JCAA POSITION STATEMENT:
1995 Summer Flounder Recreational Allocation
(from Jersey Coast Anglers Association March 1995 Newsletter)
The Jersey Coast Anglers Association, a grass roots sport fishermen's conservation and political action group representing 90 saltwater sportfishing clubs with over 30,000 members, feels that a loosening of the harvest restrictions on summer flounder presently in place for recreational fishermen is in order for the 1995 season. This relaxation is both justifiable and fair. During the initial implementation of the Summer Flounder Management Plan, recreational size limits, bag limits and seasons were set at extremely restrictive levels to head off any possibility of harvesting above the recreational harvest caps. At the same time, ASMFC and the Council bent over backwards to make sure the commercial sector was able to harvest every last pound of their allowable quota. The harvest quotas were set in accordance with the plan to maintain a 60/40 allocation of the total allowable harvest between commercial and recreational user groups. Unfortunately, that allocation ratio is no longer being maintained and we demand that the Council and Commission make changes to bring it back into line with the original intent of the plan. In the first two years of implementation; the conservative recreational bag limits and seasons resulted in landings well under the allowable cap. In 1993, the recreational user group fell short of its harvest cap by almost a million pounds and in 1994, they fell short by over two million pounds. During the development of the bag limits and seasonal closures for both 1993 and 1994, JCAA testified that the proposed regulations were too restrictive and that they would result in the recreational user group falling far short of its cap if they were adopted. We were ignored both times and we're getting very tired of being ignored by fisheries management agencies that are supposed to represent both user groups through an open door public process.
Obviously, JCAA was correct in its positions and has been proven so by the scientific data generated by the National Marine Fisheries Service. The bag limits and seasonal closures were definitely restrictive enough to prevent exceeding the recreational cap, but we can also see that they were so restrictive that they have placed the recreational user group at a decided disadvantage. In fact, they were so restrictive that they have skewed the balance of allocation between the user groups dramatically and they must be reevaluated if the original intent of the plan is to be met. As fishery managers, you must keep in mind that the summer flounder is of extreme importance to sport fishermen and the sport fishing industry as a whole and to continue chipping away at the recreational harvest with overly restrictive bag limits and seasons is doing serious damage to an important component of the sport fishing industry. For this reason, JCAA demands no bag limit, retention of the 14 inch size limit and no seasonal closures for the recreational fishery in 1995. Our justification for this position is supported by Table 10 in the Summer Flounder Monitoring Committee report dated February 15, 1995. According to Table 10 (Estimated stock numbers for 1995 and the associated unregulated recreational harvest based on the relationship between stock size and recreational landings for 1982-1992), the 1995 potential recreational landings in a year of medium recruitment would be 8,387,000 pounds. Keep in mind that the 8.387 million pound potential landing figure is arrived at with no bag limit, no size limit and no seasonal closures. Under the present plan, the recreational user group is going to be allocated 7,760,000 pounds of summer flounder, or just 627,000 pounds short of the potential landings listed in Table 10 with no restrictions whatsoever. Just the imposition of the 14 inch size limit will cut down the potential harvest so dramatically, that additional restrictions in the form of bag limits and seasonal closures are not needed. A look at the catch frequency tables provided by NMFS for recreationally caught summer flounder supports this position. The number of anglers landing an average of five fish per trip is only 1 in 25. The number of anglers landing an average of nine fish per trip is only 1 in 100. These catch frequency tables do not take into consideration the fact that only one out of every three fish an angler catches is of legal size under the 14 inch size limit and that recreational anglers release two of every three fish they catch. Therefore, the possibility of retaining 10 keeper fish per day is so slim that it doesn't even show up on the charts. The reasons are obvious. First the angler must catch 30 fish during the day to find the 10 legal size fish and, second, his chance of catching that many fish in a single day is so slim as to be almost impossible. The tables clearly show that by increasing the recreational bag limit, you do not proportionally increase the recreational landings. In fact, the increase from a six to a ten fish bag limit only increases the overall landings by 4.6%, or a poundage increase of about 300,000 to 400,000 pounds total per year. By increasing from six to ten fish, you have increased the bag limit by 66%, but only increased the landings by 4.6%. The increased economic benefit of an unregulated bag limit with no seasonal closure over a set, restrictive bag limit and the imposition of seasonal closures is dramatic, indeed.
The perception of the marine recreational fisherman that he will be able to harvest more summer flounder per trip is what fuels this economically important fishery, one that is of critical importance to party and charter boat fleets, boat rental liveries, tackle shop sales of bait and gear, and on up the distribution chain. It is the perception that fuels participation and regardless of how slim an angler's chance of actually realizing the increase in landings, it is secondary to the perception by the angling public that it can catch and take home more fish. The catch frequency tables show a clear pattern of potential recreational landings that is far more effected by the level of annual recruitment than it is by bag limits and seasonal closures and this alone should see an end to bag limits and seasonal closures for this important fishery in 1995. What is far more important in this plan is the balanced harvest ratio of 60/40. The ASMFC and Council must get back on target and re-establish the harvest equilibrium that is mandated by the plan. The restrictive bag limits and seasonal closures placed on recreational fishermen under Amendment 2 have effectively changed the allocation balance as set forth in the original plan. This can not be allowed to continue or the summer flounder plan will go from being one that was founded in a fair and equitable user group allocation to one that is usurping the harvest allocation of one user group to the benefit of the other. This can not be allowed to happen and gives further credence to our demand for the removal of bag limits and seasonal closures for the recreational sector in 1995. From the beginning, the recrea-tional user group has given this plan its support. We have conserved, practiced catch and release and lived by the rules as set down by the Council and the Commission. Now, the latest studies by marine biologists indicate that hook and release mortality is far lower than originally thought and planned for in this FMP. That means the recreational sector is actually killing far fewer summer flounder than the plan accounts for and providing an even greater conservation benefit to the fishery. The commercial user group has demanded four amendments to the plan in just the last two years, each one making it easier for them to harvest and sell greater numbers of summer flounder. Only one was actually justified, but the ASMFC and Council continue to exhibit an over-riding commercial bias in all of their management plans and kowtowed to the commercial pressure. To make matters even worse, the commercial user group is so adamant about denying the conservation efforts as imposed under this FMP that they sued the Council to further increase their harvest quota and line their pockets. They did this because the Council was supposedly too conservative in the calculations used to establish the commercial quota for 1994. At the end of the 1994 fishing season, the Council's decision to set the commercial quota a bit more conservatively was borne out as being the right decision, but the courts now demand that the commercial sector receive an additional harvest allocation that will further skew the original intent of the plan, regardless of the detrimental impact it will have on the recreational user group.
The recreational sector has worked with the Council and Commission in developing this plan and abided by the decisions that were made, regardless of our deep feeling that we were not being dealt with fairly when it came to bag limits and seasonal closures. We have made conservation our watchword! Now, we demand that the Council and Commission act properly and fairly by mandating that the recreational user group be allowed to fish under no bag limit and with no seasonal closures in 1995.
• The preceding statement was presented at the Council meeting by Gary Dickerson, Chairman of the JCAA Fluke Committee.