THE POLICY

One of the continuing themes in fisheries management this year was the notion of a “Recreational Fishing Policy”.

It’s another one of those ideas given birth down in the Gulf of Mexico, where anglers keep feeling picked on, that risks creating “collateral damage” among anglers everywhere else on the coast.

The basic premise of the push for a recreational policy is that the National Marine Fisheries Service manages fish for the benefit of commercial fishermen (I think we might find more than a couple of folks up in New England who disagree with that, but…) and doesn’t understand how to manage recreational fisheries. 

As evidence, they point to the red snapper fishery in the Gulf of Mexico where the big, bad federal government won’t allow anglers to overfish the red snapper stock or, as an alternative, turn the entire fishery over to the recreational anglers so that they can kill every red snapper that the biologists will allow.

Bill Bird, Chairman of the Coastal Conservation Association’s national Government Relations Committee, noted in public comment to the Gulf of Mexico Fishery Management Council that

“…we question the timing of an effort that represents such a significant shift in recreational fisheries management in the middle of NMFS’ attempt to craft the nation’s first Recreational Saltwater Fisheries Policy.  It is highly ironic that passage of Amendment 40 will severely limit the ability of the Council or NMFS to meaningfully implement any such policy for the Gulf recreational red snapper fishery, which is virtually the sole impetus for the creation of the policy in the first place  [emphasis added].”

The fact that most of America’s anglers probably don’t catch a single red snapper in any given year—and don’t particularly want to—doesn’t matter to these folks.  They’re using red snapper to inform a policy that will impact all of us, whether we prefer to fish for striped bass, scup, summer flounder, king mackerel, kelp bass or king salmon. 

Thus, it’s probably in our interest to take one last look at what is being proposed and perhaps make some comments that might help to clean up some of the rough spots.

Let’s start out with the fact that the policy includes good things which, if put into effect, will benefit both anglers and the fish we pursue.  However, we also have to be cognizant of the fact that the recreational fishing industry has worked pretty hard to get what it wants into the policy, and as a result, a few things got in there that are based on a questionable premise.

The trick then, for anglers, is to separate those policy elements that will benefit both fish and fishermen from the padding that the industry put in there to benefit themselves.

For example, we should first insist on the truth.

That gets stretched quite a bit by a couple of statements, one of which notes that

“Saltwater recreational fishing is a traditional, important and expanding thread in the social, cultural, and economic fabric of coastal communities in the United States.  [emphasis added]”

I’ll grant NMFS the “traditional” and “important” parts, but as to “expanding”, well, that just isn’t so, no matter how many folks were crawling over the rocks out at Montauk last fall, or how many stood shoulder to shoulder down at Hatteras when the red drum came in.

That means that the statement that

“…an increasing number of people are pursuing recreational opportunities afforded by this nation’s expansive coastal and ocean resources”

is equally untrue, if “recreational opportunities” is defined to mean “recreational fishing.”

The data on recreational fishing effort over the last ten years pretty much say it all.

Back in 2004, according to the National Marine Fisheries Service, anglers throughout the United States made about 79 million individual fishing trips (note that such number is actually low, as it does not include trips made in Alaska, California, Oregon, Texas or Washington, which do not participate in NMFS’ data collection program; however, since information from those states will be consistently absent from this discussion, the trends discussed remain valid).

By 2013, the number of annual trips had dropped to roughly 64 million, a reduction of 19%.  The drop was even sharper in many regions.  For ten years between 2004 and 2013, effort dropped by 29% in the North Atlantic, 24% in the Mid-Atlantic, 22% in the South Atlantic, 48% in Hawaii and 51% in the Caribbean. 

In all of those places, angling effort has been steadily trending down over the years.

Only the Gulf of Mexico seemed to buck the trend somewhat (remember what I wrote about the Gulf fishermen trying to shape this policy to reflect their reality, rather than that of the rest of us?).  There, anglers made about 26 million trips in 2004 and 25 million trips in 2013, which also appears to reflect a small decline, but this is one of those cases where two terminal years don’t really tell the right story or reflect dominant trends.

Both 2004 and 2013 appear to be outliers, in which Gulf effort was higher than the norm.  

Over the entire 10-year period, anglers averaged about 23.67 million trips, not very different from the 23.66 million trips that they averaged in most recent three years, 2010-2013.  So, unless you believe that 2013 was the start of a new upward trend, angler effort in the Gulf of Mexico over the past decade was flat.

Saying that angling is “expanding” or “increasing” is a factual error that needs to be fixed, but there are true policy problems that need fixing, too.

The first appears in the statement that

“the goals of this policy are to promote recreational fishing for the cultural, social and economic benefit of the nation…  [emphasis added]”

If it said, to “manage recreational fishing” for the greatest national benefit, I’d be the first one on board, but “promote” is a very different thing.

It’s just not NMFS’ job to spend taxpayer dollars to “promote” any particular industry, including those that cater to saltwater anglers.  The American Sportfishing Association does that job just fine.

It’s also dangerous to put NMFS in a position where it is responsible for both regulating anglers and promoting angling.  

It’s a no-win position for the agency, which could easily get whipsawed between its obligation to prevent overfishing and recover fish stocks (although we don’t like to admit it, anglers can overfish and, at times, be an obstacle to recovery) and its proposed job of promoting recreational fishing (even, presumably, when stocks are down).

We’ve seen that happen when NMFS tries to both promote and regulate the commercial fishing folks, and there’s really no reason to go down such a bad road again…

The policy reassures us that

“..the goals of this policy are to promote recreational fishing…through science-based conservation and management…”

and includes a statement that

“NMFS will…support ecosystem conservation and enhancement…”

both of which are good.

But the Devil is always in the details, and as you read through the policy, you realize that they guy in the red suit, with horns on his head and pitchfork in hand, has authored some of the details here.

For example, the Policy describes recreational fishing as fishing “for sport or pleasure,” with the anglers

“…retaining, consuming, sharing or releasing their catches…  [emphasis added]”

Yet it’s hard to understand why the word “retaining” is necessary, since “consuming” and “sharing” pretty well describe the only things that one can do with a dead fish, outside of selling it (which recreational fishermen, by definition, can’t do) or using it as fertilizer, which is something that the Policy certainly shouldn’t encourage.

The Policy’s specific inclusion of “tournaments” within the definition of recreational fishing just enhances that concern, because we all know that there are still a lot of big-money “dumpster tournaments” out there, in which fish—usually big apex predators such as sharks and marlin—are killed and weighed in for prizes; after such events are over, the winners drive away with their checks and the fish are driven away to a landfill, if they’re not just dumped back at sea.

Such wasteful events are a relic of the last century, and have no place in this one; no rational national recreational fishing policy should even suggest that such waste is justified.

So, as far as I’m concerned, the references to “retaining” and “tournaments” should both go away.  “[C]onsuming, sharing or releasing” pretty well cover the universe of acceptable use.  If you can conduct a tournament within those parameters, fine.  If you can't...

NMFS should also rethink the notion that the

“easing of regulatory fishery restrictions when conservation goals are achieved”

is a worthwhile Policy goal.

Sure, it’s nice if it can be done, and the measures needed to maintain a fishery at sustainable levels are usually not as strict as those needed to rebuild it, but that’s not always the case.  

The black sea bass fishery in the Mid-Atlantic is a prime case in point.  The stock is fully rebuilt and the fish are very abundant; in fact, they’re so abundant that anglers aren’t having any trouble catching them, and as a result are overfishing badly.  Next year, it appears that regulations will actually have to be tightened…

And such overfishing leads to the next concern, the promotion

“…of sustainable, safe aquaculture to support recreational fisheries…”

In plain English, that means hatcheries, and that’s not a good thing.

I touched on them in detail in an earlier blog, entitled “Seductive—but not Satisfactory.”

The bottom line is that hatcheries are, for the most part, a sign of failed fishery management policies.  They give managers an opportunity to let people overfish stocks with a clear conscience, as they know that an endless supply of “rubber fish” produced in a tank will be provided to replace what the anglers remove.  

However, there is a good body of research which suggests that hatchery fish are not as fit to survive as their naturally spawned counterparts, and if enough such fish are dumped into the water, can harm the genetic makeup of the natural population. 

Reducing our fish’s fitness to survive isn’t something that the Policy should support.

The final problems with the Policy lie in its call for

“innovative solutions to evolving science, management and environmental challenges through partnerships by supporting investigation and development of new …data collection techniques (e.g., electronic catch reporting)…”

as well as

“public-private collaboration (e.g., cooperative research and citizen science activities)…”

That’s just asking for trouble.

So far, NMFS’ efforts in the direction of “electronic catch reporting” have been notably unimpressive.

For example, anglers are supposed to report every Atlantic bluefin tuna that they land within 24 hours.  However, when I spoke with an employee of NMFS’ Highly Migratory Fisheries unit at the Recreational Fishing Summit down in Alexandria, Virginia last April, he lamented that reporting rates languished at around 20%--anglers who landed 4 out of 5 bluefin tuna fail to comply with the law.  That doesn’t bode well for electronic reporting by anglers.

It’s not clear that for-hire vessels will do any better.

Right now, federally-permitted for-hire vessels in the Mid-Atlantic summer flounder, scup and black sea bass fishery are required to file vessel trip reports, but there is reason to question the information provided.

For example, when passengers of a New Jersey party boat landed over 800 out-of-season black sea bass a few years ago, the captain told a reporter that

“I didn’t think it was that many.  And I’m not getting paid by the State of New Jersey to take fish out of people’s buckets.”

With comments such as those, it’s easy to guess that his vessel trip reports might be lacking in accuracy.

And while those passengers were taking illegal fish, the captain appears to have acted within the law.  When you consider the number of for-hire boats that don’t do everything by the book, such as those out in Montauk, New York who conducted “sushi cruises,” allowing their fares to kill and eat undersized summer flounder right on the boat, or a Sheepshead Bay boat that allows its passengers

“to keep anything and everything that they catch,”

 (and please note that these are only two examples of blatant violations; I could have bored you with plenty more if I thought that it would have served any purpose), it’s a pretty fair bet that many vessel trip reports don’t bear much resemblance to reality, and will not improve the fisheries management process.

Similar concerns surround the concepts of “cooperative research” and “citizen science”.

Any time that someone offers to “help” NMFS conduct research, our first reaction should be to question why.  

Maybe they are merely scientists, seeking to further their professional reputations by conducting research that will expand our knowledge about the fish stocks that swim off our shores.

But there is a good chance that they have more selfish motives.

Perhaps they are state employees seeking to impeach NMFS’ data, in order to get a few more fish for local residents, as we have seen happen in Alabama’s red snapper fishery.  

Maybe they will be members of the fishing industry trying to find ways for their customers to increase their kill, as we’ve seen with summer flounder.

But we can be pretty sure that what we’ll be seeing is agenda-driven research, and not the sort of objective research that should be used to manage America’s fisheries.

That shouldn’t be part of the Policy, either.

So what should be a part of a recreational fishing policy?

In my view, recognition that salt water fish are a public resource, which should be managed in a way that benefits the public as a whole, and not just particular industries.  

That should be coupled with recognition of the fact that recreational fishing is just that—recreation—and that the best recreational experiences occur when fish are abundant and fishing is fun.  Recreational fishing is not and should never be a grim grind aimed at filling the fish box—although eating some of one’s catch is a pleasure that should never be denied.

The way to provide a quality recreational experience is through good, objective science, using data that meets the highest scientific and statistical standards, obtained through reliable and verifiable sources rather than from folks with their own ax to grind.  That science must then be used to craft regulations that place the highest priority on the long-term health of fish stocks, for everything else—all economic, social and recreational benefits—depend on the fish being there.

Fishing in an empty ocean is not very much fun.

But that’s only my view.  I’m sure you have your own.

And if you do, you should let NMFS know what it is, by going to http://www.nmfs.noaa.gov/sfa/management/recreational/policy/, clicking on the links and filling out the form.

You have until December 31 to do it.

This weekend would be a good time.