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A. RECOMMENDATIONS
1. CCA Florida urges the FWC to strongly oppose the federal proposal which would prohibit all recreational grouper fishing for three months and reduce grouper aggregate limit to three fish with only one red grouper allowed.
2. CCA Florida urges the FWC to instead support measures to increase the red grouper size limit from 20" to 22" (the same as gag grouper).
There are at least two options to solve any resource problems which may exist in the recreational take. We do not understand why the National Marine Fisheries Service (NMFS) is so focused on enacting the one which causes maximum financial damage to Florida recreational fisheries.
B. COMMENTS
1. Commercial longlines have been the longstanding and major problem in the red grouper fishery. Commercial fishers take more than 80 percent of the total red grouper take and longliners take 60-70 percent of the commercial take. (see attached Table 6.3)
2. In 2001, the Florida Fish and Wildlife Conservation Commission voted unanimously to prohibit commercial grouper longlining out to 50 fathoms; however, NMFS did not take action on the recommendation.
3. The proposed NMFS emergency rule to close all recreational fishing for grouper in the Gulf for three months is completely unwarranted and punitive toward recreational anglers. In addition to prohibiting all recreational take of Gulf grouper for three months, the federal proposal would lower the current aggregate bag limit of five to three and allow only one to be a red grouper. These draconian recreational measures are being proposed at the same time NMFS is allowing commercial longline boats to take red grouper with 10,000 pound and 7,500 pound TRIP LIMITS!
4. The federal proposal against recreational anglers is caused by a bizarre and unprecedented increase in the "estimated" recreational catch of red grouper in 2004. The accuracy of estimated recreational landings is being questioned. NMFS claims that estimated recreational landings of Gulf red grouper increased from 1.536 million lbs. in 2003 to 3.530 million lbs. in 2004, a whopping 130 percent increase! Such an increase is unprecedented in the history of red grouper landings since regulations began 14 years ago. Nothing remotely close to such an increase has ever occurred since 1990. There have been dramatic reductions caused by new regulations but never such an increase. The estimates become even more suspect when you consider that Florida anglers and fishing activity was impacted by a record four major hurricanes in 2004. (see attached Table 1)
5. Past federal actions towards Gulf recreational fishermen in gag grouper management have been horribly inequitable. A CCA Florida analysis of Gulf grouper landings before and after federal regulations clearly indicated that the cumulative impact of 11 years of Gulf Council gag grouper regulations caused the annual recreational landings, after federal regulations, to be reduced by an average of 42 percent. Commercial landings were not reduced at all. In fact, after federal regulations were enacted, average annual commercial landings of gag grouper actually increased.
6. There is no reason to create major financial damage from a three month closure when an increase in the minimum size of red grouper would solve any resource problems which may exist. NMFS data indicates that an increase from 20" to 22" would reduce recreational landings of red grouper by 31 percent. The Gulf gag grouper limit is already at a 22" minimum size. (see attached Table 4)
7. NMFS argues against the minimum size increase because it would increase regulatory discards and mortality caused by release mortality. However, it is hard to believe that NMFS would allow commercial shrimp trawlers to continue shoveling millions upon millions of pounds of fish back dead into the water and suddenly become concerned about a minor increase in release mortality in the recreational fishery. A minimum size increase can be selected which will meet the resource protection goal. Why would NMFS reject that option and choose one which will inflict major financial damage on the recreational fishery?
8. NMFS has even suggested that all minimum sizes on Gulf grouper should be eliminated, a position that commercial longliners have advocated for years. However, minimum sizes have been the only management measure which has protected gulf grouper for the last 14 years. In addition, such action would lead to major increases in recreational catch of small grouper in nearshore waters and the closure of even more months of recreational fishing.
9. The Gulf red and gag grouper fisheries exist almost exclusively off of the
State of Florida. The FWC can have a major impact on the outcome of the regulations because the FWC can refuse to adopt concurring regulations in state waters. The FWC can choose different measures to protect grouper in state waters and urge the feds to concur with state regulations.
C. FINAL COMMENT
These draconian federal measures are being forced upon recreational fishers in order to fit a plan which favors and sustains the commercial longline fleet. NMFS wants to limit recreational take to 1.25 million pounds. In 2004 just 25 longliners caught 1.35 million pounds of red grouper. (see FWC info attachment)
THE NMFS MANAGEMENT SCHEME GIVES MORE RED GROUPER TO 25 LONGLINE BOATS THAN
THE AMOUNT ALLOCATED TO MILLIONS OF RECREATIONAL ANGLERS!
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