CCA Comments for Public Hearings on Amendment 39 – Regional Management of Red Snapper
The concept of regional management of red snapper in the Gulf of Mexico has been born out of the frustration felt by many anglers towards federal management. By almost any account, red snapper are more abundant now than perhaps at any point in history. Management has finally worked and no one wants to go back to the days when red snapper were small and hard to find. On the other hand, no one should be content with a management regime that is unable to find a way to reap the benefits of success.
CCA supports driving management of marine resources to the lowest level of government possible, ideally to the state level. That position is staked in the belief that the states simply have a better grasp of how to manage these resources in ways that ensure their health and stability. At the same time, state agencies have proven their expertise in providing the greatest access to those resources and maximizing the benefits of those resources for their citizens. Almost every one of this country’s great marine conservation success stories has been engineered by the states, including red drum and speckled trout.
Contrast that against our experiences with NOAA Fisheries. After decades of management, participants in the red snapper fishery were rewarded with a 27-day season and a two-fish bag limit. Proposals were even made that to reduce the bag limit to one fish in an effort to increase the number of days in the recreational season and prevent a widespread revolt against federal management. While season length is indeed crucial to the recreational sector, days alone do not make a quality fishery. History has shown the individual states’ management systems are best equipped to determine the management approach best suited to their residents. The current situation is unacceptable, and that is with a fishery that by all accounts is recovering wildly. Rather than hoping that NOAA Fisheries will someday figure out how to copy the success of the states, we believe that this proposal to allow the states to take greater control of management could provide a solution.
The transfer of management responsibility would be no easy task, and countless details remain to be fully explored. Issues over enforcement, monitoring, data collection, state boundaries, compliance and allocation will have to be fully resolved. However, CCA believes that the best results will be achieved through negotiations between the states themselves, with as little federal influence as possible. Additionally, in the development of this proposal it should be specified that states have the ability to manage the entire fishery, both recreational and commercial - including decisions on eliminating the IFQ program – as they see fit. Another option that the Gulf Council could consider is simply removing red snapper from the Reef Fish Management plan as they have recently removed stone crabs; anchor and blackline tilefish; red and rock hind; misty grouper; and schoolmaster, dog and mahogany snapper. Such action would also allow each Gulf state to optimize the use of red snapper to the highest benefit of their residents and economies.
Recreational anglers have more faith in the ability of the states to successfully manage our marine resources than in NOAA Fisheries. If enacted correctly, CCA views state-based management as a potential path to achieving our overriding goal of healthy marine resources and increased access to them for the greatest benefit of the public.