October 22, 2009
The Honorable Gary Locke
Secretary
U.S. Department of Commerce
1401 Constitution Ave., NW
Washington, DC 20230
Dear Secretary Locke:
As governors of Gulf Coast states, we are concerned at the direction and rapidity
in which the National Oceanic and Atmospheric Administration (NOAA) is moving to
implement “catch shares” programs for fisheries in the Gulf of Mexico. Our concerns
center on the potential negative impacts catch shares programs could have on our states’
economies, as well as how such programs could restrict citizens’ access to the fisheries
resources that should be shared by all.
While much emphasis is placed on the beneficial economic impact of commercial
fishing, it is important to keep in mind that recreational fishing generates some $24
billion to the economies of the Gulf States.
We understand that catch shares systems for resource management can be
effective when applied to purely commercial fisheries. However, we are concerned about
the impact catch shares could have when also applied to recreational fishers. The fisheries
being discussed in the Gulf of Mexico are managed jointly by the relevant coastal states
and the federal government. As such, the states and our citizens are partners in the
stewardship of these resources and the benefits of their use. Each of our states enjoys the
benefit of productive fishery resources, which generate significant recreation and seafood
revenues for our citizens. A healthy marine resource is vital to the local economies of
our coastal communities and is a significant contributor to the overall economy of each of
our states.
We have already seen negative impacts from the Gulf red snapper catch share
system and are concerned about negative impact from the pending program for Gulf
grouper. Creating an exclusive harvesting right for a small group of commercial
fishermen inherently marginalizes other users who do not have the same access
privileges. Those other users, recreational fishermen and commercial fishermen without
access rights, would be excluded. In purely commercial fisheries this effect can have
both economic and management benefits. But when applied in mixed-use fisheries,
recreational anglers are forced to focus their efforts in limited state waters or not
participate in the fishery at all. Neither of these outcomes is desirable.
Honorable Gary Locke
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Access and opportunity are the lifeblood of recreational fishing. Catch shares
limit accessibility for those who do not have an opportunity to participate. While this
does not create a problem when the resource is targeted exclusively by one segment, such
as commercial fishers, it squeezes out other users when applied to a mixed-use fishery.
We would like to be able to give assurances to our constituents that NOAA will not
attempt to extend catch shares policies to the recreational fishing sector.
It is also important to point out that each of our states has had great successes in
the management of recreational fisheries, and have never required limiting public access
to the resource through exclusive rights. In almost every case, the resource has enjoyed
great recovery while recreational fishing opportunities have actually been expanded.
We are concerned that in the desire to adopt and implement catch share systems
NOAA has forgotten its most fundamental responsibility under the Magnuson-Stevens
Fishery Conservation and Management Act—to maximize the net economic value from
the use of a public resource. Recreational fishing is an important activity in all of our
states, and one that we would like to see continue to grow as a healthy activity for the
public. However, we are concerned that NOAA policies could frustrate our ability to do
that.
We are confident that you, as a former Governor, understand our perspective. We
request that you allow each of the Gulf States to be able to protect its citizens’ access to
public fishery resources by allowing us to serve a key role in the decision process as to
which fisheries will have a catch share program, how those programs would be
structured, in determining the length of the subsidies in the program to the commercial
fishery and assuring proper allocation of the resource in advance of implementing any
catch share program.
We look forward to working with you to find a system that will balance your
goals for catch share systems with the needs of our citizens.
Sincerely,
Governor Rick Perry Governor Bobby Jindal
State of Texas State of Louisiana
Governor Haley Barbour Governor Bob Riley