North Carolina Fishing Reports

reelfishaholic

Cut and paste whatever you want out of the letter I am posting. Just send something in. I don't care what, just have a voice.

Make sure you sign the bottom with your name and city along with putting in your choice of what Alt you would like to vote for.

Dear S. Atlantic Council Members,

First, I would like to state that the purpose of my comments are just to voice my opinion on the currently proposed legislation. All of the references that I will make are by no means an attack on the council or any one member whom makes up the council. I will primarily address what I see is being used for the decisions and a few discrepancies that seem to differ from the data and what the general public is being told "has to be done" which may in fact, be a little misleading in the management of the fisheries in our region.

It seems that for too long the subject of the proposed "problem" isn't always defined prior to a "solution" being derived. Public meeting inputs have the attitude that the decision has already been made. As a fishermen, I would be more than happy to supply data or participate in a program to supply data, as would many of the fishermen I know, if you would educate us on what you need for information and assistance.
When will a comprehensive plan be implemented that will unite the individuals necessary in a joint effort from managers, scientists, legislators, environmental and fishers to agree on a common goal which should be to to protect our marine biodiversity along with stimulating long term economic health.

Any form of accountability on the council's part for the decisions made on our behalf as fisherman, doesn't seem to exist. Decisions are made that do not seem to have both the fish stock and fisherman's best interest at heart. I am not saying that your jobs aren't easy in any way. What I am saying is I don't understand how a governing body will tell us that the best available data may be flawed or inaccurate yet you are going to error on the side of caution and incorporate more restrictive legislation. This is happening when our fishing trips are producing large health fish for our dinner tables as never before.

The council's actions are speedy mechanisms to put increased restrictions on a fishery, yet there are no such speedy mechanisms to decrease restrictions should any fishery’s biomass indeed increase to healthier levels, or have new data to contradict the imposing limits. With such vast time frames between stock assessments, is it any wonder that fishers don't have faith in the system? We hear how it needs to produce results over a long time period such as 10 years to be accurate. Please don't site here how we can now catch more porgy. Historically, regulations don't give back but become more conservative in restrictions.

These viewpoints are directed towards Amendment 16 yet hold true of all others that are being reviewed at present including Amendment 15B which is going to eliminate the state level commercial fishing license. The concern there is that all of the state license holders are going to be moved to the recreational sector yet the recreational sector total creels aren't going to be compensated prior to the reductions. If 15% of the grouper sales sold commercially are caught by state license holders as stated in the Bag Limit Sales Prohibition, how can you move that many anglers to the recreational sector classification and not first increase the recreational creel total before imposing a reduction? You are requesting a minimum of 35% reduction in the commercial sector and 37% in the recreational sector. If 15% of the present sales are non federally permitted sales (state commercial license holders), then the recreational sector is going to actually have a reduction of 52% with the transfer of the state license holders to the recreational sector. I don't understand why this hasn't been accounted for yet. Now the commercial sector has reduced 15% of their catch without loosing the first fish. Trip tickets show the fish sales. How does this make sense? The NC Standard Commercial License Holder only accounts for 7.92% of the top 36 species sold in the finfish category. The other 92.08% is caught by federal permit holders.

MRFSS surveys have proved unreliable. Do you feel that adequate changes have been made to update the MRFSS system in the last 10 years with the advancement of technology? MRFSS is usually a year or two behind in estimating this trend, so my main concerns are about over-regulation that may not be warranted. Is there any truth to the fact that the MRFSS can't pool the NC saltwater license holders due to privacy issues? That is a prequalified group of people and would seem to make more sense than making random phone calls.

MARMAP surveys on "random hard bottoms" are the basis of most surveys done. We are talking about reef fish, fish that look for live bottom and structure to make their home. The review workshops recommended not using their data for hook and line surveys. Now we are back to analyzing trip tickets.

Data collections from things like "Chevron traps" were inconclusive due to such low catch rates and classified as "indeterminable and inaccurate" after 27 years yet older data is still used to calculate present trends.
Why are things like wave heights, sea surface temps, surface currents, hurricane impacts, DO, salinity, wind speed, wind direction, etc not included in present studies?

Why are issues like water quality and pollution along with protecting our juvenile fish using our estuaries for growth not addressed or protected? Why are all of the juvenile fish studies done in Fla only? We can pay a hog farmer or tobacco farmer not to raise their crop yet we don't address the shrimping bycatch that is drastically affecting our fish stock? Please don't tell me how great the "bycatch" gear is doing in the shrimping industry, the bycatch being shoveled overboard looks like a snow storm floating on the water coming from a shrimper. There is a reason why 300 seagulls are flying around a shrimp boat when he is pulling in his nets. I understand they have to make a living, however, subsidizes their income for the percentage necessary and stop letting them trawl on the inside and watch how well our fisheries explode.

I am concerned on how "overly conservative" the council seems to be in their calculations and proposed regulations. Below are some of the areas that if compromised to more realistic parameters, would take us out of the "overfishing" category that the grouper and snapper species are presently assessed as.

I am concerned that F (fishing mortality; the percentage of the population that dies each year from fishing) is overstated partly because it is based on:

1. Marine Recreational Fishing Statistical Survey (MRFSS) estimates of landings and discards, which have been declared unreliable and even ‘fatally flawed’ and

2. An overstated recreational release mortality of 25%

3. 2004 data being used for current fishing pressure. Obviously there has been a declining amount due to fuel and tackle prices alone.

Recreational fisheries Release mortality is presently assumed to be 25%, SEDAR 10 workshop stated Improved estimates of post-release mortality were obtained through tag release and caging methods (Burns et al. 2002; Overton and Zabawski 2003; McGovern et al.2005). Using these methods, mean mortality rates were estimated to be 21.2% (Overton and Zabawski 2003), 23% over a variety of depths (McGovern et al. 2005).
Commercial fisheries Release mortality is presently assumed to be 40%.

Your reasoning behind the proposed legislation is that the FMSY is below the F (Fish Mortality) factor, the FMSY has remained below the F (Fish Mortality) factor since 1983 in the S. Atlantic. With the council willing to error on the side of "conservative numbers and factors" is it any wonder this is the trend? Now take a look at our stocks. Have we decimated our biomass? No. I don't think real world numbers aren't being applied to gauge accurate regulation.

How can the Magnuson Stevens Act expect you to make changes within 1 year of notification if the council states that it takes 3-8 years to schedule and complete a stock assessment? For that matter, why, if notified that a stock is in "trouble", aren't scientists required to gather the current data compiled between the last stock assessment and the present date of the notifications, then review to determine if an issue really exists at the present notification time period prior to taking action?

According to your own data workshops, SSB (spawning stock biomass) increased after 1999 corresponding to implementation of the 24 inch minimum size limit. Fishing mortality has been decreasing since 1992. The gag grouper lifespan has just been raised to 26 yrs to 30 years. Does this sound as if the fishery is experiencing overfishing or possibly slated to be overfished if fish stock as a whole are living longer? This extension in the lifespan is setting us up for a future reduction by saying that you life expectancy has "dropped". Models only calculate out to 20 years in the S. Atlantic now. Why change what we already have in place.

50% of maturity is 3 years and 25.5 inches. Why don't we increase the minimum size limit to 26". It has proved effective for the size increase in 1999 to 24".

Fishing mortality in 2004 was estimated as 0.31, extremely conservative against 2007 projected mortality. Please, please, please use a more current data. This factor alone could take us out of the "overfishing" status and not require a 10-15 yr rebuilding plan.

Why is the fishing mortality rate for 2007 not being used? Obviously the fishing pressure has reduced since 2004 yet the OPPORTUNITY to fish hasn't been reduced which I think is very important and not usually taken into account when new regulations are proposed.

The council can redo the entire Vermillion Snapper stock assessment due to concerns of accuracy of the last assessment with updated data not incorporated, yet I am told by the council that the 2004 data used in SEDAR 10 for grouper won't be updated until 2011? Why can we not use current data and revisit the workshop to determine if the present proposed measures are necessary?

How can there be underfunding on the federal or local level to interpret the data that is taken every year but not incorporated or used due to lack of resources and man power as stated by the council with 3-8 years between stock assessments? I am told by several council members, "there is a war going on and the government cares more about Iraq than our own fisheries". There is something extremely troubling about statements like that. I am also told that federal government is requesting data that can't be supplied with the present system and that is the reason for such precautionary measures. All of this discussion on "the vehicle that has to take the predetermined path due to federal regulations being imposed and having our hands tied" needs help.

Why are the conclusions and recommendations from the data and review workshops which are and from the SEDAR programs not incorporated into the councils decisions on a less "cautionary or overly conservative" approach?

SEDAR 10 biologists eluded to changing the MSST, SSB, F, MFMT and alike, in one form or another due to "overly conservative" concerns.

Speaking of the SSB (spawning stock biomass), how is it calculated since there are no surveys in the S. Atlantic due to no direct fishing for Gag? If you are bottom fishing and catch a Gag, great. There are no recreational or commercial surveys done that I have been able to find that target just Gag alone due to the fact that the are a reef fish and can't be targeted solely. In order to accurately define the SSB you need to be able to study surveys of the targeted species which would enable you to make the assessment on the stock biomass. Is this the reason commercial sales data is relied on so heavily? Is this the reason that the council takes such a precautionary approach to regulation, because it appears that the entire grouper stock is estimated primarily from fish sales alone. There are too many variables for weather, hook sizes, bait, seasons, etc that would suggest that the data should be considered but not be the main staple for regulation.

SEDAR 10 Page 242

Table 38. Gag– Base run with constant catchability: Projection results under current F (starting in 2008) (fishing mortality rate fixed at the current value in 2005-2007). SSB = spawning stock biomass, R = recruits, F = fishing
mortality rate, L = landings, Sum L = cumulative landings, and D = dead discards.

For reference, relevant estimated benchmarks are SSBMSY = 7925 mt, RMSY = 500 recruits in 1000s, FMSY = 0.24/yr, and MSY = 1238 klb.

Year SSB(klb) R(1000s) F(/yr) L(mt) L(klb) Sum L(klb) D(1000s) D (klb)

2005 7468 497 0.315 663 1462 1462 21.4 108
2006 6860 499 0.315 651 1436 2898 21.4 85
2007 6062 497 0.315 589 1299 4197 26 99
2008 5604 494 0.315 528 1163 5360 29.7 122
2009 5555 491 0.315 493 1086 6447 30.9 133
2010 5660 491 0.315 489 1079 7526 30.9 135
2011 5793 492 0.315 504 1111 8636 30.8 135
2012 5898 492 0.315 521 1148 9785 30.8 134
2013 5965 493 0.315 532 1172 10,957 30.8 134
2014 6008 493 – –

Why are you showing such a drop in the projected SSB?

MSST, currently defined by the South Atlantic Council as (1-M)BMSY and is very close to BMSY because age-averaged natural mortality rate, M, is estimated as 0.14. It was stated that "the stock is not overfished and is not projected to become overfished."

A quote from SEDAR 10

"Given the uncertainties in the assessment, the biomass would be expected or could possibly, fall below MSST with a relatively high frequency even if the true biomass were close to BMSY".

We know this is a big NO NO in the first place according to NMFS guidelines. With all of the "gray" areas that exist in the fisheries legislation, MSST and BMSY being too close together is the unwritten rule that all should be following. When they are close, these "rebuilding plans" are constantly going to be "needed" on paper at least.

In Sedar 10 the Review Workshop stated that "the current definition of MSST may be overly conservative and recommends an operational definition of MSST of 4 million pounds." Yet it is still a much higher factor of 6.8 million pounds was used. There are no indications of impaired recruitment at the lowest observed SSB either.

The MFMT factor is also showing signs of being overly conservative. Couple that with the F factor used from 2004 and here I are writing this letter. Why the council feels the need to error on EXTREME caution I don't understand.

Then Natural Mortality Rate formula was calculated using the Hoenig 1983 program. A program which admittedly has flaws due to the fact that the estimate of maximum age required by Hoenig's method assumes that the age determination technique being employed is unbiased. Validating this assumption is often difficult for the older, more difficult-to-age individuals but can be accomplished by using a variety of techniques ranging from marking to analysis of radioactive isotopes (Lai et al., 1996). The estimate of longevity is also dependent on sample size and previous fishing history, which by the way, we don't have sound, accurate data on according to the councils own admission.

Hoenig (1983) showed that maximum age tends to increase slowly with increasing sample size but longevity has probably declined from historical levels because of fishing. A small sample size for age determination, underaging, and previous exploitation would all result in an overestimate of M with Hoenig's method.

Although compared to other methods, the council is still plagued with issues with accurate data and excessively cautionary management.
Maybe we don't increase the Annual Catch Limits (ACLs) as aggressively using such precautionary regulation. Lets not project a ACL increase of almost 41% by the year 2013 and take us out of the "overfishing" category.

Preliminary annual catch limits for gag grouper.

Year Annual Catch Limit
(gutted weight)

2008 694,000
2009 716,000
2010 768,000
2011 840,000
2012 916,000
2013 976,000

The 2004 stock assessment model projections show the stock becoming overfished in 2007. Are we overfished presently? Were we overfished in 2007? Please help me understand.

Greg Waugh states on 5/8/2008 that "the stock isn't overfished due to the present reduction fishing pressure, attributed to several factors such as fuel costs." He also cited that "the assessment wouldn't be redone due to funding and scheduling issues and would be revisited in 2011. Until then, we are bound by law to make changes." I do believe that the Mag / Stev act states best available data, you have data after 2004 and are not implementing it.

It is an natural assumption with the current economic situation and petroleum driven influence on our daily lives that there has been a significant decline in fishing pressure on all fishing stocks yet the council seem reluctant to revisit the issue since they already have time and effort invested into them and have decided to "stick" to their original conclusions.

Maybe we use data more current than 2004 and realize that the 37% reduction that you are calling for has already in part been addressed due to the cost of fuel and expenses that are incurred for offshore fishing. The Magnuson Stevens Act states that the new regulations need to implemented by 2010. That gives the council plenty of time to review the data that has been collected since 2004 and implement it into an updated evaluation for a stock review along with using less conservative numbers as recommended in the SEDAR 10 program to define our current status.

I believe that if current, data were used along with the above mentioned conservative factors corrected, the councils need for new legislation may not be necessary after all or to only a fraction of what is being proposed.

How about in the alternative 2 offer for the public to pick from the economic impact for the entire S. Atlantic recreational impact with a 4 month closure will only attribute to a total of $ 1,052,833. The entire state of NC will only have an impact of $ 37,130. That I don't understand. That equates to 37 trips, more or less, at a charter price of $ 1,000. The impact is is based on the "for hire" sector which is lumped in with the recreational sector as a whole. There is no account for the true recreational sector such as food, fuel, hotel, shopping, tackle, boat maintenance etc. For a 4 month NC closure, $ 37,000, REALLY?

Here are some of your own numbers. Please help me understand how you can close the season for 4 months and have an impact of $ 1,052,833 compared to the economic output listed below for the S. Atlantic finfish. With NOAA estimating that $20,000,000,000 is spent in the US on recreational fishing, I don't think the numbers below are out of line.

Retail Sales, $1,204,118,689
Total Multiplier Effect (Economic Output), $1,979,482,449
Salaries, Wages and Business Owner’s Income $581,805,683
Jobs 20,712
Federal Tax Revenues $138,699,654
State and Local Tax Revnues $122,359,975

We would like to see the gag assessment updated before a final decision is made. There are too many uncertainties and inconsistencies to move forward with an assessment that will affect such a large fishery.

The Gulf of Mexico Red Grouper assessment has been reviewed 2 years ago due to some of the same questions. The stock was overfished and experiencing overfishing. There were many corrections and this was done in less than 6 month time frame and come to find out, reductions weren't necessary.

Fishing effort is significantly reduced and is not taken into account when calculating future estimates as it should be. Since the Panel recommended the base run with constant catchability as the preferred “base model".

Economic impact and true fishing pressure of both recreational and commercial fishing is grossly inaccurate or overly conservative in my opinion, according to the data from the workshops and compared to the 2004 factors being used.

If after a review it is necessary to reduce harvest, only modest bag limit decreases or modest size limit increases should be considered acceptable if in fact a problem exists.

I am sure that the Council want to make sound decisions. The economic and social devastation wrought by these proposed Gag regulations comes at a time when effort is significantly declining (I feel permanently) due to exorbitant fuel prices. These current proposals are based on overly precautionary thresholds which compound to create the false sense of an unhealthy fishery, when in fact the fishery could be quite healthy.

Is it any wonder that the individuals that you are governing through legislation are not satisfied with the proposed solutions when they seem to have a better handle on the fish stock, behavioral patterns, abundance and realistic solutions and are not heard by you?

I urge the Council to:

1. Review the Fishing Mortality Rate of Gag
2. Review the Natural Mortality Rate of the Gag
3. Review and adjust the overly precautionary estimated factors
4. Provide the numbers for and consider as an alternative a 26” Gag minimum size limit (20% or more reduction in rec landings alone) as the FIRST tool applied to the fishery.
5. Consider the recreational creel and what is going to happen if you, through 15B, eliminate state commercial license holders and move those fishers into the recreational category without taking into account the additional reduction the sector will incur.
6. Consider not reducing the present regulations.
7. Please present a true economic impact for the S. Atlantic. A handful of fishers I know can account for your $ 37K NC impact alone.

If I have to choose from the proposed alternatives:

Commercial Regulation (35% reduction)
1. Alt 1 ........ If council won't consider Alt 1, my second choice is Alt ???

Recreational Regulations (37% reduction)
1. Alt 1 ........ If council won't consider Alt 1, my second choice is Alt ???

Finally in closing. Again I would like to mention that I am not directing this to any specific council member as a personal attack. I understand the responsibility that you have and I can imagine that some of the letters you receive are less than flattering. If I can be of any assistance, I would welcome the opportunity to assist in any way.

Sincerely,
_________________
Fishing the NC coast as much as possible.

Capt_Dave · Posted: Thu Jun 12, 2008 3:35 pm Post subject:

You can E-mail them all right here...

http://www.fryingpantower.com/modules.php?name=SAFMC
_________________
Capt. Dave

Life is SHORT....Fish Hard!

NOT a Member??You are missing ALL the Downloads........and most of the Pictures....!!

BottomDollar2 · 2nd Mate Joined: Jul 24, 2006 Posts: 31

For what ever it'll be worth I just sent mine in.
Good lord it'll be a disaster if 15B passes.

Thanks again Dave

GiddyUpGo · 1st Mate Joined: Jan 27, 2008 Posts: 76

That is great stuff there reelfishaholic. The "TRUE" economic impact on NC might be revealed to the S. Atlantic if we all sent in copies of our fishing expenditure reciepts. I'm just a poor, humble, fishing nobody, .....but I GUARANTEE you I'd take a large chunk off of that 37,000 by myself. Their projection is unacceptable.

captaingorges · Posted: Fri Jun 13, 2008 5:19 pm Post subject:

$37,000??? Seriously? Only a $37,000 impact?
_________________
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seasea · Posted: Mon Jun 16, 2008 10:59 am Post subject:

THEY WANT IT TO BE A "PROFFESSIONAL FISHERY"
EVERYONE WILL BE SCREWED. THATS WHAT THE FEDS DO, I PERSONALLY THINK THE DECISION HAS BEEN MADE ALREADY. ALL THESE LETTERS I THINK DO NOT MEAN ANYTHING TO THE COUNCIL. HARDLY ANY REC FISHERMAN ARE @ THE MEETINGS, NOTHING IS DISCUSSED. ALL I CAN SAY IS GET TOGETHER AND FILE A CLASS ACTION LAWSUIT, CONFLICT OF INTEREST, INSUFFICENT DATA ARE A START.
_________________
Anchor slave


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