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.
CCA is categorically opposed to Amendment 40, and we question the timing of an effort that represents such a significant shift in recreational fisheries management in the middle of NMFS’ attempt to craft the nation’s first Recreational Saltwater Fisheries Policy. It is highly ironic that passage of Amendment 40 will severely limit the ability of the Council or NMFS to meaningfully implement any such policy for the Gulf recreational red snapper fishery, which is virtually the sole impetus for the creation of the policy in the first place.
The effort to create a Recreational Saltwater Fisheries Policy is the result of past federal fisheries management that has failed the recreational sector, creating a world where healthier stocks and larger fish mean less and less fishing opportunity. What is needed here is a complete re-examination of federal fisheries management with regard to red snapper and alternative management strategies, not a fast-tracked amendment that will serve to put the recreational fishery in a tighter and tighter box. Amendment 40 is simply a continuation of past management mistakes that caters to some sectors yet abandons private recreational anglers.
The analysis put forth by NMFS and the Council for Amendment 40 is completely inadequate. It uses suspect past-catch history as the sole basis for allocating between private anglers and charter/for-hire operators, which is expressly discouraged by the Magnuson Stevens Act and NOAA’s own Catch Share Policy. The analysis makes no mention of the short-term or long-term implications of a policy that will lock the most valuable sector out of the federal fishery. This indicates that NMFS and the Council are focused solely on implementing rights-based management for every sector in the fishery. The Draft Environmental Impact Statement for Amendment 40 is written such that limited entry in the private recreational sector is the only acceptable policy to fix the problems in the recreational red snapper fishery when state-based management systems prove otherwise. In our view, this stance is irresponsible and intellectually dishonest. There is little, if any, evidence that rights-based systems work for private anglers and plenty of evidence that the cost of distributing, trading and tracking private catch share tags will destroy value in the fishery and drive anglers away.
While this Amendment does not explicitly propose catch shares, it represents the first step, and clears the last major obstacle, to attaining that goal. In fact, the Council has already completed a scoping document to develop this privatization of the fishery. While catch share programs may have been used with some success in commercial fisheries, they are a disaster in mixed-use fisheries. Recreational fisheries are fundamentally different activities with different motivations and drivers. There is no profit incentive to pursue fish relentlessly. The generation of value, and in this case much more value than the commercial fishery, is driven by far more complex processes than simply maximizing landings or profits. Recreational fisheries are driven by access and abundance. Catch shares have no place in these fisheries.
It is important to clarify that federal management has failed the entire recreational sector. In the face of manufactured nine-day seasons, many charter/for-hire operators are supporting Amendment 40 as the only lifeboat available to them to stay afloat. This is a false hope for many. Catch shares are expressly designed to reduce fishing fleets. The Gulf red snapper commercial sector was comprised of roughly 1,800 businesses when catch shares were implemented in 2007. There are roughly 390 today. Dramatic consolidation of the charter/for-hire fleet is virtually inevitable if Amendment 40 is approved. The majority of charter/for-hire operators in business today will be out of the fishery in the near future and the public will pay much higher prices for this loss of access.
Funneling a public resource into fewer and fewer hands and privatizing public wildlife resources for use by a select few businesses for their profit runs contrary to this country’s wildlife conservation ethic. It defies common sense that the same federal fisheries management system that created this crisis is amplifying its shortcomings with an amendment that will fundamentally change the way this country manages its fisheries and marine resources for the foreseeable future. We can rebuild and sustain these resources without resorting to such a radical departure from traditional methods. Recreational anglers share the goal of healthy marine resources, but we urge NMFS and the Gulf Council to reconsider whether further privatizing public marine resources actually helps achieve that goal in ways that other more traditional methods could not, especially when the resulting burden on the angling public and the vast economic engine it supports will be so great.
The recreational sector would be far better served by staying united and working for a management system that is geared for the enhancement of the entire sector. With regards to Amendment 40, Action Item 1, Coastal Conservation Association urges the Gulf Council to adopt Action 1, Alternative 1- No Action.
Bill Bird, Chairman
CCA National Government Relations Committee