Opportunities for Public Comment

[Broad Bill]

Originally Posted by Gerry Zagorski

Agreed on MRIP and even those on the inside know it's flawed but it falls under the umbrella of "best available science". This is reason reason why we need options that give more weight to stock assessments until we have a more reliable way of measuring recreational catches...

For those of you who are new to this, MRIP is the Marine Recreational Information Program and it's basically an attempt to quantify recreational catch based on surveys either emailed or done in person when you get back into the dock. Since they cant possibly survey everyone, some assumptions are applied to a limited amount survey data to estimate the total catch. What could possibly go wrong here

Commercial catch is a lot easier to measure since their catches are weighed and there are observes and other checks and balances to insure the integrity of what's being submitted... It's not perfect either but suffices to say, it's more accurate then MRIP.

Gerry interesting post. All the data being used by NMFS, not just MRIP for recreational catch statistics, to make critical decisions in fisheries management is covered by "Best Available Science" which is nothing more than an excuse for management to hide behind which allows them to say we have no idea what the correct information is so all we can do is work with the information we have which by the way we have no idea if it's remotely accurate or not. Example, recreational catch they've already admitted is flawed by as much as 40% which means it's probably flawed by 80%. They have no idea how to quantify recruitment, direct comment from an ASMFC Member. 25% natural mortality assumption meaning 25% of the population dies every year from natural causes as opposed to fishing related causes. How is that statistic possibly arrived out as it's completely unquantifiable. Recreational discard mortality, they have no idea what that percentage really is and there isn't a way to determine it within a safe margin of error. Weight discrepancies between commercial and recreational sectors which is the entire foundation of quotas and catch / harvest statistics. Same age class fish are assigned up to 50% - 60% different weights between sectors when weights are added up annually. How can a 3 year old fish caught commercially weigh 50% - 60% less than the same fish if caught recreationally. Making matters worse, the value are more disparate between everyone else, recreational and commercial, and North Carolina which has their own assigned values which are more out of line even though 100% of their catch comes from our waters as they work the last remaining biomass. Makes no sense whatsoever. Maybe it did when there was a southern biomass which has since been destroyed by NC and Virginia but those days are long gone. Time to update the tables. The impacts of this alone on quotas and annual harvest statistics is ENORMOUS. I've pointed this out to NMFS, ASMFC and MAFMC, they've not commented on it and choose to ignore it. I asked Kiley Dancy that question on a public call and she wasn't even aware the discrepancy existed. Annual weights if you take number of fish landed times assigned weight values for the recreational sector don't add up every year meaning the recreational sector harvest numbers are significantly overstated every year. It's not peer review, science, statistical analysis.....it's basic multiplication, it's wrong and it skews the allocation of the resource between sectors in favor of the commercial sector and at the expense of the recreational sector. Again brought to the attention of the above agencies, ignored by the same and never replied to.

Gerry yes commercial catch is easier to calculate as fish are weighed in but doesn't account for two major issues. Illicit netting which occurs repeatedly and discard percentages between federal observers and percentages reported by commercial operators on vessel trip reports. The difference are staggering for the later and there's statistics published by NMFS in prior stock assessments which illustrate it. Statistics showing glaring differences which was removed from subsequent stock assessments for obvious reasons. A majority of commercial catch occurs in the winter and these guys aren't running 50-60 miles offshore and taking smaller less valuable fish back to market. Between length of trawls, water depth being fished, air temperatures and the time fish being discarded lay on the deck as retained fish are iced and packed away, discard mortality of fish released during the winter months is probably 100% and discard rates to harvest rates I'd bet approach 100%. Commercials target the older age classes, almost predominantly females, and kill the younger age classes in the process. I'd bet anyone on the site all those shorts last year people discussed reflecting hope going forward, you won't see them as keepers next year as they're lobster food at the bottom of the ocean 50 - 60 miles offshore. It's a HUGE problem in this fishery. The NMFS should institute a keep what you catch commercial mandate for three years and put an end to commercial discard mortality. Market values through normal price and demand dynamics will adjust and catch values should be protected without killing and wasting tens of millions of fish annually of this precious resource.

Millions was spent developing MRIP, the people involved had there celebrations, pats on the back, high fives and it's a complete failure. A set of assumptions applied to another set of assumptions applied to another set of assumptions. No one will ever be able to quantify recreational catch which can't be quantified so why are we walking into the same wall every year and basing fisheries management on data which can't be validated. It's like trying to catch air, not possible. Efforts to do so are wasted efforts involving millions of dollars of wasted tax payer's money.

The fishery should be managed based on as you mentioned stock assessments and I'll add which I always do, protecting the spawning stock and the spawn. Contract out commercial operators who are on the water every day and know how to trawl to conduct assessments under the supervision of NMFS. From those assessments, we know the proportionate female population of the stock has declined significantly due to asinine regulations. Stop targeting larger age classes and close the fishery as most others are during the spawn for 3-5 years and concentrate on bolstering recruitment which is the lifeline of every salt water fishery. Don't change commercial quotas, reallocate them to months outside the stock's spawn between mid September to mid November. Ever since there's been a build up of the winter fishery in the late 90's and turn of the century targeting larger age classes, recruitment has tanked yet the powers to be sit on there ass and have the balls to say they have no idea why. A child could figure it out.

Option A,B,C,D or F, who really cares as none of them address managing the stock. If one of the options buys time and helps small business operate under draconian and senseless regulations, that's the option we should choose but none of these option address stock management which is the underlying problem killing this fishery.