Regarding Snapper Grouper Regulatory Amendment 14, Action 2 - Modify the fishing year for the black sea bass recreational sector –
It goes without saying that in a year-round fishery the start date has little impact. However we will not likely see a year round fishery for black sea bass again and a uniform start date will inevitably disadvantage one area compared to another.    We believe the Council should set the season length and perhaps a framework of time when the season can be open and allow the states to set their season to best suit their fisheries.  

Regarding Action 3 of Amendment 14 - Modify the recreational accountability measure for black sea bass –
This is a common action in several Amendments, and our position on all of them is that the Council should adopt uniform Accountability Measures for recreational fisheries that have these three essential elements:

1.  The season should be set based on when the ACT is projected to be met;
2.  Should overages in the ACL occur, payback provisions should only be implemented if the stock is overfished; the entire ACL is exceeded; and if the recreational harvest is responsible for the ACL overage.
3.  If the overage occurs in three consecutive years, paybacks in the following year should be implemented until the overages cease.  

Regarding Action 4 and Action 5 of Amendment 14 -   
We believe that when feasible, the commercial and recreational season should start at the same time.

Regarding Dolphin Wahoo Amendment 5, Action 1 - Revise acceptable biological catches (ABCs), annual catch limits (ACLs), and annual catch targets (ACTs) for dolphin and wahoo -  
We believe the use of MRIP in setting catch limits is the appropriate action and support Alternative 2.  

Regarding Dolphin Wahoo Amendment 5, Action 2 - Revise the accountability measures (AMs) for dolphin and wahoo –
We are concerned that the Accountability Measure for the commercial fishery is open-ended no matter which alternative is selected.  As long as the fishery is not overfished and the total ACL is not exceeded, overages could occur annually which would be a de facto allocation shift.  Similar to the language we suggest for recreational AMs, serial overages must be eliminated and paybacks initiated after 3 years.

Regarding Dolphin Wahoo Amendment 5, Action 3 - Revise the framework procedure in the Dolphin Wahoo Fishery Management Plan –
We believe the ability to use a framework action to adjust catch limits is appropriate and support the adoption of the preferred alternatives 2 and 3.   

In Dolphin Wahoo Amendment 5 Action 4 - Establish a commercial trip limit for dolphin in the exclusive economic zone (EEZ) in the South Atlantic Council’s area of jurisdiction -  
CCA supported a 3,000-pound commercial trip limit in 2003 as a means to ensure a directed dolphin longline fishery did not develop.  There were concerns of localized depletion by both private rec and for-hire captains.  The Council adopted the trip limit but it was not allowed by NOAA Fisheries.  Our concerns still remain.  We believe a trip limit that would have little impact on the historic dolphin fishery but preventing a longline fishery from developing is still appropriate. We support the adoption of a 3,000-pound commercial trip limit for dolphin.  

In Amendment 20 to the Coastal Migratory Pelagics FMP - Establish Regional Annual Catch Limits (ACLs) for Atlantic Migratory Group King Mackerel and Spanish Mackerel –
In general, we believe allowing the states to set their own seasons, within a seasonal framework set by the Council, and where feasible have their own quota, is appropriate.  

In Coastal Migratory Pelagics Framework, Action 1 - Modify restrictions on transfer-at-sea and gillnet allowances for Atlantic migratory group Spanish mackerel –
This provision is supposed to take care of the uncommon incidence where a Spanish mackerel gill net boat catches more than the daily trip limit and would allow that Captain to cut the net and transfer it to another federally permitted vessel, thus reducing dead discards.

This seems to be a clear “slippery slope” action that would be difficult at best to enforce.  The Advisory Panel did not like it and we do not believe this action is appropriate. We believe it makes much more sense for the Council re-examine the use of gill nets as allowable gear in the Spanish mackerel fishery if this problem persists.  

Amendments to the Fishery Management Plans for Snapper Grouper, Dolphin Wahoo, Coral, and Coastal Migratory Pelagics

All public hearings are scheduled from 4:00 p.m. to 7:00 p.m.

Wednesday, August 7
Doubletree Hotel
2080 N. Atlantic Avenue
Cocoa Beach, FL  32931
Phone: 321-783-9222

Thursday, August 8
Hilton Key Largo Resort
97000 South Overseas Highway
Key Largo, FL 33037
Phone: 305-852-5553