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FRA
guidance in WORD
FRA
guidance in pdf
How to
comment at the public hearing
1.
Fill out a public input card which will be available at the meeting (you
will be limited to 3 minutes so be ready with your notes!)
2.
When you’re called, state your name, your affiliation (FRA, Fishing Club
affiliations, etc) what type of angler you are.
3.
Tell them what your impression is of the present status of the Red
Snapper fishery
4.
Tell them that the science used to establish this rule is weak and
conflicts with your personal observations.
5.
Tell them NOT TO PASS THE AMENDMENT!
6.
Additional suggestions for comments are below.
Amendment 17A – Red
Snapper & bottom closure
-ACL and ABC
recommendations should be put on hold until such time as
National Marine Fisheries Service meets its charge under
Magnuson to significantly improve recreational data
collection. Setting ACL’s and AM’s without the proper data
is like building a house on a fatally flawed foundation; the
finest carpentry in the world will be rendered useless by
the crumbling foundation. This ignoring of the data
collection problem for the pursuit of fishing closures is
unconscionable. It will surely result in litigation.
-The current
stock of Red Snapper is healthy and growing. This is proof
that the current regulations are correct and working.
-We oppose
any changes in the Red Snapper regulations until such time
as there is reliable data to upon which to base any changes.
-The stock
assessment and historical data are based upon a failed
attempt to determine the stocks of Snapper before 1980.
-Because
there are different sets of data from before 1980, the
baseline date for stock assessments for Grouper/Snapper must
be reset to 1980 instead the arbitrary date of 1945. A new
assessment must be done before any regulations can be
implemented.
-Dr. Frank
Hester has proven that significant flaws exist in the
assessment and the Council must act upon this new
information that he has provided, reassessing the stocks
accordingly.
-The 7 to 6
vote on the interim rule shows the slimmest margin of
support necessary. Six Council members disagree with the
interim rule. The potential social and economic impact is
staggering; yet 7 people’s votes inflict billions in
economic damage, damage which is unnecessary in the eyes of
reasonable people.
-The closure
will shut down the charter fishing fleets and cause loss of
jobs in marinas, bait shops, restaurants etc. There has not
been an economic impact study done for the South Atlantic.
The current study extrapolates information from 2 boats in 1
port in the panhandle to the entire South Atlantic region.
-In the
State of Florida according to the Florida Wildlife
Commission in 2008 Saltwater fishing generated
$3,141,005,027 in retail sales, generated $326, 166,528 in
sales taxes, had a total economic impact of $5,369,293,552
and creates 54,508 jobs. This economy will be severely
impacted by this closure.
-We support
the use of circle hooks and venting tools to reduce
mortality. This reduction in mortality will serve to further
strengthen the stocks.
Snapper Grouper Amendment
17B
-ACL and ABC
recommendations should be put on hold until such time as
National Marine Fisheries Service meets its charge under
Magnuson to significantly improve recreational data
collection. Setting ACL’s and AM’s without the proper data
is like building a house on a fatally flawed foundation; the
finest carpentry in the world will be rendered useless by
the crumbling foundation. This ignoring of the data
collection problem for the pursuit of fishing closures is
unconscionable. It will surely result in litigation.
1.1
Speckled hind/warsaw grouper
We
support Alternative 1 (Status Quo).
There is
no basis for any changes to the fishery.
1.2
Golden Tilefish
We
support none of the Alternatives. Any allocation decision
for a low frequency of encounter fishery based on MRFSS is
wrong. The fatally flawed data simply does not adequately
account for recreational landings, and as such cannot be
reliably used. An alternative for a rec daily bag limit
should be enacted until such time as NMFS meets its mandate
to provide a reliable data collection system for making such
allocation decisions.
National
Standard 4 requires “such allocation shall be (A) fair and equitable to all such
fishermen”
Golden
Tilefish ACL & AM
-ACL and ABC
recommendations should be put on hold until such time as
National Marine Fisheries Service meets its charge under
Magnuson to significantly improve recreational data
collection. Setting ACL’s and AM’s without the proper data
is like building a house on a fatally flawed foundation; the
finest carpentry in the world will be rendered useless by
the crumbling foundation. This ignoring of the data
collection problem for the pursuit of fishing closures is
unconscionable. It will surely result in litigation.
We do not
support any of the proposed alternatives.
We do
however support a modified Alternative 5 in which the
accountability measure for the recreational anglers annual
catch limit is not tied in any way to the
commercial limit.
1.3 Snowy
grouper
We object to
all of the alternatives. The recreational anglers must be
given reasonable access to the Snowy Grouper. We urge the
Council to adopt an alternative that sets the recreational
limit of 1Snowy Grouper (Included in the 3 grouper
aggregate)
1.4 Black
grouper, black sea bass, gag, red grouper, and vermilion
snapper
-ACL and ABC
recommendations should be put on hold until such time as
National Marine Fisheries Service meets its charge under
Magnuson to significantly improve recreational data
collection. Setting ACL’s and AM’s without the proper data
is like building a house on a fatally flawed foundation; the
finest carpentry in the world will be rendered useless by
the crumbling foundation. This ignoring of the data
collection problem for the pursuit of fishing closures is
unconscionable. It will surely result in litigation.
We support
Alternative 1 which maintains the current regulations.
Snapper
Grouper Amendment 18
1: Extend the range of the snapper
grouper FMP north
We support
Alternative 1.
We do not
support the extension of the Snapper Grouper fishery
management plan north beyond the North Carolina/Virginia
border. Federal management has been inadequate in managing
the areas within the region; this extension would only
extend the lack of adequate management effort s into other
areas and diverts valuable resources and attention away from
the main area of concern in the South Atlantic.
2: Limit participation and effort in the golden
tilefish fishery
None of the
alternatives are justified.
We object to
all of the alternatives. The recreational anglers must be
given reasonable access to the Snowy Grouper. National
Standard 4 must not be ignored.
3: Modifications to management of the black sea bass
pot fishery
None of the
alternatives are justified.
All pot
fishing must be eliminated.
4: Separate snowy grouper quota into regions/states
-Separating
any fishery without the proper data is like building a house
on a fatally flawed foundation; The finest carpentry in the
world will be rendered useless by the crumbling
foundation. This ignoring of the data collection problem
for the pursuit of fishing closures is unconscionable.
We support
alternative 1.
5: Separate the gag recreational allocation into
regions/states
-Separating
any fishery without the proper data is like building a house
on a fatally flawed foundation; The finest carpentry in the
world will be rendered useless by the crumbling
foundation. This ignoring of the data collection problem
for the pursuit of fishing closures is unconscionable. It
will surely result in litigation.
We support
alternative 1.
6: Change the golden tilefish fishing year
None of the
alternatives are acceptable.
Exclusion of
recreational participation is unacceptable for an open
fishery.
7: Improve the accuracy, timing, and quantity of
fisheries statistics.
We support
Alternative 2. (Voluntary recreational logbook)
We cannot
support any changes to the regulations until reliable
statistics are available
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