Amendment 32 talking points – suggested highlights in
bold.
ABOUT THE DOCUMENT AVAILABILITY
Why were the documents not available until Wednesday
afternoon?
There was NO announcement when the documents WERE posted
to the website. Why not? Who made the decision to NOT tell
the public that the overdue documents were finally
available, albeit only electronically? The main document is
a 27 MEG download. That is a HUGE file. The public is
rightfully offended by the Council’s lack of respect and
obvious disdain for meaningful public input.
Does the Council have any idea or even care about the people
who have no or very limited computer access? This process
has certainly denied the general public adequate time with
the final proposals. The Excuse of ‘we’re busy’ does not
hold water. Amendment 32 had initial public hearings over a
year ago. OVER A YEAR AGO, that’s what I said. Not too
busy to push catch shares, though, as we can see by all of
the recent Council activity.
Now, the documents presented to us only days away from the
FINAL HEARINGS are still labeled DRAFT.
While the Council spends hundreds of thousands of tax
dollars on ‘outreach’ designed to ‘engage the angler in the
management process, they systematically deny us the
opportunity to provide thoughtful comments on proposed
regulations. This appears to violate the Magnuson-Stevens
Act.
How stupid do you think the public is that we will allow
you to treat us this way? We request another round of
hearings with at least fifteen days in which to review the
documents prior to a hearing.
The recreational sector has spoken loud and clear: NO
CATCH SHARES. What more does the Council need? Or is the
catch share agenda another Council damn-the-public-opinion
steamrollering of the public’s rights?
The recreational sector, including the majority of its
for hire captains, have CLEARLY SPOKEN AGAINST SECTOR
SEPARATION. So why is the Council staff preparing a sector
separation amendment? How can the Council possibly deny
their ignoring of public input?
ABOUT THE DOCUMENT ITSELF
Why is it still a draft?
How nice of them to condense 153 pages to 16 for your ease
of understanding.
The document shows that Maximum Sustainable Yield is
reduced by 25% and is renamed Optimum Yield. This is an
arbitrary 25% reduction. It will now be even easier for the
anti-fishing agenda to claim that anglers are overfishing.
What a crock of bad soup this is.
Why is the concept of re-capturing not considered? We
know full well and have scientific proof spanning fifteen
years that daily re-capture of undersized fish is a regular
occurrence, yet we treat every discard as a unique fish and
apply a high release mortality rate. This drives
regulations to eliminate fishing effort.
Why is new best available science showing minimal release
mortality in under 100 feet of water NOT being used?
Why have we not done a full benchmark stock assessment
when your Scientific and Statistical Committee asked for
it? Because of the once in 30 year red tide event, the
assessment is showing that the stock was reduced by 1/3.
This has been shown to be wrong, yet a new assessment is not
on the five year schedule of assessments.
Given that release mortality estimates HAVE been lowered
slightly, why is a 24” minimum size limit for recreational
anglers not being considered? It would result in a nearly
30% reduction in landings. The reduction should be even
higher now, given the knowledge that 2/3 of the released gag
are in state waters with an average depth of less than 30
feet. We would expect a benefit of more like 40%. All that
without destroying a person’s opportunity to fish. This
would maximize the biological effect and minimize the social
and economic impacts. DEMAND THAT THIS OPTION BE INCLUDED
AND PREFERRED. (see below).
A slot limit on a grouper is insane. Even your own Reef
Fish AP rejected it unanimously.
We are concerned that the Council is once again using a
couple of agenda-driven comments to paint the picture of the
gag fishery in the northern gulf. The individuals are
proponents of sector separation and recreational catch
shares. This is another example of selective hearing on the
Council’s part.
Why are the Interdisciplinary Planning Teams, formed and
directed by the National Marine Fisheries Service, writing
the regulations behind closed doors and without any
accountability for formulation and methodology behind
landings reduction estimates?
Just like with Red Grouper, overwhelming anecdotal evidence
has been presented attesting to strong abundance, strong
recruitment and a wide range of sizes available in the gag
fishery. These all contradict the flawed, outdated gag
assessment.
This is a 3 billion dollar mistake that the state of Florida
will bear the brunt of. We have had enough of the
mismanagement under which we have suffered for years. We
demand accountability for mismanagement.
We demand another round of public hearings, based on final
documents available AT LEAST fifteen days prior to the
hearing.
2.2 Action 2. Recreational Bag Limits, Size Limits, and
Closed Seasons
2.2.1 Gag Scenarios
PUBLIC PREFERRED ALTERNATIVE:
New full benchmark stock assessment. Interim management to be 24 “
gag minimum size, 4 fish bag limit, 2 month spawning closure
protection (Feb and March) for recreational AND commercial
harvest.
If we have a spawning protection closure, it should be closed for all
harvest.
2.2.2 Red Grouper Bag Limit
Preferred Alternative 3.
Increase the red grouper bag limit to 4 fish per person. If,
at
the end of any season, it is determined that the
recreational sector has exceeded its red
grouper ACL, the bag limit will be reduced to 3 fish. If, at
the end of any subsequent
season, it is determined that the recreational sector has
exceeded its red grouper ACL
again, the red grouper bag limit will revert back to 2 fish.
Action 3 commercial dead
discard adjustment –If dead discards are used
in recreational calculations, then they should be used in
commercial as well.
2.5 Action 5. Commercial Gag Size Limit
Alternative 1:
No action. The commercial gag minimum size limit remains at
24 inches
total length.
Female gag reach 50% maturity at about 23 inches (Figure
2.5.1). At smaller size limits, the majority of the fish
will not yet have spawned. This will reduce spawning
potential and could negatively impact the rebuilding plan.
These words say it all. What is the motivation to kill fish
before they reach sexual maturity?
2.6 Action 6. Time and Area Closures
*Note: more than one alternative and option can be selected
as preferred
Alternative 1:
No Action, Do not create additional time and area closures
that prohibit
fishing for gag and other reef fishes.
There is not enough data to accurately assess stocks. How
come we can be so precise.
Note in the chart below that our new
target is 25% less than our old one. There is more, as
they will do everything possible to make sure that we never
achieve our true optimum yield.
