Red Snapper Allocation (Responses)
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TimestampNameemail addressCity, State, Zip CodeCheck all that applyComments
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6/7/2018 10:32:49Test Testtest@gulfcouncil.orgTampa, FL 33604OtherTest
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6/15/2018 8:24:49Jim Clementscaptjmclements@aol.com• I strongly oppose reallocating red snapper from the commercial and charter sectors to the private angler sector.
• Reallocation should not be discussed at the Key West meeting because most commercial and charter fishermen can't be there.
• There are too many variables in play to even consider reallocation at this point including state EFPs, state management, and new stock assessments.
• Giving more allocation to the private angler sector rewards a group that has repeatedly overfished its quota. Commercial and charter stay within their quota. We shouldn't be penalized for this.
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6/15/2018 8:25:55Joe A.gulffresh@gmail.comMy name is Joseph Abdo, and I am emailing you in hopes that all gulf council members can read this, I feel strongly against giving more allocation to the private angler sector because it rewards a group that has repeatedly overfished its quota. Commercial and charter sectors, stay within their quota. We shouldn't be penalized for this. We have consistently played by the rules set before us. I feed my family from commercial fishing and participate in bringing fresh Gulf of Mexico fish to many homes in America. Thanks for your time
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6/15/2018 8:27:29Ben Faireybenfairey@gmail.com
Private Recreational Angler, Charter/Headboat For-Hire
I am a retired charter captain and now a private angler. I strongly oppose the council discussing a amendment for reallocation of red snapper at the key west council meeting. The timing of this discussion is suspect to me? Charter captains, commercial and a lot of private anglers cannot be there. Red snapper season in florida just opened and other states have a on going red snapper season as well. In my opinion the state EFP needs to be evaluated before any discussions about reallocation should even be considered.
Thank you
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6/15/2018 9:37:51Matthew Andrews
restless146464@yahoo.com
Commercial Fisher Hello my name is Matthew Andrews. I own and operate the f/v restless2 I have been a commercial fisherman for over thirty years. I have participated in the ifq catch share program from the very start. I strongly oppose any new amendment that would take away Fish from the commercial sector and give it to the private sector.we in the commercial industry have worked hard to help rebuild the snapper fishing.we have made a lot of sacrifices as in taking large quota cuts at the beginning and agreeing to more accountability. We are finally at a place where we can make a decent living and have some security. Thank you for you’re consideration
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6/15/2018 9:40:47Tommy Williams
greatescapefisheries@yahoo.com
When is this going to stop and when is enough, enough. For as long as I can remember the very people who are always wanting more are taking more. We have become a society of greedy people who live for today and don't care or worry about tomorrow, next week or next year. Fortunately their are a few honest hard working people left that due care about the future, I being one. Senator Garrett Graves pushed by the CCA and other donors to his cause lobbied for state management of just one species of Gulf fish, Red Snapper. Why just one species? What's next? I know what's next once total control is gained they will make all Gulf fish game fish which means no commercial harvest or sale and there goes my livelihood.
On another note the State of Louisiana championed this EFP program and in my opinion have the fewest knowledgeable enforcement officers when it comes to Reef Fish and the rules and regulations governing them. I fish out of Venice Louisiana and since 1995 I have been boarded by the Coast Guard only once while at sea and never by a state enforcement officer. I have been met by a state enforcement officer at the dock two times and he had no clue what he was doing or what to ask for. So who are they to say we can do a better job at stopping overfishing? And I thought each state was suppose to have agents at the marinas conducting spot checks/surveys during this EFP program? Haven't seen one in Cypress Cove Marina to estimate harvest rates so the state quota is managed better to prevent overfishing, that's a joke. And the Louisiana Recreational Landing Permit is a joke. I know several recreational fisherman who don't even have one or others that say if called for a survey they will lie and say that they don't harvest Red Snapper even if they do.
With this being said I strongly oppose reallocating red snapper from the commercial and charter sectors to the recreational fisherman again because this is the most mismanaged group in the entire fishery. So why should they be constantly rewarded for overfishing their allocated portion and the commercial sector remains well within its annual quota.
Ms. Muehls will you please forward my thoughts to to Gulf Council for consideration at the upcoming Key West meeting.
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6/15/2018 9:41:52Garrett Kingfvkingspride@gmail.comGalveston, TX
Charter/Headboat For-Hire
• I strongly oppose reallocating red snapper from the commercial and charter sectors to the private angler sector.
• Reallocation should not be discussed at the Key West meeting because most commercial and charter fishermen can't be there.
• There are too many variables in play to even consider reallocation at this point including state EFPs, state management, and new stock assessments.
• Giving more allocation to the private angler sector rewards a group that has repeatedly overfished its quota. Commercial and charter stay within their quota. We shouldn't be penalized for this.
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6/15/2018 10:33:41Sean Heverin seanhev77@yahoo.comLeeville, LouisianaCommercial FisherI'm a commercial fisherman in the northern Gulf of Mexico and fish from Panama City, FL to Texas and primarily based out of Leeville, Louisiana. My company name is Fish Mafia Inc and I'm an owner operator. I longline for Grouper, Tiles and Snapper. I also have another vessel I'm building that will be used for Snapper and Beeliners using bandit gear my deckhand will run that.

I'm aware of the discussion about this Red Snapper re-allocation from the commercial sector to the private sector. I'm 100% against this and I think the Red Snapper distribution should stay the same. This meeting in Key West is right in the middle of most commercial and charter fisherman peak seasons and are unable to attend the meeting. I don't think it's fair to bring this topic up at this meeting when many of us can't be there because we'll be offshore. There is alot going on with different states managing their own Snapper seasons, stock assessments etc to implement a re-allocation of Snapper from the commercial sector to recreational. The recreational sector has no accountability and routinely overfishes the Snapper that they do have.
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6/15/2018 10:34:19Martha Beneducitandm_hall@yahoo.com I have been a boat owner in the Gulf if Mexico since 1987 It is very sad what our government has allowed to happen and has contributed to in the demise of USA commercial fishing . There is no reason ti redistribute American RedSnapper shares to the private sector , When will you ever think of the small sector trying to make a living with all your rules and regs , Leave our shares alone !!!!
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6/15/2018 10:35:19Mark Tryonmdtryon@outlook.comI would urge the council not to revive the Red Snapper reallocation dispute. The last attempt to reallocate snapper from the commercial sector to the recreational sector resulted in failure as a federal judge ordered a reversal of the council decision. Meanwhile no significant underlying facts have changed which would lead one to believe that any similar scheme would produce a different result. Key facts are as follows:

1. The recreational sector despite making some progress remains unaccountable.
2. The commercial sector thru IFQ management is accountable.
3. The recreational sector continues to over fish the resource.

What more can I say.

Time spent replaying this bitter dispute would be better served exploring measures on the recreation side which would improve accountability and flexibility within the sector.
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6/15/2018 10:55:35Paul Reevesrfiseafood@yahoo.com1. I strongly oppose reallocating red snapper from the commercial and charter sectors to the private angler sector.
2. Reallocation should not be discussed at the Key West meeting because most commercial and charter fishermen can't be there.
3. There are too many variables in play to even consider reallocation at this point including state EFPs, state management, and new stock assessments.
4. Giving more allocation to the private angler sector rewards a group that has repeatedly overfished its quota. Commercial and charter stay within their quota. We shouldn't be penalized for this.
5. I make my living fishing,I was given nothing, I have my life’s savings invested. IFQ was sold to the fishermen as stability to the industry. Please stop the madness.
6. Emily please forward this email to the entire Council and staff.
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6/15/2018 14:01:03Paul Loughridge
paul.loughridge@yahoo.com
Yankeetown, FL
Commercial Fisher, Other
My name is Paul Loughridge, Pres. of Loughridge Bros. Seafood co. I am a fish house owner, as well as gulf reef fish fisherman. I own 4 reef fish vessels and am strongly opposed to reallocating ARS to the recreational sector. The rec sector has been overfishing their quota repeatedly, while the com sector has an IFQ plan that works. Also, discussing reallocation in Key West, is a long way from where almost all ARS are landed. That doesn't seem fair and equitable. Please consider the distance com fishermen would have to travel to attend this meeting, which they most likely won't, and that reallocating to a sector (rec) that we have no idea how many anglers, trips, or fish they catch. Your best available science says they have repeatedly overfished their quota.

Thanks,
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6/15/2018 14:02:32Costa Kouzounis
demosautomotive@aol.com
Commercial FisherEver since I was a teenager, I relied on the Red Snapper commercial fishing industry as my summer job and it also helped me purchase my first car: A used 1968 Ford Galaxy. I routinely worked as a deckhand and winder on many different Red Snapper commercial boats. I continue to rely on the Red Snapper commercial fishing industry today as a source of income for my family and hope the commercial fishery is just as viable for my two children as it has been for me. I am still an active fisherman with a reef fish permit and this enables me as a commercial fisherman to supply fresh Gulf Red Snapper to restaurants all over the United States and beyond.

I am strongly opposed to the reallocation of red snapper from the commercial sector to the private angler sector that has continued to over fish their quota for nearly 25 years. Why should they be rewarded when they have over fished their quota for nearly 25 years? Commercial Red Snapper fishermen continue to fish within their quota. This reallocation should not be addressed at the Key West meeting because most of the commercial industry can not attend and thus, we will not be able to express our science based statistics. This reallocation is nothing more than a fish grab by the private sector.
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8/18/2018 9:51:18James Clements
captjmclements@aol.com
Carrabelle FL 32322Commercial Fisher
I strongly oppose reallocating red snapper from the commercial and charter sectors to the private angler sector.Taking commercial quota and gifting it to the private angler sector is unfair to the commercial fishermen that have been working under an accountable management system for the last decade.Giving the private angler sector commercial quota will not solve the problems in that fishery - it will not make private anglers more accountable, it will not improve their reporting, and it will not give them more days to fish.  All it does is hurt commercial fishermen.The Council just dealt with this issue three years ago, after spending nearly 5 years fighting over it.  Why is the Council wasting its time on this issue again?
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8/18/2018 12:37:54Kenneth Burnettfishinfool447@aol.comSanta Fe. Texas 77517Commercial FisherI Strongly oppose reallocating Red Snapper from the commercial and charter sectors to the private angler sector.
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8/18/2018 12:42:01K. P. Burnettfishinfool447@aol.comSanta Fe Texas 77517Commercial Fisher
Taking commercial quota and Gifting it to the private angler sector is unfair to the commercial fisherman that have been working under an accountable management system for the last decade.
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8/18/2018 13:23:50Matthew andrews
restless146464@yahoo.com
32439Commercial Fisher
To whom it may concern
I am the owner and operator of the f/v restless 2 I have commercial fished for over thirty five years . I strongly oppose any type of reallocation especially to those who countine to abuse their own fisheries. We in the commercial sector have become almost completely accountable for our efforts unlike the recreational sector. I think that every man woman and child should have the right to enjoy one of our most precious resources. This reallocation is wrong in so many ways. Please do the right thing thank you. Matthew andrews
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8/18/2018 17:48:56Clarence Seymour Sylboat@aol.com
Ocean Springs,MS 39564
Charter/Headboat For-Hire
1-I strongly oppose reallocating red snapper from the commercial and charter sectors to the private angler sector.
2-Taking commercial quota and gifting it to the private angler sector is unfair to the commercial fishermen that have been working under an accountable management system for the last decade.
3-Giving the private angler sector commercial quota will not solve the problems in that fishery - it will not make private anglers more accountable, it will not improve their reporting, and it will not give them more days to fish. All it does is hurt commercial fishermen.
4-The Council just dealt with this issue three years ago, after spending nearly 5 years fighting over it. Why is the Council wasting its time on this issue again?
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8/18/2018 19:03:28Anthony Manali jrCrabrgrl@gmail.comAnna Maria fla 34216
Charter/Headboat For-Hire, Commercial Fisher
I've been commercially fishing for 48 yrs. Harvesting mullet, stone crab, and grouper, red snapper, ect. Providing the public who own most of the resource,
has always been my passion. The red snapper is one of my two most important landings. Your asking me to give away my portion of what I worked my entire life for and give it to recreational fishermen who are not providing red snapper to the public. I just can't support that. The pressure from the recreational sector is increasing drastically! So much so that there are no 300 hp Yamaha or mercury outboard motors available for nearly the next 12 months, Because they are going on multiple engine recreational boats that are able to reach any snapper grounds. They should have all recreational boats put pingers on everyone's boats and report to NOAA like we
do to better understand how many fish are being caught.
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8/19/2018 17:20:35William Tuckerimnanglerim@msn.comDunedin
Private Recreational Angler, Commercial Fisher, Other
Over the last 25 years, the recreational sector has, consistently, overharvested its red snapper quota in the Gulf of Mexico, effectively raiding the public trust of millions of pounds of red snapper. There has been very little consequence to these violations.

Almost every attempt at the Gulf Council to implement accountability within the recreational sector has been met with strong opposition from the recreational NGO’s, the national sport fishing associations, and their supporters on the Council. This obstructionism has been effective in delaying accountability, and has resulted in consistent overharvesting by the recreational sector.

It used to be that the recreational “conservation” groups actually promoted conservation. But over the last decade, these groups have been co-opted by the sporting goods INDUSTRY, and now, instead of concern for the health of fish stocks, the health of their sponsors’ stock prices are their primary concerns.

The recreational lobby has promoted an entitlement attitude to their constituents, and this drives their crusade for reallocation. The organizations that promote “greater access” for their supporters are, by definition, promoting less access for everyone else.

The sportfishing organizations strive for greater profits for their sponsors, including the boat, motor, and tackle manufacturers. They foster the idea that commercial fishermen are to blame for their short seasons. But the shocking truth is that managers do not know how many recreational fishermen there are, and cannot identify them. This makes the job of equitably allocating a fixed number of fish among this user group, nearly impossible. If the fishery managers are unwilling to identify and count the number of red snapper anglers, then expecting them to count the number of fish caught by these same anglers would seem unlikely.

Taking fish away from the dining consumer, who can only access red snapper by buying it for dinner, and giving his access to the recreational sector to catch for fun and for company profit, is not only unjust, but also irresponsible. Reallocation will not instill a conservation ethic among the recreational sector, but rather, it will reinforce the idea of entitlement, and reward the sector for decades of overfishing its allocation. Instead, we should be training the recreational sector to respect catch limits, and to respect the access of others, with whom they must share the resource.

The recreational sector suffers from overcapitalization. There is more active, and latent, effort in the recreational sector than is necessary to catch their quota. Instead of constraining their effort to conform with the catch limits, this sector strives to seize the access of others, so they can expand their markets, and sell more fishing products, and make more money. Selling more boats and tackle will further overcapitalize the recreational sector, and accelerate the race to catch more fish. This is a dangerous course of action, and would add incentives for overfishing.

Fishery managers should be trying to constrain catches, not explode them. We should be trying to grow our stocks. It would NOT be prudent to gift the recreational sector more fish without first having in place a system to accurately track their catches, their discards, and their participation levels.

The recent foray into States management of the recreational red snapper fishery is barely a year old, and the results are still uncertain. We should not use this confusion as a smoke screen, nor as a springboard for taking red snapper away from the fish eating public.

Staying within a sectors quota is the first step in resource management. Rewarding a track record of recreational overharvest by reallocating quota away from an accountable commercial sector would set a bad precedent, and would reinforce the idea that conservation is an option, not a responsibility.

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8/19/2018 20:14:59Mark Tryonmdtryon82@outlook.comgulf breeze,Fl,32563
Private Recreational Angler, Commercial Fisher
How can we seriously consider reallocation of red snapper to the recreational sector when the sector remains unaccountable? As of today, August 19, 2018, the recreational landings data is still incomplete. The largest component (Florida) has no data submitted per the the 2018 preliminary red snapper landings data table. Reallocation should not be revisited until data collection by the recreational sector achieves real time accuracy on par with the commercial red snapper IFQ program.
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8/19/2018 23:21:38John Rawlings
Bigjakerawlings@gmail.com
Matagorda Tx 77457Commercial Fisher
I strongly oppose reallocating red snapper from the commercial and charter sectors To the private sector Taking commercial quota and gifting it to the private angler sector is unfair to the commercial fisherman that have been working under an accountable management system system for the last decade giving commercial quota to the private sector will not solve the problems in that fishery it will not make the private sector more accountable it will not improve their reporting And it will not give them more days to fish all it does is hurt commercial fisherman The council dealt with this issue five years ago why is the council wasting time on this issue again when are we going to make The private sector accountable for their fishing and their overfishing
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8/20/2018 8:11:27William Cochrane Sr.billyc9501@gmail.comGALVESTON
Private Recreational Angler, Commercial Fisher
Even though I fish recreationally I strongly oppose reallocating red snapper from the commercial and charter sectors to the private angler sector.
Giving the private angler sector commercial quota will not solve the problems in that fishery - it will not make private anglers more accountable, it will not improve their reporting, and it will not give them more days to fish. All it does is hurt commercial fishermen.
The Council just dealt with this issue three years ago. After spending nearly 5 years fighting over it why is the Council wasting its time on this issue again?
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8/20/2018 10:34:04john T Harrisfvsbcf@gmail.comPanama CityCommercial Fisher
I strongly oppose reallocating red snapper from the commercial and charter sectors to private angler sector. Taking commercial quota and gifting it to private angler sector is unfair to the commercial fishermen that have been working under accountable management system for the last decade .
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8/20/2018 15:43:17Michael Miglini m@miglini.com
Corpus Christi, Texas, 78404
Private Recreational Angler, Charter/Headboat For-Hire, Commercial Fisher, Other
Reallocation of red snapper to the private recreational angling sector and away from the commercial and charter for hire sectors was discussed, debated, studied, voted on, and litigated over extensively in the last several years and failed for good cause. It is annoying and concerning that they Gulf Council is again taking up the issue of reallocation instead of putting the resources to work limiting private recreational overharvest.

I oppose reallocation of red snapper away from the charter for hire and commercial sectors to any sector to the private angling sector primarily for the following reasons:

The commercial and charter for hire sectors have worked hard to develop management plans which keep their harvest within their sector allocation. The commercial sector has kept it’s harvest under its allocation for a decade now and the charter for hire sector is harvesting with and it’s allocation and has been doing so for a couple years. The private angling sector has failed to develop management which prevents consistent overharvest. Gifting red snapper to a sector which is not staying within it’s allocation is unfair to those who are. Also, taking allocation of red snapper away from accountable sectors which stay under budget and putting it into a sector which is not accountable and consistently over-budget will only make overharvest of the species worse which is bad fisheries management.

Taking red snapper away from sectors which stay within their allocation and gifting it to the private recreational sector which does not stay within their allocation is not going to solve the problem of the private recreational angling sector consistently going over there allocation. Preventing the private recreational angling sector from going over there allocation will stop the private recreational angling sector from going over there allocation. Realocation will only hurt the commercial and charter for hire sectors and result in worse fishery management.
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8/21/2018 1:54:31paul d Loughridge
paul.loughridge@yahoo.com
CRYSTAL RIVER, FLCommercial Fisher
I strongly oppose reallocating ARS from the commercial sector to the recreational sector. The commercial sector has a management plan that is sustainable, and proven to work, while the rec sector is and will continue to be a complete disaster. It's unfair to reallocate from the comm sector that is accountable, to the rec sector which we have no idea how many fish they catch, how many anglers their are, and how many trips are made each season. Thank you, Paul Loughridge, pres. Loughridge Brothers Seafood Co. Fish house owner, four reef fish vessels that target grouper and ars
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8/21/2018 14:38:29John Zukleyjzukley@Mobileforest.netMobile Al 36612Commercial Fisher
I have to date invested $ 1,750,000.00 in the snapper fishery Boats, Purchased shares, gear and dockage. I am not part of the original group, I have purchased all my Shares on the open market. To take the shares and give them to a recreational guy is a crime. I am opposed to any so called reallocation because a bunch of rich folks want to kill more snapper only to have them rot in the bottom of their freezers.
Thank you
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8/24/2018 9:21:40Anthony ManaliLegmakr@aol.comAnna Maria
Charter/Headboat For-Hire, Commercial Fisher
We don't remotely have a clue on how many fish the recreational sector is catching. They don't have a clue to how much they are catching. They are catching them for themselves and we are catching them for the public. We are the public's access if they choose to have fresh fish, which I feel is somewhat overlooked.
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8/26/2018 17:42:42Marthalee Beneducitandm_hall@yahoo.comHudson,Fl 34667Commercial Fisher
To Whom it may Concern; Since I bought our first reef permit in 1990 I have seen the government take more and more away from the commercial fishing sector. I know recreational brings in more money and I know they have more money to spend on lobbyists and lawyers, but this country was founded on being fair to the working class as well as the privileged. . We have earned our shares by hard work, we have jumped through all the hoops to stay in the fishing industry competing with cheap imports with no restrictions on them and NO tariffs. We have no one protecting us or our jobs. We have to deal with closures which many times don't make sense when we throw back hundreds of a species in closed seasons but obey the laws, notifying you of comings and goings and filling out reports. Please DO NOT take anymore away from us then you already have. This country was founded on the principle of government for the people by the people but that seems to be gone in todays dealings with one of our country's oldest remaining industries. Many countries feel fishing is a valuable resource and protect their commercial fisheries, sadly not in the USA. Please leave the American Red Snapper Fishery alone unless you want to help the fisher person and their families and give us a larger percentage of the snapper fishery.
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9/8/2018 9:28:41Dj woodPapawooddj@gmail.comCommercial Fisher
***Accountability*** I strongly oppose a reallocation! Until the recreational sector is held accountable (actually knowing how much is caught) I do not agree with reallocating from an accountable sector to an unaccountable sector. Leave us out of it. There’s too many private anglers these days catching their imaginary quota too quickly? Figure it out with more imaginary data.
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1/28/2019 13:50:08Eric Brazer
eric@shareholdersalliance.org
NGOhttps://drive.google.com/open?id=1DGfukAQpmq40SMOYcSyJm9AB523TOcnG
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1/30/2019 16:56:22Dylan Hubbard
dhubbard@hubbardsmarina.com
Madeira Beach, FL
Charter/Headboat For-Hire
Hello, my name is Captain Dylan Hubbard and my family business has been fishing central west 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, and my family business alone. I am also a graduate of the marine resource education program and I hold a spot on the reef fish AP.
Allocation of red snapper
Please do not reward sectors for over running their quota. Do not penalize a sector for their under allocation of days and accountability of not over running their quota. In the fed for hire fleet as we move into the ELBs we will only become more accountable and less likely to overrun our ACT so we need smaller and smaller buffers in our sub sector. We do not have an over allocation of quota we have an under allocation of days due to high buffers that are not required in our sub sector.
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3/29/2019 15:03:26Bubba Cochrane
Bubbagoodnews@gmail.com
Galveston TX 77554
Private Recreational Angler, Charter/Headboat For-Hire, Commercial Fisher
There must be a better way to manage the recreational fishery without taking fish away from seafood consumers who deserve equal rights to this resource. Growing the amount of red snapper for both commercial and recreational sides would be more advantageous than trying to take away from one side and give it to another. This should be a collaborative effort not a fight.
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3/29/2019 15:31:14michael jennings
texassportfishing@gmail.com
Freeport Texas 77541
Private Recreational Angler, Charter/Headboat For-Hire
Reallocation of commercial fish to the recreational fishery will not solve the management problems. I would urge the council to take no action on the issue and focus it time on meaningful measures to give us recreational fisherman a better way of staying within our allocation while maximizing access.
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3/29/2019 16:56:34Casey streeter
Casey@floridawatermen.org
Matlacha, FL 33993
Charter/Headboat For-Hire, Commercial Fisher
My name is Casey Streeter. I am a first generation commercial fishermen, a share holder, I own 3 permited boats, one being a multi permitted boat, I am a reef fish whole sale and retailer in SWFL. I am strongly against any reallocation of our fishery to the recreational sector as in amendment 52. The recreational sector has shown no accountability / sustainable in the fishery and shown no steps towards build any type of program to help create sustainability and accountability. Our fishery will be headed for disaster if the stance becomes over catch to get more. If the fishery was looked at alike a credit card it would state - if you use within your limits and pay your balance on time you get more. But if you go over your limit and disregard the rules you get less. I would say until we know the exact number of participants and exact amount of effort into the resource that any type of increase should be off be table. This is an American fishery and every American should have access to the resource but if you look most Americans access this fishery through commercial channels and also from for-hire sectors. The Gulf of Mexico is not owned by the states and private anglers that surround it but all Americans that wish to enjoy part of it responsibly!
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3/29/2019 22:24:08Gary JarvisGJABD@AOL.COMdestin
Private Recreational Angler, Other
Why can't the private boat sector fish within it's own allocation and be happy with it ? The CFH sector does ,the commercial sector does , As a partner in 5 seafood restaurant with 2 or my 3 sons the commercial allocation is not all about the industry of commercial red snapper fishermen but it goes much further. Our customers ( most who are not anglers) rely on that sector for their access to wild caught gulf seafood. Just like a private boat owner who fishes for fun our customers are American citizens who should have the same level of access as a boat.owner. In fact they should have far more allocation than what they have now due to the sheer number of consumers verses the privilege few who can actually afford a boat . So if you want to explore allocation levels how about doing all Gulf reef fish not just snapper and give the majority to the American consumer where it rightly belongs .
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3/30/2019 6:40:33Brian lewisBlewis131@hotmail.comClearwater,fl,33765
Private Recreational Angler, Commercial Fisher
Dear Council Members ,

Please remember the Objectives of the Fishery Management Plan for Reef Fish Resources in the Gulf of Mexico,



Objectives of the Fishery Management Plan for Reef Fish Resources in the Gulf of Mexico.

1. To prevent overfishing and rebuild overfished stocks.
2. To achieve robust fishery reporting and data collection systems across all sectors for monitoring the reef fish fishery which minimizes management uncertainty.
3. To conserve and protect reef fish habitat.
4. To minimize conflicts between user groups.
5. To minimize and reduce dead discards.
6. To manage Gulf stocks at OY as defined in MSA.
7. To revise the definitions of the fishery management unit and fishery to reflect the current species composition of the reef fish fishery.
8. To encourage and periodically review research on the efficacy of artificial reefs for management purposes.
9. To promote stability in the fishery by allowing for enhanced fisher flexibility and increasing fishing opportunities to the extent practicable.
10. To avoid to the extent practicable the "derby" type fishing season.
11. To provide for cost-effective and enforceable management of the fishery.
12. To promote and maintain accountability in the reef fish fishery.

I think that this says a lot in itself when your considering reallocation
Please keep all user groups in mind to minimize conflict between user groups.
Ie. Fish tags are a good way to minimize conflicts and to promote conservation and Data collection .
Reduction in mortality and discards for all user groups need to be addressed before considering reallocating quota .
Please keep the eastern gulf commercial fishers in mind for some much needed help in acquiring access to quota ,ie.quota bank ,auctions , multi use of grouper allocations .
Thanks for your consideration
Regards
Brian lewis
F/V Trip limit
556461
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3/30/2019 7:00:16Brian lewisBlewis131@hotmail.comClearwater,fl,33765
Private Recreational Angler, Commercial Fisher
Dear Council Members ,

Please remember the Objectives of the Fishery Management Plan for Reef Fish Resources in the Gulf of Mexico,



Objectives of the Fishery Management Plan for Reef Fish Resources in the Gulf of Mexico.

1. To prevent overfishing and rebuild overfished stocks.
2. To achieve robust fishery reporting and data collection systems across all sectors for monitoring the reef fish fishery which minimizes management uncertainty.
3. To conserve and protect reef fish habitat.
4. To minimize conflicts between user groups.
5. To minimize and reduce dead discards.
6. To manage Gulf stocks at OY as defined in MSA.
7. To revise the definitions of the fishery management unit and fishery to reflect the current species composition of the reef fish fishery.
8. To encourage and periodically review research on the efficacy of artificial reefs for management purposes.
9. To promote stability in the fishery by allowing for enhanced fisher flexibility and increasing fishing opportunities to the extent practicable.
10. To avoid to the extent practicable the "derby" type fishing season.
11. To provide for cost-effective and enforceable management of the fishery.
12. To promote and maintain accountability in the reef fish fishery.

I think that this says a lot in itself when your considering reallocation
Please keep all user groups in mind to minimize conflict between user groups.
Ie. Fish tags are a good way to minimize conflicts and to promote conservation and Data collection .
Reduction in mortality and discards for all user groups need to be addressed before considering reallocating quota .
Please keep the eastern gulf commercial fishers in mind for some much needed help in acquiring access to quota ,ie.quota bank ,auctions , multi use of grouper allocations .
Thanks for your consideration
Regards
Brian lewis
F/V Trip limit
556461
40
4/1/2019 6:26:59William Cochrane, Sr.billyc9501@gmail.comGALVESTON
Private Recreational Angler, Commercial Fisher
As a commercial AND recreational fisherman, please do not consider passing Amendment 52.
It is simply not fair.
The commercial fisherman were given the opportunity to vote on and approved by their vote the present IFQ system.
Many commercial fishermen, like myself, were forced to mortgage everything they had to stay in the fishery and make a living.
Before IFQ’s were implemented the red snapper fishery was going down hill very fast.
Since 2007, when the IFQ started, the red snapper fishery has grown by leaps and bounds.
Now, Amendment 52 is suggested to punish these fishermen by taking their fish away?
And, not only taking it away, but gifting their fish to the recreational sector that has overfished their sector for years.
The CCA is backing this amendment. Why? CCA stands for “Coastal Conservation Association”. This amendment it not about anything “Coastal”, and it sure as heck is not about “Conservation”. It is all about getting more days for recreational fishermen to “KILL”- MORE RED SNAPPER.
Thank You.
Bill Cochrane Sr.
Galveston, TX
41
4/1/2019 10:38:30Eric Brazer
eric@shareholdersalliance.org
NGOhttps://drive.google.com/open?id=1FWjhyQaxCleOmK1aEwY7vzRnMldHqsuD
42
4/1/2019 10:52:52Mark Tryonmdtryon82@outlook.comGulf Breeze,Fl,32563
Private Recreational Angler, Commercial Fisher
This council is spending a disproportionate amount of time attempting to reallocate red snapper from the commercial sector to the recreational sector. As such other more important issues such as problems with the red grouper fishery are not being given the attention they deserve.

There are numerous reasons other than finite council resources which would lead a logical person to not pursue reallocation at this time.

1. Despite limited progress the recreational sector remains unaccountable due to lack of real time data collection methods.

2. Historical data as evidenced by the landings data provided in this amendment illustrate a track record of overfishing and unaccountability within the recreational sector. Reallocation would in effect reward overfishing.

3. At present there are serious issues in respect to meeting objectives of the fishery management plan for reef fish resources in the gulf of mexico. Most notable deficiencies relate to protecting the resource/accountability. Clearly reallocation to an unaccountable sector is incompatible with such goals.

In closing there is a table illustrating days of fishing available in the red snapper fishery. The commercial sector boasts 365 days while the recreational is significantly less. This data is misleading as nobody fishes 365 days a year in the commercial fishery. In 2018 I made 38 day trips. Hopefully in the future , state management and modern technology will allow the recreational sector to offer increased flexibility and the potential for access to the fishery throughout the year. That is where time and resources would be more wisely spent.
43
4/1/2019 11:01:36Capt Greg BallGregisfishing@gmail.comGalveston, TX, 77551
Private Recreational Angler, Charter/Headboat For-Hire
As a longtime CFH business owner/ operator I strongly oppose reallocating quota from the commercial sector and CFH sub sector to the private angler sub sector.

Reallocation is unfair, it penalizes fisherman and does nothing for conservation.

The recreational sector has exceeded its quota for many many years and should not be rewarded for doing so. The Council needs to continue its focus on growing the pie and leave the size of the slices the way they are.

Capt. Greg Ball
F/V Wave Dancer
President GPBA
44
4/1/2019 14:55:32Buddy Guindon
katiesseafoodmarkettx@gmail.com
https://drive.google.com/open?id=1KHhARD-a3AcW_6Qz_T_vnBWe1gkmu6y4
45
4/1/2019 17:00:23Larry Huntleylbhuntley@aol.comPensacola, FL 32526Commercial Fisher
- Ninty seven percent of Americans don’t fish, 83% of Floridians don’t fish
- Fish resources in federal waters, managed by NMFS, belong to all Americans
- The only access the vast majority of Americans have to fresh caught seafood is through the commercial fisherman
- Joe Patti’s Seafood Company in Pensacola is open 12 hours a day, 7 days a week serving the non fishing public and their only legal way to obtain fish is through the commercial fisherman
- Suggestion: create an amendment giving the 97% of non fishing Americans more access to their seafood I.e., increase the quotas for the commercial fisherman. Don’t take more away from the seafood eating, non fishing public

Thanks
Larry Huntley
F/V Barbara K
Pensacola
46
4/1/2019 18:00:06steve maiselmaiseltown@live.compalm harbor,fl 34683
Private Recreational Angler, Commercial Fisher
DO NOT REALLOCATE !!! No one should be rewarded for over fishing !!
47
4/1/2019 18:07:14Billy Archerbigtrig42@aol.comPanama City fl 32408
Charter/Headboat For-Hire, Commercial Fisher
Dear Council Members once again we in 2 of the Gulf's of Mexico most accountable fisheries hear that your have proposed a new amendment 52. Reallocation of red snapper to the purely private sector is just plain wrong and I strongly oppose this amendment. I have to ask you why your picking this fight? The Council just went through this a couple of years ago and failed badly through the court system why again now? I also have to ask why is the Council wanting to reward a sector of this important and valuable fishery to a group that has consistently overfished its portion of the quota almost every year in the last quarter of a century by huge margins? As a 3'd generation fisherman I can't support intentionally hurting or punishing one group of fisherman as an excuse to help another. Is this the Councils intent or goal to punish and hurt the men and women that have sacrificed with their families to rebuild the red snapper fishery? How does amendment 52 promote conservation? Giving more fish to a unaccountable sector that has refused to consider any attempt to become accountable is like giving a spoiled child more candy just because they say "they deserve it"? I would ask this Council to please focus on doing things that support this fishery in a sustainable healthy way. Many of us experienced the near collapse and worked with and through the Council process that brought red snapper back from the brink of collapse a super success story in fisheries management that this Council and fisherman can be proud of. That being said please keep in mind reallocation is unfair and penalizes the very fisherman like myself that survived the dark years of quota cuts and short seasons only to have the Council gift the purely recreational sector more fish to what means? Let the state run EFP do there job and watch and see what the answers the purely rec's can provide the Council with for solutions to there problems other than taking fish from accountable fisherman and giving them to unaccountable ones. Makes zero sense to me this amendment 52? Thank you for your time and consideration to my comments.

Capt. Billy Archer
F/V Seminole Wind
Panama City Fl
48
4/2/2019 11:43:14Shane Cantrell
shane.cantrell@icloud.com
Galveston Texas, 77550
Private Recreational Angler, Charter/Headboat For-Hire, Commercial Fisher, NGO, Other
As reallocation is again being considered by the Gulf Council, some important issues should be addressed before moving forward.

The council has indicated a will to reallocate but with no clear goal or legitimate objective for pursuing this obviously contentious issue.

As a commercial fisherman and business owner, this reallocation attempt threaten to destabilize my business for no apprent gain to any segment of the fishery. More allocation to the recreational fishery does not equate to more fishing days to the season, nor does it increase the angling experience in the recreational fishery.

In the process of rebuilding the red snapper fishery, reallocation has no benefit to the conservation of the resource. There is no efficient mechanism to ensure the quota reallocated would be managed within the ACL or ACT.

The council is squandering millions of dollars pandering to the recreational industry to reallocate while failing to meet the needs of all fishermen in the process. This push to reallocate is blinding the council from meaningful progress in other species and issues of more importance as well.
49
4/4/2019 10:50:13Lawrence Marinolmarino@oatsmarino.comLafayette, LAOther
Good afternoon. My name is Lawrence Marino, and I am here on behalf of Louisiana Attorney General Jeff Landry.
As to allocation review, now is the time to flesh out what allocation review will be, and what will result and under what circumstances. It is important to do this now not only to be prepared when it is necessary, but also to allow the discussions to be had in the abstract and as to multiple species, rather than in the heat of particular facts. The standards should be as objective, determinable, and well-defined as possible. The Reef Fish Committee moved to request this process to be begun, and Attorney General Landry fully supports doing so.
50
4/13/2019 9:09:11Donna Brooksbrooksgang3@yahoo.comLecantoCommercial Fisher
Why is this an ongoing issue? How does reallocation promote conservation ? Move forward addressing demand for seafood and bycatch issues. This can only be achieved by increase to commercial sector. Supply and demand! The price of leasing allocation will go down when we receive the increase The council should be focusing on the success of growing the pie rather then fighting over the slices.
51
6/3/2019 11:51:09Eric Brazer
eric@shareholdersalliance.org
NGOhttps://drive.google.com/open?id=1WgElbYCOBXFLUMtMde19CCQ0VgJv8RAr
52
6/7/2019 18:05:40D W MacMahon
uwheadhunter@verizon.net
Spring Hill FL 34610Commercial Fisher CCA really stands for "Coveting Commercial Allocation"
53
6/12/2019 13:44:38Nicholas PatzigPmsbigred1@yahoo.com
Fort Walton Beach, Florida 32548-5039
Commercial Fisher
I have been in the commercial fishing business since 1966, in 1990 we fishermen were required to have permits. At first the permits were free and then the government began charging for them. We older fishermen tolerated all the government changes as they came. We earned our quotas, complying with regualtions, fighting weather, and competition. Maintained our business which are assets, just as our quotas are business assets. What we do with those assets is our business. If there are any changes in our assets we will act accordingly. I can see many lawsuits coming. Changing the horse in the middle of the stream is never a good idea. The new fishermen like all new business men can never expect to be given a business asset just because they want it. Everyone must earn their business. Loans from mommy and daddy, lease with the option to buy work on a fishing boat for 20 years as i saved my money to buy my first boat. Operating fishing vessels, deck handing learning the business, learning the gear, fishing grounds, the weather, the moon phase, the fish movements, building private artificial reefs, etc. These and many other adversities we tolerated to get to were we are today. The quota we have is well earned and should never be considered to be confiscated and redistributed. Business decisions and retirements planned. The fishermen who started this whole thing should be given top priority. Much like we military veterans. Amendment 36b should be Alt 1 No Action, because any other alternative is confiscation. When it comes to the quota accounts not initiated. That quota should be distributed equally. 2.2 alternative 2, I’m quite sure, we earned it. Even if we sell our reef fish permits and decide to king mackerel fish and lease our quota. That is our quota and a business asset. That is the least we should expect for 40 years of work. Nicholas Patzig
54
6/27/2019 15:23:17Clyde/JoAnn Daughtryjdaughtry9@aol.comSopchoppy, FL 32358Commercial Fisher
When the red snapper quota system came into effect, red snapper in the extreme eastern Gulf of Mexico were bycatch rather than the predominant fish on the reef. However, things over the years have changed. Now everywhere you go, the snapper have taken over and chased the grouper away. We throw back enormous amounts of snapper and enormous snapper themselves. We have very limited red snapper quota along with many others in our area. It is difficult to locate quota for leasing and, if you do, you have to pay as much as $4.50 per pound. In order to help fishermen who have little or no quota, please review the following proposal:

Each eligible person could purchase up to 6,000 lbs. during the year. If you have less than 3,000 pounds allocated at the beginning of each year, you would qualify for this program.

If you choose to participate, a check would be done to see if you transferred any quota to anyone else. If you did, you would not qualify to participate.

You would need to utilize all of your quota before requesting to participate. So, if a person started with 3,000, they would only be eligible to request 3,000 additional pounds after utilizing their initial quota amount.

At this point, you could log in to a designated website and request 300 lbs per trip at $2.50 per pound paying with a credit card.

A previous landings check would need to be done to verify the amount used before another request could be filled. If you went over this amount and again requested to participate, whatever overage you had would be deducted from the next trip. If you went under, then the person would only request whatever amount would bring them up to 300 lbs.

There are always ways fishermen can come up with ways to “play” the system. Some fishermen might make day trips to target snapper and quickly exhaust their limit. The purpose of the program would be to give fishermen the opportunity for bycatch without having to throw back large amounts of snapper. In a perfect situation, it would allow fishermen about 300 pounds per trip about 20 trips per year.

We have no idea how many people would qualify but, a person with no quota who requested 6,000 lbs at $2.50 per pound, would be putting $15,000 into the program. I’m sure you would have enough participants to ensure the cost of paying a computer programmer to design the program. We’re sure it would be beneficial to many fishermen in our area.

Clyde and JoAnn Daughtry
43 Christy Lane
Sopchoppy, FL 32358
55
6/13/18David Walker
david@walkerbusiness.com
Floridahttps://drive.google.com/open?id=1SA7rrUiTxFAbtV06IPCBUCBPbBPJezLU
56
6/17/18Abby Webster
captainabbywebster@gmail.com
NGOOn behalf of The Charter Fishermen's Association {CFA), 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, FL this week.
We recommend the Gulf Council refrain from any action on The Red Snapper Allocation Scoping Document.

The States are in their first year of their respective Exempted Fishing Permits {EFP's). Addressing reallocation now would disrupt the EFP's. Let the plans such as the EFP's run their course and make changes based on the results provided.

Initiating this scoping document during charter season prevents most charter fishermen from attending this
Council meeting because they're fishing everyday they can.


There are too many variables in play right now that could impact reallocation (41, 42, EFPs, Congressional Bills, development of State Management Amendment). The EFP's need to be given a chance before reallocation is explored.

A purpose and need must be established before any action can take place(reallocation).
57
6/15/18John Andersonja5081956@gmail.comPanama City, FLI would like to request that the Gulf Council protect the red snapper quota for the commercial and recreational for hire sector. Without the commercial fisherman quota and the for hire recreational quota the non boat owning public will LOSE their access to this natural resource. Please protect the public s right to enjoy this natural resource!
58
6/15/18Demo Kouzounistrekka46@gmail.comCommercial FisherI am a commercial fisherman and I take my job very seriously. Not only is it my livelihood, but it gives me great satisfaction in knowing that I'm supplying fresh red snapper to vendors and customers. I have always stayed within my fishing quotas. Now my livelihood is at stake and this is due to the private sector wanting to take it away those quotas from the commercial fisherman.

Please reconsider the decision for the reallocation of red snapper from the commercial sector to the private sector. Jobs are at stake! Are you willing to destroy the commercial industry to appease recreational fisherman? Decisions concerning this reallocation should not be decided upon until all parties involved can be equally represented to discuss the issue. Not just one side only giving their input.
59
6/15/18Yonni Kouzounisdemos@sbcglobal.netCommercial FisherCommercial Red Snapper fishing has been a part of my family for a very long time. It has been a source of income for me and my family. Ever since my father introduced fishing to me, its been a passion of mine. It has been important that my family supply local restaurants with fresh Red Snapper. We have always taken our role in the commercial fishing industry as an important one -- staying within our quotas and conservation.

I am strongly opposed to the reallocation of red snapper from the commercial sector to the private angler sector. Commercial Red Snapper fishermen continue to fish within their quotas while the private sector has consistently over fished these waters. As most of the commercial fisherman from various regions cannot make the Key West meeting - no decisions should be made concerning Red Snapper reallocation until there can be adequate representation from the commercial industry. We ask that you take this into consideration and not penalize the commercial fishing industry.
60
6/15/18Demo Kouzounis, Jr. lepunte@aol.comCommercial FisherCommercial Red Snapper fishing is very important to me and my family. It is a source of income for us. Our role as part of the commercial red snapper fishing industry has always been about conservation and quotas. Now that is being threatened by the reallocation of red snapper to the private fisherman sector. While we stay within our quotas, the private sector has consistently over fished.

The reallocation of red snapper from the commercial sector to the private angler sector is a disastrous and dangerous decision. Commercial fishing jobs are at risk! We depend financially on fishing. Conservation is also at risk, as over fishing from the private angler sector could have a severe consequences to the commercial fishing industry. Extending recreational fishing season is not the answer. Private anglers will almost certainly exceed their quotas. Please consider hearing the voices of many in the commercial industry and reconsider the reallocation of red snapper.
61
6/15/18Donna Tryonmdtryon@outlook.comGulf Breeze, FLCommercial FisherReallocation of red snapper from the recreational sector to the commercial sector should not be considered until such time that recreational accountability equals that of the IFQ program. In the interim the council should consider the possibility of reallocation of snapper from the recreational sector to the commercial sector until it is proven that chronic overfishing by the recreational sector has ceased.
62
6/15/18J Daughtryjdaughtry9@aol.comI strongly oppose reallocating red snapper from the commercial and charter sectors to the private angler sector.
63
6/16/18Brian Lewisblewis131@hotmail.comClearwater, FLDear Emily,

I strongly oppose reallocating red snapper from the commercial and charter sectors to the private angler sector.
1.
1. Reallocation should not be discussed at the Key West meeting because most commercial and charter fishermen can't be there.
2. There are too many variables in play to even consider reallocation at this point including state EFPs, state management, and new stock assessments.
3. Giving more allocation to the private angler sector rewards a group that has repeatedly overfished its quota. Commercial and charter stay within their quota. We shouldn't be penalized for this .
4. We have been very patient working to rebuild this valuable fishery as a commercial fishery we still have not concluded by-catch issues for the eastern gulf/grouper fishery which has been brought up in the 5 year review .
5. Allocations must be fair and equitable , I ask how is this fair or equitable taking away from our sectors and awarding the sector that has continually had quota overruns.
6. The data collection is improving but still has a long way to go and the council must continue to make data collection a top priority before even considering this amendment .
7. Opinion : I have never been contacted to ask what fish I have landed in 33 years of fishing in the gulf ,with that said what is the private angler actually catching ? My answer: The lord only knows !
Respectfully submitted ,
Brian Lewis
F/V Trip limit 556981
Clearwater, FL 33767
727-423-6950

Emily please forward this to all of the council members emails
64
6/16/18Ken Haddadkhaddad50@gmail.comI am emailing you because ASA cannot attend the Council meeting in Key West. We want to make sure you know our positions on 3 specific agenda items.
Red Snapper Allocation: We ask that the Council continue forward on this scoping document. There is a clear need and there is substantial support to effectively review red snapper allocation and make changes as warranted. We strongly support integrating the most current NOAA policies and directives into the consideration of allocation. Specifically the Scoping Document states the following and we ask that these directives be directly considered in the progress of the document: Two NMFS Directives, Policy Directive 01-119-01 and Procedural Directive 01-119-02, provide relevant information for allocation review. As stated in the Policy Directive, an allocation review should consider FMP objectives along with other relevant factors that have changed and may be important to the fisheries allocation. Relevant factors are described in the Procedural Directive and included ecological factors, economic factors, social factors, and indicators of performance and change. Indicators of performance and change, for instance, encompasses catch/landing trends, stock status, species distribution, and information quality. If the Council determines that the FMP objectives are not up-to-date, then the Council should discuss, evaluate, and if necessary, revise the objectives.
65
6/17/18
Captain William "Tres" Atkins
tresatkins@sbcglobal.netI am reaching out to you in the hopes that you can pass my message on to as many Gulf Council members as possible.

First of all, I strongly oppose reallocating red snapper from the commercial and charter sectors to the private angler sector.

Secondly, I do not think that reallocation should even be discussed at the Key West meeting. Most commercial and charter fishermen can't make that meeting. It is just too far and we are in the middle of our busy season.

Furthermore, there are just too many things in play to even consider reallocation at this point. We have the state EFPs, state management, and new stock assessments to consider just to name a few.

Lastly, I feel that giving more allocation to the private angler sector rewards a group that has repeatedly overfished its quota. Commercial and charter stay within their quota and therefore we shouldn't be penalized for this.

I appreciate your assistance in getting this out to the Council.
66
6/17/18Capt Mike Thierrycapthierry@aol.com
Dauphin Island, AL 36528
• Hi,
• I strongly oppose any reallocation of red snapper from the charter and commercial sectors to the private angler sector.
• They have repeatedly gone over their quota and the commercial and charter boats have been good stewards of
• the resource and have stayed within their quota. We should not be penalized for that.
• The reallocation should not be discussed at the Key West meeting because most charter fishermen and commercial fishermen
• are fishing right now as it is the heart of our season. I don't think very many charter fishermen or commercial fishermen will be able to attend.
• I don't think this is the right time to bring this up because there are too many variables like state EFPs, state management and the new stock assessments. Let's finish these issues first. Please forward this email to everyone on the Council and the entire staff.
Thank you for your prompt attention to this urgent matter.
67
6/17/18Bill Cochrane Sr.billyc9501@gmail.comGalveston, TX 77554I strongly oppose reallocating red snapper between the recreational sector and charter/commercial sectors.
Please forward this email letter to the Gulf Council, staff and anyone with common sense.
I find it hard to believe that reallocation is even being considered.
Both the Charter and commercial sectors have agreed to be monitored and have a mandatory 100% accountability system. And this is the thanks we get? Seriously?
Soon after the IFQ system was started, the snapper fishery started to come back. Now with the commercial and charter sector's help, the fishery is at an all-time sustainable high.
And now our payback is taking our snapper away and giving it to a sector that has very little accountability, and zero mandatory reporting?
The charter and commercial sectors are going to be punished for doing the right thing?
Please consider dropping reallocation of any kind. It's absurd.
The Gulf Council might also want to consider this:
The Gulf of Mexico Red Snapper fishery is not about how many days the boat owning fisherman can fish for snapper. It is not about what the CCA and their high-dollar lobbyists want for their members as far as snapper fishing seasons. It's not about what Yamaha Motors wants so they can sell more outboard motors.
It's about the fish.
Worth repeating: It's About The Fish!
68
6/17/18Pickett
pickett11@tampabay.rr.com
I oppose reallocation because stealing from the commercial sector to appease the recreational sector is not only wrong but giving more quota to a sector that already overfishes and is ever growing in numbers if you gave them all the quota they would still have little fishing time in the near future
69
6/15/18Eric Brazer
eric@shareholdersalliance.org
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 Key West, Florida this week.

Reallocation.
We strongly recommend that the Gulf Council defer any action on this disruptive, divisive, and
controversial topic.

It is premature for the Council to consider reallocation options at this time. National Marine Fisheries Service’s (NMFS’s) own procedural directive1 makes clear that “the identification of purpose and need for an action and the development of action alternatives (reallocation) should occur in response to allocation review findings that a re-allocation is warranted.”

Therefore, the Gulf Council must first determine:
1. whether an allocation review is warranted, and only then
2. conduct an allocation review to determine if Fishery Management Plan (FMP) goals/objectives are not being met, or if relevant factors have changed that impact allocations.2

Neither of these steps have occurred.

First, we have seen no triggering event that determines that an allocation review is warranted. NMFS’s Procedural Directive 01-119-01 identifies “three approaches to triggering allocation reviews,” namely 1) public interest-based triggers; 2) time-based triggers; and 3) indicator-based triggers. The draft Scoping Document does not reference which of these triggers is the cause for an allocation review. The Scoping Document contains no indication that FMP objectives are not being met, that optimum yield (OY) is not being achieved, or that public testimony warrants a reallocation review, and the Gulf Council already reconsidered red snapper allocations as recently as 2015.

The Gulf Council also needs to examine additional information to conclude whether an allocation review is warranted. In particular, the “original record of a council decision [on allocation] should therefore be closely examined and thoroughly understood by a council considering an allocation review.”3

Regional Fishery Management Councils should also “carefully consider the scope of decision elements that comprise the ‘allocation’ for which a review is being considered” or risk “misguided conclusions regarding the need to review an allocation.”4 Accordingly, the Gulf Council should examine the real or de facto “allocation” between the sectors that has resulted from management failures over the past several decades. See, e.g., Scoping Document, Table 1.1.1. (showing repeated, massive overages in the recreational sector going back 22 years).

Second, even if an allocation review is properly triggered, what factors should the Gulf Council consider when conducting an allocation review?

An allocation “review” is “the evaluation that leads to the decision of whether or not the development and analysis of alternative allocations is warranted, and is not, in and of itself, an implicit trigger to consider alternative allocation[s].”5

The Gulf Council must therefore undertake an evaluation of a number of factors, including but not limited to:
• Are FMP goals/objectives not being met? Which ones are/are not?
• Do FMP goals/objectives need updating?
• What factors have changed that would impact allocations?
o E.g., Amendment 40 showed that the problem with catch accountability lies solely within the private angler component of the recreational sector.
• What are the needs of all three sectors (commercial, charter/for-hire, private angler)?
• What ecological, economic, and social factors and other performance indicators are relevant to an allocation review?

The Gulf Council needs to solicit public input on all of these issues. It is premature to consider allocation alternatives at this time without undertaking the comprehensive and detailed process set forth in NMFS’s policy directives.
70
6/19/18Christine Helmscehlers12@aol.com -I strongly oppose reallocating red snapper from the commercial and charter sectors to the private angler sector.
-Reallocation should not be discussed at the Key West meeting because most commercial and charter fishermen can't be there. This involves our livelihood and we should be represented.
-There are too many variables in play to even consider reallocation at this point including state EFPs, state management, and new stock assessments.
-Giving more allocation to the private angler sector rewards a group that has repeatedly overfished its quota. Commercial and charter stay within their quota. We shouldn't be penalized for this.
Emily, please forward this to the entire council and staff. Thank you for your consideration in this matter,
71
6/19/18Brian Helmsbrianh19035@icloud.com-I strongly oppose reallocating red snapper from the commercial and charter sectors to the private angler sector.
-Reallocation should not be discussed at the Key West meeting because most commercial and charter fishermen can't be there. This involves our livelihood and we should be represented.
-There are too many variables in play to even consider reallocation at this point including state EFPs, state management, and new stock assessments.
-Giving more allocation to the private angler sector rewards a group that has repeatedly overfished its quota. Commercial and charter stay within their quota. We shouldn't be penalized for this.
Emily, please forward this to the entire council and staff. Thank you for your consideration in this matter,
72
6/17/18Lewis T. Bessingerdolphinfish@aol.comGalveston, TX 77551https://drive.google.com/open?id=195jXqK_mPSIflT4ZLSg2vncxxEhNTyxL
73
6/19/18Frank Chivas
frank@baystarrestaurantgroup.com
Indian Shores, FLhttps://drive.google.com/open?id=1bQglvY0SB6_LzGBbWDizgBEwNOjpmPWF
74
6/19/18Billy Archerbigtrig42@aol.comHi Emily please ask the council to oppose any effort to reallocate red snapper from the commercial and or charter fore hire sectors to the private anglers sector. Reallocation should not be discussed at the Key West meeting because most commercial and charter fisherman can't be there. To much at stake here and the timing couldn't be worse for those of us with the most to lose. Why reward a private Rec sector that has over fished continually for the last several years. Please forward this to all council members.
Thank you
75
6/22/18Jamee Lowry
perdidojamee@gmail.com
Strongly oppose redistribution of snapper to private sector
76
8/20/18Mississippi Commercial Fisheries UnitedMSCFUwebs@gmail.comMSCommercial MSCFU contends that the Red Snapper reallocation discussion be postponed until after the completion of the experimental EFP’s for recreational red snapper fishing. The Gulf Council should carefully consider the accuracy and validity of electronically reported fishery dependant data. Trends in abuses of electronic reporting should also be investigated thoroughly. Red Snapper reallocation away from the commercial sector will have a vast adverse economic impact on the entire seafood supply chain. Therefore, a comprehensive analysis of the adverse impacts of shifting red snapper allocations from the commercial sector to the recreational sector should be conducted by a qualified economist that considers the entire seafood supply chain that will be affected.
77
8/20/18Mike Miglinim@miglini.comTXReallocation of red snapper to the private recreational angling sector and away from the commercial and charter for hire sectors was discussed, debated, studied, voted on, and litigated over extensively in the last several years and failed for good cause. It is annoying and concerning that they Gulf Council is again taking up the issue of reallocation instead of putting the resources to work limiting private recreational overharvest.

I oppose reallocation of red snapper away from the charter for hire and commercial sectors to the private angling sector primarily for the following reasons:

The commercial and charter for hire sectors have worked hard to develop management plans which keep their harvest within their sector allocation. The commercial sector has kept it’s harvest under its allocation for a decade now and the charter for hire sector is harvesting with and it’s allocation and has been doing so for a couple years. The private angling sector has failed to develop management which prevents consistent overharvest. Gifting red snapper to a sector which is not staying within it’s allocation is unfair to those who are. Also, taking allocation of red snapper away from accountable sectors which stay under budget and putting it into a sector which is consistently over-budget will only make overharvest of the species worse which is worse fisheries management not better.

Taking red snapper away from sectors which stay within their allocation and gifting it to the private recreational sector which does not stay within their allocation is not going to solve the problem of the private recreational angling sector consistently going over there allocation. Only preventing the private recreational angling sector from going over there allocation will stop the private recreational angling sector from going over there allocation.

Reallocation will only hurt the commercial and charter for hire sectors and result in worse fishery management.
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10/19/18Eric Brazer
eric@shareholdersalliance.org
NGOOn behalf of the Gulf of Mexico Reef Fish Shareholders’ Alliance (Shareholders’ Alliance), we would like to extend our congratulations to you as the new Chair of the Gulf of Mexico Fishery Management Council (Gulf Council) and to Mr. Dale Diaz in his new role as Vice Chair. The experience each of you brings to the Gulf Council is invaluable and we look forward to working with you in these new leadership roles.

Please accept our comments on the following issues to be discussed at the Gulf Council meeting in Mobile, Alabama next week.
While we still feel that it is premature to consider any reallocation of red snapper, we appreciate that the Gulf Council is following the directive from National Oceanic and Atmospheric Administration (NOAA) to create an allocation policy and develop triggers for allocation review by August 2019.6 It is still unclear if the Gulf Council has formalized an allocation policy and, if so, when that will be implemented. Reallocation is highly contentious and creates uncertainty in the fishery for all sectors and continuing this debate will be disruptive to the Gulf Council and divert resources from other fisheries that may need attention. Additionally, we would like to remind the Gulf Council that the last iteration of reallocation ended only three years ago and was ultimately vacated in court. The Gulf Council must to develop allocation review triggers for all mix-use species before continuing the discussion of reallocating red snapper in order to meet NOAA’s directive by the August 2019 deadline.

In the case of red snapper, not only have triggers for an allocation review not been identified for this FMP, no trigger has been identified to justify reviewing red snapper allocations. National Marine Fisheries Service’s (NMFS) Procedural Directive 01-119-01 identifies “three approaches to triggering allocation reviews,” namely
1) public interest-based triggers; 2) time-based triggers; and 3) indicator-based triggers.7 The draft Scoping Document does not reference which of these triggers is the cause for an allocation review, how that trigger was identified, by whom and when. Additionally, an allocation “review” is “the evaluation that leads to the decision of whether or not the development and analysis of alternative allocations is warranted, and is not, in and of itself, an implicit trigger to consider alternative allocation[s].”8 It appears as though the current allocation review is being used as this implicit trigger, instead of following the pathway directed by NOAA for this process: identify the trigger(s) for initiating allocation review, determine if the trigger(s) have been met, initiate review of allocation, then determine if reallocation is warranted.

Furthermore, the timing is not right for a reallocation battle because the Gulf Council is also developing several amendments that could drastically change the management of red snapper (Amendment 50, Amendment 36B), and there are multiple new data streams about recreational landings whose complicated and confusing implications must be fully understood before discussing reallocation.
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