General Fishery Comment (Responses)
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7/31/2017 11:06:39Bob Zalesbobzales2@gmail.comPanama City Beach, FLCharter/Headboat For-HireThe Gulf of Mexico Membership I represent for the National Association of Charterboat Operators (NACO) and the Panama City Boatmen Association (PCBA) have serious concerns over recent Gulf Council and NMFS actions and proposed actions. These folks have asked why the newly appointed members to serve on the Council will not be taking their respective seats and be able to fully participate and vote on issues at the August meeting as all previous appointees have over the more than 30 years I have attended Gulf Council meetings. I have explained that their terms begin on August 11 and the members whose terms end do so on August 10, the last day of the August Council meeting. They ask why the Aug meeting was set so the new appointees would not be able to serve as they have in the past.

I fully understand the council process and have tried to explain that the Chair persons of the Council select the locations of the meetings and have some input as to the dates of the meetings and some locations and dates have been previously selected a year or two ago. I also have told them I have been told by council staff that the Aug meeting location and dates were selected by the past Chairman and apparently they were not aware of the MSA required dates for old members to end their terms and new members to begin theirs so although in all previous years the Aug meeting was set so new members would be able to take their oath and fully participate, this Aug meeting was not set up for this. Some have also asked why the San Antonio hotel block of rooms was set from Aug 3 thru 15 for meeting dates from Aug 7 thru 10 and I have told them I have no answer for that unless the previous Chairman and/or staff had some reason to visit San Antonio in addition to Council business. Clearly since the room block extends into the week after the currently scheduled meeting, the meeting could have been set so new members could fully participate.

A prime concern for those I represent are the issues scheduled for final action at the Aug meeting. These include final action on future greater amberjack seasons and quota adjustments, final actions on proposed referendums for amendments 41 (charter boat proposed catch share management) and 42 (headboat proposed catch share management). In previous emails I have explained the concern about greater amberjack final actions and our strong recommendation to move that action to the Biloxi Oct meeting with all the rationale that will allow the issue to be moved to that date. Here I will attempt to explain our extremely serious concern about taking any final action on any proposed referendums to initiate any type of catch share system on the federally permitted for hire charter/headboat sectors.

As previously expressed, explained, and requested in many prior communications over the last several years we strongly suggest that the vast majority of Gulf fed permitted for hire charter/headboat owners do not want any type of catch share system. We have requested multiple times for a simple and not expensive survey be sent to the 1300 + - permit owners to find out if over 50% support a catch share program. Such a simple survey has never been sent. Over the past several years the NMFS/Council has spent untold tax dollars and many days and months of staff time working to impose a catch share system on a fleet that does not want it. Now, the NMFS/Council has scheduled final action for the Aug meeting on the two proposed referendums that no one from the public, and especially from the fed permitted owner universe, has been able to review until July 21, 2017 with final action scheduled on Aug 10, 2017. In addition, the proposed referendum for amendment 41 does not even include any Texas for hire data!!! Are the Texas vessel owners to be simply grandfathered in or do they receive special quota allocation?

This attempt to take final action on two such important issues that will forever affect the vessel owners and sector is ill-conceived and borders on complete irresponsibility at best and shows the NMFS/Council agenda to force a style of management on fishers at worst. The facts that the majority of the vessel owners affected do not want such management, the extremely late production of the documents to be finalized that will have less than 4 weeks to review and study in order to provide any type of reasonable comment, and the lack of complete data to review shows the fast track of the NMFS/Council agenda that completely ignores the will of those affected most. So all understand, the proposed referendums are not simple proposed regulations that may change yearly or seasonally like most regulations that affect what we are able to harvest, when and how. The most important decision a person who enters the for hire charter/headboat business will make is to enter the business or not. The next most important decision that person will make will be to support or not a catch share program that will affect that business for ever. Trying to make such an important decision on the proposed document in such a short period of time and based on incomplete data is, frankly, plain irresponsible. As members of the Council, the staff, the staff of the NMFS, and others working on this agenda, surely you would not make such an important decision that will affect you and your family’s future on such a presentation.

The final action proposed for the referendums must be moved to the Biloxi Oct meeting to be fair to the vessel owners who will be affected the most. We strongly urge the NMFS/Council, as we have in the past, to eliminate further discussion on this issue and move to working on more important management issues.


Capt. Bob Zales, II

Capt. Bob Zales, II
PH 850-763-7249
Fax 850-763-3558
1/4/2018 11:24:23John Paivajpaiva@verizon.netApollo Beach, FL
Private Recreational Angler
Red Snapper
Dear Gulf Coast Council Member,

I just wanted to provide some additional information in regard to the Red Snapper meeting on January 18th, 2018 in Tampa, FL.. I live in Apollo Beach, Florida. Like many other locations along the west coast, we are 45 - 60 miles from Red Snapper habitat. That equates to a two hour plus boat ride when the weather/ wind conditions allow the “average” recreational angler to access these fishing grounds. Next, add the fact that most of us work and therefore we can only go fish for Red Snapper on a very, very, infrequent basis. Now, add that the fuel cost of this trip alone is on average over $400.00 not to mention the tackle, food, drinks, and a full day away from family … it’s quite a commitment.

Now, let me inform you of my last two offshore trips (November 26th and December 31st) which were for Grouper, Mangrove Snapper, and other species. The problem was in every spot in 120 feet of water and deeper that we fished, we could not get past the Red Snapper! On the first trip we caught and released over 40+ Red Snapper all over the min. size limit and many up to 20 lbs. - the average size was approximently 8 lbs.. On our second trip we caught and released over 25+ Red Snapper. Again, they were all over the min. size limit with several were over 15lbs..

We need serious regulatory reform regarding Red Snapper and the recreational angler. I believe Red Snapper should be open year round for recreational anglers in areas along the west coast where the accessibility alone is a major restrictive component as noted above. We are not the cause of Red Snapper stock depletion! Furthermore, the two examples of my recent offshore trips, and my experience fishing offshore two or three times earlier in the year - when I was fortune enough to go offshore fishing - attest to the health of our Red Snapper Stocks off the Central West Coast of Florida.

Thank you in advance for correcting this atrocity that has befallen the average recreational angler.

Best Regards,

John M. Paiva
1/8/2018 11:35:53Bob Zalesbobzales2@gmail.comPanama City, FL
Charter/Headboat For-Hire
Amberjack discussion in Reef Fish Committee
Leann and Johnny,

On behalf of the many charter for hire vessel owners I represent across the Gulf I respectfully request more time be added to the amberjack discussion in the reef fish committee. As you both know the aj issue is very controversial and I respectfully submit that the council discussion at the Oct meeting was incomplete. As per the council minutes, in particular pages 180 thru 195, there is much discussion about potential impacts of differential bag limits and a split quota for the spring and fall seasons. In fact Andy Strelcheck stated, after the council vote on the framework, that their preliminary analysis on the estimate of harvest reduction that could be achieved by a 1 fish per 2 angler bag limit was 38% and he goes on to state that would be significant.

I strongly suggest that had the council been provided that information prior to the vote to change the fishing year the outcome could have been very different. Changing the bag limit to achieve harvest reductions in addition to a split quota for the spring and fall seasons could very well accomplish the goal of providing access to amberjack for the whole Gulf. These scenarios need the full attention of the council and input from the stakeholders as y’all have certainly heard and seen the importance of the amberjack fishery to the charter for hire fleet.

As is stated in the minutes recreational anglers have suffered through no access to amberjack by no fault of their own as they strive to comply with all the regulations placed on them. Accountability measures and other issues have resulted in limited quotas and now we even have a 26 day season due to the fact that the NOAA/NMFS failed to implement the new regulations in a proper and timely fashion. Anglers are certainly not at fault for this failure.

We strongly feel that the whole amberjack issue discussed and acted on at the last meeting was rushed and ore time is needed to address the major concerns. Amberjack are prosecuted in various ways on a variety of vessels and in different charter operations. Everything possible should be considered by the council in your efforts to properly manage this fish. Since the current committee agenda ends at 3:30 pm we see no reason why time cannot be added for more discussion. Please consider our request.


Capt. Bob Zales, II
1/8/2018 11:37:29Tom Adams
Mexico Beach, FL 32456
Charter/Headboat For-Hire
Amberjack Season
We desperatly need a spring and fall Amberjack season!! Please consider all the new info before voting in New Orleans.
As you know the aj issue is very controversial, and at the council discussion at the Oct meeting, the information was incomplete. As per the council minutes, in particular pages 180 thru 195, there is much discussion about potential impacts of differential bag limits and a split quota for the spring and fall seasons. In fact Andy Strelcheck stated, after the council vote on the framework, that their preliminary analysis on the estimate of harvest reduction that could be achieved by a 1 fish per 2 angler bag limit was 38% and he goes on to state that would be significant. That 38% should be plenty for a split season


Capt. Tom Adams
1/19/2018 14:09:25Michael Pulismikesmac2@att.netRed Snapper
Dear sirs;
I understand the need to regulate certain species of fish to prevent overfishing to the point of
extinction. However, the volume taken by commercial concerns is far greater than that taken by
private recreational fishermen. Commercial boats take all they can hold, and they keep any size.
I have seen videos of commercial boats with 12,000 to 15,000 pounds of fish with some as little
as 8 to 10 inches. This makes no sense in the effort to avoid overfishing the red snapper population.
They have no season, and the charter boats have a 49 day season while the private boat has only
3 days, and if the weather is a factor, too bad.
If the council truly wants to reestablish the snapper population they should make regulations
apply to all concerned. That would hamper the fishing industry, but that would be the price they
would have to pay for the extreme number of fish they take without any control.
Lets see all fishermen be subject too the same rules.
01/23/2018Shane Cantrellshane.cantrell@iCloud.comGalveston, TXCharter/Headboat For-HireMrs. Leanne Bosarge, Chairwoman
Gulf of Mexico Fishery Management Council
2203 North Lois Ave
Tampa, FL 33607
Dr. Roy Crabtree, Southeast Regional Administrator
National Marine Fisheries Service
263 13th Avenue South
St. Petersburg, FL 33701
Dear Chairwoman Bosarge,
The Charter Fisherman's Association is the largest federally permitted charter for-hire
organization in the region. Our organization is focused on working respectfully within the
fishery management process toward realistic solutions to problems facing the
recreational fishery and charter for hire industry. We appreciate the opportunity to
provide input and comments on a variety of fishery issues before the Gulf Council: Transparency in Red Snapper Fishing Seasons
Since the recreational sector has been lawfully divided into separate private angling and
charter-for-hire components, there has been a continually emerging disparity and lack of
transparency in the established seasons being set for the charter-for-hire component.
The private angler component is the only sector in the Gulf of Mexico that continues to
have open access; every other sector has limited access. The Gulf States deliberately
exploit the open access nature of the private angler component by setting noncompliant
fishing seasons in state waters that result in undermined federal
• The private angler component must be held solely responsible for paying back their
annual overages.
• The for-hire component has less management uncertainty and, therefore, should face
different accountability measures than the private angler component.
• The current structure of buffers and accountability measures is causing an unlawful
de facto reallocation from the for-hire component to the private 1 angler component. Thank you for your consideration of these comments.
Shane Cantrell
Executive director
Charter Fisherman’s Association
1/23/2018 7:51:14Tom Adams
Mexico Beach, FL 32456
Fishing Seasons
One scenario many of us have discussed among ourselves as well with some council and nmfs folks is a way to set a fishing season of 6 months or a little more. As you know between 2000 and 2006 we had a 6 month red snapper season from April thru Oct with a 4 fish bag limit. Most of us are now to the point that while we believe a 6 month red snapper season at 2 fish is possible under current msa requirements most likely won’t happen. But, we do see a 6 or 7 month fishing season being highly possible. One scenario could be along with vermilion snapper, red grouper, and other snappers and reef fish that are mostly open year round along with king and Spanish mackerel, cobia and other pelagics if you open trigger fish in Mar and Apr, AJ in possibly Apr and May, at least May, red snapper in June and July along with gag grouper opening on June 1, aj again in Aug and at least Sept thru Oct with trigger fish open again in Sept that we could see a fishing season of 6 to 7 months as something that the public desires to target would be open during that period. As fish species improve, which they will, then more days can be added to their respective seasons. This type of fish management is possible today and with such a season possible the economic impacts for fishermen and communities greatly improve and the adversarial feelings by those of us in the industry are greatly reduced.
1/25/2018Bob JonesSoutheastern Fisheries AssociationotherGreetings:
Southeastern Fisheries Association is obligated to call the imbalance of representation on the Gulf of Mexico Fishery Management Council to the attention of Congress. Once before in the early 1980s the coastal conservation association was able to remove many of the people associated with the seafood industry and stack the council with recreational activists. Florida did not have a commercial representative on the Gulf Council for 13 years. That's how powerful cca was.
When SFA called this imbalance to the attention of NOAA/NMFS last year they determined the Gulf Council was well balanced and did not accept our observation. Maybe they will this time.
There are only three commercial fishing seats on the Council out of 17. Only Mrs. Bosarge is engaged in the seafood industry on a direct and daily basis. Mr. Swindell and Mr. Sanchez are from a commercial fishing background and are excellent and honest members that need to remain on the Council. The Council is stacked in opposition to commercial fishing. If there is no commercial fishing, millions of seafood consumers that depend on us to bring their fair share of the fish to the market will be denied access to a resource that is there for all the people.
If we had the financial resources we would already have brought this to federal court. That seems to be the only way to break-up the current imbalance unless Secretary Ross steps in.
Thank you for any assistance you can give to protect our ability to produce seafood which creates wealth for the nation.
Bob Jones on behalf of Southeastern Fisheries Association. 01/25/18
1/29/2018 7:38:20Rob Robinette
Panama City, FL
Charter/Headboat For-Hire
I am writing you today before the meeting in New Orleans to give you are thoughts. My name is Rob Robinette and I am representing Gotta Believe Charters from Panama City Beach, Florida. The "Gotta Believe" is a Six pack vessel with a Federal Permit for Charter. We are members of both Panama City Boatsman's Association and NACO. First we are against Catch Shares for Red Snapper and any other fish. Don't believe in the system and never will. Second we would like the Amberjack season to stay on its current calendar year period of January-December. We are not against the fractional bag limit idea of 1 fish per 2 people with no increase in size limit. Basically Spring/Fall season before and after Red Snapper season. We are looking for as many days possible to stretch fishing outside of Red Snapper. Third and I am not sure if you are getting into this at this meeting is Vermillion Snapper. I saw on one of the email we received was a idea to lower the Total allowable Catch limit on Vermillion Snapper. They are not over fished nor not ongoing overfishing. Basically no problems. Unless you lower the TAC and create a problem. Why? Why create another problem when you have so many others not resolved. We ask for a little common sense in the Fishery Management side. We are not the best fisherman's nor do we have the best boat. We just want a fair system and we will be competitive. Thanks for your time. Captain Rob Robinette
02/01/2018Dylan Hubbarddylanhubbard@hubbardsmarina.comMadeira Beach, FL 33708Charter/Headboat For-HireRed GrouperLetter to the Gulf of Mexico fishery management council
January 31st, 2018
By: Capt. Dylan Hubbard, Hubbard’s Marina – MREP graduate

Hello, my name is Captain Dylan Hubbard and my family business has been fishing central west coast of Florida for nearly 90 years and four generations, plus I am a recent MREP graduate. We operate 6 federally permitted vessels both charter and head boats, and I represent the Florida Guides association as their offshore director.
Red Grouper
There is no great dilemma surrounding the red grouper fishery according to the SSC, made clear by their lack of recommendation on interim action. We urge the council to wait until standard stock assessment for red grouper in seadar 61 is completed before assessing any action on the red grouper fishery.
02/01/2018Dylan Hubbarddylanhubbard@hubbardsmarina.comMadeira Beach, FL 33708Charter/Headboat For-HireMREP ProgramLetter to the Gulf of Mexico fishery management council
January 31st, 2018
By: Capt. Dylan Hubbard, Hubbard’s Marina – MREP graduate

Hello, my name is Captain Dylan Hubbard and my family business has been fishing central west coast of Florida for nearly 90 years and four generations, plus I am a recent MREP graduate. We operate 6 federally permitted vessels both charter and head boats, and I represent the Florida Guides association as their offshore director.
MREP program
I had a great experience with the workshops and programs and I look forward to being involved again in 2018. One of the most glaring items learned at that workshop is that the gulf council, south Atlantic council, and Caribbean council all share one science center. If you include the HMS and sharks its like were sharing one science center with 5 councils while on the pacific coast there’s two science centers to one council! For the health of our fishery and sustainability of the gulf we need more readily updated assessments and more robust data sets which can only be accomplished with added science centers.
2/2/2018 7:25:49Daryl Carpenter
Charter/Headboat For-Hire
Historical Captain Permits
The Louisiana Charter Fleet is in support of consideration of taking the few Historical Captain permits and converting them to full permit privileges. The moratorium was originally put into place to “cap” the participation of charter boats in the Gulf Fishery. Since then it has served to not only cap but to also greatly reduced the fleet. The few Historical Permits that remain active have just as much invested in the industry as anyone else and should have the security to know that their permits are a part of their investment.
02/05/2018Bob Zales
Panama City, FLCharter/Headboat For-HireACL/ACT Calculation ToolAll,
After my email was sent last night I have received several responses from fed permitted charter vessel owners and some from current members of the ad hoc AP regarding the attached excel decision tool. Apparently this excel tool was provided, although according to several on the AP reluctantly, at a meeting in New Orleans a couple of years ago. I am told that Sue Gerhart provided the tool. As with all AP meetings a council member was present so we know that at least 2 people between NMFS and the Council were fully aware of the tool and the ability to use it to provide a simple way to inform fed permitted vessel owners of how much red snapper quota they could possibly expect to receive, sort of a ballpark representation. Such information has been requested by me and others many times over the years yet there has been no effort by the NMFS or Council to provide such to the fed permitted owners, and to the general public. One must ask the question, has this tool been purposely hidden from the public due to the constant efforts by the NMFS and several Council members who have actively pushed for catch shares in all fisheries as a way to further reduce capacity or is it simply a failure to properly inform the public. There is a reason.

Such information is critical to any decision making to support or not any proposed IFQ, PFQ, or any other catch share type program that gifts fishing quota for private ownership. As you can fully understand had such information been provided in the past couple of years, any reasonable minded person, especially someone who depends on fish to operate their business, most likely would have supported ending further discussion on A41/42 thus enabling the NMFS/Council to concentrate their time and tax dollars on more important issues.

There has has been an argument by a few that providing quota to individuals would ensure they would always have guaranteed quota and would not have to worry about lost days should the total rec quota be reduced. This is a mute argument since in any gifted IFQ program once the initial poundage is provided it immediately is converted to a percentage of the total quota and then the poundage increases or decreases depending on the total quota available. This means if fishing days are lost under a seasonal situation because the quota is reduced then the poundage gifted also is reduced if the quota is reduced as the percentage remains the same but poundage is reduced.

I strongly recommend that the excel tool be expanded, and surely for folks that are good in creating such tools can do so pretty quick, to include the impact on what poundage could be available for greater amberjack, trigger fish, red and gag grouper. Such information will go far to providing the data needed for people to make an informed decision on their fishing future. Such a simple tool can provide the means for folks to decide if they want the council to continue to waste time and money on this issue or end it. The reason you have heard from so many to end further action is they have used the tool and see they will lose 60% or more of what they currently harvest under the currently increasing number of fishing days. Plain and simple.

02/06/2018Pam Danapamdana@yahoo.comDestin, FLHi guys. Hope you’re all doing dandy. I just wanted to bring something up to you.

Normally, cobia season in NW Florida doesn’t start until around March 20 or later and runs through beginning of May. As you know, last year was an odd one and cobia hardly showed up at all in NWF (but they did show in good numbers in central FL and Atlantic side). With complaints from a few loud voices on a “decimated” stock and the need to curtail bag limits and sales, FWC acted accordingly to clamp down on rules.

Anyway. in last two days alone, three cobia were caught. One from Pensacola pier on Sunday. Two yesterday—one off Panama City pier and one in Destin. Mind you, people ARE NOT fishing or targeting cobia yet (e.g., and there are next to no boats on water). So, for three to be found already when so few folks are out fishing suggests to me there are many more fish out there passing through that are not being seen.

My reason for bringing this up now, and as we discussed last year, cobia migrations are cyclical and vary year to year—with occasional years of plenty followed by years of fathom. The fact that they are showing up so early and being found by the very few on the water means to me that they may be more plentiful than what was thought last year. [Recall my theory of last year’s dearth of cobia was due to warmer than normal waters driving fish to deeper cooler waters, and new migration paths formed from FADS being placed in past years deeper and further offshore — creation an offshore food source and new imprinted migration pattern like Tuna.] Anyway, last year FADS were forbidden from tournament competition so they are generally not being put out now. If the fish cannot find their food source at deep water FADS as they were imprinted to do in recent past, they would need to come in closer once again. Also, waters are cooler this year, bringing the fish in to more shallow, warmer waters and to the surface in search of sun rays. This early migration makes sense given that we had a cold snap followed by warm spring temperatures — giving the fish the “go ahead” to start their pilgrimage to Mecca (Louisiana). 😊

Anyway, It’s early so I will keep you informed but I’d proceed with caution as it pertains to further restrictions on cobia.
02/12/2018Erik Larson
Clearwater Beach, FLHello,

I have not been involved with the politics of our fishery since the embarrassing "goliath grouper workshop" a few springs ago. When I saw this email regarding the study of the abundance of red snapper in the gulf I couldn't stop myself from sending you a message.

I catch red snapper daily in 30 to 40ft of water. It's difficult to catch anything else. When is the council going to acknowledge that the science/ management is having a negative effect on the fishery and the livelihood of all that depend on it? Magnusson Stevenson is really doing a great job of destroying our fishery.

Now I'm told by the geniuses with PhDs that Obama left us a gift of aquaculture? Should I start freshwater charters? I'm about done with thinking that things will improve.

I don't need a response from you, just needed to vent before I exploded. Have no idea how you can listen to the "experts" daily and still be hanging on to your sanity.

Captain Erik Larson
Clearwater Beach Florida
Gag capital of the world(can't keep them though)
3/12/2018 13:03:14Warner Fosterjwkillntime@gmail.comPanama City
Private Recreational Angler
Making Comments
The Gulf Council could make it a lot easier to comment. As of now when making comments if one need to check back on a proposal all the entered comments are lost. There should be a way to save what has been entered.
Thank You,
3/22/2018 11:31:29Tony . SAPUTOsaputotc@comcast.netMarco Island
Private Recreational Angler
Red Grouper & Goliath in the Gulf of mexico
The Goliath groupers are a huge problem, they eat everything around including the fish you are trying to land. Need to reduce the large number of them in our area. I would like to see the Red Grouper minimum size limit reduced to 19 from 20" On an average day, 25 miles from shore, I catch and release around 15 groupers that are under 20". Quite a few are 19" but short of 20" I would still keep the harvest at 2.
I do use non-stainless steel non off set circle hooks, I even file the barb off because I know it will be less stress on the fish I release.

3/30/2018 8:14:54Jeffery Senarighisenarighi1@yahoo.comAlabama
Private Recreational Angler
Amendment 42
My wife and I are part time Alabama
residents we spend 3 months in Gulf Shores each year, the rest of the year it's Minnesota. I, and a multitude like me, are avid gulf fishermen both from shore and usually at least weekly from headboats. Three years back there was an EFP that allowed us to catch and keep red snapper and this year there was a limited triggerfish season in January. We believe Amendment 42, currently in the council, would allow us a chance to once again harvest a part of the fisheries resources and still allow the council to protect the fishery by closing season if the ACL is reached. We contribute substantially to the gulf economy along with holding local fund raisers and volunteerism and would like to be able to enjoy a portion red snapper, triggerfish, etc that are allowed to be taken. Please pass this along for the members consideration.
4/6/2018 8:29:01Chad Hanson
Discarding Fish & Generic ACL/AM
On behalf of The Pew Charitable Trusts (Pew), please accept these comments regarding several issues coming before the Gulf of Mexico Fishery Management Council (Council) at the April meeting. We support the changes to Coral Amendment 9 per the Council’s Scientific and Statistical Committee (SSC) recommendations. Additionally, we recommend modifications to the proposed discard policy regarding descending devices and venting tools, and development of
guidance for associated scientific research. Lastly, we support the recent SSC recommendation to develop robust and objective criteria to determine which species should be included in fishery management plans, and that the Council undertakes a review of these criteria and the species under federal management in this region every five years.

Addressing high rates of discard mortality is a significant conservation and management challenge in the southeast. Some of the most depleted and vulnerable species are also the most targeted, are frequently caught together, and found at depths where live release is less likely. Fishing seasons for each species differ, thus it is highly likely that when fishing for snappers and groupers, a proportion of the catch will be “out of season” and thus must be thrown back. For all of these reasons, catch and release is not currently an effective conservation strategy for many federally managed reef species.

However, a strong body of evidence indicates that widespread and proper use of descending devices could increase the rate of survival for fish that are discarded and too often do not survive due to barotrauma. This could eventually result in higher catch limits, although it is important that any “credit” applied to the fishery is based on good science. Thus, we are supportive of the Council adopting a policy intended to reduce discard mortality, but think it could be improved to better articulate the purpose of the policy and why properly releasing fish is beneficial to both fish and fishermen. We also encourage the Council to develop both research recommendations and an outreach and education plan. The research recommendations should clearly lay out the information needed to maximize the benefits from this policy, quantify implementation, and to properly calibrate any “credit,” such as an adjustment in the discard mortality rate utilized in stock assessments. The outreach and education plan could incentivize broad use of these devices and educate anglers on best practices when releasing fish.
When the Council adopted the Generic Annual Catch Limit and Accountability Measures Amendment in September 2011, it included a policy statement indicating the intent to review the appropriateness of species for inclusion in fishery management plans (FMP) every five years. This issue is coming before the Council at the April meeting under the Sustainable Fisheries Committee agenda. At its most recent meeting, the SSC recommended developing criteria, in coordination with the Council, to determine which species are in need of “conservation and management,” as required by the Magnuson-Stevens Fishery Conservation and Management Act and outlined by the National Standard One guidelines.4 It is important to identify species for which fisheries may be expanding or developing, but which are currently unmanaged, among other things. Thus, we concur with the SSC recommendation and urge the Council to instruct staff and the SSC to begin developing specific criteria to guide such an analysis.

While reviewing the Generic ACL / AM amendment, the SSC recommended criteria in addition to landings be considered when determining which species to include in FMPs for management purposes. They include information on species’ distribution, life history, catch information, and stock status. We recommend additional criteria such as vulnerability to population decline, high susceptibility to fishing, stock status indicators such as fishery trends and analysis using data limited methods, condition of primary habitat(s) or essential fish habitat, ecosystem role and importance, and predicted environmental-driven changes in fishery conditions and habitat, such as increasing sea temperatures. Combined, these criteria could be designed as a step-wise approach to prioritize species that are ecologically and economically important, and in need of federal conservation and management.

Thank you for the opportunity to provide comments on important issues coming before the
Council. As always, we look forward to discussing these and other issues with you.
4/6/2018 8:31:40Walter Lee Holton, Jr.
Tampa, FL
Private Recreational Angler
No more
I am respectfully writing to after speaking at length with Mr. Crabtree about all of the the different councils and governing body’s telling me what I can and when I can catch and feed my family what God provided and gave me dominion over as well as the 9th amendment that say’s we the people set the laws and vote them in not the other way around. As I read the commercial openings and size limits compared to the average angler that hunts and pecks to find a grunt or two it is backwards. I follow this up with I am from Tampa born and raised and have seen the changes some good some not so good, all revolve around the commercial fisherman, the catch from Texas to Key West commercial to rec. is well over 8 to 1.

I am a 100% Disabled Coast Guard Veteran with both knee’s replaced, 6 rods and 12 screws in my back, on May 21, 2018 my right knee has to be replaced again, I also deal with PTSD and have spent months in the hospital because of it, being on the water is about my only escape and fishing is my release, I can’t dive anymore and charter due to physical limitations and medication, my day’s on the water are limited by weather, Doctor’s appointments , my physical limitations meaning flat water your time slots for gags and red snapper do not work with my disabilities.

I spoke with Mr. Crabtree and I am not the only disabled person with this problem, I am not talking about other people on my boat Just me for my family I want a letter of exemption or I will write my own and take it to the Governor and then to the 7th District of the Coast Guard and on up the line I feel after what I have given up for this country a few fish a year is not much to ask for, I am open to keeping you up to date on what and where and when I catch with photo’s.
4/10/18Bob Kellycaptainbobbykelly@gmail.comOrange Beach, ALCobia I just wanted to write you today to express my concern, as well as many other professionals in my area, over the cobia stock health. It’s become glaringly obvious to the fisherman that have pursued these fish in the spring for decades, that the numbers are down. We know that there are good years and bad years in fishing but these fish have been a downward spiral for years and many of us believe that they’ve hit rock bottom this year. I personally applaud the state of Florida for their recent changes in bag limits and have reached out to Kevin and Scott in my state to initiate change as well. I believe the gulf council needs to take a very close look at these fish, especially the eastern gulf stock before they are nothing than a memory. During the spring months there are numerous tournaments for cobia every weekend. The last 2 weekends there have been 11 fish caught combined for both tournaments when usually there should be 40-50 fish a day caught. Our marina here in Orange Beach has a tournament that started April 1 and runs the entire month. There has not been a single fish even sighted after hundreds of hours of the best fisherman looking. It’s a sad state for the fish. I hope for once we can err on the side of caution before it’s too late
4/10/18Will Cokercobiaobsessed@gmail.comFort Walton Beach, FLCobiaI grew up here in Fort Walton Beach, FL and have been cobia fishing every Spring since 2005. Cobia fishing is one of my passions in life, however recent years have been so bad that it's depressing. It's blatantly apparent that there is something seriously wrong with the population and migration patterns of cobia in the Gulf of Mexico. We are now about halfway thru our typical cobia season for sight fishing them along our beaches that usually starts in mid to early March and ends in early May. So far this has been the worst year anyone has ever seen. Boats are fishing for days and not seeing a single fish. Weekend tournaments with 20 to 30 boats fishing have only seen 3 to 5 fish total weighed. People have differing opinions of what has caused the decline in fish whether it be weather patterns, over-fishing, or the oil spill. I am convinced that the oil spill is the main culprit as it occurred in April of 2010 directly in the path of the annual migration to spawn during the summer months off the coasts of TX, LA, MS, and AL. I would be interested to hear your opinion on the causes as well as feasible solutions. I know there were meetings held by FWC this winter and there was a change in regulations in Florida bag limits, but in my opinion, unless the other Gulf states before mentioned jump on board and are willing the change their regulations as well, what we do here in Florida is not going to make a difference. With all the money BP shelled out following the oil spill, I would hope there is still some funds available to help with research grants to gather much needed information to help fix this problem. Bottom line is that something needs to be done. I look forward to hearing back from you. A few years ago I contacted Jim Franks regarding this issue and he never got back to me, so I'm really hoping you get back to me. Thank you for your time.
4/10/18Gary JarvisGJabd@aol.comDestin, FLCobiaThis is a serious situation up here in the Panhandle . We have had a 10 yr decline in the volume of fish migration and the past three yrs have each we have seen remarkable deacrease in both juvenile and adult Cobia. This year so far has been not just slow ,last year was bad, this year is extremely bad. I have been a advid Cobia fisherman for 40 years. I have seen this with my own eyes and this is not a cycle which usually will change over a 3-5 yr depending on recruitment class of Cobia. We have a serious problem here, all my friends who are professional fishers in all five states concur. We need a open diolog on how best to address this issue in the EEZ. The state of Florida has taken a lead by going to 1 per person and 2 fish per boat max per trip
4/10/18Bud Millerbud@fishandgamescale.comFish & Game Scale. I have taken our prototype to several state and federal meetings. We will be taking our system to more state meetings and we are registering to display at Icast in July.
If you remember our scale system at last October council meeting, we had the scale system programed with out any input from fishery managers, but listening to comments from some state leaders we have changed the program a little. I also met with programmer to verify that the scale system could take pictures of fish as they are hung to be weighed. I was informed that he had done this already on another project and that two photos(jpg) could be attached to Email sent to person collecting data. So the scale system would validate the states phone apps, or the for hire fisherman Log Books by getting vessel Captain to reenter information submitted at time of hail out provision. The number of anglers, the number of fish, the total weight of fish and pictures of fish. The scale unit would be available when MREP personnel are not present. We can change the species in the system to whatever species of fish in open for harvest.
I had an angler who confronted me about why he wouldn’t stop and weigh his harvest, he stated he went to his own dock after fishing. Our thoughts are that upon returning the fisherman typically stop for fuel, ice and a cold beverage, so why not take thirty seconds to weigh your fish.
We did get to met with a state to demonstrate, they liked the concept but not feasible for smallest part of red snapper fishery. We believe in this concept of anglers weighing their fish. We put it out to the states we are willing to place over 400 units around gulf for just $2 from each angler. Our thoughts are if anglers helped pay they will weigh their fish. In most of our conversations with anglers they are willing to pay more if they more opportunity to fish.
4/11/2018 9:25:39Jim Greene
Destin, FL
Charter/Headboat For-Hire
Future of For-hire Management
An initiative for the development of a White Paper by the Gulf Council
The Destin Charter Boat Association (DCBA) has looked at the success of Amendment 40 and would like to start the discussion on what future For-hire management would look like if it was to be drawn in a different direction than the current proposed amendment paths.

The purpose of this initiative is to start discussions on what other management alternatives would look like if current planned amendments fail to provide a viable path to long term solutions for accountability, sustainability, and access for the For-hire industry and the anglers that rely upon these federally permitted vessels for their access point to the EEZ fisheries.

Amendment 40 has provided the For-hire industry with a documented level of unprecedented accountability within the Red Snapper fishery. Under this implemented amendment the For-hire sector has remained under the allocation’s ACL and ACT and has effectively not overfished. The success of fishing within the sector’s allocation over the last few years has been a solid proof for how removing uncertainty in the data can benefit the anglers this sector represents. It has also stabilized the industry by providing expected season lengths that allows for anglers to book their trips to the coast with confidence that the fishery will remain open.
The success of this amendment does not stop at the angling opportunities and access level purview. The ability to operate within the quota also has enormous benefits to the growth of the stock and keeps the rebuilding plan on track concerning the impact from the For-hire sector’s harvest level.
Amendment 40 has imposed a train of thought among industry leadership on how sector allocations and the approved but not yet implemented For-hire industry’s data collection program could allow for greater angling opportunities among the five major reef fish species. (Red Snapper, Grey Triggerfish, Greater Amberjack, Gag Grouper, and Red Grouper)

Future Improvements and Additions
With stabilization of the For-hire Red Snapper fishery a lot of us have viewed this as a possible solution for the other four major reef fish species. Along with that it puts us in the position to think what the implementation of the now passed “Modification to Charter and Headboat Reporting Requirements” will do to further the amount of access provided to these anglers and the benefits that will aide in future stock assessments.
The DCBA would like to see from the NMFS/Council staff what the framework and structure would be if a planned amendment was constructed to address the other four major reef fish species or one that encompassed all five. The industry is striving to find long term solutions for our anglers and businesses. If an amendment was structured to only include the other four major species, then a removal of the sunset provision in Amendment 40 would be imperative. We also would like to see the white paper structured in such a way that provides For-hire sector allocations, bag limits and seasons, and mandatory catch and effort reporting.

• Amendment 40 still has a Sunset Provision
• Modifications to For-hire reporting requirements are not yet implemented
• The other four major species do not have a sector specific allocations, amendments, or plans

• Removal of the Amendment 40 Sunset Provision
• Implementation of mandatory daily submissions of catch and effort data by all For-hire vessels
• A planned amendment addressing either the remaining four major reef fish species or one that address all five-major species
• Management strategies that include: Sector Allocations, Bag limit and Seasons, Mandatory catch and effort data reporting
• Other unexplored long term solutions
The industry wants long term solutions. No matter how the For-hire sector is handled in the future catch and effort data is and has been a goal of our industry. We have always expressed this desire to be part of the solution and remove the uncertainty from the data. We have always felt like we have been a victim of the extrapolation and survey type data collection programs. No matter which way it is structured we feel it is imperative to do our part and close the gap in data in the For-hire sector. We also hope that our data collection program can be used as an example for a future effort to reduce data uncertainty in the rest of the recreational fisheries.
We feel that the other four major species should have a similar plan. That those stocks should also enjoy the accountability and biological protections provided to Red Snapper under Amendment 40. And in the end when the five-major species have been addressed sunset provisions should be not part of the structure. The idea and push for this is long term sustainable solutions. Scrutiny and changes can be address at the scheduled program review intervals that will be predetermined within the process. Sunset Provisions are counter productive to stabilization. It is our desire to develop these discussions so that our industry has a suite of options that allow us to find the proper direction for the future of our industry.
Thank you for your consideration on this issue
4/11/2018 10:02:34Heather Burke
Destin, FL
Gulf Wide Cobia Regulations
Not understanding why the Gulf Council has not made the Cobia regulations for Florida, Gulf wide??
It is ridiculous to have Florida able to catch a MAX of 2 Cobia per day per boat to help with the Cobia repopulation BUT the other Gulf States are able to catch two per person with NO boat limits. How is this going to help with Cobia repopulation?
Until we have the same regulations for Cobia, Gulf wide there will be no increase in the cobia repopulation.
I'm all for supporting repopulation and regrowth but until the other gulf states are ALL on board with the same limits it will never happen....

Alabama 33' FL, 2 per person, No boat limit

Mississippi 33' FL, 2 per person, No boat limit

Louisiana 33' FL, 2 per person, No boat limit

Texas 37' FL, 2 per person, No boat limit

Florida 33' FL, 1 per day or 2 per vessel, whichever is less.
4/16/2018 12:14:08Eric Brazer
Galveston, TXOther
Reallocation and Gulf State EFP Applications
Dear Madam Chair,

On behalf of the Gulf of Mexico Reef Fish Shareholders’ Alliance (Shareholders’ Alliance), please accept these comments on the following issues to be discussed at the Gulf of Mexico Fishery Management Council (Gulf Council) meeting in Gulfport, Mississippi this week.
At the January 2018 meeting, we were disappointed to see the Gulf Council move forward with the initial development of a reallocation strategy. We cautioned that such a debate would be disruptive and extremely controversial, as it was throughout the Amendment 28 process, and that the courts have already weighed in on this issue (Guindon v. Pritzker).

We continue to oppose this idea and recommend that it be tabled. Short of that, we would concur with the following unanimous recommendations made by the AP on this topic:
• In reference to the January 2018 Council motion,1 to direct staff to include in the allocation scoping document, all Gulf Council-managed species with a commercial and recreational component.
• To recommend to the Council to include, in developing the allocation scoping document:
o information regarding overages by the recreational sector (and the private angler component in particular) and the de facto reallocations to the recreational sector that have resulted;
the dollar value of losses to the commercial sector, including all levels in the supply and distribution chain, that has occurred as a result of this de facto reallocation;
o recreational sector discards and discard mortality;
o management uncertainty in both the for-hire and private angler components; and
o information regarding the consumer demand for and supply chain of commercially caught red snapper, including an assessment of the number and location of end use consumers of commercially caught Gulf red snapper.

Gulf State EFP Applications
The Shareholders’ Alliance supports the EFP process. EFPs are an invaluable tool for fishermen that want to pilot new and innovative ideas to modernize fishery management. Furthermore, the Shareholders’ Alliance is not opposed in theory to permitting the states to manage private anglers as long as management is compliant with MSA requirements. To that end, we have some concerns with the details of these EFP proposals and how NMFS will ensure compliance with catch limits as required by the MSA.

For the Gulf of Mexico red snapper fishery, section 407(d) of the MSA requires that NMFS “establish ... quotas for recreational fishing ... that, when reached, result in a prohibition on the retention of fish ... for the remainder of the fishing year.” 16 U.S.C. § 1883(d)(1). To comply with section 407(d) in light of significant management uncertainty in the recreational fishery, NMFS must “implement management measures with a fighting chance of ‘result[ing] in a prohibition on the retention of fish’—be that a buffer, a dramatically shortened season, or some other strategy.” Guindon v. Pritzker, 31 F. Supp. 3d 169, 193 (D.D.C. 2014) (“Failing to do so [is] arbitrary and capricious.”). Other provisions of the MSA similarly require accountability with catch limits. See id. at 197-200;
16 U.S.C. § 1853(a)(15); see also 50 C.F.R. § 600.310.

To ensure such a “fighting chance” of adhering to the quota as required by section 407(d) and other MSA provisions, NMFS approved a 20 percent catch buffer and payback of overages. See 80 Fed. Reg. 14328 (Mar. 19, 2015).6 The 20 percent buffer, however, has proven inadequate with respect to the private angler component. In 2016, the private angler component exceeded its annual catch target (ACT) by 1.868 million pounds, and exceeded its annual catch limit (ACL) by 1.038 million pounds.7 In 2017, NMFS authorized an unlawful redsnapper season extension for Gulf of Mexico private anglers that NMFS did not even defend on the merits whenchallenged in court,8 resulting -- yet again -- in a massive overage by private anglers that caused the overfishing limit to be exceeded.9 NMFS has sworn not to commit the same unlawful action in 2018.10

The Gulf States are now proposing EFPs that collectively would permit private anglers to land up to 4.136 million pounds of red snapper in 2018 and 2019.11 This amount significantly exceeds the private angler component’s ACT of 3.108 million pounds and ACL of 3.885 million pounds. See 50 C.F.R. §§ 622.41(q)(2)(iii)(C), 622.39(a)(2)(i)(C). The states are also proposing to use their own catch monitoring systems that are different in each state. The states have contended that their own monitoring systems show that NMFS’s landings estimates are overestimated and so presumably will allow for longer seasons than NMFS would calculate using MRIP.12 Increasing this overfishing risk even further, four of the five Gulf States are proposing to reduce or even eliminate the catch buffer NMFS approved to comply with section 407(d).

Given all this -- the history of repeated recreational overages, requested catch limits that exceed the private angler component’s ACT and ACL, new and varied catch monitoring systems that are likely to increase management uncertainty, and reducing or eliminating catch buffers -- the Shareholders’ Alliance is concerned that the states’ EFPs will only continue the decades-long trend of recreational sector overages. These overages risk overfishing of the stock and result in an unlawful de facto reallocation in favor of the recreational sector in violation of the Reef Fish FMP. See Guindon, 31 F. Supp. 3d at 201. NMFS has acknowledged that it cannot exempt the states from statutory provisions such as section 407(d) through EFPs. See 83 Fed. Reg. at 12152. Accordingly, at a minimum, NMFS must maintain at least a 20 percent catch buffer across the private angler component, ensuring that the total amounts authorized to be landed under the Gulf States’ EFPs do not exceed the private angler’s ACT of 3.108 million pounds. To protect the stock in the event of any overage in 2018 resulting from the EFPs, the Gulf States should be required to pay back any 2018 overages out of their 2019 allocations as a condition of the EFPs.

Furthermore, three states (FL, AL, and MS) do not seek authority to manage the for-hire component, one state (LA) would allow for-hire vessels to opt in to its EFP, and one state (TX) would compel all for-hire vessels to fish under its EFP. The Gulf States lack legal authority to manage federally permitted for-hire vessels beyond state boundaries in these circumstances where the states’ regulations would conflict with the Reef Fish FMP. See 16 U.S.C. § 1856(a)(3). NMFS also lacks the legal authority to compel persons to fish under an EFP without their consent, as Texas requests. See, e.g., 16 U.S.C. § 1854 (NMFS lacks authority in these circumstances to unilaterally modify duly promulgated management measures that apply to regulated parties); 50 C.F.R. §
600.745(b)(4) (requiring each vessel fishing under an EFP to acknowledge and agree to the EFP terms and conditions). Also, by granting the Louisiana and Texas EFPs, NMFS would have to reduce the red snapper quota available to the rest of the for-hire component not fishing in those states in contravention to the Reef Fish FMP. Without an FMP amendment or consent of the entire for-hire component, NMFS has no power to unilaterally allocate the for-hire component’s quota among the Gulf States through issuance of EFPs. As a practical matter, the incongruity between the states’ EFPs will only increase confusion and management uncertainty and create law enforcement issues.

Finally, unless and until NMFS has determined that the landings estimates from the Gulf states’ respective catch monitoring systems constitute the best available science and has certified those systems, National Standard 2, 16 U.S.C. § 1851(a)(2), requires NMFS to continue using MRIP alongside the catch monitoring systems in four of five Gulf States that currently lack certification in order to monitor recreational sector landings and determine when the total recreational quota has been reached.

The Shareholders’ Alliance is encouraged to see the Gulf States and private anglers support the EFP process as they attempt to develop solutions for the private angler sector. Critical to this success, however, are meaningful accountability measures and certified catch monitoring systems, which are presently lacking in the proposals. Furthermore, NMFS lacks the legal authority to compel persons to fish under an EFP without their consent, as Texas requests. While we continue to support the EFP process, we raise these concerns with the details of these EFP proposals and how NMFS will ensure compliance with catch limits as required by the MSA.
4/17/2018 8:00:17Trevor HIggins
My name is Trevor Higgins and I am writing today to discuss the declining cobia numbers. It appears that although the regulations changed this year were a step in the right direction it won’t be enough to have a rebound in the population. I was hoping you could give me some insight as to what the gulf council plans to do on this matter. Thanks so much for your time and I look forward to hearing from you!
4/18/2018 8:28:06Vince Duffyvduffy3@acsi.netSpanish Fork, ALOtherCobia
The red snapper has made a huge comeback and it is do to the strict limits put on the fishery. It is now time to put your crosshairs on cobia, there has been a huge decline in the northern GOM and the fishery needs help.
4/18/2018 8:29:20Robert Summerlin
Orange Beach, AL
Charter/Headboat For-Hire
I am a charter fisherman out of Zekes marina in Orange Beach Alabama and over the past few years we have noticed a drop in the number of cobia we have already taken measures as a fleet to release any fish under 40 inches and we would like for the state and federal size limit to be changed as well
4/20/2018 7:40:42Dylan Hubbard
Charter/Headboat For-Hire
Descending Devices, Lionfish, MREP
Hello, my name is Captain Dylan Hubbard and my family business has been fishing central west coast of Florida for nearly 90 years and four generations. We operate 6 federally permitted vessels both charter and head boats, and I am here today representing my family business and my family’s business history alone. It’s not easy loosing time away from work, my family, and my dog to follow this council around the gulf but my family’s long history fishing the Gulf is worth protecting to me and makes me more driven to get through these meetings and stand up here today. I have recently completed part of the MREP program this past fall and will be attending the science portion of the program this coming week. If you haven’t had a chance to join the program, I would strongly encourage you to do so and I hope it continues to grow and flourish.
MREP program
Once again, I will add that the most glaring issues that faces this council I learned through the MREP program is that we have once science center for three councils. We need more science centers, how can you properly execute science-based management with a lack of science centers to provide those management ideas. More science centers mean more assessments and more frequent assessments and I feel this would significantly improve a multitude of problems we face in the gulf.
Becoming increasingly prolific offshore, nears shore and inshore. Strongly recommend that we do what we can to slow the spread of this disease in our gulf.
Descending devices and Venting tools
I feel this policy is very important and the additions dr. Stunz added during the committee was what I was going to stress needed to be included here today. I feel the most important part of making this successful is to get the largest numbers of anglers on board and to do that, primarily, we need to illustrate its benefits. The main benefit being lower number of dead discards will allow, perhaps, for more future fish. Education on how to properly vent & Descend would be secondary once the angler is motivated and on board with these ideas.
4/20/2018 7:52:27Scott Hickmanlistodos@gmail.comGalveston, TX
Charter/Headboat For-Hire
Amendment 40
Amend 40 has worked well, stabilized the Cfh industry and increased angler access and continues to keep CFH fleet under its ACL. I would Like to see the council reduce the CFH buffer to reap the full benefits to Cfh anglers and would also like the council to explore DCBA white paper recommendations of a multi species amend 40. I support all the recommendations of the red snapper grouper tilefish Ap.
4/20/2018 8:04:49Tom Ardfairwater2@icloud.comOrange Beach, AL
Charter/Headboat For-Hire
Cobia, Triggerfish, Amend 40
I am the owner of 4 federally permitted charter boats, 2 six passenger and 2 multi-passenger vessels. I was unable to make the meeting public comment in Mississippi today so I wanted to express some of my concerns.
Cobia: These fish are in big trouble I'd like to see a gulf wide closure until the fish stock recovers. I feel the stock has already Collapsed.
Triggerfish: Thank you for the 2 month, 1 fish season. I like it, it works, I hope we stayed under quota. We caught very large Triggers this year and kept way more than we had to throw back.
Amendment 40: its been great for the CHF industry I'd like to see the sunset removed, Id like to see the buffer lowered to 10%, Id like to see Amberjack, Triggerfish, and Grouper added to Amendment 40 and fish under seasons.
4/20/2018 9:34:06Michael A Gros
Larose, La. 70373
Private Recreational Angler, Commercial Fisher
I would like the counsel to seriously look into giving tags for fishing red snapper. It is the fairest way to help all fishermen. Anyone could get them upon request or with a small purchase. I think 20 to 30 per year is not too liberal. There is an overabundance of snapper in the Gulf right now. I've been to multiple are is on a given day and seen clouds, square miles of nothing but snapper hanging on them. Possibly millions at each! I feel if this is not controlled properly it will eventually destroy the eco system of other species! Please, this growth in snapper population needs to be monitored closely. Tags will allow fishermen to go out and be allowed to catch a small amount of fish yeary but really enjoy their few trips offshore. Many never see a red snapper on their tables because of work schedules, Especially here in gulf states that you represent! If you ask fishermen for their input, I'm sure you will get a positive response on this way to tackle a tough problem. I hope to hear good news on this, weekends, straight days openings and seasons restrict great numbers of fishermen because of weather, work schedules and other related topics. My second proposal is that you guys really need to do something about the permit system, it's not air to anyone but the few who were capable of acquiring permits for ref snapper. These guys have a monopoly going and many sit home, never leave their couch. How can you watch this happen. I really don't know the answer here but even as a lifelong commercial fishermen I can't fathom that this injustice has been perpetrated. I'm hoping that every effort is made to share the wealth and maintain healthy fish populations! These 2 proposals make more sense than any laws on record today. I'm hoping you deeply consider them, the only people who will not agree with them are the handful who have these permits. For the majority, major majority! These are fair, timely needed and should be priority #1. Thanks for your time and efforts, I am hoping to hear good news on these critical problems and it will get so much pressure off of the council. Take care, God bless you and have a great day. You can reach me at 9856772116 or Michael Gros on Facebook or, again thanks for your time and efforts!
4/23/2018 13:15:57Philip Thompson
Panama City Beach, FLCobiaShut the fishery down June 1st, 2018.. and do not open it again until March 1,2020.!!! They need to spawn and be left alone! Gulf and Atlantic!
9/4/2018 14:53:12Robert Emerick
FloridaRed Tide
4/11/18Jacob Millerjacobsmiller850@gmail.comCobia fishing has deteriorated along the gulf coast annually since i started fishing in 2010.
6/12/18WIlliam Copelandflcfuinc@gmail.comNew Port Richey, FLNGOMembers of the GMFMC,
The Florida Commercial Fisheries United Inc (FLCFU) is a non-profit corporation with the mission to support the interests of Florida's commercial fishing industry, promote sustainable fisheries policies, and advocate on behalf of commercial fishermen, fishing businesses, and consumers of saltwater products. The FLCFU hereby submits, in priority order, the following comments, concerns, and recommendations for your consideration:

There are serious problems in shallow water grouper stocks in the both state and federal waters in the Gulf of Mexico (GOM). Red Grouper and Gag Grouper stocks have been overfished, are experiencing overfishing, and are in decline. If current stock assessments indicate otherwise, they are wrong. We need to act now to begin restoring these fisheries to healthy populations by shortening recreational seasons and reducing bag limits in both state and federal waters.
FLCFU is a strong supporter of domestic aquaculture. The United States has become far too dependent on imported seafood. We currently import over 80% of all seafood we consume and over 90% of all raw shrimp available in this country are aquaculture farmed in SE Asia. It is time that we put Americans to work providing these aquacultured products and reduce, if not eliminate, our dependence on imported seafood. “Made in America” should mean something in the seafood business just like other industries.

Unfortunately, I will be unable to attend the June 2018 Key West Gulf Council meeting and will therefore be unable to discuss these issues with you in person at the meeting. Please contact me via phone or email if you would like to discuss anything in further detail.
6/14/18esherer@foe.orgDear Gulf of Mexico Fishery Management Council,

I was alarmed to hear that the Council is preparing to approve a new marine finfish aquaculture project in the Gulf of Mexico, just off Florida’s coast. I am writing to the Council to voice my opposition to this facility in waters near my home, and to marine finfish aquaculture everywhere.

These underwater feedlots are bad news all around. They are horrible for the environment and public health. They can cause massive, catastrophic fish spills –- like the release of more than 263,000 Atlantic salmon from a floating feedlot in Washington State –- which spread disease, risk genetic degradation, and create unnecessary competition with our already struggling native fish stocks.

These industrial fish farms directly discharge into our waters a whole host of pollutants aside from spilling farmed fish, including anti-foulants, excess feed, and untreated fish waste. They attract and harm predators and other wildlife. They are corporate-driven, which only means higher profits at the expense of sustainable operations and quality products. These factory farms are leading to the demise of our wild fishing communities and related industries by placing downward pressure on fishing prices and creating competition for limited marine space.

Despite Kampachi’s current plan to operate a “small-scale” facility, it has made clear that it will concurrently seek a commercial permit for a larger facility. To approve the current permit would open the floodgates to massive fish farms, and put our Gulf waters and coastal communities at significant risk.

NOAA is charged with protecting our oceans and conserving marine species and their habitats. Allowing industrial ocean fish farms in our oceans contradicts each aspect of this mission. I’m joining my Gulf neighbors today to protest industrial ocean fish farming, and call for the Gulf of Mexico Fishery Management Council and NOAA to deny the requested operation permit for Kampachi Farms, LLC to operate a marine finfish aquaculture facility in our Gulf waters.

I urge you to do everything you can to stop industrializing our oceans with factory fish farms, and instead support truly sustainable seafood production alternatives.

Thank you,
6/14/18Zachary WolfeFloridaKing MackerelDear Gulf Council,
The non-traveling group of federally permitted king mackerel fishermen of the Northeastern Gulf of Mexico Region are petitioning for an earlier open date of September 1st, 2108. This request is due to lack of time to fish our quota and make a sufficient amount of income for the year.

In the years past, the western Gulf quota has been met by the end of September. This results in the traveling fleet moving into our region on October 1st (when our zone opens) and catching most of the quota in our area. This ultimately limits all the local fishermen the ability to fish our region and provide for our families. The fish in our zone have usually moved/migrated by the second or third week in November. The weather and sea conditions in October and November can limit the days you can safely go fishing. Our proposal is an open date of September 1st, 2018. This extra month would benefit us greatly. We all feel the proposal of a September 1st, 2018 open date is essential for the livelihood of the fishermen of the Northeastern Gulf Region.

Northeastern Gulf Region King Mackerel Fishermen
Zachary Wolfe – FL 7517BK
Thomas Norvell – FL 4546PD
Micheal Bir - 940352
Unknown – FL 5549NZ
Matthew Peters – Doc# 567943
Jeremy Ruskowski – KM # 568 FL 7511CT
Dean Debars – FL 5383MZ
Unknown – KM-1437
Unknown – Bushwacker FL 1014GT
John Unknown – FL 5212LR
Michael King – DO976515 KM - 1244
Aaron Smith – 625119 KM 1085
Unknown – DO664528
6/15/18JP Brooker
St.Petersburg, FLNGOSEDAR 51
6/15/18Jim Zubrickjim@jollyrogersii.comSteinhatchee, FL 32359EFPHello Folks, I plan on being at next weeks council meeting and want to make a few points before the meeting. This meeting will probably have the least amount of stakeholders present as any time that i can remember, the most casual observer knows that the charter fleet is full throttle. Additionally; most everyone but the folks trying to back door an allocation discussion have the decency to level the playing field as the charter-for-hire and commercial sectors have always done in the past. Its obvious that the ink has not even dried on the EFP's and the FISH grab is trying to take center stage, a non accountable sector that once again wants to cause crisis among what are very optimistic times now that the states are heading in the right direction. I call on those respected council members to table this until August and better yet till the 2 years EFP's are expired.
6/15/18Eric Brazereric@shareholdersalliance.orgEFPOn behalf of the Gulf of Mexico Reef Fish Shareholders’ Alliance (Shareholders’ Alliance), please accept these comments on the following issues to be discussed at the Gulf of Mexico Fishery Management Council (Gulf Council) meeting in Key West, Florida this week.

Recreational Management.
The Shareholders’ Alliance continues to support the Exempted Fishing Permit (EFP) process.
EFPs are an invaluable tool for fishermen that want to pilot new and innovative ideas to modernize fishery management. Furthermore, the Shareholders’ Alliance is not opposed in theory to permitting the states to manage private anglers as long as management is compliant with requirements of the Magnuson-Stevens Fishery Conservation and Management Act (MSA).

However, given the history of repeated recreational overages, new and varied catch monitoring systems between Gulf States that are likely to increase management uncertainty, and reducing or eliminating catch buffers, the Shareholders’ Alliance is concerned that the states’ EFPs may continue the decades-long trend of recreational sector overages. These overages risk overfishing of the stock and result in an unlawful de facto reallocation in favor of the recreational sector in violation of the Reef Fish FMP.8

The Shareholders’ Alliance is encouraged to see the Gulf States and private anglers support the EFP process as they attempt to develop solutions for the private angler sector. Critical to this success, however, are meaningful accountability measures and certified catch monitoring systems. We look forward to seeing the results of Year 1 of these EFPs and strongly encourage any lessons learned be incorporated into Year 2 as well as into an overall private angler management strategy. To that end, we strongly urge the Gulf Council continue developing such a plan so that it is legally implementable, complete, and has the public’s confidence prior to the expiration of the EFPs.
6/20/18Dylan Hubbarddhubbard@hubbardsmarina.comMadeira Beach, FLHello, my name is Captain Dylan Hubbard and my family business has been fishing central west coast of Florida for over 90 years and four generations. We operate 6 federally permitted vessels both charter and head boats, and I am here today representing my family business alone. I am also an MREP Graduate. Really love the move to fish rules app, it works super well and is hugely utilized already and will be super nice to be able to check all the regulations in one place and people will have MUCH LESS confusion with this approach.

Once again, I will add that the most glaring issues that faces this council I learned through the MREP program is that we have once science center for three councils. We need more science centers, how can you properly execute science-based management with a lack of science centers to provide those management ideas. More science centers mean more assessments and more frequent assessments and I feel this would significantly improve a multitude of problems we face in the gulf.

Lionfish are Becoming increasingly prolific offshore, nears shore and inshore. Strongly recommend that we do what we can to slow the spread of this disease in our gulf.

I support daily electronic reporting; however, we would like to avoid VMS on the boats this would add an extra layer of expense that is not needed as we are already reporting areas fished why do you need to track it specifically? We would support the shrimp boat ELB approach with a very general area ping instead of the VMS approach with specific tracking.
8/13/18Jeff Senarighisengarighi1@yahoo.comGray TriggerfishI see that the ACT for gray triggerfish has been reached and this year’s season will be closing. I’m writing once again to the council to request they have a limited season for us snowbirds in Jan 2019 similar to what they did in Jan of this year. I can reiterate our contributions to the gulf economy, but really, how often do we have to remind the council of these facts and figures to show we are a vital part of the gulf economy? We are part time residents of the gulf and senior citizens that enjoy fishing for and eating what we catch and want triggerfish to be part of that stringer. The data for this triggerfish season is not yet complete, we know the ACT is projected to be reached but don’t know if the ACL will be. Please ask the council to set aside a portion of this resource for the winter residents of the gulf coast. Thank you
8/14/18Gary Bahngbahn@gmail.comGray Triggerfish and Red SnapperI am one of the many that would like to be able to keep a trigger fish and a Red snapper while down in Orange beach from Dec to end Feb, with the current situation it looks like neither of these two fish will be legal to keep. I can not understand why they don let us have a few weeks in the winter months, for the first part in the winter months not that many days can the charters go out, it can be either windy or to cold, and the charters boat are not always full at that. That being said the number of fish or triggers we do catch as seniors during that time frame would have little impact on the total weight or numbers that seem to be regulated. I would think they would consider us snow birds who spend anywhere from 2 to 3 months supporting the area, where as in the summer most only come for one week. I would sure hope they might consider making some changes for us.
8/15/18Rusty Reardonjjrj58@hotmail.comI know you have heard request from a very small percentage of “Snow Birds” that flock to your gulf coast January and February which is representative of the small number people fishing during the those months. That is to say we don’t have a huge impact on the catch as you do in the summer months.

I’ve outlined to you before the financial benefits we bring to the area and am pretty sure the 84 thousand employees we keep working are appreciative.

I just have a couple of questions and would love to hear your thinking on this mater.

1. I am interested to know if you have considered opening a very limited season for Trigger and Red Snapper during January and or February for Charter Boats only.

2. And if you have, I would love to see your reasoning behind the
decisions you make.


Rusty Reardon
8/15/18Neil Rademachernjrademacher@q.comMinnesotaGray Triggerfish and Red SnapperI am writing this email to try and understand the reasoning behind the current restrictions on Trigger & Red Snapper. I have been enjoying vacationing in Orange Beach in February for four
years now and will continue to do so. I really enjoy the Charter Fishing available for a nice day of fishing. The Charter services just like the commercial fisherman are just trying to make a living. For me the importance of both of these businesses are critical to the area. I believe that the Charters are just as concerned for the preservation of declining species. To restrict the Charters from catching certain species but allowing Commercial fisherman more harvesting makes no sense. Many snowbirds residing in Orange Beach during the winter are not irresponsible fish mongering individuals. I don¹t understand totally how the numbers are arrived at but I do know that when I do go out on Charters we catch a good healthy number of Triggers and Red Snapper. If the numbers of these species is in such decline than why do we consistently catch them? Something to me just doesn¹t add up.... Being able to keep just one Snapper or Trigger fish during the February month time frame doesn¹t seem unreasonable. Seems to me that more restrictions are on the Horizon. I understand that I am a small fish in a Very Big Pond but we should still be heard ...Thanks for listening to a small fish.....Sincerely yours a Minnesota Resident, Responsible Fisherman and Winter Visitor: Neil Rademacher
8/16/18William Copelandflcfuinc@gmail.comNew Port RicheyNGORed Grouper, Gag GrouperThe Florida Commercial Fisheries United Inc (FLCFU) was formed in June 2017. Our mission is to support the interests of Florida's commercial fishing industry, promote sustainable fisheries policies, and advocate on behalf of commercial fishermen, fishing businesses, and consumers of saltwater products. The FLCFU hereby submits our comments relevant to the October 2017 GMFMC meeting. Please consider the following actions and recommendations: There are serious problems in both Red Grouper and Gag Grouper stocks. Without question, these stocks are overfished, experiencing overfishing, and in decline. There is little doubt that current stock assessment data is inaccurate. FLCFU recommends the GMFMC use the best and most accurate data we have, commercial harvest, to evaluate the health of these fisheries and take immediate action to begin restoring these fisheries to healthy populations. FLCFU opposes any further actions to create or authorize an auction of IFQ shares or allocation for any fish species.Thank you for considering our comments and recommended actions for the Aug 2018 GMFMC meeting. If you have any questions, please contact me.
8/20/18Mississippi Commercial Fisheries UnitedMSCFUwebs@gmail.comMSCommercial Recreational OverfishingIII. MSCFU Expresses Concerns Regarding Chronic Recreational Overfishing - MSCFU is alarmed by the recently released MRIP recalibration data that exhibits a sharp increase in marine recreational fish landings data for nearly all species tracked. This data adds another layer of uncertainty into recreational fishing effort and landings although we do not dispute the accuracy of the data. MSCFU urges extreme caution when considering increasing access and/ or allocations for the recreational fishery.
8/20/18Mississippi Commercial Fisheries UnitedMSCFUwebs@gmail.comMSCommercial Gag and Red GrouperThere appears to be serious problems in both Red Grouper and Gag Grouper stocks. These stocks could very well be overfished, experiencing overfishing, and in decline. MSCFU recommends that the Gulf Council use the best available scientific evidence to evaluate the health of these fisheries and take immediate action to begin restoring these fisheries to healthy populations. Further evaluation of recreational fishing seasons and recreational reporting requirements for Red Grouper and Gag Grouper should be thoroughly considered immediately.
8/20/18Ocean Conservancyjbrooker@oceanconservancy.orgNGORed Tide and grouperOcean Conservancy1 is writing to provide comments to the Gulf of Mexico Fishery Management Council (GMFMC, the Council) on the ongoing red tide event in Florida and its probable severe negative impacts on critical Gulf reef fish stocks including red grouper. On August 1, 2018, the Council issued a questionnaire titled “Something’s Fishy with Red Grouper,” wherein opinions from the public are being solicited to add on-the-water perspectives to the upcoming red grouper stock assessment. Ocean Conservancy makes two specific recommendations: 1. The terminal year of the SEDAR 61 red grouper assessment should be changed from 2016 to 2018 or the 2018 fishing season should be included in SEDAR 61 as projections.2. The SEFSC should prioritize the completion of its research on interim measures for red grouper and other stocks. At the outset, Ocean Conservancy commends the Council for reaching out to the public to gain information on what is happening with red grouper, given the recreational fishery landed only around 30% of its ACL for 2017.2 Inability of fishermen to land their quotas is problematic for the overall wellbeing of the fishing public and for the local economies of coastalconservation perspective, such an underage is a troubling sign of potential problems with the health of the species and the broader ecosystem. Furthermore, Ocean Conservancy is pleased to see that the red tide event is specifically being considered in this red grouper survey. Taking into account natural mortality attributable to events such as this is of critical importance to examining the true health of the fishery, our assumptions of future productivity, and the ecosystem as a whole. Analysis of the impact of ecosystem factors such as red tide events is important and shows the value of taking an ecosystem based approach to fisheries management. Natural fish mortality can be affected by a number of factors beyond predator-prey relationships and beyond environmental conditions such as the red tide event. Additional factors may include the effects of hypoxic zones, changes in water temperature and changes in rainfall attributable to climate change, oil spills, and changes in habitat due to a changing environment. By better estimating natural fish mortality through a careful analysis of this range of both acute and prolonged environmental impacts, we can more successfully manage our stocks and safely maximize future yields. Red tide is a growth of the naturally occurring organism Karenia brevis that has been recorded in Florida since the 1840s and events occur every year. When concentrations of organisms are higher than normal, the “bloom” can have severe impacts on humans and wildlife. Red tide produces toxins that can harm or kill fish, birds, marine mammals, and sea turtles, and airborne toxins created by red tide can have harmful respiratory effects in humans. Shellfish can accumulate red tide toxins, and eating shellfish that has been contaminated with red tide can cause Neurotoxic Shellfish Poisoning in humans.3 The red tide event currently plaguing Southwest Florida is extreme, and fish kills have been reported across nearly six counties in the region. The image below, from the Florida Fish and Wildlife Conservation Commission, shows the magnitude of the event, indicating that the concentrations of red tide are in excess of 1,000,000 red tide cells per liter of water in a stretch of coastline over a hundred miles an area that overlaps with a significant portion of the range of Gulf of Mexico red grouper. communities. From a The Governor of Florida has declared a state of emergency for the area and has directed dollars to the State tourism development agency as well as to private marine research laboratories.5 On a personal note, as a sixth generation Floridian born and raised on the water I have never seen a red tide event as severe as this with such far reaching and appalling fish kills. I have seen a two hundred pound Goliath Grouper washed up on the beach in Sanibel (see attached images). On a recent spearfishing trip (August 9, 2018) I witnessed hundreds of inshore and offshore fish of varying species floating at the mouth of Tampa Bay just inside of Egmont Key, possibly pushed north from Manatee and Sarasota Counties by current and wind. The damage being done by this event is likely to have significant deleterious impacts on gulf reef fish, since red tide blooms typically impact waters out to 30-40 miles. Estimating red grouper health is already subject to a considerable amount of uncertainty, and this red tide event will likely only serve to exacerbate the potentially precarious position of the stock. Given this, the Council should request that the SEFSC assess the impacts of this event on the health and estimates of future productivity of red grouper as soon as possible. One way to do this would be to change the terminal year of the SEDAR 61 assessment from 2016 to 2018, or at least to explore the feasibility of doing so. Barring shifting the terminal year, the impacts of the red tide event on the 2018 fishing season need to be acknowledged in some way, which could include at a minimum their being included as projections in SEDAR 61. Also, the Council should encourage the SEFSC to prioritize the completion of its research on interim measures for red grouper and other stocks that is currently underway. These interim measures are intended to provide actionable advice in years without stock assessments based on current information. For red grouper, where indices of abundance are declining to their lowest levels since 1985, this type of advice would be especially valuable given the fact that red tide is likely impacting adult red grouper and could eliminate the expected strong year class that is typical of their life cycle.6 These interim measures are also important because there are similar concerns for greater amberjack, gray triggerfish, gag grouper, and cobia in addition to red grouper. We appreciate the opportunity to share this information with the Council, and please contact me directly if you have any questions or comments.
6/22/18Dylan Hubbarddhubbard@hubbardsmarina.comMadeira Beach, FLfor-hirefor-hire
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