Testimony of
Coastal Conservation Association
Joint Reef Fish Amendment 27/Shrimp 14 and Shrimp 15
Scoping Meeting Testimony
The following
testimony was presented by CCA at the scoping meetings held by the
Gulf Council in regards to the Joint Reef Fish Amendment 27/Shrimp
14 and Shrimp 15.
After review,
this scoping document does not contain enough information to provide
a basis for making decisions on various options. However, CCA
believes that there is no basis for taking any further action on the
management of recreational red snapper fishermen until the shrimp
bycatch disaster has been remedied. In simplified terms,
recreational anglers have been over-managed while shrimp-trawl
bycatch has been virtually ignored. Only when a firm bycatch
reduction plan has been put in place can the Council truly evaluate
how to continue the red snapper rebuilding plan.
Having said that, CCA would emphasize the following points:
· The Gulf Council and the National Marine Fisheries Service have
failed to reduce red snapper bycatch in the shrimp fishery despite
having a 44 percent bycatch reduction goal in place for over a
decade. Anglers have sacrificed by living with reduced bag limits
and closed seasons in order to rebuild the stock while the shrimp
industry has failed to adequately follow bycatch reduction device
requirements. According to a NMFS report, the failure was primarily
because BRDs were not installed or were not used per regulations.
Recreational anglers have complied with stricter regulations while
the shrimp industry has continued to be the source of 80 percent of
total red snapper mortality.
· The scoping documents fail to establish an adequate bycatch
reduction goal for the shrimping fleet. Red snapper bycatch
mortality from shrimp trawls must be reduced by 60 to 80 percent.
· It is impossible to set a Total Allowable Catch or begin a
rebuilding plan for red snapper without firmly establishing a
bycatch reduction target and placing regulations into effect that
will be assured of achieving that target. If anything, shrimp
bycatch should be dealt with before any changes in red snapper catch
limits are considered. These three amendments must be considered
simultaneously.
· Shrimp trawl bycatch reduction options must focus on what can be
accomplished now. Those options include time / area closures and /
or bycatch quotas that will reduce shrimp fleet bycatch by 60 to 80
percent. These need to be implemented immediately by emergency rule
to halt the destructive impact of shrimp trawls on red snapper
stocks.
· CCA wants to see an analysis of the potential bycatch reduction
that could be accomplished by expanding the existing Texas shrimp
closure throughout the Gulf and through the end of August or
September.
· The scoping document claims that reductions in shrimp effort have
occurred over recent years (prior to Hurricane Katrina) but lack any
real analysis of this claim. CCA wants to see an effective analysis
of the real changes in shrimp effort before the Council develops any
options for the proposed amendments. As it stands now, the document
does not discuss any effort reduction targets for the shrimp
industry. CCA asks the question,
How much do you have to reduce shrimping effort to attain the
necessary reduction in shrimp trawl bycatch?
· CCA wants to see in-depth analyses of the allocation impacts of
different size limits for the recreational and commercial sectors.
· We ask the Council to perform a thorough economic analysis of the
potential benefits and drawbacks associated with different
allocation formulas before developing new regulations for the
recreational and commercial red snapper fisheries.
· CCA supports establishing regulations to prevent commercial
harvesters from monopolizing the red snapper resource because of
disparities in fishing seasons, size limits or other factors. With
the introduction of the commercial IFQ system, we ask the Council to
examine regulations to move commercial harvesters to deeper waters.
In closing, CCA has been involved with the management of red snapper
in the Gulf of Mexico for more than 20 years. It has become apparent
during that time that the problems associated with this fishery
begin and end with shrimp trawl bycatch. No amount of regulation on
the recreational sector will affect a recovery of this important
species without effective bycatch reduction measures.
It is time to finally address shrimp trawl bycatch if we ever want
to get out of this mess.
Comment on Joint Reef Fish Amendment 27/Shrimp 14
& Shrimp 15 is being accepted at:
SnapperShrimp@gulfcouncil.org
To view scoping documents click on the following:
Amendment 27 to the Reef Fish FMP & Amendment
14 to the Shrimp FMP
Amendment 15 to the Shrimp FMP
