PROFIT AND LOSS

The summer flounder population is not in good shape.  

Recruitment—the number of new fish entering the population—has been below average for the last six straight years, and the size of the spawning stock has been steadily declining.

Professional fisheries biologists, who examined the most recent data, agree on those points.

However, a number of amateurs disagree. 

If you read the tripe being put out by various magazine editors, party boat captains, tackle industry reps and similar folks, you’d believe that the population is in perfect health, and that measures being imposed to keep the spawning stock from declining farther are some kind of sinister plot.

I’ve discussed some of their bullshit in recent essays, making me a little reluctant to take on summer flounder again, but a recent post on Facebook incorporates all of their specious arguments so well that it seemed worth discussing at least one more time.

It came, not surprisingly, from someone who works in the tackle industry down in New Jersey; both the industry and New Jersey have long been hotbeds of opposition to effective fishery management laws.  The beginning of the comment is telling, because it sets the stage for the rest.

“The following was written by our sales manager.  Please take a minute to read it.  The livelyhood [sic] of many people is in jeopardy.

“My name is Nick Cicero and I sit on the board of both the Save the Summer Flounder Fishery Fund and the Recreational Fishing Alliance.  However, my comments today are from the perspective of how the pending regulations will affect jobs and small businesses in New Jersey and East Coast…”

So we know right off the bat that the guy is a salesman, not a biologist.  And that his concern, from the beginning, is “how the pending regulations will affect jobs and small businesses,” not coincidentally including his, and not the health of the summer flounder stock.

Thus, when reading the rest of his comments, which often attack the accuracy and validity of the science used to assess the summer flounder population and set regulations, we have to remember at all times that they were written by a salesman, and not a biologist.  

We also should note that such comments were, by the author’s own admission, not written from the perspective of the health and needs of the summer flounder stock and that, despite the author’s professed concerns, they do not contemplate the effect on jobs and small businesses should the summer flounder stock continue to decline and fish become even less available.

The comments aren’t without some internal irony.  They lament

“Gone are the days when tackle shops and the for-hire fleet were busy year-round with anglers flocking to the shore to fish for Cod, Silver Hake, Red Hake, Winter Flounder and Boston Mackerel—all species that National Marine Fisheries Service and its regulatory initiatives has failed to restore to historically abundant levels!”

And he’s right—the New England Fishery Management Council, comprised primarily of fishermen who did not wish to impair the profitability of the groundfish fishery, ignored data that showed a decline in stocks of fish such as cod and winter flounder, and imposed inadequate regulations that led caused populations of both species to crash.

Yet, in his comments, the salesman is asking NMFS to ignore the scientific data addressing the decline in the summer flounder population, in order to preserve the profitability of the summer flounder fishery.

And while that salesman was willing to write long and vehement comments opposing further restrictions on the summer flounder fishery, a long search of Internet archives failed to reveal a similarly intense effort to place needed restrictions on the flounder and cod fisheries, to avert their impending collapse (I’ve been a member of the Atlantic States Marine Fisheries Commission’s Winter Flounder Advisory Panel since the late 1990s, and can assure you that I never saw such a pro-regulation letter sent by such salesman during that time, despite amendments being made to the management plan),

He seemed to have a similar disconnect with respect to the changing distribution of the summer flounder resource.  

He complains in his comments that

“Recent information indicates that fluke populations are shifting northward and into deeper water yet the current NMFS data is not timely enough to incorporate those dynamic changes.”

Yet the salesman knows that isn’t quite true.  

In response to the northward shift of summer flounder abundance, NMFS and the Atlantic States Marine Fisheries Commission’s Summer Flounder, Scup and Black Sea Bass Management Board shifted from their former approach of single-state management, which awarded New Jersey 39% of all recreational landings, to a regional approach which grouped New Jersey with Connecticut and New York, spread a larger allocation across all three states, and required them to adopt similar regulations.

Given his recent comments, one would think that the salesman would also have embraced such regional concept, but that was not the case.  Instead, in a press release issued by the Recreational Fishing Alliance, headed “Summer flounder regionalization a shared recipe for disaster,” he complains that

“Forcing neighbors to argue with neighbors over a totally inadequate and scientifically untenable quota allotment is result of our government’s inaction and I just don’t see this plan can to cure the ills [sic] of a broken management system…”

Some might believe that such inconsistency casts considerable doubt on the credibility of any comments made…

And with credibility already in doubt, such comments go on to attack the entire management process.

The first axis of attack is to question the reference points—that is, the values that fishery managers have adopted which include the target size of the spawning stock and the maximum level of fishing mortality that the stock can tolerate before declining.  If one believes the salesman, such reference points

“are way too high and have been since their inception!  What are reference points?  Truth be told it is the contrived number of fluke that theoretically would exist in a utopian ocean that remained untouched by man, by pollution, weather , nursery habitat degradation and climate changes or forage base fluctuations.”

Biologists disagree.  The reference points were established in the benchmark stock assessment which was completed in 2013, and peer-reviewed by a panel of international experts.  The peer review report notes that

“Current [biological reference points] are based on the F35% MSY proxy.  The Working Group considered a number of analyses which have addressed the basis for [biological reference points] for this stock and which have suggested a less conservative approach, such as F30%...moving from F35% to F30% would result in a very small increase (2%) in yield but a moderate reduction (14%) in equilibrium [spawning stock biomass] and 22% increase in fishing mortality (ie. 0.378/0.309).  For this reason the Working Group proposed that the F35% [biological reference points] should be retained…”

In other words, biologists tell us that current fishing mortality and biomass reference points are based on a stock that is just 35% of the size of an unfished stock, and not “the contrived number of fluke that theoretically would exist in a utopian ocean that remained untouched by man, as the salesman would have us believe.      

The salesman complains that

“Because for the last 6 years NMFS research Vessel Bigelow has consistently been returning catch data on young of the year fluke that is substantially lower than previous research vessels reported.  Not only is that issue one that should have been questioned immediately, but more recently a review of the nets and techniques used by the Bigelow have come under scrutiny and the accuracy of the information is highly dubious at best…”

However, when one reads the benchmark assessment, it becomes immediately clear that the survey done by the Bigelow is only one of many surveys included in the population and recruitment models. 

“Research survey indices of abundance are available from the NEFSC, MADMF, RIDFW, CTDEP, NYDSEC, NJDFW, DEDFW, MDDNR, VIMS, VIMS ChesMMAP, VIMS NEAMAP and NCDMF surveys.  All available fishery independent research surveys except for the NCDMF trawl survey in Pamlico Sound were used in model calibration.”

When the results of a dozen different surveys, carried out in nine separate states and in federal waters, combine to provide a single result, trying to impeach such result by attacking one survey is nothing more than an act of desperation.

Then the salesman’s comments assail a new target, alleging that

“NMFS Recreational catch reporting is in fact nothing more than a government sponsored dartboard!...We hear a lot about ‘peer review’ of the science and data left on the cutting room floor and unusable by NOAA Fisheries—yet when will see [sic] a ‘peer review’ of the recreational harvest survey changes clearly demanded by Congress over 10 years ago?”

The short answer to that last question is “next Tuesday,” when  the National Academies of Sciences, Engineering, and Medicine will officially announce the results of a review of the Marine Recreational Information Program, which NMFS itself asked to be conducted nearly a year ago, to uncover any flaws in the new program.

While it’s likely that the review will, in fact, find some flaws, it’s also likely that it will find that MRIP is far more than “a dartboard,” although we’ll have to wait until Tuesday to find out for sure.    

The salesman’s final two points are related.  One attacks the benchmark stock assessment, one calling it “outdated” and “past its usefulness”, and stating that

“The newly developed sex specific model created by Dr. Patrick Sullivan  with funding from [the Save the Summer Flounder Fishery Fund] and its partners needs to be incorporated [into the stock assessment] as quickly as possible as it will produce a far more comprehensive and accurate look at the fishery than the currently used model,”

which is bordering on puffery, given that such model has not yet been validated by an independent peer review.  And in any case, whether it “needs” to be incorporated into the assessment, and whether it “will produce a far more comprehensive and accurate look at the fishery” is really a matter for scientists, and not salesmen, to decide…

His final argument is that

“the recent [Save the Summer Flounder Fishery Fund] and Rutgers University onboard sex and length study results clearly detail what most fishermen already suspected which is that our current management strategy is putting undue pressure on breeding female fluke and that we would be better off harvesting a cross section of the population that would include more males…”

Once again, we have a salesman drawing scientific conclusions, this time about current management placing “undue” pressure on female summer flounder and that “we would be better off harvesting…more males.”  In doing so, he goes well beyond any conclusions drawn in the study he cited, which merely states that, under current regulations, females dominate the recreational catch, and makes no value judgments about the impact of such harvest on the health of the stock.

The bottom line is that it is the job of a salesman to sell

things.

And in the summer flounder debate, we’re faced with a host of salesmen, of various kinds, doing their very best to sell anglers on the idea that the summer flounder management program is fatally flawed.

By making unsubstantiated attacks on the science, the data and the fishery managers themselves, they seek to discredit the management process, and to enlist anglers in their fight to oppose needed, science-based harvest restrictions.

And they’re doing it for just one purpose—to keep income high in the short term, so long as the fishery lasts.

After that, well, that’s not their problem.  They’ve made their profit.

Only we anglers will be left behind, to deal with what’s lost.