Spiny Lobster Regulatory Amendment 4

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1	Timestamp	Enter your full name	email address	City, State, Zip Code	Check all that apply	Comments

2	5/4/2017 16:27:29	Bill Cuthbertson	billcuthbertson@carolina.rr.com	Wilmington NC 28411	Private Recreational Angler	There is absolutely no reason to ban spiny lobster recreational trap fishing in EEZ. As mentioned in your report only 1 person ever has requested a permit. The harvest for this method is non existent and is more of a novelty for anyone participating. If there is a problem regarding the whale migrations, a seasonal closure would be more appropriate.
3	5/25/2017 11:14:09	Testing Tester	testing@gogogo.com	testville, FL 55555	Private Recreational Angler	This is a test.
4	6/1/2017 14:51:33	Jim Atack	jim.atack@adm.com			Re: Amendment 4 Spiny Lobster May 25, 2017 Action 1: We have heard a lot of the same comments in 2011 that all of the Spiny Lobster in Florida come from other areas of the Caribbean or elsewhere, so we don’t need to establish an ACL, ABC, OFL,MSY, etc that will maintain any kind of breeding stock. Please re-read my attached comments from 2011. Since 2011 I have heard that there has been evidence that a significant percentage of the lobsters come from local recruitment (contrary to John Hunts report in ~2010, Amendment 4 acknowledges this) even though there has been very high landings which reduces the percentage from local recruitments. A better managed more sustainable fishery will yield higher percentages from local recruitment. I think this is a risky position to take and is not the kind of message we should be sending to our Caribbean partners. Is it good practice for them to harvest every living lobster upstream of our waters that is 3” or larger? How would you prefer they manage the stocks where most of the current recruitments come. If the 10 year mean landings are 5.8 MM (2001/2002 -2009/2010) then I think it is risky to establish the MSY and ACL at 2 standard deviations above the mean (7.9 MM #’s). All other fisheries set limits less than the mean. This amendment proposes using 1991-2016 mean landings plus two standard deviations to establish a 10.49 MP. I oppose this preferred alternate and recommend a lower OFL. It should be less than the mean landings and there should be accountability measures if the ACL is exceeded. I think the proper thing to do for the fishery & sustainability is to do what is right for the long term, not the short term. If you leave a higher percentage of the lobsters out there for next year there will be a larger biomass & this will help even out the landings. This could also eliminate or help reduce the negative impacts during lean landing years. Council should be more conservative with their management measures in the lobster fishery than what are the current “Council’s preferred options in Amendment 4”. I fear that some of these decisions will be based on pressure from Florida lobstermen, pack houses, greed (lobster is selling at very high prices), and opinions rather than good science and good management practices. When the data is questionable and we don’t know what caused the lack of lobster for ~10 consecutive years we should err more on the side of conservation. Council should also put in place accountability measures so that if the ACL is exceeded then the next year’s harvest should be reduced by that amount. Action 2: I endorse the proposed action to extend the prohibition of traps off the coasts of Ga, SC, & NC. I believe this fishery could be devastated in short order if trapping were to be allowed in this area. By the time you could determine that the stock was overfished actions could not be implemented quickly enough to prevent the collapse of the stock. I also think that there should be another trap reduction program. 425,000 traps can do a lot of damage to the reefs. There has been research done to show that less traps will catch the same number of lobsters with a higher CPUE. The use of undersized lobsters is deplorable – it is a waste of a valuable resource. Hundreds of thousands of lobsters are wasted this way. By switching to legal sized bait and by rotating these out by taking them to market the mortality rate on shorts can reduced to almost zero. This is another example of where the Council could have been proactive. Had they listened to the advisory panel members in 2011 the use of shorts in traps would have been eliminated. (Had they listened to the SG AP recommendations several years ago they could have prevented the overfishing of Hogfish). The SAFMC Spiny Lobster AP recommended (2 years in a row) to do away with using shorts in the lobster trap fishery. Disallowing the use of shorts will provide a reduction in undersized lobster mortality, it will make it easier for law enforcement, it will increase the annual landings, and trap efficiency will not be affected because they will continue to use live lobsters as attractants (albeit legal sized). 1) I have also heard from local lobstermen that when the lobsters get above a certain size they move to deeper water. If this is true, it could also affect local recruitment. Maybe by culling out all lobsters as soon as they reach 3” they don’t get to move to an area that will be more likely to re-populate Florida. I suggest the council take no action on increasing the ACL and suggest they instead institute some payback regulations for when the ACL is exceeded. It is great that the stock has been in good enough shape to provide increased landings over the past few years but we should now be taking actions to ensure that this fishery stays viable and sustainable by capping the total harvest and by reducing the excessive mortality caused by using shorts in the traps. Sincerely, Jim Atack
5	8/7/2017 18:12:29	Matt Manning	matthmanning@yahoo.com	Valrico, FL 33596	Private Recreational Angler	I demand that any final actions be moved to the Biloxi meeting in October because the new council members will not be able to vote at the august meeting and they need to have their say, that is why they were appointed to the council so please let them weigh in!
6	8/7/2017 18:15:11	Matt Manning	matthmanning@yahoo.com	Valrico, FL 33596	Private Recreational Angler	I demand that any final actions be moved to the Biloxi meeting in October because the new council members will not be able to vote at the august meeting and they need to have their say, that is why they were appointed to the council so please let them weigh in!
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