66th Stock Assessment / Fluke Regulations / MRIP

Found the detail report from NOAA / Northeast Fisheries Science Center for the recent 66th Stock Assessment. Want to post some information which proved critical in the recreational fishing quota remaining status quo for '19 relative to the 40% increase commercial operators received. Keep in mind this all falls under the disclaimer of "best available science" but when you have changes in historical data to the magnitude used in these models the credibility of best available science needs to be questioned.

http://www.asmfc.org/uploads/file/5d...t_SAW_SARC.pdf

Refer to page 154 which illustrates the table of changes in recreational landings being used in the current models. To give an idea of how out of control these numbers are, for 2017 the old MRIP system estimated recreational landings in 2017 at 1,447 metric tons. The new MRIP methodology is now estimating recreational landings at 4,565 metric tons, a 215% increase or 3,118 additional metric tons equivalent to almost 7 million more pounds landed in one season! For the years 2010 through 2017, recreational catch in Peer Review models has been increased by ~143% on average due to a new form of data collection when we were asked to believe prior models and published numbers were accurate. This is the primary reason the recreational angling community didn't receive a comparable 40% increase in '19 as commercial concerns did.

Refer to pages 246 and 247 which illustrates the incremental metric tons and number of fish recreational anglers are being charged with all due to a new equally speculative means of capturing and quantifying the data. I can understand 5% - 10% acceptable deviations but when key statistics being used to update models and manage the fishery are off by 100% - 200%, there's no foundation to believe these statistics are accurate or decisions based on them appropriate for the health and sustainability of the fishery.

Another relationship which makes no sense based on the above is historical levels of SSB are being retroactively adjusted to show an increase between 20% - 30% over previously reported numbers for the years 2002 - 2012 even though recreational landings estimates are said to have been grossly underestimated during that time frame. SSB levels conceivably if used in those prior years would have negated the need to reduce catch levels further for both recreational and commercial concerns per the provisions of MSA. That horse already left the barn so not only do we not get credit for those past cuts we get penalized again this year with status quo.

Truthfully I'm shocked at the degree these numbers are changed by with no substantive explanations as to why. When SSB levels fail to be attained, catch is immediately the go to solution which has proven to be the wrong solution since SSB attained it's historical high in 2002 when catch levels were three times greater than today. All other issues potentially hindering the fishery are completely ignored. It's no way for a fishery to be managed.