Angler’s Guide to the South Atlantic Fishery Management Council’s Snapper Grouper Visioning Process
The South Atlantic Fishery Management Council should be commended for creating such a robust Draft Visioning Document for the snapper-grouper fishery. Nearly everything the Coastal Conservation Association would like to see included in the suite of management options for the South Atlantic snapper-grouper fishery is included; however, and unfortunately, nearly everything we would not like to see is also included. Given the length and detail of the document, we will provide thematic comment on the seven issues we believe are most critical for the proper management of the fishery, and for ensuring commensurate access to it for recreational anglers.
1. Fishery Independent Data Collection
The greatest need we see for better management of the snapper-grouper fishery is more and better fishery independent data to feed stock assessments and management. Catch streams will rise and fall, perhaps even go away at times, but there will always be a pressing need for more and better stock assessments. The only method for achieving that goal is enough fishery independent data to conduct stock assessments on the most important species in the complex without the use of fishery dependent data. If the Council does nothing else, in our view this is the most important improvement the Council could make in the management of the snapper-grouper complex.
2. Discard Mortality
Unlike discards in inshore species such as red drum or bluefish, discards are especially problematic in the snapper-grouper fishery because of barotrauma-related mortality, which generally increases with depth. Currently, estimated discard mortality can keep fisheries from opening at all, or significantly reduce the available season length. Red snapper is a prime example.
There must be better data available for estimating discard mortality in both the commercial and recreational fisheries. Perhaps this is an avenue where “citizen science” may be useful in collecting and reporting discard from the recreational fishery. Increased observer coverage for commercial trips would be key also.
Clearly the deeper the depth where any species is caught, the greater the probability for discard mortality to occur. Thus, management measures to mitigate such mortality should be different as water depth increases. Measures that may be appropriate for deep-water species, such as 100 percent retention or no minimum size limit, may not be appropriate for shallow-water species. The greater the potential waste, the greater the need for stringent measures to mitigate that waste.
3. Catch Share Systems
CCA does not support catch share systems. We do not believe the publicly owned fishery resources of the United States should be gifted to a few individuals for their profit, to the exclusion of the public that owns them. Additionally, the Councils and NOAA have fostered an allocation system that has been accurately described as “rusted shut.” The gifting of the fishery resource compounds that problem, essentially throwing sand in the gears of the allocation machine.
Catch shares are nonsensical for recreational fisheries and are counter to most, if not all, modern perceptions of managing for recreational use – participation, access and abundance.
4. Recreational Management
It is gratifying to see the list of proposed strategies for managing recreational fisheries. Recreational fisheries are fundamentally different from commercial fisheries in both their motivation and execution. Commercial fishermen fish purely for profit, and thus have an incentive to fish efficiently. Their goal is to catch as many fish as possible as quickly as possible. Most recreational fisheries are precisely the opposite – they are prosecuted by thousands of average fishers seeking to enjoy a pastime. There is no incentive to be efficient. Some recreational fishermen are good fishers, most are not. They generally catch fish in relation to their abundance, and thus value abundance above all else.
For these reasons, effort controls such as size limits, bag limits and seasons generally work well in recreational fisheries, while they have not worked well in some commercial fisheries. There is usually no incentive to violate a season, bag or size limit in the recreational fishery, and most anglers abide by the rules with a high compliance rate. Conversely, effort controls have not worked in some commercial fisheries, as has been demonstrated repeatedly in New England and other areas.
Allocation is a basic responsibility of fisheries management and yet it is also one that Councils strive to avoid. No Council likes to be responsible for picking “winners and losers” in an allocation process and so allocations in federal fisheries have been allowed to outlive all justifications in a rusted shut system. With that in mind, we offer the following points for development of a regular, consistent, defensible allocation system:
A. Mandatory review. The Council must have a known review time for every allocation and an open, transparent review of each. The new allocation guidelines from the Council Coordination Committee and from NMFS dictate that a review interval be established and that interval should be no longer than five years. Additionally the guidelines ask that the council establish indicators that trigger a review and we recommend that those triggers include public interest and time.
B. If an allocation review is triggered, the review should focus on economic efficiency and move allocation when the allocation is deemed inefficient using economic value as the efficiency metric. Economic efficiency metrics should compare the marginal value of fish in commercial production to the marginal value of fish in recreational use. If the value of the next fish is more valuable to the recreational sector, then allocation should move towards the recreational sector. Ideally, a bioeconomic model should be used to identify the optimal allocation, but even if a full bioeconomic model is not available, allocation should be moved if point estimates are all that is available. If point estimates are all that are readily available, the allocation should be moved a small amount and the allocation should be revisited within the five-year interval requested above. Economic impacts should not be used to examine allocations alone as that is equivalent to a policy of cost maximization. Economic impacts can be used to trigger an allocation and/or examine the distributional effects of a reallocation indicated using economic efficiency criteria. The Council should request the development and use of economic valuation models for their important mixed use fisheries.
C. Future use. The numbers of people moving to coastal states is only going to increase in the future, and with it the demand for fishing opportunities. These needs must be factored into allocation decisions. Bioeconomic models can help alleviate this issue by taking into account future effort growth. Reviewing the allocation every five years will also help in this regard.
D. Past catch history should play a lesser role in future allocations. Past catch history does not take into account future needs and the data used in often suspect. The red snapper allocation in the Gulf of Mexico was set using recreational data from 1979-1982, when the Marine Recreational Fishing Statistics Survey (MRFSS) was initially implemented and the catch data is suspect, so much so that it is often not used in stock assessments. In addition, the red snapper population was at a very low level of abundance during that time period, so recreational effort was likely low also. Yet we are stuck with an allocation system that primarily uses past catch history, despite such glaring inequities.
6. Closed Areas
In the event that extraordinary conservation measures become necessary, the use of seasonal closures for the snapper-grouper fishery should be the primary management option. Spawning aggregations of stressed species should be protected with well-defined, consistent spawning season closures. Species that cannot withstand year-round harvest pressure should have well-defined, consistent closed seasons. However, large-scale total closures to all bottom fishing have not been shown to be universally successful and are not acceptable to us. Areas that specifically exclude recreational fishing should be considered only as a tool of last resort. Marine Protected Areas or Special Management Zones should only be implemented if:
- There is a clear conservation problem that cannot be adequately addressed by less severe conservation measures, such as gear restrictions, possession limits, size restrictions, quotas, or closed seasons, to reverse the targeted conservation problem. Some of the most severe marine resource conservation challenges have been successfully addressed using these tools.
The closed-area regulation includes specific, measurable criteria to determine the conservation benefit of the closed area on the affected stocks of fish and provides a timetable for no less than annual review of the continued need for the closed area.
The closed area is no larger than that which is supported by the best available science.
- Provision is made to reopen the closed area to recreational fishing when the targeted conservation problem no longer exists or a less-restrictive means of management becomes available.
There are thousands of recreational fishers that reside hours from the Atlantic Ocean, and in some states it is likely that the majority of anglers reside in inland counties. Yet the Council persists in holding public meetings almost exclusively in coastal areas. While webinars are a useful tool, public hearings are still the primary means by which the Council will gather input from the fishing public. When there is a proposed management measure that significantly affects important recreational fisheries, please consider holding public hearings in inland locations.
Thank you for the opportunity to comment on the draft Visioning Document. We look forward to working with the South Atlantic Fishery Management Council on implementing the new Amendment.