Someone help me understand the following harvest data. First chart deals with historical and current commercial quota allocations by state extracted from the Summer Flounder Commercial Issues Amendment dated August 2018. Second chart comes from the ASMFC Draft Addendum XXVlll in 2017.

If you look at Chart 2 (Recreational Harvest) North Carolina and Virginia combined in '16 were projected to make up ~3.6% of the overall recreational harvest or ~230,000 lbs relative to a coastal-wide harvest of ~6.4 million lbs.. Currently North Carolina has a 4 possession limit at 15", Virginia 4 possession at 16.5" for recreational, significantly more liberal than all northern States.

Commercial landings in 2017 were 5.83 million lbs. North Carolina and Virginia combined represented almost 50% of those landings, equivalent to other nine states combined or ~2.9 million pounds. How is that possible?

Please review the third chart and following comments which were included in a letter from New York Attorney General, Division of Social Justice Environmental Protection Bureau dated March 23, 2018 to Secretary of Commerce Wilbur Ross.:

Because older and larger summer flounder are distributed further northeast in the summer flounder’s range, and possibly due to other factors, the center of biomass of the summer flounder stock has shifted northeast since the 1980's. Trawl survey data indicate that the stock is now concentrated in the northern mid-Atlantic waters east of New Jersey and south of Long Island, and in the southern New England waters east of Long Island and south of Rhode Island and Massachusetts (see Figure 2).

That being the case, how does NC and Va. receive 50% of the commercial harvest in this fishery which I assume are being harvested from our local and offshore waters. Would appreciate others perspectives. And while we're on the subject of location of the biomass and all the global warming theorists, this has always been my opinion. While there's obviously global warming occurring which needs to be understood and addressed, my personal belief is it has little impact on this fishery since a majority of the existing biomass per the attached chart still resides in our back yard. As with most species, larger fish seek out cooler waters, I believe the illusion which many believe of a massive northern migration due to climate change is in fact the result of size increase regulations causing less of a harvest of 15" to 17.99" fish establishing the geographioc relocation of the biomass further north. Global warming didn't drive them, average size has. Review charts 4 and 5. Commercial harvets used to consist primarily of 1 - 2 year old fish (Chart 4), fish which weren't even sexually mature. So essentially past year harvests in the 2000 to 2002 and earlier years didn't even effect egg production. Today with size increases and the harvest consisting of primarily 3 year old fish and older, almost every fished harvested negatively impacts recruitment. And NMFS, ASMFC don't even address, mention or question a 90% decline in relative recruitment statistics. A three year old fish on average is ~45 centimeters or ~18" with differences between females and slower growing males. Compare all this to Chart 5 which illustrates age to length and relate that to the commercial harvest information by age on Chart 4. The regulations have allowed smaller fish to grow, but with their significantly lesser egg production capacity it's had little to no effect on increased recruitment as NMFS hoped. Instead it's put a target on larger females with incredibly greater egg production capacity and caused the biomass comprised of larger fish on average to move further north. Still find it interesting how two states, who are more responsible than any other state for the last and potentially next crash of the striped bass fishery because of commercial over fishing, receive ~50% of the commercial summer flounder quota, a majority of which are harvested in our own local waters almost 400 miles away from their home ports. They have no biomass in their area which is why recreational landings are so scarce, for that reason they're given more liberal recreational size and possession limit and provided access commercially to harvest stock (almost half the quota) in our own waters. Someone help me understand the reasons behind these decisions and allocations. To add insult to injury, commercial harvest in our area back in the 80's was estimated to be ~46% of the annual commercial harvest, today it's estimated to be ~90%! NMFS IS LEGISLATING THE DECIMATION OF RECRUITMENT AND CRASH OF THIS FISHERY. 90% of commercial harvest in our own backyard where most of the spawn takes place, tell me this isn't having serious consequences on the spawn. The more research I do the more incompetent fisheries management appears to be in their interpretation of data and policy decisions. We're working our way to a 2 fish possession limit at 27" with a season starting on March 1st and ending June 30th. Level of incompetency is without rival how the summer flounder stock is being managed.

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