SOME GOOD NEWS FOR GULF RED SNAPPER

 

One week ago, the National Marine Fisheries Service issued regulations that should help end the chronic recreational overharvest of red snapper in the Gulf of Mexico.

The regulations address one of the biggest problems currently facing the red snapper stock:  The different methodologies used by NMFS and by the five Gulf Coast states to calculate annual private-boat recreational red snapper landings, which result in each data collection program coming up with different estimates of the red snapper catch.

NMFS depends on the Marine Recreational Information Program,often referred to by the acronym “MRIP,” which was adopted a few years ago to replace the badly flawed Marine Recreational Fishing Statistics Survey.  MRIP got generally good marks when it wasreviewed by a National Academy of Sciences panel a few years ago, but it hasone major flaw—collecting, analyzing, and reviewing MRIP data takes a longtime.  Preliminary data for each two-month “wave” isn’t available until about 45 days after the wave has ended, so preliminary data for Wave 3, May and June, isn’t available until about August 15^th, data for Wave 4, July and August, isn’t available until October 15^th, etc.

Final data for each fishing year doesn’t come out until mid-April.

That sort of delay makes the use of MRIP somewhat problematic when setting annual catch limits for the next fishing year.  When a fishery requires in-season quota management, which shuts down the season once recreational catch approaches the annual catch limit rather than setting a fixed closing date, the delays associated with MRIP data render such data all but useless.

That has proven to be the case in the private-boat recreational red snapper fishery in the Gulf of Mexico.

In an effort to improve the situation, NMFS has worked with the states to develop state-specific programs that supplement MRIP and provide more timely and, perhaps, more precise estimates of recreational fishing mortality.  

Some of those programs, such as Alabama’s Snapper Check and Mississippi’s Tales n’ Scales, are designed as a census intended to capture data from every private-boat red snapper angler each time they go fishing.  Others, including  Louisiana’s LACreel and Florida’s Gulf Reef Fish Survey, are surveys.  All four state programs have been certified by NMFS as appropriate adjuncts to MRIP.  Texas also tries to estimate its anglers’ red snapper landings, but uses an archaic, uncertified program of dubious precision that is not MRIP-certified.

NMFS bears the overall responsibility for managing red snapper in the Gulf of Mexico.  Pursuant to such authority, the Gulf of Mexico Fishery Management Council has adopted Amendment 50 A-F to the Fishery Management Plan for the Reef Fish Resources of the Gulf of Mexico,  which provides the five Gulf Coast states with a limited ability to set private-boat red snapper regulations for both state waters and the federal waters of each state’s shores, provided that such regulations constrain recreational catch to or below the recreational red snapper allocation assigned to each state by NMFS.

That’s where things begin to get tricky, because of the different surveys used to estimate recreational red snapper harvest.

NMFS uses MRIP to set the state allocations, and MRIP-based landings estimates are used in the stock assessments that determine the health of the Gulf’s red snapper stock.  But the five Gulf Coast states use their own data collection systems to determine when their anglers are approaching the state red snapper allocation, and the season needs to be closed.

That’s not a problem in Louisiana and Florida, where the state surveys generally concur with MRIP.  It also isn’t a problem in Texas, where NMFS has basically thrown up its hands and stopped trying to find any accord between MRIP and Texas’ aged recreational data program, and just blindly accepts the Texas numbers.  But there is a real issue when it comes to Mississippi’s and Alabama’s estimates, because such estimates are much lower than those generated by MRIP.  As a result, Mississippi’s and Alabama’s private-boat recreational red snapper seasons run far longer than they would if MRIP data was used.

The result is a substantial overharvest of such states’ annual allocations.  To get recreational landings under control, NMFS must make the state data compatible with MRIP.  As explained by NMFS,

“The Federal Marine Recreational Information Program (MRIP) based catch limits for Florida, Alabama, Mississippi, and Louisiana are not directly comparable to the landings estimates generated by each of those states, and the state estimates are not directly comparable to each other.  In other words, each state is estimating landings in a different ‘currency.’  Therefore, [NMFS] worked with the Gulf States to develop calibration ratios so that each state’s catch limit could be converted from the Federal ‘currency’ to the currency in which each state monitors landings.”

The regulations recently issued by NMFS adopt calibration factors for each state, which are intended to constrain each state’s landings to their NMFS-assigned allocations, despite the use of state data to estimate such landings.  

In the case of Florida and Louisiana, calibrating the MRIP-based federal allocations to state landings estimates will allow such states to increase their private-boat recreational red snapper landings by about 6%.  Predictably, neither the anglers in those states nor the various organizations that purport to represent them are complaining about such increases or arguing that they are inappropriate.

But when it comes to Alabama and Mississippi, things are very different.  Both states’ recreational data programs provided catch estimates far lower than those generated by MRIP.  Thus, when Alabama’s MRIP-based 1,145,026 pound allocation is converted into the “currency” used by the state’s Snapper Check program, the allocation is cut in half, to 558,200 pounds.  Something similar happens in Mississippi, where a 154,568 pound allocation based on federal data is converted into a Tails n' Scales-compatible 59,354 pounds.

Unlike fishermen in Florida and Louisiana (and in Texas, where state data is the only data available), anglers in Alabama and Mississippi aren’t happy with the calibration process, and are doing their best to oppose their resulting 2023 quotas.

The result is a cornucopia of hypocrisy, vitriol, and disinformation.

For many years, federal data, now provided by MRIP, has been incorporated into stock assessments, where higher levels of recreational landings and increased recreationakl catch per unit of effort suggest increased red snapper abundance.   Federal data is also used to set state allocations, including the 1,122,662 pounds of red snapper allocated to Alabama’s anglers in 2022.  Anglers were perfectly happy when the higher MRIP estimates were used for such purposes. 

In another Gulf fishery, red grouper, MRIP data was recently used to shift the allocation from 76% commercial/24% recreational to 59.3% commercial/40.7% recreational—a substantial change—and anglers were just fine with that, too.  They even suggested that such data could be used to change the allocation of other Gulf species.

But when it came to estimating the recreational red snapper landings caught by Alabama and Mississippi, the same anglers—along with the organizations which purport to represent them—suddenly decided that MRIP data was no good, and that the lower state estimates of red snapper landings, which allowed anglers to take home more fish, was the right information to use.

Thus, it appeared that "good data", at least in the recreational fishermen’s eyes, was whatever data allowed them to kill more snapper, grouper, or anything else.

Organizations associated with the recreational fishing industry have repeatedly attacked the calibration effort.  They seek to maintain the current level of red snapper landings, and as a part of that process, to convince anglers that the federal data was badly flawed.  

Last summer, a letter signed by the Center for Sportfishing Policy and four member organizations, sent to the Southeast Regional Office, argued against calibration by saying, in part, that

“we are disappointed with the lack of progress by the Gulf MRIP Transition Team in understanding the differences between MRIP and state data collection programs, the apparent inability of the state programs to be used in the ongoing red snapper research track assessment, and in calibrating the state data to an MRIP currency without first having the basic understanding of the vast discrepancies caused by MRIP.  As such, we urge NOAA Fisheries to refrain from requiring any calibration until those differences are understood and a more appropriate calibration methodology is developed, if necessary, while also moving forward with any new harvest level increases across sectors.”

It's a remarkable bit of doubletalk, since (a) the Transition Team does understand the differences between MRIP and state data collection programs; such differences are what calibration is all about, (b) the reason state data can’t be used in the stock assessment is because it isn’t calibrated and thus isn't compatible with MRIP or the data from other Gulf states, (c) it fails to explain why the “vast discrepancies” between MRIP and state data are “caused” by MRIP and not by inconsistencies in the state programs, and finally—and here we get to the heart of the matter—(d) it calls for delaying calibration, but for moving forward with any increases in the harvest level.

It's a clear ploy intended to keep recreational red snapper landings as high as possible for as long as possible.  It's also dismayingly typical of the recreational rhetoric throughout the red snapper debate.

Opposition to calibration isn’t limited to the angling industry and the anglers' rights crowd.  Politicians are always sensitive to public opinion and, given that Mississippi fishermen are unhappy with how the calibration process is working out for them, it's not surprising that Senator Roger Wicker (R-MS) has jumped aboard the no-calibration bandwagon, issuing a press release saying, in part, that

“NOAA’s flawed rule is intended to prevent overfishing by modifying each state’s annual catch limits (ACLs) for red snapper.  This new formula will require calibrating Mississippi’s high quality ‘Tales n’ Scales’ data, which records accurate information for more than 95% of Mississippi’s annual red snapper catch, to the low-quality Federal Marine Recreational Information Program (MRIP) data.

“The new calibration required by the rule will reduce Mississippi’s red snapper quota by 60 percent in 2023, meaning private anglers could reach their yearly quota in as little as three weeks…”

Is the calibration approach chosen by NMFS really that bad?

NMFS doesn’t think so.  In the narrative accompanying its recent regulation, it states,

“The federal surveys have been heavily tested, scrutinized, and reviewed, and NMFS remains committed to continue improving both state and federal survey methods, all of which are subject to sampling and non-sampling errors (measurement, coverage, and non-response).  MRIP uses standardized designs across states, which ensures comparability of estimates.  Conversely, due to the differing designs by the Gulf States, it is not possible to directly compare the estimates derived from the state surveys to each other or to the estimates produced by MRIP…”

As to the claims that the Alabama and Mississippi surveys are “better,” NMFS advises that

“It is difficult to know which surveys provide the best estimates of catch.  Different statistical sampling designs can produce different estimates due to variations in sampling frames and non-sampling error such as coverage error, nonresponse error, and measurement error.  It is not unusual for established surveys to produce very different estimates for the same population parameter.”

In that regard, it may be significant that the three surveys that seek to sample red snapper anglers—MRIP, LACreel, and Florida’s Gulf Reef Fish Survey—tend to yield similar results, while the two that seek to conduct a census of all recreational red snapper fishermen—Tales n’ Scales and Snapper Check—yield results very different from those produced by MRIP, while having very substantial, and not too different, calibration ratios of 0.3840  and 0.4875, respectively.

Such result might well stem, at least in part, from anglers who fail to comply with the Mississippi and Alabama programs.  Only about 70% of Mississippi’s red snapper anglers are believed to comply with the Tales n’ Scales requirements; in the case of Alabama’s Snapper Check, the compliance rate falls to a dismal 30%.  With respect to both programs, it has also been noted that

“The self-reporting of red snapper trips and catch may be susceptible to measurement errors if permit holders are either unaware of the mandatory reporting requirements or aware and choose to deliberately try to promote a given outcome.  The pairing of the mandatory reporting with a dockside sampling survey allows for direct measurements of differences between permit holder reports of landed fish and observations of landed fish made by trained dockside survey interviewers…”

It is possible that Alabama and Mississippi anglers are intentionally providing inaccurate reports in an effort to influence future management measures.  While dockside interviews are intended to capture and account for such bad information, it isn't very difficult for unethical anglers to get around such supposed safeguard, merely by submitting their false reports only after they were certain that no interviewers were on hand.  

Thanks to the new regulations, calibration of the Gulf States’ recreational red snapper data will finally take place in 2023, provided that such regulations aren’t blocked by federal legislation or by litigation.  Either could still occur, although the likelihood of a divided 118^th Congress passing such legislation is not very high, and the probability of a federal court invalidating the regulations probably isn't too much higher.

After being involved with red snapper issues for far too many years, and having known a few of the people who are fighting to keep landings high, I have little doubt that the private boat fleet will continue their fight to over-exploit the red snapper resource.

Still, with the issuance of its most recent regulations, it looks like NMFS may finally be taking action that will address the chronic recreational overharvest of Gulf of Mexico red snapper.  That, in itself, is good news.