.LI know this will piss some people off but I've spent a considerable amount of personal time the last three years educating myself about various fisheries, understanding the process and fisheries management bureaucracy which is ultimately responsible for the health of every fishery and analyzed oceans of data published in an effort to identify trends which could lead to remedial measures nursing these fisheries back to health. I had what I now believe to be false hope that my work could and would have a positive impact on the various and many groups which depend on these fisheries and assist regulatory agencies and industry associations in that endeavor. What I've found instead is a process in my opinion so broken, disjointed with so many personal and political agendas among state and federal governments that it makes the health care system seem relatively simple and straight-forward.

Fishery management, as complicated as it is, has one primary goal and that's to manage fisheries to a level of health and sustainability. There's a lot of sub headings that fall under that statement but in the end that's what we expect from fisheries management and the governing Councils. I agree with Dan's comments that heads should roll which will stir the pot but the pot needs to be stirred otherwise nothing will change and Washington will continue focusing on "Commerce" at the public's expense "aka the recreational angler" and associated businesses dependent on them including party boats and for hire charter businesses. What's happened to the winter flounder fishery (which is the same thing happening to the summer flounder fishery) is nothing short of gross negligence, it's unconscionable how these two fisheries have been and continue to be mismanaged.

John D to your question look at the first chart attached regarding winter flounder harvest from 1960 - 2016. Notice the lbs. harvested in '81 in excess of 40 million lbs. as well as the amounts harvested during the '80 - '83 time-frame which coincided with the extreme drop off in Recruitment (egg production) and SSB (reference second chart). 80% of the harvest in '81 for the Southern New England / Mid-Atlantic "SNEMA" region represented commercial and 20% recreational. Page 35 of the "2018 Winter Flounder Specifications" document in the attached link illustrates that percentage.

http://www.asmfc.org/files/Meetings/...sentations.pdf

Also reference page 13 in particular Recruitment, Spawning Stock Biomass and Special Comments section of the Winter Flounder 52nd Stock Assessment Workshop[ (last graph) specifying weak recruitment levels and their comment "If the weak recruitment and low reproductive rate continues, productivity and rebuilding of the stock will be less than projected." This excerpt was written in 2017, recruitment has been declining since 1980 for winter flounder from ~63 million eggs in '81 to ~7 million in 2010. That's a 90% absolute decline in recruitment statistics over a 30-yr period and the best management can say is "IF". Almost 40 years later fisheries management still haven't figured it out, isn't any more well versed understanding it or have a well thought out comprehensive plan to address it. Their entire focus has been catch which to a large degree created the problem with on-going size limit increases and or over zealous catch quotas leading to the deterioration in recruitment. How is that remotely possible when we have multiple billion dollar industries futures hanging in the balance while the resources of the federal government in the case of both winter and summer flounder have done nothing remedial in the last 35-40 years to address the issue. Not only have they not addressed it, they've caused it. You can have all the models you want for Peer Review, but if they don't factor sex and length information into the equation I don't see how they can be useful guiding policy decisions in these fisheries. Egg production is a factor of age and sexual maturity, age and sexual maturity coincide with length yet as recruitment implodes in both winter and summer flounder stocks fisheries management simply continues increasing size limits for recreational and market prices continue increasing the harvest of larger fish for commercials to compensate for significant cuts over the years in catch quotas.

Review the third graph reflecting SNEMA landings and compare commercial landings and discards to recreational in general but in particular in '81, ~16,000,000 metric tons for commercial versus ~3 million metric tons for recreational. How's that for an equitable allocation of a shared resource.

Next review the fourth chart from Ct. DEP illustrating size and age of winter flounder.. Flounder reach sexual maturity around age 3-4 which per the chart are fish averaging 11"- 12". Age 1-2 year old fish average 5"- 8". How many fillets from 5"- 8" inch fish do you think are brought to market? They're killed in the tow and tossed back dead which should be the future of the fishery while mature breeders are being harvested.

Will leave you with these statistics from the SNEMA Stock Assessment. In 2013, Winter Flounder Catch for Assessment was published at 1,074 metric tons, 1,063 metric tons commercial, 11 recreational or ~1% of the overall regional harvest. In '15, catch was 749 metric tons, 737 commercial, 12 recreational. In '16, catch was published to be 678 metric tons, commercial 643, recreational 35. Again good thing our possession limit was changed in 2010 to a 2-fish daily limit since our sacrifices are giving way to once again an extremely equitable allocation of a shared resource between commercial and recreational interests.

The winter flounder biomass hasn't moved to areas unknown, it's moved to fish Co-Op's, Wegmans, Whole Foods, restaurants and Sushi markets. It's gone, SSB destroyed in the process taking recruitment with it yet we continue to allow commercial harvest without remedial measures being considered to protect the spawn and rebuild the biomass. Remember this all started in the early 80's so don't want to hear about global warming, fish moving north, environmental issues or predatory impacts since this happened quickly and for obvious reasons. This is a problem fisheries management should have seen coming a mile away but chose to ignore, take a passive approach and do nothing proactive to prevent it so now the fishery for all practical purposes is lost to recreational anglers, a shadow of what it used to be for commercial operators and will continue being so for the foreseeable future. Over 40 million pounds harvested in '81 and ~2.5 million pounds harvested in '16, an absolute debacle. For a species which primarily releases their eggs in estuaries and not off shore, after ~38 years of recruitment tanking for no one from NMFS, ASMFC or MAMFC to understand why or have proactively put measures in place to prevent it's extensive decline is why I agree wholesale changes need to occur at the management level of these fisheries. The process is beyond broken. I'm not sure whose at fault but collectively management of the winter and summer flounder fisheries has been a complete failure. 40% increase in harvest for commercials in '19 when the same problems lingers with summer flounder which appeared on the radar screen with winter flounder back in the 80's is inexcusable. Another fishery that's going to be lost if measures aren't implemented sooner than later to rebuild recruitment and circumvent the continued decline of SSB in both fisheries.

I'm absolutely disgusted. If this is going to fall on deaf ears, it's not worth the effort and a lot of businesses and people's livelihoods are going to unfortunately continue suffering the consequences of bad management while the people making the policy decisions causing the carnage feel no impact financially or economically. Where's the accountability in all this, data couldn't be any clearer, it's the decisions making process that's completely clouded.

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