Sunday, April 6, 2025

BLACK SEA BASS MANAGEMENT: WHY BOTHER TO COMMENT?

 

On April 3rd, the National Oceanic and Atmospheric Administration, the parent agency of the National Marine Fisheries Service, published a notice in the Federal Register announcing 2025 recreational management measures for the northern stock of black sea bass.

The notice notes that

“The [Mid-Atlantic Fishery Management] Council and the [Atlantic States Marine Fisheries] Commission’s Summer Flounder, Scup, and Black Sea Bass Management Board (Board) meet jointly each year to recommend recreational management measures for all three species, generally set for two years, so that recreational harvest achieves, but does not exceed, the recreational harvest targets specified by the Percent Change Approach adopted in the Harvest Control Rule Framework…Black sea bass recreational management measures were previously only set for 2024 due to a delayed stock assessment.  This action proposes the recreational management measures for only black sea bass and for only the 2025 fishing year.

“…The Council and Board recommend status quo recreational black sea bass measures for 2025, including the continued use of conservation equivalency, with regional measures expected to achieve, but not exceed, the harvest target.  A status quo approach for 2025 complies with Framework 17 [the Percent Change Approach] given that the 2025 catch and landings limit were not set “in response to updated stock assessment information” and instead were left unchanged…According to the most recent stock assessment, the biomass of black sea bass remains well above the target and overfishing is not occurring.  Black sea bass measures are being set for only one year as an updated management track assessment is expected to be available later this year and will be used to inform specifications and recreational measures for 2026 and beyond.  Therefore, the Council and Board recommended that recreational measures remain unchanged in 2025.  [citations omitted]”

While those paragraphs pretty well outline what NMFS, and more particularly NMFS’ Greater Atlantic Regional Fisheries Office, plans to do, it leaves much unsaid and, when all the facts are considered, seems almost intended to conceal relevant facts, rather than to reveal them.  

While the first paragraph was fairly straightforward, the second was, in many ways, not at all forthcoming.

Take, for example, the statement that “A status quo approach for 2025 complies with Framework 17 given that the 2025 catch and landings limit were not set “in response to updated stock assessment information.”

That statement is objectively true, but…

Why wasn’t the 2025 catch and landings limit not set “in response to updated stock assessment information”?

It wasn’t because either the Council of NMFS lacked a stock assessment to respond to.  In fact, they had two stock assessments available.  One was a so-called research track stock assessment, which employed a new population model that could better incorporate some of the more challenging characteristics of the black sea bass stock.  The other was a management track stock assessment, based on the methodology used in the research-track assessment.  

After reviewing the management-track assessment, a peer-review panel wrote

“The Panel concluded that the [Terms of Reference] had been met and the assessment is sufficient for providing catch advice.  This assessment is the first to implement the many changes in the recently completed Research Track.  Changes include the use of a single model that allows for migration between northern and southern areas, estimation of fleet specific fishing mortality in both areas, and use of an integrated measure for relative abundance from the VAST model.  The new projection methodology I [the Woods Hole Assessment Model used in the assessment]…is thought to provide a more valid characterization of future uncertainty…” 

The peer-review panel also explicitly stated that

“The assessment represents Best Scientific Information Available (BSIA) for this stock for management purposes.”

So the Council and Management Board were given a bright, shiny new tool to use to manage black sea bass.  According to the peer-review panel, that tool could do things that the tools used before just couldn’t do, and it also constituted the best scientific information available, which was a very important consideration, because National Standard 2, a critical part of the Magnuson-Stevens Fishery Conservation and Management Act, requires that

“Conservation and management measures shall be based upon the best scientific information available.”

The only thing is, neither the Council nor NMFS nor the regional office nor the Management Board wanted to use it. 

Despite the peer-review panel’s favorable review, despite the likelihood that the new assessment was more accurate than those that went before, due to how it addressed severable variables, and despite the fact that the new management track assessment represented the best available scientific information,the Management Board and the Council and NMFS chose to ignore it, and instead rely on an older assessment that gave rise to the existing regulations.

Why would they do that?

Apparently, because the new stock assessment would have required a reduction in black sea bass landings.  (Although it probably should be noted that, in issuing the 2025 management measures, NMFS and the Greater Atlantic regional office didn’t completely ignore the latest stock assessment; they were more than willing and happy to note that “According to the most recent stock assessment, the biomass of black sea bass remains well above the target and overfishing is not occurring,” which was true.  NMFS and the regional office only chose to ignore those parts of the new assessment that didn’t support their preferred narrative, that previous harvest levels should remain unchanged.)

Yes, there were various state managers who did not understand why the new assessment projected a decline in recruitment, when recruitment had been consistently robust in recent years.  That issue certainly merits investigation.

But what no one—no one at all—questioned was the new assessment’s calculation of the target biomass—that is, the biomass needed to support maximum sustainable yield—was about 11,225 metric tons, roughly 20 percent smaller than the 14,092 metric ton biomass calculated by the older assessment.

Nor did they question the new assessment’s conclusion that the maximum sustainable yield for the black sea bass stock—the level of landings that the stock could produce over an extended period—was just 3,649 metric tons, nearly 24 percent below the 4,773 metric tons previously calculated.

No one appeared to doubt that the black sea bass stock was less productive than previously believed.

But they just chose to ignore the fact, because black sea bass remained abundant, and many state managers just seemed afraid of the public reaction if they followed the scientific advice and reduced the acceptable biological catch, and thus the various catch limits, by 20 percent.  That fear was conveyed in the ASMFC’s summary of an August management meeting, which noted that

“With biomass currently more than double the target level and overfishing not occurring, it is challenging to communicate the conservation need for a 20% reduction in the [acceptable biological catch]”

And thus they didn’t even try.

After all, why try to engage in a challenging conversation, just because the best scientific information available strongly suggests that it’s the right thing to do?  

Instead, various state fisheries managers fretted about upsetting stakeholders, asking “how do we go back to stakeholders” with news of a landings reduction, worried that they were “at great risk of alienating our many stakeholders,” and declaring, despite the findings of the most recent stock assessment, that “this one [landings reduction] doesn’t make any sense.  The tone, if not the precise language, were reminiscent of parents worried about how to tell their spoiled child that he could not have any ice cream for breakfast.

The Management Board led the charge to ignore the scientific advice.  They can do that sort of thing, and have done it before, because the ASMFC has absolutely no legal obligations when managing fish stocks.  It can allow overfishing to continue unabated, it can allow overfished stocks to languish, and it can ignore the most compelling scientific information, and have no accountability at all.  Thus, when a motion was made to keep the 2024 black sea bass management measures in place throughout 2025 was made and seconded, it passed with few dissenting votes.

The Council dutifully made the 20 percent cuts, as Magnuson-Stevens required, but NMFS Greater Atlantic regional office would soon willingly undercut that statute with some active bootstrapping and some creative interpretations of the law.

NMFS and the regional office cited a regulation that reads,

“If the total catch, allowable landings, commercial quotas, and/or RHL measures adopted by the ASMFC Summer Flounder, Scup, and Black Sea Bass Management Board and the [Mid-Atlantic Fishery Management Council] differ for a given fishing year, administrative action will be taken as soon as possible to revisit the respective recommendations of the two groups.  The intent of the action shall be to achieve alignment through consistent state and Federal measures such that no differential effects occur to Federal permit holders,”

to justify the decision to violate National Standard 2 and ignore the best scientific information available, and instead conform its decision to that of the Management Board, and argued that the regulation

“require the Regional Administrator to take administrative action to align measures to prevent differential effects on Federal permit holders.”

But that is an apparent overstatement of what the regulation requires, as various sources define “revisit” as

“to consider or take up again” (Merriam-Webster),

“to talk or think about something again, with the intention of improving it or changing it” (Cambridge Dictionary),

or

“to return to an idea or a subject and discuss it again” (Oxford Learner’s Dictionaries).

The one common theme in all of those definitions of the verb “revisit” is that they all embrace the concept of returning to a topic, and reconsidering it, perhaps with the hope of improving or changing a preexisting condition, but none of those definitions suggest in any way that “revisiting” a previous decision or action requires that, after due consideration, any changes must be made.

Thus, NMFS’ and the regional office’s suggestion that the agency was required to conform its regulations to the Management Board action, and in so doing violate a very clearly stated provision of Magnuson-Stevens, is on as shaky factual ground as are a number of their other statements regarding black sea bass management.  

Similarly, NMFS’ and the regional office have taken the position that language in Magnuson-Stevens which requires “Each Council” to set annual catch limits no higher than the level recommended by that Council’s Scientific and Statistical Committee only binds the regional fishery management councils, and does not prevent NMFS from ignoring the Committee’s advice and setting an acceptable biological catch higher than the SSC recommendation (in the case of black sea bass, the Council’s SSC recommended setting the ABC 20 percent below what it had been in 2024, but NMFS and the regional office ignored that advice and maintained the ABC at its 2024 level, apparently believing that, while the Council cannot ignore the best scientific information available, the agency and its regional office may do so with impunity).

The end result is that the 2025 acceptable biological catch, annual catch limit, and related specifications (e.g., sector annual catch limits, commercial quota, recreational harvest limit, etc.) are all substantially higher than they should be, and higher than they would be had the advice in the latest stock assessment been followed.

Which leads us back to the initial question:  Why bother to comment on proposed management measures that NMFS and the regional office seem Hell-bent on adopting, regardless of what anyone else might believe?

Although I hate to say this, because I am a firm believer in participating in the management process and making everyone’s views known, in the case of black sea bass, I believe that there is no point in commenting at all.  Fisheries managers in most states, at the ASMFC, and at NMFS and the regional office seem determined to maximize landings, regardless of whether that is consistent with the best scientific advice.

Why?

I can only speculate that, at this point, fisheries managers have been so beat up by the constant whining and complaints, and just plain frequent bullying from representatives of the for-hire fleet and others in the recreational fishing industry that they’ve developed a sort of Stockholm syndrome with respect to the black sea bass fishery.

“Stockholm syndrome,” you may recall, is a term used to describe a seemingly irrational affinity that captives sometimes feel for their captors.  It got its name from a 1973 incident in which a former convict took four persons hostage in an effort to use them as leverage to free a friend from prison, and held them captive in a bank vault for six days.  After their release, none of the hoastages would testify against their former captors, and instead raised money to aid in their captors’ defense.  The former hostages apparently felt that law enforcement took irrational actions that threatened the hostages’ well-being, while the captors, who ultimately chose to release the hostages, acted more rationally, and so earned the hostages support.

It's not hard to draw an analogy between the hostages and fisheries managers who, beset at meetings by hordes of fishing boat crew and other persons, when even the completely sober folks in the crowd (which description, unfortunately, does not apply to everyone who attends such events) jeered and catcalled and insulted the professional managers, who were forced to support regulatory actions that were mandated by Magnuson-Stevens, but did not seem completely necessary given the temporary abundance of the black sea bass resource.  

Under such circumstances, it might not be surprising that the mangers became willing to ignore the science and the law, and to side with their critics in the hope that the chronic complaints and criticism might be, if not ended completely, at least be substantially reduced.

Regardless of the reason, it is just about certain that NMFS is intent on maintaining status quo regulations in 2025, regardless of what comments the public might make, and that making any comments at all would be a waste of time. 

Accepting that, the question becomes:  Can we believe NMFS when it says that “an updated management track assessment is expected to be available later this year and will be used to inform specifications and recreational measures for 2026 and beyond”?

I wish I could believe that, but given the experience of the 2025 assessment, I have serious doubts.

After all, in December 2023, the Summer Flounder, Scup, and Black Sea Bass Monitoring Committee advised the Council and Management Board against implementing the 10 percent reduction in recreational black sea bass landings supposedly mandated by the Percent Change Approach, because  that approach was designed to work with an updated stock assessment, and the planned 2023 management track assessment was never completed.  Instead, the Monitoring Committee recommended that status quo regulations be maintained, until the 2024 stock assessment provided a better idea of the stock’s status.

But when the 2024 stock assessment was completed, and seemed to require a 20 percent reduction in landings, a number of Monitoring Committee members recommended status quo once again, because they were unwilling to accept the assessment results.

So what does that bode for the 2025 management track assessment, once it is released?

If the results of the 2025 assessment rebut those of the 2024, there is little doubt that managers will take the new and better news as gospel, and after more than  a few “I told you so”s, will happily go about their business of maintaining high black sea bass landings.  And that scenario is certainly possible.

But it’s also possible that the 2025 assessment will tell a very different story.  After all, at least where I fish off Long Island (and from what people have told me, both north and south of Long Island as well), black sea bass numbers seemed to be down in 2024.  When we passed over a wreck, we no longer saw the towering schools of black sea bass rising from the ocean floor to 30 or more feet above the bottom, and most of the fish that we caught were disappointingly small, a continuation of the steadily shrinking size of the fish that we’re catching over the past decade or so.

Black sea bass benefit from a warm ocean, with the size of each year class determined not by the initial success of the spawn, but by the water temperature at the edge of the continental shelf, where young-of-the-year fish spend their first winter.  Warm, saline water tends to produce big year classes, while colder water reduces the young fish’s survival.

Last year, we observed water temperatures that were far lower than we normally see.  I had surface temperatures south of Fire Island in July that were six to eight degrees Fahrenheit cooler than what I typically see, and divers noted that bottom temperatures off Long Island were unusually cold this year.  I don’t know when the warm water started or when it ended, but it’s not at all impossible that black sea bass spawned in 2023 and/or in 2024 could have felt its effects.  If that happened, the worst case might be that we’re looking at a stock that has seen high fishing mortality removing most of the older, larger individuals, while cold water resulted in a smaller number of young fish recruiting into the population.

If the 2025 stock assessment reflects such a worst-case scenario, and shows a decline in the black sea bass population, will managers be willing to make the necessary cuts in recreational landings, which may at that point be well over 20 percent?

Or, assuming that the worst-case scenario doesn’t happen, and the 2025 stock assessment merely confirms the results of the 2024, and demonstrates that a 20 percent reduction really is needed, will managers finally concede and do what needs to be done?

I can’t confidently answer either of those questions in the affirmative.  

Black sea bass management no longer seems to have firm roots, whether those roots might take the form of a stock assessment or even just of a management plan.  Ever since 2019, black sea bass managers have, in every year but one, sought ways to avoid making the landings reductions called for by the standards and methodologies spelled out in their management plans.  Managers seem wedded to the status quo, regardless of what the data, the science, or the management plan might suggest.

I’ve already decided that they have no intention of considering public viewpoints that might differ from their own.

And I have a gnawing fear that they might not consider the findings of the 2025 assessment, either, if those findings contradict the status quo.

 



 

 

 

 

 

 

Thursday, April 3, 2025

STRIPED BASS ADDENDUM III CONTINUING TO TAKE SHAPE

 

This morning, the Plan Development Team charged with drafting the proposed Addendum III to Amendment 7 to the Interstate Fishery Management Plan met for over three and a half hours, and made some important decisions on what the initial draft addendum will look like.

To get the big question out of the way first, if we keep regulations just the way that they are, and don’t touch the commercial quota, the stock may not fully rebuild by 2029, although it will probably come close. 

If the fishing mortality rate for the years 2026-2029 averages out at 0.122, the rate needed to provide a 50% chance that the stock is fully rebuilt, that’s exactly what we end up with—a 50% chance of rebuilding.

On the other hand, if the fishing mortality rate for those years averages out just a hair higher, to 0.123, the actual fishing mortality rate for 2024, it is slightly more likely than not that the stock won’t fully rebuild, with only a 48.7% chance of rebuilding (that calculation assumes a “normal distribution” of statistical values, while another calculation using a “skewed distribution” only finds a 43.6% likelihood of rebuilding; given that my degrees are in History, English, and Law, and that I avoided any class resembling math after freshman year Calculus, I have no idea what the technical differences between the two distributions are, and so can’t explain them to you, although the words “normal” and “skewed” seem to tell at least a small part of the story).

The Striped Bass Technical Committee recommended that the Plan Development Team use the assumption that the fishing mortality rate for 2026-2029 will be 0.123 when drafting Addendum III, so at least on paper, spawning stock biomass will probably fall a little short of its target by the end of 2029.  

I know a lot of folks won’t be happy with that—I know that I’m not particularly pleased—but the truth is that it’s impossible to craft meaningful management measures that will cut landings by just 1.3%--the data just isn’t that precise, and a 1% change would be lost in the statistical noise.

In fact, the Technical Committee said that any reduction of less than 10% would be “statistically indistinguishable from the status quo.” And that turned out to be an important statement, which I’ll discuss in a while.

But first, I need to point out that, in developing Addendum III, the Management Board doesn’t have to stick with its usual 50% probability of successful rebuilding.  At the last Management Board meeting, Chris Batsavage, a North Carolina fishery manager, asked that the Technical Committee also come up with management measures that have a 60% chance of fully rebuilding the stock by the end of 2029.  Using the same set of assumptions that led to the conclusion that the stock would not quite rebuild if no management measures were changed, the Technical Committee found that removals would have to be reduced by 7% to have a 60% probability of rebuilding by 2029.

The Plan Development Team will be including management options that will achieve that 7% reduction in its first draft of Addendum III.

But…  Remember the Technical Committee comment that anything less than a 10% reduction will be “indistinguishable from the status quo?”

The Plan Development Team will also develop management options that will reduce removals by 10%, and have a greater than 60% probability of rebuilding by the end of 2029.  Because the Management Board didn’t ask the PDT to do so, the 10% reductions won’t be included in the initial draft of Addendum III, but will instead be presented to the Management Board in a separate memorandum.  That way, if the Management Board wants to consider a 10% reduction, it only needs to instruct the Plan Development Team to include the already-prepared 10% options into the draft addendum when the Board meets again in May.

We don’t know what measures to reduce removals by 10% might look like, but this morning’s meeting provided some clues about what those attaining a 7% reduction might be.

The first question is who would have to take the reductions. 

For many years, the Management Board imposed seemingly symmetrical reductions on both the recreational and commercial sectors, which required the same percentage reductions of both.  In reality, the reduction’s weren’t symmetrical, as the recreational cuts were from actual landings, while the commercial cuts were from quota, and since commercial landings often fell far below state quotas, the cuts to cuts landings were far less; sometimes, a state's commercial landings were  not cut at all.

That all changed with Addendum II to Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass, which called for anglers to cut their landings by 14%, but only required a 7% cut in commercial quotas, a reduction so small that Maryland commercial fishermen could have actually increased their landings in 2024, because they were so far below quota the year before.

The initial draft of Addendum III will carry on that tradition, and offer three options:  Reducing both commercial quota and recreational removals by 7%, reducing recreational removals by 8% while leaving the commercial quota unchanged, and a third, bizarre option, which has appeared in previous draft management documents, that would multiply the necessary 7% commercial reduction by the commercial sector’s 11% share of overall fishing mortality, and so only cut the commercial quota by 0.8% while reducing recreational removals by 8%.

Although the Management Board still needs to decide, it’s probably a good bet that all three options will appear in the draft amendment that is finally released for public comment.

The next question is how any reductions will be achieved.

Commercial reductions are fairly straightforward, with the quota cut by the agreed-upon amount.  But when it comes to cutting recreational removals, things get complicated.

Given that anglers can already retain no more than one fish, the bag limit can’t go any lower, and certainly won't increase in Addendum III, so size limits and seasons will become the only available management tools.

In the ocean fishery, where the Management Board has already agreed not to consider the harvest of fish less than 28 inches long, or slot limits narrower than three inches, the size limit, too, is unlikely to change, as none of those considered would achieve even a 7% reduction in removals.  

That’s because the current spawning stock biomass is skewed heavily toward larger fish, with the 2018 year class, which will fill the slot this year, the last of the larger year classes; every subsequent year class has been far below average.  So the 36-inch minimum size that served so well a generation ago, and is supported by many anglers today, would actually increase removals by 10%.  

Of the five alternative size limits considered for the ocean fishery, only two would decrease 2026 removals.  A slot limiting harvest to 31- to 35-inch fish would lead to a trivial 1% reduction, while a 40-inch minimum size would reduce recreational removals by 5%; neither would achieve the minimum 7% reduction needed for a 60% probability of success.  While it’s possible that Addendum III might couple a new size limit with a season, the fact that the Management Board has decided that no closed season may be shorter than two weeks makes it likely that the 28- to 31-inch slot will remain in place, and seasons will be the only tool used to reduce ocean landings—although that’s only my opinion, and not the PDT’s.

The picture in the Chesapeake Bay is a little different.  There, changes to the size limit can achieve a 7% reduction.  Moving the bottom end of the slot up an inch, to 20 to 24 inches, would cut recreational removals by 8%, while taking two inches off the top end of the slot, resulting in a 19- to 22-inch size limit, would almost double that, and reduce recreational removals by 15%.  Adopting the 19- to 22-inch slot for private boat and shore-based anglers, while leaving the current 19- to 24-inch slot in place for those fishing from for-hire vessels, would yield a slightly smaller, 14% cut.  The only minimum-size option, 22 inches, would reduce recreational removals by 10%.  

Any one of those choices could allow the current seasons to remain unchanged.

As far as possible seasons go, none have yet been calculated, although they will be soon.  However, two related issues were discussed at today’s meeting.

One was whether the seasons will be of the traditional no-harvest sort, or whether they will also ban targeting striped bass.  While I suspect options for both will be included in the draft addendum, anyone calculating no-target options must consider whether people who would have fished for striped bass will merely stop fishing during any closure, or whether they will switch to other species, but might accidentally catch bass during that time (a third scenario, that people will keep fishing for bass, but say that they’re fishing for something else, was never explicitly discussed, although I have to believe that at least some people are thinking about it).

The other issue is whether, when establishing seasons, Addendum III ought to break the coast down into two or three regions, and what states such regions should include.  The ASMFC’s Law Enforcement Committee supported a two-region breakdown, with one region running from Maine to Massachusetts and the other from Rhode Island to North Carolina, as they felt it important to keep all of the states active in the Block Island fishery in a single region.  

However, the ocean fishery in the southern states can be very different from that on the rest of the coast, militating in favor of a three-region approach.  Should such an approach be adopted, the Law Enforcement Committee supported regions consisting of Maine through Massachusetts, Rhode Island through Delaware, and Maryland through North Carolina, for ease of enforcement in the Delaware Bay.

The Plan Development Team will also calculate how seasonal closures will impact the individual states in each region, to determine whether any one state shoulders a disproportionate share of the conservation burden.  While such action may seem reasonable on its face, it carries the risk that a state--say, perhaps, New Jersey--will try to use such calculations reintroduce conservation equivalency into the management process, and use it to wiggle out of the region-wide rules, so undercutting the rebuilding process.  Although Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass explicitly prohibits the use of conservation equivalency when the stock is overfished, the Management Board has the power to end that prohibition in Addendum III.  We can only hope that such power is never used.

Specific season-related proposals will be developed at future Plan Development Team meetings, and will be discussed in a future edition of One Angler’s Voyage.

Beyond that, the only topics discussed at today’s meeting were mode splits—providing special, more lenient harvest privileges for anglers fishing from for-hire vessels, which would not be shared by the shore-based and private boat anglers, who account for 98% of all directed striped bass trips—commercial tagging procedures, and creating a uniform way to measure striped bass.

Although I believe the first issue is the most important of the three, I can’t write much about it because my internet provider chose that point in the meeting to shut down, and couldn't be restored until the discussion was over.

The commercial tagging issue revolved around the question of whether commercially caught bass should be tagged as soon as they’re caught, or in any case, before being taken off the fisherman's boat, or whether it’s acceptable for them to be tagged at the point when they’re purchased from the fisherman.  

The Law Enforcement Committee generally preferred the former option, which is already in force in all states but Massachusetts, Rhode Island, and North Carolina, believing that tagging upon capture reducing highgrading (the practice of throwing back a smaller fish, that is often dead, and replacing it with a larger, more valuable individual) and increases fishermen’s accountability, although a small minority preferred tagging at the point of first sale, saying that it reduced the administrative burden associated with sending tags to all eligible fishermen, and made it less likely that a fisherman will pass tags to someone else to conceal a black market sale.

The measurement issue arose because some states don’t specify how a striped bass should be measured, which results in the slot size limit being applied inconsistently.  A Massachusetts representative suggested language that read

“Total length means the greatest straight line length in inches as measured on a fish with its mouth closed from the anterior most tip of the jaw or snout to the farthest extremity of the tail with the upper and lower fork of the tail squeezed together.”

It seemed a simple suggestion, but led to discussions about whether a fish should be measured flat, as it would lie on a measuring board, or along the curve of its body, as anglers often measure fish with a flexible tape.  There weere also discussions of whether the rack of a filleted fish would, if measured, be the same length as the fish was when whole.

No decisions were made on either of the last two issues, but significant progress was nonetheless made.  And this morning’s meeting was only the first of four that will lead to in the initial draft of Amendment III.

Before I close, I want to make one more point.

Often, I hear fishermen—whether recreational, commercial, or for-hire—attack proposed management measures with comments like “The data’s no good,” or “It’s MRIP [the Marine Recreational Information Program, used to estimate recreational catch, effort, and landings], and I just don’t believe it,” without really understanding what folks on the Technical Committee and Plan Development Team do to assure that the data used really does represent the best scientific information available.

This morning, there were two examples of what appeared to be “outliers” in the data, data points that deviated significantly from all of the others.  One was a seemingly anomalous spike in the number of 19-inch fish caught in 2019; the other was a similar spike in the number of live releases during March and April in Rhode Island in 2021. 

In both cases, the Plan Development Team addressed the outliers in great detail, using Technical Committee advice and other analysis to resolve the seeming incongruities.  As I noted at the beginning of this essay, I am not a statistician, and have no desire to become one.  However, to my layman's eyes, the analysis and the outcomes reached this morning appeared both comprehensive and logical, and I could only come away with the belief that the PDT was doing its best to assure that the data is relies on truly reflects reality.

And on that note, I will end.

The Plan Development Team will meet three more times before it prepares the first draft of Addendum III, on April 4, 9, and 10.  I hope to sit in on all of those meetings, and let you know what went on.  Right now, the draft addendum seems to be progressing fairly well, but it remains important for all concerned anglers to monitor the document’s progress, and do their best to assure that the process remains on track, and doesn’t get hijacked by one interest group or another.

Because, if history is any guide, someone will certainly try.