Coastal Conservation Association (CCA)

System Failure
Six years of study, research and public hearings produced a ground-breaking fishery management plan. The stroke of a pen reversed it all.

By Frederic L. Miller
Chairman
National Government Relations Committee
Coastal Conservation Association

The South Atlantic Fishery Management Council should be commended for developing and releasing a precedent-setting management plan for dolphin and wahoo earlier this year. In many respects, the process that produced the plan is the way fishery management is supposed to be done.

Neither dolphin nor wahoo are considered overfished, yet a forward-thinking Council invested more than six years devising a plan to maintain the status quo of the fishery before problems had a chance to develop.

Throughout the entire Council process, stakeholders were invited to give input through dozens of public hearings. The end result was a plan unique in several respects. First and foremost, it was broadly developed in conjunction with the Mid-Atlantic and New England Councils and set limits for commercial and recreational fishermen in federal waters along the entire Atlantic coast. The plan took great pains to maintain the recreational nature of the fishery, but also took steps to preserve the traditional hook-and-line commercial fishery that has existed for decades.

The Council’s risk-averse approach was broadly supported by environmental groups, recreational anglers and the existing commercial fishery. It was a model that could have been held up as an example to fishery managers all around the country.

In developing the plan, the South Atlantic Council took several important factors into consideration. Dolphin and wahoo have always been a recreational fishery, with anglers catching about 87 percent of the harvest each year. A small commercial hook-and-line industry in the South Atlantic took most of the rest of the catch to supply fresh fish to local markets in the Southeast U.S.

The Council found that 90 percent of the commercial trips targeting dolphin/wahoo caught less than 3,000 pounds, but that 7 percent of the trips caught about 60 percent of the fish.

To preserve the traditional nature of the fishery and prevent a destructive directed commercial fishery from ever developing, the Council set a trip limit of 3,000 pounds. The relatively low limit would preserve the traditional hook-and-line commercial fishery, but would make it uneconomical for longliners to actively target dolphin/wahoo.

Additionally, to head off a surge in longline vessels switching intense fishing effort toward dolphin/wahoo after other targeted species were fished down, the Council established a control date for entry into the fishery. These criteria would require fishermen applying for a commercial dolphin/wahoo permit to either have an existing federal permit in the snapper/grouper, king mackerel or HMS fisheries, or document landings of 250 pounds of dolphin/wahoo before the control date of May 21, 1999.

No new longline effort could enter the fishery after the control date, a considerable piece of precautionary foresight that would have been invaluable not only to this fishery, but every fishery in U.S. waters. In addition to being highly indiscriminate, longlines are highly efficient. The control date was crucial to preserving the traditional nature of the entire dolphin/wahoo fishery.

The FMP that was finally sent to the National Marine Fisheries Service for final approval and implementation was regarded as the next logical evolution in the way this country manages its fisheries – a risk-averse, precautionary blueprint for an important sport fishery.

What later emerged from NMFS was a hollow shell of a plan. NMFS stripped out the trip limits and the control date, leaving dolphin/wahoo open to full exploitation by the most deadly efficient gear in the oceans – longlines.

The one nominal precautionary provision remaining in the plan, and the one on which NMFS has apparently placed all its trust for the future health of the stocks, is a throwback to traditional fishery management. It stipulates a cap of 1.5 million pounds or 13 percent of total landings for the commercial fishery.

Given the past history of this particular management practice, that is a slim reed indeed. Now, a problem has to emerge, be recognized and quantified before any management actions take place. And there are no provisions in the present FMP to act quickly. By the time the need for action is recognized, whatever fishery caused the problem is entrenched in the system. It would have been much more logical and efficient to prevent a problem from occurring in the first place.

NMFS’ strategy now is essentially to wait for a directed longline fishery to develop and for the stocks to slide into inevitable decline before taking action to “fix” the problems. However, by then it will be infinitely more difficult to reverse course.

The South Atlantic Council deserves high praise for its attempt to drag NMFS into the future of fisheries management. The Council did its part extremely well.

The public deserves a full explanation as to why, after years of science, research, countless public hearings and thousands of hours of effort by hundreds of people, NMFS was allowed to completely gut the spirit of the plan outside the process that created it.