Ms. Janet Coit
Assistant Administrator for Fisheries
National Oceanic and Atmospheric Administration
1315 East-West Highway
Silver Spring, MD 20910
Dear Assistant Administrator Coit:
We are writing to express our continued concerns with the current state of fisheries management under the National Marine Fisheries Service (NMFS). Our concerns stem from consistent issues with both NMFS’s fishery dependent and independent surveys. We urge you to work with the Senate Commerce Committee, the House Natural Resources Committee, and the undersigned Members of Congress to find a viable path forward to improve the data used for management and rebuild confidence and trust with the American public.
While these are nationwide issues, events at the Gulf of Mexico Fishery Management Council (Gulf Council) this year highlight just how much of a mess current management has become. First, NMFS continues to use the federal Marine Recreational Information Program Fishing Effort Survey (MRIP-FES) as the best scientific information available (BSIA), despite NMFS’s own pilot study estimating that MRIP-FES significantly overestimates fishing effort by as much as forty percent.1 This is causing premature fishery closures across the country, limiting both economic and recreational opportunities.
For example, MRIP-FES estimated that recreational anglers landed a staggering 1.6 million pounds of gag grouper in the Gulf of Mexico in less than two months in 2023,2 prompting concerns that reactionary management measures will follow. This fishery exists almost exclusively in Florida in the Gulf, and thus can reasonably be compared to the Florida State Reef Fish Survey—which estimated only one-seventh,3 or about 15 percent, of the federal estimate. Notably, the percent standard error (PSE) for the MRIP-FES surveys ranged from thirty-three to ninety-eight percent.4 By NMFS own admission, data sets with PSEs beyond 30 percent should only be used with caution.5 Said another way, these data from MRIP-FES are worthless and should not be used to inform management decisions.
The more precise, accurate, and timely state surveys in the Gulf of Mexico can provide the critical information on recreational landings needed to meet the requirements of federal fisheries management. While we are encouraged that NMFS has committed to reviewing MRIP-FES and working with the Gulf States Marine Fisheries Commission and the states to resolve differences and prioritize state surveys, we are disappointed in NMFS’ lack of urgency in making the transition. The Magnuson-Stevens Act requires management measures to be based on BSIA. We are very disappointed that MRIP-FES remains BSIA, despite the substantial errors NMFS has uncovered. Assuming NMFS does modify MRIP-FES after the completion of its pilot study, as it appears they will have to, it would be the third major change to the overall MRIP program in less than 20 years. Clearly, MRIP has failed, and it is time to move away from it.
Furthermore, the stock assessments conducted by NMFS continue to lack accuracy, timeliness, and even fiscal efficiency. At the last Gulf Council meeting, it was announced that SEDAR 74, the research track stock assessment for red snapper, failed its review workshop. To make matters worse, NMFS continues to disregard the most comprehensive fishery-independent study this nation has ever produced, the congressionally-directed, $10 million Great Red Snapper Count (GRSC)—which has passed peer-review.6 We understand the concern that the GRSC is a “single point estimate” compared to the historical data collected by NMFS, but at some point, NMFS must begin utilizing these improved estimates to create a more accurate assessment—and move into the modern age.
As time progresses, more and more data comparable to the GRSC will become available, and it will no longer be a single point estimate. Congress continues to support other such improved surveys, such as the South Atlantic Great Red Snapper Count. This appears to be a sound model for the future of fishery-independent surveys. Given the current failure to use the GRSC in any meaningful way in the Gulf, we have substantial concerns with how NMFS will utilize, if at all, the significant investment of public funds for similar comprehensive fishery-independent studies that are currently ongoing, such as the previously mentioned South Atlantic Great Red Snapper Count and the Gulf’s Great Amberjack Count.
The continued insistence on using poor models and questionable data over more accurate, comprehensive, absolute abundance estimates—as well as the consistent inability to complete stock assessments on time—calls into question whether NMFS should be conducting stock assessments at all. A better approach would be to use those funds to contract assessments out to academic and research institutions that are not wed to building upon and defending previous, poorly-performing stock assessment models. These third-party entities could provide substantial efficiency improvements in accuracy, timeliness, and costs.
In closing, it is worth noting that this is an opportunity for NMFS to significantly modernize fisheries management. First, while the overall MRIP system continues to fail at providing the necessary data for management, states are already showing their ability to successfully collect and provide it. NMFS can—and should—assist states in taking the lead. Second, NMFS’s fishery independent surveys also fail to provide the necessary data for creating timely and accurate stock assessments. Again, there is a solution: studies like the GRSC provide a clearer snapshot of what is in the water. The question should not be how to plug this fishery-independent information into existing flawed models, but rather “How do we use the GRSC and similar studies to set the benchmark for creating new models and data streams going forward?”
We realize and appreciate the complexities of fisheries management off our coasts. We also see opportunities to address those challenges with real solutions, and we look forward to working with you and NMFS on solutions that ensure the health and sustainability of our marine resources for future generations.
Sincerely,
Garret Graves
Member of Congress
Roger F. Wicker
United States Senator
Katie Boyd Britt
United States Senator
Bill Cassidy, M.D.
United States Senator
Ted Cruz
United States Senator
Rick Scott
United States Senator
Brian Babin, D.D.S.
Member of Congress
Cliff Bentz
Member of Congress
Jerry L. Carl
Member of Congress
Earl L. “Buddy” Carter
Member of Congress
Michael Cloud
Member of Congress
Byron Donalds
Member of Congress
Neal P. Dunn, M.D.
Member of Congress
Mike Ezell
Member of Congress
Jen A. Kiggans
Member of Congress
Anna Paulina Luna
Member of Congress
Brian J. Mast
Member of Congress
Mary Sattler Peltola
Member of Congress
John H. Rutherford
Member of Congress
Austin Scott
Member of Congress
Bennie G. Thompson
Member of Congress
Daniel Webster
Member of Congress
Bruce Westerman
Member of Congress
Robert J. Wittman
Member of Congress
1 Evaluating Measurement Error in the MRIP Fishing Effort Survey, NMFS, Office of Science and Technology, May 2023
2 https://gulfcouncil.org/wp-content/uploads/B-8-Gulf_gag_red_grouper_Jan2024v3.pdf (Note: We recognize NMFS continues to work to revise these numbers, but it only further shows the need for better underlying data.)
3 Id.
4 Id.
5 https://www.fisheries.noaa.gov/recreational-fishing-data/frequent-questions-recreational-fishing-survey-and-data-standards
6 https://gulfcouncil.org/wp-content/uploads/Gulf-SSC-Summary-Sept-2021-10192021.pdf
