CCA Comments on Amendment 17 to the SAFMC Snapper Grouper Fishery Management Plan

Posted on November 06, 2009

Thank you for the opportunity to comment on this contentious and unprecedented issue.

We recognize that the members of the South Atlantic Fishery Management Council have been put in an almost impossible position. This is a fisheries disaster that is 40 years in the making, and yet this Council has been tasked with fixing it in just two years. The federal government has conducted exactly one full, modern stock assessment on South Atlantic red snapper, leaving this Council with few options to find a way out of this unprecedented mess, and no one is happy with any of the options currently before us. That is unfair to the members of this Council, to the fishery and to the angling public.  Seldom if ever have we seen a more neglected fishery than South Atlantic red snapper. As CCA’s general counsel said recently, if a corporation was managing this fishery, we would recommend that the entire management team, and especially the CEO, be fired.
 
It remains CCA’s position that the current red snapper stock assessment be reviewed again by a panel of stock assessment experts.  We are well aware the assessment has been peer reviewed through the SEDAR process and judged to be the best available science, and that the Council's SSC has concurred in that finding.  However, in this special instance where the potential economic ramifications are so severe, we believe there must be another review of the assessment to make sure we are indeed using the best available science.   
 
If further review indicates less stringent management measures could be implemented to end overfishing and meet the rebuilding target, that would be a simple matter within the current amendment process and would help ameliorate some of the impacts being encountered by anglers in this fishery.
 
We would like to draw special attention to the mention of the need for fishery independent surveys in this fishery. CCA views fishery independent data as critical to the establishment of a better assessment process that is not solely dependent on recreational and commercial catch for data. CCA commends the Council for identifying the need for such surveys in the future. We encourage the adoption of such survey methods as quickly as possible.
 
In closing, CCA is fully aware of the tenets of the Magnuson Act that are forcing this issue, yet we do not believe that closing down fishery after fishery for recreational anglers was what Congress had in mind when it reauthorized the Magnuson-Stevens Act in 2006. Large-scale closures should always be the last option explored by fisheries managers, not the first.
 
With that in mind, CCA at this time is not able to come to a consensus to give its support to any of the alternatives before this Council. We support ending overfishing and rebuilding this stock, but urge the Council to continue searching for an alternative that avoids closures.
 
CCA is the largest marine resource conservation group of its kind in the nation. With almost 100,000 members in 17 state chapters, CCA has been active in state, national and international fisheries management issues since 1977. Visit www.JoinCCA.org for more information.
CONTACT: Ted Venker, 1-800-201-FISH
 
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We will be able to accept comments and questions on this issue until November 20, and selected comments may be posted below. Thank you.
 
Ted Venker
Newsroom Moderator
 
 
Q. Are you guys flip-flopping here? I thought you guys supported large ocean closures?
 
- Ronnie S.
Florida
 
A. It has always been our position that ocean closures should be the last management tool used, and sadly there are times when closures have to be utilized to rebuild fisheries. In this case, we were unable to come to a definitive conclusion on any of the closure options. We are for rebuilding the stock and rebuilding fisheries, but we think the Council should continue to look for options that avoid closures.