Been reading the comments on a few of these threads and researching information released from the joint Council / Commission meeting in Virginia last week discussing the 66th Stock Assessment Workshop (SAW) and '19 options among other things. Lot to think about to say the least.

First when it comes to a saltwater license, a few thoughts. Read an article that NOAA in 2011 mandated the saltwater registry so they could use that database to support conversion to a different method of determining recreational catch using the MRIP system (Marine Recreational Information Program). I always thought the registry was intended to determine the number of recreational anglers in the event a salt water license was implemented so the state could determine the amount of revenue generated. I'm sure that's a secondary benefit but doesn't appear to be the primary reason for the registry being implemented. And because of this new method, which is again at best still an estimate of recreational catch, recreational community gets status quo for '19 while the commercial sector gets a 40% increase. We transitioned from one system filled with a host of assumptions intended to quantify recreational catch to another system / process / means of collecting data filled with just as many assumptions / unknowns and in the process took a hit in the form of an offset to our 40% increase. All because we're supposed to believe this new process is correct when the old process we were told for the last 20 years was "data based on best available science" is no longer representative. That term which is thrown out religiously is just another way of saying "We have no idea if the data we're publishing and basing regulatory decisions on is accurate". Yet we pay the price.

As far as salt water licenses, excise taxes, funding for greater enforcement and or fishing facilities how about this approach. Recreational anglers fish for pleasure, commercial harvest the resource to make money and provide a living. Completely different reasons. Compare 2008 to 2017. Recreational landings per 66th SAW and MRIP we're 5,597 metric tons of summer flounder in 2008. In 2017 we landed 4,565 metric tons, an ~20% decrease in landings. Possession limit in 2008 for NJ was 8 @ 18", today it is and will remain at 3 @ 18" in '19 with a good chance of it staying that way for '20 thru '21. At the same time, commercial landings in '08 were 4,179 metric tons compared to 2,644 metric tons in '17. BUT, ex-vessel catch (catch value to commercial operators at the dock) increased from ~$21.6 million in '08 to $24.7M in '17, an ~15% increase in catch value even with significantly reduced landings. Why, because of ex-vessel market prices (supply and demand) and the harvest of larger fish in general from the 80's and 90's. Yet commercial receives a 40% increase in '19 which will increase their '19 revenue by ~$10 million based on todays average ex-vessel price per lb. while recreational anglers once again are left begging for scraps.

There's no equity in what's happened in this fishery over the last twenty years. We were asked to make sacrifices which we made and are still being asked to pay for others mistakes and I don't mean the commercial sector, I mean fisheries management in it's entirety. If commercial revenues are going to receive a 40% boost next year, the state might consider enforcement funds coming out of that pot since the people benefitting the most should subsidize the enforcement supporting the resource generating that level of revenue. Why should recreational anglers pay the tab when we make no money from the resource, spend tons of money supporting the economy yet we take hits every year in possession and size limits, overall catch quotas and season lengths. Or ask equipment manufacturers like Berkley which the recreational community keeps in business to contribute, they make ~$800 million a year pretax so they should be able to assist the funding of lobbying efforts if that's what's needed. We have a resource being taken away, are feeling the biggest impact and we're talking about paying for enforcement when the commercial harvest alone when you consider ex-vessel to market will be generating over $100 million in revenues next year. Enforcement, public access funding should be paid for by the revenues generated from the resource itself, not paid for from the pockets of the recreational angler spending insane amounts of money already to enjoy that resource and if lucky in the case of summer flounder keep three fish a day.

Sad part about last few week's webinars which has my head spinning is not one thing was discusseed at the fishery council meeting in Va. that addressed the overall health of the fishery. Most discussion centered around everyone positioning for a larger piece of the pie. NMFS still believe recruitment is down only over the last six years when it's actually been down when viewed relative to the spawning stock biomass since the mid nineties and the answer when asked is an emphatic "We don't know why". Very simple answer involving two reasons both relating to size increases and cuts in catch regulations. For commercials as their catch quotas have been cut, they've targeted larger fish with higher ex-vessel value to compensate which simultaneously increases dead discard. Have spoken to a few commercial guys (deckhands) no longer in the business who will tell you the amount of fish shoveled overboard dead will make you sick if you witnessed the carnage that takes place at sea. Recreational on the other hand have increased size limits because the regulations dictate it, we have no choice. Commercials can keep smaller fish at 14" but that's not where the value is so those size fish go back dead. This proposed 40% increase to commercials and status quo with recreational size and possession limits will do nothing but further hurt the fishery, in particulare recruitment and SSB which should be the primary point of focus.

In the 80's and 90's, more than 90% of commercial and recreational catch consisted of fish under 2 years old, predominantly sexually immature fish that had zero impact on recruitment (egg production) and therefore not part of SSB. It's a large reason SSB grew 600% exponentially between 1989 and 2002. Today, the annual harvest is almost the exact opposite, ~90 - 95% of total annual catch represents fish 3 years and older, all sexually mature and all being removed from the relative recruitment strength of SSB. Commercial weight of fish harvested on average has doubled over the last two decades compared to the 80's and 90's, recreational has tripled all due to regulations and fisheries managment philosophies of managing catch through size increases. It all started around 1996 and we're continuing down the same path that led us to the mess we're experiencing today. The regulations are killing this fishery and the frustration is the lack of acknowledgment or priority to fix it. We can raise money and lobby but we need other states to do the same and every state that makes up the Mid-Atlantic region seems to have their own agenda. These rules are made by the Federal government and the states for the most part just choose between options. Unless changes are made in Washington under Secretary of Commerce / NOAA / NMFS and at the state level, learn to accept the phrase "status quo". Maybe the most disappointing comment I heard listening to the March 6th and 7th webinar between MAFMC and ASMFC was when the Chair asked the individual presenting the 66th SAW if he considered SSB and recruitment stable at this point. The answer very carefully worded was something along the lines of "Hard to say but moving in the right direction". That answer couldn't be further from the truth based on what the data reflects. Size regulations and a 150% to 200% percent increase in the weight of fish being harvested over the last two decades has destroyed recruitment and mortally wounded the reproductive strength of SSB. '19 thru '20 regulations will only make that situation worse.

Sorry for the diatribe but if we don't start protecting the harvest of larger fish, both females and males, this fishery will never rebound which in the end is what we should all be most concerned about, for both recreational and commercial interests as well as the health of the many dependent on it. If we maintained the same regulations we had in the late nineties and early 2000's, the trajectory of SSB and recruitment would have continued and this resource would be in a much different and better place than it is today. With '19's proposed regulations and increase in quota to commercial harvest, it's going to get worse before it gets better.