Highly Migratory Species Management Division
Office of Sustainable Fisheries (F/SF1)
NMFS, 1315 East-West Highway
Silver Spring, MD 20910
Dear Ms. Brewster-Geisz,
We appreciate the National Oceanic and Atmospheric Administration’s National Marine Fisheries Service’s (Agency) desire to review the effectiveness of spatial fisheries management and the opportunity to comment on the methods for review. Regular monitoring of closed areas is necessary to ensure management objectives are being met.
However, the recreational community lacks confidence in what should be an objective and unbiased process for these evaluations. The handling of the East Florida Coast Pelagic Longline Closed Area Exempted Fishing Permit (EFP) proposal fostered distrust. The EFP was clearly motivated by commercial profit rather than an attempt to assess the targeted closed area, and its initial approval significantly impacted the credibility of the process.
To restore trust in the process and gain much needed information on spatial fisheries management nationwide, we support maximum oversight through Agency-led research and request the most robust and scientifically rigorous approach be taken through the design of formal research projects. Research development by the Agency will ensure that data collected will meet specific fishery research needs. The Agency should develop these studies transparently, maximizing opportunities for public and stakeholder input. In addition, relevant States and Federal Fishery Management Councils should be consulted for their input on proposed research. An open process will avoid another appearance of conflicts of interest in any research outcomes.
These Agency-designed studies should primarily address population dynamics within the closed areas rather than gear-type specific research or impacts, which should be undertaken cautiously and only when there is a definitive need. Should the Agency determine there is a need to conduct gear-related research, a clear and compelling argument should be made to justify such plan.
Thank you for the opportunity to comment on the Agency’s research priorities and approach for spatial fisheries management.
Glenn Hughes, President
American Sportfishing Association
Jeff Angers, President
Center for Sportfishing Policy
Patrick Murray, President
Coastal Conservation Association
Jeff Crane, President
Congressional Sportsmen’s Foundation
Guy Harvey, Chairman
Guy Harvey Ocean Foundation
Thom Dammrich, President
National Marine Manufacturers Association