Seafood Harvesters Letter Regarding Wicker Amendment to S. 1520

February 27, 2018 - Published in News Releases and Advocacy

Senator John Thune, Chairman
Committee on Commerce, Science, and Transportation
United States Senate
512 Dirksen Senate Office Building
Washington, DC 20510


Senator Bill Nelson, Ranking Member
Committee on Commerce, Science, and Transportation
United States Senate
512 Dirksen Senate Office Building
Washington, DC 20510


Dear Chairman Thune and Ranking Member Nelson,

We understand that Sen. Roger Wicker may offer an amendment in the nature of a substitute at the forthcoming markup of the Modernizing Recreational Fisheries Management Act of 2017 (S. 1520). The Seafood Harvesters’ of America (“SHA”) previously wrote to you to express concerns about that legislation (see attached February 16th letter). We again write to say that while we appreciate the efforts to revise the legislation the proposed changes fail to adequately address our concerns.

Specifically, SHA:

  • Opposes mandatory allocation reviews for fish stocks. (Sec. 101) The revised language is limited to the Gulf of Mexico and South Atlantic. These mandatory reviews only serve to burden councils by imposing costly requirements on them. Section 101 would require the South Atlantic and Gulf Councils to set aside their annual work setting catch limits and seasons for all of their managed fisheries and developing amendments to those fisheries to improve their management in order to conduct allocation reviews on all of their mixed-use fisheries. Allocation reviews should never take priority over seasonal fishery management work and management improvements of a council’s fisheries. Councils already have the ability to review allocations, and they in fact do periodically review allocations. It is therefore not necessary for Congress to impose those reviews on the councils – and in this case only two of the eight regional management councils. Section 101 would simply degrade these Councils’ ability to manage all of their species at the expense of all fishermen.
  • Opposes efforts to remove limited access privilege programs (LAPPs). (Sec. 103) LAPPs are a proven, effective management system for commercial fisheries. The revised legislation would impose a two-year moratorium on LAPPs (with limited exceptions) by the Gulf of Mexico, South Atlantic, and Mid-Atlantic Fishery Management Councils. It would also require yet another study by the National Academy of Sciences on LAPPs. LAPPs have proven to be effective management tools for commercial fisheries, and a study moratorium is not necessary, even for mixed use fisheries. If there is a desire to utilize NAS resources to study fisheries, a better use may be to review alternative fishery management regimes for the recreational sector. Section 103 also would require modifying existing LAPPs to conform to the recommendations of a study that the Congress hasn’t seen yet. The Commerce Committee should have an opportunity to review any LAPP study before deciding whether its recommendations should be required to be implemented. For example, section 201(b) of the bill directs the Secretary to implement, to the extent practicable, the recommendations of a completed NAS study on recreational catch data collection. Any study on LAPPs deserve the same careful review by the Committee before changes are made.

SHA’s issue is that neither of these proposals will improve the management of the recreational sector. Nor will they improve management of the commercial sector. They will simply make it more difficult to effectively manage the commercial sector. That should not be an acceptable outcome of a legislative effort.

We therefore hope that the Commerce Committee will reconsider this legislation and will continue to support the commercial fishing sector – a sector that provides American fishing jobs, supports fishing communities, and ensures continued access to fishery resources for consumers and the public.

Thank you for your consideration on this matter.


Christopher Brown, President

Seafood Harvesters of America

Member organizations:

Alaska Bering Sea Crabbers

Alaska Whitefish Trawlers Association

Cape Cod Commercial Fishermen’s Alliance

Cordova District Fishermen United

Fishing Vessel Owners’ Association

Fort Bragg Groundfish Association

Georges Bank Fixed Gear Cod Sector, Inc.

Gulf Fishermen’s Association

Gulf of Mexico Reef Fish Shareholder’s Alliance

Midwater Trawlers Cooperative

New Hampshire Groundfish Sectors

North Pacific Fisheries Association

Purse Seine Vessel Owners Association

Rhode Island Commercial Fishermen’s Association

South Atlantic Fishermen’s Association

United Catcher Boats


CC: Senate Commerce, Science, and Transportation Committee members

S.1520 co-sponsors