hartattack
Angler
As promised here is the letter sent this week. It was presented with a detailed document that I can email to folks by request. Using the very data that the Agencies have published thru the years it is evident that the Regs have clobbered the Fluke Fishery. This analysis examines historical trends and changes to the regulations which illustrate that the Regulators are ignoring the trends that the data shows. Between years 1990 and 2000 the stock experienced its best growth by harvesting younger age classes; since then the Regs have forced folks to harvest bigger, older fish - primarily female breeders. The stock continues to decline significantly even with significant quota cuts. The letter below comes from a NJ recreational fisherman who cares. . . . .
November 30, 2021
The Honorable Gina Raimondo Secretary of the United States Department of Commerce US Department of Commerce
1401 Constitution Avenue NW
Washington, DC 20230
Dear Secretary Raimondo,
I’m sending this correspondence to draw your attention to the current health or lack thereof with the Summer Flounder stock, concern by many regarding its decade long decline of 72 million fish or 37% of its population between 2010 and 2017 while requesting your intervention into the management decisions being made of this vitally important fishery to the coastal states making up the Mid-Atlantic and New England Regions. A fishery, which in the nineties through the first decade of 2000, under a very different set of regulations, experienced its most prolific growth over the last fifty years. Growth which saw the stock increase in population from 62 million to 194 million, the spawning stock increase from ~7,000 metric tons to ~68,000 metric tons or a 900% increase while annual recruitment as would be expected on average rose to its highest levels in the last five decades. An amazing success story for fisheries management, commercial and recreational sectors, businesses and shore community’s dependent on the health of the fishery and of course the stock itself.
Unfortunately, the historic growth of the nineties and early 2000 gave way to substantial declines in the stock over this past decade after the stock was officially declared rebuilt in 2010. Declines as marine fisheries own data substantiates, caused by the use of recreational size minimums increased too high causing a number of unintended changes and consequences to the stock. Changes causing an imbalance in the gender composition of annual harvest, a change in harvest composition which caused a significant change in the gender composition of the biomass, an overall decline in the spawning stock all resulting in a substantial decline in annual recruitment which the fishery can’t support even at greatly reduced catch levels. The fishery is and has been in a downward cycle over the last decade and without changes to the current regulations that trend will continue. Shore communities and business dependent on the health of this fishery will continue experiencing extreme socio-economic consequences. As shown on page 32 of the comprehensive analysis, the recreational sector alone reported 4.5 million less directed angler trips in 2019 than 2011 around the time recreational size minimums reached their highest levels. In 2018, of the 8.6 million directed recreational angler trips reported, 7 million or 82% resulted in zero fish harvested. Recreational anglers won’t continue spending hard earned money for the cost of a day’s fishing with family or friends only to come home and order take out. Especially in today’s trying times with the financial impacts the Covid-19 Pandemic has caused the average consumer.
Using 13 million trips as the baseline from 2011, over the period 2012 to 2019 there’s been 23 million less angler trips over that 8-year period costing the recreational sector, shore communities and associated businesses conservatively $4.6 billion in revenues as onerous and ineffective regulation continue to cause severe economic and social consequences while threatening a legacy fishery long associated as a cornerstone activity of shore communities of the Mid-Atlantic and New England Regions. We’re risking even greater consequences to the fishing industry and these same communities if the manner in which this stock is being managed prospectively doesn’t change.
A once thriving fishery driven by effective regulations promoted the harvest of the younger age class fish while allowing older age classes to perpetuate the future of the stock. Twenty-years of sacrifices later, we employ regulations promoting the harvest of older age groups making up the spawning stock with an emphasis on large female breeders and the stock as one would expect is experiencing some it’s sharpest declines since crashing in the late eighties. The eighties crash was caused by over harvest of the resource, today’s declines are caused by the harvest of the wrong age classes, older age classes, within the stock the direct result of regulations over the past decade and a half. A different set of challenges threatening the future viability of the stock. For comparison sake, the below table illustrates key metrics of the fishery between the decade of the nineties when the stock experienced its most prolific growth and this past decade through 2017 when the stock reversed course experiencing its most substantial declines since the eighties.
Unprecedented growth between 1990 and 2000 represents improvements over a 10-year period of time. Conversely, declines in the stock between 2010 and 2017 represent steep reductions over a shorter 7-year period. The rate of decline over a considerably shorter period of years in addition to the magnitude of those declines needs to be a major cause of concern and point of focus for everyone involved in the governance of the fishery. These trends reflect a major shift in the stock and in this case the data clearly shows a direct and inverse relationship between increased size minimums used to constrain recreational harvest to the reduction of the spawning stock and mature female population leading to historically low recruitment classes over this past decade which in turn lead to sharp declines in the biomass population. We took a very well balanced fishery between sectors and gender composition of the population in the nineties, changed the regulation to focus both sectors on the harvest of older age classes with historically high discard rates completely disrupting that balance.
As a point of reference, note the 14” and 18.35” recreational size minimums between periods which represents the average of size minimums for the four states mentioned above calculated on a weighted average basis based on each state’s representative share of the recreational quota. The four states combined represent approximately 85% of the annual recreational quota and therefore are a true representation of the size minimums governing a majority of recreational harvest. Remember these are size minimums, fish actually harvested will be larger. Between periods, the nineties had four years with size minimums as low as 13” between 1990 and 1993. Between 2009 and 2011, the average size minimums increased for these four states to 19.38, ranging between 18” for NJ and a high of 20.5” - 21” for NY and RI. At those size minimums based on science’s length and gender data from trawl studies and Rutgers 2016 Sex and Length Study, a high percentage pf fish harvested are females and fish comprising the spawning stock of the fishery. That time frame, as the below graphs illustrate, is when the fortune of the fishery deteriorated resulting in a decade of significant declines. Declines resulting in a 137 million decline in the change of the overall population between two periods 10 to 15 years apart, a 50,000 metric ton net decline in the change of the spawning stock population, a 61 million swing in the change of the population of mature female breeders accompanied not surprisingly by crushing declines in yearly recruitment statistics. The fishery is in the process of failing, there’s no other way to view or interpret the data.
. . . . Continued on post #2 of Dept of Commerce Letter
November 30, 2021
The Honorable Gina Raimondo Secretary of the United States Department of Commerce US Department of Commerce
1401 Constitution Avenue NW
Washington, DC 20230
Dear Secretary Raimondo,
I’m sending this correspondence to draw your attention to the current health or lack thereof with the Summer Flounder stock, concern by many regarding its decade long decline of 72 million fish or 37% of its population between 2010 and 2017 while requesting your intervention into the management decisions being made of this vitally important fishery to the coastal states making up the Mid-Atlantic and New England Regions. A fishery, which in the nineties through the first decade of 2000, under a very different set of regulations, experienced its most prolific growth over the last fifty years. Growth which saw the stock increase in population from 62 million to 194 million, the spawning stock increase from ~7,000 metric tons to ~68,000 metric tons or a 900% increase while annual recruitment as would be expected on average rose to its highest levels in the last five decades. An amazing success story for fisheries management, commercial and recreational sectors, businesses and shore community’s dependent on the health of the fishery and of course the stock itself.
Unfortunately, the historic growth of the nineties and early 2000 gave way to substantial declines in the stock over this past decade after the stock was officially declared rebuilt in 2010. Declines as marine fisheries own data substantiates, caused by the use of recreational size minimums increased too high causing a number of unintended changes and consequences to the stock. Changes causing an imbalance in the gender composition of annual harvest, a change in harvest composition which caused a significant change in the gender composition of the biomass, an overall decline in the spawning stock all resulting in a substantial decline in annual recruitment which the fishery can’t support even at greatly reduced catch levels. The fishery is and has been in a downward cycle over the last decade and without changes to the current regulations that trend will continue. Shore communities and business dependent on the health of this fishery will continue experiencing extreme socio-economic consequences. As shown on page 32 of the comprehensive analysis, the recreational sector alone reported 4.5 million less directed angler trips in 2019 than 2011 around the time recreational size minimums reached their highest levels. In 2018, of the 8.6 million directed recreational angler trips reported, 7 million or 82% resulted in zero fish harvested. Recreational anglers won’t continue spending hard earned money for the cost of a day’s fishing with family or friends only to come home and order take out. Especially in today’s trying times with the financial impacts the Covid-19 Pandemic has caused the average consumer.
Using 13 million trips as the baseline from 2011, over the period 2012 to 2019 there’s been 23 million less angler trips over that 8-year period costing the recreational sector, shore communities and associated businesses conservatively $4.6 billion in revenues as onerous and ineffective regulation continue to cause severe economic and social consequences while threatening a legacy fishery long associated as a cornerstone activity of shore communities of the Mid-Atlantic and New England Regions. We’re risking even greater consequences to the fishing industry and these same communities if the manner in which this stock is being managed prospectively doesn’t change.
A once thriving fishery driven by effective regulations promoted the harvest of the younger age class fish while allowing older age classes to perpetuate the future of the stock. Twenty-years of sacrifices later, we employ regulations promoting the harvest of older age groups making up the spawning stock with an emphasis on large female breeders and the stock as one would expect is experiencing some it’s sharpest declines since crashing in the late eighties. The eighties crash was caused by over harvest of the resource, today’s declines are caused by the harvest of the wrong age classes, older age classes, within the stock the direct result of regulations over the past decade and a half. A different set of challenges threatening the future viability of the stock. For comparison sake, the below table illustrates key metrics of the fishery between the decade of the nineties when the stock experienced its most prolific growth and this past decade through 2017 when the stock reversed course experiencing its most substantial declines since the eighties.
Unprecedented growth between 1990 and 2000 represents improvements over a 10-year period of time. Conversely, declines in the stock between 2010 and 2017 represent steep reductions over a shorter 7-year period. The rate of decline over a considerably shorter period of years in addition to the magnitude of those declines needs to be a major cause of concern and point of focus for everyone involved in the governance of the fishery. These trends reflect a major shift in the stock and in this case the data clearly shows a direct and inverse relationship between increased size minimums used to constrain recreational harvest to the reduction of the spawning stock and mature female population leading to historically low recruitment classes over this past decade which in turn lead to sharp declines in the biomass population. We took a very well balanced fishery between sectors and gender composition of the population in the nineties, changed the regulation to focus both sectors on the harvest of older age classes with historically high discard rates completely disrupting that balance.
As a point of reference, note the 14” and 18.35” recreational size minimums between periods which represents the average of size minimums for the four states mentioned above calculated on a weighted average basis based on each state’s representative share of the recreational quota. The four states combined represent approximately 85% of the annual recreational quota and therefore are a true representation of the size minimums governing a majority of recreational harvest. Remember these are size minimums, fish actually harvested will be larger. Between periods, the nineties had four years with size minimums as low as 13” between 1990 and 1993. Between 2009 and 2011, the average size minimums increased for these four states to 19.38, ranging between 18” for NJ and a high of 20.5” - 21” for NY and RI. At those size minimums based on science’s length and gender data from trawl studies and Rutgers 2016 Sex and Length Study, a high percentage pf fish harvested are females and fish comprising the spawning stock of the fishery. That time frame, as the below graphs illustrate, is when the fortune of the fishery deteriorated resulting in a decade of significant declines. Declines resulting in a 137 million decline in the change of the overall population between two periods 10 to 15 years apart, a 50,000 metric ton net decline in the change of the spawning stock population, a 61 million swing in the change of the population of mature female breeders accompanied not surprisingly by crushing declines in yearly recruitment statistics. The fishery is in the process of failing, there’s no other way to view or interpret the data.
. . . . Continued on post #2 of Dept of Commerce Letter
