June 20, 2013 Gulf of Mexico Fishery Management Council 2203 N Lois Avenue, Suite 1100 Tampa, Florida 33607 USA Mr. Chairman and Members of the Council: Thank you for considering these comments on behalf of Fish for America. We are an organization committed to providing safe and healthy seafood to millions of American consumers. We are an industry that is beginning to realize the very real benefits of sustainability. We are highly accountable to all stakeholders of Gulf resources! We are pioneering the traceability of every pound of our harvest from the Gulf to the plate. Our comments today are specific to the Scoping Document for Amendment #28 and the apparent lack of guidance and rationale for the proposed actions. More specifically, we consider the Council’s Guidelines for Allocation and seek to call into question the Council’s motivations for even considering such a poorly justified public policy action. The Scoping Document offers two reasons for proposing Amendment #28; a requisite five year review of FMP allocations and the tenuous conclusion of the Carter/Agar papers that small reallocations MAY be warranted in the reef fish complex. The Scoping Document does not, however, offer any other social or economic rationale for moving forward, nor does it offer any clear objectives that reallocation seeks to achieve and analyses to quantify the effects. This is in direct contradiction of the Council’s own Guidelines 2(b) and (d). Item 1.C(2) is probably the strongest indictment of the current proposed action on reallocation; “Allocation shall…consider efficient utilization of fishery resources, but prohibit measures that have economic allocation as its sole purpose.” If the Council is unwilling to consider additional accountability measures and request NMFS to conduct other socioeconomic analyses, then this guideline alone should result in the immediate demise of the Amendment #28 process. The current state of the recreational fishery should also preclude moving forward with this amendment. Guideline 2(f) states “Indirect changes in allocation, i.e., shifts in allocation resulting from management measures, should be avoided or minimized to the extent possible”. The recreational sector has overfished their annual allocation fourteen of the past twenty-two years; most dramatically, by double their allocation in the early 1990’s and most recently, by one-and-a-half times. Speaking strictly in terms of reallocation of commercial quota to the recreational fishery, and if the TAC were not exceeded, the 2009 season represented an effective allocation ratio of 7% commercial to 93% recreational. Did that huge indirect reallocation improve the recreational fishing experience? Season length has dropped 86% in six years to a low of 27 days scheduled for 2013. Item #3, Suggested Methods for Determining (Re)Allocation identifies twenty-three potential mechanisms for implementing and determining the efficacy of a reallocation action; however, the Council seems justified in analyzing only two of these mechanisms (historical landings and net benefits to the nation) in moving forward with Amendment #28. The structure of this proposed amendment and the rest of the Council’s agenda effectively rule out the possibility of considering fish tags, sector separation, measures for recreational accountability or any of a dozen other economic criteria which are ALL clearly articulated in the Council’s Guidelines for Allocation. While the Council may feel obligated to address allocation issues, and is being subjected to an extraordinary campaign by a recreational advocacy group, Amendment #28 as outlined in the Scoping Document is bad public policy and a profound disservice to the commercial, charter/headboat and recreational constituents who all deserve better adherence to TACs and a better quality fishing experience; NOT allocation for the sake of allocation. Thank you, David McCarron, Fisheries Economist On behalf of Fish for America
Posted on: Thu, 20 Jun 2013 17:26:03 +0000
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