October 11, 2012
Re: Gulf of Mexico Gag Grouper Management
We understand that the Gulf of Mexico Fishery Management Council has asked for the input of the Commission on the management of gag grouper in the Gulf. We view this as a long overdue concession in light of the vast majority of gags being landed from the Gulf of Mexico waters are landed on Florida shores, and an effective way to avoid any inconsistency between state and federal regulations. We would like to share with you our views on the ongoing management of gags in the Gulf.
Perhaps the biggest issue we have had with the management of gags to date (as well as certain other species) has been the lack of an allocation between sectors that is not only fair but also provides the greatest benefit to our state and the nation. All analyses of the relative economic impacts of the recreational and commercial sectors for gags have overwhelmingly shown the greatest impact to come from the recreational sector. We reject as patently unfair the idea that those who exploit a public resource for profit should be able to do so while the public realizes not even a reasonable season or reasonable size or bag limits. We thus urge the Commission to recommend that the Gulf Council promptly re-allocate the allowable catch of gag grouper fairly and to allow for the greatest benefit to our state and our nation before the 2013 management regulations are put in place.
A second problem that exists with the commercial take of gags in the Gulf is the lack of protection of the stock during its spawning aggregations. Like a number of animals, gags are known to be "harem breeders", meaning that a single dominant male attends to a number of females. These large males tend to be the most aggressive feeders during the spawning aggregations and often caught very early in the spawn, which leaves the spawning potential of the stock well below what it would be if no directed effort were permitted for the commercial sector during the spawn, as is the case with the recreational sector.
We also view the new release devices, such as the SeaQualizer, and techniques that have recently come to light as effective ways to reduce release mortality from the "baro-trauma" that often results in fish caught in deeper waters. The Gulf Council should immediately review the studies that have shown the effectiveness of these new devices and techniques and should permit their use unless concerns that we have not seen are shown to exist.
In terms of a bag limit and the open season for the recreational take of gags, CCA Florida urges the longest possible season and strongly advocates in favor of a no less than a 2 fish bag limit. Because reducing the bag limit to 1 fish will not significantly lengthen the season, we would very much like to see the bag limit stay at 2 fish. Although the split season proposals that we have seen would not provide as long an open season as the single season proposals that we have seen, we recognize that a split season may provide the greatest benefit to the most Floridians and our visitors and we are not opposed to a split season that includes equal summer and winter subseasons with the maximum number of allowable days.
We very much appreciate your service on the Commission and our relationship with you is very important to us. We hope that you will consider these comments in the spirit intended and that you will please contact us to discuss any questions or comments.