This page is dedicated to a discussion with Pew Charitable Trust.
My first question for PEW.
PEW,
I would like to thank Holly Binns and Debbie Salamone for
agreeing to have an open and honest discussion about how we should manage our
fisheries in a way that limits waste, feeds more people, and rebuilds stocks
from decades of mismanagement. My first question for PEW will include a brief
statement explaining how our fisheries are currently being
mismanaged.
The problem with the way our fisheries are being managed comes
down to the Regulatory Discards that are a waste of our resources. Fishermen are
being forced to discard countless dead and dying fish in the name of
conservation. Our fishery managers are planning ahead for this tragic waste by
allocating up to 100% of a Total Allowable Catch to dead discards. Over 40 tons
of perfectly edible Red Snapper in the southeast are being discarded every year
to slowly die and go to waste because they do not meet some arbitrary length. In
addition to unreasonable size limits, derby fisheries fill annual quotas in a
matter of weeks sometimes. Once the quota is filled, the fishery is shut down
and we are forced to discard any of the illegal fish we accidentally catch while
fishing for legal species that live in the same areas. The discards that add up
to thousands of tons of wasted seafood financially devastate fishermen and
compromise our safety at sea. We must stay at sea longer and in worse weather
until we catch enough legal fish to pay the bills. Derby fisheries and
Regulatory Discards played a key role in the death of Alan Nelson two years ago.
He drowned on a cold dark winter night trying to support his 19 month old baby.
This was the final event that forced me to do something. I am responsible for
the safety of my crew regardless of the laws we must follow. I did not want to
come home one trip without my deckhand and have to explain to his wife and three
kids how their father and husband died. I started offering simple solutions to
our fishery managers that would limit the waste and promote our safety at sea.
They told me to take it up with Congress if I did not like what they were doing.
I am hoping that through this discussion we can stand united in support of
actions that would follow the Magnuson-Stevens Act mandates to limit waste, make
efficient use of our resources, and promote fishermen’s safety at sea.
My first question for PEW is this. Please tell me which solutions
PEW supports or opposes and why. Please address each solution.
1. Establish a Total Allowable Catch for each targeted species and By-Catch Allowances for non-target species.
This is already being done for most fish and I support it.
2. Remove the size limits that are causing so much of the waste in our fisheries. We should not only be
targeting the breeding stock while leaving a truncated stock of little fish to
grow slowly as they compete for the same food source. Size limits leave the
runts to pollute the gene pool and reduce the overall health of the stock as
well as the average size of the fish in it. Larger fish produce more and
healthier offspring.
3. The quotas should be properly managed with split seasons and possession limits that are adjusted to levels
that fill the quotas without any long closures. The adjustments could be made
quarterly or after a predetermined amount of the seasonal quota has been caught.
We could target the fish with high limits and still keep the ones we
accidentally catch that have lower limits. This would work well for both
recreational and commercial fisheries.
4. Removing the size limits would allow us to harvest an entire Total Allowable Catch. I realize there must
be a cushion that ensures the TAC is not exceeded. I suggest setting aside ten
percent of each TAC for the less fortunate in society. Recreational fishermen
could donate any fish they did not want to eat to that quota. Commercial
fishermen could bring in everything we land. We could sell our possession limits
and donate any overages to the poor. Those fish could be distributed to soup
kitchens and food pantries across America.
5. Once the TAC of each species is properly managed, we need to start looking at ways to enhance our
resources so we can feed even more people. Artificial Reefs are the perfect
union of aquaculture and commercially or recreationally harvested wild fish. The
new reefs greatly increase the total bio-mass an area can support. They not only
help the seafood we harvest, they also help turtles, corals, and anything else
that lives on or around structure. Sandy barren bottom supports very little life
in our offshore waters. Structure creates the base of the food chain. Increasing
the amount of food and shelter available allows stocks to achieve a higher
Optimum Yield than even in a virgin fishery. We should be enhancing our
resources rather than restricting our freedom to access them.
These five simple solutions would almost eliminate Regulatory
Discards while rebuilding stocks faster and feeding many more people.
Thank you,
Chris McCaffity
www.freefish7.com
freefish7@hotmail.com
I would like to thank Holly Binns and Debbie Salamone for
agreeing to have an open and honest discussion about how we should manage our
fisheries in a way that limits waste, feeds more people, and rebuilds stocks
from decades of mismanagement. My first question for PEW will include a brief
statement explaining how our fisheries are currently being
mismanaged.
The problem with the way our fisheries are being managed comes
down to the Regulatory Discards that are a waste of our resources. Fishermen are
being forced to discard countless dead and dying fish in the name of
conservation. Our fishery managers are planning ahead for this tragic waste by
allocating up to 100% of a Total Allowable Catch to dead discards. Over 40 tons
of perfectly edible Red Snapper in the southeast are being discarded every year
to slowly die and go to waste because they do not meet some arbitrary length. In
addition to unreasonable size limits, derby fisheries fill annual quotas in a
matter of weeks sometimes. Once the quota is filled, the fishery is shut down
and we are forced to discard any of the illegal fish we accidentally catch while
fishing for legal species that live in the same areas. The discards that add up
to thousands of tons of wasted seafood financially devastate fishermen and
compromise our safety at sea. We must stay at sea longer and in worse weather
until we catch enough legal fish to pay the bills. Derby fisheries and
Regulatory Discards played a key role in the death of Alan Nelson two years ago.
He drowned on a cold dark winter night trying to support his 19 month old baby.
This was the final event that forced me to do something. I am responsible for
the safety of my crew regardless of the laws we must follow. I did not want to
come home one trip without my deckhand and have to explain to his wife and three
kids how their father and husband died. I started offering simple solutions to
our fishery managers that would limit the waste and promote our safety at sea.
They told me to take it up with Congress if I did not like what they were doing.
I am hoping that through this discussion we can stand united in support of
actions that would follow the Magnuson-Stevens Act mandates to limit waste, make
efficient use of our resources, and promote fishermen’s safety at sea.
My first question for PEW is this. Please tell me which solutions
PEW supports or opposes and why. Please address each solution.
1. Establish a Total Allowable Catch for each targeted species and By-Catch Allowances for non-target species.
This is already being done for most fish and I support it.
2. Remove the size limits that are causing so much of the waste in our fisheries. We should not only be
targeting the breeding stock while leaving a truncated stock of little fish to
grow slowly as they compete for the same food source. Size limits leave the
runts to pollute the gene pool and reduce the overall health of the stock as
well as the average size of the fish in it. Larger fish produce more and
healthier offspring.
3. The quotas should be properly managed with split seasons and possession limits that are adjusted to levels
that fill the quotas without any long closures. The adjustments could be made
quarterly or after a predetermined amount of the seasonal quota has been caught.
We could target the fish with high limits and still keep the ones we
accidentally catch that have lower limits. This would work well for both
recreational and commercial fisheries.
4. Removing the size limits would allow us to harvest an entire Total Allowable Catch. I realize there must
be a cushion that ensures the TAC is not exceeded. I suggest setting aside ten
percent of each TAC for the less fortunate in society. Recreational fishermen
could donate any fish they did not want to eat to that quota. Commercial
fishermen could bring in everything we land. We could sell our possession limits
and donate any overages to the poor. Those fish could be distributed to soup
kitchens and food pantries across America.
5. Once the TAC of each species is properly managed, we need to start looking at ways to enhance our
resources so we can feed even more people. Artificial Reefs are the perfect
union of aquaculture and commercially or recreationally harvested wild fish. The
new reefs greatly increase the total bio-mass an area can support. They not only
help the seafood we harvest, they also help turtles, corals, and anything else
that lives on or around structure. Sandy barren bottom supports very little life
in our offshore waters. Structure creates the base of the food chain. Increasing
the amount of food and shelter available allows stocks to achieve a higher
Optimum Yield than even in a virgin fishery. We should be enhancing our
resources rather than restricting our freedom to access them.
These five simple solutions would almost eliminate Regulatory
Discards while rebuilding stocks faster and feeding many more people.
Thank you,
Chris McCaffity
www.freefish7.com
freefish7@hotmail.com
This is the response to my first question.
The Pew Environment Group is very pleased to engage in this discussion about the
future of our valuable fish resources. Our goal is abundant fish, a healthy
ocean ecosystem, and a strong economy. Overfishing threatens a resource we all
share. Implementing science-based solutions will put us on a path toward
sustainable fishing that will ensure robust fish populations for recreation,
businesses, seafood eaters, and future generations.
Chris McCaffity asked Pew’s Southeast project director, Holly Binns, to explain her
position on five ideas he proposed. These are her responses:
Chris, Idea No.
1: Establish a total allowable catch
for each targeted species and bycatch allowances for nontarget species. This is
already being done for most fish and I support it.
Holly: Nearly everyone agrees you can’t catch too many fish
year in and year out without negative consequences. Worldwide and especially
here in the United States, science-based total allowable catch limits (that
include bycatch) have proven to be the most effective way to avoid catching too
many fish. That approach is the foundation of sustainable fisheries management.
Very often during the past several decades, commercial fisheries have exceeded
their quota, or total allowable catch, without consequence. Past fishery
management measures proved ineffective. Fishing pressure increased, and
technology made it easier to find fish, successfully target them, and travel
farther offshore safely. As a result, 10 species in the South Atlantic were
being caught faster than they could reproduce -- the highest number of
over-exploited fisheries in the United States. We are pleased the South
Atlantic Fishery Management Council has made progress in turning this around. We
will continue to work with the Council and stakeholders like you to figure out
how to refine this approach and ensure it works efficiently on the water. We all
want the same thing – abundant fish populations capable of supporting commercial
fishing jobs, recreational fishing opportunities, and a healthy, balanced ocean
ecosystem.
Chris, Idea No.
2: Remove the size limits that are
causing so much of the waste in our fisheries. We should not only be targeting
the breeding stock while leaving a truncated stock of little fish to grow slowly
as they compete for the same food source. Size limits leave the runts to pollute
the gene pool and reduce the overall health of the stock as well as the average
size of the fish in it. Larger fish produce more and healthier offspring.
Holly: Years of overfishing have harmed the age structure of
some of our stocks, reducing the number of older, larger fish that often have a
much greater reproductive capacity. Management needs to address that problem. We
agree that in some cases size limits create unnecessary discards, particularly
for fish that do not survive catch and release. Red snapper are a good example
because large numbers of fish were being thrown back dead due to a high size
limit and low release survival rate. In that case, we were supportive of
removing minimum size limits for red snapper. Size limits can be harmful in
deep-water fisheries in particular because few fish survive after being caught.
There are, however, appropriate uses for size limits that can benefit the
fishery. Many fisheries occur in shallow water where most fish have high
survival rates when released. Black sea bass is a good example. In that case,
a minimum size limit is intended to allow fish to spawn at least once before
they are landed, thus preventing overfishing while causing very little discard
mortality.
Chris, Idea No.
3: The quotas should be properly
managed with split seasons and possession limits that are adjusted to levels
that fill the quotas without any long closures. The adjustments could be made
quarterly or after a predetermined amount of the seasonal quota has been caught.
We could target the fish with high limits and still keep the ones we
accidentally catch that have lower limits. This would work well for both
recreational and commercial fisheries.
Holly: Your suggestions for extending the fishing season with
split seasons, possession limits, and in-season adjustments make sense, if
implemented properly. We have urged the Council to use these approaches, both
because they extend the fishing season for fishermen, and because they help to
prevent overfishing by making the catch limits easier to monitor. In January
2012, Spanish mackerel reached 75 percent of its quota. The NMFS adjusted
possession limits in an effort to slow the fishery, avoid exceeding the catch
limit, and avert an early season closure. We agree that these approaches should
be used for more fisheries. As the new system of catch limits is implemented and
refined, we will continue to urge the Council to implement approaches like you
suggest here, as appropriate.
Chris, Idea No.
4: Removing the size limits would
allow us to harvest an entire total allowable catch. I realize there must be a
cushion that ensures the TAC is not exceeded. I suggest setting aside 10 percent
of each TAC for the less fortunate in society. Recreational fishermen could
donate any fish they did not want to eat to that quota. Commercial fishermen
could bring in everything we land. We could sell our possession limits and
donate any overages to the poor. Those fish could be distributed to soup
kitchens and food pantries across America.
Holly: We agree that if discard mortality could be eliminated
or significantly reduced, more of the annual catch limit could be available to
fishermen. We also agree that there is some merit in evaluating the ideas of
eliminating size limits and retaining all fish caught, particularly for
deep-water fisheries. These programs would be very difficult to monitor and
enforce due to the lack of observers on fishing vessels and the region’s
reliance on self-reporting. We are supportive of pilot projects that would
attempt full retention programs for species with low release survival rates,
coupled with increased monitoring to better track results.
Chris, Idea No.
5: Once the TAC of each species is
properly managed, we need to start looking at ways to enhance our resources so
we can feed even more people. Artificial reefs are the perfect union of
aquaculture and commercially or recreationally harvested wild fish. The new
reefs greatly increase the total bio-mass an area can support. They not only
help the seafood we harvest, they also help turtles, corals, and anything else
that lives on or around structure. Sandy barren bottom supports very little life
in our offshore waters. Structure creates the base of the food chain. Increasing
the amount of food and shelter available allows stocks to achieve a higher
optimum yield than even in a virgin fishery. We should be enhancing our
resources rather than restricting our freedom to access them.
Holly: We have not taken a position on artificial reefs
because the science is not conclusive. Some fish may be helped by properly
designed artificial reefs, but there is also a possibility that artificial reefs
only aggregate fish in a small area, making them more vulnerable to overfishing.
There are several recent studies on artificial reefs that may be of
interest:
Optimal number of sites in artificial pelagic multisite fisheries. R. Hilborn, P. Auger,
C. Lett, A. Moussaoui, S. Pioch. Canadian Journal of Fisheries and Aquatic
Sciences 2010, 67(2):296-303, 10.1139/F09-188.
Site fidelity, movement, and growth of red snapper: Implications for artificial reef
management. A.J. Strelcheck, J.H. Cowan Jr. 2007.
Are high densities of fishes at artificial reefs the result of habitat limitation or
behavioral preference? J.A. Bohnsack. Bulletin of Marine Science 44(2) 631-645 (15). March 1989.
A perspective of the importance of artificial habitat on the management of red
snapper in the Gulf of Mexico. R.L. Shipp, S.A. Bortone.
Red snapper management in the Gulf of Mexico: Science- or faith-based?
J.H. Cowan Jr., C.B. Grimes, W.F. Patterson III, C.J. Walters, A.C. Jones,, W.J.
Lindberg, D.J. Sheehy, W.E. Pine III, J.E. Powers, M.D. Campbell, K.C. Lindeman,
S.L. Diamond, R. Hilborn, H.T. Gibson, K. A. Rose.
Question from Pew to Chris:
We appreciate your active participation in the
management of our region’s fisheries. As a commercial fisherman, what would you
like your fishery to look like 10 years from now? Would your landings be
higher? Would you be able to target one species more heavily, or a greater
number of species? Would you be able to fish year-round?
My answer to PEW's question and one them.
Holly,
Thank you for answering my question and asking me a very good
one. I was happy to see how much we have in common. We do not have to agree on
everything to work together where we can find common ground. Please excuse the
length of my response. It will explain where I would like to see the fishery in
ten years and how we could make it happen.
Let’s start with your question about if we should be able to
target one species more heavily or spread the pressure over multiple species
throughout the entire year. We absolutely should spread the fishing pressure
out over multiple species for the entire year. There are several ways to
achieve this with very few negative impacts. Quotas should be divided among the
states based on historical landings. Each state has different water and weather
conditions that make regional management inherently unfair. Many fisheries are
being shut down before North Carolina fishermen really have a chance to work in
ideal conditions. This played a key role in the death of Alan Nelson as he was
working in bad weather before the Vermilion Snapper derby fishery was closed.
State quotas would allow seasonal openings to coincide with the best conditions
for a particular state.
The quotas should be properly managed regardless of whether they
are split among the states or remain regional. Some commercial fisheries like
the one for Vermilion Snapper have split seasons. Other fish with quotas that
are being filled quickly should also have split seasons. At this time, the
seasonal and annual quotas should be properly managed with Trip Poundage Limits
(TPLs) that are set no higher than 1,000 pounds for the first 75% of a quota.
The TPLs should be adjusted to levels that fill the quotas without any long
closures for the remaining 25%. The adjustments may not be made exactly when
75% has been caught. It would be just fine to have the adjustment after
anywhere between 70% and 80% of a quota has been filled. In addition to TPLs
for each species, there could also be a 3,000 pound aggregate trip limit for
each commercial vessel. The important part is to keep any one species from
being illegal to sell. We could target the fish with high TPLs while still
keeping the ones with lower TPLs. This is a multi-species fishery and some of
all fish will still be caught even if we cannot keep them. Fishermen are forced
to discard any illegal fish, dead or alive. This tragic waste and abuse of our
resources is almost totally avoidable if we simply MANAGE the quotas properly.
This management plan could be applied to recreational bag limits and quotas if
there was a recreational bottom fish permit established and an electronic
reporting system set up for both sectors.
As much as 100% of a Total Allowable Catch (TAC) is being
allocated to dead discards of undersized fish. I can go along with Holly’s
assessment of size limits in her answer to my first question. We should remove
size limits on fish that live a majority of their lives in water deeper than 20
fathoms. All other size limits should be set at the minimum length required for
a species to breed once. The amount of Regulatory Discards increases
significantly with every inch a size limit is arbitrarily increased. I still
firmly believe the fish, fishermen, and consumers would be much better off if
fishermen were required to keep what we catch regardless of size until our
possession limits are met and count everything landed against the quotas that
would be considerably closer to the TAC without all of the dead undersized
discards. Removing size limits on fish living beyond 20 fathoms and science
based size limits on shallow-water species is a good compromise.
Now that we have limited the waste in our snapper/grouper
fisheries, we need to enhance them with Artificial Reefs. They are the perfect
union of aquaculture and commercially harvested wild seafood. There are two key
things needed to increase the amount of fish or wildlife an area can support.
Those are more food and shelter. Artificial Reefs provide both. They will
initially draw fish from other areas, but in time they will increase the total
bio-mass an area can support. Drawing fish to Artificial Reefs also eases
pressure on natural reefs and opens them up for juvenile fish. It should not
matter where we catch our fish as long as we abide by the possession limits and
quotas. The reefs would not only help the fish we target, they would also help
corals, turtles, and almost anything that lives on or around structure.
Artificial Reefs would be a great way to feed the world’s growing population
without destroying more wildlife habitat for farm land.
We are losing many of the fish houses on the water because they
do not have a dependable supply of local seafood to sell. I have suggested the
idea of Community Seafood Unloading and Processing Facilities as way to ensure
we always have a place on the water to unload our catches. The facilities could
be built in aesthetically pleasing and environmentally friendly ways with grant
money for working waterfronts and funds from the Saltonstall-Kennedy tax on
imported seafood. They could double as museums that would preserve the
commercial fishing heritage of the area they are located. Tourists could visit
the museums and also watch as local seafood is unloaded, inspected, and labeled
as Wild Caught Seafood from that state. We could develop markets for
underutilized species and use any scraps from processed seafood for things like
gourmet cat food, crab pot bait, chum, or organic fertilizer. We should be
making wise use of ever part of the seafood we harvest.
These solutions would achieve all of the honorable goals of catch
shares without the negative impacts. Catch shares have proven to destroy
independent artisanal fishermen in favor of big corporations. Catch shares
create waste by forcing fishermen to discard any fish they do not have shares
for. Catch shares are not so much a management tool as they are an allocation
tool that favors those who overfished the most while punishing those who fished
more responsibly.
This is a summary of what I would like to see our fishery look
like in ten years. I would like to see fishermen consulted about how quotas are
managed before any management measures are considered. I would like to see
fishermen have final approval of any management measures with a 2/3 majority
vote of permit holders in the effected fishery. I would like to see fishermen,
NGOs, and fishery managers work together on collecting and analyzing accurate
data to be used in credible stock assessments. I would like to see the TACs
adjusted according to those credible assessments. I would like to see the quotas
be much closer to the TACs with the removal of some size limits and science
based size limits for other fish. I would like to see the quotas properly
managed with split seasons on some species and possession limits that are
adjusted after approximately 75% of a quota has been caught to a level that
fills the quota without any long closure. I would like to see a law that
required a permit holder to work that permit for at least five years before
allowing anyone else to work it for them. I would like to see us enhance our
fisheries with Artificial Reefs rather than restricting our access with area
closures. I would like to see Community Seafood Unloading and Processing
facilities that do not compete with existing seafood markets or dealers. These
solutions would follow all Magnuson-Stevens Act mandates including the ones to
limit waste, make efficient use of our resources, and promote fishermen’s
safety at sea.
We are in the middle of a Regulatory Capture of our fisheries
that will do irreparable harm if the course of fishery management does not
change very soon. Failure to act will cause TONS of perfectly edible fish to
continue being discarded, dead or alive. Failure to act will cause more
fishermen to lose everything we have worked for and even cost some fishermen
their lives. Failure to act will make us more dependent on imported seafood
that is harvested in countries with very little if any regulation. We should be
showing other nation’s by example how they can have a responsible harvest of
wild seafood with very little waste. We should be boycotting seafood from
nations that do things like finning sharks. We should be looking at ways to
feed more people while limiting waste and protecting our resources from
overfishing. We should be trying to protect the artisanal fishermen as well as
our proud heritage and the public’s access to safe American seafood. We should
be using the centuries of collective on-the-water experience professional
fishermen would like to share rather than focusing on mostly fishery
independent data. We can do all of this if we will work together using sound
science, common sense, and remember the Golden Rule.
I am not against regulations and fully understand the need for
them. I just want regulations that have as many positive benefits as possible
and limit the negative impacts to the fish, fishermen, and consumer while
allowing stocks to achieve Optimum Yield.
My question for PEW is this.
Will PEW publicly support science based size limits set no higher
than the length required for a species to breed once as well as the use of split
seasons and possession limits to properly manage existing quotas while working
with fishermen on ways to collect and analyze accurate data to be used in
credible stock assessments?
Holly:
We support many of these ideas, Chris. I agree it’s a good idea to slow down the fishery when the majority of the quota has been reached. Trip limits in our hook and line fisheries can effectively slow the fishery down. The key is ensuring that the data collection system is improved so that fishery managers know when the quota for each species is close to being reached in time to take action. We also have supported appropriate size limits, but we look at that on a case-by-case basis.
One of the most important factors in ensuring sustainable fisheries is to take steps to protect spawning capabilities for species. That can be done in various ways, including protections for known or suspected spawning sites, limiting catch of certain species when they spawn, or setting the size limit to ensure
fish are able to reach reproductive maturity before they are caught. In fact we recently urged the Gulf of Mexico Fishery Management Council to increase the size limit for greater amberjack for precisely that reason. And we are encouraged that the South Atlantic Fishery Management Council is pursuing protections for speckled hind and Warsaw grouper that may include spawning sites.
However, we are not comfortable making a blanket commitment to supporting size limits in every case, because for some species—particularly those caught in deepwater—the bycatch mortality rate is so high that most won’t survive catch and release. In those cases, it might make more sense to have a full retention policy and look at other options to protect spawning capabilities for that species.
We also support cooperative research programs that team fishermen with trained scientists to collect needed information on the region’s fisheries, because fishermen bring a wealth of valuable, on-the-water experience and knowledge to the table. One of the main reasons we support the Congressional legislation addressing the
Saltonstall-Kennedy funds is that it would provide a stable and long-term funding source for those types of projects, as well as improved fisheries data collection and monitoring.
My response: I agree with limiting the catch of some species during spawning seasons. The key is to LIMIT the catch with low possession limits rather than total closures that create more Regulatory Discards. We need to be able to keep some of everything and target fish with higher limits because this is a multi-species fishery. I disagree with raising the size limit on Greater Amberjack because they tend to get worms in their meat as they get bigger. Very few people like eating wormy fish. Longer size limits also remove more of the breeding stock
while leaving a glut of smaller fish that grow slower as they compete for the same food source. I firmly believe that quotas should be managed with possession limits rather than size limits. The size of the fish should not matter as long as we do not exceed the quotas. That being said, I am willing to work with PEW and others on removing size limits for deep-water fish and reverting back to science-based size limits on others. Some shallow-water and pelagic fish do not tolerate being discarded very well so I agree that we need to look at this on a case-by-case basis.
PEW’s Question: We appreciate your reaching out to our staff to engage in a constructive dialogue on some current fishery management issues. Would you be supportive of the South Atlantic Fishery Management Council requiring a vessel monitoring system (VMS) for commercial snapper-grouper fishermen, as suggested at the recent Snapper-Grouper Advisory Panel meeting, to make catch data available more quickly, which could in turn be used to slow down the fishery before the annual catch limit is reached?”
My Answer: I DO NOT support any Orwellian Vessel Monitoring System (OVMS). The Snapper-Grouper Advisory Panel suggested ALL recreational and commercial fishing vessels in federal waters be required to have an OVMS. I agree with the AP that if one minority group is forced to have OVMS and pay the monthly spy fine, that law should violate the privacy, freedom, and Constitutional Rights of all user groups equally. Electronic reporting of recreational and commercial catches within three days of a trip would achieve the goal of collecting catch data more quickly. This would eliminate the South Atlantic Fishery Management Council’s (SAFMC) excuse of lag time in data for not adjusting possession limits after 75% of a quota has been landed. The reduced limits would make it much easier to extrapolate when each quota will be filled and help avoid overages. The other reason for forcing offshore fishing vessels to have an OVMS is to keep us out of Marine Protected Areas (MPAs). This is where we could really work together to solve several problems with one good solution. I would like to see NGOs, NMFS, NOAA, private businesses, and fishermen work together on a way to build and maintain Data Collection
Platforms (DCPs) on MPAs. Some of the funding for the DCPs could come from the Saltonstall-Kennedy tax and by reallocating the millions of tax dollars NOAA is using to advance unwanted catch share schemes. The DCPs could be powered with wind, wave, solar, and tidal energy. They could have cameras under water to provide constant footage of the MPAs. Cameras above water could make sure no unauthorized vessels entered the MPAs. Both video feeds could be streamed online along with the other data. We could have thousands of viewers monitoring the MPA and charge advertisers to reach them. The DCPs would also provide mariners with a visual marker to avoid or seek as refuge in case of emergency. The DCPs would act as Artificial Reefs and increase the bio-mass each MPA could support. The SAFMC, PEW, and others have argued that Artificial Reefs only
attract fish from natural reefs. I argue that increasing the amount of food and habitat increases the amount of fish or wildlife an area can support. Think of it like this. Would 1,000 acres of land with 100 acres of forest and 900 acres of clear cut area support the same amount of wildlife as 1,000 acres covered with forest habitat and the food it provides? Maybe a good compromise would be that all new MPAs should be Artificial Reefs that create ideal habitat in the right areas to protect species like Speckled Hind and Warsaw Grouper. The Snowy
Grouper MPA off of NC is located around a shipwreck.
Everyone agrees we need better data. The 72 hour electronic reporting of every recreational and commercial fishing trip and DCPs would allow us to collect much more data in a timely manner. The hard deadlines to
end overfishing in the Magnuson-Stevens Act have been met. We need to take our time and think through our next management measures. Any rush should be to mitigate some to the severe negative impacts created by rushing to meet those hard deadlines. We need to properly manage the quotas that have been drastically reduced based on “fatally flawed data”. We need to end the total closures and work to limit the hundreds of tons of Regulatory Discards that are wasting our resources, destroying our jobs, and denying consumer’s access to
American seafood.
Please think about if you would want to be forced to buy an expensive OVMS for your car and pay some corporate or government bureaucracy every month to spy on you to make sure you obeyed the speed limits, no parking zones, and other traffic laws. There are alternatives to OVMS and ways to solve most problems without restricting freedom and violating our constitutional rights. We need to think about ways to solve problems that maximize the positive benefits and minimize the negative impacts.
My question for PEW: Will PEW work with me on a public document we can both support and present to the South Atlantic Fishery Management Council at the December meeting in North Carolina? We will have to agree to disagree on some issues but I believe we can find some common ground on others.
Thank you for answering my question and asking me a very good
one. I was happy to see how much we have in common. We do not have to agree on
everything to work together where we can find common ground. Please excuse the
length of my response. It will explain where I would like to see the fishery in
ten years and how we could make it happen.
Let’s start with your question about if we should be able to
target one species more heavily or spread the pressure over multiple species
throughout the entire year. We absolutely should spread the fishing pressure
out over multiple species for the entire year. There are several ways to
achieve this with very few negative impacts. Quotas should be divided among the
states based on historical landings. Each state has different water and weather
conditions that make regional management inherently unfair. Many fisheries are
being shut down before North Carolina fishermen really have a chance to work in
ideal conditions. This played a key role in the death of Alan Nelson as he was
working in bad weather before the Vermilion Snapper derby fishery was closed.
State quotas would allow seasonal openings to coincide with the best conditions
for a particular state.
The quotas should be properly managed regardless of whether they
are split among the states or remain regional. Some commercial fisheries like
the one for Vermilion Snapper have split seasons. Other fish with quotas that
are being filled quickly should also have split seasons. At this time, the
seasonal and annual quotas should be properly managed with Trip Poundage Limits
(TPLs) that are set no higher than 1,000 pounds for the first 75% of a quota.
The TPLs should be adjusted to levels that fill the quotas without any long
closures for the remaining 25%. The adjustments may not be made exactly when
75% has been caught. It would be just fine to have the adjustment after
anywhere between 70% and 80% of a quota has been filled. In addition to TPLs
for each species, there could also be a 3,000 pound aggregate trip limit for
each commercial vessel. The important part is to keep any one species from
being illegal to sell. We could target the fish with high TPLs while still
keeping the ones with lower TPLs. This is a multi-species fishery and some of
all fish will still be caught even if we cannot keep them. Fishermen are forced
to discard any illegal fish, dead or alive. This tragic waste and abuse of our
resources is almost totally avoidable if we simply MANAGE the quotas properly.
This management plan could be applied to recreational bag limits and quotas if
there was a recreational bottom fish permit established and an electronic
reporting system set up for both sectors.
As much as 100% of a Total Allowable Catch (TAC) is being
allocated to dead discards of undersized fish. I can go along with Holly’s
assessment of size limits in her answer to my first question. We should remove
size limits on fish that live a majority of their lives in water deeper than 20
fathoms. All other size limits should be set at the minimum length required for
a species to breed once. The amount of Regulatory Discards increases
significantly with every inch a size limit is arbitrarily increased. I still
firmly believe the fish, fishermen, and consumers would be much better off if
fishermen were required to keep what we catch regardless of size until our
possession limits are met and count everything landed against the quotas that
would be considerably closer to the TAC without all of the dead undersized
discards. Removing size limits on fish living beyond 20 fathoms and science
based size limits on shallow-water species is a good compromise.
Now that we have limited the waste in our snapper/grouper
fisheries, we need to enhance them with Artificial Reefs. They are the perfect
union of aquaculture and commercially harvested wild seafood. There are two key
things needed to increase the amount of fish or wildlife an area can support.
Those are more food and shelter. Artificial Reefs provide both. They will
initially draw fish from other areas, but in time they will increase the total
bio-mass an area can support. Drawing fish to Artificial Reefs also eases
pressure on natural reefs and opens them up for juvenile fish. It should not
matter where we catch our fish as long as we abide by the possession limits and
quotas. The reefs would not only help the fish we target, they would also help
corals, turtles, and almost anything that lives on or around structure.
Artificial Reefs would be a great way to feed the world’s growing population
without destroying more wildlife habitat for farm land.
We are losing many of the fish houses on the water because they
do not have a dependable supply of local seafood to sell. I have suggested the
idea of Community Seafood Unloading and Processing Facilities as way to ensure
we always have a place on the water to unload our catches. The facilities could
be built in aesthetically pleasing and environmentally friendly ways with grant
money for working waterfronts and funds from the Saltonstall-Kennedy tax on
imported seafood. They could double as museums that would preserve the
commercial fishing heritage of the area they are located. Tourists could visit
the museums and also watch as local seafood is unloaded, inspected, and labeled
as Wild Caught Seafood from that state. We could develop markets for
underutilized species and use any scraps from processed seafood for things like
gourmet cat food, crab pot bait, chum, or organic fertilizer. We should be
making wise use of ever part of the seafood we harvest.
These solutions would achieve all of the honorable goals of catch
shares without the negative impacts. Catch shares have proven to destroy
independent artisanal fishermen in favor of big corporations. Catch shares
create waste by forcing fishermen to discard any fish they do not have shares
for. Catch shares are not so much a management tool as they are an allocation
tool that favors those who overfished the most while punishing those who fished
more responsibly.
This is a summary of what I would like to see our fishery look
like in ten years. I would like to see fishermen consulted about how quotas are
managed before any management measures are considered. I would like to see
fishermen have final approval of any management measures with a 2/3 majority
vote of permit holders in the effected fishery. I would like to see fishermen,
NGOs, and fishery managers work together on collecting and analyzing accurate
data to be used in credible stock assessments. I would like to see the TACs
adjusted according to those credible assessments. I would like to see the quotas
be much closer to the TACs with the removal of some size limits and science
based size limits for other fish. I would like to see the quotas properly
managed with split seasons on some species and possession limits that are
adjusted after approximately 75% of a quota has been caught to a level that
fills the quota without any long closure. I would like to see a law that
required a permit holder to work that permit for at least five years before
allowing anyone else to work it for them. I would like to see us enhance our
fisheries with Artificial Reefs rather than restricting our access with area
closures. I would like to see Community Seafood Unloading and Processing
facilities that do not compete with existing seafood markets or dealers. These
solutions would follow all Magnuson-Stevens Act mandates including the ones to
limit waste, make efficient use of our resources, and promote fishermen’s
safety at sea.
We are in the middle of a Regulatory Capture of our fisheries
that will do irreparable harm if the course of fishery management does not
change very soon. Failure to act will cause TONS of perfectly edible fish to
continue being discarded, dead or alive. Failure to act will cause more
fishermen to lose everything we have worked for and even cost some fishermen
their lives. Failure to act will make us more dependent on imported seafood
that is harvested in countries with very little if any regulation. We should be
showing other nation’s by example how they can have a responsible harvest of
wild seafood with very little waste. We should be boycotting seafood from
nations that do things like finning sharks. We should be looking at ways to
feed more people while limiting waste and protecting our resources from
overfishing. We should be trying to protect the artisanal fishermen as well as
our proud heritage and the public’s access to safe American seafood. We should
be using the centuries of collective on-the-water experience professional
fishermen would like to share rather than focusing on mostly fishery
independent data. We can do all of this if we will work together using sound
science, common sense, and remember the Golden Rule.
I am not against regulations and fully understand the need for
them. I just want regulations that have as many positive benefits as possible
and limit the negative impacts to the fish, fishermen, and consumer while
allowing stocks to achieve Optimum Yield.
My question for PEW is this.
Will PEW publicly support science based size limits set no higher
than the length required for a species to breed once as well as the use of split
seasons and possession limits to properly manage existing quotas while working
with fishermen on ways to collect and analyze accurate data to be used in
credible stock assessments?
Holly:
We support many of these ideas, Chris. I agree it’s a good idea to slow down the fishery when the majority of the quota has been reached. Trip limits in our hook and line fisheries can effectively slow the fishery down. The key is ensuring that the data collection system is improved so that fishery managers know when the quota for each species is close to being reached in time to take action. We also have supported appropriate size limits, but we look at that on a case-by-case basis.
One of the most important factors in ensuring sustainable fisheries is to take steps to protect spawning capabilities for species. That can be done in various ways, including protections for known or suspected spawning sites, limiting catch of certain species when they spawn, or setting the size limit to ensure
fish are able to reach reproductive maturity before they are caught. In fact we recently urged the Gulf of Mexico Fishery Management Council to increase the size limit for greater amberjack for precisely that reason. And we are encouraged that the South Atlantic Fishery Management Council is pursuing protections for speckled hind and Warsaw grouper that may include spawning sites.
However, we are not comfortable making a blanket commitment to supporting size limits in every case, because for some species—particularly those caught in deepwater—the bycatch mortality rate is so high that most won’t survive catch and release. In those cases, it might make more sense to have a full retention policy and look at other options to protect spawning capabilities for that species.
We also support cooperative research programs that team fishermen with trained scientists to collect needed information on the region’s fisheries, because fishermen bring a wealth of valuable, on-the-water experience and knowledge to the table. One of the main reasons we support the Congressional legislation addressing the
Saltonstall-Kennedy funds is that it would provide a stable and long-term funding source for those types of projects, as well as improved fisheries data collection and monitoring.
My response: I agree with limiting the catch of some species during spawning seasons. The key is to LIMIT the catch with low possession limits rather than total closures that create more Regulatory Discards. We need to be able to keep some of everything and target fish with higher limits because this is a multi-species fishery. I disagree with raising the size limit on Greater Amberjack because they tend to get worms in their meat as they get bigger. Very few people like eating wormy fish. Longer size limits also remove more of the breeding stock
while leaving a glut of smaller fish that grow slower as they compete for the same food source. I firmly believe that quotas should be managed with possession limits rather than size limits. The size of the fish should not matter as long as we do not exceed the quotas. That being said, I am willing to work with PEW and others on removing size limits for deep-water fish and reverting back to science-based size limits on others. Some shallow-water and pelagic fish do not tolerate being discarded very well so I agree that we need to look at this on a case-by-case basis.
PEW’s Question: We appreciate your reaching out to our staff to engage in a constructive dialogue on some current fishery management issues. Would you be supportive of the South Atlantic Fishery Management Council requiring a vessel monitoring system (VMS) for commercial snapper-grouper fishermen, as suggested at the recent Snapper-Grouper Advisory Panel meeting, to make catch data available more quickly, which could in turn be used to slow down the fishery before the annual catch limit is reached?”
My Answer: I DO NOT support any Orwellian Vessel Monitoring System (OVMS). The Snapper-Grouper Advisory Panel suggested ALL recreational and commercial fishing vessels in federal waters be required to have an OVMS. I agree with the AP that if one minority group is forced to have OVMS and pay the monthly spy fine, that law should violate the privacy, freedom, and Constitutional Rights of all user groups equally. Electronic reporting of recreational and commercial catches within three days of a trip would achieve the goal of collecting catch data more quickly. This would eliminate the South Atlantic Fishery Management Council’s (SAFMC) excuse of lag time in data for not adjusting possession limits after 75% of a quota has been landed. The reduced limits would make it much easier to extrapolate when each quota will be filled and help avoid overages. The other reason for forcing offshore fishing vessels to have an OVMS is to keep us out of Marine Protected Areas (MPAs). This is where we could really work together to solve several problems with one good solution. I would like to see NGOs, NMFS, NOAA, private businesses, and fishermen work together on a way to build and maintain Data Collection
Platforms (DCPs) on MPAs. Some of the funding for the DCPs could come from the Saltonstall-Kennedy tax and by reallocating the millions of tax dollars NOAA is using to advance unwanted catch share schemes. The DCPs could be powered with wind, wave, solar, and tidal energy. They could have cameras under water to provide constant footage of the MPAs. Cameras above water could make sure no unauthorized vessels entered the MPAs. Both video feeds could be streamed online along with the other data. We could have thousands of viewers monitoring the MPA and charge advertisers to reach them. The DCPs would also provide mariners with a visual marker to avoid or seek as refuge in case of emergency. The DCPs would act as Artificial Reefs and increase the bio-mass each MPA could support. The SAFMC, PEW, and others have argued that Artificial Reefs only
attract fish from natural reefs. I argue that increasing the amount of food and habitat increases the amount of fish or wildlife an area can support. Think of it like this. Would 1,000 acres of land with 100 acres of forest and 900 acres of clear cut area support the same amount of wildlife as 1,000 acres covered with forest habitat and the food it provides? Maybe a good compromise would be that all new MPAs should be Artificial Reefs that create ideal habitat in the right areas to protect species like Speckled Hind and Warsaw Grouper. The Snowy
Grouper MPA off of NC is located around a shipwreck.
Everyone agrees we need better data. The 72 hour electronic reporting of every recreational and commercial fishing trip and DCPs would allow us to collect much more data in a timely manner. The hard deadlines to
end overfishing in the Magnuson-Stevens Act have been met. We need to take our time and think through our next management measures. Any rush should be to mitigate some to the severe negative impacts created by rushing to meet those hard deadlines. We need to properly manage the quotas that have been drastically reduced based on “fatally flawed data”. We need to end the total closures and work to limit the hundreds of tons of Regulatory Discards that are wasting our resources, destroying our jobs, and denying consumer’s access to
American seafood.
Please think about if you would want to be forced to buy an expensive OVMS for your car and pay some corporate or government bureaucracy every month to spy on you to make sure you obeyed the speed limits, no parking zones, and other traffic laws. There are alternatives to OVMS and ways to solve most problems without restricting freedom and violating our constitutional rights. We need to think about ways to solve problems that maximize the positive benefits and minimize the negative impacts.
My question for PEW: Will PEW work with me on a public document we can both support and present to the South Atlantic Fishery Management Council at the December meeting in North Carolina? We will have to agree to disagree on some issues but I believe we can find some common ground on others.
