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Snapper Grouper Amendment 17A - Red snapper are currently undergoing overfishing and are overfished. Amendment 17A establishes Annual Catch Limits (ACLs) and Accountability Measures (AMs) for red snapper, long term management measures to rebuild the red snapper stock, and a monitoring program for red snapper. Management options include closure of the red snapper fishery plus alternatives for area closures for all snapper grouper fishing to address bycatch of red snapper, permitted fishing zone, and various monitoring program alternatives.

Amendment 17A Red Snapper & Bottom Closure

-I oppose any changes in the Red Snapper regulations until such time as there is reliable data to upon which to base any changes.

-The stock assessment and historical data are based upon a failed attempt to determine the stocks of Snapper before 1980.

-Due to the fact that there is no reliable data before 1980, the baseline date for stock assessments for Grouper/Snapper must be reset to 1980 instead the arbitrary date of 1945, and a new assessment must be done before any regulations can be implemented.  In addition, the release mortality rate was increased by over a factor of 3 without any scientific justification or tagging recovery program to support this drastic change.

-Dr. Frank Hester has proven there exist flaws in the assessment and the Council must act upon this new information that he has provided and reassess the stocks accordingly.

-Professors Waldner and Chesnes of Palm Beach Atlantic also reviewed the assessments concluded that the estimates were wrong and stated that the NMFS has no idea of the historic population of Red Snapper.

-The 7 to 6 vote on the interim rule shows that there are many questions as to the nature and effect among the Council members and no overwhelming consensus to enact such a draconian and unprecedented closure.

-Council members cannot enact such a far reaching measure based upon information that is admitted to be flawed is irresponsible.

-The closure will shut down the charter fishing fleets and cause loss of jobs in marinas, bait shops, restaurants etc. There has not been an economic impact study done for the South Atlantic. The current study extrapolates information from 2 boats in 1 port in the panhandle to the entire South Atlantic region.

-In the State of Florida in according to the Florida Wildlife Commission in 2008 Saltwater fishing generated $3,141,005,027 in retail sales, generated $326, 166,528 in sales taxes, had a total economic impact of $5,369,293,552 and creates 54,508 jobs. This economy will be severely impacted by this closure.

-I support the use of circle hooks and venting tools to reduce mortality. This reduction in mortality will further strengthen the stocks.

Snapper Grouper Amendment 17B - Establishment of ACLs and AMs for 9 remaining species in the snapper-grouper complex currently listed as undergoing overfishing. Alternatives include a proposed deepwater closure, allocations for golden tilefish, aggregate ACLs for gag, black grouper and red grouper, and AMs to close fisheries once the ACL is met.

Snapper Grouper Amendment 17B

1.1 Speckled hind/warsaw grouper
I support Alternative 1 (Status Quo).
There is no basis for any changes to the fishery.

1.2 Golden Tilefish
I support Alternative 4
The 50/50 recreational/commercial allocation is the only alternative that complies with National Standard 4 as being (such allocation shall be (A) fair and equitable to all such fishermen)

Golden Tilefish ACL & AM
I do not support any of the proposed alternatives.
I do however support a modified Alternative 5 in which the accountability measure for the recreational anglers annual catch limit is not tied in any way to the commercial limit.

1.3 Snowy grouper
I object to all of the alternatives. The recreational anglers must be given an equal and separate allocation of the Snowy Grouper. We urge the Council to adopt a alternative that
(a)	Allocates 50% recreational allocation at 41,450 lbs.
(b)	sets the recreational limit of 1Snowy Grouper (Included in the 3 grouper aggregate)

1.4 Black grouper, black sea bass, gag, red grouper, and vermilion snapper 
I support Alternative 1 which maintains the current regulations.

Snapper Grouper Amendment 18 - Additional measures are being considered for the snapper-grouper complex, including expansion of the management unit northward, limiting access for the golden tilefish fishery, measures for the black sea bass pot fishery, change in fishing year for golden tilefish, improvements in fisheries statistics, and designation of Essential Fish Habitat (EFH) as necessary.

Snapper Grouper Amendment 18

1: Extend the range of the snapper-grouper FMP north

I support Alternative 1.

I oppose the extension of the Snapper Grouper fishery management plan north beyond the North Carolina/Virginia border. The SAFMC has failed to properly manage the areas within their region; the extension would only extend the mismanagement into other areas and takes the focus away from the main area of concern in the South Atlantic.

2: Limit participation and effort in the golden tilefish fishery

None of the alternatives are acceptable.

The SAFMC must set the allocation at 50% recreational/ 50% commercial. The present 97% commercial/3% recreational allocation is unfair in violation of the National Standard 4 of the Magnuson Stevens Act. Further all longline fishing must be banned.

3: Modifications to management of the black sea bass pot fishery

None of the alternatives are acceptable.

All pot fishing must be eliminated.

4: Separate snowy grouper quota into regions/states

I support alternative 3.

I support the separation into states and specifically separating Florida into its own management region.

5: Separate the gag recreational allocation into regions/states

I support alternative 3.

I support the separation into states and specifically separating Florida into its own management region.

6: Change the golden tilefish fishing year

None of the alternatives are acceptable.

I have no opinion on the change of the Golden Tile fishing year, but the allocation must be changed to 50/50.

7: Improve the accuracy, timing, and quantity of fisheries statistics.

I support Alternative 2. (voluntary recreational logbook)

I demand that the Council not make any changes to the regulations until such time as there is reliable statistics upon to base any new regulations.

Florida Fish and Wildlife Conservation Commission will consider passing Atlantic Grouper Consistency Rules.

In December, the Florida Fish and Wildlife Conservation Commission will consider passing Atlantic Grouper Consistency Rules 68B-14.0036 and 68B-14.0039. These rules are companion rules to the ill-conceived Amendment 16 of the South Atlantic Snapper/Grouper Fishery Management Plan.  I strongly disagree with Amendment 16, and with FWC adopting these companion rules.

Amendment 16 as passed by the South Atlantic Fishery Management Council and the National marine Fisheries Service is based on flawed data and assessments. The incomplete and flawed data these agencies are using as the basis for the South Atlantic Grouper population was collected using the much-maligned Marine Recreational Fisheries Statistics Survey (MRFSS) system. MRFSS was not designed and was never intended for this purpose, according to SAFMC scientist John Carmichael. MRFSS has also been described as fatally flawed by Dr. Patrick Sullivan, chairman of the National Research Councils Congressional peer review during a review that failed MRFSS.

By design, MRFSS was created to only measure trends, and was never intended to numerically measure recreational angler s catches.  This has lead to an internal bias towards the collection of data from commercial and headboats. This leads to serious problems with the data collected in that these sectors target smaller fish in shallower waters than recreational anglers. Older larger fish tend to be solitary and in deeper water and this makes them not a target for headboats and commercial fishermen. This flaw in the MRFSS system creates a bias in the data that underestimates the number, size and age of the average fish.

The truth is the Grouper population in the Atlantic Ocean off the coast of Florida is healthy and thriving. Research has shown the Grouper population is growing, not declining. This is proof the current regulations are working and changes are unnecessary and ill advised. The impetus for these new regulations are not brought about by a problem in the Grouper stocks but by pressure from anti fishing environmental groups led by The Pew Foundation and the Environmental Defense Fund. These groups are pushing their antifishing agendas on the Federal agencies in the guise of management. Florida cannot allow these environmental extremists to hijack Florida?s fisheries just because the federal agencies buckled to their pressure. It is the responsibility of the Florida Fish and Wildlife Conservation Commission to represent the citizens of Florida, not Washington based special interest groups.

As you are aware, saltwater fishing generated $3,141,005,027 in retail sales, $326,166,528 in sales taxes, had a total economic impact of $5,369,293,552 and creates 54,508 jobs in Florida alone in 2008 according to a Florida Fish and Wildlife Conservation Commission survey.  This groundless and unwarranted closure would cause the loss of a large portion of this revenue and cause the loss of many of the 54,508 jobs. Prior to proposing this closure the SAFMC failed to perform an economic impact survey on its effect on the economy. Instead, the SAFMC attempted to extrapolate a Gulf study done on 2 fishing boats in the Florida panhandle to the entire South Atlantic region.

The actions of the South Atlantic Fishery Management Council and the National Marine Fisheries Service in proposing and approving Amendment 16 based upon what is known to be fatally flawed assessments were arbitrary and capricious. It was a violation of their duty to properly manage the South Atlantic Fishery. For the Florida Fish and Wildlife Conservation Commission to enact regulations based upon the same flawed assessments would be equally a violation of the duty of the Florida Fish and Wildlife Conservation Commission to properly manage the fishery and be arbitrary and capricious.