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Please read the announcement below calling for public comment on Sector Separation. Please provide your comment. Sector Separation will not go into effect if the Dept. of Commerce does not approve of the scheme.



The following Southeast Fishery Bulletin from NOAA Fisheries is being sent to our readers as a courtesy.

SOUTHEAST FISHERY BULLETIN
(Gulf of Mexico)

FB15-006
Peter Hood
727-824-5305

January 23, 2015


NOAA Seeks Comments on a Proposed Rule to Establish Two Recreational Sub-Quotas for Gulf of Mexico Red Snapper

Comment Period Ends March 9, 2015

NOAA Fisheries is seeking public comment on a proposed rule that would establish distinct private angling and federal for-hire sub-quotas for red snapper. These measures are outlined in Amendment 40 to the Fishery Management Plan for the Reef Fish Resources of the Gulf of Mexico submitted by the Gulf of Mexico Fishery Management Council (Council). The proposed rule published in the Federal Register on January 23, 2015, with the comment period ending March 9, 2015.

NOAA Fisheries encourages constituents to access the proposed rule and Amendment 40 at http://sero.nmfs.noaa.gov/sustainable_fisheries/gulf_fisheries/reef_fish/2013/am40/index.html for more complete information.

If implemented by NOAA Fisheries, this rulemaking would provide a basis for increased flexibility in future management of the recreational sector, and reduce the chance for recreational quota overruns, which could jeopardize the rebuilding of the red snapper stock. This rule would implement the management measures in Amendment 40.

Proposed Management Measures
The rule would establish sub-quotas for federally permitted for-hire vessels and private anglers who fish for red snapper for a three-year period beginning in 2015.
• The federal for-hire component would be comprised of all for-hire operators with a valid or renewable federal reef fish charter vessel/headboat permit.
• The private angling component would be comprised of private recreational anglers and other for-hire operators who do not have a federal reef fish charter vessel/headboat permit.
The rule would implement sub-quotas from the 5,390,000-pound red snapper recreational quota using Amendment 40's allocation of 42.3 percent to the federal for-hire component and 57.7 percent to the private angling component.
• The federally permitted for-hire quota would be 2,279,970 pounds.
• The private angling quota would be 3,110,030 pounds.
Finally, the rule would establish separate red snapper annual catch target and season closure provisions for the federal for-hire and private angling components. For both components, each season would start June 1 and continue until the individual component's annual catch target is projected to be caught. A 20 percent buffer is applied to the recreational quota to get the annual catch target, which is then allocated between components. At this time, NOAA Fisheries cannot project season lengths for the components because it is waiting to receive 2014 recreational landings data as well as the results of an update to the red snapper stock assessment. Contingent on the approval of Amendment 40 and input provided on the proposed rule, season lengths will be announced in the final rule.
Based on a sunset provision selected by the Council in Amendment 40, the management measures implemented through this rulemaking would end after three years unless the Council takes additional action. The Council is currently evaluating other measures to manage the recreational sector including red snapper regional management.

Request for Comments
NOAA Fisheries must receive comments on this proposed rule no later than March 9, 2015. We will address all comments specifically directed to Amendment 40 or the subsequent proposed rule in the final rule. You may obtain electronic copies of Amendment 40 and the proposed rule from the NOAA Fisheries Web site:
http://sero.nmfs.noaa.gov/sustainable_fisheries/gulf_fisheries/reef_fish/2013/am40/index.html or the e-Rulemaking Portal: www.regulation.gov.


How to Submit Comments
You may submit comments on the proposed rule, identified by NOAA-NMFS-2014-0107, by any of the following methods:
Electronic Submission: Submit all electronic public comments via the Federal e-Rulemaking Portal. Go to
http://www.regulations.gov/#!docketDetail;D=NOAA-NMFS-2014-0107, click the "Comment Now!" icon, complete the required fields, and enter or attach your comments.

Mail: Submit written comments to Peter Hood, NOAA Fisheries, Southeast Regional Office, Sustainable Fisheries Division, 263 13th Avenue South, St. Petersburg, Florida 33701-5505.

Instructions: Comments sent by any other method, to any other address or individual, or received after the end of the comment period, may not be considered by NOAA Fisheries. All comments received are a part of the public record and will generally be posted for public viewing on www.regulations.gov without change. All personal identifying information (e.g., name, address, etc.), confidential business information, or otherwise sensitive information submitted voluntarily by the sender will be publicly accessible. NOAA Fisheries will accept anonymous comments (enter "N/A" in the required fields if you wish to remain anonymous). Attachments to electronic comments will be accepted in Microsoft Word, Excel, or Adobe PDF file formats only.


About Gulf of Mexico Fishery Management Council
The Gulf of Mexico Fishery Management Council is one of eight regional Fishery Management Councils established by the Fishery Conservation and Management Act of 1976. The Council prepares fishery management plans, which are designed to manage fishery resources within the 200-mile limit of the Gulf of Mexico.
 

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Posted my comment although it does not matter what we say.
Your right
But My comment is that if they do not have an Accurate system to count the fish We Catch then they should Butt out of the Private sector all together and let Each State regulate their OWN !!!
 

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Here are some excerpts from The Environmental Defense Fund's response to AM 40 - it really would be humorous if it wasn't so tragic.

"...Looking ahead, the agency can lead the recreational red snapper fishery to improved fishing opportunities and accountability to conservation goals by developing effective management tools for the recreational quota and its sub-sector allocations. These tools include IFQ management in the for-hire fishing sector and harvest tag and angling management organization (AMO) management in the private angler sector. Also, while red snapper is in the spotlight, many valuable fish species have competing user groups and are following the same failed pattern. The best path forward would be to extend sector allocations, sector-specific buffers and paybacks, and comprehensive management tools across the Gulf of Mexico’s multispecies fishery.

Amendment 40 presents an opportunity for anglers to resolve these differences and participate in management as unified groups that have a direct stake in the outcomes of policies.Moving beyond the conflicts will clear the way for anglers to share and build upon the economic and conservation benefits of the Gulf of Mexico’s successful commercial red snapper fishery. We believe this is the most important conservation benefit that Amendment 40 can deliver – that it can create new opportunities for meaningful management improvements, not just in the recreational red snapper fishery but also in other Gulf of Mexico recreational and commercial fisheries that are in need of management reform.

Kristen McConnell
Senior Conservation Manager
The Environmental Defense Fund
Gulf of Mexico Oceans Program

Daniel Willard, PhD
Economist
The Environmental Defense Fund
Gulf of Mexico Oceans Program"

There you have it - straight from the horse's mouth - Amendment 40 is ALL ABOUT implementing IFQs in the for-hire industry and fish tags for everyone else. And, as I have stated on numerous occassions, AM 40/Catch Shares is NOT just about Red Snapper - it's about converting every federally-managed fish that swims out there into private commodities.

They claim it will lead to increased fishing opportunities, yet AM 40 ignores the effects of its implementation on the largest stakeholder group in the Gulf - the private recreational fishermen. Far from leading to increased fishing opportunities, AM 40's segregation powers are projected to result in 1/50th of fishing days for private recs vs for-hire boats this year. Bogus propaganda to the extreme.

They claim it is a resolution to the conflict between fishermen when in reality it is the source of the conflict.

They claim it's only for red snapper, but red snapper is just the gateway fish for implementation of Catch Shares to all of the fish we catch.

Roy Crabtree claims that AM 40 has nothing to do with Catch Shares - he is a liar.

Here is the link to voice your opinion on the matter;
http://www.regulations.gov/#!submitComment;D=NOAA-NMFS-2014-0107-0128
 

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Discussion Starter · #7 ·
TIPS FOR SUBMITTING EFFECTIVE COMMENTS*
Overview from: http://www.regulations.gov/docs/Tips_For_Submitting_Effective_Comments.pdf

A comment can express simple support or dissent for a regulatory action. However, a constructive, information-rich comment that clearly communicates and supports its claims is more likely to have an impact on regulatory decision making.

These tips are meant to help the public submit comments that have an impact and help agency policy makers improve federal regulations.

Summary
 Read and understand the regulatory document you are commenting on
 Feel free to reach out to the agency with questions
 Be concise but support your claims
 Base your justification on sound reasoning, scientific evidence, and/or how you will be impacted
 Address trade-offs and opposing views in your comment
 There is no minimum or maximum length for an effective comment
 The comment process is not a vote – one well supported comment is often more influential than a thousand form letters

Detailed Recommendations
1. Comment periods close at 11:59 eastern time on the date comments are due - begin work well before the deadline.
2. Attempt to fully understand each issue; if you have questions or do not understand a part of the regulatory document, you may ask for help from the agency contact listed in the document.
Note: Although the agency contact can answer your questions about the document’s meaning, official comments must be submitted through the comment form.
3. Clearly identify the issues within the regulatory action on which you are commenting. If you are commenting on a particular word, phrase or sentence, provide the page number, column, and paragraph citation from the federal register document.
a. If you choose to comment on the comments of others, identify such comments using their comment ID’s before you respond to them.Page 2 of 3
4. If a rule raises many issues, do not feel obligated to comment on every one – select those issues that concern and affect you the most and/or you understand the best.
5. Agencies often ask specific questions or raise issues in rulemaking proposals on subjects where they are actively looking for more information. While the agency will still accept comments on any part of the proposed regulation, please keep these questions and issues in mind while formulating your comment.
6. Although agencies receive and appreciate all comments, constructive comments (either positive or negative) are the most likely to have an influence.
7. If you disagree with a proposed action, suggest an alternative (including not regulating at all)
and include an explanation and/or analysis of how the alternative might meet the same
objective or be more effective.
8. The comment process is not a vote. The government is attempting to formulate the best policy, so when crafting a comment it is important that you adequately explain the reasoning behind your position.
9. Identify credentials and experience that may distinguish your comments from others. If you are commenting in an area in which you have relevant personal or professional experience. (i.e., scientist, attorney, fisherman, businessman, etc.) say so.
10. Agency reviewers look for sound science and reasoning in the comments they receive. When possible, support your comment with substantive data, facts, and/or expert opinions.
You may also provide personal experience in your comment, as may be appropriate. By supporting your arguments well you are more likely to influence the agency decision making.
11. Consider including examples of how the proposed rule would impact you negatively or positively.
12. Comments on the economic effects of rules that include quantitative and qualitative data are especially helpful.
13. Include the pros and cons and trade-offs of your position and explain them. Your position could consider other points of view, and respond to them with facts and sound reasoning.
14. If you are uploading more than one attachment to the comment web form, it is recommend that you use the following file titles:
Attachment1_<insert title of document>
Attachment2_<insert title of document>
Attachment3_<insert title of document>
This standardized file naming convention will help agency reviewers distinguish your submitted attachments and aid in the comment review process.Page 3 of 3
15. Keep a copy of your comment in a separate file – this practice helps ensure that you will not lose your comment if you have a problem submitting it using the Regulations.gov web form.

Form Letters
Organizations often encourage their members to submit form letters designed to address issues common to their membership. Organizations including industry associations, labor unions, and conservation groups sometimes use form letters to voice their opposition or support of a proposed rulemaking. Many in the public mistakenly believe that their submitted form letter constitutes a “vote” regarding the issues concerning them. Although public support or opposition may help guide important public policies, agencies make determinations for a proposed action based on sound
reasoning and scientific evidence rather than a majority of votes. A single, well-supported comment may carry more weight than a thousand form letters.
* Throughout this document, the term “Comment” is used in place of the more technically accurate term “Public Submission” in order to make the recommendations easier to read and understand.

Disclaimer: This document is intended to serve as a guide; it is not intended and should not be considered as legal advice. Please seek counsel from a lawyer if you have legal questions or concerns.
 

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A few more things you might want to think about. Historical catch data covers a period time prior to GPS and especially differential and WAAS. The new electronics made it much easier for recreational anglers to find fishing spots and that is one reason why the pounds caught by recreational anglers has increased---that increase will remain and perhaps even get get better for the amateur. Point being we should not go back in time to get the average pounds per sector when the recreational fleet was much less effective in finding red snapper. We should use data from 2011-2013 to predict the future not data from old technology.

Point 2. The snapper fish has been turned into catch and release for both sectors. We know snapper have a high release mortality but have no way of measuring the impact. Amendment 40 will do nothing to reduce By-catch mortality.

Point 3. Artificial reefs have likely made a huge difference in the current population levels of red snapper and appear to be doing the same with Lionfish. Recent research has demonstrated that Lionfish drive snapper off the reef. This introduces a new level of uncertainty in population assessments. Such uncertainty only compounds the difficulty in trying to understand the impact of new changes to management of the fishery. It is a bad time to throw Amendment 40 into the pot.
 
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