Originally Posted by Ttmako
This is long but please read.
For years, recreational fishermen have willingly participated in fisheries management, abiding by increasing regulatory measures. These have included lower bag limits as well as higher minimum size requirements. We have done this because we have been led to believe stocks will improve and a return to reasonable allowable catches will resume. This is supported by testimony given Monday by both the Coast guard as well as an enforcement officer. Specifically, the coast guard increased fisheries boarding’s and the violation rate dropped to 1.3% from 5.9% a year earlier. (tab 5).
I attended the council meeting in Baltimore and was appalled by what I heard the council mention. The council admitted they have been regulating this fishery for 24 years and other than irate fisherman, has nothing to show for it. The current management measures assume better data by 2022. So in 24 years they have not been able to put forth a viable, accurate, agreeable measurement of the size of the fluke fishery nor have they been able to accurately measure the demand recreational fisherman put upon that fishery. So to put that timespan into context, over the previous 24 years, Google was invented, smartphones have flourished, and we have gone to war with Iraq, twice. The world trade center was destroyed and a new freedom tower has been built. I’m not clear why the council is unable to produce an accurate number of fish and a better estimate of the number of fisherman. It should not be anywhere near as complicated as any the items previously mentioned.
The proposal to further decrease the recreational quota by 40% is untenable and will have serious unintended consequences, including losing the support of the constituents they serve.
Every year the quota is reduced and recreational fishermen are squeezed with lower limits and higher minimum sizes. These reductions are all based on data that you willingly and arrogantly admit is flawed. The recreational community passionately believes the science is completely flawed. Simply because, they as participants, do not see or experience what you are telling them. If there was some believable science or data to substantiate and prove the stocks were indeed at risk, fisherman would help. However, there is no tangible evidence to show the stock is in danger. The issue from my perspective is not the quantity of fluke, it is the size of the fluke we are catching. This summer most days we caught dozens of 16-17.99999” fluke that we had to throw back. How many of these perfectly edible viable fish died because some model tells me I had to throw it back, even gut hooked fish. I’m sorry but that is not conservation.
The unintended consequence first and foremost will lead to devastating losses in the already struggling for hire fleet, bait and tackle shops, marinas, etc. Secondly, some recreational participants will no longer support these unsubstantiated quota reductions. This final straw will provide them motivation to just ignore the rules and keep whatever they want.
It is imperative for the recreational community and the fisheries regulators get on the same page. To do that, the following framework is proposed:
1. Establish parity with commercial size limits. It is simply not equitable that commercial fishermen can keep 14" fluke and those size limit never change. Move the recreational limit to 14", allowing people to keep a limit of fluke. Conversely, increase the commercial size limit so there is a minimum size for both constituents. Again, the fluke stock is abundant and the current bag limit (5 fish) is reasonable. However, the increasing size limit is the problem.
2. Institute a slot limit. Current regulations are forcing fisherman to harvest the bigger female breeding stock, which negatively impacts the spawning biomass. This is totally counterproductive to preserving the stock and what we are trying to accomplish. I urge you to incorporate this important and relevant information to your models. In addition to a slot limit gut hooked fish should be kept and counted against the limit. There is no reason to throw a 17” gut hooked fish over the side.
3. Improve science and data collection. For many years NOAA has been asked to update the stock assessment and data collection techniques used to survey anglers. Both the assessment and survey data are inadequate and thus are providing misleading outputs to your model. As the saying goes, garbage in garbage out.
Before making such drastic reductions, it is imperative the stock assessment be updated as soon as possible to get a better understanding of the benchmark and measure the impact of regulatory measures. Party boat captains are simply the best source to measure the health of the stock. Utilize the VTR that they are required to complete. Its widely acknowledged the survey data (MRFFS and MRIP) is inaccurate. My guess is 75% of the fluke captured are caught by the for-hire fleet. NOAA has substantial resources and should have adequate funding to leverage technology to make more accurate assumptions about the biomass as well as angler effort.
4. Measure the effects of the recent quota reductions. Regulations need time to work. Changing the bag, size limits and season every year is a disservice as we are not able to see the benefit of the increased regulations. Let's see what happens with the status quo until the science improves.
5. The way we fluke fish has changed. Many anglers are changing the way they fish which may have implications on the fishery. Today more anglers are using bucktails, large teaser hooks and artificial baits to target fluke. Utilizing this methodology cuts down on gut hooked fish. It still happens, but not where near the extent of dragging bait on Kahle hooks. This needs to be taken in to account in surveys and models.
I implore the fisheries council and NOAA to not reduce the recreational quota on fluke. Implementing such a drastic reduction based on flawed science will disenfranchise the entire recreational fishing community and they will lose whatever support remains. The result is people will simply keep what they want and the biomass will certainly suffer.
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