Sportfishing Coalition's Letter to NOAA

[Hoo Nose]

It looks like a few other organizations are offering some thoughts on MSA.

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February 23, 2010

Jane Lubchenco, Ph.D.
Administrator
National Oceanic and Atmospheric Administration
1401 Constitution Avenue, NW
Washington, DC 20230

Dear Dr. Lubchenco:

Given the impending breakdown of recreational saltwater fisheries management in this country, the
nation’s recreational fishing and boating community urges you to take immediate action within your
administrative authority to address the severe, and escalating, restrictions on recreational saltwater
fishing. We ask that you:
• Take decisive, immediate action to improve recreational fisheries data by redirecting existing
funds and personnel to focus on real-time management data.
• Collect socio-economic data on recreational fishing in the communities most likely to be
impacted by near-term or expected fisheries closures.
• Provide federal-level direction to the fishery management councils to use common-sense in their
management approaches while the administration collects the requisite data to make sound
management decisions.

Following decades of inadequate data collection, stock monitoring and assessment, we believe that the
recent closure of the South Atlantic red snapper fishery and the proposed closure of over 12,000 square
miles to all fishing from 98 feet to 300 feet, is the tipping point of what we view as a fisheries
management “train wreck” that calls for immediate administrative and fiscal action.

At stake are more than 500,000 jobs that depend on recreational saltwater fishing and $250 million a
year in excise tax and fishing license revenue which provide substantial funding for coastal states’
fisheries management programs and an outdoor recreational activity supported by 94 percent of the
American public.

The foundation of the sportfishing industry and the broader sportfishing community is sound fisheries
management that results in public access to sustainable fisheries. From the industry’s continuing
support of the federal manufacturers’ excise tax, which constitutes the cornerstone of the states’
fisheries programs, to myriad actions that promote and support essential habitat programs, to efforts
that maintain and increase access to fishable waters; America’s sportfishing community has steadfastly
approached conservation challenges and opportunities in a deliberate and collaborative fashion.

Saltwater recreational fishing has increased in popularity in recent years as people migrate to the
nation’s coastal areas. As you know, unlike most freshwater resources where the states have full
authority for fisheries management, saltwater fisheries management is a shared responsibility between
the National Oceanic and Atmospheric Administration’s (NOAA) National Marine Fisheries Service
(NMFS) and state agencies. Over the years, while state natural resource agencies have enhanced their
fisheries and angler data, NMFS has done little to improve recreational fishing angler and stock
assessment data. It is so “data poor” that the U.S. Commission on Ocean Policy has called for a
substantial investment in fisheries data and stock assessments. Further, in 2006 the National Academy



Dr. Jane Lubchenco
February 23, 2010
Page 2

of Science’s National Research Council called the Marine Recreational Fisheries Statistics Survey
conducted by NMFS “fatally flawed.”

As required by the 2006 reauthorization of the Magnuson-Stevens Fishery Conservation and
Management Act (MSA), NMFS has increased the regulatory measures applied to recreational fishing
but has yet to measurably improve either the data collection or its basic understanding regarding
recreational saltwater fishing. This is despite repeated requests by the recreational fishing community
to improve important recreational fishing data, such as fishery independent stock assessments for key
species, angler catch data and economic data. We respectfully assert that the agency simply does not
have the tools to successfully manage recreational fisheries as envisioned by the Magnuson-Stevens
Act.

According to NMFS and the regional fishery management councils, the only option available to them
and the regional fisheries councils is to close fisheries, thereby eliminating recreational fishing
opportunities and jobs. The January 2010 Atlantic red snapper fishery six-month interim closure, on the
heels of the first stock assessment in 10 years, is only one example of what is a looming fisheries
management “train wreck.” Mandated annual catch share limits for the Gulf of Mexico reef fish complex
is another example; more than 30 of the 44 species found there have never been assessed and basic
biological information is lacking. Along with black sea bass, summer flounder, South Atlantic and Gulf
Grouper, amberjack and other fisheries, these are prime examples of NMFS’s inability to reconcile
inadequate data collection, stock monitoring and infrequent stock assessments which the Magnuson-
Stevens Act mandates.

The recreational fishing industry is faced with massive fisheries closures, and the attendant job loss,
because the appropriate investment in recreational fishery economics data and angler catch data has
not been made. In addition, stock assessments for recreationally important species have been a lower
priority for NMFS than is justified by the economic contribution of the recreational fishing community.
Recreational fishing accounts for only three percent of the marine finfish harvested by weight, yet it
produces 56 percent of the jobs from all saltwater fisheries. Unquestionably marine recreational fishing
is a coastal economic engine that deserves an investment commensurate with the jobs and economic
output it provides to the nation, not to mention the millions of hours of recreation it provides to 13
million saltwater anglers who have an $83 billion impact on the nation’s economy. The agency needs to
focus on the sector that has the least environmental impact but provides the largest economic return to
the nation’s economy and allocate fisheries on that basis.

We urge the implementation of measures that not only address short-term needs but also set in place a
strong and effective infrastructure for federal marine fisheries management. We have not come to
these decisions lightly or quickly. Our coalition has analyzed the challenges that face NOAA, NMFS and
marine fisheries management in general. We have considered many scenarios and we believe the
comprehensive package we are proposing is the best approach.

We look forward to the opportunity to discuss potential administrative and funding mechanisms which
include:

• Substantially increasing funding for improved recreational data and statistics programs focusing
on catch data, economics and stock assessments for each of the next five fiscal years, as well as
funding for permanent and continuing data collection and analysis.
• Creating a multi-pronged program to promote and implement angler catch-and-release
techniques that will reduce release mortality; improve fisheries conservation; and expand and
improve ethical angling practices.
• Making potential regulatory changes to provide regional fishery management councils the
authority to include adaptive management and experimental alternatives in rebuilding plans.


Dr. Jane Lubchenco
February 23, 2010
Page 3

• Developing a program within NMFS to assist in the restoration and enhancement of a fishery and
its habitat using techniques such as artificial reefs, hatchery operations and other proven
programs.
• Expanding the required economic impact analysis of fishery management measures to include
impacts on all associated industries, such as tackle shops, manufacturers, marinas, restaurants
and other affected businesses, and require fishery management councils to adjust management
measures to mitigate for these impacts.
• Identifying and consistently implementing fishery independent stock assessment technologies
(e.g., acoustic technology, DNA tagging, underwater video and other technologies) to improve
the accuracy of stock assessments. Efforts should include a pilot project through the
Cooperative Research Program that focuses on improving data for the South Atlantic red
snapper fishery.
• Convening a blue ribbon panel with NMFS, industry, states and interested nongovernmental
organizations to identify the long-term data, statistical, research and funding needs of the
regional fishery science centers. The outcomes of this panel will help to inform the appropriation
needs related to recreational fishing data and statistics for NMFS and coastal state fishery
agencies.
• Developing a recreational fishing program and staff within NMFS that is commensurate with the
national economic contribution of recreational fishing.

These are necessary first steps that must be taken quickly to address all the challenges before us,
especially the data and science deficit and the systemic fisheries management problems. Should these
administrative remedies prove insufficient, or should NOAA be unable or unwilling to provide relief
promptly in these critical areas, then in order to address this fisheries “train wreck” and ensure that we
avoid further crashes, it will be necessary to examine those existing statutory requirements on
overfishing that cannot be reasonably met with existing data and management tools.

Dr. Lubchenco, last October during the American Sportfishing Association’s annual meeting, you stood
before the sportfishing and boating community and pledged to be our champion saying that you are
personally committed to a national policy which recognizes the importance of recreational fishing and
ensures that it can continue to thrive. Many of the proposals we submitted will require additional
appropriations from Congress, and we urge your support for our efforts.

We look forward to the opportunity to discuss these and other solutions at your earliest possible
convenience.

Sincerely,

Mike Nussman, President and CEO Jeff Angers, President
American Sportfishing Association Center for Coastal Conservation

Pat Murray, President Rob Kramer, President
Coastal Conservation Association International Game Fish Association

Thom Dammrich, President Ellen Peel, President
National Marine Manufacturers Association The Billfish Foundation


cc: The Honorable Gary Locke, Secretary, U.S. Department of Commerce
Mr. Eric Schwaab, Director, National Marine Fisheries Service

[Hoo Nose]

WASHINGTON, D.C. – February 23, 2010 – Today, a coalition of marine recreational fishing, boating, and conservation organizations and businesses called on the Obama administration to take immediate action to address a crisis within the federal fisheries management system. In a letter to National Oceanic and Atmospheric Administration (NOAA) Administrator Dr. Jane Lubchenco, the American Sportfishing Association (ASA), The Billfish Foundation (TBF), the Center for Coastal Conservation (CCC), the Coastal Conservation Association (CCA), the International Game Fish Association (IGFA), and the National Marine Manufacturers Association (NMMA) laid out an initial framework to immediately address serious and escalating problems resulting from inadequate implementation of the Magnuson-Stevens Fishery Conservation and Management Act and the chronic problems that exist within the federal marine fisheries management system.

The coalition emphasizes that there are available administrative actions that can be taken right away to address the concerns of the sportfishing and boating industries and the nation’s 13 million saltwater anglers who depend on well-managed, healthy marine fisheries. Read the full letter sent to Dr. Lubchenco here.

Given NOAA’s recent ban on recreational fishing for red snapper from North Carolina through Florida and the potential for additional bans on key recreational saltwater fisheries, much of the frustration that exists in the grassroots recreational fishing community over these management decisions has boiled over into organized protests including, one being held Wednesday, February 24, in Washington, D.C.

With today’s letter, the coalition called upon the administration to:

* Take decisive, immediate action to improve recreational fisheries data by redirecting existing funds and personnel to focus on real-time management data.
* Collect socio-economic data on recreational fishing in the communities most likely to be impacted by near-term or expected fisheries closures.
* Provide federal level direction to the fishery management councils to use common-sense in their management approaches while the administration collects the requisite data to make sound management decisions.
* Develop a recreational fishing program and staff within NMFS commensurate with the national economic contribution of recreational saltwater fishing.

The coalition’s groups look forward to working closely with the Obama administration and NOAA to implement solutions to effectively deal with our nation’s marine fisheries resources.

Below are comments made today by the coalition’s group leaders:

American Sportfishing Association
Mike Nussman, President and CEO
"We support healthy fisheries and good fishery management. It's good for anglers, our business and our economy. We’ve developed common-sense administrative and appropriations proposals that address the need for timely, accurate data while preserving efforts to rebuild our marine fisheries. We see these as a starting point for actions that must be implemented to address the short and long term problems.”

“Unfortunately, what we are seeing now is crisis management rather than fisheries management and this must stop before more jobs are lost and more of the nation’s recreational anglers are unnecessarily shut out.”

The Billfish Foundation
Ellen Peel, President
“Stock assessments for recreationally important species have been a lower priority for NMFS than is justified by the economic contribution of the recreational fishing community. Recreational fishing accounts for only three percent of the marine finfish harvested by weight, yet it produces 56 percent of the jobs from all saltwater fisheries.”

The Center for Coastal Conservation
Jeff Angers, President
“The groups represented in this effort are demanding conservation-oriented measures that deliver the best possible opportunity not only for America’s anglers and the businesses that depend on them, but also for America’s marine resources to achieve their fullest potential. We expect to see the same commitment from NMFS.Their failure to do so has led to the current crisis of confidence and is threatening to bring the entire system to a standstill.”

The Coastal Conservation Association
Pat Murray, President
"There is a great deal of frustration among recreational anglers, much of it attributable to an agency that doesn't have the data, the science orthe will to properly manage us. Recreational anglers have always been willing to do what is right to maintain healthy marine resources, but it is hard to have faith in many of the management measures we are seeing out of NMFS right now. There is a better path than the one they are on."

International Game Fish Association
Rob Kramer, President
“We must deal with the unintended consequences of the 2006 Magnuson-Stevens Act reauthorization. We hope that our recommendations will help to get this agency, on which 13 million recreational saltwater anglers depend, back on track.”

National Marine Manufacturers Association
Thomas J. Dammrich, President
“NOAA Fisheries’ severe restrictions on recreational fishing are a direct result of the agency’s failure to collect important data on these fisheries, including the impacts of recreational fishing and boating. Unless NOAA takes quick and decisive action to improve its data and management of recreational fisheries, these large-scale closures will drive down boat sales and negatively impact U.S. marine industry jobs.”

[Hoo Nose]

All this talk about the Rally, but no one has anything to say about what 6 major organizations are doing to support us?

[Free_Jumper]

Hoo Nose,

Sport Fishing Forums > SportFishermen.com's General Forums > Mix It Up & Introductions > Fishing Regulations
Fishing industry leaders petition administration to fix mismanagement

I liked the letter - I'm sending to my elected officials endorsing the contents and the refocusing of NMFS efforts.

From the letter - “Many of the proposals we submitted will require additional

appropriations from Congress, and we urge your support for our efforts.”

TO GET $$$ REPROGRAMMED NEEDS VOTER CONCERN to be voiced.

[Topaz Fisherman]

This is a very impressive group/coalition. I too like what this letter says. Thank you for posting it Hoo Nose.

[Russell A. Jost]

Feb.24th in DC would have been increditble if these 5 organizations had supported it and put there fullforce and memberships behind the rally. Instead they choose to go their on route. Anyone know why? Was there some political reason? They certainly could have still sent the above letter.