Skylar

01.07.2014 Your letters, ASMFC

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Fish Report 1/7/14 </SPAN>

Going & Went </SPAN>

Your Letters </SPAN>

ASMFC Comment & "Open For Business?" </SPAN>

Taking shots at us constantly, its only a matter of time until an estimate catches the sea bass fishery square in the forehead. </SPAN>

Managers Should Reconsider all MRIP/MRFSS sea bass catch estimates using the full statistical spread offered by MRIP for this data-poor fishery, including any estimates pertinent to present-day regulation.</SPAN>

MRIP created no repair to our recreational catch estimates. It failed and is dragging the sea bass fishery down with it. </SPAN>

The 'repair' to recreational estimates, if there is to be one, must be in management's use of the full statistical spread. </SPAN>

8,220 "Oyster Castle" reef blocks by the rail – 2,438 at Jimmy's Reef – 1,540 at Ake's – 288 at Lindsey Power's Isle of Wight Reef.. </SPAN>

New Truckload Coming! Big-Big Thanks To Randy & Rolfe! </SPAN>

See the Reef Foundation's Website</SPAN> ocreefs.org</SPAN> if you'd care to help fund reef building. Or snailmail a check – any check!</SPAN>

Ocean City Reef Foundation</SPAN>

P.O. Box 1072</SPAN>

Ocean City, MD 21843 </SPAN></SPAN>

My @mediacombb email address is a memory. Please use mhawkins@siteone.net</SPAN> for correspondence.. </SPAN>

Greetings All, </SPAN>

Not a stellar start to the 2014 tog season. Been some limits, even a few guys having to share; but only Dean's 12 pounder stands out. </SPAN>

That and Stanley's 4.5 pounder. But that was just a fluke. </SPAN>

No, really. </SPAN>

A flounder. </SPAN>

Fish bit a tog-intended shrimp on January 1st. </SPAN>

Strange. </SPAN>

We've already tagged over 100 tautog. Unfortunately, only a precious handful were over the 16 inch legal size limit. </SPAN>

Did have 2 guys fish two days without catching a fish while adjacent anglers caught well. This fishery, more than any other my boat targets, is supremely unforgiving. </SPAN></SPAN>

If you can't handle a skunk - and these guys certainly could – stay off the rail. No one wants to fish in the cold with a whiner. </SPAN></SPAN>

Will Be Cheerfully Attending Previous Obligations Until Saturday, January 11th, When I'm Offering A Tog Trip From 6:00AM to 1:30PM for $100.00 - 14 Anglers Sells Out.. (supposed to breeze up heavy in the afternoon..) </SPAN></SPAN>

Longer Tog Trips – Tuesday, January 14th & Wednesday, Jan 15th – 6:00AM to 5:00PM - $150.00 – 15 Anglers Sells Out.. </SPAN></SPAN>

We provide green crabs. You're welcome to bring any kind of crab you like – even lobster, even plastic. </SPAN></SPAN>

If You Book — BE SURE TO LEAVE A GOOD CONTACT NUMBER & DON'T TURN YOUR PHONE OFF! </SPAN></SPAN>

No Live Fish Leave The Boat - Dead & Bled - Period.</SPAN> (I Believe The Live-Fish Black Market Has Hurt The Tog Fishery, But Not As Much As Bad Sea Bass Regulations)</SPAN></SPAN>

Agreed With Or Not, All Regulations Observed – Maryland: 4 Fish @ 16 Inches. </SPAN>

Reservations For Tautog Trips at 410 - 520 - 2076 — They Answer 24/7. </SPAN>

LEAVE YOUR BEST POSSIBLE CONTACT NUMBER</SPAN> - Weather Cancelations Are Common - I Make Every Attempt To Let Clients Sleep In If The Weather's Not Going Our Way.. </SPAN>

Bring A (not terribly big) Fish Cooler With ICE For Your Party.. A 48 QT Cooler Is Good For 2 Guys. Even Now You Should ICE Fresh Fish.. </SPAN>

Be A Half Hour Early - We Like To Leave Early.</SPAN>

Clients Arriving Late Will See The West End Of An East Bound Boat.. </SPAN>

If You Won't Measure & Count Your Fish The State Will Provide A Man With A Gun To Do It For You. We Measure & Count — ALWAYS — No Exceptions!</SPAN>

I often get calls & emails asking "when are the big tog trips?" Or, "Put me on the big tog trip list." </SPAN></SPAN>

Incredibly fortunate to have caught clients 6 tog over 20 pounds, I can assure you none were planned for. Its also true several of those jumbos were caught in sight of the beach. </SPAN></SPAN>

There are longer & shorter trips, but no "big tog" trips. </SPAN></SPAN>

Believe me, I just want clients to get bit. </SPAN></SPAN>

No one would call 2014 red hot. </SPAN></SPAN>

At least not yet.. </SPAN></SPAN>

Because of "Catch Estimates Gone Wild" sea bass are closed Jan/Feb/March/April/& most of May with a longer fall closure expected as well in 2014. Every tightening of sea bass puts more pressure on tautog.. Books & papers abound on Ecosystem Based Fishery Management. We're presently writing whole chapters on what not to do. Perhaps future managers will learn from our mistakes: Or, It Could Happen Tomorrow.. </SPAN></SPAN>

(see section below for an opportunity to offer specific comment to the sea bass management plan — Repairing this mess sooner would be better.) </SPAN></SPAN>

About that comment period..</SPAN></SPAN>

"In theory there is no difference between Theory & Practice, but in practice there is." Yogi Berra </SPAN></SPAN>

We really need managers to change their practice & reconsider their theory. </SPAN></SPAN>

Asking Under-Secreatary of NOAA and the Secretary of Commerce to help fix sea bass is much more than making comment to ASMFC. </SPAN></SPAN>

I've heard from a few folks who have written letters to the new head of NOAA, Dr. Kathy Sullivan. </SPAN>

Those letters, some of them very well-written, are just being opened and may or may not make it to the Boss-Lady's desk. </SPAN>

Well-written or not makes absolutely no difference – having written at all & honestly absolutely DOES make a difference. </SPAN>

Time will tell. Perhaps we'll all get a nice form-letter telling us how NOAA appreciates feedback pertaining to "Fisheries In Crisis" as from an uncaring Congressman or Senator. (I've had very well-studied responses from Hill staffers, others have shared form-letters with me indicating respondents had no clue.) </SPAN>

It's very possible we'll be read & understood at NOAA & Commerce. </SPAN>

Possible..</SPAN>

*</SPAN>

It's an old joke in fisheries management: "Fishermen don't like the data." </SPAN>

Except I've been offering well-thought & well-reasoned criticisms of very specific points in the data. </SPAN>

If readers hadn't written, I believe 2014's sea bass season would be Closed —period— because of Recreational Accountability Measures. We would have had to "Pay Back" all of MRIP's purported recreational overage before ANY sea bass season could recommence. </SPAN>

Our letters helped many in the management community to see exactly why Accountability Measures should not be based on estimates with no real value. Managers today plainly see they're being given untruthful centerpoints. That's why some managers worked hard to pass the Omnibus Amendment for Recreational Accountability Measures – that's why we have any cbass season at all in 2014.</SPAN>

Now NOAA's acting as though we recreational sea bass fishers "Owe Them" yet another part of our season & another part of our bag limit.. </SPAN>

The new Secretary of Commerce, Penny Pritzker (NOAA Chief Dr. Sullivan's boss) was sharp enough to attend Harvard & Stanford. Her slogan is, "America's Open For Business." </SPAN>

Pardon us Mrs. Pritzker: Is that "..unless some crazy danged catch estimate wants your business closed?" </SPAN>

Let's ask the lady. </SPAN>

***</SPAN>

(In case you're new to this or just in need of a refresher..) The Marine Recreational Information Program (MRIP) is now responsible for estimating our catch. Where commercial catch is typically weighed and sold by the pound, recreational catch is estimated. This estimating used to be done by the MuRFSS program which was ordered replaced by Congress. Delivered several years too late, the new MRIP program immediately offered even more ludicrous catch estimates than MuRFSS had previously. </SPAN>

Its very, very important to note here: MRIP offers fishery managers a "statistical spread" called a 'percentage standard error' or PSE. This is not dissimilar from "margin of error" in a political poll — EXCEPT — No one would ever pay for, nor report on, a political poll with margins of error greater than +-6%. Pollsters offering PSEs common to catch estimates of 50, 80 – even 100+ would be laughed out of the business.. </SPAN>

You see: Where statisticians offer management the whole spread as Their Answer; Where, statistically, an estimate's true value is equally likely anywhere along an often enormous set of values; Where statisticians admit, "Hey, we've only got 33 fish to go on here. We're 95% confident NY private boats might have caught between 40,000 & 385,000 sea bass, and, you know, they probably weighed about 2 pounds apiece.. Don't you think?" </SPAN>

That spread now ignored and has been since 1997 or so; Managers long-ago decided to use only the centerpoint to expedite regulation – because finding and agreeing on a reasonable catch value was disruptive & slowed, not just Council proceedings, but every aspect of management: Using centerpoints—period, and allowing absolutely no discussion of their statistical validity streamlined management's processes. </SPAN>

So, Where MuRFSS had NJ shore tog fishers catching 74,000 fish off those cold, wind-swept jetties in Mar/Apr, 2010—an estimate I thought could never be trumped in ridiculousness: The long awaited "New & Improved" program, MRIP, steps up & says: "Oh No, it wasn't 74,000 tog caught from those NJ jetties in late winter, it was 173,000!" </SPAN>

(According to expert witnesses including Capt. Al Ristori, these anglers likely caught in the dozens of fish & in no possible way tens of thousands – even in the whole fishery's history put together for Mar/Apr.)</SPAN>

When MRIP replaced MuFRSS, I knew we had a problem right away. </SPAN>

*** </SPAN>

Pre-dating the MRIP roll-out; since 2004 private boat catch estimates have skyrocketed to where one state's catch will be manyfold the entire East Coast's party/charter landings. </SPAN>

Varying somewhat from state to state; No one I've spoken with in the party/charter sea bass fishery thinks private boats even catch a little more than their state's for-hire fleet. In MD I'd doubt any estimate where private boats caught more than 15% of the party/charter catch. </SPAN>

Every two-month estimating period for sea bass has an egregious over-estimate of private boat catch in one state or another – but never two states together. It's as if sea bass were mindful of political boundaries. </SPAN>

Occurring in many species' estimates; these private boat spikes were amplified, not remedied, when MRIP began. </SPAN>

Continuous regulatory tightening since 2009 has left sea bass fishers in sorry economic shape owing to emergency closures, reduced seasons & lower bag limits - all stemming from catch estimate centerpoints that no one, not even in the management community, actually believes. </SPAN>

Today's managers did not create this mess, did not start the policy of using centerpoints, but we'll have to ask them to fix it. </SPAN>

There's a lot that needs fixing. </SPAN>

Catch estimates need to get tightened-up. </SPAN>

Managers need to be able to call Bad Statistics now & again.. </SPAN>

It really is true that fully one-quarter of the 2013 coastwide sea bass quota is credited to the NY private boat fleet for catch made in July/August. At just over 500,000 pounds, that's much more sea bass than the entire party/charter fleet from Florida to New Hampshire caught from January 1st to Oct 31st. </SPAN>

It really is true that this sky-high NY private boat catch estimate is based off of thirty-three observed sea bass — 33 — that's how many sea bass MRIP actually saw. </SPAN>

All the catch estimates I have written about these last several years, including the first one in 1998, have been reported accurately. Not one of those estimates' centerpoints was remotely accurate, yet each has adversely & permanently impacted recreational regulation. </SPAN>

Right now we need to write comment to the ASMFC about the current sea bass plan. There are meetings up & down the coast too where you can make public comment. </SPAN>

Might as well write your State regulators & MAFMC Council-Members while you're at it. </SPAN>

Drop another line to NOAA's new boss. Dr. Sullivan's the Under-Secretary to NOAA. </SPAN>

Her boss is the Secretary of Commerce, Mrs. Penny Pritzker. </SPAN>

One an astronaut, the other has a strong business background with degrees from Harvard & Stanford. Somebody in Commerce has to get it: Managing Recreational Fisheries With Centerpoints From Bad Catch Estimates Is Destroying Our Industry. </SPAN>

It's not helping the fish either. </SPAN>

We need help. </SPAN>

This has to get fixed. </SPAN>

We're scarcely "Open For Business" Mrs. Pritzker. In fact, I believe many of us are just one bad catch estimate away from regulatory collapse. </SPAN>

Write Penny Pritzker, Secretary Commerce TheSec@doc.gov</SPAN> </SPAN>

Meeting schedule & Comment link at http://www.asmfc.org</SPAN> </SPAN>

My Comment Below. </SPAN>

Regards,</SPAN>

Monty </SPAN>

Capt. Monty Hawkins </SPAN>

mhawkins@siteone.net</SPAN> </SPAN>

Partyboat Morning Star</SPAN>

http://morningstarfishing.com</SPAN> </SPAN>

Ocean City, MD </SPAN>

** </SPAN>

Comment For ASMFC Black Sea Bass Management Plan — 1/7/14 – M. Hawkins – Partyboat "Morning Star" OC, MD. </SPAN>

Managers Should Reconsider all MRIP/MRFSS sea bass catch estimates using the full statistical spread offered by MRIP for this data-poor fishery, including any estimates pertinent to present-day regulation. </SPAN>

I Strongly Support Regionalization of Sea Bass & Summer Flounder Management — Its biologically mandatory to moving management forward. </SPAN>

However, There Is No Poorer Choice For Foundational Management Data Than Recreational Catch Estimates. </SPAN>

Sea bass restoration, an honest re-creation of historical reef-fish populations, is inescapably stuck in a MuRFSS/MRIP created quagmire. Wild assertions of incredible spikes in catch are not true and never have been. </SPAN>

Each catch-estimate's effect on regulatory tightening cumulative; here's a run-down of recent management actions due to estimate spikes.</SPAN>

Management employed the MRFSS assertion of a 1,122% spike in Massachusetts Private Boat sea bass landings during Wave 4 (July/Aug) 2009 to create an "Emergency Closure" in the fall of 2009. </SPAN>

Rhode Island anglers had no similar summer success, nor did Massachusetts' party/charter operators. </SPAN>

The following year those private boaters are again asserted to have caught an incredible number of sea bass, far more than the whole coast's for-hire fishers - but this time in spring. </SPAN>

Although a shortened season, a regulatory-caused economic collapse in the coast-wide for-hire fishery was averted by quota increase. </SPAN>

As I recall, in 2011 we were left alone with the remnants of our historical fishing season because MRFSS data came in low – our quota was not 'exceeded.' </SPAN>

In 2012, however, Massachusetts's private boat spring catch again sprang-up by 200,000 fish (despite their lowest bag limit ever) & NY's private boat catch also climbed 100,000 fish.. </SPAN>

These "amazing" assertions of catch are far higher than any amount of for-hire catch. Convicted of being over quota by MRIP/MRFSS centerpoints; there is again an "Emergency Closure" in the fall of 2012. </SPAN>

These MA private boat anglers who outfished the coast's for-hire fleet so amazingly in the summer of 2009 & again in the spring of 2010 & 2012 then caught virtually no sea bass when their bag limit doubled in summer.</SPAN>

In 2013 a status quo is negotiated — but 'status quo' is regulation at its historical strictest. </SPAN>

For 2014 a total closure looms because of 2012's asserted overage & a new round of incredible assertions, including NY private boats outfishing the entire coasts' for-hire yearly total while NY party/charter is said to have their second-worst (post-Sandy) sea bass season in a decade. Recreational Accountability Measures averted by hard work on managers' part; There is a strong likelihood of smaller bag limits & shorter seasons for recreational sea bass fishers in 2014 owing, as always, to incredible spikes in landings that no one believes. </SPAN>

Taking shots at us constantly, its only a matter of time until an estimate catches the sea bass fishery square in the forehead. </SPAN>

MRIP created no repair to our recreational catch estimates. It failed and is dragging the sea bass fishery down with it. </SPAN>

The 'repair' to recreational estimates, if there is to be one, must be in management's use of the full statistical spread. </SPAN>

We have not gone over-quota. </SPAN>

Further regulation will not benefit sea bass, nor has any regulatory tightening of the last 12 years. </SPAN>

I would encourage managers to consider shifting 'age at maturity' stock enhancement/diminishment & also consider whether reef-fish require reef; consider whether reef restoration is a viable restoration strategy for our region's primary reef-fish. </SPAN>

My Regards,</SPAN>

Monty </SPAN>

Capt. Monty Hawkins </SPAN>

mhawkins@siteone.net</SPAN> </SPAN>

Partyboat Morning Star</SPAN>

http://morningstarfishing.com</SPAN> </SPAN>

Ocean City, MD</SPAN></SPAN>

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