Tuesday, August 26, 2014

{Tidal Potomac Fly Rodders} Re: NMFS's Recreational Saltwater Fisheries Policy

Oh brother. Does anyone listen to Witek anymore?

In the interest of full disclosure, I work for CCA National and was very involved in CCA MD. I also work for NMFS and other NGO's. In an interest of fuller disclosure, Witek used to work for CCA. This reeks of sour grapes.

Witek couldn't be further off the mark, frankly. The National Policy was not created for red snapper. The National Policy process was proposed at the last Recreational Fishing Summit, hosted my NMFS, this past spring. I was a participant in the summit. The recreational industry and recreational advocacy groups proposed the policy in response to NMFS own admission that it had a commercial fisheries bias. It is a response to repeated attempts by the Councils and NMFS to manage fisheries as if only commercial outputs are important. The crux of the argument is that recreational anglers are motivated far differently than commercial fishermen, that recreational fishermen prefer abundance over maximum sustained yield, that absolute certainty in catch levels is neither attainable or necessary for recreational fisheries management, there has to be some process for changing allocations that doesn't simply reward past mistakes and, finally, policy makers should think long and hard about privatizing public resources when one of those resource users is the recreational sector. None of these issue are specific to red snapper, we just happen to seem them being played out in the most onerous way possible in red snapper.

Let's take the last point as one example. Bill Bird was referring to waiting to further privatize the red snapper fishery until after NMFS and the recreational community have decided if catch shares, or privatizing the public fishery resource, is indeed appropriate for mixed commercial/recreational fisheries. As a bit of context, red snapper is fully recovered but is still within the legally mandated recovery window. The stock is likely much larger than is currently estimated. Last year the overall quota was raised several million pounds. But because the stock is so thick and the individual fish are increasing in size, recreational catch-per-unit effort is through the roof. So this year it takes less effort to catch the same amount of fish as last year. But the mortality rate is stable or falling. Seasons get shorter and shorter. This year's recreational season will be 9 days. Except on the commercial side. They were granted a private right to the red snapper and can catch those fish whenever they want. So now the charter/for-hire industry wants in on the stability. So they are going to take more than half the current recreational quota and privatize it in Amendment 40. If that Amendment passes, it will be the end of the private recreational red snapper fishery. Within a year, they will close Federal waters to the private angler completely unless they can afford to go out on a charter or headboat. All of this is happening while the stock is in better shape than ever and while NMFS economic analysis indicates that the recreational sector should have their allocation of red snapper increased. 

Catch shares have shown to be excellent tools in commercial fisheries. 60% of all boats leave the fishery practically overnight. They make the remaining participants wealthy instantaneously. The jury is out regarding whether or not they have stock benefits. But never mind that; NMFS is hell bent on instituting them in all fisheries. However, every time catch shares are instituted in a mixed commercial/recreational fishery, the recreational sector is crushed. Do some reading on AK halibut. Many in the recreational community think our public resources should not ever be privatized. Would you like to manage a portfolio of tags for all the fish you wanted to keep? Worrying about being able to find a few striper tags on Craigslist before you went fishing? Or maybe there wouldn't be any trade and you'd put your name in a hat for a random draw of tags. Most recreational anglers are not interested in that. Most are more interested in the opportunity to go fishing. How would this impact catch and release fishing? Would they allow trading and sale of recreational tags? There are more questions than answers. Bird's statement is maybe we should answer some of those questions before we blindly go down that road. Recreational catch shares HAVE NEVER been used in recreational fisheries. There are currently two studies evaluating their use underway. They may work. They may not. But it should be investigated before implementation. Maybe we should at least wait until the studies that are underway are completed. That is what Bird is saying.

Instead, Amendment 40 is being rushed through without that analysis. Many feel that the North American wildlife management model should be applied to saltwater fisheries. Where it has been used, it has been very successful (read all inshore species in the Gulf, all freshwater fisheries, all hunting). The states do not manage to a hard quota in saltwater, they manage to a mortality rate and they set that rate to maximize abundance and opportunity. And it works. CCA isn't asking for more fish for more fishes sake and certainly not asking for more fish if those increases would jeopardized stock health. CCA is a conservation association. Just look at their call for a voluntary 1 fish bag limit in MD.  All CCA, and the rest of the recreational community is asking for, is some flexibility and a halt of the privatization process until NMFS can examine the issue fully. Right now, NMFS, the Council and the commercial quota holders think the only option forward with red snapper is limited entry; some sort of tag based system that limits the number of anglers. And that may indeed be necessary. But the way into that as a solution isn't privatization without any analysis. What Witek also fails to mention is that public comment, from both the charter/for-hire sector and the private recreational community, is overwhelmingly opposed to Amendment 40. 

I'm happy to talk more about this stuff on or off line. I'm headed to the Council meeting tomorrow to watch how Amendment 40 plays out in real time. 

Thanks for posting this up. If you love the resource, you need to stay up on policy. And get involved. But make sure your sources of information go beyond me and certainly beyond the blogosphere. Get educated. Pay attention. Act. 

Brad

On Monday, August 25, 2014 12:59:33 PM UTC-7, Misha Gill wrote:
I read this interesting blog post about the National Marine Fisheries Service's (A division of NOAA) proposed Recreational Saltwater Fisheries Policy and thought you all might be interested. I am interested to get yalls perspectives. The author of the post essentially claims that the Coastal Conservation Association is trying to hijack or dilute the new policy to suit its constituency's purposes, which is selling tackle to Gulf of Mexico anglers chasing Red Snapper. Fair warning, the tone of the article is a little shrill, but if there's any truth to it then it's pretty alarming. You can also comment directly on the proposed policy here if after reading you want to take action. 

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