On August 10, the
National Marine Fisheries Service announced that it would issue an exempted
fishing permit that would allow a commercial fishing operation to engage in “pelagic
longline research” off the east coast of Florida, in an
area that had been closed to longlining since 2001.
The closures were adopted as an important fishery conservation
measure. As noted in the
Final Environmental Assessment issued in respect of the exempted fishing permit,
“The closures were implemented to reduce bycatch and
incidental catch of overfished and protected species by [pelagic longline] fishermen
who target [highly migratory species].
At the time, Atlantic blue marlin, white marlin, sailfish, bluefin tuna,
and swordfish were overfished, and bycatch reduction was a component of
rebuilding efforts. In particular, the
U.S. was implementing a 1999 swordfish rebuilding plan, and the closure helped
reduce bycatch of juvenile swordfish.
Several other laws required that NMFS address bycatch in [highly
migratory species] fisheries, including the [Endangered Species Act], which
required reductions in sea turtle take in the [pelagic longline] fishery. National Standard 9 of Magnuson-Stevens Act
also requires that fishery management plans minimize bycatch and bycatch
mortality to the extent practicable.”
Pelagic longlines have a bad—and well-deserved—reputation as
bycatch-prone gear, and it’s not surprising that the issuance of the exempted
fishing permit met with strong opposition from the recreational fishing
community, which will have to compete with the longliners both for the
available swordfish and for the many other species that the longliners kill as
bycatch.
In February, The
Center for Sportfishing Policy sent NMFS a letter opposing the exempted fishing
permit, which was co-signed by a number of other organizations, including
the American Sportfishing Association, the National Marine Manufacturers
Association and the Coastal Conservation Association. The letter informed NMFS that
“…our organizations see no legitimate need for the proposal
and have a great deal of concern on the potential impacts of the proposed
research. According to the Draft Environmental
Assessment issued by NMFS, if the [exempted fishing permit] is approved and
research is conducted for the three years requested, an additional 5,499 undersized
swordfish, 759 billfish and 6.135 sharks that are prohibited from retention
will be killed over and above what would take place in the [pelagic longline]
fishery if the [exempted fishing permit] was not issued. These estimates are a grim reminder of the
threat that efficient, indiscriminate longlines pose to conservation gains not
just in the [closed area], but in all of the world’s oceans…”
The venerable International
Game Fish Association, one of the original members of the Center for
Sportfishing Policy, wrote its own letter to NMFS opposing the issuance of the
exempted fishing permit, arguing in part
“We are also concerned with projected blue marlin and
sailfish bycatch. Blue marlin are currently
overfished and experiencing overfishing and even a modest increase in bycatch
mortality from the [exempted fishing permit] is not acceptable to IGFA and its
members. Sailfish represent the highest
projected billfish bycatch (424 fish annually) from the proposed [exempted
fishing permit]. IGFA would like to
emphasize that the results of the 2016 western Atlantic sailfish stock
assessment are equivocal.
“While the assessment reports that it is “not likely” that
the stock is overfished or experiencing overfishing, the ICCAT Standing
Committee on research and statistics has stated that: ‘Both the eastern and western sailfish stocks
may have been reduced to stock sizes below [the biomass that would produce
maximum sustainable yield].’
“The IGFA is cognizant that the US continues to struggle to
fully capture its ICCAT swordfish quota and that there are concerns the quota
underage may be reallocated to other countries who’s [pelagic longline] fleets
do not fish by the same conservation standards as ours. Nevertheless, we do not feel that this
international issue justifies compromising the conservation benefits gained
from implementing the [closed area]…”
“Authorizing longline gear to fish within the Closed Zone
could cause the conservation successes gained to be reversed. No reasonable explanation can be given to
consider the [exempted fishing permit] application, other than once an application
is received the NMFS must give it review and public notice.
“Why not continue to build upon the realized conservation
successes that were generated by the agency’s closures of the waters in the
zone? Any doubt as to the results of a
change in policy should err to benefit the marine resources… [emphasis added]”
“RFA finds it next to impossible for NMFS to deny the
conservation value of the…closed area or claim that a reintroduction of pelagic
longlines into the closed area is necessary to evaluate its effectiveness. This closed area was instrumental in spurring
the recovery of north Atlantic swordfish and creating a recreational swordfish
fishery that now holds significant socioeconomic value to the coastal
communities of Florida. Furthermore, the
closed area has also allowed the near-shore, recreational sailfish fishery to
become one of the most valuable non-consumptive fisheries in the world…”
It’s hard to disagree with any of the above statements,
particularly when other
gear is available to commercial swordfishermen which produces far less bycatch
and discard mortality than do longlines.
I completely agree with those who believe that there was no need to
introduce longlines into the long-closed area east of the Florida coast, and
who would have preferred that NMFS not issue the exempted fishing permit.
Even so, it’s important to note the
Final Environmental Assessment’s assurance that
“The additional swordfish landings would be counted against
the ICCAT-recommended U.S. swordfish quota, which has been consistently
underharvested in recent years and catch would remain well within the available
quotas…
“Catches of all tunas, except skipjack, are projected to
decrease relative to otherwise authorized routine fishing operations in the
open area under either alternative if fished the level of effort requested by
the applicant…
“Bycatch of all billfish, except sailfish, are projected to
decrease relative to otherwise authorized routine fishing operations in the
open area under either [alternative] at the level of effort requested by the
applicant…”
Thus, no overfishing of the swordfish resource would be
taking place, while bycatch of tuna and most billfish would be reduced,
although there would be a substantial increase in the number of sharks killed.
It’s also important to note that issuance of the exempted
fishing permit only benefits the commercial fishing sector, and has arguably
negative consequences for the recreational fishery, which will face greater
commercial competition for the available swordfish.
Thus, it’s perhaps not surprising that recreational fishing
organizations find it so easy to criticize NMFS’ decision to issue the exempted fishing permit, which will have no negative
long-term impact on the swordfish resource, while praising other NMFS actions that allow the recreational community to overfish both red snapper and summer
flounder, and could have negative impacts on the resource and the commercial
sector.
Earlier this year, when
NMFS issued a temporary rule re-opening the private-boat recreational red
snapper fishery in the Gulf of Mexico, it admitted that
“The stock is still overfished…if employed for a short period
of time, this approach will ultimately delay the rebuilding of the stock by as
many as 6 years. This approach likely
could not be continued through time without significantly delaying the
rebuilding timeline. Similarly, the
approach will necessarily mean that the private recreational sector will
substantially exceed its annual catch limit, which was designed to prevent
overfishing the stock.”
Yet, even though NMFS admits that the reopening will lead to
anglers “substantially” overfishing an already overfished stock, and delay the
recovery of the stock for as much as six years, the angling organizations that
were so concerned about the negative conservation impacts of the exempted
fishing permit on a relatively healthy swordfish stock had no concerns at all.
In fact, they welcomed the overfishing
despite its consequences, with
the Center for Sportfishing Policy issuing a statement saying, in part,
“Today’s announcement is a fix—albeit a short-term fix—that will
allow millions to enjoy one of America’s greatest pastimes and boost economies
far beyond the Gulf of Mexico—including in the manufacturing and retail sectors
in non-coastal states.
“The federal fisheries management system is failing
recreational anglers on many levels, and the red snapper is the ‘poster fish’
of the quagmire. The temporary rule
directly addresses this problem, giving millions of recreational anglers in the
Gulf of Mexico an opportunity to enjoy America’s natural resources and giving
the Gulf economy a much-needed shot in the arm…
“Anglers commend the Trump Administration and Members of
Congress for hearing our calls for more access to federal waters—and for taking
action…”
“a welcome boon to anglers who have been painted into a
corner by a federal fisheries management system that does not understand us and
would often just rather ignore us,”
although it’s difficult to argue that NMFS ignores anglers
as much as anglers are trying to ignore how badly they’re overfishing the Gulf
red snapper stock. Such overfishing
makes it tough to understand how CCA, so concerned about non-overfished swordfish,
can say that because of the reopening and despite the inevitable overfishing
“The recreational community should feel vindicated, and we
should take heart that after years of being systematically sidelined by NOAA
Fisheries, our efforts to encourage our elected officials in Congress to engage
in this man-made management disaster are yielding results…As a result of our
passion and our refusal to be cast aside, anglers will be allowed to venture
into the Gulf of Mexico with their family and friends on weekends throughout
the summer in pursuit of the most popular offshore fish in our waters…”
In the Mid-Atlantic, something similar occurred.
Due
to poor recruitment, summer flounder abundance has steadily declined, until it
reached the point that the stock might soon become overfished. As a result, the Atlantic States Marine
Fisheries Commission adopted a management plan that required Connecticut, New
York and New Jersey to reduce their bag limit from 5 fish to 3, increase their
size limit from 18 to 19 inches and keep the same 12-day season that they had
in 2016.
Connecticut
and New York went along, but New Jersey refused, insisting on keeping its
size limit at 18 inches and shortening its season to 104 days, arguing that,
between the two changes, New Jersey’s regulations would have the same
conservation impact as those that ASMFC would impose. ASMFC disagreed, found the state to be out of
compliance with the summer flounder management plan, and referred the matter to
the Secretary of Commerce who, if he agreed, would impose a moratorium on
summer flounder fishing in New Jersey waters until the state adopted
regulations acceptable to ASMFC.
The Secretary of Commerce failed to support the findings of
ASMFC and its scientists. Instead, he
found that New Jersey was right, and that its regulations did have conservation
equivalency with those adopted by ASMFC.
It
was the first time that the Commerce Department failed to support ASMFC’s
findings, and throws the future of ASMFC’s cooperative interstate management
program into doubt. It also won’t do
the summer flounder any good; the best available science indicates that,
because Commerce overturned ASMFC’s finding, New Jersey will catch about 94,000
more fish than is scientifically prudent.
Yet, once again, angling organizations seem to believe that
such overfishing is a good thing.
The same Recreational Fishing Alliance that opposed the
notion of longliners receiving the exempted fishing permit—even though
swordfish would not be overharvested as a result—celebrated the Secretary of
Commerce’s decision, with Jim
Donofrio, RFA’s Executive Director, reportedly saying
“[Commerce Secretary] Ross was brilliant in his
decision. The Trump administration has
challenged a broken fishery management system in this country, and I applaud
them for doing it.”
Which makes it seem that the recreational fishing community
has no coherent policy when it comes to matters of conservation, stock
rebuilding and overfishing.
Do they really believe, as The Billfish Foundation stated,
that “Any doubt as to the results of a change in policy should err to benefit
the marine resources,”?
Or is the Coastal Conservation Association’ support for
anglers being “allowed to venture into the Gulf of Mexico with their family and
friends on weekends throughout the summer in pursuit of” red snapper, even if
that means that the red snapper resource will be badly overfished, and its
recovery delayed for years, more representative of the recreational
organization’s position?
Because those two stances seem to be diametrically opposed,
and without a coherent underlying management philosophy.
Unless, of course, the underlying philosophy is that commercial harvest
should be subject to precautionary management, with all doubts resolved in
favor of the resource, while recreational harvest should be free of
biologically-based constraints, with overfishing accepted as a matter of course
if it lets more people kill fish and lets angling-related businesses make more
money.
Kind folks might call that sort of philosophy schizophrenic.
Critical folks might call it self-serving.
And some folks might call it hypocrisy.
None of those folks would be wrong.
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