Comment from Capt Christopher Rooney, Jacksonville Offshore Sportfishing Club

Document ID: NOAA-NMFS-2008-0111-0078
Document Type: Public Submission
Agency: National Oceanic And Atmospheric Administration
Received Date: January 09 2009, at 09:41 AM Eastern Standard Time
Date Posted: February 25 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: November 7 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: February 23 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 80815ef2
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As my representative in Congress, I am forwarding this letter to you, written by Ms. Becky Hogan, co-owner of one of the longest-running headboat operations in northeast Florida, because you need to be aware of an imminent economic disaster in your district as well as other congressional districts in the states of Florida, North Carolina, South Carolina, and Georgia. I am an avid recreational fisherman, living and working within your district. While I am a recreational fisherman, these proposed changes outlined below by Ms. Becky Hogan, who may be contacted at (904) 514-5200, will virtually eliminate the headboat/for-hire charter fleet in your district, equating to millions of dollars in lost revenues for your district and the entire state of Florida. As you already know, the Census Bureau conducts the “National Survey of Fishing, Hunting and Wildlife-Association Recreation” every five years and, once again, Florida is the number one fishing destination according to the latest survey conducted in 2006. Anglers in our sunshine state spent $4.4 billion in 2006, more than any other state. These monies were spent on charter boat fishing, private recreational fishing, at boat retailers, obtaining fishing licenses, at tackle shops, marinas, gas stations, hotels, restaurants, etc. With an already weakening economy, imagine the extreme negative economic impact by approving Amendments or Interim Rules proposed by the South Atlantic Fishery Management Council (SAFMC) that will STOP fishing for many species beginning in January of 2009. As a representative of the 111th Congress, scheduled to start meeting January 6, 2009, you will need to closely monitor all of the activities by the SAFMC, who under the Magnuson-Stevens Fishery Conservation and Management Reauthorization Act of 2006 (MSA), have the responsibility to end over- fishing in Florida (as well as North Carolina, South Carolina, and Georgia) by 2010, for all species experiencing overfishing. The ability to continue to fish for/harvest red snapper in the State of Florida (east coast, Atlantic Ocean) by both recreational and commercial fishermen is in jeopardy. At the latest SAFMC meeting in Wilmington, NC (Nov 30- Dec 5, 2008), the Council revealed that a COMPLETE INDEFINITE CLOSURE of the red snapper fishing industry may be necessary to comply with the MSA. Management alternatives could include both time/area closures (FOR ALL SNAPPER/GROUPER SPECIES), as opposed to the use of reduced bag limits, and/or limited seasonal spawning closures. Data presented by members of the Council to support these potential closures at the past years’ meetings, where public testimony was heard, appears to be extremely INCONSISTENT with information provided during the public comment period by seasoned recreational, for-hire/headboat, and commercial fishermen, with regards to the condition of the red snapper stocks in northeast Florida. This public testimony IS SUPPOSED to be considered when evaluating alternatives to end alleged overfishing of red snapper. The potential for a COMPLETE RED SNAPPER CLOSURE comes on the heels of the Council’s recent approval of Amendment 16, which if approved by the Secretary, will include a yearly four month closure (January through April) for all shallow water grouper, to address overfishing of these species. Also included in Amendment 16 is a complete 5 month closure (November through March) for recreational harvest of vermilion snapper and a 50% reduction in the bag limit from current regulations (10 fish to 5 fish) during the open season. In accordance with the National Standards (Appendix D, MSA), conservation and management measures shall, consistent with the conservation requirements of this Act (including the prevention of overfishing and rebuilding of overfished stocks), take into account the importance of fishery resources to fishing communities in order to (A) provide for the sustained participation of such communities, and (B) to the extent practicable, minimize adverse economic impacts in such communities. I feel, along with many of my fellow constituents, that the SAFMC should inform the National Marine Fishery Service that additional time and funding is needed to accurately evaluate pertinent data and to include public testimony required under the MSA. These actions would serve to protect both our economy and our natural resources. The Council must be held accountable for insufficient data and poor time management affecting their decisions regarding MSA compliance, by presenting in laymen terms all quality control measures for assimilating and evaluating their data at future council meetings. The future of recreational fishing depends on it.

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Comment from Brian Thornton, Recreational
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Comment from Capt Christopher Rooney, Jacksonville Offshore Sportfishing Club
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