If you pay any attention to fishery management issues (and
if you’re reading this blog, it’s pretty clear that you do), you know that one
of the most contentious issues, which comes up year after year, is the estimate
of recreational landings.
Commercial landings are pretty easy to measure, because
commercial fishermen, as well as the processors and packing houses that
purchase their products, are generally required to report such landings on a
timely basis. To be sure, there are
holes in the process. Some fail to
report, some report late and some fish are sold outside of formal channels of
distribution. Illegal landings and fish
sales occur. But on the whole,
commercial landings are reported and recorded in something not too far from
real time, and management based on those reports is pretty reliable.
But when it comes to recreational landings, it’s not that
easy. There are thousands of commercial
fishermen on the coast; there are millions of anglers. Commercial fishermen tend to land a lot of
fish at the same time, and do so at fish buyers’ docks and in other,
predictable locations. Anglers land
their fish in ones and twos—sometimes in dozens—along every part of the coast;
some are caught from the banks of tidal creeks in the dark of night, others are
landed at busy marinas and still others at private docks in the anglers’ backyards.
There are few real-time reporting requirements for
recreational fishermen, but at least one that does exist—recreational
reporting of bluefin tuna—is typically ignored. And it is physically and economically
impossible to physically interview every angler at the end of every trip.
As a result, fisheries managers have had to devise ways to
estimate recreational landings, based on
creel surveys that provide data on catch frequency and composition,
coupled with telephone surveys that provide a window on angler effort. Such effort, called the Marine Recreational
Fisheries Statistics Survey, or “MRFSS,” represented a supposedly statistically
valid means to obtain such landings data.
Like all estimates derived from surveys, those derived from
MRFSS included some inherent level of error.
Such error was fairly insignificant when the survey was used to measure then
overall harvest of a commonly-encountered species along the entire coast over
the course of a year. However, when
managers used MRFSS to gauge the landings of species that is not caught very
often, and/or tried to limit the scope of the survey by state, time period or recreational
sector (e.g., shore angler, party boat angler, etc.), the level of error
increased significantly, sometimes rendering the estimate practically unusable.
And that was a problem, because as managers began to rebuild
overfished stocks, and rebuilding plans required strict regulation of all
fishermen, including anglers, MRFSS’ inherent errors became both a practical
and a political problem.
MRFSS became the favorite whipping boy of any member of the
angling community who wanted to kill a few too many fish, but was prevented
from doing so by regulations based, in part, on the MRFSS numbers. The recreational fishing industry, which
generally saw rebuilding programs as a threat to current profits, were
particularly vehement. Comments made by the Save the
Summer Flounder Fishery Fund were typical:
“Despite the degree of economic downturn in the USA, the
unprecedented amount of inclement weather this past summer, and by almost all
accounts, a general downturn in angler participation, the Marine Recreational
Fisheries Statistics Survey (MRFSS) has determined that increasingly significant
landings of Summer Flounder have occurred!
The MRFSS data also shows effort and participation numbers at odds with
first hand industry observations!
“This information is completely contrary to evidence gathered
by marine fisheries businesses up and down the coast.”
Such comments were used by organizations
intent on undermining the conservation and rebuilding provisions of the Magnuson-Stevens Fishery
Conservation and Management Act to alienate anglers from the management
process.
And in truth, MRFSS estimates were somewhat flawed due to
biases that had become part of the system, a fact confirmed by a
National Academy of Sciences review.
So the National Marine Fisheries Service set out to overhaul
the process of estimating recreational harvest, with the eventual goal of
replacing MRFSS with a new
methodology called the Marine Recreational Information Program (MRIP).
At this point, MRIP remains a work in progress. That is mainly because NMFS
is being very careful to get it right, and avoid making the sort of
mistakes that it made with MRFSS. MRIP is being phased in over a period of years, and NMFS
has asked that it be reviewed by the National Research Council before it is
fully implemented to detect any problems before they infect the data.
Thus, both fisheries managers and anglers on every coast of
the United States were getting close to enjoying the benefits of a robust catch
estimate system—until the red snapper
anglers down in the Gulf of Mexico intervened.
The intervention didn’t take place because the red snapper
anglers had a problem with MRIP,
which is actually leading to higher estimates of acceptable biological catch
and maximum sustainable yield (although they have encouraged states to create their own
surveys to challenge NMFS’ numbers).
Instead, they convinced Alabama
Republican Richard Shelby, who sits on the Senate Appropriations Committee,
to insert language into the Omnibus
budget bill that would hold money for
MRIP’s full implementation hostage, not
permitting its expenditure until the red
snapper anglers get a stock assessment that they approve.
Now, it’s not as if red snapper have not already been
assessed.
The Gulf of Mexico Fishery
Management Council conducted a
benchmark stock assessment in 2013, and issued an 1,100 page report
summarizing its findings.
The Data Workshop, which provided the information on which
such assessment was based, included a 30-person panel composed of individuals
from federal and state fishery management bodies, as well as the private sector,
and considered a trove of information that included 33 papers produced solely
for the workshop, as well as 50 other reference papers that explored aspects of
the Gulf’s red snapper population.
The conclusions reached in the stock assessment were peer reviewed
by a panel of independent experts, and updated
in 2015.
The stock assessment clearly represents the best available
science. However, Gulf red snapper anglers don’t want an assessment that represents the
best available science, they want an
assessment that lets them kill more fish.
Thus, they prevailed upon Senator Shelby to pass a law
requiring NMFS to conduct an assessment that places emphasis on artificial
reefs and oil rigs where red snapper congregate, and thus is likely to edge
population estimates—and harvests—substantially upward, whether such estimates
are scientifically valid or not.
And want to hold up MRIP implementation until they get their
way.
The saddest thing may be that they’re proud of what they’re
doing. In a press release issued by the
Coastal Conservation Association on December 16, Pat Murray, CCA’s
President, is quoted as saying
“It is impossible to get the red snapper fishery back on a
course that makes sense for the angling public under the current broken federal
management system…We are fortunate to have Sen. Shelby not only recognize the
systemic problems, but begin fixing this frustrating situation.”
Murray wasn’t alone in his sentiments. Senator Shelby’s actions were also praised by
the American
Sportfishing Association and the Center
for Coastal Conservation, among other organizations.
In endorsing such outrageous disruption of needed federal
recreational data improvements, in the name of solving a single, parochial
problem, they have all essentially flipped the bird and issued a big “Screw
You!” to anglers in the rest of the nation who fish for cod, haddock, winter
flounder, summer flounder, black sea bass, bluefish, weakfish, scup, striped
bass, red drum, speckled trout, king mackerel or any other species that is
dependent upon good recreational harvest estimates for its management.
Shortly after I started writing this blog two years ago, I
posted a piece called “Red
Snapper Anglers Embarrass Us All,” which remains the single most popular
essay that I have written; each week, a few folks still read it. It describes how the Gulf’s red snapper
anglers, and their selfish political machinations, cast discredit on all of
America’s recreational fishermen.
But that piece is now a little passé.
With this latest effort to deny the rest of America’s
anglers the benefit of accurate data estimates and the sort of good fisheries
management that such estimates bring, the Gulf red snapper anglers, or at least its self-centered core and the organizations which represent them, who are
willing to bring down the federal fisheries management system just so they can
score some sort of Pyrrhic victory against NMFS and the Gulf of Mexico Council,
have now demonstrated themselves to be not just an embarrassment, but an actual
threat, to responsible anglers and angler-related businesses on every coast.
It is disappointing to see how far once-reasonable folks have fallen.
But today, that’s just the way things are.
"Best Available Data" doesn't ensure one is using the "BEST DATA" in the decision making process.
ReplyDeleteIt could be totally irrelevant and stll be labelled "best available data".
Which is a good argument against Shelby blocking efforts to make the process better.
ReplyDeleteAlthough the most interesting thing is that the people who attack the data rarely have better data to offer in its place