In Response to “Another View on Gulf Red Snapper Management”
from The Fishing Wire

Recreational angling stakeholders recently released a joint one-pager on the potential impacts of bureaucratic decisions regarding the red snapper fishery in the Gulf of Mexico. As part of that release, the Congressional Sportsmen’s Foundation (Foundation) – not the Congressional Sportsmen’s Caucus – issued a press release on the current proposal before the Gulf of Mexico Fishery Management Council (Council) that looks to pit components of the recreational sector against one another. While coverage of the one-pager has been well-received, the release’s recreational angling outlook received a naïve assessment entitled “Another View on Gulf Red Snapper Management” as published in the July 24 edition of the Fishing Wire.

The author, a former representative on the Gulf of Mexico Fishery Management Council, criticizes the Foundation and its partners for suggesting that the Council has not done a good job of developing real solutions to the challenges facing red snapper anglers. He states that, “In reality, the Council has been working on red snapper management alternatives for decades by implementing various management tools, such as bag and size limits, seasons, and quotas.” Unfortunately, the “reality” we’ve seen is shorter and shorter federal recreational red snapper seasons, culminating in the shortest ever: nine days in 2014. If sector separation (Amendment 40) is successful, the average recreational angler will likely see zero days in federal waters despite snapper populations that are more abundant than ever documented. How can the trend of fewer and fewer days to fish for the healthiest population of red snapper in history be considered successful management?

It is clear the author subscribes to the theory that separating the two identifiable components of the recreational sector will solve the problems for recreational anglers, especially the charter-for-hire (CFH) component. If you are a charter captain who was given only nine days to fish this year, having your own quota may seem like the silver bullet you need to make a living. Any business owner could sympathize with looking for an alternative lifeline. But one must question if it is really the salvation of the industry?

Although he states there is no comparison between the commercial sector’s catch share program and sector separation, later on he says that “each new recreational sector would be responsible for their quota.” How can a small, finite number of charter captains not be allocated some form of individual shares or quota? Although an Individual Fishing Quota (IFQ) program for the CFH sector is not specifically part of Amendment 40, the 178-page amendment document makes several references where this form of catch shares would be an option for managing the new CFH sector if Amendment 40 is successful. That, combined with the current Head Boat Exempted Fishing Permit (EFP) and the proposed Alabama Charter-for-Hire EFP, suggests that is exactly where this is headed – Individual charter captains holding individual shares of quota.

Charter captains need only to take a look at other sector separation and catch share programs to be concerned. In all catch share fisheries to date, over 50% of all fishery participants exited the fishery. Ultimately, if you don’t hold an initial share, you are out of luck to begin with. That’s what catch shares are designed to do … to reduce capacity by getting boats off the water. There will be winners, yes. But there will be losers as well. More losers than winners. Is it worth the gamble? Just ask an Alaskan charter boat captain how sector separation in the halibut fishery has worked for them.

The author points out that since the commercial sector’s individual fishing quota went into effect, that sector has not exceeded their quota once, while the recreational sector has exceeded their quota most every year. This is the same argument used by the commercial sector to emphasize how great the commercial IFQ program is while labeling the recreational sector “unaccountable.” Despite what the commercial industry and environmental groups proclaim, recreational anglers (both private and CFH components) have been accountable and abide by the law and the regulations. It is the federal system of fisheries management that has been “unaccountable” and has failed the recreational fishing public as a whole.

Finally the editorial states that, “Currently, there are two distinct components of the recreational fishing sector…” According to section 407(d) of the Magnuson-Stevens Act, which deals specifically with red snapper, there is just one. Private recreational anglers and CFH are distinctly treated as a single component and rightly so. One has the means of accessing red snapper on their own, whether they own a boat or know folks who do, while the other provides a service for the rest of the American public who does not. The recreational sector of the red snapper fishery is intended for any American to be able to go to the Gulf of Mexico and catch red snapper if they so choose. All other successfully managed Gulf recreational fisheries have the same two components of the recreational sector, yet they are successfully managed as one. Why do we need to split the two for Gulf red snapper to provide relief for a minority of the CFH captains?

In short – we don’t. The Council needs to get serious about managing the fishery as a whole. Trying to apply that same commercial model to the recreational sector has proven unsuccessful. Holistic management will require some controversial, but appropriate, choices like that of true re-examination of allocations, not just above 9.12 million pounds. The current quota of 49% recreational/51% commercial has not been updated in nearly three decades and was established at a time when recreational angling for red snapper was at an all-time low using survey methodologies that have since been replaced because of gross inaccuracies. That, in and of itself, begs for a new look at where we are today. Red snapper, and all our marine fisheries resources, belong to us all. Good government mandates that we make the best use of our public trust resources for the benefit of the nation as a whole.

We need to take a hard look at how the states would manage red snapper. The states have successfully managed recreational fisheries for a century, but not based on how the Council or NOAA fumbles with fisheries management. States have been successful because they manage on a rate of harvest and not by trying to squeeze every pound out of the fishery as does federal fisheries management with its concept of maximum sustainable yield. The Council needs to implement alternative, harvest-based management of the fisheries, or simply give it to the states which have more experience and better data.

Red snapper can be managed to benefit both recreational and commercial fishermen. However, sector separation will only ensure that there are a few winners and a bunch of losers. Sector separation is not the answer.

Mike Nussman
American Sportfishing Association

Jeff Crane
Congressional Sportsmen’s Foundation

Pat Murray
Coastal Conservation Association

Steve Stock
Guy Harvey Foundation

Jeff Angers
Center for Coastal Conservation

Thom Dammrich
National Marine Manufacturers Association