In that piece, I noted that the
initiative was the brainchild of the North Carolina legislature, and was not
proposed by the state agencies that had real expertise in fisheries
management. I also noted that the
reporting system was going to have to be built from scratch, which may be a difficult task to complete by December, and that there was no guarantee
that the state’s fisheries management agencies had either the money or the
personnel to maintain and operate such system on a continuing basis, much less collate,
analyze, and employ the data it develops in any meaningful way.
I also noted that there was no
realistic way to enforce a supposedly mandatory recreational reporting system,
since once an angler had returned from fishing at the end of the day, enforcement authorities have no way of knowing either that the angler had been fishing
or that any reportable fish had been caught, unless law enforcement agents
contacted the angler during the fishing day, such angler had reportable fish in
their possession at the time of contact, and the enforcement personnel followed
up to make sure that a report was filed—a labor-intensive procedure that would
surely take up time far better spent in more meaningful enforcement activities. For that reason, I suspected that anglers
would be slow to comply with the reporting requirement.
Solely with respect to
recreational data collection (he also commented on commercial data, but that is
outside the scope of this essay), Mr. Thomas wrote,
“Despite the significance to our economy
and culture, those responsible for maintaining a robust fishery population have
precious little data to guide their efforts…
“…without reliable numbers, many policy
decisions will be wrong, risking the very existence of critical species in our
coastal waters, unnecessarily limiting recreational fishing seasons, and
ultimately harming the entire fishing industry…
“On the recreational side, the data
used to inform fishery management decisions is collected through a federal
survey process known as the Marine Recreational Information Program. With rare exceptions, this annual data stream
is the only source of recreational harvest data used by state fish agencies to
set size limits, daily creel limits, and season lengths.
“Not shockingly, the federal surveys have
their limitations, and in August 2023 new sources of error were identified that
brought the survey program to a halt through at least 2026.”
It all sounds good, and it’s nearly
impossible to disagree with Mr. Thomas’ basic premise: Effective fisheries management is based on reliable
data. However, Mr. Thomas’ comments in
support of the North Carolina legislature’s reporting scheme often veer wide of
the mark.
To begin, there is no reason to
believe that the reporting system ultimately adopted by North Carolina will provide
the “reliable numbers” that Mr. Thomas calls for. In discussing accuracy and error in
recreational data surveys, the Marine Recreational Information Program Data
User Handbook informs us that
“Coverage error occurs when members of a
target population are omitted, duplicated, or wrongly included in a sample
frame.”
The Access Point Angler Intercept
Survey used to sample recreational catch, landings, and effort is designed to
include all members of the target population—that is, it is designed to capture
a representative sample of fishermen that includes all demographic categories in
the same proportion that such categories are present in the angling population. While the North Carolina survey currently
being developed would ideally capture every striped bass, red drum, speckled
trout, flounder, or weakfish landed by recreational anglers in North Carolina
waters, such ideal is not at all realistic.
Instead, different segments of
the angling population will have different compliance rates, and because there
is currently no provision for either determining such differing compliance
rates or adjusting the raw data to take compliance rates into account, the
reporting data will almost certainly be biased by what is called “coverage
error.” For example, is a more educated and
more affluent angler fishing primarily for recreation more or less likely to
report their catch than is a less educated angler who fishes for food, to
supplement what they can afford to buy at the grocery store?
Will boat fishermen, pier
fishermen, beach fishermen, backwater fishermen, and those who fish from
for-hire vessels all report at the same rates, or will the rates differ from
group to group?
Will there be racial or ethnic
differences in reporting rates? In that
regard, is an angler who speaks English as a second language, particularly if
they aren’t close to fluent, report at the same rate as a native
English-speaker?
Will reporting differ by age and
by familiarity with any technology that may be used to file reports? Will a serious angler, who fishes multiple
times each week, report at the same rate as the weekend warrior or the angler
who only fishes a few times each year?
I could come up with other such questions,
but you get my point. MRIP gets around
such questions by directly contacting and interviewing the anglers present at spots—marinas,
launching ramps, fishing piers, parking lots—where anglers access the resource,
and thus stands a pretty good chance of encountering anglers representative of
the overall population.
But the proposed North Carolina
reporting system, which is reliant on anglers taking the initiative to
affirmatively report their landings, relies on anglers’ good faith and
willingness to comply, which is certainly not a given.
In addition, the scope of the North
Carolina reporting system will be too limited, for only landings need be
recorded. While that might work with
commercial fisheries, in which every fish caught is landed provided that it
meets any applicable minimum size, trip limits, or season, in recreational
fisheries, which see many fish released even though they might be legal to
keep, not recording releases creates a significant problem.
For example, looking at just the
five species included in the reporting requirements, 99%
of the striped bass, 92% of the weakfish, 86% of the red drum, and 82% of the
spotted seatrout (but, supposedly, only 3% of the southern flounder) caught by North
Carolina anglers in 2023 were released, and so would not be captured by the
proposed survey. Yet not every released
fish survives, and in species that see anglers release significantly more fish
than they keep, release mortality can constitute a significant proportion of
overall fishing mortality. In the case
of North Carolina striped bass, for example, the roughly 10,000 fish expected
to succumb to release mortality (if the generally accepted
9% release mortality rate for striped bass is applied) would exceed
recreational harvest by an order of magnitude.
The failure to record the number
of fish released would thus result in a substantial underestimate of fishing mortality
for some species.
The proposed North Carolina
reporting system also fails to record effort—the number of times that anglers
choose to go fishing. That is a critical
omission, and one that severely degrades the utility of the reported data. That’s because effort matters. There is a very big qualitative difference in
a fishery where 1 million red drum are caught in 500,000 trips, and one in
which it takes 3 million trips to catch the same number of fish. The former situation might signal a healthy
stock, while the latter might indicate a stock in decline, so landings
information alone, without the context of effort, provides little useful
information.
And speaking of effort, Mr.
Thomas is completely wrong when he states that “new sources of error were
identified that brought the survey program to a halt through at least 2026.” While it is true that the National Marine
Fisheries Service has reason to believe that its Fishing Effort Survey
overstates the number of times that anglers go fishing, and so somewhat
inflates catch and landings estimates, NMFS has not halted the MRIP program,
but instead continues to survey angler catch, landings, and effort, while
remaining mindful of the possible overestimates.
Thus, Mr. Thomas fails to make a
compelling case in support of mandatory recreational landings reports.
The failure to record releases or
angling effort, and the failure to eliminate sources of coverage error, means
that such mandatory reports will not provide the “reliable numbers” that managers need to
manage fish stocks. Mr. Thomas tries to minimize
the issues created by angler non-compliance by arguing that
“Reporting big game harvests in ingrained
in our culture, although it might shock you to learn that not everyone reports
their deer kills. And here is the
remarkable thing—that’s okay! The
data is still valuable.
“Our state wildlife agency doesn’t need
100% accuracy because it monitors trends in the reported harvest—how it
compares to last season, where it’s concentrated, and the like.”
But if all Mr. Thomas is
interested in is trends, then he—and North Carolina’s fisheries managers—already
get that from the Marine Recreational Information Program. Even with the likely errors in the Fishing
Effort Survey, MRIP’s ability to display year-to-year trends remains unchanged.
There is no reason to burden North
Carolina fishery managers, or North Carolina anglers, with another reporting
program that, at best, will only duplicate data already produced by MRIP.
Any money that might be dedicated
to the proposed reporting system would be better used to enhance MRIP surveys
within North Carolina, so that more anglers can be surveyed and the uncertainty inherent in any estimate can be reduced.
The North Carolina legislature
will probably prove unwilling to admit that it made a mistake, allocate more funds
to enhance MRIP, and repeal the reporting requirement, even though that would
be the wisest thing to do. However, we
can hope that North Carolina’s example, where significant money and effort will
be expended on a program of dubious merit, which was never requested by the
professional managers and will provide no recreational data not already
provided by MRIP, will dissuade other states from making the same mistake.
Very well written Charlie. Thanks.
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