Posted - 03/21/2007 : 7:45:44 PM
| This was my response to Amendment 30 and these are the people I sent it to.
Dear, Mr. Vice President, Richard Cheney, Louisiana State Representative Mr. Bobby Jindal and The Gulf of Mexico Fisheries Management Council,
I was at the Louisiana, Gulf Council Scoping Meeting last night 3/20/2007. From what I gathered by the question Harlon Pierce, Gulf Council Member, asked all of the fishermen, is that you have no idea what is out there. And that makes me wonder how can you impose limits on fish if you don't know what’s out there? Harlon's question to everyone that took the podium was, "would you object to filling out a trip ticket?" That question tells me you don't have the data you need to make an intelligent decision. So, quit trying to screw the recreational fisherman out of more fish when you don't have the data to prove over fishing, bycatch percentages or catch amounts. Also quit trying to claim every species as "over fished" until you know what is out there. Did the Gulf Council already forget what happened last time they jumped to the conclusion that Red Grouper was over fished? The Gulf Council wanted to pass an emergency ruling by none other than Dr. Roy Crabtree, himself. Then the Gulf Council closed the season only to find that the stock assessments were invalid and when the new stock assessments were made, Red Grouper wasn’t being over fished.
Gag Grouper, there are plenty of gag groupers out there but many of the breeding stock of the fish are caught by the long liners. Want to help the problem, Ban Longlining.
Red Grouper, this fish doesn't exist in Louisiana, quit trying to regulate Louisiana the same as Florida.
Amberjack, this fish has had a decline several years ago, when the long liners hit the scene. As far as the fish still declining, that's just simply not true. Amberjack declines started back in the late 80's and early 90's. Back then when we dove the oilrigs, we'd see schools of 80-100lb. amberjacks. Now you might see 1 or 2, 80-100 lb. fish in a school of 50-60lbers. As far as the number of fish, it is still high on the rigs off the coast of Louisiana. Just the larger fish are not as plentiful. The recreational fisherman, with hook and line can't even catch the larger fish because they wrap the fishing line in the rig and break it off. The only people that can consistently catch the larger Amberjacks are Long liners. Want to solve the problem of Amberjack over fishing, Ban Longlining.
Triggerfish, this fish is not even a targeted species by most fishermen. The only people I can think that would target them in any quantity are commercial fishermen. Divers do spear them for rodeos but you are talking fish numbers in the single digits. As far as declining populations, you need to come scuba diving with me in the Grande Isle block 40's or South Timbilier 60's or Ship Shoal 180's or as far down the Louisiana coast as you care to go but just stay in 100' of water, and you better wear ear protection if you don't know what your doing because the hungry little piranha’s will eat your ears off the side of your head. Whoever told you this fish was declining is telling you an outright lie. But if you think there is a problem with them being over fished, stop the culprit, Ban Commercial fishing for Triggerfish.
Florida and Louisiana are 2 totally different ecosystems. One suggestion, at last nights’ meeting was that the NMFS should consider splitting the Gulf of Mexico up into 2 groups, "Western Gulf" and "Eastern Gulf". In Florida the population is around 21 million people and in Louisiana the population is 7 million people, in Florida they have a commercial fleet of several hundred boats, in Louisiana they have a fleet of 50 boats. In Florida the fishing is done over coral or natural reefs, in Louisiana the fishing is done on the offshore oil platforms.
On the number 1 major coral reef in Louisiana, “The Flower Garden Reef”, spearfishing is “not allowed”. I have not personally dove the Flower Gardens but I am told by those that have, it’s not even worth bringing a spear gun down on. There just aren’t many fish worthy of spearing. Now the oil platforms around the Flower Gardens have some of the most abundant sea life in the Gulf of Mexico. I have dove those and can attest to that myself.
I have to ask, how can the NMFS not count fish in its data collection process if they come off of an artificial structure? A natural structure is formed when a coral polyp grows on a rock, but who knows, it may have grown on a piece of metal. Such is the case of the Offshore Oil Platforms in the Gulf of Mexico. These platforms are totally encrusted with coral. I thought it was illegal to take coral from the Gulf of Mexico or to destroy reefs; the oil companies do it every time they take down an offshore platform. Much the same as cutting down hundred year old Oak Trees, every time this happens habitat is destroyed. Please look at the website made by Steve Kolian, http://towersoflife.com/.
The oil platforms provide havens for an abundance of fishes including the reef fish discussed in Amendment 30, with the exception of Red Grouper. (Red Grouper may be present but just about all Louisiana fishermen will claim they have never seen or caught one). I also understand that Alabama has an artificial reef that they claim is home to 30 percent of all the Gulf of Mexico’s red snapper. How can the NMFS ignore these fish? A fish is a fish no matter where it swims. The NMFS should concentrate its efforts on increasing habitat and maybe make a deal with the oil companies to not tear down their abandoned oil platforms. If you make the habitat the fish will come.
I have been diving the Gulf of Mexico for 25 years. In that time I've made probably 1000 dives on different platforms, I've also dove the Florida Panhandle, Mississippi and Alabama. If you want data that you can count on send me some diving biologists, I will take them out and show them the fish. The Gulf Council will have to pick up the tab. But they really need to know how to dive; they must be able to handle themselves in dirty water, deep depths and strong current.
I understand that Greenpeace and the Sierra Club are involved in a lawsuit with the NMFS to make them lower recreational fishing limits, even though sufficient data has not been collected. The recreational fishermen spend 13 BILLION dollars a year on fishing, while the commercial fishermen spend 50 Million dollars a year on fishing. I think the NMFS needs to cater towards the recreational fishermen a little bit more rather than trying to take our God given rights away. Longlining is destroying all of the reef fisheries along with bottom trawling.
Longlining, takes the larger fish of each of the reef species, in most cases the larger fish of a species isn’t even as valuable as a quality eatable fish. The fish are older and the meat is not as good, but the main problem is the fish are the mature, breeding stock of the species. I’m not talking about taking 1 or 2 of the larger of the species as in trophy hunting, I’m talking about stretching out 15 miles of cable, with hooks attached every 3’ and catching whole breeding grounds at a time. If you wanted to decimate a species of fish, I couldn’t think of a better way.
Bottom Trawling, the most wasteful practice I can think of, scrapes anything growing on the bottom of any aquaculture off, whether it be grass, new coral polyps, coral, fish, crabs all for a very small amount of shrimp. Every 4 lbs. of bycatch equals 1 lb. of shrimp. And that will only hold true if the shrimp boat captain puts his net where the shrimp are, there are many drags where the shrimpers don’t catch any shrimp at all. Does anybody remember the Bull Croaker (2-4lb. croakers)? I do, we used to catch boxes and boxes when I was a kid, along with red snappers at the first rigs you’d get to in the Gulf. If you wanted to catch a big red snapper, you used a small bull croaker. Bottom trawling has managed to decimate an entire age class of fish, an edible fish at that, also a fish that red snappers used to eat.
One more thing as far as the meeting the last night, Louisiana has 2 representatives on the Gulf Council, a recreational representative and a commercial representative, why did we only have our commercial representative at the meeting last night for a meeting room full of recreational fishermen?
To sum up what I’m trying to say, the recreational fisherman have taken all the cuts they are going to take, we have 2 cobias, 4 red snappers, 5 groupers, 1 amberjack. What are you planning to cut us to next, 1 fish per day, while the commercial fishermen catch unlimited amounts of fish, fish 365 days a year because no on is enforcing the laws on them? Its time for you point your finger at someone else, someone that doesn’t spend 13 billion dollars to help the economy, the real cause of the problem and tell them its time to cut your limits instead. Why don’t you try protecting a billion dollar industry instead of protecting a million dollar industry?
Develop habitat, stop the wasteful fishing practices that are going on in the Gulf and there will be plenty of fish for everyone and their kids in the future.
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Posted - 03/21/2007 : 8:17:06 PM
| LOUIS: that says it all-i am in complete agreement on all your points--recreational fishermen catch pounds--not tons--everyone knows it's money-lobbying-and this thing is controlled by people who have no idea what fish populations are here because they sit at desks.hey i like seafood too but trawling does more damage than good.i don't know the anser to that one but we should extend our continental waters to 500 miles for foriegn boats and keep our boats honest instead of having a meeting every year and guessing.tax paying recreational fishermen should be given BETTER limits instead of them saying fish decline is our fault.do the math-that's impossible!HERE GOES HOPE I DON'T GET POOFED
Posted - 03/22/2007 : 12:55:40 PM
Here is the letter I am sending to the Council. I haven't finished the CC: list yet but I'll send it out to several folks.
Note to the Gulf Council regarding Reef Fish Amendment 30.
First allow me to say thank you for the opportunity to comment on this important issue. It is through this process that we all hope to assure the health of fish stocks for generations to come.
I attended the Gulf Council’s meeting held in the New Orleans area on 20 March 2007. At this meeting it was revealed that there is additional information on Grouper populations forthcoming. With this in mind it was proposed that the Council consider splitting Amendment 30 into two separate amendments. One would address Amberjack and Triggerfish and the second (a new amendment) would address Red and Gag Grouper separately. This would allow the remnants of Amendment 30 to continue on schedule in order to address the Amberjack and Triggerfish issue in a timely manner. This would also allow the Council to wait on a decision for Grouper until the latest, and presumably more accurate, data is available. I want to again state my support for splitting Amendment 30 so that immediate measures may be taken on Amberjack and Triggerfish and Grouper can then be managed separately with the best available data. Please split Amendment 30.
In the event Amendment 30 continues in its present form I would like to offer a few comments regarding Red and Gag Grouper.
In the Council’s own scoping document they write:
"Red grouper and gag comprise the major components of the shallow-water grouper aggregate, but until now have been managed separately, with management measures for one stock having consequences for the other stock. A purpose of this amendment is to co-manage gag and red grouper by implementing concurrent management measures."
But then in the Council’s action statements they propose raising the Red Grouper limits 15% and reducing the Gag limits by 10-11%. By the Council’s own statement wouldn't increasing the Red Grouper TAC by 15% also increase the Gag catch/discards by that same amount, thereby making a 10-11% reduction actually a 4-5% increase in Gag mortality? Therefore by increasing the Red Grouper TAC the Council would be contributing to Gag overfishing.
Again, according to the Council’s own statement, Red and Gag Grouper should be managed together, not separately.
From the Council’s Amendment 30 Scoping Document I quote:
"Approximately 99 percent of the landings (of Red Grouper) were from the west coast of Florida and the rest were from Alabama".
So by its own admission the Council is proposing legislation that would affect the entire Gulf of Mexico Grouper fishery in order to address an overfishing situation that can only possibly occur off the west coast of Florida, since Gags and Reds are to be managed together, not separately, and 99% of Red Grouper landings came from the west coast of Florida.
I contend that the Council can not effectively manage the Grouper fishery, nor any reef fish fishery for that matter, on a Gulfwide basis. If Gag Grouper are being overfished in conjunction with the Red Grouper fishery then this is clearly a Florida issue and should be managed accordingly.
I propose that the Council split the Gulf into separate Reef Fish management zones. I propose three zones, an Eastern Zone to comprise the entire west coast of Florida from the Keys to the Alabama state line. A Central Zone would comprise Alabama, Mississippi and Louisiana. A Western Zone would include the entire Texas region. These zones should then be used in the management of all reef fishes, not just Grouper.
This allows the Council to address the shallow water reef fish fishery in Florida, which by the Council’s own admission is a unique situation, separately from the deeper water fishery around the oil rigs of the Central Gulf coast, and also separately from the Texas coast which differs again from either of the other two zones.
Again, it is my hope the Council will split Amendment 30 in order to consider the new Grouper data. If not then we must utilize the data included in the Amendment 30 Scoping Document.
With regard to the Gag Grouper stock, the Council has no idea what the minimum stock size should be, no idea what the stock overfishing level is and no idea what the optimum yield should be. Reductions or increases in limits based on the data included in this scoping document is therefore akin to creating a household financial budget without knowing how much money you make, how much money you spend, or how much money you need to live on. You just figure you are probably spending too much money so you’ll decrease your expenditures by 10-15% and see if the bill collectors stop calling.
Two of the Council’s action plans for Red Grouper include increasing limits. By their own admission the Council, by that action, would then be contributing to the overfishing of Gag Grouper as Gag Grouper are linked, as bycatch, with the Red Grouper fishery.
Personally I have been fishing off the coast of Louisiana now for about 7 years. I have never caught a Red Grouper. I can't remember ever catching a Gag Grouper that was undersized. Yet the Council’s report states that Red Grouper landings in 2004 (according to table Red-1) were 8.7 million pounds for the combined sectors and Gag Grouper landings in 2004 (according to Table Gag-1) were roughly 7.8 million pounds for the combined sectors. That means that more Red Grouper were landed than Gag which in its own scoping document the Council states occurs 99% of the time in the waters off the west coast of Florida.
Again reinforcing the need for separate management zones for all reef fish.
Table Gag-1 also states that recreational landings in 2004 were 4.9 million pounds and dead discards of (presumably undersized) Gags for the recreational sector were 9.1 million pounds in 2004. This means that for every Gag that was retained, i.e. landed, by the recreational sector almost two fish were thrown back (again presumably undersized) as dead discards. Since Grouper are routinely brought up from depth and can not be reliably released in viable condition I propose the Council change the rules regarding Gag Grouper retention. Assuming a five fish aggregate limit the retention rules should state that the first Gag Grouper caught, up to the possible five fish limit as part of the aggregate, regardless of size, are to be kept and no culling of catch is allowed. In the Council’s scoping document they state that,
“The Council has requested analyses for reducing the 22-inch minimum size limit. Reducing the minimum size limit would decrease dead discards, but would increase fishing mortality and result in less gag becoming mature before harvest, and would likely increase the rate of retained harvest. To offset increases in fishing mortality, additional regulations would likely be necessary to constrain harvest.”
I do not agree with this statement. Decreasing the minimum size to first fish caught, no culling of catch, would completely reduce the 9.1 million pounds of recreational dead discards to zero. Assuming this 9.1 million pounds is already undersized fish the resulting increase in harvest of undersized fish will not outweigh the savings of 9.1 million pounds of dead discards. From the Council’s own document, regarding recreational fishermen, “few anglers harvest more than three gag currently.” If that is true then according to table Gag-1 for each of those three Gags that are landed almost six are discarded dead. That means that the average fisherman kills nine Gags on an average fishing trip. If they are restricted to first fish, no culling, then leaving the limit at five would result in the average fisherman having only the possibility of killing five fish, A FOUR FISH PER AVERAGE FISHERMAN SAVINGS. Assuming a four fish savings out of an average nine fish kill this is a 44% savings which would immediately end overfishing of Gag Grouper stocks and contribute considerably to an abundance.
In summary I ask the Council to split Amendment 30 into two separate amendments in order to address the Grouper stocks utilizing the new data and allowing immediate action on the Amberjack and Triggerfish issues.
I also ask the Council to separate the Gulf of Mexico managed area into three separate zones as outlined above in order to more effectively manage reef fish stocks.
I also ask the Council to implement a “first fish caught, no culling” rule for Gag Grouper based on the data in the Council’s Amendment 30 Scoping Document. If this data is revised and the Council sees fit to split Amendment 30 so that this new data may be analyzed before a decision is made then I may amend this position. But based on the discard data included in the scoping document a first fish caught rule will save fish and end overfising.
With regard to Amberjack and Triggerfish I would ask the council to implement their alternative for an increase in the size limit of Amberjack and Triggerfish with no seasonal closure and no decrease in bag limits.
Again, thank you for your work on this important issue. May we all be good stewards of the sea and its resources.
Captain Al Domescik
A private hook and line fisherman speaking up for myself.
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