Sunday, September 5, 2021

CONGRESSIONAL SPORTSMEN'S FOUNDATION SUPPORTS BAD GULF RED SNAPPER SCIENCE

 Last week, the Congressional Sportsmen’s Foundation issued a press release critical of federal red snapper management in the Gulf of Mexico.  In particular, the Foundation criticized the National Marine Fisheries Service’s insistence that state-generated red snapper harvest data be calibrated, so that it could be used in conjunction with data generated by NMFS’ Marine Recreational Information Program.  The release also praised the Gulf of Mexico Fishery Management Council’s April refusal to require such calibration in advance of the 2021 red snapper season, and more recent, August refusal to require such calibration ahead of the 2022 snapper season.

I’ve written about the calibration issue before.  The story is fairly straightforward. 

All five of the states bordering the Gulf of Mexico have developed their own programs for estimating annual red snapper catch, landings, and effort.  The designs of four of those programs, Florida’s State Reef Fish Survey, Alabama’s Snapper Check, Mississippi’s Tales ‘n Scales, and Louisiana’s LA Creel (Texas still employs an archaic survey first adopted in 1974 and revised in 1983, which was developed without NMFS guidance and has not, and almost certainly will never be, certified by the agency), have been certified by NMFS as “statistically valid for monitoring recreational catches.” NMFS has stated that

“Estimates from these surveys can be used for federal scientific stock assessments and fishery management once a transition plan is developed that addresses:

“1.  How to best integrate these supplemental surveys with the general MRIP surveys.

“2.  How to best adjust historical estimates based solely on the general MRIP surveys to be consistent with new estimates based on the integrated approach.  [emphasis added]”

As early as January 2017, it was recognized that use of data from the state-administered surveys

“in stock assessments and management actions, requires their conversion into a ‘common currency’ that makes them comparable to historical MRIP estimates.  Implementation of such a conversion requires development of peer-reviewed scientifically valid methods, which is expected to take an additional six months.  [emphasis added]”

Four and one-half years have now passed, and the needed “common currency” has not yet been developed, yet the Congressional Sportsmen’s Foundation, like the Gulf Council itself, is seeking even more delay.

The reason for such opposition is just what one might expect:  If state-administered data were recalibrated to make it comparable to MRIP estimates, such data would show that anglers in some states, including Alabama, Mississippi, and Texas, significantly overfished their state red snapper quotas, and would face substantially more restrictive regulations in order to correct the problem.  Thus, the Center for Sportfishing Policy and its affiliated organizations, which have actively working to disrupt science- and data-driven red snapper management in the Gulf for the last decade or so in order to hike the recreational red snapper kill, has gone all-in to discredit the recalibration process.

Last week, we saw how Ted Venker of the Coastal Conservation Association, one of the founding organizations behind the Center, use “alternative facts” and a “post-truth” approach in an effort to undercut calibration and federal red snapper management.  Now, the Congressional Sportsmen’s Foundation, another leading member of the Center, is taking its turn at undermining federal red snapper management.

To give the Foundation what little credit it may be due, its rhetoric wasn’t quite as heated as that coming out of the CCA, and it’s claims were more in the nature of post-truth spin rather than full-out alternative facts. 

It first set the tone by heading its press release

“Gulf Council Hands Red Snapper Debacle Back to NOAA Fisheries,”

as if the problem was created by that federal agency, instead of by the Gulf Council’s intransigent refusal to move forward with badly needed calibration, and too many Gulf Council members’ willingness to violate the oath that they swore upon being seated.  That oath states, in part, that

“I, [name of the person taking oath]…commit myself to uphold the provisions, standards, and requirements of the Magnuson-Stevens Fishery Conservation and Management Act…”

At the August Gulf Council meeting, there was plenty of reason for the Council members to believe that the provisions of Magnuson-Stevens required them to begin the data calibration process.  Such reason came in the form of a memo from Dr. Clay Porch, Director of the Southeast Fisheries Science Center, to Dr. Andrew Strelcheck, the Acting Regional Director of NMFS Southeast Regional Office, and a subsequent letter from Dr. Strelcheck to Dr. Carrie Simmons, the Executive Director of the Gulf of Mexico Fishery Management Council.

Dr. Porch’s memo advises Dr. Strelcheck that, with respect to the Gulf of Mexico Red Snapper Recreational Data Calibration and Recreational Catch Limits framework action approved by the Gulf Council at its April 2021 meeting,   

“Alternative 1 [No Action—Retain the state-specific red snapper private angling component annual catch limits (ACL) established in Amendment 50A for the Fishery Management Plan (FMP) for Reef Fish Resources in the Gulf of Mexico (Reef Fish FMP)] should be explicitly identified as a non-viable option…[such alternative is] expected to result in the private angling sector continuing to exceed the total ACL indefinitely.

“In the discussion of alternative 1 add the underlined to the following sentence:

‘This is inconsistent with the requirements of the Magnuson-Stevens Fishery Conservation and Management Act and is therefore not a viable option for management.’”

The Gulf Council followed that much of Dr. Porch’s advice.  But Dr. Porch also noted that

“The decision to defer the effective start date for preferred alternative 2 [Modify the state-specific red snapper private angling component ACLs using the ratio calibrations developed by the National Oceanic and Atmospheric Administration’s (NOAA) Office of Science and Technology (OST) and the respective Gulf states] to 1/1/2023, when it could be in place for 2022, is not based on best available science.  All other alternatives presented in the framework action can be implemented by 2022 and no definitive justification for the separate treatment of alternative 2 was presented in the discussion of the action.  The deferred start date for alternative 2 would, as stated in the document, result in the private sector ACL being exceeded in 2022.  This is inconsistent with the requirements of the Magnuson-Stevens Fishery Conservation and Management Act.

“The effective date for alternative 2 should be moved to 1/1/2022 and all supporting text should be updated to reflect this change.  [emphasis added]”

In response to that advice, Dr. Strelcheck informed the Gulf Council that

“The [Southeast Fisheries Science Center] responded with comments on the Framework Action on June 21, 2021…One of the comments indicated that Preferred Alternative 2 was not based on the best available science because it delayed the implementation of the calibration methodology until 2023.  The [Southeast Fisheries Science Center stated that delaying implementation would result in the private angling component exceeding their annual catch limit in 2022.  The [Southeast Fisheries Science Center] points out that this is ‘inconsistent with the requirements of the Magnuson-Stevens Fishery Conservation and Management Act.’

“…Because the Council has yet to transmit the Framework Action to [the Southeast Regional Office] for implementation, I request the Council add this to the August 2021 meeting agenda to review and address  the [Southeast Fisheries Science Center] comment…”

Despite such request, the Gulf Council voted against amending the Framework Action as requested by Dr. Strelcheck, and so abandoned their oath to comply with the provisions of Magnuson-Stevens, thus setting the stage for NMFS to disapprove their illegal action, and leave red snapper management in limbo.

Perhaps those who ignored their oath and their duty believed that they were in a win-win situation; whether NMFS approved the 2023 recalibration date, or whether it disapproved the Framework Action, recreational red snapper quotas for the 2022 season would remain status quo.  Or maybe they are hoping that disapproval will lead to the Secretary of Commerce issuing emergency regulations to prevent overfishing, which their allies might challenge in a friendly court.

Whatever their thinking, the Congressional Sportsmen’s Foundation chose not only to support, but to praise, the oathbreakers.  And they did so on the flimsiest pretenses, admitting that

“Averting a severe cut in the 2021 red snapper seasons in Alabama and Mississippi, the Gulf of Mexico Fishery Management Council voted at the April meeting to delay implementing the calibration of the Gulf states data collection programs until 2023,”

and then justifying such vote by saying

Why it Matters:  Red snapper are one of the most important recreational species in the Gulf of Mexico, and particularly in the states of Mississippi and Alabama.  Prior to the April 2021 meeting of the Gulf of Mexico Fishery Management Council, these two states were facing potential drastic cuts in their private recreational red snapper season because of discrepancies in angler catch reporting between the old federal data programs and the new, more reliable state data collection programs…”

It’s important to note the misdirection here; while the state-administered data programs may be better suited for in-season management, as they process the data more quickly than NMFS’ MRIP, there are no objective, peer-reviewed studies suggesting that such programs are inherently more accurate than MRIP; the entire point of the NOAA Fisheries certification process is to assure that such programs are good enough to use for fisheries management.  The notion that the state-administered programs are more accurate is purely a construct of the Center, which prefers such programs simply because they make recreational landings appear to be smaller.

The Congressional Sportsmen’s Foundation tries to hide that naked truth behind a thin cloak of science, arguing that

“The justification for delaying the calibration is to provide time for NMFS to work with the states to determine the reason for the data discrepancies and to provide an opportunity to develop a more suitable calibration methodology based on the recommendations of a recent National Academy of Sciences report—Data and Management Strategies for Recreational Fisheries with Annual Catch Limits (2021).”

Such argument suggests that “the reason for the data discrepancies” is unknown, which is certainly untrue; as noted above, NMFS recognized that the differences in methodology between the state-administered programs and MRIP would lead to “data discrepancies” nearly five years ago.  It also suggests that the current calibration methodologies are somehow inconsistent with the National Academy of Sciences report.

But let’s look at what that report really says.  In the chapter titled “Optimizing Use of MRIP Data and Complimentary Data for In-season Management,” the report states that

“Since stock assessments rely on a long time series of consistently collected data, and many federally managed stocks straddle state and survey boundaries, intercalibration of surveys is essential whenever a single survey is insufficient to support all assessment and management needs.  Rigorous survey intercalibration requires temporal and special overlap between surveys.  The need for intercalibration and the consequences of using different, uncalibrated surveys for various aspects of assessment and management are evident where different surveys provide very different estimates of the same unknown quantity (in the same units) and where precision of surveys is perceived or known to differ.  [emphasis added]”

The report also notes that

“coordination is particularly critical in regions where survey methods may vary across states or specific fishery contexts, as well as when new survey programs are launched or modified.”

The Gulf recreational red snapper fishery certainly fits that description.

It would seem, then, that contrary to the Congressional Sportsmen’s Foundation’s suggestions, recreational red snapper data in the Gulf, where state-administered surveys and MRIP “provide very different estimates” of recreational red snapper landings, and where the “precision of surveys is perceived…to differ,” demands calibration of the state-collected data.  Delay in calibrating such data would appear to be directly the opposite of what the report recommends, which is that

Interstate Fisheries Commissions, States, NOAA Fisheries, and other members of MRIP Regional Implementation Teams should anticipate and take into account the need for intercalibration and continued survey development when new recreational fisheries surveys and survey methods are considered.  These needs should also be clearly communicated to anglers, fishery managers, and other stakeholders.

Although NMFS has “clearly communicated” the need for calibration of state-collected data since at least 2017, describing such need on multiple websites, and the Congressional Sportsman’s Foundation doesn’t deny

“that a calibration to ensure consistent currencies between states [although, given a strict reading of the Foundation’s press release, not between the states and MRIP] is necessary,”

the Foundation is still attempting to push such calibration off into the future, seemingly in the hope that a new red snapper stock assessment might render harvest reductions unnecessary.

Because, in the end, despite all of the efforts to swaddle its argument in a more attractive wrapper, the Congressional Sportsmen’s Foundation’s objections to calibrating the state-collected red snapper data, like the objections of the CCA and Center for Sportfishing Policy, are not about good science.  Rather, they are all about finding a way to let recreational fishermen to kill far more fish than good sense or good science would allow.

Multiple press releases, sent out by various entities, may make it appear that a diverse array of organizations are lining up to criticize federal red snapper management.  But in the end, what we really have is the Center for Sportfishing Policy playing the tune, and groups like the CCA and Congressional Sportsmen’s Foundation getting up to dance when the Center pulls on their strings.

No one who is actively involved in Gulf fishery management is fooled by the display.  Only the angling public is gulled, the very same angling public that such organizations pretend that they serve.

 

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