Controversy Brewing at Fishery Management Councils

By January 11, 2022Uncategorized

Fixing recreational data should be straight-forward, but it’s not.

One of the most confusing debates in all of fisheries management these days is the subject of NOAA Fisheries recalibrating its own historical recreational harvest data (not to be confused with the controversy over calibrating state fisheries data with federal data – that’s an entirely different recalibration controversy).

In its simplest form, this recalibration is the method by which NOAA’s historical recreational harvest data for a species of fish is recalculated using improved techniques. The controversy comes because the process often (but not always) yields a larger allocation of fish to the recreational sector. These percentage shifts can be quite large, but because the process deals solely with recreational data, the impact to the commercial sector is zero in terms of that sector’s poundage quota. Nevertheless, commercial harvesters opposed to any benefit to the recreational sector under any circumstances are preparing for battle over what should be a routine, automatic adjustment.

To begin, you must understand how NOAA Fisheries has collected recreational harvest data and how that process is being updated. The NOAA Fisheries program for collecting recreational fishing catch data is called the Marine Recreational Information Program (MRIP). MRIP consists of two components and the first is the angler intercept portion, where an interviewer approaches you at a boat ramp or an ocean pier or marina and asks to see your catch, among other questions. From this they estimate the Catch per Trip.

The second portion of the survey was done by telephone. Someone would call household landlines and ask how many times whoever answered went fishing in the past few weeks. Not that many years ago, this process was entirely random. Surveyors would call coastal households with no indication anyone there even fished other than the fact that it was a coastal household. Recreational licensing systems have narrowed down the universe of potential call recipients at least to households with a registered angler. The information from this landline call would be used to estimate the Number of Trips that anglers had taken.

From those two estimates NOAA would use a simple calculation to estimate the total of what anglers had caught: average Catch per Trip multiplied by Number of Trips = Catch. Every time you have ever heard anglers accused of catching more than their allocation, it has been based on this tenuous multiplication of an estimate by another estimate.

It became clear that the second part of the program – the Coastal Household Telephone Survey – was not the best way to gather data on trips, simply because people were switching to cell phone and landline use was declining. It was felt the telephone survey was probably under-estimating the number of trips. So NOAA Fisheries tested new methods for estimating trips and came up with a mail survey as the best method. The new method estimated a two- to six-times increase in the number of recreational trips, which translated into higher catch than previously thought.

This is where the controversy begins.

Imagine you were managing a fishery with a 100,000-pound annual catch limit that was allocated 70 percent recreational and 30 percent commercial and, like most fish stocks, there is no stock assessment available. That means 70,000 pounds for the rec sector and 30,000 pounds for the commercial sector. For simplicity’s sake, we’ll say the new information from the mailed survey (now known as the Fishing Effort Survey or FES), increased the estimated recreational catch by a factor of two. That means the new annual catch limit is 170,000 pounds, and since every “new” pound in that catch limit came from the rec sector, the allocation shifts to 82 percent recreational (140,000 pounds) and 18 percent (30,000 pounds) for commercial. After all, the original allocations were set based on catch history. With the new MRIP method, that history, and the resulting new allocation, are more accurate.

Though the commercial sector has not lost any pounds of harvest in this process, it has not stopped some quarters from labeling this recalculation “unfair.” Often the argument is made to just apply the old percentages to the new annual catch limit. In the example above, that would mean applying the 70:30 ratio to the new limit of 170,000 pounds. That would equate to 119,000 pounds for the rec sector and 51,000 pounds for commercial. In this scenario, 21,000 pounds has been reallocated to the commercial quota even though that sector did nothing to justify it. Since the new allocation reflects greater historical recreational fishing effort, not giving the entire increase to the rec sector actually damages the rec fishery and would result in shorter seasons. Giving the entire increase to the rec sector would almost certainly not result in a longer season for most fisheries since the greater allocation is being harvested by greater effort. In most scenarios, both sectors would largely stay status quo despite the change in allocation. If we don’t give those rec fish to the rec sector, we are only setting up the fishery for a management failure by giving the sector actually less fish than they had last year.

For stocks with a stock assessment that calculates an overfishing limit, the increase in effort and the resulting increase in allocation percentage is not as direct. Most stock assessments are full of variable datasets used to determine the status of the stock. While the recreational catch and discard data is just one dataset among several, it is often among the most robust – it would be difficult to do many stock assessments without the recreational data. So, two- to six-fold increase in recreational catch sends a strong signal that the stock size had to be much larger for those fish to be caught. While the change in allowable catch might not be as simple as those stocks without an assessment, common sense indicates the increase in stock size and thus allowable catch was primarily due to the increase in recreational catch.

There has also been talk of these recalculations rewarding an “unaccountable” sector with more allocation. This implies that the recreational sector was catching more fish than it was supposed to, so it should be restrained, not rewarded. This is faulty logic that ignores the fact that this change came about solely due to a peer reviewed change in the science of how recreational data is collected. The increase represents fish that were actually caught by the recreational fishery, and those fish had to come from somewhere. What the new process makes clear is that managers have never had a clear idea of what anglers were catching or how big the population of fish is/was.

Since the commercial and recreational catch data are often the most robust datasets managers have – and are the driving force in a stock assessment determining the size of the stock and thus the allowable catch – the new process defines a more accurate reality in the fishery.

Recalibrations of this nature dealing with historic data should be automatic. Instead, they are poised to be fought over tooth and nail and that is a failing of the federal management system. Allocations should be managed by a regularly scheduled, certified process that looks not only at the most accurate past catch history available but also at modern and forward-looking data like economics and demographics. NOAA Fisheries’ reluctance or inability to guide a true reallocation process and rely instead solely on decades-old, incorrect past catch history for allocations means that recalibrations like this are subject to intense battles.

With recalibrations expected for every fishery under federal management, there is a lot at stake in this process for recreational anglers.

Kevin Hickson

Author Kevin Hickson

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