Mary Janine Vara
NOAA Fisheries
Southeast Regional Office
Sustainable Fisheries Division
263 13th Avenue South
St. Petersburg, Florida 33701

Re: Generic Amendment to the Fishery Management Plans for Snapper-Grouper, Golden Crab, and Dolphin and Wahoo

Dear Ms. Vara,

Thank you for the opportunity to comment on theGeneric Accountability Measures and Dolphin Allocation Amendment. Coastal Conservation Association is the largest marine resource conservation group of its kind in the country, with more than 130,000 members in chapters from coast to coast to coast. We are concerned primarily with the dolphin allocation issue in this amendment, and the ongoing willingness of federal managers to manipulate allocation decisions, to the detriment of the angling public.

The Coastal Conservation Association is opposed to arbitrary changes in sector allocations based on little more than a guess. The conclusion of the limited economic discussion in the document was:

Considering that, based on historical landings, neither the commercial sector nor the recreational sector would likely reach their respective ACLs under any of the alternatives, it may be concluded that none of the alternatives would result in significant short-term or long-term negative economic effects on either sector.

This economic argument is not based on the best available science. It ignores any value that anglers might hold for the value of taking a dolphin trip without any harvest. It also ignores the economic value anglers hold for more robust stocks and larger fish. All three of these types of value have shown to be important and have the potential to generate substantial economic value. This is economic value that will be harmed with higher commercial harvest.

This council has seen the types of conflict that can occur between recreational fishermen and the longline fleet. These increased negative interactions that will result from a growing commercial fishery have the potential to negatively impact the value of taking a dolphin trip, regardless of whether the anglers on that trip harvest any dolphin. Anglers also prefer larger fish and more interactions with fish. Both require the correct age class management and stock size management that is more in line with a goal of maximum economic yield than maximum sustained yield. Greater commercial fishing will reduce both large fish and the stock size.

This allocation change will therefore likely result in reduced economic benefits to recreational anglers and reduced economic benefits to the nation.

These sorts of arbitrary re-allocations at the behest of the commercial industry also serve to undermine all the hard work of scientists have completed inside and outside NMFS and the councils regarding how allocations changes should be undertaken. NMFS and the Councils are currently working on formal allocation guidelines that run completely contrary to these types of arbitrary shifts in allocations. Those guidelines dictate a formal process and a detailed examination of criteria including economic criteria. Data exists to examine the recreational values detailed above. There are existing NMFS studies that have estimated these values for the recreational sector. Yet NMFS claims the quote above represents the best available science on this important issue. It is not the best available science. This analysis does not even include a basic theoretical analysis of the impacts of this re-allocation, let alone use any existing data.

This economic analysis is appalling and shows a total lack of fairness or equity in the council process. When the recreational sector asks for additional allocation they are generally shouted down or held to an impossible scientific burden of proof. However, when the commercial sector asks for additional fish this council bends over backward to accommodate the request and NMFS ignores the best available science - produced by NMFS - in order to push the re-allocation through. At the very least, NMFS and the councils should follow their own scientific guidance and conduct themselves with a little more transparency. This move would also continue the “lose-lose” scenario facing the angling public, in which accountability measures are imposed if the recreational quota is exceeded, and yet the allowable recreational catch is reallocated if the recreational quota is not achieved.

CCA has commented on this amendment previously, when it was under consideration by the South Atlantic Fishery Management Council, and asked for two considerations:

  1. A thorough socio-economic study on dolphin must be performed before any decision is made on allocation. This is an important fishery to Atlantic coast recreational fishermen and the impact of shifting allocation away from the recreational sector must be fully assessed and understood. The data exists to conduct this sort of analysis. There are existing estimates of the marginal value of recreational dolphin harvest and the economic value of taking dolphin trips.
  2. One of our primary concerns is the possible rise of a directed commercial dolphin fishery, especially a longline fishery. That would raise the possibility of localized depletion of dolphin that could affect recreational fishing success. We are deeply disappointed that trip limits are not an option for dolphin management as they are the best tool to prevent a directed commercial fishery from developing. This option has been suggested repeatedly and NMFS has consistently refused to promote or even consider this common-sense alternative.

South Atlantic dolphin is primarily a recreational fishery, and the current commercial allocation reflects fish that are caught incidentally in other fisheries.  That scenario changes dramatically if a directed commercial dolphin fishery develops that can catch large numbers of them, which is what will happen if the allocation shifts sufficiently.

A trip limit would prevent this development, and we would remind NOAA Fisheries that the South Atlantic Fishery Management Council adopted trip limits for this fishery in an earlier amendment, only to have them stripped out by NOAA Fisheries. It is an ongoing source of concern to CCA and to recreational anglers that NOAA Fisheries tends to pick and choose management options according to its own cryptic criteria, regardless of what the Councils determine.

CCA urges the Secretary to use this opportunity to demand NOAA Fisheries develop and implement a more thorough, standardized process for the allocation of our marine resources. In the meantime, we recommend that the allocation remain static and that trip limits be adopted as a safeguard against the development of a directed commercial dolphin fishery.

Regards,

Bill Bird, chairman
CCA National Government Relations Committee