Everyone write a letter to the people on the amendment 15 b doc. call them!!!!!!!!
To: Bob Mahood December 2, 2007
Executive Director, South Atlantic Fishery Management Council
Re: Input on Amendment 15
I would like to address concerns that I have with SAFMC taking away the ability for a Standard NC Commercial License holder to sell their catch under the recreational bag limits. I have read thru the Amendment 15B proposal and have trouble understanding the benefit of such a restriction. There are 73 species in the Snapper / Grouper category. Being bound to the Recreational bag limit is hard enough and now I may not be able to sell Grouper or Snapper at all. I pay a higher renewal fee for my license, commercially register my vessels and have to purchase and maintain special safety equipment required by the Coast Guard for commercial fishing vessels, yet the Standard Commercial Fisherman doesn’t seem to be considered a real commercial fisherman in cases like this. I supplement my income and provide for my family with this license because it allows me to catch and sell all of my catch (Snapper and Grouper are my major income producing catch). Restricting the sale of fish in this category will greatly diminish the purpose of holding a Standard NC Commercial Fishing License for me & many other fishermen, not to mention the market value of it. How can I recoup the price I paid for the license or why am I restricted in the use of the license if the primary reason for the purchase has been taken away? The fisheries resource management is supposed to be the primary focus of all amendments but all I see is political power used to shift control to a specific "sector" instead of what is best for all fishermen.
Is it going to be that much more cost effective to eliminate the trip tickets for our license category? I would also like to point out that the most recent Amendment 15B (INCLUDING A DRAFT ENVIRONMENTAL IMPACT STATEMENT, INITIAL REGULATORY FLEXIBILITY ANALYSIS, DRAFT REGULATORY IMPACT REVIEW AND DRAFT SOCIAL IMPACT ASSESSMENT/FISHERY IMPACT STATEMENT) to the “Fishery Management for the Snapper/Grouper Fishery of the South Atlantic Region” must be redone. The impact statements, assessments, analyses, & impact reviews are incomplete & do not account for the major groups that it will affect. The largest Group (7,000 Commercial Fishermen without Federal Permits) is not properly evaluated in Amendment 15B. Instead Amendment 15B only divides the fishermen into 2 Major Groups:
a) Group # 1 was defined as the Commercial Fisherman with Federal snapper/grouper permits
Group # 2 was defined as Recreational Fisherman (Charter Boats & Head Boats)
Whereas the Fisherman should have really been divided into 4 Major Groups:
a) Group # 1 can be defined as the Commercial Fishermen with Federal Snapper/Grouper permits
Group # 2 can be defined as Recreational Fishermen (Charter Boats & Head Boats)
c) Group # 3 can be defined as Commercial Fishermen with State issued Commercial Fishing Licenses with endorsement to sell Licenses.
d) Group # 4 can be identified as Recreational Angler (Saltwater Recreational License only) while not fishing on the Charter or Head Boats.
The study performed does not address many of the issues with eliminating the sale of fish by Group #3. It will not be fair or ethical to eliminate the sale of fish caught by Group #’s 2 & 3. These people are trying to make a living just like the Fishermen in Group # 1.
There are several underlining reasons that have been listed in Amendment 15B for the removal of these privileges and they are as follows:
1) Recreational quotas could be counted twice.
If the fish were caught and sold under the "Recreational" classification now and counted accidentally towards the commercial quota, by eliminating the Rec division, you only managed to put more money in the commercial fisherman's pocket. The same amount of fish will be taken from the stock. The only difference is who will be cashing the check from the sale itself.
MRF states that the "Annual Recreational Harvest" is only about 8 % of the total US harvest of finfish.
If the species stock were the true focus, this would in-fact be an accidental asset for the species instead of hurting it. It should be easier to either add a question on the trip ticket to define the type of license held by the person selling the fish or simply subtract the total sale volume from the Federal Snapper / Grouper permit holders from the totals produced from all of the trip tickets.
2) The council has expressed an interest of establishing a "professional snapper grouper fishery".
The next sentence says "The intent of this action is to ensure regulations are fair and equitable, fish harvested by the recreational sector are not counted toward commercial quotas, and the total landings data are accurate".
How is this fair? Can't we change the method of how the fish are recorded with a few different questions on the collection, and by that also make the data more accurate?
At the end of the day, is it all about money and whose pocket the sale of the fish goes into (Commercial or Recreational classed fisherman)?
3) Conflict between Recreational and Commercial fisherman would have a degree of finality to the issue.
You will be taking the rights from one group and shifting control of a small specific market to another group. Do you think Recreational Fishermen are going to get a warm and fuzzy feeling towards the Commercial sector after you take away their sales privileges?
4) To eliminate the ability to subsidize the cost of a fishing trip through the sales of harvested Snapper/Grouper.
What is wrong with being able to sell fish under the Recreational Bag limit trip quota? Does it matter whether the fish is sold or given away? How will this help the fish stock? I don't see the correlation here. I quote Amendment 15B ‘A dead fish is a dead fish’.
It is stated in Amendment 15B that no evidence exists to suggest that the act of selling fish to subsidize the cost of the trip is a significant component to total recreational demand. Therefore, reduced angler demand is expected to be minimal. This may be true for the Charter boats, but it would have a large impact on Group # 3 & Group # 2 on the days that they do not have a paid charter.
5) The fish stock is not going to benefit from the new allocation. If the fish that are caught & sold under the Recreational Bag Limit are being counted as commercial right now, and they take that away from us, the Commercial Guys with Federal S/G Permits will get more money in their pockets.
Recreational Fisheries Release mortality is presently assumed to be 25% and Commercial Fisheries Release mortality is presently assumed to be 40%.
Data collected from 1992 - 2004 was done thru the commercial sector. This mortality rate was primarily based on a study, which consisted of deep drops using electric reels in a commercial setting, and is in no way representative of the recreational catch & release mortality.
Fish in the cited studies had extremely long times on deck (2-5 minutes) for measuring and handling before being released. This added to the baro trauma experienced by the fish and also increased the % mortality.
The recent Gulf of Mexico Red Grouper SEDAR study accounted for this, which forced the Gulf Council to lower their release mortality to 10 -12 % for recreational discards. Why are SAFMC mortality rates so different?
As another example, (according to Florida Fish and Wildlife Research Institute), there is a Florida Headboat survey underway which shows that observed release mortality is less than 2% for grouper caught between 20 meters and 40 meters of depth. Since most of the recreationally caught fish in the South Atlantic are caught in less than 40 meters of depth, the mortality rate of 10 % would be far more appropriate.
50% of maturity for Gag grouper is 3 years and 25.5 inches. So why is the minimum size for Gag grouper still at 24”? Studies suggest that minimum fish size should allow 50% or more of the fish to have spawned before being harvested. So why not increase the recommended minimum size of 26” or 28”?
Why are Gag grouper closed for spawning during March & April commercially during their spawning season, yet the recreational season is still open to two gags per person?
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.
From the 2006 License & Statistics Annual Report:
There are 801 registered (2005) Commercial Snapper / Grouper Permits to date.
There are 8,896 Standard Commercial Fishing Licenses
787 of the licenses are held by Charter / Head boats
As of this survey, the economic impact for 2005 attributed to the Standard NC Commercial Fishing License was $ 119,503,230 creating a total of 8,846 jobs, 560 of those being new jobs.
There has to be a win/win solution. It can't be to take the privileges away from one sector and give it to another. Please consider what you are doing to license holders. We have followed the rules, purchased the license for sale purposes, paid renewal fees, etc. There may need to be changes in the data collection method, but at the end of the day, who is actually going to benefit from this part of the proposal & why?
In Summary:
1) I strongly object to prohibiting the sale of commercially caught snapper and grouper that I catch and sell under my NC Standard Commercial Fishing license.
2) Gag grouper fish mortality rates must be revisited along with the stock assessment.
3) Minimum size for Gag Grouper must be increased to at least 26”
4) Amendment 15 impact statements, assessments, analyses, & impact reviews must be redone.
Sincerely,
Selling Grouper Snapper taken away by our federal Govt. only a few benifit 
