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
Thursday, August 8
The concept of regional management of red snapper in the Gulf of Mexico has been born out of the frustration felt by many anglers towards federal management. By almost any account, red snapper are more abundant now than perhaps at any point in history. Management has finally worked and no one wants to go back to the days when red snapper were small and hard to find. On the other hand, no one should be content with a management regime that is unable to find a way to reap the benefits of success.
CCA supports driving management of marine resources to the lowest level of government possible, ideally to the state level. That position is staked in the belief that the states simply have a better grasp of how to manage these resources in ways that ensure their health and stability. At the same time, state agencies have proven their expertise in providing the greatest access to those resources and maximizing the benefits of those resources for their citizens. Almost every one of this country’s great marine conservation success stories has been engineered by the states.
Contrast that against our experiences with NOAA Fisheries. After decades of management, participants in the red snapper fishery were rewarded with a 27-day season and a two-fish bag limit. Proposals were even made that to reduce the bag limit to one fish in an effort to increase the number of days in the recreational season and prevent a widespread revolt against federal management. While season length is indeed crucial to the recreational sector, days alone do not make a quality fishery. We believe the individual states are best equipped to determine the management approach best suited to their residents. The current situation is unacceptable, and that is with a fishery that by all accounts is recovering wildly. Rather than hoping that NOAA Fisheries will someday figure out how to copy the success of the states, we believe that this proposal to allow the states to take greater control of management could provide a solution.
The transfer of management responsibility would be no easy task, and countless details remain to be fully explored. Issues over enforcement, monitoring, state boundaries and compliance will have to be fully resolved. However, CCA believes that the best results will be achieved through negotiations between the states themselves, with as little federal influence as possible. Additionally, in the development of this proposal it should be specified that states have the ability to manage the entire fishery – both recreational and commercial – including decisions on eliminating the IFQ program - as they see fit. Another option that the Gulf Council could consider is simply removing red snapper from the Reef Fish Management plan as they have recently removed stone crabs; anchor and blackline tilefish; red and rock hind; misty grouper; and schoolmaster, dog and mahogany snapper. Such action would also allow each Gulf state to optimize the use of red snapper to the highest benefit of their residents and economies.
Recreational anglers have more faith in the ability of the states to successfully manage our marine resources than in NOAA Fisheries. If enacted correctly, CCA views state-based management as a potential path to achieving our overriding goal of healthy marine resources and increased access to them for the greatest benefit of the public.
The remaining public hearing schedule for Reef Fish Amendment 39 is as follows:
Wednesday, August 7, 2013
Holiday Inn Select
2001 N. Cove Boulevard
Panama City, FL
Thursday, August 8, 2013*
Renaissance Mobile Riverview Plaza Hotel
64 South Water Street
Monday, August 12, 2013*
Hilton St. Petersburg Carillon Parkway
950 Lake Carillon Drive
St. Petersburg, FL
All meetings begin at 6:00 pm and will conclude at the end of public comment,but no later than 9:00 pm.
NOTE: * Denotes the meeting will cover Recreational Regional Management of Red Snapper as well as Amendments 19 & 20 to the Coastal Migratory Pelagics Fishery Management Plan.
Can't attend any of the meetings? Comments on Reef Fish Amendment 39 will also be accepted online at https://bit.ly/177mEcD.
Copies of the public hearing documents can be obtained by calling 813-348-1630, or by visiting www.gulfcouncil.org.
RECOMMENDATION - Based on the information provided in the Manatee County Plan Amendment Summary, CCA Florida believes that the project will cause major damage to marine habitat in the immediate area; therefore we oppose the proposed Plan Amendment for the Long Bar Pointe project.
COMMENTS AND REASONS FOR OPPOSITION
The Long Pointe Bar, LLP development already had approved 1,086 single family homes and 2,531 Multi-family homes in 2006. The Plan amendment would add a 300 room hotel, a 300 berth marina, 72,000 square feet of office space, 120,000 square feet of commercial space, and a 84,000 square foot conference center. All of the development would be on 463.2 acres. The County memo indicates that 294.7 acres are in the Coastal High Hazard Zone.
The County document states that "no development details" have been submitted with the map amendment and the details will be reviewed in the later stages of the review process."
This shoreline is one of the last undeveloped shorelines in the area with vast mangroves and sea grasses. Details about the marina construction and location are not included. Two options are possible. One would be to dredge a canal through the shallow waters, sea grasses and mangroves to an upland dug out basin. Another would be to construct piers extending outward from the shoreline. Substantial dredging would be needed in any case. The amount of dredging in either case would be highly damaging to the mangroves and seagrasses. This special marine habitat formed by the mangroves, seagrasses, oysters and other species are essential habitat for snook, redfish, seatrout, juvenile snapper and grouper as well as countless aquatic animals.
The next public hearing on the project is on August 6, 2013. The hearing was changed from the County Commission Chambers to accommodate the expected large crowd in opposition to the project.
The applicant already has a large project previously approved. The major additions included in the amendment, especially the 300 berth marina will have a significant adverse impact on the marine environment. CCA Florida opposes the approval of the Plan amendment by the Manatee County Board of County Commissioners.
Voice your opposition at the upcoming Manatee County Commission Meeting
August 6, 2013 - 1:30 PM - Bradenton Area Convention Center