-- Mike Able, President. Haddrell's Point Tackle & Supply

Transcription

1 South Atlantic Fishery Management Council I would like to express my support for alternative 2 in the Snapper Grouper Amendment 19. Our BSB have rebuilt, they are an extremely important fish to our fishing community and I strongly urge the council to support alternative 2. Kindest regards, -- Mike Able, President Haddrell's Point Tackle & Supply

2 Dear Sirs, Alternative 2 is by far the most consistent with the Fishery Council s ACL control rule for black sea bass. Please vote for Alternative #2. Sincerely, Don Acree

3 Please select alt 2 for Amendment 19. In the future, I would rather you consider increasing the minimum size instead of reducing the bag limit. Our self imposed size limit has always been 14". I can't understand why anyone would want to keep a 12" black sea bass when there are so many larger fish caught. Marlene Augustine

4 No matter what TAC you decide, the commercial allocation should be increased and the recreational allocation decreased until both approach 50%. The reasoning is this: Commercial catches are so closely monitored that each fish is practically known by his first name and family tree. The truth about the recreational catch remains as much a mystery as it has always been. The new method of calculation is no better than the old. Until you institute a recreational license for federal waters and a concurrent logbook program you will essentially know nothing.tony Austin

5 Never even saw the so-called hand I was supposed to click on to speak. We are in trouble when Florida continues to fish for BSB inside state waters Tony

6 Please choose option #2 Cam Benedict

7 Please pass Alternative 2 concerning amendment 19. Michael J. Campbell Georgetown, SC

8 I support black sea bass annual catch limit Alternative 2 in Snapper-Grouper Amendment 19. from Yaho Sent o! Mail on Android Chris Campbell

9 The Coastal Conservation Association North Carolina wishes to congratulate the SAFMC on the recovery of Black Sea Bass in the South Atlantic. I appreciated the opportunity to attend the recent webinar on this topic. I thought this was a very effective way to review information from SAFMC. Please keep me informed of these events in the future. CCA NC strongly supports Option 3 of the proposed amendment to the allowable catch limit for Black Sea Bass which would substantially increase the current ACL for black sea bass. Option 3 would set the ACL at a consistent level for three years. This would allow for a potential extension of the fishing season in the future. Option 3 would also provide for both consistent regulations over the same period and conservation benefits as well. Option 3 will also ensure a greater "buffer" for possible overages in either the commercial or recreational landings due to catch reporting delays. Hopefully, in the future the SAFMC might consider allowing the states to set regulations that provide conservation equivalency. This could benefit North Carolina as we have different size limits, bag limits and seasons depending on whether you fish north or south of Cape Hatteras. This confuses many of our "casual" recreational fishermen. It might be possible to minimize these differences if the state could manage these on a more coordinated basis. Thank you, Bill Mandulak, Chairman, CCA NC Fisheries Committee

10 Addendum to comments sent May 6, :41 PM: I strongly favor option 2 in Amendment 19. Coffey

11 1. The Black Sea Bass (bsb) season should be open year round in South Carolina. The fishery has always been primarily a winter fishery, and this would allow charter boats to have a constant source of income. Aside from charter boats, far fewer private recreational boats fish in the winter, therefore fewer bsb are taken then. 2. The limit on bsb should be 15 fish per person per day this year. 3. The minimum size limit for commercial fishermen should be 12 inches; the minimum size limit for recreational fishermen should be 14 inches. This would assure more females to re-produce before they morph into males. 4. Non-stainless circle hooks should be required for bsb. 5. Recreational fishermen should be polled via South Carolina saltwater fishing licenses in March, 2014 to report twelve months catch by month. 6. The method of determining the ACL should be published in detail so fishermen can understand and support the process. T. F. Coffey

12 SAFMC, I support the proposed increase to the ACL for Black Sea Bass (BSB) given as Alternative 2. I think for the time the recreational bag limit should stay at 5 per person per day. If the stock shows signs of increase after 2013 then the ACL of 2,133,000 should remain for the next several years. I support the closure of the commercial pot fishery from Nov 1 April 30. I believe a better alternative is to have the shallow water snapper and grouper recreational seasons (Including BSB) combined for a total open season from May 1 Nov 30 at the current size and bag limits. This will allow anglers to keep what they catch and reduce by-catch as well as give a closed spawning season. This will result in an easier to manage fishery with more productive trips for anglers while still allowing the stock to rebuild. The commercial fishery should also be closed during this time for this complex as part of a balanced management strategy. Thanks, Fowler B. Del Porto

13 I am in support of black sea bass annual catch limit Alternative 2 in Snapper-Grouper Amendment 19. Tom Driver Summerville, SC

14 My opinion for almost all fisheries, not just black sea bass, is to reduce commercial fishing. Let the masses feed on chicken, beef, pork - products that are easily farmed and managed. Save the fisheries for recreational fishing. Let someone that spends that gas and time to go out fishing keep a few for their meal for a longer season. I am not opposed to reasonable limits but let the casual fisherman keep a few. I know this won't be looked upon favorably by big business but they are also the ones that are trouncing the fisheries whenever they can. If they had a modicum of self-regulation, these steps wouldn't even be necessary. Thank you for your consideration. Ric Fiano Savannah, GA

15 I support black sea bass annual catch limit Alternative 2 in Snapper-Grouper Amendment 19. Scott Fulton Mt Pleasant SC

16 Dear Mr. Mahood As a long time avid fisherman of Black Sea Bass I would like to offer comments that I feel would be the greatest action to preserve the population of the Black Sea Bass. I fish in my own boat but have fished on many head boats and would like to offer the following observations. Even with the circle hook rule many Sea Bass are killed by inexperienced fishermen and bad dehooking of smaller Sea Bass, which results in a kill ratio much greater than the number of keeper size Sea Bass that are taken. I've watched as over 100 people catch and kill hundreds and hundreds of small Sea Bass from deep hooking, poor skills of hook removal and just plain neglect of the fish's health. These boats go out day after day with the same results. As any bottom fisherman can and will attest to, most Black Sea Bass caught will be in the size range of 10" to 12" with the seldom 13" to 14" when fishing within 20 to 30 miles offshore during summer month. While people continue to catch and kill so many Black Sea Bass seeking the keeper size bass, I feel this could be avoided by making the Black Sea Bass a "slot fish". Look at what that has done for the Red Drum population. With a five(5) fish daily limit and a slot size of 10" to 14" I feel the ABC and ACL could be more closely monitored and with more accuracy, it would eliminate the useless killing of so many fish on a daily basis and would benefit the charter boat community as a whole, increase the Sea Bass population, make for a much healthier stock and benefit the stock over the long run. I look at it this way, instead of so many people catching and killing 10 to 20 fish a day that are under sized limits, they would catch their 5 daily bag limit, stop fishing and 15 more fish would be saved to grow and increase the total stock. Thank you for taking the time to review and consider my comments. I'm no authority on fish management but only a common sense fisherman. Please feel free to contact me with any feedback and corrections of my thoughts on this subject. Keith Gray N. Myrtle Beach SC

17 Option 2 is the only option you should be considering out of the plans suggested. Thank You, Paul Hankins

18 Based on the data we could keep black sea bass open year round and avoid closures in 2015 if Commercial Pots were banned permanently. Hook and line fishing should be the only way allowed to Harvest BSB. Thank You, Paul Hankins

19 My name is Harry Campbell Jr. I live in Pooler, GA. I fish the inshore and nearshore waters in Savannah. I thought you would like to know that I have been catching Black Sea Bass in inshore waters. This is something that never used to happen until you all increased the size limits, reduced the daily creel, and closed the season. Congratulations! Job well done! Now remove the limits before the rest of the inshore species begin to suffer! Black Sea Bass are voracious and eat everything in sight. Thank you for your time. Harry Campbell

20 Thanks for someone opening their eyes, and realizing that Black Seabass are thicker than fleas on a hound dogs back. One item that needs to be adressed is having regional seasons. While North Carolina may enjoy great Seabass fishing June 1st, out inshore reefs are normally too hot for Great Seabass, and Red Snapper fishing, until early fall, when our water temperature begins to cool. In the past Seabass season closed about the time thatthe fish move into our waters. Certainly 'Alternative 3 ", appears to be an acceptable proposal, as it more than doubles the allowable catch. I agree that pots should be out of the water November- May 1st., as a precaution to protect "Right Whales".Our Jacksonville Offshore Sport Fishing Club, which use to install 7 maintain marker bouys on our inshore reefs, have now been prohibited from that activity, even though they provided a safety purpose. In the mid seventies and early eighties, our club had 800+ members, today less than 200. Parking at Mayport boat ramp, including overflow, was 6:00 A.M. every decent weekend. Today, main parking lot is less than 1/2 full, except during Greater Jacksonville Kingfish tournament, or during the September Red Snapper season last year. The first weekend was horrible weather, however no adjustment to allow another weekend was allowed, except for Commercial interests. The costs involved in offshore fishing, a weak economy, and unnecessary regulations, have all but destroyed what use to be a thriving industry. I suspect a 5 Seabass limit should keep the Seabass season open yera round, as certainly their are fewer fishermen fishing Atlantic Waters. Bob Houghton

21 F/V HULL'S SEA LOVER Robert K. Mahood, Executive Director South Atlantic Fishery Management Council (SAFMC) 4055 Faber Place Drive, Suite 201 North Charleston, South Carolina Thursday May 02, 2013 Re: Black Sea Bass (BSB) Snapper Grouper (SG) Regulatory Amendment 19 written comment To: Bob Mahood, The results of a 2013 National Marine Fisheries Service (NMFS) Southeast Fisheries Science Center (SEFSC) Black Sea Bass (BSB) stock assessment update suggest, with high statistical confidence, that the stock is neither Overfished (68% confidence) or undergoing Overfishing (93% confidence). This updated NMFS/ SEFSC stock assessment, with results that are getting closer to reality, indicates a huge biomass and a rebuilt stock of BSB in the South Atlantic Council Region (SAFMC). I agree with the SAFMC s Scientific and Statistical Committee (SSC) that the acceptable biological catch (ABC) values, as presented by NMFS/SEFSC, are the best scientific information available according to the Magnuson-Stevens Reauthorized Act (MSRA). On Wednesday April 10, 2013, the SAFMC SSC reviewed the assessment report and accepted the NMFS/ SEFSC updated BSB assessment results. The SSC then recommended the following BSB ABCs based on landed catch (whole weight): 2013 = million lbs = million lbs = million lbs. The MSRA National Standard 1 guideline advises managers to employ "Conservation and management measures shall prevent overfishing while achieving, on a continuing basis, the optimum yield [OY] from each fishery for the United States fishing industry. The SAFMC voting members should vote to have ABC=OY=ACL, for the commercial sector, as a result of the high confidence in BSB stock status. The annual catch target (ACT) for the recreational sector, likewise, should be as close to the ACL as possible. The P-star (P*) analysis, as calculated by NMFS/SEFSC, is the most credible method for arriving at a buffer between ABC and the over fishing limit (OFL). I do not agree with further buffering from the OFL by adjusting of ACLs down using fishing yield (F) at 75% of maximum sustainable yield (MSY). This alternative is not consistent with the opinion of the NMFS/ SEFSC and the Council s SSC. The SAFMC should choose to either use a step down ACL using the SSC values as described with Alternative 2 Table 2.1 on page 10 in the SG Regulatory Amendment 19 document, or create an Alternative 4 with a median of the three years ( ) ABC. Both methods allow for more BSB catch than does a F at 75% of MSY. The large buffer already calculated in the ABC projections and the positive results of BSB update started with the SouthEast Data, Assessment and Review (SEDAR 25) Data Workshop (DW), then more buffer with the SEDAR 25 Assessment Workshop (AW) thru to the Review Workshop (RW), then to the 2013 SEDAR 25 Update, and finally to the SAFMC SSC choices. We, the fishing communities, have been buffered (pencil whipped) enough. Additionally, the Beaufort Assessment Model (BAM) model, itself, is extremely conservative as a result of data limitations; and produces some of the most restrictive results of any assessment models available to the NMFS toolbox, in my opinion. The Marine Resources Monitoring, Assessment and Prediction (MARMAP) fishery independent information, the index that drove the results of the 2013 BSB update, is more reliable for BSB than any other species that MARMAP manages, as it is an easily trappable fish. Most of the sampling by chevron traps has historically been conducted offshore of the Carolinas. Below is the graph of catch per unit of effort (CPUE) Figure # 12 (PDF page 65 of 96) using chevron traps. The trend is of a biomass growing rapidly and expanding into many new areas. ORMOND BEACH, FLORIDA

22 F/V HULL'S SEA LOVER Figure 12. Observed (open circles) and estimated (line, solid circles) index of abundance from MARMAP chevron traps. Every fisherman on the water who has worked the ocean for 30 or more years knows that the BSB stock is as large as it has ever been across time. BSB live from the river all the way across the bottom shelf out to 600 feet of water. In the state of Georgia this can be 50 miles offshore. BSB live on all types of bottom from sand ridges to live sponge, worm, clam, crab, hard bottom low relief to the highest limestone ledges, rocks, steeples artificial reefs and wrecks. The spatial area for the BSB habitat is enormous for the South Atlantic Council region, estimated with 1,100 miles of shoreline, out to 200 miles in a lot of the region; but the spatial area of sampling and areas fished for harvest is small in comparison. The areas that are untouched and that have never been fished for harvest provide more than enough biological buffer to give the fishing industry sectors the full annual catch limit (ACL) as projected by the SSC. The fishing industry has been beaten down, needlessly, over the past several years. We have sacrificed much during this rebuilding. It is time to put us back to work. The BSB stock has been rebuilt for years and continues to grow and expand exponentially. This is a success story and the SAFMC voting members need to let us harvest this valuable resource. One thing is for certain, if the BSB results showed bad news (i.e negative CPUE trends) the analysts would not be talking about the uncertainty in the bad results. They would just say the bad results were precise and believable. Now that we have good results (i.e robust positive CPUE trends), the talk about uncertainty won t stop, and some say that these positive results should be taken with a great deal of caution. I say: Give us the BSB back that belong to the citizens. The system has worked, the results are in and robust with a high degree of statistical confidence. We ran the marathon and won, you saw us cross the finish line with your own eyes. Do not doubt what your eyes have seen. Economically and recreationally, the fishing industries have given up everything. Give us the prize, give us our business back; give the consumers and anglers their BSB back as recommended by the SAFMC s SSC. Thank you for considering my written comment. Captain Jimmy Hull Hull's Sea Lover Vessel ID # BSB Endorsement Permit # SBPE-7 ORMOND BEACH, FLORIDA

23 F/V HULL'S SEA LOVER PS: Below is a testimony from 2011 by a lifetime Headboat Captain the first year that the BSB stock was considered rebuilt according to this update assessment. 05/04/11 To Whom It May Concern: I am a 65 year old charter head boat fishing captain. I have fished many different boats in the south Atlantic area off Daytona since Today, I am the captain of the 125 passenger head boat Pastime Princess out of New Smyrna. On an almost daily bases, the passengers are catching between 1000 and 2000 Black Sea Bass plus other variety of fish., From all my years of fishing experience the Sea Bass are more plentiful now than ever before. We do not target the Sea Bass because of the inability to keep these fish, however, the fish are so abundant that each fishing spot we arrive on has a plethora of Sea Bass biting our hooks. Your scientist have stated that the Sea Bass Population was much greater in the 1980 s than today s population. I have to take exception to this data and would like to be informed of the captains and the name of the boats that this information was gathered from during that time. I was never made aware of or given any log books to record my catches in the 1980 s and I know of no other captains who were recording catches before Each day of fishing, all the captains are in radio contact comparing their catches and discussing the temperament of different fishing spots. To the man, each one of us say, The Sea Bass are here and they are very abundant! Respectfully, Captain George Locke 1883 Magnolia Av. South Daytona, Fl (386) ORMOND BEACH, FLORIDA

24 Mike Collins, Administrative Officer South Atlantic Fishery Management Council 4055 Faber Place Drive, Suite 201, North Charleston, SC May 2, 2013 Re: Comments on Snapper Grouper Regulatory Amendment 19 [77 Fed. Reg , April 22, 2013] Dear Mr. Collins, On behalf of the more than 11 million members and constituents of The Humane Society of the United States and Whale and Dolphin Conservation, I am writing with regard to the proposed amendment to regulations that may affect the timing and location of effort directed to capturing black sea bass. Because changes to the Annual Catch Limits, Annual Catch Targets and Allowable Biological Catch could adversely affect critically endangered North Atlantic right whales when they are present in the southeast, we support the proposal to institute an annual prohibition on the use of black sea bass pots during November 1- April 30 to prevent interactions with North Atlantic right whales. We are appointed members of the National Marine Fisheries Service (NMFS) Atlantic Large Whale Take Reduction Team (the TRT) which focuses on reducing risk of entanglement to endangered large whales. While the TRT is concerned with reducing entanglement risk for a number of species of endangered large whales, including humpback whales; the focus of the TRT s concerns in the southeast is the North Atlantic right whale. Where a cause of death can be determined, over half of all right whale deaths are a result of entanglement in commercial fishing gear (NMFS, 2012). NMFS has found that there is no level of mortality, however low, that can be considered insignificant to this imperiled population (Id.). Both trap/pot gear and gillnets are involved in entangling right whales. Though it is not always possible to determine the origin of line entangling whales, where the gear could be identified, rope associated with trap/pot gear was more frequently found on entangled right whales than rope associated with gillnets. (Johnson et al., 2005) Indeed, it is trap/pot gear that is generally used in the capture of black sea bass (see SAFMC Amendment 19 briefing book Appendix C, at table C-1). It is well known that this species travels to and gives birth in the waters off the southeastern United States, from Florida to at least as far north as Cape Fear,

25 North Carolina (NMFS, 2012). Some, but not all of these waters are within designated critical habitat. In 2007 the NMFS Southeast Fisheries Science Center issued a report to assist in the agency s consideration of revisions to the boundaries of the southeast right whale critical habitat that included most of these waters. (Garrison, 2007) Based largely on that report, NMFS enacted broad time and area restrictions to protect right whales from entanglement within the seasonal gillnet restricted area. [72 Fed.Reg , 34636; June 25, 2007] In designating the restricted area, NMFS characterized the waters within this Southeast gillnet restricted area, which extends to the southern border of North Carolina, as a substantial and core portion of the right whale calving area. In recent years, there has been increasing evidence of right whales outside of the restricted area also using the waters of North Carolina for calving. Despite the paucity of monitoring effort in the area, limited data indicate that the waters of North Carolina may well be part of the calving area. Systematic surveys conducted off the coast of North Carolina during the winters of 2001 and 2002 sighted at least eight calves, suggesting the calving grounds may extend as far north as Cape Fear. Four of the calves were not sighted by surveys conducted further south. One of the mothers photographed was new to researchers, having effectively eluded identification over the period of its maturation (McLellan et al. 2004). NMFS itself suggests that calving likely extends into southern North Carolina (NMFS, 2012). There are also more recent media reports of newborns off North Carolina. In December, 2008 a newborn right whale stranded off the coast of Avon, N.C. It was less than a week old and had failed to thrive. (WAVY, 2008). A female right whale nicknamed Calvin is believed to have given birth twice off North Carolina, in the years 2004 and 2008, with one of the instances apparently just off Wrightsville Beach, North Carolina. (StarNews,2008 ) Two mothers with small calves were seen in North Carolina in March of this year. (NOAA/NMFS, undated) The area from Florida through North Carolina requires precaution when consideration is given to permitting activities that can harm the remnant population of right whales. Given the wellknown history of entanglement in lines associated with trap/pot fisheries, it is prudent to prohibit use of black sea bass pots in these waters from November through April, when right whales and their newborns are most likely to be present. We strongly support this prohibition. Sincerely, Sharon B. Young Marine Issues Field Director The Humane Society of the United States syoung@humanesociety.org And 2

26 Regina Asmutis-Silvia North American Director Whale and Dolphin Conservation cc. Roy Crabtree, NMFS Southeast Region David Bernhart, NMFS Southeast Region References Cited Garrison, L.P Defining the North Atlantic Right Whale Calving Habitat in the Southeastern United States: An Application of a Habitat Model. NOAA Technical Memorandum NOAA NMFS-SEFSC-553: 66 p Johnson, A., G. Salvador, J. Kenney, J. Robbins, S. Kraus, S. Landry and P. Clapham Fishing gear involved in entanglements of right and humpback whales. Marine Mammal Science 21 (4): Available at: McLellan, W.A., E. Meagher, L. Torres, G. Lovewell, C. Harper, K. Irish, B. Pike, and A.D. Pabst Winter right whale sightings from aerial surveys of the coastal waters of the US Mid-Atlantic. Presented at the 15th Biennial Conference on the Biology of Marine Mammals. NMFS U.S. Atlantic and Gulf of Mexico Marine Mammal Stock Assessments North Atlantic right whale. Available at: NOAA/NMFS, undated. North Atlantic Right Whale Sightings. Searchable database. National Marine Fisheries Service, NEFSC. Available at: StarNews, Right Whale Makes Encore Appearance off Wrightsville Beach. Star News Online. December 30, Available at: WAVY Another Right Whale Stranded in North Carolina. February 2, Available at 3

27 I applaud the effort of the council to increase the Annual catch limits on the Black Sea Bass. I operate a Charter /Headboat out of southeastern North Carolina. My experience the last few years was that there was no shortage of Black Sea Bass. In fact during the Spring months until the water warms there are so manhy large Black Sea bass that you hardly catch anything else because there are so many aggressive large black sea bass. What I would like the Council to address now is the fact that the season needs to be opened earlier than June 1st in North Carolina. Like I said there is a vast abundance of Black Sea Bass in the waters off southeastern North Carolina. The current regulations prevent me and others from being able to run nearshore fishing trips earlier in the season. By not having a earlier open season you are causing some to break the law and harvest these same Black Sea Bass illegally in accordance with the rules although there are thousands and thousands of them out there. Please address the opening date. It is way to late in the season and it is not justified due to the large population of Mature fish. Respectfully, Capt. Matt Hurlbut

28 We have a particular area about 2 miles square out of the Charleston jetties about 13 mile out that we have been fishing for 20 years. It is a hard bottom area that has been very productive. The last 2 to 3 years we have been catching bigger fish and limiting out quicker each trip( when the limit use to be 12 ). We have seen the limit change from 10 to 12 from unlimited catch to 5 each person. It does not matter what time of year, the fish are always there. The present limit does not make economical sense for my family and friends to travel from Columbia to fish for 5 each ($300). When the limit was 15, that would make a little economical sense, 30 fillet each fisherman. We felt like we were getting something for the expense. We would do four maybe five of these a year. We have stopped those trips completely. The only time we fish for BSB is returning home from a trolling trip. Stop at the BSB hole limit out in 3 drops and head in. This happens three times a year max. What I do not understand if the BSB are overfished, why we are catching them more and quicker each year. It is like they are under fished. I am for any proposal to increase the bag limit, so my family can once again enjoy our little fishing spot close to the coast and feel like we have something to show for the day. Thank you for your time, and we appreciate the tough decision that you have to make to ensure all will benefit. R Wayne Jackson

29 I support alternate #2 of grouper-snapper amendment 19. Thanks, Sent from Windows Mail JAC12561

30 I support amendment 2... thanks, capt jay sconyers aces up fishing

31 I support alternative # 2 thanks Robert Leach

32 This is in response to your request for public comment. There is no current reason to have a season for sea bass because in my expeeience there is no shortage. Increasing the size limit to 13 inches makes no sense. It was hard enough to catch the daily limit at 12 inches because they rarely grow this big in Florida waters. Charles ludwig

33 I have had a charter fishing business for 12 years and a full time mate on charter vessels for 5 years before that. Closing sea bass season is about the most asinine law Iv ever seen in my life. Not only have you completely run me out of business with your idiotic laws you have thrown our reef fisheries out of whack. Do you have any idea how much a sea bass eats? The last ones I caught were puking up small red snapper and trigger fish. They have completely over run every reef and live bottom out to 150 feet. you should pay people extra to kill as many as possible to fix your wrong doing. People like me who you have put out of business. So I guess you see where I stand on this subject. Sea bass here are the same as red snapper in the gulf. OVER POPULATED because of your lack of accurate scientific data or better yet common since. Lynam

34 To All, I have hesitated to respond to this simply b/c I wanted to try and fully understand decisions that were made and voted on by the SG AP for the SAFMC to consider at the next meeting in Florida. I feel like we have a very intelligent and diverse AP but I also wonder if sometimes we don t fully understand the alternatives and because of this may lack in a more intuitive mode for discussion before making a final decision. I know that not all of us on the SG AP have extensive knowledge on all the different species we vote on, but because of such a broad area of diversity on the AP we sometimes can lean on others that do have this knowledge to help with a better understanding and our decision. The reason I am saying this is the reasoning behind why we decided as a group to vote for Alternative 3 on Amendment 19 rather than Alternative 2? To the best of my knowledge looking back after Dr. Luiz Barbieri presented the SSC s findings, which stated that, Black Sea Bass were found to be neither overfished nor experiencing overfishing and the assessment update also indicated that the stock has been completely rebuilt. A motion was made right on the heels of this presentation for Alternative 3 without much discussion. I simply could say to you that I didn t fully understand the difference between the two options ALT 2 or 3 or what the outcome would be. I wanted to vote in a direction that supported ALL fishermen (commercial and recreational) that have suffered immensely through this Black Sea Bass fiasco but also vote for something that seemed sustainable and would not carry us backwards in time to a place we had just come from. Those of us that fish in the northern part of our region know that this short-lived species is running rapid through out like cockroaches and have felt that this was an appropriate and accurate update determination by the SSC. On the other hand after reading a couple of written comments on Amendment 19 that were submitted which I wish I had had an opportunity to read before the AP meeting I now feel like maybe we should have discussed Alternative 2 more. The reason I am saying this is because I am trying my best to understand why we as a group decided to leave three hundred thousand pounds of fish on the table by selecting ALT 3 when the SSC said we could have them based on the new BSB update?

35 The way I look at it now is we came through the fire from an era of overfished and overfishing which we have defeated through a long suffering period of a closed fishery, reducing the catch limit down and implementing a more restrictive minimum size limit. All of this added to an over abundance of this species through out. If we had gone the other route of ALT 2 I believe some of us were concerned we would fall right back into the same trap we had just got out of and didn t want to go through that again, but now I am thinking that because of all the measures we have taken in the past to get to this point we have created a more sustainable fishery for the future much like what has happened with the Vermillion s which now are going to be opened year round. Maybe we should have considered this more carefully and discussed it more at length what the real likely hood of exceeding the BSB ACL would be. I am still wrestling with the comparison of the two alternatives and what would be best, so please don t think I am condemning the final outcome totally or our decision I am just questing whether we as a group fully understood what was stated and proposed between the two alternatives 2 and 3 and whether we should have discussed this further! Thanks, Mark Brown Charleston, SC

36 I want to register my support for Alternative 2. Thanks, Stephen May

37 Regulatory Amendment 19 Public Comments I am Chris McCaffity, a commercial fisherman from North Carolina. I would like to thank the council and stock assessment team for working to increase the Black Sea Bass quota as soon as possible. Now that the stock has been rebuilt, we should focus on limiting waste while keeping the fishery open as long as possible and enhancing Black Sea Bass habitat with artificial reefs to increase their biomass. We should not plan ahead to waste 45,000 pounds of bass this year when we could use that seafood to feed people and produce revenue. Please consider these positive solutions. 1. Remove the size limit or revert back to eight inches. 2. Allow a minimum of one fish and up to 10% of a catch to be undersized or over the limit. 3. Set aside a portion of the 45,000 pounds allocated to dead discards along with 10% of the commercial quota for a 100 pound bycatch allowance after the primary quota has been landed. 4. Align the opening date for Black Sea Bass with the shallow-water grouper opening on May 1 st to avoid excessive regulatory discards like will occur until June 1 st this year. 5. Set up a way for recreational fishermen to voluntarily submit fishing reports online. 6. Issue some ethical angling tips on how to handle fish that must be discarded and discouraging high-grading or catch and release fishing for species with high discard mortality rates. 7. Follow Alabama s model for allowing the public to place artificial reefs in areas of sandy barren bottom to increase the total biomass of fish an area can support. Thank you for taking the time to read my comments. I would be happy to go into more detail on these solutions if anyone has any questions

38 , My name is Capt Ron McPherson we meet several yrs ago at the BSB Sedar Comm meeting. You need to eliminate the closures on BSB since you have finally figured out that there is no problem with the stock. You also need to raise the bag limit to 10 per person per day. Five yrs ago it was 15. And lastly you need to give North Carolina our share of the quoted based on what we were catching 5 to 10 yrs ago. But definately not last year when Florida caught way more than their share and closed our season early. All I'm looking for is fair and reasonable management of this very important fish. I appreciate your time and consideration on this most important issue. Sincerely, Capt Ron McPherson Highlander Charters Inc

39 I am Wayne Mershon owner of Kenyon Seafood in Murrells Inlet, SC (Federal Dealer # 1051). I am commenting on Amendment 19 about black sea bass. I believe ACL Alternative 2 would be the best action by the council. I know the council has heard the outcry from all fishermen, commercial and recreational, about the abundance of BSB, and how they are taking over complete areas, making it harder to harvest other species of fish. I have personally observed many times while catching black sea bass that they are opportunist feeders and will eat their own weight in a day of many juvenile snapper-grouper species that are also being managed by the council. The SSC is cautious in their estimates of the ABC and the council has to use this information. I believe at this time Alternative 2 allows fishermen to benefit from the extra fish, while still constraining the catch with a conservative ACL calculation that is consistent with the SAFMC s own ACL control rule for black sea bass and the SSC s acceptable biological catch recommendations. It would not be fair to fishermen to not allow the harvest of the extra black sea bass that are over and above the rebuilt stock level, and for the council to suddenly change the rules on how the ACL is set. Alternative 2 is the best choice for fishermen, allowing for the highest ACL s, and is consistent with the fisheries council s control rule for black sea bass. Thank you Wayne Mershon Murrells Inlet, SC

40 SAFMC Robert Mahood, Executive Director 4055 Faber Place Drive, Suite 201 N Charleston, SC May 8, 2013 Dear Mr. Mahood, The North Carolina Watermen United (NCWU) agrees that black sea bass are plentiful and approves the proposed action to increase the ACL in both the recreational and commercial fisheries for the Regulatory Amendment 19 to the Snapper Grouper Fishery Management Plan. We would like to propose that the season be extended and leave the bag limit as it stands. We also agree that the current allocation for black sea bass 43% commercial and 57% recreational remain the same. Thank you. Yours truly, Duke Spencer Captain Duke Spencer Board Member, NCWU Duke@CaptainDuke.com

41 To: SA Council Please consider this public comment supporting alternative 2 when making any decisions regarding black sea bass. As you well know, BSB are one of the most important recreational and commercial species in the region. With so many restrictions and closures many for hire and commercial businesses are barely hanging on. Every decision that you make has an impact on the region, however sea bass is especially important to so many. The results of the assessment and update should be given consideration as the science continues to improve in our region. Many fishermen are beginning to see some light at the end of the tunnel with increased limits on vermillion, golden tile, sea bass, and other species. With that being said there are still huge problems with the data being used in the BSB assessment and the update and I have listed them below. Here is a quote from SEDAR 25 page 77, regarding effort in the BSB fishery, supporting the lack of area sampled and spatial coverage of the fishery. This has caused a very conservative result to occur from the assessment and the update. Although depth was an important consideration for discard mortality, most of the effort and discard of black sea bass occurs in shallow water 1. Nearly every data set used in the BSB assessment has spatial coverage issues. 2. No one can trap in the Gulf Stream current. 3. Almost no one fishes for sea bass beyond 30 miles from shore. 4. Headboats are limited to about 30 miles on average and catch sea bass often as by-catch. 5. Chevron traps are only set April to October. 6. Only a mean of 207 Chevron traps set each year in an area with over 2 million acres of hard and soft bottom habitat. 7. Most charter boats and recreational boats do not fish for them other than by catch. 8. Nearly all of the historic commercial landings data is skewed because it was from about 45%. of the fishable region NC and SC with very little fishing in GA and FL. If there is any uncertainty in this assessment and update it is that they are both extremely conservative due to the data limitations. Recently the Mid-Atlantic council made this recommendation for sea bass in that region: The SSC met in January and initially concluded that the additional information relative to fishery performance, stock size, and recruitment were insufficient to justify an ABC adjustment for black sea bass. However, after evaluating the constant catch level that has been in place for three years, the SSC concluded that the 4.5 million pound ABC is extremely conservative and recommended an increase to 5.5 million pounds for the next two years. The SSC s reconsideration of the ABC and the Council s modification of the quota represent important steps towards resolving this issue, said Council Chairman Rick Robins. The Council will continue to work with the Northeast Fisheries Science Center to ensure that we have adequate and current science to support the management of this important resource.

42 The Mid Atlantic Council and their SSC increased the ABC by 22% because they believe that the science being used in the Mid Atlantic is extremely conservative. In the SA the sea bass stock has been rebuilt in less than half the time that is was supposed to with recreational limits set at 10 per person and no closed season except for the most recent years. It is safe to assume that the assessment of BSB in the SA is even more conservative than the assessment in the Mid Atlantic, yet alternative 3 would reduce the ABC by 17%. How can one branch of the NMFS increase the ABC of a species by 22% because they think an assessment is too conservative and another branch, reduce it by 17% when they are both using the best available science in both assessments? Please choose Alternative 2 and allow the people of the region to catch the full amount for the next three years and then reevaluate. If we see problems with catch rates with the stock then you can make adjustments. This stock was rebuilt twice as fast as expected with a 10 per person bag limit and almost year round recreational fishing. This stock is extremely healthy and fishermen should be allowed to catch the full amount allowed under Magnuson. Due to the limited range of fishing, lack of spatial data, and science, have built in a buffer already and that is why the stock rebuilt so quickly. Thank you, David Nelson

43 I support alt 2 on amendment 19. The SSC has spoken and they have said what the fishermen have been saying all along. Let us catch the fish we deserve to catch. Check the science out in three years and then make adjustments. Thanks. Paul Nelson

44 Black Sea Bass Amendment 19-Comments: This is from the SAFMC and is a summary of the pending Webinar As follows: Summary of Effects Alternative 2 -- greater socio-economic effects that Alternative 1 (No action) Alternatives 2 & 3 -- benefit commercial hook-and-line participants in particular since the annual closure only applies to black sea bass pots Alternatives 2 & 3 -- would improve harvest opportunities, extend the season for the commercial fleet, and have positive social effects on recreational anglers and for-hire businesses that catch black sea bass. What all of this fails to address is the recreational fisherman who is not a deep water fisherman, but a weekend angler who fishes at near shore reefs and wrecks in 45 to 75 feet of water. This segment of the angling public is the driving force of the economy on a cumulative basis, or that was the situation prior to the so-called management of the species by the current managers. A situation of a different bag and creel limit for recreational and commercial anglers never has been satisfactorily addressed. Neither has the disparity of the frequency of angling been addressed in light of the total and cumulative economic impact. But it appears that the commercial end of the spectrum continues to be a favored sector. The concept of one size fits all for all sectors is yet another flaw of all of these plans. The divergence of conditions from North Carolina to the eastern tip of Florida is just not the same. That is why we have totally different states in that area of angling, otherwise we would have one large homogeneous state. Until a state by state decision is made based on the conditions off those states, no plan will be fair to all segments of the angling community. Again, the interests of the near shore fisherman is not taken into account in any of these plans to their very exclusion even though they vastly outnumber all other interests in this area of regulation on a combined basis. That is why the economic impact has been so crushing to them. No one is looking out for their interests. That is why none of your alternatives is palatable to the recreational community. The prime time for a economically feasible offshore trip for sea bass is from January through March in the close in reefs of out to forty-five feet for the small craft angler. You ignore that issue to the detriment of those anglers and continue to do so. The draconian bag and size limits make it not a viable recreational option for the middle class angler to expend upwards of $20, or more for a rig capable of offshore fishing under your current so-called alternatives. Have you ever done a study to see the segmentation of the recreational anglers into those who are close inshore versus those who venture into deeper waters? I dare say no you have not done that and do not recognize the fact that the sea bass migrate out to deeper water when you open the season in June and back in when the you close it. That action in itself excludes many anglers in the present tense and far into the future for that matter. Do not insult me with a retort that you do address these issues, for I know that you would have a separate set of regulations for those very anglers if that were the case. That would be a sub-category of recreational anglers who, again, far outnumber all other categories combined. Finally, until

45 you do address these issues do not look for a broad spectrum of support from the anglers of this region and those who love the sport and the recreation that it supplies. Submitted by James Newman

46 I support option 2 as my preferred option for dealing with Sea Bass. Thank you, Brad Nyers Product Management, Strategy and Innovation Lead

47 Dear SAFMC Council: I am a local charter boat operator and spend many days on the water. In the past two years the Sea Bass population has literally exploded from 35 feet out beyond 100 feet. We have had two years of very short seasons and catch limits. The Sea Bass are so thick in many places that you can not catch anything but Sea Bass. I have witnessed them eating bare jig heads and others follow up from the depths trying to steal the jig head from the hooked fish's mouth. Anyone spending time on the water will attest to this. I am not a scientist but common sense tells me that the Sea Bass must be hurting other species by eating anything and everything available. We need to go back to higher limits and longer seasons to get our ecosystem back in balance. Thank you for this opportunity to voice my concern: Capt. Chris Papera

48 Gentlemen: Please do something to correct the awful situation the Black seabass season closure and catch limits have created. An increase in the ACL and eliminating the six month season closure are minimal steps in the right direction. Increasing the daily catch limit would also help greatly. Anyone who has tried bottom fishing in the last several months has come back complaining about the swarms of Black seabass. It's almost impossible to get bait to the bottom to go after Sheepshead or other bottom dwellers. I recommend a year-round season and at least 10 fish per person per day keeping the current 13 inch minimum size. Please do something to restore a favorite winter fishing opportunity. Thank you, -- Bob Patterson James Island

49 For several years (20), I have had the pleasure of fishing the reefs off SC. We have always had an abundant amount of Black Sea Bass (BSB) Grouper/Snapper. You have changed the lengths of fish and we needed too. Over the years we have seen the growth of the BSB as if you drop you line on any reef the BSB would eat your bait before any other species could have a chance. I call this the Black plague. This is a PROBLEM. I believe you need to lift the bag limit and keep in place the minimum length. If it wasn t broke why fix it!!! But if I have to support anything on this matter: support SAFMC catch limits for alt #2 snapper-grouper amen. #19. But please understand we didn t have a BSB problem until someone dream them self into a position! Sincerely, Kevin T. Ragsdale, concerned SC FISHERMAN

50 Annual increase of stocks should be given only to the Hook and Line Fisheries, so that it will extend fisheries to at least January 1st and to reopen March 1st, for hook and line fisheries so charter for hire boats have the opportunitity to carry their charter. When fisheries ACL are within 20,000 pounds, trapping should be shut down, and to resume fisheries for commercial hook and line until quota's have been met. If the stocks have improved so much, why was my Trapping Permit taken from me? I am a 100% commercial fisherman for 35 years, before you ever even started collecting data. "You took a hammer out of my tool chest, when I need it, it is gone." I have been buying trap tags all along, what's up with that? I would like a reply to my question. Thank you. Ricky Rambeaut rambeaut@att.net

51 I would love to know how in the face of hoards of black seabass off East Central Florida, the seabass was declared overfished and experiencing overfishing in the first place? I've been diving off East Central Florida for over 30 years. Over the past several years seabass in this region were never over fished nor experiencing over fishing. Do say otherwise is a despicable prevarication. There are a number of dive spots where they number in the tens of thousands, and they are plentiful in all reef areas, and a nice legal size too. I wish I could uncover just what the stock assessment was comprised of? Was it in multiple areas, multiple depths and truly encompassing the entire South Atlantic? Was it just in a few areas where they may have been either moved by cold water or an area that they are not normally ensconced? Whatever the stock assessment was, it was seriously in error! Open black seabass year round with a size and catch limit. Ron Rincones Valkaria, Florida PS: Many Red Snapper are being inadvertently killed by the lack of education in proper release techniques and proper tools.

52 I am writing in regards to the amendments for Black Sea Bass. Personally in think there is no shortage of or ever been a shortage of Black Sea Bass off the Carolina coast. I honestly think it s absurd that the most abundant fish in our fishery has been put in such of a protective state. These fish are actually becoming a nuisance. They are choking out the other reef fishes like the way kudzu cuts out all vegetative life. Your council will be best served by listening to the charter fleet that see s the trend annually for any fish species in our immediate area. If the members of your council are not fishermen from every area under the umbrella that SAFMC controls the regulations, then we have a broken system that cannot work for the good of the species and any other species that are affected by your decisions. The best thing to do would be to give the recreational fisherman a yearlong season with the current size limit and maybe even increase the creel. That is my current position and opinion. There has to be a better way of conserving the resources we love so much and I am not satisfied with the current, blatant disregard of the fisherman s voice in these matters. Thanks, RLA Associates, PA Jeffrey W. Sawyer, PLS - Associate Surveyor

53 SOUTHEASTERN FISHERIES ASSOCIATION (SFA) EAST COAST FISHERIES SECTION (ECFS) Robert K. Mahood, Executive Director South Atlantic Fishery Management Council (SAFMC) 4055 Faber Place Drive, Suite 201 North Charleston, South Carolina Thursday May 09, 2013 Re: Black Sea Bass (BSB) Snapper Grouper (SG) Regulatory Amendment 19 written comment To: Bob Mahood, The Southeastern Fisheries Association (SFA) East Coast Fisheries Section (ECFS) would like to submit this written comment about the SG Regulatory Amendment 19 for BSB annual catch limit (ACL) changes. The results of the 2013 National Marine Fisheries Service (NMFS) Southeast Fisheries Science Center (SEFSC) SouthEast Data, Assessment and Review (SEDAR 25) Black Sea Bass (BSB) Update stock assessment suggest, with high statistical confidence, that the stock is neither Overfished (68% confidence) or undergoing Overfishing (93% confidence). This updated SEDAR 25 stock assessment now with results that are getting closer to the reality on the water that indicates an increasing biomass and is now on hindsight a rebuilt stock of BSB in the South Atlantic Fishery Management Council (SAFMC) region since We agree with the SAFMC s Scientific and Statistical Committee (SSC) that the acceptable biological catch (ABC) values, as presented are the best scientific information available according to the Magnuson-Stevens Reauthorized Act (MSRA) National Standard 2 guidelines. The SAFMC SSC met during April 9-11, 2013 to discuss the final SEDAR 25 BSB Update Assessment document dated March 2013 and conducted by the NMFS SEFSC analysts. The SSC effort to confirm the acceptable biological catch (ABC) for BSB included reviewing the NMFS P* [P-star] analysis and found it was an adequate buffer between the ABC and the overfishing limit (OFL). The SFA ECFS believes that the risk of overfishing the rebuilt BSB biomass is negligible and adding more buffer as found with Alternative 3 using Fishing mortality (F) at 75% of MSY is creating more of a burden to the BSB fishing industries leading to premature closures to both sectors. The ABC should be equal to the optimum yield (OY) and equal to the ACL [ABC=OY=ACL]. As a result the SFA ECFS supports the SG Regulatory Amendment 19 Alternative 2 for this BSB ACL Action. We disagree with the more restrictive Alternative 3 that leaves available valuable BSB stocks uncaught that could be landed by recreational entities and by commercial fishing interests. The published calving season with the Atlantic Large Whale Take Reduction Plan (ALWTRP) has been November 15 to April 15 for years now. We have issues with the SG Regulatory Amendment 19 action during the Northern Right whale calving season to remove all BSB Pot fishing gear from the ocean before November 01 each year. This action proposes that BSB Pot fishing gear remain stored on land until after April 30 of the following year. The November 01 to April 30 removal of BSB Pot fishing gear each year from Cape Hatteras, North Carolina south to Cape Canaveral, Florida due to vertical lines when there has never been a known interaction with this traditional gear is an overreach by the NMFS 111 W. GRANADA BLVD ORMOND BEACH, FLORIDA SFAECFS@AOL.COM Page 1

54 SOUTHEASTERN FISHERIES ASSOCIATION (SFA) EAST COAST FISHERIES SECTION (ECFS) using the ALWTRP. Vertical lines are a bigger issue in the Northeast United States and recent SAFMC BSB regulation changes includes a 1000 pound gutted weight trip limit, a 35 BSB Pot limit maximum on board and/or set, and no Pots left in the water when the vessel returns to port just took effect this past fishing season. These recent SAFMC changes have serious benefits for reducing the potential interaction with protected species like Northern Right whales, especially when it is noted that the BSB Pot fishery is prosecuted in areas further offshore than these whales tend to aggregate or migrate generally. An alternative to giving up the BSB Pot fishing gear during the traditional ALWTRP calving season during November 15 to April 15 each year should also include a commercial start date of April 16 and continue through November 14 each year, as long as the commercial BSB ACL is uncaught. The remaining commercial ACL for BSB could then be landed using hook and line by commercial fishermen with a Snapper Grouper permit during November 15-April 15 each year. The hook and line fishery currently opens at the same time as the BSB Pot fishery and for the Unlimited Snapper Grouper permits operate with the same trip limits. Thank you for the opportunity to submit our written comment before the SAFMC meets during the special May 13, 2013 webinar to set the new BSB ACL for several years. We also wish to emphasize that the NMFS SEFSC needs to conduct another BSB Update assessment beginning sometime in 2015, the last year of the current projections. Jimmy Hull, Chairman SFA ECFS JGH/rhh 111 W. GRANADA BLVD ORMOND BEACH, FLORIDA SFAECFS@AOL.COM Page 2