Dear Mr. Phillips,
I am a resident of Gloucester-- a Down East community-- and a retired
Research Fishery Biologist with 30 years of service with NOAA, National
Marine Fisheries Service. I hold a life-time Saltwater Recreational
Fishing license, and a Retired Standard Commercial Fishing license. As a
private citizen, I am opposed to House Bill H918 ("Designation of
Coastal Game Fish"). I am perplexed that this bill was written without
regard for science, fishery economics, and without regard for the
process the NC Division of Marine Fisheries employs in developing
management plans.
In the late 1990's, the Fishery Reform Act was
enacted and the NC Division of Marine Fisheries was mandated to develop
management plans for valuable recreational and commercial species. Most
recently a management plan was completed for red drum and approved by
the NC Marine Fish Commission. A management plan for spotted seatrout is
in progress.
Briefly I would like to present a synopsis of these plans:
The foundation for any fishery management plan is the stock assessment.
The red drum stock assessment indicated that this species was
"recovering" and populations were exceeding the target set by a previous
assessment. This recovery was a result of a harvest slot size for both
commercial and recreational fishermen that protect younger and older
fish, a cap on trip limits for both groups, a cap on the commercial
annual harvest, and designating the red drum a commercial by-catch
species. The recent management plan recognized that recreational and
commercial discard mortality needed to be addressed and steps were taken
to reduce discard mortality.
A recently-completed stock assessment for spotted seatrout indicates
that this species is being overfished with recreational harvest being a
major contributor to fishing mortality. An annual comparison between the
recreational and commercial landings indicate a relatively rapid
increase in recreational landings from 2001 through 2006, whereas
commercial landings were generally "flat" with a slight increase in 2006
that was most likely a result of a strong 2005 year class. In addition,
recreational discards have been increasing significantly since 2003,
indicating a potential significant increase in hooking mortality.
The Coastal Fishery Reform Group has been lobbying in an aggressive
manner to designate the above mentioned species as coastal game fish.
Their arguments, which have appeared in various newspapers and have been
summarized on your web site are seriously flawed in fishery management
and fishery economic principles. It would be difficult to find a fishery
economist that would agree with their sophomoric economic arguments that
are their driving force for supporting proposed bill (H918). The data
that the Reform Group utilize was "cherry picked" from a draft, spotted
seatrout, economic impact assessment report, with no obvious
consultation with fishery economists. In a draft "Frequently Asked
Question" document that will be available on the NC Division of Marine
Fisheries web site in the near future, their economist states:
His question -- "Which should be used in making policy decisions,
economic impacts or economic values?"
His answer -- "There is a clear consensus among social scientist who
work in fisheries on this subject. An economic impact assessment is best
used to estimate the impact of potential changes in policy in terms of
job and revenue losses or growth. **Economic impact assessments should
_not _be used in making allocation decisions between different fishery
sectors.* Instead, economic value and social value should be taken into
consideration in conjunction with biological concerns." *
I need to add, hoping to avoid the complexities of economic theory, that
estimating economic value is more than involving the price of a good and
is enormously difficult to estimate. I highly recommend that committee
members consult with an economist for more detailed information on this
issue.
Conflicts between commercial and recreational fishermen have been
reported. The number and severity of these conflicts is difficult to
document, but real and potential severe conflicts can be formally
addressed. The Division of Marine Fisheries can mediate these conflicts
by bringing together stakeholders and arriving at a solution that is
equitable to all parties. I would hope that legislators will avoid
addressing and resolving fishery conflicts and be very cautious in
drawing conclusions from anecdotal claims of conflict.
The development of NC Fishery Management Plans are costly both in human
and financial resources. A considerable amount of time is spent
developing a stock assessment, holding advisory committee meetings that
include public input, and NC Marine Fisheries Commission hearings
before the plan is a approved. In my opinion, it is perplexing and
disturbing that the legislature has decided to manage fisheries based on
pressure from organizations whose economic arguments--the main stated
purpose for their proposal--appear flawed, hence their intentions
questionable. This in my opinion is a bad bill particularly at a time
when the NC commercial fisheries are "endangered." This bill is biased
towards a very well organized and influential group (Coastal Fishery
Reform Group and the CCA of North Carolina) whose input to the bill are
scientifically and socially wanting and illogical, and whose philosophy
have little empathy for commercial gill net fishermen.
Allyn Powell
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