Seafood Harvesters of America: Letter to Chairman Lamborn and Ranking Member Huffman, U.S. House of Representatives
The Honorable Doug Lamborn, ChairmanThe Honorable Jered Huffman, Ranking MemberU.S. House of RepresentativesCommittee on Natural Resources – Subcommittee on Water, Power and Oceans1522 Longworth House Office BuildingWashington, DC 20515Chairman Lamborn and Ranking Member Huffman,On behalf of the Seafood Harvesters of America, I am writing to convey our positions on legislation to reauthorize the Magnuson-Stevens Act (MSA) and to address the management of recreational fisheries including Red Snapper in the Gulf of Mexico.The Seafood Harvesters of America represent fishermen across the nation that are privileged to go to sea every day to bring to market healthy, domestic, sustainable seafood. Our commercial fishermen depend upon and live with accountability in our fisheries and transparency in the regulatory process and believe that MSA has been central to the success our nation has achieved in rebuilding our fish stocks.With regards to MSA reauthorization, the Harvesters agree with the need to replace the 10-year rebuilding deadline with one based on biology and life cycle of species. Science needs to guide management decisions. Consequently, Fishery Management Plans should rebuild populations within a life-cycle of the species, with sufficient backstops and without loopholes such as “to the extent practicable” to ensure overfishing does not take place.The Harvesters believe that replacing the term “overfished” with “depleted” is a wise action as it eliminates unfairly placing blame on fishing for the decline in fish stocks, which are frequently the result of changing environmental conditions rather than overfishing.We agree with efforts to increase transparency in the council process and support extending efforts to require all councils votes to be recorded roll call votes to assure accountability and transparency in the process.The Harvesters are concerned with the top-down national marine monument designation process and support having MSA guide efforts to set aside marine protected areas through the essential fish habitat process. Furthermore, we support having the regional fishery management councils determine whether fishing should be restricted in all marine protected areas.The Harvesters believe that improvements in gaining more accurate and timely data on commercial and recreational fishing data is critical for better managing our nation’s fisheries. Data modernization, technology development and implementation of smart phone applications could add tremendous value and significantly decrease uncertainty in estimating landings. transparency and accountability are essential for successful fishery management as reducing uncertainty provide tangible economic benefits by maximizing sustainable yields.The Harvesters would support an MSA reauthorization that focused on the aforementioned areas. However, we have significant concerns about proposals to alter the annual catch limit requirements. ACL’s have been central to recent gains in fish stocks across the nation. We also oppose efforts to restrict the councils’ discretion to use the full suite of management tools at their disposal, including catch shares. Limited access privilege programs have been very successful in some regions, but may not be appropriate in other fisheries and thus should be left to the discretion of the councils. The Harvesters are also concerned about legislative proposals that place unfunded mandates on the councils to conduct activities that they do not have the staff or resources to complete, thus getting in the way of their existing core functions.We are concerned with the hurdles places on the use of exempted fishing permits (EFP) as proposed in H.R.2023. EFPs have been an effective tool for testing new technologies and management schemes for fisheries, which already have significant oversight and approval protocols through the councils and NOAA. We should be streamlining not restricting opportunities to be innovative.With regards to legislative efforts to better manage the red snapper fishery, we should not lose sight that the fishery has rebounded dramatically over the past decade, while acknowledging that the stock health in the eastern Gulf is still in trouble. Consequently, we cannot endorse the Snapper Act (H.R.3588) as currently written because it does not hold the recreational sector accountable for fishing within the annual catch limits. The commercial and for-hire charter sectors have always fished within our catch limits and fairness dictates that the same standard should stand for the recreational sector. Failure to do so will lead to overfishing and could reverse the gains in the stock that have been achieved.We greatly appreciate your leadership in promoting the best interests of the commercial fishing industry, including protecting the healthy ecosystems upon which our fisheries thrive. We hope that Congress can uphold its valued tradition of passing a bipartisan MSA reauthorization.Sincerely,Kevin R. WheelerExecutive Director