Recreational Fishing Alliance
176-B South New York Road
Galloway NJ 08205
Phone  (609) 404-1060 - Fax (609) 404-1968

December 22, 2005

Robin Riechers, Chairman                                                                                                                                   

Gulf of Mexico Fishery Management Council
2203 N. Lois Avenue, Suite 1100
Tampa, Florida 33607
813 348-1711 fax

Dear Chairman Reicher:

 Recreational Fishing Alliance (RFA) is a national 501(c)(4) non-profit grassroots political action organization whose mission is to safeguard the rights of saltwater anglers, protect marine, boat, and tackle industry jobs, and ensure the long-term sustainability of our nation’s marine fisheries. The RFA has a membership and affiliate network of over 80,000 saltwater anglers, marine manufactures/retailers, scientists, and other outdoor enthusiasts. On behalf of our membership, I respectfully request that the Gulf of Mexico Fishery Management Council (Council) include a formal and thorough discussion of proposed actions that will address adjusting recreational red snapper size and bag limits in Reef Fish Amendment 27/Shrimp Amendment 14. We believe the current management of the fishery fails to meet the requirements of federal law on several levels. We cite these failures as supporting our request to analyze recreational red snapper size and bag limits in these Amendment proceedings.

 Without a doubt, red snapper is one of the most important species in the Gulf of Mexico and the nation. The recreational red snapper fishing sector includes individual anglers, party and charter boat businesses, boat builders, fishing tackle manufacturers, bait and tackle retailers, marinas, and many other businesses in the fishing community. On average, 480,000 recreational fishing trips in the Gulf are directed towards red snapper per year. While it is difficult to determine the exact value of the recreational red snapper fishery, it accounts for a significant portion of the $3.3 billion spent annually by 6.8 million recreational anglers in the Gulf States. This fishery is also a major component of the Gulf tourism industry, as over 47 percent or 3.2 million anglers that fish in the Gulf are from out-of-state. The cumulative impact of both in- and out-of-state anglers’ expenditures for red snapper fishing is a significant input in the regional economy. A loss or reduction in this fishery does not go unfelt.

 For these reasons, it is absolutely paramount that the management of red snapper be attentive of the fishery’s needs, is conservation minded, and efficient. As you are aware, the Magnuson-Stevens Fishery Conservation and Management Act (Magnuson), Public Law 94-265, outlines standards that the fisheries management process must follow to ensure the above mentioned criteria are considered. After reviewing current scientific literature and SEDAR reports, in addition to discussions with industry leaders, it is clear that the current red snapper management fails to provide the greatest overall benefit to the nation and that many of the Magnuson standards are not being met. Our analysis is outlined below.

 National Standard 5, Sec. 301 (a)(5), mandates that conservation and management measures shall consider efficiency, where in efficiency is defined to include minimizing waste. Throughout the history of red snapper management waste in the form of regulatory discard has always been an issue. The recreational red snapper fishery is regulated via fishing seasons and minimum legal size and bag limits to control the sector’s impact on the stock. The undesirable side-effect of these controls is regulatory discarding. Regulatory discarding is a wasteful practice that serves no public interest and results in negative economic impacts to party and charter boat businesses, boat builders, fishing tackle manufacturers, bait and tackle retailers, marinas, and many other businesses are all part of fishing communities. Numerous scientific papers have identified bag and size limits as a source of discard mortality in the recreational fisheries. Discards occurring in the recreational red snapper fishery account for a significant portion (65%-85% over the last ten years) of the total catch. The ratio of discard to catch has steadily increased since the inception of the MRFSS program in 1981. Current estimates for 2004 indicated a Gulf discard to catch ratio of 0.66. The ratio of discard to harvest is even higher, approximately, 1.95 for the 2002-2004 time series.

 While the scientific community has becomes better at assessing fish stocks, these improvements have not been conveyed to the management side of this particular fishery. The level of discarding represents a failure to improve efficiency in this fishery. Noting this trend, it should be apparent that the current recreational size and bag limits should be reconsidered as they serve are potentially serving as obstacles to achieving greater efficiency. It should be a priority of the Gulf Council to examine ways to improve this inefficient management of the recreational red snapper fishery in the above referenced amendments.

 National Standard 4, Sec. 301 (a)(4), instructs that conservation and management measures shall be (A) fair and equitable to all fishermen. Reef fish Amendment 27/Shrimp Amendment 14 will deal with adjustments to the commercial minimum size limits. This reflection was initiated by recent analysis that found that commercial minimum size limits may be ineffective in meeting conservation goals. By excluding the recreational sector from these discussions, these amendments hold preference for commercial red snapper fishermen and therefore, are not consistent with National Standard 4. It would, however, be equitable if the same analysis were performed on the current recreational size and bag limits. Under the current system, the recreational harvest is predicted at the beginning of the fishing season and operates without in-season adjustment. Compared to commercial landings that can be very closely monitored and stopped when a quota is reached, the recreational performance is not typically known until the season has come to an end. Therefore, discards must be estimated and factored into the total allowable catch at the beginning of the year. As discussed in the above section, discards continue to remain a substantial portion of the allowable landings.

 The level of discarding attributed to recreational anglers, coupled with the discard mortality rate, results in a greater portion of allowable recreational landings being taken up by unharvested mortality. This situation results in negative social and economic impacts for party and charter boat businesses, boat builders, fishing tackle manufacturers, bait and tackle retailers, marinas, and many other businesses are all part of fishing communities, in addition to lower quality of life for the individual angler. When discarding reaches levels currently being experienced, the dissatisfaction within the fishery should automatically trigger the Council to perform an analysis similar to that being done for the commercial minimum size limit. It would seem that more pressing to managers to perform this analysis for the recreational fishery since this fishery has the potential to be more open ended in terms of annual outcome. Converting discard mortality to landings is very desirable for both commercial and recreational fishermen and it is only fair to address this issue in both fisheries.

 National Standard 2, Sec. 301 (a)(2), states that conservation and management measures shall be based upon the best scientific information available. Red snapper is currently managed as a single Gulf stock. Research has shown variations in growth rate parameters, genetic markers and otolith microchemistry between red snapper sampled from the western Gulf to those sampled from the Eastern Gulf. In addition, the average depth of red snapper catch is significantly deeper in the western Gulf compared to depth of catch in the eastern Gulf. According to numerous SEDAR reports, this depth difference produces different discard mortality rates for the two regions. As more evidence emerges, managing Gulf of Mexico red snapper as a single stock may not be appropriate.

 Discussions with recreational red snapper stakeholders also support the assertion that improvements could be made if red snapper were managed as two stocks throughout the Gulf. Anglers have reported that the mean red snapper catch length frequencies vary markedly between the east and west ends of the Gulf. Industry members also indicate the season is not compatible with actual demand, which too varies throughout the year in the Gulf. We request the Council acknowledges these points and initiates in depth analysis about the potential of managing the red snapper as two separate stocks during the amendment process.

 National Standard 9, Sec. 301 (a)(9), mandates that conservation and management measures shall minimize bycatch and minimize mortality associated with bycatch. Discarding in the recreational red snapper fishery is at unprecedented levels spurred by regulations. Nearly 70 percent of all caught red snapper are discarded. In Texas for example, mortality associated with discarding made up just under a third of the total red snapper harvest for that state. Gulf wide, over 2 million red snapper are discarded and the trend over the last decade indicates a continued increase in this number.

 Clearly, the management of the recreational component of this fishery is not working. It is our request that the Council explore alternative regulations that will reduce regulatory discards. Preliminary analysis done using Gulf-wide recreational catch data indicates that a scenario such as keeping the first 5 fish then stopping fishing has the potential to lower discard rates. Such alternatives may also have the benefit of spreading harvest over a broad range of age classes and have the potential to extend the recreational season, possibly even to 12 months. A longer recreational red snapper season, promulgated from reduced mortality associated with regulatory discarding, would be a tremendous benefit to the fore-hire sector that desperately needs the ability to fish for red snapper in the winter months. Both aspects will improve angler satisfaction and allow industry members to conduct their businesses more efficiently.

 Additionally, reducing regulatory discards and converting them to landings would improve the overall red snapper stock assessment. Discards, as reported through MRFSS, carry a greater chance of error as they are reported from recollection as opposed to recording a physical landing. Discards have been identified as a source of limited confidence in red snapper stock assessments. By reducing regulatory discards, our understanding of the stock and our ability to meet management goals increases.

 For all of the foregoing reasons, we request the Council to include discussion of adjustments to recreational red snapper size and bag limits in Reef Fish Amendment 27/Shrimp Amendment 14. I believe we have cited sufficient problems with the currently recreational red snapper management to justify our request.

Respectfully submitted,

James A. Donofrio
Executive Director