Comment on FR Doc # E8-08756

The current IFQ gulf red snapper program is not fair. Small boat operators like myself were discriminated against when the red snapper IFQ allocations were given out. Most of my qualifying poundage was caught from a 20 foot center console boat. Bound by 200 pound trip limits before the IFQ and seasons that started on the first 10 days of the rough sea months of February and March, small boats couldn't get out many days to fish. From the 5 best years I had out of the 7 years used for the compilation of my historical snapper catches, one year my total catch suffered greatly because that fall season a hurricane pushed in tons of small red grouper off Pensacola and snappers couldn't be caught within my range. All you could catch was small red grouper. That off year included in my 5 best years for determining my IFQ reduced my total allocation percentage because the fall season was when the bulk of my snapper catches occured. This year I was allocated 2656 pounds of red snapper and I caught it in 8 short day trips on my small boat. I basically was done by 4/2/08 and was just saving my last 131 pounds for the fall. When fuel prices started climbing, I elected to finish up my allocation on 5/13/08. I also charter fish and with the shorter federal red snapper season and limits, my charter business is down 60% compared to last year. The bigger boats with their 2000 pound limits before the IFQ could go out in rough conditions and compile massive historical catches. Small boats were discriminated against because they were limited to 200 pound trip limits and calm sea conditions.