It’s another presidential election year, so like clockwork,
the recreational fishing industry is again pushing its political agenda on the
public and the incoming administration, in the form of a document titled The
Future of Sportfishing: Policy
Recommendations from the Recreational Fishing Community.
This year, their efforts raise particular concerns, for despite
their usual attempts to undercut marine conservation and management, they have
somehow convinced a couple of legitimate conservation organizations,
Backcountry Hunters and Anglers and Trout Unlimited, to support their attempts to distort the goals of marine fisheries management in order to maximize industry profits, even if doing so puts marine resources at risk.
As it has done in the past, the American Sportfishing
Association uses the commercial fishing industry as a foil, couching its
policies as a necessary response to a pro-commercial management system and arguing
that
“…Historically, preference has been given to the commercial
fishing industry. The sportfishing
industry is an afterthought and saddled with antiquated, commercial focused,
management plans and inaccurate data.”
They don’t provide any factual support for those assertions,
of course, and the commercial fishing industry might well take exception, and complain about shrinking commercial quotas and the
reallocation of a portion of those commercial quotas to the recreational sector,
as has recently occurred in the case of summer flounder, scup, black sea bass,
bluefish,
gag
grouper, amberjack,
and other species.
In partial defense of the ASA,
the National Marine Fisheries Service has discovered a flaw in the Marine
Recreational Information Program, which is used to estimate recreational
effort, catch, and landings, but it
is actively working to correct the problem.
Otherwise, the American Sportfishing Association’s rhetoric
is an appeal to emotion, not rational debate.
For example, it makes the claim that saltwater anglers are
“contributing over 40 billion dollars to the economy, despite
being responsible for only 2 percent of all marine fish harvest (with
commercial fishermen being responsible for the remaining 98 percent).”
While those figures may be true, their truth hides a deeper
deception on the part of the ASA, for most of the commercial landings are
composed of fish that are not targeted by anglers; in
2022, commercial landings included 2.7 billion pounds of walleye
pollock, as species that does not support any recreational fishing activity,
along with 1.44 billion pounds of menhaden, a fish that neither strikes artificial lures nor bites at a baited hook.
Thus, when comparing commercial and recreational landings,
neither species, which dominate the overall commercial landings, are really relevant to the discussion.
But when we start looking at fish of interest to anglers, it
quickly becomes clear that recreational fishermen account for a lot more than 2
percent of the landings, and often kill the lion’s share. Thus, in
the case of striped bass, recreational fishermen are responsible for 89 percent
of the overall fishing mortality; with recreational landings nearly five times
the commercial harvest.
Based on available NMFS landings data
for the commercial and recreational sectors, in 2022, recreational fishermen on the Atlantic coast were
responsible for 97 percent of all dolphin landings, 83 percent of the bluefish,
66.5 percent of the king mackerel, 63 percent of black sea bass and 59 percent
of all scup landings—even though, in the case of the latter species, the
recreational allocation was only 35 percent of the annual catch limit. The foregoing are all federally-managed
species. When we look at species managed
on a state or regional basis, along with the aforementioned striped bass,
anglers were responsible for 97 percent of red drum landings, 95 percent of
black drum, 94 percent of tautog, and 90 percent of all spotted seatrout
landings.
So, while commercial fisheries do dominate landings for some species of interest to anglers—primarily groundfish that can be trawled in large numbers or pelagic
forage species such as mackerel that are trawled or purse seined tens of thousands
of pounds at a time—recreational fishermen take the greater share of
many other fish stocks, enough to make it clear that the American Sportfishing
Association’s efforts to cast recreational fishermen as victims fails in the
face of the facts.
But then, the rest of the ASA’s document, at least as it
applies to marine fisheries, also fails to stand up to any sort of fact-based
analysis.
Take, for example, the assertion that
“The Marine Recreational Information Program (MRIP) is the
federal data collection system for recreational fishing. However, the program has routinely been shown
to be highly inaccurate, including a recent study that found the program
overestimates recreational catch by 30-40%.
This has led to inaccurate stock assessments, lower quotas, and
shortened seasons…”
Again, we find one truth—NMFS did find that MRIP was
overestimating recreational effort, and so catch and landings—used in an effort
to make multiple false statements appear valid.
To begin, MRIP has not “routinely been shown
to be highly inaccurate.” Instead, MRIP’s sampling and
catch estimation procedures were hailed by a panel of the National Academy of
Sciences as
“a vast improvement over the previous sampling
and estimation procedures and reflect state-of-the-art methods in
survey sampling. [emphasis added]”
Somehow, the ASA seems to have left that part out of their
report. One might almost think that the
omission might have been intentional.
The one instance in which MRIP was found to be
inaccurate occurred when a recent study—because MRIP, unlike the various state data programs
that ASA actively supports, does conduct ongoing quality control
studies to better ensure the quality of its data—revealed that, probably
because of how the survey’s questions were ordered, anglers were overstating
the number of trips that they took, which translated into an overestimate of
catch and landings.
However, contrary to the American Sportfishing Association’s
assertions, such overestimates did not lead to “inaccurate stock assessments,
lower quotas, and shorter seasons,” at least if, by “inaccurate stock
assessments,” one means an assessment that does not accurately reflect the
status of a stock.
In fact, just the opposite occurs.
To address the stock assessment issue first, the primary
purpose of such an assessment is to determine whether stock abundandce is
at a sustainable level, and whether that abundance is increasing, decreasing, or
staying relatively stable. The size of a stock is far less important than its status, for
if the stock is healthy and being fished at a sustainable rate, its precise
size is of little real concern. To that
point, when discussing the error in MRIP, NMFS noted that, because of the error
and any subsequent corrections,
“the magnitude of historical estimates may change, but
critical catch and effort trend information is expected to remain similar. It’s important to note that stock
status determinations are relatively consistent when trend information hasn’t
changed. [emphasis added]”
Thus, the ASA is not correct when it claims that MRIP data,
even if it overstates landings, leads to “inaccurate stock assessments,” as estimates of stock status and trends remain valid.
The ASA is also incorrect when it argues that the errors in MRIP
lead to “lower quotas, and shorter seasons,” for in reality, such errors lead
to higher recreational (and commercial) catch limits and longer seasons—perhaps higher catch
limits and longer seasons than the stock can easily sustain.
That’s because recreational catch data is one of the inputs
used when stock assessments are prepared, and when such data indicates that anglers
are catching a lot of fish, the population model assumes a larger stock size,
because the fish the anglers are catching have to come from somewhere. We
saw this in the 2018 benchmark striped bass assessment, when a higher estimate of
recreational landings was an important factor in driving the estimate of
spawning stock biomass from 61,000 metric tons in 2012 to more than 68,000
metric tons in 2017, at the same time that the same catch estimate contributed to increasing the values
for the biomass target and threshold.
Such higher estimates of spawning stock biomass lead to
higher, not lower, quotas for both recreational and commercial fisheries.
Yet the ASA ignores such facts as it continues to press for more liberal regulations
and higher recreational landings, in the hope that such regulations will
generate higher profits for the recreational fishing industry. Thus, its report calls for
“implementation of alternative management approaches authorized by the Modern Fish Act.”
An
example of such “alternative management approaches” is the so-called “Percent
Change Approach” being utilized by the Mid-Atlantic Fishery Management Council,
which allows NMFS to set recreational harvest targets that exceed the
recreational harvest limit and even the sector annual catch limit, and which,
if combined with the commercial quota, could lead to landings exceeding the
overall annual catch limit, and even the acceptable biological catch and
overfishing limit, effectively doing an end run around the
conservative management approaches established by the Magnuson-Stevens Fishery
Conservation and Management Act.
But then, conservative management and long-term
sustainability has never been the ASA’s lodestars. The American Sportfishing Association is a
trade association, and its purpose is to promote the interests of the
recreational fishing business which, like any business, is all about maximizing
profits.
Its willingness to turn its back on conservation concerns is
made manifest in two of the other stated goals in the report,
“Withdraw North Atlantic right whale vessel speed rule and
partner with industry on technology safety solutions,”
and
“Create a task force to develop mitigation protocols for
shark depredation.”
Both deal with animals that are at low levels—in the case of
right whales, critically low levels—of abundance, and neither make the animals’
welfare a priority, but rather elevate industry interests above conservation
concerns.
The ASA’s position on the North Atlantic right whale is
particularly callous.
The
National Marine Fisheries service calls the North Atlantic right whale
“one of the world’s most endangered large whale species,”
and notes that
“human interactions still present the greatest danger to this
species. Entanglement in fishing gear
and vessel strikes are the leading causes of North Atlantic right whale
mortality…
“There are approximately 360 individuals remaining, including
fewer than 70 reproductively active females…The number of new calves born in
recent years has been below average.”
The whale is clearly a species in very serious trouble.
Yet the ASA would have the federal government withdraw
proposed regulations that would require vessels as small as 35 feet in length—vessels
the size of many recreational fishing boats—to slow to 10 knots in areas where
and at times when right whales are likely to be present, in order to avoid whale-killing
vessel strikes, because such regulations would hamper some fishing activities
and might be a drag on recreational fishing industry profits. The report argues that
“The recreational fishing community advocates for common
sense solutions to conserving the North Atlantic right whale. The 2022 Amendments to the North Atlantic
Right Whale Vessel Strike Reduction Rule ineffectively applies a broad-brush
management approach that will be costly to implement, practically impossible to
enforce, and damaging to recreational boating, fishing, and coastal economies
along the Atlantic coast.”
Now, I have no idea whether the proposed regulations would
make any difference to the right whale population or not; I didn’t participate
in the public comment period, because I lacked enough knowledge to form a
meaningful opinion. But it would seem
that, given the state of the right whale population, it is not a “common sense
solution” to allow fishing boats to rip through the species' nursery or feeding grounds
at more than 30 knots, when
vessel strikes—including strikes from recreational fishing boats—are known to have
killed both adults and calves.
“Common sense” would seem to
demand that regulators err on the side of caution.
If the ASA thinks that the proposed
rules are too broad, and place too much of a burden on the recreational fishing
community, then it is the Association’s burden to offer workable alternative
solutions to the problem of recreational vessel strikes that can be put into
effect now, not at some possible point in the future. Merely saying that
“Several marine electronics companies have
technologies that can detect NARW in real time and are hard at work at integrating
how that information can be instantaneously communicated with boaters”
is not good enough.
Eliminating regulations that may
provide real protections today, in the hope that industry will someday
develop a technology that might protect the whales, and that boaters, under no
legal obligation to react to that information, will operate their vessels in a
responsible manner when whales are in the vicinity, is wishful thinking, not a
solution.
Hastening the extinction of a
species such as the North Atlantic right whale, just so the recreational
fishing industry might earn a few more dollars, is the height of irresponsible
narcissism.
We see the same sort of narcissism,
at a less critical level, in the ASA’s approach to shark depredation. The issue, in a nutshell, is that anglers venture
out on the ocean in search of fish that are the shark’s natural prey. Such fish are hooked, struggle against the
pull of the line, and their struggles are noticed by sharks that, doing what
400 million years of evolution have directed them to do, then make a meal of the
distressed animal. In response, anglers get
upset that ab apex marine predator fed on the fish they wanted to play with, and
perhaps eat themselves, and the issue of shark depredation is born.
Of course, shark depredation is
nothing new.
If you read the books written by
fishermen who ventured offshore in the years before the Second World War,
anglers such as S. Kip
Farrington, Van
Campen Heilner, and Ernest
Hemingway, you’ll learn that shark depredation was the norm back then, with marlin,
bluefin tuna and other big fish regularly mutilated by sharks before they were
landed. Even in the late 1960s and early
1970s, when I was doing a fair amount of codfishing from Rhode Island-based
party boats, it was pretty well accepted that, at some point during the day,
one or more sharks would happen along and steal a few cod. It was just the way things were.
“people gradually accept environmental
decline. Marine Biologist Daniel Pauly
calls this habituation ‘shifting baseline syndrome.’ For fisheries, each new generation of
fishermen accepts the current, often reduced, status of fish populations as the
baseline and forgets that there was a time when these species were much more abundant.
“In this case, modern anglers are comparing
increased numbers of sharks in the Gulf of Mexico to the past 30 years—a time
when many shark populations were overfished.
“The recovery of populations that were once
overfished can create an opposite situation, known as lifting baselines, with
conservation and management efforts leading to population increases.
“Instances where populations have been
overfished and then rebuilt can create a perception of overabundance. When the species that’s recovering is a
predator, that can lead to human-wildlife conflict.”
Thus, the “shark depredation”
debate. As some shark populations slowly
rebuild, and as the number of anglers also increases, there is greater
competition for the same prey species—grouper, snapper, cod, haddock, yellowfin
tuna, and the like—and greater calls from the recreational fishing community,
including the American Sportfishing Association, to “do something” about the
shark “problem.”
The ASA complains that
“Shark depredation, when a shark bites or
consumes the hooked catch as it is being retrieved, is increasing in prevalence
and leading to poor quality fishing experience and concerns about fishery
sustainability.”
Such statement ignores the fact that
fish stocks had no problems dealing with sharks for hundreds of millions of
years; it was only when fishermen—not only anglers, but commercial fishermen,
too—came on the scene that sustainability became an issue. And it never really addresses the fact that
the sustainability of shark populations is important, too.
Still, it probably is possible to
find a middle ground, for as Dr. Drymon writes,
“…The Gulf’s sportfishing industry has grown,
and it is likely sharks learn to associate the presence of boats with an easy
meal.
“Shark deterrents are available, and new
versions are continually being developed.
Some fishermen are changing their practices to avoid sharks—for example,
shifting locations frequently and never anchoring or fishing offshore to avoid
coastal species such as bull sharks…
“In my view, measures like these, along
with better data about which sharks are taxing anglers and where, are the most
promising ways to help anglers coexist with sharks in the Gulf.”
And if that’s all the ASA wants to
do, perhaps there isn’t a problem. The report notes that
“Legislation introduced in the 118th
Congress, called the Supporting the Health of Aquatic Systems through Research,
Knowledge, and Enhanced Dialogue (SHARKED) Act, would create a task force to
research technologies and other methods that can reduce the prevalence of shark
depredation,”
and so long as the efforts to reduce depredation focus on technology and changing angling practices, all should be well.
However, the phrase “other
methods that can reduce the prevalence of shark depredation” call all too
easily be interpreted to include “other methods that can reduce the prevalence
of shark depredation by reducing the prevalence of sharks.” I sit on NMFS’ Highly Migratory Species
Advisory Panel, and it is very clear from their comments at Panel meetings that
a number of industry representatives believe that shark
numbers are already too high—such members being confused by the “lifting baseline” mentioned by Dr.
Drymon—and support and sometimes actively call for adopting measures that will halt the restoration of some
shark stocks and reduce the abundance of others, even though biologists like
Dr. Drymon tell us that
“As reports of depredation increase, so do
calls for culling shark populations…
“Studies show, however, that predator removal
is rarely an effective strategy. It’s
particularly ineffective for species such as sharks that move around a lot and
will readily recolonize areas that have been culled. Predator culls also pit people with different
values, such as fishing boat operators and conservationists, against each
other.”
Should the debate over shark
depredation get to the point that culls are seriously considered, it’s not hard to figure out
which side the American Sportfishing Association and its allies would support. After all, it already supports
“reducing pinniped [seal and sea lion]
populations in the river systems”
of the Pacific Northwest in order
to prevent them from preying on salmon valued by anglers. Going from there to reducing shark
populations in order to lessen shark depredation on hooked sportfish is not a
very long journey.
The ASA report addresses other
issues, but in such cases the theme remains the same:
Giving lip service to conservation, while promoting policies that subordinate
good science and thoughtful conservation practices to policies that will
provide short-term economic benefits to the sportfishing industry, while
putting the long-term health of marine resources in doubt.
The American Sportfishing
Association, as a trade organization and as the voice of the recreational
fishing industry, has every right to promote policies likely to help its
members’ bottom lines, but recreational fishermen should never make the mistake of
thinking that the ASA is looking out for them, just as policymakers should
never make the mistake of thinking that the ASA speaks for recreational fishermen, instead of the fishing industry.
ASA speaks for itself. It speaks for its members. And those concerned about the long-term health
of our nation’s living marine resources should not be pleased with much of what it has
to say.
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