You can criticize my work all you wish as your entitled to your opinion, but I’d ask you to refrain from putting words in my mouth. Once again, I never said the 14" size minimum commercially is the driving force for commercial operators harvesting larger fish. To the contrary I’ve repeatedly said significantly higher market prices for larger older age class fish based on market demand created that opportunity. I’ve stated and believe size increases to the recreational sector have been implemented as a means of managing catch to facilitate those age classes being inaccessible to the recreational sector and available exclusively for harvest by the commercial sector due to the size disparity between sectors. You can disagree all you wish with the intent of management, but the result is 40 – 45 million older age classes in the biomass have become the exclusive property of the commercial sector and not available to the general public for harvest. The recreational community can catch them, be assessed a 30% discard penalty further reducing the portion of their RHL quota for harvest, but they can’t harvest them. Personally I call that an egregious disparity in the regulations between sectors and what I believe is a violation, as stated, of Standard 4 of MSA. Recreational has become the stocking arm so to speak for the commercial fishery in the sense the fish we’re forced to release are subsequently targeted by commercial operations for their higher prices. Review the attached graph trending commercial landings weights, ex-vessel values and wholesale price per lb. for the period 1994 through 2018, source page 7 of the “MAFMC Summer Flounder Fishery Information Document” dated August 2019. If you need a copy, I’d be happy to provide it. Annual landing weights have been cut in half, while simultaneously ex-vessel values (catch values) have tripled and the price per lb. has quadrupled. I guess based on your argument, you would want us to believe that’s being driven by all the 14” fish being retained because of the commercial minimum size limit. If you do, stop here because truthfully there’s no sense continuing.

My goal is not and never has been to lower recreational limits or increase commercial size limits. My focus from day one has been and continues to be understanding what's happened and is happening in this fishery leading to a 70 million fish or 40% decline in the population between 2009 and 2017, a 40 - 45 million decline in the female component, why recruitment levels have precipitously declined this past decade by 200 million from the preceding decade, why every age class has undergone a significant decline in gender composition and why discard rates have approached levels never before seen. Discard rates which I believe are under-reported in the commercial sector based on unbiased reports from federally mandated observers reflected in the attachment. Those percentages are a disgrace. For the 5-yrs I referenced in my previous post, '01, '06, '07, '08 and '09, commercial discards averaged close to 100% of landings those years. I want to quantify that statement so everyone understands what that means. For those five years, commercial landings were slightly in excess of 55 million pounds. So the commercial sector harvested 55 million lbs. of older age classes and in the process based on onboard observers killed 55 million pounds of lesser market value younger age classes to promote higher ex-vessel values. At the time, commercial harvested weights averaged roughly 2.25 lbs. per fish and discard weights averaged 1.25 lbs. consisting almost entirely of age classes 0 to 2. Older age classes harvested, younger age classes killed. If you don’t believe my analysis, I strongly suggest you read pages 58 and 59 of the 57th SAW under “Commercial Discard Estimates at Age”. 55 million pounds at an average of 1.25 lbs. means in those 5 years 44 million fish were killed in the process of harvesting the equivalent weight of older age class higher market value fish. Want to repeat that, 44 MILLION fish were killed in the process of harvesting the same weight of older age class higher market value fish. That’s 36% of the last reported biomass, too unreal to imagine but the graph I posted yesterday which I’ll include again with this post doesn’t suggest it, it validates it. To further put it in perspective, the recreational harvest limit for 2019 – 2021 is 7.69 million lbs. a year in comparison.

I’ve been vocal regarding my concerns about the commercial harvest being allowed during the spawn on the most concentrated biomass in the history of this fishery. With today’s technology, highly concentrated biomass and a complete lack of understanding what impacts that practice has on the efficacy of the spawn, it’s impossible to quantify the effects this is having on the health of the fishery. 64% of the 2018 commercial catch came from three regions right in our backyard. Areas 537, 613 and 616. View the attached graph “Summer Flounder Catch” from the same “Summer Flounder Fishery Information Document” referenced above. And then tell me trillions of eggs being destroyed harvesting a highly concentrated and materially gender impaired spawning stock isn’t hurting this fishery. The season should be shut down during September / October and the 10% – 15% of the commercial quota being harvested in those months re-allocated to other months of the year. Don’t take away quota, reallocate so as not to coincide with the spawn. 200,000,000 less new fish recruited into the stock decade over decade and management does nothing to address the problem and even worse indicates after a decade or more of declining recruitment they have no idea what the cause is. Any fishery with below average recruitment already has one foot in the grave. This fishery is no different and while management hypothesizes about ocean acidification, global warming, climate change, density differential, predation etc. the problem worsens with no remedial action taken. Many fisheries have regulations, closed seasons, closed regions, catch and release to protect the spawn and the spawning biomass, not sure why this fishery is any different.

Billfish to answer your question, it's my understanding the basis for commercial discards come from data provided on Vessel Trip Reports "VTR's" which operators are required to submit each trip. It's strictly an honor system, they can have 100% discards on a trip and report 20% and no one would know otherwise. There isn't enforcement at sea when it comes to discards. Look at the graph I posted yesterday and again with this post today and note the glaring differences in percentages reported between observers and operators on VTR's (blue and black bars in the first attached chart). In the video you posted, which I'm well aware of, does anyone honestly believe those large fish were tossed overboard and 14" fish retained. Please, at some point in these discussion common sense has to be applied.

The fishery needs to come first and management has been operating under the same flawed management philosophy for the last 15 - 20 years while the fishery is failing. If the above statistics in your opinion don't paint the picture of a failing fishery, you and I have a different definition of failing. Commercial operations over all these years and through all these cuts have increased ex-vessel prices due to elevated market prices of their catch, the most critical metric for commercial operators. In the meantime, recreational has sacrificed ridiculous decreases in possession limits and increases in size minimums, been forced to endure shortened seasons and lost harvest rights to 40 - 45 million fish. In 2018, 67% of angler trips ended up with one fish landed, 24% ended up with two fish. And that excludes trips were no fish were harvested. Reference attached graph. The sacrifices in this fishery have fallen squarely on the recreational sector and we’re still at risk of further cuts if recruitment continues its decline which is pretty much a statistical certainty.

All these problems are created in my opinion and based on what the data is telling us for two reasons. You can't harvest a resource twelve months out of the year, pound them during their spawn, target older age classes selectively or due to regulatory mandates and think you can have a sustainable fishery. It is precisely those reasons the stock crashed in 1988 and the biomass population declined to 78 million fish of which age groups 0 - 2 accounted for 75 million of that population. Meaning the older age classes were wiped out. We’re doing exactly the same thing today. Kill the breeders, kill younger age classes in the process, destroy the strength of the spawning stock, recruitment is decimated and the cycle continues.

Your comments don’t concern me based on who they’re coming from. I’ve done more analysis, research, communicated with marine fisheries, the Commission and Counsel more in the last three years than you will in your lifetime. All my comments, interpretations and conclusions are based on data developed by the science you so adamantly espouse. You show complete lack of respect for the members on this site and provide no tangible contribution to the issues plaguing this fishery. My efforts have been to focus attention on what the data is telling us are the problems. I have no concerns about my approach yet you dismiss them as dubious and tenuous for reasons only known to you and reasons truthfully I could care less about. My efforts and fight are for the recreational angling community, the commercial sector, future generations and upmost the fishery itself. It's being grossly mismanaged and the time has more than come for fisheries management to be held accountable.

I’ll finish by asking three questions I’d like you to answer for the site and its members since you seem to have such great insight into this fishery. First, I’ve never come across language in MSA, state regulations or any material which said commercial operators are required to retain any fish over 14”. All the language I’ve seen basically says “commercial operators will not be allowed to harvest or be in possession of fish under 14”. I’d be interested where that language exists. Second if my interpretations and conclusions are wrong, I’d be interested in your theory as to why the biomass declined by 70 million fish or 40% of its population between 2009 and 2017, what caused 40 - 45 million decline in the female composition, why recruitment levels have tanked this past decade by 200 million from the preceding decade, why every age class has undergone a material and significant decline in gender composition and why discard rates have approached levels never before seen. Please address each of those five issues. And lastly, I know what my efforts have been these last three years fighting for the fishery and the rights of both the commercial and recreational sector. Regardless of the outcome, I can sleep soundly at night knowing I tried making a difference. The same way the RFA, SSFFF and many others have given their time willingly to fight for the fishery and our collective rights to access it. Without them, we'd have no voice and no representation whatsoever and this fight would be over. I know what I’ve done or tried to do, would appreciate hearing what your contributions have been for the same. Remember “People in glass houses shouldn’t throw stones”.

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