2024 Fluke Regs

[Broad Bill]

First I completely agree with everything on Hammers post. And there's still so much more seriously broken with how sector quotas are set and how the fishery in general is being managed but I won't bore you with those details even though they're substantial. And I'd guarantee, after extensive research, almost no one knows how these statistics are put together to arrive at annual regulations. That's how NMFS, ASMFC and MAMFC want it so the basis of their misguided decisions never see the light of day.

I want to add a few key points to what Hammer said and comment briefly on Dclark2's question about 18" fish. Remember we once had a successful management formula and effective regulations for this fishery which promoted historical growth in the 90's. The stock went from an estimated 78 million population in 1988 at a 13.5" size limit to 183 million population in 2004 before the recreational size minimum started being increased by NMFS with yearly increases raising the then 15" - 15 1/2" size limit in 2001 to an average of 18" to 19" coastal wide today. 105 million fish were added to the stock population in 16 years, if we retained those regulations the stock based on analytics would exceed 300 million fish today and both the commercial and recreational sector would be benefitting from that growth and the stock would be the healthiest its ever been. Why did we switch? Some have an opinion, here's mine. Larger fish, older age classes, bring materially higher market values to commercial operators and NMFS's primary goal for the commercial sector, as stated, is to protect and increase commercial catch values.

What's the easiest way to accomplish that? Increase recreational size minimums so that a substantial portion of the entire summer flounder biomass is now only harvestable by commercial operators by pushing access to and the harvest of those classes from the recreational sector to the commercial sector. Classes which would accomplish NMFS's goal of increasing catch values to the commercial sector. That's entirely what this has been all about for the last 25 years. Adding insult to injury, commercial operators maintained their right to harvest fish at 14" minimums which obviously recreational anglers can't so they have the best of both worlds and since they don't want 14" fish as that's not where the money is they simply get thrown back dead. That's where this fisheries problems began.

Second problem this change of philosophy transformed the fishery from the practice of harvesting younger age classes, protecting the spawning stock and letting the breeders insure the future of the stock to harvesting all sexually mature fish, killing God only knows how many sexually immature juvenile age fish in the process. Fish which represent the future of this and any stock. Short term greed at the expense of long term sustainability of the resource. A management philosophy which will never work providing us the dire regulations we've had forced down our throats for years along with another fishery struggling to survive.

Dclark2, to answer your question, now that the average size minimum of all states is in the area of 18 to 18 1/2", if you do your own research or clean your own fish you'll realize that 100% of fish over 18" are sexually mature fish. And over 95% of fish over 18" are female, compounding the problem, and one reason we've been seeing lower recruitment numbers for decades. NMFS's own data says so as does other independent studies conducted on the fishery.

If you look at male / female size to age class tables, an 18" fish on average is a 6-year old male since they grow slower and don't grow as large as females or a 4-year old female. Now factor in, which most people don't realize, the 25% per year natural mortality rate assumed in this and most fisheries. Think through what that means, it's significant. Year 1, for every 100 fish, the assumption is 25% are lost to just natural mortality, sickness, predation etc., which would bring every new recruitment class from 100 to 75 after the first year. After year two that same class goes to 56. Year three that class, just based on natural mortality, goes to 42 and by year 4 the population of that age class is now 31 fish. After year five, the population loses another 25% or approximately 8 fish and drops to 23 and after year 6 you lose another 6 fish and the age classes population drops to 17 fish. So by increasing size minimums for recreational anglers, NMFS has not only allowed but guaranteed 70% to 85% of every recruitment class will succumb to natural mortality alone, before factoring in the impacts of fish related mortality, before the recreational sector can harvest those classes. Assuming those statistics are remotely accurate, it's amazing there's any 18" fish left for the recreational sector to harvest. This is a very questionable, dangerous and proven failed approach to managing this stock. It's actually counter-intuitive to how most stocks are managed. NMFS and North East Fisheries Science Center "NEFSC" need to seriously rethink their approach to managing the summer flounder fishery. Their argument is current regulations are the best means of managing catch in the recreational sector and gives age classes more years to spawn. The reality is those fish, which we release all season long, get annihilated by commercial netters during their spawn and migration in the fall to their offshore wintering grounds and for the fish that survive the gauntlet of nets, no one managing this fisheries has any idea what impact dragging nets through spawning fish has on the efficacy of the spawn which could be causing massive impacts to annual recruitment. These fish are so stressed out someone at least needs to explore the implications of dragging during the spawn. Why do so many other fisheries have closed seasons during the stocks spawn but with this fishery management refuses to address that issue. Because the fish are still in shore and the powers to be want the commercial sector to have access to them without having to travel 50 to 70 miles offshore two months later and they want the commercial sector to have a 12-month year-round fishery to promote catch values which everyone else pays the price for. As I've stated before, short sided management decisions not for the benefit of the stock itself will only lead to long term problems and that's what we're dealing with here.

Until, if ever, we change this thought process, the management of this fishery will never change and the results we've been seeing over the last two to three decades will follow suit and continue in a downward spiral. Revert back to harvesting younger age classes before natural mortality kills 70% - 85% of those classes, stop targeting the harvest of exclusively sexually mature fish, let the large breeders insure the future of the stock and protect the yearly spawn from the current onslaught by the commercial sector. The population will increase exponentially, landings will follow suit, we'll substantially reduce the harvest of sexually mature fish, reduce discard mortality rates and recruitment will sky rocket higher. Change the regulations to promote the harvest of younger age classes before losing those classes to natural mortality, stop all commercial netting in September and October and this fishery within three years will explode to levels never before seen.