Comment from William Tucker

Please see attachment for Word file. Dear NOAA Fisheries Service, Fishermen’s Advocacy Organization strongly supports the implementation of Amendment 29 to the Gulf reef fish FMP. Finally, we will have the tools necessary to manage effort in the grouper fishery. We are happy to move beyond the traditional command and control structures of the past because of their inherent incentives to add capacity. This resulted in a cat and mouse relationship between regulators and fishermen, and excessive effort in the fishery. IFQ’s, in contrast, align the incentives for resource conservation with the economic well-being of fishermen. Because IFQ shareholders will be individually limited to harvesting only a percentage of the commercial quota, there is an incentive for fishermen to act responsibly, and avoid wasting fish that could expand the biomass if only left alive in the water to spawn again. The attitude toward eliminating waste will evolve quickly because the health of each fisherman’s business is directly linked to the health of the fish stock as a whole, and the benefits are tangible and countable. Because of the proprietary attitude that catch shares promote toward the resource, stakeholders become stewards. We particularly like that the IFQ is inclusive of small-scale fishermen. Even though some operators will choose to exit the fishery, it is noteworthy that their exodus will be voluntary. This is in sharp contrast to the traditional “Limited Entry” minimum landing thresholds that effectively ejected small-scale operators from the fishery. Additionally, we recognize the management streamlining that accompany catch share management, and the shifting of responsibility to the fishermen to decide on an individual basis how best to navigate such things as reduced commercial quotas and annual allocations. Fishermen’s Advocacy Organization strongly supports the implementation of the Gulf of Mexico grouper-tilefish IFQ. William E Tucker Pres. Fishermen’s Advocacy Organization PO Box 222 Dunedin, Fl 34697