mrfssletter

Dear Mr. Chairman:

        After reviewing the Wave 3 and 4 MRFSS data for the summer flounder fisheries in New York and New Jersey, the Recreational Fishing Alliance is convinced that this data is inaccurate and unreliable. The Wave 3 and 4 MRFSS data that we have reviewed shows a significant increase in the 2003 Wave 3 and 4 landings compared to 2002 Wave 3 and 4 data. By all accounts, this MRFSS data showing an increased summer flounder catch is inconsistent with National Weather Service data, party and charter boat Vessel Trip Report (VTR) data, bait and tackle sales data, marina service data, marine fuel sales data, and state boat registration data.

        First, as evidenced by the enclosed data from the National Weather Service (NWS), New York and New Jersey experienced particularly poor weather during the months of May and June 2003. The recreational summer flounder fishery, like all recreational fisheries, is heavily dependent upon favorable weather. Wind, sea conditions, precipitation and temperature each have a significant impact on the recreational summer flounder fishery. Adverse weather conditions invariably result in less recreational effort and participation and thus, less landings.

        The extremely poor weather conditions experienced by New York and New Jersey in May and June 2003 resulted in significantly less effort and participation in the recreational summer flounder fishery. However, the MRFSS data indicates the opposite!

        We strongly urge the Monitoring Committee to review the enclosed NWS data, consider these dynamics of the recreational summer flounder fishery, and question the accuracy and reliability of the Wave 3 and 4 MRFSS data.

        Second, the enclosed data based on New York and New Jersey party and charter boat VTRs demonstrates that these vessels made significantly less summer flounder trips in May and June 2003 than May and June 2002 because of the adverse weather conditions. If 80-foot party boats are not sailing for summer flounder because of adverse weather conditions then thousands of 18-30 foot recreational fishing vessels in New York and New Jersey will not be sailing either.

        We strongly urge the Monitoring Committee to review the enclosed
party and charter boat data, consider these dynamics of the recreational summer flounder fishery, and question the accuracy and reliability of the Wave 3 and 4 MRFSS data.

        Third, the enclosed data provided by members of the New York
Fishing Tackle Trade Association (NYFTTA) demonstrates that New York summer flounder bait and tackle sales during May and June 2003 were significantly lower than May and June 2002. The adverse weather conditions in New York during this time period recorded by NWS resulted in significantly less effort and participation in the recreational summer flounder fishery which led to less summer flounder bait and tackle sales. If summer flounder bait and tackle purchases were down during May and June 2003, it is highly unlikely that recreational landings could increase. Yet, MRFSS says landings increased.

        We strongly urge the Monitoring Committee to review the enclosed
New York summer flounder bait and tackle data, consider these dynamics of the recreational summer flounder fishery, and question the accuracy and reliability of the Wave 3 and 4 MRFSS data.

        Fourth, the enclosed data from both the New York and New Jersey Marine Trades Association demonstrates that recreational marina services and fuel sales were down in May and June 2003 compared to May and June of 2002 as a result of the adverse weather conditions. Less recreational marina services and fuel sales means less effort and participation in the summer flounder fishery and thus, less landings. However, MRFSS shows the opposite.

        We strongly urge the Monitoring Committee to review the enclosed
MTA marina service and marine fuel sales data, consider these dynamics of the recreational summer flounder fishery, and question the accuracy and reliability of the Wave 3 and 4 MRFSS data.

        Finally, the enclosed data provided by the State of New York and the State of New Jersey demonstrates that recreational boat registrations dropped in May and June 2003 compared to May and June 2002. Many of the recreational boats registered in New York and New Jersey participate in the recreational summer flounder fishery. Logically, if recreational boat registrations were down, effort and participation in the summer flounder fishery was also down. Less effort and participation means less landings, yet, MRFSS shows the opposite.

        In conclusion, the 2003 Wave 3 and 4 MRFSS data for New York and New Jersey says the recreational summer flounder catch increased in 2003. By all other indications, this was impossible. National Weather Service data, party and charter boat Vessel Trip Report (VTR) data, bait and tackle sales data, marina service data, marine fuel sales data, and state boat registration data all indicates that effort and participation in the recreational summer flounder fishery was down. We strongly urge you to consider this before making recommendations for the 2004 summer flounder fishery.

       Respectfully submitted,
       John Mantione