Dr. Steve Branstetter,
NOAA Fisheries, Southeast Regional Office
263 13th Avenue South
St. Petersburg, Florida 33701


Dear Dr. Branstetter,

The Coastal Conservation Association is opposed to the exempted fishing permit (EFP) application filed by the Mississippi Department of Marine Resources to allow Mississippi-licensed for-hire vessels to harvest and possess Red Drum from federal waters during the course of regular for-hire fishing trips.  The application states that the EFP’s purpose is to collect biological information on offshore Red Drum to aid biologists in assessing the status of the population in a future stock assessment. Information already available to the Gulf of Mexico Fishery Management Council and to NOAA Fisheries shows this EFP will not achieve the stated scientific goals, and that it should be rejected.

Very clear scientific goals were established at the Special Red Drum Workgroup in July 2014 - none of which are addressed by this proposal.  The workshop was requested by the Gulf of Mexico Fishery Management Council to determine what information was available and what was needed to develop a stock assessment on Red Drum. The workshop was attended by members of the Gulf Council’s Science and Statistical Committee, key members of the Council’s Red Drum Committee, and other experts from around the Gulf of Mexico. The workshop determined that “fishery-dependent" data (such as those collected by fishermen and those that would be collected by this EFP) were already more than adequately represented for each state. 

The workshop identified that what is needed is “fishery independent data,” scientifically collected without selectivity bias that is a commonly associated with data collected from fishers.  Additionally, the workshop determined that the necessary information would need to include broad geographic areas from around the Gulf of Mexico, not just from Mississippi.  More specifically, these Red Drum experts determined that the primary data needed could be acquired by harvesting 10 to 20 fish from 40 to 60 schools (400 to 1200 fish total) from subsampling purse seines. In fact, this legitimate gathering of necessary scientific data to assess the health of the stock is already underway by a number of institutions. The ATTACHED PRESENTATION OUTLINING THE FINDINGS OF THE RED DRUM WORKSHOP was presented to the Gulf Council and is part of the public record.

The Gulf Council’s Red Drum Workshop identified exactly the type of harvest necessary to provide information on the status of the Red Drum stock.  This also included a need for extensive mark and recapture (i.e. catch and release) study to estimate abundance. The EFP application filed by the Mississippi Department of Marine Resources will provide data that are at best duplicative and unnecessary, and will fulfill none of the desired inputs outlined by the Red Drum Workshop.  At worst, approval of this application will signal that misuse of the EFP process will continue to not only be tolerated but encouraged, and will open the door to widespread targeting of Red Drum brood stock by the for-hire industry under the guise of science.

Red Drum is the iconic sport fish of the Gulf Coast and one of the greatest marine conservation success stories in the nation. The model of protecting the brood stock and allowing it to provide a robust, sustainable fishery for the public to enjoy is fundamentally sound and delivering at a very high level. In an era that has been characterized by high levels of acrimony and distrust between the angling public and federal fisheries management, it would be extremely detrimental to future cooperation for this EFP to be seen as the first step to dismantling the underpinnings of the red drum fishery. We urge NOAA Fisheries to reject this application.


Bill Bird, Chairman
CCA National Government Relations Committee