On May 1, the Mid-Atlantic Fishery
Management Council (MAFMC) released a
request for proposals “to evaluate the feasibility of
developing a fishing mortality (F) based management approach to the
recreational summer flounder fishery.”
Currently, summer flounder are
managed with a combination of bag limits, size limits and seasons intended to
constrain recreational harvest to, or below, the annual catch limit (ACL), and
thus prevent overfishing. There is no coastwide consistency in the measures
adopted; they regularly differ from state to state although, for regulatory
purposes, some states have been combined into two- or three-state regions.
In December of each year, the MAFMC
and the Atlantic States Marine Fisheries Commission’s Summer Flounder, Scup and
Black Sea Bass Management Board (Management Board) hold a joint meeting, where
estimates of the current year’s recreational harvest are compared with the ACL
for the upcoming season. Depending on whether such estimate is higher, substantially
lower or just slightly below the ACL, managers will either adopt more
restrictive regulations, relax existing rules or leave the current regulations
unchanged.
It is a system that should work in
theory but, in practice, leads to regulations that fluctuate wildly from year
to year. As noted by
James J. Gilmore, Director of the New York State Department of Environmental
Conservation’s Division of Marine Resources,
“There seems to be a poor relationship between the
recreational measures (derived from calculations based on MRIP) and the
performance (as estimated by MRIP). Regional summer flounder management has
been in place for the last 3 years (2014-2016). During this period regulations
adopted by each region have not changed…This strategy has provided regulatory
stability coastwide, which we have not experienced in many years. While this
stability is generally appreciated by fishermen, managers benefit as well by
having an opportunity to look at how capricious harvest and harvest estimates
can be. Under consistent measures there are numerous factors that may influence
recreational harvest in a state, with weather and fish availability to anglers
among the most important. Harvest estimates are in turn influenced by the
actual magnitude of harvest and the variability inherent in a survey (catch
sampling and the subsequent catch expansion). Under 3 years of consistent
regulation from 2014-2016, coastwide harvest estimates in numbers of fish have
ranged from 1.6-2.5 million fish, varying as much as 50% between years. When we
consider a smaller geographic scale, this variability increases to 66% between
years in the CT-NJ region, and an average of 133% at the individual
state level. It is difficult to say how much of this variability is
due to estimation vs. actual harvest magnitude.”
Such fluctuations in landings
estimates make it very difficult to craft regulations that protect the stock
from overfishing while still providing anglers a reasonable opportunity to
enjoy the summer flounder resource.
For the past few years, elements within
the angling community have suggested that “by managing the
recreational sector based on harvest rate as opposed to a poundage-based quota,
managers have been able to provide predictability in regulations while also
maintaining a healthy population.” The Atlantic States Marine Fisheries
Commission’s (ASMFC) striped bass management program is often cited as a
successful example of such an approach.
MAFMC seems to be buying into that
argument, for in its request for proposals, it said that
“An F-based recreational fishery management approach to
similar to [sic] that implemented by the Atlantic States Marine Fisheries
Commission Management Plan (FMP) for Atlantic Striped Bass could be explored or
used for comparison…Benchmark or update stock assessments monitor fishing
mortality and spawning stock biomass trends and relationship to the established
reference points. Depending upon the stock assessment results, if warranted,
regulatory changes are then made to reduce fishing mortality and promote stock
rebuilding.”
So exactly how would an F-based
management plan work? And could such an approach work for summer flounder?
To answer those questions, one must
first realize that managers are already using fishing mortality to manage
summer flounder. In itsreport to the
August 2016 meeting of the MAFMC, the Summer Flounder Monitoring
Committee (Monitoring Committee) explained that more restrictive regulations
were needed because “The fishing mortality rate (F) in 2015 was 0.390, 26%
above the fishing mortality reference point FMSYPROXY=F35%=0.309.”
In fact, the three ways of
calculating landings—fishing mortality, poundage and numbers of fish—are all
more or less interchangeable. Applying the target fishing mortality rate to the
biomass results in a hard-poundage quota; dividing that poundage-based quota by
the average weight of the fish caught provides a quota based on numbers of
fish. In the end, they’re merely three different terms that describe the same
amount of dead fish.
Thus, when MAFMC, and some of the
angling community, talk about “F-based” management, what they’re really talking
about is a different way of calculating recreational landings. Instead of using
the Marine Recreational Information Program (MRIP) to determine annual
landings, an F-based approach derives an estimate of recreational removals from
a stock assessment.
Such an approach has both benefits
and drawbacks.
There is little doubt that an
F-based approach would lead to more accurate estimates of recreational harvest.
In the current system, MRIP estimates provide the sole gauge of recreational
harvest; in an “F-based” system, MRIP estimates would be only one data source
among an array of fishery-dependent and fishery-independent surveys used to
calculate the health of the stock.
On the other hand, an F-based
management system depends on expensive, time-consuming stock assessments. The
stock assessment update used to establish 2017 summer flounder regulations was
based on data collected through the end of 2015. Managers augmented that update
with more recent commercial landings information and MRIP-based estimates to
determine how the stock fared in 2016.
In the sort of F-based management
system being contemplated by the MAFMC, the MRIP-based estimates would not
determine the next year’s regulations; instead, any changes would depend on
stock assessments using data that is, at best, a year old, and potentially much
older if the assessment isn’t updated on an annual basis.
That’s probably fine when dealing
with a fully-rebuilt stock, as a single year of modest overharvest—perhaps even
a couple of consecutive years—is unlikely to do significant harm to the population.
However, in the case of summer flounder, we’re dealing with a population that, according to
MAFMC’s Science and Statistics Committee, “is dangerously close to
being overfished, which could happen as early as next year if increased efforts
to curb fishing mortality are not taken.”
When dealing with a stock in that
kind of condition, which has already suffered from six consecutive years of
below-average spawning success, such stock could easily become overfished by
the time that managers, dependent solely on a stock assessment, discovered that
overfishing was taking place.
Striped bass, although often touted
as a good example of why F-based management works, actually illustrate why such
an approach is beset with problems.
About a decade ago, the striped bass
found itself in a situation very similar to that now facing summer flounder. Spawning success
was below average in four out of the five years between 2006 and 2010. In
response, the spawning stock biomass fell from around 78,000 metric tons (mt)
in 2003 to approximately 58.2 mt in 2012, just above the 57.6 mt
threshold that defines an overfished stock.
Fishery managers’ response to the
striped bass decline was very different from their response to summer flounder.
In the case of summer flounder, when landings exceeded poundage-based catch
limits, recreational regulations were immediately changed in an effort to
reduce harvest to sustainable levels.
In the case of striped bass, anglers
began expressing concerns for the health of the striped bass stock around 2007,
but since there was no poundage-based annual catch limit in place, managers
didn’t even consider any remedial action until a 2011 assessment
update warned that “Female [spawning stock biomass] will fall
slightly below the threshold by 2017.” At that point, the stock would be deemed
“overfished,” yet ASMFC’s Striped
Bass Management Board ultimately decided to take no immediate action,
because overfishing was not yet occurring and the
spawning stock biomass was not yet overfished.
So the decline continued. Action was
finally taken when a new benchmark
assessment was released in 2013, but even then,regulations
intended to address the stock’s problems were not put in place until 2015.
Today, the spawning
stock biomass remains a mere 1,200 mt above the threshold denoting an
overfished stock, and 13,000 mt below its target. Had striped bass
been managed with a poundage-based annual catch limit, the regulations needed
to halt the stock’s decline could have been adopted much sooner, and the
striped bass spawning stock probably would be in much better condition.
Thus, both anglers and fishery
managers would be wise to view any proposal to abandon annual catch limits for
summer flounder with skepticism, and question whether any F-based management
program can react quickly enough to detect and respond to further populations
declines in the stock.
They should also be leery of H.R. 2023, the so-called Modernizing
Recreational Fisheries Management Act of 2017, which explicitly
provides for the use of “alternative fishery management measures” in
recreational fisheries. As the MAFMC’s recent request for proposals
illustrates, current federal fisheries law already allows for F-based
management measures, but such measures must be “consistent with and [meet] the
Council’s requirements to implement Annual Catch Limits (ACLs) and
Accountability Measures (AMs) as mandated under the Magnuson Stevens Act.”
H.R. 2023 could eliminate such
requirements, and permit the use of alternative management measures with no
reference to ACLs or accountability measures at all.
Could such alternative management
measures work for summer flounder?
Perhaps, if the stock was at or
above target levels, and managers continued to update the assessment annually,
so that they could catch any change in stock status in a reasonably timely
manner.
But given that the summer flounder
stock is now at real risk of becoming overfished, the delays inherent in an
F-based system make it more likely that abundance could slip beneath the
threshold before anyone realized that overfishing remained a problem. That
makes abandoning a hard-poundage catch limit a bad idea at this time.
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This post originally appeared in "From the Waterfront," the blog of the Marine Fish Conservation Network, which can be found at http://conservefish.com/blog/
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