Framework Action to Modify the Recreational Red Snapper ACTs
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TimestampFull Nameemail addressCity, State, Zip CodeCheck all that applySubjectComments
6/16/2017 9:10:38Testgulfcouncil@gulfcouncil.org33607OtherTestTest
8/2/2017 19:31:09Matt Manning
Valrico, FL 33596
Private Recreational Angler
Rec Reps and ARS daysThe Rec sector needs some REAL rec reps on the Council with ZERO ties to commercial fishing. The rec reps in place are commercial fishing insiders with one exception. The DO NOT and CANNOT represent us. We are being Legislated without Representation. This is a total trust violation that the council wants to hear from us at all. Sec. Ross has been listening to us. Respect and Open communications could begin to happen if we have real reps. Continue the same and we will push to have Secretary Ross. mandate our rights to 317 ARS days and ask for a commercial fishing ban. The fish houses can buy fish from the for-hire Captains that we support if you want to continue to abuse the resource and ignore us. We already have your top Boss'es Sec. Ross's respect and the Rec Anglers have 10x the numbers and money of commercial operations. We support the State Agencies and For Hire Captains are NOT in commercial fishing. We have the numbers and the money and we will be heard from via communication or Mandates from above. We have that battle won already. The Council's time is ticking unless you change your tune greatly toward the rec sector...
8/2/2017 21:25:55Mark RoyallRoyallti@gmail.comBradenton FL 34209
Private Recreational Angler
Red SnapperPlease delay voting on new items until the full board is seated later this year (2017).
8/4/2017 8:55:52Brendon Straub
Longwood, Florida, 32779
Private Recreational Angler
Please delay voting on new items until the full board is seated later this year (2017).
8/4/2017 9:01:30Chad andrewsFlsurfer1122@aol.comSarasota,fl 34233
Private Recreational Angler

I demand that any final actions be moved to the Biloxi meeting in October because the new council members will not be able to vote at the august meeting and they need to have their say, that is why they were appointed to the council so please let them weigh in!
8/4/2017 9:40:22Warren Kampe
Private Recreational Angler
Would like to see meeting held in Biloxi in October so new council members will be involved .
8/4/2017 9:40:38Warren Kampe
Private Recreational Angler
Would like to see meeting held in Biloxi in October so new council members will be involved .
8/4/2017 11:25:12mitch coleman
mexico beach fl 32456
Private Recreational Angler, Charter/Headboat For-Hire
snapper modsplease delay vote to Fall to allow new council members input and see what totals are coming out of Summer season
8/4/2017 21:56:54Chad andrewsFlsurfer1122@aol.comSarasota,fl 34233
Private Recreational Angler

I demand that any final actions be moved to the Biloxi meeting in October because the new council members will not be able to vote at the august meeting and they need to have their say, that is why they were appointed to the council so please let them weigh in!
8/5/2017 19:45:27Chad andrewsFlsurfer1122@aol.comSarasota,fl 34233
Private Recreational Angler

I demand that any final actions be moved to the Biloxi meeting in October because the new council members will not be able to vote at the august meeting and they need to have their say, that is why they were appointed to the council so please let them weigh in!
8/9/2017 15:31:28Dylan Hubbard
Charter/Headboat For-Hire
We feel the red snapper fishery is very robust and has really recovered in the eastern gulf and remains strong in the northern and western gulf. We feel that red snapper is a species that has been a conservation champion recovering quickly and dramatically to the point that we are forced to run away from the huge areas of red snapper we find closer and closer to shore in the central west coast of Florida. Due to this, we feel the ACL for red snapper in the rec and for hire sectors should be increased by a minimum of 10%. The larger ACL would allow for the bigger 25% buffer for the rec sector while still allowing the possibility of more fishing days if the ACT is not exceeded at the end of 2017 for the rec sector. We feel the for-hire component has not hit its ACT or ACL so the buffer for this sector should be decreased again allowing more possible fishing days and seasons made longer allowing more time for the federal for hire component to reach its ACT.
Chapter 2.1 – Action 1 – We suggest Alternative 3a increasing the rec sector ACT buffer to 25% in conjunction with alternative 4c decreasing the for-hire sector ACT buffer by 10%
If the ACL for both sectors combined was increased by 10% than the above alternatives would both increase the possibility of more fishing time while ensuring the ACTs are not exceeded, which triggers the payback in the following fishing year like we have seen in the rec sector during 2017.

9/6/2017 10:36:04Thomas Hiltonhilton@rt-nav.comArcola, Texas
Private Recreational Angler
Mr. Rindone and Gulf Council,

In regard to the upcoming Scientific & Statistical Committee Meeting, I would like to address one item on the agenda;

Review of Framework Action to Modify the ACT for Red Snapper Federal For-Hire and Private Angler Components – Rindone

If they are going to address the red snapper ACT for the For-Hire component, I would like to see some true "scientific" and "statistical" analysis of the for-hire landings/landing potential.

In particular, I would like to see a detailed analysis of the 299 Florida panhandle charter boats relative to the boat capacity and permit capacities. As you can see on the enclosed table 1.1.3, there are 212 "6 pack" boats plus 87 "multi-passenger" vessels that can carry up to over 80 passengers each. I believe there is a disconnect between the permit passenger capacities vs the boat passenger capacities as well as the impact of these multi-passenger boats on the red snapper landing numbers.

1) Please provide documentation of the actual passenger capacities of each FL panhandle vessel relative to its permit capacity - for example, a permit may provide the ability to carry 45 passengers but the boat can only take 6 passengers legally. If you cannot provide the ACTUAL passenger carrying capacity for each FL Panhandle boat, then how can you provide any realistic data relative to modifying the ACT?

2) In addition, the permit passenger capacity represents the approved potential carrying capacity for that permit - the permit holder can certainly legally purchase a larger boat AT ANY TIME to accommodate the permit passenger capacity if his current boat's capacity is smaller than his permit capacity, correct? If so, what safeguards are in place to detect if the FL Panhandle boats greatly increase their passenger carrying capacity? What is the potential impact on the for-hire ACT if this happens?

3) I would like to see a realistic "scientific" and "statistical" analysis of the numbers of FL Panhandle boat capacities and their red snapper landings for 2016 and/or 2017 - if you cannot provide this, then how can you make any realistic management decisions relating to the Gulf of Mexico red snapper at all? Please see the analysis below.

Lastly, I would like to see a detailed "scientific" and "statistical" analysis of how many of the 219 Texas federally permitted charter boats in Texas went fishing in 2016 along with their average landings per boat. Considering that Alabama's 132 charter boats landed 699,689 pounds of red snapper in 2016, and FL panhandle's 299 charter boats landed 737,803 pounds of red snapper, it seems extremely odd that Texas' 219 charter boats landed only 20,063 pounds of red snapper in 2016. According to these numbers, Alabama CFH boats averaged 5,300 pounds/boat of red snapper in 2016, or 115 pounds per season day per boat in 2016. FL Panhandle boats landed 2,467 pounds/boat of red snapper in 2016, or 54 pounds per season day per boat in 2016 (extremely odd considering the very LARGE NUMBER of multi-passenger vessels in FL Panhandle). Texas charter boats landed 92 pounds/boat of red snapper in 2016, or 0.42 pounds per season day per boat in 2016. I KNOW our Texas charter captains are better than that, especially when considering there are more and larger red snapper off of the Texas coast than found in the eastern Gulf.

Of the above figures, Alabama's is closest, as Mr. Anson provided documentation that on average in 2016, Alabama charter boats landed 130 pounds PER TRIP per boat when the six packs are averaged with the multi-passenger boats. The six packs averaged 105 pounds PER TRIP and the multi-passenger boats averaged 175 pounds PER TRIP - remember that many boats in Alabama and FL Panhandle run multiple TRIPS PER DAY. The FL Panhandle boats only landed 54 pounds per boat PER SEASON DAY? Again, considering the fact that FL Panhandle has almost 3 TIMES the number of multi-passenger boats than Alabama, this number seems extremely low. THEN, we come to Texas charter boats landing 0.42 pounds per season day per boat;

1) Please provide "scientific" and "statistical" analysis of how this was possible. How many Texas charter boats went fishing in 2016? 1? 100? How many? How many trips did they take? The NMFS has vetted and accepted these numbers. If you cannot answer these very basic questions, considering the EXTREMELY low numbers as compared to other Gulf state charter boat numbers, then please explain how you can even consider anything relative to modifying the ACT for the Gulf for-hire component?

I'm no fisheries scientist, but I believe that any reasonable person can see that the for-hire sector DID NOT underfish their quota in 2016 as advertised - if reasonably-calculated figures were used, it would show that the for-hire sector has an EXTREMELY HIGH PROBABILITY that it OVERFISHED its quota in 2016 - by at least 500,000 pounds and probably closer to 1 million pounds. Instead, everyone is claiming the for-hire sector is somehow "more accountable" under Sector Separation when in reality it is NOT more accountable and should have been penalized by mandated payback provisions in setting their 2017 season. INSTEAD, the for-hire sector was given even MORE fishing days in 2017. Considering that the for-hire sector had a lower quota in 2017 couple with MORE DAYS than 2016, it likewise points to an extremely high certainty that the for-hire sector AGAIN OVERFISHED its quota in 2017. It is clear that this modification to the for-hire / private rec ACT is politically motivated to make Sector Separation look better than it is, much like the bogus attempt to give the for-hire sector 49 days and the private recs just 3 days to fish in federal waters this year was designed as a PR mechanism to promote the supposed benefits of Sector Separation.

If you cannot provide unbiased answers to the above questions using transparent, valid scientific and statistical calculations, then you need to stop considering any modification to the ACT at all. You need to START providing transparent, realistic data calculations to base management decisions upon, using transparent, viable scientific and statistical principles instead of the obviously unrealistic politically-motivated data that you are currently using. There is no justification for using antiquated, illegal management techniques such as Segregation and Discrimination to manage our Gulf fisheries which Sector Separation and AM 30B obviously currently are based upon. You need to begin consideration of allowing Sector Separation to sunset as originally promised in addition to rescinding AM 30B.

A recreational fisherman is a recreational fisherman regardless of what platform his feet are standing upon and you need to start managing them based on reasonable calculations and fair equitable access as mandated by Magnuson.

Thank you for your time.

All the best,

Thomas J. Hilton

Recreational fisherman - Arcola, Texas
9/6/2017 14:24:36Thomas Hiltonhilton@rt-nav.comArcola, Texas
Private Recreational Angler
The reason for my original email is that the questions posed are NOT addressed (adequately) in any of the Council documents. If they are, I would appreciate it if you could provide where, specifically, I can find them.
Obviously, the intent of modifying the ACT is to give the for-hire a reduced buffer and the private recs an increased buffer in an attempt to make Sector Separation look better than it really is.
You, Mr. Rindone, need to provide answers to the questions posed before any potential action is taken on this matter, because for example, IF the Texas charter boats actually landed 1/2 million+ pounds MORE than the 20,063 pounds shown, then the appropriate course of action is to take that scenario into account PRIOR to any actions modifying the ACT. If the for-hire sector most likely overfished its quota in 2016 (and 2017), then the mandated payback provisions would take affect and would certainly affect decisions relative to modifying the ACT.
You need to show a plausible scenario of how many Texas charter boats fished in 2016 and how many times they went fishing in 2016 to arrive at the 20,063 pounds of red snapper number.
Quick cocktail napkin calculation: 20,063 pounds / 130 pounds per trip = 154 trips for the entire 219 Texas charter boats in 2016 - less than 1 trip per permitted boat in 2016's entire 46 day season. Is that a "reasonable calculation to promote conservation" as mandated by NS 4 in Magnuson? I do not believe it is. If you believe that it is, then please provide documentation of that rationale.
Quick cocktail napkin calculation: Let's say 180 out of the 219 Texas charter boats fished 30 days out of the 46 day season in 2016, landing 130 pounds of red snapper per trip. 180 x 30 x 130 = 702,000 pounds - NOT 20,063 pounds. 700,000 pounds is more in line with what other comparable Gulf states charter boats landed in 2016, by the way, and is a "reasonable calculation to promote conservation" as mandated by NS 4 in Magnuson, in my opinion. If you disagree, please provide documentation as to why 700,000 pounds is not a reasonably calculated landings number for Texas charter boats.

The questions posed regarding the FL panhandle boats also need to be adequately addressed and answered before any further action on modifying the ACT for the recreational components.

If you, Mr. Rindone, do not believe it is necessary to answer the questions posed, then I am requesting that Dr. Crabtree and/or Council staff to provide adequate answers since SOMEBODY at the NMFS/Gulf Council level SHOULD be able to DOCUMENT their data here.
Considering that the ACT meeting has been cancelled due to Hurricane Irma, this should provide you with ample time to answer the questions posed before the ACT meeting is rescheduled.

Thanks in advance, and I hope everyone in Irma's way stays safe.


Thomas J. Hilton
9/6/2017 14:25:23Bob Bryant
Private Recreational Angler
Hold on a second…

Since there is absolutely no…as in ZERO accountability or special data collection for the recently separated for hire sector, then under no circumstances can the private recreational angler be saddled with a higher buffer while easing the buffer on the For Hire.

The is NO DATA referencing that of the 43% provided to the CFH sector, that they over fished or under fished, any more than there is data showing the private recreational angler did such.

Again we are using the horse to push the cart here.

A40 should have never happened without mandatory reporting and accountability already in place….PERIOD…..

407D mandates that all within the sector be punished for overages, CFH is a subsector of the recreational quota, it is not a sector onto itself and as such has not been given a separate quota, which would then split the entire ACL into 3 portions, commercial, CFH, and private.

Let’s stop compounding the errors of the past made by the previous council members and use this opportunity to move forward with real management.

The GOM is not your private pool of property to gift here and there as you please, regardless of what NOAA fisheries may think.
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