Comment from David Plowden, fisherman

Thank you for your decision not to pass the interim rule. You were right that the benefits to the fisheries are outweighed by the cost to the fisherman's loss of income. The cost of Amendment 16 ( the closure of all groupers (black, red, scamp) for 4 months would be devastating to fishermen and the fisheries business. The benefits of Amendment 16 would probably not even be seen. Black grouper has been my only income since the early 90's even before the permits were required. Over this time I saw the size limit change from 18 to 24". This change seemed to help the stock although some years are going to be better anyway due to good year and bad year trends. The benefits are further reduced since the amount of fishing time is limited by the weather this time of year. Nature makes the rules during the winter months. One other point I'd like to make about data and statistics is these numbers can't possibly show what really living out there. For example, I fish about 15 different stops during a days fishing. On one stop I may catch about 5 groupers, these fish are dead. These fish are dead, but data uses the fish for data for what is living. This is flawed at the start. These 5 fish don't tell shat else was living under the boat at this stop. How many groupers did not want the bait? How many groupers took the bait but did not hook up? How many came off the hook on the way up? How many were so big they cut the line off on a rock? The data and statistics from these 5 dead fish cannot answer the questions about how many fish are actually living there. It's like trying to figure the population by counting the number of people dying and not really knowing how many are born. The data collected on groupers is too flawed to support amendment 16. The benefits of amendment 16 would also be outweighed by the cost to the economy. With the economy the way it is a 4 month closure would be the wrong direction. We have a domestic product here that would be replaced by an import. And these imports are probably being caught with little regulation in place. Please consider not doing the 4 month closure. David Plowden, Commercial Fisherman Regina Plowden, Fish Dealer