RECREATIONAL LANDINGS OF GULF RED SNAPPER: THE TRUTH WILL OUT

People don't quote time-tested aphorisms too often these days, but that doesn’t mean that those old bits of wisdom don’t still ring true.

When I look at what’s going on with recreational red snapper fishing down in the Gulf of Mexic, one of those sayings come clearly to mind

“The truth will out,”

although the same people and organizations on the Gulf Coast who have been fighting federal fishery managers for the better part of the decade are  still doing their best to keep their dreams of overly-liberalized regulations from running aground and breaking up on the shoals of reality.

As long-time readers of this blog already know, the Gulf recreational red snapper fishery has long been a source of controversy, with the boating and angling trades associations, in alliance with “anglers rights” groups purporting to represent the chronically-overfishing private boat anglers, squared off against just about everyone else on, including federal regulators, the conservation community, the commercial and for-hire fleets, and private boat anglers who are more concerned with the long-term health of the stock than in maximizing short-term landings.

The fight culminated in what was colloquially known as the “Modern Fish Act,” a bill originally intended to relieve anglers of many of their responsibilities for conserving coastal fish stocks, and perhaps to steal a little bit of quota from the commercial fishery in order to increase recreational landings even more, along the way.  But Congress knew better than to let that happen, and the version of the Modern Fish Act that passed turned out to be an inconsequential sop to the Gulf snapper fishermen, and little more.

However, those fishermen and organizations did manage to convince the Gulf of Mexico Fishery Management Council to allow the states to set private boat recreational red snapper regulations for both state and federal waters, provided that such regulations constrained recreational red snapper harvest within both the recreational annual catch limit and each state’s allocation of fish.

After the Gulf Council adopted such regulations, the whole Modern Fish Act crowd celebrated, with Jeff Angers, president of the Center for Sportfishing Policy, an umbrella organization for all of the angling and boating groups trying to water down the way federal fishery managers regulate recreational fishing, saying in a press release that

“We have reason to celebrate today thanks to the willingness of state fish and wildlife agencies on the Gulf Coast and the leadership of Secretary Ross and congressional champions like Senator Richard Shelby (R-Ala.) and Representatives Garret Graves (R-La.), Steve Scalise (R-La.) and Austin Scott (R-Ga.).  Over the past two years, private recreational red snapper anglers in the Gulf have become more active partners in the states’ data collection systems and enjoyed much longer red snapper seasons than the federal system was able to provide.”

The same press release declared

“This alternative management approach provides a proven model that could be applied to other fisheries to improve public access while ensuring conservation of America’s marine resources.”

I wrote about all of this last June, in a piece that noted that the different state and federal estimates of angling catch, landings, and effort, which all employ different methodologies and so return different results, still had to be calibrated, in order to come up with a “common currency” that allows such estimates to be accurately compared and combined.  I noted that despite the Center’s hype, the new management approach

“still has a few bugs in it.”

I observed that such problems

“can be fairly easily fixed, provided that the members of the Gulf Council have the requisite political will, and further provided that the states…are willing to get their recreational landings data into a form that is both accurate and usable on a regional basis.”

I also admitted that I was somewhat skeptical that would happen, saying

“given the seemingly intransigent problems that have allowed the private recreational sector to continually kill too many red snapper, at this point, the only thing I can say is that I’ll believe it when I finally see it, and not a moment before.”

It appears that my skepticism was justified.

Understand, it’s not that the Gulf Council or state fishery managers are shirking their jobs.  They’re not, even though one could argue that they might have been able to put things in place somewhat faster.  Instead, the usual suspects—representatives of the organizations that comprise the Center for Sportfishing Policy—are not celebrating anymore.

Instead, they may be ruing the fact that they forgot another old aphorism

“Be careful what you wish for, because you might get it,”

as they discover that merely handing private boat red snapper management over to the states doesn’t mean that they will be able to keep killing too many fish.

The calibration issue explains why.

The current recreational red snapper regulations have, over the past couple of years, been based on a 2018 stock assessment which, in turn, relied upon federal recreational effort data derived from the now-abandoned Coastal Households Telephone Survey, which was found to significantly underestimate recreational landings.  That survey has since been supplanted by a new Federal Effort Survey that replaces the random calls used in the Telephone Survey with a questionnaire randomly mailed to registered anglers as well as to some members of the general public (in order to capture unlicensed anglers). 

The new effort survey has revealed that recreational red snapper landings in some states were roughly 2 ½ times higher than previously believed.  That means that the recreational regulations based on the effort data derived from the old telephone survey may not have been sufficiently restrictive.

There is also the question of state landings estimates, which differ from those developed by the federal Marine Recreational Information Program, and how to incorporate those into stock assessments and the regulatory process.

There are at least two issues at play here.

One is that MRIP is at its best when relatively large numbers of anglers are surveyed; the relatively short red snapper season necessarily limits such number, particularly when data is developed on a single-state basis, and thus impairs the precision of the estimates.  For the years 2015-2019, the average “percent standard error” used to judge the precision of MRIP private boat red snapper estimates was between 21 and 22 in west Florida and Alabama, and nearly twice that in Mississippi, although it should be noted that Mississippi’s estimates grew increasingly precise over the years, and by 2018 and 2019, were roughly in the same range as the other states’ numbers.

The other is that each survey uses a slightly different methodology, which means that if the same surveys were used to sample the angling population in the same area, all would return different results, because they would sample somewhat different subsets of that population, and do it in somewhat different ways.  Thus, all of the surveys must be calibrated so that, when their estimates are combined, all of the numbers would be expressed in a “common currency” that assured that managers would be comparing apples to apples, rather than trying to turn an entire fruit bowl into some sort of coherent and meaningful data.

And that’s what currently has the Center and its constituent organizations upset.  Based on the original state allocations and resultant regulations, they had believed that anglers would have longer red snapper seasons, in which they might harvest more fish.  But when the calibration is done, that doesn’t happen.  Instead, it shows that the states of Alabama, Mississippi, and Texas have all overfished their red snapper quotas, and will have to be held accountable for the result.

If there is one thing that the Center detests, it is anglers being held accountable for their overages.  Tjhe Center and its member organizations are all about promoting anglers’ rights, but when it comes to anglers’ responsibilities, well, that’s not really their thing.

So a recent article in The Fishing Wire finds those folks complaining again about red snapper management.

“Just two years after approving a plan to allow the Gulf states to develop their own recreational data collection systems to better manage red snapper and certifying those state programs, NOAA Fisheries intends to force the states to calibrate their data back to the flawed federal data system that caused significant turmoil in the first place.  The federal data system, Marine Recreational Information Program (MRIP), has been widely criticized by many in the recreational fishing community, the states and in Congress, and its limitations are what led the each of the states to develop their own data collection systems.”

Such comments are an interesting collection of fact, spin, and half-truths that serve to cloud the actual issues, rather than to provide any real understanding.  For example, the state programs were certified to work in conjunction with, and not supplant, the Marine Recreational Information Program.  In fact, the National Marine Fisheries Service views them as a part of that program, referring to the “MRIP state surveys” and saying

“The MRIP state surveys are designed to improve regional monitoring of the recreational red snapper catch and effort.  Estimates from these surveys can be used for federal scientific stock assessments and fishery management once there is a transition plan that describes how to integrate state and general data, and how to calibrate new and historical catch and effort data.”

Thus, the state surveys were always intended to be a part of what the anglers’ rights crowd call the “flawed federal data system.”  And the next thing to ask is exactly why the federal system is supposedly “flawed?”  The National Academy of Sciences evaluated it back in 2017, and gave it pretty high marks—not a perfect score, there’s always room for improvement, but still a good grade—and made it clear that it was appropriate for most management purposes.

To take that question a step further, why was MRIP “widely criticized by many in the recreational fishing community, the states and in Congress [but not, it should be noted, by scientists, statisticians and others who are have the academic qualifications to intelligently pass judgment upon its worth]?”

The answer to that is pretty simple:  Because MRIP, and the calibrated state surveys, won’t allow Gulf private boat red snapper anglers to kill as many fish as they want to, and thus—or so people believe—won’t allow boat manufacturers and dealers to sell as many vessels, and won’t allow tackle manufacturers and shops to sell as much gear, as using state data in its raw and uncalibrated form.

If you look at the comments made by the Center for Sportfishing Policy, as well as by many unrelated members of the angling industry, you’ll discover that the criteria for data and science and such are pretty simple:  “Good data” and “good science” let you kill more fish, while “flawed” systems and “bad data” lead to more restrictive regulations.  It’s really as simple as that.

Thus, here in the Mid-Atlantic region, we saw the fishing industry embrace a 2016 stock assessment that found that the black sea bass biomass was well over twice the biomass target, and based on that assessment, demand less restrictive rules.  

But then we saw the very same people challenge the conclusions of stock assessments that said that striped bass and bluefish were overfished, positing vast unassessed populations of both species somewhere offshore, and in the case of striped bass, complaining thatthe stock assessment based its findings on population models and thestatistically verifiable data that it used to populate those models, and not on“alternative data” [yes, that phrase was used] that assumed the existence ofsuch offshore populations, and so the striped bass stock’s health.

It’s no different with red snapper.  The prospect of red snapper anglers being held accountable for their overages—overages that, as I noted in my essay last June, were predictable before the season ever started—outrages the responsibility-averse anglers’ rights crowd, with Ted Venker, the inappropriately-titled “conservation director” or the equally inappropriately-named “Coastal Conservation Association,” whining that

“There is clearly some gamesmanship going on…After the states invested the time and money to build more timely and accurate data systems and operated them for more than two years, NOAA Fisheries now comes back and says that all the new data must be converted back into its own flawed system for management purposes…It is absurd.”

It’s hard to decide whether Venker’s comments are intentionally disingenuous, or whether he merely lacks sufficient understanding of how MRIP works, and needs to do a bit more research before making any more embarrassingly inaccurate comments.

For while the state surveys—what NMFS clearly acknowledges were always intended to be the MRIP state surveys—do provide more timely data than did the un-enhanced MRIP system, discussions of which is “more…accurate” misses the point that calibrating the state surveys to MRIP isn’t about any survey’s inherent accuracy, but instead about putting all of the surveys’ data together in a way that allows them to be compatible. 

It’s like emptying out your wallet at the end of the year, after doing a bit of traveling, and finding that along with too few American dollars, you have some Canadian dollars, and a handful of Euros, too.  But since you can’t spend Canadian dollars or Euros in the United States, you convert them all to American dollars so that you can use them.  Along the way, you find that the currencies aren’t all worth the same:  Canadian dollars are worth less than their American counterpart, while Euros are worth more, but once converted to U.S. currency, they all spend the same.

That’s the same sort of relationship that the state surveys have to MRIP.  Although the folks howling about the unfairness of it all are concentrating on Alabama, Mississippi and Texas, which overfished so badly that they might not have any federal red snapper season at all next year, they conveniently ignore the fact that when you convert the western Florida data to the MRIP norm, just like converting Euros to U.S. dollars, Florida ends up getting more fish.

Things don’t just go one way.

But once again, a system that takes fish away is “bad,” so you whine, while one that provides a few extra is “good,” so…

Of course, it’s not just the Center and its disciples who are unhappy with the calibration results.  The states of Texas and Louisiana have now filed suit against the Department of Commerce and NMFS, hoping to avoid the impacts of emergency regulations that will shorten or shut down their red snapper seasons.  It’s particularly ironic that Texas would do so, as its state survey is so old—it precedes not only MRIP, but MRIP’s predecessor survey, which went on line in 1981—and creaky that correlation with MRIP is impossible.  In its 2017 review of MRIP, the National Academy of Sciences noted that

“Unfortunately, no comparison of results between the Texas survey and the MRIP exist…

“A full review of the Texas Marine Sport Harvest Monitoring Program is beyond the scope of this report.  However, based on a presentation to the committee about the survey and on discussion with regional partners and stakeholders it is questionable whether the estimates produced by Texas are comparable to those of the MRIP.  At the very least, it is highly advisable that the Texas survey be reviewed by an independent panel so that its applicability to regional fisheries assessment and management can be objectively assessed.  [emphasis added]”

For those not used to the genteel language of scientific reports, that highlighted phrase can be roughly translated into “and Texas ought to talk to somebody about replacing their crappy survey with something that might really work.”

But even so, the anglers’ rights folks claim that, by revising the numbers, it’s NMFS, and not Texas, that is wrong.

Although the state management effort generated a lot of false hope, it’s pretty clear that the red snapper debate in the Gulf of Mexico is far from over.  No matter who's counting, private boat anglers are still killing too many fish, and need to be brought to account.

Scientists will continue to refine their surveys and methods, trying to find the truth.  Fishery managers will work to apply the scientists' data to the management plan, in an attempt to prevent overfishing and keep the red snapper recovery on track.

And the Center and its asssociates will keep howling about how unfair it all is, and keep telling the world that the science—and the entire management process is flawed.

Unless, of course, one day gives them more fish.