Post #2 Letter for Summer Flounder, continued

hartattack

Angler
Dec 22, 2018
98
130
33
Central Joisey
In a fishery where females grow significantly larger and live longer than males and larger fish bring a substantially higher wholesale value to the commercial sector, the use of increased size minimums to manage catch comes with a high degree of risks. Mandating a majority of the recreational harvest be filled by mature older age classes comprising the spawning stock, coupled with the commercial sector forced to harvest those same older age classes to mitigate the impacts of 67% cuts in landing weights between 2004 and 2017 has wreaked havoc on this fishery. As stated, increased size minimums eroded the spawning stock, the female population and recruitment levels in the fishery. Associated declines in the overall population further compounded the problem by mandating reduced catch quotas. The balance that existed in this fishery in the nineties when both sectors were harvesting younger age classes and the fishery was thriving has since been replaced by regulations mandating or causing the exclusive harvest of older age classes completely altering the gender composition of the stock while causing extreme amounts of waste in the fishery in the form of historically high discard mortality rates. Between 2009 and 2011 in the recreational sector alone, 165.5 million fish were caught in the process of harvesting 11.5 million fish due to heightened size minimums, a 93% discard ratio. Not sure any stock can survive regulations causing those levels of discards in the fishery. The stock is in a downward spiral it won’t pull out of unless regulations are changed to change catch composition, protect the spawning stock, rebuild the female population, reduce discard mortality rates and protect the spawn to bolster annual recruitment levels.

The below charts, from managements own data, couldn’t be more evident of what’s causing the stock’s declines. When recreational size minimums surpassed 15” to 16”, gender proportions in the stock were completely changed (Sex Ratio narrative on page 60 – 61 of the 66th Stock Assessment reflects that as does the Seasonal Female Proportion Trawl Study results by NEFSC on pages 313 – 317 of the Assessment). The mature female population declined by over 30 million fish in seven short years losing 50% of its population from 2010, the spawning stock declined by 61 million fish or 42% over the same time frame while recruitment revisited levels not seen since the late eighties. We need to introduce a slot fish and gradually work our way Honorable Gina Raimondo November 30, 2021 Page 4 of 6 back to the size minimums in place during the nineties if there’s any hope for this fishery to recover. Regulations focusing purely on increasing recreational size minimums without consideration given to the associated impacts on discard mortality, gender balance, impacts to the spawning stock, the stocks largest and most productive female breeders and ultimately recruitment won’t nurse this fishery back to health and the ramifications of ignoring these impacts will insure continued declines. Declines causing further and significantly more severe socio-economic impacts to the Mid-Atlantic and New England states participating in this fishery as well as industry, businesses and the recreational community dependent on the stock’s health and well-being and ultimate survival. A picture paints a thousand words. Please review the below five graphs, right to left, top to bottom. It summarizes everything wrong with this fishery over the past decade. Recreational size minimums were increased too high causing a substantial decline in SSB removing over 50% of the sexually mature female population sending recruitment levels plummeting causing the stock to lose over 70 million of its population in 7 short years. All caused by the inherent risks associated with the misuse of elevated size minimums in this fishery based on reasons previously stated. Regulations have to change otherwise we’ll lose this fishery and the economic consequences to industry and the Mid-Atlantic and New England States will change from extreme to catastrophic.


Secretary Raimondo, under your oversight, I’m asking for the leadership of NOAA, NMFS, US Senators representing the states participating in this fishery to intervene and work with ASMFC, MAFMC and various state agencies to change the philosophy being employed to manage this stock. For too many years, the problems facing the stock have been largely ignored and actually intensified with management focusing only on reduced catch levels and higher recreational size minimums. Both sectors were actually landing twice today’s current quota in the nineties when the stock was thriving so rule out catch levels as a problem in this fishery. Clearly that approach hasn’t helped the stock, it’s actually made matters worse. This is all about harvesting the wrong age classes and the negative impacts its having on the fishery. Recreational size minimums overall need to be reduced and a slot size introduced immediately for this fishery to start the recovery process and ultimately survive. Eventually, we need to work our way back to the regulations in place in the nineties. They worked to perfection then for 16-years, no reason to believe they won’t be equally as effective today.

The fate of many businesses including party boats and for hire operators, commercial operators, economies of shore based communities, a legacy recreational fishing activity and sadly another fishery all hang in the balance. Many jobs will be lost and families and people hurt when billions in revenue a year continue disappearing due to regulations strangling a fishery which flourished thirty years ago. This is all regulations driven, not environmental as many theorist want people to believe. MSA is a fact based data driven legislation requiring policy and management decisions based on data derived from “Best Available Science”, not speculative theories. The data science has worked diligently to develop is loudly and unequivocally telling us what the problems facing this fishery are and what the causes are. We need to start listening to the trends the data is revealing.

Hopefully your attention and involvment in this matter will invoke changes in the management of this fishery and stave off social and more importantly economic disaster before the train completely leaves the tracks. A comprehensive 36-page document is included based on Marine Fisheries data analyzing historical trends in the stock relative to regulations over the better part of the last four decades in support of all positions, statements and conclusions made in this document. Your intervention in this matter is requested, needed and would be greatly appreciated. Sincerely Submitted,


CC:
National Oceanic and Atmospheric Administration (via mail) National Marine Fisheries Service (via mail) The Honorable Senator Elizabeth Warren – Massachusetts (via mail) The Honorable Senator Edward J. Markey – Massachusetts (via mail) The Honorable Senator Jack Reed – Rhode Island (via mail) The Honorable Senator Sheldon Whitehouse – Rhode Island (via mail) The Honorable Senator Richard Blumenthal – Connecticut (via mail) The Honorable Senator Christopher Murphy – Connecticut (via mail) The Honorable Senator Charles E. Schumer – New York (via mail) The Honorable Senator Kirsten E. Gillibrand – New York (via mail) The Honorable Senator Robert Menendez – New Jersey (via mail) The Honorable Senator Corey A. Booker – New Jersey (via mail) The Honorable Senator Thomas R. Carper – Delaware (via mail) The Honorable Senator Christopher A. Coons – Delaware (via mail) The Honorable Senator Benjamin L. Cardin – Maryland (via mail) The Honorable Senator Chris Van Hollen – Maryland (via mail) The Honorable Senator Mark R. Warner – Virginia (via mail) The Honorable Senator Tim Kaine – Virginia (via mail) The Honorable Senator Richard Burr – North Carolina (via mail) The Honorable Senator Thom Tillis – North Carolina (via mail) ASMFC Summer Flounder Committee Members (via email) MAFMC Summer Flounder Committee Members (via email)
 

george

Administrator
Staff member
Dec 19, 2018
2,760
2,655
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Commack NY
www.nyangler.com
@hartattack Excellent job. One of my close and very knowledgeable friends has been saying this for years. There wasn't a problem until they got involved.

I hope its considered, and I do think it might. I do wish you were representing a group of anglers but in either case you have the facts.
 

Bassmaster

Angler
May 7, 2019
961
779
93
53
I have noticed that very few boats fish for fluke. Mostly half day trips but very few are full day. Most boats go for porgies and sea Bass during the summer months. Only fluke full day boat I know of that goes 7 days a week and full day is miss Montauk. No full day boats in Captree. Not many boats for fluke On a full day basis.
 

hartattack

Angler
Dec 22, 2018
98
130
33
Central Joisey
... I do wish you were representing a group of anglers but in either case you have the facts...

Thanks George. The author is working with RFA and SSFFF, and has already procured endorsement from NJFishing.com. Would you be willing to endorse this study on behalf of NYAngler.com? It would go a long way in raising awareness and promoting synergy between states. Thanks for your consideration.
 

hartattack

Angler
Dec 22, 2018
98
130
33
Central Joisey
2022 Fluke Regulatory meetings begin next week, details below

I kindly ask George if the study I posted last week can be endorsed by NYAngler.


Upcoming MAFMC Meeting
Just wanted tp post the Summer Flounder recommendations from the Monitoring Committee for the upcoming meeting next week December 13 - 16. This was taken right from the briefing materials for the meeting which can be found at the link above.

For all these reasons, the MC was not comfortable with the Council staff recommendation for a
33% liberalization in harvest in 2022 compared to 2018-2021 average harvest. The MC considered
a few different methods for calculating possible liberalization amounts, including a weighted
average of recent years harvest with 2021 down weighted, or recommending a liberalization of
25% based on the increase in the RHL between 2021 and 2022. However, many MC members
were concerned that these increases would still pose too much of a risk of exceeding the 2022
RHL. Given these concerns, the MC recommended status quo regional measures for summer
flounder. However, if the Council and Board prefer liberalizations, the MC recommended a
maximum coastwide liberalization of 16.5%, which is half of the 33% liberalization
recommendation in the Council staff memo.

Under conservation equivalency, the MC also recommended status quo non-preferred
coastwide measures including a 19-inch minimum size, 4 fish bag limit, and open season May
15-September 15.
 

hartattack

Angler
Dec 22, 2018
98
130
33
Central Joisey
On air now, the author of the Fluke Analysis I posted:

........guest on the Michael Shepherd Radio Talk show WOND (1400 am radio and 92.3 fm) tomorrow morning between 7:00 and 8:00 am discussing among other things the state and fate of the Summer Flounder fishery. Bill Shillingford, whose been a long time Advisory Panel (AP) Member, will be on the show along with other local business owners involved with and dependent on the health of fisheries in New Jersey.

If anyone is interested and wants to listen in or call in and comment or share your opinions, following is the link:

Programming - WOND