THE MARINE RECREATIONAL INFORMATION PROGRAM IN THE MID-ATLANTIC

The Marine Recreational Information Program, better known as MRIP, is many salt water fishermen’s favorite whipping boy.  It’s a matter of killing the messenger:  MRIP data often tells anglers things that they don’t want to know, and thus it is deemed to be bad.

MRIP has also inherited the stigma of its predecessor, the infamous Marine Recreational Fishing Statistical Survey, or “MRFSS,” which really was a flawed program, that had its flaws only made worse by the way in which it was used.

MRFSS was originally designed to reveal broad trends in coastal recreational fisheries.  And it did a pretty fair job of revealing long-term, coastwide trends in recreational effort and landings of various species, despite the many biases that, scientists learned to their dismay, were inherent in that survey’s design.

But it was completely unsuited for state-by-state quota management of recreational fisheries, and when it was used for that—because managers lacked any better tool—its shortcomings quickly became obvious.  A 2006 National Academy of Sciences study report, Review of Recreational Fisheries Survey Methods, advised that

“Both the telephone and access components of [MRFSS] have serious flaws in design or implementation and use inadequate analysis methods that need to be addressed immediately.”

Those who called the MRFSS “fatally flawed” had some technical justification for their comments.

However, MRIP is an entirely different animal, that was thoughtfully created from the ground up to address the flaws cited in the 2006 study.  When the National Academy took a look at MRIP a few years ago, its comments were generally favorable. 

Its report, Review of the Marine Recreational Information Program, which was released early in 2017, stated that

“Work to redesign the National Marine Fisheries Service’s recreational fishery survey program (now called the Marine Recreational Information Program) has yielded impressive progress over the past decade in providing more reliable data to fishery managers.  Major improvements to the statistical soundness of the survey designs were achieved by reducing sources of bias and increasing sampling efficiency as well as through increased coordination with partners and engagement of professional consultants.”

“…The methodologies associated with the current Fishing Effort Survey, including the address-based sampling mail survey design, are major improvements from the original Coastal Household Telephone Survey that employed random-digit dialing to contact anglers.  [emphasis added]”

“…The new Access Point Angler Intercept Survey design (used to interview anglers and record their catch) is a substantial improvement on the MRFSS intercept survey methodologies.”

So it looks as if the folks at the National Academy—in this case, eight PhD-level scientists and statisticians, along with a high-level specialist from the Pacific Fishery Management Council—believe that the MRIP survey is, if not perfect, a solid fishery management tool.

And that’s an important thing to know if you have anything to do with fish governed by the Mid-Atlantic Fishery Management Council, where recent operational stock assessments of bluefish and black sea bass relied heavily on MRIP estimates; a third operational assessment for scup was less reliant on MRIP, but the 2020 scup fishery will nonetheless be impacted by MRIP results.

In all three cases, updated MRIP data, driven by the new mail-based Fishing Effort Survey, which the National Academy found to constitute “major improvements from the old Coastal Households Telephone Survey,” revealed that anglers are fishing more, and catching far more fish, than previously believed.

That revelation should be seen as good news, because it provides fishery managers with better data on which to base their decisions.  When included in fishery scientists’ virtual population analyses, it also shows that fish are more abundant than previously believed, and that they can sustain higher landings levels than those that had been governing the fisheries.

However, many in the angling industry have been dismayed by the new data, because it also shows that recreational landings have often been far above sustainable harvest levels, and that cutbacks may be required.

As a result, many in the industry have been quick to condemn the new MRIP estimates.  Some said that they had no faith in the revised recreational landings estimates, and reportedly called them

“inaccurate and fundamentally flawed,”

descriptions that might have applied to MRFSS, but not to the new MRIP numbers.

Others said that the data was

“unbelievable.”

Many also said that they had

“no trust”

in the revised estimates; apparently, without giving any consideration to the statistical principles and testing underlying the changes, they merely argued that the data wasn’t trustworthy because if estimates could be revised once, they can be revised again.

Without exception, the criticisms of the revised MRIP data was neither sophisticated nor based on any sort of statistics or science.  That isn’t too surprising, since unlike the National Academy members who endorsed the current MRIP approach, the critics were not statisticians, and none had earned PhDs or other advanced degrees.  It’s pretty safe to say that the education of some—perhaps most—of them ended at high school, and that they couldn’t create—or analyze—a statistical model if their life depended on it (something that is true for most of us, although most of us are wise enough to admit to our ignorance and depend on people with the skill and knowledge to get the job done).

For the most part, the critics were people who were either a part of, or otherwise represented, the recreational fishing industry, who recognized that the new MRIP data could have a negative impact on short-term profits.

And that was more than enough to render such estimates bad—at least in their view—for neither science nor sophistication would help their bank accounts grow over the next couple of years.

From the standpoint of current income, the revised MRIP numbers brought mostly bad news.

The most benign outcome, from that perspective, came with summer flounder, where the new MRIP figures were included in a benchmark stock assessment released early this year.  When new recreational catch estimates were added to the other data in that benchmark assessment, managers understood that the summer flounder stock was larger than previously believed, and that the target and threshold fishing mortality rates could be increased without harming the stock.  

At the same time, because anglers had been landing far more summer flounder than managers had believed, recreational regulations couldn’t be relaxed, even though the recreational harvest limit was substantially increased; landings and stock size were already in balance.

As a result, the recreational harvest limit already adopted for next season will remain in place.  According to MRIP data just released today, 2019 summer flounder landings between March and August—a period that reflects most of the landings coastwide—are just slightly below landings for 2018, so the chance of regulations remaining unchanged next year is also fairly high.

That’s probably not the case for bluefish, black sea bass or scup.

As things stand now, black sea bass might see the least change going into next year.  The operational assessment indicated that the stock is currently very abundant—at around 240% of the target level—but that the population is declining, and recent recruitment of new fish into the stock hasn’t been high enough to reverse that trend at any time soon.  Still, the findings of the operational assessment will allow a substantial increase in the 2020 recreational harvest limit. 

Unfortunately, that increase won't be large enough to bring the harvest limit in balance with the new estimate of recreational landings; if 2019 regulations equal those of 2018, 2020 regulations will have to be tightened enough to reduce those landings by 30%.  So far—through the end of August—2019 black sea bass landings are about 92% of last year’s landings, so much will depend on what happens in September and October, when most of the remaining recreational harvest is usually landed.  

If landings during those months equal those during the same periond in 2018, when such landings were proportionately larger than they are in most years, anglers will still be looking at substantial cuts.  If September/October landings fall back to a more typical share of the annual harvest, the cutbacks might not be too bad—assuming that landings remain low for the rest of 2019.  Unusually high harvest during November/December, as supposedly happened in 2016 and 2017, could completely upend that picture.

The recreational scup fishery shares many of the same features as does the black sea bass fishery—a very healthy but declining stock, and recreational landings that are predicted to be higher than the 2020 recreational harvest limit—but it also has its own quirks.  

Those quirks include an allocation slantedsharply toward the commercial sector, which never lands anything close to itsentire quota, meaning that, if the National Marine Fisheries Service can find away to transfer unused commercial quota to the recreational side, anglers’increased landings provide no problems at all—but if no transfer is made, based on 2018 landings, anglers are looking at something like a 50-percent-plus reduction in harvest, and some truly restrictive rules that aren’t really justified by the health of the stock. 

Given that, so far, 2019 scup landings seem to be running ahead of landings in 2018, without any quota transfer, the 2020 cuts—and the 2020 landings—could be even more severe than predicted.

But even given the scup situation, it’s bluefish that will probably be hit the hardest.  The operational assessment found them to be overfished; if any solace could be found at all, it could be found in the fact that anglers didn’t overfish in 2018, as they had in previous years.  But that seems to be a one-year phenomenon, for so far in 2019, anglers have landed about 50% more bluefish than they did last year.  Thus, unless landings tank for the rest of 2019, we’re likely to see some very restrictive regulations emerge from the joint Mid-Atlantic Council/ASMFC Bluefish Management Board meeting in December.

Given that, it’s understandable why there’s a lot of wishful thinking going on, by people who desperately want the new MRIP estimates to be wrong. 

But science and statistics are not on their side.  And wishful thinking does not constitute a coherent fishery management policy.

In the long run, they might be thankful for that.  Because as I wrote a week ago, the recreational catch estimates were recalculated back to 1981, a period that includes the years used to determine the recreational/commercial allocation of a number of important Mid-Atlantic species.  The Mid-Atlantic Council and ASMFC’s Summer Flounder, Scup and Black Sea Bass Management Board has embarked on a new amendment which might end up changing current allocations to match what recreational and commercial fishermen were actually catching during the years when allocations were set.

That means that the same MRIP numbers that some members of the recreational community are cursing now may end up giving them more fish—in the case of scup, significantly more fish—than they are allowed to catch today.

Which led to an interesting dance at the last Council meeting, when at least one Council member who has made a second career out of condemning MRFSS and later MRIP had to find a way to support the reallocation amendment, and ended up making statements that while he could never support a management action—including reallocation—based solely on MRIP, he supported amendment.

Which at this point, although perhaps not in the future, is based solely on MRIP.

That leads to the most important point.

Data that is collected in a statistically valid matter—as the National Academy tells us the MRIP data is—can be neither good nor bad.  It is simply data, and part of the puzzle that fishery mangers put together every time they need to determine the health of a stock, or the need for new management measures.

Sometimes that data will bring good news.  Sometimes the news will be bad.

But killing the messenger, and impugning MRIP when it brings bad news, is never the right response.  At least not unless there is statistically valid, peer-reviewed data that is at least as compelling as that reviewed in the 2017 National Academy report.

The right response is to do what the data suggests is needed for the long-term health of fish stocks.

Anything else is not merely the wrong response, it is the irresponsible one.

HOW TO SHOOT YOURSELF IN THE FOOT AT THE MID-ATLANTIC FISHERY MANAGEMENT COUNCIL

Let’s start with the basics.  Fisheries management is a science, that takes years of sweat and study to learn.

To do it well requires multiple sources of accurate data, which are then incorporated into complex computer models, which models are, in turn, subject to review by a panel of independent experts, who determine whether both the models and the data are suitable for management purposes.

It also requires that fishery managers recognize that their data, and their findings, are not perfect, but instead always incorporate a greater or lesser amount of uncertainty.  Identifying sources of uncertainty is important, and can allow managers to account for at least some of the unknowns when estimating the health of a stock or recommending future harvest levels.

Thus, at last week’s meeting of the Mid-Atlantic Fishery Management Council, attendees were advised that major sources of uncertainty in the bluefish operational stock assessment included the revised Marine Recreational Information Program (MRIP) estimates of anglers’ catch and effort, the increased importance of dead discards in the assessment, uncertainty as to whether the full allowable biological catch will actually be caught, the relatively scarce data regarding the 60% of the biomass that is six years old or older, uncertainty about how the MRIP index and MRIP estimates interact in the stock assessment, and whether commercial discards are larger than currently believed.

Because of those and other sources of uncertainty, managers are unable to provide a perfectly precise estimate of any species’ spawning stock biomass, or of any other value used to assess and/or manage the stock.  So, in the case of the bluefish operational stock assessment, instead of only providing a single point estimate for the size of the spawning stock biomass, the assessment said

“Spawning stock biomass (SSB) was estimated to be 91,041 (metric tons) in 2018, about 46% of the updated target biomass reference point SSB_MSY proxy=SSB_35%=198,717 (metric tons), and 92% of the SSB_threshold=99,359 (metric tons).  There is a 90% chance that SSB in 2018 was between 66,840 and 99,299 metric tons.  [emphasis added, internal references deleted]”

That last sentence, which I emphasized in the quote above, tells us a lot. 

First, it tells us that after incorporating all of the uncertainty that the assessment team was aware of, the best they can tell us, employing what is referred to as a “90% confidence interval,” is that 2018 spawning stock was somewhere between 66,840 and 99,299 metric tons; the 91,041 metric ton point estimate was effectively the peak of the probability bell curve that then fell away to—and past—those values.

It also tells us that there is very little doubt that the bluefish stock is overfished, and in need of rebuilding, for even the high figure in the range provided, 99,299 metric tons, would fall very slightly below the spawning stock biomass threshold that defines an overfished stock.  However, it does not tell us that the stock is overfished with absolute certainty.  Because a 90% confidence interval was used, there remains a 10% chance that the spawning stock could be either smaller than 66,840 or larger than 99,299 metric tons—although given the shape of the curve, the likelihood is that if the stock fell outside of the 90% confidence interval, it would do so on the low side.

Apologies for getting so deep into the statistical side of things, but I still have to dive just a bit deeper before I get to the “shoot yourself in the foot” part of this essay. 

That’s because uncertainty doesn’t only impact potential size of the confidence interval surrounding each important point estimate; it’s because higher uncertainty also raises the risk that management decisions will go wrong, and won’t adequately protect fish stocks.

So the Mid-Atlantic Council’s Scientific and Statistical Committee is governed by a policy which sets one of three “coefficients of variation” (CV) that are used to create buffers that account for uncertainty and its potential for increased risk.  

A CV of 60 is used when uncertainty is relatively low, while a CV of 100 is employed for more typical levels of uncertainty, and a CV of 150 used when uncertainty is particularly high.  The buffer between the overfishing limit and the allowable biological catch—which is often equivalent to the annual catch limit—established to account for scientific uncertainty, typically increases when higher CVs are set.

In the 2015 benchmark bluefish stock assessment, the level of uncertainty was deemed low enough to justify a CV of 60, but due to the uncertainty inherent in the bluefish operational assessment, that CV was increased to 100.  At the October 8 Mid-Atlantic Council meeting, when explaining why a CV of 100 was chosen, the Chair of the Council’s Scientific and Statistical Committee advised that

“The chief uncertainty with Bluefish relates to patterns in the revised MRIP estimates.”

And that makes sense.  The revised MRIP methodology is new, and even though it has undergone rigorous testing and review, it is only prudent to make sure that it is producing more accurate estimates before placing unquestioned reliance on its results.

Thus, in fisheries such as bluefish and black sea bass, where recreational catch plays a large role in the health of the stock and the MRIP estimates have a big impact on the assessments and on future projections of catch and stock health, managers are adopting larger CVs, and so reducing the recreational harvest limit, in order to account for the increased uncertainty.

But here’s where the whole “shoot yourself in the foot” thing comes in.

While scientists are exhibiting due caution with respect to the new MRIP estimates, some members of the recreational community, including those who sit on recreational advisory panels, have gone beyond caution, and have aggressively rejected the new MRIP approach.  For example, the report of the Summer Flounder, Scup and Black Sea Bass Advisory Panels’ meeting reported that in the recreational scup fishery,

“Multiple advisors said that they had no faith in the data from the Marine Recreational Information Program (MRIP), which they see as inaccurate and fundamentally flawed.”

The report of a September 24 Advisory Penal webinar states that, with respect to black sea bass,

“Many advisors said they have no trust in the Marine Recreational Information Program (MRIP) data.  One advisor said it’s not true that we now know that recreational catch is higher than we previously thought because we don’t know that the revised numbers are accurate.”              

At the October 9 meeting, Council staff quoted advisors who called some MRIP data “unbelievable.”

Often, many of the advisors, and many fishermen, don’t think that anyone is listening to their complaints, but comments at the October 9 meeting demonstrated that just isn’t true.

One of the topics that the Council and ASMFC's Summer Flounder, Scup and Black Sea Bass Management Board discussed that day was possible changes to the commercial/recreational allocation.  

The Council and Management Board ultimately decided to begin work on an amendment that might do just that.  One of the justifications for revisiting allocation was that the new MRIP numbers indicated that recreational harvest was, and had always been, higher than previously believed, even during the base years that determined how the commercial/recreational allocations would be set.

Naturally, some of the commercial fishermen present, and even a few who supposedly represent the angling sector, expressed doubt about the accuracy of the MRIP estimates, and questioned whether the Council could justify reallocating fish based on MRIP estimates that, as evidenced by the higher CVs, even the Scientific and Statistical Committee seemed to doubt.

And that’s when the most interesting comment was made by the SSC’s Chairman.  

It seems that the Scientific and Statistical Committee’s cautious approach to MRIP wasn’t merely due to the newness of the revised estimates, and the need to be careful until there are a few more years of data to confirm the estimates’ validity. 

It seems that the SSC has been listening very carefully to the advisors’ criticisms of MRIP, and that those criticisms have led the SSC to consider why the MRIP estimates seem to diverge so much from the advisors’ views of the fishery.  Thus, those criticisms, and the questions that they raised, were one of the factors that caused the SSC to increase the CVs in a couple of fisheries, and so lower the recreational harvest limits for 2020 and 2021.

Thus, by their relentless criticism of MRIP, some of those advisors, who typically argue for higher recreational harvest limits, helped to convince the SSC to increase the CVs, and so lower the harvest limits in upcoming years.

Which is why it’s probably a good idea to thoroughly understand the management process, and how each factor plays into management decisions, before shooting off your mouth.

Because you might end up shooting off your own foot as well.

IS REALLOCATION THE SOLUTION TO PROBLEMS AT THE MID-ATLANTIC FISHERY MANAGEMENT COUNCIL?

I’ve written about it before:  I hate allocation issues, and avoid them whenever I can.

Fights over who gets what share of the fish are always long, bitter, divisive and, all too often, completely unproductive, when after months—sometimes years—of debate, everyone ends up about where they originally started.

I’ve long believed that, instead of commercial and recreational fishermen wasting time fighting over who gets the biggest slice of an already too-small pie, it makes more sense for everyone to work together to make the pie bigger, so that everyone can get what they need, even if what they get isn’t everything that they might want.

But every now and then, a situation arises that justifies looking at reallocation not merely from the usual selfish view, but as a real answer to a fisheries problem, or to correct a true error that has been perpetuated for far too many years.

That sort of situation arose at the October 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, when they looked at the question of the recreational harvest limit for scup in upcoming years.

It turns out that the scup population remains very healthy.  It produced the largest year class on record in 2015, and even though recruitment over the ensuing three years was below average, the spawning stock biomass still stood at about 200 percent of the target level at the end of 2018 and, although it has been declining since then, is still likely to stand at about 175 percent of target at the end of 2020.

In addition, 78% of the scup catch is allocated to the commercial fishery, which has repeatedly failed to come close to landing its entire quota.  In recent years, the commercial fishery has caught between 55 and 84% of its quota, with the high occurring in 2017, followed by the low one year later.

For years, it appeared that recreational fishermen didn’t catch their entire quota, either; for the period 2014-2018, their catch ranged from 63 to 98 percent of their quota.  Their high point occurred, like the commercial high, in 2017, although the low occurred three years earlier.  In 2018, managers believed that about 76 percent of the recreational allocation was caught.

But when the operational stock assessment came out earlier this year, it appeared that the earlier estimates of recreational catch were very wrong.  Once the data was revised in accordance with a new and improved methodology being used to estimate recreational fishing effort, it turned out that anglers had caught far more scup than previously believed.  The estimate of 2018 landings, for example, increased from 5.61 million to 12.98 million pounds.

And the Mid-Atlantic Council’s Scientific and Statistical Committee, which sets the Allowable Biological Catch for scup each year, set that ABC at either 35.77 million pounds for 2020 (and 30.67 million pounds in 2021), or at 33.22 million pounds, if the Council decided to carry the 2020 ABC over into 2021. 

That spelled trouble for anglers, because 22 percent of 35.7 million pounds—even if discards are taken out of the equation—is a lot less than 12.98 million pounds.  In fact, it’s little more than half of that figure.

Which means that some very severe restrictions would have to be put in place to get landings down to the 2020 recreational harvest limit of 6.51 million pounds.

Cuts of that magnitude would have been controversial even if they were biologically necessary.  In this case, the controversy will be even worse, and with some justification, because while constraining the recreational landings to 6.51 million pounds, and imposing what could be truly Draconian restrictions on recreational landings, is required by the current management plan, such measures are not necessary to prevent overfishing the stock.

Remember, that 78 percent of the scup catch is allocated to the commercial sector.  And that the commercial sector has historically left between 15 and 45 percent of its catch uncaught.  So the recreational overage would, more than likely, be completely offset by the fish that the commercial boats leave in the water.

From a biological standpoint, there is no reason to address the recreational overage by transferring uncaught commercial fish to the recreational sector’s quota.

However, from a procedural standpoint, that’s far easier to say than to do.

The summer flounder, scup and black sea bass management plan contains no provision permitting such an inter-sector transfer.  And it does not list inter-sector transfers as one of the management actions that can be addressed in a so-called “framework,” a simpler management action that is far easier, and faster, to impose than a full plan amendment.

Thus, it appears that anglers may be facing severe scup restrictions in 2020 because of bureaucratic, rather than biological, imperatives.

Yet all is not yet lost.

The folks at the Greater Atlantic Regional Fisheries Office understand the problem, and don’t want to cause unnecessary harm to recreational fishermen or to the recreational fishing industry.  Over the next couple of months, they will be working with the Mid-Atlantic Council and the ASMFC to figure out if there is any way to satisfy both the legal requirements for management action and the needs of the recreational fishing community.

Hopefully, by the time the Council and the ASMFC meet again in December, the Regional Office will have found a solution that will get everyone through the 2020 fishing year.

At the same time, the Mid-Atlantic Fishery Management Council is working on a long-term solution that will prevent this sort of problem from arising again.  Last Wednesday, the Council, by a vote of 13 to 4, and the Summer Flounder, Scup and Black Sea Bass Management Board, by a vote of 10-1, decided to initiate work on an amendment to reconsider the recreational/commercial allocations of summer flounder, scup and black sea bass.

Scup clearly present the most compelling case, given that anglers are clearly demonstrating a need for a larger quota, while the commercial sector is unable to catch its entire quota.  

Or perhaps “unable” is the wrong word; “unwilling” would be closer to the truth.  Because the truth is, the supply of scup far outstrips the demand, and if the commercial fleet brought more scup to market, the price would drop through the floor. 

Even at current harvest levels, the fish demand a relatively low price.   According to the National Marine Fisheries Service website, in 2017, here in New York, black sea bass sold for an average ex vessel price of $3.67 per pound, and summer flounder for $4.88; scup, on the other hand, brought just 72 cents.  

At that price, the commercial demand for scup isn’t likely to grow much at any time soon.

So a reallocation of the unused commercial scup allocation to the recreational sector would very much fit the requirements of the Magnuson-Stevens Fishery Conservation and Management Act’s National Standard 4, which requires that allocations that assign harvest privileges among fishermen are

“fair and equitable to all such fishermen.”

It’s hard to imagine anything more fair and equitable than allocating fish away from fishermen who don’t catch them—and don’t seem to want to—and allocating them to fishermen who will (it should be noted here that the scup fishery, whether recreational or commercial, is essentially a “meat” fishery, where fish are caught primarily for consumption; allocation considerations can be very different in the case of recreational fisheries such as bluefish and striped bass, where the catch, not the consumption, of fish is the primary purpose of most anglers).

But there is another argument that favors reallocation, and it goes beyond simple fairness, to the very text of the fishery management plans.

The commercial/recreational allocations weren’t just snatched out of the air.  They were determined with reference to “base years,” a period of time before allocations were set, and before any quotas were established for the fisheries.  By looking back at such base years, managers could determine the natural proportion of fish caught by each sector, before any restrictions on landings could warp that relationship.

The commercial/recreational allocation for scup was established in 1996, and was based on catch (not landings) during the years 1988-1992.  At the time, managers believed that, during those years, commercial fishermen caught 78 percent of the scup, while anglers caught the remaining 22 percent.

Now, the revised recreational catch estimates tell us that wasn’t true, and that anglers actually caught 35 percent of the scup during those years.  If the respective commercial and recreational catch during those base years are truly the determinant used to set allocations, the recreational scup allocation should be increased to 35%.

It seems that history and equity both demand that the scup allocation be revisited—and that a reallocation be adopted to make the current recreational management issue go away.

A similar historical situation exists, if to a lesser degree, with summer flounder and black sea bass.

The summer flounder allocation, which is currently 40 percent recreational and 60 percent commercial, is based on landings in the years 1981-1989; applying the revised recreational landings estimates to those years would result in the recreational share being increased to 45 percent.  The current 51 percent recreational share of the black sea bass fishery was based on landings during the years 1983-1992; it increases to a 55 percent share if the revised recreational figures are used.

The new omnibus amendment will determine whether adopting the revised recreational catch and landings estimates, or perhaps adopting some other revised allocation, is the right thing to do.  Anglers familiar with how reallocation efforts usually turn out might doubt that this effort will yield any different results, but at this point, I think that there are reasons for hope.

Michael Luisi, a fisheries manager from Maryland who chairs both the Mid-Atlantic Council and the ASMFC’s Summer Flounder, Scup and Black Sea Bass Management Board, said that he considers the amendment

“a high priority,”

while Michael Pentony, NMFS’ Regional Administrator, announced that

“We view this as an urgent issue.”

So there is plenty of reason to believe that reallocation could happen and that it could happen relatively soon.

Of course, “soon,” when it comes to any government action, still takes a while.  The best estimates are that an omnibus allocation amendment could be produced, if all goes well, in about two years.

Still, given that it would be addressing allocations that date back two or three decades, two years isn’t that long to wait.  

In the meantime, we can hope that the Regional Office will come up with something to address the scup problems before we start fishing next year.

I’m going to be optimistic, and bet that they’ll get it done.

Yes, I know that sort of optimism runs against my basic nature.  So does getting involved in allocation fights.

But sometimes, breaking out of your usual rut can be justified.

I think, and very much hope, that this is one of those times.

MANAGING FISH AS A BUSINESS ASSET

For many of us, fishing is recreation, and fish are a critical public resource that we need in abundance to make that recreation worthwhile.

But for other people, fishing is a business, and whether that business involves catching fish to be sold for other folks to consume, or taking anglers out onto the water so that they can catch fish for themselves, there is one common thread:  If fish aren’t abundant and available, running a successful fishing business becomes a lot harder.

It’s not unreasonable to maintain that fish, although a public resource, are also a fishing business’ most important asset.

That being the case, it might be worthwhile to consider a fish stock from a business perspective.  From that perspective, fish are a lot like capital goods, such as airplanes or heavy machinery, in that the income received from today’s orders—or, from the fish produced in this year’s spawn—won’t generate profits until four, six, or more years from now. 

Thus, to assure that a fishing business remains healthy in the future, it’s not enough to look just at how many orders you’re filling—or how many fish you’re catching—today.  You have to look at developing trends, and figure out how they will translate into profits three, five or even ten years down the road.

Historically, the fishing business isn’t very good at that.  The industry tends to focus on maximizing their catch in the short term, and spend too little time worrying about how their short-term behavior will affect the long-term prospects of both the industry and the individual businesses that comprise it.

Probably no fishery provides a better example of that than the recreational black sea bass fishery in southern New England and the upper mid-Atlantic, both because the stock assessment was updated this year, providing a clear picture of the stock’s current status, and because management of the fishery has been embroiled in controversy for the past few years.

It’s probably best to begin with the fact that the stock produced an incredibly successful year class in 2011, which resulted in numbers of sea bass being caught in places, such as western Long Island Sound, where they had not been abundant for years, and in an explosion of fish on both natural and man-made structure in areas where they were more typically found (the management unit for the northern stock extends from Cape Hatteras, North Carolina to the Canadian border).

At the same time, the summer flounder population, which has traditionally supported a very large summer fishery, particularly in the New York/New Jersey/Connecticut region, has been steadily declining as a result of below-average spawning success, that began around 2011.  That has caused many anglers and for-hire vessels that once concentrated on summer flounder to shift effort onto black sea bass, either as part of a mixed-species fishery or in the course of directed black sea bass trips.

That combination of factors led to much higher black sea bass abundance, and also to much higher black sea bass landings, both because greater abundance made the fish easier to find and easier to catch, and because of the increased angler effort as recreational fishermen shifted out of the summer flounder fishery.

As a result, fishery managers have been forced into a no-win situation where, despite an extremely healthy and abundant stock, they have had to impose very restrictive regulations, particularly on anglers fishing in the region of peak sea bass abundance, the waters between New York and Massachusetts, in order to avoid overfishing.  Those restrictive regulations angered many anglers, and were particularly irksome to members of the recreational fishing industry, who are depending more and more upon black sea bass to get them through the year.

Because they were focused firmly on the present—and even on the recent past, when black sea bass abundance peaked--and not thinking much about the future, such persons didn’t treat the fish as an asset that would play a possibly critical role in the future health of their businesses, but insread treated them more like a feedstock that would always be readily available, and would never become scarce in the future.

A recent operational stock assessment, that included new data and updated a benchmark assessment released late in 2016, has now illustrated why such a short-term mindset could do future harm.

While the operational assessment informs us that

“Spawning stock biomass (retro adjusted SSB) was estimated to be 33,407 [metric tons] in 2018, about 2.4 times the updated biomass target reference point,”

which sounds like good news, a deeper review of the information contained therein reveals significant reasons for caution.  Again, from a business perspective, the biggest concern shouldn’t be the size of the sea bass stock today, when fish are unquestionably abundant, but whether that stock will remain anywhere near as abundant in the future.  

In that respect the news is hardly as good, as the stock has been declining steadily since 2014, and there is no reason to believe that abundance will increase again soon.

I suspect that some people will instantly challenge that assertion, and note that the benchmark stock assessment conducted in 2016, and released early the next year, also indicated that black sea bass abundance in 2014 was about 2.4 times target.  Based solely on that information, they would argue that stock abundance has remained virtually unchanged since 2014, and that there is no reason why regulations can’t be relaxed.

Of course, anyone claiming that would be dead wrong.

The estimates of spawning stock biomass made in the operational assessment were based, in part, on new information that was not available when the benchmark assessment was made in 2016.  That information helped fishery managers to understand that, in 2014, the spawning stock biomass in 2014 was bigger than originally thought, and was far more than 2.4 times the size of the target SSB.

Let’s look at some hard figures that demonstrate that fact—although I warn you before I begin that this may get more than a little confusing and more than a little wonky, just because of the way the calculations made in stock assessment sometimes work.

There is a table on p. 26 of the operational assessment that shows that the spawning stock biomass was 34,712 metric tons in 2014, but had fallen to 22,199 metric tons, just 64% of the 2018 figure, by the end of 2018.

I can already hear people wonder what I’m talking about.  

Didn’t I just say that the 2018 biomass was 33,407 metric tons in 2018?

The answer is yes—and no.

That’s because there sometimes are quirks that arise in stock assessment estimates, which are referred to as “retrospective bias,” which one biologist described as

“systematic changes in estimates of population size, or other assessment model-derived quantities, that occur as additional years of data are added to, or removed from, a stock assessment.”

Retrospective bias tends to be at its worst in what is called the “terminal year” of an assessment—in this case, in 2018—and skews estimates away from the true values for fishing mortality, spawning stock biomass, etc.  As additional years’ data are added to the calculation, that data begins to eliminate the bias that originally appeared in each year’s estimates, and brings those estimates closer to the actual values.

The black sea bass assessment shows significant retrospective bias.  The operational assessment advises that

“There remains a significant retrospective pattern in both the northern and southern assessment models.  The retrospective pattern in the north over-estimates [fishing mortality] by 44% over the last 5 terminal years and under-estimates SSB by 43%.  In the southern region, the opposite pattern prevails where [fishing mortality] is under-estimated by 22% and SSB is over-estimated by 22%.  The 2018 regional model estimates of [fishing mortality] and SSB were adjusted for internal retrospective error (north [fishing mortality] (0.46) adjusted for retrospective=0.32, north SSB (15,924 mt) adjusted for retrospective=28,063 mt; south [fishing mortality] (0.38) adjusted for retrospective=0.49, south SSB (6,539 mt) adjusted for retrospective=5,361.”

Thus, the SSB estimate for 2018 was both 22,199 metric tons (as calculated in the assessment) and 33,407 metric tons (after such calculation was corrected for retrospective bias).  But the important thing to remember is that the retrospective bias applied to all terminal years between 2014 and 2018; while corrections for such bias led to higher estimates of SSB, they did not impact the annual trends in SSB exhibited during those years.  So, while the SSB in 2018 was substantially higher than 22,199 metric tons, the SSB in 2014 was also proportionately higher than 34,712 metric tons, meaning that even if the absolute numbers changed, the SSB is still exhibiting a marked downward trend.

If all of that is confusing, here’s a chart from the operational assessment that will hopefully put it back into perspective.  Looking at the solid line that denotes the spawning stock biomass, it is clear that SSB has been steadily declining since 2014.

The operational assessment provides the answers for why that is true.  In order to have a big spawning stock biomass, black sea bass must also have high levels of recruitment—young fish to replace those removed from the stock—to keep the biomass high.  And as the assessment relates,

“The 2011 year class is estimated to be the largest in the time series at 144.7 million fish,”

which is why the spawning stock biomass reached such a high level in 2014,

“and the 2015 year class was the second largest at 79.4 million fish,”

which sounds like good news at first, but when one realizes that quite a few people originally thought that the 2015 year class was as large as the 2011, the fact that it was only a little more than half that size makes it pretty clear why the high spawning stock biomass level fueled by the 2011s had to decline as fish were removed from the stock.

But that’s not the worst news.  The operational assessment also reveals that

“Recruitment of the 2017 year class as age 1 in 2018 was estimated at 16 million, well below average.”

In fact, recruitment of the 2017 year class was the worst in the entire time series, which goes back 30 years.  And that recruitment, shown for 2018 in the chart provided above, was markedly worse than anything measured before; even the second-worst year saw recruitment that was at least 50% higher.

Thus, the current decline in the spawning stock biomass isn’t going to end at any time soon.  There aren’t enough fish being recruited into the population to fuel an increase in the foreseeable future.

That doesn’t mean that black sea bass are facing a crisis; at the current rate of decline, the spawning stock biomass might shrink to a size close to the target level in another four or five years, at which point it will still represent a perfectly healthy population.

Still, those fishing businesses that have become heavily dependent upon abundant black sea bass ought to start thinking about how they will cope as a shrinking black sea bass population inevitably results in lower annual catch limits and, if effort remains at current levels, additional restrictions on recreational and commercial landings.

The Mid-Atlantic Fishery Management Council, meeting jointly with the Atlantic States Marine Fishereis Commission’s Summer Flounder, Scup and Black Sea Bass Management Board, will address 2020 black sea bass specifications when it meets next Wednesday.  Although they won’t set recreational regulations at that point, and will wait until more data is available in December before doing so, the Council has already noted that, even though both the commercial and recreational harvest limits will be increased significantly in 2020,

“The revised estimates of [recreational] catch and landings are several times higher than the previous estimates for shore and private boat modes, substantially raising the overall black sea bass catch and harvest estimates.”

As a result,

“despite notable potential [recreational harvest limit] increases, recreational harvest will likely need to be restricted compared to recent levels.  For example, estimated 2018 recreational harvest using the revised [Marine Recreational Information Program] estimation methodology (7.92 million pounds/3,593 mt) was 22-31% higher than the potential revised [recreational harvest limit] (depending upon the [allowable biological catch] approach used.  If 2018 harvest is similar to 2019 harvest, the 2020-2021 [recreational harvest limits] under either [allowable biological catch] approach will require more restrictive bag limits, minimum fish sizes and open seasons compared to recent years to prevent [recreational harvest limit] overages.”

That’s not going to go over well with many fishing industry folks, who are completely focused on the current abundance and aren’t thinking about the future at all.  They want to increase their landings today, apparently believing that the current abundance willl continue forever.

That might work in the short term, but any competent businessman knows that when you're bucking a downtrend, it makes sense to conserve your assets and build up a reserve that will help you get through harder times.  It's never a good idea to mortgage tomorrow in order to spend more today,

For those who ignore that rule—and there are plenty who always do—there will still be a future.

But their businesses probably won’t be a part of it.