November 14, 2014
Mr. Robert Mahood
South Atlantic Fishery Management Council
4055 Faber Place Drive; Suite 201
North Charleston, SC 29405
Re: Snapper Grouper (SG) Fishery Management Plan (FMP) Regulatory Amendment 22 (RA-22) Three Actions for Gag Grouper and Wreckfish Annual Catch Limits (ACLs), Optimum Yield (OY) and Recreational Bag Limits
The Southeastern Fisheries Association (SFA) East Coast Fisheries Section (ECFS) submits this written comment to the South Atlantic Fishery Management Council (SAFMC) about the three actions and alternatives based on the recent stock assessments for changes to the Gag grouper and Wreckfish ACLs, OY and recreational bag limits found in the SG FMP RA-22. The SFA ECFS will select preferred alternatives for the three RA-22 actions described below. With Action 3 Preferred Alternative 2, the SG Advisory Panel (AP) as a consensus recommended that the 5% recreational allocation be reduced to 1%
and SFA ECFS supports that suggestion.
Action 1. Revise the annual catch limits (ACL) and optimum yield (OY) for gag
SFA ECFS Preferred Alternative 2. ACL = OY = ABC projected landings from 2015-2019 with P*=0.3. The ACL for 2019 would remain in place until modified.
Table S-1. ABC and ACLs for gag specified under Alternative 2 (Preferred) where ACL = OY = acceptable biological catch (ABC).
Action 2. Modify the recreational bag limit for gag within the aggregate bag limit
SFA ECFS Preferred Alternative 1 for No Action. Retain the current aggregate grouper bag limit of 3 fish. Within this limit, only one fish can be a gag or black grouper.
Action 3. Revise the annual catch limits (ACL) and optimum yield (OY) for wreckfish
SFA ECFS Preferred Alternative 2. ACL = OY = Proposed ABC. The ACL for 2020 would remain in place until modified.
Table S-8. ABC and ACLs for wreckfish specified under Alternative 2 (Preferred) where ACL = OY = ABC.
However the SFA ECFS does not support the allocation of 5% of the new ABC to the recreational sector. This choice is made because after investigation it does not appear that any recreational landings for wreckfish have been physically intercepted during recent years. The SFA ECFS would prefer to see a 1% allocation for the recreational sector with developing this new fishery as the SG AP recently chose, and reapply the remaining 4% back to the commercial sector allocation before finalizing SG RA-22.
Later, if the recreational sector can prove that they have been able to land the 1% allocation the SAFMC can choose to revisit this proposed action in a future amendment, perhaps after the next wreckfish stock assessment update.
Thank you for this opportunity to comment.
Jimmy Hull, Chairman