JCAA Comments on Summer Flounder, Scup & Black Sea Bass Allocation Amendment

by Paul Haertel
(from Jersey Coast Anglers Association April 2021 Newsletter)

Below are the comments submitted by JCAA regarding the Summer Flounder, Scup and Black Sea Bass Amendment. While many of you may not understand it or even know about it, if you fish for these species, this is probably the most important amendment to come down the pike in quite some time. It is going to affect what the recreational harvest limits will be many years to come. Should the ASMFC and MAFMC decide to leave the percentage splits between commercial and recreational fishermen as they are right now, we are in a heap of trouble. We need everyone who fishes recreationally to become involved in this!

3/15/21
ASMFC and MAFMC,

The Jersey Coast Anglers Association represents approximately 75 fishing clubs throughout our state and we appreciate this opportunity to comment on the Summer Flounder, Scup and Black Sea bass Allocation Amendment. We would like to start with a little history. Back in the 1970’s it was widely accepted that recreational fishermen accounted for a much higher percentage of the catch and landings of fluke, scup and sea bass than the commercial fishermen. Eventually it was decided that quotas needed to be established and that percentages of the allocation would be split between the commercial and recreational sectors. However, regarding fluke the NMFS numbers were used by ASMFC/MAFMC in setting up the base years that favored the commercial fishermen after they had devastated the stock. This occurred because during the fall and winter, commercial fishermen found that the fluke were concentrated far offshore near the continental shelf. NMFS then approved a 60/40 split favoring the commercial fishermen when the split should have been the other way around and based on historical data. Recreational fishermen were given the short end of the stick back then and the problem only compounded over the years. Imagine how many more fish the recreational sector would have accounted for had the quotas been fairly assigned and regulations had not become so restrictive over the years. It is because of this that JCAA believes that even the most favorable options for recreational fishermen in the amendment are insufficient.

However, in 2018 the MRIP numbers were recalculated, and the revised estimates revealed that the recreational fishermen had caught far more fish than originally believed going back to 1981. That in turn caused our fisheries managers to conclude that the stock biomass for fluke, scup and sea bass was significantly higher than the previous estimates had shown. Regarding fluke, the higher biomass estimate resulted in a 49% increase in the quota for commercial fishermen and a 49% increase in the RHL for recreational fishermen. However, regulations for recreational fishermen could not be liberalized because the previous year’s landings estimate indicated they were already equal to the 2019 RHL. The allocation percentages for all three species do not reflect the current understanding of the recent and historic proportions of catch and landings between the two sectors. In other words, the heart of the problem is that though the revised data revealed that recreational fishermen were responsible for a much higher percentage of the catch, the split between the two sectors could not be changed without an amendment. We now have this amendment before us and that is why you must act to rectify this situation as soon as possible.

Regarding the amendment itself we would like to make the following recommendations:

As good stewards of the resources we recommend catch based allocations for all three species. This method gives incentive for both commercial and recreational fishermen to reduce their dead discards as there may be an opportunity to increase their landings if they are able to do so.

Though we passionately believe that all of the proposed percentage increases of the RHL for recreational fishermen are insufficient, we recommend the following:

  • Fluke – Option 1a-3 (60% recreational 40% commercial)
  • Scup – Option 1b-4 (59% commercial 41% recreational) provided a catch-based approach is chosen. If a landings-based approach is chosen we support options 1b-7 (50% commercial 50% recreational) as it would provide the most benefit to the recreational sector in the form of higher angler satisfaction, greater economic opportunity and more revenue for the for-hire sector compared to other allocation alternatives.
  • Sea Bass – Option 1c-3 (76% recreational 24% commercial)

Regarding phase-in alternatives, we recommend immediate implementation and certainly no more than two years. By not correcting this problem as soon as possible, the catch and landings numbers would be skewed favoring the commercial fishermen during the years before full implementation takes place. Then in the future, these years might be used in management decisions and once again recreational fishermen would end up with the short end of the stick. In fact, it is a shame that the new MRIP data and allocation changes were not done at the same time. The commercial sector was given larger quotas than they should not have been given and now they do not want to give it back. Most don’t even understand the problem.

Lastly, we are opposed to quota transfers between the sectors.

Respectfully submitted, John Toth President, Jersey Coast Anglers Association (JCAA)
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