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4/25/2012 7:27:28Kenny Begneaudbegneauk@bellsouth.netAfter reading the proposal, I agree with it. No Action. What's the deal. There is no information in the proposal. Blank pages, blank tables, blank data. The only proposed action is no action. Since the limited opportunity for Red Snapper, I have become a Triggger Fisherman. The only problem is there are so many Red Snapper, I can't catch the 14 inch or bigger Triggers. I think the 14 inch size limit on Triggers is all that is necessary to manage this species. A 14 inch Trigger is a big trigger. I think one of the flaws in obtaining data on Triggers and Red Snapper is the biologist are looking in the wrong places. I fish in Louisiana and I know our state is probably unique with all of the offshore platforms. I have been fishing the GOM for 45 years and in the past 10 have seen dynamic changes in the locaction of fish species. My personal opinion is that the dead zone has changed much of the habits and location of species. Last year in August while speckled trout fishing in 10ft of water in the Eugene Island area we were catching 12 inch Red Snapper 2 at a time on double trout rigs. In 45 years I have never experience this. In June of the past 5 years we have caught 15 to 20 pound Red Snapper in 18 ft. of water. In both places we catch small Trigger fish on a regular basis. For the past few years that I have known about, Red Snapper or being caught by Trout fisherman in 10 ft of water. These are the same rigs that never produced Red Snapper. I think this is being caused by the dead zone. I think no study will be worthwhile without also considering the effect of the dead zone. Hopefully more accurate data will be used for the Trigger Fish than the Red Snapper studies.Lafayette, La. 70508
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5/2/2012 10:22:10JOHN LAUBENTHAL MDjlaubmd@juno.comI do NOT support increasing the Minimum Size Limit for Recreational Fishermen as I feel the current 14" min. size is appropriate. If the Gray Triggerfish are 'overfished' & 'undergoing overfishing' then consideration should be given to granting then 'Gamefish' status & closing them to Commercial Fishing until their stocks are completely rebuilt & stable. Also more research is needed to consider the negative effects on Gray Triggerfish due to the dramatic rebound of the Red Snapper population.Panama City Beach
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6/20/2012 11:17:53Randy J Riharjriha@spectraenergy.comHaving fished offshore Texas for 15 years I can truly say that very few people retain triggerfish, as cleaning them is a pain and the amount of meat obtained doesn't justify the effort. However, I have seen the triggers decline over the years and it has coincided with the tremendous increase in red snapper. Looks to me like you guys are causing the problem with your screwed up snapper regs and now you want us to take the hit. Doesn't seem right to me. Sugar Land TXPrivate Recreational Angler
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6/21/2012 1:45:44Paul Alagnabeach_trade@yahoo.comOnce again the recreational sector is being closed out of a fishery while the commercials are allowed continued access. There should be no commercial fishing allowed for any species that is considered overfished or undergoing overfishing.

When will the council learn that they are working FOR THE PEOPLE, not just for commercial fishermen exploiting and profiting from a public resource???		Palm Harbor, Florida 34683Private Recreational Angler
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6/27/2012 13:22:39Mark Thomas Kelleyladykelleycharters@yahoo.comOn Gray triggerfish if we went with The four bag limit would there still be a two month closure in May and June. If there still is the closure how low would the bag limit need to be to do away with the two month closure.
I would be happier with a smaller bag limit and no closure. I feel right know in the rebuilding time frame keeping a few would be better than a closure for two months.		Panama City Florida 32408Charter/Headboat For-Hire, Commercial Fisher
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6/27/2012 15:49:32Kenny Begneaudbegneauk@bellsouth.netI think the 4 fish limit is fine along with the 14 inch size limit. What I have a problem with is the May-June closed season. Unlike the Florida angler that can run a few miles to catch their fish, I fish out of Bayou Dularge, La. Almost all of my offshore fishing occurs during Red Snapper season. A normal trip involves 120 to 130 miles of running round trip. 25 miles to get to the coast, then 36 miles to get to 58 feet of water. You've taken away Amberjack and Gag Grouper during the Snapper season and now you want to take away Triggerfish. I know most of these dates are being driven by the wants of the commercial charterboats to have something to fish for every month out of the year but in Louisiana its a totally different story. Look at your own numbers on Triggerfish and you quickly see that only a small percentage of the Triggerfish harvest occurs west of the Mississippi River. This isn't because we don't have them. We have plenty. It's because they are not a targeted species. Most people won't even keep them when they catch them. We all grew up considering them a trash fish. Not the case with me. They are one of my favorite eating fish. You just have to know how to clean them. Please split the gulf into zones. One size does not fit all. Let us catch our Triggers during Snapper season. How do you think the people of South Dakaota would feel if we closed Pheasant season due population of Pheasants in Louisiana? That's about what this amounts to. Lafayette, La. 70508Private Recreational Angler
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6/28/2012 8:47:47Terry Migaudtgmigaud@cox.netOn a May-June closure, as mentioned that is part of the peak season for fishing in the Gulf. The Louisiana Council of Underwater Diving Clubs (LCUDC) is against those days. We not not against a longer closure but not doing the summer months when we already close for other fishes.. As most fish spawn in the early spring, we would suggest a closure of November to April as being longer and less disruptive to diving season. On the 4 fish bag limit, that is not a problem as we ususlly get 0 to 4 triggerfish on most trips.
Thanks
Terry Migaud,
LCUDC Sec/tre 		Metairie, LA 70001Private Recreational Angler
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8/7/2012 11:02:30Richard Coatneyr.coatney@coastaldrilling.comOVER ABUNDANCE OF RED SNAPPER. NEED LONGER SEASON AND LARGER CREEL LIMITSLAF. LA. 70508Private Recreational Angler
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10/24/2012 5:10:39Elizabeth Fetherstonefetherston@oceanconservancy.orgOctober 22, 2012


Mr. Doug Boyd, Chair
Gulf of Mexico Fishery Management Council
2203 North Lois Avenue, Suite 1100
Tampa, FL 33607

RE: Comments on the Final Draft of Amendment 37 to the Gulf of Mexico Reef Fish Fishery Management Plan

Dear Mr. Boyd:

On behalf of Ocean Conservancy, please accept the following comments with respect to the Gulf of Mexico Fishery Management Council’s (Council) final draft of Amendment 37 to the Reef Fish Fishery Management Plan (Amendment 37) intended to end overfishing and revise the rebuilding plan for gray triggerfish in the Gulf of Mexico.

Gulf of Mexico gray triggerfish have been managed under a rebuilding plan since 2008, after a 2006 stock assessment (SEDAR 9 2006b) indicated that the population was experiencing overfishing and could be overfished. Amendment 30A (2008) to the Gulf Reef Fish FMP put in place a rebuilding plan for gray triggerfish that included commercial and recreational annual catch limits (ACLs) and annual catch targets (ACTs) as well as in-season and post-season accountability measures (AMs). Implementation of those management measures was projected to have the gray triggerfish population rebuilt by 2013. However, a recent update stock assessment for gray triggerfish (SEDAR 9 Update, 2011) revealed that population status has worsened, that overfishing is still occurring, and that the rebuilding target will likely not be met. As per the requirements of the Magnuson-Stevens Fishery Conservation and Management Act (MSA), the National Marine Fisheries Service (NMFS) and the Council must now prepare and implement a fishery management plan, plan amendment or proposed regulations to end overfishing immediately and ensure population rebuilding in as short a time as possible, not to exceed ten years.

Amendment 37 proposes changes to the gray triggerfish rebuilding plan to comply with this MSA requirement. Ocean Conservancy supports the new rebuilding timeline selected in Action 1. However, we have some concern about specific management measures to achieve the new rebuilding goal.

The Council is setting the new ACL at the SSC’s ABC recommendation of 305,300 lbs. At this catch level, the population is projected to be rebuilt within 5 years, which falls just within the legally allowable rebuilding limit. We support the use of the Council’s ACT control rule to determine the level of the ACT (Action 2, preferred alternative 4), set below the ACL to reduce the risk of exceeding the ACL. We furthermore support the establishment of fixed commercial and recreational closures during peak spawning (Action 3.1 preferred alternative 2 and Action 4.1 preferred alternative 4). Lower-than-average gray triggerfish recruitment was identified by the SEDAR 9 Update as a potential issue of concern regarding population rebuilding, and a peak spawning closure will alleviate fishing pressure during this important time. We are also supportive of a recreational in-season closure when the ACT is reached or projected to be reached and an overage deduction if the population is overfished (Action 5, preferred alternatives 2 and 4).

While we commend the Council on the above management decisions, we also have some concerns about the success of Amendment 37. Under the Council’s preferred choice of combination of commercial management measures under Action 3 (June and July closure and 50 lb trip limit), the commercial ACT and ACL are projected to be exceeded, meaning an in-season closure will likely be necessary. We recommend that the Council modify its preferred alternatives under Action 3 to a combination of options that results in projected landings that stay below the ACT and certainly below the ACL. This would result in more predictability for commercial fishermen and reduce the risk of exceeding the ACL and compromising the rebuilding schedule.

The preferred recreational management measures in Action 4 do result in projected landings that remain below the recreational ACT, which is highly desirable because in-season recreational landings data are not as timely and accurate as commercial data, making in-season closures a less effective management tool for the recreational than for the commercial sector. Nevertheless, a concern remains because the recreational management alternative evaluation model (as well as the commercial model) assumes that fishermen comply with the 14 inch minimum size limit. However, a 2012 SERO analysis shows that a significant portion of recreational (as well as commercial) landings have remained below the 14 inch minimum size limit over the last three years. If the minimum size limit is not complied with, the actual reduction in landings achieved may not be as great as the SERO model predicts, and recreational landings may in fact end up exceeding the ACT and ACL.

We encourage the Council and NMFS to conduct outreach and education to ensure the minimum size limit is adhered to. Until there is some indication as to the effect of education and outreach efforts, we recommend that NMFS and the Council consider the proportion of undersized fish landed in projection models that evaluate management alternatives to avoid exceeding the ACL in the fishery.

Sincerely,


Elizabeth Fetherston
Deputy Director, Fish Conservation Program
Ocean Conservancy
449 Central Avenue, Suite 200
St. Petersburg, FL 33701
St. Petersburg, FL 33701NGO
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10/15/2012 14:06:18Scott Hawkinsscotthawkins2003@yahoo.comI don't agree with putting a closed season on Triggerfish. With the LONG closed season on Red Snapper, that would leave a recreational fisherman with virtualy nothing to keep when they went out for most of the summer. I would agree with putting a bag limit in place, as long as it's not something crazy like 2 per person. Personally when my wife and I go out, we catch a few of triggerfish and usually will only keep 2 to eat. We don't freeze them and only eat fresh, but let's not put something in place that is too restrictive such as has happened with the endangered red snapper that we all catch too many of.Navarre, FL, 32566Private Recreational Angler
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10/16/2012 5:48:02James McQuillanshovelhead@gmail.com· Changing the current rebuilding plan *IN FAVOR
· Establishing a commercial closed season *IN FAVOR
· Establishing a commercial trip limit * IN FAVOR
· Establishing a recreational closed season *IN FAVOR
· Establishing a triggerfish–specific recreational bag limit . *IN fAVOR
· Allowing NOAA Fisheries to close the fishery if the Annual Catch Target is reached *IN FAVOR

As a recreational angler I would support measures to protect Gray Triggerfish. I would prefer lower bag limits and a longer season. I do not take lightly the fact that commerical fishermen depend on fishing to support their families however they along with recreational anglers must do everything needed to protect our resources. My personal preference is getting on the water and catching fish for as many months as possible. I only use circle hooks and have no problem with catch and release with lower bag limits.		Tierra Verde, FL. 33715Private Recreational Angler
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10/18/2012 8:51:13Richard Rogerscatdad100@yahoo.comAs far as the closed grouper season(feb-march) I say leave it closed if its going to shave off any more days for gags as that time of year is slow for charters and weather is bad as well.As far as limiting gag to 1 per person Im not for it as long as we can have 3-4 months of it then leave it at 2 pp to make it worth going out there in the first place.
Triggerfish got hammered because of snapper season and now grouper being closed,Im ok with a season and catch limits of at least 5 per person would be fine.
I saw this proposed last year and it was shot down but why not take the total days of red snapper season and spread it out to only weekend or friday,saturday,sunday or saturday,sunday,monday and could even rotate that on weekly basis,the average joe just cant afford to go that many times in a 30 day period on a private or charter boat but being most days fall during the week it would require private boat guys to take off work,vacation,etc.or just have 4 wkends to fish.This seems to give the charters guys way more opportunity to catch red snapper anyway you slice it.		Freeport,Florida,32439Private Recreational Angler
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