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|10/2/2017 10:10:31||Eric Brazer|
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 Biloxi, Mississippi next week.
Options Paper – Framework Acton to Require either Descending Devices or Venting Tools on board Vessels Possessing Reef Fish.
The Shareholders’ Alliance welcomes the opportunity to discuss discards and discard mortality of reef fish species. Consistent with our previous public comments, we continue to encourage fishery practices and management tools that minimize (or eliminate) discards and discard mortality.
We note that Table 2.1.1 on page 4 of the Options Paper cites SEDAR 31 recreational discard mortality assumptions at 10% with venting and at 20% without venting.
In 2015, the National Marine Fisheries Service (NMFS) ran a projection to determine the impacts to the red snapper stock in the Eastern Gulf resulting from reallocation under Amendment 28. Upon reviewing this projection, the Gulf Council’s Science and Statistical Committee (SSC) concluded that the spawning potential ratio (SPR) “in the western Gulf continues to increase, but the SPR in the eastern Gulf declines, and the decline is exacerbated by increasing allocation to the recreational sector.”1 In particular, NMFS’s projection assumed, among other things, that recreational discard mortality would be 10% going forward, a figure derived from use of venting tools that are no longer required.2 Without venting, recreational discard mortality is estimated to be 21%.3 In fact, 38 of 66 studies relied upon for assessment purposes concluded that recreational discard mortality is greater than 21%. The commercial sector commissioned former Southeast Fisheries Science Center (SEFSC) staff scientist
Jakob Tetzlaff to undertake further projections to help quantify the potential impacts of reallocation
based on alternative assumptions about recreational selectivity and discard mortality. His findings were
troubling, even without considering the effects of reallocation.
One conclusion that Mr. Tetzlaff came to was that “the Eastern Gulf stock is extremely sensitive to
higher levels of discard mortality” and that if recreational discard mortality is assumed to be 21% (as
observed without venting), “the Eastern Gulf stock is eventually fished to extinction when following the
yield streams from the SEDAR 31 base model.” The SSC has not previously reviewed Mr. Tetzlaff’s projections (which were all run using the stock
assessment model from SEDAR 31). Particularly given recent events, the Gulf Council would benefit
from the SSC’s assessment of Mr. Tetzlaff’s projections.
The Gulf Council is now developing an Options Paper that assesses the efficacy of venting tools and/or
descending devices, and given that SEDAR 52 is presently underway, it is reasonable to provide the SSC
with an opportunity to formally evaluate Mr. Tetzlaff’s work in the context of these two analyses. In addition, the presentation by Dr. Cass-Calay at the last Gulf Council meeting indicated that NMFS’s decision to re-open the private angler season for an additional 39 days this year could have implications for spawning stock biomass (SSB) and SPR in the Eastern Gulf where the recreational fishery is focused. Specifically, Dr. Cass-Calay’s presentation showed that the average size of fish is projected to decrease by 8-12 percent in the Eastern Gulf as a result of the expanded season this year for private anglers. Removing more of the larger fish from the Eastern Gulf at this time could have effects on SSB and SPR in that region. Mr. Tetzlaff’s findings about the effects of recreational discard mortality in the Eastern Gulf could be particularly relevant given these projections.
To that end, we ask that the Gulf Council direct the SSC to review the Tetzlaff report (attached hereto) at its next meeting (proposed for January 2018).
Thank you for the opportunity to comment.
Eric Brazer, Deputy Director
Gulf of Mexico Reef Fish Shareholders’ Alliance
|10/4/2017 14:13:01||Dylan Hubbard|
|Madiera Beach, FL|
My family business has been fishing central west coast of Florida for nearly 90 years and four generations. Today we operate 6 federally permitted vessels including two 65+ passenger head boats and four federally permitted charter vessels. On top of these permits, I am also here today to represent the Florida Guides association as their Offshore Director. Finally, I am a CCA life member as well. Descending devices and Venting tools
We would like to see venting tool outreach begin well before any type of policy making them required is enacted. We find first hand on the party boats that an inexperienced angler with a venting tool can do more damage than good. On the charter boats its much easier due to the captain and crew handing nearly every fish and using proper handling and venting techniques. Descending devices are nearly impossible to use unless the bite is slow and if it’s slow were moving on to find better fishing. We use venting tools in every fishing seminar before fishing on any long-range party boat fishing trip. Also, we do venting tool outreach at our fishing seminars around the area and state and we find it very easy to instruct an inexperienced angler how to vent property using this in person instruction using a bait fist as an example. The important thing to include in the outreach to anglers learning how to use venting tools and to encourage anglers who currently utilize venting tools properly is to give credit to the anglers for improving their dead discard numbers thanks to proper venting tool use and proper fish handling techniques.