CCA Comments on Amendment 28 - Red Snapper Reallocation
Coastal Conservation Association commends this Council for taking steps to finally update an allocation that is based entirely on suspect harvest data from 1979-1987. We encourage the Council to develop consistent methods and regular reviews of allocations for all the fisheries under its jurisdiction. Allowing the allocation of a fishery as important as red snapper to remain static for more than two decades in the face of vast economic and demographic changes is an injustice to all participants in the fishery, as well as the coastal economies of all the Gulf Coast states.
While we believe that a much more dramatic re-allocation is not only reasonable, but justified, CCA supports the Council’s preferred alternative, Alternative 5, of Amendment 28, which will maintain the commercial and recreational red snapper allocations at 51% and 49% of the red snapper quota, respectively. If the red snapper quota is greater than 9.12 mp, 75% of the amount in excess of 9.12 mp to the recreational sector and 25% to the commercial sector.
It should be noted that evidence such as the recent work produced by the Council’s own Socio-Economic Science and Statistical Committee (SESSC) supports a larger allocation shift to the recreational sector than that provided by Alternative 5. Allowing an allocation to sit stagnant for such a long period creates the impression that any changes will be virtually untouchable going forward. This should not be the case. Regularly reviewing allocations and incorporating the latest data will alleviate much of the apprehension and pressure of this entire process. Given the highly politicized environment on this issue, Alternative 5 is simply the most viable alternative at this time.
We understand that the Council has heard arguments from some quarters that reallocation should not be considered at all until the recreational sector is “fully accountable” for its harvest. While there is certainly a debate to be had over whether it is desirable or even possible to manage the vast and diverse recreational community the same way that fewer than 400 commercial vessels are managed, we would remind the Council that those are points to be considered outside of this amendment. Relevant to that debate would be the fact that red snapper stocks continue to improve despite the alarmist statements being made related to recreational community accountability. Amendment 28 is designed to review a severely outdated allocation; it is not a recreational management amendment. For this amendment, it is far more appropriate for the Council to deliberate on the validity of the current red snapper allocation and evaluate any modern analyses that examine reallocation.
According to the 1989 Amendment 1 to the Reef Fish Management Plan, the current Gulf red snapper allocation of 51% commercial: 49% recreational was based on commercial and recreational landings from 1979-1987, a time when the stock was at or near its lowest point. This is a critical factor because of the very different motivations that drive commercial and recreational fishermen to go fishing. The commercial fishery is motivated by profit. When a stock declines, the fish become more valuable and for a time commercial fishermen may actually increase effort to harvest the more valuable product. Conversely, one of the primary drivers for recreational effort is the opportunity to encounter a fish. Thus when a stock declines, so does effort. The current allocation was set when the red snapper population was at its lowest level, when recreational fishermen would have had a difficult time encountering them in any abundance and their catch was depressed. In fact, four of the nine lowest recreational landings in the 33-year time series were used to set the recreational allocation.
Additionally, the allocation is based on recreational landings data that were gathered by the Marine Recreational Fisheries Statistics Survey (MRFSS), which the government first began using in 1979. Federal fisheries managers regularly discard MRFSS data from the first few years due to its unreliability. There are questions about the quality of harvest data even today, which makes the accuracy of an allocation set using data gathered from 1979 to 1987 by a new and untested or uncalibrated MRFSS system extremely suspect. As the Council is well aware, the entire MRFFS system has been replaced due to questions about its accuracy. The recreational red snapper harvest data produced last year by the new MRIP system, which showed an unexpectedly huge recreational harvest that is still being evaluated, is a vivid demonstration of the potential for significant discrepancies in recreational harvest from the data gathered by MRFSS.
Taken together, these two factors strongly suggest that the 51/49 split almost certainly represents a severely artificially inflated commercial share. It is likely that the allocation was never set properly in the first place and until that is rectified the problems of short seasons and recreational overages will only grow worse, even as the red snapper stocks continue to improve. Setting an allocation based on the latest information available is critical to setting the fishery on a level playing field and ensuring a proper foundation for future recreational management action.
To achieve that, CCA supports using modern, forward-looking criteria to set allocations that provide the greatest benefit to the nation, rather than past-catch history. Economics should be one of the key factors taken into account to set forward-looking allocations and an analysis completed this year by the Gulf Council’s Socio-Economic Science and Statistical Committee (SESSC) shows the economic benefits to the nation increase as red snapper quota is shifted to the recreational sector. The SESSC did not find a limit for how much quota should be shifted, but the economic benefits were still increasing with shifts of up to 10 percent of the quota to the recreational sector, which was the largest shift analyzed.
A number of other independent economic studies have shown that the current allocation makes no sense, including a groundbreaking “bioeconomic” report by Wade L. Griffin and Richard T. Woodward of Texas A&M University funded by NOAA Fisheries in 2009. In that report, the economics of the entire reef fish complex, of which red snapper is a significant component, were analyzed, as well as the four segments of the fishery that impact the complex – private boat recreational anglers, shrimping, commercial fishing and charter/for-hire. The report found that the present value of the total economic value of the shrimp and reef fish fisheries for the period 2009 to 2032 is $11.8 billion. Of that total, private boat recreational anglers account for $9.1 billion, clearly the most economically vibrant part of these fisheries.
It is understood that economics are only part of the debate. Until a consistent allocation review formula is developed and employed regularly this process is still subject to manipulation by politics and emotion. Economics provides one of the few objective criteria to evaluate fishery allocations that deliver the greatest benefits to the nation and the relatively modest shift in allocation contained in Alternative 5 is more than justified by the available economic evidence.
By only reallocating available increases, Alternative 5 provides a path to finally begin the process of regularly evaluating the allocation of red snapper. CCA applauds the Council for undertaking this process and urges Council members to act.
CCA National Government Relations Committee