Zales Comment on FR Doc # 07-05245

December 6, 2007 Peter Hood NOAA Fisheries Service Southeast Regional Office Sustainable Fisheries Division 263 13th Ave. South St. Petersburg, FL 33701 Sent Via Fax; 727-824-5308 RE: 0648-AT87 Dear Mr. Hood, On behalf of the Panama City Boatman Association I wish to submit comments regarding Amendments 27/14 and the economic devastation associated with these amendments. The data that was used to disallow the 10% reduction in effort was flawed. The increase in landings associated with region 1 on the west coast of Florida was skewed due to questionable reporting on whether fish were landed in state or federal waters. Due to the fact that state waters experience the vast majority of effort when these fish were extrapolated throughout state water trips it showed an unrealistic amount of landings. As you are aware the State of Florida kept their waters at a 4 fish bag limit so when anglers were questioned where they fished they were forced to say state waters for fear of violations being brought against them. Reports from our membership state that the number of trips fished in July and August were down up to 60% from previous years. According to the last stock assessment the Florida Panhandle landed 34% of the recreational landings of red snapper. Reports from charter industry vessels and the members of our association indicate loss of trips from 20-60% for 2007 due to the current interim rule. Several vessel owners have reported they can no longer remain in the business and have placed their vessels on the market. The economic impact associated with reducing the season by over 2 months and cutting the bag limit in half is resulting in small businesses closing their doors. The EIS associated with Amendment 27 grossly underestimates the losses, both social and economic that have and will occur as a result of the proposed rule. NATIONAL STANDARD 8 clearly says that the social and economic impacts to communities should be considered when creating new regulations and the fact that the EIS is seriously flawed shows that the real social and economic impacts have not been considered. Our coastal communities will suffer unnecessarily in 2008 with a shorter season and lower bag limit, however by the end of the year it will be to late to say the NMFS was wrong and the reduction in effort was greater than 10%, these businesses will be gone! The NMFS has used skewed EISs in the past to indicate minor impacts to communities when the real impacts have created real problems, i.e.: red grouper, vermilion snapper. We respectfully request that you reconsider the 10% reduction in effort, as we believe it is a conservative estimate. Sincerely, Robert F. Zales, II President Panama City Boatman Association