Recreational fishing catch, landings, and effort data has long been a controversial issue.
For many years, there was no reliable data at all. The National Marine Fisheries Service occasionally
put together some figures, but the methodology used was shaky, and relied far
too much on anglers’ memories of what happened as much as six months before.
Fishery managers recognized that they needed better data in
order to properly manage fish stocks, and thus the Marine Recreational Fisheries
Statistics Survey, better known by its acronym, “MRFSS,” was developed. MRFSS began collecting recreational data in
1981. The estimates that it generated didn’t cause much controversy until
the late 1999s, largely because they had little direct impact on the angling community. While scientists may have incorporated them
into stock assessments and other research, they did not play a major role in the
rulemaking process.
That all changed with the passage of the
Sustainable Fisheries Act of 1996 which, for the first time, required federal
fishery managers to prevent overfishing, promptly rebuild overfished stocks,
and manage marine fish in accord with the best available scientific information.
Before the 1996 Act, federal fishery management councils, more concerned with the short-term interests of the fishing industry than in the long-term health of fish stocks, tolerated overfishing and eschewed meaningful rebuilding programs in an effort to maximize economic returns.
After the Act was passed, they no longer had
the luxury of condoning profitable overharvest; the
Mid-Atlantic Fishery Management Council was embarrassed after its summer
flounder management measures, legally required to prevent
overfishing, were invalidated in a federal appellate court decision which noted
that
“The disputed 1999 [total allowable landings] had at most an
18% likelihood of achieving the target [fishing mortality rate]. Viewed differently, it had at least an 82%
chance of resulting in [a fishing mortality rate] greater than the target [fishing
mortality rate]. Only in Superman
Comics’ Bizarro world, where reality is turned upside down, could the [National
Marine Fisheries] Service reasonably conclude that a measure that is at least
four times as likely to fail as to succeed offers a ‘fairly high level of
confidence.’ [emphasis added]”
That decision put the NMFS, as well as the regional fishery
management councils, on notice that Congress, supported by the courts, was serious about conserving and managing the nation’s marine fish stocks. Business as usual, meaning the councils turning a blind eye to commercial and
recreational overharvest in the name of economic gain, would no longer be
tolerated.
The age of meaningful and generally effective federal
fisheries regulation had begun.
For the first time, the MRFSS estimates had a real-world impact on recreational fishermen who, for the first time, were going to be faced with regulations limiting the size and number of fish that they could take home.
MRFSS estimates would
be used to calculate those regulations.
Because both the recreational and commercial landings for all three of those species had to be constrained, the annual catch limit had to be split between the recreational and commercial sectors.
MRFSS estimates would be employed for that purpose, too.
In the mid-Atlantic region, three of the most popular
recreational species, summer flounder, scup, and black sea bass, were badly
overfished, and the regulations imposed to rebuild the stocks sharply cut into
the number of fish going into recreational fishermen’s bags, buckets, and
coolers.
The recreational summer flounder fishery was the first to feel the pinch of the new rules; affected members of the fishing industry quickly blamed MRFSS, along with the rest of the scientific data, for the more restrictive regulations.
An angling column in the Long Island, New York publication Newsday stated, in part,
“Its obvious to anyone who has been on the water this year
that fluke are not the decimated species some data suggests. It’s the data, particularly the 2003 Marine
Recreational Fisheries Statistics Survey (MRFSS), that is the basis for the
48.5 percent reduction. The numbers
collected that year are considered fundamentally flawed by many, yet as the
only recognized source of information for the Atlantic States Marine Fisheries
Commission, they have been used to establish policy.”
The Newsday piece was relatively mild compared to the
criticisms of MRFSS that emerged in some other outlets.
While some of that criticism was just sour grapes spewed by an angling industry unhappy about having to play by new rules, it also contained a real truth. MRFSS was, in fact, badly flawed.
“The MRFSS…should be completely redesigned to improve its
effectiveness and appropriateness of sampling and estimation procedures, its
applicability to various kinds of management decisions, and its usefulness for
social and economic analyses…
“…the current methods used in the MRFSS for sampling the
universe of anglers and for determining their catch and effort are
inadequate. Sampling of each group of
anglers (i.e., private, guided, head boat, charter boat) present challenges
that differ across the groups…Both onsite and offsite methods suffer from
weaknesses that may lead to biases in catch and effort estimation. Finally, the estimation procedure for
information gathered onsite does not use the nominal or actual selection
probabilities of the sample design and therefore has the potential to produce biased
estimates for both the parameters of interest and their variances.”
The National Research Council report led Congress to call for a
new, more accurate means of producing recreational fishing estimates. Thus, the Marine Recreational Information
Program, or “MRIP” was born.
“Work to redesign the National Marine Fisheries Service’s
recreational fishery survey program (now referred to as the Marine Recreational
Information Program) has yielded impressive progress over the past decade in
providing more reliable data to fisheries managers. Major improvements to the statistical
soundness of the survey designs were achieved by reducing sources of bias and
increasing sampling efficiency as well through increased coordination with partners
and engagement of expert consultants…
“The methodologies associated with the current Fishing Effort
Survey, including the address-based sampling mail survey design, are major
improvements from the original Coastal Household Telephone Survey that employed
random-digit-dialing to contact anglers…
“The new Access Point Angler Intercept Survey design [used to
interview anglers and record their catch] is a substantial improvement on the
MRFSS intercept survey methodologies…”
The bottom line seems to be that MRIP is a much more reliable source of recreational fishing data than MRFSS had been.
One
of the unexpected consequences of MRIP’s new Fishing Effort Survey was that,
when the recreational effort data (and thus, after calculation, the
recreational catch and landing data) was compared to that of MRFSS, it seemed
that anglers were fishing a lot more, and catching and keeping a lot more fish,
and that MRFSS had underestimated the number of fish that anglers removed from fish populations.
Viewed in a vacuum, that information didn’t mean very much.
There was some early panic that the new MRIP data
would mean that anglers were overfishing their allocations everywhere on the
coast, but that’s not how fishery management actually works. The fact that anglers had been catching more
fish, and still were catching more fish, than managers realized meant that there
must also be more fish in the ocean than managers had believed, and that as a
result, annual catch limits for many species could be increased.
In some cases, stock
assessments for striped bass and bluefish did show that, because recreational
catch and landings were higher than believed, such stocks had not only
experienced extended periods of overfishing (although bluefish
were not subject to overfishing in the terminal year of the most recent
operational assessment), but were also overfished. Yet the data cut two ways, for in the
most recent benchmark assessment for summer flounder, which many of us expected
to reveal an overfished stock, the MRIP data showed that the stock, while not
completely healthy, was not overfished at all.
Overall, MRIP’s new, higher estimates were not well-received
by those in the recreational community, and primarily those in the
recreational fishing industry, who habitually agitate for more permissive
fishing regulations. An
Advisory Panel report prepared by the Mid-Atlantic Fisheries Management Council
noted that
“Multiple advisors said they had no faith in the data
provided by the Marine Recreational Information Program (MRIP), which they see
as inaccurate and fundamentally flawed,”
and went on to describe multiple complaints about the
program.
However, the scientists who prepare stock assessments for
Mid-Atlantic Council-managed fish had no such qualms about the MRIP data.
They employed it in the benchmark assessment of summer flounder. As a result, spawning stock biomass was estimated to be 44,552 metric tons at the end of 2017, compared to an earlier assessment that found the SSB to be just 36,240 metric tons at the end of 2015.
After reviewing the
available data, including the MRIP data, the benchmark
assessment also found the summer flounder stock to be less productive than
previously believed, a finding which allowed managers to increase the threshold
fishing mortality rate, which defines overfishing, from 0.309 to 0.448, while
reducing the target spawning stock biomass from 62,394 metric tons to 57,159
metric tons. That
allowed the Council, in 2019, to increase the commercial quota to 11.53 million
pounds, and the recreational harvest limit to 7.69 million pounds, compared to
a 2018 commercial quota of 6.44 million pounds, and a recreational harvest limit of
4.42 million pounds.
The operational assessment for black sea bass, bluefish, and
scup, released the same year, also incorporated the new MRIP data.
Such operational assessment updated the spawning stock
biomass target for bluefish to 198,717 metric tons, a substantial increase from
the
111,228 metric ton target that prevailed in 2018. It was heavily dependent on MRFSS
estimates of recreational landings. It
also found the bluefish stock to be overfished, which resulted in a decrease in
the recreational and commercial catch limits.
In the case of black sea bass, the MRIP-influenced
operational assessment estimated the spawning stock biomas to be 33,407 metric tons at the end of 2018, about 240% of the newly-revised 14,092 metric ton
target, both of which figures were substantially higher than the
14,183 million pound biomass and 9,667 metric ton target predicted by a 2015 benchmark stock assessment.
As a result of the operational assessment’s findings, the
commercial black sea bass quota was increased from 3.52 in 2019 to 5.26 metric
tons in 2020, while the recreational harvest limit was increased from 3.66
metric tons to 5.48.
The Mid-Atlantic Council seemed completely willing to accept
the higher estimates of spawning stock biomass, the higher biomass targets, and
the higher catch limits that flowed from the new MRIP estimates.
However, something different occurred when it came to using
the very same MRIP estimates to constrain recreational landings. Suddenly, the MRIP estimates were surrounded
with doubt.
That
was particularly true in the case of black sea bass. Council staff advised
that
“…The impact of MRIP data on the stock assessment is one of
multiple factors which resulted in a 59% increase in the [recreational harvest
limit in 2020 compared to 2019. However,
because the new MRIP data show that black sea bass harvest is much higher than
previously thought, this increase in [recreational harvest limit] will not
allow for increased recreational harvest.
In fact, a 29% reduction in harvest compared to 2019 would be required
to prevent an overage…
“Given challenges associated with transitioning to management
based on the new MRIP data, high availability of black sea bass to anglers, and
a very healthy stock status, there may be a consideration that recreational
management measures remain unchanged in 2020 compared to 2019 to allow more time
to gradually transition to a management system that accounts for changes in the
MRIP system that accounts for new changes to the MRIP data. However, status quo recreational
management measures could result in an 18% [acceptable biological catch]
overage and a 7% underage of the overfishing limit (OFL). Given the [scientific and statistical
committee’s] concerns about uncertainty in the OFL, maintaining status
quo recreational measures could be too risky…
“…The 2017 year class was 72% below average. It cannot be assumed that future year class
strengths will be above average. Therefore,
it is not appropriate to assume that because the stock has maintained a high
biomass despite several past [acceptable biological catch] overages it will
continue to do so if 2020 catch exceeds the [acceptable biological catch]. For these reasons, maintaining status quo
recreational management measures in 2020 poses a conservation concern. [emphasis added]”
The staff comments seemed well reasoned, but the Summer Flounder, Scup, and Black
Sea Bass Monitoring Committee disagreed.
At
the December 2019 Council meeting, it recommended status quo regulations for
2020, and provided justifications that directly contradict Council staff’s
advice. Such contradictory statements
included
“Biomass has remained well above target despite multiple
years of [acceptable biological catch] overages,”
“May continue to see periodic above-average year classes with
mild winters,”
and
“Need for 20% reduction largely driven by MRIP change and
sector allocation, not a conservation need.”
The Council (as well as the Atlantic States Marine Fisheries
Commission’s Summer Flounder, Scup and Black Sea Bass Management Board, which
jointly approves black sea bass management measures) was fast to adopt the
Monitoring Committee’s recommendation for status quo rules. Council discussions included a number of comments
that questioned the MRIP data, and the accuracy of the estimates of high
recreational landings.
But the funny thing is, no one at the table, whether
they belonged to the Council or to the Management Board, raised a hand to
question the higher catch limits that were largely based on the same MRIP data
that they were unwilling to use to constrain recreational landings.
“ridiculous,” “impossibly high,” and “wrecking the management
process,”
but not a single one suggested that the same MRIP numbers
should not be used to increase the recreational catch limit.
I’m not a statistician, so I lack the technical
knowledge to know whether MRIP is badly flawed, although I find the National
Academy of Sciences report a very convincing reason to believe that it is
not.
After all, the Academy members who authored that report, unlike me, or the fishermen and vessel operators who make up most of the Council, do
have the training to know.
But whether those numbers are right or wrong, the Council
needs to come up with a consistent approach to MRIP, because right now, we’re
living in the worst of all worlds.
On one hand, the Council accepts the higher biomass estimates
that flow from the MRIP numbers, which in turn permit higher annual landings even
though, if the MRIP numbers are wrong, those larger catch limits could do real
harm to fish stocks.
On the other hand, the Council has, so far, been unwilling
to fully embrace the MRIP data, and use it to adequately constrain recreational
harvest to the higher catch limits that are based on the same estimates. That also can harm the stock.
Whether MRIP is right or wrong, the Council has a
consistency problem.
If it believes that the MRIP data is right, it needs to use
that data to craft recreational fishing measures likely to constrain landings
to or below the recreational harvest limit.
If it believes that the MRIP data is wrong, then it needs to
be consistent, and keep overall landings below the spawning stock biomass
targets established before such new MRIP data was incorporated in stock
assessments, because the new biomass targets are only as good as the MRIP data
they are based on.
Either way, it needs to find a logically consistent course.
Accepting the MRIP data when it provides greater landings,
and questioning it when it constrains the catch, is not the right way to go.
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