Thursday, October 6, 2022

NMFS SEEKS ANGLER INPUT ON RECREATIONAL FISHING POLICY

 

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.

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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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