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Highly Migratory Species Report
by John T. Koegler
(from Jersey Coast Anglers Association May 2003 Newsletter)
ACCSP
Atlantic Coastal Cooperative Statistics Program (ACCSP) is a long mystifying name. It is a partnership of 23 state and federal coastal resource management agencies. You will become more familiar with the ACCSP in the future. The impact of the ACCSP reports on recreational anglers will affect the recreational numbers for all fisheries with a fishery management plan as ACCSP data replaces Marine Recreational Fishery Statistical Survey (MRFSS). MRFSS is the current federal program that estimates recreational angler catches. ACCSP’s intent is noble. Its prime directive is that accurate catch information results in good management decisions.
One result of their interest in accurate fishing data is a new program to count charterboat and headboat landings. ACCSP plans to start in May 2003 to statistically estimate recreational landings from charterboats and headboats. This is surprising since this statistical program will replace a current NMFS mandated hard count program known as Vessel Trip Reporting (VTR). Most fish species caught from charterboats and headboats require federal permits and are mandated to be reported as a hard count number plus any discards to NMFS Gloucester, Mass. for Mid-Atlantic based charter and headboats. The fish species currently requiring charterboat/headboat permits in federal waters are: NE multi-species which includes all the New England ground species, summer flounder, black sea bass and scup (porgies), monkfish, Atlantic mackerel, squid and butterfish, bluefish, tilefish, Atlantic herring, and spiny dogfish.
These hard count numbers may not have ever been fully tabulated despite NMFS mandated reporting requirement. The explanation given was that there is a budget problem and NMFS cannot count everything. A more supportable explanation is that charterboat and headboat landings were under reported the same way the whole recreational catch was. This means that by always underestimating total recreational catch NMFS will underestimate the total stock biomass and the whole recreational sector is then also penalized by smaller quota allocations. And more shocking is NMFS desire to end this program as soon as the new ACCSP program is up and running. In all other past changes in fishery management plan counting systems, NMFS has always taken the position that any new landing counting program must run concurrently with the old program to determine how the new program is functioning to validate the accuracy of the new program. Could it be that they do not want us to have information that shows us how bad the new surveys will be?
Why would NMFS eliminate a hard count program for a statistical program? Cynics would say the VTR program gave NMFS information that was contrary to their commercialization of recreational fisheries. VTR was a hard count program and did not allow regulators to control the resulting numbers. Would NMFS really eliminate a mandated program just because it could not be manipulated? This is the first and only time that a hard count NMFS program has ended in favor of a statistical survey. Managers set and control the parameters in any statistical program and, therefore, influence the resulting numbers in a major way.
The real issue can be explained this way. Charterboat operators have been asking NMFS for a long time to accurately count their landings. They have been delaying this program until all key recreational fisheries have a fishery management plan in force. The percentage split of Total Allowable Landings (TAL) between commercial and recreational has already been determined. This new landing data will likely permit NMFS to continue their commercialization of the ocean’s resources, since the new program will allow the ACCSP division of ASMFC to control the charterboat landing numbers.
There are no rules in the current fishery management system to accommodate or adjust commercial/recreational quota splits for these new higher landings from undercounted fisheries, even if historical.
If the FMP allocations and quotas are not adjusted for new statistical estimates, the recreational landings could be sharply higher and result in more restrictive rules for both recreational and charterboat/headboats.
Charterboat captains as a group believe that current bag limits have dramatically reduced the number of customers that fish on their boats each year. Many operators state that if the management rules get any tougher, they will be out of business. Future fishing trips will often not be enough to earn the income needed to survive. Many headboats have already changed their trip schedules. They run other non-fishing trips such as sunset cruises, dive trips, special event trips to earn the income needed to survive. They even change fisheries such as their fall canyon tuna trips by the big headboats. Some owners now move their boats south to North Carolina or Florida to keep their income high enough to pay the bills.
Having seen the total number of headboats constantly drop in major ports like Manasquan and Atlantic City, the future is not bright for their business. There has been a desire by some to split the recreational fishery between charterboat/headboats and private anglers. Could it be they want to divide the recreational community and get us fighting amongst ourselves so we become less effective? Since charterboat/headboats are considered commercial by NMFS, why not assign part of the current commercial quota to them, since the NMFS system had undercounted their landings, possibly deliberately. The new ASMFC- ACCSP program will bring to an explosive boil a problem that has been on the back burner for an extended period of time.
Some Options:
It is believed by the charterboat operators that this new program will sharply increase their reported landings. Their landings are not new- it is just that NMFS did not desire to accurately count them. So they ignored the entire issue and greatly undercounted recreational landings before quotas and allocation percentages were determined.
One solution is to adjust the commercial/recreational quota splits and make them accurate in the face of overwhelming evidence that NMFS has refused to accept that charterboats are a major part of the fishery management plan’s original landing totals. Given the recreational sad record in getting “fair and equitable treatment as required by the National Standards” from the fishery, NMFS and the Atlantic States Marine Fisheries Commission making such major changes will take much hard work. It may be difficult without the help of a federal judge given our fishery managers’ long history of commercial biases. This leaves lawsuits as the only sure option. Charter and headboats cannot accept the resulting tougher quotas, bag and season limits, because this will become nothing less than incremental regulatory elimination.
A New Approach
RFA, the NMMA and a growing list of supporters have filed a petition with NMFS on fluke to adjust the recreational commercial split from the current 60% commercial/ 40% angler to 50% commercial 50% angler. This petition has strong support from the historical data used in the original split of this fishery. The historical records indicate that recreational fluke is almost always greater than the commercial fishery. The only time there were greater commercial landings is when they collapsed the fishery. Then the NMFS and Atlantic States Marine Fisheries Commission did as they always do, rewarded the commercial fishery for destroying the stock by giving them the larger quota.
Since NMFS has 90 days to give a determination of merit of this petition, we do not have long to wait to find out what comes next.