I. RECOMMENDATIONS
- CCA
FLORIDA
SUPPORTS AND STRONGLY URGES THE GULF COUNCIL TO PROHIBIT THE USE OF BOTTOM LONGLINES OUT TO 50 FATHOMS.
- CCA
FLORIDA
URGES THE GULF COUNCIL TO DELETE THE CREDIT FOR THE “FAKE” REGULATION ON THE COMMERCIAL FISHERY, THE ONE MONTH CLOSURE, AND ADOPT OTHER REAL MEASURES TO ACHIEVE THE NECESSARY REDUCTION IN COMMERCIAL TAKE.
II. COMMENTS
- COMMERCIAL OVERFISHING IS CLEARLY THE PROBLEM WITH RED GROUPER
Gulf stocks of red grouper have been designated as “overfished” and federal agencies are under a legal mandate to stop overfishing and restore depleted grouper stocks. On average, the commercial fishery takes 75% of the Gulf red grouper landings, with some years as high as 87%. Recreational take is so small that even if the Council prohibited all recreational take it would not be sufficient to restore the fishery. Commercial longlines take 66% of the commercial landings.
- LONGLINE GEAR APPLIES MORE PRESSURE THAN THE FISHERY CAN BEAR
Longline boats stay out multiple days setting many miles of baited hooks and lines. The gear is capable of applying intense fishing effort and getting large catches even on declining stocks of fish. The Gulf’s red grouper stocks have been hammered into an overfished condition by the fleet of longline boats not by hook and line fishermen.
-
FLORIDA
FISH AND WILDLIFE CONSERVATION COMMISSION SUPPORTS THE LONGLINE GEAR PROHIBITION
99% of all Gulf red grouper are caught off of and landed in
Florida
. It is a
Florida
fishery and the Council should recognize and support the recommendations of the
Florida
fisheries agency. The Florida Fish and Wildlife Conservation Commission has taken a strong position on this issue and has urged the Council to prohibit longlines out to 50 fathoms.
- ALL OTHER AREAS OF GULF AND
SOUTH ATLANTIC
PROHIBIT LONGLINING OUT TO 50 FATHOMS
The area off of west
Florida
is the only area from
Texas
to
North Carolina
where bottom longlines are allowed inside of 50 fathoms.
- THE COUNCIL SHOULD ELIMINATE THE “CREDIT” FOR THE ONE MONTH COMMERCIAL CLOSURE BECAUSE IT IS A FAKE REGULATION
The Council has proposed giving the commercial industry an 8% harvest reduction “credit” toward the necessary 45% reduction in red grouper landings for the existing one month closure. However, as we predicted, the one month closure did not reduce commercial landings. In fact, commercial landings increased dramatically. The one month closure was a complete failure (see landings in attachment B). Giving “credit” amounts to double counting a fake regulation. The council needs to include additional real regulations to control and reduce commercial take.
THE GULF COUNCIL AND NMFS CANNOT IGNORE THE LEGAL AND POLICY IMPLICATIONS OF KNOWINGLY INCLUDING A REGULATION WHICH IS A PROVEN FAILURE AS PART OF A CONGRESSIONALLY MANDATED RECOVERY PLAN.
- REDUCE RED GROUPER BAG LIMIT ON RECREATIONAL FISHERS FROM FIVE FISH TO TWO FISH
“The regulations that became effective in 1990 at least in part, accounted for a 70 percent decline in the recreational harvest by number and a 41% decline by weight from the average of the two preceding years.”
The Red Grouper Fishery of the
Gulf of Mexico
– Assessment 3.0
Schirripa, Legault & Ortiz - 1999
CCA Florida does not support the current Gulf Council recommendations for red grouper restrictions on recreational fishers. Our recommendation is to modify the current aggregate grouper bag limit such that only 2 of the 5 fish could be red grouper. This would reduce recreational landings by about 6%, not the 45% that the Council wants to impose. However, the Gulf Council’s past actions toward recreational fishermen in grouper management have been horribly inequitable. (See attachment A). The cumulative impact of eleven years of Gulf Council gag grouper regulations have caused average annual recreational landings, after federal regulations, to be reduced by a whopping 42%! Commercial gag landings have not been reduced at all. In fact, after enacting federal regulations, average annual commercial landings have actually increased by 7%!
CCA
FLORIDA
DOES NOT SUPPORT AN INCREASE IN MINIMUM SIZE TO 22 INCHES UNLESS THE INCREASE APPLIES TO BOTH THE COMMERCIAL AND RECREATIONAL FISHERIES.
Based on what the Council has already done to recreational fishers in gag grouper regulations it is reasonable for the Council to take the greater percentage reductions for red grouper recovery out of the commercial industry. It would not compensate for the horribly inequitable impacts on recreational fishers in gag grouper management, but it would be a good start in the right direction.
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