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Discussion Starter #1
:mad: What do you think?


FB15-002

Peter Hood
727-824-5305



January 20, 2015



Notice of Availability for Public Comments on a Proposal to Establish Two Recreational Sub-Quotas for Gulf of Mexico Red Snapper



Comment Period Ends March 17, 2015



NOAA Fisheries seeks public comment on Amendment 40 to the Fishery Management Plan for the Reef Fish Resources of the Gulf of Mexico. The Gulf of Mexico Fishery Management Council (Council) has submitted Amendment 40 to NOAA Fisheries for review, approval, and implementation. The Notice of Availabilityfor public comment on this amendment published in the Federal Register on January 16, 2015. This bulletin only summarizes the proposed actions and their effects. NOAA Fisheries encourages constituents to access Amendment 40 and its associated Final Environmental Impact Statement at

http://sero.nmfs.noaa.gov/sustainable_fisheries/gulf_fisheries/reef_fish/2013/am40/index.html

for more complete information.




Purpose of the Amendment 40

If approved by NOAA Fisheries, Amendment 40 would provide a basis for increased flexibility in future management of the entire recreational sector, and reduce the chance for recreational quota overruns, which could jeopardize the rebuilding of the red snapper stock.



Proposed Management Measures

Amendment 40 proposes to 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 for-hire operators who do not have a federal reef fish charter vessel/headboat permit.
Amendment 40 would allocate the 5,390,000-pound red snapper recreational quota based on historical landings data for each sub-group. Federally permitted for-hire vessels would receive 42.3 percent of the recreational quota, and private anglers would receive 57.7 percent of the recreational quota.

The federally permitted for-hire quota would be 2,279,970 pounds.
The private angling quota would be 3,110,030 pounds.
Finally, Amendment 40 would establish separate red snapper annual catch targets 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 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 final 2014 recreational landings data as well as the results of an update to the red snapper stock assessment.



The Council proposes to sunset this action 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 notice no later than March 17, 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 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 this document,
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.
 

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Red Snappa Slappa
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Honestly....at this point who really cares...our rights are being sold to the highest bidder...its not about stock assessments or over harvesting anymore...once the word catch SHARES and STAKE HOLDERS were introduced it was game over....as sad as it is, when a commercial fisherman or a "for hire fisherman" can profit from a fish that I as a law abiding citizen of the USA am prohibited from fishing for or keeping on any of the same dates or times...it just proves that the resource has been sold to the highest bidder...
 

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hmm

What is the quota for the commercial guys?

Please correct me if I am wrong or out of line here. Red Snapper are prominently caught from Panama City to Texas. How many recreational anglers are fishing in this area for Red Snapper? Lets say it is 4,000 anglers. That would be 777lbs of red snapper caught per angler a year! If the average fish weights 8lbs, that is 97 fish per angler! That means each angler would have to go fishing 48 days out of the year to catch their 2 per person. If there was a 6 week season, that is 42 days. So technically no matter how hard I try I would never come close to quota?
 

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What is the quota for the commercial guys?

Please correct me if I am wrong or out of line here. Red Snapper are prominently caught from Panama City to Texas. How many recreational anglers are fishing in this area for Red Snapper? Lets say it is 4,000 anglers. That would be 777lbs of red snapper caught per angler a year! If the average fish weights 8lbs, that is 97 fish per angler! That means each angler would have to go fishing 48 days out of the year to catch their 2 per person. If there was a 6 week season, that is 42 days. So technically no matter how hard I try I would never come close to quota?
Don't try and make sense of the numbers it will never work out. NOAA can't explain them either and Alabama's data collection from last year proved how over blown the Feds estimates on landings were.

If they want sector separation let the charter guys get a piece of the commercial quota and leave the rec tac to the rec anglers.
 

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Discussion Starter #7 (Edited)
NOAA land

:mad: " So technically no matter how hard I try I would never come close to quota? " Welcome to NOAA land.


Public comments on Amendment 40 have been overwhelmingly opposed to sector separation. This opposition was not always at the forefront during Council meeting due to public testimony routinely dominated by a relatively few charter for-hire captains, who testified at multiple locations.

Summary of public comments received through the Gulf of Mexico Fishery Management Council web site in support of and opposed to Amendment 40.
OPPOSED 2,008 96.3%
SUPPORT 77 03.7%
Council Motion: To approve Amendment 40 and that it be forwarded to the Secretary of Commerce for review and implementation, and deem the codified text as modified in discussion as necessary and appropriate, giving staff editorial license to make the necessary changes in the document. The Council Chair is given the authority to deem any changes to the codified text as necessary and appropriate.
Motion carried 10-7 by roll call vote:
FOR: Perret, Bosarge, Greene, Williams, Walker, Sanchez, Crabtree, Dana, Pearce, Anson
Dr. Pam Dana, the recreational representative on the Gulf Council, voted YES!
AGAINST: Riechers, Bademan, Diaz, Fischer, Boyd, Matens, Stunz

Amendment 40’s sector separation divides the recreational quota of the allocated red snapper stocks into separate private angler and charter for-hire components.
The action adopted by the majority lacks support, especially from the Gulf states, and hinders future management of the fishery. This amendment and this vote signify that federal management of the red snapper fishery is broken. The way Amendment 40 was pushed through the Council process does not foster cooperative and collaborative work between the Council and the Gulf states to manage this fishery.
Most importantly, it violates several National Standards. As such it is both bad policy, and in violation of the Act. For these reasons, the Secretary should reject the amendment.
1. The Problems with Amendment 40
Despite growing popularity and demand for red snapper, private anglers will be extremely disappointed next year when they begin planning their trips. If current projections remain true, they may be faced with a one day fishing season for red snapper in federal waters. This is a consequence of Amendment 40, and it creates a situation that is unsafe to the anglers, and limits management of the fishery.
1.1 Amendment 40 Threatens Private Anglers
Amendment 40 disproportionately harms private anglers. While their 2015 season may shrink to just one day, the for-hire charter boat season will grow by up to 266.7%.1 Private recreational anglers who fish from their own vessels will be extremely limited in their fishing opportunities. As a result, they will be forced to pay for charter services, which will have more than 30 days of fishing from federal waters.
Charters and headboats are an important part of the Gulf’s local economies, but they do not stand on their own. Private anglers represent a significant component, especially among residents and tourists. Such an inequitable distribution may have serious adverse impacts on the social and economic situations in numerous coastal communities, especially those that do not have federally-permitted charter for-hire fleets and rely primarily on private angler expenditures. Unfortunately, Amendment 40 was approved by the Council without being presented or having a chance to review these socioeconomic impacts.
1.2 Amendment 40 Stifles Ongoing Management Plans
Sector Separation also limits management of the species. While the amendment distinguishes between private anglers and for-hire charters, the Act does not. Section 407(d) of the Act distinguishes between the commercial and recreational sectors, but specifically places charter for-hire fishing in the recreational side. This means that despite Amendment 40, private and charter for-hire anglers will continue to be subject to a single recreational quota. If one component of the fishery harvests more than their share, it will directly impact the other component’s quota and season length, conceivably dropping their season to zero days despite the amendment. Although the purpose and need of Amendment 40 states the amendment would “reduce the likelihood for recreational quota overruns which could jeopardize the rebuilding of the red snapper stock,” simply dividing the recreational quota into subcomponents will not accomplish this.
The Gulf states have been working toward a plan for managing the recreational sector through regional management. Such a plan could address local biological, social, and economic differences among regions while ensuring continued recovery of the Gulf red snapper stock. All five states, as well as anglers throughout the Gulf, support development of a regional approach. In response to calls for a regional management approach and better data collection, each of the Gulf states have implemented their own systems for collecting recreational catch and effort data for red snapper (and in some cases other reef fish species).
Unfortunately, Amendment 40 complicates management by creating a very different set of rules for the federally-permitted charter for-hire industry and private anglers. It adds to conflicts at the docks by pitting private anglers and federally-permitted charter for-hire vessels against each other, exacerbating perceived inequities in the fishery, and complicating regulations. If regional management moves forward under Amendment 39, then it will presumably apply only to the private anglers, who will see drastic reductions in allowable harvest thanks to Amendment 40. The result will be a complicated patchwork of regulations depending on subsector and area fished, with very little room for robust management, which is exactly what the Act was designed to avoid. Instead, regional management could simplify management, maximize local social and economic benefits, and improve data collection and accountability in the red snapper fishery.
Thanks to ACME Ventures Fishing for providing the above information
 

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Red Snappa Slappa
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from the above reading, with a 96% opposition , and the vote is still to send the measure forward......its time for a little investigative work to see who is getting paid behind the scene, then make sure they serve time, elect new members to the board, and hand them copies of the indictments to show them that they are elected to work on our behalf, and not to line their own pockets by selling off our resources....this process actually works
 

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Discussion Starter #9
Agreed 100%. "who is getting paid" is the big question. Our, or what was once our, fishery is all about greed.
A very disturbing point is that Pam Dana, recreational fisherman representative on the council, voted for 40. Just who does she really represent is the big question. We knew what 'follow the money trail' Crabtree would do, but Dr. Dana is a different story.
One problem is these jackasses are appointed, not elected. IF they had to face the VOTE it would be a completely different story.
 

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Discussion Starter #11
Appointed council members

Council member are appointed by the Department of Commerce. Before Pam Dana's first term (Florida recreational representative) our own Bo was governor Scott's number one choice . The DOC appointed Pam instead.
It would be a completely different story if all council members were elected instead of appointed.
 

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Discussion Starter #16
Personally I am for compliance with the Federal season. A 70+ state season would benefit only those in Northern Florida at everyone else's expense. Most of Florida has NO red snapper in state waters.
 

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I have a question. Are you for a 70 or more day state season or are you for the states to go complaint and have 25 days of Federal season?
Please post up the documentation that shows that we would get 25 days if the states went compliant.

Thanks in advance.

Personally, I like Tommy's idea of a 120 day Florida season (10 days/month) - THAT should generate some meaningful discussion on the REAL issues at hand.
 

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Discussion Starter #19
It must be remembered that NOAA increased the American red TAC. That, in itself, would indicate a "one day season this year."
 

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Freshwater Flounder
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...

If they want sector separation let the charter guys get a piece of the commercial quota and leave the rec tac to the rec anglers.
If you ask me ... charter boat fishing is commercial fishing.
 
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