Wednesday, April 25, 2018

Fish Report 4/25/18 - A Regulatory Death?

Fish Report 4/25/18 
New Reef Pics - Video Soon
Help Wanted

I've foreseen MRIP's regulatory cancer finally entrapping our southern region for some while. 
We will have won or lost this battle in a few day's time. 

A reef sunk in the 1970s is overgrown with corals. A product of good reef habitat is fish - you can't stop it.

Need Two Deckhands - Partyboat Experience Not Required (I sure didn't have any when I started) If you know someone who loves to fish, wants to learn, wants to work deck & work year round, & can pass DOT drug tests - email

Greetings All, 
Put my favorite diver, Nick Caloyianis, over some artificial reef at the Bass Grounds Sunday afternoon. This after back to back days of volunteer-manned block trips to both Wolf & Daughters and Nana Daub's Reefs; he found visibility quite good in 55 feet of chilly, 42* water. 
With camera gear likely worth more than my boat, and 40+ years of u/w videography for NatGeo/Discovery; he shot fabulous stills/video of our reef-block drops & several older artificial reefs. A barge from 1998 had extensive growth & numerous tog, but sea bass were absent owing the cold. The most extensive coral coverage was, of course, on a reef sunk in the late 1970s. (included)
I only have pics for now - video's coming. Will post video on FaceBook & at when edited for size. 

Very Seriously: 
I've been encouraging folks to write DC/State legislators & fisheries regulators for years. Most recently about MRIP's (NOAA's recreational catch estimating program) ..most recently about MRIP's upcoming "recalibration." 
NOAA wants to increase Private Boat estimates by 3.3X, & Shore estimates by 6X.. 
These recreational catch estimates are already LOL dumb. To increase them by multiplication is a crime against reason. 

Up until a few days ago, managers had a plan to divide from Maine to Hatteras into 3 regions of separate recreational sea bass regulation. I argued for just such divisions even before regulation began, back in the mid-1990s -- it's obvious from tag returns that "habitat fidelity" MUST be factored into sea bass management. 
Now: although commercial VTRs (mandatory Vessel Trip Reports that Party/Charter must also fill out daily) VTRs show sea bass being caught just fine in area 621 (from MD/VA line to southern NJ) - yet recreational catch estimates portray a vastly different picture where Private Boats from NY, CT, MA, & RI are each-and-all able to catch more sea bass than every single Party/Charter operator from Florida to Maine. (well, nearly so for RI..)
NY's estimates have shown where their Private Boats 
alone can outfish ALL Commercial effort from Hatteras north, and 2X the Party/Charter catch along the entire East Coast. 
Yet NY's Private Boat voices continually complain of Party Boats cleaning off their sea bass? 
NOAA's catch estimates & NY fisher's complaints are logically irreconcilable. Both cannot be true. If NY Private Boats are such a brute force on the sea bass fishery as MRIP claims, it would be NY Party/Charter patrons wailing aloud..
Have asked many in my industry, "What do you think the split is between Private Boat & For-Hire with sea bass in your area?" 
It's never over 50%.. Down here I doubt it's 20% -- Yet MRIP portrays incredibly more sea bass from any of a number of state's private boats outcatching ALL Atlantic Coast Party/Charter. 
One state's Private Boat catch, NY, equals even as much as 2X All Party/Charter along the whole coast....

Despite regulation tightening annually, MRIP has created a visage where regulation factually decreases Party/Charter catch (as stricter regulation would logically have,) while their Private Boat guesstimates, (and now even for Shore anglers!) shoot for the moon.. Regulation logically curtails Party/Charter catch, yet Shore & Private Boats attain insanely new highs. 

As noted in previous Fish Reports: at the Saltwater Recreational Fishing Summit in DC a few weeks back I had the whole room of about 200, half of whom were with NOAA/NMFS/Council/Commission - had them all laughing at several MRIP estimates. 
Yes, asserting NY's Private Boaters are able to outfish ALL Commercial Trap/Trawl despite increasing size limits & decreasing bag/seasons is funny. 
Yes, MRIP asserting Maryland Shore anglers could land FIFTY THOUSAND POUNDS of sea bass when we've only been able to find ONE ANGLER who claims to have caught a keeper sea bass from shore is funny. 
Yes, asserting NY's LARGEST AVERAGE SEA BASS ARE CAUGHT FROM SHORE IS JUST (insert salty wheelhouse verbiage if you'd like) STUPID!
On & on & on.. I've written about this scientific travesty for years. No, Decades. Since 1998 in fact. 

But having managers laugh at the data they use to destroy recreational access to fabulously rebuilt fisheries is not at all the same as having them TAKE ACTION against their required use of this data. 

There is no federally regulated fishery that has not been impacted by NOAA's recreational catch estimates. 
Now recreational sea bass fishers of all types are about to be shown, "Proven by statistic" if you will, to be so far above our allowed recreational sea bass quota that NOAA will be "forced" to take drastic action. 

This action could, in a few day's time, be the end of dedicated full-day sea bass trips from Hatteras north. Our season could be shrunk to a few weeks, our size limit increased beyond ridiculous, and our bag limit scarcely able to stink a pan

..all because, so help me; All Because NOAA Requires Managers To Use MRIP Catch Estimates No One Believes - use the very estimates a room full of top management will laugh at. 

Below is a letter I wrote 4/24/18 broadly across the top of management. Going to snail mail it too, although that may be too late... 
Email to your state regulators? You can send it to Commerce Secretary William Ross at & NOAA's top brass, including bosses RDML Gallaudet & Oliver, at ...
Never-Ever has the Secretary of Commerce been so dialed-in to our statistical worries. 
Never-EVER has the big-boss at NOAA been more keen on recreational fishing. 
If you like taking home sea bass after a day on the ocean off DelMarVa, NEVER EVER has it been more important to WRITE! 

I've foreseen MRIP's regulatory cancer finally entrapping our southern region for some while. 
We will have won or lost this battle in a few day's time. 

Capt. Monty Hawkins 
Partyboat Morning Star

Sent 4/24/18 
Greetings Secretary Ross, Undersecretary Gallaudet, Mr. Oliver, Mr. Rauch, Mr. Werner, Mr. Moore, Mr. Beal, Mr. Hare, & Mr. Luisi,

I've recently encouraged fishers to write you all concerning MRIP's recalibration. Little did I know a far more pressing issue would surface before your recreational data underwent even greater statistical magic..

Sea bass in the Mid & North Atlantic are now believed at their highest population since the 1970s. In the waning days of unregulated fisheries we had sea bass & a sea bass fishery. Catching them has been an important part of my livelihood for nearly forty years. 
Owing NOAA's staunch adherence to MRFSS & then MRIP recreational catch data; regulation will soon have done what unregulated fishing, even mighty foreign trawlers, could not. Owing only recreational catch data no one believes, management is on the verge of destroying the recreational sea bass fishery in the Mid-Atlantic via over-regulation. 

The whole room laughed when I quoted MRIP's NY 2016 sea bass catch at NOAA's recent recreational summit. Some of you were there. 
But that estimate, and its ilk from previous years & 2017 too, is exactly why For-Hire fishers are at this regulatory precipice. Because MRIP creates the illusion of Private Boat catch in grand scale, of going 'over quota' as if wholly unregulated, we are continually treated as over-fishing criminals.

I promise you all, while both sea bass & sea bass fishers would benefit greatly were NOAA to seek knowledge of habitat lost in the early part of industrial fishing's rise & begin its restoration; to further restrict this fishery is indeed an economic crime - a robbery by statistic. 

Why are we about to be so impacted by catch estimates everyone laughs at? Why is an estimate showing NY Private Boats harvesting more sea bass than All Commercial catch north of Hatteras (or 2X more than All Atlantic Party Charter) about to completely destroy what's left of the public's faith in this process? Why do MRIP estimates so routinely show the predictable result of declining catch in the For-Hire estimates whenever regulation has tightened, yet wildly increase Private Boat at the same time?
Why will regulators soon act again "To Prevent Overfishing" when even they do not believe MRIP's accusations.. 
How in blazes has it come to pass that a population of fish far above their 'rebuilding target' --a population greater than dreamed (but not as great as it will be when habitat is at last grappled) -- why is the sea bass fishery in need of graver-still recreational restriction? 
Because MRIP catch data so bad even a room slam-full of fishery management's best & brightest will laugh at it is, regardless, always used as if factual, that's why. 

I've written some of you for decades about this. MRIP might have some fancy pedigree from the statistical community, but when it comes to on the water observation -- it's just crazy talk. 
Real Crazy  
..but MRIP's crazy certainly results in real regulation.   

Biology & Ecology have no seat at management's table. Statistics own the regulatory process. 

Everything done with sea bass since 1998 has been mostly driven by a spike or two in one state/one mode's estimates. MRIP's gotten away with it for so long they're about to add multiples in 'recalibration'. 

I fought hard for management of sea bass & tautog in the early & mid 1990s. Men threatened to burn my boat, "Regulation Will Destroy Us" they said. 
Looks like they were right. 

What a mess perfect adherence to bad data has wrought. 
Below are a few examples from past writings. 
MRIP doesn't even offer management a sort-of reasonable guess. 
No endeavor could withstand inclusion of so much bad information. 

Will my life's work be lost in a few more days? 
It will if people in charge don't at last stand up against bad recreational catch data.

Capt. Monty Hawkins
Partyboat Morning Star 
Ocean City, MD  

Here's a direct comparison of the old MuRFSS program & NOAA's new MRIP recreational catch estimating method.  
This table shows Massachusetts Party/Charter catch estimates from both programs. It also shows MRIP's PSE spreads. (PSE = percentage standard error. Similar to "Margin of Error" in a political poll.) 
Estimate StatusYearWaveSpeciesNew MRIP  {Old MRFSS}PSE  or MRIP's Margin of Error Spread
FINAL2004JULY/AUGUSTSCUP752,942        {19,547}48.9    or      20,000 to 1,450,000
FINAL2005JULY/AUGUSTSCUP     1,382       {12,557}   67.3    or        Zero to 3,200
FINAL2006JULY/AUGUSTSCUP  76,908        {49,624}46.2   or       6,000 to 140,000
This is a steady fishery. Party/Charter catch the heck out of scup up there.   

A MuRFSS table: (Marine Recreational Fishing Statistics Survey)
Species: ATLANTIC COD - Massachusetts - 
  Private Boats Only - Mar/April
  (March was Closed in 2010MRFSS
According to this data fishery managers had to use, small recreational boats in Massachusetts - "Private Boats" - caught and killed 1.5 million cod in 2010. That's because, despite 10s of thousands of tag returns, all recreational cod discards - throwbacks - were also counted as dead in 2010.
Using MRIP's "Avg Weight Pounds" from March/April 2010 of 9.6 pounds apiece in the same data-set, we see Massachusetts' small private boats "must" have caught 14,176,000 pounds of cod, by official estimate, in April of 2010 -- March was closed. They had to catch them in just April. 
Massachusetts's commercial fishers, (known world-wide for their gentle handling of a resource?) landed 1,060,000 pounds in the same period. 
Small boats in MA had never-ever caught like that before. Ever. Yet they had just outfished the commercial sector by 13 million pounds in one month.. On paper. 
It was Private Boat owners' who were responsible for the sudden demise of Gulf of Maine cod that year. 
It should also be noted that while these Private Boats were decimating the newly-rebuilt cod stock during New England's notoriously foul April marine weather; that while Grady Whites & Boston Whalers were fishing incredibly hard in an ocean where men in large fishing boats die; that while outboards were catching 14.2 Million pounds of cod in April; the For-Hire Partyboat/Charter boat cod catch for the same period was 52,000 pounds -- not even a hundred-thousand pounds..
A life-long partyboat skipper told me, "There's no way Private Boat catches even 5% of what For-Hire lands in March/April." 

NOAA would learn a lot by asking "What's the percentage of catch?" where recreational fisheries are concerned. Considering the mind-numbing inaccuracies of data already used, a simple estimate based solely off For-Hire VTRs would be far more accurate for regulation's purpose and a heck of a lot cheaper.
Recreational Private Boat fishers in New York, in 2016, are said to have caught 1,846,000 pounds of sea bass all year. Not the whole coast's Private Boats - just New York.
Management truly fears this powerful force & must factually react to it in regulation. 
NY Private Boats All Year
Estimate StatusYearCommon NameHarvest (A+B1) Total Weight (lb)PSE
To put that 1,846,122 pounds of Private Boat sea bass catch by one state's Private Boats in perspective: the 10 year average for all Commercial Trawl & Trap from Cape Hatteras to the Canadian border is 1,612,000 pounds a year.. (They do not publish commercial data w/o a year's delay, but 1.6 million is going to be pretty close.) Therefore NY's private boats outcaught commercial fishers from North Carolina to Maine by 234,000 pounds. 
All Mid-Atlantic & North Atlantic For-Hire
Estimate StatusYearCommon NameHarvest (A+B1) Total Weight (lb)PSE
A manager would have to conclude - and I do mean "Have To" - that NY's Private Boats outfished every Party & Charter Boat north of Hatteras by 625,000 pounds in 2016. That information is, after all, straight out of NOAA.guv's "Best Available Scientific Information." 
They would also Have To conclude these small boats outfished the trawl fleets & trap boats from Hatteras north. 
Yet the truth of it is this - NY Party Boats are cursed by NY Private Boaters for 'cleaning out' their reefs' sea bass. 
That's logically irreconcilable from MRIP's assertion NY Private Boat is an out of control overfishing monster. 

MRIP is as Crevecoeur's birds..  "I shudder when I recollect that the birds had already picked out his eyes, his cheek bones were bare; his arms had been attacked in several places, and his body seemed covered with a multitude of wounds. From the edges of the hollow sockets and from the lacerations with which he was disfigured, the blood slowly dropped, and tinged the ground beneath. No sooner were the birds flown, than swarms of insects covered the whole body of this unfortunate wretch, eager to feed on his mangled flesh and to drink his blood." 

I truly fear the worst. 
Your sudden recognition of bad data's affect on recreational regulation, and a willingness to stop it, is my only hope. 

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

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