Sunday, June 18, 2023

CONFRONTING RECREATIONAL BYCATCH IN THE SOUTH ATLANTIC

 

Fishery management is rife with controversy.  But if anything in that arena comes close to a universal truth, accepted by the commercial, recreational, and for-hire sectors, as well as by managers and the environmental community, it is the notion that bycatch is bad.

The Magnuson-Stevens Fishery Conservation and Management Act defines bycatch as

“fish which are harvested in a fishery, but which are not sold or kept for personal use, and includes economic discards and regulatory discards.  Such term does not include fish released alive under a recreational catch and release fishery management program.”

Magnuson-Stevens, in establishing national standards for fishery conservation and management, states that

“Conservation and management measures shall, to the extent practicable, (A) minimize bycatch and (B) to the extent bycatch cannot be avoided, minimize the mortality of such bycatch.”

Most people, and particularly anglers, tend to think of bycatch as a problem caused by commercial fisheries.  They think of things like turtles and marine mammals incidentally killed by miles-long pelagic longlines, cod unintentionally caught in trawls targeting haddock, pollock, and/or Acadian redfish, or the trail of striped bass, accidentally killed and intentionally dumped, floating in the wake of a dragger seeking other species.

In 2007, the angler-oriented Coastal Conservation Association, along with two marine fishery-oriented conservation groups, sued the Secretary of Commerce, who oversees the National Marine Fisheries Service, alleging among other things that, because approximately 90% of red snapper fishing mortality in the Gulf of Mexico was attributable to bycatch in the shrimp trawl fishery, the red snapper fishery management plan should contain provisions that addressed such bycatch.  The United States District Court for the Southern District of Texas in deciding the case of Coastal Conservation Association v. Gutierrez, ordered the Secretary to

“consistent with his obligations under [Magnuson-Stevens], approve a red snapper rebuilding plan, considering measures to reduce bycatch in the shrimp fishery, within the next nine months.”

 NMFS has since recognized the contribution that reducing such bycatch has made to rebuilding the Gulf red snapper population, although it doesn’t generally acknowledge the lawsuit.  The Coastal Conservation Association is far less reticent to hail the impacts of its litigation on the red snapper’s recovery, and it is not hesitant to point it’s finger at the impacts of commercial bycatch on the red snapper stock.

But what happens when the shoe finds itself on the other foot?

What happens when recreational bycatch begins to cause meaningful harm to a commercial fishery?  And in particular, to a commercial red snapper fishery?

We’re starting to see the answer to that question play out in the South Atlantic, where a group of commercial fishermen are suing the current Secretary of Commerce, Gina Raimondo, for NMFS’ failure to rein in bycatch in the recreational red snapper fishery, which failure, the plaintiffs allege, violates the clear language of Magnuson-Stevens.

The matter is Slash Creek Waterworks, Inc., et al v. Raimondo.  It was filed in the United States District Court for the District of Columbia on June 16, and challenges a recently-adopted temporary rule governing the South Atlantic red snapper fishery, alleging

“The Amendment 43 regulations, in conjunction with the temporary rule, establish and implement an annual catch limit for red snapper that is set in terms of landings only—ignoring dead discards, which represent the overwhelming majority of catch.  This approach fails to limit catch of South Atlantic red snapper, fails to prevent overfishing, and creates a de facto reallocation of red snapper to the recreational sector, each of which is contrary to law.”

The underlying facts of the case are difficult to dispute. 

The most recent South Atlantic red snapper stock assessment, designated “SEDAR 73,” was released in March 2021.  It found that the stock was both overfished and experiencing overfishing, and noted that

“…Since 2010, general recreational discards have been the dominant source of fishing mortality.

“…the exploitation rate has remained above [the fishing mortality threshold] since the late 1970s, with the exception of 2013.  Since 2010, the exploitation rate has been dominated by dead discards, especially from the general recreational fleet.

“…The general recreational fleet has been the dominant source of removals, for both landings and dead discards.  Since 2010, total landings have remained at or below [the landings level associated with fishing mortality at maximum sustainable yield], however discards have exceeded [the discard level associated with fishing mortality at maximum sustainable yield] for most of these years.”

There is thus little reason to doubt that recreational fishing mortality, and not commercial fishing activities, is the greatest single obstacle to red snapper rebuilding.  There is also little or no reason to doubt that it is recreational discard mortality, and not recreational landings, that creates the biggest and most intractable problem.  As noted by the South Atlantic Fishery Management Council,

“…overfishing [is] primarily driven by the high numbers of fish in the recreational fishery released throughout the year that don’t survive.  These dead fish comprise approximately 85% of the allowable removals in the fishery.  Due to the high proportion of the removals being dead discards, reductions in landings alone, even no allowable landings, will not end the overfishing of Red Snapper.  Therefore, in order to end overfishing, the Council must also reduce dead discards.  [emphasis added]”

It's important to note that such recreational dead discards accrue “throughout the year,” in fisheries for other species, and not just during the brief recreational red snapper season.  Thus, if the argument successfully made by the Coastal Conservation Association in Coastal Conservation Association v. Gutierrez has any lasting merit, NMFS has an obligation to address red snapper bycatch in other fisheries—in this case, in other recreational fisheries—in order to discharge its statutory obligation to rebuild red snapper.

NMFS appears to have agreed.

According to the American Sportfishing Association, the primary trade association for the fishing tackle industry,

“NOAA Fisheries strongly advocated for [the South Atlantic Fisheries Management Council] considering time/area bottom fishing closures for snapper grouper in the ‘short term’ to end overfishing of red snapper.  The NOAA Fisheries Southeast Regional Administrator noted that discard mortality needed to be reduced by 65% to end overfishing and that bottom fishing closures should be considered as a way ‘to keep people off the fish’…They specifically discussed options such as depth limits, seasonal closures, and/or area closures of snapper grouper fishing in federal waters.”

That the American Sportfishing Association opposed such regulations isn’t particularly surprising, given its job of promoting fishing tackle sales and protecting the profits of the fishing tackle industry.  However, it turns out that the Coastal Conservation Association—the very same association that went to court in an effort to place additional burdens on the commercial shrimp industry, in order to promote red snapper rebuilding in the Gulf of Mexico—is opposed to such measures as well.

I suppose “coastal conservation” doesn’t look so attractive when the fishery that someone is trying to burden happens to be your own.  It is, after all, far more appealing, and far less troublesome, to conserve someone else’s fish.

“…Off the states of North Carolina, South Carolina, Georgia, and Florida, a booming red snapper population is threatening to close all bottom fishing in the region for years.  Red snapper are currently in a rebuilding plan that won’t conclude for more than two decades, but they are already so numerous that NOAA Fisheries calculates that just what anglers catch as bycatch is overfishing red snapper…

“What’s driving this dilemma is a requirement that the Council end overfishing within two years of being notified of the condition.  NOAA Fisheries notified the Council over a year ago that based on the last stock assessment red snapper were undergoing overfishing, so the regulatory clock is ticking—loudly.  NOAA says a complete ban on directed harvest will not end the overfishing, so it believes something must be done to substantially decrease the discards (and discard mortality) to end overfishing.”

Recreational opposition to the closures was so substantial that the South Atlantic Council backed off any plans that it might have had to impose time and area restrictions, thus assuring that overfishing will continue in the South Atlantic red snapper fishery, and that recreational fishermen will, despite clear language in Magnuson-Stevens, to remain unaccountable for their overages.

In response, the commercial fishermen sued, making three related claims.

Their first claim is very simple.  Despite Magnuson-Stevens’ clear mandate that

“Conservation and management measures shall prevent overfishing while achieving, on a continuing basis, the optimum yield from each fishery for the United States fishing industry,  [emphasis added]”

the Council and agency has allowed overfishing to continue, even though use of the word “shall” takes away all Council discretion; neither the regional fishery management councils nor NMFS have any authority to permit overfishing in a fishery management plan, plan amendment, or other management measure.

And the term “overfishing” addresses all fishing mortality, not merely landings.  Magnuson-Stevens defines overfishing as

“a rate or level of fishing mortality that jeopardizes the capacity of a fishery to produce the maximum sustainable yield on a continuing basis.”

Magnuson-Stevens also requires that every regional fishery management council

“develop annual catch limits for each of its managed fisheries that may not exceed the fishing level recommendations of its scientific and statistical committee or the peer review process described [elsewhere in the law].”

To provide additional guidance to the regional fishery management councils charged with implementing such requirement, NMFS must publish guidelines (which do not have the force of law, but are nonetheless persuasive authority) addressing annual catch limits and related issues.  Some of the guidelines relevant to the South Atlantic red snapper situation state

“Each Council shall develop [annual catch limits] for each of its managed fisheries that may not exceed the ‘fishing level recommendations’ of its [scientific and statistical committee] or peer review process (Magnuson-Stevens Act Section 302(h)((6)).  The SSC recommendation that is most relevant to the ACLs is [acceptable biological catch], as both ACL and ABC are levels of annual catch.”

“Acceptable biological catch” is defined as

“a level of a stock or stock complex’s annual catch, which is based on an ABC control rule that accounts for the scientific uncertainty in the estimate of [the overfishing limit], any other scientific uncertainty, and the Council’s risk policy,”

while the “overfishing limit” is defined as

“the annual amount of catch that corresponds to the estimate of [the maximum fishing mortality threshold] applied to a stock or stock complex’s abundance and is expressed in terms of numbers or weight of fish.  [emphasis added]”

When we apply that statutory and regulatory language to the South Atlantic red snapper fishery, we find that Amendment 43 to the Fishery Management Plan for the Snapper Grouper Fishery of the South Atlantic Region doesn’t seem to comply.  Instead of basing the annual catch limit on the annual catch—that is, both dead discards and landings—the South Atlantic Council based it on landings alone, ignoring the dead recreational discards that comprise 85% of all fishing mortality.

The plaintiffs in the commercial fishermen’s lawsuit thus, not unreasonably, argue that the annual catch limit set in Amendment 43, and in the recently issued temporary regulation, violates the clear language of Magnuson-Stevens.  It seems somewhat difficult to disagree.

The plaintiffs' second claim is very similar to the first.

Plaintiffs’ third claim is that, because dead recreational discards make up such a large percentage of the overall catch—far more than the 71.93% allocated in the management plan, even before recreational landings are taken into account—both Amendment 43 and the temporary regulation constitute a de facto reallocation of the red snapper resource, and that such reallocation does not meet the “fairness” standard established by Magnuson-Stevens.

This claim is a tricky one.  It has been made in challenges to management actions affecting other species, but a definitive ruling on the “de facto reallocation” theory has not yet been made.  The relevant NMFS guidelines define an allocation as

“a direct and deliberate distribution of the opportunity to participate in a fishery among identifiable, discrete user groups or individuals.  Any management measure (or lack of management) has incidental allocative effects, but only those measures that result in direct distributions of fishing privileges will be judged against the allocation requirements of [National] Standard 4…”

It seems simple for NMFS to successfully argue that, because it didn’t explicitly increase the 71.93% recreational share of the South Atlantic red snapper fishery, it did not reallocate the resource.  On the other hand, the South Atlantic Council and the agency both decided that it was acceptable to ignore dead recreational discards, which constitute 85% of all fishing mortality, and only apply the established allocation to the other 15% of fishing mortality represented by recreational and commercial landings.

Could that decision to ignore dead discards constitute a “direct and deliberate distribution of the opportunity to participate in” the red snapper fishery?  That’s something a judge must still decide, but it is somewhat difficult to believe that NMFS may endorse a regional fishery management council’s decision to take actions which would have a profound impact on a sector’s ability to participate in a fishery, to the benefit of another sector, and be exempt from any judicial review of the fairness and equity of such action just because the word “allocation” was never used.

Hopefully, the District Court down in Washington will finally provide some clarity on that issue.

In the meantime, the lawsuit brought by the commercial plaintiffs is likely to cause some real consternation among recreational fishermen, and recreational advocacy groups, in the southeast, who have long acted as if the commercial sector was solely responsible for overfishing and overfished stocks.  We can probably expect such organizations to file amicus curiae (“friend of the court”) briefs in the matter, seeking to uphold the current management approach.

In time, we'll find out whether the plaintiffs prevail, or whether the courts will bless NMFS’ and the Council’s decision to ignore dead recreational discards.

In the meantime, the suit serves as a potent reminder that harmful bycatch isn’t limited to the commercial sector, and that sometimes, recreational anglers can, just by fishing, cause meaningful harm.

 

 

 

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