TimestampFull Nameemail addressCity, State, Zip CodeCheck all that applyComments
12/18/2019 16:16:38Testtest@test.comTampa, FL 33607OtherTesting
12/19/2019 7:07:44Bob Zales
Madeira Beach, FLOther
1/27/2020 9:44:29Eric Brazer
Galveston, TXNGO
1/27/2020 9:58:07Catherine Bruger
St. Petersburg, FLNGO
6/12/2020 8:56:15Catherine Bruger
St. Petersburg, FLNGO
6/16/2020 10:14:19Eric Brazer
6/16/2020 11:07:03Sepp Haukeboshaukebo@edf.orgNGO
6/16/2020 11:17:58Sepp Haukeboshaukebo@edf.orgNGO
6/26/2020 10:34:09Catherine Bruger
NGOGood afternoon,

Per our discussion, attached is our exploration of a Gulf-wide buffer concept. I’m not sure how you would like to distribute with other Council members. Though our continued preference is a temporary rule calibrating the ACLs for each state, this option would work if the buffer is set at a level which prevents overfishing.

We calculated that a 20% buffer will not be sufficient to keep the private angler component below the 4,269,000 ACL. Attached, you can see that a 32-33% buffer could prevent overages by iterating cell C3. Our buffer calculations do not account for the 2019 paybacks to LA. Last, we note that summing landings among states (even calibrated state quotas) can’t be completed without first converting back to MRIP units.

Please feel free to contact me to discuss further.

Thank you again
7/8/2020 9:05:48Bob
Charter/Headboat For-Hire
Sorry for the lateness of this email but have been extremely busy fishing every day. Please provide this to all ssc members for their meeting tomorrow and Thursday. Thanks,

On behalf of the Gulf members of the National Association of Charterboat Operators (NACO) and the commercial grouper longline members of the Southern Offshore Fishing Association (SOFA) I offer these comments about the info y’all are discussing. As all know we requested this type of workshop after your January meeting where this new mrip fes survey was discussed and recommended changes to the Gulf Red Grouper Fishery were made based on the new mail survey with the effort component added. We have provided numerous comments about our concerns for the for hire charter and commercial grouper fishermen about the dramatic shift of recreational fishing effort back to 1985 which has arbitrarily caused a proposed shift in the original allocation of red grouper from 76% commercial to 24% recreational to the proposed change to 60% commercial and 40% recreational. As all now know this arbitrary shift adversely affects both sectors as the commercial sector loses quota reducing the future ability to provide historical catches of red grouper to consumers and at the same time, although it appears the recreational sector gains, in reality they lose as the new numbers indicate the rec sector over harvested their quota which has resulted in the council/nmfs now looking to alter the red grouper season and/or bag and size limits. Any reduction in season will result in fewer days fishing, resulting in negative social and economic impacts to fishermen in the Gulf and all Gulf states.

In my over 35 years of experience working with some of you, the council, nmfs, and state of Florida on recreational data systems I have seen many changes. While some have been positive many have not. As all know each time a new data system comes on line the S&T folks work to figure out how a recent data system would impact the past harvest and effort had such a system been in place 30 years ago. Frankly, while I understand computer modeling may provide such info, the reality is such info is impossible to determine with any accuracy. Social, economic, fishing activity, and many other real life factors from 30 years ago cannot be compared to the same activity today. Fishing equipment, vessels, engines, electronics, and a host of others did not exist 30 years ago anywhere similar to what is available today. The dramatic increases in effort, thus resulting in increased harvest, over the past 30 years based on a new mail and effort survey are frankly, almost impossible to fathom. Every Gulf state, excluding TX, and almost all up the eastern seaboard have questioned these new numbers as they make no reasonable sense. These questions do not just come from those of us on the water. I have been fishing for 55 years and can testify fishing is nothing like 55 years ago. The number of people on the water, vessel access, equipment were no where near what it is today. The numbers produced which are arbitrarily shifting the allocations between users are simply outrageous.

While I understand and appreciate the effort by the nmfs and science center folks to try to make the data systems the same for all years with their recalibration efforts, it may be that we need to just accept what the past stock assessments used for the periods they were for. If the new mail fes survey is to be considered the new best system, then start now with the new system and move forward. We do not understand how this arbitrary shift in effort and harvest can alter the current stock status so dramatically that a stock will change from not overfished or overfishing to overfished and overfishing simply based on a computer change based on the attempt to change history. We strongly suggest that you recommend leaving the historical effort and harvest numbers as they are and then move forward with the new system.

In addition, we are very concerned about any arbitrary shift of allocation based on highly questionable past effort and harvest numbers, especially when the council and nmfs are working on a system to discuss reallocation through a process approved by the council utilizing stakeholder input that will consider all impacts to the users, social, economic, effort, and harvest. The proposed reallocation system is currently being discussed and we recommend this system be the one used for any reallocation of any fishery. If you are going to change allocation based on questionable past harvest numbers then don’t waste your time and out tax dollars developing a reallocation system. We don’t need both.

I am sorry the COVID has caused the meeting to be held by webinar as in person meetings are far more productive as they allow for true interaction among participants. Unfortunately I will be unable to participate on the webinar as I am fishing every day trying to catch up on lost income from being shut down due to the virus. I look forward to the seeing the results of your meeting and encourage all to consider every detail on this most important issue. Thanks,
Capt Bob Zales, II

Capt Bob Zales, II
10/26/2020 10:55:35Catherine Bruger
10/29/2020 12:27:42Dylan Hubbard
Madeira Beach, FL
Charter/Headboat For-Hire
10/30/2020 8:27:41Scott Hickmanlistodos@gmail.comGalveston, TX
Charter/Headboat For-Hire
Hope all of you are safe and doing well. Miss seeing all of you. Some points our charter boat association and members crafted and myself and our membership at CFA listed below. Thanks for considering and hope to see y’all in person in 2021. Been one helluva busy year for fishing, seems the charter industry and the recreational fishery as a whole has benefited here in Texas and other places from the pandemic with so many Americans getting involved in outdoor activities. God Bless and Calm Seas... Capt Scott Hickman Galveston Texas /
1. Greater amberjack count being facilitated by Sea Grant and needs to focus on spawn and timing of spawn, as well as indices of abundance. Cooperative research projects to incorporate professional CFH fishermen should be part of the RFP requirements and is important for the success of the greater amberjack count
2. Illegal charters continue to be a HUGE issue, thank you for taking up LETC meeting motion at full council – this is huge issue all over the gulf – unlicensed operators biggest issue, regulations need to be formulated that "any consideration or fee makes it a charter
3. "We encourage the council to begin a planned amendment for Sector allocations for the major reef fish species important to our fleets by adding gag & red groupers, greater amberjack, gray triggerfish as proposed in the CFA plan
4. We have grave concerns over impact to our season if FES calibration and common currency is not dealt with now not later. A lot of changes are on the horizon in the next 1-3 years and we don’t want to look up in 3 years to see all the waters we fish have been hammered. Our livelihood still depends on ability to catch fish, if all the stock that lives in fishable waters is hammered, that isn’t good for us or the anglers we provide access to. Let’s proceed with caution, factor for uncertainty, and not go wild with catch recommendations.
5. Shark, goliath grouper and marine mammal predation is a key issue that needs to be explored and solutions found because it is already out of control.
6. Keep moving SEFHIER ELB program moving forward with stakeholder input, port ambassadors great idea. Being able to operate trips with malfunctioning units is imperative and having a back up hail in/hail out via email or phone capability must be included in the regulations . Gps archival units must be diverse and included as type approved equipment option verses ony VMS .
12/1/2020 11:48:33Bob
Charter/Headboat For-Hire
Unfortunately I will miss the morning session and public testimony so am sending my comments here.

On behalf of the members of SOFA I wish to reiterate our comments regarding the sharks populations and predation problems across the Gulf. I will be sending comments to HMS on their proposed amend 14 and strongly encourage the council to stress the HMS division expedite any and all measures that will help to reduce the current populations of sharks in the Gulf. As y’all have heard over and over the shark problem is increasing and needs to reduced.

SOFA members applaud the work by Dr. Stunz and his team on the great rs count. We look forward to the decisions that come from this effort and hopefully the work will show a much stronger and abundant rs population in the Gulf. This is good for all sectors. While we have supported the state management of rs to provide more fishing days to the pri rec sector, we have serious issues and concerns over the continued lack of restraint provided by the states on pri rec harvest of rs and are seriously concerned about any possible reduction of quota in the commercial fishery due to the constant overfishing. We are also concerned about continued and constant pri rec data issues and how those are affecting quota management. While some states seem to have developed much better data collection the lack of a standard currency to ensure all are on the same page when calculating effort and harvest data is a continuing problem. This issue must be addressed.

I have provided comments on behalf of SOFA regarding the aquaculture areas of opportunity and stress our serious concerns about the real potential impacts on fish cages due to the increasing hurricane events in the Gulf. All know that hurricanes cause extensive damage above and below the water and simply dropping cages to the bottom does not remove them from harm. SOFA members are also seriously concerned about the increased potential of increased red tide events due to the increased and concentrated fish waste from aquaculture operations. Y’all are well aware of the red tide events and impacts on our fishery stocks. The members are also concerned about the loss of fishing access due to no fishing zones around any aquaculture operation. With the increased efforts by the enviro and governmental communities to institute the 30x30 program, additional no fishing zones is a serious concern.

SOFA members are still concerned about the impacts of the changes in effort and harvest data by the pri rec sector due to the FES recalibrations. Most people are concerned about the dramatic and unrealistic increases in past effort and harvest rates and how those impact current management decisions. Vermilion snapper is another classic example as the current ABC is recommended to be more than double due to the FES recalibration. The current ABC is not being exceeded yet there are motions to increase rec bag limits. The commercial harvest has been relatively stable so there is no indication the commercial harvest will increase to the levels projected. While the proposed rec bag limit increases are a generous gesture until we are more confident in the proposed increases of ABC can be achieved we cannot support this substantial change.

Trigger fish management is still a problem so any increase in quota is welcome. Hopefully we will be able to fish year round soon so we encourage you to adopt the quota increase.

On behalf of the Gulf members of NACO and PCBA I wish to provide comments. We also fully support all efforts to reduce the shark populations for all the same reasons as the commercial fishermen.

We also applaud Dr Stunz and his team for their work on rs and look forward to the decisions for future management based on their work. We have the same concerns about loss of quota for the for hire sector due to the pri rec overfishing and reiterate all the concerns of the commercial fishermen. I also commented on the AOAs with the same comments provided on behalf of SOFA. Our concerns about the Vermilion snapper proposals are the same as those of SOFA and I stress our major concern with the FES calculations on all species. We are still not convinced that the changes in historical rec data make reasonable sense. We fully support the increase of quota for trigger fish but do not support any management changes in seasons, bag limits, or size limits. We currently are not able to fish the season of Mar, Apr, and May because the quota is reached. Had it not been for the Covid issue we would not have had a fall season. Any opening prior to March will only serve to reduce the much needed season of Mar, Apr, and May. Until and unless we are able to have enough quota to keep the current seasons open we do not support any change is status quo.

As Ms Bosarge has stated about proposed reef amend 48 being a rush to implement and the need to have more info on the possible impact on many stocks we support the delay of any final action at this meeting. This is a position of all the associations I represent.


Capt Bob Zales, II

Fishery Management Consultant


Capt Bob Zales, II
12/1/2020 11:34:13Catherine Bruger