Opportunities for Public Comment

[pddmd]

Just wanted to let people know that there are 2 very important issues right now that have public comment deadlines approaching
1) The ASMFC is asking for comments concerning their Setting Recreational Measures addendum. The way they manage recreational fisheries now has a sunset provision of 12/25. If no action is taken, ASMFC will revert back to the way they managed prior to 2022. Attatched is a youtube link that ASMFC produced to describe the options. Adam Nowalsky is very deeply involved in this and is a proponent of option C. Deadline for public comment is 2/15/25
https://youtu.be/37qmtbxlw74
https://asmfc.org/files/PublicInput/...nt_Dec2024.pdf

2)NJDEP is putting forward a proposal that would grant them more power concerning public access to our shore. This would give DEP the authority to restrict/prohibit access to areas considered as critical habitat not only to endangered species, but also to threatened or possibly threatened species. Several of the areas included not just shoreline access, but up to 300yds into the water. The Non Game and Endangered Species Council worked wit DEP on this, but refused to include the Marine Fisheries Council in a stakeholder meeting
Below find the document and the instructions on how to comment
Deadline 2/13/25
https://dep.nj.gov/njfw/wildlife/reg...otection-rule/

[AndyS]

Thanx ! Several of the areas included not just shoreline access, but up to 300yds into the water. How can they enforce this with 127 miles of coastline ?

[Gerry Zagorski]

Thanks for posting this Pat... A lot of information in the links and videos some of which I'm sure other simple minded people like me don't fully understand.

Off the top of my head, any of the proposed fishery management options is better then reverting back to the the old way of doing it since they did not seem to help the fish or the fishermen... It would however be great to get more information on why Adam thinks C is the better option. Comments due by 2/15 to comments@ASMFC.org

As far as the NJDEP expanding their authority to further restrict public access to sensitive areas for endangered wild life like birds and turtles. I get that but seems to me we here in NJ are already crippled by lack of public access for both fishing and recreational activities so not sure I would support that unless the public had some input on the areas that would be considered. Comments due by 2/13 can be submitted here https://dep.nj.gov/rules/rule-comment-form/

[Gerry Zagorski]

A bit more clarification on why option C is being supported by NJDEP, the NJ Marine Fisheries Council and our state representatives in the ASMFC. There's a lot more involved but these are the cliff notes and my basic understanding after talking to Dr Pat (pddmd in this thread) who is on our states Marine Fisheries Council.

As mentioned above, reverting back to the old option is not a good choice because it wasn't doing anything for the fish or the fishermen. It also caused sea saw regulations that were subject to change ever year and there was hardly any weight given to stock assessment data. It also condensed the time line for information to be digested, public comments and decisions to be made. Other options like C allows us to put in place a 2 year plan so we don't have sea saw regulations from year to year and it takes into account stock assessments which is a much better measurement of the health of a fishery. The old system which if we were to do nothing, would be put back in place and in general was more focused on quotas vs assumed catch data like MRIP if we were assumed to catch more then our quota we'd be penalized in the following years regulations. We all know the MRIP data can not be trusted and the health of a fishery is better measured by the stock status.

Where C differs from the rest of the plans is it would allow more liberalization and relaxed regulations for fisheries that have been rebuilt. Perfect example here is Sea Bass which has exceeded the rebuild target for several years now but the regulations have not been relaxed.

Options D and E have some nuclear options that would allow fishery management to take more unilateral emergency actions like closing down fisheries completely... Further they are based on Catch rather then Harvest like AB and C.. Catch means any fish legal size or not that are landed are measured, Harvest means the only fish retained are measured and I assume some mortality rates applied for released fish... The fear with a catch based system is you may loose the flexibility to trade longer seasons for larger legal fish or visa versa, which gives the states more flexibility.

I'd be interested in other opinions but those are the state and council recommendations and Dr Pat said he'd be monitoring this thread if anyone needs more clarification or had questions.

[hammer4reel]

How about they actually get a format to get a better accounting of what’s actually going on with the fisheries .

MRIP data has been found to be totally unreliable .
Using bad info in any of the management plans isn’t going to help any of the fisheries .

Bad management of our fisheries has caused a huge demise of MANY valuable resources.

Until better methods of actual accounting is done it’s all BULLSHIT .


.

[Gerry Zagorski]

Originally Posted by hammer4reel

How about they actually get a format to get a better accounting of what’s actually going on with the fisheries .

MRIP data has been found to be totally unreliable .
Using bad info in any of the management plans isn’t going to help any of the fisheries .

Bad management of our fisheries has caused a huge demise of MANY valuable resources.

Until better methods of actual accounting is done it’s all BULLSHIT .


.

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 what we recreationals 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.

[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.

[hammer4reel]

Originally Posted by Broad Bill

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 ice 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. Every 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.

To add to that , why even have tight limits here in Nj including the local commercial harvest .
When boats from NC can come into the same waters and take 30000 pounds a week .
Where local boats are allowed 1500 pounds .

7 day boats are absolutely crushing the stocks from NC to Massachusetts taking their landings back there .
Just because the major cutting houses are there .

A state should not be allowed to rape all the other states resources when they have destroyed theirs .

Anyone who has looked into what’s going on in NC with their fisheries management can see big $ is being made while recs don’t even get to keep a fish for dinner .

Shouldn’t be putting the burden on recs to do the right thing to only see those fish end up in another states landings

.

[pddmd]

In the past, our commercial representatives have fought against a "license to land" in NJ. So a boat from NC can land in NJ if they are following the landing regulations for NJ, without paying a separate fee. That idea may be changing going forward. As other states charge NJ commercial fishermen a landing fee, NJ fishermen are starting to listen to dialogue on reciprocity. That being said, I believe that any fees of that sort would have to come legislatively.

i think we all know that this addendum is not perfect, but this is an opportunity to comment on how the ASMFC will move forward. i believe there are 2 options, scream and yell that this is broken, or try to make at least one part of it less broken.

[Broad Bill]

Pat I'm not necessarily disagreeing or trying to be argumentative but the core problem with the fishery is the decline of the stock due to misguided regulations, the substantial decline of SSB and female gender composition causing a substantial decline in recruitment over the past decade. How does any of this address any of these problems? And let's be realistic, this fishery from NMFS, ASMFC and MAFMC has been given to the commercial sector. What the recreational sector gets is left overs at best. The issues these options address don't at all address the overall health and survival of the stock or the fair allocation of the resource between sectors so really what's the relevance? I know you're the messenger and trying to help so thanks for that effort but these options in my opinion are the equivalent as I've said in past of rearranging the deck chairs on the Titanic.