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  FAIRNESS in FISHERIES MANAGEMENT

Click here for a powerpoint presentation on 30B

Gulf of Mexico Fisheries Management Council Amendment 30B Gag and Red Grouper

This Amendment has serious implications for the recreational and commercial fisheries in the Gulf of Mexico.

Special Grouper news:

The FRA, in partnership with the Southern Offshore Fishing Association, has hired Dr. Trevor Kenchington.  Dr. Kenchington has found, IN THE FRA-FORCED REVIEW OF GAG, published September, 2007, that overfishing for Gulf Gag has ended and may not have been occurring in the first place.

View from the Helm-

What a ride, my friends.  Two weeks ago, we appeared to be dead men walking, with our execution scheduled for April 11th.  Execution for a crime not committed.  Wrongful execution.  And somebody KNEW the truth, but for unknown reasons conspired to move forward with economically devastating regulations that were totally unnecessary.  Who would do this?  Why?  Sounds like some pressure from the anti-fishing crowd with some sleight of hand science.

I am not a Ph. D. of Marine Biology, but I knew something was wrong with the Gag assessment.  So wrong, in fact, that in early 2007 the National Marine Fisheries Service agreed to the FRA's request for an UNPRECEDENTED review of a completed stock assessment before it was even offered for regulatory use.

This FRA-FORCED final review of the Gag grouper showed that overfshing for Gag had ended in 2005, and, in fact, may never have been occurring.  Ignoring their own knowledge that overfishing had ended, the National Marine Fisheries Service chose to go forward in its quest for a 45% reduction in Gag landings.  NMFS conveniently failed to mention to the Gulf Council that overfishing was not occurring.  No overfishing means no action required.  Why was this ignored?  Why was 45% of the Gag Grouper pie being stolen?

45% of our PIE.  Someone is stealing our pie.  Will we be shortsighted enough to argue over what is left, or will we be incensed that someone is stealing our pie and ACT TO GET OUR PIE BACK?  I'm in the action crowd, as I simply cannot stand someone stealing from me.  I'm going to take mine back and teach the thieves a lesson they won't soon forget.  I hope you feel the same.

Frustrated and facing some sort of punishing regulations, I had nowhere to turn.  All the scientists in the United States seem to be afraid of the National Marine Fisheries Service.  Other recreational groups, with the exception of the FLORIDA GUIDES ASSOCIATION, did absolutely NOTHING about this science being questionable.  Even a group who employs a full time Ph. D. that is in attendance at nearly every Gulf Council meeting did NOTHING about the science.  That group seemed content with allowing our pie to be stolen. They focused on splitting up what was left instead of fighting for what was stolen.

So I had a talk with somebody else who was willing to fight for the 45% of the pie that was being stolen.  The only other group capable and willing to fight for our pie was the Southern Offshore Fishing Association, headed by Bob Spaeth.  To arrive at the point we are at today, Bob and I set aside our differences to concentrate on our common ground and get our pie back.

Since the FRA is so under funded, we arranged to share the cost of Dr. Trevor Kenchington with SOFA.  Dr. Kenchington is currently reviewing the Gag Assessment.  It looks like it was a good decision, as Dr. Kenchington's initial findings have coaused the Gulf Council to delay action on Gag action on Gag Grouper and are optimistic that we will need no new regulations at all for Gag grouper.  We will be asking for our Five Red Grouper as part of the aggregate.  I would like to note that SOFA had a prior relationship with Trevor, which facilitated the ease and speed of Trevor's willingness to respond.  Without SOFA, I am sure that Trevor would not have moved as quickly, and certainly not without cash retainer and some references for the FRA.

The train has left the station and is steaming full bore down the track. 

We are on track for a new day in fisheries management, a day when the fishermen have their own staff of believable, reliable scientists who will tell us the truth about our stocks. 

A day when FAIRNESS IN FISHERIES MANAGEMENT will be reality, not just a mission statement.

• Get the FRA Comments and position on Amendment 30B items.  click here for the pdf

• Read suggestions for preparing your public input.

• See the full Gulf Council Document in pdf  click here

View From The Helm

The final round of Gulf Council Public Input is being taken for Gulf Gag and Red Grouper Amendment 30B. Final action will be taken at the Gulf Council’s Full meeting in Baton Rouge, LA the week of April 7-11.

We all need to attend.  Attached is the FRA’s input for preferred alternatives and some other alternatives not currently listed.  Please review them and support them if you can.  Go to the Gag Grouper Public Input page on the FRA website, www.joinFRA.org for public input guidance sheets as well as meeting locations and reference materials.

Here is how I see it:

A one gag limit would reduce landings way beyond what is required because it would destroy the recreational sector's OPPORTUNITY to fish for grouper, causing social and economic devastation at a time when the states can ill afford unnecessary loss of economic activity.

Credit for effort reduction is essential to the survival of the recreational grouper fishery, given that effort has fallen by 35% on offshore trips (more than nine miles) into the Gulf from Florida, per the governments own MRFSS numbers.  The Florida Gulf Coast is where nearly all Red and over 85 % of Gag grouper are landed.  The majority of the FL Gulf Coast requires long, fuel consumptive trips that will become more and more expensive as the cost to run an offshore private boat will average $5 per mile by this summer.  We contend that effort will continue to decline for the foreseeable future as fuel prices rise.  Fuel at the dock is already $4.35 per gallon for mid grade in Madeira Beach, FL.

An alternative with a recreational 24” Gag minimum length and five aggregate grouper should be evaluated.

A 24” size limit would help to CONSTRAIN RECREATIONAL EFFORT targeting Gag grouper WITHOUT UNNECESSARILY LIMITING OPPORTUNITY to fish. 

Higher size limits constrain fishing effort.  Lower size limits will increase landings of small fish before they reach maturity and increase the recreational effort because it is easier to catch a smaller fish.  Lower size limits will cause more anglers to target the fish, thereby increasing effort and landings.

Serious flaws remain with the gag grouper stock assessment, causing economically and socially devastating regulations which we feel are unnecessary.  The FRA has hired a biologist to review and apply corrections to the Gag assessment.

These new rules for the recreational sector will cause a negative billion dollar impact on the state of Florida alone.  NMFS  is making a BILLION DOLLAR BUNGLE.  You can help stop it. Watch for the next alert which will direct you to contact our legislators.

The precautionary levels at which our landings are being set will surely cause the stock to appear to be undergoing overfishing.  We are having these precautionary levels reviewed.

The new accountability measures being proposed will get us shut down quickly, it the current proposals are advanced.  We contend, and we will fight this all the way to Washington, DC, that if we do not land our entire allowable quota in a given year, that unused quota be added to the next year, without restriction or expiration.

This is only fair, given that once we hit our quota, we will be shut down, and if we go over, we will have it come off of next year’s quota.  The FRA contention allows for the cyclical nature of the fish stocks and the fishing effort.

The Marine Reserves area of this amendment is there because ONE Council member continues to slip it into the plan.  This must be brought to light and corrected.

We need to turn out at these public input meetings.  They are at night, so you do not have to take a day off of work.

SHOW UP AND MAKE YOURSELF HEARD.  YOU HAVE THE POWER TO MAKE A DIFFERENCE.

Sea ya there!

Denny O'Hern

Executive Director

Fishing Rights Alliance

www.joinFRA.org

Terms Of Reference

NMFS- National Marine Fisheries Service.

MRFSS-  Marine Recreational Fishing Statistical Survey

GULF COUNCIL - Makes the fishing rules for Gulf Federal waters.

PUBLIC INPUT GUIDANCE for GULF COUNCIL Public Input on Amendment 30B     

RELAX.  BE POLITE WHEN YOU SPEAK.

If you don’t wish to speak, your presence matters.  You can submit a comment card indicating your thoughts or support for a group.  The write WILL NOT SPEAK.  The card is a record of your presence and desire to be counted. 

When presenting your comments to the Council at these hearings, you should always state your name and city/state of residence at the beginning of your comments.  This will give credibility to your message.

Mention that you are a recreational angler and (mention all that apply) that you fish, dive, spearfish, hunt lobster, own a boat, own a business, you work at a business that gets some/most/all of its business from fishing, you be affected if fishing activity is reduced.

FRA talking points-

• REDUCED EFFORT SHOULD ELIMINATE NEED FOR ANY REDUCTION

• STOCK ASSESSMENT STILL IS UNRELIABLE

• ECONOMIC IMPACT OF REGULATIONS

• A 24" RECREATIONAL GAG GROUPER SIZE LIMIT

• ACCOUNTABILITY MEASURES TO INCLUDE US RETAINING UNUSED PORTIONS OF OUR QUOTA

• NO MARINE PRESERVES

• DISCARD MORTALITY CREDIT FOR VENTING TOOLS, DEHOOKERS AND CIRCLE HOOKS

A one gag limit would reduce landings way beyond what is required because it would destroy the opportunity to fish for grouper.

Credit for effort reduction is essential to the survival of the recreational grouper fishery.

An alternative with a 24" gag and five aggregate grouper should be evaluated.

Serious flaws remain with the gag grouper stock assessment, causing economically and socially devastating regulations which we feel are unnecessary, given that effort has fallen by 35% on offshore trips (more than nine miles) into the Gulf from Florida.  We contend that effort will continue to decline for the foreseeable future as fuel prices rise.  Fuel at the dock is already $4.35 per gallon for mid grade in Madeira Beach, FL.

Where is our credit for the venting tools, dehooking devices and circle hooks that we are about to be required to use because they "reduce discard mortality"?  Give us credit when we earn it.

When we have discard mortality reduction methods implemented, we should get that percentage applied to our landings figures.  Give us credit when we earn it.

We want a 24" gag size limit factored into alternatives for landings reduction.

A 24" gag minimum gives a 20% reduction BY ITSELF.

A 24" size limit would help to CONSTRAIN EFFORT targeted at Gag grouper WITHOUT UNNECESSARILY LIMITING OPPORTUNITY. 

Higher size limits constrain fishing effort.  Lower size limits will increase landings of small fish before they reach maturity and increase the recreational effort because it is easier to catch a smaller fish.  Lower size limits will cause more anglers to target the fish, thereby increasing effort and landings.  Higher size limits constrain effort by discouraging fishing for smaller, easier to catch fish.

Bag limits and size limits work, witnessed by the red grouper and vermillion snapper stock recoveries.

Where is our credit for the venting tools, dehooking devices and circle hooks that we are required to use because they "reduce discard mortality"?  Give us credit when we earn it.

As far a accountability measures go, we want our unused quota added to the following year.   Fair is fair.  Give us credit when we earn it.

TELL THE COUNCIL YOUR ANSWERS:

Has your effort reduced or increased since 2003?

How do you feel that fuel prices will impact your frequency of offshore fishing?

Will you fish less often because of fuel prices?

We want a full Economic Impact Analysis for the grouper.  It will cause a negative economic impact of nearly one billion dollars, with a direct economic expenditure effect of $300 million.  The Social Impact Analysis is UNACCEPTABLE.

Some notes fromt the FRA postion on Amendment 30B:

Allocation-

No change from amendment one until the full reallocation is done.

A full reallocation cannot be done without solid recreational data, which is three years away.

This interim allocation is an end run n the reallocation issue.

ACCOUNTABILITY MEASURES

We want accountability measures to include our quota being carried forward if we do not harvest our allowable catch in a given year. We contend that it is only fair to carry forward unused portions of quotas due to the cyclical nature of the fish stocks and fishing effort.

Landings for the rec sector will be coming from MRFSS, which is proven unreliable and has been specifically stated to NOT be an in season quota monitoring system.  There appears to be no mechanism for correcting any mistakes that NMFS might make in estimates which would close the fishery before it had reached its quota.

We also are concerned that if a fish stock increases in size with subsequent landings increases, the sectors will be penalized for a robust fishery with no relief coming until a new stock assessment is completed.  Give us credit when we earn it.

SIZE LIMIT ALTERNATIVES

We request consideration a 24" gag, five aggregate grouper, including red grouper, gag, black and other grouper.  We estimate this will yield a 20 % reduction in gag, coupled with the 35% offshore effort reduction that has occurred.  THIS EFFORT REDUCTION IS SHOWN BY THE MRFSS NUMBERS. We do not expect to see gas prices ever go lower.  it now costs nearly $4 per mile to run and average offshore boat, and we expect that gas prices will only increase.

We want credit for the effort reduction.  We also feel that the gag assessment is in need of refinement.  We feel that the stock is in good shape and is sustainable at or very near the current fishing levels for the recreational fishery.

NO CLOSED SEASONS. 

Bag limits and size limits work, witnessed by the red grouper and vermillion snapper population.

DISCARD MORTALITY REDUCTION

When we have discard mortality reduction methods implemented, we should get that percentage applied to our landings figures.  Give us credit when we earn it.

MARINE RESERVES

WHY IS ONE COUNCIL MEMBER ABLE TO HAVE THE ENTIRE SECTION ON MARINE PRESERVES INCLUDED WITHOUT THE OTHER COUNCIL MEMBER'S INPUT?

The Marine Reserves alternative has no place in this or any other fisheries management plan.

Marine reserves have no proven value or quantifiable effects on the fisheries. The marine reserves measures should be moved to considered but rejected, and not considered until there are quantifiable benefits that can be considered.

Economic misinformation within the 30B document:

The typical Gulf marine recreational angler was 44 years old, male (80%), white (90%),

employed full time (92%), and had an average annual household income of $42,700. The

average number of years fished in the state was 16. The average number of fishing trips taken in

the 12 months preceding the interview was approximately 38 and these trips were mostly (75%)

one-day trips. The average expenditure on the intercepted trip was less than $50.