Sunday, April 7, 2024



I have probably observed the debate over the recreational red snapper fishery in the Gulf of Mexico for close to twenty years, if not a bit more, and if anything has proved true over that time, it’s that the folks who represent the private-boat recreational red snapper fishery have are particularly averse to two things: accepting their share of the responsibility for the health of the red snapper resource, and telling the unvarnished truth about what is really going on with red snapper management.

From the time that I first became familiar with the fishery, I have seen representatives of the large and growing private-boat recreational fleet blame some or all of the red snapper fishery’s problems on the commercial fishery, on shrimp trawler bycatch (that one, at least, contains a kernel of truth), on the catch-share program that ended commercial overfishing, on the limited fleet of for-hire vessels, on environmental organizations that seek to limit fishing mortality, on federal fishery managers, on the statisticians supporting the Marine Recreational Information Program and, most recently, even on the sharks that have been swimming in the Gulf’s waters for millions upon millions of years.

About the only people those anglers’ rights groups opt not to blame are the recreational fishermen themselves, despite data demonstrating chronic angler overharvest that continues, mostly unabated, for years.  Instead of accepting their responsibility for angling overages, every time recreational fishermen are found to exceed their annual harvest limit, they react like the spoiled four-year-old caught with his hand in the cookie jar who, instead of admitting to the transgression, takes the offensive and wails that “Nobody loves meeee!”

And like a spoiled child, those red snapper anglers will dissemble, skewing the truth in a desperate effort to elicit sympathy and convince someone—just about anyone—to take their side.

The most recent example of such behavior emerged this week, in the form of an opinion piece titled “The Great Red Snapper Count:  A Costly Disappearing Act,” which appeared on the website of the Coastal Conservation Association, arguably the most militant of the anglers’ rights groups involved in the red snapper debate.

The primary thrust of the opinion piece was that the results of the so-called “Great Red Snapper Count,” which was supposed to be an extensive survey of the red snapper population in the U.S. portion of the Gulf of Mexico, have been squandered, because

“the $12 million independent study funded by Congress…is gathering dust on a shelf at NOAA.  Anglers have seen no substantive changes in management of the fishery.  Almost a decade after the funding was approved, it’s almost as if the [Great Red Snapper Count] never happened.”

And that bothers the Coastal Conservation Association and its red snapper-hungry members, because

“The [Great Red Snapper Count] was finalized in 2021 and found a red snapper population that was at least three times larger than NOAA’s estimates…When it was released, Sen. Shelby [who was primarily responsible for obtaining the appropriation funding the study] said via Twitter that he was ‘proud to have led the efforts in Congress to fund the Great Red Snapper Count.’  He added, ‘Hopefully this data will allow for more red snapper fishing opportunities in the Gulf.’”

There is little doubt that more red snapper was what the CCA and its members wanted, too, and they were considerably piqued when they didn’t get them.

It was that pique that led to more dissembling and more misleading comment.

The opinion piece told readers that

“NOAA pledged to take the findings of the [Great Red Snapper Count] and incorporate them into its next assessment of red snapper, which was scheduled to begin in 2021,”

and tried to convince them that

“it would have been reasonable to expect the results of the [Great Red Snapper Count] to simply become the new benchmark,”

but that’s not how science works.  Data needs to be validated before it can be accepted.

And that’s when the CCA opinion piece really began to blow smoke, alleging that

“In January 2024—eight years after Congress funded the independent study and three years after it was finalized—NOAA announced that it was unable to produce a viable stock assessment for red snapper, the most studied species in the Gulf reef fish complex.  It turns out that NOAA’s red snapper stock assessment model contains more than a stunning 2,900 parameters, each with its own level of uncertainty and bias.  The model simply could not stand under its own weight.  Due to the model’s remarkable instability, reviewers recommended NOT including the findings from the Great Red Snapper Count at all.”

But that's not exactly what went on.

It’s true that the most recent Gulf red snapper stock assessment, formally known as SEDAR 74, the Stock Assessment Report for Gulf of Mexico Red Snapper, did not pass peer review and will not be used for management purposes.  Sometimes that happens.  The point of a so-called “benchmark” stock assessment is to consider new approaches to managing a particular species (in this case, SEDAR 74 included both the Great Red Snapper Count data and a proposal to divide the Gulf red snapper fishery data into three areas instead of the two used before), and the point of performing an independent peer review of such an assessment is because sometimes, when trying to explore new approaches, the assessment scientists will, unfortunately byt perhaps inevitably, get a few things wrong.

Apparently, that happened in SEDAR 74.

As for the rest of the claims made by the CCA, perhaps it’s best to refer to the presentation made to the Gulf of Mexico Fishery Management Council’s Scientific and Statistical Committee on February 28, which set out the reviewers’ objections to SEDAR 74.

Doing that, it appears that the peer review panel wasn't unduly concerned with SEDAR 74 ‘s “stunning 2,900 parameters” (although it did feel that the model was “too complex”) and their related uncertainty (all scientific data contains some level of uncertainty).  It also appears that there is little evidence that “the model simply could not stand under its own weight.”  Nor is their any evidence that, as the CCA opinion piece claimed, the Great Red Snapper Count data wasn’t included in SEDAR 74 because of “the model’s remarkable instability.”

Instead, the peer reviewers listed five main concerns with SEDAR 74:  Criticisms of it as a so-called “research track” stock assessment that took a new management approach to red snapper; how the assessment treated age and length data; how the assessment identified the red snapper stock; uncertainty in catch and landings data; and the Great Red Snapper Count data itself.

Yes, that’s correct.  The Great Red Snapper Count data didn’t fall victim to a faulty stock assessment.  Instead, the incorporated Great Red Snapper Count data was part of the reason why the assessment failed to pass peer review.

Let’s look at that in a little more detail.

Far from the Coastal Conservation Association’s contention that “it would have been reasonable to expect the results of the [Great Red Snapper Count] to simply become the new benchmark,” thepeer review panel, which was composed of members of the National Academy ofSciences Council of Independent Experts, and so had no inherent biases for oragainst the stock assessment, determined that

“It was premature to include the [Great Red Snapper Count] estimates in the model as potential biases have not been quantified and composition data were not available.”

The difference between the two comments was as stark as the difference between amateurs and professional fisheries scientists interpreting a set of data, and the difference between advocates for a particular result and disinterested researchers evaluating a particular source of information.

While the amateurs and the advocates are quick to decide that the Great Red Snapper Count’s findings justify an increase in red snapper harvest, the educated, professional fisheries scientists are far more reluctant to grant their imprimatur to a study that remains open to question.  At best, the professionals from the Council of Independent Experts found that the Great Red Snapper Count data could be used as ancillary information, even if the data does not fit into the assessment model.

Thus, despite the fact that, in funding the Great Red Snapper Count, Congress described its purpose as

“Estimating the absolute abundance of red snapper in the U.S. Gulf of Mexico,”

the peer review panel questioned whether the Count was a true absolute abundance estimate, and asked whether it should be treated as such.  During the panel discussion, there was some question as to whether the Great Red Snapper Count was even meant to be used as part of the stock assessment process.

In fact, the peer review panel had sufficient questions about the Great Red Snapper Count that it suggested that a new research team, separate from the team that developed the Count, examine some aspects of the data.  The panel recommended that such new team, ideally in consultation with the principal investigators from the Great Red Snapper Count, explore and quantify biases in the Count—if such exploration is even possible.  The peer review panel also recommended that such new, separate team examine the County’s catchability estimates, an issue that is closely tied to the issue of bias.

Beyond that, the peer review panel felt that additional inquiry was needed to determine whether the different survey methods and survey gear used in the Great Red Snapper Count caught snapper at the same rate, whether the Count truly selected all Age 2+ red snapper throughout the Gulf of Mexico, and whether the estimates provided by the Great Red Snapper Count are more or less reliable than estimates achieved through other methodologies, particularly when such estimates conflict.

There was also apparently a real question about whether the length composition data provided by the Great Red Snapper Count was representative of red snapper size distribution throughout the entire Gulf of Mexico.

The bottom line was that, while the Coastal Conservation Association is trying to convince its members, as well as the general public, that the Great Red Snapper Count is the most accurate gauge of red snapper abundance (and so justifies a substantial increase in the recreational red snapper kill), the fisheries professionals on the Council of Independent Experts who reviewed SEDAR 74, and reviewed the Great Red Snapper Count in a SEDAR 74 context, disagree.  They view the Great Red Snapper Count as a possibly useful study that may nonetheless be beset by biases and some questionable data.

In order to produce a benchmark stock assessment more likely to survive the peer review process, the peer review panel suggested that the stock assessment team revisit a number of issues, including recreational landings and discard data; age and length composition data; returning the stock assessment to a two-area, rather than a three-area, structure; the model’s sensitivity to changes in the steepness, natural mortality, and landings values; the evaluation of the starting year of the model, and shrimp trawl bycatch data.

The peer review panel also suggested that the stock assessment team revisit the Great Red Snapper Count data, but admitted that it didn’t really know how that ought to be done.

Thus, the Great Red Snapper Count was probably nowhere near as great as its proponents would have you believe.

After all of the hype, all of the effort, and all of the money spent on counting red snapper in the Gulf of Mexico, it appears that the results of the Count are far less impressive than the Coastal Conservation Association and other angling industry and anglers’ rights organizations had predicted and hoped.  In the end, the Great Red Snapper Count represents a very big data set that provides fisheries managers with some new, and some very flawed, information, which represents not a panacea, but merely another set of numbers to be crunched, analyzed, and put in their proper context by state and federal fisheries managers in the Gulf of Mexico.

The Great Red Snapper Count data is not “gathering dust on a shelf,” as the CCA claims.

It was included in SEDAR 74, as NOAA Fisheries had promised.

But the simple truth is, the Count is flawed, and should not be used to justify any fishery management action until more research is done.  The CCA and the rest of the anglers’ rights community can whine and complain that the Count wasn’t accepted at face value, and that anglers still can’t take home as many red snapper as they might like.

But the fact remains that the Great Red Snapper Count appears to be flawed, and that much more work is required before it might be ready to use to manage red snapper.

The anglers’ rights folks don’t like that fact, but it is fact just the same.

The Great Red Snapper Count just is not as great as the CCA and its allies pretend it to be.







































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