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I. INTRODUCTORY STATEMENT
Dolphin, a colorful, acrobatic fighter, is the most sought-after offshore fish on the east coast of Florida and is the backbone of the offshore charter, guide and private recreational fishery. Dolphin is a significant part of Florida's FOUR BILLION DOLLAR saltwater recreational fishery - the largest in the United States.
Although there is no comprehensive stock assessment for dolphin in the northern area of its range (ie. Southeastern United States), there has been a preliminary stock assessment in the dolphin's southern range (Barbados area) and one of the key implications from that assessment is that:
"There is a high risk of stock depletion with little warning given that the fishery may remain feasible at low stock levels because of the tendency of the fish to aggregate, and the current trends for increasing fishing effort.
"There is a potential for recruitment overfishing given that fish are economically valuable before size at first maturity, and the high interannual variability in abundance apparently driven by environmental factors." [SAFMC, 1999]
CCA Florida is very concerned about the emergence of a commercial longline fishery directly targeting dolphin. In the last few years, a number of commercial boats have begun to directly target dolphin and have landed up to 28,000 pounds per trip. In addition, there has been an increase in recreational landings, particularly in North Carolina.
The longline threat and the absence of any federal management plan or regulations for dolphin highlights the immediate need for a dolphin fishery management plan.
For the most part, federal fishery management plans have been recovery plans, not management plans. CCA Florida strongly supports the South Atlantic Council's efforts to develop and implement a dolphin management plan before the overfishing and damage occurs.
II. RECOMMENDATIONS
A. ALLOCATION
Recommendation: ALLOCATE DOLPHIN RESOURCE TO BOTH RECREATIONAL AND COMMERCIAL HARVESTERS BASED ON THE HISTORICAL AVERAGE CATCH FROM 1984 TO 1997 (90% RECREATIONAL AND 10% COMMERCIAL).
Discussion: It is extremely important to establish a strong allocation position in the plan now before the commercial longline fishery expands and begins to supplant the recreational fishery. Sharks, amberjack, gag grouper are all examples of predominantly recreational fisheries which were impacted and supplanted by commercial fishers. Historically, dolphin has always been an overwhelmingly recreational fishery. The 90:10 allocation position needs to be taken now to protect the resource and the economic value of this extremely important recreational fishery.
B. COMMERCIAL TRIP LIMITS
Recommendation: 1,000 POUNDS PER TRIP.
Discussion:In the South Atlantic, a commercial trip limit of 1,000 pounds would not reduce commercial hook and line take at all but would reduce longline take by 31%.
Commercial longline boats currently have several ways in which they take dolphin. One is as by-catch in the swordfish and tuna fishery. Another is by modified dolphin gear included as part of the swordfish and tuna longlines. A third is longline gear designed for and directed at dolphin. Longlines directed at dolphin have brought in catches up to 28,000 pounds per trip. Some people believe that a 4,000 pound trip limit would eliminate a directed longline fishery. However, that is not true for the "modified" swordfish and tuna longlines, which include gear designed to take dolphin. The only way to eliminate the dolphin "by-catch" in longlines is to eliminate the gear. A 1,000-pound trip limit would prevent a directed longline fishery but would allow retention of "by-catch" in the swordfish and tuna longline fisheries.
Some other interesting points are:
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"For the most part dolphin landings have been dominated by the recreational fishery. Commercial fishing for dolphin has been a relatively modest fishery in the past, but has grown with recent effort shifts. The directed fishery for dolphin in the South Atlantic has consisted of approximately 3 or 4 longline vessels that participated on a regular basis off the costs of North and South Carolina (NMFS, 1997). Within the past few years, there has been an increase in longline landings of dolphin with the participation of swordfish and shark longliners who have been adapting their gear to simultaneously target dolphin and focus more effort after shark and swordfish quotas are met." [SAFMC, 1999]
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Regarding the recent increase in commercial longline take - "In 1997 there were 1,504 trips that landed dolphin to sell. Seven trips had greater than 2,000 pounds, and those seven trips accounted for 48% of the entire commercial landings for the state of North Carolina. The catch rates were 20 to 30 thousand pounds per trip." [Daniels, Dolphin & Wahoo SAFE Report]
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Average commercial take by gear type is 69% hook and line, 30% longline, 1% unknown.
C. MINIMUM SIZE
Recommendation: FORK LENGTH OF 20"
Discussion: Establishing a minimum size of 20 inches is probably the easiest, least disruptive way to regulate recreational take, while providing enhanced resource protection. Most dolphin are sexually mature at 18 inches, all are mature at 20 inches. A released 18" fish will be 20" in less than one month. A 20" fork-length dolphin is roughly equivalent in weight to an 18" redfish.
Some argue that dolphin are too "wild" to measure and release them alive. While that is certainly true for bigger fish (10 pounds and up), small dolphin (those less than 24") can be measured and released alive. Florida has had a commercial 20" minimum size for many years.
In the South Atlantic, a recreational minimum size of 20 inches would reduce recreational landings from all recreational sectors by 17% in number and 4% in weight. These estimates are based on current NMFS recreational landings data.
D. RECREATIONAL BAG LIMITS AND BOAT LIMITS
Recommendation: SEVEN FISH PER PERSON, DAILY LIMIT.
Discussion: Florida and North Carolina currently have a ten-fish recreational bag limit; Georgia has a 15-fish limit; and South Carolina has proposed a seven-fish limit.
In the South Atlantic region, a seven-fish limit would reduce the weight of recreational landings by 4% for head boats, 11% for charter boats, and 9% for private boats.
E. PROHIBIT SALE OF RECREATIONAL CAUGHT FISH
Recommendation: PROHIBIT SALE BUT PROVIDE SOME EXCEPTION FOR CHARTER BOATS - WHICH WOULD BE PHASED OUT OR REDUCED OVER SOME PERIOD OF TIME.
Discussion: Commercial sale by charter boats should be reduced or phased out over some pre-determined period of time. Charter boats have traditionally relied upon the sale of dolphin for many years and there is no compelling reason for an immediate "cold turkey" prohibition on sale by charter boats.
III. CLOSING COMMENTS
In 1999, CCA Florida's State Board of Directors adopted a position statement which endorsed the development of a federal management plan for dolphin; including new recreational controls and a complete prohibition on the take of dolphin by commercial longline gear. However, CCA Florida has placed its efforts for a complete ban on dolphin take by longlines on hold pending the outcome of the "bluewater agreement" by Coastal Conservation Association, The Billfish Foundation, American Sportfishing Association and Bluewater Fishermen and the outcome of the South Atlantic Council's dolphin management efforts.
We very strongly encourage the Council to take action to:
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maintain the historical 90% recreational to 10% commercial allocation.
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prevent the development of a directed longline fishery.
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restrict and control recreational take.
DOLPHIN NEED AND DESERVE A MANAGEMENT PLAN NOW. . . NOT A RECOVERY PLAN LATER.
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