Yes I agree on Amendment 16. Fishing during Jan to April is to windy to enjoy anyway , Let the Grouper has some fun and multiply. I use Circle hoods all the time with no problem. Just let the fish take it a little longer. One question comes to mind. Will the bait rigs with small hooks also be circle hooks. Be kinder hard to catch bait with them.
Regards; Bob La Barbera Marathon FL
Dear S. Atlantic Council Members,
First, I would like to state that the purpose of my comments are just to address concerns that we have with the data used for decisions on the management of the fisheries in our region. It seems that for too long the subject of the proposed "problem" isn't always defined prior to a "solution" being derived. Public meeting inputs have the attitude that the decision has already been made. As a fishermen, I would be more than happy to supply data as would many of the fishermen I know, if you would educate us on what you need for information and assistance.
Just finding out about these meetings is hard enough, try getting on the SAFMC website and finding SEDAR 10 REPORT or Magnuson Stevens Scoping document and reading the entire thing along with understanding it is another issue altogether.
Too long have fisherman been pitted against each other, both commercial and recreational, in an attempt to, in my opinion, redirect focus on the issue at hand. Any form of accountability on the council's part for the decisions made on our behalf as fisherman, doesn't seem to exist. Decisions are made that do not seem to have both the fish stock and fisherman's best interest at heart. Politics appear to also be playing a huge role in the decisions made on our behalf and do at times, seem detrimental to the cause.
The council's actions are speedy mechanisms to put increased restrictions on a fishery, yet there are no such speedy mechanisms to decrease restrictions should any fishery’s biomass indeed increase to healthier levels, or have new data to contradict the imposing limits. We hear how it needs to produce results over a long time period such as 10 years to be accurate. Please don't site here how we can now catch more porgy. That is a sad example on the council's part at best. Historically, regulations don't give back but become more conservative in restrictions.
These viewpoints are directed towards Amendment 16 yet hold true of all others that are being reviewed at present.
As I have read extensive amounts of information including SEDAR 10 along with information from the SAFMC, etc. I have a couple of points that I would like to bring up.
From the SAMFC website and I quote
Lack of basic management data on many of the species still remains the major obstacle to successful management. MRFSS surveys have been proven unreliable. What changes in the last 10 years have been changed to upgrade the survey system? MRFSS is usually a year or two behind in estimating this trend, so my main concerns are about over-regulation that may not be warranted. MARMAP surveys on "random hard bottoms" are the basis of most surveys done. We are talking about reef fish, fish that look for live bottom and structure to make their home. Data collections from things like "Chevron traps" were inconclusive due to such low catch rates and classified as "indeterminable and inaccurate" after 27 years yet older data is still used to calculate present trends. Why are things like wave heights, sea surface temps, surface currents, hurricane impacts, DO, salinity, wind speed, wind direction, etc not included in present studies? Why are issues like water quality and pollution along with protecting our juvenile fish using our estuaries for growth not addressed or protected? We can pay a hog farmer or tobacco farmer not to raise their crop yet we don't address the shrimping bycatch that is drastically affecting our fish stock? Please don't tell me how great the "bycatch" gear is doing in the shrimping industry, the bycatch being shoveled overboard looks like a snow storm floating on the water coming from a shrimper. I understand they have to make a living, however, subsidizes their income for the percentage necessary and stop letting them trawl on the inside and watch how well our fisheries rebound. I am concerned on how "overly conservative" the council seems to be in their calculations and proposed regulations. Below are some of the areas that if corrected to more realistic parameters, would take us out of the "overfishing" category that the grouper and snapper species are presently assessed as.
I am concerned that F (fishing mortality; the percentage of the population that dies each year from fishing) is overstated partly because it is based on
1. Marine Recreational Fishing Statistical Survey (MRFSS) estimates of landings and discards, which have been declared unreliable and even ‘fatally flawed’ and
2. An overstated recreational release mortality of 25%.
Recreational fisheries Release mortality is presently assumed to be 25%, SEDAR 10 workshop stated Improved estimates of post-release mortality were obtained through tag release and caging methods (Burns et al. 2002; Overton and Zabawski 2003; McGovern et al.2005). Using these methods, mean mortality rates were estimated to be 21.2% (Overton and Zabawski 2003), 23% over a variety of depths (McGovern et al. 2005). Commercial fisheries Release mortality is presently assumed to be 40%. Your reasoning behind the proposed legislation is that the FMSY is below the F (Fish Mortality) factor, the FMSY has remained below the F (Fish Mortality) factor since 1983 in the S. Atlantic. With the council willing to error on the side of "conservative numbers and factors" is it any wonder this is the trend? Now take a look at our stocks. Have we decimated our biomass? No. Clearly real world numbers aren't being used to guage accurate regulation.
How can the Magnuson Stevens Act expect you to make changes within 1 year of notification if the council states that it takes 3-8 years to schedule and complete a stock assessment? For that matter, why, if notified that a stock is in "trouble", aren't the data compiled between the last stock assessment and the present date of the notifications, reviewed to determine if an issue really exists at the present notification time period prior to taking action?
According to your own data workshops, spawning stock biomass increased after 1999 corresponding to implementation of the 24 inch minimum size limit. Fishing mortality has been decreasing since 1992 yet the gag grouper lifespan has just been raised to 26 yrs to 30 years. The life expectancy factor has been raised recently which is also affecting the formula into an "overfishing" status.
50% of maturity is 3 years and 25.5 inches. Why don't we increase the minimum size limit to 26". It has proven effective for the size increase in 1999 to 24".
Fishing mortality in 2004 was estimated as 0.31, extremely conservative against 2007 projected mortality.
Why is the fishing mortality rate for 2007 not being used? Obviously the fishing pressure has reduced since 2004 yet the OPPORTUNITY to fish hasn't been reduced which I think is very important and not usually taken into account when new regulations are proposed.
The council can redo the entire Vermillion Snapper stock assessment due to concerns of accuracy and possible "gross negligence" of the last assessment with updated data, yet I am told by the council that the 2004 data used in SEDAR 10 for grouper won't be updated until 2011? Are you kidding me? With the impact that fuel has alone on the frequency of fishing trips which has been declining since 2004, why can we not use current data and revisit the workshop to determine if the present proposed measures are necessary?
How can there be underfunding on the federal or local level to interpret the data that is taken every year but not incorporated or used due to lack of resources and man power as stated by the council with 3-8 years between stock assessments?
Why are the conclusions and recommendations from the data and review workshops which are and from the SEDAR programs not incorporated into the councils decisions on a "less cautionary or overly conservative" approach?
SEDAR 10 biologists recommended changing the MSST, SSB, M, F, MFMT and alike, in one form or another due to "overly conservative" concerns.
MSST, currently defined by the South Atlantic Council as (1-M)BMSY, is very close to BMSY because age-averaged natural mortality rate, M, is estimated as 0.14. It was recommended to change the M and wasn't done. It was stated that "the stock is not overfished and is not projected to become overfished."
Given the uncertainties in the assessment, the biomass would be expected or could possibly, fall below MSST with a relatively high frequency even if the true biomass were close to BMSY. In Sedar 10 the Review Workshop stated that the current definition of MSST may be overly conservative and recommends an operational definition of MSST of 5 million pounds. Yet it is still the factor of 6.8 million pounds was used.
The MFMT factor is also showing signs of being overly conservative. Why the council feels the need to error on EXTREME caution I don't understand.
Then Natural Mortality Rate formula was calculated using the Hoenig 1983 program. A program which has flaws due to the fact that the estimate of maximum age required by Hoenig's method assumes that the age determination technique being employed is unbiased. Validating this assumption is often difficult for the older, more difficult-to-age individuals but can be accomplished by using a variety of techniques ranging from marking to analysis of radioactive isotopes (Lai et al., 1996). The estimate of longevity is also dependent on sample size and previous fishing history, which by the way we don't have sound, accurate data on according to the councils own admission. Hoenig (1983) showed that maximum age tends to increase slowly with increasing sample size but longevity has probably declined from historical levels because of fishing. A small sample size for age determination, underaging, and previous exploitation would all result in an overestimate of M with Hoenig's method. Although compared to other methods, we still have an issue with accurate data and excessively cautionary management. Maybe we don't increase the Annual Catch Limits (ACLs) as aggressively using such precautionary regulation. The 2004 stock assessment model projections show the stock becoming overfished in 2007.
Greg Waugh states on 5/8/2008 that "the stock isn't overfished due to present reduction fishing pressure, attributed to several factors such as fuel costs." He also cited that "the assessment wouldn't be redone due to funding and scheduling issues and would be revisited in 2011."
It is an natural assumption with the current economic situation and petroleum driven influence on our daily lives that there has been a significant decline in fishing pressure on all fishing stocks yet the council seem reluctant to revisit the issue since they already have time and effort invested into them and have decided to "stick" to their original conclusions.
Maybe we use data more current than 2004 and realize that the 37% reduction that you are calling for has already in part been addressed due to the cost of fuel and expenses that are incurred for offshore fishing. The Magnuson Stevens Act states that the new regulations need to implemented by 2010. That gives the council plenty of time to do a stock review with less conservative numbers as recommended in the SEDAR 10 program.
Maybe the council shouldn't use such a precautionary approach to regulation on data that they admit isn't as accurate or current to date as it should be.
I believe that if current, data were used along with the above mentioned conservative factors corrected, the councils need for new legislation may not be necessary after all.
How about in the alternatives offer for the public to pick from the economic impact for the entire S. Atlantic recreational impact with a 4 month closure will only attribute to a total of $ 1,032,000. An example is the entire state of NC will only have an impact of $ 37,000. That is ridiculous. That equates to 37 trips at a charter price of $ 1,000. The impact is for the "for hire" sector which is lumped in with the recreational sector as a whole. There is no account for the true recreational sector such as recreational food, fuel, hotel, shopping, tackle, boat maintenance etc. For a 4 month NC closure, $ 37,000, REALLY?
We would like to see the gag assessment redone. There are too many uncertainties and inconsistencies to move forward with an assessment that will affect such a large fishery.
- The Gulf of Mexico Grouper assessment has been reviewed due to some of the same questions. There were many corrections and this was done in less than 6 month time frame.
Fishing effort is significantly reduced and is not taken into account when calculating future estimates as it should be.
Economic impact and true fishing pressure of both recreational and commercial fishing is grossly inaccurate.
If after a review it is necessary to reduce harvest, only modest bag limit decreases or modest size limit increases should be considered acceptable if in fact a problem exists.
I am sure that the Council want to make sound decisions. The economic and social devastation wrought by these proposed Gag regulations comes at a time when effort is significantly declining (I feel permanently) due to exorbitant fuel prices. These current proposals are based on overly precautionary thresholds which compound to create the false sense of an unhealthy fishery, when in fact the fishery could be quite healthy.
Is it any wonder that the individuals that you are governing are not satisfied with the proposed solutions when they seem to have a better handle on the fish stock, behavioral patterns, abundance and realistic solutions and are not heard by you?
I urge the Council to:
1. Review the Natural Mortality Rate of Gag 2. Review and adjust the overly precautionary estimates 3. Provide the numbers for and consider as an alternative a 26” Gag minium size limit (20% or more reduction in rec landings alone) as the FIRST tool applied to the fishery. 4. Invite Dr. Trevor Kenchington to the SSC and Council meeting in June. Dr. Kenchington has extensive knowledge of both the Gulf of Mexico and the South Atlantic fisheries and could prove an excellent resource in the interpretation of current data parameters.
Thank you for your time and the opportunity to voice my concerns.
Best Regards,
Craig Andrews Southport, NC
Aquatic Release Conservation, Inc. PO Box 730248 • Ormond Beach, Florida • 32173-0248 • The United States of America Phone: (877) 411-4272 • Fax: (386) 274-2228 Email: [email protected] • Website: www.dehooker4arc.com
May 12, 2008
Bob Mayhood Executive Director South Atlantic Fishery Management Council 4055 Faber Place Drive, Suite 201 North Charleston, SC 29405 [email protected]
Re: Comment on Amendment 16 to the Snapper Grouper Fishery Management Plan
Dear Executive Director Mayhood,
We appreciate the opportunity that South Atlantic Fisheries Management Council (SAFMC) and NOAA Fisheries is giving ARC and the public to comment on this most important Amendment 16. We feel that we have been adequately informed and notified in a timely manner of all germane and relevant issues, options, and comment deadlines by SAFMC and NOAA Fisheries. We have received notice through various sources via the internet, notices, and public hearing notice.
Historical Participation
ARC is commenting on this Amendment 16 today as a historical participant in the reef fish fishery and Charter/headboat industry for over 35 years, a participant in the pioneer historical HMS fisheries for over 27 years, a private sector careful handling and release gear technologist and manufacturing company for over 17 years, as well as a post-release survival conservation organization. Many of ARC’s principles and fisheries partners are avid ethical recreational anglers.
Fisheries Partnerships
ARC continues working in cooperation and as a fisheries partner with the NOAA Fisheries, U.S Fish and Wildlife Service, FL Sea Grant, the Councils, Commissions, Mote Marine Science Lab, the commercial and recreational industry, NGOs, gear technicians, veterinarians, and researchers to co-design and co-develop safe handling and release technologies, tools, and protocols for the anglers and fishermen in order to safely release all hook and line caught aquatic resources in a manner that will ensure the maximum probability of survival, consistent with National Standard 9 of the (M- 1
SFCMA), Endangered Species Act (ESA), Marine Mammal Protection Act (MMPA), and other important national and international fisheries laws and conservation norms.
Ethical Angling
ARC is also commenting today as education/outreach instructors and conservation organization whose goals are to teach salt/freshwater youth and adult ethical angling, safe handling, venting, and release skills/techniques in order to significantly increase post- release survival of sea turtles, other targeted and non-target species, as well as protected resources. ARC has been and continues to be an advocate for the use of circle hooks in the commercial and recreational hook and line fisheries to further increase post-release survival of released aquatic species by reducing serious hook wounding and allowing for easier and safer hook removal.
ARC’s Comments:
ARC will focus its comments mainly on those Alternatives and areas in the fishery where we have the most experience and expertise. We have had a significant amount of experience and expertise in careful handling, disentanglement, venting and release technologies, techniques, protocols, and workshops in the South Atlantic, Caribbean, GOM, and Pacific domestic pelagic (PLL) and bottom longline (BLL) fishery, in the South Atlantic, Caribbean, and GOM, Charter/headboat reef fish industries, the Mid- Atlantic striped bass fishery and international PLL fisheries.
ARC agrees with, and recommends implementing all of Amendment 16 Actions, Preferred Alternatives, Preferred Options and Preferred Sub-options that minimize bycatch mortality of sea turtles, smalltooth sawfish, reef fish, and other targeted and non- targeted bycatch and/or economic and regulatory discards.
2.1.3 Reduce Bycatch of Snapper Grouper Species
Comment: ARC recommends Preferred Alternative 2c which states:
Alternative 2. Reduce recreational and commercial bycatch mortality by requiring the following for a person on board a vessel to fish for snapper grouper species in the South Atlantic EEZ:(a) use of venting and dehooking tools and (b) use of non- offset, nonstainless steel circle hooks when using natural baits to fish for snapper grouper species in one of the following South Atlantic EEZ fisheries:
Alternative 2a. Commercial snapper grouper fishery. Alternative 2b. Recreational snapper grouper fishery. Alternative 2c (Preferred). Both commercial and recreational snapper grouper fisheries. Regulations recently implemented in the Gulf of Mexico under Gulf Reef Fish Amendment 14/27, at 50 C.F. F. §622. 41 (m) are as follows: (m) Required gear in the Gulf reef fish fishery. For a person on board a vessel to fish for Gulf reef fish in the Gulf EEZ, the vessel must possess on board and such person must use the gear as specified in paragraphs (m)(1) through (m)(3) of this section. (1) Non-stainless steel circle hooks. Non-stainless steel circle hooks are required when fishing with natural baits.
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(2) Dehooking device. At least one dehooking device is required and must be used to remove hooks embedded in Gulf reef fish with minimum damage. The hook removal device must be constructed to allow the hook to be secured and the barb shielded without re-engaging during the removal process. The dehooking end must be blunt, and all edges rounded. The device must be of a size appropriate to secure the range of hook sizes and styles used in the Gulf reef fish fishery. (3) Venting tool. At least one venting tool is required and must be used to deflate the swim bladders of Gulf reef fish to release the fish with minimum damage. This tool must be a sharpened, hollow instrument, such as a hypodermic syringe with the plunger removed, or a 16-gauge needle fixed to a hollow wooden dowel. A tool such as a knife or an ice pick may not be used. The venting tool must be inserted into the fish at a 45-degree angle approximately 1 to 2 inches (2.54 to 5.08 cm) from the base of the pectoral fin. The tool must be inserted just deep enough to release the gases, so that the fish may be released with minimum damage.
Comment: Amendment 16 in the South Atlantic is consistent with Amendment 14-27 in the GOM, which are both consistent with Amendment 18A in the GOM and proposed 15B in the South Atlantic for safe release of sea turtles. This type of gear technology transference represents a significant effort to increase post-release survival of sea turtles, reef fish, and other economic and regulatory discards within these fisheries. ARC applauds the efforts of the South Atlantic Council and the Gulf of Mexico Council for their continued efforts to maintain a sustainable environmentally friendly fishery.
4.3.2 Economic Effects of Measures to Reduce Bycatch
Alternative 2 would require these devices only for the commercial sector (Alternative 2a), or only the recreational sector (Alternative 2b), or both sectors (Preferred Alternative 2c). The general benefits from Alternative 2 would come in the form of enhancing the various measures in place for the recreational and/or commercial sectors by lowering incidental take of managed species. There is also the possibility that circle hooks would increase harvests, and this could directly result in improving net profits by increasing revenues or reducing costs. The general short-term effects, however, of requiring these devices aboard fishing vessels would be to increase fishing costs if these devices were not used at all by any vessels. Those vessels that already use these devices would unlikely experience any increase in fishing costs. Part of this cost increase would be mitigated by the possible reduction in labor cost if these devices were actually effective in reducing bycatch of species that would have to be culled from total catch and be thrown back to the water.
Comment: Proper use of dehooking devices will save valuable terminal tackle and save re-rigging time, as well as prevent any injuries to the angler from the expected cuts and jabs that can occur when handling your catch. Releasing fish unharmed without touching them significantly reduces injuries and associated costs from miss-handling.
ARC agrees that circle hooks can increase the catch rate of most species. Proper use of circle hooks coupled with dehooking devices, after practice, can speed up the fishing operation making the angling adventure cost effective.
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The consensus within the recreational and commercial sectors is that there is widespread acceptance and use of circle hooks, venting tools, and dehookers. The safe retrieval of valuable terminal tackle pays for the purchase of the dehooking technologies within a fishing trip or two.
Many state agencies and extension and research services, e.g., Florida Sea Grant, have conducted workshops or designed educational brochures detailing proper dehooking and venting procedures and indicating simple methods for altering commonly available instruments such as hypodermic needles to serve as venting tools. Needle-nose pliers can be used as dehooking devices. Ready-made dehooking devices and venting tools are available for purchase from various sources for less than $15 each. Hence, the economic impacts of requiring dehooking tools and venting devices on either the commercial or recreational sector would be relatively low.
Comment: ARC has worked in cooperation and as fisheries partners with NOAA Fisheries, Fl Fish and Wildlife Service and Florida Sea Grant to conduct commercial protected species workshops and recreational workshops on the proper use of venting tool and dehooking device technologies and protocols and recommends that this same type of education/outreach workshop be provided to the fishermen and anglers to ensure the proper use of the circle hook, venting and dehooking technologies.
4.3.3 Social Effects of Measures to Reduce Bycatch
Alternative 2 offers ways to reduce the recreational bycatch mortality by requiring the use of venting and dehooking tools and non-offset, non-stainless steel circle hooks. These measures will impose some short-term negative social impacts but the long-term social impacts should be positive as the stock recovers.
Comment: Proper use of dehooking devices will save valuable terminal tackle and save re-rigging time, as well as prevent any injuries to the angler from the expected cuts and jabs that can occur when handling your catch. Releasing fish unharmed without touching them significantly reduces injuries and associated costs from miss-handling.
The consensus within the recreational and commercial sectors is that there is widespread acceptance and use of circle hooks, venting tools, and dehookers. The safe retrieval of valuable terminal tackle pays for the purchase of the dehooking technologies within a fishing trip or two. ARC agrees the long term social impacts will be positive as the stock recovers.
4.7.1.5 Practicability of Management Measures in Directed Fisheries Relative to their Impact on Bycatch and Bycatch Mortality
Amendment 16 includes actions that require the use of circle hooks, venting tools, and dehooking devices, which could reduce discard and bycatch mortality in the snapper grouper fishery. Cooke and Suski (2004) found mortality rates were lower for circle hooks than J-style hooks. Burns et al. (2002) found more red snapper caught with rodand-reel gear died from hook mortality than all other causes combined, including depth, stress, and handling. Mandatory use of circle hooks in all fisheries could benefit
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the biological environment by reducing acute and long-term mortality caused by J-hook usage.
If circle hooks decrease CPUE (GMFMC 2007), then a net benefit to the stock could occur. In addition, circle hooks could reduce regulatory discards; thereby providing additional benefits to the stock. Modifying gear to reduce bycatch and bycatch mortality would also have beneficial effects on the biological and ecological environment of non targeted species. Incidentally caught species in the directed gag and vermilion snapper fishery include red grouper, scamp, red snapper, gray triggerfish, and greater amberjack. Some of these species have similar mouth morphology, which is an important factor in the effectiveness of circle hook use (Cooke and Suski 2004). As a result, hooking mortality on these species would be reduced. Therefore, the mandatory use of circle hooks has the potential to reduce fishing mortality and help stressed snapper grouper species return to a healthy sustainable level.
Amendment 16 could also require the use of venting tools when harvesting snapper grouper species from the EEZ. Venting, when properly executed, is believed to increase survival of released fish. The use of venting tools may also reduce predation on reef fish species by allowing rapid return to depth making them less vulnerable to predators. Discarded fish stranded at the surface become easy prey for marine mammals, sea birds, and large predators such as amberjack, barracuda, and sharks (Burns et al. 2002).
Dehooking devices can allow fishermen to remove hooks with greater ease and more quickly from snapper grouper species without removing the fish from the water. If a fish does need to be removed from the water, dehookers could still reduce handling time in removing hooks, thus increasing survival.
Comment: ARC agrees circle hooks could reduce regulatory discards, providing benefits to the stock. Circle hooks do have the potential to reduce fishing mortality and help stressed snapper grouper species return to a healthy sustainable level.
We agree that (with the proper training) venting deeper caught reef fish (60’ or more) will reduce bycatch mortality in this fishery as well as allowing these deeper caught reef fish to return to a sustainable environment without the increased risk of predation.
Dehooking devices will significantly increase post release survival, minimizing the time the fish is above its normal habitat while keeping the fish in the water (not touching the fish) to reduce suffocation.
ARC believes that the implementation of circle hooks, venting tools and dehooking devices will reduce bycatch mortality when used properly. Voluntary workshops should be available to the anglers and fishers to teach proper protocols and techniques to ensure safe handling and release of reef fish and other incidentally caught species.
Post-Release Survival
Significantly increasing post-release survival in hook and line fisheries is extremely important in order for any successful sustainable conservation management regime to be
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effective and work. ARC is aware of the numerous actions that are being taken by NOAA Fisheries, the Commissions, and the Councils to address bycatch post-release mortality problems and to develop viable post-release survival solutions. Aquatic Release Conservation sincerely applauds and supports all of these post-release survival efforts.
Based on the current best available data, the immediate implementation, proper use, education and outreach of NMFS approved and minimal design standard dehooking devices, venting tools, and circle hooks could significantly decrease post-release mortality by an estimated 55-95% of not only all released reef fish species, but all hook and line caught and released species domestically and globally.
Description of Minimal Design Standard NMFS Approved Dehookers, Venting Tools, and Circle Hooks
In order to obtain the highest level of post-release survival (55-95%) possible, it is critical to use the proper NMFS approved and minimal design standard dehookers, venting tools, and circle hooks for that specific fishery. It is also important to properly instruct fishery participants on their proper and safe use (i.e. workshops and protocols).
ARC highly recommends that NOAA Fisheries and the Council specifically describe and designate which dehookers, venting tools, and circle hooks that will meet NOAA Fisheries minimal design standards and that are NMFS approved in order to gain the maximum probability of survival within the shortest time period, as well as be consistent across the fisheries.
Consistent and comparable NMFS minimal design standard and approved dehookers, venting tools, and circle hooks will benefit research, enforcement, education, outreach, and transference of technologies from angler to angler, fishery to fishery, and from region to region, as has been evidenced by the 2004 Sea Turtle Final Rule-HMS FMP-69 FR 35599 and the Careful Handling and Release technologies, circle hooks, and protocols (i.e. NOAA Technical Memorandum NMFS-SEFSC-524) that were developed in that successful research initiative.
There are numerous types and styles of dehookers, venting tools, and circle hooks available to fisheries participants. Not all of them work as effectively as others. In fact, use of improper dehookers, venting tools, and circle hooks could cause additional injury to the released fish. It is important that dehookers, venting tools, and circle hooks be comprehensively described, meet NMFS minimal design standards, and be NMFS approved.
Dehookers
Currently there are several styles and types of NMFS approved dehookers readily on the market that meet the NOAA Fisheries minimal design standards and have been extensively field tested by researchers and the industry. Several of these NMFS approved dehookers safely remove external (i.e. lip, beak, and foul hooked) circle and J-style hooks such as the ARC Pigtail-curl Dehooker, J-style Dehooker, Flip Stick Dehooker, Scotty’s Dehooker, Roby Dehooker, and NOAA/Bergmann Dehooker.
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The NMFS approved ARC Pigtail-curl Dehooker can safely remove internal (i.e. mouth, throat, and esophagus) circle and J-style hooks that are deeper swallowed. From our experience working with multiple species and with various types of hooks, approximately 10-20% of circle hooks can be deeper ingested (depending on hooking technique) and will necessitate a dehooker that can also safely remove internal hooks.
In addition, it may take hook manufacturers and managers some time to effect a complete implementation and transfer of circle hooks across this reef fish fishery in the GOM, Caribbean and South Atlantic. During this transition time, some anglers will continue to use J-style hooks which will tend to be deeper swallowed and will necessitate a deep- hook dehooker to safely remove those specific hooks and under those conditions
These minimal design standard and NMFS approved dehookers have already proven to be extremely successful in safely removing hooks (internal and external) and line from sea turtles, marine mammals, protected species, targeted and non-targeted species. These NMFS approved dehookers have already been successfully transferred from fishery to fishery and from species to species (with slight modifications as to size and length).
ARC recommends the use of similar and consistent dehookers that are used for the sea turtles careful handling and release requirements that are currently required in the pelagic longline (PLL) industry (Sea Turtle Final Rule-HMS FMP-69 FR 35599), in the bottom longline (BLL) industry (Rule for Dehooking and Complimentary Caribbean Measures for Commercial Shark Fishery), and GOM Amendment 18A for careful handling and release of sea turtles and smalltooth sawfish in the GOM Reef Fish Fishery with slight modifications to the length of the handle and the size of the “working end” (i.e. pigtail- curl size) in order to accommodate the smaller size of hooks and mouth spread dimensions of snapper and other reef fish species of this reef fish fishery.
In addition to any other dehooker requirement that is required for sea turtle, smalltooth sawfish and other protected species release, ARC recommends for this specific reef fish fishery, a 16” handheld “Sportsman” ARC pigtail-curl dehooker safe internal and external hook removal and the J-Style, Flip Stick, Scotty’s, Roby, or NOAA/Bergmann dehooker (with slight modifications to size to accommodate this specific reef fish fishery) for safe external hook (only) removal.
Venting Tools
Preliminary data from a 15-year study conducted at Mote Marine Lab (Burns and Porch, in prep.) suggest that venting increases survival in red snapper caught in deep water. A venting tool can be any hollow, sharpened instrument that allows gases to escape. Ice picks and knives are not suitable because simply puncturing the fish is undesirable and can result in mortal injury (Florida Sea Grant 2005).
Proper and safe venting can significantly increase post-release survival by releasing gases that are built up by fish being caught and brought up from deeper depths (60+ feet). The proper and safe venting of these gases can allow the released fish to return to its natural barometric environment and to a safe depth in a timely manner that can significantly decrease predation and resulting mortalities.
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There has been a noted increase of the types and styles of venting tools that are now and will soon be on the market. ARC recommends that the required venting tools meet NMFS or FL Sea Grant’s minimal design standard and be approved so as to make sure that the venting tool and techniques is not harmful or dangerous to the fish or the angler. Venting technique and protocols that have developed by Florida Sea Grant and Mote Marine Lab should be implemented and followed for a safe venting procedure and maximized survival rates.
ARC has been working in cooperation and as a fisheries partner with FL Sea Grant for several years in order to help transfer venting tool technologies and protocols to the reef fish fishery.
Circle Hooks
The use of circle hooks will significantly increase post-release survival, primarily because of the hooking position and depth that the circle hook tends to be embedded in fish (corner of the mouth) which causes less serious injury than that of a deeper swallowed hook (J-style hooks). A circle hook embedded in the corner of the mouth is an easier hook to remove rapidly, thus significantly increasing the released fish’s chance of survival.
There are numerous styles and types of circle hooks on the market today. Not all circle hooks actually gain the same benefits than that of other circle hooks. As evidenced in the 2001-2003 NED Experimental design, a specific Lindgren Pittman 18/0 non-offset and 10% offset hook was specifically described and minimally designed approved in the NED experiment and then later implemented.
It may take some time for hook manufacturers (i.e. Eagle Claw, Mustad, Owner, etc.) to gear up enough NMFS approved and minimal design standards circle hooks in order to supply to the entire GOM, Caribbean and South Atlantic reef fish fisheries. During this circle hook gearing up time period, reef fish participants may still be using J-style hooks which will tend to be deeper swallowed.
Conclusion
Anglers and fishers can significantly increased post-release survival of all hook and line caught and released species by safely and quickly removing all hooks (circle or J-style) and terminal tackle/gear, whether hooked in the jaw, mouth, or deep swallowed/ingested in the throat, esophagus, or gut. The ability to safely remove hooks and gear from sea turtles, protected resources, reef fish, other targeted, and non-targeted species without touching or removing them from the water will reduce lactic acid build-up and stress, prevent further/multiple hook wounding and infection, keeps the anglers from having to touch the released species and breaking the slime barrier (breaking the slime barrier can result in infection), and reduces the time the released catch is out of the water (suffocation), as well as keeping anglers and fishers fingers and hands away (extended reach handles) from the more dangerous species’ teeth, beaks, spines or jaws (safety at sea).
8
Thank you for allowing Aquatic Release Conservation to comment on these most important Amendment 16 issues. We hope that some of these comments will be of assistance.
Sincerely,
______Shawn Dick, President/CEO Aquatic Release Conservation Director, ARC Outreach and Education Director, Angler Conservation Education (ACE) 501c3 Fisheries Partner 2001-2003 NED Experimental Design Fishery Fisheries Partner with NOAA Fisheries (Mandated PLL and BLL Workshop Initiatives) Fisheries Partner with Florida Sea Grant (FL Sea Grant/Novak Venting Tool) Co-Author of NOAA Technical Memorandum NMFS-SEFSC-524 (PLL and BLL Sea Turtle Safe Handling and Release Protocols) Member: Recreational Fishing Alliance (RFA) Member: International Game Fish Association (IGFA) Member: American Sportsfishing Association (ASA) Member: The Billfish Foundation (TBF) Member: American Fisheries Society (AFS) Member: Blue Water Fishermen’s Society (BWFA) Member: Coastal Conservation Association (CCA) Committee Member: FishAmerica Foundation
AND
______Christy Clow Aquatic Release Conservation Chief Instructor, ARC Education / Outreach Angler Conservation Education (ACE) 501c3 Chief Instructor, ACE Education / Outreach Fisheries Partner with NOAA Fisheries (Mandated PLL and BLL Workshop Initiatives) Fisheries Partner with Florida Sea Grant (FL Sea Grant/Novak Venting Tool) Member: International Game Fish Association (IGFA)
9
I am writing these comments in response to the proposals on the docket for changes for the harvest of gag grouper and vermillion snapper.
We are the owner/operators of the F/V Capt.Lew a partyboat operating out of Fort Pierce Florida.
Over the last several years the Council has implented various measures for vermillion snapper including a size increase a couple of years back.As we have previously stated we don't know the impact of this change on the vermillion stocks since no one that I am aware of can state with any certainty how long it takes a vermillion to reach 12"'s.Since the implentation of the size increase we have seen an increased number of undersize vermillions.We are also seeing the vermillion in areas that we have not seen them before.This is based on an average of nearly 200 trips per year since the size increase.On the other hand we see no appreciable increase in the number of keeper verms.It appears to us that there is no good data available to make any changes to the existing regulations for our area..As we previously sated in prior comments good data results in good decisions.Right now no good data exists that justify any changes to the status quo.Since most of the people that provide you with input spend considerably less time on the ocean seeing what is happening in real time I suggest you take real time inputs into account in your decision making process.
Our comments concerning gag grouper are as follows. In the past 12 months we have caught far fewer keeper gags and have caught very few large fish(over 30#'s).In previous years we would catch many fish in the 30-45# range.On the upside we are catching a significantly higher number of throwbacks.The throwbacks generally range in size from 12-21"'s and are caught at depths from 70 -110'.We are also seeing fewer fish caught during what we used to think was grouper season,January through April.We are now seeing more keepers in May through December.I don't know the reason for this change but have a couple of theories.Number 1 is bait availability and number 2 is water quality primarily water temperature during the winter months.We keep temp readings on all our trips in addition to other water qualtity related items(nearly 2000 trips since 1999) and since the storms Frances,Jean,etc.water temps during the months referenced above are down on average 2-2.5degrees.Bait is als o no where near as plentiful,namely cigar minnows and threadfind herring.Fish go where the foreage is and in my opinion have moved from our area to where foreage is more readily available.Since you state you don't know if gag are overfished I would suggest a bag limit reduction for gags to 1 per boat per trip with a year round open season.Realistically,this is about what we see on a good day.Most other days no keeper gags are in our catch.Concerning circle hooks,offset or otherwise,they don't make a hill of beans difference in fish survivability.Venting tools on the other hand are key to the fish making it back to the bottom and we fully support the venting tool requiremant for all species in the snapper grouper complex.We have used them on all our trips for the last 9 years.
Please take our comments into account in your decision making process.Protracted litigation does no one any good,especially the fish.A sustainable fishery is what the stakeholders want whether recreational or commercial.Remember the SSFFF and what happens when you back a sleeping Tiger into a corner.
Respectfully submitted,
Lewis P.Augusta Big Fish,Inc. F/V Capt.Lew
Grouper Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFC's own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely bycatch mortality and habitat destruction from trawling and longline activities. I believe that NO CHANGES are required at this time, and the SAMFC's preferred alternatives would have a drastic economic impact.
I am against alternative 2 (Establish a gag spawning season closure January through April...) in that there is no reliable data on recreational landings to support this position. This alternative places a greater burden on the recreational sector. Further a ban of all longlining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I support Alternative 3 (Directed Commercial Quota)
I support Alternative 4 (Divide Directed Commercial Quota into 2 regions). In addition, I support the regional management of the recreational sector with Florida being a separate management area
In reference to Alternative 5. Recreational measures:
I am against Alternative 5a (Reduce the 5-grouper aggregate bag limit to a 3-grouper...January- April fishery closure). This alternative places an unfair burden on the recreational sector without a comparable reduction to the commercial landings. I am against alternative 5 in that there is no reliable data on recreational landings to support this position. Further a ban of all longlining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I am against Alternative 5b (December - April closed season, retain current bag limits...). I am against alternative 5b in that there is no reliable data on recreational landings to support this position. Further a ban of all longlining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Amendment 16 also includes alternatives to reduce bycatch mortality by requiring the use of venting/dehooking tools and circle hooks. I agree with this as it reduces mortality and aid in the recovery of the stocks.
Vermillion Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The spikes in this fishery have been caused by the SAMFC shifting pressure from the Sea Bass fishery which in turn has concentrated pressure on the Vermillion fishery. In addition, the explosion of the Goliath Grouper populations is putting increased pressure on this fishery. I would suggest a limited take/season on the Goliath Grouper fishery.
I am against Alternative 2 (Interim Allocations). I would suggest that SAMFC increase data collection on both the fishery health and fishery utilization before enacting any changes. In addition, a ban of all longlining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Sincerely, John Barber Dear S. Atlantic Council Members,
First, I would like to state that the purpose of my comments are just to address concerns that we have with the data used for decisions on the management of the fisheries in our region. It seems that for too long the subject of the proposed "problem" isn't always defined prior to a "solution" being derived. Public meeting inputs have the attitude that the decision has already been made. As a fishermen, I would be more than happy to supply data as would many of the fishermen I know, if you would educate us on what you need for information and assistance.
Just finding out about these meetings is hard enough, try getting on the SAFMC website and finding SEDAR 10 REPORT or Magnuson Stevens Scoping document and reading the entire thing along with understanding it is another issue altogether.
Too long have fisherman been pitted against each other, both commercial and recreational, in an attempt to, in my opinion, redirect focus on the issue at hand. Any form of accountability on the council's part for the decisions made on our behalf as fisherman, doesn't seem to exist. Decisions are made that do not seem to have both the fish stock and fisherman's best interest at heart. Politics appear to also be playing a huge role in the decisions made on our behalf and do at times, seem detrimental to the cause.
The council's actions are speedy mechanisms to put increased restrictions on a fishery, yet there are no such speedy mechanisms to decrease restrictions should any fishery’s biomass indeed increase to healthier levels, or have new data to contradict the imposing limits. We hear how it needs to produce results over a long time period such as 10 years to be accurate. Please don't site here how we can now catch more porgy. That is a sad example on the council's part at best. Historically, regulations don't give back but become more conservative in restrictions.
These viewpoints are directed towards Amendment 16 yet hold true of all others that are being reviewed at present.
As I have read extensive amounts of information including SEDAR 10 along with information from the SAFMC, etc. I have a couple of points that I would like to bring up.
From the SAMFC website and I quote
Lack of basic management data on many of the species still remains the major obstacle to successful management. MRFSS surveys have been proven unreliable. What changes in the last 10 years have been changed to upgrade the survey system? MRFSS is usually a year or two behind in estimating this trend, so my main concerns are about over-regulation that may not be warranted. MARMAP surveys on "random hard bottoms" are the basis of most surveys done. We are talking about reef fish, fish that look for live bottom and structure to make their home. Data collections from things like "Chevron traps" were inconclusive due to such low catch rates and classified as "indeterminable and inaccurate" after 27 years yet older data is still used to calculate present trends. Why are things like wave heights, sea surface temps, surface currents, hurricane impacts, DO, salinity, wind speed, wind direction, etc not included in present studies? Why are issues like water quality and pollution along with protecting our juvenile fish using our estuaries for growth not addressed or protected? We can pay a hog farmer or tobacco farmer not to raise their crop yet we don't address the shrimping by catch that is drastically affecting our fish stock? Please don't tell me how great the "by catch" gear is doing in the scrimping industry, the by catch being shoveled overboard looks like a snow storm floating on the water coming from a shrimper. I understand they have to make a living, however, subsidizes their income for the percentage necessary and stop letting them trawl on the inside and watch how well our fisheries rebound. I am concerned on how "overly conservative" the council seems to be in their calculations and proposed regulations. Below are some of the areas that if corrected to more realistic parameters, would take us out of the "overfishing" category that the grouper and snapper species are presently assessed as.
I am concerned that F (fishing mortality; the percentage of the population that dies each year from fishing) is overstated partly because it is based on
1. Marine Recreational Fishing Statistical Survey (MRFSS) estimates of landings and discards, which have been declared unreliable and even ‘fatally flawed’ and
2. An overstated recreational release mortality of 25%.
Recreational fisheries Release mortality is presently assumed to be 25%, SEDAR 10 workshop stated Improved estimates of post-release mortality were obtained through tag release and caging methods (Burns et al. 2002; Overton and Zabawski 2003; McGovern et al.2005). Using these methods, mean mortality rates were estimated to be 21.2% (Overton and Zabawski 2003), 23% over a variety of depths (McGovern et al. 2005). Commercial fisheries Release mortality is presently assumed to be 40%. Your reasoning behind the proposed legislation is that the FMSY is below the F (Fish Mortality) factor, the FMSY has remained below the F (Fish Mortality) factor since 1983 in the S. Atlantic. With the council willing to error on the side of "conservative numbers and factors" is it any wonder this is the trend? Now take a look at our stocks. Have we decimated our biomass? No. Clearly real world numbers aren't being used to gauge accurate regulation.
How can the Magnuson Stevens Act expect you to make changes within 1 year of notification if the council states that it takes 3-8 years to schedule and complete a stock assessment? For that matter, why, if notified that a stock is in "trouble", aren't the data compiled between the last stock assessment and the present date of the notifications, reviewed to determine if an issue really exists at the present notification time period prior to taking action?
According to your own data workshops, spawning stock biomass increased after 1999 corresponding to implementation of the 24 inch minimum size limit. Fishing mortality has been decreasing since 1992 yet the gag grouper lifespan has just been raised to 26 yrs to 30 years. The life expectancy factor has been raised recently which is also affecting the formula into an "overfishing" status.
50% of maturity is 3 years and 25.5 inches. Why don't we increase the minimum size limit to 26". It has proven effective for the size increase in 1999 to 24".
Fishing mortality in 2004 was estimated as 0.31, extremely conservative against 2007 projected mortality.
Why is the fishing mortality rate for 2007 not being used? Obviously the fishing pressure has reduced since 2004 yet the OPPORTUNITY to fish hasn't been reduced which I think is very important and not usually taken into account when new regulations are proposed.
The council can redo the entire Vermillion Snapper stock assessment due to concerns of accuracy and possible "gross negligence" of the last assessment with updated data, yet I am told by the council that the 2004 data used in SEDAR 10 for grouper won't be updated until 2011? Are you kidding me? With the impact that fuel has alone on the frequency of fishing trips which has been declining since 2004, why can we not use current data and revisit the workshop to determine if the present proposed measures are necessary?
How can there be underfunding on the federal or local level to interpret the data that is taken every year but not incorporated or used due to lack of resources and man power as stated by the council with 3-8 years between stock assessments?
Why are the conclusions and recommendations from the data and review workshops which are and from the SEDAR programs not incorporated into the councils decisions on a "less cautionary or overly conservative" approach?
SEDAR 10 biologists recommended changing the MSST, SSB, M, F, MFMT and alike, in one form or another due to "overly conservative" concerns.
MSST, currently defined by the South Atlantic Council as (1-M)BMSY, is very close to BMSY because age-averaged natural mortality rate, M, is estimated as 0.14. It was recommended to change the M and wasn't done. It was stated that "the stock is not overfished and is not projected to become overfished."
Given the uncertainties in the assessment, the biomass would be expected or could possibly, fall below MSST with a relatively high frequency even if the true biomass were close to BMSY. In Sedar 10 the Review Workshop stated that the current definition of MSST may be overly conservative and recommends an operational definition of MSST of 5 million pounds. Yet it is still the factor of 6.8 million pounds was used.
The MFMT factor is also showing signs of being overly conservative. Why the council feels the need to error on EXTREME caution I don't understand.
Then Natural Mortality Rate formula was calculated using the Hoenig 1983 program. A program which has flaws due to the fact that the estimate of maximum age required by Hoenig's method assumes that the age determination technique being employed is unbiased. Validating this assumption is often difficult for the older, more difficult-to-age individuals but can be accomplished by using a variety of techniques ranging from marking to analysis of radioactive isotopes (Lai et al., concerns of accuracy and possible "gross negligence" of the last assessment with updated data, yet I am told by the council that the 2004 data used in SEDAR 10 for grouper won't be updated until 2011? Are you kidding me? With the impact that fuel has alone on the frequency of fishing trips which has been declining since 2004, why can we not use current data and revisit the workshop to determine if the present proposed measures are necessary?
How can there be underfunding on the federal or local level to interpret the data that is taken every year but not incorporated or used due to lack of resources and man power as stated by the council with 3-8 years between stock assessments?
Why are the conclusions and recommendations from the data and review workshops which are and from the SEDAR programs not incorporated into the councils decisions on a "less cautionary or overly conservative" approach?
SEDAR 10 biologists recommended changing the MSST, SSB, M, F, MFMT and alike, in one form or another due to "overly conservative" concerns.
MSST, currently defined by the South Atlantic Council as (1-M)BMSY, is very close to BMSY because age-averaged natural mortality rate, M, is estimated as 0.14. It was recommended to change the M and wasn't done. It was stated that "the stock is not overfished and is not projected to become overfished."
Given the uncertainties in the assessment, the biomass would be expected or could possibly, fall below MSST with a relatively high frequency even if the true biomass were close to BMSY. In Sedar 10 the Review Workshop stated that the current definition of MSST may be overly conservative and recommends an operational definition of MSST of 5 million pounds. Yet it is still the factor of 6.8 million pounds was used.
The MFMT factor is also showing signs of being overly conservative. Why the council feels the need to error on EXTREME caution I don't understand.
Then Natural Mortality Rate formula was calculated using the Hoenig 1983 program. A program which has flaws due to the fact that the estimate of maximum age required by Hoenig's method assumes that the age determination technique being employed is unbiased. Validating this assumption is often difficult for the older, more difficult-to-age individuals but can be accomplished by using a variety of techniques ranging from marking to analysis of radioactive isotopes (Lai et al., 1996). The estimate of longevity is also dependent on sample size and previous fishing history, which by the way we don't have sound, accurate data on according to the councils own admission. Hoenig (1983) showed that maximum age tends to increase slowly with increasing sample size but longevity has probably declined from historical levels because of fishing. A small sample size for age determination, under aging, and previous exploitation would all result in an overestimate of M with Hoenig's method. Although compared to other methods, we still have an issue with accurate data and excessively cautionary management. Maybe we don't increase the Annual Catch Limits (ACLs) as aggressively using such precautionary regulation. The 2004 stock assessment model projections show the stock becoming overfished in 2007.
Greg Waugh states on 5/8/2008 that "the stock isn't overfished due to present reduction fishing pressure, attributed to several factors such as fuel costs." He also cited that "the assessment wouldn't be redone due to funding and scheduling issues and would be revisited in 2011."
It is an natural assumption with the current economic situation and petroleum driven influence on our daily lives that there has been a significant decline in fishing pressure on all fishing stocks yet the council seem reluctant to revisit the issue since they already have time and effort invested into them and have decided to "stick" to their original conclusions.
Maybe we use data more current than 2004 and realize that the 37% reduction that you are calling for has already in part been addressed due to the cost of fuel and expenses that are incurred for offshore fishing. The Magnuson Stevens Act states that the new regulations need to implemented by 2010. That gives the council plenty of time to do a stock review with less conservative numbers as recommended in the SEDAR 10 program.
Maybe the council shouldn't use such a precautionary approach to regulation on data that they admit isn't as accurate or current to date as it should be.
I believe that if current, data were used along with the above mentioned conservative factors corrected, the councils need for new legislation may not be necessary after all.
How about in the alternatives offer for the public to pick from the economic impact for the entire S. Atlantic recreational impact with a 4 month closure will only attribute to a total of $ 1,032,000. An example is the entire state of NC will only have an impact of $ 37,000. That is ridiculous. That equates to 37 trips at a charter price of $ 1,000. The impact is for the "for hire" sector which is lumped in with the recreational sector as a whole. There is no account for the true recreational sector such as recreational food, fuel, hotel, shopping, tackle, boat maintenance etc. For a 4 month NC closure, $ 37,000, REALLY?
We would like to see the gag assessment redone. There are too many uncertainties and inconsistencies to move forward with an assessment that will affect such a large fishery.
- The Gulf of Mexico Grouper assessment has been reviewed due to some of the same questions. There were many corrections and this was done in less than 6 month time frame.
Fishing effort is significantly reduced and is not taken into account when calculating future estimates as it should be.
Economic impact and true fishing pressure of both recreational and commercial fishing is grossly inaccurate.
If after a review it is necessary to reduce harvest, only modest bag limit decreases or modest size limit increases should be considered acceptable if in fact a problem exists.
I am sure that the Council want to make sound decisions. The economic and social devastation wrought by these proposed Gag regulations comes at a time when effort is significantly declining (I feel permanently) due to exorbitant fuel prices. These current proposals are based on overly precautionary thresholds which compound to create the false sense of an unhealthy fishery, when in fact the fishery could be quite healthy.
Is it any wonder that the individuals that you are governing are not satisfied with the proposed solutions when they seem to have a better handle on the fish stock, behavioral patterns, abundance and realistic solutions and are not heard by you?
I urge the Council to:
1. Review the Natural Mortality Rate of Gag 2. Review and adjust the overly precautionary estimates 3. Provide the numbers for and consider as an alternative a 26” Gag minimum size limit (20% or more reduction in rec landings alone) as the FIRST tool applied to the fishery. 4. Invite Dr. Trevor Kenchington to the SSC and Council meeting in June. Dr. Kenchington has extensive knowledge of both the Gulf of Mexico and the South Atlantic fisheries and could prove an excellent resource in the interpretation of current data parameters.
Thank you for your time and the opportunity to voice my concerns.
Best Regards,
IRA BARD WILMINGTON,NC
Jack, here is a reply that was sent from Mac Currin. Please tell me that my business is not be yanked out from under me because as Mr. Currin states, the board has a "general feeling". Here is the exact quote.
"The council is considering this measure partly because of a general feeling that all South Atlantic fisheries should be professional fisheries"
My business means to much to me to let a general feeling by the board destroy it. No facts at all were mentioned, not one study to support their decision.
Mr Currin is making a dangerous assumption that if we cant sell that we will stop fishing. Can you ask the board what it plans on doing if we continue to fish and harvest the same numbers and the feds get the leftover shares from our fish? In essence we will be double dipping and the resource will suffer major consequences.
Can you present this to the board.
Chris
Here is the letter that was sent out.
Thank you for providing your views on the bag limit sales provision in Amendment 15B to the snapper grouper plan. I have heard from a number of people who are in your similar situation.
The situation with many snapper-grouper species is dire. The commercial quotas are being reduced and recreational measures are also being taken to reduce the mortality of many species. The federally permitted fishermen are finding themselves in a more and more difficult situation. Having to compete with SCFL holders in NC and charter boats in FL who are landing bag limits of snapper-grouper further reduces the ever shrinking quotas that they allowed to catch. If not addressed, this will shortly result in very long closed seasons and economic hardship for everyone- you included.
The council is considering this measure partly because of a general feeling that all South Atlantic fisheries should be professional fisheries composed of people who are totally dependent on fishing for their livelihood. As the quotas and bag-limits are reduced, the proportional impact on the professionals is greater and greater. In addition, if you rely on snapper- grouper sales to fund your fishing and pay for your boat, I believe that you will find it hard to justify a trip offshore to catch 2 groupers and a handful of beeliners during the few months that the fishery will be open, even if this action was not taken.
Again, thank you for your input.
Mac Currin" ----- Original Message ----- From: "Jack McGovern"
> Thank you for comment Mr. Branco. It will be provided to the SAFMC. > > Jack > > Branco wrote: > > Mr. McGovern: > > > > I am writing this email to voice my concerns on the SAFMC amendment > > that would essentially put my commercial fishing operation out of > > business. I am concerned that if this amendment passes it will have a > > deleterious effect on our local economy as well. With the world > > economy in recession we cant take jobs away. I currently sell my fish > > with my NC standard commercial fishing license. The last 3 years my > > business has contributed $16,000 per year to the local > > economy(gas,bait,tackle,insurance,etc). If my privilege to sell > > grouper/snapper is taken away then not only does the local economy > > suffer but so does my ability to support it. It sounds like a loss to > > everyone. Lets get together so all parties can reach a win/win > > agreement. I am all for the proper management of our resources but to > > completely suspend our privileges is unfair. And to make matters > > worse, some of the voting members in the safmc hold federal permits > > that would monopolize the market. > > > > thank you, > > > > chris branco
Gentleman, I must tell you that as a member of a hugh fishing population in the state of Florida I was sorely disappointed to see what proposals were being looked at after such flawed data collection. I have fished the east coast of Florida since the first years of the 70's and I will tell you I have not seen the Grouper and snapper in as good of shape as we do right now. The current measures are working and they are working well. It is a pretty old saying that if it is not broke don't fix it. Great advances were made with the removl of long lines and it has been a proven fact that it worked well. Yet we now are letting them back to start over? This does not make an effective method of saving or resoures. You my friends have been put into a very hard place to make what you think are the correct changes to pass on to our future generations the resources we so much love. Please do it with the most acturate and available information and not just some phone calls to homes on the coast. I heard things such as "the sport fisherman are ruining the fisheries" to "band live wells". Well I am affraid that does not make any sense. If you become more acturate at catching fish you have to catch LESS fish to harvest your limit. This saves some fish from wasted and not properly returned. I also am living proof that the current economy is radidly slowing down the rate at which fish are caught as well. My charters have fallen to almost half of what they have been as I along with most others have had to raise rates which in return disallows many people from having any disposable income to go fishing. One point in fact is to look at the boats for sale. There are so many out there which are no longer being used it makes you wonder how many will be left. I urge you to reconsider your choices and to spend more time on trying to remove laws whcih cause you to make changes that don't need to be made or should not before you have acturate research. You have consen to take on this task and we do expectyou to make wise choices as the resources you are working with belong to all of us which includes are yong ones. Capt. Jeff Brown
Grouper Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFCs own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely by-catch mortality and habitat destruction from trawling and long line activities. I believe that NO CHANGES are required at this time, and the SAMFCs preferred alternatives would have a drastic economic impact.
I am against alternative 2 (Establish a gag spawning season closure January through April...) in that there is no reliable data on recreational landings to support this position. This alternative places a greater burden on the recreational sector. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I support Alternative 3 (Directed Commercial Quota)
I support Alternative 4 (Divide Directed Commercial Quota into 2 regions). In addition, I support the regional management of the recreational sector with Florida being a separate management area
In reference to Alternative 5. Recreational measures:
I am against Alternative 5a (Reduce the 5-grouper aggregate bag limit to a 3- grouper...January-April fishery closure). This alternative places an unfair burden on the recreational sector without a comparable reduction to the commercial landings. I am against alternative 5 in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I am against Alternative 5b (December - April closed season, retain current bag limits...). I am against alternative 5b in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Amendment 16 also includes alternatives to reduce by-catch mortality by requiring the use of venting/dehooking tools and circle hooks. I agree with this as it reduces mortality and aid in the recovery of the stocks.
Vermilion Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The spikes in this fishery have been caused by the SAMFC shifting pressure from the Sea Bass fishery which in turn has concentrated pressure on the Vermilion fishery. In addition, the explosion of the Goliath Grouper populations is putting increased pressure on this fishery. I would suggest a limited take/season on the Goliath Grouper fishery.
I am against Alternative 2 (Interim Allocations). I would suggest that SAMFC increase data collection on both the fishery health and fishery utilization before enacting any changes. In addition, a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Sincerely, Capt. Jeff Brown
Dear S. Atlantic Council Members,
First, I would like to state that the purpose of my comments are just to address concerns that we have with the data used for decisions on the management of the fisheries in our region. It seems that for too long the subject of the proposed "problem" isn't always defined prior to a "solution" being derived. Public meeting inputs have the attitude that the decision has already been made. As a fishermen, I would be more than happy to supply data as would many of the fishermen I know, if you would educate us on what you need for information and assistance.
Just finding out about these meetings is hard enough, try getting on the SAFMC website and finding SEDAR 10 REPORT or Magnuson Stevens Scoping document and reading the entire thing along with understanding it is another issue altogether.
Too long have fisherman been pitted against each other, both commercial and recreational, in an attempt to, in my opinion, redirect focus on the issue at hand. Any form of accountability on the council's part for the decisions made on our behalf as fisherman, doesn't seem to exist. Decisions are made that do not seem to have both the fish stock and fisherman's best interest at heart. Politics appear to also be playing a huge role in the decisions made on our behalf and do at times, seem detrimental to the cause.
The council's actions are speedy mechanisms to put increased restrictions on a fishery, yet there are no such speedy mechanisms to decrease restrictions should any fishery’s biomass indeed increase to healthier levels, or have new data to contradict the imposing limits. We hear how it needs to produce results over a long time period such as 10 years to be accurate. Please don't site here how we can now catch more porgy. That is a sad example on the council's part at best. Historically, regulations don't give back but become more conservative in restrictions.
These viewpoints are directed towards Amendment 16 yet hold true of all others that are being reviewed at present.
As I have read extensive amounts of information including SEDAR 10 along with information from the SAFMC, etc. I have a couple of points that I would like to bring up.
From the SAMFC website and I quote
Lack of basic management data on many of the species still remains the major obstacle to successful management. MRFSS surveys have been proven unreliable. What changes in the last 10 years have been changed to upgrade the survey system? MRFSS is usually a year or two behind in estimating this trend, so my main concerns are about over-regulation that may not be warranted. MARMAP surveys on "random hard bottoms" are the basis of most surveys done. We are talking about reef fish, fish that look for live bottom and structure to make their home. Data collections from things like "Chevron traps" were inconclusive due to such low catch rates and classified as "indeterminable and inaccurate" after 27 years yet older data is still used to calculate present trends. Why are things like wave heights, sea surface temps, surface currents, hurricane impacts, DO, salinity, wind speed, wind direction, etc not included in present studies? Why are issues like water quality and pollution along with protecting our juvenile fish using our estuaries for growth not addressed or protected? We can pay a hog farmer or tobacco farmer not to raise their crop yet we don't address the shrimping bycatch that is drastically affecting our fish stock? Please don't tell me how great the "bycatch" gear is doing in the shrimping industry, the bycatch being shoveled overboard looks like a snow storm floating on the water coming from a shrimper. I understand they have to make a living, however, subsidizes their income for the percentage necessary and stop letting them trawl on the inside and watch how well our fisheries rebound. I am concerned on how "overly conservative" the council seems to be in their calculations and proposed regulations. Below are some of the areas that if corrected to more realistic parameters, would take us out of the "overfishing" category that the grouper and snapper species are presently assessed as.
I am concerned that F (fishing mortality; the percentage of the population that dies each year from fishing) is overstated partly because it is based on
1. Marine Recreational Fishing Statistical Survey (MRFSS) estimates of landings and discards, which have been declared unreliable and even ‘fatally flawed’ and
2. An overstated recreational release mortality of 25%.
Recreational fisheries Release mortality is presently assumed to be 25%, SEDAR 10 workshop stated Improved estimates of post-release mortality were obtained through tag release and caging methods (Burns et al. 2002; Overton and Zabawski 2003; McGovern et al.2005). Using these methods, mean mortality rates were estimated to be 21.2% (Overton and Zabawski 2003), 23% over a variety of depths (McGovern et al. 2005). Commercial fisheries Release mortality is presently assumed to be 40%. Your reasoning behind the proposed legislation is that the FMSY is below the F (Fish Mortality) factor, the FMSY has remained below the F (Fish Mortality) factor since 1983 in the S. Atlantic. With the council willing to error on the side of "conservative numbers and factors" is it any wonder this is the trend? Now take a look at our stocks. Have we decimated our biomass? No. Clearly real world numbers aren't being used to guage accurate regulation.
How can the Magnuson Stevens Act expect you to make changes within 1 year of notification if the council states that it takes 3-8 years to schedule and complete a stock assessment? For that matter, why, if notified that a stock is in "trouble", aren't the data compiled between the last stock assessment and the present date of the notifications, reviewed to determine if an issue really exists at the present notification time period prior to taking action?
According to your own data workshops, spawning stock biomass increased after 1999 corresponding to implementation of the 24 inch minimum size limit. Fishing mortality has been decreasing since 1992 yet the gag grouper lifespan has just been raised to 26 yrs to 30 years. The life expectancy factor has been raised recently which is also affecting the formula into an "overfishing" status.
50% of maturity is 3 years and 25.5 inches. Why don't we increase the minimum size limit to 26". It has proven effective for the size increase in 1999 to 24".
Fishing mortality in 2004 was estimated as 0.31, extremely conservative against 2007 projected mortality.
Why is the fishing mortality rate for 2007 not being used? Obviously the fishing pressure has reduced since 2004 yet the OPPORTUNITY to fish hasn't been reduced which I think is very important and not usually taken into account when new regulations are proposed.
The council can redo the entire Vermillion Snapper stock assessment due to concerns of accuracy and possible "gross negligence" of the last assessment with updated data, yet I am told by the council that the 2004 data used in SEDAR 10 for grouper won't be updated until 2011? Are you kidding me? With the impact that fuel has alone on the frequency of fishing trips which has been declining since 2004, why can we not use current data and revisit the workshop to determine if the present proposed measures are necessary?
How can there be underfunding on the federal or local level to interpret the data that is taken every year but not incorporated or used due to lack of resources and man power as stated by the council with 3-8 years between stock assessments?
Why are the conclusions and recommendations from the data and review workshops which are and from the SEDAR programs not incorporated into the councils decisions on a "less cautionary or overly conservative" approach?
SEDAR 10 biologists recommended changing the MSST, SSB, M, F, MFMT and alike, in one form or another due to "overly conservative" concerns.
MSST, currently defined by the South Atlantic Council as (1-M)BMSY, is very close to BMSY because age-averaged natural mortality rate, M, is estimated as 0.14. It was recommended to change the M and wasn't done. It was stated that "the stock is not overfished and is not projected to become overfished."
Given the uncertainties in the assessment, the biomass would be expected or could possibly, fall below MSST with a relatively high frequency even if the true biomass were close to BMSY. In Sedar 10 the Review Workshop stated that the current definition of MSST may be overly conservative and recommends an operational definition of MSST of 5 million pounds. Yet it is still the factor of 6.8 million pounds was used.
The MFMT factor is also showing signs of being overly conservative. Why the council feels the need to error on EXTREME caution I don't understand.
Then Natural Mortality Rate formula was calculated using the Hoenig 1983 program. A program which has flaws due to the fact that the estimate of maximum age required by Hoenig's method assumes that the age determination technique being employed is unbiased. Validating this assumption is often difficult for the older, more difficult-to-age individuals but can be accomplished by using a variety of techniques ranging from marking to analysis of radioactive isotopes (Lai et al., 1996). The estimate of longevity is also dependent on sample size and previous fishing history, which by the way we don't have sound, accurate data on according to the councils own admission. Hoenig (1983) showed that maximum age tends to increase slowly with increasing sample size but longevity has probably declined from historical levels because of fishing. A small sample size for age determination, underaging, and previous exploitation would all result in an overestimate of M with Hoenig's method. Although compared to other methods, we still have an issue with accurate data and excessively cautionary management. Maybe we don't increase the Annual Catch Limits (ACLs) as aggressively using such precautionary regulation. The 2004 stock assessment model projections show the stock becoming overfished in 2007.
Greg Waugh states on 5/8/2008 that "the stock isn't overfished due to present reduction fishing pressure, attributed to several factors such as fuel costs." He also cited that "the assessment wouldn't be redone due to funding and scheduling issues and would be revisited in 2011."
It is an natural assumption with the current economic situation and petroleum driven influence on our daily lives that there has been a significant decline in fishing pressure on all fishing stocks yet the council seem reluctant to revisit the issue since they already have time and effort invested into them and have decided to "stick" to their original conclusions.
Maybe we use data more current than 2004 and realize that the 37% reduction that you are calling for has already in part been addressed due to the cost of fuel and expenses that are incurred for offshore fishing. The Magnuson Stevens Act states that the new regulations need to implemented by 2010. That gives the council plenty of time to do a stock review with less conservative numbers as recommended in the SEDAR 10 program.
Maybe the council shouldn't use such a precautionary approach to regulation on data that they admit isn't as accurate or current to date as it should be.
I believe that if current, data were used along with the above mentioned conservative factors corrected, the councils need for new legislation may not be necessary after all.
How about in the alternatives offer for the public to pick from the economic impact for the entire S. Atlantic recreational impact with a 4 month closure will only attribute to a total of $ 1,032,000. An example is the entire state of NC will only have an impact of $ 37,000. That is ridiculous. That equates to 37 trips at a charter price of $ 1,000. The impact is for the "for hire" sector which is lumped in with the recreational sector as a whole. There is no account for the true recreational sector such as recreational food, fuel, hotel, shopping, tackle, boat maintenance etc. For a 4 month NC closure, $ 37,000, REALLY?
We would like to see the gag assessment redone. There are too many uncertainties and inconsistencies to move forward with an assessment that will affect such a large fishery.
- The Gulf of Mexico Grouper assessment has been reviewed due to some of the same questions. There were many corrections and this was done in less than 6 month time frame.
Fishing effort is significantly reduced and is not taken into account when calculating future estimates as it should be.
Economic impact and true fishing pressure of both recreational and commercial fishing is grossly inaccurate.
If after a review it is necessary to reduce harvest, only modest bag limit decreases or modest size limit increases should be considered acceptable if in fact a problem exists.
I am sure that the Council want to make sound decisions. The economic and social devastation wrought by these proposed Gag regulations comes at a time when effort is significantly declining (I feel permanently) due to exorbitant fuel prices. These current proposals are based on overly precautionary thresholds which compound to create the false sense of an unhealthy fishery, when in fact the fishery could be quite healthy.
Is it any wonder that the individuals that you are governing are not satisfied with the proposed solutions when they seem to have a better handle on the fish stock, behavioral patterns, abundance and realistic solutions and are not heard by you?
I urge the Council to:
1. Review the Natural Mortality Rate of Gag 2. Review and adjust the overly precautionary estimates 3. Provide the numbers for and consider as an alternative a 26” Gag minium size limit (20% or more reduction in rec landings alone) as the FIRST tool applied to the fishery. 4. Invite Dr. Trevor Kenchington to the SSC and Council meeting in June. Dr. Kenchington has extensive knowledge of both the Gulf of Mexico and the South Atlantic fisheries and could prove an excellent resource in the interpretation of current data parameters.
Thank you for your time and the opportunity to voice my concerns.
Best Regards,
William Todd Callan
To The Distinguished Members of the South-East Atlantic Fisheries Council;
I am writing to you because of my increasing concern regarding the Gag Plan for the Keys. My experience as a recreational diver, and an educator, lead me to conclude that the plan, as it is currently laid out, is completely inappropriate for the Florida Keys. I am particularly concerned because the plan, though well intentioned, is missing its target completely. If you proceed without revision you will actually be causing more damage to a valuable fishery, rather than protecting it.
Please consider these key points. • Your currently proposed closure dates (January – April) would allow for Grouper to be harvested during their spawn! Black Grouper, the predominant grouper population here, spawn primarily in April and May at full moons. Unfortunately, the current laws open Grouper at the very height of the spawn. • Current regulations have created "Derby Fishing" for Grouper when combined with a large spear fishing contest held annually on the opening. The aggregating grouper are overharvested in 3-4 days and it takes until Fall for other groupers to repopulate patch reefs and inshore areas. Fish which use to spawn and then be harvested over a 3-4 month period are now harvested in a weeks period. A "Grouper mini season" ensues. • A closure of April and May to all harvest, recreational and commercial is a valid, logical solution. The law enforcement here in the Keys is extremely understaffed. More officers and patrolling is needed. The complete closure to both sectors would help to simplify Law Enforcement efforts. No gray areas, no loopholes. • By closing to both recreational and commercial you would also be helping to protect the fisheries by curtailing the rampant illegal fish sales, a problem which has been shamefully ignored and is cause for uncountable quantities of illegally caught and sold fish. Recreational fisherman and the restaurants are bold in their acquisition of illegal fish because there is no one regularly checking their books, coolers and sales. Monitoring illegal fish sales • In recent years there has been an increasing number of divers from areas outside of the Keys. They travel in large groups, hunt and spear everything they see, without regard for the environment in which they are in. • Some will argue that higher fuel prices have slowed effort by less trips being made. What is not taken into account is the boats making trips now carry more people (harvesters). The Internet sites such as provide a forum where alike minded harvesters connect and arrange trips on recreational boats and share expenses for their seat. So people who previously would have never fished together combine costs. Thus, the number of harvesters is actually increased. These vessels do not have appropriate Federal or State permits, nor licensed captains, or insurance. On two separate but related subjects included in the Gag Plan • Make an exception for using “J” hooks for yellowtail. They cannot be hooked with a circle hook.[Seana Cameron] a few conversations with anyone who fishes can tell you that. • No retention of grouper or snapper by charter captain and crew. A large portion of those fish are being sold. Charter fishing is for “sport” and the captains/owners of those boats are paid regardless. More importantly the charter boat permit rule regarding the sale of “one persons recreational catch” is universally ignored. Again, this practice feeds the illegal sale of fish to restaurants. Most fish houses will buy up to 6 people’s recreational limit arguing it's the recreational boat limit. If the boat is not booked they fish themselves and sell the catch.
Thanks you for your time and attention to these matters. Please take these arguments to heart. I care deeply about the waters that surround us, and respect those who work to protect them responsibly.
Sincerely,
Seana Cameron
Grouper Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFCs own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely by-catch mortality and habitat destruction from trawling and long line activities. I believe that NO CHANGES are required at this time, and the SAMFCs preferred alternatives would have a drastic economic impact.
I am against alternative 2 (Establish a gag spawning season closure January through April...) in that there is no reliable data on recreational landings to support this position. This alternative places a greater burden on the recreational sector. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I support Alternative 3 (Directed Commercial Quota)
I support Alternative 4 (Divide Directed Commercial Quota into 2 regions). In addition, I support the regional management of the recreational sector with Florida being a separate management area
In reference to Alternative 5. Recreational measures:
I am against Alternative 5a (Reduce the 5-grouper aggregate bag limit to a 3- grouper...January-April fishery closure). This alternative places an unfair burden on the recreational sector without a comparable reduction to the commercial landings. I am against alternative 5 in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I am against Alternative 5b (December - April closed season, retain current bag limits...). I am against alternative 5b in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Amendment 16 also includes alternatives to reduce by-catch mortality by requiring the use of venting/dehooking tools and circle hooks. I agree with this as it reduces mortality and aid in the recovery of the stocks.
Vermilion Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The spikes in this fishery have been caused by the SAMFC shifting pressure from the Sea Bass fishery which in turn has concentrated pressure on the Vermilion fishery. In addition, the explosion of the Goliath Grouper populations is putting increased pressure on this fishery. I would suggest a limited take/season on the Goliath Grouper fishery.
I am against Alternative 2 (Interim Allocations). I would suggest that SAMFC increase data collection on both the fishery health and fishery utilization before enacting any changes. In addition, a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Sincerely, Mitchell Carter I support the comments above. I feel that the by-catch of commerical fisherman is most destructive to fishery.
Dear (council members name),
Thank you for the opportunity to comment on Amendment 16 to the South Atlantic Fishery Management Council’s Snapper Grouper Fishery Management Plan. The Coastal Conservation Association is a private, non-profit marine fishery conservation organization with over 97,000 members in 15 state chapters from Maine to Texas.
Most fish in this complex are long lived, slow growing species that cannot tolerate intense fishing pressure. The management history of the snapper/grouper complex is a testimony to inadequate regulations often applied too late. Past management has led us to what most fishermen now see as draconian season closures coupled with low bag limits and quotas. However, while painful, we believe these reductions are necessary to rebuild gag grouper and vermillion snapper stocks, as required by law.
Our comments are below.
Gag Grouper
Interim Gag Allocation Alternatives and Resulting Commercial Quota & Recreational Allocation
Alternative 2 (preferred). Define interim allocations for gag based upon landings from the ALS, MRFSS, and headboat databases. The allocation would be based on landings from the years 1999-2003. The allocation would be 51% commercial and 49% recreational (Table 2-4). This alternative would establish a commercial quota of 353,940 pounds gutted weight and a recreational allocation of 340,060 pounds gutted weight. Commercial quotas associated with allocation alternatives for gag taking into consideration estimate of PQBM.
CCA Comment: In the absence of better data to examine allocations, Alternative 2 seems the most equitable. We support Alternative 2 until a better method is devised to set allocations.
Management Alternatives for Gag
Alternative 2 (Preferred). Establish a gag spawning season closure January through April that applies to both the commercial (20% reduction) and recreational (31% reduction) sectors; no fishing for and/or possession of gag would be allowed. In addition, no fishing for and/or possession of the following species would be allowed: black grouper, red grouper, scamp, red hind, rock hind, yellowmouth grouper, tiger grouper, yellowfin grouper, graysby, and coney.
CCA Comment: As long as it applies equally for both sectors, CCA supports a spawning season closure for gag grouper.
Alternative 5b. Close the month of December to recreational harvest and/or possession of gag, black grouper, red grouper, scamp, red hind, rock hind, yellowmouth grouper, tiger grouper, yellowfin grouper, graysby, and coney. This alternative would retain the existing 5-grouper aggregate bag limit and 2 gag or black grouper bag limit. The December through April closure plus the reduction in bag limits would result in a 42% reduction in harvest.
CCA Comment: CCA supports Alternative 5b. We believe the season closure provides the most effective conservation benefit to stop overfishing of gag and rebuild the stock.
Vermilion Snapper
Interim Vermilion Snapper Allocation Alternatives Alternative 1 (no action). Do not define interim allocations for vermilion snapper.
Alternative 2 (preferred). Define interim allocations for vermilion snapper based upon landings from the NMFS landings (ALS), NMFS Marine Recreational Fisheries Statistics Survey (MRFSS), and NMFS headboat databases. The allocation would be based on landings from the years 1986-2005. The allocation would be 68% commercial and 32% recreational. This alternative would establish a commercial quota of 385,002 pounds gutted weight (427,352 pounds whole weight) and a recreational allocation of 181,177 pounds gutted weight (201,107 pounds whole weight).
CCA Comment: CCA supports Alternative 2, until such time as better allocation criteria are developed.
Management Alternatives for Vermilion Snapper
Alternative 4. Adjust recreational bag/size limit and establish a recreational closed season; no fishing for and/or possession of vermilion snapper would be allowed during the closed season; and captain/crew on for-hire vessels would not be able to retain vermilion snapper
Alternative 4d (Preferred). Reduce the bag limit from 10 to 4 vermilion snapper (45% reduction) and a season closure (no fishing for and/or possession) of October through th May 15 (38% reduction) (Total reduction = 66%).
CCA Comment: CCA supports Alternative 4d. We believe the season closure provides the most effective conservation benefit to stop overfishing of vermillion snapper and rebuild the stock. In addition we are intrigued by an option with no minimum size and presume this is an effort to reduce regulatory discards. While we wonder what reducing the size/age of entry into the fishery does to the reference point calculations, it may be time to experiment with this option to see if it in fact reduces discards or just causes high grading. We believe the season closure helps mitigate any potential problems that may occur.
Reduce Bycatch of Snapper Grouper Species
Alternative 1. No Action. Do not require use of venting tools, dehooking devices, and circle hooks to reduce bycatch.
Alternative 2. Reduce recreational and commercial bycatch mortality by requiring the following for a person on board a vessel to fish for snapper grouper species in the South Atlantic EEZ: (a) use of venting and dehooking tools and (b) use of non-offset, non- stainless steel circle hooks when using natural baits to fish for snapper grouper species in one of the following South Atlantic EEZ fisheries: Alternative 2a. Commercial snapper grouper fishery. Alternative 2b. Recreational snapper grouper fishery. Alternative 2c (Preferred). Both commercial and recreational snapper grouper fisheries.
CCA Comment: CCA supports Alternative 2c.
Allow NMFS Regional Administrator (RA) to Make Adjustments to Management Measures after pending Vermilion Snapper SEDAR Assessment
Alternative 1. No Action. Do not allow the Regional Administrator (RA) to adjust the management measures based on the outcome of the new vermilion snapper SEDAR benchmark assessment.
Alternative 2 (Preferred). Allow the RA to adjust the management measures as specified in Table A based on the outcome of new vermilion snapper SEDAR benchmark assessment.
CCA Comment: CCA supports Alternative 2.
We appreciate the opportunity to comment on these important fishery management options. Please feel free to contact us if you have any questions.
Yours truly,
State Chair, President or GR Committee chair.
Grouper Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFCs own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely by-catch mortality and habitat destruction from trawling and long line activities. I believe that NO CHANGES are required at this time, and the SAMFCs preferred alternatives would have a drastic economic impact.
I am against alternative 2 (Establish a gag spawning season closure January through April...) in that there is no reliable data on recreational landings to support this position. This alternative places a greater burden on the recreational sector. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I support Alternative 3 (Directed Commercial Quota)
I support Alternative 4 (Divide Directed Commercial Quota into 2 regions). In addition, I support the regional management of the recreational sector with Florida being a separate management area
In reference to Alternative 5. Recreational measures:
I am against Alternative 5a (Reduce the 5-grouper aggregate bag limit to a 3- grouper...January-April fishery closure). This alternative places an unfair burden on the recreational sector without a comparable reduction to the commercial landings. I am against alternative 5 in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I am against Alternative 5b (December - April closed season, retain current bag limits...). I am against alternative 5b in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Amendment 16 also includes alternatives to reduce by-catch mortality by requiring the use of venting/dehooking tools and circle hooks. I agree with this as it reduces mortality and aid in the recovery of the stocks.
Vermilion Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The spikes in this fishery have been caused by the SAMFC shifting pressure from the Sea Bass fishery which in turn has concentrated pressure on the Vermilion fishery. In addition, the explosion of the Goliath Grouper populations is putting increased pressure on this fishery. I would suggest a limited take/season on the Goliath Grouper fishery.
I am against Alternative 2 (Interim Allocations). I would suggest that SAMFC increase data collection on both the fishery health and fishery utilization before enacting any changes. In addition, a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Sincerely, As a Brevard recreational diver and fisherman for the last 20 years I have never seen better populations of snapper and grouper. WHAT ARE YOU GUYS THINKING!!
Mr. Robert Mahood Executive Director
GROUPER/SNAPPER BILL I THINK THIS IS A CONFLICT OF INTEREST BEING THAT SOME PEOPLE THAT ARE VOTING HAVE FEDERAL PERMITS...... IF THIS PASSES THERE WILL PROBABLY BE LAWSUITS ON THE HORIZON. RECREATIONAL FISHERMAN WILL CONTINUE TO CATCH THE USUAL AND THEIR CATCH WILL NOT BE COUNTED IN HARVEST QUOTAS...... WHAT IS THIS ACCOMPLISHING? I TOTALLY SUPPORT CONSERVATION, BUT THIS IS GIVING THE FEDS A LICENSE TO STEAL IN A WAY.
Sincerely, Carlton Clark 417 Lynette Dr. Wilmington, NC 28409 Gentlemen,I think your amendment 16 would be a disaster to commercial fishermen. I have noted the last couple of yearss a remarkable decline in recreational and commercial fishermen starting the first of May. This is a good sign for the spawning snappers. This and the cost of gas and bait will automatically regulate the snapper population without the proposed Amendment 16 for the use of circle hooks instead of jay hooks.
Sincerely, Gerald Dent, A commercial fisherman
Mr. Robson,
I wanted to drop you a line to briefly voice my opinion on Amendment 16. My first reaction is "What are you people thinking?" Sometime back in 2007, the SAFMC received updated stock assessment information indicating over fishing of gag grouper and vermillion snapper. It is not clear where this data came from or how it was gathered. But, based on this "proof," it has fallen back on the Magnuson-Stevens Reauthorization Act, which it says mandates that it fix the perceived problem within one year. Mr. Robson you and your colleagues need to look up "knee-jerk" in the dictionary. It's obvious there needs to be more specific scientific studies performed before any reasonable minded person makes such an important decision.
One of the first recommendations is a total closure for gag grouper from January to April in all federal waters for both commercial and recreational anglers. But then, almost as a footnote, the SAFMC adds these other species to the closure list: black grouper, red grouper, scamp, red hind, rock hind, yellowmouth grouper, tiger grouper, yellowfin grouper, grasby and coney. These "preferred" alternatives as stated by the SAFMC would be punitive for recreational anglers and disastrous for charter and head boat operations on the Eastern seaboard not to mention an incredible loss in tourist dollars. Ask yourself- Would you pay $80 for a head boat trip in order to bring home four small vermillion snapper?
FYI-A news release by the SAFMC says it is accepting written comments on these rules and that details on how to submit written comments will be posted at www.safmc.net. Try to find it. There is no mechanism to comment online, where the easiest access would naturally be.
Amendment 16 would also mandate that all anglers, commercial or recreational, use venting tools and dehooking devices, which makes sense. But it would also mandate the use of stainless steel non-offset circle hooks when fishing live or dead bait for grouper or snapper. Most would agree that circle hooks do cut down on fish mortality. But stainless steel- obviously an angler is not making these recommendations- stainless steel hooks can stay imbedded in a fish forever, while others rust out within weeks. Where is the logic in this recommendation?
Lastly-no thinking angler argues that our stocks of saltwater fish do indeed need management. But when 10 percent of the boats get 90 percent of the resource, something's very wrong. And when non-specific data is used to close down thousands of miles of ocean to anglers who spend billions of dollars a year in Florida to bring home a fresh fish dinner, the proposed action seems closer to a crime.
Thank you for your time and hopefully I'll be thanking you for reacting responsibly. Please forward this to your Florida colleague Anthony Larocci as there is no email address on your website to contact him.
Scott A. Donaldson
Sir, It has come to our attention that it is proposed to open the grouper season during the spawn period of April/May. It is our considered opinion this will have a detrimental effect on fish stocks here in the Keys. We urge you reconsider this measure. We suggest that both commercial and recreational fishing be banned during the critical spawn period of April and May. We are the Captains of the National Park Service M/V Fort Jefferson, a 110' supply vessel serving the Dry Tortugas National Park. One of the roles of the M/V Fort Jefferson is support of various research groups working within the park. While we are sending these comments as private citizens we will also be expressing our concerns to the members of several agencies. I believe you will be hearing from them to express their concern as well. Regards Captain Clay Douglass Captain Janie A. Douglass
Blue 99 HD1200S 93 Winnebago Warrior
I think you are hurting recreational fishing by closing the season. You would serve the public interest by changing the bag limit or size limit only and no season closure to recreational fishing. It is a proven economic fact that recreational boaters provide more dollar impact to communities with the overall dollars they spend along with what they spend with charter captains. Please consider only changing the bag limit or size and not a seasonal closure.
William M. Eastwood, CFP ®
Eastwood & Associates Wealth Strategies, LLC.
3210 N. Wickham Road Suite 4
Melbourne, FL 32935
Phone: (321)-757-3323
Fax: (321)-757-0553
Grouper Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFCs own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely by-catch mortality and habitat destruction from trawling and long line activities. I believe that NO CHANGES are required at this time, and the SAMFCs preferred alternatives would have a drastic economic impact.
Sincerely, Joseph M. Falango
The Florida Coastal and Ocean Coalition Caribbean Conservation Corporation & Sea Turtle Survival League • Reef Relief ● Gulf Restoration Network • Natural Resources Defense Council • The Surfrider Foundation • Ocean Conservancy • Environmental Defense Fund
May 15, 2008
Sent via Electronic mail
Mr. George Geiger, Chairman South Atlantic Fishery Management Council 4055 Faber Place Drive, Suite 201 N. Charleston, SC 29405
RE: Comments on Public Hearing Draft Snapper-Grouper Amendment 16 (Gag Grouper and Vermilion Snapper)
Dear Chairman Geiger,
On behalf of the Florida Coastal and Ocean Coalition (Coalition), please accept these comments regarding the South Atlantic Fishery Management Council’s (SAFMC) Public Hearing Draft Snapper-Grouper Amendment 16 (Gag Grouper and Vermilion Snapper). The Coalition is a collaborative effort of conservation organizations which have joined forces to conserve, protect and restore Florida’s coastal and marine environments, including restoring marine ecosystems and ensuring robust fisheries. Our steering committee organizations represent millions of citizens across the country and over 200,000 members, businesses and activists in Florida deeply concerned for the unique marine resources in Florida and the South Atlantic.
We are deeply concerned about the health of our offshore fisheries and the status of many reef fish populations due to increasing fishing pressure, bycatch mortality, continued adverse impacts to coastal and marine habitats, and lack of adequate consideration to the biology of individual fish species. We would like to thank the Council for providing this opportunity to submit our views on the Amendment 16, which is intended to end overfishing for gag grouper and vermilion snapper in the South Atlantic, and offer the following comments:
Gag grouper were identified as experiencing overfishing in the Southeast Data Assessment and Review process number ten (SEDAR 10), and vermilion snapper were
9 Island Avenue, Suite 501, Miami Beach, FL 33139 (305) 586-1961 • [email protected] www.flcoastalandocean.org Chairman George Geiger Page 2 of 3 SAFMC Amendment 16 Commenting May 15, 2008
identified as undergoing overfishing in 2007.1 Consequently, the Coalition recommends that the National Marine Fisheries Service (NMFS) and the SAFMC immediately institute management measures that end overfishing of these two species, achieve optimum yield, incorporate appropriate buffers in catch levels and quotas that are set to ensure that overfishing is prevented, count and minimize bycatch, and protect essential gag spawning areas and depleted male gag in the South Atlantic.
The Coalition also supports the following specific recommendations for Amendment 16: • We support the Council’s preferred alternatives for setting maximum sustainable yield (MSY) and optimum yield (OY) status determination criteria for both gag (Alternatives 2 and 2b) and vermilion snapper (Alternatives 2 and 2b) as defined by the stock assessment review panel; • We support the Council’s preferred alternatives for setting total allowable catch (TAC) for gag (Alternative 2) and vermilion snapper (Alternative 2) at the fishing mortality level that achieves optimum yield (OY); • We support the Council’s preferred alternatives that set a hard quota to achieve the commercial portion of the TAC for gag (Alternative 3) and vermilion snapper (Alternative 2) and to implement a commercial and recreational gag closure to protect spawning aggregations and resident male fish (Alternative 2); and, • We support the Council’s preferred alternative to require gear to reduce bycatch mortality in snapper grouper species (such as circle hooks, venting tools, etc.) (Alternative 2c).
The Coalition also believes that the SAFMC and NMFS must ensure that management measures to end overfishing of gag grouper and vermilion snapper are implemented as quickly as possible. We urge completion of this amendment and submission to the Secretary at the June council meeting as the one-year time limit for its preparation expires June 12, 2008.
Essential to the sustainability of any fishery resource is ensuring that annual mortality targets and limits – that account for both landed catch and bycatch – for a managed species must end and prevent overfishing, that appropriate buffers are in place to ensure an appropriate likelihood of success, that abundant levels of prey species exist, and that habitats used by these species and their prey are protected. The Magnuson Stevens Fishery Conservation and Management Act (MSA) requires that fisheries must be managed to achieve optimum yield on a continuing basis, not simply to prevent overfishing at the MSY level.2 The Coalition is encouraged by the preferred alternatives indicated in the Draft Environmental Impact Statement for Amendment 16 and is supportive, in general, of its contents. We applaud the South Atlantic Council and the Fisheries Service for their leadership and commitment to the critically important issue of ending overfishing and ensuring sustainability of our public trust resources.
1 Vermilion Snapper SEDAR Update Process #3 2 16 U.S.C. § 1851(a)(1). Chairman George Geiger Page 3 of 3 SAFMC Amendment 16 Commenting May 15, 2008
The Coalition appreciates the opportunity to provide these comments on the Public Hearing Draft of Amendment 16 to the Snapper Grouper Fishery Management Plan. We look forward to working with the SAFMC and NMFS in the future to ensure the sound management of South Atlantic fishery resources.
Sincerely, Gary Appelson – Caribbean Conservation Corp. Sarah Chasis, J.D. – Natural Resources Defense Council Ericka D’Avanzo – Surfrider Foundation Jerry Karnas – Environmental Defense Fund Paul G. Johnson – Reef Relief Joe Murphy – Gulf Restoration Network David White, J.D. – Ocean Conservancy
cc: Charlie Crist, Governor, State of Florida Ken Haddad, Exec. Director, Florida Fish & Wildlife Consv. Commission Rodney Barreto, Chairman, Florida Fish & Wildlife Consv. Commission Thomas McIlwain, Chairman, Gulf of Mexico Fishery Mgmt Council Distribution
Grouper Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFCs own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely by-catch mortality and habitat destruction from trawling and long line activities. I believe that NO CHANGES are required at this time, and the SAMFCs preferred alternatives would have a drastic economic impact.
I am against alternative 2 (Establish a gag spawning season closure January through April...) in that there is no reliable data on recreational landings to support this position. This alternative places a greater burden on the recreational sector. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I support Alternative 3 (Directed Commercial Quota)
I support Alternative 4 (Divide Directed Commercial Quota into 2 regions). In addition, I support the regional management of the recreational sector with Florida being a separate management area
In reference to Alternative 5. Recreational measures:
I am against Alternative 5a (Reduce the 5-grouper aggregate bag limit to a 3- grouper...January-April fishery closure). This alternative places an unfair burden on the recreational sector without a comparable reduction to the commercial landings. I am against alternative 5 in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I am against Alternative 5b (December - April closed season, retain current bag limits...). I am against alternative 5b in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Amendment 16 also includes alternatives to reduce by-catch mortality by requiring the use of venting/dehooking tools and circle hooks. I agree with this as it reduces mortality and aid in the recovery of the stocks.
Vermilion Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The spikes in this fishery have been caused by the SAMFC shifting pressure from the Sea Bass fishery which in turn has concentrated pressure on the Vermilion fishery. In addition, the explosion of the Goliath Grouper populations is putting increased pressure on this fishery. I would suggest a limited take/season on the Goliath Grouper fishery.
I am against Alternative 2 (Interim Allocations). I would suggest that SAMFC increase data collection on both the fishery health and fishery utilization before enacting any changes. In addition, a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
In additions to these Amendments I think the statistic gathering on SAFMC part was not in interest of the Recreational fisherman and not very convincing. They need to use a more accurate way of gathering recreational catches. There are too many assumptions. During the meeting the explantion of how SAFMC gather these statistics where not convinicing in any manner.
Sincerely, Jerry Fedele
Florida Keys Commercial Fishermen’s Association (Formerly Monroe County Commercial Fishermen, Inc.) P.O. Box 501404, Marathon, FL 33050 Phone: 305-743-0294 Cell: 305-619-0039 Email: [email protected]
May 16, 2008
Mr. Gregg T. Waugh South Atlantic Fishery Management Council 4055 Faber Place Drive, Suite 201 North Charleston, SC 29405
RE: SAFMC Snapper Grouper Amendment 16
On behalf of the Florida Keys Commercial Fishermen’s Association (FKCFA) I am submitting public comment on the South Atlantic Fisheries Management Council’s Amendment 16 (measures to end overfishing for gag grouper and vermilion snapper). Specifically, the association requests: an exemption for yellowtail and grey snapper fishermen from the circle hook requirement, a six month closure in the Florida Keys on gag grouper only and a “Florida Keys” only quota for all species. For years, size and bag limits along with quotas have strengthened the sustainability of our fisheries. However, the usefulness of long continuous spawning closures is questionable especially during the economic peak of a region’s fishing season. The intent to protect spawning populations sounds great, but applying the practice is not as simple as closing down a fishery for four months. The compounding effects of hurricanes, operating costs (chum, ice, fuel) and competitively priced imports makes a four month closure a serious threat to the economic viability of the commercial snapper/grouper (S/G) fisheries in Monroe County. In Australia, the annual spawning season coral reef fish closures for 2007 took place in October, November, and December over nine-day periods coinciding with the new moons. All reef fish congregate to spawn when they receive particular physical, chemical, social and biological cues. If we really want to protect fish in the “act” of spawning we need distinct knowledge of spawning dynamics and specific measures to provide appropriate protection. According to the SAFMC document, Potential fishing communities in the Carolinas, Georgia, and Florida: An effort in baseline profiling and mapping ( 2002; Jepson et al.) in 2001, Monroe County had 36% of the Snapper Grouper Class 1 permits and 42% of the Class 2 permits for an overall total of 34% of the S/G permits available at that time. According to the commercial trip ticket and logbook data collection programs, Monroe County alone lands about 25% of the entire South Atlantic catch of shallow water groupers and only 1% of it is of gag grouper In other words, Monroe County lands 9 times (900%) the amount of black grouper and 8 (790%) times the amount of red grouper than the entire East Coast of Florida. In addition, other commercially significant groupers such as red and black grouper constitute 42% and 35% of Monroe County’s grouper fishery, respectively wheras gag constitute less than 1% of the total Monroe County grouper harvest (see Figure 1). Although past analyses may indicate that red and black grouper are below OY status, no SEDAR stock assessment has been conducted for these species so we do not definitively know if there is a need to reduce their fishing mortality. Consequently, it may not be necessary to propose catch restrictions on red and black grouper, especially in the Florida Keys. Furthermore, given the lack of appropriate social and economic analyses regarding the impacts of a four month grouper closure on the Florida Keys fishery, we feel such a closure would be a disservice to commercial and recreational fishermen, particularly when the only species that needs protection constitutes an insignificant amount of the overall harvest. In order to comply with mandates to end overfishing and reduce bycatch in SAFMC grouper fisheries, FKCFA proposes that an alternative to the four month closure would be a six month closure of the gag fishery in Monroe County to offset any bycatch mortality that might occur while fishing for reds and blacks. The FKCFA also proposes that the S/G fishery be regionalized and separate quotas be set for the Florida Keys. We offer this suggestion based on the commercially insignificant amount of gag harvested in Monroe County and urge the Council to adopt a “regional” approach by creating management boundaries at the Monroe-Dade County line. Given that the Florida Keys represents the most valuable sub-tropical commercial fishing region in the South Atlantic, (consistently ranking in the top 10 nationally), and the region holds approximatly 1/3 of the total snapper grouper permits and a quarter of all snapper grouper landings, FKCFA strongly believes the region warrants more specific management measures and associated impact analyses than are provided in Amendment 16. In addition, the FKCFA believes the proposal in Amendment 16 to eliminate the use of j- hooks to reduce bycatch mortality in gag grouper and vermillion snapper will dramatically affect the ability of the Monroe County commercial yellowtail and grey snapper fishermen to harvest their historical quantities of fish. The commercial yellowtail and grey snapper fisheries are unlike any other fishery in South Florida because of the way fish are “brought to the surface” using chum. Yellowtails are harvested at a rapid rate; on the surface with j-hooks and natural bait. Fishermen report that a circle hook will increase the probability for a yellowtail to “spit” the hook (due to the metal sensation in its mouth). Fishermen also point out that circle hooks will force them to unhook the fish by hand instead of using an ice box dehooker, thus cutting their productivity by up to 50%. Circle hooks do reduce the potential for “gut-hooking” a fish but the socio-economic effects of eliminating j-hooks in the commercial yellowtail and grey snapper fisheries has not been adequately evaluated in Amendment 16. Until there is a definitive study demonstrating that commercial yellowtail fisheries will be similarly viable using circle hooks, FKCFA respectfully requests the SAFMC to allow commercial yellowtail and grey snapper fishermen to continue to use j-hooks by removing the measure to eliminate the use of j-hooks in Amendment 16 for these species. The FKCFA would be glad to contact our membership and assist the Council by producing a j-hook vs. circle hook “demonstration project” to provide greater insight into this issue. In conclusion, closing Monroe County’s grouper fishery during its peak season of economic importance will be devastating to our local fishermen and economy. The aforementioned statistics support FKCFA’s proposal to refrain from completely closing the commercially significant grouper fisheries in Monroe County. We want healthy fisheries and we will work with the Council to rebuild overfished fisheries and help sustain our resources and industry. However, closing the entire grouper fishery to offset the bycatch mortality of one fish that is only a minor component of our fishery is far to burdensome for the limited benefits that would accrue. Given the lack of social and economic impact analyses, such a measure also may be in violation of the Magnuson Stevens Fisheries Conservation Management Act. We respectfully request the Council to consider our proposed options for protecting gag and reducing bycatch in the snapper-grouper fishery. Sincerely, Scott E. Zimmerman M.Sc., Executive Director
To Whom It May Concern:
I would like to voice my negative opinion to a change in the recreational fisherman’s bag limits for Grouper and Snapper. I feel blaming the recreational fisherman in what is very obviously a problem with the commercial fisherman and their tactics to down right wrong. We need to keep the dollars and cents coming into our local economy by recreational fisherman, and to cut the bag limits on these species would cut much needed revenues in these hard financial times.
Please do not change the current recreational bag limits, but do take a long hard look at the commercial fisherman and how they come up with their ‘science’ data.
Robin Folsom Cocoa, FL
Grouper Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFCs own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely by-catch mortality and habitat destruction from trawling and long line activities. I believe that NO CHANGES are required at this time, and the SAMFCs preferred alternatives would have a drastic economic impact.
I am against alternative 2 (Establish a gag spawning season closure January through April...) in that there is no reliable data on recreational landings to support this position. This alternative places a greater burden on the recreational sector. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I support Alternative 3 (Directed Commercial Quota)
I support Alternative 4 (Divide Directed Commercial Quota into 2 regions). In addition, I support the regional management of the recreational sector with Florida being a separate management area
In reference to Alternative 5. Recreational measures:
I am against Alternative 5a (Reduce the 5-grouper aggregate bag limit to a 3- grouper...January-April fishery closure). This alternative places an unfair burden on the recreational sector without a comparable reduction to the commercial landings. I am against alternative 5 in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I am against Alternative 5b (December - April closed season, retain current bag limits...). I am against alternative 5b in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Amendment 16 also includes alternatives to reduce by-catch mortality by requiring the use of venting/dehooking tools and circle hooks. I agree with this as it reduces mortality and aid in the recovery of the stocks.
Vermilion Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The spikes in this fishery have been caused by the SAMFC shifting pressure from the Sea Bass fishery which in turn has concentrated pressure on the Vermilion fishery. In addition, the explosion of the Goliath Grouper populations is putting increased pressure on this fishery. I would suggest a limited take/season on the Goliath Grouper fishery.
I am against Alternative 2 (Interim Allocations). I would suggest that SAMFC increase data collection on both the fishery health and fishery utilization before enacting any changes. In addition, a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Sincerely, Mark Arnett Jordan Weaver Gregory Clifford Christopher Costello Troy Denson Stanley E Yekalis Dwayne L. Wilson Charles H. Turner J Bronson Stubbs Scott Rowe Lisandro Rosales Austin Raimundo Rodney Pratt michael s mccrory James Martin Gary Heidelberg 14351 Hampshire Bay Circle Winter Garden, Florida 34787 Jeffery A. Dunbar Russell Derrick Charles J Ellis Jack P. Hill, Esq. Capt. Dennis Young (SEA DANCER CHARTERS) Charlie McCullough Andrew J. Nicoll Jupiter, FL Lane C. Lauderback Roger Montz Gary Price 1599 Thornapple Lane Sanford, FL 32771 Pam McFarland David w. Taylor Robert D King Ronald W. Collins Robert D. McCullough, Jr. bill kirtley Robert Skrypek Michael V. McGuire Juliann G. Orvis I whole heartily support any move that retains the rights of recreation fishermen to continue enjoy the thrill of fishing for grouper. In 1948 our family moved to Florida because my father was a diehard outdoorsman. I do not want in any way to harm the rights to these fishermen and women have enjoyed for decades to be hampered by business or special interests leaning toward the needs of commercial fisheries. Lee Southard Chelsea Kiley Jeffrey A Page Christian Von Bargen Dennis W Parker Gregory Williams Richard Yates Michael Vona Eric M. Greenawalt Sr. William B, Barnett Gary Rauch Brent Compton Jennifer Naruta Gordon Naruta Jr Stephen sanders 6229 wild orchid dr lithia Fl 33547 Corey Johnson jason canin Joseph Booker Capt. William Baugh Jack Hexter Joel Barnes Stephen Trier Jeff Eberhardt Capt Chris Endicott Jason Dohaney leroy conley Marc Weber Lee Beall Fern Ochakoff Capt Paul Varian Michael A. Judy Kevin Kelley David Cheshire Frank Trudeau David S. Pietschman Tom McAleney Kenneth McDonald David Ingram Julie A Berry Charles E. Albine Mike Nelson Marvin Haynes Jerome Sheppard Douglas Nenninger J. Marshall Hultin Skip Chauvin John Schommer Jack Mountford Jim Benard Allen Watson
Grouper Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFCs own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely bycatch mortality and habitat destruction from trawling and longline activities. I believe that NO CHANGES are required at this time, and the SAMFCs preferred alternatives would have a drastic economic impact.
I am against alternative 2 (Establish a gag spawning season closure January through April...) in that there is no reliable data on recreational landings to support this position. This alternative places a greater burden on the recreational sector. Further a ban of all longlining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I support Alternative 3 (Directed Commercial Quota)
I support Alternative 4 (Divide Directed Commercial Quota into 2 regions). In addition, I support the regional management of the recreational sector with Florida being a separate management area
In reference to Alternative 5. Recreational measures:
I am against Alternative 5a (Reduce the 5-grouper aggregate bag limit to a 3-grouper...January- April fishery closure). This alternative places an unfair burden on the recreational sector without a comparable reduction to the commercial landings. I am against alternative 5 in that there is no reliable data on recreational landings to support this position. Further a ban of all longlining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I am against Alternative 5b (December - April closed season, retain current bag limits...). I am against alternative 5b in that there is no reliable data on recreational landings to support this position. Further a ban of all longlining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Amendment 16 also includes alternatives to reduce bycatch mortality by requiring the use of venting/dehooking tools and circle hooks. I agree with this as it reduces mortality and aid in the recovery of the stocks.
Vermillion Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The spikes in this fishery have been caused by the SAMFC shifting pressure from the Sea Bass fishery which in turn has concentrated pressure on the Vermillion fishery. In addition, the explosion of the Goliath Grouper populations is putting increased pressure on this fishery. I would suggest a limited take/season on the Goliath Grouper fishery.
I am against Alternative 2 (Interim Allocations). I would suggest that SAMFC increase data collection on both the fishery health and fishery utilization before enacting any changes. In addition, a ban of all longlining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Sincerely, Lori Barber
Mark P. Wilson Carlos Nugent Capt Ronald L Sam Monroe Nolan E Lain Jr Cottell
Thomas Dohaney Alan Franco Andrew Charles Rodecker Brad Londeree Steve Quincy Robbie C. Linton Clark Lachcik Captain George Richford Jr. Kevin F. Rose Bradford R Spalding Joe Demato Eric R. Roberts Michael Greensrein Kathy O'Shay James Grizzard Jeff Coutant mikel placket Jimmy Goodwin Patrick J. Magrady cindy st. john robert blackledge Jack Mountford robert st john Mark Kowalski Chip Gaines matt perkins Janie Kowalski Warren Potter anthony Kramer chris bruce Brett Taylor tami tuper Steve Thompson Tony E Ford John J. FitzGerald Charles W. Moore Don Newhauser Christopher Hudson Drew Wilson Corey Bartlett theresa Fitzgerald Steve Williamson Danny Markowski Taylor M. Johnson R.C. Barenchik Steve Collins, Florida Sport Fishing Association Karl Pappas James Lloyd V.P. Dave Heil Danny Mills John Middleton Meli Londeree David Dannelly Peter Reccasina Chris Curole Ronald C. Berry ( TenneSEAan ) doug mays Steven B. Tate
Robert Cornell Michael F. Perry John Roach
Scott Sciullo Harold W. Umstattd Jr. Ed Jekielek
Robert p ives III Walter J Doerschuck III John Wingell
Brian Wright Leon Vetsch Leigh Davis
Jon Scholtens Bradley J. Latraverse Kurt J. Grau
Douglas J. Pritchard David McDonald Captain Rob Hammer
Colby Harris Robert Harris, COnchy Jorge Rodriguez Joe's Marine and Tackle, Lewis P.Augusta Key West Fl S. Todd Tharp
Jim Mason Ruben Barreiro Paula L. Cowart, Southern Dayz Randy McLendon John M Carney Perry Kirton Laura Rogers Stephen M. William Thomas Brian Dohaney Rob Murphy Welder
Joe Favata Glenn Misco Brian H. Sauer
Steve Gillespie Kenneth Nies Rita J. Sauer
Ron Varona Bob Lachcik Keith Reno
Paul E Ramirez William Alvarez Philip C. McDonald
Jose C. Bofill Andrew Alvarez Jo J Reeves
Walter Eismann AJ Claudio Garalde
Jorge Fernandez Mike Parr Melissa Guzman francisco martinez Michael Colter Ben A. Driver
James Hornbuckle Bruce E. Mock Dwight Griffis
Capt Stan Knae Dave Barrett Gene Miles Tim Lemieux Savannah, GA ryan landowski heidrun kane Chris Cass Elsa Bravo
JOHN WILLIAMS Louis Sanchez Paul Golub jreg botner Osmani Rodriguez Ryan Davis joseph barge Jorge S Perez Tom Adrien
Lino Suarez Jr. DMD daniel spencer Steve Singler
Jason Davis Brady Gaughan Howard W tuten
Terry Winn Robert P Walter Bill Trinka
Ron Teke Kendall W. Allen Arturo Sola
Clinton Winn Roger E. Mauzey Dinty J. Musk Jr.
DAVID R. ANDREW Geoffrey Richards James & Donna Carrier 208 Williams Randy T. Aloise Richard L. Wilson Rd. Winter Springs Florida , Capt Ken M Doss Cheryl Wilson Donna Golub jesse a gurganus John H. Riedel Allen Watson denise driver Samuel Thomas Downey III Jim Benard Robert S. Miller GEORGE W GREENE Jack Mountford John "BooDreaux" Baumann Gianni Bertuzzelli John Schommer
Donald K Henley James D. Ashcraft Skip Chauvin
Christian M. Rodriguez Stephen Patrick J. Marshall Hultin Childers jim Crawford Douglas Nenninger Bernie Presha jerry cummings Jerome Sheppard William and Jo Hyatt Cory Gauron Marvin Haynes Stephanie Conrad Richard J Wilson Mike Nelson
Charles E. Albine
Julie A Berry
Kenneth McDonald
Tom McAleney
David S. Pietschman Grouper Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFCs own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely by-catch mortality and habitat destruction from trawling and long line activities. I believe that NO CHANGES are required at this time, and the SAMFCs preferred alternatives would have a drastic economic impact.
I am against alternative 2 (Establish a gag spawning season closure January through April...) in that there is no reliable data on recreational landings to support this position. This alternative places a greater burden on the recreational sector. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I support Alternative 3 (Directed Commercial Quota)
I support Alternative 4 (Divide Directed Commercial Quota into 2 regions). In addition, I support the regional management of the recreational sector with Florida being a separate management area
In reference to Alternative 5. Recreational measures:
I am against Alternative 5a (Reduce the 5-grouper aggregate bag limit to a 3- grouper...January-April fishery closure). This alternative places an unfair burden on the recreational sector without a comparable reduction to the commercial landings. I am against alternative 5 in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I am against Alternative 5b (December - April closed season, retain current bag limits...). I am against alternative 5b in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Amendment 16 also includes alternatives to reduce by-catch mortality by requiring the use of venting/dehooking tools and circle hooks. I agree with this as it reduces mortality and aid in the recovery of the stocks.
Vermilion Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The spikes in this fishery have been caused by the SAMFC shifting pressure from the Sea Bass fishery which in turn has concentrated pressure on the Vermilion fishery. In addition, the explosion of the Goliath Grouper populations is putting increased pressure on this fishery. I would suggest a limited take/season on the Goliath Grouper fishery.
I am against Alternative 2 (Interim Allocations). I would suggest that SAMFC increase data collection on both the fishery health and fishery utilization before enacting any changes. In addition, a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Sincerely, David Cheshire
Kevin Kelley Corey Johnson Lee Southard
Michael A. Judy Stephen sanders Michael V. McGuire 6229 wild orchid dr Capt Paul Varian lithia Fl 33547 Robert Skrypek
Fern Ochakoff Gordon Naruta Jr bill kirtley
Lee Beall Jennifer Naruta Robert D. McCullough, Jr. Marc Weber Brent Compton Ronald W. Collins leroy conley Gary Rauch Robert D King Jason Dohaney William B, Barnett David w. Taylor Capt Chris Endicott Eric M. Greenawalt Sr. Pam McFarland Jeff Eberhardt Michael Vona Gary Price Stephen Trier Richard Yates 1599 Thornapple Lane Sanford, FL 32771 Joel Barnes Gregory Williams Roger Montz Jack Hexter Dennis W Parker Lane C. Lauderback Capt. William Baugh Christian Von Bargen Andrew J. Nicoll Joseph Booker Jeffrey A Page Jupiter, FL
jason canin Chelsea Kiley Charlie McCullough
Capt. Dennis Young 14351 Hampshire Bay SEA DANCER Circle Matthew Lankford CHARTERS) Winter Garden, Florida 34787 John T. Means Jack P. Hill, Esq. John D.Hannan Larry Abel Charles J Ellis Steve Dewey, Port Saint John Ryer Jordan Weaver John, FL. Jennifer White Rodney Pratt Captain Mark K Wright Raymer Sale Austin Raimundo William C. Rhodes Steve Burch Stanley E Yekalis David M. Powell Erik Huffman J Bronson Stubbs Dawn A. Brady Rich Adamoviic James Martin Jan Charles Potter Jim Thompson michael s mccrory Richard Endres Colby Woodward Jeffery A. Dunbar Richard F. Miller Richard P. Randolph Gregory Clifford wylie nagler Orange County FL 32809 Troy Denson Ernesto Diaz Chris Shewmaker Russell Derrick patrick Murphy Jeff Young Mark Arnett Ken Cardoza Stehen Carman Lisandro Rosales Daniel R. Lacey Michael K Hughes Dwayne L. Wilson H D Robuck III Trevor Luce
Christopher Costello David Paladino Eric Kubes
Scott Rowe Brendan Crooks Kenneth Hjelm
Charles H. Turner Brett A. Hyde Jeff Johns
Michael A McCane Captain Ron Surrency Joshua Hayman Atlantic Coast Charters Gary Heidelberg Inc. Dustin Pate (904)759-2057 Jay Jasperson Victor Alas Ed Skupeen
Danny Flippin Mike Periord Robert Bees
Captain George charles hancock John A Herrera LaBonte Randy Docks John Little Kathleen M. Nafziger Daniel Finelli Jeff Kyle Mel H. Waters Paul M Earl Michael Travis Gary Lillig Cliff Hagan Richard Praeger james sigler charles michael Brad Good Trish Gaines hawn Matt Schubert William J. Fazio Yuri Vakselis Tim Gregson Michael Adkins David Rogers Mike Kosiba Matthew Esposito Kenneth Harris David L. Clapp Chris Bucalo Jacob Gardner John Schmidt joseph wommack LARRY MANCINI jeep edson Micah S. Richardson Paula Mancini mARK hADDEN Ernest D. Feltman Bill Eisenzapf Andrew Moore Paulkassab Joshua Dickerson 52 Clemson St. Vu Le Lee Longworth Charleston, SC 29403 David R. Henderson joseph p stewart sr John Brady donald drenguba Ricky Baturin James A. Muscara
Christopher J. Lembo Joseph Carrasquillo christian mathisen
Ryan Brown Andrew Davis Ernest C Johns Jr
Nicholas Khalil Fazah Steve Howard John Bosgraaf dustin fleiner Jack Bergquist Dan Robuck Sr
Paul Partlow armando suarez
Chris Bartlett
Bryan Anderson jeffrey scott weikel
Jesse Elliott david willis
Brian Belzel
Lee Martines
Rick Reddick Purpose One Charters george Kelley
Jason Wetmore
Steven L Prater william charles marcotte jr.
Lee Clair john a hulsey
Alan Meyers
Todd A Major
JAMES A CURTIS CAPT USN RET I am sending a letter attached by request from the following individuals and their location. I have been asked to do so do to time and computer access.
Marty Gribble Charlotte, NC Waxhaw, NC Ira Bard Wilmington, NC Rob Swiger Allen Hendrick Charlotte, NC Greenville, SC Jerry Danko Waxhaw, NC Robert Munson Chris Shaffer Charlotte, NC Conway, SC Linda Cable Southport, NC Rodney Smith Daniel McIntyre Charlotte, NC Wilmington, NC Mario Giamattei Charlotte, NC Tim Bondurant Erin Burge Charlotte, NC Conway, SC Mickey Czarny Southport, NC William Rucker Jo Aygun Waxhaw, NC Charlotte, NC Reid Goodman
Dear S. Atlantic Council Members,
First, I would like to state that the purpose of my comments are just to address concerns that we have with the data used for decisions on the management of the fisheries in our region. It seems that for too long the subject of the proposed "problem" isn't always defined prior to a "solution" being derived. Public meeting inputs have the attitude that the decision has already been made. As a fishermen, I would be more than happy to supply data as would many of the fishermen I know, if you would educate us on what you need for information and assistance.
Just finding out about these meetings is hard enough, try getting on the SAFMC website and finding SEDAR 10 REPORT or Magnuson Stevens Scoping document and reading the entire thing along with understanding it is another issue altogether.
Too long have fisherman been pitted against each other, both commercial and recreational, in an attempt to, in my opinion, redirect focus on the issue at hand. Any form of accountability on the council's part for the decisions made on our behalf as fisherman, doesn't seem to exist. Decisions are made that do not seem to have both the fish stock and fisherman's best interest at heart. Politics appear to also be playing a huge role in the decisions made on our behalf and do at times, seem detrimental to the cause.
The council's actions are speedy mechanisms to put increased restrictions on a fishery, yet there are no such speedy mechanisms to decrease restrictions should any fishery’s biomass indeed increase to healthier levels, or have new data to contradict the imposing limits. We hear how it needs to produce results over a long time period such as 10 years to be accurate. Please don't site here how we can now catch more porgy. That is a sad example on the council's part at best. Historically, regulations don't give back but become more conservative in restrictions.
These viewpoints are directed towards Amendment 16 yet hold true of all others that are being reviewed at present.
As I have read extensive amounts of information including SEDAR 10 along with information from the SAFMC, etc. I have a couple of points that I would like to bring up.
From the SAMFC website and I quote
Lack of basic management data on many of the species still remains the major obstacle to successful management. MRFSS surveys have been proven unreliable. What changes in the last 10 years have been changed to upgrade the survey system? MRFSS is usually a year or two behind in estimating this trend, so my main concerns are about over-regulation that may not be warranted. MARMAP surveys on "random hard bottoms" are the basis of most surveys done. We are talking about reef fish, fish that look for live bottom and structure to make their home. Data collections from things like "Chevron traps" were inconclusive due to such low catch rates and classified as "indeterminable and inaccurate" after 27 years yet older data is still used to calculate present trends. Why are things like wave heights, sea surface temps, surface currents, hurricane impacts, DO, salinity, wind speed, wind direction, etc not included in present studies? Why are issues like water quality and pollution along with protecting our juvenile fish using our estuaries for growth not addressed or protected? We can pay a hog farmer or tobacco farmer not to raise their crop yet we don't address the shrimping bycatch that is drastically affecting our fish stock? Please don't tell me how great the "bycatch" gear is doing in the shrimping industry, the bycatch being shoveled overboard looks like a snow storm floating on the water coming from a shrimper. I understand they have to make a living, however, subsidizes their income for the percentage necessary and stop letting them trawl on the inside and watch how well our fisheries rebound. I am concerned on how "overly conservative" the council seems to be in their calculations and proposed regulations. Below are some of the areas that if corrected to more realistic parameters, would take us out of the "overfishing" category that the grouper and snapper species are presently assessed as.
I am concerned that F (fishing mortality; the percentage of the population that dies each year from fishing) is overstated partly because it is based on
1. Marine Recreational Fishing Statistical Survey (MRFSS) estimates of landings and discards, which have been declared unreliable and even ‘fatally flawed’ and
2. An overstated recreational release mortality of 25%.
Recreational fisheries Release mortality is presently assumed to be 25%, SEDAR 10 workshop stated Improved estimates of post-release mortality were obtained through tag release and caging methods (Burns et al. 2002; Overton and Zabawski 2003; McGovern et al.2005). Using these methods, mean mortality rates were estimated to be 21.2% (Overton and Zabawski 2003), 23% over a variety of depths (McGovern et al. 2005). Commercial fisheries Release mortality is presently assumed to be 40%. Your reasoning behind the proposed legislation is that the FMSY is below the F (Fish Mortality) factor, the FMSY has remained below the F (Fish Mortality) factor since 1983 in the S. Atlantic. With the council willing to error on the side of "conservative numbers and factors" is it any wonder this is the trend? Now take a look at our stocks. Have we decimated our biomass? No. Clearly real world numbers aren't being used to guage accurate regulation.
How can the Magnuson Stevens Act expect you to make changes within 1 year of notification if the council states that it takes 3-8 years to schedule and complete a stock assessment? For that matter, why, if notified that a stock is in "trouble", aren't the data compiled between the last stock assessment and the present date of the notifications, reviewed to determine if an issue really exists at the present notification time period prior to taking action?
According to your own data workshops, spawning stock biomass increased after 1999 corresponding to implementation of the 24 inch minimum size limit. Fishing mortality has been decreasing since 1992 yet the gag grouper lifespan has just been raised to 26 yrs to 30 years. The life expectancy factor has been raised recently which is also affecting the formula into an "overfishing" status.
50% of maturity is 3 years and 25.5 inches. Why don't we increase the minimum size limit to 26". It has proven effective for the size increase in 1999 to 24".
Fishing mortality in 2004 was estimated as 0.31, extremely conservative against 2007 projected mortality.
Why is the fishing mortality rate for 2007 not being used? Obviously the fishing pressure has reduced since 2004 yet the OPPORTUNITY to fish hasn't been reduced which I think is very important and not usually taken into account when new regulations are proposed.
The council can redo the entire Vermillion Snapper stock assessment due to concerns of accuracy and possible "gross negligence" of the last assessment with updated data, yet I am told by the council that the 2004 data used in SEDAR 10 for grouper won't be updated until 2011? Are you kidding me? With the impact that fuel has alone on the frequency of fishing trips which has been declining since 2004, why can we not use current data and revisit the workshop to determine if the present proposed measures are necessary?
How can there be underfunding on the federal or local level to interpret the data that is taken every year but not incorporated or used due to lack of resources and man power as stated by the council with 3-8 years between stock assessments?
Why are the conclusions and recommendations from the data and review workshops which are and from the SEDAR programs not incorporated into the councils decisions on a "less cautionary or overly conservative" approach?
SEDAR 10 biologists recommended changing the MSST, SSB, M, F, MFMT and alike, in one form or another due to "overly conservative" concerns.
MSST, currently defined by the South Atlantic Council as (1-M)BMSY, is very close to BMSY because age-averaged natural mortality rate, M, is estimated as 0.14. It was recommended to change the M and wasn't done. It was stated that "the stock is not overfished and is not projected to become overfished."
Given the uncertainties in the assessment, the biomass would be expected or could possibly, fall below MSST with a relatively high frequency even if the true biomass were close to BMSY. In Sedar 10 the Review Workshop stated that the current definition of MSST may be overly conservative and recommends an operational definition of MSST of 5 million pounds. Yet it is still the factor of 6.8 million pounds was used.
The MFMT factor is also showing signs of being overly conservative. Why the council feels the need to error on EXTREME caution I don't understand.
Then Natural Mortality Rate formula was calculated using the Hoenig 1983 program. A program which has flaws due to the fact that the estimate of maximum age required by Hoenig's method assumes that the age determination technique being employed is unbiased. Validating this assumption is often difficult for the older, more difficult-to-age individuals but can be accomplished by using a variety of techniques ranging from marking to analysis of radioactive isotopes (Lai et al., 1996). The estimate of longevity is also dependent on sample size and previous fishing history, which by the way we don't have sound, accurate data on according to the councils own admission. Hoenig (1983) showed that maximum age tends to increase slowly with increasing sample size but longevity has probably declined from historical levels because of fishing. A small sample size for age determination, underaging, and previous exploitation would all result in an overestimate of M with Hoenig's method. Although compared to other methods, we still have an issue with accurate data and excessively cautionary management. Maybe we don't increase the Annual Catch Limits (ACLs) as aggressively using such precautionary regulation. The 2004 stock assessment model projections show the stock becoming overfished in 2007.
Greg Waugh states on 5/8/2008 that "the stock isn't overfished due to present reduction fishing pressure, attributed to several factors such as fuel costs." He also cited that "the assessment wouldn't be redone due to funding and scheduling issues and would be revisited in 2011."
It is an natural assumption with the current economic situation and petroleum driven influence on our daily lives that there has been a significant decline in fishing pressure on all fishing stocks yet the council seem reluctant to revisit the issue since they already have time and effort invested into them and have decided to "stick" to their original conclusions.
Maybe we use data more current than 2004 and realize that the 37% reduction that you are calling for has already in part been addressed due to the cost of fuel and expenses that are incurred for offshore fishing. The Magnuson Stevens Act states that the new regulations need to implemented by 2010. That gives the council plenty of time to do a stock review with less conservative numbers as recommended in the SEDAR 10 program.
Maybe the council shouldn't use such a precautionary approach to regulation on data that they admit isn't as accurate or current to date as it should be.
I believe that if current, data were used along with the above mentioned conservative factors corrected, the councils need for new legislation may not be necessary after all.
How about in the alternatives offer for the public to pick from the economic impact for the entire S. Atlantic recreational impact with a 4 month closure will only attribute to a total of $ 1,032,000. An example is the entire state of NC will only have an impact of $ 37,000. That is ridiculous. That equates to 37 trips at a charter price of $ 1,000. The impact is for the "for hire" sector which is lumped in with the recreational sector as a whole. There is no account for the true recreational sector such as recreational food, fuel, hotel, shopping, tackle, boat maintenance etc. For a 4 month NC closure, $ 37,000, REALLY?
We would like to see the gag assessment redone. There are too many uncertainties and inconsistencies to move forward with an assessment that will affect such a large fishery.
- The Gulf of Mexico Grouper assessment has been reviewed due to some of the same questions. There were many corrections and this was done in less than 6 month time frame.
Fishing effort is significantly reduced and is not taken into account when calculating future estimates as it should be.
Economic impact and true fishing pressure of both recreational and commercial fishing is grossly inaccurate.
If after a review it is necessary to reduce harvest, only modest bag limit decreases or modest size limit increases should be considered acceptable if in fact a problem exists.
I am sure that the Council want to make sound decisions. The economic and social devastation wrought by these proposed Gag regulations comes at a time when effort is significantly declining (I feel permanently) due to exorbitant fuel prices. These current proposals are based on overly precautionary thresholds which compound to create the false sense of an unhealthy fishery, when in fact the fishery could be quite healthy.
Is it any wonder that the individuals that you are governing are not satisfied with the proposed solutions when they seem to have a better handle on the fish stock, behavioral patterns, abundance and realistic solutions and are not heard by you?
I urge the Council to:
1. Review the Natural Mortality Rate of Gag 2. Review and adjust the overly precautionary estimates 3. Provide the numbers for and consider as an alternative a 26” Gag minium size limit (20% or more reduction in rec landings alone) as the FIRST tool applied to the fishery. 4. Invite Dr. Trevor Kenchington to the SSC and Council meeting in June. Dr. Kenchington has extensive knowledge of both the Gulf of Mexico and the South Atlantic fisheries and could prove an excellent resource in the interpretation of current data parameters.
Thank you for your time and the opportunity to voice my concerns.
Best Regards,
Craig Andrews Southport, NC
From: Dennis Foster 4205 Twin Palm Lane Melbourne, FL 32904 ph: 321-674-2138 email [email protected]
I would like to submit the following commits on the Snapper Grouper Amendment 16 to go on record before the SAFMC Council.
1. I encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. By the Council’s own estimate, this fishery is currently not over fished. I believe that the current regulations are doing a great job of maintaining the health of this fishery, and the SAMFC’s preferred alternatives would have a severe negative impact on the benefits this fishery provides economically to the coastal communities.
2. I am against alternative 2 (Spawning season closure January through April) seeing how there is no reliable data on recreational landings on which to base this closures benefit. I would highly suggest an alternative closure of all commercial harvest by spear fishing during the months of June, July and August. This would protect the fishery during the coldwater up-welling, when the fish become very lethargic and overly vulnerable to this harvest method.
3. I encourage the SAFMC to adopt Alternative 3 (Directed Commercial Quota)
4. I encourage the SAFMC to adopt Alternative 4 (Divide Directed Commercial Quota into 2 regions). I would support the recreational sector within Florida as also being divided into a separate management area.
5. I am against Alternative 5a (Reduce the bag limit from 5 to 3 grouper and January-April season closure). I believe this places additional undo restrictions on the recreational and charter/head boat fleet, without similar reductions in the commercial landings quota. Again I would recommend you look at the commercial harvest by spear fishing during the months of June, July and August during the cold water upwelling periods.
6. I am against Alternative 5b (December - April closed season, retain the current bag limits).
7. I encourage the SAFMC to adopt the alternatives to reduce by-catch mortality by requiring the use of venting/de-hooking tools and circle hooks. However to help gain public support and ensure compliance with these new measures, I would suggest simply requiring “circle hooks” and not defining their exact material or geometric make up at this time..
Sincerely,
Dennis Foster
Hi to all Managers of the Oceans, I have been fishing the east coast of Florida since 1994. I am a snow bird who each year travels from NY to Florida for the months of January, February, March and April. I fish on a head boat three times a week during this time period and my main targeted species are Snapper and Grouper. While I can understand there may be a need to limit the harvest I disagree with penalizing the recreational fishermen. This season on the Captian Lew out of Fort Pierce, Florida I made 20 trips out of 40 scheduled due to cancelations due to weather. On these twenty trips I managed to catch 12 mangrove snappers from 3 to 10 pounds. There may have been some groupers hooked but 40 pound test on rocky bottom will rarely hold these girls. For this winter season I saw around 15 groupers caught, 13 of which were release as short. When I think back to the late 90’s I can remember catching 1 or 2 grouper and 4 or 5 snapper per trip myself. I only keep what I can eat and return the rest to the ocean. While my yearly trips to Florida help the local economy, they will become un-necessary should you close grouper and snapper for the winter months. Perhaps closing grouper and snapper to the commercial fishermen only during those months might be a better solution. The commercial guys can always go catch other stuff and sell it. This would allow the local economy to benefit from the cash flow of the snow birds recreational fishing.
How about Amendment George: 1. Commercial: Close Snapper and Grouper to the Commercial Fishermen during January, February, March and April. 2. Commercial: Reduce the tonnage 33% in proportion to the time line for commercial for the rest of the year. (Why allow them to take the same amount of fish at a different time?) 3. Recreational: Year round reduce the Bag Limit on Grouper to 1 per day per person, 24” inches of course. 4. Recreational: Year round reduce the Bag Limit on Snapper to 4 per person per day, stay at 12” inches or even go up to 16”. 5. Forget the circle hooks, they will only allow the amateurs to actually catch a mature mangrove snapper. 6. Stricter penalties for Commercial Boats fishing the closed areas, this could help fund Line 7. 7. Introduce a fishery system similar to that on the Gulf Coast, yeah restock instead of restrict.
Under Amendment George, everybody gives a little, no one side is deprived, recovery time may be quicker then you think.
Sincerely, George Church
Dr. Regional. National
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2008 part or by for via Joshua Giordano-Silliman 5/16/08 1170 N Shadow Dr Mt Pleasant, SC 29464 Written Comments for Public Scoping, Snapper-Grouper Amendment 16, Amendment 18 (Red Snapper) To The Snapper Grouper FMP.
Attn: South Atlantic Fisheries Management Council, NOAA, Dept of Commerce
To whom it may concern,
I do believe that we are facing tough challenges with our fisheries management. It is of the responsibility of all parties affected to work together to ensure the future of fishery. There are too many examples within the world of what long term damage that can be placed on a fishery. As an American citizen, I accept my responsibility to properly manage, conserve, and preserve our beautiful natural resources for future generations. It is my intent to help with all governmental, commercial, recreational, and conservation agencies and individuals to protect our resources for the wealth of our nation.
Several of the proposals in the mentioned amendments do conflict with an individual’s inalienable rights of life, liberty, and the pursuit of happiness. Some of the proposals directly conflict the Standards of the Magnuson-Stevens Act. One of my objectives is to show were these flaws exist and provide input for correction. The comments are organized by chronological order of amendments and are as follows.
Snapper Grouper Amendment 16: Gag Grouper: The recommendation of the restriction in harvest to Foy to equal 75% maximum sustain yield is a great one. It would seem to allow for 25% of MSY to remain each year to build back stock. The TAC of 694,000 lbs of gutted weight doesn’t seem to be optimal as I would think for the demand for grouper recreational or commercial. Current assessment data may or may not provide enough information to make TAC statistics real. It is understood that this may be the best science available for TAC statistics, but it is not complete science. Recreational catch and by-catch numbers do not exist on a large scale. The lack of proper documentation by individual recreational is a direct conflict. It is possible the TAC should be lower to implement the Standards of the Magnuson-Stevens Acts because of the lack of recreational data over the years. A federalized input system of catch and by-catch recording needs to be put in place to help procure more data. Of the Interim Gag Allocation Alternatives and Resulting Commercial and Recreational Allocations, I support an alternative that is not mention, Alternative 5 JSGS. Alternative 5 JSGS would comprise 50% recreational, 30% commercial, and 20% for hire (commercial) allocations. It is my hypothesis that the recreational angler cannot fulfill the 50% quote, but only 30%. The other 20% remaining would help build stock. The 30% commercial should be easy to obtain. The 20% for hire (commercial) is attainable and would legitimize the selling of bag limit fish. It would not take from the recreational allocation on the basis the individual has chosen to exchange their harvest for monetary payment. The individual has chosen to attain the harvest in a recreational manner, yet does not seek to consume the harvest. This alternative would increase the value for the services for commercial and for hire fishing, provide the demanded fish to market, and end overfishing without interfering with an individual’s recreational fishing. Of the Management Alternatives for Gag I support Alternative 1 with minor changes, and Alternative 6 JSGS (not mention). I do not believe assessment data of stock is accurate. The minor changes to Alternative 1 would be a trip-limit restriction of tonnage for commercial with no size limit to reduce discard mortality. Allow the commercial fishing to go do their jobs, return and report, and then release to return to work. It would be argued that is unfair to allow commercial fishing keep any size and not the recreational or for hire. In developing a sustainable management program, it would reduce wasteful mortality and successfully provide the demanded resource. Alternative 6 JSGS would directly improve the management of the fishery, increase the stock, and provide new data on the capability of recovery of the fishery. Alternative 6 outlines short term closures for all mention shallow water grouper species (gag grouper, black grouper, warsaw grouper, red grouper, scamp, red hind, rock hind, yellowmouth grouper, tiger grouper, yellow fin grouper, graysby and coney). The short term closures would be approximately five year closure to possession of specific species within the closure block. The alternative outlines Block A closures would include Gag, Black, Warsaw and groupers, starting January 1, 2009. Block B closures would begin January 1 2016 and include Scamp, Rock Hind, Red Hind, Yellowmouth and Yellow Fin groupers. Block C closures would begin January 1 2021 and include Red,tigers, graysby, and coney groupers. Once closure has past, current recreational limits from 2007 go back into effect with improved catch and by catch data resources. The five year cycles represent the time allowed for a protected generation to be born and allowed to mature and reproduce with little fishing pressure. The alternative 5a and 5b directly conflict with the 10th standard of Magnuson-Stevens Act of promoting safety at sea. December to April is great months to go fishing for said species out of Charleston S.C. The ocean is calm and there are not threats of afternoon thunderstorms. People fishing from Charleston S.C. at times have to venture out past twenty nautical miles for adequate fishing. It is uncontrollable climatic conditions and seasons of the ocean that require such a travel, not overfishing. If I was asked when I wanted to take someone to go fish from Charleston for grouper, my response is December to April because of the weather. These alternatives are great for helping rebuilding stock, but pose the risk of removing safety. I would amend the alternatives. Allow one legal harvest during January to April of said species that corresponding to a federal harvest tag. This will improve recreational data during the spawn months. Prohibit the sale of bag limit from December to April. Reduce grouper bag limit to 3, allow for 2 of any one species. A full bag limit would have to be from two different species. Vermillion Snapper: A final rule was passed in 2006 to end overfishing of black sea bass and vermillion snapper. I believe that final rule has worked. I can go and catch limits of said species with low discard for undersized fish. I support a 50% recreation 30% commercial and 20% for hire allocation of TAC for vermillion snapper. Commercial fisherman needs the freedom from size limit to attain a trip limit to reduce by catch and discard mortality. I further support the Alternative 3c in directed commercial quota season. Of the Alternative 4, I do accept an increase in the recreational size of 14 inches. From my personal experience, I am in compliance as of now. I do accept the reduction of the bag to 5 fish and not 4. Simplification of the regulation needs to happen; it just needs to be reduced by half. It is simpler to follow, and I believe that the vermillion stock is not in danger. Reduce Bycatch of Snapper Grouper Species: The some of the proposals in Alternative 2 are good. Why has it taken this long to from such a plan? My father worked on a for hire headboat in the early 1980’s. They all knew about venting then, some of them would practice it. Why hasn’t something been done in past? We could have been lowering discard mortality for the last twenty years. The proposal of circle hooks is pointless from a natural point of view. When a fish decides his is going to eat, he just inhales. Fish, especially groupers, essentially by pass their mouths and try to direct the food straight into the stomachs. Hence, gut hooked fish, be it a J or circle hook the hook doesn’t change the fish’s eating habits. If some of the reasoning for circle hooks is based on stats of less discard mortality. I would believe it is based on long lining stats and an individual not getting a good hook set, hence the fish swam away. Through my research I have yet to come across a report on recreational fishing with circle hooks and stats. There isn’t one on a large or consistent scale. Allow NMFS Regional Adminstrator (RA) to Make Adjustments to Mangement Measures after pending Vermillion Snapper SEDAR Assessment: I support Alternative 1. The alternative 2 is a clear waste of resources of time and money. The suggestion of Alternative 2 nullifies all energy placed into develop of a sustainable fisheries plan, including all other proposals presented by SAMFC in regard to vermillion snapper. Vermillion snapper is not in danger, yet individual waste of the government resources is abundant by openly talking in good faith to citizens about management and alternatives with the intent of only changing things without the public input. Vermillion snapper should not be discussed until after the assessment is completed. Currently, there is an ongoing stock assessment of vermillion and we don’t have the best science available until after the stock assessment is complete. Instead of violating the second standard of the Magnuson-Stevens Act all ruling should wait until the assessment is complete.
Amendment 18 (Red Snapper) To The Snapper Grouper FMP: The need to reduce fishing mortality is essential to the long term sustainability of Red Snapper. Through my personal experience, I can go and attain the bag limit of Red Snapper today. It would be acceptable to reduce the bag limit to 1 per person per trip. It would be unacceptable to prohibit Red Snapper period. If a closure is so drastically need, then a closure of the commercial sector is warranted. The commercial sector produces more pressure on all species. It is not true that the recreational angler out produces commercial 2-3 fold. The data that stipulates recreational over commercial in productivity is wrong. Commercial deep trawl netting of the seventies and early eighties did more damage to the stock than any other form of harvesting. A single Red Snapper per person is acceptable; individuals have the right to harvest seafood as granted from heavenly powers. Individuals have rights to provide their harvest to the well being of themselves and those who they chose to share with. Individuals have the right to go safely attain their harvest; enjoy their fellowship of one another, and to properly manage the resources for future generations. I am not the only person who believes they are entitled by a heavenly power to do so. I am also not the only person who enjoys eating fresh Red Snapper. The information and organization of the FMP is good, but points out some major stumbling blocks in management. Overfishing has occurred since 1960, the Magnuson-Stevens Act passed 1976, and today we are beginning to start lower discard mortality rates by requiring venting and de-hooking tools. In conclusion: There are many more alternatives that need to be discussed. Fairness to fisheries management is essential. Proposals of alternatives need a design that surpasses individual appointments, congressional terms, and presidential terms. SAMFC, NOAA, and The Department of Commerce need to develop programs of outreach of recreational data, general public awareness, and long term plans and goals. Many people believe that some of the alternatives are proposed to stop bottom fishing period. I know of people associated with conservational lobbies who say that is exactly the goal of these current reductions. That individual’s lobby has done nothing for the individual person in the protection of their fishing rights. No agency or individuals in the nation is going to stop people from bottom fishing. If they believe can and it is the right thing to do. I would personally arrest them and charge them with treason, for being an enemy of the state, and wanting to violate civil rights of citizens. The future will be much brighter for all without the treasonous criminals. I am open to future comments and questions. I would like to thank all parties involved (SAMFC, NOAA, and Dept of Commerce) for accepting my written comments.
Signed, Joshua Giordano-Silliman [email protected]
Grouper Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFCs own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely by-catch mortality and habitat destruction from trawling and long line activities. I believe that NO CHANGES are required at this time, and the SAMFCs preferred alternatives would have a drastic economic impact.
I am against alternative 2 (Establish a gag spawning season closure January through April...) in that there is no reliable data on recreational landings to support this position. This alternative places a greater burden on the recreational sector. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I support Alternative 3 (Directed Commercial Quota)
I support Alternative 4 (Divide Directed Commercial Quota into 2 regions). In addition, I support the regional management of the recreational sector with Florida being a separate management area
In reference to Alternative 5. Recreational measures:
I am against Alternative 5a (Reduce the 5-grouper aggregate bag limit to a 3- grouper...January-April fishery closure). This alternative places an unfair burden on the recreational sector without a comparable reduction to the commercial landings. I am against alternative 5 in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I am against Alternative 5b (December - April closed season, retain current bag limits...). I am against alternative 5b in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Amendment 16 also includes alternatives to reduce by-catch mortality by requiring the use of venting/dehooking tools and circle hooks. I agree with this as it reduces mortality and aid in the recovery of the stocks.
Vermilion Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The spikes in this fishery have been caused by the SAMFC shifting pressure from the Sea Bass fishery which in turn has concentrated pressure on the Vermilion fishery. In addition, the explosion of the Goliath Grouper populations is putting increased pressure on this fishery. I would suggest a limited take/season on the Goliath Grouper fishery.
I am against Alternative 2 (Interim Allocations). I would suggest that SAMFC increase data collection on both the fishery health and fishery utilization before enacting any changes. In addition, a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Sincerely, Juliann G. Orvis I whole heartily support any move that retains the rights of recreation fishermen to continue enjoy the thrill of fishing for grouper. In 1948 our family moved to Florida because my father was a diehard outdoorsman. I do not want in any way to harm the rights to these fishermen and women have enjoyed for decades to be hampered by business or special interests leaning toward the needs of commercial fisheries.
Dear S. Atlantic Council Members,
First, I would like to state that the purpose of my comments are just to address concerns that we have with the data used for decisions on the management of the fisheries in our region. It seems that for too long the subject of the proposed "problem" isn't always defined prior to a "solution" being derived. Public meeting inputs have the attitude that the decision has already been made. As a fishermen, I would be more than happy to supply data as would many of the fishermen I know, if you would educate us on what you need for information and assistance.
Just finding out about these meetings is hard enough, try getting on the SAFMC website and finding SEDAR 10 REPORT or Magnuson Stevens Scoping document and reading the entire thing along with understanding it is another issue altogether.
Too long have fisherman been pitted against each other, both commercial and recreational, in an attempt to, in my opinion, redirect focus on the issue at hand. Any form of accountability on the council's part for the decisions made on our behalf as fisherman, doesn't seem to exist. Decisions are made that do not seem to have both the fish stock and fisherman's best interest at heart. Politics appear to also be playing a huge role in the decisions made on our behalf and do at times, seem detrimental to the cause.
The council's actions are speedy mechanisms to put increased restrictions on a fishery, yet there are no such speedy mechanisms to decrease restrictions should any fishery’s biomass indeed increase to healthier levels, or have new data to contradict the imposing limits. We hear how it needs to produce results over a long time period such as 10 years to be accurate. Please don't site here how we can now catch more porgy. That is a sad example on the council's part at best. Historically, regulations don't give back but become more conservative in restrictions.
These viewpoints are directed towards Amendment 16 yet hold true of all others that are being reviewed at present.
As I have read extensive amounts of information including SEDAR 10 along with information from the SAFMC, etc. I have a couple of points that I would like to bring up.
From the SAMFC website and I quote
Lack of basic management data on many of the species still remains the major obstacle to successful management. MRFSS surveys have been proven unreliable. What changes in the last 10 years have been changed to upgrade the survey system? MRFSS is usually a year or two behind in estimating this trend, so my main concerns are about over-regulation that may not be warranted. MARMAP surveys on "random hard bottoms" are the basis of most surveys done. We are talking about reef fish, fish that look for live bottom and structure to make their home. Data collections from things like "Chevron traps" were inconclusive due to such low catch rates and classified as "indeterminable and inaccurate" after 27 years yet older data is still used to calculate present trends. Why are things like wave heights, sea surface temps, surface currents, hurricane impacts, DO, salinity, wind speed, wind direction, etc not included in present studies? Why are issues like water quality and pollution along with protecting our juvenile fish using our estuaries for growth not addressed or protected? We can pay a hog farmer or tobacco farmer not to raise their crop yet we don't address the shrimping bycatch that is drastically affecting our fish stock? Please don't tell me how great the "bycatch" gear is doing in the shrimping industry, the bycatch being shoveled overboard looks like a snow storm floating on the water coming from a shrimper. I understand they have to make a living, however, subsidizes their income for the percentage necessary and stop letting them trawl on the inside and watch how well our fisheries rebound. I am concerned on how "overly conservative" the council seems to be in their calculations and proposed regulations. Below are some of the areas that if corrected to more realistic parameters, would take us out of the "overfishing" category that the grouper and snapper species are presently assessed as.
I am concerned that F (fishing mortality; the percentage of the population that dies each year from fishing) is overstated partly because it is based on
1. Marine Recreational Fishing Statistical Survey (MRFSS) estimates of landings and discards, which have been declared unreliable and even ‘fatally flawed’ and
2. An overstated recreational release mortality of 25%.
Recreational fisheries Release mortality is presently assumed to be 25%, SEDAR 10 workshop stated Improved estimates of post-release mortality were obtained through tag release and caging methods (Burns et al. 2002; Overton and Zabawski 2003; McGovern et al.2005). Using these methods, mean mortality rates were estimated to be 21.2% (Overton and Zabawski 2003), 23% over a variety of depths (McGovern et al. 2005). Commercial fisheries Release mortality is presently assumed to be 40%. Your reasoning behind the proposed legislation is that the FMSY is below the F (Fish Mortality) factor, the FMSY has remained below the F (Fish Mortality) factor since 1983 in the S. Atlantic. With the council willing to error on the side of "conservative numbers and factors" is it any wonder this is the trend? Now take a look at our stocks. Have we decimated our biomass? No. Clearly real world numbers aren't being used to guage accurate regulation.
How can the Magnuson Stevens Act expect you to make changes within 1 year of notification if the council states that it takes 3-8 years to schedule and complete a stock assessment? For that matter, why, if notified that a stock is in "trouble", aren't the data compiled between the last stock assessment and the present date of the notifications, reviewed to determine if an issue really exists at the present notification time period prior to taking action?
According to your own data workshops, spawning stock biomass increased after 1999 corresponding to implementation of the 24 inch minimum size limit. Fishing mortality has been decreasing since 1992 yet the gag grouper lifespan has just been raised to 26 yrs to 30 years. The life expectancy factor has been raised recently which is also affecting the formula into an "overfishing" status.
50% of maturity is 3 years and 25.5 inches. Why don't we increase the minimum size limit to 26". It has proven effective for the size increase in 1999 to 24".
Fishing mortality in 2004 was estimated as 0.31, extremely conservative against 2007 projected mortality.
Why is the fishing mortality rate for 2007 not being used? Obviously the fishing pressure has reduced since 2004 yet the OPPORTUNITY to fish hasn't been reduced which I think is very important and not usually taken into account when new regulations are proposed.
The council can redo the entire Vermillion Snapper stock assessment due to concerns of accuracy and possible "gross negligence" of the last assessment with updated data, yet I am told by the council that the 2004 data used in SEDAR 10 for grouper won't be updated until 2011? Are you kidding me? With the impact that fuel has alone on the frequency of fishing trips which has been declining since 2004, why can we not use current data and revisit the workshop to determine if the present proposed measures are necessary?
How can there be underfunding on the federal or local level to interpret the data that is taken every year but not incorporated or used due to lack of resources and man power as stated by the council with 3-8 years between stock assessments?
Why are the conclusions and recommendations from the data and review workshops which are and from the SEDAR programs not incorporated into the councils decisions on a "less cautionary or overly conservative" approach?
SEDAR 10 biologists recommended changing the MSST, SSB, M, F, MFMT and alike, in one form or another due to "overly conservative" concerns.
MSST, currently defined by the South Atlantic Council as (1-M)BMSY, is very close to BMSY because age-averaged natural mortality rate, M, is estimated as 0.14. It was recommended to change the M and wasn't done. It was stated that "the stock is not overfished and is not projected to become overfished."
Given the uncertainties in the assessment, the biomass would be expected or could possibly, fall below MSST with a relatively high frequency even if the true biomass were close to BMSY. In Sedar 10 the Review Workshop stated that the current definition of MSST may be overly conservative and recommends an operational definition of MSST of 5 million pounds. Yet it is still the factor of 6.8 million pounds was used.
The MFMT factor is also showing signs of being overly conservative. Why the council feels the need to error on EXTREME caution I don't understand.
Then Natural Mortality Rate formula was calculated using the Hoenig 1983 program. A program which has flaws due to the fact that the estimate of maximum age required by Hoenig's method assumes that the age determination technique being employed is unbiased. Validating this assumption is often difficult for the older, more difficult-to-age individuals but can be accomplished by using a variety of techniques ranging from marking to analysis of radioactive isotopes (Lai et al., 1996). The estimate of longevity is also dependent on sample size and previous fishing history, which by the way we don't have sound, accurate data on according to the councils own admission. Hoenig (1983) showed that maximum age tends to increase slowly with increasing sample size but longevity has probably declined from historical levels because of fishing. A small sample size for age determination, underaging, and previous exploitation would all result in an overestimate of M with Hoenig's method. Although compared to other methods, we still have an issue with accurate data and excessively cautionary management. Maybe we don't increase the Annual Catch Limits (ACLs) as aggressively using such precautionary regulation. The 2004 stock assessment model projections show the stock becoming overfished in 2007.
Greg Waugh states on 5/8/2008 that "the stock isn't overfished due to present reduction fishing pressure, attributed to several factors such as fuel costs." He also cited that "the assessment wouldn't be redone due to funding and scheduling issues and would be revisited in 2011."
It is an natural assumption with the current economic situation and petroleum driven influence on our daily lives that there has been a significant decline in fishing pressure on all fishing stocks yet the council seem reluctant to revisit the issue since they already have time and effort invested into them and have decided to "stick" to their original conclusions.
Maybe we use data more current than 2004 and realize that the 37% reduction that you are calling for has already in part been addressed due to the cost of fuel and expenses that are incurred for offshore fishing. The Magnuson Stevens Act states that the new regulations need to implemented by 2010. That gives the council plenty of time to do a stock review with less conservative numbers as recommended in the SEDAR 10 program.
Maybe the council shouldn't use such a precautionary approach to regulation on data that they admit isn't as accurate or current to date as it should be.
I believe that if current, data were used along with the above mentioned conservative factors corrected, the councils need for new legislation may not be necessary after all.
How about in the alternatives offer for the public to pick from the economic impact for the entire S. Atlantic recreational impact with a 4 month closure will only attribute to a total of $ 1,032,000. An example is the entire state of NC will only have an impact of $ 37,000. That is ridiculous. That equates to 37 trips at a charter price of $ 1,000. The impact is for the "for hire" sector which is lumped in with the recreational sector as a whole. There is no account for the true recreational sector such as recreational food, fuel, hotel, shopping, tackle, boat maintenance etc. For a 4 month NC closure, $ 37,000, REALLY?
We would like to see the gag assessment redone. There are too many uncertainties and inconsistencies to move forward with an assessment that will affect such a large fishery.
- The Gulf of Mexico Grouper assessment has been reviewed due to some of the same questions. There were many corrections and this was done in less than 6 month time frame.
Fishing effort is significantly reduced and is not taken into account when calculating future estimates as it should be.
Economic impact and true fishing pressure of both recreational and commercial fishing is grossly inaccurate.
If after a review it is necessary to reduce harvest, only modest bag limit decreases or modest size limit increases should be considered acceptable if in fact a problem exists.
I am sure that the Council want to make sound decisions. The economic and social devastation wrought by these proposed Gag regulations comes at a time when effort is significantly declining (I feel permanently) due to exorbitant fuel prices. These current proposals are based on overly precautionary thresholds which compound to create the false sense of an unhealthy fishery, when in fact the fishery could be quite healthy.
Is it any wonder that the individuals that you are governing are not satisfied with the proposed solutions when they seem to have a better handle on the fish stock, behavioral patterns, abundance and realistic solutions and are not heard by you?
I urge the Council to:
1. Review the Natural Mortality Rate of Gag 2. Review and adjust the overly precautionary estimates 3. Provide the numbers for and consider as an alternative a 26” Gag minium size limit (20% or more reduction in rec landings alone) as the FIRST tool applied to the fishery. 4. Invite Dr. Trevor Kenchington to the SSC and Council meeting in June. Dr. Kenchington has extensive knowledge of both the Gulf of Mexico and the South Atlantic fisheries and could prove an excellent resource in the interpretation of current data parameters.
Thank you for your time and the opportunity to voice my concerns.
Best Regards,
Sending my comments about the proposed reductions.
Thank you
Dear S. Atlantic Council Members, First, I would like to state that the purpose of my comments are just to address concerns that we have with the data used for decisions on the management of the fisheries in our region. It seems that for too long the subject of the proposed "problem" isn't always defined prior to a "solution" being derived. Public meeting inputs have the attitude that the decision has already been made. As a fishermen, I would be more than happy to supply data as would many of the fishermen I know, if you would educate us on what you need for information and assistance. Just finding out about these meetings is hard enough, try getting on the SAFMC website and finding SEDAR 10 REPORT or Magnuson Stevens Scoping document and reading the entire thing along with understanding it is another issue altogether. Too long have fisherman been pitted against each other, both commercial and recreational, in an attempt to, in my opinion, redirect focus on the issue at hand. Any form of accountability on the council's part for the decisions made on our behalf as fisherman, doesn't seem to exist. Decisions are made that do not seem to have both the fish stock and fisherman's best interest at heart. Politics appear to also be playing a huge role in the decisions made on our behalf and do at times, seem detrimental to the cause. The council's actions are speedy mechanisms to put increased restrictions on a fishery, yet there are no such speedy mechanisms to decrease restrictions should any fishery’s biomass indeed increase to healthier levels, or have new data to contradict the imposing limits. We hear how it needs to produce results over a long time period such as 10 years to be accurate. Please don't site here how we can now catch more porgy. That is a sad example on the council's part at best. Historically, regulations don't give back but become more conservative in restrictions. These viewpoints are directed towards Amendment 16 yet hold true of all others that are being reviewed at present. As I have read extensive amounts of information including SEDAR 10 along with information from the SAFMC, etc. I have a couple of points that I would like to bring up. From the SAMFC website and I quote
Lack of basic management data on many of the species still remains the major obstacle to successful management. MRFSS surveys have been proven unreliable. What changes in the last 10 years have been changed to upgrade the survey system? MRFSS is usually a year or two behind in estimating this trend, so my main concerns are about over- regulation that may not be warranted. MARMAP surveys on "random hard bottoms" are the basis of most surveys done. We are talking about reef fish, fish that look for live bottom and structure to make their home. Data collections from things like "Chevron traps" were inconclusive due to such low catch rates and classified as "indeterminable and inaccurate" after 27 years yet older data is still used to calculate present trends. Why are things like wave heights, sea surface temps, surface currents, hurricane impacts, DO, salinity, wind speed, wind direction, etc not included in present studies? Why are issues like water quality and pollution along with protecting our juvenile fish using our estuaries for growth not addressed or protected? We can pay a hog farmer or tobacco farmer not to raise their crop yet we don't address the shrimping bycatch that is drastically affecting our fish stock? Please don't tell me how great the "bycatch" gear is doing in the shrimping industry, the bycatch being shoveled overboard looks like a snow storm floating on the water coming from a shrimper. I understand they have to make a living, however, subsidizes their income for the percentage necessary and stop letting them trawl on the inside and watch how well our fisheries rebound. I am concerned on how "overly conservative" the council seems to be in their calculations and proposed regulations. Below are some of the areas that if corrected to more realistic parameters, would take us out of the "overfishing" category that the grouper and snapper species are presently assessed as. I am concerned that F (fishing mortality; the percentage of the population that dies each year from fishing) is overstated partly because it is based on 1. Marine Recreational Fishing Statistical Survey (MRFSS) estimates of landings and discards, which have been declared unreliable and even ‘fatally flawed’ and 2. An overstated recreational release mortality of 25%. Recreational fisheries Release mortality is presently assumed to be 25%, SEDAR 10 workshop stated Improved estimates of post-release mortality were obtained through tag release and caging methods (Burns et al. 2002; Overton and Zabawski 2003; McGovern et al.2005). Using these methods, mean mortality rates were estimated to be 21.2% (Overton and Zabawski 2003), 23% over a variety of depths (McGovern et al. 2005). Commercial fisheries Release mortality is presently assumed to be 40%. Your reasoning behind the proposed legislation is that the FMSY is below the F (Fish Mortality) factor, the FMSY has remained below the F (Fish Mortality) factor since 1983 in the S. Atlantic. With the council willing to error on the side of "conservative numbers and factors" is it any wonder this is the trend? Now take a look at our stocks. Have we decimated our biomass? No. Clearly real world numbers aren't being used to guage accurate regulation. How can the Magnuson Stevens Act expect you to make changes within 1 year of notification if the council states that it takes 3-8 years to schedule and complete a stock assessment? For that matter, why, if notified that a stock is in "trouble", aren't the data compiled between the last stock assessment and the present date of the notifications, reviewed to determine if an issue really exists at the present notification time period prior to taking action? According to your own data workshops, spawning stock biomass increased after 1999 corresponding to implementation of the 24 inch minimum size limit. Fishing mortality has been decreasing since 1992 yet the gag grouper lifespan has just been raised to 26 yrs to 30 years. The life expectancy factor has been raised recently which is also affecting the formula into an "overfishing" status. 50% of maturity is 3 years and 25.5 inches. Why don't we increase the minimum size limit to 26". It has proven effective for the size increase in 1999 to 24". Fishing mortality in 2004 was estimated as 0.31, extremely conservative against 2007 projected mortality. Why is the fishing mortality rate for 2007 not being used? Obviously the fishing pressure has reduced since 2004 yet the OPPORTUNITY to fish hasn't been reduced which I think is very important and not usually taken into account when new regulations are proposed. The council can redo the entire Vermillion Snapper stock assessment due to concerns of accuracy and possible "gross negligence" of the last assessment with updated data, yet I am told by the council that the 2004 data used in SEDAR 10 for grouper won't be updated until 2011? Are you kidding me? With the impact that fuel has alone on the frequency of fishing trips which has been declining since 2004, why can we not use current data and revisit the workshop to determine if the present proposed measures are necessary? How can there be underfunding on the federal or local level to interpret the data that is taken every year but not incorporated or used due to lack of resources and man power as stated by the council with 3-8 years between stock assessments? Why are the conclusions and recommendations from the data and review workshops which are and from the SEDAR programs not incorporated into the councils decisions on a "less cautionary or overly conservative" approach? SEDAR 10 biologists recommended changing the MSST, SSB, M, F, MFMT and alike, in one form or another due to "overly conservative" concerns. MSST, currently defined by the South Atlantic Council as (1-M)BMSY, is very close to BMSY because age-averaged natural mortality rate, M, is estimated as 0.14. It was recommended to change the M and wasn't done. It was stated that "the stock is not overfished and is not projected to become overfished." Given the uncertainties in the assessment, the biomass would be expected or could possibly, fall below MSST with a relatively high frequency even if the true biomass were close to BMSY. In Sedar 10 the Review Workshop stated that the current definition of MSST may be overly conservative and recommends an operational definition of MSST of 5 million pounds. Yet it is still the factor of 6.8 million pounds was used. The MFMT factor is also showing signs of being overly conservative. Why the council feels the need to error on EXTREME caution I don't understand.
Then Natural Mortality Rate formula was calculated using the Hoenig 1983 program. A program which has flaws due to the fact that the estimate of maximum age required by Hoenig's method assumes that the age determination technique being employed is unbiased. Validating this assumption is often difficult for the older, more difficult-to-age individuals but can be accomplished by using a variety of techniques ranging from marking to analysis of radioactive isotopes (Lai et al., 1996). The estimate of longevity is also dependent on sample size and previous fishing history, which by the way we don't have sound, accurate data on according to the councils own admission. Hoenig (1983) showed that maximum age tends to increase slowly with increasing sample size but longevity has probably declined from historical levels because of fishing. A small sample size for age determination, underaging, and previous exploitation would all result in an overestimate of M with Hoenig's method. Although compared to other methods, we still have an issue with accurate data and excessively cautionary management. Maybe we don't increase the Annual Catch Limits (ACLs) as aggressively using such precautionary regulation. The 2004 stock assessment model projections show the stock becoming overfished in 2007. Greg Waugh states on 5/8/2008 that "the stock isn't overfished due to present reduction fishing pressure, attributed to several factors such as fuel costs." He also cited that "the assessment wouldn't be redone due to funding and scheduling issues and would be revisited in 2011." It is an natural assumption with the current economic situation and petroleum driven influence on our daily lives that there has been a significant decline in fishing pressure on all fishing stocks yet the council seem reluctant to revisit the issue since they already have time and effort invested into them and have decided to "stick" to their original conclusions. Maybe we use data more current than 2004 and realize that the 37% reduction that you are calling for has already in part been addressed due to the cost of fuel and expenses that are incurred for offshore fishing. The Magnuson Stevens Act states that the new regulations need to implemented by 2010. That gives the council plenty of time to do a stock review with less conservative numbers as recommended in the SEDAR 10 program. Maybe the council shouldn't use such a precautionary approach to regulation on data that they admit isn't as accurate or current to date as it should be. I believe that if current, data were used along with the above mentioned conservative factors corrected, the councils need for new legislation may not be necessary after all. How about in the alternatives offer for the public to pick from the economic impact for the entire S. Atlantic recreational impact with a 4 month closure will only attribute to a total of $ 1,032,000. An example is the entire state of NC will only have an impact of $ 37,000. That is ridiculous. That equates to 37 trips at a charter price of $ 1,000. The impact is for the "for hire" sector which is lumped in with the recreational sector as a whole. There is no account for the true recreational sector such as recreational food, fuel, hotel, shopping, tackle, boat maintenance etc. For a 4 month NC closure, $ 37,000, REALLY? We would like to see the gag assessment redone. There are too many uncertainties and inconsistencies to move forward with an assessment that will affect such a large fishery. - The Gulf of Mexico Grouper assessment has been reviewed due to some of the same questions. There were many corrections and this was done in less than 6 month time frame. Fishing effort is significantly reduced and is not taken into account when calculating future estimates as it should be. Economic impact and true fishing pressure of both recreational and commercial fishing is grossly inaccurate. If after a review it is necessary to reduce harvest, only modest bag limit decreases or modest size limit increases should be considered acceptable if in fact a problem exists. I am sure that the Council want to make sound decisions. The economic and social devastation wrought by these proposed Gag regulations comes at a time when effort is significantly declining (I feel permanently) due to exorbitant fuel prices. These current proposals are based on overly precautionary thresholds which compound to create the false sense of an unhealthy fishery, when in fact the fishery could be quite healthy. Is it any wonder that the individuals that you are governing are not satisfied with the proposed solutions when they seem to have a better handle on the fish stock, behavioral patterns, abundance and realistic solutions and are not heard by you? I urge the Council to: 1. Review the Natural Mortality Rate of Gag 2. Review and adjust the overly precautionary estimates 3. Provide the numbers for and consider as an alternative a 26" Gag minium size limit (20% or more reduction in rec landings alone) as the FIRST tool applied to the fishery. 4. Invite Dr. Trevor Kenchington to the SSC and Council meeting in June. Dr. Kenchington has extensive knowledge of both the Gulf of Mexico and the South Atlantic fisheries and could prove an excellent resource in the interpretation of current data parameters.
Thank you for your time and the opportunity to voice my concerns.
Marty Gribble Charlotte, NC
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for We operate a fleet of 6 boats that bottom fish for grouper year round. We cannot survive a 4 month closure. Gag is not a common South Florida fish. It is not a reef fish. You can close Gag year round if you like, BUT please do not close Red and Black Grouper for anytime period as we need a 12 month year to pay the bills.
We can accept a reduction in the Grouper bag limit from 5 to 3, a 40% reduction but a zero bag limit would tie our boats to the dock while boat payments, dockage and insurance payments go on.
Thank you,
Captain Andy Griffiths owner of www.fishandy.com
Captain Billy Bullard, Charterboat Allison Jane Captain James Rogers, Charterboat Emily Anne Captain Brian Welzenbach, Charterboat Stephanie Captain Eddie Griffiths, Charterboat Capt. Andy Captain Paul Benson, Charterboat Audrey D. Captain Bob Condo, Charterboat Lady Dana
Mr. Bob Mahood,
Thank you for considering my comments as part of the public input.
As I'm sure you are aware, what works best in an overfished area is to prohibit commercial activity and limit recreational take to whatever modest catches are necessary to protect and grow OUR natural resources.
It has worked wonders for decades in Everglades National Park!!
Recreational fishing is just around 5% or so of catches.
The problem is NOT with recreational fishing, it's with commercial fishing!!! It's so obvious. Not to mention all the money recreational fishing brings to the local economies. Our natural resources of recreational fish should not be a commercial commodity, just like the white tail deer, (Look how well they have done).
PLEASE LET'S USE OUR HEADS ON THIS ONE.
Also, I think the venting & hook release tools are a good idea.
Thank you,
Greg Harrison 954 S Orlando Ave Winter Park, Fl 32789
Dear South Atlantic Council Members,
First, I would like to state that the purpose of my comments are just to address concerns that we have with the data used for decisions on the management of the fisheries in our region. It seems that for too long the subject of the proposed "problem" isn't always defined prior to a "solution" being derived. Public meeting inputs have the attitude that the decision has already been made. As a fishermen, I would be more than happy to supply data as would many of the fishermen I know, if you would educate us on what you need for information and assistance.
Too long have fisherman been pitted against each other, both commercial and recreational, in an attempt to, in my opinion, redirect focus on the issue at hand. Any form of accountability on the Council's part for the decisions made on our behalf as fisherman, doesn't seem to exist. Decisions are made that do not seem to have both the fish stock and fisherman's best interest at heart. Politics appear to also be playing a huge role in the decisions made on our behalf and do at times, seem detrimental to the cause.
The Council's actions are speedy mechanisms to put increased restrictions on a fishery, yet there are no such speedy mechanisms to decrease restrictions should any fishery's biomass indeed increase to healthier levels, or have new data to contradict the imposing limits. We hear how it needs to produce results over a long time period such as 10 years to be accurate. Please don't cite here how we can now catch more porgy. That is a sad example on the Council's part at best. Historically, regulations don't give back but become more conservative in restrictions.
These viewpoints are directed towards Amendment 16 yet hold true of all others that are being reviewed at present.
As I have read extensive amounts of information including SEDAR 10 along with information from the SAFMC, etc. I have a couple of points that I would like to bring up.
From the SAFMC website and I quote
Lack of basic management data on many of the species still remains the major obstacle to successful management.
MRFSS surveys have been proven unreliable. What changes in the last 10 years have been changed to upgrade the survey system? MRFSS is usually a year or two behind in estimating this trend, so my main concerns are about over regulation that may not be warranted.
MARMAP surveys on "random hard bottoms" are the basis of most surveys done. We are talking about reef fish, fish that look for live bottom and structure to make their home. Data collections from things like "Chevron traps" were inconclusive due to such low catch rates and classified as "indeterminable and inaccurate" after 27 years yet older data is still used to calculate present trends.
Why are things like wave heights, sea surface temps, surface currents, hurricane impacts, DO, salinity, wind speed, wind direction, etc. not included in present studies?
Why are issues like water quality and pollution along with protecting our juvenile fish using our estuaries for growth not addressed or protected? We can pay a hog farmer or tobacco farmer not to raise their crop yet we don't address the shrimping bycatch that is drastically affecting our fish stock? Please don't tell me how great the "bycatch" gear is doing in the shrimping industry, the bycatch being shoveled overboard looks like a snow storm floating on the water coming from a shrimper. I understand they have to make a living, however, subsidizes their income for the percentage necessary and stop letting them trawl on the inside and watch how well our fisheries rebound.
I am concerned on how "overly conservative" the Council seems to be in their calculations and proposed regulations. Below are some of the areas that if corrected to more realistic parameters, would take us out of the "overfishing" category that the grouper and snapper species are presently assessed as.
I am concerned that F (fishing mortality; the percentage of the population that dies each year from fishing) is overstated partly because it is based on
1. Marine Recreational Fishing Statistical Survey (MRFSS) estimates of landings and discards, which have been declared unreliable and even ‘fatally flawed’ and
2. An overstated recreational release mortality of 25%.
Recreational fisheries Release mortality is presently assumed to be 25%, SEDAR 10 workshop stated Improved estimates of post-release mortality were obtained through tag release and caging methods (Burns et al. 2002; Overton and Zabawski 2003; McGovern et al. 2005). Using these methods, mean mortality rates were estimated to be 21.2% (Overton and Zabawski 2003), 23% over a variety of depths (McGovern et al. 2005). Commercial fisheries Release mortality is presently assumed to be 40%. Your reasoning behind the proposed legislation is that the FMSY is below the F (Fish Mortality) factor, the FMSY has remained below the F (Fish Mortality) factor since 1983 in the South Atlantic. With the Council willing to error on the side of "conservative numbers and factors" is it any wonder this is the trend? Now take a look at our stocks. Have we decimated our biomass? No. Clearly real world numbers aren't being used to gauge accurate regulation.
How can the Magnuson Stevens Act expect you to make changes within 1 year of notification if the Council states that it takes 3-8 years to schedule and complete a stock assessment? For that matter, why, if notified that a stock is in "trouble", aren't the data compiled between the last stock assessment and the present date of the notifications, reviewed to determine if an issue really exists at the present notification time period prior to taking action?
According to your own data workshops, spawning stock biomass increased after 1999 corresponding to implementation of the 24 inch minimum size limit. Fishing mortality has been decreasing since 1992 yet the gag grouper life span has just been raised to 26 years to 30 years. The life expectancy factor has been raised recently which is also affecting the formula into an "overfishing" status.
50% of maturity is 3 years and 25.5 inches. Why don't we increase the minimum size limit to 26". It has proven effective for the size increase in 1999 to 24".
Fishing mortality in 2004 was estimated as 0.31, extremely conservative against 2007 projected mortality.
Why is the fishing mortality rate for 2007 not being used? Obviously the fishing pressure has reduced since 2004 yet the OPPORTUNITY to fish hasn't been reduced which I think is very important and not usually taken into account when new regulations are proposed.
The council can redo the entire Vermilion Snapper stock assessment due to concerns of accuracy and possible "gross negligence" of the last assessment with updated data, yet I am told by the Council that the 2004 data used in SEDAR 10 for grouper won't be updated until 2011? Are you kidding me? With the impact that fuel has alone on the frequency of fishing trips which has been declining since 2004, why can we not use current data and revisit the workshop to determine if the present proposed measures are necessary?
How can there be underfunding on the federal or local level to interpret the data that is taken every year but not incorporated or used due to lack of resources and man power as stated by the council with 3-8 years between stock assessments?
Why are the conclusions and recommendations from the data and review workshops which are and from the SEDAR programs not incorporated into the councils decisions on a "less cautionary or overly conservative" approach?
SEDAR 10 biologists recommended changing the MSST, SSB, M, F, MFMT and alike, in one form or another due to "overly conservative" concerns.
MSST, currently defined by the South Atlantic Council as (1-M)BMSY, is very close to BMSY because age-averaged natural mortality rate, M, is estimated as 0.14. It was recommended to change the M and wasn't done. It was stated that "the stock is not overfished and is not projected to become overfished."
Given the uncertainties in the assessment, the biomass would be expected or could possibly, fall below MSST with a relatively high frequency even if the true biomass were close to BMSY. In Sedar 10 the Review Workshop stated that the current definition of MSST may be overly conservative and recommends an operational definition of MSST of 5 million pounds. Yet it is still the factor of 6.8 million pounds was used.
The MFMT factor is also showing signs of being overly conservative. Why the council feels the need to error on EXTREME caution I don't understand.
Then Natural Mortality Rate formula was calculated using the Hoenig 1983 program. A program which has flaws due to the fact that the estimate of maximum age required by Hoenig's method assumes that the age determination technique being employed is unbiased. Validating this assumption is often difficult for the older, more difficult-to-age individuals but can be accomplished by using a variety of techniques ranging from marking to analysis of radioactive isotopes (Lai et al., 1996). The estimate of longevity is also dependent on sample size and previous fishing history, which by the way we don't have sound, accurate data on according to the Council's own admission.
Hoenig (1983) showed that maximum age tends to increase slowly with increasing sample size but longevity has probably declined from historical levels because of fishing. A small sample size for age determination, underaging, and previous exploitation would all result in an overestimate of M with Hoenig's method. Although compared to other methods, we still have an issue with accurate data and excessively cautionary management.
Maybe we don't increase the Annual Catch Limits (ACLs) as aggressively using such precautionary regulation. The 2004 stock assessment model projections show the stock becoming overfished in 2007.
Greg Waugh states on 5/8/2008 that "the stock isn't overfished due to present reduction fishing pressure, attributed to several factors such as fuel costs." He also cited that "the assessment wouldn't be redone due to funding and scheduling issues and would be revisited in 2011."
It is an natural assumption with the current economic situation and petroleum driven influence on our daily lives that there has been a significant decline in fishing pressure on all fishing stocks. Yet the Council seems reluctant to revisit the issue since they already have time and effort invested into them and have decided to "stick" to their original conclusions.
Maybe we use data more current than 2004 and realize that the 37% reduction that you are calling for has already in part been addressed due to the cost of fuel and expenses that are incurred for offshore fishing. The Magnuson Stevens Act states that the new regulations need to implemented by 2010. That gives the Council plenty of time to do a stock review with less conservative numbers as recommended in the SEDAR 10 program.
Maybe the Council shouldn't use such a precautionary approach to regulation on data that they admit isn't as accurate or current to date as it should be.
I believe that if current, data were used along with the above mentioned conservative factors corrected, the councils need for new regulations may not be necessary after all.
How about in the alternatives offer for the public to pick from the economic impact for the entire South Atlantic recreational impact with a 4 month closure will only attribute to a total of $ 1,032,000. An example is the entire state of North Carolina will only have an impact of $ 37,000. That is ridiculous. That equates to 37 trips at a charter price of $ 1,000. The impact is for the "for hire" sector which is lumped in with the recreational sector as a whole. There is no account for the true recreational sector such as recreational food, fuel, hotel, shopping, tackle, boat maintenance etc. For a 4 month North Carolina closure, $37,000, REALLY?
We would like to see the gag assessment redone. There are too many uncertainties and inconsistencies to move forward with an assessment that will affect such a large fishery.
- The Gulf of Mexico Grouper assessment has been reviewed due to some of the same questions. There were many corrections and this was done in less than 6 month time frame.
Fishing effort is significantly reduced and is not taken into account when calculating future estimates as it should be.
Economic impact and true fishing pressure of both recreational and commercial fishing is grossly inaccurate.
If after a review it is necessary to reduce harvest, only modest bag limit decreases or modest size limit increases should be considered acceptable if in fact a problem exists.
I am sure that the Council want to make sound decisions. The economic and social devastation wrought by these proposed Gag regulations comes at a time when effort is significantly declining (I feel permanently) due to exorbitant fuel prices. These current proposals are based on overly precautionary thresholds which compound to create the false sense of an unhealthy fishery, when in fact the fishery could be quite healthy.
Is it any wonder that the individuals that you are governing are not satisfied with the proposed solutions when they seem to have a better handle on the fish stock, behavioral patterns, abundance and realistic solutions and are not heard by you?
I urge the Council to:
1. Review the Natural Mortality Rate of Gag.
2. Review and adjust the overly precautionary estimates.
3. Provide the numbers for and consider as an alternative a 26” Gag minimum size limit (20% or more reduction in recreational landings alone) as the FIRST tool applied to the fishery.
4. Invite Dr. Trevor Kenchington to the SSC and Council meeting in June. Dr. Kenchington has extensive knowledge of both the Gulf of Mexico and the South Atlantic fisheries and could prove an excellent resource in the interpretation of current data parameters.
Thank you for your time and the opportunity to voice my concerns.
Sincerely,
John A. Herrera, M.Acc., J.D., LL.M., CPA Law Offices of John A. Herrera 2501 South Ocean Boulevard Suite 107 Boca Raton, FL 33432
Grouper Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFCs own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely by-catch mortality and habitat destruction from trawling and long line activities. I believe that NO CHANGES are required at this time, and the SAMFCs preferred alternatives would have a drastic economic impact.
I am against alternative 2 (Establish a gag spawning season closure January through April...) in that there is no reliable data on recreational landings to support this position. This alternative places a greater burden on the recreational sector. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I support Alternative 3 (Directed Commercial Quota)
I support Alternative 4 (Divide Directed Commercial Quota into 2 regions). In addition, I support the regional management of the recreational sector with Florida being a separate management area
In reference to Alternative 5. Recreational measures:
I am against Alternative 5a (Reduce the 5-grouper aggregate bag limit to a 3- grouper...January-April fishery closure). This alternative places an unfair burden on the recreational sector without a comparable reduction to the commercial landings. I am against alternative 5 in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I am against Alternative 5b (December - April closed season, retain current bag limits...). I am against alternative 5b in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Amendment 16 also includes alternatives to reduce by-catch mortality by requiring the use of venting/dehooking tools and circle hooks. I agree with this as it reduces mortality and aid in the recovery of the stocks.
Vermilion Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The spikes in this fishery have been caused by the SAMFC shifting pressure from the Sea Bass fishery which in turn has concentrated pressure on the Vermilion fishery. In addition, the explosion of the Goliath Grouper populations is putting increased pressure on this fishery. I would suggest a limited take/season on the Goliath Grouper fishery.
I am against Alternative 2 (Interim Allocations). I would suggest that SAMFC increase data collection on both the fishery health and fishery utilization before enacting any changes. In addition, a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Sincerely, Hank Hicks-"Please put me on your list of fishermen that are standing against the Red Snapper ban!"
Captain William R. Hoge Sea Love Charters 220 Nix Boat Yard Road St. Augustine, FL 32084
To the South Atlantic Fishery Management Council,
My name is Captain William R. Hoge, and I am writing this comment in regards to the management alternatives under consideration in Amendment 16. I graduated from University of Miami in 1987 with a double major in Marine Science/Biology and a minor in Chemistry. For the first nine years after graduation, I worked as an environmental consultant to the United States Air Force (USAF). One of my tasks for the USAF was the writing and implementation of fish and wildlife plans. I currently live in St. Augustine, Florida where I have worked as a deckhand on party boats, commercial fished, and captained for the past 13 years. In January of 2005, I purchased Sea Love Charters.
Sea Love Charters has been part of St. Augustine since 1980 and part of Daytona since the 1960’s. Sea Love has the only party boats operating out of St. Augustine. The Sea Love Charter fleet consists of “Sea Love II”, a 70 foot party boat with a 67 passenger capacity, the “Sea Love III”, a 50 foot party boat that holds 35 passengers, and “Reel Therapy”, a 40 foot six pack sport boat. Tourists from around the country and world specifically visit St. Augustine to go fishing. Last year, Sea Love Charters took out approximately 40,000 people fishing. It is a safe and economical way for a large family to enjoy fishing on the ocean.
We try to operate everyday, but during the winter months the weather can be quite inclement, and we will only be capable of running maybe a dozen trips during a bad month. During the summer months, one or all of the vessels will run everyday, and on weekends all vessels will be filled to capacity. The majority of our customers during the summer are tourists, and the easiest fish to target for the kids and novice fisherman and the one that makes up the majority of our catch, at times up to 90%, is the vermillion snapper. As the cost of a fishing trip goes up, presently $80 for an all-day trip, due to the ever increasing cost of fuel, fishermen want to ensure that they are getting the best value for their money. This is usually accomplished by catching a nice stringer of fish. By overly restricting bag limits and or implementing season closures, customers will think twice about the value of a deep sea fishing trip. Harsh restrictions on vermillion snapper bag limits and/or closures could ultimately have a dramatic negative impact upon the number of people who would want to visit St. Augustine and go fishing on a party boat or who would want to go fishing in general.
An all day fishing trip aboard the Sea Love party boats is eight hours. We will not return to the dock early if we reach our bag limit on vermillion. As good as the vermillion fishing is presently, it would take only several hours to reach our limit if the bag limit is reduced to four fish per person. Once the limit of vermillion is reached, we will try to target other species such as sea bass or big fish such as grouper, cobia, and amberjack. This could have a negative impact upon these other species. Because of the high cost of fuel, we sometimes cannot make the long run to leave an area and target other species. Thus, our customers will continue to kill vermillion through dehooking a gut hooked fish, through lack of proper venting, and through predation by barracudas and amberjack when a fished is released. Why not keep these fish for a customer that’s paid a sizeable amount of money to go fishing. If the vermillion bag limit must be reduced from ten fish, my crew agrees that an acceptable bag limit would be seven or eight fish without having a dramatic impact upon the business. A four fish limit is far too restrictive and ridiculous. Due to the larger size of vermillion being caught, an increase of the size limit to 13 inches would also be acceptable.
There are obviously other alternatives that the council could consider rather than drastic bag restrictions and season closures. The other options that have been addressed by the council include exclusion of captain and crew from the bag limit, use of dehooking and venting tools, and the use of circle hooks. Very seldom when there is a full boat will we ever meet our limit of vermillion snapper. This is due in large part to seasickness and lack of fishing experience. With smaller crowds of twenty or so people is it easy to reach our limit of vermillion. No matter what size of the crowd, we very seldom reach our bag limit of grouper. Only in the case of smaller groups and six pack charters will limiting the crews catch make a difference.
I try to impart upon my crew that we are stewards of this resource and to take care when removing hooks from fish and ensure that larger fish such as red snapper and grouper are properly vented if needed. In the case of the larger fish, we will cut the hook if the fish has swallowed it and must be released due to illegal size. At $.10 per hook, this gets very costly and we cannot allow this practice on vermillion snapper. Also, with 67 passengers in the middle of a wide open vermillion bite, it is very difficult for the crew to vent every fish before it is released. If proper venting and dehooking is required for vermillion, we will ensure each mate on the boat is equipped with the proper tools. One alternative that I would certainly consider is the requirement for circle hooks. Currently we use #4/0 J hooks, and I see the damage they can do. Sea Love Charters will have no problem implementing the circle hook.
Having fished in St. Augustine for the past 13 years, I can attest that I have not seen a decline in the number of red and vermillion snapper but rather an increase in size and numbers. I do not claim to know how fisheries scientists and regulators interpret their data. I do know that this past winter and spring have had some of the best fishing in our waters that I can remember. We have practically come back from every trip with large stringers of vermillion. Not only has the snapper fishing been good, the grouper fishing has also been excellent. Talking to the other party boats in Jacksonville including the King Neptune and Miss Mayport, this is the best fishing that they have seen in 30 years.
I think further grouper restrictions will not have a serious impact upon the party boat business. In the locations that we fish, it is very difficult to catch grouper due to the structure they inhabit. They have a tendency to get in structure and cut the line. The typical tourist is not going to catch these fish. On a very good day, we may catch a half dozen grouper. I just don’t think the party boats have a severe impact upon the grouper fishery. I would not mind a bag limit of one per person, but I think a January to April closure is quite extreme and would upset the local fisherman enough not to fish during these months. A two month closure could be acceptable.
The increase in numbers and the continued health of our fisheries is continually documented in the National Oceanic and Atmospheric Administration (NOAA) fisheries reports we do for every trip. The NOAA representative, Dan the “Fish Man”, who visits our dock and documents our catches on a regular basis should be contacted to attest how good our fishing has been. Mark Koryha, a Florida Wildlife Commission (FWC) biologist, is also a regular visitor and surveyor on our boats. He will also attest to the health of our vermillion fishery. Both of these state and federal biologists should be consulted before it is concluded that our local vermillion snapper fishery is in decline and extreme measures need to be taken to preserve it.
Sea Love Charters is the largest harvester of vermillion snapper in the waters out to 100 feet in St. Augustine. The 100 foot mark is typically 25 to 30 miles offshore of the St. Augustine Inlet. Fishing year round, I can attest that there are no other vessels in this area that regularly commercial fish vermillion in this depth or area. There are times during the summer months that certain areas get covered up by the small recreational fishing boats, but the handful of people fishing in these boats can only do so much damage to the fishery.
During the winter months, primarily November to February, the weather can be so bad that fishing offshore is severely limited. During the month of January in years past, I’ve documented only several days of fishing on the party boats. Also, during the summer months, any hurricane that passes anywhere near Florida will have a negative impact upon our weather. Last year we lost most of May and October due to low pressure systems and hurricanes. The ever increasing cost of fuel has also prevented many fishermen from traveling the 20 to 30 miles offshore to catch fish. Thus, winter storms, summer hurricanes, and the skyrocketing cost of fuel all help in lessening the fishing pressure.
According to John Weeks, who has been in the St. Augustine commercial fishing business since the 1970’s, the vermillion fishing stocks have been steadily increasing. Mr. Weeks is currently the owner of The Seafood Shoppe, a wholesale/retail seafood outlet located off the Intracoastal Waterway in St. Augustine that he established in 1991. Mr. Weeks has only five commercial snapper boats that operate out of his market. These five vessels mainly concentrate on harvesting vermillion snapper. In Georgia, he states, there are only four commercial boats reporting vermillion snapper catches. There is not a lot of commercial fishing for red snapper or grouper aboard these vessels.
Mr. Weeks has consistently seen the small commercial fleet have excellent vermillion snapper catches. With a considerable less number of commercial boats fishing than in the past, there is certainly a lot less pressure upon vermillion stocks. Maybe, this is the reason that the fishery stocks have shown a considerable decline in the catch statistics. Basically, between Ponce Inlet in Daytona and Mayport Inlet in Jacksonville, there are two party boats and five commercial boats that regularly fish the thousands of square miles of ocean. The fact is, there is no pressure upon these fish. The heavy restrictions that are proposed for the vermillion fisheries will have dire consequences for the skeletal commercial fleet remaining in St. Augustine and for other species that must be targeted to compensate for the loss of the snapper fisheries. If these restrictive measures become law, Mr. Weeks feels there will be no need for a fish house on the water since the commercial fleet will be out of business.
Mr. Weeks pointed out that if his market cannot consistently supply a particular product to the consumer, i.e. vermillion snapper, demand for the product will decrease. With the proposed closures, there will be no product. Thus, the market will have to depend more and more on imports where the quality just does not compare with the locally caught fish. Not only is the quality going down, but the price will go up. Mr. Weeks agrees with the captains and fishermen who are on the water on a regular basis; the fisheries agencies cannot be reading the catch data correctly.
Mr. Weeks would like the fisheries management agencies to give the current regulations that are in place a chance to work. In particular, the March and April closure for gag grouper which was implemented not long ago. He feels these restrictions are working, and they are doing what they were intended to do, increase the grouper stocks.
It is on average 55 miles to the continental shelf from the St. Augustine Inlet. From Cape Canaveral to the Outer Banks, there are thousands of square miles of suitable habitat for vermillion snapper. Off the west coast of Florida, vermillion snapper are not very common. Why can’t there be localized regulations for the area between Cape Canaveral and Cape Hatteras as compared with the Florida west coast or with south Florida and the Florida Keys where the continental shelf is sometimes several miles offshore. Basically, it is a lot easier to deplete bottom fish off the coast of south Florida than it is off the coast of northeast Florida.
I personally have 1.5 million dollars at stake in the fishing business. I feel I provide a great product in the Florida tourism business. Florida is the sport fishing capital of the world, and many people come to this great state just to fish. Placing serious restrictions and closures upon the very species that supports my business can have serious consequences on weather or not I’m able to stay in business and can also have serious impacts on the Florida tourism business. Everyone knows how important it is to have children experience the thrills of the outdoors. Unfortunately, the new adage may be “Take a kid fishing,.….but you can’t keep the fish.”
I certainly hope that the council listens to all the concerns presented to them by the fishing public in general about the consequences of the management alternatives considered in Amendment 16. There will be a disastrous impact upon commercial and recreational fishing and upon the tourism business if these strict regulations are implemented. A compromise can certainly be found that can benefit the fishery and still support the fishing business. If the council has any questions regarding this information, please do not hesitate to call me at (904) 501-2158.
Sincerely,
William R. Hoge President, Sea Love Charters
Grouper Alternatives
I was born in Florida and have lived in this state my entire life. My wife and I recently had our first child. I look forward to the day when I can take her fishing and pass down the heritage of this sport that was passed down to me. THE GROUPER AND SNAPPER FISHING I HAVE EXPERIENCED IN THE LAST FIVE YEARS HAVE BEEN THE BEST I HAVE EVER SEEN. I hope that the SAFMC will act in the interest of the people and not just the few that stand to gain financially by their decisions. As with all things, history will provide clarity and the decisions of the SAFMC will be seen for what they truly are. I hope people will look back on the decisions soon to be made by the SAFMC and see people who acted in the interest of everyone of this fine state and the others in it's district.
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFCs own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely by-catch mortality and habitat destruction from trawling and long line activities. I believe that NO CHANGES are required at this time, and the SAMFCs preferred alternatives would have a drastic economic impact.
I am against alternative 2. This alternative places a greater burden on the recreational sector while long lining and shrimping continues to clearly have a devastating negative impact stocks.
I support Alternative 3 (Directed Commercial Quota)
I support Alternative 4 (Divide Directed Commercial Quota into 2 regions). In addition, I support the regional management of the recreational sector with Florida being a separate management area
In reference to Alternative 5. Recreational measures:
I am against Alternative 5a (Reduce the 5-grouper aggregate bag limit to a 3- grouper...January-April fishery closure). This alternative places a greater burden on the recreational sector while long lining and shrimping continues to clearly have a devastating negative impact stocks.
I am against Alternative 5b (December - April closed season, retain current bag limits...). This alternative places a greater burden on the recreational sector while long lining and shrimping continues to clearly have a devastating negative impact stocks.
Amendment 16 also includes alternatives to reduce by-catch mortality by requiring the use of venting/dehooking tools and circle hooks. I agree with this as it reduces mortality and aid in the recovery of the stocks.
Vermilion Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The spikes in this fishery have been caused by the SAMFC shifting pressure from the Sea Bass fishery which in turn has concentrated pressure on the Vermilion fishery. In addition, the explosion of the Goliath Grouper populations is putting increased pressure on this fishery. I would suggest a limited take/season on the Goliath Grouper fishery.
I am against Alternative 2 (Interim Allocations). I would suggest that SAMFC increase data collection on both the fishery health and fishery utilization before enacting any changes. In addition, a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Sincerely, David Ingram
Islamorada Charter Boat Association & South Atlantic Charter Boat Association P.O. Box 462, Islamorada, Florida 33036
May 14, 2008
Mr. George Geiger, Chairman & Council Members South Atlantic Fishery Management Council 4055 Faber Place Drive, Suite 201 North Charleston, SC 29405
Re: Public Comment on SAFMC Amendment 16
Dear Mr. Geiger & Council Members,
Our Associations would like to address several provisions of Amendment 16 we feel could or will have a significant impact on the charter/headboat industry and thus merit additional consideration by the Council.
GAG GROUPER
Gag grouper are and have been a species of concern to us in South Florida and the Florida Keys. Although we continue to catch gag grouper with some regularity in both areas, we have not seen spawning stocks of this species since the very early eighties. However, this has not been our experience with other grouper species, including both blacks and reds. These two species are caught with a great deal of regularity and anglers continue to report steady stock improvements in both species, possibly resulting from the demise of wire mesh fish traps in both the Atlantic and the Gulf of Mexico and other unknown factors.
We also recognize the lack of abundance in gag grouper is perhaps more indigenous to South Florida and the Keys than it is to other areas under Council jurisdiction. In fact that point was so compelling, the Snapper/Grouper Advisory Panel passed and forwarded to Council a motion I made at our September 2008 meeting asking for two distinct management areas on gags. The original motion actually called for a distinction between NC, SC, GA and the Northern half of Florida on one side and South Florida and the Keys on the other. The version passed by the Council distinguishes NC/SC as being different from GA/FL. With nearly a thirty year time frame to examine we must ask ourselves if the lack of spawning aggregates of gag grouper in South Florida and the Keys is not simply part of the natural order of things?
So basically, you have no argument from South Florida and Keys fishermen with regard to stricter management measures for gag grouper. However, the Council’s plan to stop all grouper fishing during the months of January thru April under the guise of protecting gags is unreasonable, even being termed by some as insanity. In essence this
1 provision will effectively remove grouper of all types from the list of species available to recreational, charter/headboat and commercial fishermen for nearly the entire grouper fishing season. Or, as Capt. Joe Petrucco of Islamorada so aptly put it, “The Council is going to mandate the use of circle hooks for fish we are not allowed to catch. A closure on shallow water grouper plus the mandated use of circle hooks just doesn’t make sense.” Where is the justification? Where are the stock assessments on the species, other than gag, that would justify such stringent action on the part of the Council?
We ask you to stick with gag grouper and leave the other species alone until such time as adequate scientific data and field evidence indicates the need for additional protection. Changes in bag limits and elimination of crew members from the total permitted on for-hire vessels is a significant step in controlling and regulating grouper species other than gag which, as previously mentioned, warrant additional regulation in South Florida and the Keys. The proposed four month closure on all grouper will prove devastating to recreational, charter/headboat and commercial fishermen.
VERMILION SNAPPER
In contrast to the disappointment of stagnant gag grouper stocks, those of vermilion snapper in Georgia, Florida and the Keys appear to be quite robust. Not only are they relatively abundant, their size is also an excellent indicator of the quality and health of the fishery with fish to six pounds not uncommon. Vermilions in South Florida and the Keys are mostly targeted in deep water with the majority of them being caught in 180’ or deeper. This is in sharp contrast to the fishery in Northern Florida, Georgia, South Carolina and North Carolina.
The initial reaction to any closures in South Florida and the Keys was ambivalent with anglers feeling they would simply turn their attention to yellowtail or mangrove snapper instead. After some reflection, a number of charter/headboat operators expressed concern about a loss of business from customers that specifically fish for vermilions. And since the fishery appears to be extremely healthy in the area, those operators would like to see the Council move to a more regional management system providing less impact on the respective users in South Florida and the Keys.
Charter/headboat operators in Georgia and North Florida are also expressing grave concerns about the impact on their businesses, if the Council takes severe remedial action on vermilions. Capt. Steve Ament, a member of the Snapper/Grouper Advisory Panel and Savannah headboat operator for nearly thirty years, has repeatedly testified about the relative abundance of vermilion snapper in North Florida and Georgia.
In retrospect, we ask the Council to take a closer look at the impact any restrictive measures will have on the charter/headboat industry in these areas and consider a more regional management schematic for this species in Georgia and Florida.
2 RED SNAPPER
Red snapper are an inconsequential part of the fishery in South Florida and the Keys. In contrast, the species is of great economic importance to charter/headboat operators in North Florida and Georgia and documentation presented by Capt. Steve Ament and others attests to their relative abundance in those areas. Again, we must press the Council on their behalf to take a closer look at the broad management plan being proposed for red snapper. It will have a severe impact on areas where red snapper do not appear to be in need of additional restrictions or closures.
CIRCLE HOOKS
In general there has been little or no opposition to the use of circle hooks when bottom fishing for snapper and grouper. Some, like well-known guide Capt. Bouncer Smith of Miami, are simply saying they would bridle their live, bottom baits, if circle hooks become mandatory. In fact Capt. Smith almost exclusively uses circle hooks for all species including recent experimentation and limited success with swordfish.
Anglers are most concerned about how the regulation would affect them in targeting yellowtail and mangrove snapper. Fishermen are almost unanimous in their use of the Mustad #9174 J-hook targeting these two species. In 99% of the cases anglers are chumming these fish up into the water column and an aggressive style of angling is necessary to catch them. Baits are free-lined in the current and once the fish has taken the bait anglers must respond rapidly and set the hook or the fish will simply spit the bait after feeling the presence of the hook or drag from the fishing line. With yellowtails, timing is everything. Even though a particular fish has eaten a bait, it will continue to feed into the current along with the other snapper in the school and hook setting with circle hooks could be problematic.
Our members endorse the use of circle hooks when bottom fishing for snapper and grouper and many operators are already using them. With regard to yellowtail and mangrove snapper, we would be willing to conduct additional research on the use of circle hooks for yellowtail and mangrove snapper to determine their efficacy. This is not an unreasonable request considering similar data gathering was done prior to implementation of mandatory circle hooks for sailfish.
In fact, we are presently working with Council member Tony Iarocci, the Islamorada Charter Boat Association, Organized Fishermen of Florida and the Florida Keys Commercial Fishermen’s Association to provide some preliminary data on the use of circle hooks for yellowtail and mangrove snapper for the Council at the June meeting.
Almost all of the data on the use of circle hooks for sailfish was gathered by Dr. Eric Prince in collaboration with Captains Ron Hamlin, Jimbo Thomas and Bouncer Smith and surprisingly, the catch ratios of tournaments mandating the use of circle hooks, long before the NMFS requirement, has actually gone up. We might very well find the same results in the use of circle hooks with regard to yellowtail and mangrove snapper.
3 Remember, a significant reason for the objection to the use of circle hooks on sailfish was simply because we needed to re-educate the fishermen to a different style of angling. This could also prove to be the case with yellowtails and mangrove snapper.
Implementing a test period and gathering results and data on the use of circle hooks for both species would be influential in supporting the Council’s case for their mandated use. In our opinion it is worth the time and effort to gather this information prior to action by the Council. We have many for-hire operators and commercial fishermen in South Florida and the Keys willing to conduct any testing the Council might choose to initiate.
IN CONCLUSION
We realize the Council’s desire to avoid micro-management of the many species of fish under their jurisdiction. However, broad management plans seem to be causing as many problems as they are resolving. Public meetings are becoming more volatile as fishermen from all of the user groups question the validity of the data gathering processes and voice concerns that little respect is being given to what is actually taking place in the field.
This should be of serious concern to the Council. The late Captain Pete Gladding of Key West was perhaps one of the most influential fishermen in demonstrating the importance of the great weight that should be given to the testimony of the various user groups. When the evidence of what fishermen have on ice in their fish boxes contrasts sharply with the evidence of mathematical formulas, it becomes incumbent on all of us to take a closer look.
Respectfully submitted,
Bill Kelly
Capt. Bill Kelly
Contact Information: 305-394-5333 [email protected]
4 Dear South Atlantic Council Members,
First, I would like to state that the purpose of my comments are just to address concerns that we have with the data used for decisions on the management of the fisheries in our region. It seems that for too long the subject of the proposed "problem" isn't always defined prior to a "solution" being derived. Public meeting inputs have the attitude that the decision has already been made. As a fishermen, I would be more than happy to supply data as would many of the fishermen I know, if you would educate us on what you need for information and assistance.
Just finding out about these meetings is hard enough, try getting on the SAFMC website and finding SEDAR 10 REPORT or Magnuson Stevens Scoping document and reading the entire thing along with understanding it is another issue altogether.
Too long have fisherman been pitted against each other, both commercial and recreational, in an attempt to, in my opinion, redirect focus on the issue at hand. Any form of accountability on the council's part for the decisions made on our behalf as fisherman, doesn't seem to exist. Decisions are made that do not seem to have both the fish stock and fisherman's best interest at heart. Politics appear to also be playing a huge role in the decisions made on our behalf and do at times, seem detrimental to the cause.
The council's actions are speedy mechanisms to put increased restrictions on a fishery, yet there are no such speedy mechanisms to decrease restrictions should any fishery’s biomass indeed increase to healthier levels, or have new data to contradict the imposing limits. We hear how it needs to produce results over a long time period such as 10 years to be accurate. Please don't site here how we can now catch more porgy. That is a sad example on the council's part at best. Historically, regulations don't give back but become more conservative in restrictions.
These viewpoints are directed towards Amendment 16 yet hold true of all others that are being reviewed at present.
As I have read extensive amounts of information including SEDAR 10 along with information from the SAFMC, etc. I have a couple of points that I would like to bring up.
From the SAMFC website and I quote
Lack of basic management data on many of the species still remains the major obstacle to successful management. MRFSS surveys have been proven unreliable. What changes in the last 10 years have been changed to upgrade the survey system? MRFSS is usually a year or two behind in estimating this trend, so my main concerns are about over-regulation that may not be warranted. MARMAP surveys on "random hard bottoms" are the basis of most surveys done. We are talking about reef fish, fish that look for live bottom and structure to make their home. Data collections from things like "Chevron traps" were inconclusive due to such low catch rates and classified as "indeterminable and inaccurate" after 27 years yet older data is still used to calculate present trends. Why are things like wave heights, sea surface temps, surface currents, hurricane impacts, DO, salinity, wind speed, wind direction, etc not included in present studies? Why are issues like water quality and pollution along with protecting our juvenile fish using our estuaries for growth not addressed or protected? We can pay a hog farmer or tobacco farmer not to raise their crop yet we don't address the shrimping bycatch that is drastically affecting our fish stock? Please don't tell me how great the "bycatch" gear is doing in the shrimping industry, the bycatch being shoveled overboard looks like a snow storm floating on the water coming from a shrimper. I understand they have to make a living, however, subsidizes their income for the percentage necessary and stop letting them trawl on the inside and watch how well our fisheries rebound. I am concerned on how "overly conservative" the council seems to be in their calculations and proposed regulations. Below are some of the areas that if corrected to more realistic parameters, would take us out of the "overfishing" category that the grouper and snapper species are presently assessed as.
I am concerned that F (fishing mortality; the percentage of the population that dies each year from fishing) is overstated partly because it is based on
1. Marine Recreational Fishing Statistical Survey (MRFSS) estimates of landings and discards, which have been declared unreliable and even ‘fatally flawed’ and
2. An overstated recreational release mortality of 25%.
Recreational fisheries Release mortality is presently assumed to be 25%, SEDAR 10 workshop stated Improved estimates of post-release mortality were obtained through tag release and caging methods (Burns et al. 2002; Overton and Zabawski 2003; McGovern et al.2005). Using these methods, mean mortality rates were estimated to be 21.2% (Overton and Zabawski 2003), 23% over a variety of depths (McGovern et al. 2005). Commercial fisheries Release mortality is presently assumed to be 40%. Your reasoning behind the proposed legislation is that the FMSY is below the F (Fish Mortality) factor, the FMSY has remained below the F (Fish Mortality) factor since 1983 in the S. Atlantic. With the council willing to error on the side of "conservative numbers and factors" is it any wonder this is the trend? Now take a look at our stocks. Have we decimated our biomass? No. Clearly real world numbers aren't being used to guage accurate regulation.
How can the Magnuson Stevens Act expect you to make changes within 1 year of notification if the council states that it takes 3-8 years to schedule and complete a stock assessment? For that matter, why, if notified that a stock is in "trouble", aren't the data compiled between the last stock assessment and the present date of the notifications, reviewed to determine if an issue really exists at the present notification time period prior to taking action?
According to your own data workshops, spawning stock biomass increased after 1999 corresponding to implementation of the 24 inch minimum size limit. Fishing mortality has been decreasing since 1992 yet the gag grouper lifespan has just been raised to 26 yrs to 30 years. The life expectancy factor has been raised recently which is also affecting the formula into an "overfishing" status.
50% of maturity is 3 years and 25.5 inches. Why don't we increase the minimum size limit to 26". It has proven effective for the size increase in 1999 to 24".
Fishing mortality in 2004 was estimated as 0.31, extremely conservative against 2007 projected mortality.
Why is the fishing mortality rate for 2007 not being used? Obviously the fishing pressure has reduced since 2004 yet the OPPORTUNITY to fish hasn't been reduced which I think is very important and not usually taken into account when new regulations are proposed.
The council can redo the entire Vermillion Snapper stock assessment due to concerns of accuracy and possible "gross negligence" of the last assessment with updated data, yet I am told by the council that the 2004 data used in SEDAR 10 for grouper won't be updated until 2011? Are you kidding me? With the impact that fuel has alone on the frequency of fishing trips which has been declining since 2004, why can we not use current data and revisit the workshop to determine if the present proposed measures are necessary?
How can there be underfunding on the federal or local level to interpret the data that is taken every year but not incorporated or used due to lack of resources and man power as stated by the council with 3-8 years between stock assessments?
Why are the conclusions and recommendations from the data and review workshops which are and from the SEDAR programs not incorporated into the councils decisions on a "less cautionary or overly conservative" approach?
SEDAR 10 biologists recommended changing the MSST, SSB, M, F, MFMT and alike, in one form or another due to "overly conservative" concerns.
MSST, currently defined by the South Atlantic Council as (1-M)BMSY, is very close to BMSY because age-averaged natural mortality rate, M, is estimated as 0.14. It was recommended to change the M and wasn't done. It was stated that "the stock is not overfished and is not projected to become overfished."
Given the uncertainties in the assessment, the biomass would be expected or could possibly, fall below MSST with a relatively high frequency even if the true biomass were close to BMSY. In Sedar 10 the Review Workshop stated that the current definition of MSST may be overly conservative and recommends an operational definition of MSST of 5 million pounds. Yet it is still the factor of 6.8 million pounds was used.
The MFMT factor is also showing signs of being overly conservative. Why the council feels the need to error on EXTREME caution I don't understand.
Then Natural Mortality Rate formula was calculated using the Hoenig 1983 program. A program which has flaws due to the fact that the estimate of maximum age required by Hoenig's method assumes that the age determination technique being employed is unbiased. Validating this assumption is often difficult for the older, more difficult-to-age individuals but can be accomplished by using a variety of techniques ranging from marking to analysis of radioactive isotopes (Lai et al., 1996). The estimate of longevity is also dependent on sample size and previous fishing history, which by the way we don't have sound, accurate data on according to the councils own admission. Hoenig (1983) showed that maximum age tends to increase slowly with increasing sample size but longevity has probably declined from historical levels because of fishing. A small sample size for age determination, underaging, and previous exploitation would all result in an overestimate of M with Hoenig's method. Although compared to other methods, we still have an issue with accurate data and excessively cautionary management. Maybe we don't increase the Annual Catch Limits (ACLs) as aggressively using such precautionary regulation. The 2004 stock assessment model projections show the stock becoming overfished in 2007.
Greg Waugh states on 5/8/2008 that "the stock isn't overfished due to present reduction fishing pressure, attributed to several factors such as fuel costs." He also cited that "the assessment wouldn't be redone due to funding and scheduling issues and would be revisited in 2011."
It is an natural assumption with the current economic situation and petroleum driven influence on our daily lives that there has been a significant decline in fishing pressure on all fishing stocks yet the council seem reluctant to revisit the issue since they already have time and effort invested into them and have decided to "stick" to their original conclusions.
Maybe we use data more current than 2004 and realize that the 37% reduction that you are calling for has already in part been addressed due to the cost of fuel and expenses that are incurred for offshore fishing. The Magnuson Stevens Act states that the new regulations need to implemented by 2010. That gives the council plenty of time to do a stock review with less conservative numbers as recommended in the SEDAR 10 program.
Maybe the council shouldn't use such a precautionary approach to regulation on data that they admit isn't as accurate or current to date as it should be.
I believe that if current, data were used along with the above mentioned conservative factors corrected, the councils need for new legislation may not be necessary after all.
How about in the alternatives offer for the public to pick from the economic impact for the entire S. Atlantic recreational impact with a 4 month closure will only attribute to a total of $ 1,032,000. An example is the entire state of NC will only have an impact of $ 37,000. That is ridiculous. That equates to 37 trips at a charter price of $ 1,000. The impact is for the "for hire" sector which is lumped in with the recreational sector as a whole. There is no account for the true recreational sector such as recreational food, fuel, hotel, shopping, tackle, boat maintenance etc. For a 4 month NC closure, $ 37,000, REALLY?
We would like to see the gag assessment redone. There are too many uncertainties and inconsistencies to move forward with an assessment that will affect such a large fishery.
- The Gulf of Mexico Grouper assessment has been reviewed due to some of the same questions. There were many corrections and this was done in less than 6 month time frame.
Fishing effort is significantly reduced and is not taken into account when calculating future estimates as it should be.
Economic impact and true fishing pressure of both recreational and commercial fishing is grossly inaccurate.
If after a review it is necessary to reduce harvest, only modest bag limit decreases or modest size limit increases should be considered acceptable if in fact a problem exists.
I am sure that the Council want to make sound decisions. The economic and social devastation wrought by these proposed Gag regulations comes at a time when effort is significantly declining (I feel permanently) due to exorbitant fuel prices. These current proposals are based on overly precautionary thresholds which compound to create the false sense of an unhealthy fishery, when in fact the fishery could be quite healthy.
Is it any wonder that the individuals that you are governing are not satisfied with the proposed solutions when they seem to have a better handle on the fish stock, behavioral patterns, abundance and realistic solutions and are not heard by you?
I urge the Council to:
1. Review the Natural Mortality Rate of Gag 2. Review and adjust the overly precautionary estimates 3. Provide the numbers for and consider as an alternative a 26” Gag minium size limit (20% or more reduction in rec landings alone) as the FIRST tool applied to the fishery. 4. Invite Dr. Trevor Kenchington to the SSC and Council meeting in June. Dr. Kenchington has extensive knowledge of both the Gulf of Mexico and the South Atlantic fisheries and could prove an excellent resource in the interpretation of current data parameters.
Thank you for your time and the opportunity to voice my concerns.
Best Regards,
Captain Stan Jarusinski Swansboro, N. C.
To Whom It May Concern, I am writing to voice my concern. Every alternative that was presented at yesterday's meeting (5/12/08) was slanted in favor of commercial fishermen. Based on what I and my fellow fishing partners observed from this scoping meeting, it is outrageously obvious that powerful lobbyist for commercial fishermen have gotten behind Amendment 16. You are wrong to hastily put this before the public and then tell us (the taxpayer) we only have 3 short days to try to reverse these actions. It is obvious that your group has had much more time to gather some extremely biased information. As a recreational fisherman, I have witnessed the waste produced by commercial fishermen. They rape the ocean taking what they want and discarding the rest overboard. They are allowed to keep even the smallest fish they catch with no size limit or count. How do you consider such practice to be environmentally friendly to the fish population? Recreational fishermen are careful to not keep the precious breeding stock and to release young fish. This is not the case with the commercial industry. You want to allow them an extended time to catch their limit, yet you want to cut the time the recreational taxpayer can enjoy being out on the water. This in an injustice to the general public. Furthermore, the economy is terrible and Amendment 16 will diminish recreational fishing as we know it. Why would anyone want to purchase a $40,000+ boat to catch one fish? I know that I am just one person and one vote, but I have a many friends who also fish which feel the same way. A recent economic study in the state of GA. states that 350 million+ dollars from recreational fishing was added to the economy versus 57 million contributed by commercial fishermen(crabbing shrimping,and fishing). Georgia's economy does not need to take another blow. Any new Amendment should push for the opposite of what you are bulldozing. It should allow the recreational fisherman more time on the water and limit the time and catch of the commercial industry. Maybe the answer is to push for stricter regulations on the commercial fishing industry. Please don't try to cut even more what the taxpaying weekend recreational fisherman can catch. Fishing is a sport to be enjoyed by many generations to come. Such unfair regulations and rules against recreational fishermen does not encourage future generations to become active in this sport.
Sincerely, J. Christy Robinson
4459 Constance Rd. Jesup, GA. 31545 912-586-6139
I regularly fish the Florida Keys. I spend about two thousand a month for the purpose of catching some fish and crayfish with my friends and family. I do not try to pack my freezer nor feed the neighborhood. I simply want to be able to go and fish and keep my catch. I am a native Floridian and during my fifty plus years I have never known a fishery that was threaten by recreational fishing. Keeping a reasonable size and quantity limit makes sense but to rule out bottom fishing for months at a time is not needed. Instead I would recommend banning commercial fishing at those times when the fish are most threaten and restrict the quantity of fish kept recreationally. It is people like me who spend a ridiculous amount of money for the amount of fish that I keep that provide the highest use of the fishery.
Sincerely, Raymond Kimsey.
Allen Leary Atlantic Offshore, Inc. m/v Thunderstar & m/v Gulfstream 4 Seafood Drive Mount Pleasant, SC 29464 [email protected]
This letter is to comment on the proposed Amendment 16 to the Magnusun-Stevens Act. I attended the public scoping meeting held in Charleston, SC Tuesday afternoon May 13, 2008. However, I did not have time to comment at the end of the meeting. I am the owner of the only large headboat left in the Charleston area. My concern with this proposed amendment is mainly with the vermillion snapper preferred alternative of 4 fish per person and a season closure. Along with the preferred grouper alternative, this amendment if passed with these allocations will put me and many other headboat operators out of business. As you know our main staple is the vermillion snapper because the majority of the fishermen we take are novice fisherman. Council has already passed amendment 13C in September 2006 which was supposed to end over-fishing in 3 years. Why are we not waiting to see the yield trends and the catch per unit effort trends in this three year period? I’m sure council remembers the reason why they went with the alternatives in amendment 13C is largely because of the socioeconomic impact to the commercial fishery. Well the commercial fishery has not even met their TAC in a given year since this was in place. That means that the companies still in the fishery are not feeling an impact from the amendment. This is the same with the history of developing amendments to the magnuson-stevens act. The recreational side of the fishery, especially the for-hire sector, continues to see decreases in bag limits and increases in size limits while the commercial sector is unharmed. This is not working. Amendment 13C was the first amendment that established a TAC for any snapper-grouper species for the commercial sector. Amendment 12 established a trip limit for the red porgy for the commercial sector. Prior to these amendments bag limits were unlimited and the commercial side was only regulated by diminishing the fleet. Now this did not prove to solve anything as the commercial fisherman who lost their licenses were not showing any catches. Hence, the only ones who lost their license were those who weren’t using it anyway. Again, the commercial fishermen who actually made their livelihood from fishing in the south Atlantic were not affected. Gregg Waugh stated that the only fishery that shows sign of rebuilding is the red porgy fishery, which was due to the harsh regulations placed on the fishery. For those who have not put 2 and 2 together, it is more than a coincidence that this is the only species that has a commercial trip limit. One of the ways that we can replenish fish stocks on a wide range of species at one time is to have trip limits placed on all species of fish so that one species is not targeted over another. The recreational side has fished this way since the beginning of placing regulations on fish. If these fish stocks are not replenishing themselves the way Council and the SSC have predicted, it is because the commercial sector still fishes with unlimited trip regulations (unlimited since TACs have not been met). Trip regulations need to be in place for the commercial side to make fisherman target all species of fish on a per trip basis as recreational fisherman do. If we do not catch too many of one species then there is enough for everyone to be happy. Commercial fisherman will frown upon this due to the fact that they target the species that is biting. If grouper are not being caught due to the time of the year, the moon, or other conditions, they turn to the vermillion snapper or other species. They would be upset if they were regulated this way and they did not have a good catch on certain species. My answer to this is welcome to our world. Welcome to the world of the for-hire and recreational fisherman. I have held my voice on this because of my close friends which are commercial fisherman, but as I am faced with losing my business I must speak up. I feel that the commercial sector has not been dealt with as harshly as needed because of the fact that their livelihood is in jeopardy. Well this is no different from headboat and for-hire sector, especially the head boats as there are some for-hire boats who charter just to pay for the boat. If this economic impact drives the decision making process, then I propose that Council breaks the for-hire / headboat sector out of the recreational sector and we come up with a better allocation that would allow us to stay in business. Headboats cannot stand an economic impact of $2 million. I beg council to rethink these alternatives based history. It is a harsh fact that we are not meeting our MSY goals due to the way the commercial industry has been regulated. As Council is mandated to address over-fishing, this does not mean that all of the sudden we need to affect all sectors the same way. The recreational sector has always endured trip limits. Amendment 16 should bestow trip limits on commercial fisherman with little impact on the for-hire sector. For-hire fishermen have lived with regulations that would damage the commercial sector severely. We cannot stand another hit. This idea of trip limits has proven itself with the red porgies. Let’s prove it for all species.
Allen Leary Atlantic Offshore, Inc. 4 Seafood Dr. Mount Pleasant, SC 29464 [email protected]
Dear S. Atlantic Council Members,
First, I would like to state that the purpose of my comments are just to address concerns that we have with the data used for decisions on the management of the fisheries in our region. It seems that for too long the subject of the proposed "problem" isn't always defined prior to a "solution" being derived. Public meeting inputs have the attitude that the decision has already been made. As a fishermen, I would be more than happy to supply data as would many of the fishermen I know, if you would educate us on what you need for information and assistance.
Just finding out about these meetings is hard enough, try getting on the SAFMC website and finding SEDAR 10 REPORT or Magnuson Stevens Scoping document and reading the entire thing along with understanding it is another issue altogether.
Too long have fisherman been pitted against each other, both commercial and recreational, in an attempt to, in my opinion, redirect focus on the issue at hand. Any form of accountability on the council's part for the decisions made on our behalf as fisherman, doesn't seem to exist. Decisions are made that do not seem to have both the fish stock and fisherman's best interest at heart. Politics appear to also be playing a huge role in the decisions made on our behalf and do at times, seem detrimental to the cause.
The council's actions are speedy mechanisms to put increased restrictions on a fishery, yet there are no such speedy mechanisms to decrease restrictions should any fishery’s biomass indeed increase to healthier levels, or have new data to contradict the imposing limits. We hear how it needs to produce results over a long time period such as 10 years to be accurate. Please don't site here how we can now catch more porgy. That is a sad example on the council's part at best. Historically, regulations don't give back but become more conservative in restrictions.
These viewpoints are directed towards Amendment 16 yet hold true of all others that are being reviewed at present.
As I have read extensive amounts of information including SEDAR 10 along with information from the SAFMC, etc. I have a couple of points that I would like to bring up.
From the SAMFC website and I quote
Lack of basic management data on many of the species still remains the major obstacle to successful management. MRFSS surveys have been proven unreliable. What changes in the last 10 years have been changed to upgrade the survey system? MRFSS is usually a year or two behind in estimating this trend, so my main concerns are about over-regulation that may not be warranted. MARMAP surveys on "random hard bottoms" are the basis of most surveys done. We are talking about reef fish, fish that look for live bottom and structure to make their home. Data collections from things like "Chevron traps" were inconclusive due to such low catch rates and classified as "indeterminable and inaccurate" after 27 years yet older data is still used to calculate present trends. Why are things like wave heights, sea surface temps, surface currents, hurricane impacts, DO, salinity, wind speed, wind direction, etc not included in present studies? Why are issues like water quality and pollution along with protecting our juvenile fish using our estuaries for growth not addressed or protected? We can pay a hog farmer or tobacco farmer not to raise their crop yet we don't address the shrimping bycatch that is drastically affecting our fish stock? Please don't tell me how great the "bycatch" gear is doing in the shrimping industry, the bycatch being shoveled overboard looks like a snow storm floating on the water coming from a shrimper. I understand they have to make a living, however, subsidizes their income for the percentage necessary and stop letting them trawl on the inside and watch how well our fisheries rebound. I am concerned on how "overly conservative" the council seems to be in their calculations and proposed regulations. Below are some of the areas that if corrected to more realistic parameters, would take us out of the "overfishing" category that the grouper and snapper species are presently assessed as.
I am concerned that F (fishing mortality; the percentage of the population that dies each year from fishing) is overstated partly because it is based on
1. Marine Recreational Fishing Statistical Survey (MRFSS) estimates of landings and discards, which have been declared unreliable and even ‘fatally flawed’ and
2. An overstated recreational release mortality of 25%.
Recreational fisheries Release mortality is presently assumed to be 25%, SEDAR 10 workshop stated Improved estimates of post-release mortality were obtained through tag release and caging methods (Burns et al. 2002; Overton and Zabawski 2003; McGovern et al.2005). Using these methods, mean mortality rates were estimated to be 21.2% (Overton and Zabawski 2003), 23% over a variety of depths (McGovern et al. 2005). Commercial fisheries Release mortality is presently assumed to be 40%. Your reasoning behind the proposed legislation is that the FMSY is below the F (Fish Mortality) factor, the FMSY has remained below the F (Fish Mortality) factor since 1983 in the S. Atlantic. With the council willing to error on the side of "conservative numbers and factors" is it any wonder this is the trend? Now take a look at our stocks. Have we decimated our biomass? No. Clearly real world numbers aren't being used to guage accurate regulation.
How can the Magnuson Stevens Act expect you to make changes within 1 year of notification if the council states that it takes 3-8 years to schedule and complete a stock assessment? For that matter, why, if notified that a stock is in "trouble", aren't the data compiled between the last stock assessment and the present date of the notifications, reviewed to determine if an issue really exists at the present notification time period prior to taking action?
According to your own data workshops, spawning stock biomass increased after 1999 corresponding to implementation of the 24 inch minimum size limit. Fishing mortality has been decreasing since 1992 yet the gag grouper lifespan has just been raised to 26 yrs to 30 years. The life expectancy factor has been raised recently which is also affecting the formula into an "overfishing" status.
50% of maturity is 3 years and 25.5 inches. Why don't we increase the minimum size limit to 26". It has proven effective for the size increase in 1999 to 24".
Fishing mortality in 2004 was estimated as 0.31, extremely conservative against 2007 projected mortality.
Why is the fishing mortality rate for 2007 not being used? Obviously the fishing pressure has reduced since 2004 yet the OPPORTUNITY to fish hasn't been reduced which I think is very important and not usually taken into account when new regulations are proposed.
The council can redo the entire Vermillion Snapper stock assessment due to concerns of accuracy and possible "gross negligence" of the last assessment with updated data, yet I am told by the council that the 2004 data used in SEDAR 10 for grouper won't be updated until 2011? Are you kidding me? With the impact that fuel has alone on the frequency of fishing trips which has been declining since 2004, why can we not use current data and revisit the workshop to determine if the present proposed measures are necessary?
How can there be underfunding on the federal or local level to interpret the data that is taken every year but not incorporated or used due to lack of resources and man power as stated by the council with 3-8 years between stock assessments?
Why are the conclusions and recommendations from the data and review workshops which are and from the SEDAR programs not incorporated into the councils decisions on a "less cautionary or overly conservative" approach?
SEDAR 10 biologists recommended changing the MSST, SSB, M, F, MFMT and alike, in one form or another due to "overly conservative" concerns.
MSST, currently defined by the South Atlantic Council as (1-M)BMSY, is very close to BMSY because age-averaged natural mortality rate, M, is estimated as 0.14. It was recommended to change the M and wasn't done. It was stated that "the stock is not overfished and is not projected to become overfished."
Given the uncertainties in the assessment, the biomass would be expected or could possibly, fall below MSST with a relatively high frequency even if the true biomass were close to BMSY. In Sedar 10 the Review Workshop stated that the current definition of MSST may be overly conservative and recommends an operational definition of MSST of 5 million pounds. Yet it is still the factor of 6.8 million pounds was used.
The MFMT factor is also showing signs of being overly conservative. Why the council feels the need to error on EXTREME caution I don't understand.
Thanks,
Jamie S. Ledford Gentlemen, After attending the Public hearing on Amendment 16 in New Bern on May 15th, we have couple of concerns. My wife (Connie) and I are a small Commercial Fishing Operation out of Cape Carteret, NC for Snapper and Grouper on our boat Best Friends. At present this is our only source of earned income. We can live with (and support) the January through April closure during the spawning season for grouper. We recognize the need to rebuild the stocks of Gag Grouper but do not understand the reasoning to close all grouper when the Gag Grouper allotment has been reached. Gag grouper are primary caught in less than 100 ft of water. When fishing for Red Grouper we fish from 115 ft to 150 ft and rarely catch Gag Grouper. On a normal trip over 100 ft, if we catch 600 to 700 lbs of grouper only one or two may be Gag Grouper. They will be primarily Red Grouper with a few Scamps, Yellow Mouth ect. We were under the impression that Red Grouper are going to be addressed in another Amendment and feel that this isn't right to use Gag Grouper stocks as a means to eliminate all Grouper fishing. Another concern is the use of Circle hooks. We use Circle for Grouper fishing but not for snappers (beeliners and red porgy) or trigger. We've tried them but have had little success in efficiently catching these fish with circle hooks. The use of deep drop or hydraulic fixed mounted reels with "L" bars doesn't lend itself to circle hooks well. We typically drop a line down with a couple of "J" hooks on leaders and count to 10 and bring them up. The bungee cord sets the hook, a circle hook gets pulled from the fish's mouth since they don't have time to get the hook far enough into it's throat. We can not remember ever gut hooking a fish with this method which is the only justification for circle hooks. For some one holding a hand rod this may be OK but it is not for a commercial operation.
Thank you for your consideration, Connie & Larry Leuthauser
Grouper Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFCs own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely by-catch mortality and habitat destruction from trawling and long line activities. I believe that NO CHANGES are required at this time, and the SAMFCs preferred alternatives would have a drastic economic impact.
I am against alternative 2 (Establish a gag spawning season closure January through April...) in that there is no reliable data on recreational landings to support this position. This alternative places a greater burden on the recreational sector. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I support Alternative 3 (Directed Commercial Quota)
I support Alternative 4 (Divide Directed Commercial Quota into 2 regions). In addition, I support the regional management of the recreational sector with Florida being a separate management area
In reference to Alternative 5. Recreational measures:
I am against Alternative 5a (Reduce the 5-grouper aggregate bag limit to a 3-grouper...January-April fishery closure). This alternative places an unfair burden on the recreational sector without a comparable reduction to the commercial landings. I am against alternative 5 in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I am against Alternative 5b (December - April closed season, retain current bag limits...). I am against alternative 5b in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Amendment 16 also includes alternatives to reduce by-catch mortality by requiring the use of venting/dehooking tools and circle hooks. I agree with this as it reduces mortality and aid in the recovery of the stocks.
Vermilion Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The spikes in this fishery have been caused by the SAMFC shifting pressure from the Sea Bass fishery which in turn has concentrated pressure on the Vermilion fishery. In addition, the explosion of the Goliath Grouper populations is putting increased pressure on this fishery. I would suggest a limited take/season on the Goliath Grouper fishery.
I am against Alternative 2 (Interim Allocations). I would suggest that SAMFC increase data collection on both the fishery health and fishery utilization before enacting any changes. In addition, a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Robbie C. Linton Fiber Line I&C Planner Weyerhaeuser - Port Wentworth Mill Phone: 912.966.6022 Fax: 912.966.6070 Email: [email protected]
Grouper Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFCs own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely by-catch mortality and habitat destruction from trawling and long line activities. I believe that NO CHANGES are required at this time, and the SAMFCs preferred alternatives would have a drastic economic impact.
I am against alternative 2 (Establish a gag spawning season closure January through April...) in that there is no reliable data on recreational landings to support this position. This alternative places a greater burden on the recreational sector. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I support Alternative 3 (Directed Commercial Quota)
I support Alternative 4 (Divide Directed Commercial Quota into 2 regions). In addition, I support the regional management of the recreational sector with Florida being a separate management area
In reference to Alternative 5. Recreational measures:
I am against Alternative 5a (Reduce the 5-grouper aggregate bag limit to a 3- grouper...January-April fishery closure). This alternative places an unfair burden on the recreational sector without a comparable reduction to the commercial landings. I am against alternative 5 in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I am against Alternative 5b (December - April closed season, retain current bag limits...). I am against alternative 5b in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Amendment 16 also includes alternatives to reduce by-catch mortality by requiring the use of venting/dehooking tools and circle hooks. I agree with this as it reduces mortality and aid in the recovery of the stocks.
Vermilion Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The spikes in this fishery have been caused by the SAMFC shifting pressure from the Sea Bass fishery which in turn has concentrated pressure on the Vermilion fishery. In addition, the explosion of the Goliath Grouper populations is putting increased pressure on this fishery. I would suggest a limited take/season on the Goliath Grouper fishery.
I am against Alternative 2 (Interim Allocations). I would suggest that SAMFC increase data collection on both the fishery health and fishery utilization before enacting any changes. In addition, a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Sincerely, Michael Massey I am sick and tired of recreational sportfisherman being the target of unfair rules and regulations when the commercial fisherman are the real reason for the decline in numbers I will definetly vote those officials out that continue to harass recrecreational sportfisherman IT IS TIME OUR VOICES WERE HEARD!
Written Comment Amendment 16
After attending the Public Comment Meeting in New Bern last evening I also have these comments to submit:
First we were very shocked to hear the girls from Atlantic Fisheries Commission or where ever they were from Commenting to the Council on your great work and that "expediency was recommended", etc...at this Fisheries Meeting we thought was for fishermen...I guess it is for all Public...even though...they are not public they are SPECIAL INTEREST GROUPS...anyway... aren't they paying lobbyist enough to do their pork barreling for them?????????????
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RECOMMENDATIONS to the Council We would like to ask that you:
1. Consider the landings data graph you showed us at the meeting and the fact that it shows commercial landings are already down and recreational landings are up!
2. Consider what the definition of commercial means in comparison to that of recreational!
3. Consider that recreational landings should not be sold at all being they are caught for fun and hobby, not work!
4. Consider the economical impact your closures are going to have on the commercial fishermen...they are endangered species too you know...you've made them that way!
5. Consider supplementing monetary losses to the commercial fishermen when you close the grouper fishery (or any other fishery) for 4 months...1/4 of the year...Grouper afterall is the highest paying species in the complex. They cannot supplement by targeting amberjack or triggerfish at 1/4 of the value!
6. The same applies to the vermilion snappers and the percentages you want to allow the commercial versus the recreational, it's unfair! There again the commercial guys are trying to feed the nation and support their families... versus recreational is solely for fun and hobby and they should not be allowed to sell any!
7. I also have a retail market...... I do not import fish because the public does not want to eat imported food that is not regulated...... no domestic grouper in my shop for 4 months is going to greatly impact my sales...... as it again is the highest priced species. Closing and opening fisheries is the worst effect on marketing that there is!!!!
8. We have "recommended" to you before. Why don't you give everyone 1000# trip limit on every species per trip...or 2500# overall trip limits...but don't close us for months at a time...on any species... anything but closures...GOD WE PRAY!!!!
9. You know you really should consider these facts and consider the real commercial fisherman first...... he is and has made a living at this for generations...... it is our constitutional right to choose fishing as our vocation...... therefore it is unconstitutional of you to OVER regulate him out of business......
10. It is not out of your hands. It was not Congress alone without the advice of you and NMFS & NOAA that Revised the Magnuson Act to show no consideration to the fisherman versus the fish! It is in your hands...... and it is on your hands! GOD HELP US.
Kathy Mathis RUNNERS SEAFOOD 4824 - Highway 24 Morehead City / Newport, NC 28570 252-393-8474
I would like to submit a correction to the written comment submitted by myself yesterday: No. 5 = "10 years ago there were 2400 Fed. permits in the South Atlantic Region...now there are only 900...which would put us reduced already by 63%!!! And yes we would love to see 63% of fisheries management "canned"!!!!
RUNNERS SEAFOOD 4824 - Highway 24 Morehead City / Newport, NC 28570 252-393-8474
Written Comment / Amendment 16
It is hard to find the words to address yet another round of pending amendments...so I research and try to find the answers I am looking for...
These amendments always come from "updated stock assessments" so I download the book written by Andrew B. Cooper...your "stock assessment guru"...there I see allot of words like: uncertainty and theory...and terms like: adding complexity and estimating uncertainty... and my words are yet harder to find......
I on the other hand am not "uncertain" nor have to "theorize" nor have to "add complexity" or "estimate uncertainly".... I have lived the commercial fisherman's life through my husband, others, and having a seafood business of our own.... all total now for 24 years... and here are the things that I KNOW:
1. Special interest groups funded the Magnuson Act and certainly the Reauthorization of it a few years ago; special interest groups for conservation yet for recreational interests.
2. In the original Act it was stated that if any regulations effected the fishermen economically they had to be readjusted...... that was certainly changed in the Reauthorization...now you can shut us down in a year if you deem necessary. But with the "uncertainty of theories" and the "estimation of uncertainties" you still take it run with it...oh I nearly forgot "the best available data"...
3. Not only are your stock assessments wrong now...WHAT ARE YOU COMPARING IT TO? I also KNOW for a fact that the original data collected in the 1980's was all ESTIMATED data...so the numbers are bunk! Dealers in the 80's (I know because I worked for one...they would not allow their workers time to add up real numbers for NCDMF...they gave them some bunk on a piece of paper!)... I get Dealers Reports right now because I am a dealer...and those data stats are bunk...their estimations of price and value...they don't ask us to give it to them...they estimate it!!! That is wrong!!! I believe your stock assessments are wrong today because you are using a THEORY to estimate the age of the fish. Weren't you all supposed to wait for the earbone data to be analyzed before going ahead with these ludicrous closures? That's what I got out of the Public Scoping Meeting held in Atlantic Beach back last fall...but I haven't seen it mentioned anywhere.
4. As I do not believe the stock assessments are correct...nor your theories and formulas...Neither did the fishermen in the Gulf...and they hired an Attorney from Canada THAT PROVED THEY WERE NOT OVERFISHED!!! PROVED THAT THEIR STOCK ASSESSMENTS WERE INCORRECT...AND THEIR FISHERY IS NOT BEING CLOSED!!!!
5. At this time of re-election of President in our government...and time of bad government...it is a pity that every office couldn't be emptied. All this fisheries management for instance is a horrific waste of tax payers money. Ya'll already out number us ...... oh I wish I had the stats on that ...... But there needs to be a quota put on the amount of management that can be on one industry!!!!!! 10 years ago there were 2400 Fed. permits in the South Atlantic Region....now there are only 240...... wow I estimate that to be down by 90%!!!! I would love to see 90% of fisheries management "canned"!!!!
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* Jan - Apr spawning season closure on all groupers is unfounded, unnecessary, unbelievable, undemocratic, and pure communism.
* Division of commercial quota between regions...... could be good for NC
* Reduction of bag limit from 5 to ??? This is not needed. IF YOU WHAT TO CUT DOWN ON CATCHES OF GROUPER WHY DON'T YOU STOP RECREATIONAL FISHERMEN FROM SELLING THEIR CATCHES??? WHY DO YOU ALLOT RECREATIONAL FISHERMEN TO BUY A FEDERAL PERMIT WHEN HE ONLY FISHES ON THE WEEKENDS? THE FIRST PERMITS EVER THE KING PERMITS...THERE WAS A INCOME VERIVACATION FORM WHEREAS HE HAD TO MAKE 50% OF HIS LIVING FROM COMMERCIAL FISHING TO GET ONE!!!!!!!!! THAT SHOULD BE IN EFFECT TODAY......
*You want to establish a commercial quota on vermilion snapper....jeez UNFOUNDED, UNNECESSARY, UNDEMOCRATIC......
*You want to establish a closed recreation season October - May...... UNFOUNDED, UNNECESSARY, UNDEMOCRATIC......
*on dehooking tools / we already use them
*on circle hooks / only lazy fishermen from Little River use them ... and drift ...while they drink
*Why don't ya'll take up fishing then come tell us something!!!
RUNNERS SEAFOOD 4824 - Highway 24 Morehead City / Newport, NC 28570 252-393-8474
My husband, Capt. Gilbert Mathis would like to Comment on Amendment 16:
He would like to recommend to the Council that they do not impose these "closures" on the commercial fishery...that they instead:
1. Require 50% Income Verification to acquire a commercial fishing license in any state or to acquire a federal snapper/grouper permit.
2. All imports should be inspected and have tax tariffs imposed on them.
><> ><> ><> Capt. Gilbert Mathis F/V Atlantic Runner F/V Double Trouble & RUNNERS SEAFOOD 4824 - Highway 24 Morehead City / Newport, NC 28570 252-393-8474
To: South Atlantic Fishery Management Council
I have been fishing the South East Coast of the US for approximately 40 years. My father was a commercial / charter fisherman and so was his father. I grew up in a little town in Florida called Ponce Inlet just south of Daytona Beach. Everyone in this little town of about 150 people fished, shrimped, crabbed or made a living of some sort from the water. It was a wonderful place to grow up and to learn a trade and tradition that I thought would never end. Over the years I have observed huge catches of fish that now have come back to haunt us in the future with regulations that could destroy many lives and businesses. It’s unfortunate that we have allowed this industry to come to this. I have been for years proactive in my own venue in regulating what we catch so as not to completely destroy what we have so our children and grand children we’ll still be able to enjoy the fruits of the sea as we know it. People in general across the board with whatever they are doing are greedy. You see it in everyday life with many things. It’s a sad human trait. Self- control sometimes has to be implemented. In regards to my experiences in the fishing industry I have had many over the years. I have been in the charter and commercial fishing business all of my life and I have observed peoples reactions to regulating the industry. This is very hard for people who have invested their whole lives and have families and boat / home mortgages to pay. If regulations are so stringent as to completely devastate our business to become a non-profit situation then we lose everything. This effect could potentially have long term effects on not only the fisherman but the fish houses, restaurants, tackle shops, hotels, state and federal income tax and the list goes on. I know that when I was commercial fishing my mind set was to kill all and to catch as many as possible. Most will agree that it’s the more, more syndrome. More fish more money. Commercial fishing is a tough game. I know I was deep in it for years but, at some point you have to come to some sort of realization that things are going to change whether you want it or not. I started noticing reductions in catches years ago but I also noticed influx cycles and decrease cycles of different types of species from year to year. I observed fish in their natural habitat by scuba diving. I have recorded video of the reefs off of Charleston and the different types of fish that live in certain depths and how they respond to fishing pressure. I do know that commercially when fishing for the bottom fish such as Gag Grouper, Vermillion and Red Snapper that each fish responds to fishing a little different. They are all vulnerable but they do have some interesting characteristics. For instance Gag Grouper during January and February have a recruitment process in order to go to spawn. They migrate out to deeper water or further south to find the right temperatures and depth in order to commence the process. During this time frame they are very vulnerable and I have personally caught fish off of one spot while commercial fishing down to the last one. I knew this because I dove this spot afterwards to see for myself. I was personally terrified at what I saw, because at that point I realized the need to modify the way I was doing things. I had to adjust my own thinking and to revamp my business away from commercial and more towards charter in order to preserve the resource for the future. I slowly graduated myself away from full time commercial fishing into part time and then eventually completely separating myself and thrusting forward into the charter business full time. I did this in the late 90’s. I have seen a dramatic effect in regards to places that I used to commercial fish that I have left alone for years have rebuilt themselves with new recruitment of fish and because of self control and regulations that were put in place by the governing bodies it has been a great scenario for the charter fisherman. Having set catch limits have truly been an asset to this industry and I believe that set catch limits on the fish for the commercial sector such as what we have now for the charter sector could be beneficial to all. I know they wouldn’t want to swallow this and their will be a conflict but, It would be better than a complete closer. In regards to the Vermillion Snapper and Red Snapper, both of which have similar but also different characteristics. They too can be pressured down to just a few fish left on a particular spot as I have personally observed but, unlike the Gag they have a tendency to quit biting and to become wary and harder to catch after a period of time. Snapper in general have always had that reputation. I have also noticed with them that if you leave them alone for a few months they become less wary and are easier to catch. I also know that these fish group up for spawning time and find an area of little to no fishing pressure in order to do this. I remember the days of the so called bonanzas off of the Florida coast for these species and how now we are paying for it. I know that this is not going to be a easy decision but I implore you to not be to rash in this decision, especially when your dealing with peoples lives and livelihoods. I have my own suggestions to this situation and I hope that you will sincerely take a look at what I purpose in order to conserve and to protect our resource for the future. As I mentioned the commercial fishery is an industry that could use some regulations on the amount of fish per species caught. Trip limits such as the ones that are currently in force for the charter industry. This was done with the Red Porgies with great results and success and proved to be a defining factor that trip limits do work and can work for the commercial sector too! Closures to correspond with other fishery closures would make enforcement less of a headache and easier to accomplish. The Red Porgy and Gag Grouper are currently closed to commercial harvest from January till April annually. I suggest that you use this time frame for the recreational fisheries too. This would fall into a time frame of when these fish are spawning and gathering to spawn. Red Snapper could be added to this list without to much difficulty since they also fall into this same spawning time frame. This has been so successful in regards to the Red Porgy population that we are now inundated every trip with Red Porgies. If this is not enough then I also suggest for the recreational sector, who by the way always bows to the regulations and try’s very hard to work with the councils in regards to fishery management to reduce the catch limits by 50%. This would be a hard price to pay but in regards to some of the other options that I have seen would be doable and would still be a major step forward to end any type of overfishing of these species. I also suggest that the 250lbs. trip limit, the same amount set by the council during the emergency closer time for the Red Porgies be set in place for the Gag Grouper, Vermillion and Red Snapper as was done for the Red Porgies. This action was successful and has had noticeable results. This would be a measure that could work and after a period of time when the fisheries seem healthier and have rebounded such as the Red Porgies have then these restrictions could possibly be gradually relaxed. In regards to the circle hooks and venting devices. Snappers and Groupers I don’t have problem with we can make this work but, if we are restricted in the amount we can keep by 50% and have to diversify to other fish in order to keep fishing for something we have to be able to do this with some sort of results. Trigger fish and porgies are nearly impossible to catch on circle hooks. I have seen very few fish die in the waters under 160 feet due to the pressure. Occasionally we’ll have one but, maybe at the most one fish per day if that. The hooks we use currently on my boat are bronze only and if a fish is gut hooked and needs to be released you cut the line and he will survive. Their bile acids will eat a hook up in just a couple of days. Most fisherman will confirm catching fish with old eat up hooks still in there stomachs and throats that are just about completely gone. Just fragment left. I feel like requiring the use of non-stainless steel hooks and venting device tools a sufficient measure in protecting the fish from harm when released. I personally have a rule on my boat that if the fish is not long enough or we have our limit we release them as soon as possible without handling them which seems to be a much better method for their survival. We learned how to vent the fish properly from the aquarists of the South Carolina Aquarium. Before opening of the facility they made numerous trips on my boat catching fish for the aquarium and teaching us about how to take care of them, which by the way was quite a learning experience. This information was very valuable in helping us to release fish without harm and understanding the process of survival. We all want the same thing in the long run. You must know that no one wants the destruction of a resource that is so valuable to us all and we need to try and reason out a regulated enforceable method of control that will benefit and not destroy us in the process. There are also other factors that play into this equation to consider. I am absolutely positive that pollution is taking its toll on our reefs and I have seen this with my own eyes. Natural and unnatural causes, I could give a lecture on this. Foreign fisherman being allowed to fish in our waters with permits issued from our very own government. This is a slap in the face of U.S. fisherman since they don’t have similar regulations in their own countries. Law enforcement is stretched thin and with so may different types of things to have to check keeping it simple is a must in order to achieve thins goal. Most enforcement officers that have checked us recently don’t even know what type of fish they are checking they have to ask us what they are. Recreational weekend warriors as I call them catch fish all the time and keep them, over the catch and size limit. It’s frustrating to us when we try very hard to abide by the laws set forth by our government and see people keeping fish that aren’t legal. It seems unfair to us when we are the ones trying so hard to just stay afloat in this industry. I ask that you please take the time to review and understand all of the facts before making any decisions. I know it seems like your under a lot of pressure to accomplish this in a specified amount of time but, The Magnuson Fisheries Act has a clause in regards to making decisions on the economic effects and I believe you could convince anyone that extending a deadline on any final decision that could possibly effect many peoples lives needs absolute, positive, confirmation from as many resources as possible and studied and understood fully before any action is taken. I ask you to please consider this for the sake of us all. Thank You.
Sincerely, Capt. Mark Brown Charter Boat Teaser2 Mount Pleasant, SC 29466 (843) 881-9735 www.charlestonfishing.net
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LI Erc4n eic a; Council Members:
My name is Captain Tom Moran and I have been fishing Key West for 25 years. I have caught grouper Jan - March and do not see any roe during those months. I have noticed in these months of April and May the Black Grouper congregate and are heavy with roe. April and May are the 2 months grouper season should be closed to all recreational,commercial and charter vessels. April and May are the only 2 months I have seen grouper with eggs.
Thank you, Captain Tom Moran 954-818-1525
Re. Amendment 16:
No, I do not agree!!! It makes no logical sense and abusive to close so many species for protecting Gag Grouper. If you wish to Protect from overfishing, then you need to target the commercial fishermen who catch large quantities at a time. Do not go after the commercial vessels that cater to sport fishermen or sport fishermen who can manage bag limits.
Also, If you apply the rule only to Gag grouper, it would also be an acceptable solution.
Thank you,
Ted Mutch XM Satellite Radio, Inc. 3161 S.W. 10th Street Deerfield Beach, FL 33442 Office: (954) 571-4351 Cell: (954) 326-8689 Fax: (954) 360-2521
My name is Capt. Michael Nelson, I’m a second generation capt (along with all three of my brothers) and have been fishing the Atlantic waters off East central Florida from about the time I started walking. My father has been fishing the same waters for 55 years. He has seen alot of changes and I have seen a few of the same. I remember when their were no limits and you could fill the box every day with an assortment of fish. Then in about the early 80’s there was a decline in catches till about the early to mid 90’s when new regulations were put in place. Fishing started to get better and catches have continued to increases. Now its nice to be able to take a charter and pretty much guaranty them several red snapper and grouper, if not their limit. I think the science is way off and SAFMC admits that its not accurate. All or at least 90% of the reported numbers come from commercial boats, the charts that were shown at the meeting never took the decrease in amount of commercial vessels into account. My suggestion is to have a website that all the recreational vessels, including charter boats can go to and submit their catches for record. I think you’ll get more accurate numbers if you take both recreational and commercial into account. The regulations in place now are working, I don’t think any kind of closure or change in the size/bag limit are needed, the fish are there and on the increase. Thanks and hope this helps to make the right decision.
Capt.Mike hello,My name is capt.skip nielsen. I have been a professional charter capt. fishing out of budnmarys marina in Islamorada since 1971. gags and blacks are in serious trouble. I believe red groupers are in much worse shape. Most of the red grouper problem started with bottom longlining from the tortugas north. caught most of the big breeders in the deeper ledges. now blacks and gags are targeted by groups of commercial freediving spearfisherman all up and down the keys. these guys are very good at what they do. also people target the big blacks of key largo using live speedos for bait. there should be slot limits at the very least year round. I believe the grouper population needs a 5 year moratorium. look how the goliath population has rebounded. but if no moratorium at least amendment 16 will help. I listen to people whining about the short term. they do not see the big picture. like I wrote. i've been fishing since 1971. first it was fish traps then bottom longlining. now spearfisherman and just too many people fishing that really know how to catch. and...... no enforcement and poaching the nursury on the reef patches and westside of the keys in the rock holes. its sad so I hope you pass the amendment. if you need more imput from me do not hesitate to email me at. [email protected] captain skip nielsen p.o.box 697 Islamorada,Florida 33036 305 664 9314 thankyou and I hope these comments are considered
May 14, 2008
Sent via e-mail and U.S. mail Mr. George Geiger, Chairman South Atlantic Fishery Management Council 4055 Faber Place Drive, Suite 201 N. Charleston, SC 29405
RE: Public Hearing Draft Snapper-Grouper Amendment 16 (Gag and Vermilion Snapper)
Dear Chairman Geiger,
Ocean Conservancy1 is writing to provide the following comments on the South Atlantic Fishery Management Council’s (SAFMC) preparation of public hearing draft for Amendment 16 to the Snapper-Grouper Fishery Management Plan (Amendment 16) intended to end overfishing of gag grouper and vermilion snapper in the South Atlantic.
Summary
In general, we support the development of this DEIS and urge the SAFMC and NMFS to act swiftly to implement certain management measures assessed in this environmental review document that will be sufficient to end overfishing and achieve optimum yield of gag and vermilion snapper. We are encouraged by, and support the selection of preferred alternatives for many of the actions listed in the DEIS (Ocean Conservancy takes no position on the allocation actions in this document). We believe that if these current preferred alternatives are finalized and implemented, they will go a long way in ensuring the sustainable management of these two important fish stocks and reduce mortality in the commercial and recreational fisheries to levels consistent with legal mandates designed to ensure healthy fisheries and productive ecosystems.
Our comments (explained in detail below) are summarized here: • We support the Council’s preferred alternatives for setting the MSY and OY status determination criteria for gag (Alternatives 2 and 2b) and vermilion snapper (Alternatives 2 and 2b) as defined by SEDAR;
1 Ocean Conservancy is a non-profit organization with more than 150,000 members who seek to promote healthy and diverse ocean ecosystems. Through research, education, and science-based advocacy, Ocean Conservancy informs, inspires and empowers people to speak on behalf of the ocean. • We support the Council’s preferred alternatives for setting TAC for gag (Alternative 2) and vermilion snapper (Alternative 2) at the F(oy) level; • We support the Council’s preferred alternatives for management measures to achieve the commercial portion of the TAC for gag (Alternative 3) and vermilion snapper (Alternative 2) and to implement a commercial and recreational gag spawning closure (Alternative 2); and • We support the Council’s preferred alternative to require gear to reduce bycatch in snapper grouper species (Alternative 2c).
Background
Gag were identified as having overfishing occurring in the Southeast Data Assessment and Review process number ten (SEDAR 10). Stock assessment models reveal that overfishing is occurring and that males have been reduced down to 8% of the population.2 We therefore recommend that the National Marine Fisheries Service (NMFS) and the SAFMC institute management measures that end overfishing immediately, achieve optimum yield, incorporate appropriate buffers to ensure that overfishing is ended and prevented, count and minimize bycatch, and protect essential gag spawning areas and depleted male gag in the South Atlantic.
Vermilion snapper was identified as undergoing overfishing in 20073. Despite the assertion in Snapper-Grouper Amendment 13C that a total allowable catch (TAC) of 1.1 million pounds (gutted weight) was sufficient to prevent overfishing, the current estimate of fishing mortality is more than twice the rate identified as F(max). We therefore recommend that NMFS and SAFMC adopt management measures that implement catch limits that immediately end overfishing and achieve optimum yield, incorporate appropriate buffers to ensure that overfishing is ended and prevented, and include measures to count and minimize bycatch. We urge that management measures for both these species be approved for submission to the Secretary of Commerce at the June council meeting in accordance with the legal timelines for ending overfishing.
Applicable Law
Pursuant to the Magnuson Stevens Fishery Conservation and Management Act (MSA) the National Marine Fisheries Service (NMFS) and SAFMC must prepare a fishery management plan, plan amendment or regulations to end overfishing of any population of fish within one year of being identified as undergoing overfishing by NMFS.4 The Fisheries Service has made the determination that gag and vermilion snapper are indeed undergoing overfishing and that the year timeline comes to an end in June.5
The MSA now requires councils to “develop annual catch limits for each of its managed fisheries that may not exceed the fishing level recommendations of its science and
2 SEDAR 10. 3 Vermilion Snapper SEDAR Update Process #3 4 16 U.S.C. §1854(e). 5 Dr. Roy Crabtree (NMFS) letter to SAFMC Chairman Geiger dated June 12, 2007. statistical committee (SSC).”6 Those SSC recommendations must “prevent overfishing” and “achieve rebuilding targets.”7 By 2010, the South Atlantic Council must also develop specific targets in management plans called “annual catch limits” that prevent overfishing and incorporate accountability measures to ensure those limits are not exceeded.8 While this additional mechanism to ensure an end to overfishing is not immediately required, the South Atlantic Council should proactively implement this mechanism both to save time in rule development and because it is clear that overfishing continues to be an issue and additional safeguards now, rather than in two years, will benefit the sustainable management of these species.
In addition, any fishery management plan amendments must establish a standardized reporting methodology to assess the amount and type of bycatch occurring in the fishery and include measures that minimize bycatch and unavoidable bycatch mortality to the extent practicable.9 This requirement was recently underscored by a federal court decision relating to a Gulf of Mexico reef fish, red snapper.10 Furthermore, fishery management plan amendments must contain provisions to minimize, to the extent practicable, adverse impacts of fishing on essential fish habitat.11
Specific Recommendations for Amendment 16
Gag Management Reference Point Alternatives (2.1.1.1) For species that are not identified as overfished, management measures must achieve optimum yield (OY) on a continuing basis. In order to accomplish this, an OY, or process for determining an annual OY must be detailed. The national standard guidelines recommend expressing OY in terms of numbers or weights of fish but provide other options for determining this parameter.12 Target reference points, such as OY should be set safely below limit reference points – potentially a catch level associated with fishing mortality rate or some other level defined by the status determination criteria.
This approach is consistent with the trend in fisheries management of treating MSY as a management limit that should rarely be exceeded and using OY as a management target safely below the MSY threshold. This change in approach is based on past experiences of overfishing occurring despite MSY based management.13
We support Preferred Alternative 2 that sets gag maximum sustainable yield (MSY) at the level defined by the SEDAR process and Preferred Alternative 2b defining
6 16 U.S.C. § 1852(h)(6). 7 16 U.S.C. § 1852(g)(1)(B). 8 16 U.S.C. § 1853(a)(15). 9 16 U.S.C. §1853(a)(11) and 16 U.S.C. §1851(a)(9). 10 See CCA et al. v. Gutierrez, 4:05-cv-01214, slip op at 9 (Texas S.D. March 12, 2007) (holding that each plan or amendment must address bycatch). 11 Id. at §1853(7). 12 50 CFR §600.310(f)(4). 13 Goodman, et. al, 2002. Draft Scientific Review of the Harvest Strategy Currently Used in the BSAI and GOA Groundfish Fishery Management Plans. Report prepared for the North Pacific Fishery Management Council. optimum yield (OY) at 75% of F(msy). We would note, however, that it is not enough to merely put an OY goal to paper, and specific management measures must have a very high percentage chance of achieving this goal on a continuing basis.
Gag Total Allowable Catch (2.1.1.2) As discussed above, the appropriate management standard for gag is the attainment of OY on a continuing basis. In addition to considering ecosystem considerations and management uncertainties, an OY management target should contain a significant buffer with the threshold (MSY) so that short term fluctuations will not trigger overfishing. We therefore recommend the Council adopt Preferred Alternative 2 that sets the TAC for 2009 onwards at the yield at F(oy).
Gag Management Measures (2.1.1.4) We commend NMFS and the Council for considering bycatch of gag and explicitly subtracting the anticipated post-quota bycatch mortality (PQBM) from the allowable catch. We support both the creation of a hard commercial quota and the use of the PQBM concept that was endorsed by the SSC and used in Amendment 15a. We commend NMFS and the Council for further considering the bycatch of gag during the proposed spawning season closure in this action by prohibiting the harvest and possession of species that co-occur with gag, many of which have their own conservation concerns or have their population status unknown. We therefore recommend that the Council adopt Preferred Alternatives 2 and 3 in this action.
We do not have any recommendations for specific measures to achieve necessary reductions in recreational gag grouper fishing mortality, but offer a consideration for managing that sector of the fishery. Because of the absence of accountability measures and overage pay-back provisions in this document, it is critical to enact regulatory measures that have the appropriate probability of achieving the management targets – in this case the F(oy) target from the section titled “Gag Total Allowable Catch.” The possibility exists for optimistic assumptions about management effectiveness and effort shifts to compromise the ecological and economic integrity of the gag fishery. Management measures in the recreational gag fishery must have – consistent with the Technical Guidance for implementing National Standard 114 – an 80% chance of achieving the OY target set forth in the gag TAC action. Failure to achieve this probability of success would, we believe, fall short of the legal requirement to end and prevent overfishing under the Magnuson Act. Setting an OY-based target for fishery management is not merely an academic exercise, but a mandate that must then be followed up with measures to achieve the goals set forth by Congress with appropriate probability of success. We therefore encourage the SAFMC to give this consideration when setting Annual Catch Limits, Overfishing Limits and the buffer between the two.
Vermilion Snapper Management Reference Point Alternatives (2.1.2.1)
14 Restrepo, V.R. (convener), et. al 1998 Technical Guidance on the Use of the Precautionary Approaches to Implementing National Standard 1 of the Magnuson-Stevens Fishery Conservation and Management Act. NOAA Technical Memorandum NMFS-F/SPO-31, NOAA/NMFS 2004. For species that are not identified as overfished, management measures must achieve OY on a continuing basis. In order to accomplish this, an OY, or process for determining an annual OY must be detailed. The national standard guidelines recommend expressing OY in terms of numbers or weights of fish but provide other options for determining this parameter.15 Target reference points, such as OY should be set safely below limit reference points – potentially a catch level associated with fishing mortality rate or some other level defined by the status determination criteria.
This approach is consistent with the trend in fisheries management of treating MSY as a management limit that should rarely be exceeded and using OY as a management target safely below the MSY threshold. This change in approach is based on past experiences of overfishing occurring despite MSY based management.16
We support Preferred Alternative 2 that sets vermilion snapper maximum sustainable yield (MSY) at the level defined by the SEDAR process and Preferred Alternative 2b defining optimum yield (OY) at 75% of F(msy). We would note, however, that it is not enough to merely put an OY goal to paper, and specific management measures must have a very high percentage chance of achieving this goal on a continuing basis.
Vermilion Snapper Total Allowable Catch (2.1.2.2) As discussed above, the appropriate management standard for vermillion snapper is the attainment of OY on a continuing basis. In addition to considering ecosystem considerations and management uncertainties, an OY management target should contain a significant buffer with the threshold (MSY) so that short term fluctuations will not trigger overfishing. We therefore recommend the Council adopt Preferred Alternative 2 that sets the TAC for 2009 onwards at the yield associated with 75%*F(msy).
Vermilion Snapper Management Measures (2.1.2.4) We commend NMFS and the Council for considering bycatch of vermilion snapper and explicitly subtracting the anticipated post-quota bycatch mortality (PQBM) from the allowable catch. We support the use of the PQBM concept that was endorsed by the SSC and used in Amendment 15a. We therefore recommend that the Council adopt Preferred Alternatives 2 in this action. Preferred Alternative 3 appears to be a way to reduce the race for fish and we do not object to splitting the quota into two seasons.
We do not have any recommendations for specific measures to achieve necessary reductions in recreational vermilion snapper fishing mortality, but offer some considerations for managing the recreational fishery. Because of the absence of accountability and pay-back provisions in this document, it is critical to enact regulatory measures that have the appropriate probability of achieving the management targets – in this case the F(oy) target from the section titled “Vermilion Snapper Total Allowable Catch.” The possibility exists for optimistic assumptions about management effectiveness
15 50 CFR §600.310(f)(4). 16 Goodman, et. al, 2002. Draft Scientific Review of the Harvest Strategy Currently Used in the BSAI and GOA Groundfish Fishery Management Plans. Report prepared for the North Pacific Fishery Management Council. and effort shifts to compromise the ecological and economic integrity of the vermilion snapper fishery. Management measures in the recreational vermilion snapper fishery must have – consistent with the Technical Guidance for implementing National Standard 117 – an 80% chance of achieving the OY target set forth in the gag TAC action. Failure to achieve this probability of success would, we believe, fall short of the legal requirement to end and prevent overfishing under the Magnuson Act. Setting an OY-based target for fishery management is not merely an academic exercise, but a mandate that must then be followed up with measures to achieve the goals set forth by Congress with appropriate probability of success. We therefore encourage the SAFMC to give this consideration when setting Annual Catch Limits, Overfishing Limits and the buffer between the two.
We strongly oppose raising the size limit of vermilion snapper any further. Specific attention must be paid to using size limits as a management tool. As past managers attempted to deal with the failing health of snapper-grouper populations they were primarily guided by short term economic concerns. They therefore increased the legal size of fish that could be landed in an attempt to slow down the rate of capture to extend the fishing season. This resulted in high numbers of fish that are slightly below the legal size limit being thrown back dead or dying as bycatch. Changes in size limits must be analyzed as a way to reduce both commercial and recreational discards in these fisheries. While size limits may prove useful for some fish, they may not be appropriate for others. Changes in size limits should be based on biology and the reduction of bycatch of snapper-grouper species, not misguided attempts to slow the rate of capture. Raising the vermilion size limit further appears to be in direct contradiction to National Standard 9 which lists as its primary mandate to reduce bycatch and as a secondary directive to reduce the mortality of such bycatch.18
We do, however, find biological merit to the simultaneous closure of gag and vermilion snapper to harvest. Bycatch and bycatch mortality continue to be an impediment to ending overfishing and rebuilding fisheries that target snapper and grouper in the Southeast. In some instances, bycatch itself is the cause of overfishing (see SEDAR 15 South Atlantic Red Snapper) and falls under the mandate of National Standard 1. Complimentary closures of co-occurring species in need of large harvest reductions appear to offer a solution to this complicated problem.
Reduce Bycatch of Snapper Grouper Species (2.1.3) As noted above, reducing the mortality of discarded fish is a secondary priority if and only if the reduction in fish discarded as bycatch cannot be achieved. That said, we urge NMFS and the Council to adopt any measures that can help reduce discard mortality in both the commercial and recreational snapper grouper fisheries. We fear (based on
17 Restrepo, V.R. (convener), et. al 1998 Technical Guidance on the Use of the Precautionary Approaches to Implementing National Standard 1 of the Magnuson-Stevens Fishery Conservation and Management Act. NOAA Technical Memorandum NMFS-F/SPO-31, NOAA/NMFS 2004. 18 50 CFR §600.350(a)(1). analysis done on similar gear modification for the Gulf of Mexico red snapper fishery19) that these measures will not have a significant impact on bycatch mortality, but support the adoption of Preferred Alternative 2c as a step towards achieving the Congressional mandate articulated in National Standard 9 and realizing the forgone yield due to bycatch mortality.
Allow NMFS Regional Administrator (RA) to Make Adjustments to Vermilion Snapper Management Measures While we appreciate the unfortunate situation NMFS and the Council are in with regard to the timing and substance of vermilion snapper stock assessments, we remain concerned that this action sets an unfortunate precedent in the South Atlantic for development of management measures to address conservation issues identified by the best available science within the legally allowable timeline. Time and again fisheries of the Gulf and Atlantic coasts have suffered for delays that have been made in the name of collecting, analyzing or generating more or better science. Congress has made it clear that these types of delays, and the chronic overfishing that they enable, will not be tolerated. We are hesitant to support measures that feed the mentality that delay and inaction will bring more palatable results. Yet it is impossible to ignore the dramatic difference that incorporation of age information made to the recent Gulf of Mexico vermilion snapper stock assessment. For this reason, we are putting our substantial reservations aside, albeit with great trepidation. We appreciate NMFS and the Council pressing forward with this amendment with all deliberate haste to date, and encourage swift – if not immediate – submission to the Secretary of Commerce.
Implementation Timeframes
The SAFMC and NMFS must ensure that management measures to end overfishing of gag grouper and vermilion snapper are implemented as quickly as possible. We urge completion of this amendment and submission to the secretary at the June council meeting as the one-year time limit for its preparation expires June 12, 2008.
Conclusion
Essential to the sustainability of any fishery resource is ensuring that annual mortality targets and limits – that account for both landed catch and bycatch – of a species end and prevent overfishing, that appropriate buffers are in place to ensure an appropriate likelihood of success, that abundant levels of prey species exist and that habitats used by these species and their prey are protected. The MSA requires that fisheries are managed to achieve optimum yield on a continuing basis, not simply to prevent overfishing at the MSY level.20. We are encouraged by the preferred alternatives indicated in the DEIS for Amendment 16 and are supportive, in general, of its contents. We applaud the South Atlantic Council and the Fisheries Service for their leadership and commitment to the
19 Draft Supplemental Environmental Impact Statement (DSEIS) for Amendment 27 to the Reef Fish Fishery Management Plan (Amendment 27) and Amendment 14 to the Shrimp Fishery Management Plan at 209, GMFMC, April 2007. 20 16 U.S.C. § 1851(a)(1). critically important issue of ending overfishing and ensuring sustainability of our public trust resources.
Ocean Conservancy appreciates the opportunity to comment on the Public Hearing Draft of Amendment 16 to the Snapper Grouper Fishery Management Plan. We look forward to working with the SAFMC and NMFS in the future to ensure the sound management of South Atlantic fishery resources.
Sincerely,
Elizabeth H. Fetherston Southeast Fish Program Manager Ocean Conservancy 449 Central Ave. Suite 200 St. Petersburg, FL 33701 Dear Council Members-
The Fishing Rights Alliance (FRA) is comprised of recreational anglers, for-hire captains and commercial permit holders united in the pursuit of sound, fair management of marine fisheries for sustainable harvest. United by the bond of fishing, we join together to urge you to consider the following suggestions for Amendment 16.
We must point out for the record that the South Atlantic Gag stock assessment was prepared alongside of the Gulf of Mexico’s own Gag assessment. The two assessments were done by the same groups of scientists and we fear, suffer from similar problems. The Natural Mortality Rate, M, used in both assessments appears to be overly precautionary and not reflective of the stock.
It was of such grave concern that the Gulf Council has delayed action until their own SSC can review the information and concerns presented by Dr. Trevor Kenchington, representing the FRA and SOFA- essentially the commercial and recreational sector representatives. We urge the Council to invite Dr. Kenchington to your June meeting. Dr. Kenchington will have material prepared for your SSC in advance of their meeting.
We are profoundly concerned with the OVERLY precautionary assumptions and levels used in developing the need for these regulations. We urge you to review the astoundingly low estimated economic impact of these regulations. The implications are troubling.
Dr. Kenchington will provide our scientific input for suggested values for Natural Mortality, Foy, MSY and other levels that are currently, in our opinion, overly precautionary and cause a false indication of a troubled stock. We urge the Council to give heavy consideration to the economic and social implications of any new regulations, as set forth by the National Standards.
We have concerns with the Gag assessment as well as the management alternatives being developed. Provide the numbers for and consider as an alternative a 26” Gag minimum size limit (20% or more reduction in recreational landings alone) as the FIRST tool applied to the fishery.
Effort is reduced by close to 50% from 2004, while per capita expenditures for offshore fishing have increased. In other words, the same people are spending more money per year and taking fewer trips per year, meaning the cost of a trip has nearly doubled in four years.
The opportunity to fish is the driver of the fishery. Closing fishing for a third of the year and reducing the bag limit the remainder of the year is tantamount to killing the heritage of fishing and the fishing industry. Why do this when you can CONSTRAIN effort AND reduce landings by raising the minimum size by ONLY TWO inches while minimally impacting the OPPORTUNITY to fish? The economic impact of a two inch size increase would be negligible, yet landings would be reduced by 20% with NO CLOSED SEASONS and NO BAG LIMIT REDUCTION. This is truly a win-win solution. Yet we see nothing about this as an alternative. The FRA wonders what forces have prevented this from being done.
In closing, we urge the Council to:
1. Review the Natural Mortality Rate of Gag. 2. Review and adjust the overly precautionary estimates. 3. Provide the numbers for and consider as an alternative a 26” Gag minimum size limit (20% or more reduction in recreational landings alone) as the FIRST restriction applied to the fishery. 4. Invite Dr. Trevor Kenchington to the June SSC/Council meeting in Orlando, FL. Dr. Kenchington has extensive knowledge of both the Gulf of Mexico and the South Atlantic fisheries. The FRA, SOFA and the Gulf Partnership would be happy to make Dr. Kenchington available, as we have to the Gulf Council. It should be noted that the Gulf Council invited Dr. Kenchington to their April meeting and then to a specially convened SSC meeting in May. 5. Consider the reduced effort that is a result of increased fuel prices which are projected to increase for the foreseeable future. Most recreational offshore boats either will or do now cost over $5 per MILE to run. In 2004, that cost was less than $2.
Thank you for the opportunity to express the views and concerns of the FRA membership.
Dennis O'Hern Executive Director
Fishing Rights Alliance 4604 49th Street North, #34 St. Petersburg, FL 33709
727.692.6902 www.joinFRA.org
Dear SAFMC,
My name is Geoffrey Owens,I have been a commercial fisherman/spear fisherman for the last twelve years. I am currently captain of the F/V Rolling Thunder out of St. Augustine,FL. I average twenty five to thirty commercial trips a year,make over 500 dives from 60-180 ft. I fish from Frying Pan Shoals to West Palm Beach ,FL Commercial fishing is my lone source of income that supports me and my family of four.
I am writing in concern of amendment 16. I am in strong disagreement of this amendment. At the last meeting I attended in Daytona Bch,Fl the council presented amendment 16.In the preface the council said that vermilion snapper as of 2004 was undergoing overfishing,but also admitted that they did not believe that the sedar assessment data was correct. How can you legally make a law on inaccurate data?In 2006 vermilion snapper went to a TAQ of 1,100,000 lbs. Has this quota ever been met? If overfishing was occurring wouldn't we be meeting our quota? I know the sedar assessment is based on a mathematical equation based on how many fish are being caught,or how many fish you think are being caught. This method may work for people that sit in an office and never see the ocean, but to make legal decisions that will have severe socio-economic impacts doesn't work for me and the thousands of families you affect.
The truth is you have no idea how many fish are out there, if you did then the vermilion snapper would not be in question. Within the last three years these fish have made outstanding progress in the areas I fish and dive. We are catching vermilion snapper in places we have never caught them. We are catching larger fish in shallower depths. I have worked on head boats since 1991 and have never seen the size of fish we are catching in shallow water. Normally,we don't catch commercial size fish in less than twenty-one fathoms,this year we were able to target them for sustainable catches in 85 ft. I believe this is hardly a characteristic of a species that is overfished. In my diving experience,I have seen vast schools of vermilion snapper in 110-170 ft. This year I have witnessed schools in areas where I've never caught a vermilion snapper. I would sugge st that you let me take an observer with a underwater camera to document this. Ihave offered my vessel in the past to take observers with no response. Please tell me the council is interested in better data collection. When we fish on these schools,a good catch is 200-400 lbs. Typically they quit biting after you swing off the spot. During spawning phases they will bite better. A good catch for a five day trip would be 2500lbs.
I am in favor of a 1500 lb. trip limit,to insure the sustainability of this fishery. I think a one inch increase in the size limit would also help. As far as the recreational closure I believe is unnecessary,this will have severe impacts on the charter boat industry. Head boat tickets for a one day trips are around 65-80 dollars per person. Nobody will pay this much to catch four vermilion snappers. The vermilion snapper is the backbone of the commercial and charter boat fishing industry in Northeast Florida,and with rising fuel costs it is harder and harder to make a living. Please find a better management alternative for this fishery.
In reference to the gag grouper,these fish do not spawn off Northeast Florida until late March so a Jan.-Feb closure is unessacary. At the Daytona meeting I proposed a complete closure recreational and commercial in March and April to crate a unmolested bio-mass during the spawning season. I propose this in addition to raising the size limit to 28 inches. Keep this measure for gag grouper only,do not include the rest of the grouper complex,we must have scamp and red grouper to fish for during the gag closure. And no regional closures,I believe this measure is illegal and will do no good. As boats from one region will fish in the other so how could you accurately keep track of the quota?
Thank you for your attention in this matter.
Sincerely,
Captain Geoffrey Owens.
Please allow April and May for Grouper. Thanks for your consideration.
Regards, Bob Papke
From: Mark Purcell 151 Eber Road Apt. 607 Melbourne, Florida 32901 Phone: 321-725-1895 Email: [email protected]
I recently attended the Public Hearings/Scoping meeting on 5-9-08 in Port Canaveral Fl., and would like to submit the following commits to go on record before the SAFMC Council.
I encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. By the Council’s own estimate, this fishery is currently not over fished. I believe that the current regulations are doing a great job of maintaining the health of this fishery, and the SAMFC’s preferred alternatives would have a severe negative impact on the benefits this fishery provides economically to the coastal communities.
I am against alternative 2 (Spawning season closure January through April) seeing how there is no reliable data on recreational landings on which to base this closures benefit. I would suggest an alternative closure of all commercial harvest by spear fishing during the months of June, July and August. This would protect the fishery during the coldwater up-welling, when the fish become very lethargic and overly vulnerable to this harvest method.
I encourage the SAFMC to adopt Alternative 3 (Directed Commercial Quota)
I encourage the SAFMC to adopt Alternative 4 (Divide Directed Commercial Quota into 2 regions). I would support the recreational sector within Florida as also being divided into a separate management area.
I am against Alternative 5a (Reduce the bag limit from 5 to 3 grouper and January-April season closure). I believe this places additional undo restrictions on the recreational and charter/head boat fleet, without similar reductions in the commercial landings quota. I would suggest an alternative closure of all commercial harvest by spear fishing during the months of June, July and August. This would protect the fishery during the coldwater up-welling, when the fish become very lethargic and overly vulnerable to this harvest method.
I am against Alternative 5b (December - April closed season, retain the current bag limits). I would suggest an alternative closure of all commercial harvest by spear fishing during the months of June, July and August. This would protect the fishery during the coldwater up-welling, when the fish become very lethargic and overly vulnerable to this harvest method.
I encourage the SAFMC to adopt the alternatives to reduce by-catch mortality by requiring the use of venting/de-hooking tools and circle hooks. However to help gain public support and ensure compliance with these new measures, I would suggest simply requiring “circle hooks” and not defining their exact material or geometric make up at this time..
Concerning the Council’s proposed alternatives for the vermilion snapper fishery. I do not have sufficient experience and or knowledge of this fishery to provide any meaningful comments for the Councils consideration.
Sincerely,
Mark Purcell
Re. Amendment 16:
My input on this plan is No, do not agree---to close so many specie for the stated reason of protecting Gag Grouper is downright abusive to those of us that depend on the resource and does not make any logical sense. Fix this rule to protect Gag grouper only and it becomes more acceptable. thank you,
Oscar Reyes Naltron Corp cell(954)448-0501 direct connect 159*172159*1 fax (954)370-6188
I, cannot believe this!!!! Every Alternative that was presented today 5/12/08 was in favor of the commecial fishermen. From what I also observed from this scoping meeting , is that this is a done deal. I am not surprised with big money and powerful LOBBYIST what is fixing to happen to the recreational TAX PAYER . From the slides I saw the commercial fisherman should have the biggest restriction, because they do the most harm. The economy is terrible and this move is going to DESTROY recreational fishing as we know it. Why would I buy a boat to catch one fish? The economy has already begun to take its toll on rec. fishing, high gas prices, weekend warriors, bad weather,etc. ,has allowed my family and myself to fish a total of six offshore trips in 2007. So your fish count on my behalf is bogus. I know that Iam just one person, one vote, but I have a very large family(with a bunch of votes) that feels the same way I do. I have read were an economic study in the state of GA. alone that 350millon plus dollars from recreational versus 57 millon commercialy (crabbing shrimping,and fishing)... This should be a NOBRAINER .... and a new ALT. should be applied 60percent recreational 40 percent commercial. Another part I cannot believe is that, commercial fishermen will be allowed to fish until ther quotas are filled even into the propsed closed seasons. This is a slap in the face. It is apparent that commonsence is not a consideration of every day people of this matter. Do not get me wrong I want fishing for generations to come, and so let us reconsider where the biggest waste, who is doing the harm to the grouper snapper fisheries. If you close it for REC. then you better close it for the commercial.... I recently read an article in the WOODSNWATER periodical about what the Gulf council was trying to do based on information given by the NMFS. This was put on hold due to some bad information from the NMFS. Who checks these commercial vessels of their catch? I know they would not lie. To determine the accuracy of the commercial catch, why can't we have goverment inspector at each commercial facility? (We have meat inspectors) This is very frustrating to think ONE more freedom is being shutdown due to BIG GOVERMENT AND BIG BUSINESS once again. In closing just my pesonnel belief is that big time lobbist has won one more time.
Dean Robinson Grouper Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFCs own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely by-catch mortality and habitat destruction from trawling and long line activities. I believe that NO CHANGES are required at this time, and the SAMFCs preferred alternatives would have a drastic economic impact.
I am against alternative 2 (Establish a gag spawning season closure January through April...) in that there is no reliable data on recreational landings to support this position. This alternative places a greater burden on the recreational sector. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I support Alternative 3 (Directed Commercial Quota)
I support Alternative 4 (Divide Directed Commercial Quota into 2 regions). In addition, I support the regional management of the recreational sector with Florida being a separate management area
In reference to Alternative 5. Recreational measures:
I am against Alternative 5a (Reduce the 5-grouper aggregate bag limit to a 3- grouper...January-April fishery closure). This alternative places an unfair burden on the recreational sector without a comparable reduction to the commercial landings. I am against alternative 5 in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I am against Alternative 5b (December - April closed season, retain current bag limits...). I am against alternative 5b in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Amendment 16 also includes alternatives to reduce by-catch mortality by requiring the use of venting/dehooking tools and circle hooks. I agree with this as it reduces mortality and aid in the recovery of the stocks.
Vermilion Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The spikes in this fishery have been caused by the SAMFC shifting pressure from the Sea Bass fishery which in turn has concentrated pressure on the Vermilion fishery. In addition, the explosion of the Goliath Grouper populations is putting increased pressure on this fishery. I would suggest a limited take/season on the Goliath Grouper fishery.
I am against Alternative 2 (Interim Allocations). I would suggest that SAMFC increase data collection on both the fishery health and fishery utilization before enacting any changes. In addition, a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Sincerely, robert rodriguez - leave everything as it is. stop implementing things that affects recreational fishing for the fishing public
Please do not pass this admendment at this time. There are too many commercial fishermen, and fishing business concerns that are struggling to make a living with the price of gas close to $4 per gallon and diesel at $5 per gallon. Everyone needs a break right now when they have families to feed. Sinerely, Judyn Safewright Grouper Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The grouper fishery is not over fished, and current economic conditions and fuel prices are already decreasing fishing pressure on most Grouper species. By SAMFCs own estimate, this fishery is currently not over fished, and the data being used was collected before drastic increases in fuel cost that have decreased pressure on this fishery. In addition, I would suggest that the SAMFC look into ways to reduce or eliminate completely by-catch mortality and habitat destruction from trawling and long line activities. I believe that NO CHANGES are required at this time, and the SAMFCs preferred alternatives would have a drastic economic impact.
I am against alternative 2 (Establish a gag spawning season closure January through April...) in that there is no reliable data on recreational landings to support this position. This alternative places a greater burden on the recreational sector. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I support Alternative 3 (Directed Commercial Quota)
I support Alternative 4 (Divide Directed Commercial Quota into 2 regions). In addition, I support the regional management of the recreational sector with Florida being a separate management area
In reference to Alternative 5. Recreational measures:
I am against Alternative 5a (Reduce the 5-grouper aggregate bag limit to a 3- grouper...January-April fishery closure). This alternative places an unfair burden on the recreational sector without a comparable reduction to the commercial landings. I am against alternative 5 in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks.
I am against Alternative 5b (December - April closed season, retain current bag limits...). I am against alternative 5b in that there is no reliable data on recreational landings to support this position. Further a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Amendment 16 also includes alternatives to reduce by-catch mortality by requiring the use of venting/dehooking tools and circle hooks. I agree with this as it reduces mortality and aid in the recovery of the stocks.
Vermilion Alternatives
I STRONGLY encourage the SAFMC to adopt Alternative 1 and to make no changes to the current regulations. The spikes in this fishery have been caused by the SAMFC shifting pressure from the Sea Bass fishery which in turn has concentrated pressure on the Vermilion fishery. In addition, the explosion of the Goliath Grouper populations is putting increased pressure on this fishery. I would suggest a limited take/season on the Goliath Grouper fishery.
I am against Alternative 2 (Interim Allocations). I would suggest that SAMFC increase data collection on both the fishery health and fishery utilization before enacting any changes. In addition, a ban of all long lining and pushing shrimping out past 30 fathoms would have a greater and faster result in rebuilding the stocks).
Sincerely, Anthony Sartori, Merritt Island florida, I'm a commercial fisherman out of port canaveral florida. I have been doing this many years. I believe you all have it wrong. I hook and line fish and I commercially dive. I have experiened most of floridas waters first hand. It is my belief that you have allowed the fishery to become unbalanced due to hard regs on snook, redfish and goliath grouper. These fish all prey on juvenile snapper and grouper. If you dive any wreck you will be amazed at how many very large snook there are and how many goliaths. Redfish devastate the spawning beds of fish. The balance isn't there. I have had 400lb plus goliaths eat 20 lb snapper off my spear. I have had them eat an entire ring of flounder off my belt. I have seen snook in a feeding frenzy eating young fish of all sorts. I have seen redfish as big as ones leg, tear up spawning beds.I experience all this first hand. I go everyday the weather allows. To close a fishery on old BAD Data is bad business.It will again set off a Bad balance in nature. You don't have it right now.By closing it you won't have it right either. Regs need to be lighter on snook, redfish, and an opening for goliaths. Most commercial fishermen I talk to, say to just open them to rec anglers. I agree, allow a more open slot limit for snook and redfish allow them to take more then 1, allow them to have a lottery for taking of goliath grouper.This will allow some to be taken, to help the balance of the snapper /grouper fishery. Now it is all about the money generated from the snook and redfish. But due to greed We have allowed them to get to where they are top preditor eating what they want anyime anywhere. Now We look to take away ones livelyhood in another fishery, on flawed data. You are welcome on My boat. I will show you more snapper and grouper then any of you have seen. It isn't bad like you say. But it could be if you allow this unbalanced fishery to go on. Again you are invited on my boat to do surveys and to get proper Data,to make the right decision based upon facts and not flawed data. Remember when a Recreational angler claims there aren't any fish ask them how often do they go and how well do they know how to fish? Fish aren't as dumb as one might think they adapt like We do. Please feel free to call 321- 208-8022.I was at the snapper grouper meeting at port canaveral .I don't want to see this fishery ruined due to people who are going on data that is not correct and based upon other statements from people who don't know the fishery first hand . Again feel free to call Anthony Sartori
From: Gus Schage [mailto:[email protected]] Sent: Monday, May 12, 2008 7:48 AM To: Kim Iverson Subject: fishing regulations
I RESPECT THE JOB THE MANAGAMENT COUNCIL HAS AT IT,S CHARGE . I FEEL THE SAFMC IS OUT OF TOUCH WITH THE PEOPLE AND THE TRUE NUMBER OF FISH TAKEN. THE EVERYDAY PERSON JUST DOES NOT IMPACT THE GROUPER AND VERMILLION SNAPPER STOCK THAT MUCH. I ONLY AVERAGE ABOUT 50 HOURS A YEAR ON MY BOAT AND I THINK THAT I AM ABOVE AVERAGE BOTTOM FISHERMAN. MY BOAT LAST YEAR, 2007 HAD A TOTAL OF NINE GROUPER, WITH TWO OF THEM RED GROUPER AND THE REST GAGS. I OWN A BOAT TO FISH I ONLY KILL WHAT I AM GOING TO EAT. I GUS SCHAGE CAN NOT BELIEVE THAT THE SAFMC HAS THE BEST INTEREST OF THE NON COMMERCIAL FISHERMAN.
Snapper Grouper Amendment 16 (gag and vermillion) Comments:
Marginal science and biased econo-centric leanings by the South Atlantic Fishery Management Council (SAFMC) is driving the commercial snapper/grouper fishery into extinction. The management strategy employed by SAFMC will eventually render profitability impossible for commercial fishermen in this sector of the wild caught fishery. Ironically the best data allowing scientist to assess fish stock status will be lost with this fishery.
Accountability in the commercial snapper/grouper fishery is rock solid in contrast to the less than anecdotal guess work used to quantify the recreational catch totals. Restricting only the commercial sector by prohibiting the catch of these fish once their annual quota is filled is an attempt to solve less than fifty percent of the problem.
The only restriction at this closure time on the recreational sector will be no sale of the bag limit. This is only a loss of a commercial feature not normally associated with a recreational activity and will reduce the rate of increase in stock biomass. Fair and equitable treatment demands accountability from all sectors involved in the fishery
Science-based corrective action can only be accomplished with reliable data collection and this is not being done for the recreational sector. This deficiency of viable scientific data coupled with demands for a myopic bottom-line only consideration will not adhere to the “fair and equitable” mandate.
The Alliance could ask that Alternative 1 (no action) should be adopted until reliable recreational catch data is equal to or greater than the reliability of the commercial landings. While this measure would help the commercial fishermen in the short run it would only delay a long overdue corrective action vital to the recovery of the grouper and vermillion snapper stocks.
The commercial industry recognizes and agrees with the need to implement more stringent rules and regulations in the snapper/grouper complex and asks that the SAFMC adhere to the “fair and equitable” and “accountability” mandates. The industry also asks that management take note of the decreased effort in the commercial sector and increasing pressure from the recreational sector.
There is evidence indicating that this sacrifice by the commercial snapper/grouper fishermen paves the way for a reallocation of the resources from commercial to recreational. This should not be the case and reduced effort by the commercial fishermen resulting in increasing stock biomass should be banked in a commercial account and the interest paid to the commercials upon recovery of the stocks as promised by the National Marine Fisheries Service.
Frank Blum Executive Director SCSA
SOUTH CAROLINA SEAFOOD ALLIANCE 815 Savannah Hwy. Suite 204 Charleston, SC 29407
Dear S. Atlantic Council Members,
First, I would like to state that the purpose of my comments are just to address concerns that we have with the data used for decisions on the management of the fisheries in our region. It seems that for too long the subject of the proposed "problem" isn't always defined prior to a "solution" being derived. Public meeting inputs have the attitude that the decision has already been made. As a fishermen, I would be more than happy to supply data as would many of the fishermen I know, if you would educate us on what you need for information and assistance.
Just finding out about these meetings is hard enough, try getting on the SAFMC website and finding SEDAR 10 REPORT or Magnuson Stevens Scoping document and reading the entire thing along with understanding it is another issue altogether.
Too long have fisherman been pitted against each other, both commercial and recreational, in an attempt to, in my opinion, redirect focus on the issue at hand. Any form of accountability on the council's part for the decisions made on our behalf as fisherman, doesn't seem to exist. Decisions are made that do not seem to have both the fish stock and fisherman's best interest at heart. Politics appear to also be playing a huge role in the decisions made on our behalf and do at times, seem detrimental to the cause.
The council's actions are speedy mechanisms to put increased restrictions on a fishery, yet there are no such speedy mechanisms to decrease restrictions should any fishery’s biomass indeed increase to healthier levels, or have new data to contradict the imposing limits. We hear how it needs to produce results over a long time period such as 10 years to be accurate. Please don't site here how we can now catch more porgy. That is a sad example on the council's part at best. Historically, regulations don't give back but become more conservative in restrictions.
These viewpoints are directed towards Amendment 16 yet hold true of all others that are being reviewed at present.
As I have read extensive amounts of information including SEDAR 10 along with information from the SAFMC, etc. I have a couple of points that I would like to bring up.
From the SAMFC website and I quote
Lack of basic management data on many of the species still remains the major obstacle to successful management. MRFSS surveys have been proven unreliable. What changes in the last 10 years have been changed to upgrade the survey system? MRFSS is usually a year or two behind in estimating this trend, so my main concerns are about over-regulation that may not be warranted. MARMAP surveys on "random hard bottoms" are the basis of most surveys done. We are talking about reef fish, fish that look for live bottom and structure to make their home. Data collections from things like "Chevron traps" were inconclusive due to such low catch rates and classified as "indeterminable and inaccurate" after 27 years yet older data is still used to calculate present trends. Why are things like wave heights, sea surface temps, surface currents, hurricane impacts, DO, salinity, wind speed, wind direction, etc not included in present studies? Why are issues like water quality and pollution along with protecting our juvenile fish using our estuaries for growth not addressed or protected? We can pay a hog farmer or tobacco farmer not to raise their crop yet we don't address the shrimping by catch that is drastically affecting our fish stock? Please don't tell me how great the "by catch" gear is doing in the shrimping industry, the by catch being shoveled overboard looks like a snow storm floating on the water coming from a shrimper. I understand they have to make a living, however, subsidizes their income for the percentage necessary and stop letting them trawl on the inside and watch how well our fisheries rebound. I am concerned on how "overly conservative" the council seems to be in their calculations and proposed regulations. Below are some of the areas that if corrected to more realistic parameters, would take us out of the "overfishing" category that the grouper and snapper species are presently assessed as.
I am concerned that F (fishing mortality; the percentage of the population that dies each year from fishing) is overstated partly because it is based on
1. Marine Recreational Fishing Statistical Survey (MRFSS) estimates of landings and discards, which have been declared unreliable and even ‘fatally flawed’ and
2. An overstated recreational release mortality of 25%.
Recreational fisheries Release mortality is presently assumed to be 25%, SEDAR 10 workshop stated Improved estimates of post-release mortality were obtained through tag release and caging methods (Burns et al. 2002; Overton and Zabawski 2003; McGovern et al.2005). Using these methods, mean mortality rates were estimated to be 21.2% (Overton and Zabawski 2003), 23% over a variety of depths (McGovern et al. 2005). Commercial fisheries Release mortality is presently assumed to be 40%. Your reasoning behind the proposed legislation is that the FMSY is below the F (Fish Mortality) factor, the FMSY has remained below the F (Fish Mortality) factor since 1983 in the S. Atlantic. With the council willing to error on the side of "conservative numbers and factors" is it any wonder this is the trend? Now take a look at our stocks. Have we decimated our biomass? No. Clearly real world numbers aren't being used to gauge accurate regulation.
How can the Magnuson Stevens Act expect you to make changes within 1 year of notification if the council states that it takes 3-8 years to schedule and complete a stock assessment? For that matter, why, if notified that a stock is in "trouble", aren't the data compiled between the last stock assessment and the present date of the notifications, reviewed to determine if an issue really exists at the present notification time period prior to taking action?
According to your own data workshops, spawning stock biomass increased after 1999 corresponding to implementation of the 24 inch minimum size limit. Fishing mortality has been decreasing since 1992 yet the gag grouper lifespan has just been raised to 26 yrs to 30 years. The life expectancy factor has been raised recently which is also affecting the formula into an "overfishing" status.
50% of maturity is 3 years and 25.5 inches. Why don't we increase the minimum size limit to 26". It has proven effective for the size increase in 1999 to 24".
Fishing mortality in 2004 was estimated as 0.31, extremely conservative against 2007 projected mortality.
Why is the fishing mortality rate for 2007 not being used? Obviously the fishing pressure has reduced since 2004 yet the OPPORTUNITY to fish hasn't been reduced which I think is very important and not usually taken into account when new regulations are proposed.
The council can redo the entire Vermillion Snapper stock assessment due to concerns of accuracy and possible "gross negligence" of the last assessment with updated data, yet I am told by the council that the 2004 data used in SEDAR 10 for grouper won't be updated until 2011? Are you kidding me? With the impact that fuel has alone on the frequency of fishing trips which has been declining since 2004, why can we not use current data and revisit the workshop to determine if the present proposed measures are necessary?
How can there be underfunding on the federal or local level to interpret the data that is taken every year but not incorporated or used due to lack of resources and man power as stated by the council with 3-8 years between stock assessments?
Why are the conclusions and recommendations from the data and review workshops which are and from the SEDAR programs not incorporated into the councils decisions on a "less cautionary or overly conservative" approach?
SEDAR 10 biologists recommended changing the MSST, SSB, M, F, MFMT and alike, in one form or another due to "overly conservative" concerns.
MSST, currently defined by the South Atlantic Council as (1-M)BMSY, is very close to BMSY because age-averaged natural mortality rate, M, is estimated as 0.14. It was recommended to change the M and wasn't done. It was stated that "the stock is not overfished and is not projected to become overfished."
Given the uncertainties in the assessment, the biomass would be expected or could possibly, fall below MSST with a relatively high frequency even if the true biomass were close to BMSY. In Sedar 10 the Review Workshop stated that the current definition of MSST may be overly conservative and recommends an operational definition of MSST of 5 million pounds. Yet it is still the factor of 6.8 million pounds was used.
The MFMT factor is also showing signs of being overly conservative. Why the council feels the need to error on EXTREME caution I don't understand.
Then Natural Mortality Rate formula was calculated using the Hoenig 1983 program. A program which has flaws due to the fact that the estimate of maximum age required by Hoenig's method assumes that the age determination technique being employed is unbiased. Validating this assumption is often difficult for the older, more difficult-to-age individuals but can be accomplished by using a variety of techniques ranging from marking to analysis of radioactive isotopes (Lai et al., 1996). The estimate of longevity is also dependent on sample size and previous fishing history, which by the way we don't have sound, accurate data on according to the councils own admission. Hoenig (1983) showed that maximum age tends to increase slowly with increasing sample size but longevity has probably declined from historical levels because of fishing. A small sample size for age determination, underaging, and previous exploitation would all result in an overestimate of M with Hoenig's method. Although compared to other methods, we still have an issue with accurate data and excessively cautionary management. Maybe we don't increase the Annual Catch Limits (ACLs) as aggressively using such precautionary regulation. The 2004 stock assessment model projections show the stock becoming overfished in 2007.
Greg Waugh states on 5/8/2008 that "the stock isn't overfished due to present reduction fishing pressure, attributed to several factors such as fuel costs." He also cited that "the assessment wouldn't be redone due to funding and scheduling issues and would be revisited in 2011."
It is an natural assumption with the current economic situation and petroleum driven influence on our daily lives that there has been a significant decline in fishing pressure on all fishing stocks yet the council seem reluctant to revisit the issue since they already have time and effort invested into them and have decided to "stick" to their original conclusions.
Maybe we use data more current than 2004 and realize that the 37% reduction that you are calling for has already in part been addressed due to the cost of fuel and expenses that are incurred for offshore fishing. The Magnuson Stevens Act states that the new regulations need to implemented by 2010. That gives the council plenty of time to do a stock review with less conservative numbers as recommended in the SEDAR 10 program.
Maybe the council shouldn't use such a precautionary approach to regulation on data that they admit isn't as accurate or current to date as it should be.
I believe that if current, data were used along with the above mentioned conservative factors corrected, the councils need for new legislation may not be necessary after all.
How about in the alternatives offer for the public to pick from the economic impact for the entire S. Atlantic recreational impact with a 4 month closure will only attribute to a total of $ 1,032,000. An example is the entire state of NC will only have an impact of $ 37,000. That is ridiculous. That equates to 37 trips at a charter price of $ 1,000. The impact is for the "for hire" sector which is lumped in with the recreational sector as a whole. There is no account for the true recreational sector such as recreational food, fuel, hotel, shopping, tackle, boat maintenance etc. For a 4 month NC closure, $ 37,000, REALLY?
We would like to see the gag assessment redone. There are too many uncertainties and inconsistencies to move forward with an assessment that will affect such a large fishery.
- The Gulf of Mexico Grouper assessment has been reviewed due to some of the same questions. There were many corrections and this was done in less than 6 month time frame.
Fishing effort is significantly reduced and is not taken into account when calculating future estimates as it should be.
Economic impact and true fishing pressure of both recreational and commercial fishing is grossly inaccurate.
If after a review it is necessary to reduce harvest, only modest bag limit decreases or modest size limit increases should be considered acceptable if in fact a problem exists.
I am sure that the Council want to make sound decisions. The economic and social devastation wrought by these proposed Gag regulations comes at a time when effort is significantly declining (I feel permanently) due to exorbitant fuel prices. These current proposals are based on overly precautionary thresholds which compound to create the false sense of an unhealthy fishery, when in fact the fishery could be quite healthy.
Is it any wonder that the individuals that you are governing are not satisfied with the proposed solutions when they seem to have a better handle on the fish stock, behavioral patterns, abundance and realistic solutions and are not heard by you?
I urge the Council to:
1. Review the Natural Mortality Rate of Gag 2. Review and adjust the overly precautionary estimates 3. Provide the numbers for and consider as an alternative a 26” Gag minimum size limit (20% or more reduction in rec landings alone) as the FIRST tool applied to the fishery. 4. Invite Dr. Trevor Kenchington to the SSC and Council meeting in June. Dr. Kenchington has extensive knowledge of both the Gulf of Mexico and the South Atlantic fisheries and could prove an excellent resource in the interpretation of current data parameters.
Thank you for your time and the opportunity to voice my concerns.
Best Regards,
Roland Sharon P.O. Box 1005 Eagle Lake, Fl 33839
SAFMC-- Snapper- Grouper Written Comment May 16 2008
To Whom It May Concern,
I, Marilyn Solorzano, am against the emergency closing of the Vermillion Snapper (aka Beeliner). I do not believe this species is over fished, and that there is not enough scientific evidence to the contrary. I believe that we are over regulating fisheries unnecessarily at the expense of hard working people in industry. I, myself, do not fish in this fishery, but am associated with those who do and hear overwhelming comments on the vast quantity of a species that the council now wants to declare a emergency ruling to prohibit.
Please reconsider this rash proclamation, as I believe it is not in the best interest of the species, the industries involved, or fishermen who pursue this interest.
It is my civic duty as an American to speak out. We, the American people HAVE to start being productive and utilize what this countries has, or we will cease to exist as a free and prosperous nation.
NO MORE LIMITS ON FISHERIES!
Thanks Marilyn Solorzano
Lee Starling here, I am a commercial fisherman and diver in Key West. I have fished for 35 years
The Gag plan for the Keys is completely inappropriate for our area. Grouper , primarily Blacks spawn on April and May full moons. This is the predominant grouper population. Unfortunately the current laws open Grouper at the very apex of the spawn. The past 2 years current regulations have created "Derby fishing" for grouper. combined with a large spearfishing contest held annually on the opening. The aggregating grouper are overharvested in 3-4 days and it takes until fall for other groupers to repopulate patch reefs and inshore areas. Fish which used to spawn and then be harvested over a 3-4 month period are now harvested in a weeks period. A "Grouper mini season" ensues.
I personally have collected for FWCC roe samples for 3 years and these samples prove to be largest and mature during these months.I will have FWCC Research forward submitted data
I feel a closure of April and May to all harvest , recreational and commercial is valid, logical solution. The Law Enforcement here is extremely understaffed. More Officers and patrolling is needed. The complete closure to both sectors would help to simplify Law Enforcement efforts. No gray areas , no loopholes. This will also help to curtail illegal sales. State of Florida would need to adopt the same rules. State and Feds work together.
In the keys over the last 3 years I have seen a large increased amount of effort, primarily from divers.Most target black grouper. Also Freedivers are hired from Miami to work on local commercial boats. They target almost exclusively grouper.Many people who used to travel to the Bahamas now come to the keys since the the fishing rules have become more strict. These recreational boaters have long range high speed boats , what was considered far is a short run for thier vessels. The recently popular spearfishing contest also bring large amounts of harvestors , many commercial for the event. All this effort occurs on the spawn. These "new" pool of harvestors from Miami also harvest many unregulated species such as barracuda,and jacks. These are now being grossly overfished also.
Some will argue that higher fuel prices have slowed effort by less trips being made. What is not taken into account is the boats making trips now carry more people (harvestors). The Internet sites such as spearboard.com provide a forum where alike minded harvestors connect and arrange trips on recreational boats and share expenses for thier seat. So people who previously would have never fished together combine costs and the number of harvestors so effort is actually increased. These vessels do not have appropriate Federal or State permits,nor lisc Captains, or insurance.
Please make an exception for using j hooks for yellowtail, they cannot be hooked with a circle hook.
No retention of grouper or snapper by charter captain and crew. A large portion of those fish are being sold. The charter boat permit rule regarding the sale of one persons recreational catch is largely ignored.Most fish houses will by up to 6 peoples recreational limit arguing it's the recreational boat limit.On the days they have no charters they fish themselves and sell the catch.
Thank you for the opportunity to address the council, I hope this gives some insight into our changing fisheries in the Florida Keys. Lee Starling
From: [email protected] [mailto:[email protected]] Sent: Friday, May 16, 2008 4:20 PM To: Kim Iverson Subject: reg. snapper, grouper regulations & closures
This letter is in response to Keynoter, Fish Plans Draw Worry, May 14, 2008. It was about Snapper, grouper regulations and Jan. to Apr closure.
I believe size limits and bag limits in place at this time should have more time to prove themselves. To say you can only have one snowy grouper is silly. If you are deep dropping and using several hooks with electric reels you sometimes come up with 3 or 4 at a time. The eyes are popped out and the bladders burst, they are not going to survive if released. That goes for all deep water fish, grouper or snapper. Therefore limit the amount of hooks on a line. Using circle hooks is okay on bigger fish such as wahoo, mackerel, dolphin, bill fish etc. But it is of no use in shallow water for yellowtail snapper, grouper etc. We use a #1 or #2 hook and most of the time they are just lip hooked. One thing that could be done is to remove the barbs when snapper fishing. When you close the season on one species it just puts pressure on a different one. Leave it work out by quota and size limit. It would be much easier to regulate. If you are a commercial fisherman and not catching enough to make it worthwhile, you will quit all on your own as many have already done. Quit trying to put us out of business. If you do, is there a plan to subsidize us? I have been commercial fishing for 28 years and there is no retirement plan for a commercial fishermen. Fishing is our way of life.
Donald Strohm Key West
To Whom It May Concern:
I recently received a newsletter from the South Atlantic Fishery Management Council, which deeply concerns me. It is in regards to Amendment 16, the Snapper Grouper Fishery Management Plan (FMP). This amendment if passed could result in a four month total closure of all shallow grouper species (even those that are not undergoing over fishing), as well as, a bag reduction to one fish per person per day.
As I’m sure you are aware, a significant amount of income and jobs in this state are derived from recreational fishing. A four month closure during the prime grouper fishing season, when not many other fish are available for offshore charters to catch, threatens to put many struggling charter captains out of business and their family’s on the streets. This proposed regulation would have a devastating impact on many local businesses, including: marinas, tackle shops, dive shops, boat and equipment manufacturers, Wholesale and retail Seafood shops and Restaurants as well as any other industry which thrives off the money coming into the state through recreational fishing.
This hastily prepared amendment, which lacks proper supporting scientific evidence is unfortunately due to the Magnuson-Stevens Fishery Conservation and Management Reauthorization Act, which states that the Council must end overfishing within a one year period once overfishing is identified. In my opinion and that shared by many others, the “best available data” which has identified gag grouper as over-fished is deeply flawed. There is No argument that many Grouper stocks in the Gulf and Atlantic are at some of the highest levels of biomass they have been at in the last 15 years. Their stock assessment also does not take into account the dramatic reduction in fishing effort due to the current economic situation and the rocketing fuel prices.
The Magnuson-Stevens Act contains arbitrary and rigid rebuilding requirements. While these provisions have spurred growth in many fisheries, they have also unnecessarily restricted recreational anglers on numerous occasions and have not taken into account the dynamic marine environment. In many instances sound science and accurate data, which requires more time is needed to properly address the situation.
Congressman Pallone from NJ introduced the Flexibility in Rebuilding American Fisheries Act of 2008 (Introduced in House) HR 5425 IH on February 13, 2008. I hope that you will look into this piece of legislation and support it in any way that you can.
As a voter and citizen of Florida, I strongly urge you to take note of this pressing situation and do everything in your power to ensure that these new regulations, hurriedly contrived and likely based on dubious data are NOT put into place. If Amendment 16 is passed in its current form by the SAFMC it will undoubtedly bankrupt many tackle shops, party boats, commercial fishermen and other Florida residents who derive significant portions of their income from the grouper fishery.
Thank you for your time,
Captain Ron Surrency Atlantic Coast Charters Inc. (904)759-2057 [email protected] The Florida Times-Union
May 18, 2008
Another snap decision by Fisheries Council
By JIM SUTTON, The Times-Union
One thing you can say about the South Atlantic Marine Fisheries Council is that it never met a fishing management plan it didn't like. ------
Last Sunday, I outlined some of the preferred alternatives for the SAFMC's new Amendment 16, which included harsh restrictions on grouper in federal waters and on vermillion snapper.
Now meet Amendment 18. This one is all about red snapper, we're told, but read the fine print. The data document, which is meant to let those interested know what's going on in preparation for public meetings, was published as a "Scoping Document - May 2008." The scoping meetings were held between May 7 and 15 in five cities across the Southeast. Public input has ended.
The potential management measures could include one or a mixture of the following, according to the SAFMC scoping document:
- Prohibit all harvest and possession of red snapper year-round and establish a seasonal closure for shallow water snappers or all species in the snapper/grouper management unit. (More about this later.)
- Reduce the bag limit from two to one snapper per person or one snapper per boat per day combined with a seasonal closure.
- Reduction or elimination of the 20-inch size limit. The SAFMC hopes this action will reduce culling smaller fish and cutting down on resultant mortality of released fish.
- Establish a closed season that could apply to shallow- water snappers.
- Establish time/area closures that could apply to red snapper, the shallow-water snappers or all species in the snapper/grouper management unit.
Note the language "snapper/grouper management unit." There isn't enough space to list them all, but there are 73 separate species that Amendment 18 could "protect." The cast of characters includes spadefish, blue runner, black sea bass, golden tilefish, cubera snapper, jack crevalle, lane snapper, mutton snapper, triggerfish, red snapper, sailor's choice, sheepshead, grunt, yellowtail snapper, vermillion snapper, Warsaw grouper and more. Lots more.
Feeling helpless feels bad. But that's exactly what anglers on the southeast coast have become. The meetings are finished; the final day of comment is over. And nobody I talked to, including officials in Tallahassee and leaders of guide and charter boat associations, saw this one coming.
The SAFMC says the meetings were adequately advertised.
Why would the SAFMC consider such drastic remedies to normal levels of fishing pressure, whatever the relative benchmark used? Where was the data three, five or seven years ago that should have pointed to - and negated - this crisis-level management? The SAFMC reports that it will consider "emergency interim action" on this amendment in Orlando June 8-10.
In other words, how could years of data on stock assessments be that far behind those now used as proof that it might be necessary for a total closure of more than 70 species of grouper and snapper?
I don't claim to understand what kind of weird science or previous inaction drove us to this level of presumed resource mismanagement.
But here's how the scoping document explains its stock status criteria. I will leave it at that, hoping it clears things up for you as well:
"Status Determination Criteria: The maximum fishing mortality threshold (MFMT) is defined by the Council as F-MSY, and the Review Workshop has recommended using F-40%SPR as a proxy. The minimum stock size threshold (MSST) is defined as (2 - M) SSB-MSY, where the SSB refers to Spawning Stock Biomass; SSB-MSY is the level of SSB when the fishery is operating at maximum sustainable yield, and constant M is 0.078. The Review Workshop has recommended using SSB-F40% as a proxy. Technically, "overfishing" is defined as occurring whenever F (is greater than) MFMT and a stock is "overfished" when SSB (is less than) MSST. Current status of the stock and fishery are represented by the latest assessment year (2006)."
(904) 359-4215
Mr. Robert Mahood Executive Director
Snapper/ Grouper Admendments First and foremost I want to thank each of you for taking the time to hear each of our concerns. I\'m a recreational fisherman in NC, I also possess a NC SCFL. I have never engaged in selling any fish associated within the current proposed admentments and the primary purposes of my SCFL is Bluefin Tuna fishing and tax relief purposes. I do have concerns with some of the comments I have read on these purposed issues. If you are truely concerned about conserving these species wouldn\'t it be better if a person, like myself, is reporting what I catch, by selling and reporting with a trip ticket, versus catching the fish recreationally and not reporting it. Because let\'s be honest YOU have no way of know what a recreational fishernman catches. My point is if I could sell my recreational catch you would have a quanative measure of what I took versues knowing nothing, because believe me, YOU have no idea whats being killed or sold blackmarket, trust me!
I read emails posted on recreational fishing websites, from members of the SAFC, that these quotas should be left to \"Professional\" fisherman because they depend on this for their livelyhood. The day of the true \"commercial fisherman\" are all but gone, they are a dieing breed, due to rising expenses and cluture issues. The largest portion of the people I see engaged in this fishery have full-time jobs and grouper fish on the side. Let\'s be honest, unless these people have been in business for a while they can\'t afford the $25,000 it takes to get the permits. Why not let the recreational folks sell their catch, they are going to catch it anyway, at least this way it\'s reported, and it\'s truely an insignificant # of the toatal lbs caught.
I have fished with friends who have the appropiate snapper/ grouper permits and I get a FIRST HAND view of the true overfishing that takes place. It disgust me that I possibly can\'t take a recreational limit and not sell it when my buddy can sell thousands of pounds a day becuase he can afford the permits and he\'s a millioniare.
Please understand I don\'t depend on selling any fish to pay for my hobby, it would be nice to offset the cost by selling our recreational catch. With the rising cost of fuel I don\'t know how long anyone is going to be able to sell their catch. At least were supplying a demand for people who can\'t get fresh fish.
Thank you in advance for making the right decission. DON\"T further drive the market undergroud. Let the rec guys sell the rec limit, they are catching it anyway and you will at least be able to track and account for it. I thought the the main reason beind the Magnusum Stevenson Act was to prevent one population from getting more than their share of the total quota. With the proposed admendments the majority of the quota will go to the permit holders, or as Mac calls them Professional fisherman, far from the truth.
Thankfully, Eric Swain
Sincerely, Joseph Swain 5016 The Woods Rd Kitty Hawk, NC 27949 you have the grouper spawn wrong. it should be closed during april and may when they really spawn.
Mr. Szymanski Dear S. Atlantic Council Members,
First, I would like to state that the purpose of my comments are just to address concerns that we have with the data used for decisions on the management of the fisheries in our region. It seems that for too long the subject of the proposed "problem" isn't always defined prior to a "solution" being derived. Public meeting inputs have the attitude that the decision has already been made. As a fishermen, I would be more than happy to supply data as would many of the fishermen I know, if you would educate us on what you need for information and assistance.
Just finding out about these meetings is hard enough, try getting on the SAFMC website and finding SEDAR 10 REPORT or Magnuson Stevens Scoping document and reading the entire thing along with understanding it is another issue altogether.
Too long have fisherman been pitted against each other, both commercial and recreational, in an attempt to, in my opinion, redirect focus on the issue at hand. Any form of accountability on the council's part for the decisions made on our behalf as fisherman, doesn't seem to exist. Decisions are made that do not seem to have both the fish stock and fisherman's best interest at heart. Politics appear to also be playing a huge role in the decisions made on our behalf and do at times, seem detrimental to the cause.
The council's actions are speedy mechanisms to put increased restrictions on a fishery, yet there are no such speedy mechanisms to decrease restrictions should any fishery’s biomass indeed increase to healthier levels, or have new data to contradict the imposing limits. We hear how it needs to produce results over a long time period such as 10 years to be accurate. Please don't site here how we can now catch more porgy. That is a sad example on the council's part at best. Historically, regulations don't give back but become more conservative in restrictions.
These viewpoints are directed towards Amendment 16 yet hold true of all others that are being reviewed at present.
As I have read extensive amounts of information including SEDAR 10 along with information from the SAFMC, etc. I have a couple of points that I would like to bring up.
From the SAMFC website and I quote
Lack of basic management data on many of the species still remains the major obstacle to successful management. MRFSS surveys have been proven unreliable. What changes in the last 10 years have been changed to upgrade the survey system? MRFSS is usually a year or two behind in estimating this trend, so my main concerns are about over-regulation that may not be warranted. MARMAP surveys on "random hard bottoms" are the basis of most surveys done. We are talking about reef fish, fish that look for live bottom and structure to make their home. Data collections from things like "Chevron traps" were inconclusive due to such low catch rates and classified as "indeterminable and inaccurate" after 27 years yet older data is still used to calculate present trends. Why are things like wave heights, sea surface temps, surface currents, hurricane impacts, DO, salinity, wind speed, wind direction, etc not included in present studies? Why are issues like water quality and pollution along with protecting our juvenile fish using our estuaries for growth not addressed or protected? We can pay a hog farmer or tobacco farmer not to raise their crop yet we don't address the shrimping bycatch that is drastically affecting our fish stock? Please don't tell me how great the "bycatch" gear is doing in the shrimping industry, the bycatch being shoveled overboard looks like a snow storm floating on the water coming from a shrimper. I understand they have to make a living, however, subsidizes their income for the percentage necessary and stop letting them trawl on the inside and watch how well our fisheries rebound. I am concerned on how "overly conservative" the council seems to be in their calculations and proposed regulations. Below are some of the areas that if corrected to more realistic parameters, would take us out of the "overfishing" category that the grouper and snapper species are presently assessed as.
I am concerned that F (fishing mortality; the percentage of the population that dies each year from fishing) is overstated partly because it is based on
1. Marine Recreational Fishing Statistical Survey (MRFSS) estimates of landings and discards, which have been declared unreliable and even ‘fatally flawed’ and
2. An overstated recreational release mortality of 25%.
Recreational fisheries Release mortality is presently assumed to be 25%, SEDAR 10 workshop stated Improved estimates of post-release mortality were obtained through tag release and caging methods (Burns et al. 2002; Overton and Zabawski 2003; McGovern et al.2005). Using these methods, mean mortality rates were estimated to be 21.2% (Overton and Zabawski 2003), 23% over a variety of depths (McGovern et al. 2005). Commercial fisheries Release mortality is presently assumed to be 40%. Your reasoning behind the proposed legislation is that the FMSY is below the F (Fish Mortality) factor, the FMSY has remained below the F (Fish Mortality) factor since 1983 in the S. Atlantic. With the council willing to error on the side of "conservative numbers and factors" is it any wonder this is the trend? Now take a look at our stocks. Have we decimated our biomass? No. Clearly real world numbers aren't being used to guage accurate regulation.
How can the Magnuson Stevens Act expect you to make changes within 1 year of notification if the council states that it takes 3-8 years to schedule and complete a stock assessment? For that matter, why, if notified that a stock is in "trouble", aren't the data compiled between the last stock assessment and the present date of the notifications, reviewed to determine if an issue really exists at the present notification time period prior to taking action?
According to your own data workshops, spawning stock biomass increased after 1999 corresponding to implementation of the 24 inch minimum size limit. Fishing mortality has been decreasing since 1992 yet the gag grouper lifespan has just been raised to 26 yrs to 30 years. The life expectancy factor has been raised recently which is also affecting the formula into an "overfishing" status.
50% of maturity is 3 years and 25.5 inches. Why don't we increase the minimum size limit to 26". It has proven effective for the size increase in 1999 to 24".
Fishing mortality in 2004 was estimated as 0.31, extremely conservative against 2007 projected mortality.
Why is the fishing mortality rate for 2007 not being used? Obviously the fishing pressure has reduced since 2004 yet the OPPORTUNITY to fish hasn't been reduced which I think is very important and not usually taken into account when new regulations are proposed.
The council can redo the entire Vermillion Snapper stock assessment due to concerns of accuracy and possible "gross negligence" of the last assessment with updated data, yet I am told by the council that the 2004 data used in SEDAR 10 for grouper won't be updated until 2011? Are you kidding me? With the impact that fuel has alone on the frequency of fishing trips which has been declining since 2004, why can we not use current data and revisit the workshop to determine if the present proposed measures are necessary?
How can there be underfunding on the federal or local level to interpret the data that is taken every year but not incorporated or used due to lack of resources and man power as stated by the council with 3-8 years between stock assessments?
Why are the conclusions and recommendations from the data and review workshops which are and from the SEDAR programs not incorporated into the councils decisions on a "less cautionary or overly conservative" approach?
SEDAR 10 biologists recommended changing the MSST, SSB, M, F, MFMT and alike, in one form or another due to "overly conservative" concerns.
MSST, currently defined by the South Atlantic Council as (1-M)BMSY, is very close to BMSY because age-averaged natural mortality rate, M, is estimated as 0.14. It was recommended to change the M and wasn't done. It was stated that "the stock is not overfished and is not projected to become overfished."
Given the uncertainties in the assessment, the biomass would be expected or could possibly, fall below MSST with a relatively high frequency even if the true biomass were close to BMSY. In Sedar 10 the Review Workshop stated that the current definition of MSST may be overly conservative and recommends an operational definition of MSST of 5 million pounds. Yet it is still the factor of 6.8 million pounds was used.
The MFMT factor is also showing signs of being overly conservative. Why the council feels the need to error on EXTREME caution I don't understand.
Dennis Tonge
Dear Mr. O 'Hara,,
I am writing you to voice my opinion concerning the grouper spawning season.
I have known "Lobster Lee" for a decade and I know two things; first, that he is a man of the sea and would do nothing to harm our marine environment. I believe he would take a land based job rather than hurt the fish population. In fact, if this time period is passed as proposed by the Marine fisheries he would be able to take more fish but he would not. Secondly, if you look a little deeper into the facts offered by the Marine Fisheries you will find their studies are based on the entire State of Florida, not just our Keys. They are wrong to make the 'assumption' that fish 500 to 1000 miles away in different water temperatures and weather cycles behave in the same way as do our fish that are in an environment more like the Bahamas or the Caribbean.
Once again, agencies that are large like yourselves seem to have a tendency, in your busy schedule, to study vast reports rather than specific ones. I invite you to table this purposed time ban for the Fl. Keys. It will only hurt us locally and do exactly the opposite of what you are trying to achieve.
Very truly Yours,
Capt. Albert Tropea 30 Year Keys Resident
From: Jason Ward [mailto:[email protected]] Sent: Sat 5/17/2008 4:20 PM To: Gregg Waugh; Bob Mahood; Kim Iverson Subject: Logical ERROR in Amendment 16, Alternative #2
I would like to point out something that may not have been taken into consideration with alternative #2 for Amendment 16. Alternative #2 states:
'Alternative 2 (preferred). Define interim allocations for gag based upon landings from the ALS, MRFSS, and headboat databases. The allocation would be based on landings from the years 1999-2003. The allocation would be 51% commercial and 49% recreational (Table 2-4). This alternative would establish a commercial quota of 353,940 pounds gutted weight and a recreational allocation of 340,060 pounds gutted weight.'
There is one anomoly here that will become of issue if amendment 15B is passed which states in the documentation the following information: http://www.safmc.net/Portals/6/Library/FMP/SnapGroup/SGAmend15BSDEISApril08.pdf
'Current estimates of annual bag-limit sales are approximately 17 percent of total snapper grouper sales, or approximately 1.5 million pounds valued at approximately $2.6 million (nominal ex-vessel value). To the extent that recreational trip demand is influenced by the ability to subsidize the cost of a fishing trip through the sales of bag limit-fish, under the status quo, angler trip demand under Alternative 1 should remain unchanged. Under Alternative 1, the Federal commercial snapper grouper sector would continue to be denied access to snapper grouper species that are harvested under the bag limit, sold, and counted against the commercial quota.'
It is important to point out here that if this is true, then the *fair* split is not 51%\49% since 17% of these 'commercial landings' are actually recreational anglers selling under the commercial quota (which will no longer be allowed). This means that (17% of 51% is) 8.67% of the TAC has actually been recreational landings sold under the commercial quota. Therefore, if amendment 15B is passed, which dictates that these recreational landings will start being counted under the recreational quota and not under the commercial quota anymore, then it goes without saying that the 'fair' split would be for the recreational side to reclaim this part of the quota since they caught these fish between 1999-2003 as the intent of the split dictates. That is 51% - 9% = 42% commercial and 49% + 9% = recreational. This means that the fair split for the past data from 1999-2003 would NOT be 51%\49%, but instead would be 42% commercial and 58% recreational. That is if true commercial is counted as commercial and true recreational is counted as recreational.
Another scenario to put a spin on this:
Hypothetically speaking if Amendment 16 was decided as 'no action' and Amendment 15B was passed to disallow the sale of recreational catch, then this would actually INCREASE the commercial boat landings quota by 21% (because their true catch of 42% would jump to 51% of TAC which is a 21% increase (42 * 1.21 = 51)). The commercial permit moratorium already shows a shrinking number of commercial vessels and should not see an increase in quota. The recreational side is growing and should naturally see this quota increase if any. Thus, as we all know, alternative #2 is preferred by the SAFMC and if this does pass, and then TRUE intent is to keep the split as it were, then we need to take this into account with a 42\58 split.
Thanks, Jason Ward
R.L Warrilow Daddy O Charters 90 Sirius Ln Key West ,Fl. 33040
May 20, 2008
South Atlantic management council
Gentlemen:
I would like to address the council in regards to the proposed changes to Amendment 16 , specifically the areas covering grouper season, the use of the blunt nose pliers and circle hooks.
It has been stated that assessments of the gag grouper show a reduction in the population of this species.
I think it would be of great benefit to the council to look into the impact the goliath grouper has had on the population of the juvenile gag grouper which tend to gather in the same shallow water wrecks as the much larger and more aggressive goliath grouper. You can go to wrecks that were populated with small gags in the past and all that you find are goliath grouper that have grown to great proportions by eating the nursery size gags and blacks. I do realize that it is much easier to shot gun the problem, just blast away and if it sounds like grouper close the season, that way you don’t have to put a lot of thought into it and the Government cannot say you didn’t do any thing.
When the Council made the last changes, by increasing the length from 20” to 24” inches and closed the season from March to May, it could be under stood but we are now getting back to the shot gun effect. If you have a problem with the gag grouper address this problem doesn’t just say well we will just close it all. You have to understand that everything you do affect thousands of people in one way or another.
After attending the meeting on May 7 th and listening to your biologist, Greg Waugh, Iam convinced that you are in fact shot gunning . Mr. Waugh stated that there was no problem with the grouper, other than the gag, yet you persist in implementing rule that are unnecessary. We were told that these changes were all but in place at which time most of the attending fishermen wanted to know why you even hold these meetings if your minds are made-up before you even listen to any alternative programs.
I know you hear a lot of negatives when things like this come out and you get little input. this must be frustrating at times. Try compromising a little. Reduce the daily limit to 2 [two] grouper per day per person[ rather than as it stands now 5[five] per day per-person] and a passion limit of 4[four] per boat z Page 2 May 20, 2008 which ever is least, this will cause a stir in the charter and head boat people due to the fact that the fish they catch, grouper, mutton snapper, yellow tail, king fish,etc.,will go to market when the client has gone and the money goes to the Capt. And possibly shared with the crew, by doing this you could insure that the grouper fishery would not be depleted and you would not have to place an outrages law in place closing the season during a time period that even your biologists know ,and admit, no spawning activity is taking place. If this closure is put into place the members of our fishing council will look foolish and you have travel a long hard path to gain credibility over the past several years, unlike the gulf council who have all but ruined their fisheries and credibility, using bad information and no common sense.
.
The next issue I would like to address is that of the blunt nose pliers and the circle hook.
I look at this as the same problem. Here you have a problem created by biologists who do not understand the fish that they are trying to protect. This is another example of persons hearing something and thinking it should be used for all fish. I agree that the circle hooks has its place in fishing but it does not apply to fish the size of most snapper. If you were talking red snapper, mutton snapper,kingfish,grouper and other fish of that size I could understand but with fish that have a minimum size limit of 12” the circle hooks will cause a mortality rate ,on our nursery size yellow tail, that I don’t think any of us are ready to deal with. Think of it this way, you hook a fish 8” long and have to use blunt nose pliers to remove a hook that is half again the size of a “ J “ hook of the same number size. The first thing that happens is that you have to hold the fish much tighter, then the pliers will not fit in the mouth , you grab the hook and pull ,If the fish is not dead when it hits the water it will be because it cannot feed with out lips. You always get the person that says” well they have dehookers now” That is very true,we are also using “J” hooks, but there is no way that they will work with the circle hook this means handling every fish which will reduce our catch of yellow-tail by approximately 30 percent. Your biologists just completed a study on the yellow-tail snapper and gray snapper, using their words,” there is no problem now and none in the foreseeable future”. So why the circle hooks? Is it because it is convenient to rubber stamp something the gulf council adopted therefore you don’t have to think about it?
One more thing that needs to be addressed is the matter of placing South Florida, which is tropical in nature, under the same criteria as the northern states which have colder waters and have many more and different problems to deal with. It is still unconceivable to me that laws made for their fisheries are forced upon us when we don’t have the same species of fish or problems.
I would like to take this time to thank you for standing up and saying NO to LAPP. I know this took
Courage.
Respectfully submitted,
R.L.Warrilow 90 Sirius Ln. Key West Fl.,33040 z Page 3 May 20, 2008