Sunday, August 11, 2019

Anna on the record regarding southern flounder

The following was read into the record in May of 2015 at my final NC MFC meeting, some clarifying notes have been added in italics. 

 “Our purpose as a Commission should be to protect the resource as our primary objective. When the resource can sustain harvest, all the user groups including commercial, recreational, consumers and those who simply like to know the fish are out there should be allowed to utilize the resource.
The problem is that we cannot continue to allow harvest at current levels while ensuring the long term viability of the Southern Flounder stock in NC.
During the initial FMP development in 2005 the indicated reduction required to stop overfishing and achieve a sustainable harvest was approximately 40%.  Instead, the commission opted for an estimated 25% reduction through various management measures.
The recreational sector did achieve some reductions in harvest as compared to the 2005 levels.  Regulations implemented by the 2005 FMP had no impact on commercial landings which continued to increase through 2009. In addition, the commission chose to twice grant exceptions to the pound net fishery and allowed harvest in December in contradiction to the standing FMP.  The management measures chosen by the commission, based on the best science at the time were intended to end overfishing and rebuild the stock but they failed.
In 2009 another stock assessment was completed and accepted for management.  Although that assessment would not pass peer review today due to new information available on Southern Flounder stock structure, it was the best available at the time.
Based on that information there was some cause for hope, even though it was also clear that a reduction in the overall harvest was needed to achieve a sustainable harvest.
Due to the hardships being faced by our commercial large mesh gill net fishery (from interactions with endangered sea turtles and newly required federal management measures), no further restrictions were placed on commercial gear types. The federally required measures appeared to be enough to result in a harvest reduction of about 20% which was assumed to be enough to end overfishing in two years and achieve a sustainable harvest.  
Soon after implementation, exemptions from the “settlement agreement”  (federal rules required to mitigate the endangered species interactions with large mesh anchored gill nets) were granted to areas including Albemarle, Croatan, Roanoke Sounds and an extra day of harvest was allowed south of Beaufort inlet.
A decrease in harvest was seen in 2010 and 2011 across all commercial gears, but analysis of commercial landings suggested lower availability in the Albemarle Sound Management Area as the main reason for the decline, not regulations.
Commercial harvest increased again in 2012 substantially.  This demonstrated that yet again the efforts by the Commission to achieve a consistent harvest reduction across the commercial sector and achieve an overall sustainable harvest level had failed. During this same time recreational regulation did achieve some additional reductions.
Although the 2014 stock assessment was not approved for management, I find the following reasons for concern and need for action:
·        The original FMP was developed to expand the spawning stock biomass. The current biomass (based on 2014 information) is stable meaning that all attempts to manage the fishery have not resulted in an increase in biomass.
·        High fishing mortality on pre spawn fish is occurring which can and apparently has limited the rebuilding of the stock by limiting the reproductive potential.
·        An extremely high portion of the landings consist of Age 0 and Age 1 immature fish. This is not good for the long term sustainability of the stock. (Juvenile Overfishing)
·        The data does not indicate any year classes moving through the population and the age structure is truncated.
·        Signs point to declines in recruitment and abundance as well as availability to recreational fisherman.
·        Even though the 2014 stock assessment was unable to model an open population, tagging studies indicate that our fish head south and no real indication that the opposite is true (Meaning that we do not appear to receive fish from other systems).
·        We also have new information that points toward a substantial amount of fish being retained for personal consumption or donations which are not tracked on trip tickets and therefore not included as a source of removal in the assessments.
The original 2005 FMP includes a statutory requirement to rebuild the stock within 10 years. There is enough information available from the 2014 assessment to indicate that we have NOT rebuilt this stock during that time period.
Many of the decisions made by this Commission over the last 10 years were due to concerns for the fisherman and the devastating socio economic impacts that come from drastic cuts.
While I am highly sympathetic to the concerns and fears of the commercial fishing industry, it is the duty of this Commission to take steps that will rebuild Southern Flounder and ensure the long term viability of the stock.  To achieve this I view the Commission as having two possible courses of action:
1) The first would put the central focus of the Commission on job retention over stock health and require reductions across gear types causing socio economic hardships across the board while likely increasing discards dramatically to achieve reductions in catch BUT retain the appearance of equity.
2) The second route puts the central focus of the Commission on the resource but requires a restructuring of the fishery to achieve a measurable management harvest while still providing access to the resource and consideration to discards, bycatch and protected species interactions.
Regardless of the path forward our purpose at this table is to achieve a sustainable level of harvest and ensure the long term viability of the stock. After 10 years of management I do see a critical need to move forward.”
-----Anna Beckwith --May, 2015

The result of the NC Fisheries Association lawsuit on flounder management:
Below is a quick summary of the management measures that were so incredibly controversial at the time.  There were six proposals put forth at the May 2015 Commission Meeting.  All are worth reading and many good ideas on how to restructure the fishery were provided.  
In the Nov. 2015 meeting the Commission voted to move forward the following management measures:
Commercial size limit increase to 15 in
Minimum mesh size for gill nets increased to 6 in
Escape panels mesh size in pound nets increased to 5.75 in
These recommendations survived the lawsuit/injunction and were implemented.

At this same meeting, the Commission also passed the following management measures but they were stopped by the lawsuit and never implemented:
Southern flounder gill nets prohibited from Oct 16-Dec 31
Recreational southern flounder fishery closed from Oct 16 – Dec 31
Pound net quota corresponding to a 38% reduction
Commercial southern flounder gig fishery closure when pound net quota is reached.

A few thoughts from Anna on large mesh gill nets, pound nets and gigs:
Large Mesh Gillnets
While never approved by the Commission, a controversial management measure was proposed to ban anchored large mesh gill nets in 2016. The proposed measure read as follows:
Large Mesh Anchored Gill Nets: Effective January 1 2016 large mesh anchored gill nets will be a prohibited gear in the taking and possession of flounder in internal waters. (This would still have allowed drop/strike/run around netting and properly deployed drift nets with large mesh gill nets but would have eliminated “set” or anchored nets).

Pound nets are a good gear type.  They allow release of undersized fish, have limited mortality when interacting with protected species and could be managed by quota and monitored reasonably well.  This being said, there is room for additional management consideration. I am not suggesting that all the ideas below are appropriate or needed but that some may be worth discussing as part of the needed restructuring of the fishery via an amendment.   The pound net permit application process is extremely concerning, almost guaranteeing all applications to be approved.  It blows my mind that additional pound net permits continue to be granted given the state of the southern flounder stock.   Further consideration of capacity by area and increasing required gaps between pound nets should be considered to allow increased escapement by flounder to their offshore spawning grounds. 

A few additional management measures for consideration might include:
·        Construction of escape panels including increasing the number or size.    
       Assess if the location, type of webbing or placement can be altered to increase escapement.
·        Assess capacity by area; set max number of pounds allowed per area.
·        Limit number of pound net permits and/or allowed harvest per SCFL.
·        Limit number of pounds harvested per pound net set each year. 
·       Prohibit pound nets in crab spawning areas. (Already delineated near inlets, allowing flounder to escape into the ocean.) 
·        Implement TAC (total allowable catch) by region, recognizing seasonality in Northern, Central and Southern Zones.
·        Require daily reporting as condition of permit.
·        Moratorium on new pound net permits and permit transfers until a sustainable harvest is achieved.

Commercial Gigs: Allow only 4 days per week with a 15 inch size limit and trip limit of 36 flounder per valid SCFL on the boat with a max of 2 limits per boat.