The Jersey Coast Anglers Association represents 75 recreational fishing clubs who fish the waters off New Jersey. Our member clubs have reviewed the draft addendum and provide the following comments.
We support and recommend either Option 2A or Option 3A since they appear to be the same for the following reasons.
The Option, which is not in this document, which should be, is that the Harvest Quota be revisited and increased to a more realistic level consistent with the historical information provided in this document.
First and most importantly the Statement of the Problem has made basic assumptions that must be addressed. The Stock Status on page 4 states, “Based on the June 2010 assessment update, the stock is not over fished and over fishing is not occurring (Shepherd and Nieland 2010). The stock has been considered rebuilt since 2009.” Why then is it necessary to even consider this document with its unrealistic low harvest quota?
That said, the harvest level for the last 15 years has varied from a high of 4.3 mlbs in 1997 when there was no harvest limit and a size limit of 9” with the season open all year to a low of 1.2 mlbs in 1998 when the harvest limit was 3.15 mlbs, the size limit was 10” and the season was closed for two weeks in August. In 2000, 2001 and 2002 the harvest exceeded the harvest limit. From 2003 to 2008 the harvest limit varied from 4.13 mlbs to 2.11 mlbs and the harvest never exceeded the limit.
Therefore until 2008 there did not seem to be a problem with either the catch level or the harvest limit at a 12” size limit. So what happened in 2009 and 2010 to cause a perceived problem? The harvest limit was lowered to 1.14 mlbs in 2009, which guaranteed that the harvest limit would be exceeded even with the increase in size to 12.5”. In 2010 the harvest limit was increased from the 2009 level to 1.83 mlbs. This was still less than the 2008 level of 2.11 mlbs, which was the lowest in the time series since 1996. Not surprisingly the harvest exceeded the harvest limit. The real problem is seemingly the low quota.
One only has to look at the entire picture to see where the problem lies. It is clear that the PROBLEM is in the harvest limit. Anyone who has been on the water fishing for Sea Bass for the last 15 years would have a difficult time reconciling in their minds that the fishery has varied as much as the numbers in this document would indicate. In addition there is no clear trend in the harvest numbers, which come from the MRFSS survey, which was specifically designed to view trends in a fishery. The numbers vary considerably thus supporting that there is a clear problem with the data used to estimate the harvest level.
One would think that since the harvest numbers are taken from a survey designed to show trends then the longest possible time frame must be used to estimate a harvest level. As such Option 2A or Option 3A are the only viable options, which is the state by state regulation based on a 5 year landing average. Using time frames of less than 5 years does not adequately reflect the trends that are occurring in the fishery.
It also does not compute that with a shortened season that the harvest in 2010 should have exceeded the harvest in 2009. Something is wrong with this picture. A root cause analysis should be conducted to ascertain where the problems lie. It is difficult to follow the logic used in this document. Why did the harvest levels and harvest limits remain relatively constant in the 2004 -2006-time frame?
Looking at Table 3 for 2006 to 2008 on page 13 again shows the inaccuracy of the data used in this document. The table shows 0% fish caught in waves 1 and 2 from New Jersey north to Massachusetts. There was an offshore fishery during that time frame. This fact is noted on page 4 of the document under fishery description and yet it is ignored and 0% fish are reported. If Party Boat Logbook data had been even glanced at this data would at least show some fish caught.
There is another misconception in the document. On page 7 it is noted: “The MRFSS data used to set state by state specific conservation equivalent measures produces more variable results when used on a state-by-state basis. As the coverage area increases the variability of the data decreases; therefore, adopting regional or coast wide approaches will give more credibility to the data.” This is illogical. This is a question of sample size. The incorrect assumption is that the sample size has increased; therefore the data is more credible. What is not considered is that increasing the coverage area introduces additional variables such as different weather patterns and fish availability. Therefore the data in each individual area must be examined separately. Combining areas cannot be used as a justification that the variability decreases. What it does show is that the sample size in each individual state is totally inadequate.
