There is an issue with rec scup regs for this year

[BoatGuy]

I received this from a concerned angler and I thought I'd pass it along.

There is an issue with rec scup regs for this year. Here is a synopsis:

- There was a recommendation for a 56% reduction from last year to meet the RHL for 2022. The Council and Board recommended a size increase of one inch, which is predicted to result in a reduction of less than 30%.

- NMFS has not accepted these measures, and as a result has proposed to close federal waters to scup fishing, which will also preclude vessels holding a federal permit from catching scup anywhere. A federal waters closure will cause significant problems for the majority of the rec sector.

- Scup are currently at double the target biomass, at 400 million pounds. Average estimated harvest from 2018 to 2021 was under 13 million pounds. With the proposed reduction, 2022 rec harvest should be less than 10 million pounds.

- Reducing scup harvest by half when the biomass is double the target is completely outrageous, and can only increase the public's distrust of and frustration with the management process.

As with sea bass, the only potential solution to this action by the Service is an overwhelming public outcry. Only a very large number of comments has a chance of resulting in a change.

Public comment for the scup and sea bass rules is open until Tuesday, may 3rd. Everyone that has the slightest interest in scup should write an email based on the above points in their own words, or at the very least send the basic comment listed below, before that date. They should also be encouraging everyone they know to submit a comment along these lines. Add or change a few features to personalize your comment. Use the following link for comment:

Regulations.gov

Congressional representatives should also be contacted and urged to pressure the Secretary of Commerce to ease this action. Political pressure on elected officials is the best avenue available to get this changed. Take the time to write to your state senators, and your congressional representatives to urge them to lean on the Secretary of Commerce.

Sample Letter:

I am writing to encourage NMFS to reconsider the decision to close scup in federal waters. With the biomass at double the target, 400 million pounds, and the potential harvest of less than10 million pounds, it is difficult to understand the need for a reduction of over 50% in harvest over the past three years average. Such action will only serve to further degrade my confidence in the realistic and efficient mechanism of the management process, especially after the drastic change in the MRIP process that has wildly increased recreational harvest limits, but the biomass remains well over what we are expected to maintain.

The extreme socioeconomic impact that these measures will inflict on the sector are punishing, and offer no hope for recreational fishermen after all of the sacrifices that they have made across this and other species. The Service does not hesitate to take decisive measures when a fishery falls below the threshold biomass, but cannot see the sense in using a large surplus of biomass to ease the impact of a reduction in harvest that is required due to an inflexible management process. The difference of harvesting a part of one percent of the biomass will go a long way in repairing the faith and investment that the recreational community has in the way the Service treats both the fishery and the user groups.

 

[Roccus7]

Word of advice: DO NOT COPY the sample letter. If they get 5,000 of the same letter, it get's logged as ONE.

My 2¢: Nobody should be surprised that the continued pounding of Scup the past few years would have consequences as their abundance have made them the default target in the absence of legal fluke & BSB. The regulators cannot allow this to continue, which is why NMFS rejected the proposal. Even when your bank account is very flush, continued huge withdrawals will have disastrous implications in future years and the regulations try to prevent this.

You have to ask yourself, do you really want to keep kicking the can down the road fueling the future possibility of a complete shutdown? Do you really need 50 porgies a trip or will a dozen be more than adequate for a few nice meals? The problem with the management playbook is once a population falls below threshold, it's really in bad shape, with stripers once again showing that fact. Action has to be taken as soon as the trend heads down and over harvesting in one year needs to be paid back the next year.

Pay me now, or pay me later...

 

[george]

Word of advice: DO NOT COPY the sample letter. If they get 5,000 of the same letter, it get's logged as ONE.

My 2¢: Nobody should be surprised that the continued pounding of Scup the past few years would have consequences as their abundance have made them the default target in the absence of legal fluke & BSB. The regulators cannot allow this to continue, which is why NMFS rejected the proposal. Even when your bank account is very flush, continued huge withdrawals will have disastrous implications in future years and the regulations try to prevent this.

You have to ask yourself, do you really want to keep kicking the can down the road fueling the future possibility of a complete shutdown? Do you really need 50 porgies a trip or will a dozen be more than adequate for a few nice meals? The problem with the management playbook is once a population falls below threshold, it's really in bad shape, with stripers once again showing that fact. Action has to be taken as soon as the trend heads down and over harvesting in one year needs to be paid back the next year.

Pay me now, or pay me later...

I agree. But if you have any interest in fishing for these species please take the few minutes and send a message.

 

[Roccus7]

I agree. But if you have any interest in fishing for these species please take the few minutes and send a message.

Yes George, I did not mean to imply that letters shouldn't be written on any fisheries management issue; just the opposite. I wanted to make sure that the folks avoided the "here's a form letter, just copy it and email it in" pitfall, as these types of letters are grouped together by ASMFC as a single response.

It may take an extra 10 min to "personalize" a letter, but it's critical for your voice to be counted by the regulators.

 

[george]

Hey Dom,

I agree 100%. It's best to read the issue and give your view.

We both know of many times these comments were read after the decision was made. What I like about this is how you can read the comments as they're posted. No more guessing or excuses.

 

[PaulE]

Individual letters and emails with the same content do not get counted as one item. They may be viewed by individual managers as less valuable, but each comment is counted as its own and categorized as positive or negative. Each comment is also printed in the briefing book sent to the Board and Council, and published in the Federal Register.

There is nothing wrong with the 33% reduction in scup that was recommended by the Board and Council, in my opinion. I think there would have been nothing wrong with status quo. If you look at the rec harvest numbers and the biomass, the difference is miniscule. There is a required reduction of 56%, due to the way the ABC and RHL are determined. With well over double the biomass at 400 million pounds, we are looking at taking an additional million pounds. Does that sound reckless?

50 fish and 30 fish bag limits are not the issue. Although many people believe that nobody needs that many, if you want to think that way, nobody needs any. It's a sport. The winning team doesn't eat the football at the end of the day. But the fish we play with have great nutritional and economic value to many anglers, and the sport has gotten quite expensive. Why can't the catch offset the financial burden? It's not supposed to be a sport for the wealthy. Aside from that, if you want to achieve the recommended reduction through the bag limit, it would need to be 7 fish and that would come up 5% short of the recommended reduction. Does anyone feel that a seven fish bag limit for scup would ever be reasonable, or even somewhat justifiable?

Also, as with black sea bass (which everyone should be sending in similar comments on, whether you are for status quo or a reduction, whatever your philosophy may be), the allocation amendment is going to increase the RHL in 2023 for both species, so to go from 7 scup this year to what we had last year would seem to be very... bureaucratic, wouldn't you say?

 

[george]

@PaulE I couldn't agree with you more. 7 scup would be tough on anglers, especially those targeting them in the sound. There isn't much else around. Not to mention that there are porgies everywhere!

The problem we face as rec anglers is that the process is hard to understand and everyone wants to do the right thing. Many don't understand that this move by NMFS is wreckless and could put a damper on those that enjoy catching and eating porgy.

 

[MakoMike]

Its going to be interesting in how this pans out. GARFO is required by law to prevent overfishing. But IIRC if you looks at the species (both commercial and recreational) I don't think they would be subject to overfishing in 2022. OTOH GARFO can't unilaterally change the commercial/recreational split.