"Dr. Lubchenco, last October during the American Sportfishing Association's annual meeting, you stood before the sportfishing and boating community and pledged to be our champion, saying that you are personally committed to a national policy which recognized the importance of recreational fishing and ensures that it can continue to thrive," the Feb. 23 letter states. "Given the impending breakdown of recreational saltwater fisheries management in this country, the nation's recreational fishing and boating community urges you to take immediate action within your administrative authority to address the severe, and escalating, restrictions on recreational saltwater fishing."
The letter from the American Sportfishing Association, The Billfish Foundation, the Center for Coastal Conservation, the Coastal Conservation Association, the International Game Fish Association and the National Marine Manufacturers Association asked Lubchenco to implement three specific actions:
• That she mandate "decisive, immediate action" to improve recreational fisheries data through the redirection of funding and personnel to focus on real-time management data.
• The collection of socio-economic data about the potential impact communities affected by closures.
• That federal-level direction be provided to fishery management councils "to use common sense in their management approaches while the administration collects the requisite data to make sound management decisions."
"Following decades of inadequate data collection, stock monitoring and assessment, we believe that the recent closure of the South Atlantic red snapper fishery and the proposed closure of over 12,000 square miles to all fishing from 98 feet to 300 feet is the tipping point of what we view as a fisheries management 'train wreck' that calls for immediate administrative and fiscal action," the letter to Lubchenco reads. "The January 2010 Atlantic red snapper fishery six-month interim closure, on the heels of the first stock assessment in 10 years, is only one example of what is a looming fisheries management 'train wreck.'
"Mandated annual catch share limits for the Gulf of Mexico reef fish complex is another example; 30 of the 44 species found there have never been assess and basic biological information is lacking."
Coalition members suggested eight actions Lubchenco could take to implement the requested administrative and funding changes:
• Substantially increasing funding for improved recreational data and statistics programs focusing on catch data, economics and stock assessments for each of the next five fiscal years, as well as funding for permanent and continuing data collection and analysis.
• Creating a multi-pronged program to promote and implement angler catch-and-release techniques that will reduce release mortality, improve fisheries conservation, and expand and improve ethical angling practices.
• Making potential regulatory changes to provide regional fishery management councils the authority to include adaptive management and experimental alternatives in rebuilding plans.
• Developing a program within NMFS to assist in the restoration and enhancement of a fishery and its habitat using techniques such as artificial reefs, hatchery operations and other proven programs.
• Expanding the required economic impact analysis of fishery management measures to include impacts on all associated industries, such as tackle shops, manufacturers, marinas, restaurants and other businesses. Also, require fishery management councils to adjust management measures to mitigate these impacts.
• Identifying and consistently implementing fishery independent stock assessment technologies to improve the accuracy of stock assessments. Suggestions included use of acoustic technology, DNA tagging and underwater video. This item would also include a pilot project through the Cooperative Research Program to focus on improving data for the South Atlantic red snapper fishery.
• Convening a blud-ribbon panel with NMFS, industry, state and interested nongovernmental organizations to identify the long-term data, statistical, reearch and funding needs of the regional fishery science centers.
• Developing a recreational-fishing program and staff within NMFS that is commensurate with the national economic contribution of recreational fishing.
The coalition believes these steps would reverse draconian measures made necessary because of NMFS official's refusal to invest in gathering scientific data.
"The recreational fishing industry is faced with massive fisheries closures, and the attendant job loss, because the appropriate investment in recreational fishery economics data and angler catch data has not been made," the letter points out. "In addition, stock assessments for recreationally important species have been a lower priority for NMFS than is justified by the economic contribution of the recreational fishing community."
The coalition also pointed out that recreational fishing accounts for a mere 3 percent of marine finfish landings by weight, but produces 56 percent of the jobs from all saltwater fisheries.
"Unquestionably, marine recreational fishing is a coastal economic engine that deserves an investment commensurate with the jobs and economic output it provides to the nation, not to mention the millions of hours of recreation it provides to 13 million saltwater anglers who have an $83 billion impact on the nation's economy," the letter reads. "The agency (NMFS) needs to focus on the sector that has the least environmental impact but provides the largest economic return to the nation's economy and allocate fisheries on that basis."