I am writing in support of all actions contained in Amendment 18B. The separation of the commercial ACL between longline (75%) and hook and line or bandit gear (25%) will finially allow the bandit fishermen to participate in the fishery under a defined allocation. Under current regulations the commercial ACL is prosecuted under a 4,000 pound trip limit. If 75% of the allocation is landed by September 1st the trip limit is reduced to 300 pounds. In recent years the longline fishery has been over the allocation which has precluded the 300 pound trip limit from being implemented. Also, in earlier years longline fishermen dominated production during the 300 pound trip limit. When this regulation was implemented it was the council's expectation that longline fishermen would not participate during the 300 pound trip limit. They not only participated but dominated landings during this period. The council has a history of making provisions to support the continued participation of the bandit fishermen. In Amendment 13C the council included a provision for a portion of the quota to be set aside and be landed under a 300 pound trip limit. Allocating 25% of the commercial allocation to bandit gear will allow the fishery to be open during a longer time period providing golden tilefish to the public for a much longer timeframe. Thanks for the opportunity to comment on this issue.
Comment from Ben Hartig
This is comment on Proposed Rule
Fisheries of the Caribbean, Gulf of Mexico and South Atlantic: Snapper-Grouper Fishery off Southern Atlantic States; Amendment 18B
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