Thursday, October 5, 2017


Let’s start out by agreeing on one simple truth:  Fishing isn’t much fun without fish.

To have a viable sport fishery, and a viable sport fishing industry, there must be enough fish around to keep anglers interested.  The fish don’t necessarily have to be biting.  One of the things that keeps angling interesting is figuring out how to convince reluctant fish, whether they’re striped bass or bluefin or mangrove snapper, to actually ingest what we offer.  But the fish have to be there, and if some of those fish are big ones, that makes things even better.

The self-appointed leadership of the saltwater fishing community freely acknowledged that fact in their 2014 manifesto, A Vision for Managing America’s Saltwater Recreational Fisheries, in which they noted that

“federal fisheries managers set catch limits for recreational and commercial fishing at or near maximum sustainable yield.  While this may be an ideal management strategy for commercial fishing, where harvesting the maximum biomass is desired, it is not an effective management tool for saltwater recreational fishing.  Recreational anglers are more focused on abundance and size, structure of the fisheries, and opportunities to get out on the water.”
That sounds right and good.  The organizations who contributed to the “Vision” document—the American Sportfishing Association, Coastal Conservation Association, Center for Sportfishing Policy and the rest—can certainly talk the “abundance” talk.

But when it comes to walking the "abundance" walk, the story is starkly different.

Over the past five or six years—at least since the founding of the Center for Sportfishing Policy (formerly, the Center for Coastal Conservation)—it is hard to recall a single instance in which the various manufacturing and anglers’ rights organizations behind the “Vision” report came together to seek greater abundance of a federally-managed fish species.

Instead, they have repeatedly staked out positions and praised federal actions that, at best, would maintain harvest near the very level they had condemned—maximum sustainable yield—and at worst would increase harvest beyond that threshold of sustainability, and lead to overfishing and the delayed recovery of overfished stocks.

The most blatant example of that is the various organizations’ reaction to the Commerce Department’s now-infamous decision to reopen the private-boat recreational red snapper season in the Gulf of Mexico last summer, even though the National Marine Fisheries service admitted that

“The stock is still overfished…if employed for a short period of time, this approach may delay the ultimate rebuilding of the stock by as many as 6 years.  This approach likely could not be continued through time without significantly delaying the rebuilding timeline.  Similarly, the approach will necessarily mean that the private recreational sector will substantially exceed its annual catch limit, which was designed to prevent overfishing the stock.”
If an organization was truly seeking an abundance of fish, and really believed that “harvesting the maximum biomass” by setting catch limits “at or near maximum sustainable yield” was a bad idea, it would have seen the red snapper reopening as a very bad thing.  After all, by pushing back rebuilding by as much as six years, the reopening would keep red snapper abundance lower for an extended period of time. 

Knowingly allowing the private boat recreational sector to “substantially exceed its annual catch limit” would not only lead to decreased abundance, but would result in overfishing, increasing red snapper landings above maximum sustainable yield, a level that the “Vision” report already condemned as anathema to anglers.

Given those things, one would think that the folks calling out for “abundance” would have condemned the Commerce Department’s actions.

But that’s not what happened.

“a welcome boon to anglers who have been painted into a corner by a federal fisheries management system that does not understand us,”
and went on to say that

“The recreational angling community should feel vindicated, and we should take heart that after years of being systematically sidelined by NOAA Fisheries, our efforts to encourage our elected officials in Congress to engage in this man-made disaster are yielding results…As a result of our passion and our refusal to be cast aside, anglers will be allowed to venture into the Gulf of Mexico with their family and friends on weekends throughout the summer in pursuit of the most popular offshore fish in our waters…”
CCA was not alone.

“The federal fisheries management system is failing recreational anglers on many levels, and the red snapper is ‘poster fish’ of the quagmire.  The temporary rule directly addresses this problem, giving millions of recreational anglers in the Gulf of Mexico opportunity to enjoy America’s natural resources and giving the Gulf economy a much-needed shot in the arm…
“Anglers commend the Trump Administration and Members of Congress for hearing our calls for more access to federal waters—and for taking action.  We must now find a permanent solution to the problem…”

“While this is neither a perfect nor a long-term fix, it will provide much-needed relief for the recreational fishing industry this year while a permanent solution for Gulf red snapper is developed…
“Despite the continued frustrations with federal saltwater fisheries management, progress is being made both at the regional and national levels to make the system work better for recreational fishing.  The Gulf red snapper season extension clearly shows that our industry’s concerns are being heard.”
Three comments, from three organizations which, if the “Vision” document is to be believed, all supposedly support “abundant” fish stocks, yet they all praised the red snapper reopening—even though NMFS admits that it will have a negative impact on the abundance of snapper.


But Gulf red snapper is only part of a much bigger picture, one that is revealed in the last paragraph of the CCA press release, which says

“This order signifies that we have left the ramp, but we still have a long run ahead of us.  We must ensure that this renewed scrutiny on the inherent problems in the federal management of this fishery leads to meaningful reforms to the Magnuson Stevens Act…”
What sort of “meaningful reforms”?

Those are described in another CCA press release, which heralds a bill called the “Modernizing Recreational Fisheries Management Act of 2017,” often referred to as the “Modern Fish Act.”  In that release, CCA assures readers that

“The Modern Fish Act addresses many of the recreational fishing community’s priorities including allowing alternative management for recreational fishing, reexamining fisheries allocations, smartly rebuilding fishery stocks, establishing exemptions where annual catch limits don’t fit and improving recreational data collection…”
Readers might notice that increasing the abundance of fish stocks doesn’t appear as one of the stated priorities, and that some priorities, such as “smartly” (which, given the exuberance over the red snapper reopening can be read as “slowly, if ever”) rebuilding fish stocks and creating exemptions to annual catch limits, are likely to cause abundance to remain stagnant or decline…

But what makes the CCA press release truly instructive are the quotes from some of CCA’s allied organizations, with respect to the Modern Fish Act.

The National Marine Manufacturers Association said

“We applaud the introduction of the Modern Fish Act in the House and the efforts of Rep. Graves and his colleagues to modernize the federal regulations governing access to the public’s natural resources by boaters and anglers…  [emphasis added]”
while the American Sportfishing Association hailed the bill because

“…The Modern Fish Act addresses the core issues within federal saltwater fisheries management that are limiting the public’s ability to enjoy saltwater recreational fishing…  [emphasis added]”
Again, both were clearly more concerned with the public’s ability to go fishing—not an unreasonable position for organizations speaking on behalf of their industries—than with the abundance of fish stocks.

But the most interesting quote of all came from Jim Donofrio, executive director of the Recreational Fishing Alliance, the only CCA ally that was neither a contributor to the “Vision” report nor a member of the Center for Sportfishing Policy.  

Donofrio said

“For decades in federal fisheries management, recreational fishing was always an afterthought.  The Modernizing Recreational Fisheries Management Act…finally addresses the specific needs of the recreational fishing community, stands to bring parity to fisheries management and will get anglers back on the water.  [emphasis added]”
The Recreational Fishing Alliance’s statement isn’t remarkable for what it says, which isn’t much different from what was being said by representatives of the other organizations.  What makes it remarkable is the RFA’s endorsement of the Modern Fish Act in light of that organization’s historic opposition to the concept of “abundance.”

Three years ago, just a few months after the “Vision” report came out, Jim Hutchinson Jr., then the Managing Director of the RFA, authored a piece for the organization’s blog.  Titled “Environmental Defense Fund:  Another Abundance of Crap,” the blog attacks the concept of “abundance” as merely a ploy by “the environmental business community” to harm recreational fishermen.  

It begins

“There’s a new buzzword circulating throughout the recreational fishing community of late; a word that’s being actively embraced by many saltwater anglers because of its simple, seemingly straightforward connotation that gives those who speak it a sense of ample warmth and coziness.
“That word is abundance…”
It goes on later to say

“asking for abundance is another way of saying ‘please, take away my right to fish.
“I know it sounds good when presented by well-spoken, hip conservationists who claim to be friend to both fish and fishermen.  Ripping a page from the 21st century progressives’ handbook, these angling elite tear into the fishing industry, demonizing those who earn profit in some way, shape or form from the harvest of fish, while pledging to build our oceans to levels of abundance never seen in our lifetime on behalf of the ‘99’ percenters who apparently struggle to catch even a single fish in these dire environmental times…
“The ‘fish first’ conservationists are talking a good game and leading some folks to believe that oceans of abundance will punish greedy business owners while leaving more fish in the ocean to catch, but its really just a ploy to build support for reduced fishing participation through shortened seasons and bag limits.”
Again, that was written less than six months after the “Vision” report, with its endorsement of the “abundance” concept, was released, which makes it reasonable to assume that RFA had a very different vision than the one such report espoused.

Three years later, Hutchinson is no longer managing director of RFA, although he still seems to be close to the organization.  His attitudes on “abundance” don’t seem to have changed, as he recently wrote in The Fisherman

“On the other hand, some of the opposing [the weakening of Magnuson-Stevens] environmental groups have been working to create new statutory definitions, one in particular through manipulating the word ‘abundance.’  Statistically speaking, abundance is primarily a theoretical measure of how many fish are in a population or a fishing ground.  In preying upon anger emotions in promoting abundant fisheries (as in ‘we need fish in such vast abundance that I can’t help but catch a few on every trip even while using the new fly I tied with dental floss and a pipe cleaner’), some of the very same groups who helped create the statutory definition of ‘overfishing’ manufacturing acronyms like ACL and AM, hope to somehow influence Congress into writing up yet another mealy mouth, statutory definition.”
It can be that Hutchinson no longer speaks for RFA, but it appears that RFA’s position on “abundance” remains the same as it was back in 2014.  In another Fisherman article, which appeared last March, Hutchinson wrote

“In his first formal address to employees upon arrival at the Department of Commerce on March 1, Secretary Ross outlined a series of goals and initiatives for the agency moving forward, including ‘obtaining maximum sustainable yield for our fisheries.’  According to the Recreational Fishing Alliance’s (RFA) Jim Donofrio, that statement alone is a game-changer.
“'That’s the green light to hold the line on the bogus proposal we have in front of us right now [to reduce summer flounder landings in response to a declining biomass and six consecutive years of below-average spawns]…'”
When you put it all together, it seems like the Recreational Fishing Alliance likes the idea of fishing “at or near maximum sustainable yield,” and isn’t very supportive of the concept of managing for abundance.

That immediately leads to the question of why a group with such a philosophy would ally itself so closely with CCA and the other "Vision" contributors that it is quoted in a Coastal Conservation Association press release.  And if CCA, the American Sportfishing Association, the Center for Sportfishing Policy, the National Marine Manufacturers Association and other allied groups truly want fish stocks to be managed for abundance, and not for maximum sustainable yield, why would they partner with RFA?

And why would RFA support the Modern Fish Act, if such act really would cause fishery managers to seek greater abundance rather than higher harvests?

There is an old adage that says

“You will be judged by the company you keep.”
In the Bible, Matthew 7:15-20 states

“Beware of false prophets, who come to you in sheep’s clothing, but inwardly they are ravening wolves.  You will know them by their fruits.  Do men gather grapes from thornbushes or figs from thistles?  Even so, every good tree bears good fruit, but a bad tree bears bad fruit.  A good tree cannot bear bad fruit, nor can a bad tree bear good fruit.  Every tree that does not bear good fruit is cut down and thrown into the fire.  Therefore by their fruits you will know them.”
When an organization such as CCA, which claims to support abundance, works so closely with an organization such as RFA, which wants fish to be harvested at maximum sustainable yield, that it quotes RFA in its press release, you have to start wondering just a little bit about CCA’s dedication to the abundance concept—and wonder whether their pet project, The Modern Fish Act, just might result in some fish getting scarcer.

But when CCA, along with organizations such as the American Sportfishing Association and the Center for Sportfishing Policy aggressively support measures that will decrease abundance, such as the reopening of the recreational red snapper season in the Gulf of Mexico, it’s time to stop wondering.

Because their words about abundance and managing for less than maximum sustainable words sound pretty good.

But by their fruits—delaying red snapper rebuilding while overfishing the stock, and seeking laws that will let them treat other federal fisheries in the same way—you will know them.

And thus you know that there talk of abundance and healthy stocks is just window dressing, for the only abundance they seek is in fishermen’s coolers and industry coffers, and not in our future sea.



  1. do you have any thoughts to share about red snapper possibly displacing gag and black groupers? they seem to be competing for habitats? Also my concern is about the red snapper discard mortality. We appear to be wasting as many or more than we keep?

    1. While I haven't read all the science on the interrelationships between the various members of the Gulf reef ecosystem, I tend to question the notion of one species of fish displacing others that have historically shared the same habitat. The animals have evolved to live together over tens of thousands--perhaps hundreds of thousands--of years, and over that time have carved out unique niches in the ecosystem that give each an opportunity to survive (e.g., snapper will feed higher in the water column than grouper). Having said that, human-driven ecosystem change, whether it is overfishing of a particular species, changes to habitat or overfishing a forage species, can throw off the balance between the species and provide one with an advantage over the other. But I'm not aware of any such situation affecting the species that you mentioned. As far as discard mortality goes, there have been various studies on that. In deeper water, it can be substantial.