Comment Form: Vision Blueprint for the Snapper Grouper

Transcription

1 From: To: Subject: Date: Amber Vonharten Comment Form: Vision Blueprint for the Snapper Grouper Fishery Thursday, July 23, :45:08 PM Comment Form: Vision Blueprint for the Snapper Grouper Fishery State: Florida How do you participate in the snapper grouper fishery? Restaurant Owner/Chef Please add your general comments and recommendations about the Draft Vision Blueprint for the snapper grouper fishery here: Management: What actions do you support? I support strategy 1.1 action B. consider voluntary sector share management. Fishermen in the South Atlantic should have the same opportunity as fishermen in other parts of the country. I support strategy 1.2 action A, spawning season closures. Protecting spawning fish is a common sense approach to any fisheries management. I support 1.3 action A. I support 2.2 action A, F and G. I support 3.1 action A. I support 4.1 action A. I support 4.4 action A,B and C. I support 4.5 action A. I support 5.1 action A, B and C. I support 5.2 action, A and B. I support 5.3 action A. I support 5.4 action A and E. I support 6.1 action A, B, D and L. What actions do you NOT support? Under Strategy 4.2 I don't support Action C. Under strategy 4.3 I don't support Action B. Under strategy 5.2 I don't support Action C. Science: What actions do you support? What actions do you NOT support? Communication:

2 What actions do you support? What actions do you NOT support? Recreational: What actions do you support? What actions do you NOT support?

3 From: To: Subject: Date: Amber Vonharten Comment Form: Vision Blueprint for the Snapper Grouper Fishery Tuesday, July 28, :24:50 PM Comment Form: Vision Blueprint for the Snapper Grouper Fishery State: Florida How do you participate in the snapper grouper fishery? Recreational, For-hire/Charter Please add your general comments and recommendations about the Draft Vision Blueprint for the snapper grouper fishery here: While it is an overall good idea to have long term "Goals", doing so without first having a solid basis of fact (science) in which to bas any such decisions accomplishes little. Unfortunately, with most data and science out of the councils control, it leaves us with little more than we have now to work with.and that's a huge problem. It truly is like putting the 'Cart before the Horse'. having followed the process from the original port meetings to this latest round of input meetings, and having followed up with many others attending other meetings from the one I attended, several themes were found in common. Accurate data, something reliable and trustworthy needs established. Few trust what we have now. 'New and Novel' Management Schemes are neither wanted or needed. The Gulf states have taken it upon themselves to get reliable data, and exposed huge flaws with MRIP. Now, Florida is looking to expand their Gulf coast Reef Fish permit plan to our East coast.to actually find out how many people participate in the offshore fishing, unlike what MRIP does to determine a number. Again, this is out of council control, but the very thing needed before all other items. Captain Henry ACME Ventures Fishing Management: What actions do you support? Using good, reliable data to manage with. I would even support Recreational Fish Tags IF, and only IF they were used to collect effort data in determining an accurate participation number. I support as a Charter Captain a electronic reporting system, weekly perhaps, to log trip data, effort, etc. I support real time commercial and dealer reporting (well same day, not VMS). I support the management of our fisheries on Good, Reliable, Current and Complete science based data. What actions do you NOT support? Catch Shares, IFQ, LAPP, TURF, Sector Separation, Fish Tags for effort control. VMS. Science: What actions do you support? What actions do you NOT support?

4 Communication: What actions do you support? What actions do you NOT support? Recreational: What actions do you support? What actions do you NOT support?

5 From: To: Subject: Date: SAFMC Amber Vonharten Comment Form: Vision Blueprint for the Snapper Grouper Fishery Tuesday, July 14, :50:20 AM Comment Form: Vision Blueprint for the Snapper Grouper Fishery State: Florida How do you participate in the snapper grouper fishery? Commercial Please add your general comments and recommendations about the Draft Vision Blueprint for the snapper grouper fishery here: Management: What actions do you support? Number one priority in my region (SE Florida) is a zero bag limit for mutton snapper during May and June. The 10 fish/person limit is simply not working, and we are seeing fewer and fewer fish each season at the few known spawning sites. At least one historical spawning site has been dead for almost a decade. It is not uncommon to see a single boat off Key West with 10 people onboard fishing for muttons. A zero bag limit has worked in other species that congregate, and will work for mutton as well. This limit would apply to recreational fishermen as well. What actions do you NOT support? Individual quotas. This concept is as un-american as it gets. Just because someone has had small landings in recent years doesn't mean they don't plan to increase landings in the future. The driving force behind any free-market economy is the desire to grow. ITQs or something like them simply eliminate the little guys and give the fishery to the big guys, which is unfair. You can argue that one can simply buy a larger share of the catch, but there are two points to counter this argument: 1) the shares may not be available if no one wants to sell their share, and 2) it adds an unreasonable cost to a small operation that is already dealing with many inflated costs. Individual shares, with the dynamics of the fishery in my area at least, will just not work other than to drive the fishermen that are doing the least harm to the resource our of the fishery. Onboard Monitoring systems: again, we are already dealing with many costs that have risen much faster than the price of fish. Adding an additional heavy cost will only hurt the little guys, again. In SE Florida, there is only one area we can fish, so whether I fish Key Largo or Islamorada, I'm fishing the only reef we have and it doesn't not help anyone for me to have a system giving my exact position. Perhaps in other areas, but here it is simply not necessary and will add nothing to management. I already report the location of my landings in my logbooks. Science: What actions do you support? A study on the effects of power chumming on reef fish populations, especially yellowtail snapper. I've been involved in the snapper/grouper fishery since the 1970's, long before there was such a

6 thing as a snapper/grouper management scheme, and I will tell you that I've seen many disturbing changes. For many years, we found yellowtail snapper and other species all along the reef, from off Miami all the way to the Dry Tortugas. The fish weren't found everywhere all the time, but rather, you could find them just about anywhere at any time depending on season, currents, water clarity, moon, and other factors. Some areas were known to hold certain fish of a specific size class at the same time of year. In the last two decades, I've made two observations: 1) the preferred method for catching yellowtail has shifted from night fishing with modest amounts of chum, to daytime fishing with excessive amounts of chum targeted in one specific location, and 2) vast areas that once held yellowtail are now completely devoid of any life. I think the two are related. Such a concentrated effort of fishing, i.e. heavy chumming, has concentrated the schools of yellowtail in certain spots where they become used to being fed, much like the stingrays in Grand Cayman and Tarpon in Islamorada. This cannot be healthy for the reef ecosystem. With yellowtail being so widespread and once so plentiful, I'm sure they had an important role to play throughout the reef. With most of the fish now concentrated in distinct locations where they come to be fed, and eventually caught, I would wonder if we are not killing the reef in the long-term. I admit that I am guilty of the same act, with catches as big as ~1,000 lbs in one day in one spot, but that doesn't mean that I can just pretend that it won't hurt me in the future. I'd like to see yellowtail and other associated species more widespread as they once were. I'll leave it to the scientists to determine how to design such a study. What actions do you NOT support? Communication: What actions do you support? What actions do you NOT support? Recreational: What actions do you support? What actions do you NOT support?

7 From: To: Subject: Date: SAFMC Amber Vonharten Comment Form: Vision Blueprint for the Snapper Grouper Fishery Saturday, July 11, :02:44 PM Comment Form: Vision Blueprint for the Snapper Grouper Fishery State: Florida How do you participate in the snapper grouper fishery? Recreational Please add your general comments and recommendations about the Draft Vision Blueprint for the snapper grouper fishery here: Objective 4 is weak. We need much more than improvement in the data. We need confirmation that the data is statistically representative of the snapper and grouper fishery. Using a 40% or higher discard rate is laughable and should invalidate the results of your assessments. Why can't you verify, validate and crosscheck your estimated stock assessments? Maybe that should be done by an impartial outside party. The real fishermen know that the snapper are prolific right now. Management: What actions do you support? What actions do you NOT support? Science: What actions do you support? What actions do you NOT support? Communication: What actions do you support? What actions do you NOT support? Recreational: What actions do you support? What actions do you NOT support?

8 From: To: Subject: Date: SAFMC Amber Vonharten Comment Form: Vision Blueprint for the Snapper Grouper Fishery Friday, July 10, :42:48 PM Comment Form: Vision Blueprint for the Snapper Grouper Fishery State: Florida How do you participate in the snapper grouper fishery? For-hire/Charter Please add your general comments and recommendations about the Draft Vision Blueprint for the snapper grouper fishery here: HI Amber Our local ( Northern Palm Beach County) Grouper population has been almost totally wiped out in recent years due to heavy pressure from Divers as well as Fishermen. We fish two trips per day almost every day and we haven't caught ten legal fish this year. I offer a free trip if anyone releases a grouper or 10+ pound Mutton. We raise a lot of eyebrows that way hoping to raise consciousness. We don't need ten /person snapper limits 5 is fine. Lanes should be 10" Mangroves 12" Dolphin 24" theres not much to eat otherwise. I remember when it was easy to look like I knew what I was doing, it's getting tougher. Thanks for what you are doing, the fishes need your help Cap'n Bill Taylor F/V Black Dog Management: What actions do you support? Increase the number of officers and staff pay them more What actions do you NOT support? Dumping of lake waters on farmland east of Lake O has wiped out the Loxahatchee River and estuary of all of its Oysters after we spent millions seeding the river a few years ago. I'm not even growing barnacles on my boat. If you let them kill the estuaries you won't have any fish to manage Science: What actions do you support? What actions do you NOT support? Communication: What actions do you support? What actions do you NOT support?

9 Recreational: What actions do you support? What actions do you NOT support?

10 From: To: Subject: Date: Amber Vonharten Comment Form: Vision Blueprint for the Snapper Grouper Fishery Tuesday, September 01, :23:12 PM Comment Form: Vision Blueprint for the Snapper Grouper Fishery State: Florida How do you participate in the snapper grouper fishery? Recreational Please add your general comments and recommendations about the Draft Vision Blueprint for the snapper grouper fishery here: I appreciate that ya'll are asking for our feedback, but I've gotta be honest and say that this is a hodge-podge of ideas and not really a "vision". And, there's a lot of things that are repeated over and over again, just in slightly different language, which makes this more confusing than it needs to be and hard to follow. I hope that you will clean this up and make it more focused so that we can understand better exactly what you are proposing (or not). If I turned something like this into my boss, he'd send it back and tell me to do it over again, but shorter. Anyway, there are some good ideas here and some not-so-good ideas. I'm going to list the ideas I think are the best ones. Oh, and one more thing. When you guys send out your notice about closing this or that, you never say why. When I get an from FWC saying that snook is closing, they always tell me why the cold snap, etc. I wish you guys would do that. Thanks again for the opportunity, I hope you take my comments as they are meant, to be constructive. Management: What actions do you support? Objective 1. Develop management measures that consider subregional differences and issues within the fishery. Strategy 1.1 Consider development of different types of quota-based management systems. Actions: A. Employ tools to gauge snapper grouper permit holder support prior to consideration of any new potential individual fishing quota program (i.e, referendum for commercial sector, surveys, etc.). Strategy 1.3 Consider use of alternative sub-regional management strategies that are not quotabased. Actions: A. Use staggered spawning season closures to address latitudinal differences in spawning activity. Objective 2. Develop innovative management measures that allow consistent access to the fishery for all sectors. Strategy 2.1 Support development of management approaches that address retention of snapper grouper species. Actions: A. Consider bag limit and trip limit adjustments such as,

11 Use a step-down approach when a species is approaching the ACL for either sector; Consider smaller trip limits and bag limits for certain species. D. Implement a charter boat limit instead of a per person limit on charter trips. * *NOTE: These actions also apply to Objective 4 (reducing discards). Strategy 2.2 Support development of management approaches that address the amount of effort in the snapper grouper fishery. Actions: A. Consider a recreational stamp/license for the snapper grouper fishery. B. Implement a limited number of days for fishing for deepwater species. (R, FH) C. Manage effort/permits in the commercial and for-hire sectors. G. Explore options for a privately-funded buy-out program for the commercial sector. Strategy 2.3 Support development of management approaches that account for the seasonality of the snapper grouper fishery. Actions: A. Consider a recreational season for harvest of deepwater species by region. B. Consider a time-out period of no fishing for the recreational fishery. D. Consider seasons for co-occurring species and stagger the seasons (use depth as a criteria mid-shelf and deepwater). F. Shift the red snapper season outside of their known spawning season. Strategy 2.4 Support development of management approaches that consider flexibility in setting Annual Catch Limits. Actions: B. Use adaptive management for almaco jack and rudderfish to slowly increase the ACL. C. Use multi-year ACLs that use blocks of years to manage the ACL for a species (multi-year catch specifications). D. Ensure more data-poor species use alternative data-poor assessment approaches. Strategy 2.5 Consider development of alternative management approaches to expand access to the fishery. Actions: C. Evaluate the use of harvest tags for specific snapper grouper species. D. Use depth to set zones for recreational harvest of snapper grouper species. E. Consider measures to simplify regulations for both sectors. (i.e. limits, aggregates, etc.) Objective 3. Ensure that management decisions help maximize social and economic opportunity for all sectors. Strategy 3.1 Consider development of management approaches that assist fishery-dependent businesses to operate efficiently and profitably. Actions: B. Consider predictability in for-hire business planning when making management decisions. C. Consider non-traditional stakeholders/ businesses when making management decisions (chefs, eco-tourism operators, bait/tackle shops, marinas) Strategy 3.2 Consider development of management approaches that support recreational fishing and allow increased opportunity for trip satisfaction. Actions: A. Consider effort control strategies that include: Setting fishing seasons with post-season adjustments for the following season.* In-season/post-season bag limit adjustments instead of closures.* Set fishing seasons for co-occurring species.* Set bag limits that support participation (aggregate bag limits).* B. Consider development of artificial reefs or special management zones for the recreational sector only. C. Consider development of species complex specific permits (similar to existing HMS

12 permit). Objective 4. Develop management measures that reduce and mitigate discards. Strategy 4.1 Consider management approaches that consider catch limits, seasons, and the biology of the fishery in order to minimize bycatch of snapper grouper species. Actions: A. Use spawning Special Management Zones. C. Consider a spawning closure for all snapper grouper species with a low ACL. E. Set a season for deepwater species and shallow water species by area. Strategy 4.2 Consider management approaches that address the impact of depth on bycatch of snapper grouper species. Actions: A. Consider full retention of deepwater species. B. Establish a season for deepwater species. C. Consider removal of size limits for deepwater species. D. Consider alternate electronic monitoring methods for all sectors to obtain data on depth to monitor catch composition and location. E. Use zone-based management that is set by depth. Strategy 4.3 Reconsider management strategies that use size limits to reduce bycatch. Actions: B. Consider no-size limits for snapper grouper species. Strategy 4.4 Develop management approaches that support Best Fishing Practices to help avoid bycatch and reduce discard mortality. ` Actions: A. Promote opportunities for research, development, and evaluation of gear and technology to reduce bycatch (i.e., hook type/use, gear competitions, descending devices). Objective 5. Support management measures that incorporate ecosystem and habitat considerations for the snapper grouper fishery. Strategy 5.1 Support the enhancement of habitat for the snapper grouper fishery. Actions: B. Evaluate the use of artificial reefs as a mechanism to improve fishery production. C. Consider artificial reefs with limited or no fishing allowed. Strategy 5.2 Evaluate biologicial, economic, and social impacts when developing ecosystem and habitat management approaches. Actions: A. Consider the impacts of human population growth and distribution on habitats. Strategy 5.3 Consider management approaches that support monitoring and enforcement of managed areas established to protect and conserve ecosystems and habitat. Actions: A. Consider the use of alternative electronic monitoring systems or other innovative technology (surveillance buoys, drones, etc.) to monitor fishing activity in all sectors. Strategy 5.4 Consider spatial management approaches to protect and conserve ecosystems and habitats for the snapper grouper fishery. Actions: A. Consider development of managed areas (MPAs, spawning SMZs) that allow no harvest of snapper grouper species. B. Consider additional restrictions on existing managed areas (MPAs, etc.).

13 C. Evaluate areas that may be suitable for spawning Special Management Zones (SMZs). D. Establish clear goals for creation of Habitat Areas of Particular Concern (HAPCs). E. Create no-anchor zones to protect fragile habitat. Objective 6. Develop management measures that support optimal sector allocations for the snapper grouper fishery. Strategy 6.1 Support management approaches that consider the mechanics of designing allocation strategies (who, what, how, and social/economic considerations). Actions: A. Consider separate allocation for charter/headboat sectors. B. Evaluate existing sectors and current harvest to help determine allocation strategies. Strategy 6.2 Identify alternative methods for determining allocation shifts and managing allocations within the fishery. Actions: D. Consider establishing allocations by permit (each permit holder gets an allocation that fluctuates based on the ACL). G. Specify the allocation focus for each sector (Commercial-offshore; Recreational-nearshore). What actions do you NOT support? Strategy 2.3 Support development of management approaches that account for the seasonality of the snapper grouper fishery. Actions: E. Adjust the seasonal spawning closure for shallow water grouper and consider, shortening by 1-month; allow fishing but reduce bag limit; or a rolling closure throughout the region. Strategy 2.5 Consider development of alternative management approaches to expand access to the fishery. Actions: A. Investigate expansion of fisheries for under-utilized species. B. Evaluate applicability and develop policies for aquaculture of snapper grouper species in the region. Strategy 5.2 Evaluate biologicial, economic, and social impacts when developing ecosystem and habitat management approaches. Actions: C. Consider no new MPAs. Objective 6. Develop management measures that support optimal sector allocations for the snapper grouper fishery. Strategy 6.1 Support management approaches that consider the mechanics of designing allocation strategies (who, what, how, and social/economic considerations). Actions: E. Manage by economic levels (primary, secondary, tertiary) in the fishery (1-harvesters, 2- dealers, 3- support industries). Science: What actions do you support? I support everything except the one thing below. What actions do you NOT support? F. Consider utilizing third party analysis and assessments using a standard stock assessment process

14 this seems like the fox guarding the hen house let commercials hire their own scientist to do a stock assessment and guess what?! they can catch as much as they want. big surprise. Communication: What actions do you support? Objective 1. Develop communication approaches that provide streamlined and timely information to increase awareness and engage stakeholders. Strategy 1.1 Expand the use of innovative technology to improve stakeholder participation and to communicate the Council process. Actions: A. Expand the format for public hearings through the use of web-based hearings facilitated by staff. B. Utilize remote listening stations for public hearings and educational meetings to increase participation from remote groups of stakeholders. D. Utilize web-based tools (webinars, video conferencing, etc.) and other technology to collect public comment and provide educational workshops. Strategy 1.2 Utilize the Council s website as a clearinghouse for easy to access information on Council news, regulations, fishery management plans, and management actions. Actions: C. Create a separate page for educational resources/materials produced by the Council on various topics. Strategy 1.3 Consider use of alternative outreach approaches to further engage stakeholders in the management process. Actions: I. Support expansion of the Marine Resource Education Program SouthEast (MREP-SE) to other areas of the region. M. Support more informal port meetings for educational purposes on relevant fishery issues/topics to include current and upcoming management issues. Objective 2. Ensure that Council communication encourages and supports engagement with a diverse audience of stakeholders. Strategy 2.1 Use targeted communication strategies to maintain and increase stakeholder engagement with the Council. Actions: D. Develop 1-page fishery management resources (print and electronic) for distribution to targeted audiences/sectors. E. Consider use of appropriate outreach materials that meet the needs of a wide generational range of stakeholders. ADD: Include info on why things are happening. Objective 3. Improve awareness and understanding of fishery science and research and how these inform management. Strategy 3.1 Support collaboration with academic and research institutions, non-governmental organizations and agency partners on development of fishery-related outreach programs and materials. Actions: A. Develop recreational angler education programs about how to reduce discards (i.e., barotrauma, best fishing practices for handling/releasing fish, descending devices, etc.). Strategy 3.2 Support outreach programs that address the process of a stock assessment and how results are used in management.

15 Actions: A. Develop targeted outreach programs aimed at all sectors about the Council process, including the role of the Scientific & Statistical Committee. B. Develop angler education programs about fisheries science, stock assessments and data collection. C. Expand the use of educational webinars to convey information about stock assessments, data collection, and other fishery science concepts. Objective 4. Improve awareness and understanding of how social and economic issues are linked to fisheries management measures. Strategy 4.1 Work with agency partners to provide stakeholders with information on seafood and fishing business marketing strategies that may increase profits. Actions: B. Work with MREP partners to add a seafood and fishing business marketing module to the annual MREP-SE Management Workshop. C. Provide informational resources to fishermen about marketing of alternative/ underutilized species. What actions do you NOT support? This would leave out most of the fishermen in the region, especially recreational fishermen who don't have a charter or commercial permit, so it's a bad idea: Objective 1. Develop communication approaches that provide streamlined and timely information to increase awareness and engage stakeholders. Strategy 1.1 Expand the use of innovative technology to improve stakeholder participation and to communicate the Council process. Actions: G. Consider hosting webinars just for snapper grouper permit holders on various topics. These are just not a good use of the Council's resources, especially when you need to focus on getting better data: Strategy 1.3 Consider use of alternative outreach approaches to further engage stakeholders in the management process. Actions: B. Consider an advertising campaign highlighting Council activities and success stories. C. Consider use of informal polls/surveys to take input on a specific management action or direction being considered by the Council (before Council starts to develop and take action). F. Consider creation of an incentive rewards program for stakeholders that remain active in the management process. G. Consider using recorded telephone messages to reach active stakeholders about Council activities. L. Consider using paid angler focus groups to solicit input on specific management issues. Recreational: What actions do you support? Strategy 1.1 Support an efficient decision making process for development of management measures for the snapper grouper fishery. Actions: A. Evaluate the current Council process. B. Consider mechanisms for streamlining the process of amendment development. C. Consider alternative methods for collecting public input on proposed management actions.

16 D. Ensure timely access of amendment documents and other materials to the Council and the public. Objective 2. Build capacity to streamline management efforts and better coordinate with management partners. Strategy 2.1 Enhance existing and develop new partnerships with agencies, academic institutions, and other organizations to support comprehensive management strategies for the snapper grouper fishery. Actions: D. Expand partnerships with academic and research institutions to coordinate fisheries science research to address data needs within the snapper grouper fishery. E. Identify non-traditional partnerships and sources of funding to support fisheries science, research and management activities (industry, NGO supported, etc.) Objective 3. Improve communication with stakeholders to ensure the needs of the fishery are understood and considered throughout the Council process. Strategy 3.1 Support a formal and informal process for engaging stakeholders in the snapper grouper fishery. Actions: B. Consider alternative methods for collecting public input. C. Evaluate the composition of advisory panels, committees, etc. to ensure representation meets the interests and needs of the fishery. What actions do you NOT support? Nothing jumps out as a really bad idea from the list.

17 From: To: Subject: Date: Amber Vonharten Draft Document Wednesday, July 22, :44:58 PM Dear Amber, None of these meetings are in my area, but I encourage a strong conservation approach to fisheries management. I also support creating areas where there is no take of fish to protect fish aggregations. Regards, Drew Martin Conservation Chair, Loxahtchee Group, Sierra Club 720 Lucerne Ave. #1396 Lake Worth,Fl

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83 Comments on DRAFT Vision Blueprint for the Snapper Grouper Fishery July 2015 Submitted by Mike Merrifield Governance (General Comment) There should be more pressure to achieve a total harvest as close to Maximum Sustainable Yield as possible. Anything less is irresponsible to the American consumers, the American recreational anglers, the American commercial fisherman and global fisheries outside the US. The demand for seafood in the US will never be able to be met by domestic, wild-caught fisheries, as evidenced by the fact that 94% of seafood in this country is imported. However, it is the responsibility of American fisheries managers to achieve Maximum Sustainable Yield harvest levels, as stated in MSA, to reduce exploitation of less well managed fisheries in foreign countries. (General Comment)There is a general misconception portrayed by the council (which is conveyed in other sections of this document) that governance of commercial fishing pertains to commercial fisherman, docks/fish-houses and processors. The seafood harvest industry itself consists of fisherman (captains and deckhands), boat-owners, docks, fish houses and processors that make their living from harvesting seafood, however, they represent a fraction of the constituents of this sector the American seafood consumer. The American public is slowly waking up and becoming educated on the source of the seafood they consume. Just as we are seeing an increase in organic and non-gmo foods in our groceries stores, because the American consumer is demanding it, so to are they demanding to know where their seafood is coming from, how it was harvested, were there human right violations AND why are we not harvesting our own natural resources at Maximum Sustainable Yield. This group is not often in attendance at the council process but their interest is meagerly represented by an under-funded commercial industry. But ask any commercial fisherman what purpose they fulfill and they will undoubtedly refer to themselves as food producers. This is why the evaluation of economic impact to the commercial fishery based on ex-vessel price is not right. It does not incorporate the extended value this product represents to the American consuming public. (Objective 1) Any method or tool that can be utilized to expedite management decisions would be a benefit to a system beleaguered with bureaucracy. The expediency in which a fishery can be shut down does not match the expediency for opening one up. The tools are not in place to make this happen. Obtaining the necessary requirements to open a fishery are cost prohibitive science is the stranglehold of fisheries management. (Objective 1, S-1.1, A-C and Objective 3) evaluate effectiveness of placing kiosks at various sites (ie fish houses for commercial, marinas for recreational, docks for charter) for broadcasting bulletins/news, providing access to council website and recording typed, audio or video comments. (Objective 2) It is unclear to me how the Actions in this section will meet the Objective. It appears to me there is an underlying objective to openly forge more relationships with other

84 outside entities to provide what the council has not been able obtain from within necessary science to make good management decisions. The challenge is in balancing entity objectives to meet the stated goal: transparency, balanced, timely, flexible, well-defined. Communicaiton (Objective 1) refer to kiosk idea under Governance. Also request commercial, recreational and charter entities with websites to have links to SAFMC pages. This can include bait & tackle shops, gear distributors, service industries, Standard Marine, West Marine, etc. Offer rewards for clicks that result in valid, meaningful comments. (Objective 1, S-1.3) Please do not send recorded messages to phones. Most people are primarily cell phone users and these are extremely irritating. I like Action K as a means for getting input, it s also great PR and gets council people out in the public. Share a booth with state partners like FWC. (Objective 1) During a road trip council staff/members should schedule dockside visits to meet with commercial, recreational or charter stakeholders. Get to know the people being impacted by management decisions in their work place instead of it always being the other way around. (Objective 3, S-3.1) We do educational field trips now at our dock and would like to have outreach materials to hand out or a representative to participate. We have periodic events designed to educate the public about domestic seafood. We are constantly combating misinformation and recommendations issued by non-local engos. Where are you? Why are you not proud and standing up for what you do? (even if some of us think it is extremely conservative, there have been great and painful strides made toward getting our stocks sustainable) (Objective 3, S-3.2) More needs to be done to assist AP members in understanding the council process and where they fit in the process. Needs to be more explanation of stock assessment models. Why the council is so dependent on evaluations from the SSC. Why the SSC is so deficient in data and how data proxies are derived. Good luck. (Objective 4) Not sure what Action A and B would look like or what it would be designed to attain. I think market factors need to play a part in fisheries management as part of best utilization of the resource. We are always promoting underutilized species. It is hard to alter consumer choices at the retail market level. It is almost impossible to change restaurant purchasing behavior because they are driven by what their customers want. We are beginning to see some chefs try to promote this concept alongside traditional offerings. (General) Council does not promote, advertise, celebrate, broadcast, etc. fisheries management successes such as meeting sustainability goals, how much recreational fishing opportunity the American public participated in each year and how much fish was estimated to have been taken home by anglers to enjoy, how much fish was put on the market by commercial fisherman for the non-boating public to enjoy and how much was served by restaurants. The council spends a lot of money producing literature touting conservation achievements. There are other achievements.

85 (General) Promote NOAA Fish Watch. Monterey Bay Seafood Watch classifies Red Snapper as a fish to AVOID. WHY? Is it not sustainably harvested? It is under a rebuilding plan and either cannot be harvested or is harvested in extremely limited quantities. Seafood Watch is recommending you let Red Snapper harvested from the south Atlantic rot on the dock rather than purchase it. We should be recommending you jump at the chance to purchase a south Atlantic Red Snapper because it is a rare and fortunate opportunity. Science (Objective 1, S-1.1, Action-F) I think consideration of utilizing reputable, third-party entities to do stock assessments, economic assessments, etc. is a great idea. This would need to be clearly defined, analyzed from a cost/benefit perspective and presented to stakeholders. Stakeholder participation would go a long toward trust in objectivity. Transparency is required. (Objective 1, S-1.2) Nothing mentioned here about collection of recreational data which represents a huge data gap. (Objective 2, S-2.1) Researchers need to be in the field more interacting with charter, commercial and recreational stakeholders. This opens a 2-way communication stream that benefits both. (Objective 2, S-2.2) The recreational sector needs to be encouraged over time into becoming a responsible, accountable group that is given right to utilize a valuable, food-producing resource of the American people. With that right comes the requirement to report what portion of the resource they are using. Volunteering gives the impression you have the choice to participate or not. Ojective 3, S-3.1, Action A) This is a BIG concern. Currently, the difference between economic valuation of recreational versus commercial is unequitable and absolutely wrong. Using exvessel price for commercial value and extensive, extraneous costs for recreational only serves to minimize commercial value. Determining allocation strategies based on this unbalanced economic analysis could result (and currently does) in short-changing the non-boating, American consumers access to a public. (Objective 4, S-4.1, Actions A&B) Observers are expensive but can generate valuable data. This program needs to develop good observers and employ them strategically. This is a great tool for a third party research organization to have access to and deploy as needed. (Objective 4, S-4.1, Action C) I do not support video monitoring. VMS could probably be achieved in the commercial fishery over time. Increasing accountability of the commercial sector while not requiring any accountability of the recreational sector does not make sense on multiple levels. The miniscule improvements in commercial data input, enforcement and accountability pale in comparison to any strides made toward more recreational accountability, where the biggest data gaps and little accountability exist. (Objective 4, S-4.2, Actions A-F) are all good. Basically, any step toward more recreational accountability is good. (Objective 4, S-4.2, Action G) Needs to be ways to audit logbook data against landing/trip ticket data. If it already exists then more audits need to be performed. This will help eliminate pounds

86 that only exist on paper to pad landings for fisheries the council would like to go to Catch Shares (most of them) and also help eliminate unreported pounds. (Objective 4, S-4.2, Action H) Reporting is a requirement for the privilege to participate in whatever sector you belong. I assume this was intended to get recreational input. Change the mindset. (Objective 4, S-4.2, Action I) Consequences must always outweigh the benefits of the action you want to stop or you will not accomplish your goal. Consequences must also be equitably applied to all, both in when it is enforces as well as the impact of the consequence. (Objective 4, S-4.2, Action K-M) Improve bycatch reporting eliminate discards. (Objective 5, S-5.1) Studying cause and effect of environmental factors on these species is good for predictability and helping maintain health stocks. It shouldn t take a scientist to understand any and all pollutants directly or indirectly introduced will have some accumulative effect on the ecosystems that will eventually impact the fish stocks. Numerous outfalls, releases from Lake Okeechobee, increases in the cruise ship presence, etc. should be evaluated for their cumulative impact. (Objective 5, S-5.2 & 5.3) When I first started attending SAFMC meetings I asked a SSC member why we don t have model prediction charts similar to hurricane prediction charts. The response was we were nowhere near having that level of sophistication and the number of variables required to replicate that were infinitely times more. While this is an admirable goal and we should continue to collect data toward that end, I think the limited resources should be focused on stock assessments and analysis that help the fisheries in the nearer term. Management The second paragraph of the Background statement at the beginning of each section made it clear Catch Shares will always be on the table, which is understandable, however there seemed to be a fair amount of focus on them, in one form or another, throughout this section, even though there was a majority of opposition expressed at all the meetings. (Objective 1) Regional issues need to be considered to attempt to address differences in access due to distance from port. (Objective 1, S-1.1, Action B) Voluntary share management is a concept that should not exist. A sector should either be under quota management or not. Splitting a sector in to one percentage being Catch Share and the remaining not should not be an option. (Objective 1, S-1.1, Action C) For commercial sector, referendum is required with all permitted participants required to vote. (Objective 1) There was no mention of a tag system for this objective. Are tags not the recreational equivalent to IFQs? (Objective 1, S-1.2) This section consist of elements that need to be defined IF/WHEN a quota management system is elected by referendum. It does not need to be a part of this document. (Objective 1, S-1.3) Maybe, rather than listing all the tools available under Objective 1, it might be better to develop a sector methodology for developing a management strategy by sector

87 that meets the requirements of the management goal. Defining working groups, public input, council approval, etc. (Objective 2) These actions would be specific objectives of the sector methodology. (Objective 2) Eliminating Discards must be a goal of all sectors. (Objective 2, S-2.2) These actions would be specific objectives of the sector methodology. (Objective 2, S-2.2, Action G) What is meant by a privately-funded buy-out program for the commercial sector? (Objective 2, S-2.3) These items would be addressed best in a sector specific forum. (Objective 3, S-3.1, A) Market factors should be considered in commercial resource management to get the best value through the entire supply chain for the resource. (Objective 3, S-3.1, B) Same considerations in the for-hire sector regarding market value. (Objective 3, S-3.1, C) Chefs are NOT non-traditional stakeholders of commercially caught seafood resources. Chefs, retail customers, road-side customers, restaurant goers that eat seafood ARE the stakeholders the commercial sector represent. This is a paradigm shift the council and staff need to understand. Impacts to the commercial sector are impacts to the consumer, wholesale, retail, restaurants, the dining public, (Objective 3, S-3.1, D) New entrants to endorsement, permits, tag distribution, etc. need to be addressed by each sector in their working group meetings. (Objective 3, S-3.1, E) Catch Shares and owner-operator do not co-exist well. Catch Shares will eliminate owner-operators and create share croppers. (Objective 3, S-3.2) Should be defined by recreational sector working group. (Objective 4) This should be a specific management goal that must be addressed by each sector working group in the development of their sector management plan. Each sector must have specific goals that must be met in their plan. (Objective 5) These items would be addressed by sector working groups with cross-sector solutions being developed. (Objective 6) Optimal is in the eyes of the sector. Allocations need to be distributed fairly with the capability to easily move un-used allocation to a sector that has utilized their allocation within a season. The goal is Maximum Sustainable Yield. (Objective 6, S-6.1, Action E & F) Levels may be an approach to equitably evaluate economic value of resources allocated to each sector. Using ex-vessel price as the economic value for commercially allocated resources grossly undervalues the economic contribution of the commercial sector to our economy.

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