jason colby

PETITION BY CLF FOR MORATORIUM ON ATLANTIC COD

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___________________________________________________

BREAKING NEWS TODAY - PETITION BY CLF FOR MORATORIUM ON ATLANTIC COD - FEB. 13, 2020

 

"The mismanagement of the Atlantic cod fishery is a direct result of NMFS approving risk-prone actions year after year that elevated short-term economic interests over long-term conservation benefits for the fishery and fishing communities.

 

The consequences of that ultimately bankrupt strategy have been severe for Atlantic cod, which is reduced to a distant memory of its former glory; the commercial fishing industry, which has lost hundreds of jobs and fishing operations; recreational fisheries that are continually denied fishing opportunities; and the diminished health of the marine ecosystem."

 

These days in fishery mis-management, nothing should surprise me, but this news passed to me this afternoon on the Conservation Law Foundation filing a lawsuit on the failure of the regulatory decisions approved by NMFS in rebuilding codfish over the last quarter of a century.

 

I have given a read through of the document, and it is damning to say the least with the Petitioner requesting for a Emergency Action (pg.8) taken on both GOM and GB as both stocks continue to be in a over fished state with over fishing occurring. As much it is noted that there continues to be a failure of Council and as much the Service to approve regulatory decisions that do not meet accepted timetable rebuilding deadlines.

 

Of note is the failure of the Service to comply with National Standard Guideline 1 (pg.2) with the preeminent statements in these prior federal court rulings:

 

  • nder the Fishery Act, the Service must give priority to conservation measures.”
“The Act sets this priority in part because the longer-term economic interests of fishing communities are aligned with the conservation goals set forth in the Act. Without immediate efforts at rebuilding depleted fisheries, the very long-term survival of those fishing communities is in doubt.” “Part of the reason Congress elevated conservation over economic interests is that conserving fish populations yields the double benefit of both improving the environment and providing long-term economic return.”

 

For those who do not realize how serious this lawsuit is, these two points standout especially on the "disruption of spawning behaviors.....":

 

1- "Rather than create a flagship of U.S. fisheries management, NMFS made Atlantic cod the poster child for fishery management failure and the consequences of adopting short-term economic decisions that jeopardized the long-term future of this once seemingly inexhaustible fishery."

2- "Impaired population dynamics and reproduction at low spawning stock biomass, depletion of spawning grounds, and disruption of spawning behaviors by fishing activities, all likely also play a role."

 

There is no doubt that this will catch the attention of the hierarchy in NOAA, but so in NMFS, and that what we may believe is "set for the upcoming season," could be re-looked at and modified to address the concerns within this document (copy & paste link if necessary in your browser):

 

https://www.clf.org/wp-content/uploads/2020/02/CLF-Petition-for-Rulemaking-Atlantic-Cod_FINAL.pdf

 

As serious as a heart attack in what can now be going on with the near future management with codfish.

 

Note: Look carefully through the images posted below.

 

 
Captain Jason Colby
Little Sister Charters
 
 

02.13.20

 

mail?url=https%3A%2F%2Fmcusercontent.com mail?url=https%3A%2F%2Fmcusercontent.com mail?url=https%3A%2F%2Fmcusercontent.com mail?url=https%3A%2F%2Fmcusercontent.com
 
Just to be clear, in the chart just above the top two lines (projections) are what the government says will happen with their "management". The lower lone indicates "reality".  How can these people continue to have jobs?
It continues with the most recent stock assessment for fluke (summer flounder), sea bass and scup, all of which had their target quotas exceeded and yet the "fishery managers" are cranking up the commercial quotas for those species. In Massachusetts alone the state has just proposed a 60% commercial increase in sea bass quota. They feel if they are not screwing recreational fishermen and the fish stocks over as best they can that they are not doing their jobs!

Jason





 
 
Edited by jason colby

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Interesting.  What bothers me the most will be the collateral damage in that will a successful suit force closures of areas to ALL fishing, in that trawling there for haddock, mean cod get caught too?

 

Would they have the "insight" to allow Rod and Reel fishing in closed areas, in that you can release inadvertently caught cod?  Nah, it was NMFS that originally said there was a 100% mortality rate on released cod and stood by it until Tim Tower pointed out that he was getting returns on the tagged cod he release so I think they moved the number down to like 30% IIRC...

Edited by Roccus7

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Speaking of Tim:

 

This doesn't surprise me.  Seems ironic that the same group that was so gung ho in getting the Catch Share system implemented is now suing the government for the one thing responsible (the Catch Share/Commercial Sectors) for the demise of the cod stocks. To even think about allowing more landings of cod under the present circumstances, seems laughable. And, I agree, the resource has to come first. I guess what I think is a healthy cod stock is not what I envisioned as a healthy cod stock. Maybe the ones who are left aren't old enough to realize how it was. Or maybe everyone is just satisfied with less.  This is certainly a very frustrating system.

mail?url=https%3A%2F%2Fstatic.e-junkie.com%2Fsslpic%2F112016.8234753e3e147bfe49c2b3b815daa405.jpg&t=1581687779&ymreqid=47f842eb-4782-2309-2cf3-5d03ac010000&sig=8JfApTNLFQBX_nkxTCphRg--~C
William R. Tower, III (Tim)
President, Bunny Clark, Corp.

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The original info was sent to me by my friend Steve. Below is another well thought out response:

 

Steve,

 
It's what I've been saying for the last 3 years as it relates to the summer flounder fishery and other fisheries which have failed.  There is no long-term perspective if a 17-year decline in a single fishery is allowed to continue while the Commission and Council maintain status quo measures and turn a blind eye to managing the fishery.  And as if that decline isn't bad enough, on top of it the commercial sector receives a 50% increase last year which is possibly one of the most insane policy decisions the Commission and Council have made for a fishery that's been in a prolonged decline since 2003 and in the throes of its worst recruitment levels in the last at minimum 50 years.  For the last 10 years recruitment levels have been at record lows.  Recruitment however has shown signs of weakening since 1997 and zero measures were taken to address the cause of that problem which is arguably the most important aspect in the sustainability of any fishery.  In addition what the Commission and Council describe as the most effective and efficient means of managing removals by the recreational community is no doubt in my mind the means they employed to shift 75% of the harvestable biomass from the recreational sector to the exclusive harvest rights of the commercial fishery so they could benefit from the harvest of older age classes with higher market values.  It's why I predict the summer flounder fishery will surpass its record low by the year 2024 in just about every key category including the biomass itself.  It's also why the average catch per angler directed trip recreationally in 2018 resulted in 1.3 fish being caught per angler and it's exactly why recruitment levels dropped in excess of 200 million fish over this past decade.  It's a sad testament to how policy decisions are being made today and how the concept of fisheries management has morphed into a mechanism to exploit the resources of the ocean as opposed to managing them for growth, sustainability and long-term benefit to both commercial and recreational interests.

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Jason the CCT had that in its paper of late and with out question how in the hell do these same folks continue to direct the mismanagement of our aquatic species based upon what they have projected never ever coming close to what they predicted? What will it take when we have no fish left, before some dimwit on the board realizes what they continue to implement does not and had not worked  for the fish in the water. Flounder, Cod ,Striped bass  will continue to decline unless some one grow s a pair and decides that we need drastic measure , even if it means a closer to all user groups , but no matter what, one user group should not be given preference over another and that is clear as mud to those who are guiding these management controls on a devastated resource we all should be enjoying rather then wondering how we can save it for the future,      Peace  

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39 mins ago, Angler #1 said:

Jason the CCT had that in its paper of late and with out question how in the hell do these same folks continue to direct the mismanagement of our aquatic species based upon what they have projected never ever coming close to what they predicted? What will it take when we have no fish left, before some dimwit on the board realizes what they continue to implement does not and had not worked  for the fish in the water. Flounder, Cod ,Striped bass  will continue to decline unless some one grow s a pair and decides that we need drastic measure , even if it means a closer to all user groups , but no matter what, one user group should not be given preference over another and that is clear as mud to those who are guiding these management controls on a devastated resource we all should be enjoying rather then wondering how we can save it for the future,      Peace  

Carl-

 

I've always said we have it all wrong: Instead of managing for ("assumed") "Maximum Sustainable Yield", as is the mantra of The MS Act, we should be managing for "abundance", first and foremost. 

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3 hours ago, jason colby said:

The original info was sent to me by my friend Steve. Below is another well thought out response:

 

Steve,

 
It's what I've been saying for the last 3 years as it relates to the summer flounder fishery and other fisheries which have failed.  There is no long-term perspective if a 17-year decline in a single fishery is allowed to continue while the Commission and Council maintain status quo measures and turn a blind eye to managing the fishery.  And as if that decline isn't bad enough, on top of it the commercial sector receives a 50% increase last year which is possibly one of the most insane policy decisions the Commission and Council have made for a fishery that's been in a prolonged decline since 2003 and in the throes of its worst recruitment levels in the last at minimum 50 years.  For the last 10 years recruitment levels have been at record lows.  Recruitment however has shown signs of weakening since 1997 and zero measures were taken to address the cause of that problem which is arguably the most important aspect in the sustainability of any fishery.  In addition what the Commission and Council describe as the most effective and efficient means of managing removals by the recreational community is no doubt in my mind the means they employed to shift 75% of the harvestable biomass from the recreational sector to the exclusive harvest rights of the commercial fishery so they could benefit from the harvest of older age classes with higher market values.  It's why I predict the summer flounder fishery will surpass its record low by the year 2024 in just about every key category including the biomass itself.  It's also why the average catch per angler directed trip recreationally in 2018 resulted in 1.3 fish being caught per angler and it's exactly why recruitment levels dropped in excess of 200 million fish over this past decade.  It's a sad testament to how policy decisions are being made today and how the concept of fisheries management has morphed into a mechanism to exploit the resources of the ocean as opposed to managing them for growth, sustainability and long-term benefit to both commercial and recreational interests.

That sounds like an almost direct quote from some of Tom Smith's missives.

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15 mins ago, MakoMike said:

That sounds like an almost direct quote from some of Tom Smith's missives.

Yes, that was from Tom.

Where do you stand on this issue?

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Just now, jason colby said:

Yes, that was from Tom.

Where do you stand on this issue?

I think Tom may be onto something with his argument that the natural sex selection of the SSB has been skewed by the regs. But he has several false assertions, like the commercial fleet just started targeting bigger fish a couple of years ago and that the commercials are targeting the fish during the spawn, which they are not doing. Plus he doesn't offer any solutions.

 

We can't go back to any number of fish above 14 inches, as that will cause tremendous overfishing by the recreational sector. Same goes for any slot limits that would be reasonable from a recreational fisherman's point of view. The only way we can stay with the SSC's targeted RHL is to severely restricted the season. Like maybe a one month season that no one seems to want to do.

 

Plus there has also been some thought that it's not the sex structure of the SSB that is the problem but rather increased depredation on juvenile fluke by dogfish, which is another popular theory. At least the new assessment eliminated the retrospective pattern in the old assessment which caused so many problems. I think our best bet for the short term is to continue on the path we are on, get the reallocation done, which should substantially increased the RHL and then see where we stand. In the meantime we should ask the boys in Woods Hole to study the poor recruitment and see what they come up with. 

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The rebuilding charts say it all.

 

In any venture you need measurable and specific goals that define success and failure, a chart like that is perfect for setting and measuring expectations.

 

There should be prescribed consequences for success and failure.  

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5 mins ago, MakoMike said:

 But he has several false assertions, like the commercial fleet just started targeting bigger fish a couple of years ago and that the commercials are targeting the fish during the spawn, which they are not doing. Plus he doesn't offer any solutions.

 

 

Mike-I really don't want to get into how wrong you are on almost all counts but I will start with this part above: It is a known fact that many, many draggers with small daily quotas (200-400 pounds/day) have been catching "thousands of pounds" of smaller fluke to retain their limit of larger, more valuable fish. 

Are you going to deny this? And if you don't deny it, then doesn't that contradict what you stated?

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34 mins ago, jason colby said:

Mike-I really don't want to get into how wrong you are on almost all counts but I will start with this part above: It is a known fact that many, many draggers with small daily quotas (200-400 pounds/day) have been catching "thousands of pounds" of smaller fluke to retain their limit of larger, more valuable fish. 

Are you going to deny this? And if you don't deny it, then doesn't that contradict what you stated?

No regardless of whether it's true or not it certainly hasn't started recently. The bigger fish have always brought a higher price than the smaller fish. The price incentive to focus on bigger fish has always been there, there is nothing new about that.

 

I don't know what the rules are in MA, but during the summer in RI the landing limits are 50 to 100 pounds a day, so no one has a quota of 200-400 pounds. If your quota is 50 pounds you aren't going to make very many tows to fill your quota, one tow will probably do it, towing costs money and I doubt it would be worth the cost of an additional tow to swap out 25 pounds of slightly bigger fish. In fact most permitted vessels in RI won't even untie the lines to go out and make a tow for 50 pounds of fish. So if you have the same rules as in RI either you have a bunch of really dumb commercial fisherman or your "known facts" are simply wrong.

 

 

Edited by MakoMike

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3 mins ago, MakoMike said:

No regardless of whether it's true or not it certainly hasn't started recently. The bigger fish have always brought a higher price than the smaller fish. The price incentive to focus on bigger fish has always been there, there is nothing new about that.

 

I don't know what the rules are in MA, but during the summer in RI the landing lints are 50 to 100 pounds a day, so no one has a quota of 200-400 pounds. If your quota is 50 pounds you are aren't going to make very many tows to fill your quota, one tow will probably do it, towing costs money and I doubt it would be worth the cost of an additional tow to swap out 25 pounds of slightly bigger fish. So if you have the same rules as in RI either you have a bunch of really dumb commercial fisherman or your "known facts" are simply wrong.

Wrong again!

According to The Massachusetts DMF website: 

Nets Jun 10 - Oct 31 14 in. 300 lb.

 

So if you do the math, I tow once, keep 150 pounds out of 1000, retaining only the "sushi jumbos" at $6/pound and I toss the 850 pounds of legal, but less valuable ($2.50-$3.00/pound) over as dead discards and I tow again for another $450-$500 take. Screw the extra $50 in fuel and the 1700 pounds of fish I wasted, "I'm getting mine!" Unethical practice PAYS...

I am 100% sure that not all draggers are like that but I am also 100% sure that SOME ARE JUST LIKE THAT. There are (barely) no observers at this point and even if there ere the practice is not illegal AND there is no accountability for the discards against a quota.

I also see occasional notices sent out to the state email list that the quota isn't being filled fast enough so they are "raising/liberalizing" the daily amount (usually up to 500 lbs/day)  for the rest of a given month. They never seem to stop and consider that they are not reaching the quota because it was set too high for the available biomass in the first place.

There are also far too many draggers and gill netters working inshore waters and we (recreational anglers) have not had a good run of inshore fluke in over 5 years. Now the state is increasing the commercial limits! WTF?

This is an accross the board, systematic case of mismanagement and as a "so called fishery manager", you can help but first you have to open your eyes to the problems and stop denying they exist.

   

 

 

 

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26 mins ago, jason colby said:

Wrong again!

According to The Massachusetts DMF website: 

Nets Jun 10 - Oct 31 14 in. 300 lb.

 

So if you do the math, I tow once, keep 150 pounds out of 1000, retaining only the "sushi jumbos" at $6/pound and I toss the 850 pounds of legal, but less valuable ($2.50-$3.00/pound) over as dead discards and I tow again for another $450-$500 take. Screw the extra $50 in fuel and the 1700 pounds of fish I wasted, "I'm getting mine!" Unethical practice PAYS...

I am 100% sure that not all draggers are like that but I am also 100% sure that SOME ARE JUST LIKE THAT. There are (barely) no observers at this point and even if there ere the practice is not illegal AND there is no accountability for the discards against a quota.

I also see occasional notices sent out to the state email list that the quota isn't being filled fast enough so they are "raising/liberalizing" the daily amount (usually up to 500 lbs/day)  for the rest of a given month. They never seem to stop and consider that they are not reaching the quota because it was set too high for the available biomass in the first place.

There are also far too many draggers and gill netters working inshore waters and we (recreational anglers) have not had a good run of inshore fluke in over 5 years. Now the state is increasing the commercial limits! WTF?

This is an accross the board, systematic case of mismanagement and as a "so called fishery manager", you can help but first you have to open your eyes to the problems and stop denying they exist.

   

 

 

 

Do yourself a favor any never buy a dragger, with your math you'll be broke in a week. Do you realize what you even typed? You would throw $2,500 worth of fish (850 pounds at $3) overboard in order to spend more money to get an additional $500 worth of fish. Great businessman there. So by your logic you'd rather make less money ($1,000 for two tows) than you can make in one tow ($2,500 for the smaller fish plus the $400 for the jumbos = $2,900 total) and spend more time and money doing it! 

 

I must be missing something because I can't believe you are that dumb.

 

As far as the rest of your complaint goes, that complained about action (or maybe inaction) is the direct result of the so called green groups getting congress to mandate that the SSCs have the final say on how many fish can be caught. The SSC sets the TAC and all of the other numbers flow off of that. The councils, NMFS, GARFO, etc. etc. cannot change the TAC set by the SSC and the mandate to the councils, NMFS etc. is that the ACL be harvested without exceeding the ACL. That's the law (Magnusson-Stevens) if you don't like it get it changed, but those are the rules all of the managers have to live by. IMHO much better than the ASMFC which has no enforceable rules.

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