coming.. I'm only going to mention a few species here, but this "recalibration" affects every fishery under NOAA's regulatory purview. 

An example: Although some in NY complain long and loud about Party/Charter catching all the decent sea bass from wrecks & artificial reefs at the very beginning of season; in 2016 MRIP had NY's Private Boat Only sea bass landings at 1,824,000 lbs; yet ALL Party/Charter for the ENTIRE ATLANTIC COAST had just 828,000 lbs. 
This NY estimate must be Dead Wrong. 
These Recreational Catch Estimates, a very expensive part of management, hold JUST NY's Private Boats landed almost ONE MILLION MORE POUNDS OF SEA BASS than the whole coast's Party/Charter effort. 
And private boat guys in NY are complaining about Party Boats taking all the sea bass before they can get out? 
Both cannot be true..

I'll have 38 years of fishing for sea bass from Maryland's single seaport this year. Along this part of the coast Private Boats fishing offshore are more concerned with flounder & the bluewater species than sea bass. I'd estimate Private Boats actually account about 20% of MD's sea bass. In every port, and for every fishery, "Percentages of Catch" can be devised that would give regulators a more solid feel for possible errors, some huge, in MRIP catch estimates. 
For instance, in 2014 & 2015 Maryland Party/Charter were reported by MRIP to have landed more sea bass than Private Boats - with Shore landing near-zero. That's a likely outcome. 
In 2016 MRIP (expressing great disdain for any need for veracity in their data) showed MD Shore fishers as having landed the most pounds of sea bass. Shore! 
I know guys who take their shore fishing seriously. No one was able to confirm a single (NOT ONE!) legal 12.5 inch sea bass caught from shore, yet MRIP has these boat-free anglers landing quite nearly 50,000 pounds in 2016 --- And Shore Also Had THE LARGEST AVERAGE MD SEA BASS! 
The fishery flip-flopping yet again, in 2017 MD Private Boats are 'estimated' to have caught 6X more sea bass than Party/Charter, a very unlikely outcome 
..and soon that number will increase 3.3 times if this "MRIP Recalibration" goes through. That's simply laughable about the Private Boat catch; but to increase the inconceivable 2016 MD Shore estimate 6X to 300,000 lbs of sea bass is a crime against reason. 

Let's see: 
Please recall All Party/Charter along the entire Atlantic Coast caught 828,000 pounds of sea bass in 2016. We surrender daily catch logs. We TELL THEM what we caught. There's just No Excuse for this number to be very far off.
MRIP also estimates Private Boats landed 1,842,000 lbs in NY during 2016 -- 831,000 lbs in Connecticut -- 814,000 lbs in MA -- & even 493,000 lbs in Rhode Island. 
When factoring in MRIP's new "Recalibration" - Party/Charter doesn't budge. Not that they actually do, but MRIP ought to have our landings about right. There should be no need of 'recalibration' in our For-Hire data.

MRIP's numbers on Private Boat, however, will skyrocket after recalibration. NY Private Boat's 2016 catch will become 6,079,000 lbs of sea bass (so, from over twice what our whole coast's Party/Charter landed to over 7X greater the state where Private Boat very publicly complains about Party/Charter.) 
Under "Recalibration" CT's Private Boats, instead of just tying with all Atlantic Coast Party/Charter, will then have 3X greater sea bass catch than all professional effort. 
MA's Private Boat sea bass slayers will also have suddenly landed 3X more than All Atlantic Coast For-Hire too  ..yet fishers up that way routinely describe the sea bass fishery as pretty evenly split between Private Boats & Party/Charter. Not at the "All US East Coast Party/Charter Level" but evenly divided at the Massachusetts's-only Private Boat/For-Hire split. 

For the whole east coast MRIP shows 4,500,000 lbs of Private Boat sea bass landings in 2016 &, again, just 828,000 lbs for Party/Charter (AKA "For-Hire")  .. This estimate, the estimate that currently stands, (pre-recalibration) is far out of proportion.
It cannot be true.  
Now with MRIP's "Recalibration" we'll witness many years of quota evaporate to "Accountability Measures" as 3.3 is factored in. Recalibration will raise recreational Private Boat catch to about 15 million pounds, versus not-quite a million lbs of For-Hire catch. 

It's just as bad, maybe worse, for Flounder. 
As an example: In the dawning of "The Sandy Effect" on summer flounder (fluke) - That is, just when the first of the entire spawn, nearly a whole juvenile year class lost to hurricane Sandy, which struck in the height of flounder spawning time & just when the tiniest of flounder fry would need optimal marine conditions to survive in good number: those fluke would have been becoming legal in 2016 - but died in the storm. This is an enormous decline fisheries scientists saw, & to which regulators responded in 2017 with a full 30% quota reduction for everyone across the board. 
In 2016 Party/Charter fluke landings were shown to drop like a rock in the MRIP data. Makes sense. There's a vacuum where new fish should be 'recruiting' to the fishery. Yet Private Boat catch jumped about two million pounds to 5,536,000 lbs of fluke. 
Pretty amazing.. 
That's not counting discards--releases--which NOAA holds die in huge number. Those 5.5 million pounds are just what came ashore in our coolers. 
In this same period of sudden Private Boat increase, All Party/Charter dropped about 250,000 pounds to 461,000 lbs in 2016. 

Under the upcoming MRIP recalibration this jaw-dropping discrepancy in rec catch estimates will jump 3.3X to 18,269,000 lbs (more than double all commercial landings for any year.) If regulators respond to catch as they always have - what they perceive is legally required - we'll be so far overquota we may not see another flounder season for years. 
Not only will there suddenly be a an enormous jump in catch, but a far-more enormous jump in dead discards. It's entirely possible JUST DISCARDS, fish we released, will absorb any flounder quota we might receive for years to come. 
A summer flounder (fluke) closure will be the only way to lower our dead discard numbers. 

"No" you say? Think that could never happen? 
Consider red snapper in the South Atlantic region. I watched as a young lady, (& plainly unenthused with MRIP data,) presented the South Atlantic Fishery Management Council's reasoning for COMPLETELY closing red snapper below Hatteras. She showed how just the discard estimate (recreational release mortality) had put South Atlantic recreational fishers over their meager snapper quota in 2014 & 2015 -- yet the 2016 number offered close to zero release mortality. They could have had a season last year but are "paying back" previous overages via Accountability Measures.. 
This year's 'recreational bycatch' estimates are sky high again; a frequent wandering seen in catch estimates. 

It seemed plain in a crowd of not quite 200--and many of these folks at the top of fishery management's regulatory world; it seemed plain that few believed MRIP's estimates. 
But, as ever, the South Atlantic Council followed the law. MRIP is, according to NOAA, "The Best Available Science" and must be used in fisheries regulation. If MRIP sez we're overquota - that's what it's going to be. 

I am confident there has NEVER been less trust by professionals in management over catch estimate data; that any confidence in catch estimates shown in management's early years has evaporated. 

But regulators will still follow the law. 
If MRIP tells managers there were actually 4 years of summer flounder quota caught after 'recalibration', bet your last dollar Accountability Measures will kick in. We'll have to "Pay It Back." 
We'll do that with several closed seasons. 

Whether red drum, cobia, fluke, tautog -- whatever -- doesn't matter. They all have MRIP catch estimates. 
Once recalibration has occurred, every fish with fed/state regs will show a huge jump in catch. 
We'll then see a sudden jump in regulatory tightening. 

Funny how in the early years of sea bass management, (began in 1997,) the population off DelMarVa climbed exponentially into 2003. Those cbass we were loading our coolers with back then had never been protected by season closure, nor even a bag limit - just a size limit  ..a size limit we'd begun in Maryland five years before formal regulation. 
Funny how we're allowed far fewer cbass today than back then, yet there's ALWAYS need of greater regulation. 
Ponder this: with ALL THE REGULATORY TIGHTENING we've been made to suffer in the recreational sea bass fishery--all driven because we'd 'Gone Far Overquota'--the sea bass population is fully 240% ABOVE the rebuilding target. Looking at a population graph of today's population makes the incredible fishing of the early 2000s look like a small bump. 
How DID sea bass do SO WELL with ALL THAT OVERFISHING GOING ON? (..according to MRIP.)
And now MRIP wants regulators to believe that although sea bass are incredibly beyond their restoration target population levels, after recalibration in 2016 Private Boat fishers will have harvested more sea bass in a year than all Party/Charter & Commercial fishers will take in a few years..
Funny too how NOAA's been far too busy to discover our seafloor reef habitat; how habitat's loss in the early decades of industrial stern towed fisheries--through the 1950s & into the 1970s--had the exact same affect on sea bass production as if you'd cut down thousands of acres of trees 
..and pondered why squirrel hunting just wasn't the same. 
It remains true there were more sea bass caught commercially from 1950 to 1961 (weighed catch) than in all the years since combined. 
I remain convinced, "Reef Restoration Makes Fisheries Restorations Simple."

It's also mighty funny how since the 2003 correction to Party/Charter catch data, (when we reigned-in really bad For-Hire estimates being created even though we were surrendering daily catch reports) -- since 2004 Private Boat catch numbers have soared. 
And Soared
And Soared. 
Now they're going to JUMP into the stratosphere? 
If MRIP's 'recalibration' sticks, rec catch will become far higher than commercial ever was.  

MRIP believes because there are more Private Boats, they MUST catch more fish. More & More fish.
I keep trying to tell them For-Hire businesses carry all the folks who do not have a sturdy sea-going craft. In the shoulder seasons we often carry boat owners too as they (wisely) put their rigs in storage. Our collective Party/Charter client base represents a LOT more people than just the boat owners and their friends.....

In a meeting room with close to 200 folks; 40 from NOAA and many others from the regulatory community, I brought up several examples as I have in this letter -- did it three times. 
Every time the room erupted in laughter. 
About the only laughter, really. 
Seemingly embarrassed, one long-time NOAA staffer said from the dias, "You're not looking at final estimates." 
I told him (and everyone else) I'd just looked the numbers up moments before, that they were indeed all "Final Estimates." 
More laughter.. 
Maybe they were laughing at me? Maybe everyone in that conference room thought it perfectly reasonable that in 2016 NY Private Boats caught 2X as many sea bass as ALL Atlantic Coast Party/Charter? Maybe all those professional regulators & all those Fisheries Ph.D.s thought NY's Private Boats suddenly having caught 7X more sea bass than ALL Atlantic Coast Party/Charter ought to be obvious? 
Maybe they believe "Shore" really was the best place to catch sea bass in Maryland during 2016? And that the BIGGEST average-sized sea bass (3 lbs) of 2016 really were caught from Shore in NY? 

I don't think so. 
I think they were laughing at their own data. 
Trust this: although regulators may not believe the MRIP data they're being forced to use as though true: Use it they will. 
And we'll pay. 

If you are a For-Hire operator from Maine to Texas, I believe your business model is about to implode. 
If you own or work at a saltwater-oriented tackle shop or marina, sales may get mighty slim. 
If you own a salt-water capable boat, you may soon question the wisdom of all those maintenance, insurance, license, & marina fees -- all the monies paid regardless whether you ever go fishing. 
If you are simply a recreational angler, I believe your seasons & bag limits are about to become incredibly smaller, your size limits larger: You May Not Be Allowed To Fish AT ALL For Some Species. 

Want to do something about it? 
Those guys in charge now do NOT strike me as easily fooled. The Secretary of Commerce has seen his share of bad data and how .gov can be a pain in the neck for businesses. The Undersecretary to NOAA can probably calculate star transits in his head. He struck me as truly smart.  
So very different today than ever before: if these people at the top ask the fisheries management community what they honestly think, it will be no laughing matter for MRIP. 
Write an email. Better to send snail mail. 

The ONLY WAY to prevent this upcoming, fully configured & all ready to go "MRIP Recalibration" from wreaking havoc on our regulations is to WRITE!

Write your DC Reps, your State Reps. Write your State Fisheries Director & Natural Resources Secretary. 
But most of all write Secretary Ross; Undersecretary of NOAA Gallaudet, and NOAA Assistant Administrator for Fisheries, Chris Oliver. 
Want to do two more? Write Sam Rauch, Deputy Assistant at NOAA Fisheries; & Francisco Werner, Director of Scientific Programs & Science Advisor. (Hey Dr. Werner, If a WHOLE ROOM FULL OF PROFESSIONALS is laughing at your 'best available science' something's probably gone wrong..)
All these folks - all of them & ESPECIALLY your DC Reps - really do WANT to hear from outside their staff on issues. 
Writing truly can & does impact regulatory decisions.  
I'm positive. 

Don't let Someone Else do it -- WRITE!
Because people at the top are loathe to make email addresses public - do it the old fashioned way. It's generally considered more effective anyway. 

Recalibration will create an enormous regulatory seizure of what remains of our fisheries. 
We must write. 
All of us. 

Addresses below. 
I know some will want a sample letter - a cut & paste. 
Thing is, they don't work. 
MRIP is already bad data. I've written to my DC Reps since 1998 about it. I've written innumerable 'fish reports' about laugh out loud, but actually sad, MuRFSS & then MRIP data. Now MRIP wants to make their data incredibly worse. Many times worse. 
Just Write. 
The data's obviously already WRONG. Now NOAA's going to make it worse? 



Capt. Monty Hawkins 
Partyboat Morning Star 
Ocean City, MD

Secretary of Commerce Ross - (Might work.. Writing's better)
1401 Constitution Ave NW, Washington, DC 20230

NOAA Undersecretary RDML Gallaudet, and Francisco Werner, NOAA's Director of Scientific Programs & Science Advisor: 
1401 Constitution Ave NW, Washington, DC 20230

NOAA Assistant Administrator for Fisheries, Chris Oliver: Deputy Assistant at NOAA Fisheries, Sam Rauch: (also )
NOAA Fisheries 
1315 East-West Hwy 
Silver Spring, MD 20910

There's no way I can list everyone's DC & State reps - they all google - type in a name & "contact us" -- there's also -- from here you can find your reps..

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Morning Star Sport Fishing · 12940 Inlet Isle Lane Slip B-2 · Ocean City, Md 21842 · USA

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