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A. INTRODUCTION
The National Marine Fisheries Service (NMFS) has indicated that they will enact, by emergency action, major new restrictions on the recreational fishery for Gulf red and gag grouper. The action is caused by a bizarre and unprecedented increase in the estimated recreational catch of red grouper in 2004. One management measure being discussed is 1) lowering the recreational aggregate grouper bag limit to three fish and only one can be a red grouper, and 2) prohibiting all recreational take of red and gag grouper for four months. These draconian recreational measures are being proposed at the same time NMFS is allowing commercial longline boats to take red grouper with a 10,000 pound TRIP LIMIT!
The Gulf red and gag grouper fisheries exist almost exclusively off of the State of Florida. The Florida Fish and Wildlife Conservation Commission must become actively involved in this issue to prevent the virtual elimination of the recreational grouper fisheries.
B. RECOMMENDATIONS
1. FWC should immediately urge the NMFS to conduct public hearings in Florida before taking action to enact any substantial new regulations on recreational take of red and gag grouper in federal waters off of Florida's Gulf coast.
2. FWC should petition the NMFS and Gulf of Mexico Fisheries Management Council under Section (306)(a)(3)(B) to have the Council/NMFS delegate the authority to develop the management plan and regulations for gulf red and gag grouper off of Florida to the State of Florida.
3. FWC should request the NMFS to determine and compare the adverse economic impacts of major new restrictions on the recreational fishery vs. re-allocating a portion of the commercial longline take to the recreational fishery.
C. ACCURACY OF ESTIMATED RECREATIONAL LANDINGS
The NMFS claims that estimated recreational landings of 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 completely unprecedented in the history of red grouper landings since regulations began 14 years ago (See attachment A). NMFS claims to have rechecked the data, the extrapolations, and multipliers and found no errors; however, nothing remotely close to such an increase has ever occurred. 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.
D. ADDITIONAL COMMENTS
- The Gulf red and gag grouper fisheries are Florida fisheries. More than 95 percent of all the gag and red grouper taken in the Gulf of Mexico are taken off of and landed in Florida. Despite the overwhelming dominance and importance to Florida, the other Gulf states have controlled the management decisions because Florida has only 4 of the 17 seats on the Gulf of Mexico Fishery Management Council.
- The Gulf of Mexico Fishery Management Council's past actions towards recreational fishermen in gag grouper management have been horribly inequitable. A CCA Florida analysis of Gulf grouper landings before and after federal regulations clearly indicates 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 actually increased. The process of adopting inequitable regulations began in 1990 when the Gulf Council approved major regulations to protect gag and red grouper including an increase in minimum size from 12 to 20 inches, a five-fish recreational bag limit, and a combined red/gag grouper quota on commercial fishers. These 1990 federal regulations caused a huge 54 percent reduction in recreational gag catch; however, there was no reduction in commercial take. The 8-inch increase in minimum size limit in particular had a very substantial impact on recreational anglers and no impact on commercial landings.
- In 2002, a NMFS stock assessment indicated that, for the first time in many years, gag grouper were not overfished. The entire recovery of Gulf gag grouper came as a result of a series of inequitable harvest restrictions on recreational fishermen only. Commercial fishers were subjected to essentially fake regulations - quotas so high that they were never reached, a short one-month closure that was negated by increasing effort before and after the closure, and small area closures that were negated by shifts to other nearby waters. In fact, the increases in commercial gag landings after federal regulations began actually undermined and delayed the recovery and caused even greater restrictions on recreational take.
- Commercial longlines have been the longstanding and major problem in the red grouper fishery. Commercial fishers take more than 80% of the total red grouper take and longliners take 60-70% of the commercial take.
- In June 2001, the FWC voted unanimously to request the Gulf Council to prohibit longlining out to 50 fathoms (See attachment B). The move would eliminate commercial longlining of Gulf red and gag grouper.
CONCLUSION
Without intervention and strong assistance from the FWC, the NMFS and Gulf Council will continue the pattern of horribly inequitable regulations against Florida's recreational grouper fishery and Florida will suffer substantial and unwarranted economic damage.
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