Secretary Pritzker, Many Good People,
I'll soon have 40 years in recreational fishing; my livelihood earned just 100-some miles from Washington, DC & spent mostly on the nearshore corals of the Mid-Atlantic.
Our fisheries survived foreign fleets--overfishing in its grossest form when our own government, the Department of State, traded fishing rights for military bases on foreign soil.
We came from that & thrived in early management as population after population soared.
Now, through use of recreational catch estimates from first MRFSS & then MRIP, fishery after fishery is being lead to the alter of overfishing and sacrificed as the Mayans lead their enemies.
There's no blood, but the pain is brutal. You're tearing the economic heart out of recreational fishing for what is, essentially, a scientific hoax.
It needs to stop.
It really, really, needs to stop.
I guarantee - these estimates are blinding fisheries science & management in the worst ways & causing needless economic ruin.
An oh-so brief look at recreational catch estimates:
Many in the For-Hire fisheries must surrender catch reports. These daily forms, sometimes several a day, are required to reapply for permits. No "VTR" reports? No permits. It's serious & we take it seriously.
But somewhere in NOAA there's a roadblock that says, "These reports are no good as data. Our catch estimates are better." I think it's probably one or two guys, hold-overs from the Bureau of Commercial Fishing.
Maryland's official For-Hire MRIP catch-estimate of black sea bass, my specialty, is 56 fish -total- for 2105. Many of Maryland's party & charter boats, many times, submitted catch reports far higher from a single day's fishing.
You cannot push with a string. While I can positively falsify many low estimates with actual recorded catch, please believe the only thing that stops the lows from being as bad as the highs is zero.
An MRIP estimate cannot enter the negative.
Over-estimates, however, have no boundaries. Catch can & does go to the moon in implausible numbers. MRIP's assertions of catch survives the entire regulatory process even when not a single soul at the table believes the data: No One.
Overfishing thusly proven; that's not numbers you hear crunching. It's the bones of our economy.
My God it hurts. The pain of false accusations destroying our businesses is unreal.
From the "new & improved" MRIP program we've got guys sitting on buckets this time of year in New Jersey catching more tautog from shore---from NJ's rockpile jetties in cold water when the dang things ain't even biting; those guys caught more tautog in 2010 than all US For-Hire & Commercial effort caught all YEAR.
Sadly, that's hardly the dumbest estimate..
Time, after time, after time, there are single states' Private Boats outfishing all US For-Hire fishers; sometimes all US Commercial too -- and in just a few weeks!
I tell all of you; this is fantasy.
These catches are not real.
Did little plastic boats in Massachusetts really waylay the entire Gulf of Maine's cod population in five late-winter/early spring weeks of 2010? While those boats were all in storage? While their owners, if out fishing, were on For-Hire boats?
Red snapper & other Gulf reef fish, cod in New England, black sea bass in the Mid-Atlantic; such wonderful escalations in population have been squandered to suite the demands of bad data -- overfishing seen on computer destroys our industry.
Worse still, these catch estimates are given such singular importance that the sciences of biology & ecology are removed from all regulatory effort as we perpetually hunt what should have been controlled decades ago - overharvest.
Commerce was never meant to be the office of economic destruction, but by putting positively pathetic recreational catch estimates before biology & ecology, you're succeeding.
Corals just a few miles off DelMarVa remain undiscovered & unimportant in fisheries restoration. We may have 10 to 15% of the original natural hardbottom reef from before industrial stern-towed gear loss began some 75 years ago. That habitat's discovery & restoration isn't even a twinkle in science's eye.
Failure to respond to oyster collapse in the Delaware & Chesapeake Bays with industrial vigor has allowed the Mid-Atlantic ocean to turn green.
Deep blue sea? Nah.
Every generation of anglers losses 15 to 20 miles of blue water. We'll soon have to develop markets for jellyfish.
Management's ability to biologically force young fish to spawn is completely absent any fishery plan, yet the very idea of 'maximum sustainable yield' relies on a population's spawning response--an instinctual desire to achieve habitat capacity before slowing. That's the sweet spot - that's the economic driver - that's what real fisheries management will look like; and that's the biological response that can carry many species beyond any current notion of 'restored.'
Conversely; unrecognized, it can slow spawning to a crawl.
We know how to grow oysters on vertical hard substrates.
We know how to grow nearshore corals where no one's found use of them.
We're witness to true exponential population growth in fishes.
Yet the United States choses to smother biology, ecology & coastal economies with data unfit to line a bird cage -- MRIP's recreational catch estimates offer singularly important control over management's outcome.
We've come to a truly bad place with that.
This year NOAA will even close cobia with the exact same track - overfishing seen only on a computer owns the sea.
Great mercy but it needs to stop. Closures & regulatory tightening leave us worse & worse economically while offering precious little--to even retarding--fisheries restoration progress.
Almost 40 years of work.. I believe I shall die like a farm animal, in harness, in the field; toiling against a system that, though evidence lay all around, refused to learn how to make more fish.
Please Commerce! Please relieve us from the spikes in MRIP's catch estimates before it's entirely too late. Please Commerce, Please NOAA, Please allow managers, who have only the best of intentions, to call what they see in our current recreational catch estimates. Please see that Bayesian stops are applied to catch: both lows & highs have real boundaries. You must recognize them & apply them to management.
The National Academy of Sciences is investigating MRIP right now. Where before some lofty ideal of 'perfection in statistics' has always held ground - Please Commerce, Please NOAA, Please ask instead that our estimates be correct. Seek truth in the estimates, not flower-tossing celebration of perfect statistics.
And please, look at fishings' past for rapid rise in populations. Unlike catch statistics, those periods will reveal methods of population increase employable by management to create thriving waterfront economies.
MRIP creates a sea of Can't while forcing management to ignore an ocean of potential.
Unleashing even a fraction of that potential would restore a lot of faith in government.
Someone Please Help..