SEAFOOD HARVESTERS OF AMERICA: LETTER TO SECRETARY WILBUR ROSS

June 16, 2017The Honorable Wilbur RossSecretary,
United States Department of Commerce1401 Constitution Avenue NWWashington, DC 20230The Seafood Harvesters of America are deeply concerned about the temporary rule issued by the Department of Commerce to re-open and significantly extend the private angling component for red snapper in the exclusive economic zone of the Gulf of Mexico. We would greatly appreciate the opportunity to discuss with you how this rule could impact the health of the stock, the commercial fishing industry and the seafood supply chain.We believe the rule clearly violates the Magnuson-Stevens Act (MSA), sets a dangerous precedent in undermining regional fisheries management and will result in overfishing a valuable species that we have fought hard to recover. Accountability is the driving force for sustainable fishery management and consequently, the commercial sector has consistently adhered to its quotas and allocations. The MSA requires that any overages in fishing be paid-back in the following year to maintain the integrity of the rebuilding schedule. However, the action taken by the Department of Commerce does the opposite by rewarding the recreational sector for overfishing its quota last year.The rule acknowledges that “red snapper is overfished,” “the amount of red snapper that can be caught by private anglers is near an all-time high,” and “this approach may delay the ultimate rebuilding of the stock by as many as 6 years.” It justifies overfishing citing that “recreational fishing generates economic activity as consumers spend their income on various goods and services needed for recreational fishing.” The economic benefits of recreational catch are dwarfed by those of the commercial sector and seafood supply chain that support the jobs, tax revenue and economic benefits of businesses that catch, process, transport, market, prepare, serve and sell red snapper across the nation. Therefore, we would like to know if the Commerce Department considered the economic loss that the assumed overfishing would have on the seafood industry, including the charter boat and commercial sectors, before promulgating this rule.The red snapper fishery has been a success story with the biomass of the species having more than doubled over the past decade. Consequently, allocations and landings for all sectors have also more than doubled during this time. Because recreational fishermen have garnered greater access to catch red snapper in state waters, access to federal waters has declined, but overall access and landings have continued to grow substantially. Therefore, it is a false narrative to declare that the shortened federal season is creating significant economic hardship when it is the direct result of the extended state seasons, which have been a boon to local economies that support a growing recreational fishery.The Seafood Harvesters of America support the concept of a unified state-federal season, and believe that it should require regional management and prevent overfishing. We would like to meet with you as soon as possible to find an equitable solution that improves access to red snapper, protects the local economies that support all fishing sectors, and continues to rebuild this valuable fishery to the benefit of all Americans.Thank you for your consideration of our concerns.Kevin Wheeler, Executive Director