Candy
04-29-07, 09:05 AM
EMERALD COAST REEF ASSOCIATION, INC 13 Nov 2006
P.O. BOX 273
Niceville, FL 32588
Dr Roy E. Crabtree, Regional Administrator
NOAA Fisheries Service
13th Avenue South
St. Petersburg, Fl 33701
Subject: Draft Environmental Impact Statement (DEIS) to Evaluate Alternatives to Set Gulf of Mexico Red Snapper Total Allowable Catch and Reduce Bycatch in the Gulf of Mexico Directed and Shrimp Trawl Fisheries
Dear Dr Crabtree:
Emerald Coast Reef Association (ECRAI.org) is a non-profit 501 (c) (3) forty-two member organization dedicated to the research and development of artificial reefs for the enhancement of depleted reef fish populations. We believe that artificial reefs should be considered as a method of increasing the population of juvenile snappers and subsequent recruitment into the breeding/directed fishery stock. The effectiveness of this strategy has been demonstrated by the resurgence of the snapper fishery off the coasts of Louisiana and Alabama.
We strongly object to the alternative measures proposed in the DEIS. The DEIS fails to address the impact of artificial reefs. It proposes to simultaneously reduce the Total Allowable Catch (TAC), the minimum size limit for the commercial fishery and implement an Individual Fishing Quota (IFQ). These actions are interdependent and will create conflicts between the commercial and recreational sectors when the commercial fishery targets juvenile snapper that inhabit the public artificial reefs.
We agree that the mortality rate for the commercial fleet is high. However without a market analysis there is little assurance that the commercial fleet will keep 13 inch snapper. One can envision a scenario where the supply of whole small snapper exceeds demand, the value drops and small snapper again become bycatch.
Less than one year after the National Resources Council determined that the Marine Recreational Fisheries Statistical Survey (MRFSS) was useless for estimating the recreational TAC, NMFS continues to use the survey and proposes to reduce the recreational catch by 1.5M lbs. If you don’t know the size of the recreational catch, how can you quantify a reduction? The survey is not the only weak link in the population modeling process. Directed and indirect (shrimp trawl) fishery mortality rates have a way of changing by factors of 2 or more apparently based on little more than anecdotal reports from fishermen. The large bycatch has created predator dependencies from sharks, barracudas and bottlenose dolphins that remain an unknown contribution to the overall mortality rate.
The Gulf of Mexico Fishery Management Council (GOMFMC) is fully aware of the limitations of our understanding of the red snapper fishery and took the position that no change in the directed fishery should be proposed until the full effects of the 2005 hurricane season on fishing effort are quantified. We think the NMFS should respect the position of the GOMFMC, revise the DEIS in consideration of the deficiencies we have identified and halt the proposed interim rule reducing the TAC, minimum length and bag limits.
Please contact me if you have any questions. I may be reached at (850) 678-1461 or by e-mail at parsonskg@cox.net.
Sincerely,
Gary Parsons, President, Emerald Coast Reef Association
P.O. BOX 273
Niceville, FL 32588
Dr Roy E. Crabtree, Regional Administrator
NOAA Fisheries Service
13th Avenue South
St. Petersburg, Fl 33701
Subject: Draft Environmental Impact Statement (DEIS) to Evaluate Alternatives to Set Gulf of Mexico Red Snapper Total Allowable Catch and Reduce Bycatch in the Gulf of Mexico Directed and Shrimp Trawl Fisheries
Dear Dr Crabtree:
Emerald Coast Reef Association (ECRAI.org) is a non-profit 501 (c) (3) forty-two member organization dedicated to the research and development of artificial reefs for the enhancement of depleted reef fish populations. We believe that artificial reefs should be considered as a method of increasing the population of juvenile snappers and subsequent recruitment into the breeding/directed fishery stock. The effectiveness of this strategy has been demonstrated by the resurgence of the snapper fishery off the coasts of Louisiana and Alabama.
We strongly object to the alternative measures proposed in the DEIS. The DEIS fails to address the impact of artificial reefs. It proposes to simultaneously reduce the Total Allowable Catch (TAC), the minimum size limit for the commercial fishery and implement an Individual Fishing Quota (IFQ). These actions are interdependent and will create conflicts between the commercial and recreational sectors when the commercial fishery targets juvenile snapper that inhabit the public artificial reefs.
We agree that the mortality rate for the commercial fleet is high. However without a market analysis there is little assurance that the commercial fleet will keep 13 inch snapper. One can envision a scenario where the supply of whole small snapper exceeds demand, the value drops and small snapper again become bycatch.
Less than one year after the National Resources Council determined that the Marine Recreational Fisheries Statistical Survey (MRFSS) was useless for estimating the recreational TAC, NMFS continues to use the survey and proposes to reduce the recreational catch by 1.5M lbs. If you don’t know the size of the recreational catch, how can you quantify a reduction? The survey is not the only weak link in the population modeling process. Directed and indirect (shrimp trawl) fishery mortality rates have a way of changing by factors of 2 or more apparently based on little more than anecdotal reports from fishermen. The large bycatch has created predator dependencies from sharks, barracudas and bottlenose dolphins that remain an unknown contribution to the overall mortality rate.
The Gulf of Mexico Fishery Management Council (GOMFMC) is fully aware of the limitations of our understanding of the red snapper fishery and took the position that no change in the directed fishery should be proposed until the full effects of the 2005 hurricane season on fishing effort are quantified. We think the NMFS should respect the position of the GOMFMC, revise the DEIS in consideration of the deficiencies we have identified and halt the proposed interim rule reducing the TAC, minimum length and bag limits.
Please contact me if you have any questions. I may be reached at (850) 678-1461 or by e-mail at parsonskg@cox.net.
Sincerely,
Gary Parsons, President, Emerald Coast Reef Association