Do the Math - The TRUTH Behind the Commercial Red Snapper Harvest

An Editorial by Thomas J. Hilton
 
March 17, 2006
 

I have documentation that shows there is a VERY REAL possibility that the commercial exploitation is about 23 MILLION POUNDS being landed by the commercial snapper boats each year - if you figure in the 80% MORTALITY OF REGULATORY DISCARDS (plus 100% mortality of smaller fish being cut up for bait), we are looking at a possible total of about of 42 MILLION POUNDS being killed each year by these guys.  The bad news here is that the figures above are based on the assumption that they are abiding by the law regarding their pounds/trip – we have documentation that many are bringing in hundreds of pounds over their allotted trip allowance each time they hit the docks.


WHAT THE GOVERNMENT’S FIGURES SHOW:

There are 130 active red snapper class 1 license holders and 452 active class 2 license holders. There are 137 possible red snapper class 1 license holders and 628 possible class 2 license holders.
452 permits x 200# = 90,400# per trip
130 permits x 2000# = 260,000# per trip
Total permits = 350,400 pounds per trip (If each active permit holder took one trip)

4,651,200# TAC / 350,400# = 13 fishing days allowed per YEAR (1.18 trips per month x 11 months) based on allowable TAC – any more fishing beyond 1.18 trips/month (on average) is over-TAC. 

However, according to gov’t figures, the commercial fleet has not met it’s quota each year (?)

http://sero.nmfs.noaa.gov/pubann/quotas/redsnapper/redsnapper05.htm  

Preliminary 2005 Gulf Commercial Red Snapper Landings for the Spring and Fall Season   2005 Totals 3,484,259 pounds (?)

3,484,259# / 350,400# = 9.94 or 10 trips PER YEAR on average per permit holder. (Less than 1 trip per month x 11 months is what is being claimed).  I know that commercial snapper fishermen are extremely hard-working individuals, but NOBODY can make a living at this going fishing less than 1 time per month.


WHAT THE PEOPLE ON THE DOCKS KNOW:

Fishable days (6 days/month x 11 months) / Fishing Days allowed in 2005...66/131 = 50% of days fished in the number of days allowed in the season. (reasonable to assume, and is in line with law enforcement observations).

Fishable days due to weather = 6 days/month x 11 months = 66 Fishable Days/year x 350,400# = 23,126,400 pounds currently being harvested per year. (18,475,200 # over TAC)


Currently, many commercials head offshore 3-4 days BEFORE the season starts – it is common knowledge (including law enforcement officials that I have talked with) that they can be found ganging up about 8 miles offshore in the afternoon of the first day of the season with their holds already full of snapper.  If they come in before 4:00 PM, the system is setup so that they will stand a high chance of getting busted.  If they come in at 4:30 PM or later, they will have no problems.  According to law enforcement officials on the docks, on average, commercials fish 6 days per season and bring in 2,300 to 2,500 pounds of red snapper per trip (totaling over 20 million pounds per year just for Class I permits).  The fish taken to the markets are divided; a certain portion are placed on the books and paid by check at the going rate (+_$3.50/lb) – the remaining are paid cash (+_$2.50/lb) and are marketed on the black market (thus the ridiculously low 3,484,259 pound commercial TAC figures). 

I also have information that the Gulf Council has been informed by Federal Wildlife agents of the fact that there IS criminal overfishing by the commercial sector, yet there is NOTHING on the table to address this vital issue.   Not only is the Gulf Council casting a blind eye to the core problem facing this fishery, but members on the Council are pushing for the implementation of IFQ’s.  This would be an absolute disaster (according to law enforcement officials on the docks).   Verification of what is happening today cannot be done due to lack of enforcement, and IFQ’s will make verification of what is actually brought to the docks exponentially harder.

My position is that NOTHING should be changed until a verifiable system has been put into place to bring ACCOUNTABILITY into the system. Until then, NO changes should be on the table regarding IFQ’s, TAC, Seasons, did I mention IFQ's?...NOTHING, except developing a Task Force to step up enforcement of EXISTING REGULATIONS. Until enforcement can bring about solid, reliable figures on what is actually being harvested, anything the Council does regarding changing the system should be considered highly suspect. 
 

If we are truly interested in turning around the snapper situation, there should be a multi-pronged approach; 

1) ENFORCEMENT NEEDS TO BE PRIORITY ONE. 

With all due respect, management of the snapper over the last 16 years or so cannot be considered a success story.  Part of the problem is that there is a definite disconnect between what the fisheries managers are claiming to be true, (and thus basing their decisions upon) and what is actually happening on the docks.  Without enforcement of the existing laws to verify what is actually happening, changing the laws now has an extremely poor chance of improving the snapper situation.  Develop a plan to beef up enforcement, give the enforcement personnel the powers needed to do their job effectively, and slap offenders with REAL penalties, (which should include revocation of permits) and you will allow 10’s of millions of snapper to stay in the water to reproduce each year. 

2) FIRST FIVE RULE NEEDS TO BE IMPLEMENTED IMMEDIATELY.

Ever since fisheries mangers put into place a minimum size limit on the red snapper, the snapper population has done nothing but go down a slippery slope.  More fish are killed by regulatory discards alone than go into the combined ice chests of recreational or commercial snapper fishermen alike – the minimum size limits need immediate abolishment.  Institute a law that requires that recreational fishermen keep the first five snapper that they catch – there is no reason to throw a fish overboard.  Commercial fishermen likewise should not be discarding any fish – catch their pounds/trip limit and head for the docks.   This will allow millions of snapper to stay in the water to reproduce that are now being killed needlessly each year.  To draft legislation without taking discard mortality in the equation is certainly not in the Red Snapper’s best interest – any reasonable person can see that. 

3) INITIATE A PRO-ACTIVE REEFING PROGRAM.

Fisheries mangers for too long have focused solely on the back-side of the process (harvest), and not on the front end (encouraging and fostering the growth of juvenile snapper).    An example of a great success story where they have focused on the front end is the great state of Alabama.  Alabama has only 40 miles of coastline, yet Alabama recreational anglers account for 43% of the entire catch of Red Snapper in the entire Gulf of Mexico!    This is due DIRECTLY to their incredible artificial reefing program, which encompasses about 1,600 square miles of permit areas.  Juvenile snapper experience an extremely high mortality rate due to predators – provide suitable habitat to allow them to escape, and we will see an increase in the survivability of millions more fish each year. 

In closing, you may have noticed that each of the suggestions in the 3 preceding paragraphs result in millions of snapper being allowed to stay in the water to reproduce each year.  Think of the cumulative positive effect this could have on this very important fishery!  It’s also sad to think what the cumulative effect of over 16 years of needlessly killing millions of snapper (each year).  Reversing this trend not only can be done IT MUST BE DONE ! 

Sincerely, 

Thomas J. Hilton