Comment from Troy Sapp, Florida Guides Assoc.

Amendment 30 B will require a person aboard a federally permitted Gulf of Mexico commercial or for hire reef fish vessel to comply with federal regulations for reef fish species regardless of where the fish are harvested to increase compliance with federal regulations. The NMFS is once again trying to segregate the charter community from the recreational sector with this action and in this case is grouping charter boats with commercial fishing vessels. This action will continue to set a dangerous path for recreational fishing as it is intended to divide what has been historically one entity. This rule under the guise of non compliance is doing nothing more than stealing the opportunity for federally permitted charter boats to operate in state waters when federal waters are closed to reef fish. Charter boats do not sell fish, they sell opportunity for anglers to catch their legal recreational limits and should always be held to the same recreational rules. As for the closure to commercial fishing during this period I would agree. State waters historically have not been subjected to large scale industrial fishing operations due to destructive gear being prohibited for many years now. This proposed rule also insinuates that only federally permitted charter boats “that have their business reputations at stake” would be of a greater non compliance threat than the thousands of recreational anglers and non permitted charter boats that would still be able to operate in state waters during the federal water closures. I would certainly like to see the science, if any, that would support this action. The FFWCC has not implemented a closure of state waters for reef fish. They are well aware of the recreational efforts and also realize that part of that effort comes from charter boats. If the time comes for reductions in total catch I can only presume that it will be an across the board reduction in total catch and will include the entire recreational sector. This presumption is based on past actions by the FFWCC to maintain fairness in fishery management and to assure the sustainability and wise use of the resource. Based on the lack of science and the singling out of one sector of the recreational angling community I respectfully request that amendment 30B be revised to eliminate special requirements for federally permitted charter boats that would be inconsistent with state laws while operating in state waters. Captains Troy and Jill Sapp Fins and Tails Guide Service Florida Guides Association Senior Vice President Tsapp22334@aol.com www.florida-guides.com