South Atlantic Fishery Management Council Public Hearings and Scoping Meetings for Proposed Federal Fisheries Management Measures
Generic Accountability Measures and Dolphin Allocation Amendment
Before any consideration is given to an arbitrary shift of dolphin allocation from the recreational sector to the commercial sector, CCA requests a thorough socio-economic study on the impacts of such a shift. Such an analysis should be a regular component of fisheries management under any circumstances. The federal fisheries management system must abandon the practice of assigning allocation based on past-catch history and instead base decisions on current social, economic, behavioral and conservation criteria. CCA is opposed to arbitrary allocation shifts such as the one being proposed here for dolphin and has long called for NOAA Fisheries to establish a standardized, regular allocation process as a fundamental part of fisheries management.
CCA remains 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 is primarily a recreational fishery and the current commercial allocation reflects the fish that are caught incidentally in other fisheries. We do not want to see a directed commercial dolphin fishery develop that can catch large numbers of them, which is what could happen if the allocation shifts sufficiently. A trip limit would prevent that, and we urge the Council to reconsider its rejection of trip limits.
On the Dolphin Allocation Amendment, CCA supports Action 2 Alternative 1 – No action on dolphin allocation.
Snapper Grouper Amendment 36
Locking the public out of fishing grounds is a highly controversial and emotionally charged proposition for the recreational angling community. Closed areas should never be taken lightly. Although CCA regards closures as the very last tool that should be applied in fisheries management, it appears that speckled hind and warsaw grouper might warrant special protection in order to rebuild. The Council has stopped all directed harvest and is now trying to manage discard mortality. We appreciate the Council’s willingness to explore options other than closing large areas of productive bottom fishing areas.
For species that have been shown to need a greater level of protection beyond the elimination of a directed fishery, CCA has supported the identification of spawning aggregation sites and other sites where they are known to congregate and tailor closed areas to the time when the fish are aggregated there. These types of effort controls have worked well in recreational fisheries, as they have worked well in terrestrial wildlife management and inland fish species, most of which have a bag limit and closed season for harvest.
Closing areas is a dramatic step in fisheries management and should only be considered as a last resort. If there is sufficient evidence to support a spawning aggregation closure, CCA requests that the Council take into account the following points to gain the greatest level of understanding from the recreational fishing community:
The size of any closed area should be as small as possible and constructed on a case-by-case basis. Any such closure should be accompanied by a research plan that will evaluate the effectiveness of closing areas. It is critical that the Council justify the rationale behind any closed areas. The fishing public could support spawning aggregation closures, especially if they see the benefit to the resource in the rules. Small, targeted seasonal closures to protect spawning aggregations will find much greater public support than massive year-round closures.
Recreational fishermen have long supported the placement of artificial reefs to improve fisheries. The document suggests placing artificial reefs within closed areas, which could help production and recruitment. The Council should also consider placing artificial reefs on open plain bottoms devoid of structure in an amount similar to any closed area. The Council could adopt a “No Net Loss” policy for bottom fishing that would benefit all. A federal/private sector partnership on a systematic artificial reefing program could be a mutually beneficial option in response to any opposition to closures from the recreational angling community. CCA would be eager to work with the Council and NOAA on such a habitat plan to lessen the negative impact of any closures on the recreational angling community.
Prior to the implementation of a closed areas to protect spawning aggregations, the Council should require the use of fishing devices or practices that can reliably reduce discard mortality in snapper-grouper species. Some deep-drop release devices have shown to be highly effective at increasing the survivability of released deep-dwelling species.
Establish a date-certain sunset provision for the expiration or renewal of the closed areas depending on results. A plan to monitor and evaluate the spawning aggregation closure regularly is absolutely critical to the success of this action. Without monitoring and evaluation this action is meaningless, and will face considerable skepticism and resentment from the recreational angling community. Open-ended closures with no goals or criteria attached to them cannot be supported.
- In the creation of the targeted areas, the Council should give consideration to a provision for transiting closed areas with equipment stowed.