CCA comments - Atlantic Cobia, Dolphin and Yellowtail Snapper

CCA Comments on Amendment 10 to the Dolphin Wahoo FMP (dolphin) and Amendment 44 to the Snapper Grouper FMP (yellowtail snapper)

Posted on August 01, 2016

South Atlantic Fishery Management Council Public Hearing and Scoping Meetings

CCA Comments on Amendment 10 to the Dolphin Wahoo FMP (dolphin) and Amendment 44 to the Snapper Grouper FMP (yellowtail snapper)


Amendment 10 to the Dolphin Wahoo FMP

The original intent of the South Atlantic Fishery Management Council (SAFMC) was to manage dolphin primarily as a recreational species and still allow the historic commercial fisheries to operate. The vast majority of the harvest has historically occurred in the recreational sector, which depends on abundance as a key factor in management to increase the encounter rates. Dolphin are a critical component of the private boat and for-hire fleet fishery all along the Atlantic coast.

The commercial fisheries were largely composed of incidental catches made while targeting other species. The commercial fishery changed significantly in 2014 and 2015 when dolphin caught in the longline fishery increased substantially, causing a closure of the commercial fishery in 2015.

We believe the SAFMC should, as a matter of policy, protect the historic small scale commercial fishery and limit the longline fishery if necessary. We are opposed to any change in sector allocation unless and until there has been a comprehensive economic evaluation to determine the most efficient allocation. NMFS Fishery Allocation Policy, released August 1, 2016, requires such an analysis. Such an evaluation would necessarily include the willingness to pay for catch as well as harvest. Recreational angler prefer thick stocks of large fish, particularly for dolphin. Dolphin is often the "day saver" for both the for-hire and private fleet and it has earned that reputation because of its abundance and excellent food quality. Reducing the current allocation would most certainly reduce value and likely decrease economic efficiency and the recreational angler is owed a thorough examination of the values that would be taken from them.

Additionally, it is unfair and inequitable to require detailed and time-consuming studies each time a recreational sector asks for a change in allocation when the commercial sector need only propose a change in an amendment and it goes straight to a vote without any analysis. Shifting uncaught fish simply because they are uncaught makes little sense and is antithetical to managing for a recreational fishery

Under Action 2, CCA opposes Alternatives 2, 4, 5, 6 and 7 and support Alternative 1, no action.

Alternative 3 is intriguing and although greater understanding is necessary as to how it might be implemented, it is possible CCA would not oppose the carry-over of a sectors uncaught Annual Catch Limit (ACL) for future harvest.

These same comments apply to the yellowtail snapper proposed management measures.


Coastal Migratory Pelagics FMP – Framework 4

The recreational fishery for cobia is poorly understood. Coastwide cobia harvest since 2005 has fluctuated from a low of about 350,000 pounds in 2011 to highs in the 900,000 pound range for a few years, until 2015 when more than 1.5 million pounds were estimated to be harvested. It is not clear if this increase was in response to a strong year class but clearly something fundamentally changed in this fishery that fishery managers do not fully understand. Radical regulation changes based on a single year of data are a keen source of frustration in the recreational angling community and further erode trust in the federal fisheries management system.

The cobia fishery is prosecuted primarily in state waters on fish moving into estuaries to spawn, making them vulnerable to intense fishing pressure. CCA supports reasonable regulations that lessen pressure on spawning aggregations and could support measures to increase the season length, such as a

reduction in bag limit to one fish and perhaps boat limits, and an increase in minimum size, as releasing cobia is a common practice. According to MRIP estimates, about half the cobia caught since 2005 have been released.

CCA supports Action 3, Alternative 2 to modify the current cobia recreational Accountability Measure (AM). The current AM is unnecessarily restrictive and unlike other AMs within the SAFMC’s jurisdiction.

We understand the Atlantic States Marine Fisheries Commission is considering the adoption of a Cobia Fishery Management Plan. Since the majority of harvest occurs in state waters, this would make sense. In addition, the states could handle problem such as occurred here through conservation equivalency or other measures.