IF THE CRITICS OF MRIP ARE RIGHT

Estimating recreational fishermen’s landings is hard.

Unlike commercial fishermen, recreational fishermen don’t have to report their landings, don’t offload their catch to licensed dealers who are also required to file their own reports, and aren’t concentrated in a relative handful of ports along the coast.  Instead, recreational fishermen are far more abundant than their commercial counterparts, and dock their boats not only at large marinas, but at smaller facilities or even in their own back yards.  There is also a large contingent of anglers who trailer their boats  and have no need of docking facilities at  all, along with another large contingent who eschew powerboats, and prefer to fish from shore or from kayaks and similar, hand-powered vessels.

The size and diversity of the recreational fishing community makes it impossible for fishery managers to contact each angler individually, in order to get an accurate estimate of recreational landings.  Instead, managers must try to gauge angler effort, catch and landings by means of a survey that samples only a very small proportion of anglers, who they hope are representative of the larger angling population.

The quality of the data produced depends on the quality of the survey used.  In the past, the surveys were not very good.  

Prior to the 1980s, there was no regular, formalized estimates of recreational fishing activity; the sampling that occurred was conducted under very lax standards that rendered it unreliable.  In 1979, the National Marine Fisheries Service adopted the Marine Recreational Fishing Statistical Survey, usually shortened to “MRFSS,” which was a substantial upgrade from the surveys conducted earlier, but still had many serious shortcomings.  MRFSS was frequently criticized by both managers and recreational fishermen, and a 2006 study by the National Academy of Sciences found that a complete overhaul of the survey was needed.

Thus, NMFS replaced MRFSS with a new Marine Recreational Information Program, or MRIP.  More than a decade of design, pilot projects, academic review and program upgrades passed before the new program became fully implemented.  However, the end result was a survey that used new methodologies to provide more accurate estimates of recreational effort, and so of anglers’ catch and landings.

Not surprisingly, the new, fully-implemented program, with its more accurate estimates, provided results different from those obtained through MRFSS or prior versions of MRIP.  That was particularly true with respect to angler effort, which was never adequately captured by earlier surveys.

Now, the vociferous critics of MRFSS and the early incarnations of MRIP, who had long claimed that fishery management decisions were based on inaccurate data, have a problem.  NMFS has developed a recreational fishing survey that, according to a National Academy of Sciences study released in 2017, is fundamentally sound, and seemed to address most of the previous criticisms.

The only problem was that the new, more accurate survey methodology showed that anglers were catching and killing a lot more fish than anyone had previously believed.  So the critics, almost all of whom claimed that recreational landings were being overestimated and that regulations were thus too restrictive, found themselves on the horns of a dilemma:  They got the more accurate survey that they asked for, but it was giving them answers that were just the opposite of what they had wanted.

Far from revealing that anglers were really catching fewer fish, and sol leading to more relaxed regulations, the fully-implemented MRIP revealed that they were really catching more.

A lot more.

That wasn’t, in itself, a bad thing, because the fact that more fish were being caught also meant that in order to support such higher levels of landings, the fish stocks had to be larger and/or more productive than managers had previously believed.  As Meredith Moore, writing for the Ocean Conservancy, explained,

“Taken at face value, these numbers are going to come as a bit of a shock to many recreational fishermen.  The new surveys will likely show that the amount of fishing from the recreational sector (for instance, the number of trips they take, or the number of hours that they spend out on the water)—known as their effort—is three to five time higher then that old surveys indicated.  This is likely to translate into higher catch levels as well.

“…All of the new MRIP calibrations will need to be run through individual stock assessments for each fish stock before we understand how these changes will impact our integrated system of fisheries science and management.  And you can get some unintuitive results.  For instance, it’s easy to imagine that higher recreational catch means they were catching far too much—if you compare revised catch levels to their old catch limits, it will certainly look that way.  But higher catch levels, combined with our independent understanding that the stocks have been getting healthier, could mean that there were more fish out there than we thought, or that the fish were more productive (better at reproducing) than we understood.  So, while we definitely could get some bad news out of individual stock assessments, jumping to conclusions now is premature.  It will take a couple of years of number crunching (stock assessments can take a while) to figure out which stocks may need more attention, and which are still doing fine.”

And, so far, that’s how things have been working out.  While a benchmark stock assessment for striped bass, as well as an operational assessment of the bluefish stock, both of which incorporated the new recreational data, revealed that those stocks have become overfished, a benchmark assessment of the summer flounder stock, as well as operational assessments of scup and black sea bass, show both of those populations to be doing well.

Of course, that hasn’t quieted the critics, who are now intent on discrediting the new MRIP estimates, even if such assessments are accurate.  Some of the raving has only the most tenuous connection to reality; one Maryland party boat captain, for example, recently wrote that

“Recreational fishers are due a 31% cut in summer flounder/fluke quota in 2020.

“In the coming years its expected that commercial black sea bass quota will be increased upwards of 70% while recreational quota takes a 29% hit…

“Recreational scup quota will be cut 59% while Commercially [sic] allowed landings rise sharply.

“On & on…

“I’ve been trying to warn management for years.  Decades actually.

“What a mess.”

But the real mess lies in his misapprehension and/or miscommunication of what’s truly going on.

Presentations made at the October 2019 joint meeting of the Mid-Atlantic Fishery Management Council and the Atlantic States Marine Fisheries Commission’s Summer Flounder, Scup and Black Sea Bass Management Board show that the recreational summer flounder “quota” (actually the “recreational harvest limit”) for 2020 will be 7.69 million pounds, exactly what it was in 2019, with no “cut” made at all.

In the case of black sea bass, far from the “recreational quota tak[ing] a 29% hit” the 2020 recreational harvest limit, at 5.48 million pounds, will be nearly 50 percent higher than the 2019 harvest limit of 3.66 million pounds.  That hardly sounds like a problem.

And while scup have experienced below-average recruitment in 2016, 2017 and 2018, leading to a decline in biomass and a related decline in both commercial quota and the recreational harvest limit, the recreational limit will only drop from 7.37 million pounds in 2019 to 5.92 million pounds in 2020.  While that’s still about a 20 percent reduction, it falls far short of the hysterical claim that “recreational scup quota will be cut by 59%.”  (The claim that “Commercially allowed [scup] landings will rise is equally inaccurate, as the commercial scup quota will fall from 23.98 million pounds in 2019 to 20.11 million pounds—about 16 percent less—in 2020; “landings” may not change at all, as a lack of market demand has led to the commercial sector chronically underfishing its annual quota.)

Having said that, it’s true that the new data shows that recreational landings have been so much higher than managers thought that 2020 landings for black sea bass and scup would have to be reduced substantially in order to constrain anglers to or below the recreational harvest limit (updated recreational estimates for summer flounder came out nearly a year earlier, and thus were incorporated into 2019 regulations, which were no more restrictive than those in place for the 2018 season—there was no “cut” of any sort then or now).

But even those seemingly needed reductions were not adopted at the December joint meeting of the Council and Management Board, even though likely 2020 landings will probably exceed the recreational harvest limit for both species, and such landings will probably result in the overall commercial and recreational catch exceeding the acceptable biological catch for black sea bass.  It is not yet known whether NMFS will accept that action, or require that landings be constrained within the recreational catch limits, as federal law seems to require.

Whether or not landings reductions are ultimately imposed on the recreational scup and black sea bass fisheries, it’s clear that any such reductions will be due to anglers landing too many fish, and not to draconian cuts in the recreational harvest limit.  So we see the landings estimates challenged, with representatives of the recreational fishing industry calling them

“ludicrous”

and

“unbelievable,”

although such critics consistently present only opinion, and no hard and verifiable data, to support their remarks.

But, just for the sake of argument, let’s assume that the critics are right.  Let’s assume, despite all of the objective information to the contrary, that MRIP doesn’t work and severely overestimates recreational landings.

Where are we then?

To start, we end up with a lot fewer fish in the ocean.  Black sea bass provide a good example.  The recent operational assessment indicated that black sea bass biomass, which peaked in 2014, stood at about 240 percent of the target level at the end of 2018; the stock is only expected to fall to about 160 percent of target by the end of 2021.  That’s a much more optimistic view than that put forward by the benchmark assessment released in early 2017, which estimated that biomass had peaked around 240 percent in 2014, and would fall to somewhere between 123 percent and 160 percent of target by the end of 2019.

One of the big differences between the estimates of black sea bass abundance in the benchmark and operational assessments was the higher recreational landings estimates, which led to the biomass estimate being revised upward.  Without the new recreational estimates, we’d be looking at a much smaller current biomass, and even with the lower landings estimate, would probably be looking at steadily tightening regulations as the spawning stock biomass continues to decline.

So at best, from a recreational regulations perspective, even if MRIP’s critics were right, we’d probably be in about the same place we are in today, because landings estimates and biomass estimates are inextricably linked.

From a biological perspective, things aren’t quite so benign.  

If MRIP’s critics are right—as unlikely as that possibility is, it still remains a possibility—the higher commercial quotas and recreational harvest limits would lead to overfishing on a large scale.  

That being the case, so long as fishery managers have any doubts at all about MRIP’s accuracy, they should err on the side of caution and assure that overall fishing mortality remains well within the acceptable biological catch, and maybe even increase the buffer between the ABC and overfishing limit a bit, to be sure.

Not that doing anything like that would silence the critics, who will continue to yowl so long as their catch is constrained. 

Back in 2009, the party boat captain I quoted above wrote

“Last year and the year before the Marine Recreational Fishing Statistics Survey—MRFSS—said that Maryland shore flounder fishers out-fished the party boat and charter boats 18 & 12 to one.

“How they can make that assertion and have it stick I have no idea.

“Now MRFSS has us to filling the recreational quotas for scup, summer flounder (fluke) & black sea bass for the entire coast:  Not just Maryland—everywhere.  There is the distinct possibility that these three fisheries will be closed for the rest of 2009 in the coming week…

“Numbers, numbers, numbers.  Management is looking at state by state//recreational-commercial [sic] numbers, the landings data.  And, great mercy, the recreational numbers are from MRFSS…”

So it’s pretty clear that when it came to MRFSS, he wasn’t a fan.

Yet toward the end of his generally fact-free rant about MRIP that I quoted before, he wrote

“Please write your DC reps and Fed/State Fisheries personnel (addresses far below) and ask that they reinstate MRFSS (NOAA’s old recreational catch estimating program) before MRIP disrupts ALL Marine Fisheries & perhaps quite soon, causes fish stocks to ,  up and down the Mid & North Atlantic.  [emphasis added]”

As I noted above, there is a chance that, if the MRIP critics are right, overfishing will result from the new biomass estimates, although even if that is the case, we can hope and expect managers to detect the downward trends in abundance before much is any crashing takes place.

Still, that writer's unexpected nostalgia for MRFSS doesn't mean that the critics off MRIP are right.  Instead, it's just evidences that fact that they criticize MRIP and its data solely because it doesn’t conform to their view of the world.