The National Marine Fishery Service has published the public comment draft (link) of many months of work by NMFS to formulate a recreational fishing policy that will guide the department’s future actions regarding saltwater recreational fishing including regulation making. There are further links on the page that will take you to the pdf draft policy [recfish_policy_public_comment_draft] and also that enable you to send in any comments that you may have. The comments sent in by Stripers Forever’s appear at the end of this broadcast. We urge you to read the draft policy as well as SF’s comments, then to submit your own comments. The more recreational anglers and industry people they hear from the more motivated they assume our constituency is, and that can only help us down the road.

In general we agree with what they say. NMFS states that they “recognize the important social, cultural, and economic benefits associated with saltwater recreational fishing, and are committed to pursuing a collaborative stewardship approach promoting public access, fishery accountability, and regulatory enforcement.” The question is just how this philosophy will be transferred into NMFS actions in how they treat areas like exploitation versus conservation, resource allocation, and regulations that do affect recreational fishing opportunities such as seasons, closed areas etc. The record in the past has had mixed reviews as have the agency’s votes from their seat on the Atlantic States Marine Fisheries Commission.

NMFS defines in this document the recreational fishing community as containing “the businesses and industries, such as the for-hire fleet and tournaments, which support them.” This an important statement since SF believes that the guiding and charter boat industry is an important part of public recreational fishing and not a separate category to be lumped in with commercial fishing. Those desiring to continue past commercial sovereignty over the ocean regulatory process have tried to weaken the recreational fishing constituency by driving a regulatory wedge between for hire boats and anglers fishing on their own. SF has fought to stop this from happening. We believe that guides, head boats and charter boats exist to enable individual members of the public to access and enjoy the public fishery resources.

Brad Burns President, Stripers Forever and Ken Hastings ASMFC Policy Coordinator, Stripers Forever

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Stripers Forever Comments on the draft NMFS Recreational Fishing Policy

We have read the draft NMFS recreational fishing policy statement, and we applaud the formal recognition by NMFS of the socio economic value of recreational fishing, the rights of the public to access this resource, and the fact that the guiding and charter industry are not elements of commercial fishing, but rather enablers of recreational fishing access.

Our concern is that we do not see any evidence of commitment on the part of NMFS to make sure that these declared values are given the appropriate weight in management decisions that NMFS may participate in.  Mr. Sam Rauch of NMFS moderated a workshop at the Summer 2014 Atlantic States Marine Fisheries Commission meeting where he candidly discussed some perceived inadequacies in fisheries management that would be addressed by the new policy. In particular, he singled out the subject of allocation between stakeholder groups as an example of a policy “rusted in place” and in need of updating. The website announcing the policy update process promised direction in making the hard decisions that appears to be absent from the draft document.

The challenges regarding allocation described in the National Standards section of the Magnuson Act suffer from the lack of direction more than some other aspects of the Act. For example, consider the statement regarding allocation that says: “If it becomes necessary to allocate or assign fishing privileges among various United States fishermen, such allocation shall be (A) fair and equitable to all such fishermen; (B) reasonably calculated to promote conservation; and (C) carried out in such manner that no particular individual, corporation, or other entity acquires an excessive share of such privileges.”

Instead of addressing these obviously subjective descriptions of lofty goals, NOAA has concentrated on technical reports describing how economics theory might provide the guidance for maximizing the socio-economic “value” of our fisheries. Between 1990 and 2012 there have been repeated attempts to get traction with this approach, all of which have failed because these concepts have never been developed into a clear policy that is applied to fishery management decisions.

The Executive Order signed by President Clinton in 1993 directed fisheries managers to rely on economic “Net National Benefits” to drive management decisions. Twenty-two years later, a decade-long debate over decreasing striped bass abundance has terminated in a new addendum to the Fisheries Management Plan without ever mentioning “Net National Benefits” or any of the goals established by the National Standards. In fact the debate and decision process degenerated into the age old struggle pitting the financial desires of the current harvesters against what would truly provide the greatest benefit to the most people.

If the job of NOAA is to help ensure that fisheries managers adhere to Magnuson, then we need stronger, clearer policy documents to bridge the gap between lofty goals in the Act and the real world.