Summer Flounder Allocation Scoping Comments

Today is the last day to submit comments for the summer flounder scoping sessions being undertaken by MAFMC. I submitted the following comments earlier today and would recommend as many as possible do the same. When you understand the data and statistics driving the fishery, you'll understand the management of this fishery have placed other agendas ahead of the health of the fishery itself and fair allocation between sectors. Here's an excerpt from an article discussing New York's current lawsuit against the Department of Commerce looking to attain a higher percentage of the commercial quota for NY which I happen to agree is justified, but read the last sentence if you think this stock and others, all public resources, aren't being horse traded for the benefit of alternate agendas.

In fact, New York fisherman have already been caught cheating in one of the largest fishing investigations in U.S. history. Even back in 2010, New York had been complaining about its fluke allocation and the Mid-Atlantic Fishery Management Council allowed New York to catch more with one condition: Fisherman were supposed to keep track of their sales from the extra quota and return a percentage to NOAA to fund scientists.

Following are my comments submitted earlier today.

Additional comments regarding the scoping process specifically as they relate to the summer flounder fishery.

For summer flounder, 60% of the annual total allowable landings is allocated to the commercial fishery and 40% to the recreational fishery based on 1980-1989 landings data. These allocations were implemented in 1993 through Amendment 2 to the Fishery Management Plan (FMP).

While I’m in agreement the allocation of the stock between industry sectors should reflect an historical perspective, using statistics from 30 to 40 years ago is outdated and obsolete as every aspect of the fishery in the 80’s is different than today considering the regulations in place, prevailing catch statistics of the fishery and the stock’s current attributes. In addition, that decade can be summarized as one of over-fishing the stock ultimately leading to the collapse of the fishery in 1988 when recruitment statistics hit their record low of ~12 million new recruits, SSB hit a record low the following year in 1989 at ~7,000 metric tons and the biomass population collapsed to a mere ~62 million fish, a low water mark for the fishery as well. Hardly statistics or a period in the history of this fishery I would base current management or allocation decisions on. FMP needs to be amended to incorporate an allocation methodology using a rolling average of catch characteristics between sectors reflective of the current fishery. A trailing 10 to 15-yr average would be a more prudent methodology allocating the stock in a manner representative of current regulations and catch statistics. I would argue the same to be true for all fisheries under management. No business operates on statistics from 40 years ago, why would we apply those principles to fisheries management.

As a side note, I find it interesting in light of the FMP mandate to use 1980 to 1989 as the baseline period determining quota allocations, that the 80’s represented the only decade of the past four where weight values based on age groups for recreational landings were lower than weight values assigned to similar age classes used to calculate commercial landings. Size minimums at the time were the same at 13” for both sectors so average landings weights by age by sector arguably should have been identical but are not. Today, 70% of landings in both sectors represents age classes 2 to 4, and if you compare weight values assigned in 2017 to both sectors recreational values on average are 43% higher than commercial. The impacts of this are twofold; first lower weight valuations for recreational landings in the 80’s giving rise to a higher allocation percentage for the commercial sector. Second, subsequent year weight values relative to recreational age groups based on new MRIP data for comparable age classes has driven annual recreational landings higher leading to more restrictive regulations. More restrictive regulations ultimately leading to a higher allocation of annual catch quotas to the commercial sector which is precisely why the commercial sector was granted a 104% increase in commercial quota over the last two years while the recreational sector on a net basis maintained status quo. New MRIP statistics for the decade of the 80’s, with all their uncertain assumptions, are reflecting a 60/40 split in favor of the commercial sector being used as the baseline behind this allocation process per FMP but for the years 1990 to 2017 that same allocation methodology reflects a 55/45 split in favor of recreational. A 15% difference in allocation percentages based on the last 27-yrs. of landings statistics being completely ignored in this scoping process for the summer flounder fishery.

In 2018, directed angler trips of ~1.6 million resulted in 2.4 million fish landed recreationally. That equates to angler trips specifically targeting summer flounder resulting in on average 1.5 fish per trip. In the process, recreational landings came in at 7.6 million lbs., slightly under the 2018 recreational harvest limit “RHL”. What that means is in spite of higher regulatory state possession limits, those possession limits are in reality theoretical limits. Practical possession limits for the recreational community have been reduced to slightly more than a one possession daily trip limit. Meaning if on average 2 fish are harvested daily at today’s average weight per fish, the recreational community will over fish the RHL by an estimated 2.5 million lbs. triggering even more restrictive regulation in the future. Since going lower than one fish is a mathematical impossibility, the entire stock might as well be shifted to the exclusive harvest rights of the commercial sector since that’s essentially what the current regulations combined with new MRIP valuations have taken this fishery to. Recreational sector went from no possession limits, to 10 years ago, to 8, to 5, to 3 and as mentioned for all practical purposes today has been reduced to a 1-fish possession limit.

The commercial sector was granted a 104% increase in their landings quota from 5.66 million lbs. in 2017 to 11.53 in 2020. Number of fish landed commercially in 2000 was 5.6 million. In 2019, with the recent benefit of the quota increase, it’s estimated to decline by 9% to 5.1 million fish. For comparison sake, recreational landings in 2000 was 13.05 million fish compared to projected 2.22 million in 2020, an 83% decrease in fish landed over the last two decades. From a weight perspective, recreational landing in 2000 was approximately 26 million pounds based on new MRIP, projected in 2020 to be 7 million lbs. or a 74% decrease. Commercial over the same time frame was 11.2 million lbs. in 2000 with a projected quota in 2020 of 11.53 lbs. representing a 3% increase. If you thought the fishery was in a state of decline in recent years, see what 2020 holds in store with a 104% increase in commercial harvest pounding these stocks offshore during the fall spawn and mild winter months while staging offshore at the shelf. There’s every reason to believe the 2020 season will be one of the worst years in recent memory.

This fishery for all practical purposes has been taken away from the recreational sector. Regulations are killing a family tradition shore-based communities have been founded on, are causing significant economic consequences to the recreational sector and if not addressed will eventually destroy this fishery currently experiencing a slow death. Starting with the allocation methodology mandated by FMP and continuing with the use of size minimums recreationally and the unabated harvest by the commercial sector of older age classes, over 80% of their harvest occurring in the EEZ during the spawn and winter offshore fishery, this fishery is trending in the wrong direction. Regulations have wreaked havoc on the fishery and this allocation methodology and new MRIP statistics have wreaked considerable havoc on the recreational sector. Both need to change.

The above disparities outlined in this fishery have to be a direct violation of MSA National Standards 4 - “Allocations” as well as FMP 9.2.1.4 (A), (B) and (C) “regarding non-discriminatory measures between fisherman of all states”, “fair and equitable allocation of the resources” “carried out in such a manner not to prejudice any individual, corporation or other entity acquiring excessive shares of such privileges”.

It’s important for everyone to understand what’s happening here. The fishery is dying and the recreational community’s rights to a fair share of the resource have been violated. Today is the last day of public comments for the scoping meetings on the MAFMC website. If you want to get involved and voice your concerns, here’s the link to leave an email with your comments to Julia Beaty at MAFMC.

http://www.mafmc.org/comments/sfsbsb...tion-amendment

Your voice needs to be heard or this fight is over.

[Gerry Zagorski]

Keep at it Tom!!

[Brewlugger]

Comment sent. Thanks Tom.

[dales529]

Great analysis again Tom! Sheds some much needed light into the recreational landings which we all have known for a long time have been skewed against us. We all need someone like you to get to the bottom of it.

If i can be of any more help let me know.

I know how much work you have put into all this and also know how underappreciated it seems but please keep it up.