Most
anglers probably don’t realize that the National Marine Fisheries Service
(NMFS) has a policy that addresses recreational fisheries management (Recreational
Policy). Most anglers have probably never even considered the issue.
Yet it’s an issue that deserves some thought for, as the
introduction to the Recreational Policy notes, “The purpose of this policy is
to provide guidance for Agency consideration in its deliberations pertaining to
the development and maintenance of enduring and sustainable high quality
saltwater recreational fisheries. This policy identifies goals and guiding
principles to be integrated into NMFS’ planning, budgeting, decision-making,
and activities, and includes examples of implementation concepts and strategies
supported by NMFS.”
The existing Recreational Policy, which was adopted in 2015, is
an outgrowth of discussions held at the 2014 National Saltwater Recreational
Fishing Summit, an event jointly sponsored by NMFS and the Atlantic States Marine
Fisheries Commission. Those discussions, in turn, were informed by a document
titled “A Vision for Managing America’s Saltwater Recreational Fisheries” (Vision
Statement), which was created by a panel assembled by a coalition of sportfishing
industry and “anglers’ rights” organizations, and issued under the aegis of the
Theodore Roosevelt Conservation Partnership a month before the 2014 Summit
began.
The Vision Statement’s very first recommendation was that NMFS
adopt a recreational fishing policy, so it wasn’t surprising that NMFS did so
just one year after the 2014 Summit was held.
The Recreational Policy is built “around six overarching themes:
1) Support ecosystem conservation and management, 2) Promote public access to
quality recreational fishing opportunities, 3) Coordinate with state and
federal management entities, 4) Advance innovative solutions to evolving
science, management, and environmental challenges, 5) Provide scientifically
sound and trusted social, cultural, economic, and ecological information, and
6) Communicate and engage with the recreational fishing public.
While those broad themes generally coincide with the concerns of
the recreational fishing public, many of the details were clearly driven by the coalition of recreational
fishing organizations, centered on or around the Gulf of Mexico,
that created the Vision Statement and engaged in an intense lobbying effort
that urged NMFS to include the Vision Statement’s priorities in its new
Recreational Policy.
Now, NMFS is reaching out to saltwater anglers and to the
larger recreational fishing community, asking them to suggest needed changes to
the Recreational Policy. As the agency explains, “Developed with extensive
public input, the 2015 Policy reflects the priorities of the day…NOAA
recognizes the need to adapt with a changing climate and the evolving needs of
recreational fisheries and anglers. With the perspectives shared during the 2022
National Saltwater Recreational Fisheries Summit, NOAA Fisheries requests your
input on revising the Policy…”
Given the conversations that took place at the 2022 National
Saltwater Recreational Fisheries Summit, that’s a welcome invitation, and one
that saltwater anglers ought to take advantage of.
The 2022 Summit may have been, in terms of diverse angler input,
the most impressive summit yet. While the 2014 Summit was largely orchestrated
by a handful of organizations seeking to promote the Vision Statement’s
priorities, and the 2018 National Saltwater Recreational Fishing Summit,
although far more freewheeling, still saw the same organizations try to control
the debate, the 2022 Summit was the first in which the voices of a broad array
of anglers, representing every corner of the coast and largely unaffiliated
with the big national advocacy groups, achieved something like parity with
those of the Gulf-centered industry organizations.
And those anglers had some interesting things to say, which
suggested that the Recreational Policy was, indeed, in need of revision. While
the 2014 Summit was all about promoting the Vision Statement, and the 2018
Summit saw, as the resulting report noted, “participants [discuss] the
key obstacles impeding increased opportunity and stability in recreational
fisheries,” the 2022 Summit, with its theme “Recreational Fisheries in a Time
of Change,” was focused on the future, and anglers thoughts of what such future
should be.
NMFS has released the “National Saltwater Recreational Fisheries Summit Report 2022,” which
describes the topics addressed and the themes that emerged. It describes a few
“cross-cutting themes” that anglers returned to throughout the two days of the
2022 Summit. In describing such themes, the report observed that
There is broad recognition that
climate change is affecting traditional angling opportunities, and in order to
effectively adapt, more attention is needed to understand and regularly
incorporate human dimension considerations into decision making. This ranges
from assessing the intrinsic values of fishing to better understand [optimum
yield], to considering cultural practices associated with non-commercial
fisheries in the Pacific Islands…
Throughout the sessions, there were
calls for more precise and timely fishery-dependent and independent data that
accurately represent the fishery. These are not new requests; however, some of
the solutions offered represent a shift in thinking away from a heavy reliance
on fishery-independent data, and towards new and more diverse data
streams…However, the path to collecting and incorporating new data streams,
including mechanisms to assure their scientific validity, may require shifts in
federal and state management, and partnerships with stakeholders.
…Finally, participants voiced
support for recent recommendations from the 2021 National Academies of
Sciences, Engineering, and Medicine (NASEM) review of the Marine Recreational
Information Program (MRIP), and the role of regional MRIP implementation teams
in addressing those recommendations.
Management flexibility was viewed as
a double-edged sword by various stakeholders in the recreational fishing
community, where some were optimistic about its potential, and others expressed
apprehension. There was traction around the desire of anglers to maintain
fishing opportunities (i.e., the experience) over catching certain amounts of
target species…
…Particularly during this time of
increased offshore development in wind energy and aquaculture, the recreational
fishing community is being asked and urged to be more involved in scoping,
review, mitigation, and compensation processes. This is in addition to specific
state and regional fisheries meetings, and broader regional or coastwide
conversations around climate change/scenario planning and [Fishery Ecosystem
Plans]. Stakeholders are participating in these forums, but questions remain
around how to deepen the reach to the angling community, and how to increase
the diversity of those around the table…
None of those issues is adequately addressed in the current
Recreational Policy.
The most notable omission from the existing Recreational Policy
is the lack of any consideration of what the 2022 Report calls “the intrinsic
value of fishing,” and “maintain[ing] fishing opportunities…over catching
certain amounts of target species.” Instead, the Recreational Policy emphasizes
harvest, focusing on things such as artificial reefs that aggregate fish into
easily exploitable concentrations, “aquaculture tools and technologies” (i.e.,
hatcheries that lessen the need for sustainable management of wild fish
stocks), allocating fish to the recreational sector, “longer fishing seasons,”
and “increased allowable catch levels.”
A revision to the Recreational Policy that recognizes the purely
recreational aspects of angling, and the value of an abundance of fish in the
ocean, apart from any harvest considerations, seems to be badly needed.
The quality of recreational data has been among anglers’
perennial concerns. While the Recreational Policy includes aspirational
language about “improving fisheries science and management,” “developing and
supporting cutting-edge scientific tools,” and “collecting recreational catch
and effort…data that support transparent and participatory management and
conservation of saltwater recreational fisheries,” it never addresses the need
to use available data appropriately, with regard for its inherent limitations.
The precision of Marine Recreational Information Program data is
highly dependent on the number of anglers surveyed; when the data
reflect angler activity in a limited geographical area or over only a short
period of time, such precision is badly degraded. Yet fishery managers continue
to craft management measures based on a single state’s data, often further
narrowed by sector or two-month wave, even thought the scientific validity of
such data is questionable.
Amending the Recreational Policy to discourage the use of such
unreliable data would lead to more effective regulations that bolster anglers’
faith in the management process, and better align with the recommendations made
by the National Academies.
Finally, the Recreational Policy should be changed to provide
for far greater outreach, which encourages a more diverse set of anglers to
engage in the management process. While such policy already talks about
“empowering” anglers to engage with fishery managers, such engagement is not
actively encouraged, nor does it typically occur. Instead, a small group of affiliated
organizations purport to speak for the entire angling community, and too often
promote management measures that promote their short-term concerns instead of
anglers’ long-term interests.
Fortunately, NMFS is now giving anglers an opportunity to speak
for themselves, by providing them the opportunity to suggest revisions to the
Recreational Policy.
From now through December 31, 2022, anglers may submit their comments on the Recreational Policy through the
NMFS website. The agency has also scheduled three webinars, during which
comments will be accepted; although two such webinars have already occurred, a third will be held on November 22, 2022, from 6:00 to
7:00 p.m. Eastern time. NMFS will also be making a number of live presentations, usually in conjunction with regional
fishery management council meetings, between now and December 1, 2022.
Thus, anglers will have ample opportunity to provide NMFS with
comments that reflect their concerns and to help amend the Recreational Policy
to better address recreational fishermen’s wants and needs.
It’s an opportunity that shouldn’t be missed.
-----
This
essay first appeared in “From the Waterfront,” the blog of the Marine Fish
Conservation Network, which can be found at http://conservefish.org/blog/
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