Ed. Note : This is a letter from the CSC to the Gulf of Mexico Fisheries
Management Council in regards to Amendment 40 and Sector Separation.
October 20, 2014
Kevin Anson, Chairman Gulf of Mexico Fisheries Management Council 2203 North Louis Avenue Suite 1100 Tampa, Florida 33607
RE: Reef Fish Amendment 40 – Sector Separation for the Recreational Red Snapper Fishery
Dear Chairman Anson:
As leaders and members of the Congressional Sportsmen’s Caucus (CSC), we are writing today to express our concerns regarding the Gulf Council’s (Council) fast track of Amendment 40, also known as “sector separation”. The CSC was founded in 1989 to provide a voice for America’s sportsmen and women on Capitol Hill. It’s the largest and most effective bipartisan caucus in Washington, D.C., with nearly 300 members representing 49 states.
The suddenly accelerated speed at which the Council seeks to subdivide the recreational red snapper fishery into two individual components or “sectors” is unacceptable for an action that will likely have far reaching impacts on local communities, the economy, state-based conservation funding, thousands of recreational anglers, and ultimately the charter/for-hire industry for which it is meant to help. A decision of this magnitude requires careful deliberation and calculated safeguards to ensure that the best interest of the American public is first and foremost. Furthermore, there are several concerns regarding potential statutory violations that must be fully explored and resolved before moving forward with any such fundamental change to the interpretation of the Magnuson-Stevens Act and the way we manage marine recreational fisheries in the United States. We fear thorough analysis of these concerns has not been sufficiently undertaken by NOAA Fisheries or the Council relative to Amendment 40.
It is difficult to understand why red snapper management is so unique that it requires such a radical departure from methods that have successfully managed the vast majority of our fish and terrestrial wildlife resources. Indications are that the red snapper stock is recovering well ahead of schedule, which suggests that the current problems with red snapper are not biological, but rather man-made. It appears that some failure of our federal fisheries policy is producing a system in which access to a healthy fishery resource is being funneled through fewer and fewer entities. Unnecessarily restricting public access to a sustainable resource is an undesirable and untenable result for any wildlife resource management system, and one that should be avoided at all costs.
Fundamentally, we struggle to see where Amendment 40 offers a solution to the challenges facing the recreational sector. For the private recreational component, which represents by far the largest number of recreational red snapper anglers, it virtually ensures few, if any, days to fish in federal waters. While we fully support a better management approach to alleviate the hardships of an extremely short recreational season on the charter/for-hire fishery, providing more days of fishing for a select few while
completely ignoring the impacts to the majority of participants is irresponsible. Other options that address the needs of the recreational fishery as a whole should be on the table.
Finally, the controversy surrounding Amendment 40 and the Council and NOAA Fisheries willingness to move forward without first reaching consensus among the affected stakeholders, or even within the Council’s own reef fish committee, presents a more pressing question as to the Council’s ability to effectively manage the nation’s fishery resources in the Gulf of Mexico. The fishery management councils were entrusted by Congress to find a balance between the needs of our fisheries and the people who participate in the fisheries. Striking a fair and equitable balance among the participants of the red snapper fishery is a critical step that is clearly missing from Amendment 40.
As a voice for America’s sportsmen and women across the nation, we urge you to table any further consideration of Amendment 40 until such time as a thorough analysis of the scientific, legal, economic and cultural impacts of sector separation have been completed and alternative management approaches, such as regional management, have been appropriately considered.
CC: Dr. Roy Crabtree, NMFS Southeast Regional Administrator Doug Gregory, Executive Director, Gulf of Mexico Fishery Management Council