Comprehensive Fishery Management Plan for Feeding People and Limiting Waste
My name is Chris McCaffity. I am a commercial fisherman who has been offering simple solutions that would mitigate many of the severe negative impacts associated with fishery laws that do not follow most of the mandates in the Magnuson-Stevens Act (MSA). The MSA is a law dictating how America’s fisheries are to be managed and contains requirements like limiting waste, making efficient use of our resources, and promoting fishermen’s safety at sea. Most of the fishery laws that have been rushed through since the reauthorization of the MSA have not followed those three requirements. This has caused tons of perfectly edible seafood to be discarded and wasted while financially devastating fishermen. The financial devastation has caused fishermen to risk life and limb in foul weather trying to make one more trip before a fishery is closed early due to mismanagement of the quotas. This has caused at least one man I know to lose his life. Alan Nelson was out trying to support his 19 month old baby. His death was the event that forced me to do something. I did not want to come home one trip without my deckhand and have to inform his wife and three kids that I lost their father and husband at sea. I am responsible for the safety of my crew regardless of the laws we must follow. It also broke my heart to be forced to throw back so much of our catch even though most of the Regulatory Discards were obviously going to die. The fishery managers seem to feel absolved of any personal responsibility for their actions because they are just doing what they are paid to do.
Please keep an open heart and mind as you consider this comprehensive fishery management plan that I offer as an alternative to HB-353, catch shares, and derby fisheries. This plan could show other nations by example how they can limit waste while feeding more people and allowing stocks to achieve Optimum Yield. It is really not that hard if we simply use sound science, common sense, and remember the Golden rule. We should be focusing on enhancing our resources rather than just restricting access to them. Earth’s oceans and waterways have the potential to always feed many more people than they do now if we properly manage them.
I would like to point out that the vast majority of people involved in fishery management are good people. Most of them have good intentions and just want to earn a paycheck. There are a few public servants in the leadership with other motives. They seem to maliciously mismanage our fisheries in an attempt to advance other agendas like catch shares and area closures. If their actions are not malicious, the only other option is gross incompetence. One example of this is that they refuse to properly manage the lower quotas with possession limits that are adjusted throughout the year to levels that would fill the quotas without any long closures. This creates dangerous derby fisheries like the one that cost Mr. Nelson his life. The fishery manager’s only answer to end this is a catch share scheme that destroys many of the small businesses in every fishery they “help”. Catch shares are not so much a management tool as they are an allocation tool. Big corporations will in time own our fisheries and control your access to local seafood.
Some environmental “charities” have been aggressively advancing Agenda 21 mandates in fishery policy while most of the rest passively support these efforts. Fleet consolidation through catch shares and massive area closures using the Precautionary Principal seem to be the two biggest threats at this time. Some environmentalists even want to ban fishing. I have learned these things the hard way as I initially reached out to the “charities” that showed up at fishery meetings. I did not think they would want countless dead and dying fish to be discarded and wasted. I thought they would have a little compassion for their fellow man and support actions to promote our safety at sea. My blissful ignorance was shattered as one “charity” after another told me things like fishermen are liars and deserve what we are getting. They did not even care about the fish. The Regulatory Discards and compromised safety helped them advance Agenda 21. I have challenged several environmental “charities” to a televised public debate about how we should be managing our fisheries. They have all refused! They should be willing to defend what they are paid to believe. I will state my case and defend it!
There are three key things we need to do to properly manage almost any fishery. Permit holders in individual fisheries should come up with specific management plans for their fishery that follows all of MSA mandates. Fishermen should have final approval of any plan with a 2/3 majority vote of permit holders in the affected fishery.
1. Establish a Total Allowable Catch (TAC) for each targeted species and a by-catch allowance for non-target species.
2. Remove all size limits. They have proven to be a government mandated waste of our resources. The fishery managers currently allocate up to 100% of a TAC to Regulatory Discards that are mostly associated with size limits. An average of 30% of a TAC is allocated to dead discards of undersized fish. This adds up to millions of pounds of perfectly edible seafood that is discarded and wasted in the name of conservation.
3. The final part of this simple management plan is to properly manage the quotas with split seasons and possession limits that are adjusted to levels that fill the quotas without any long closure. Here is an example for the approximate Vermilion Snapper TAC.
The Vermilion Snapper TAC is about 1,000,000 pounds. The tragic waste associated with size limits requires about 300,000 pounds be allocated to dead Regulatory Discards. This leaves an Annual Catch Limit (ACL) of 700,000. The ACL should be split into two seasonal quotas that begin with the best times of year to catch them. The first 350,000 pound seasonal quota should begin in March with a Trip Poundage Limit (TPL) of 1,000 pounds for each vessel. The TPL should be adjusted to a level that fills the quota without a long closure after approximately 75% of the seasonal quota has been filled. This is a breakdown of how the adjustments should go.
a. Keep the TPL at 1,000 pounds if there is only one month left in the season.
b. Adjust the TPL to 500 pounds if there are two months left in the season.
c. Adjust the TPL to 300 pounds if there are three months left in the season.
d. Adjust the TPL to 200 pounds if there are four months left in the season.
e. Adjust the TPL to 100 pounds if there are five months left in the season.
The next season would start in September with a 1,000 pound TPL. Any overages from the last quota could be deducted and any unused quota should be added to the next seasonal quota. Every species should be managed this way. We could target the species with high TPLs while still keeping those with lower TPLs. This would achieve any honorable goals of catch shares.
Removing size limits and properly managing the quotas would eliminate most of the waste in our fisheries. We could avoid even more waste with this additional action. Set aside ten percent of each TAC that should be greatly increased with the removal of size limits for the poor. This would create a cushion for both the fish and fishermen. Recreational fishermen could donate any fish they did not want to eat to the quota for the less fortunate. Commercial fishermen could bring in our entire catch and sell our possession limits. Any overages could be donated to the quota for the poor rather than discarding the seafood or facing heavy fines, seizure of our property, and even imprisonment. This would allow us to make wise use of everything that is being killed while collecting accurate date to use in credible stock assessments and for properly managing quotas. This would provide consumers with a dependable supply of safe American seafood throughout the entire year. It would also allow fishermen to work all year. It would follow the MSA mandates to limit waste, make efficient use of our resources, and promote our safety at sea. We should not be torturing fish to death and wasting them to “help” them. We should kill what we catch quickly and use it wisely. Everything landed should be counted against the possession limits and the quotas.
There are three key things needed to enhance a stock of fish in the water or wildlife on land.
1. Increase the amount of food available.
2. Increase the amount of shelter available.
3. Predatory stress invokes a reproductive response.
Keeping the fisheries open all year creates consistent predatory stress that causes fish to produce more offspring. Removing the size limits also allows more of the large breeders to continue replenishing the stock. Removing nothing but the large fish causes the gene pool to be polluted by runts and smaller fish. We are left with a glut of small, weak, slow-growing fish. This negatively impacts the overall health of the stock and the average size of the fish in it.
The amount of food and shelter could be increased with an aggressive Artificial Reef (AR) program. ARs are the perfect union of aquaculture and commercially or recreationally harvested wild fish. The ARs can be very cheap and effective. We can feed many more people than we do now if we enhance our resources rather than always restricting our access to them.
Inshore fisheries could be helped with portable aerators that could be moved to areas with low oxygen levels that cause millions of fish to suffocate every year. The aerators could also help to break down pollutants and keep Speckled Trout from freezing to death during cold-stun events.
One of the unintended consequences of the mismanagement of our fisheries is that we are losing many of the places on the water to unload our seafood. I would like to see some of the grant money for working waterfronts and funds from the Saltonstall-Kennedy tax on imported seafood be used to create Community Seafood Unloading and Processing Facilities (CSUPF). These waterfront facilities should be accessible to existing dealers and seafood markets. They could double as museums to preserve the fishing heritage of the area where they are built. Tourist and locals could visit the museums and also watch as local seafood is unloaded, inspected, and labeled as Wild Caught Seafood from the state the facility is located in. The CSUPFs would also be a great place for scientists and students to collect tissue samples and take measurements of many different kinds of seafood. Markets could be cultivated for underutilized species like the skates and rays that are eating most of the Bay Scallops in North Carolina before fishermen have a chance to harvest them for consumers. Marine patrol officers could watch as catches are unloaded. They could collect any seafood that exceeded possession limits for the quota set aside for the poor. The cleaned seafood could be shipped to soup kitchens and food pantries. This would feed many hungry people across America every day.
These common sense solutions are based on a deep love of the sea as well as input from fellow fishermen, fishery managers, environmentalists, and concerned citizens. I tried to come up with ideas that are easy to implement and enforce while benefiting all user groups and our marine resources. We could actually increase the amount of seafood available for recreational and commercial harvest while feeding many more people and allowing stocks to rebuild from decades of mismanagement. We could do this without causing hard-working American fishermen to be forced out of their chosen profession or compromising our safety at sea. We could also stop wasting tons of perfectly good seafood. We simply need to use sound science, the slightest bit of common sense, and remember the Golden Rule.
I would like to take this opportunity to publicly challenge PEW, ED, CCA, and any other charity involved in fishery issues to an online typed debate that anyone interested can view. I also extend this debate challenge to Roy Crabtree, Gregg Waugh, David Cupka, Tom Burgess, or any member of the South Atlantic Fishery Management Council, National Marine Fisheries Service, and the National Oceanic and Atmospheric Administration. Please contact me if you will accept my debate challenge or want to observe it. firstname.lastname@example.org I will be happy answer any questions about things like removing size limits or how Artificial Reefs can be the perfect union of aquaculture and commercially harvested wild fish. I want to have an honest discussion about how we can always have a responsible harvest of healthy fisheries with very little or no waste.
Please take a few minutes to send a copy of my plan to your politicians and these people.
This is a link to members of the U.S. Senate: http://www.senate.gov/general/contact_information/senators_cfm.cfm
This is a link to members of the U.S. House of Representatives: http://www.house.gov/representatives/
This is a link to members of the N.C. Legislature: http://www.ncga.state.nc.us/
This is an e-mail address for the N.C. Maritime Strategy Committee: email@example.com
This is an e-mail address for N.C. Governor Perdue: firstname.lastname@example.org
This is an e-mail address for PEW: email@example.com
This is an e-mail address for Environmental Defense: firstname.lastname@example.org
This is an e-mail address for the Coastal Conservation Association: email@example.com
This is an e-mail address for Roy Crabtree: firstname.lastname@example.org
This is an e-mail address for Gregg Waugh: email@example.com
This is an e-mail address for David Cupka: firstname.lastname@example.org
This is an e-mail address for Tom Burgess: email@example.com
I know this is a lot of people to contact. Please just send a copy of the plan or a link to it to at least one person whenever you can spare a minute of internet time. You will be helping to feed the hungry and stop the waste of our resources. Think of it like the games many people play online, but one that actually benefits society and does more than pass time. Please help me defend this freedom and resource that I love the way you would like me to help you if the roles were reveresed. This is a great way to practice the Golden Rule. The only way any of this plan will be implemented is if enough concerned citizens show their support for it. Thank you!