Coastal Conservation Association
Testimony
Joint Reef Fish Amendment 27/Shrimp Amendment 14
Public Hearings
May 2007 

It is time for the management system to stop the overfishing of red snapper and recover this fishery. Recreational anglers have been promised recovery for years, and for years a number of measures have been applied to the directed fishery and to control shrimp bycatch. Those measures so far have resulted in only a management failure. It is time for the management system to put a plan in place that is fair to the stakeholders and to the fish. We need a plan that produces recovery and stops overfishing through verifiable measures.

Everyone in this room is here today because of a history of management neglect and failure. CCA filed its lawsuit in Houston to force change in the management system. With the judge’s ruling, we are looking to the Council to make those changes.

There are two components to achieve these objectives—the plan has to control both the directed red snapper fishery and shrimp bycatch.  The following points should be included in this amendment:

1)      Reduce bycatch in the commercial fishery -

Bycatch mortality approaches 100 percent in the directed commercial fishery for red snapper. CCA supports lowering the commercial minimum size which will allow the industry to keep smaller fish that otherwise would be thrown back dead. However, if the Council proceeds with this size limit reduction, action must be taken to physically separate the commercial industry and recreational anglers, possibly by restricting the commercial fleet from near shore structure.

Furthermore, the Council should also adopt limits on the number of hooks that can be fished on a commercial single rig and require only large hook sizes that will lower the hookup rate of undersized fish.

2)       Use caution when addressing the recreational minimum size limit -

We have seen analyses by NMFS scientists that a reduction in recreational minimum size will handicap recovery efforts. If the Council chooses to reduce the minimum size from 16 to 14 inches, it must not negatively impact recovery and must not significantly reduce the recreational open season for red snapper.

3)      Modify recreational fishing gear and release practices to reduce bycatch mortality -

CCA has proposed to fund research to determine the fate of released fish and create an educational program of best release tactics of red snapper for recreational anglers. Additionally, NMFS should immediately begin research on the correlation between hook sizes and the size of fish hooked. We believe there is a real chance to reduce the catch of undersized fish through the use of larger circle hooks.

4)      Reduce juvenile red snapper mortality by the shrimp industry in the western Gulf of Mexico -

·         CCA urges the Council to set a 74 percent reduction in shrimp trawl effort from the 2001-2003 level. 

·         This reduction can and should be achieved through direct and enforceable reductions in shrimp effort.

·         That reduction can be achieved through a combination of attrition due to economic factors in the industry; use of a more effective BRD that is verifiable on at least an annual basis; and time and area closures in areas of the Gulf with the greatest abundance of juvenile snapper.

·         All shrimp trawlers in offshore waters must be required to have a Vessel Monitoring System on board to aid in the enforcement of this measure.

·         CCA also recommends a strong and aggressive policy of enforcement of shrimp trawl bycatch regulations by NMFS and the appropriate state agencies.

·         A necessary component of this rebuilding plan will be a framework process to close shrimping in the Gulf in conjunction with the annual Texas shrimp closure – roughly June through mid-July – to the extent necessary to compensate for any overages in allowable effort in the previous year. This framework must be efficient and timely.

5)      5) Science must dictate harvest levels to support recovery -

CCA has always relied on the science to help specify what position to take on harvest.  We are disappointed that given the management failures of the past, science now dictates that the total allowable catch must be reduced in the near term in order to recover the stock. It is critical to note yet again that science also shows that red snapper cannot begin to recover unless there is a corresponding reduction in shrimp bycatch. Further reductions in TAC are a tough measure for us to take, but we realize that the mistakes of the past give us no choice today.

In conclusion, we would like to thank the Council again for this opportunity. We are very disappointed that federal regulators have been unwilling or unable to produce a recovery of this stock for more than 20 years. It is extremely frustrating for recreational anglers to face cutbacks and further restrictions yet again.

It is CCA’s hope that this amendment produces the significant, enforceable regulations needed to reverse this history of failed management and we can reach a period of healthy red snapper stocks and increased TACs for recreational anglers.