Snapper Controversy In A Nutshell - by Tom Hilton

[Scubaru]

The Snapper Controversy In a Nutshell
( OR: Have Our Regulators Gone NUTS?)
By Thomas J. Hilton

The CCA filed a lawsuit a while back with the NMFS, demanding reduction in shrimper bycatch, citing that 80% of every year-class of snapper are killed in shrimp trawls. The Ocean Conservancy and Gulf Restoration Network did the same, filing suit with the NMFS, citing the same 80% mortality lie and other inaccuracies. All 3 parties were enjoined into one single lawsuit. To quote from Ocean Conservancy; "Overfishing has reduced red snapper populations to less than 3% of their historic levels". The 3% of historic levels claim is pure bunk. Bob Shipp, one of the world's leading experts on GOM fisheries points out that there are more snapper out there right now than any other point in history, due to the abundance of man-made structure (surface platforms and artificial reefs).

The 80% juvenile snapper mortality figure comes from 1985 data. The latest data shows that 0-2 year old snapper mortality is about 26% due to shrimper bycatch. That is a huge difference. Common sense also tells us that even if President Bush issued a Presidential Order to decimate ALL juvenile snapper with shrimp nets, it would be an impossibility due to the fact that shrimpers cannot trawl where a large majority of these snapper live - on rocks, around surface platforms, etc. In addition, these 0-2’s have a naturally high mortality rate anyway of about 80%.

Capt. Elliott's decision to close up shop is the first ripple of an economic Tsunami that will swamp the Gulf of Mexico coastal communities, and it is a direct result of the above-mentioned lawsuit, as the recreational bag limit is tied directly to shrimper bycatch. NMFS is looking backward to penalize us for failures in the past to address the bycatch. I don’t think that the NMFS even has a clue about how many Red Snapper are actually out in the Gulf. In 2000, NMFS claimed there were only 4 million 0-2 year old red snapper in the entire Gulf, yet the U.S. Geological Survey report stated that there were 8 million 0-2’s on the oil platforms alone at that time. (Oil platforms, remember, only account for about 0.4% of the total hard substrate area of the Gulf). Of course the NMFS refuses to count fish found around man-made structures such as oil platforms and artificial reefs. (Refer to Dr. Shipp's quote above!) In addition, there were tens of thousands of other known natural structures conducive to snapper habitation not taken into account here.

None of the aforementioned so-called "conservation / enviro.orgs" are willing to place the blame squarely on the true cause of overfishing for this species; commercial overfishing. Historically, fish stocks have been depleted by what? Commercial over-exploitation due to the greed factor. It would make sense that, if you were truly interested in protecting the stocks, the first thing you would do is to eliminate commercial fishing. However, what do we see today? Environmentalists and Commercial Fishermen walking the halls of Congress hand in hand. When Commercial Fishermen and Environmentalists get into bed together, you know the resulting offspring is not only going to be ugly, but dangerous.

Instead of focusing on the true problem (commercial exploitation due to lack of enforcement), the Gulf Council and NMFS are giving commercials a free pass to fish 365 days a year, on the honor system known as Individual Fishing Quotas (IFQ’s). IFQ’s are a bad idea - they will have disasterous results for the fishery due to the following reasons;

1. The removal of what few enforcement tools that we had (10 day seasons and trip limits) and instead relying on high-tech gizmos (VMS) to track the vessels' whereabouts is a recipe for disaster. (Runner boats could easily circumvent the tracking capabilities of VMS). They are shifting the enforcement to occur on land (because it’s easier) but on-the-water enforcement is much more effective.
2. Giving the commercials 365 day access to the resource. They cannot enforce EXISTING laws due to lack of on-the-water enforcement, and simply changing the law does NOTHING of substance. The commercials know this, and that's why they have not opposed any reduction in TAC, as they know they will be able continue to do what they please. It will be a slaughter-fest resulting in the decimation of the stocks.
3. Gifting of a public trust resource to 80 or so individuals is not only un-American, it will be difficult to undo, since then you will be talking about ownership rights.

One example of bad stewardship exhibited by the NMFS was in December 2005, after the hurricanes had caused the snapper to gang up on inshore oil platforms for protection. The snapper were more vulnerable to being caught since they were so closely packed on these structures. Instead of enacting truly effective measures to protect the species, the NMFS in fact opened up the ENTIRE month of December to commercial fishing. The slaughter was unbelievable. What's worse, is that this took place at the same time that the NMFS was holding scoping meetings to reduce the recreational bag limits to 2 fish!

There is an additional disturbing trend of increased landings by long liners - it went from 26,000 pounds in 1993 with 103 boats fishing to 423,000 lbs / 255,000 lbs in 2004 / 2005 respectively, with only 68 boats fishing. These are the breeders - if the NMFS is truly interested in protecting the stocks, the VERY FIRST THING that needs to be done is to eliminate ALL long lining initially, in a prelude to eliminating ALL commercial snapper fishing. That would solve the problem - end of story.

It is disturbing that the NMFS and Gulf Council are micro-managing the harvest when they should be focused on the cultivation. Red Snapper are "habitat-limited". It doesn't matter what species we are talking about - deer, dove, quail, snapper, etc - if you provide habitat, they will flourish. The 40 mile stretch of coastline that is Alabama's access to the Gulf represents 40% of ALL recreationally-caught Red Snapper in the ENTIRE GULF OF MEXICO! Why? Alabama fishery managers recognized this, and created 1,260 SQUARE MILES of artificial reefing areas there. It's an incredible success story, but guess what? The NMFS refuses to include the fish counted over these reefing areas in their analyses. The enclosed graphic tells it all (40% snapper)

I believe there is an effort to drive the recreational fishermen off of the water, thereby increasing the bottom line for the commercial sector. Take a look at the graph below, and I think you can see a trend; (Number of Fishing Days Allowed)

Here are the preliminary IFQ allocations; http://www.realtime-navigator.com/initial_ifq_alloc.xls I have given
values based on $3/pound at the dock both for the existing 9.12 TAC and proposed 6.5 TAC. These figures show several problems;
1. There are WAY too many permits out there than needed to get the job done,
2. The numbers don't support what people on the docks know - relatively few fishermen could make a living based on these figures...there IS a huge black market for snapper. Based on these figures, Class 1 permit holders went fishing on average 1.4 times per month and caught their 2,000 lb trip limit. Class 2 permit holders caught their 200 lb trip limit an average of 4.2 trips PER YEAR. Yeah, right.

[Scubaru]

This spreadsheet also shows a total value of $13.4 million dollars for the entire GOM commercial snapper fishery - extrapolate a total economic impact of about $50 million from hook to plate. The recreational economic impact is about $8 BILLION, so the commercial red snapper fishery is less than 1% of the total picture. Despite this fact, the Gulf Council gives them 51% of the resource. If this were a corporation, wouldn't it be unethical to gift the top 1% of executives with 51% of the profit? Sounds like corporate welfare. This is especially troublesome when you realize that 80% of all snapper consumed in the US today is imported - you could completely eliminate the entire GOM Red Snapper commercial fishery and not appreciably affect the market.

In fact, I suggest we do just that – eliminate the commercial harvest of red snapper in the Gulf of Mexico by paying the Commercial Fishermen NOT TO FISH, much like the government paid farmers via farm subsidies NOT TO PLANT. Why did the government do that? It made the most economic sense that’s why. We can do the same thing here - pay the commercials to stay home and NOT fish for a period of 5 years. That will give them enough time to find other ways to make a living, as it is obvious the Gulf ecosystem cannot support both recreational and commercial pressure – the importance of recreational fishing to the US economy is paramount here.

The immediate benefits to be achieved by removing the commercials from the fishery are; 1) TAC could be lowered to 4.5 million pounds with virtually no effect on recreational fishermen or their bag limits. 2) the 4.5 million pound TAC in conjuction with removal of the illegal commercial fishery would trigger a dramatic increase in recovery of the fish stocks. 3) The huge economic engine that powers the offshore fishing industry is virtually unscathed – charterboats, head boats, boat manufacturers, motels, bait camps, marinas, etc. will be able to operate profitably. 4) The Commercial Fishermen get paid for doing nothing for a period of 5 years by a federal subsidy program allowing plenty of time to find another type of job. The only problem that I see here is that the commercials are not likely to want to do this, as the claimed landings are certainly a fraction of their actual income from snapper fishing. It would be interesting to see their response to such an offer!

Here are some figures provided by Bobbi Walker of the Gulf Fishery Council;
Shrimp Fishery
*In 2005 effort was down in the shrimp industry by more than 60%, which relates to a 50% reduction in dead red snapper bycatch .
*In 2006 effort was down an additional 10%, however there is indication that effort is down 30% in the 10-30 fathom lines, which is where the majority of shrimp trawls encounter juvenile red snapper.
*This means that the shrimp industry is probably at their 74% reduction in bycatch; however there are no management measures in place to assure this reduction will continue. In other words we may have the reduction for 2006,
but there is no guarantee it will continue without capping the effort where it was in 2006.
*The interim rule proposal to set a goal of 50% reduced effort would allow for more bycatch mortality than took place in 2006. Remember that the reduced effort percentage does not equal the reduced dead red snapper bycatch.
*Although we are very happy that this bycatch reduction occurred in 2006 the problem still exists that the rebuilding plan called for 44% bycatch reduction beginning in 1998 and increasing to 50%, which did not occur. I do know that because that bycatch mortality reduction did not occur during that time frame we are looking at lower TAC's to compensate for that failure of the NMFS to enforce that requirement.

Please see a related article, "Congressional intervention might save Gulf red snapper." By Robert Sloan, as published in the Beaumont Enterprise.

The NMFS (formerly known as the U.S. Department of Commercial Fisheries) has mismanaged the Gulf fishery to the point that a new direction, new management is urgently needed. Roy Crabtree and Bill Hogarth need to be fired immediately and replaced with competent people who truly have the best interests of the United States citizens at heart. Their habitual re-adjusting of baseline data, their refusal to use the best available data or to even implement processes to determine such data is clear and undeniable;
1) Grossly over-estimating recreational effort and under-estimating
commercial effort in the models
2) Refusal to acknowledge the success of artificial reefing in replenishing
fish populations - there is no habitat component in the current
National Marine Fisheries Service models.
3) Refusal to acknowledge huge populations of snapper in the Gulf found around oil platforms, artificial reefing areas, and other hard substrate.
4) Refusal to acknowledge the existence of huge stocks of sow snapper on the mud flats after longliners were moved out beyond the 50 fathom curve. (The NMFS claims there wasn’t enough time to include in this important component in the assessment).
5) Refusal to acknowledge the egregious illegal commercial black market.
6) Refusal to implement an effective enforcement strategy to curb the illegal commercial overfishing.
7) Refusal to count dead fish due to regulatory discards.
8) Pushing for approval of IFQ’s without adequate enforcement or penalties. This will result in a totally unmanageable illegal fishery due to 365 day access.

WHAT IS CRITICAL TO NOTE HERE, IS THAT IF ANY ONE OR MORE OF THE 8 BULLET POINTS ABOVE WERE ADJUSTED IN THE NMFS MODEL, IT WOULD SHOW THAT THE GULF OF MEXICO RED SNAPPER STOCK IS NOT OVERFISHED, NOR IS IT UNDERGOING OVERFISHING!

Here’s what needs to be done to fix this crisis;
1. Fire Crabtree and Hogarth. Make it clear to their replacements that it is their duty to make decisions based on what’s best for the United States as a whole, and not just small special interest groups such as commercial fishermen and environmentalists.
2. Revamp the data collection process. This is the 21st century and the age of the Internet – information can and should be processed accurately at almost real-time speeds. Accurate information is vital if we are to make informed decisions. The stock assessment on which the interim rule is based was conducted prior to the 2004 hurricane season! Not acceptable.
3. Eliminate commercial fishing for Red Snapper in the Gulf of Mexico. Establish a subsidy program to pay the commercials to stay home for 5 years and placed in other jobs.
4. If other species are deemed to be over-fished in the future, it should be an automatic requirement that there be an immediate commercial closure for that species.
5. Revamp the Magnuson Act to ensure fairness across all sectors.
6. Eliminate regulatory discards – go to the First Five Fish rule.
7. Increase enforcement to ensure regulations are followed.
8. Create a pro-active Gulf-wide habitat program to ensure the health of the fish stocks.

If these measures are implemented, the American Red Snapper and all other species in the Gulf of Mexico will be ensured healthy and robust populations now and in the future.

Sincerely,
Thomas J. Hilton

[Squidward]

Well thats the longest damn nutshell I've ever seen...

[Scubaru]

Well thats the longest damn nutshell I've ever seen...

:cone:

[Louis Rossignol]

That is a true work of art.

[JLittle44]

Great writting and thats what it takes: Publicly expose the BS and keep beating them over the head with good old fashioned common sense until it seeps in. Outstanding post!

Viva La TGBR!

[Seth]

that made for very good reading, and the funny thing is, a 10 year old could understand this logic "If other species are deemed to be over-fished in the future, it should be an automatic requirement that there be an immediate commercial closure for that species."

it aint rocket science ya know :)


im curious about something.. in barbados, our red snapper live from 70 - 85 fathoms, very rarely deeper, and even more rarely shallower, do they live that deep up there?

[sharpshooter]

Seth, I have seen red snapper in 90' off the St. Petersburg, Fl. area.

[Bottom Dweller]

Hell Jose, I caught them in 50 feet this year on charters and saw them there on almost all dives in 50 to 80 feet.

[fishkilla]

everyone needs to read this!

[inletsurf]

im curious about something.. in barbados, our red snapper live from 70 - 85 fathoms, very rarely deeper, and even more rarely shallower, do they live that deep up there?

I am on the Atlantic side of central Florida, but I have shot red snapper as shallow as 55 feet. They are pretty abundant here in 70-135 feet, and I have had a lot of success fishing them in 240-300 feet depths.

Great article!!!

[Screen Name]

Bob Shipp, one of the world's leading experts on GOM fisheries points out that there are more snapper out there right now than any other point in history, due to the abundance of man-made structure (surface platforms and artificial reefs).

But..........

None of the aforementioned so-called "conservation / enviro.orgs" are willing to place the blame squarely on the true cause of overfishing for this species; commercial overfishing.

Never mind.........

WHAT IS CRITICAL TO NOTE HERE, IS THAT IF ANY ONE OR MORE OF THE 8 BULLET POINTS ABOVE WERE ADJUSTED IN THE NMFS MODEL, IT WOULD SHOW THAT THE GULF OF MEXICO RED SNAPPER STOCK IS NOT OVERFISHED, NOR IS IT UNDERGOING OVERFISHING!

Well, even though there is no problem........

3. Eliminate commercial fishing for Red Snapper in the Gulf of Mexico.

Not sure I get it, seems to be contradictory to me. Is this guy saying that shrimp trawls do not waste a large qty of juvenile red snapper?

The big problem seems to be that Red Snapper populations are currently healthy, yet NMFS is determined that everyone gets to fish less, including the commercials, which have been substantially cut in recent years. When that happens, people start beating up on each other, rather than getting the bad data thrown out. NMFS loves it!

Just my opinion.

[Mikerotch]

Privatize the resource. Auction off the ocean in blocks to the highest bidder, be they commercial or recreational and then let each take care of their own resource as they see fit. I remind you all, there is never going to be an end to the fighting over who gets what, so long as it is "public". Resources that are "public" get abused, please see 1. the American Buffalo, 2. DoDo birds, 3. etc. Resources that are private are always looked out for. Please see 1. cows 2. horses 3. chickens. I submit that there are no animals that are privately owned that are endangered and far less privately owned water is poluted. Imagine those of us who love spearfishing pooling our resources to buy several multi thousand acre tracts and managing it as we see fit. Meanwhile, suppose the commercial guys had several multi thousand acre tracts that they took care of. They would not ever overfish again, lest they put themselves out of business, in which case someone with better management skills would fill the void. I'm sure many will say, "we can't afford it" to which I say "you already are affording it, you're just buying a crappy, corrupt, political p.o.s. that you have absolutely minimal control over."

Mikerotch, believer in the original American thinking

[Mobile Diver]

I agree with John (Screen Name). It is contradictory to the point of ridiculous to say the stock is not overfished, but advocate ending commercial fishing to prevent the stock from being overfished.

That said, there IS some great stuff there, especially about the artificial reefs & lack of enforcement of the commercial longliners. We outlawed trapping; we can outlaw longlining as well. Based on the data I have seen in these discussions, I see no reason to outlaw commercial bandit gear and/or spearing.

He may have already done so, but I would be very interested in what Denny/FRA have to say about this.

[Flying Bajan]

Seth,

What we call a red snapper is actually either a queen or yellow eye snapper. Both deepwater species, the American Red Snapper is different.

[Seth]

queens are even deeper, 120 fathom range :) we get the yelloweye, and a red eyed red snapper down here tho

[Ed Walker]

Even I caught red snapper this year and I dont usually venture very far offshore. In fact, fishing from my 23 footer, we had never seen a red snapper off Tarpon Springs until this year. What wer the local landings in this part of the Gulf 12 years ago? Close to nada I believe. When I was growing up if a boat brought in a true Amercican red to the tampa bay area they'd get thier name in the paper. Now that they are abundant we folks have to drive away from the schools.
I did hear a horror story from a friend whos dad owns a longline boat. Red snapper aint the smartest fish and when a longline in set over them its real ugly.

[Louis Rossignol]

Jim Smarr sums this up a little, basically the NMFS's computer is facked, if one component changes in their computer, the problem is solved.

Can you believe, all the ARS's around the oil rigs where I live are not counted because they are living on an artificial reef?

Well Hell, let's get those ****in commies off of my rigs.

Here is Jim's words, I get too pissed off, this is known as the "8 point bulletin"


The Real Story behind the NMFS Red Snapper “numbers”.



What is critical here is that the NMFS is stacking the deck on the model to make it appear as if, as it says in the first sentence of the DEIS; THE GULF OF MEXICO RED SNAPPER STOCK IS OVERFISHED, AND IS UNDERGOING OVERFISHING!

Change any one of the bullet points below, and guess what? The species is not overfished, nor is it undergoing overfishing! Therefore, we could fish year-round, 4 fish limits, etc., if we could get somebody (such as TPWD Coastal Fisheries - hint, hint, to plug in REALISTIC numbers in the NMFS model. That would be a powerful tool in this fight.

1) Grossly over-estimating recreational effort and under-estimating
commercial effort in the models. NMFS did not collect reports or trip sheets
For four months so an estimate could be substituted. This was a 30 to 40 % error
as in falsely inflated effort. The result has been the model has the recreational effort
Erroneously higher than real time data shows.


2) Refusal to acknowledge the success of artificial reefing in replenishing
fish populations - there is no habitat component in the current
National Marine Fisheries Service models.


3) Refusal to acknowledge huge populations of snapper in the Gulf found around oil platforms, artificial reefing areas, and other hard substrate. The Bureau of Minerals Management has a study showing 8 million 2 year old Red Snapper around the oil platforms in the Gulf of Mexico. NMFS Catchem Model only credits the entire Gulf of Mexico with having only 4 million 2 year old Red Snapper. There are tens of thousands of occurrences’ of other structure that are known to hold 2 year old Red Snapper.


4) Refusal to acknowledge the existence of huge stocks of sow snapper on the mud flats after longliners were moved out beyond the 50 fathom curve. (The NMFS claims there wasn’t enough time to include in this important component in the assessment).
NMFS has catch reports from longliners prior to there being moved beyond the fifty fathom curve. These fish a huge stock of “Sow Snapper” just disappeared out of the stock assessment and are not included in the current model. This made the stock assessment fall dramatically for no reason.

5) Refusal to acknowledge the egregious illegal commercial black market in the Red Snapper Fishery. Australia has implemented a mandatory 3 year jail sentence for everyone evolved ie Capt. ,Crew and permit holder, 800,000 dollar fine aus dollars = to about 700,000 us dollars, Loss of permit along with forfeiture of vessel
to curb rampant illegal commercial Overfishing.


6) Refusal to implement an effective enforcement strategy to curb the illegal commercial overfishing. The Commercial Sector has used a “Water Taxi” service to run illegally caught or over quota fish to the dock under the cover of darkness. This practice is no different than the bootleggers of the “Prohibition” era of the 1920’s.
NMFS has 3 Federal Agents covering the entire State of Texas. When confronted with a zero Total Allowable Catch there were Commercial Fishermen asking for any number as long as they could continue to fish. They would have accepted 1.28
Million Pounds. This statement speaks volumes. Now that they have IFQ’s they
would just never seem to reach their quota. This shows intent to fish illegally since no man with IFQ shares could have paid expenses with such a meager Total allowable Catch.






7) Refusal to count dead fish due to regulatory discards. We have asked for a first five or four fish rule. Regulatory Discards or Bycatch numbers are from five to twenty fish to one keeper at a 16” slot limit. NMFS refuses to allow a first five rule. We want
To take the first five and have the model credit us for the fish not killed due to eliminating regulatory discards. The Shrimp Industry has a credit or debit. We simply think a credit for fish not killed would increase the numbers in the fish stocks in reality. Currently NMFS ignores regulatory discards in the Recreational Sector. These
Fish be they 5,10,15,20 or more to one are dead under current slot rules.
8) Pushing for approval of IFQ’s without adequate enforcement or penalties. This will result in a totally unmanageable illegal fishery due to 365 day access.

WHAT IS CRITICAL TO NOTE HERE, IS THAT IF ANY ONE OR MORE OF THE 8 BULLET POINTS ABOVE WERE ADJUSTED IN THE NMFS MODEL, IT WOULD SHOW THAT THE GULF OF MEXICO RED SNAPPER STOCK IS NOT OVERFISHED, NOR IS IT UNDERGOING OVERFISHING!

[kaborkian]

Just sent your 8 bullets to Peter Hood, NOAA. Lets keep at it, never give up.

[mrfish87]

I said it before and I'll say it again.....take them diving on the rigs....let them see what we have.....I could not get a shot off on a decent snapper at ST 130 because I was completely surrounded by 12 - 15 inch red snapper...It was like swimming through a school of baitfish....but hell lets not count those fish because they are on an "artificial reef"......didn't Al Walker do a survey about the density of fish ont he rigs...and the fact that they are not just live there but are breeding increasing the population.......Rock on Rok.....see ya Saturday........Robbie

[Louis Rossignol]

Just sent your 8 bullets to Peter Hood, NOAA. Lets keep at it, never give up.

Ya know, I couldn't even find Peter Hood on the website, is he still there? I did find several other people though,

http://www.nmfs.noaa.gov/ocs/contactus.htm

we can bug the hell out of all these people.

[Denny]

He may have already done so, but I would be very interested in what Denny/FRA have to say about this.

Red snapper has been mismanaged for 20 years. The CCA didn't fix it and God knows they had enough time.

Frivolous lawsuits filed by another group have rendered impotent that group's threat of litigation.

The REAL problem stems from the screwed-up math (remember my Grandad's saying? "Figures don't lie, but liars sure can figure").

There has been no consideration of the Red Sanpper stock expansion back to the Eastern Gulf (Florida's side) and the true impact of shrimp-trawl by-kill have been ignored or downplayed.

Who is to blame?
You'd be stunned. If I posted it here, I'd piss a lot of people off.
Just remember: Things are not always as they appear.

The current move to gather $100,000 for a lawsuit against the interim rule is a pure wate of time and money, IMHO ( I should have a good idea, as the FRA was the victor in the ONLY successful litigation against an interim rule).

Profiteering from the current situation is reaching epidemic proportions and , when the dark shroud of secrecy is pierced by the light of truth, many people will be exposed (and, hopefully, embarrassed).

Shrimping has been blamed for a major impact on the Red Snapper stock, yet it is IGNORED and DENIED by a group that is begging for YOUR support.

The FRA has been asked to help out on the issue becase we simply kick azz when we get into a fight.

When I fight, I need to know that I am NOT getting punched from behind by those who claim to be on my side. This fight is SO screwed up that I don't even know who to trust standing behind me. Nobody has earned that trust.

[Mobile Diver]

Denny,

Your post doesn't entirely surprise me. The first post in the thread giving the shrimp trawlers a total pass seemed out of place as well as the obvious contradictions. If they want support they have to tell the WHOLE truth.

It also seems that the regulators don't like to acknowledge ANY benefit from oil rigs or artificial reefs. Guess they are in love with things in their "natural" state. The fish disagree, though, & flock to any man-made structure they can find.

[hardcore]

It sure would be smart IMHO to have different rules for different areas in the gulf.........oh ya I forgot no one enforces the rules that are in place anyway, Never-mind.

[jimbob]

i think full size jewfish sure can eat a hell of allot of snapper off of one piece of reef....hell here in daytona jewfish are on every single wreck i dive and one small tug has about 3 dozen on it....i think a tagged season on jewfish will help snapper, and other grouper populations out some..just my thought.. not trying to distract anyone from the conspiracy...