Action Needed Fluke Sea Bass and Scup

[Gerry Zagorski]

Originally Posted by dakota560

Gerry just tried sending in the letter from my mobile device but never received the email code to complete the filing. Will try later today once I'm home.

I have a question so I understand the process. A few years ago New York sued to have their share of the commercial quota increased. The lawsuit was filed against the Secretary of Commerce, NOAA and NMFS, collectively Marine Fisheries. An allocation within the commercial sector as opposed to an allocation here between sectors. But an allocation nonetheless. ASMFC and MAFMC weren't at all named in the lawsuit.

At the same time when I had numerous email exchanges with ASMFC and MAFMC Members a few years ago, I was told numerous times they don't set the policies, their handed down from National Marine Fisheries and their hands are essentially tied. In essence state versus the Federal Government since I believe both ASMFC and MAFMC are state chartered institutions. States could and do recommend Conservation Equivalency measures but it sounded like everything else was a Federal mandate.

These letters addressing changes to the allocation are being directed at the state level, my question is do the states have the authority to make that change or is this an MSA mandate with the ultimate authority in the hands of Washington?

Hey Tom - The overall % splits by species between commercial and recreational are a joint decision between the state and federal managers. So, yes we do need address our concerns to both and the form does that.

After going to the site and choosing NJ and filling out the form, I got a confirmation back letting me know that my comments were sent to:
- Assemblyman Eric Houghtaling - NJ State
- Commissioner Fote - NJ State
- Member Nowalsky - Both NJ State and Federal
- Member Hughes- Federal
- Commissioner Cimino - Both NJ State and Federal

Back to my question about who is ultimately responsible for sector allocations in the summer flounder fishery or all fisheries for that matter. The attached files reflect a portion of the NY lawsuit I referred to. First file is who the suit was filed against which is Marine Fisheries or Washington, Federal in other words. Second attachment discuss the basis for the suit. New York wanted a higher percentage allocation of the commercial quota since the current allocation no different than the sector allocation is completely outdated. The point here isn't the law suit, the point is who the suit was filed against which presumably addresses the party with the authority of making those allocation decisions, in this case the Federal Government or Marine Fisheries. There's more pages obviously to the basis of the suit but based on the second attachment, you get the point. That being the allocation methodology is outdated, no different then the sector allocation being significantly outdated with the inception of using New MRIP to quantify recreational landings and catch.

Again with that said, is the outdated 60/40 split a decision made by a Committee involved in the fisheries management process or is it an allocation based on legal precedent. Legislation in other words. And who makes that determination, is it Martine Fisheries (Washington), ASMFC and or MAFMC (state charter) or someone behind door number three.

Fisheries management is a very complex structure which would rival the institutions and agencies that manage the health care industry. I believe it's extremely important to know two things. First who has the ultimate authority to make the sector allocation this thread addresses and second why wasn't the allocation changed immediately when New MRIP statistics were introduced because based on your email and my calculations four years ago, the recreational sector would have received an approximate 50% increase in allocation and therefore quota by going from 40% to closer to 60% for 2018, 2019, 2020, 2021 and possibly dependent on next week's meeting results 2022. The public deserves to know whose hands that decision rests in and why the decision wasn't made concurrent with the use of New MRIP statistics.

Since you have inroads to RFA and obviously are working with ASA, I'm sure you have the answer to those questions so I for one would appreciate an answer to further my understanding of the fisheries management process.

Gerry I got the same email....thanks!

When you say the sector allocation is a joint decision by the state and feds, what state agencies are we talking about? Since the letters are being sent to the Commission and Council, are they the state agencies you're referring to. If not, specifically which agencies are involved?

[tjd24]

DONE

[Gerry Zagorski]

Tom - Yes it's confusing it's a % on top of % game

As far as the NY law suit, NY was fighting not to change the coast wide % for recs vs com %. That was already decided by a larger group including all the states and feds and that's what we're fighting for now, a higher % to recs.

What NY was arguing for was a higher % of the total com % to get passed down to them.

Not going to debate, go sideways or answer any more questions here since our most important mission right now is to get the overall % of coast wide is to try and get more % to recs.

Tom - Yes it's confusing it's a % on top of % game

Gerry not really sure what that means.

As far as the NY law suit, NY was fighting not to change the coast wide % for recs vs com %. That was already decided by a larger group including all the states and feds and that's what we're fighting for now, a higher % to recs.

What NY was arguing for was a higher % of the total com % to get passed down to them.

That's exactly what I said in my earlier post

Not going to debate, go sideways or answer any more questions here since our most important mission right now is to get the overall % of coast wide is to try and get more % to recs.

Didn't realize we were debating.

I asked a simple question where in the process is the sector allocation made and who is responsible for making it? Why would you ever consider that a debate?

I thought productive exchanges were welcomed on the site. You're asking people to sign a letter being sent to ASMFC and MAFMC. My question was simply are they the governing bodies responsible for changing the allocation in this process. I assume the answer is yes but wanted your confirmation so I and others understand. You posted the thread asking for signatures and support, assume it would be in your best interest if everyone knew what they were signing and how the process worked

My other observation is if they are the agencies responsible for changing the allocation percentages between sectors based on New MRIP back in 2018, why has it taken 4 - 5 years to make the allocation change since it's had significant impacts to the recreational sector, the fishery as a whole and consequentially the commercial sector. They seem like benign and fair questions to ask, unfortunate you don't seem to agree.

[Togfather2530]

I know this goes against the goals of recreational fishing enthusiasts but as I read this post it got me thinking. I know my freezer is full and I’m always giving fish away since I usually go once a week or every other at least. I don’t really see that we really need to keep more fish recreationally. The way I see it that will just increase the cost of fish at the supermarket for everyone which is already expensive. We are fishing recreationally and they are fishing commercially to make a living and feed people. From an environmental standpoint a commercial boat has much less environmental impact than 1 million recreational boats running around the ocean to get the job done. As much as the regs are stiffer than the free-for-all it was back in the day, an avid fisherman still has plenty of fish to eat and if they are any good of a fisherman they can’t even eat them all. Just another view point that’s all, I guess I’m looking at what’s best for everyone not just the recreational fisherman.

[hammer4reel]

Originally Posted by Togfather2530

I know this goes against the goals of recreational fishing enthusiasts but as I read this post it got me thinking. I know my freezer is full and I’m always giving fish away since I usually go once a week or every other at least. I don’t really see that we really need to keep more fish recreationally. The way I see it that will just increase the cost of fish at the supermarket for everyone which is already expensive. We are fishing recreationally and they are fishing commercially to make a living and feed people. From an environmental standpoint a commercial boat has much less environmental impact than 1 million recreational boats running around the ocean to get the job done. As much as the regs are stiffer than the free-for-all it was back in the day, an avid fisherman still has plenty of fish to eat and if they are any good of a fisherman they can’t even eat them all. Just another view point that’s all, I guess I’m looking at what’s best for everyone not just the recreational fisherman.

I feel totally opposite of that .
Recreational fishery brings in billions of dollars of revenue for these fisheries .
Every state has its gems .
You don’t see Colorado or Idaho commercially sending you elk to eat . The Dakota their pheasants.
Our gem here is the salt water fishery, we shouldn’t have to feed the world , if they want to eat it they should have to come here to catch it.

Allowing just a few boats to harvest and earn a living selling all the fish from the ocean instead of millions of anglers just doesn’t cut it


.

[Gerry Zagorski]

Originally Posted by dakota560

Gerry not really sure what that means.

That's exactly what I said in my earlier post

Didn't realize we were debating.

I asked a simple question where in the process is the sector allocation made and who is responsible for making it? Why would you ever consider that a debate?

I thought productive exchanges were welcomed on the site. You're asking people to sign a letter being sent to ASMFC and MAFMC. My question was simply are they the governing bodies responsible for changing the allocation in this process. I assume the answer is yes but wanted your confirmation so I and others understand. You posted the thread asking for signatures and support, assume it would be in your best interest if everyone knew what they were signing and how the process worked

My other observation is if they are the agencies responsible for changing the allocation percentages between sectors based on New MRIP back in 2018, why has it taken 4 - 5 years to make the allocation change since it's had significant impacts to the recreational sector, the fishery as a whole and consequentially the commercial sector. They seem like benign and fair questions to ask, unfortunate you don't seem to agree.

Tom - I don't know the answer to your question as to why it's taken 4 or 5 years. What I do know is we have an opportunity right now to get more favorable percentages allocated to the recreational sector. That in it self makes total sense to me and I'd like to stay focused on that task.

Originally Posted by Togfather2530

I know this goes against the goals of recreational fishing enthusiasts but as I read this post it got me thinking. I know my freezer is full and I’m always giving fish away since I usually go once a week or every other at least. I don’t really see that we really need to keep more fish recreationally. The way I see it that will just increase the cost of fish at the supermarket for everyone which is already expensive. We are fishing recreationally and they are fishing commercially to make a living and feed people. From an environmental standpoint a commercial boat has much less environmental impact than 1 million recreational boats running around the ocean to get the job done. As much as the regs are stiffer than the free-for-all it was back in the day, an avid fisherman still has plenty of fish to eat and if they are any good of a fisherman they can’t even eat them all. Just another view point that’s all, I guess I’m looking at what’s best for everyone not just the recreational fisherman.

I'll keep saying it until people understand. Today's problems with the fishery isn't a catch problem, it's a catch composition problem driven by inflated recreational size minimums and quota cuts in both the recreational and commercial sector. The allocation Gerry posted about is important for one reason, but not what most people think. It has to happen in order for the recovery plan to work. Can't post right now but will later today. I suggested it to the Commission and Council two years ago and what I got in return was a bunch of theoretical jargon.

Togfather, as it relates to the recreational sector and your comments, right or wrong, Marine Fisheries data indicates 82% or 7 million recreational trips in 2018 ended up with zero keepers, 13% ended up with one keeper. That's a problem. In excess of 4 million less trips between 2011 and 2019, that's a huge social and economic problem to the recreational community and shore based communities and small businesses.

Commercial has an 80% assumed mortality rate for discards, recreational is 10%. Factor that into your thought process. Natural mortality takes 25% of the population every year, why are we waiting to harvest older age classes who've already lost 60 - 80% of their class to natural mortality. To put that in perspective, in 2017 the biomass population was estimated at 121 million. So it's assumed we'll lose 30 million fish in 2018 from natural mortality. Wouldn't it make sense to harvest them at younger age classes as in the nineties before being lost to predation? And in the process, wouldn't it make more sense harvesting a 15.5" male as opposed to a 20" female. It's not one fish for one fish. It's one immature male versus a significant mature breeder which can drop 3 million eggs a year.

We've been engrained to think only about catch because that's all management talks about. It's all we think about, what's our quota? Between 2004 and 2017 landing weights have declined by almost 60% and the stock is declining at a record rate. It's failing. We need to stop talking about weight and talking about size, gender and recruitment strength.