The author is the owner/operator of a commercial longline boat operating in the shark and grouper fisheries of the Gulf of Mexico.



What do the terms that NMFS makes so many decisions based upon actually mean?

Well, the truth seems to be, "your guess is as good as mine." As far as I can tell, the definition of "undergoing overfishing" and "overfished" aren't based on any concrete evidence, don't require any strict adherence to any particular standards and are actually a bit cyclical. A fish stock is undergoing overfishing if it is overfished and it is overfished if it has undergone overfishing.

Get it?   No?   Me neither.

OK, well how about the NMFS' own actual definitions? On the sero.nmfs.noaa.gov website (what scientist doesn't love a good acronym?) you can download the GULF OF MEXICO GROUPER MANAGEMENT IN FEDERAL WATERS FREQUENTLY ASKED QUESTIONS .pdf (and what government employee doesn't love a good long name for a proprietary file?) where you can read their own definitions:

“How do fishery managers determine whether fish populations are undergoing overfishing. . . ”
“A fish population is considered to be undergoing overfishing if it is fished at a rate that exceeds the rate that would produce the maximum amount of fish over time.”

“How do fishery managers determine whether fish populations are . . . overfished?”
“A fish population is considered to be overfished if it declines below a legally defined threshold level, which is defined differently for each fish population based on life history characteristics and other factors.”

OK, got it now?   No?   Me neither.

I do have a couple of questions though, please.

  • How do they know what the rate is that would produce a maximum amount of fish?
  • Is that maximum stock of fish or maximum catch of fish?
  • If it is stock, doesn't no fishing equate to the rate that would produce the maximum amount of fish?
  • If it is catch, wouldn't unregulated fishing with no limits produce the maximum amount of fish?
  • Who determines what the maximum amount of fish is, anyway?
  • Over how much time?
  • How do they know what the population is or what it has declined to?
  • Who defined the threshold level anyway?
  • What is the threshold level?
  • What the hell does that even mean?
  • Whose life history characteristics are these threshold levels based on?
  • Who collected all these "life histories" anyway?
  • What exactly are these "other factors"?

Too many questions. Far too few answers.

The simple fact is, they are making conclusions based on lousy data, much of which they just plain make up. These conclusions affect the lives and livelihoods of many people. Not just the fishermen and their families suffer, but everyone involved in the whole trickle down effect of cutting off the domestic fish supply suffers. Fish houses suffer. Fish house workers suffer. Bait, ice and tackle suppliers suffer. Fuel docks suffer. Truck drivers suffer. Restaurants and their workers suffer. Retail fish markets and their employees suffer. And then, at the bottom of the stream, tourists suffer through imported fish dinners often being passed off as fresh local products.

The only people who don't suffer are the scientists and government employees who are traipsing from one meeting held at a Mariott resort with rates ranging from $109 to $309 per night ("Nestled on a 1,100-acre wildlife sanctuary, the Bay Point Marriott Resort offers relaxing recreational activities, top-rated golf courses, and thrilling water sports in a luxurious resort setting") to another held at "The Doubletree Hotel in the fashionable Coconut Grove area of Miami" (with rates starting at $199/night) for week long "workshops" to discuss the same old papers and catch records, all faulty or fatally flawed, over and over again before harrumphing a few times and determining that yes, the poor fish are suffering at the hands of that dadgum criminal element masquerading as a commercial fishing industry trying to produce a food product for the domestic market.

One paper used to determine the health of the sandbar stocks surveyed the Large Coastal Shark population in the eastern Gulf of Mexico from 2001 to 2004 and used a fishing method that no commercial shark fisherman would ever use, it just doesn't catch enough fish. It also used longline gear, which does catch fish, but it used steel leaders which don't catch sandbars, small "j hooks" which don't catch sandbars, fished during the daylight hours which doesn't catch sandbar sharks, soaked the gear for 4 hours which isn't long enough for any success and then...surprise...arrived at a "catch per unit effort" that no commercial fisherman would be able to stay in business working with.

(I'd cite the exact paper I'm referring to here but, mysteriously, they ask that you not cite the papers being used to make these assessments since the papers themselves are only part of the process and the results may differ.) Hunh? Yup, they really do. Look at this page, then take a look at the list of the papers used. The one I'm referring to is only one of many but it is one that arrives at some very important and very wrong conclusions that have apparently been accepted as valid by those attempting to shut down this fishery.

They simply do not know how to collect the data, yet they continue to act as if the data they have collected is valid and use it to make decisions that are life altering for a whole industry and its participants.

They point out that the workshops are "open to the public" and that they encourage participation from those impacted by the results....yet two out of the last three Large Coastal Shark workshops took place during limited shark openings and all three were held at expensive beach resorts, spread out over the state. The only people who can afford to attend them all are the people holding them who attend at public expense and have little else to do with their time since discussing these lousy figures and statistics is their actual job.

Me, I think I'm going to go overfish something.


Michael Athorn: for grouperboat.com

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