When the Modernizing Recreational
Fisheries Management Act (Act) was passed in 2018, it
included the provision that
The Secretary [of
Commerce] shall, within 90 days after the date of the enactment of the
Modernizing Recreational Fisheries Management Act of 2018, enter into an
agreement with the National Academy of Sciences to evaluate, in the form of a
report, how the design of the Marine Recreational Information Program, for the
purposes of stock assessment and the determination of stock management
reference points, can be improved to better meet the needs of in-season
management of annual catch limits…and what actions the Secretary, [regional
fishery management] Councils, and States could take to improve the accuracy and
timeliness of data collection and analysis to improve the Marine Recreational
Information Program and facilitate in-season management; and within 6 months
after releasing [such] report…submit to Congress recommendations regarding
changes to be made to the Marine Recreational Information Program to make the
program better meet the needs of in-season management of catch limits and other
requirements under such section; and alternative management approaches that
could be applied to recreational fisheries for which the Marine Recreational
Information Program is not meeting the needs of in-season management of annual
catch limits… [internal formatting omitted]
The National Academy
of Sciences issued the report called for in the Act, Data and Management
Strategies for Recreational Fisheries with Annual Catch Limits (NAS
Report), in 2021. In February 2023, the National Marine Fisheries Service
(NMFS) released the required Report to Congress,
in which the agency addressed the NAS Report’s recommendations.
There were twelve
such recommendations, which could be grouped into five broad categories: 1)
Improving the timeliness and precision of MRIP; 2) Calibrating the data
provided by the Marine Recreational Information Program (MRIP) with that
provided by ancillary surveys; 3) Considering provisions that would allow
fishery managers to roll over the uncaught portion of the recreational catch
limit into succeeding years; 4) Reviewing the National Standard 1 guidelines;
and 5) Engaging recreational stakeholders to discuss the concept of “optimum
yield.”
Despite such
recommendations, the NAS Report and Report to Congress won’t necessarily have a
substantial impact on MRIP, since the Act called for both to focus on
“in-season management of annual catch limits,” and as the Report to Congress
observed, “In-season management is not required for most fisheries nationwide
due to broad regional diversity in management needs.” At the same time, many of
the recommendations are applicable to any recreational fishery, and not merely
to those requiring in-season management, and so may be applied more broadly.
Improving MRIP
That is particularly
true of recommendations that would improve the timeliness and accuracy of MRIP
estimates. However, the NAS Report made it clear that, while MRIP provides
“critically important” data to fishery managers, and offered suggestions for
improving the quality of such data, there were practical limitations to such
improvements.
Currently, MRIP provides
catch and landings estimates broken down into two-month “waves.” Preliminary
data from each wave is customarily made available about forty-five days after
the wave’s end. The NAS Report notes that MRIP could provide data of equivalent
quality on a monthly basis, but that it would require “an approximate doubling
of the resources…allocated to its survey programs” in order to do so.
The NAS Report also
found that, if provided with additional resources, MRIP could provide
preliminary estimates for each two-month wave about two weeks sooner than it
does today, but that doing so “would put additional stress on existing MRIP
staff and systems,” and noted that “for purposes of in-season management, the
benefits of a modest advance in the release of preliminary estimates for
bimonthly waves would not be likely to justify the costs of accelerating the
data processing and estimation phases of each bimonthly cycle.”
NMFS’ responses in
the Report to Congress were in general accord with the NAS Report’s findings, although
the agency suggested that such report might have overestimated the cost of
reporting recreational data on a monthly, rather than bimonthly, basis. The
Atlantic States Marine Fisheries Commission, which was also invited to comment
on the NAS Report, proposed reducing the costs of monthly data reports by
limiting such reports to the months of May through October, when angling
activity was greatest, and relying on bimonthly reporting for the rest of the
year.
Regardless of the
improvements that might be made to MRIP itself, the NAS Report highlights the
benefits of supplementing MRIP with data from other sources. One suggestion,
that has parallels in the management of some game birds and mammals pursued by
hunters, is that managers issue tags which must be affixed to harvested fish;
another is that anglers participating in NMFS-managed fisheries obtain permits
that would make it easier to identify and survey such anglers.
While the former
approach may appear attractive, the Report to Congress made it clear that it
was disfavored by NMFS, which stated that “Harvest tags have been widely
considered for in-season management, but only attempted at the Federal level
for various Atlantic [highly migratory species] and at the state level in
Louisiana. In those instances, they were unsuccessful due to costs,
underreporting, and noncompliance.”
Requiring permits for
anglers fishing in federal waters received a slightly warmer response, with
NMFS noting, “A variety of license endorsements have been successful in some
specific cases (e.g., Atlantic [highly migratory species], and Louisiana’s LA
Creel), but may be difficult to implement at large scales due to high potential
for bias and burden on state and regional staff. [references omitted]” NMFS
expressed a willingness to consider such permits, on a case-by-case basis, if
recommended by a regional fishery management council.
The agency was much
more receptive to the recommendation that MRIP be supplemented with surveys
conducted by states, regional fishery management commissions, or other
entities. The Report to Congress noted that “NMFS and partners indicate that
this recommendation is being implemented in the Atlantic, Gulf, and West Coast
regions…NMFS further felt that management needs of regional or Council-managed
species would best be met by ensuring new supplemental surveys truly supplement
MRIP, meaning that they are designed to be statistically comparable and
compatible with existing MRIP estimates…”
Calibrating Data
Such comment leads
directly to what may be the most controversial issue
addressed in the NAS Report: The need to calibrate supplemental surveys to make
them compatible with MRIP.
It has been a hot
topic in the Gulf of Mexico red snapper fishery, which is one of the few
recreational fisheries where in-season management comes into play. NMFS has
agreed to give each state a share of the overall recreational harvest, along
with some latitude to
adopt its own red snapper season, size limit, and bag limit, with the
understanding that a state’s season will close once its recreational quota is
landed. Each state has developed its own recreational data collection program
to track red snapper landings.
The problem is that
each of the state data programs uses a different methodology than that used by
MRIP or any of the other states, so none of the state catch estimates are
directly comparable to any other set of data. That doesn’t matter for Florida
or Louisiana, as their estimates are similar to MRIP’s, but it is causing some
trouble in Alabama and Mississippi, where state estimates are far lower than
those made by MRIP, causing anglers to overfish such states’ quotas. NMFS has calibrated Alabama
and Mississippi’s estimates to be compatible with MRIP, but because that has
led to smaller state quotas in 2023, anglers in those states are opposing NMFS’ efforts.
Such issues are
reflected in the NAS Report’s comment, “Compared with MRIP surveys, alternative
or supplemental surveys have been shown to provide different estimates for
recreational catches for the same fishery (stock and area). Differences between
estimates can be moderate, or quite substantial.” They are also reflected in
the comment that “Public perceptions of differences between MRIP and
alternative surveys in methodology, final catch estimates, and the precision of
the estimates are a source of consternation among anglers, fisheries managers,
and other stakeholders.”
In response to such
comments, the Report to Congress states that, as one might expect, NMFS will
continue to work with its fishery management partners to calibrate MRIP and any
supplemental surveys. Where the estimates produced by MRIP and such surveys are
“significantly” different, NMFS intends, “subject to availability of funds,” to
investigate the cause of such differences, “with particular emphasis on
determining the nature and extent of non-sampling error;” make changes that
address the source of such non-sampling error; recommend and provide technical
support for its fishery management partners’ research into the sources of error
in supplemental surveys; and continue to educate such partners and stakeholders
with respect to “information about sources of survey error and the basis and
need for calibration.”
The importance of the
latter step cannot be underestimated, for even if all the sources of error in
the surveys are addressed, without adequate public outreach and education,
stakeholders will still be vulnerable to various parties’ efforts to undercut
faith in the data collection and calibration process, in order to achieve
political goals.
The NAS Report and
the Report to Congress address many other technical issues related to
calibrating catch estimates and improving the accuracy and timeliness of MRIP,
at a scale too fine to be discussed in further detail. Fortunately, the other
items included in the reports can be summarized more easily.
Improving Recreational Management
The possibility of
rolling over the uncaught portion of an annual catch limit, in whole or in
part, so that it may be landed in a subsequent season, is a question that
sometimes arises in regional fishery management council deliberations. The NAS
Report notes that such rollovers “could allow the recreational sector to
achieve a high level of [annual catch limit] utilization in a way that would be
both practical and cost-effective while reducing risks of extreme overages and
subsequent payback.”
While that comment
isn’t wrong, such rollovers may not be appropriate in every circumstance,
particularly in fisheries for species where achieving “a high level of [annual
catch limit] utilization” is not necessarily anglers’ primary goal. NMFS, in
its Report to Congress, states that it has developed guidance relating to such
rollover provisions, and further states, “The implementation of carry-over
provisions must be done on a fishery-by-fishery basis, and regionally, NMFS and
partners indicated the use of carry-over provisions have only been successful
in specific cases.”
Thus, while regional
fishery management councils may consider such rollovers when circumstances
warrant, they probably won’t appear in too many management plans.
The NAS Report also
recommended that “NMFS should review the National Standard 1 guidelines to
assure that agency guidance with respect to recreational accountability
measures aligns with the timeliness and precision of harvest estimates produced
by MRIP.” NMFS replied that it has already done so, stating in its Report to
Congress that “NMFS has reviewed the National Standard 1 guidelines and
believes that they provide the flexibility to develop [accountability measures]
that are appropriate, given the precision and timing of NMFS estimates.”
NMFS goes on to state
that it supports the regional fishery management council’s efforts to craft
appropriate accountability measures, and that it believes that the current
National Standard 1 guidelines provide sufficient flexibility to allow such
councils to do so.
What the NAS Report
didn’t recommend, but perhaps should have, is that NMFS actually follow the
National Standard 1 guidelines that it develops. Very few of the annual
specifications developed by the regional fishery management councils include
the annual catch targets recommended in the guidelines to account for
management uncertainty, much of which is directly related to “the timeliness
and precision of harvest estimates produced by MRIP” specifically referenced in
the NAS Report.
Finally, the Report
to Congress responds to a NAS Report recommendation that “NMFS and the Councils
should develop a process for engaging recreational fisheries stakeholders in a
more in-depth discussion of optimum yield and how it can be used to identify
and prioritize management objectives that are better suited to the cultural,
economic, and conservation goals of the angling community.” Such recommendation
raises an issue too often ignored by
fisheries managers.
However, the NAS
Report seemed to conflate the concept of setting an optimum yield with the
precise monitoring of recreational catch limits, something that the Report to
Congress noted was “not directly related to optimum yield, but raise[s]
additional, separate considerations.” More relevant to the optimum yield issue,
NMFS provided a “Proposed Course of Action,” that “NMFS continued the
discussion of optimum yield at the National Saltwater Recreational Fisheries
Summit in March 2022, and will develop further courses of action related to
this recommendation, as needed.”
In view of that
response, it’s worthwhile to note how the final report from the
Summit described such discussion of optimum yield. It describes
how Mike Leonard, Vice President of Government Affairs for the American
Sportfishing Association, observed that federal fisheries law permits setting
annual catch limits below maximum sustainable yield when other social and
economic factors are considered, but that
this has not been put
into practice by most [regional fishery management] councils. A review and
analysis of the use of [optimum yield] in U.S. fisheries management found that
current [annual catch limit] and [optimum yield] specifications processes
rarely account for social and economic factors, or ecosystem considerations,
and if they do, it is on an ad-hoc, species-specific basis.
Catch and release is
being viewed as underutilizing the resource just because they are catching
below the [annual catch limits]. This may drive a desire to transfer allocation
[from the recreational to the commercial sector].
It also described how
recreational stakeholders present at the Summit seconded Mr. Leonard’s
sentiments, talking about the “intrinsic value” of recreational fishing that
can’t be represented merely in economic terms, or in pounds of dead fish; one
group of anglers highlighted the “economic value of fish left in the water, understanding
what satisfaction means to different stakeholders,” and “what the values are
for a particular fishery.”
Yet, when regional
fishery management councils consider optimum yield, to the extent that they
consider it at all, their emphasis is consistently on just the “yield,” the
number of fish that may be killed and retained, rather than on the “optimum.”
Managing a primarily recreational stock for abundance and its recreational
value remains an alien concept; when the Mid-Atlantic Fishery Management Council
last amended its management
plan for the bluefish fishery, a fishery where anglers are
responsible for about 85% of the landings and release close to two-thirds of
the bluefish that they catch, it eschewed any meaningful analysis of optimum
yield, and instead included a provision that would transfer any “unused,”
meaning “unharvested,” recreational quota to the commercial sector.
Thus, this issue,
too, deserves NMFS’ attention.
In the end, the NAS
Report, and NMFS’ Report to Congress, focused primarily on recreational data
issues, and such issues are unquestionably important and in need of attention.
But NMFS should not ignore the management issues; they are also important, and
need attention, too.
-----
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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