Modification of Annual Catch Limits for Gulf of Mexico Red Snapper (Responses)

	A	B	C	D	E	F
1	Timestamp	Enter your full name	email address	City, State, Zip Code	Check all that apply	Comments

2	1/26/2021 23:44:10	Frank Kornegay	fckornegay@aol.com	Gulf Shores, AL. 36542	Private Recreational Angler	The Great Snapper Count data should be the basis for all snapper decisions, beginning immediately for the 2021 season in Alabama and other Gulf states.
3	4/5/2021 10:09:02	Test	Test@test.com	Test	Other	Test
4	4/7/2021 19:20:33	Luin Burchfield	LPBURCHF@GMAIL.COM	Foley, AL, 36535	Private Recreational Angler	Please for the sake of many seasoned and brand new recreational anglers, severely limited by COVID-19, use the data provided by the Great Snapper Count, and correct the severly flawed NOAA system (or however it must be done), in order to allow recreational anglers a safe (no mad dashes in questionable seas), and reasonable fishing season. So many people need a relief from this Government madness that is COVID-19, lets not let them do it to us anglers who can practice a perfect social distancing activity in a safe and responsible manner. I believe we all know there are a LOT of Red Snapper out there...
5	4/9/2021 14:48:08	Drew Stevens	yachtdr22@gmail.com	Corpus Christi, TX		Greetings all, I would like to offer some feedback about the purposed limits. First, Standardized State data collection and reporting; There has to be a model that offers the Gulf states similar data gathering and accounting. This is PARAMOUNT. I am certain there is a program that will work for all. Second, Realistic numbers and projections. The Commercial element of the fisheries have had a paid consortium pushing and fighting for them. The Recreational element has consistently had their quotas reduced to point of very few Gulf fish caught due to the short Season vs weather window. Underfishing of Snapper has done more harm than good!!! Yes, congratulations, your conservation efforts have done their job, almost too well….. I have been fishing from Corpus Christi, TX since I got here in the Coast Guard in 1991 In that time I have seen the snapper population go from almost nil. Joking about catching 15”ers and stepping on them to make them legal. To now, the snapper are so think and so ravenous that they have dominated the depths. We have gone from little catch to catching & releasing over 100 (2 anglers) in 55 minutes We have gone from abundance of Grouper and Amber Jack to almost Nil. The Red Snapper have consumed all of the young of the other species. I remember not being able to get to the bottom with bait due to the overwhelming population of Grey Triggers to now not getting to the bottom with a bare hook because the snapper are so ravenous they will hit bare hooks! We need to think out the heard just a bit to bring balance to the species. Thank you for your attention Drew Stevens Corpus Christi, TX
6	4/12/2021 12:43:08	Catherine Bruger	cbruger@oceanconservancy.org			https://drive.google.com/file/d/10ZMqpXUhTkrlIwYdSJ0qhtQ-MAJUMmjJ/view?usp=sharing
7	4/13/2021 8:32:43	Eric Brazer	eric@shareholdersalliance.org		NGO	https://drive.google.com/file/d/1rLjMELNU7Kereh_gYcYGacDffamaxI3x/view?usp=sharing
8	4/15/2021 8:09:01	Dylan Hubbard	dhubbard@hubbardsmarnina.com	Madeira Beach, FL	Charter/Headboat For-Hire	https://drive.google.com/file/d/1eh8KRWdX8ArA3iaUjpPUcJ7XvX91PTIw/view?usp=sharing
9	4/15/2021 9:53:53	Charles Witek	charleswitek@gmail.com	New York	Private Recreational Angler	Dear Ms. Muehlstein: I ask you to share the below thoughts to the Gulf of Mexico Fishery Management Council, as it addresses current red snapper issues that, depending upon how they are resolved, has implications for both other Gulf species and fisheries managed by other regional fishery management council: How data, such as that developed in the Great Red Snapper Count, should be reviewed prior to its use for managing fisheries, and how to reconcile recreational catch estimates and other data from multiple sources that employ different methodologies. Although I am a New York resident, do most of my fishing in northeastern waters, and am only a very occasional participant in the red snapper fishery, I'm providing this comment because I am concerned that if the Gulf Council condones the hasty and inappropriate use of data such as that generated by the Great Red Snapper Count, and/or refuses to require the calibration of state fisheries data, even though the need for such reconciliation has been acknowledged for years, such bad management practices won't be limited to Gulf red snapper. When stakeholders get away with bad management practices, such bad management tends to spread. Already, some of the proposals that we've seen at the Gulf Council, which would allow anglers to escape accountability avoid annual catch limits, and otherwise evade the clear responsibilities of the Magnuson-Stevens Fishery Conservation and Management Act are beginning to appear, in slightly altered form, in measures being considered at the Mid-Atlantic Fishery Conservation and Management Act, where, in the name of "recreational fisheries reform," they threaten to degrade management for summer flounder, black sea bass and scup. As an angler who believes that the future of healthy recreational fisheries depends on good, science-based fisheries management, and as a writer who comments on fisheries management issues, I offer the following recent blog post for distribution to Gulf Council members in connection with the current Council meeting. The original blog, which contains links that did not carry over into the below transcription, can be found at http://oneanglersvoyage.blogspot.com/2021/04/gulf-red-snapper-good-science-good-data.html Thank you. ONE ANGLER'S VOYAGE Thursday, April 8, 2021 GULF RED SNAPPER: GOOD SCIENCE, GOOD DATA, AND PEOPLE WHO DON'T LIKE EITHER ONE Last month I wrote about the Great Red Snapper Count. I described how it found a Gulf of Mexico red snapper population that is three times as large as previously believed, and explained why that finding might not translate into significantly larger red snapper quotas this year. I also noted, both in last month’s essay and in other pieces that I posted in December and in September of 2020, that some folks were trying to bog down current efforts to calibrate state fisheries data so that it can be used in conjunction with the federal Marine Recreational Information Program (MRIP), because the calibration would lead to tighter regulations and lower red snapper landing—even though, from a scientific and statistical standpoint, such calibration is the right thing to do. But to organizations which, over the past decade or so, spent lots of their members’ donated money, along with political favors and institutional prestige, trying to find ways to put more dead red snapper in anglers’ coolers, good data and good science aren’t all that attractive if they lead to shorter seasons and lower recreational harvest limits. Thus, they try to spin the story in a way that makes good science look bad, in order to make bad management measures look like something good. I expected a resurgence of that sort of thing after an Alabama TV station revealed that the Gulf Council’s Scientific and Statistical Committee set 2021 acceptable biological catch for red snapper at 15.4 million pounds—just 300,000 pounds more than the 2020 red snapper ABC (ABC), despite the Great Red Snapper Count’s findings. That was a very small increase, given that Gulf scientists were willing to raise the 2021 Overfishing Limit (OFL)—the level of landings that, in theory, would produce maximum sustainable yield--to 26.6 million pounds, more than 11 million pounds above the 2020 OFL. The National Marine Fisheries Services’ guidelines for compliance with National Standard 1, which prohibits overfishing and requires fisheries to be managed for optimum yield, state that “Acceptable biological catch (ABC) is a level of a stock or stock complex’s annual catch, which is based on an ABC control rule that accounts for the scientific uncertainty in the estimate of [the Overfishing Limit], any other scientific uncertainty, and the [relevant regional fishery management] Council’s risk policy. [emphasis added]” In 2020, the Gulf Council’s Scientific and Statistical Committee (SSC) felt comfortable setting the ABC at 15.1 million pounds, only 400,000 pounds below the OFL, suggesting that they didn’t think that there was all that much scientific uncertainty clouding their calculations. But in 2021, after receiving the results of the Great Red Snapper Count, the SSC was willing to raise the OFL by about 70 percent, to 26.6 million pounds, but despite that, was only willing to raise the ABC by about 2 percent. The very big difference between the 2021 OFL and ABC signals that there is a lot of scientific uncertainty surrounding the new OFL, probably because the Count data was released so recently that there has not been time to fully incorporate it into the stock assessment model. Under such circumstances, one would expect the SSC to act like prudent professionals, and not raise the ABC prematurely; such increase can always be made next season, when and if their analysis shows that it is safe to do so. Such a cautious approach is very much in accord with the statement of Dr. Gregory Stunz, the lead researcher on the Great Red Snapper Count project, who said, upon its completion, “This is just the beginning of future assessment meetings and activities with managing agencies, Scientific and Statistical Committees, the NOAA Southeast Fisheries Science Center, and the Gulf of Mexico Fisheries Management Council. These activities will facilitate direct incorporation of these data into the management process.” Unfortunately, just as biologists can generally be relied upon to do the right thing, and approach new data with caution and not take actions that might put the red snapper stock at risk, one can generally rely upon the various fishing tackle industry, boating industry, and anglers’ rights groups involved in Gulf snapper issues to do the wrong thing, and call out for hasty decisions, provided that they involve the kind of haste that puts more fish in some members’ coolers and more money in other members’ bank accounts, even if that creates additional risks to the stock. That’s why it wasn’t surprising to read a recent op-ed in The [Biloxi, MS] Sun Herald, written by Jeff Angers, president of the Center for Sportfishing Policy, which criticized any efforts to hold anglers in Alabama and Mississippi accountable for substantially exceeding their 2020 red snapper allocations, saying “The risk of overfishing may be at an all-time low. Based on the Great Red Snapper Count, Gulf Coast anglers are due an increase in quota. Not a decrease.” In making those statements Angers, who as far as I know does not hold even a baccalaureate degree in fisheries science—or any other field of biology—seemed far more certain about the implications of the Count’s findings than the biologists on the SSC. Perhaps there’s some truth in the old saying about fools rushing in… But maybe it's just a story of red snapper anglers in the Gulf getting just what they asked for, and then not being happy with how things worked out. For many years, such anglers complained that federal estimates of red snapper landings both overestimated anglers’ harvest, and took so long to prepare that they forced red snapper season to end sooner than they needed to. So they urged the states to come up with their own landings estimates. A number of states did just that, working with NMFS to develop state programs that would estimate recreational landings in a more timely fashion than does MRIP, and would merit certification as a part of MRIP. Alabama and Mississippi were among the states that put such programs in place. Although the state programs were certified as supplements to MRIP, they each used a slightly different methodology, and thus yield somewhat different landings estimates even if fed the same data. In order to make all of the state programs’ estimates compatible with MRIP, the state data had to be converted into a sort of “common currency.” The need to do such calibration has been recognized since at least the fall of 2018, when it was discussed at a workshop on estimating the Gulf recreational red snapper catch. In June 2020, it became clear that if state landings estimates were calibrated to work with MRIP, some Gulf states, most notably Alabama and Mississippi, would would receive substantially smaller 2020 recreational red snapper quotas than they would if the uncalibrated state estimates were used. The Gulf Council was asked to do a preliminary calibration of state and MRIP data, because if the uncalibrated state data was used, overfishing would almost certainly occur. NMFS acknowledged that such concerns were legitimate, and even provided the states with preliminary figures that could be used, when setting season lengths, to avoid such overharvest. The states chose not to adopt the NMFS recommendations. Thus, the table was set. Since November 2018, everyone involved with Gulf red snapper management has known that, in order to properly incorporate the states’ recreational red snapper landings estimates into the Gulf-wide management process, such estimates must be calibrated to work within MRIP. And since last June, everyone has also known that, if uncalibrated state data was used to set 2020 recreational red snapper regulations, both Alabama and Mississippi would almost certainly badly overfish their state allocations. But, somehow, Angers doesn’t seem to have gotten the message. While he, unlike the biologists on the SSC, appears more than willing to hastily embrace the weeks-old Great Red Snapper Count data, and assure all and sundry that it justifies a substantial quota increase, he doesn’t seem to understand the need for calibrating the state landings data before it can be used to manage the resource. Instead, he argues that there is “no federal deadline for calibration,” and so neither the Gulf Council nor NMFS should try to convert state data into the required “common currency.” He apparently takes that position because “If NOAA Fisheries rushes the council to calibrate the data in April, they will likely reduce the private recreational red snapper quota by half or more in Mississippi and Alabama for years. Therefore when the data is calibrated, it punishes these two states the most... “With summer quickly approaching and families looking to make vacation plans around red snapper seasons, now is not the time to rush this management action…” Angers goes on to say that “The council should take its time to make the most informed decision using the best available science,” which is somewhat ironic, given that there is no serious doubt that the calibrated data would reflect the best available science, would be statistically valid, and would improve red snapper management. But since such calibration would also reduce the 2021 recreational quota, particularly in Mississippi and Alabama, and perhaps impact the sales of some Center members, in that case science doesn’t seem to matter—recalibration shouldn’t be done. What Angers and the Center seem to be saying is that NMFS and the Gulf Council should be quick to recognize data, such as the results from the Great Red Snapper Count, if such data might lead to an increased quota or prevent a reduction in a state allocation. But both NMFS and the Council should be slow to calibrate state landings data because such calibration could lead to reduced state allocations, and hold anglers accountable (Angers prefers the term “punish”) for exceeding allocations last year. At that point, it becomes obvious that from Angers' and the Center's viewpoint, the discussion isn’t really about good science, or good data, at all. It’s just about killing more fish. And when that’s all that you want, good science and good data just get in the way.
10	8/19/21	Eastern Gulf Fishermen	multiple			https://drive.google.com/file/d/1Ri88_egegkIqswWaLZFI1RfQH93ua-Cj/view?usp=sharing
11	8/19/21	Eastern Gulf Commercial Fishermen	multiple		Commercial Fisherman	https://drive.google.com/file/d/1El4KGALYzpA7amy6wr1_ecWkfSIRJAoD/view?usp=sharing
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100