SEPT 24, 2017 - CAPTAIN MONTY HAWKINS: Dear Secretary Ross," - How Statistics Are Bringing An Industry Down - MRIP's Magic Quota Eraser - Want To Help Fix It?

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SEPT 24, 2017 - CAPTAIN MONTY HAWKINS: Dear Secretary Ross," - How Statistics Are Bringing An Industry Down - MRIP's Magic Quota Eraser - Want To Help Fix It?

Postby EC NEWELLMAN » Sun Sep 24, 2017 10:59 pm

The latest from Captain Monty Hawkins, owner and operator of the fv MORNING STAR out of OCEAN CITY, MD.

Fish Report 9/23/17

Dear Secretary Ross," - How Statistics Are Bringing An Industry Down - MRIP's Magic Quota Eraser -

Want To Help Fix It?


Not Currently Sailing. Will wait until sea bass reopen Oct 22nd.. Might sail beforehand, maybe. Will announce right here if so. Lot of life outside of fishing going on.


I do especially want to thank NOAA Fisheries and all the scientifically-blind who have reviewed MRIP's catch data for this beautiful weekend off. It's allowed me some serious writing time.

From Below: If anglers aren't concerned enough by now to write a stinkin letter, then we shall surely see the continuation of MRIP's trend. They'll add catch & add catch from Shore & Private Boat until we're completely closed by Accountability Measures.

If you, the reader, would care to involve yourself in the fight to rid marine recreational fishing of this MRIP catch data chicanery--where coming closures will make today's seem mild, or even just under-stand why government guessing at what we caught could be a problem in today's computerized world: Read On. The piece starts just a few paragraphs down..

If you know anyone with pallets of unsalable block...


I know a fishy place or two we can store them. Forever. Will pay for trucking. If you have a few blocks in the backyard taking up space and just making snake reef, bring em. We'll toss em overboard with the rest.

Thank You Capt. Jeff Bauer of Potomac Valley Brick for finding a(nother!) truckload of miscast block.

Please Support the Ocean City Reef Foundation!

http://www.ocreefs.org

We're Nowhere Near Reef Building's True Potential.


2017 Reef Raffle!! Benelli USA has donated another spectacular shotgun!


A Benelli Super Black Eagle II, 25th Anniversary Limited Edition, 12ga 28" in Black Cerakote.. Tix are $10.00 - available aboard and/or email if you want me to mail you some. If you want to sell some, could REALLY use the help. Drawing is always the Sunday after Thanksgiving..

19,100 Reef Blocks deployed at numerous sites:


- TNC's Restoration Reef 278

- Doug Ake's Reef 3,300

- St. Ann's 1,888

- Al Giles/OC RUST Reef 1,426

- Eagle Scout Reef 954

- Sue's Block Drop 529

- Nichols' Concrete 1122

- Capt. Bob's Inshore Block Drop 691

- Benelli Reef 418

- Capt. Bob's BG Reef 704

- Wolf & Daughters Reef 220

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Capt. Dan Iacangelo pushes over a unit with block number 19,000 aboard. Take a few blocks everyday; we left that unit at Capt. Bob Gowar's Reef at the Bass Grounds.

Here's a two and a half minute video of St. Ann's & Nichols' Concrete block piles Wes put together.

https://www.youtube.com/watch?v=WAuaIWd ... re=youtube


Too young for substantial growth, I assure you the fish haven't seemed to mind. Spread thin at first, you can see St. Ann's Reef drop-target at 1:20, followed by mid-1990's concrete and fresh block at the Nichols' Concrete. The white patches on old concrete are star coral, which, given time, forms well-used rugosity for our region's reef residents.

Perhaps the main thing you'll notice, especially in the second part, is how pea-green the water is. Wasn't long ago that area was, "The Deep Blue Sea." Clean, clear ocean water is blue, not green - especially not that kind of green.

But NOAA's not worried about that, not marine water quality.


They have spied "recreational overfishing" again & again. According to their catch estimates we're more greedy than the foreign factory trawlers we threw out with the first Magnuson-Stevens Act in 1976.. This piece describes how the Feds can believe such a rotten gut-barrel full as that..

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Greetings All,

Had some dern fine fishing before the closure; now done for a while. Price I pay for specializing in sea bass.. Sitting at the dock three gorgeous days already; have a month to come of closed sea bass season.

New Jersey anglers have already been closed on fluke (usually called flounder below Cape May) & sea bass since Labor Day. It was only because of a high-up political decision that NJ was allowed to target fluke all summer. The state went "out of compliance" on NOAA/ASMFC/MAFMC* determined harvest levels this past spring.


NJ's regulators knew their regulations would not suffice to restrict harvest enough..on a computer. They also knew the computer was slam-full of fish feathers; that absolutely no damage to US fisheries resources would come of ignoring over-strenuos guidance from NOAA.

Secretary of Commerce, Mr. Ross, told NOAA: "Let it slide."

And so they did.

* If this alphabet soup isn't your gig, I'll try to always keep it spelled out somewhere nearby.

NOAA? Really? Alright.. National Oceanic & Atmospheric Administration. NOAA is a small part of the US Dept of Commerce; & NMFS, the National Marine Fisheries Service, (previously the Bureau of Commercial Fishing,) is a small part of NOAA.

ASMFC is a multi-state Commission (3 reps per state as I recall) and also has Federal reps from Coast Guard, NOAA, & NMFS -- it stands for Atlantic States Marine Fisheries Commission and is focused on fish within 3 miles of shore. Surely you realize many species cross in & out of the 3 mile line -- there's regulatory complexity because of that boundary, a boundary drawn owing to how far a cannon could shoot early in our country's history..

MAFMC = Mid-Atlantic States Fishery Management Council handles outside the 3 mile boundary to 200 miles. Theres also a SAFMC - South Atlantic | GS - Gulf States | New England NEFMC.. Councils & Commissions can all RECOMMEND laws that must then be approved by NOAA & published in the Federal Register.

MRIP is the NOAA program which estimates recreational catch from Texas to Maine. Marine Recreational Information Program. (This piece is mostly centered on MRIP & how NOAA forces its use at the Council/Commission level.)

MRFFS was the previous program, replaced by MRIP in 2012.

In my opinion--from my experience beginning in 1998, MRIP is far worse at guessing recreational catch than MuRFFS was. Combined with strengthening of law addressing over-quota situations, I doubt some recreational fisheries will survive but a few more seasons. Maybe not this season because MRIP's wild accusations of being far over quota have already begun..


..so NJ went, "Out of Compliance" on fluke in 2017.


That means NOAA did not approve the regulations NJ wanted for their state's recreational flounder fishermen. Any other time -ever- NOAA would have been shutting a state down that went out of compliance -- any other time ever.

Federal regs, issued by NOAA, would have locked New Jersey's season up in a vault. But NJ has a secret weapon in Governor Christie. He must have Secretary Ross of Commerce on speed dial. The Governor's connection to the President oughtn't be forgotten either and is perhaps what's actually in play.

Rule #1: When trying to accomplish something in politics, EVERYONE's your friend!


Make no mistake; it wasn't as though NJ said, "Eh, we just don't like NOAA's recommendation. We want to be GREEDY."

No, NJ Fisheries personnel are supremely mindful of restoration & management.

NOAA was insisting, however, that NJ use a catch estimate, a bad catch estimate from MRIP. There's no way the estimate could be true. The assertion of NJ's Private Boat anglers going far over quota--of Private Boats catching 2X as many fluke as the previous year--was sunbaked, maggot infested, & stinking to high-heaven codswallop.

*
From Fish Report 7/16/17:


How did Party/Charter landings of summer flounder decline coastwide an average of 31.7% in 2016 while Private Boats from just 4 states had a 2,284,514 pound increase? How did Private Boats from 4 states experience a 96.9% increase in catch despite what nearly everyone agrees is a declining population of fish.

(This coast-wide decline in summer flounder/fluke is timed PERFECTLY as an affect of Hurricane Sandy. The just-legal fluke of today were days-old/weeks-old newly spawned survivors of that hurricane.)
*

NOAA to Managers: No Adjustments To MRIP Data Allowed.


Even when errors are obvious. So the doubling of Recreational Fluke Landings by MRIP --while Commercial & For-Hire Recreational are factually dropping substantially-- turns into a major regulatory fiasco.

In my now several-decade long pursuit to rid marine recreational fisheries of catch statistics as the single-most important contributor to recreational fishing's regulation; NOAA & the scientific community at-large have continued to hold recreational catch estimates as suitable for use --just fine-- across broad areas.

NOAA laughs-off "State-by-State," & "Mode" (e.g. Shore/Private Boat/For-Hire) in two month "Wave" data, (e.g. where Wave 3 is May/June.) In every letter written to my DC Reps by NOAA at various times, and in different administrations, they claim not to use catch estimates like that--not in such small slices.


As recently as Dr. Sullivan, an astronaut & Under-Secretary of NOAA, ('under' because Wilbur Ross is the Secretary of Commerce & NOAA is 'under' Commerce,) ..her letter to Congress from a few years ago was a rehash: "Oh no Mr./Mrs. Upper dot-Gov Official, Wave//State-by-State//Mode estimates are not how we use MRIP data."

NOAA has always told inquiring Senators, Congressional Representatives, & Commerce above them; "Oh No. Our statistics were never meant to be used like that; not in any wave form. They're just broad guidance & get more accurate as more and more layers are included."

..then, at the very next level of governance down


---from NOAA & Commerce's innocent upper offices, down to where the real work of recreational fisheries management occurs: here broad-region & year-long catch estimates are busted apart in every wavy-way possible. It's as though boulder being mined for crushed-rock road bedding. From Texas to Maine: State-by-State Wave Data is the heart & soul of modern U.S. Fisheries Management.

They do not close 2 weeks of Massachusetts' season and a month somewhere else using coastwide data fields -- they have to use the smaller 2 month 'wave data.' Management today would be an instant trainwreck if they couldn't use wave data.

Statistically, they're thinking a 'whole estimate' is safer; as if a small amount of habanero pepper were somehow mixed in to a large vat of vanilla ice cream--that everyone will be fine--it's OK, Carry On.

Instead, these wave estimates, these small parts of larger estimates, are loaded with disastrously high spikes & also zeros. It's not a small amount of habanero -- the spikes are huge.

Mistakes in wave estimates aren't some tiny thing having no affect on the whole


-- well, sometimes; but many times too they're of a singular influence. A single mode of wave data can exceed that mode's entire history of catch. (see NY Sea Bass, Wave 6, Nov/Dec, Private Boat, 2016 below.)

Other times a single sector, from a single state, from a single two-month wave, will be shown to have landed more of a species than all other participants--even including commercial harvest. (See NJ Shore Tautog, 2010, Wave 2; where the 'new & improved' MRIP, on the day of its release, showed a 100,000 tog increase on what had been one of MuRFSS worst estimates ever.

The brand new "Repair" showed how guys sitting on buckets & freezing along NJ jetties -praying for the first tog bites of 2010 during March/April- how those fellows outfished ALL Commercial & For-Hire Recreational-----For The ENTIRE YEAR! Yup, we been repaired alright..)


Spikes, or "outliers" in statistician-speak,

are common in all manner of statistics.

They are usually dealt with harshly -- discarded.



In US Recreational Fisheries they are embraced & treated as if Moses himself spoke the data.

I'm telling any who will read, that's not a tiny bit of habanero - it's a dump-truck load. MRIP spikes DO NOT blend in and disappear! More & more errors, sometimes huge, are now folded into management's history. With no repair anywhere on the horizon, worse estimates still are coming. We're seeing more and more closures; losing more & more season.

It really was Congress's intent to "use the best scientific information available." But calling MRIP 'science' is to slap Newton, Einstein, & Marie Curie unconscious and call it a pat on the back..

Science must be testable. NOAA will suffer no test of MRIP save a statistical analysis ..and statisticians luv MRIP.


I think it's pretty easy to check MRIP data for real-world accuracy, but that's because I fish & have suffered from catch data's inaccuracies for 20 years.

NOAA POLICY WILL NOT ALLOW CONSIDERATION OF SPIKES. Not in any fashion. Whatever MRIP says the catch is - Deal With It. No CHANGES to an estimate are allowed. Not only are outliers embraced, regulators are allowed no wiggle-room even within PSE - which is like a political poll showing "plus or minus 3%" - except in MRIP's wave data PSEs are often above 100!


No matter how implausible a State/Wave/Mode estimate -- Use It.

No Matter how unsure the statistician of the work, Use It.

No matter that no one in fisheries management believes an estimate - Use It.



Fishery closures first began with the MAFMC's 1998 sea bass closure.


I remember that foolishness in detail. A closure caused by a single spike: an elevated two month wave, in one state and mode, (NJ, Wave 6, Sea Bass, Party/Charter--almost 2 million fish.)

Today, with the now-frightful specter of "Accountability Measures," where recreational catch overages must, by federal law, be paid back before fishing can resume as normal; closures look to become a regular event--have. Worsening is unavoidable.

It is 100% possible that an MRIP estimate will be so high in 2017 as to close sea bass or flounder from Cape Hatteras north for all of 2018. We already have a good start in NJ's 2017 May/June Wave 3 Private Boat sea bass estimate.. (below)

Accountability Measures (AMs in the manager's world) ..AMs are why, even with sea bass now at 240% of their rebuilding target -- more than double what management had anticipated as a "success" -- AMs are why even while NOAA tells Congress of its wonderful success: We Are Closed. Accountability Measures mean we wicked overfishing scoundrels are paying dearly for having harvested beyond our legal quota.

Except we really didn't. I'll show why I believe that below. The following catch tables should infuriate recreational anglers & anyone in a business tied to recreational fishing. But they won't. This is dull stuff. It's really hard to communicate, and it's been getting worse slowly--for a long time. Many people believe 'we cannot win.'

I believe we can.

A couple letters, a couple stamps.. It's a hell of a lot easier than what folks dealing with a natural disaster face. Irma & Harvey just recent examples -- we can AVOID further disruption in the recreational fisheries by convincing Secretary Ross these bad MRIP statistics are completely upending coastal recreational fisheries' economies.

Post a letter.


I know some want a 'sample' to cut & paste.. They get sorted out and discounted fast. Put some thoughts to paper. They don't want some monstrosity like this. "Why aren't fishery managers allowed to discount recreational MRIP catch data even THEY do not believe?"

Print & Sign.

Send. (addresses below)


I've recently had party/charter operators from DE & MD's coast take note of how many Private Boats they've seen in September.


Very typically, on our last day of sea bass season I fished a reef well known to anyone in the region with a marine-capable boat. Another party boat from DE fished nearby as did several charters -- and one Private Boat.

Flat calm -- no secret spot -- last day of season -- sea bass biting fine -- lots & lots of open reef: there were roughly 90 persons fishing aboard Party/Charter boats at this artificial reef site.
Looked like maybe 4 guys on the Private Boat.

Many days we see no Private Boats at all. During some periods of the year I see no Private Boats for months.


All year I've seen an abundance of Private Boats one time -- once. Memorial Day weekend & flat calm; with 18 Private Boats fishing Maryland's largest offshore artificial reef; even then these Private Boat anglers were still outnumbered by For-Hire anglers.

MRIP has told me, in person & in front of soon-retiring NOAA Regional Administrator, John Bullard:

"Of course Private Boats outfish Party/Charter! They have a lot more boats!"

Yeah.. But there's a heck of a lot more people who DON'T own a boat, but still like fish & fishing. We For-Hire guys even carry a lot of boat owners when everything's under wraps for winter..

If your information sources from a computer alone -whether in a corner office or deep in the cube farm- on a computer those Private Boat guys are sometimes FAR WORSE than all of a State's trawl, trap & party/charter.

Outfishing ALL professional effort, these Private Boats sop up far more than their share of quota. It causes all manner of regulatory mayhem.

Gosh, in MRIP's world sometimes surf casters can even cast miles???


Here's an estimate I'm deeply familiar with:


MD Annual Sea Bass (BSB) This is NOAA's Best Scientific Information Available?


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Readers from my own client base might be pondering why in Billy Blue Blazes they EVER paid to get on my boat when the boys down at the jetty & on Rt. 50 bridge were boxing them up! Man! Nearly HALF of MD's sea bass -- a species I commonly run 25 miles for so catch clients a few for dinner..Darn!

Sea bass were being caught like CRAZY from shore!


Man, I could sure use that extra fuel money during this closure..Except there were NONE caught from shore. Not a single legal fish.

In that MD estimate there might have been a few short sea bass taken from shore. That would explain at least a tiny fraction of this blow-out MRIP estimate -- an estimate I would bet my life is dead wrong. So, a few illegal shorts -- Right MRIP?

MD Shore Only


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Did a few short fish, illegal fish, skew the data?


Not so much.

Those are Nice Fish! Front page of local fish rags if caught from shore..Shore caught sea bass represented by this table are much larger, on average, than sea bass I put clients on far to sea. The DelMarVa region's size limit is 12.5 inches.


Sure, my clients caught some far larger, but we also measured to 12.5 inches with a micrometer trying to get dinner..

In MRIP's landings we see Shore had nearly 50% of MD's sea bass. And, Boy, were they dandies..


The truth of that estimate is there were a few short sea bass seen in the Chesapeake. Those few fish, less than a dozen as I recall, after being crunched through MRIP's Magic Quota Eraser turned into nearly half of MD's landings..

Sea bass fishery closed because NOAA insists their data is just fine, even if there is inexplicable population growth. With the sea bass population far above restoration target, MRIP's wave data makes regulators look like complete idiots for using it.

WHY IS THIS GARBAGE ALLOWED TO DESTROY RECREATIONAL FISHING'S ECONOMIC VITALITY?


I promise all who will read -- MRIP's estimates might make a statistician happy, but they have no place being used as a precise measure in the regulation of our fisheries. I am confident MRIP Wave/Mode inaccuracies are the cause of very nearly ALL recreational fishing's regulatory challenges.
2018 is NOT going to be better.

NJ Private Boat Sea Bass


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Already in 2017 we see NJ's Private Boat sea bass estimate at 444,063 fish, yet in the last five years that same group of participants landed just 197,809 all added together...

It would be completely in Management's purview to close spring sea bass to Private Boat, yet leave it open to Party/Charter -- see red snapper in the Gulf.


I anticipate there'd be some push-back on that. But maybe not. Derned if it isn't a hard thing to get folks to tell their government what they think. Post all day & all night -- But write a meaningful Comment on NOAA Policy? Nah.

NJ Party/Charter Sea Bass (here to reveal its contrariness to common sense - compare to table above)


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By using "Percentage of Catch" as a check, anyone can see likely errors in the estimates..


Here MRIP's saying in 2014 & 15 Party/Charter caught virtually all NJ's sea bass.

Then, suddenly!, in 2017 Private Boats revolted?

Blocking access to NJ's wrecks & reefs so Party/Charter couldn't get on the pieces?

I'd put my wager on 2012 or 2016's percentage split... (all percentage calculations done at https://percentagecalculator.net )

Were NOAA and other .Gov entities to crack the whip on catch data submitted by For-Hire operators, and they are with electronic reporting beginning next year: Given a known value of For-Hire catch--and with knowledge of "Percentage of the Catch"--it would be as simple as 10th grade geometry to figure out what Private Boat caught --- or get a dern-site closer than MRIP does now.

Sample -- an illustration. In 2019, Wave 1, January/February, all Party/Charter operators report exactly 172,000 sea bass. Because NOAA diligently sought to understand factual percentage splits, (and not use the stuff they currently dream up,) we know Party/Charter catches 99.3% of Wave 1 Winter sea bass landings. Therefore the total coastal landings are 172,171 sea bass caught.

That "Percentage of Catch" would, of course, be substantially different for wave 4 - high summer. But still calculable & far more accurately than MRIP's rubbish today.

New Jersey Only: MRIP has Party/Charter clients at 4.7% of all ocean Wave 3 May/June effort combined; or 6.5% of all NJ ocean boat-only Effort.

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To refresh - here is MRIP's NJ catch estimate again for Wave 3, 2017


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These percentages do not square AT ALL with MRIP's stated percentages of Effort in the table immediately above..

Go Deeper:


Lets say a Party Boat averages 35 souls a day & a Charter 6 anglers. MRIP therefore asserts NJ had 97 Party Boat Trips the spring of 2017, or 4 Party Boats fishing every day in the 24 day spring season..

Sounds pretty unlikely - very light. Certainly not accurate; but, hey, it's an approximation using Best Available Scientific Information Available..

Lets also say every Charter Boat is maxed. That's 2,145 Charter trips divided by 24 days = 89 Charter Trips a day. (Boys are doing GOOD! Maybe they're running 3 trips a day? Relax..it's an approximation!)
I would anticipate Private Boat is somewhere between 3 & 4 anglers on average -- every Private Boat out sea bassing is here credited with 4 anglers. That makes 111,016 trips in 24 days or 4,625 Private Boats out every day of sea bass season. Of course, most of that effort (Charter too) would actually occur on Saturdays giving a truly sky-high number of boats fishing offshore for sea bass on weekends.
I'll leave it at the far-lower number spread across all days evenly.

Here we have MRIP informing us -- and this is "The Best Scientific Information Available" that regulators must use -- MRIP's telling us there are 1,156 private boats for every Party Boat; & 52 Private Boats for every Charter Boat out fishing every day of sea bass season.

If there were a fleet of one Party Boat & 12 Charters; then, using NOAA's MRIP data, we should see 624 Private Boats accompanying that fleet of For-Hire effort -- with 7 of those fleets along the Jersey coast..

Pretty clever thinking there. Be some amazing sea bass fishing. Because NOAA asserts this is real catch; we ought to see real boats.

Not the ocean I'm accustomed to looking at -- This is MRIP's version. NJ has a great reef building program. But according to MRIP, y'all better ramp it up more..

If I did that calculation using real-life effort, where most Private Boats sail on Saturdays -- I'm guessing this would near 4,000 Private Boats per fleet of Party/Charter on Saturdays, even leaving a still-large fleet on weekdays.

Going bigger & broader, MRIP has all ocean effort, all year, by boat, from Cape Hatteras to the US/Canadian border, at 11.5% For-Hire, & 88.5% Private Boat. Man, that's a different ocean than we fish. That computer fishing fleet doesn't look right at all compared to Party/Charter operators on-the-water observations.

Even in the busiest times of year, on a summer holiday with a flat-calm Memorial Day (as the real-life Maryland example above,) Private Boat rarely approaches For-Hire in an angler count. In other regions it might surpass For-Hire on such days - but I doubt by much.

I've asked an awful lot of skippers: Many report often seeing no Private Boats in the shoulder seasons save weekends & holidays. Only a very few have ever written that they thought there was a bit more Private Boat effort (or catch) than For-Hire, and then only on summer Saturdays/Holidays..

For my idea of 'Percentage of the Catch' test of MRIP data to work, NOAA would have to talk to the recreational highliners. Guys on Private Boats & Party/Charter who fish a lot could offer a fairly close approximation of real 'Percentage of the Catch' for among several species -- but only in the region they are familiar with.

Some Private Boat guys are really good at fishing. Some of them bag 'em up big time. Others trail Party/Charters like the moons of Saturn - satellites that never leave. Then too, there are Party/Charter operators like that as well. (the shame..)

From what I've seen it's fair to say fishing skill varies in both anglers & skippers aboard Party/Charter & Private Boats. What's not fair to say is Private Boat catches 84% of the sea bass from Cape Hatteras to the Canadian line across a year's time..

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A current (ill-informed) comparison of Sea Bass Percentage of Catch Across Recreational Modes.


A well-respected Rhode Island charter skipper pondered,

"I go out day after day in the fall and see no one. Where does this Private Boat catch come from?"


Another skipper in Montauk;

"Only rarely would Private Boat anglers outnumber Party/Charter in summer."

As for myself? Flip these numbers all around for sea bass, then virtually eliminate Shore catch, & I'd think those percentages about right. That is, I believe Party/Charter probably catches about 70% of our region's sea bass when calculated over a year.

NOAA will tell Congress & Commerce, "Nothing to see here. We have everything under control. Look at this National Academy of Sciences report - Yes Mr./Mrs. Senator, All's Well At MRIP!"

Except what might appear statistically pure, & thought so even at the highest levels of academia; the truth is MRIP stinks worse than a week old fish kill when it comes to real-world picture making.


So.. How do we fix it? Write Secretary Ross at the US Dept. of Commerce:

(Remember!! First Rule of Politics: Everyone's Your Friend When You're Trying To Get Something Done!) We do not need MRIP's repair right away. That will come. We need managers at Council/ Commission level to be able to disregard obviously bad MRIP estimates. NOAA will NOT allow any change from the 'centerpoint' of an estimate. Secretary Ross can change that policy. .

Secretary of Commerce W. Ross
1401 Constitution Ave NW
Washington, DC 20230


Would be better to address a staffer directly, but I haven't any idea who they are. Someone WILL open your letter & read it.

Send another to:

Mr. Benjamin Friedman
NOAA Acting Deputy Under Secretary
1401 Constitution Ave NW Rm 5128
Washington, DC 20230


And, a new guy in DC -- but not at all new to fisheries!

Mr. Chris Oliver - CINC NMFS
NOAA Fisheries
1315 East-West Highway
Silver Spring, MD 20910


You Should CC your congressional reps as well -- by mail, but to a field office. If you write directly to DC, and this may be true with letters to Commerce as well, their mail is delayed going through DHS screening.. Printing them and applying a wet signature, perhaps with a note for the poor staffer who actually has to read it is fine..

Do not ignore your state's Governor either; Especially if you live in NJ. These folks all Google easily. Look for the "Contact Us" button. Elected reps are able to help you get heard in Commerce & in DC as well.

NOAA's policy of using MRIP 'as-is' needs to change. The Secretary of Commerce can alter our worsening history in the stroke of a pen -- swiftly.

M u c h - m u c h - m u c h - s l o w e r - You may also want to support HR 2023:

"Modernizing Recreational Fisheries Act of 2017."


It has a lot of language I find appealing -- language that applies specifically to recreational data and specifies MRIP be hauled-up before the National Academy of Sciences --AGAIN-- and this time asked: "To Evaluate whether the design of MRIP, for the purposes of stock management reference points, is compatible with the needs of in-season management of annual catch limits & whether in-season management of annual catch limits is appropriate for all recreational fisheries."

Yeah! That!

Here's some more grist.
*****

NY Wave 6 Sea Bass – Final


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Hmmm... NY's Private Boats caught 94% of their early winter sea bass?

NY's Party/Charter guys going soft? I see in the news lately maybe that's not too likely.. Here MRIP asserts the giant leap in the coastal sea bass estimate owes ONLY to NY Private Boats..but NOAA always tells us how Wave/State/Mode estimates are of no consequence.

Here is NY Black Sea Bass in "Wave 6" or November/December from my 4/24/17 Fish Report


- Note MRIP Raised Party Boat significantly, raised Charter a bit too, & yet resisted efforts to have Private Boat lowered -- they actually raised a little..Especially note how the catch jumped! What? In Nov/Dec??

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Only in a statistic could NJ Shore anglers catch more tautog in early spring months than ALL NJ's Commercial Trap/Trawl & ALL Party/Charter fishers -- ALL YEAR!

Mid & North Atlantic For-Hire - All Year


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Just NJ Shore March/April Only


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All Party/Charter & Commercial Trap/Pinhook/Trawl --All Year!-- is a few thousand pounds less than what MRIP claims these NJ jetty fishers took in a few weeks..

And, by golly, MRIP's proud of it too. No really. They are.

In response to my questions: From MRIP's newsletter "Marine Recreational Information Program Update November 19, 2012"

http://www.gsmfc.org/pubs/fin/MRIP/Update_11-19-12.htm


Question:

How can you say MRIP is "better" than MRFSS when there are still so many estimates that appear to be obvious outliers? Specific examples include:


• Wave 2, 2010, New Jersey Shore Mode tautog catch. The estimate was 483,198 pounds. That number is greater than the TOTAL for-hire Wave 2, 2010, catch PLUS the total (NJ) commercial landings for the WHOLE YEAR. (I could have correctly said "All US For-Hire & ALL US Commercial For The Whole Year")

• Wave 3, Massachusetts Private Boat Mode black sea bass catch. The estimate was 246,973 sea bass in Wave 3 alone. That number is greater than the catch of the entire East Coast for-hire fleet through Wave 3.

Where's the head-count?

Where are the statistical stops to prevent wild flyers in the data?

Isn't there some way to clearly flag the "bad" numbers and only report the ones that make sense?


(Head-count is the heart of "Repair." MRIP was supposed to use license info. That's WHY we have licenses/registrations now. All that business is for MRIP. They still don't use license data as I'd anticipated. What license info they do use is inflated greatly owing to 'everyone who doesn't get a license' - a completely nut-so "drawn from thin air" escalation of recreational catch..)


MRIP Responds (and this was published in a smooth-glossy of theirs..)

Dear Capt. Monty,

Thank you for your questions. These are important issues with complex explanations that straddle the line between the science of producing estimates of recreational fishing activity, and the most appropriate use of those estimates to fairly and sustainably manage recreational fisheries. . . .
..
With these improvements in place, we can say with confidence that we have enhanced the quality of our estimates. In fact, the cases you cite are good examples for demonstrating exactly what we mean by that...


Truly at the height of bureaucratic ambiguity. Here's my take-away: "Yeah, these estimates aren't even close. Ain't statistics grand?"


If anglers aren't concerned enough by now to write a stinkin letter, then we shall surely see the continuation of MRIP's trend. They'll add catch & add catch from Shore & Private Boat until we're completely closed by Accountability Measures.

In fact, MRIP announced they intend to do exactly that -- they intend to add 300 to 500% to Shore & Private Boat.

There was a meeting in early summer 2017 about it. The Commercial community is up in arms about it because they've been told MRIP may have to add 10X more catch..


That would mean they're getting really ripped-off. I guarantee they are not. We are.

The idea, "Guys! If we just put up with this pain a short while more, everything's gonna be great again!" is absolute baloney. When fisheries production is responding to management, populations grow swiftly. When management has no idea it's best path forward, is strapped to data with no veracity, we have today.

Catch Restriction is never going away. We have to have it. But neither can Catch Restriction carry us to the finish line. I believe Restriction/Regulation of Catch has given nearly all it has to offer.

If we are to truly restore our marine fisheries we must address:


A) The Greening Of The Mid-Atlantic -- where algae-green water has now replaced once-blue seas from 2 miles to even sometimes 50 miles out. Although there is no scientific recognition of any water quality affect/decline at sea, it's plain as day in fishing's history. This repair work has been ongoing for decades, but only in consideration of estuarine repair.

Only recently has there been large-scale successes in oyster reef restoration.

In my opinion, The Nature Conservancy lead the way at their VA Coastal Preserve. It may still be true, was a few years ago, that there are more oysters growing in Virginia's back-bays, the coastal bays along the Atlantic, than in all of the Chesapeake.

Virginia, followed by Maryland, then found using almost any substrate that doesn't lay flat like shell will allow oysters to flourish. Using loose shell mimics a dead reef sprawled across the bottom (but they sure are nice to dredge.)

Concrete & Rock jut upwards & off the bottom offering vertical surfaces for spat to attach to -- just like a live oyster reef. When you see "oysters growing on oysters" in profusion, and you can today at many sites, successful restoration of our once-grand biofilter is only a measure of effort away. Yeah, it's a big measure--huge; but now we know how to turn the ocean blue.

While doing so, while finally building oyster reef at an industrial scale to match it's destruction; we'll also form an astonishing fisheries production engine in our estuaries with hardbottom reef --- And revitalize oyster harvest in ways not thought possible. Industrial Biofilter Reefs will be unimaginable oyster spawning machines. They'll figure out how to capture excess spat & monetize it.

B) We MUST address the complete absence of knowledge concerning seafloor habitat. With perhaps 10 to 15% of the original natural hard bottom reef remaining, (and maybe far less,) the notion of a full restoration of any species of fish even remotely tied to marine reef having already occurred is laughable.

We have lost coral reef in grand scale & know nothing of it. It's not damage occurring today, it's damage that occurred after WWII and into the 1970s. It's as if we were looking at a wheat field hoping to restore squirrels with hunting controls.

C) Our greatest immediate increases in fisheries productions will be found in spawning production. Specifically, by discovering our ability to manipulate at what age fish join the spawning stock.. I have it made plain in sea bass. (Not that I have any real traction in the fisheries science community..)

In the earliest days of management, and indeed before management began, we saw fantastic sea bass production -- a wonderfully increasing population -- despite also growing extraction.

I'm positive that population growth owed to an instinctual response in sea bass to spawn young -- even fish of a few months of age would sometimes begin spawning ..and that's EXACTLY what researchers found in all studies on sea bass prior to the regulated era. After we hit 12 inches, sea bass began to spawn at age 3 & 4 -- not age zero & 1 anymore. Production-wise, delaying maturity was like turning off a switch.

Even the most deeply-rooted environmental groups are OK with unregulated harvest of Pacific mahi. Here from Oceana:

http://oceana.org/marine-life/ocean-fis ... olphinfish

"Though the common dolphinfish (mahi) is heavily fished by recreational and commercial fishers, its high productivity and young age at maturity have so far protected it from overfishing. Populations are stable and are able to support the heavy fishing. Currently, scientists consider the common dolphinfish to be a species of least concern."

When we've learned how to use Habitat Fidelity in conjunction with Manipulating Age at Maturity, some species can be made nearly as productive as mahi. When I witnessed sea bass at Habitat Capacity in 2003, I realized the only way to increase the sea bass population then was by increasing the amount of habitat available to them. We were only 6 years in to Federal management..

Glad I was paying attention. Glad I began self-regulation on an 88 foot party boat 5 years before federal regs, that I was allowed to. It is these forever & unending battles over "quota that disappeared" in MRIP's magic quota eraser that blind managers to our more immediate tasks.

We have got to form a firmer truth of recreational catch or remain mired in this regulatory quagmire, battling against an un-winnable foe until at last our recreation & recreational businesses are preserved only as animals of the La Brea Tar Pits -- drowned in statistical tar

With an ocean of potential we have made a mess. Write Secretary Ross. See if he'll start us out.

Regards,
Monty

Capt. Monty Hawkins
capt.montyhawkins@gmail.com
Partyboat Morning Star
http://morningstarfishing.com
Ocean City, MD


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