August 20, 2014
Gulf of Mexico Fishery Management Council
2203 N Lois Avenue
Tampa, Florida 33607 USA
Dear Chairman Boyd,
Thank you for the opportunity to comment on Reef Fish Amendment 40 – Sector Separation. Coastal Conservation Association has been involved in federal fisheries management since the 1980s and has rarely witnessed such a relentless manipulation of the federal fisheries management process to secure extraordinary rights for a select portion of the fishery.
South Atlantic Fisheries Management Council Public Comment ends at 5pm on August 18
Regarding the transferability of Dolphin and Wahoo filets into the US EEZ from the Bahamas
Dolphin Wahoo Amendment 7 and Snapper Grouper Amendment 33
CCA believes that the SAFMC should make the federal dolphin and wahoo regulations consistent with the existing federal reef fish regulations with regard to the possession, transportation and landing of Dolphin and Wahoo legally caught under Bahamian regulations and brought into the US EEZ. Under existing regulations, Snapper and Grouper are able to be brought back into the United States filleted, but Dolphin and Wahoo are required to be landed with the head and fins intact. CCA urges the South Atlantic Fishery Management Council to modify current regulations to allow dolphin and wahoo that have been legally caught in the Bahamas to be transported from and landed in the United States filleted and with two (2) filets being counted as one fish. CCA also urges the Council to define “stowed fishing gear” as “unrigged fishing gear,” as this would be a common-sense solution for the numerous center consoles that transit back from the Bahamas.
People often ask why recreational anglers have such an adversarial relationship with the federal fisheries management system, and the answer is as simple as it is obvious. The National Marine Fisheries Service was created to assist and promote the domestic commercial fishing industry. Period. Only relatively recently did NMFS even begin to acknowledge a recreational component.
It is in the agency’s DNA to be a partner and collaborator with commercial fishing interests. Who is in the White House – Republican, Democrat or Other – doesn’t matter because the bureaucratic heritage at the agency never changes. You may get a new head of the Department of Commerce or a new administrator for NMFS, but the core pro-commercial mindset buried deep in the agency itself is virtually untouchable. Regional council members come and go, but federal and council staffers are the omnipresent architects of federal fisheries policy, crafting (or not crafting, as the case may be) the analysis and options that guide the councils on complicated matters.
Chaos reigns at Gulf Council
Gulf Council’s own Red Snapper Advisory Panel rejects sector separation
TAMPA, FL (7-30-14) – Even as the Gulf of Mexico Fishery Management Council fast-tracks a highly controversial plan to break the recreational red snapper fishery into private boat anglers and charter/for-hire operators, the Council’s own Red Snapper Advisory Panel voted today to reject the concept entirely.
Gulf Red Snapper Recreational Fishing Workshops will be held this month
The Florida Fish and Wildlife Conservation Commission wants to hear from you!
They are asking how to better manage the recreational fishery. Some of the topics will include Sector Separation, Individual Fishing Quota’s, and Regional Management.
Public Hearing Locations
All hearings will start at 6pm
July 28: Pensacola, Pensacola City Hall (2nd-floor Hagler Mason room), 222 W. Main St.
July 29: Destin, Destin Community Center, 101 Stahlman Ave.
July 30: Panama City, Florida State University – Panama City, lecture hall of Holley Center, 4750 Collegiate Drive
July 31: Carrabelle, Carrabelle City Hall cafeteria, 1001 Gray Ave.
Aug. 11: St. Petersburg, Fish and Wildlife Research Institute, 3rd-floor conference room, 100 Eighth Ave. SE.
CCA believes sector separation is simply a continuation of policies that address the symptoms of failed management without offering solutions that work for all components of the fishery. By creating an entirely new sector using only suspect past catch history, federal managers are just repeating the mistakes of the past and catering to the least economically beneficial aspects of the fishery. Under the current proposal, specific charter/for-hire operators could receive 54% of the recreational Red Snapper quota, while private anglers will likely not have a federal season at all as soon as next year.
Individual fishing quota’s (IFQ’s) give a public resource to an individual business to use as its own. IFQs will further privatize the red snapper fishery, 51 percent of which is already held privately by commercial harvesters. IFQs are expressly designed to reduce capacity. Once implemented, it is inevitable that the charter/for-hire industry will begin radical consolidation, further reducing access to this public resource. IFQs are a commercial management tool that has no business in a mixed-use fishery. Should a fundamentally flawed federal management system be allowed to privatize public resources that benefit some user groups and penalize others?
Regional Management is an option that would allow the states to tailor the management of marine resources like red snapper beyond state waters. Unlike the federal system, the states have shown a superior ability to manage wildlife resources for the greatest benefit of their citizens and have shown a much greater understanding of recreational fisheries. Regional management would allow each state to determine how best to manage its natural resources using the tools that have worked so well for species such as red drum, speckled trout, and snook.
Coastal Conservation Association Florida
Dedicated to Conserving and Protecting Florida’s Marine Resources
P.O. Box 568886, Orlando, Florida 32856-8886 (407) 854-7002 Fax (407) 854-1766
July 16, 2014
Dr. Steve Branstetter
Southeast Regional Office
263 13th Avenue South
St. Petersburg, FL 33701.
Dear Dr. Branstetter,
The Coastal Conservation Association (CCA) appreciates the opportunity to comment on the proposed Exempted Fishing Permit (EFP) for the Alabama For-Hire red snapper fishery, which has been extensively debated by the Gulf Council. We feel compelled to note that the Council’s Reef Fish Committee originally voted 5-4 to recommend that NOAA Fisheries deny this permit. The vote of the full Council to overturn the Committee’s recommendation shows the level of disagreement and controversy related to managing this troubled fishery by exempted fishing permit.
The nine-day recreational season for red snapper in 2014 was a convoluted product of a flawed federal law, outdated allocations and inappropriate management tools for the recreational sector. It was, however, ideal for creating the conditions for some charter/for-hire operators to be receptive to the lure of individual fishing quota programs for that industry. We have noted the careful avoidance of promoting this and other similar schemes as catch share programs, but that is certainly what they are, and we question whether the larger for-hire industry has been made fully aware of the inevitable economic outcome. Since catch share programs are expressly designed to reduce capacity, we are opposed to such programs in the recreational sector since they reduce access to red snapper. In addition, it is very possible that for-hire operators who feel compelled by current circumstances to favor this course of action today could find themselves out of the fishery entirely within just a few years. This aspect of IFQ programs should be emphasized by Council staff at least as energetically as the possible benefits for the select few winners.
Imagine a Gulf coast where recreational anglers suddenly saw a catch share initiative created for a few coastal fishing guides. Certain (not all) guides would be able to have a determined portion of a fishery and could sell opportunities to go fish for red drum…even if the fishery had been closed to the general private recreational angler. It is hard to think that recreational anglers who fought so hard to restore redfish stocks from the perils of gillnets, purse seines and the blackened redfish craze would now have a significant portion of the fishery given away to a handful of guides. Sound far-fetched?
The Gulf of Mexico red snapper fishery is already in this brave new world of fisheries management. It is a fishery that could be almost completely privatized as soon as the end of this year and be held from that point forward by commercial fishing and private charter businesses using this public resource for profit. It is very likely, as soon as next season, private boat owners will not be allowed to venture into federal waters to catch a red snapper and bring it home.
If Amendment 40 passes, it is likely that up to 75 percent of the entire Gulf red snapper fishery will be privately held, for private profit.
The Gulf of Mexico Fishery Management Council has scheduled a series of public hearings over the next few weeks on a dangerous privatization scheme for Gulf red snapper (see full schedule below). Reef Fish Amendment 40 - Sector Separation proposes to separate charter/for-hire businesses from the recreational sector and give personalized allotments of red snapper to use as their own.
The concept has been cast as a reasonable response to a broken federal management system, but it is a perilous development for recreational angling as it represents a huge step in the privatization of our fisheries.