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Draft Saltwater Recreational Fisheries Policy Response


Jerry A
Background: Today (November 19, 2014) NOAA Fisheries released a draft Saltwater Recreational Fisheries Policy for public review and comment until December 31. Developed in cooperation with anglers, the Regional Fishery Management Councils, and the Interstate Marine Fisheries Commissions, the policy will serve as a guide for agency actions and responsibilities. Sources:

1. http://www.nmfs.noaa.gov/sfa/management/recreational/policy/index.html
2. http://www.nmfs.noaa.gov/sfa/management/recreational/documents/recfish_policy_public_comment_draft.pdf
3. http://www.nmfs.noaa.gov/sfa/management/recreational/documents/recfish_policy_fact_sheet.pdf
4. http://www.nmfs.noaa.gov/sfa/management/recreational/documents/recfish_policy_discussion_guide_final.pdf

Draft Saltwater Recreational Fisheries Policy Response
Submitted by Jerry A. Adams, <insert address here>
November 25, 2014

Point #1
Any National Policy reaches far beyond the individual States jurisdiction. It is important that we include worldwide partners as well including likeminded groups like the Organisation for Economic Co-operation and Development (OECD). Including all interested parties would build a cooperative resource that could be utilized in many ways. As the European Alliance Anglers share the same global body of water that we do their interpretation and scientific research goals should be integrated as well. The more diverse people we have working toward a common goal the better result we?ll all enjoy in the end.

Point #2
Take the case of Recreational Angling vs Angling for profit. The European Anglers Alliance produced a definition on Recreational Angling agreed to by the European Anglers Alliance at the General Assembly 2004 in Dinant, Belgium. The OECD defines recreational fishers/fishing, in general, refers to fishing for sport or pleasure. I believe that the distinction should be clearly made between one that utilizes a shared resource solely for self-sustenance, sport or pleasure and one that does so for profit. It does not matter if the person typically utilizes a resource for self but occasionally does so for profit. In planning and organizing a shared resource these two activities must be distinctly separated and dealt with differently ? no matter how the catch is made. Here I refer to the European Anglers Alliance's definition on Recreational Angling defining recreational angling as the activity of catching or attempting to catch fish, principally by rod and line, pole or hand-held line for non-commercial purposes; provided recreational anglers do not sell the fish they catch. I do not want to exclude the many other ways in which fish and other desired aquatic organisms are captured; ie. nets, woven traps, weirs, diving, spearfishing, hand fishing, doodling or noodling, etc.

I disagree with the European Anglers Alliance definition of Other Recreational Fishing that includes long lines. Long line fishing is a commercial fishing technique, for profit. We must make a clear cut and unambiguous distinction between what is done for self, or for the family group (individual consumption), and what is done for profit. By definition recreational angling is not done for profit. Angling for profit, no matter how small the impact on the shared resource, must be held under commercial fisheries rules and not be a part of the ever decreasing recreational take allowed.

Point #3
This is a selfish point but I feel that it is one that needs to be made. The needs of the recreational fishers/fishing and the Recreational Angling Sector (RAS) or the economy that these activities supplement should take priority over commercial fishing ventures. The RAS includes but is not limited to, ?tackle shops and tackle manufacturers, bait suppliers, charter-boating, recreational boat builders and handlery suppliers, marina operators and specialised angling media, angling tourism and other related business and organisations as well as the whole management environment (e.g. public agencies) to varying degrees dependant on or directed at recreational angling.1?

An alternative to commercial fisheries lies in initiatives wherein individuals are making a case for raising fish for consumption in self-contained structures. They take no water from the outside world, I'm assuming after the initial setup, and release no effluent back into the general eco-system. What this means is that since it is a self-contained sterile, if you will, environment there's more control over the fish than is available in the open water fish farms. These large-scale aquaculture growth centers are creating technology and building fish factories on land, releasing almost no pollution and in turn are fertilizing vegetable crops with the waste product. These farmed fish never need antibiotics, hormones or other chemicals to keep them healthy. And because they are kept in optimal conditions, they grow twice as quickly as fish in traditional net pens.

Of course in my black and white military mind I think of the areas of the country where land once was passed over because it had little or no agricultural value, from a surface farming perspective. This could be a real estate initiative as well. One could place an operation like this just about anywhere in the country and close proximity to the market place would make transport costs less and keep the product fresher for the consumer. I think it's a very neat idea and making the needs of the recreational anglers a priority will help to drive technology like this to feed the masses rather than relying upon a finite and limited resource wild catch to do so.

Thank you for providing me with the opportunity to be heard on these important issues. Jerry A. Adams

1 http://www.eaa-europe.org/fileadmin/templates/eaa/docs/DEFINITION-EAA_Angling_Def_long_FINAL_EN.pdf