NOAA National Saltwater Recreational Fisheries Policy

The National Oceanic and Atmospheric Administration is in the process of overhauling it recreational fishing policies. Stripers Forever sees this as an opportunity to create a new national policy that will guide and improve local fishery management decisions that have not been good for the needs or rights of recreational salt water fishermen.

Here are Stripers Forever’s comments to NOAA:

Stripers Forever, a conservation and recreational advocacy organization focused on striped bass along the East Coast offers the following comments on NOAA recreational fishing policy.

NOAA must stand up in the fishery management process for recreational fishing.  On a local basis it is very difficult for recreational fishing to get the consideration it is due because commercial fishing has historically been seen as the more important use of the resource.  Politicians are very slow to take new and forward thinking positions that they do not thoroughly understand, and these politicians control the appointment process for all aspects of local fishery management.

The federal government often has a different view of wildlife management than the states because it is not as easily controlled by small segments of the public.  The history of waterfowl management provides one of the clearest examples of how the influence of the federal government was needed to change the fishery management practices within the states.   Action by the federal government could now be very important in improving recreational fishing opportunities, and this would overall be very beneficial.

There are a number of strong justifications for giving a great deal more consideration to recreational fishing than it currently receives.

I.  Issues that justify greater allocations and management consideration for recreational fishing.

A.  Personal Use Allocations

SF sees recreational fishing as members of the public directly accessing for their own personal use and enjoyment a resource that all citizens have an equal right to.  The precedents are clear in wildlife management that this individual right has the highest primacy when compared to other harvesting.

In many cases today we see commercial fishing quotas taking such a bite out of a scarce resource that a reasonable personal use harvest is not possible, and this is simply wrong.  NMFS should stand up for the rights of individual citizens to have a fair harvest allocation before commercial fishing harvests the surplus – if in fact there is any surplus.

B.  Conservation

Because of the comparatively inefficient and non-invasive equipment used by recreational fishers they do not take large percentages of a fish population from a defined area at any one time.    Recreational equipment also tends to be far less harmful to the environment than commercial gathering techniques such as bottom dragging, nor does it cause ghost fishing issues that take place with the use of gill nets.  Also, because there is no profit motive fishing will generally not occur beyond taking the bag limit.  The greater conservation values in recreational fishing activity when compared to commercial fishing should be recognized and supported.  If, for instance, a fishery or a fishing location cannot support commercial fishing activity recreational activities should not be automatically banned just because commercial fishing activities are not appropriate.

C.  Economics

In most or perhaps all fisheries that are participated in by recreational anglers the public benefits by receiving a greater amount of economic activity than if the same fish were taken by commercial fishing.  There is no justification for harvesting the fish commercially if it generates less economic activity than would be available through recreational fishing.  In spite of rhetoric about providing seafood for people, all commercial harvest does when confronted with a limited resource is to take fish away from those willing to harvest their own and sell them to someone else.  No additional seafood can be created, and less economic activity and jobs are produced in the process.

D.  Social Benefits

The great American conservationist Gifford Pinchot said:  “Conservation is the foresighted utilization, preservation and/or renewal of forests, waters, lands and minerals, for the greatest good of the greatest number for the longest time.”  Surely our continued management of fish to fulfill the desires of the small number of people within the commercial fishing industry provides benefits for less people than a recreational fishery with many times the participants.  For those fish enjoyed by recreational fishing it is obvious that the greatest social benefits can be achieved by optimizing the populations of those species to get the most public participation in the fishery.

E.  Right Thing To Do

It is obvious to all thinking individuals that we should not destroy our populations of ocean fish, yet that is exactly what we have done.  Commercial fishing interests have been able to leverage local politicians and on up the political ladder to have the greatest influence of any user group on the fishery management process.  The result has been the essential destruction of our marine fish populations.  Clearly these practices have to end and we need to rebuild our fishery populations.  It will not be possible to do this and manage them allowing as much commercial harvest as we have in the past.  NOAA has the ability to greatly influence the fishery management process for the better by adopting and promoting policies that recognize the rights of recreational anglers and the benefits of recreational salt water angling.  Typically local fishery management has no guiding policies of any kind, and NOAA’s policies will become the benchmark.

II.   Additional issues that must be addressed to improve recreational fishing experiences and enjoy the associated benefits.

1. “Willingness to Pay (WTP)” must be replaced with some other more practical allocation metric – one that the managers can understand and apply today.  The fact that each individual recreational participant is a citizen with equal rights to all others must be recognized.
2. Minimum standards for recreational fisheries must be established – a hard catch per unit effort (CPUE) should be set where possible to ensure an acceptable probability of catching a fish.
3. Abundance must be evaluated in terms of the minimum catch per unit effort established for a “successful” recreational fishery in recognition of the fact that it takes more fish to have a successful recreational fishery.  For fisheries participated in by recreational anglers it must be formally recognized that maximum sustainable yield (MSY) is not an appropriate concept.
4. Better effort data must be continuously collected for the recreational fishery. MRFSS and MRIP have been relied on for years, not because they provided the best data but because they were easiest to implement.
5. Recreational participation in the management process at the council and commission level must be increased. These venues are traditionally saturated by commercial interests. For many jurisdictions, there is essentially very little recreational representation at the ASMFC.
6. We need to stop hiding behind phrases like “fair and equitable,” and words like “reasonable” that are poorly defined in the context of fisheries. The federal recreational fisheries policy should either stop using these terms or give them some teeth in practical terms that can influence policies. When the law says that allocation policies shall “Not permit a particular individual, corporation, or other entity to acquire an excessive share of fishing privileges,” what does the word “excessive” mean?

Sincerely:

Brad Burns President of Stripers Forever

You also have the right to make your own comments. Here is the link to where you can do that on your own.

If we don’t speak up we will be ruled by those who do. Let your opinions be known.