Today, at 12:01 am, another federal recreational red snapper
season drew to a close in the Gulf of Mexico.
From some reports, it has been one of the most unsatisfying seasons so
far, not only for its length, but for a host of problems ranging from a dearth of willing
fish off Florida to the weather system that eventually became Tropical
Storm Colin creating hostile sea conditions in much of the Gulf, which led
the National Marine Fisheries Service to add an extra two days to the season.
So what happens next?
Maybe a month ago, in a Manhattan restaurant, I chanced into
a couple of old friends, who I once worked with on fisheries matters. We’re on different sides of the red snapper
debate these days, but we enjoyed a good meal and a good discussion. At the end, one of them asked me the
question: “How would you fix red
snapper?”
I couldn’t provide an immediate answer. But I did note that folks needed to admit one
simple truth: There will never be enough
red snapper to make everyone happy; demand will always exceed supply.
Anglers need to face up to some other things, too.
They need to accept the true impacts that recreational
fishermen have on the stock. For
example, I once received
a comment to another red snapper essay that asked
“[M]e as a recreational angler will probably get out fishing
offshore dependent on the weather and finances 20 times a year, and will only
fish red snapper certain times of the year.
How am I responsible for the decimation of this stock?”
The person asking that question, he forgot is that he is not
alone, but instead is is just one of many other anglers, all having an impact
on the red snapper stock.
According to a
report issued by the American Sportfishing Association in 2013, in just
one year salt water fishermen spent 1,480,312 angler/days fishing in
Alabama, 1,532,519 angler/days in Louisiana, 2,293,475 angler/days in
Mississippi and 8,157,241 angler/days in Texas.
They also spent 36,347,825 angler/days fishing in Florida, although that
wasn’t broken down between the Atlantic and Gulf coasts. Even if the Florida number was cut in half,
the figures show that, in the aggregate, anglers made more than 30 million fishing
trips in a single year in the Gulf of Mexico. While only a minority of those trips targeted
red snapper, the overall effort was
still clearly large enough to have an impact on the stock, even if each angler’s
individual impact was very small.
Then there’s angler behavior. The fishing mortality attributed to the
recreational red snapper fishery is a combined estimate of the number of fish
landed and an estimate of the number of released fish that die, as determined
by the Marine
Recreational Information Program and various studies on released
fish’s survival. What isn’t accurately
reflected in those numbers is the practice of “highgrading” or “culling,” in
which an angler keeps a limit of fish, but keeps on fishing; when a larger red
snapper is caught, the smallest fish is discarded, dead, into the ocean and
replaced by the larger one. It’s
impossible to know how serious such problem is, but I have spoken with Gulf
Coast charter boat captains with many years’ experience in the red snapper
fishery, and they tell me that such activities take place on far too many
trips.
Finally, anglers need to take full ownership of the fact
that, even without highgrading being taken into consideration, current
regulations are the result of anglers consistently overfishing the red snapper
stock for many years—although that
was not the case in 2014, when anglers stayed within their annual catch target,
nor was it the case last
season, when recreational anglers substantially exceeded the annual catch
target, but did not exceed the annual catch limit, thus proving the worth
of the 20% buffer between the target and ACL, adopted
at the behest of a federal judge to impose accountability on the fishery.
That 20% buffer, and the fact that it has apparently prevented
recreational overharvest in recent years, demonstrates that the fishery can, in
fact, be “fixed,” even if progress is made in very small steps.
The fact that recreational overfishing has apparently been
halted, at least for now, also raises the question of whether the fishery needs
any “fixing” at all and, if it does, what, exactly, needs to be “fixed.”
If you ask the folks who condemn the system, the biggest
problem is the short federal season, which limits anglers’ ability to access
the red snapper. In some ways, complaints
that
are both disingenuous and dishonest, as they completely
ignore much longer state seasons (as long as 365 days in Texas), that both
allow anglers to harvest fish in state waters and give them cover to run
farther offshore and illegally harvest red snapper in federal waters, an
opportunity that far too many anglers are willing to exploit.
There are only two ways to lengthen the federal season—either
find a way to provide more fish to anglers, or find a way to limit the number
of anglers catching the fish that are currently available.
So far, all of the effort has been spent on ways to provide
more red snapper to anglers. That has
proven a difficult and generally unproductive process; the only successful
effort has been a recent increase in anglers’ share of the harvest,
from 49% to 51.5%, a change so small that it was hardly worth the effort
involved.
Otherwise, the
angling community’s efforts have been aimed at weakening the conservation and
stock rebuilding requirements of federal law, or by evading those
requirements completely by taking
management authority for red snapper away from federal managers and handing it
over to the states. Both efforts, if
successful, would provide anglers with higher red snapper landings in the short
term, but over a longer period of time would likely cause real harm to the
stock, and leave anglers worse off than they are today.
Fortunately, for the moment, such efforts have stalled.
The only other way to get anglers more fish is to give them
access to the commercial quota.
The recent allocation change will probably be the Gulf of
Mexico Fishery Management Council’s last word on the subject for now. Given that the commercial red snapper fishery
is well-managed and completely sustainable, and supplies the non-fishing public’s
desires to dine on red snapper, there is little or no objective reason for
shifting fish from the commercial to the recreational sector.
On the other hand, there is also little or no objective justification for preventing
commercial fishermen from selling some or all of their quota to anglers on a
willing buyer/willing seller basis—that is, for selling or leasing such quota
if the commercial fishermen found it economically advantageous to do so, and
voluntarily decided to transfer quota to recreational fishermen, just as they
might lease it to other commercial fishermen, in any particular year.
Doug
Olander, the Editor-In-Chief of Sport Fishing Magazine, took a look at the
question a couple of weeks ago. He
notes that the North Pacific Fishery Management Council allows such
inter-sector quota transfers in the Pacific halibut fishery, and laments that
the Gulf Council isn’t willing to do the same.
Mr. Olander then suggests that the only way to get it done is to shift
responsibility for red snapper management to the Gulf states.
Although I agree with his basic premise, that inter-sector
quota sales would be a good thing, the downside of stripping NMFS of its
authority to manage red snapper would be greater than any advantage gained,
primarily because doing so would strip the red snapper of the protections
granted by the Magnuson-Stevens Fishery Conservation and Management Act. Without those protections, authority to
manage red snapper would be shifted from a science-based federal management system
to a state system where politics and short-term economic considerations would
be the primary drivers.
As an alternative, I suggest that angling interests should
sit down with representatives of the for-hire, commercial and conservation
communities, and work in good faith to find a solution.
That would require them—and everyone else—to leave their
egos at the door. Organizations would
have to be willing to forgo tub-thumping
press releases that impugn others’ interests while throwing red meat to such
organizations’ members. Each side
would have to forthrightly confront its own faults and flaws, as well as others’
legitimate concerns, and try to craft a compromise that takes all such things
into account.
The biggest obstacle to inter-sector transfer is probably accountability. The current commercial fishery is fully
accountable, with vessels calling in to regulators before making a trip,
monitored by a vessel monitoring system throughout the voyage, and calling in
again to provide regulators with the time and place that a catch will be
landed. Anglers are currently subject to
few such strictures, although in some states, they may be required to report
red snapper landings after their return.
The problem is, anglers often forego such reporting. New York charter boat captain John
McMurray, writing in Salt Water Sportsman,
noted that bluefin tuna anglers are required by law to report their landings
within 24 hours, but
“NOAA estimates that compliance with recreational bluefin
reporting requirements is a mere 20 percent.
I’d suggest it’s even lower.”
As an active member of New York’s tuna fishing community, I’d
agree. Reporting is particularly
problematic when a boat brings in 2 or 3—or 8 or 10—bluefin above the legal bag
limit, and/or illegally sells its catch through the back door of a restaurant
or fish store, which are, unfortunately, common practices here on Long Island.
It’s hard to believe that similar issues wouldn’t arise with
Gulf red snapper.
Another suggestion that’s making the rounds is to limit the
number of anglers able to access the red snapper resource, probably by issuing
a limited number of tags that would each allow an angler to harvest a single
fish.
One
proposal that has recently been making the rounds would have the
recreational fishery more closely resemble the for-hire and commercial
fisheries, in that each fish would have to be tagged, and fishermen couldn’t
pursue red snapper without having an unused tag on board.
Supposedly, such a program would benefit the
fish, because it would make anglers more accountable, and it would benefit the
anglers as well, because it would do away with the need for closed seasons and,
except as limited by the number of tags on hand, bag limits. Fishermen with excess tags would be able to
transfer them to those needing more.
It sounds like a great idea, except for one thing.
There are millions of recreational fishermen operating in
the Gulf of Mexico. If every one of them
killed just one red snapper, they would blow right through the recreational
quota.
Thus, tags would have to be limited to accord with the size
of the recreational quota.
The easiest way to do that would be by some sort of lottery. Here in New York, when hunters applies for a
license, they have the opportunity to try for a “deer management permit” which
allows them to take a doe, in addition to any buck that they might take
pursuant to their general license. The
number of management permits is limited; for a fee of $10, the hunter gets to
enter a lottery and perhaps win a the right to kill a doe.
The same sort of approach could be used for red snapper,
with each state assigned a limited number of tags to offer, provided in lots of
5, 10 or some other number. Unsuccessful
anglers would receive a “preference point” that would give them a better chance
in the following year’s lottery. Federal
managers would make possession of such state permit a prerequisite to possessing
snapper in federal waters.
It would require a voluntary/state federal agreement to implement,
and otherwise sounds as if it would work, but…
Last
year, only 46% of successful New York deer hunters reported their kills, as
required by law. That’s less than
half. While better than the reporting
rate for bluefin tuna, it’s still pretty dismal, and that’s even after the
check stations and enforcement roadblocks aimed at ensuring compliance come
into play.
There’s no reason to believe that Gulf red snapper anglers
would report at higher rates.
The issue remains one of accountability. And that is an issue uniquely within anglers’
control.
Putting together something that works would be neither easy
nor impossible. So to the question “How
would you fix red snapper,” I’d now give the following response:
In many ways, the system is not broken. The commercial and for-hire fisheries seem to
be staying within their annual catch targets, and in the past couple of years,
overfishing by private boat recreational anglers appears to have finally been
constrained. The stock is being
successfully rebuilt, with more fish and more and older age classes appearing
in the population. Those are all good
things.
However, the length of the recreational season in federal
waters remains a sticking point. In
order to extend that federal season, I would do the following things.
1. Bring
states into compliance with the federal season and regulations. Since red snapper landings, wherever they
occur, affect the length of the federal season, shortening state seasons would
result in a longer federal season, not coincidentally because it would make it
far more difficult for anglers to poach red snapper in closed federal waters,
where the bulk of the population is found.
With poaching brought under control, the number of fish reported as caught in state waters is
likely to plummet, allowing the federal season to expand.
2. Allow
the inter-sector transfer of commercial quota on a willing buyer/willing seller
basis. No commercial fisherman
should be forced to give up any part of his or her quota. However, if such fisherman chose to sell or lease quota to a
recreational fisherman or other clearly identifiable and responsible party, such
transfers should be permitted.
3. Implement
a tag system covering the entire recreational quota. No angler would be allowed to land, or
possess, a red snapper unless that fish was marked with the proper tag (anglers
purchasing/leasing commercial quota would have alternate reporting
requirements). All such tags would have
to be of a construction that only permits one-time use (such tags are common in
the commercial fishery) and would have to be attached immediately upon landing
the fish. Reporting would be required
within 24 hours, and a failure to report or return unused tags would render a
fisherman ineligible to apply for tags in future years.
4. Implement
meaningful accountability measures.
A red snapper fisherman would have to call in to an established number
before leaving the dock, providing regulators with the name of the boat, port
and expected time of return. Upon
return, the fisherman would have to call in before reaching the dock, providing
regulators with the number of fish on board and the tag numbers used, thus
helping to prevent re-use or the non-attachment of tags. Anglers buying/leasing commercial quota would
have to comply with commercial regulations re reporting harvest, but not vessel
monitoring.
5. Implement
penalties strong enough to deter violators. This one is self-explanatory. However, the regulations must be
zero-tolerance, with no allowance for “accidental” failures to call in on
departure or return, failure to tag
fish, etc. Fines must be substantial,
sanctions on future ability to obtain tags imposed, and forfeiture of vessel
and gear a possibility in the case of repeat offenders.
Yes, I know much of that is
pie-in-the-sky. But I also know that if
I can come up with some sort of workable framework, folks intimately involved
with the fishery can too, and probably devise something far better.
That is, they can if they are
willing to embrace cooperation instead of confrontation, are willing to reach a
compromise that meets the dictates of science and federal law, and are willing
to consider the wants and needs of sectors along with than their own.
Would the result be perfect and
make everyone happy?
Absolutely not.
But it would still be a lot better
than what they have now.
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