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…”
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.
“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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