MALIGNING MRIP FOR FUN AND PROFIT PART II: FOR PROFIT, FULL COOLERS, AND POLITICAL GAINS

Last Thursday, I described how the Marine Recreational Information Program, which the National Marine Fisheries Service uses to estimate recreational effort, catch, and landings, has become the favorite punching bag for anglers, the angling industry, and the angling press, who blame it for every tightening of recreational fishing regulations, without ever bothering to take the time to figure out how MRIP actually works.

Today, we’ll look at a more cynical group of MRIP critics, the organizations, industry spokesmen, and politicians who have at least a basic understanding of MRIP’s workings, yet continue to pour out unjustified criticisms in an effort to undermine the federal fishery management system and so generate higher recreational landings, greater short-term profits, and more political support.

The situation has existed for quite a while, well before MRIP even existed.  Back then, recreational data was generated by something called the Marine Recreational Fishing Statistical Survey, or “MRFSS,” which really was badly flawed; MRIP was only developed after a National Academy of Sciences report revealed how bad MRFSS actually was.

MRIP, on the other hand, received a mostly favorable review from a similar National Academy of Sciences panel before it was adopted as NMFS' standard data-gathering tool.

That doesn’t mean that MRIP doesn’t have flaws.  There is unavoidable uncertainty in every estimate that MRIP produces, with such uncertainty higher in estimates based on a smaller number of samples.  And last year, NMFS did discover that anglers were unintentionally entering inaccurate data into the Fishing Effort Survey, which has probably inflated effort estimates, and so estimates of catch and landings.

But those problems are being addressed, the former with guidelines for the proper use of MRIP data, particularly data derived from very limited samples, the latter with a multi-year program that will determine the extent of the issue and develop a workable fix.

However, entities seeking to undercut the the fishery management system for their own gain are always quick to jump on any real or imagined flaw in order to advance their arguments that they system is  broken.  Thus, it was hardly surprising to see Ted Venker, Vice President of the Coastal Conservation Association, perhaps the largest “anglers’ rights” group in the country, place an article on the Sport Fishing website which began,

“When NOAA Fisheries announced that yet another major flaw had been discovered in its recreational data collection program, called the Marine Recreational Information Program—Fishing Effort Survey (MRIP—FES), it didn’t come entirely as a shock.  After all, this data system that NOAA uses to estimate recreational (rec) catch and effort on various species has been reworked three times in the last 13 years and has been labeled ‘fatally flawed’ by the National Academies of Sciences.  It is known for producing results that leave rational people scratching their heads.”

Such comments are dishonest and intentionally deceiving on multiple levels.  They conflate MRFSS and MRIP, implying that there is no difference between the two when, as noted above, MRIP was designed as a replacement for MRFSS that addressed the older survey’s shortcomings and represented a substantial improvement over its predecessor.  It was MRFFS, not MRIP, that was deemed ‘fatally flawed.”  MRIP estimates were first used in 2017, and so clearly could not have been “reworked three times in the last 13 years.”  And it was particularly misleading to start off with the statement that “yet another major flaw has been discovered [emphasis added],” in MRIP, since the issue with the Fishing Effort Survey represents the first time that MRIP has run into any sort of systemic hitch.

But such misstatements are to be expected in an opinion piece that is intended not to enlighten, but to misdirect readers into taking the author’s preferred political path.

Why would the representative of a major anglers’ rights group provide such less-than-forthright information?  For those attuned to fisheries politics, the answer is right in the accompanying photo, which shows six presumably recreational fishermen posing with a bunch of dead red snapper.

For at least the past 15 years, the Coastal Conservation Association and allied industry groups, currently gathered together under the umbrella of the Center for Sportfishing Policy, have defended anglers’ chronic overfishing of red snapper in the Gulf of Mexico, demanded a larger share of the overall landings, and attacked federal fishery managers and the management system for denying their demands.

Their ultimate goal is to replace MRIP with state data-gathering systems, which often return lower landings estimates and thus allow managers adopt more liberal recreational regulations.  The Sport Fishing article, which concludes that

“This latest break in the federal fisheries management system offers a brief window of opportunity to et out of this repeating, dysfunctional cycle, and it is up to anglers to motivate their states agencies [sic] and elected officials to seize it,”

makes that goal perfectly clear.

At the same time, when it comes to MRIP, the anglers’ rights crowd finds itself whipsawed.  It’s easy for them to criticize MRIP when estimates of high landings lead to more restrictive regulations.  But in many cases, not only in the Gulf of Mexico, but also in management actions like the Mid-Atlantic Fishery Management Council’s Summer Flounder, Scup, and Black Sea Bass Commercial/Recreational Allocation Amendment, the higher MRIP landings estimates resulted in fishery managers increasing recreational allocations while reducing the commercial sector’s share of fish landings.

When that happens, you never hear spokesmen for the recreational fishing industry or the anglers’ rights groups saying that the MRIP numbers are wrong.  Instead, they defend the reallocation, even if that means going to court, as it did in the case of red grouper in the Gulf of Mexico.

Thus, even in the midst of Venker’s screed against MRIP, we find the following:

“The agency confessed a couple of months ago in a series of dramatic conference calls with Congress, Councils and stakeholders that its data program is overstating recreational effort by 30 to 40 percent, and the more cynical among us were somewhat expecting it.  As the latest iteration of the rec data system, the MRIP-FES was driving corrections in the allocation of allowable catch to the rec sector in some prized fisheries.  NOAA Fisheries is loath to reallocate fisheries under any circumstances, and being forced to correct its allocation in favor of the rec sector because of its own data system was undoubtedly a bitter pill for a commercially oriented agency to swallow.”

Thus, at the same time that he was blasting NMFS for maintaining MRIP, and blasting MRIP for overstating recreational effort, Venker was hinting that NMFS’ announcement of errors in MRIP estimates was a predictable effort by the agency to minimize reallocations of fish to the recreational sector, intimating that NMFS might have either fabricated, or overstated the extent of, the alleged error in order aid the commercial fishing sector.

Thus, the reader is led to Venker’s preferred conclusion that no matter what NMFS does, if its actions lead to either more restrictive recreational regulations or reduced recreational landings, such actions can only be based on bad data, bad intentions, or both.

Thus, the effort to undermine federal fisheries management proceeds.

The recreational fishing industry, represented by the Center for Sportfishing Policy, the American Sportfishing Association, and the National Marine Manufacturers Association, has also used the error discovered in the Fishing Effort Survey to seek alternatives to MRIP.  As part of such criticism, such organizations reveal the reasons for their concerns, noting that

“using incorrect recreational estimates to inform the status of fisheries and make management decisions could have severe implications for fish stocks, anglers, businesses, communities and the economy.”

There’s little doubt that, in their eyes, the implications for “businesses…and the economy” prevail, as along with endorsing the strategy of replacing MRIP with state data programs, such organizations endorse “alternative management” which will

“(1) provide stability in the recreational bag, size, and season limits; (2) develop strategies to increase management flexibility; and (3) achieve accessibility aligned with availability/stock status.”

It’s significant to note that all three points enhance anglers’ ability to keep and kill fish; none prioritize maintaining fish stocks at healthy and sustainable levels.

That emphasis also comes through loud and clear in legislators’ criticisms of MRIP and the federal management system.

Last month, 24 federallegislators, led by Rep. Garret Graves (R-LA) and Sen. Roger Wicker (R-MS) senta letter to NMFS complaining about the agency’s continued use of MRIP and itsfailure to adopt the data developed by state fisheries agencies and other non-federal sources.  Not surprisingly, given that both legislators come from states bordering the Gulf of Mexico and frequently work with and receive meaningful support from the Center for Sportfishing Policy, it’s hardly surprising that they repeat the same arguments made by that organization and its affiliates, and provide the same lack of objective support for their claims, and use some of the same misleading arguments.

For example, the letter complains that

“MRIP-FES estimated that recreational anglers landed a staggering 1.6 million pounds of gag grouper in the Gulf of Mexico in 2023, prompting concerns that reactionary management measures will follow.”

Yet that’s just not true. 

A quick look at NMFS’ “Recreational Fisheries Statistics Queries” website will show that anglers landed an estimated 954,650 pounds of gag in 2023, not 1.6 million.  The only way that the estimate might be inflated to something close to 1.6 million pounds is to consider the uncertainty inherent in the estimate, and assume that landings were at the upper extreme of the possible range.  Even that only gets you to 1.5 million pounds, not 1.6.  Andd if the legislators want to argue that the landings could have been as high as 1.5 million pounds, they should also admit that, given the lower end of the confidence interval, landings may also have been as low as 380,000 pounds.

Similarly, the letter states that

“This fishery exists almost exclusively in Florida in the Gulf, and thus can reasonably be compared to the Florida State Reef Fish Survey—which estimated only one-seventh, or about 15 percent, of the federal estimate.  Notably, the percent standard error (PSE) for the MRIP FES surveys ranged from thirty-three to ninety-eight percent.  By NMFS own admission, data sets with PSEs beyond 30 percent should only be used with caution.  Said another way, these data from MRIP-FES are worthless and should not be used to inform management decisions.”

That argument is flawed from more than one perspective.

First, the key MRIP datum used to set regulations would be the point estimate of 954,650 pounds (readers should note that a recent change to the fishery management plan will require the use of Florida’s State Reef Fish Survey data to gauge private vessel landings, rather than MRIP, going forward, although NMFS’s data will still be used for shore-based anglers and for-hire vessels), which had a percent standard error of 30.7, very slightly over the level subject to NMFS’ cautionary warning.

One only begins to see excessively high PSEs when the data is broken down by mode (e.g., shore, charter, etc.), state, and 2-month “wave,” at which point the percent standard error for data relating to shore anglers in Florida during September and October is, in fact, 98, while the PSE for Alabama charter boats during the same period is 83.1.  With respect to such high PSEs, NMFS advises

“MRIP does not support the use of estimates with a percent standard error above 50 and in those instances, recommends considering higher levels of aggregation (e.g., across states, geographic regions, or fishing modes).”

Thus, the letter’s reference to a PSE of 98, while technically true, is also a red herring, as using such estimate would constitute a misuse of MRIP data.  Using the MRIP data properly, which would mean basing management measures on the aggregate estimate of 954,650 pounds, and perhaps adding a buffer for management uncertainty, in case the actuallandings were substantially higher.  When used in that manner, the MRIP data would be far from “worthless.”

Perhaps more to the point, while the legislators’ letter and associated press release were quick to criticize the use of data with a PSE in the low 30s, and repeatedly referred to state data surveys as

“more exact,”

“better and more precise,”

“the best availabler science,”

and

“more precise, accurate, and timely”

(the “timely” comment is undoubtedly true), nowhere do the legislators provide the PSEs associated with state landings estimates to support their claims.  Instead, like the various organizations that such legislators consult with and represent, they present naked claims of state superiority but provide no objective evidence to support their claims.

Instead, it would appear that, like the various industry organizations, the legislators prefer state data because state estimates tend to be lower and allow more relaxed regulations.  Such motivations are made clear in statements made by both Sen. Wicker and Sen. Ted Cruz (R-TX), with the former stating that

“It’s up to the federal government to listen, incorporate states’ data, and, in turn, give Mississippi anglers more chances to catch red snapper [emphasis added],”

while the latter commented that

“Not utilizing state-led fish surveys…hampers both economic and recreational opportunities for Texas fishermen and the entire nation.  [emphasis added]”

It’s probably notable that neither senator asserted that using state data would reduce the likelihood of overfishing, make it easier to rebuild overfished stocks, or better maintain healthy, sustainable fish stocks in the long term, since it’s likely that, for such legislators no less than for the various industry and anglers’ rights organizations that they represent, such considerations are not among their highest priorities, if in fact they are priorities at all.

It's all about increasing harvest and economic gain (and, most likely, the votes and campaign contributions that might be engendered should such increases occur).

But all that is typical of MRIP critics, whenever and wherever they might make themselves heard. 

Instead of seeking to improve a valuable fishery management tool that, if used correctly, could help managers to maintain the healthy fish stocks that are essential to maintaining sustainable fisheries in the long term, they seek to discredit MRIP and federal fishery managers, in favor of state programs of uncertain—and certainly unspecified—precision, in order to increase landings and profit regardless of how that might impact the stock.

MRIP is imperfect, and still needs some work, yet it nonetheless comes closer to perfection than do its usual critics, who seem driven by little more than the chance to kill more fish, make more money, or enjoy other, similar personal gains.