I have some serious concerns about these triggerfish regulations. The data clearly VERY CLEARLY shows that it is a regional issue. My concern is about precedent. This is the perfect example of a problem that should be managed on a regional basis. If they won’t take steps to do it for something as uninteresting as a triggerfish, will they every take a regional management position?

Also, how many hits do recreational anglers need to take on Amberjack? Haven't we done our part already? It seems to me that the commercial guys need to step up a bit more when it comes to this fishery.

Come on Texas guys. I've highlighted your options.

Gulf Council Seeks Public Input on Proposed Reef Fish Amendment 30A - Greater Amberjack and Gray Triggerfish – and Reef Fish Amendment 29 – Grouper Effort Management

Tampa, Florida – August 20, 2007 * The Gulf of Mexico Fishery Management Council (Council) has scheduled a series of Gulf wide public hearings and scoping meetings to solicit public comment on two proposed Amendments.

The first amendment - Amendment 30A to the Reef Fish Fishery Management Plan - contains potential management measures to modify the rebuilding plan for greater amberjack and to establish a rebuilding plan for gray triggerfish in order to end overfishing and rebuild the stocks of both species. These measures would reduce the directed greater amberjack harvest by 32% and reduce harvest of gray triggerfish by 49%.

Greater amberjack have been under a rebuilding plan since 2003, but a new stock assessment concludes the stock remains overfished and is undergoing overfishing. Gray triggerfish are also overfished and undergoing overfishing, according to another recent stock assessment.

Amendment 30A also contains management measures that consider re-allocation of the greater amberjack and gray triggerfish resources between commercial and recreational fishers, as well as accountability measures to ensure compliance with the rebuilding plans.

The second amendment - Reef Fish Amendment 29 - is in the scoping phase and aims at rationalizing effort and reducing overcapacity in the commercial grouper fishery. Included in the draft document are five options for making the grouper fishery more efficient. These options include:

· Eliminating latent permits
· A buyback or buyout program
· Permit endorsements
· Individual Fishing Quota (IFQ)
· Individual Transferable Effort Quota (ITEQ)

Interested parties are encouraged to participate in this process. While written comments on both documents should be received no later than October 25, 2007, comments on the Amendments will be accepted throughout the process. Copies of the scoping document for Amendment 29 and the draft public hearing document for Amendment 30A can be obtained by calling the Council at 813-348-1630, or by e-mailing the Council at gulfcouncil@gulfcouncil.org.

For stakeholders and other interested parties who are unable to participate in the meetings, comments and suggestions can be submitted to the Council via e-mail: Amendment29scoping@gulfcouncil.org for Amendment 29, and Amendment30A@gulfcouncil.org for Amendment 30A. Comments may also be submitted via US mail: 2203 N. Lois Avenue, Suite 1100, Tampa, FL 33607, or by fax: (813) 348-1711. Other opportunities to provide input on these amendments will include a series of public hearings for Reef Fish Amendment 29, final public hearings on both issues, and open public comment sessions held during each Council meeting.

All public hearings begin at 6:00 p.m. with Amendment 30, followed by the scoping hearing for Amendment 29. Meetings will conclude by 10:00 p.m.

Meeting dates and locations are as follows:

September 10, 2007
W Hotel
333 Poydras Street
New Orleans, Louisiana
501-525-9444

Wingate Inn
12009 Indian River Road
Biloxi, Mississippi
228-396-0036

September 11, 2007
Courtyard by Marriott
3750 Gulf Shores Pkwy
Gulf Shores, Alabama
251-968-1113

Holiday Inn
5002 Seawall Blvd.
Galveston, Texas
409-740-3581

September 12, 2007
Palacios Recreational Center
2401 Perryman
Palacios, Texas
361-972-2387

Edgewater Beach Resort
11212 Front Beach Road
Panama City, Florida
800-331-6338

September 13, 2007
Holiday Inn Emerald Beach
1102 S. Shoreline Blvd.
Corpus Christi, Texas
361-883-5731

September 17, 2007
Radisson Hotel
12600 Roosevelt Boulevard
St. Petersburg, FL 33716
727-572-7800

September 18, 2007
Sombrero Cay Club Resort
19 Sombrero Blvd.
Marathon, Florida
305-743-2250

September 19, 2007
Clarion Hotel
12635 S. Cleveland Avenue
Ft. Myers, Florida
239-936-4300

Meetings are open to the public and are physically accessible to people with disabilities. Requests for sign language interpretation or other auxiliary aids should be directed to the Council office within five business days of the meeting date.

The Gulf of Mexico Fishery Management Council is one of eight regional fishery management councils established by the Magnuson*Stevens Fishery Conservation and Management Act of 1976. The Gulf of Mexico Fishery Management Council prepares fishery management plans designed to manage fishery resources in the U.S. Gulf of Mexico.

Hope they get the document ready in time for the hearings.

From: Charlene Ponce [mailto:Charlene.Ponce@gulfcouncil.org] On Behalf Of GulfCouncil
Sent: Wednesday, August 22, 2007 8:05 AM
To: John Little
Subject: RE: Amendment 30A

Mr. Little:

The revised version of Amendment 30A will be available later this week. I’ll be happy to send you an electronic copy then.

Sincerely,

Charlene Ponce
Public Information Officer
Gulf of Mexico Fishery Management Council
813-348-1630 ext. 229
Charlene.ponce@gulfcouncil.org

There's a lot of us planning to attend the east coast meetings. I've reviewed the original version of Ammendment 30A, and it was confusing. The only thing I can see is that they're considering several optioins for restricting both commercial and recreational harvest limits.

When the revised version of the ammendment comes out, Can we expect the FRA to publish a statement of position on the matter before the meetings begin? It would be nice to have some 'marching orders' so we don't just show up at the meeting without an agenda.

South Atlantic Gag Grouper and vermillion public comments public comments


Schedule for Snapper Grouper Amendment 16 (Gag grouper & Vermilion snapper):
Scoping through September 17, 2007
Council reviews Options Paper & provides direction to Staff/Team – September 17-21,
2007 meeting
Scientific & Statistical Committee reviews Amendment/Draft Environmental Impact
Statement (DEIS) at their December 2-4, 2007 meeting
Council approves Amendment/DEIS for public hearings – December 2-7, 2007 meeting
Public hearings – January/February 2008
Council reviews public hearing input and approves actions – March 3-7, 2008 meeting
Council reviews and approves final Amendment/FEIS for formal review by the
Secretary of Commerce – June 8-13, 2008 meeting
Intent to have regulations in place – January 1, 2009



We are concerned that F (fishing mortality; the percentage of the population that dies each year from fishing) is overstated partly because it is based on 1. Marine Recreational Fishing Statistical Survey (MRFSS) estimates of landings and discards, which have been declared unreliable and even ‘fatally flawed’ and 2. An overstated recreational release mortality of 26%.

The recreational release mortality is unrealistically high at 26% and should be 10-15%. This mortality rate is primarily based on a study which consisted of deep drops using electric reels in a commercial setting and is in no way representative of the recreational release mortality
Cited studies had long times on deck (2-5 minutes) for measuring and handling before being released, adding to the barotrauma experienced by the fish and also increasing the mortality of the fish.. The Gulf red grouper study accounted for this.
The Gulf of Mexico Red Grouper assessment used a 10% release mortality for recreational discards, 45% for commercial. Why are ours so different?


There is a Florida Headboat survey underway which shows that observed release mortality is less than 2% for grouper caught between 20 meters and 40 meters of depth. (Florida Fish and Wildlife Research Institute)

The gag assessment should be redone. There are too many uncertainties and inconsistencies to move forward with an assessment that will affect such a large fishery. - The Gulf Gag assessment has been reviewed due to some of the same questions. There were many corrections and this was done in less than 6 months.
.

Recreational effort is significantly reduced and is not taken into account when calculating future estimates. Fuel prices have driven the reduction in trip frequency and the increase in cost per trip. MRFSS is usually a year or two behind in estimating this trend, so we are worried about over-regulation.

Calculating Annual Catch Limits should be done in a less ‘precautionary’ manner, as there are speedy mechanisms to put increased restrictions on a fishery, yet there are no such speedy mechanisms to decrease restrictions should a fishery’s biomass increase to healthier levels.

Captain and Crew bag reduction: No quantifiable benefits. There is no basis for any estimate of the amount of reductions in landings realized by this option.

Allocation:
What percentage of recreationally counted fish are also being counted on the commercial side, being double counted and amplifying the commercial allocation?
What would a reduction in recreational bag limits do to the commercial landings?

Economic impact of recreational fishing is underestimated.

Marine Protected Areas are unacceptable as a management tool. Until they can provide a quantifiable benefit, there is no place for them in a management plan. They are useless as management tools and should not be promoted as having any quantifiable benefit.
If a bad decision was made, it can be reversed.


Vermillion Snapper-
If there is no confidence in the estimation of biomass, what degree of confidence is there in the assessment status of overfishing? What is wrong with the assessment? Why was the Gulf Vermillion in trouble, then miraculously declared recovered and never in trouble in the first place?

Only modest bag limit decreases or modest size limit increases would be considered acceptable.

Thanks for taking the time to post this Denny.

Hearings in Galveston are tonight. I've got a white button-down and the same goatee. Hope to see some of ya'll there.

Galveston is a Gulf Council hearing. Stabbin was talking South Atlantic.
The Gulf comments will be posted in an hour for Amendment 30A.

Galveston is a Gulf Council hearing. Stabbin was talking South Atlantic. I had forgotten how massive the original 30A was. Glad they at least broke it up.

Although I do not have a current affiliation with them, I thought this was pretty well written:

Background
1990: Management was initiated in Amendment 1 to the Gulf Reef Fish Plan with a recreational bag limit of three fish per angler per day and a 28-inch minimum size. Commercial folks resisted the quota at the final hearing and instead received a larger (36-inch) minimum size. The allocation was formally adopted at 84% (recreational) and 16% (commercial).

The amendment document noted (p. 247): "Since 1979, the recreational sector has taken about 86% of the total harvest; however the proportional commercial harvest has increased from less than 5 percent prior to 1982 to 34 percent in 1987." Clearly the Council was trying to stabilize the fishery at its historic allocation ratios and prevent expansion of the commercial sector.

These actions were supposed to produce a 45% reduction in harvest for both sectors. However, there was no 45% reduction in commercial harvest. In the four years prior to 1990 annual recreational landings averaged 4.45 million pounds, commercial landings 1.65 million pounds. In the four years from 1990 to 1993 annual commercial landings averaged 1.29 million pounds – or only a 22% reduction. In the same years recreational landings were reduced by 42%.

1997: Recreational bag limit reduced to 1 fish per angler per day at the request of the recreational sector because of concerns that amberjacks were continuing to fall in abundance.

1999: Because commercial catches were not being constrained effectively, a one month closed season was added to the commercial sector. In the following year, despite the closure, commercial landings increased from 777,190 pounds to 921,795 pounds. When the one-month closure was proposed CCA had argued that it would simply allow effort to shift to the other months and would not reduce catches.

The 2006 assessment showed that the fishing mortality (F) level that would yield MSY was Fmsy = 0.57. At that time, estimated 2004 fishing mortality was F2004 = 1.52, so the F level was at 152% of the needed level. Although this assessment was recognized to be a bit shaky by both the assessment group and the reviewers, CCA has not argued against its conclusions and we have supported the needed conservation goals.

At present, the effective allocation of catch is 68% (recreational) to 32% (commercial) - solely as the result of a failure to limit commercial harvest effectively.

The economic analyses of the allocation alternatives (p. 133 - 136 Public Hearing Document for Amendment 30A) shows a net gain in "economic value" of $1.1 million for status quo (84% recreational to 16% commercial); a net loss of $1.1 million for Alternative 2 (60% recreational to 40% commercial); and a net gain of $0.29 million for the selected preferred option (71% recreational to 29% commercial). The economics (and this is value, not total impact which would yield much higher numbers) argues for status quo on the allocation.

The same document (p.15, Table 2.1.1) shows the needed reductions in harvest to achieve the conservation goal given different allocations.
At the status quo (Alternative 1, 84% recreational to 16% commercial), recreational harvest would be reduced 15%, commercial harvest 67%.

Alternative 2 (60% recreational to 40% commercial) would require a 40% recreational reduction and a 15% commercial reduction.

The preferred alternative (3) using average catches from 1981 - 2004 (71% recreational to 29% commercial) would require a 29% reduction in recreational catch and a 38% reduction in commercial.

Table 2.1.6 (p. 25) shows catch reductions for the recreational sector that would be afforded by increases in the size limit. Increasing the size limit to 30 inches would yield a reduction between 14.3% and 16.1 % (depending on release mortality, 20% or 10%), basically achieving the conservation goal if the status quo allocation is maintained. CCA believes 10% is likely the best estimate of release mortality. Going to 31 inches would yield a reduction of 23% to 26%.

Speaking Points for Public Hearings
Amberjack
• The only reason that the recreational share of this fishery fell to 68% at present was the failure of the National Marine Fisheries Service and the Gulf Council to control commercial harvest.

• There is no sense of fairness or good governance in forcing the recreational sector to suffer from the lack of controls over the commercial fishery.

• The regulations implemented in 1990 were supposed to yield a 45% reduction in commercial and recreational landings. According to the data in Table 1.1.1 of the public hearing document, in the three years following implementation of those regulations commercial landings dropped only 23%. Why was this failure to attain the conservation goal allowed to continue?

• Commercial landings have never been controlled and this is the mainly the reason that the stock is overfished.

• The proposed bag limit is overly confusing and is not consistent with any bag limit set previously by this Council or any Gulf state.

• There has never been a re-allocation of resources from the commercial to the recreational sector in the history of the Gulf Council’s operations.

• The allocation does not need to be changed; it needs to be enforced.


I still think triggerfish is a regoinal issue and should be dealt with as such.

September, 2007

FRA position statement for public input hearings for final action on the Gulf Council’s Amendment 30A, Greater Amberjack and Gray Triggerfish
click here for a draft of the hearing document (http://www.gulfcouncil.org/Beta/GMFMCWeb/downloads/BB%202007-08/A-July-23-07-RF-30A.pdf)
GREATER AMBERJACK

Action 1. Modifications to Greater Amberjack Allocations –
We support Alternative 1 Status Quo No allocation change
The recreational anglers agreed to one fish long ago as a conservation measure. We have not met our quota since undergoing the one fish bag limit regulation. The commercial sector has gone over its quota since 1990 and now wants credit for that proportion of the landings. This is wrong and punishes the recreational angler for taking conservative measures to ensure a sustainable fishery.

Action 2. Modifications to the Greater Amberjack Rebuilding Plan
We support the Preferred Alternative 2. Modify the rebuilding plan specified by Secretarial Amendment 2. It reads:
Directed TAC levels for the 2008 through 2012 would be set at the directed yield for
each year as defined by the constant FOY projection from the 2006 assessment. TAC for
2008 would be 1.9 mp, TAC in 2009 would be 2.5 mp, TAC in 2010 would be 3.1 mp,
TAC in 2011 would be 3.5 mp, and TAC in 2012 would be 3.7 mp.
Given that the assessment is so uncertain, this will allow us to maintain a sustainable harvest while we gather further information on the fish.

Action 3. Accountability Procedures for the Greater Amberjack Rebuilding Plan
We support Alternative 1. No action. Do not establish an accountability procedure for the greater amberjack rebuilding plan.

We are concerned that MRFSS ( Marine Recreational Fishing Statistical Survey) would be used as the landings figure by which the RA could adjust the quota. MRFSS is NOT an in season or even year to year reliable indicator of landings.

Action 4: Greater Amberjack Recreational Management Alternatives
We support none of the listed alternatives and ask that the following alternatives be considered as preferred. We oppose any reallocation of the fishery. The recreational sector conserved while the commercial sector went over their quota unrestrained. Fair is fair. The recreational sector should not be punished for conserving their portion of allowable landings.

We support ADDING Alternative 6 - A one amberjack per day per angler limit, 30 inch minimum and making it the Preferred Alternative. Captain and crew are excluded from retaining their catch. This achieves a 20% reduction, which is all the recreational sector needs to take.

The recreational sector relies on the opportunity to fish as an economic driver. One fish per day per angler is the lowest acceptable limit for Greater Amberjack.



Action 5: Greater Amberjack Commercial Management Alternatives
We support No reallocation. We support managing the fishery with a quota.


GRAY TRIGGERFISH

Action 6: Thresholds and Benchmarks for Gray Triggerfish
We support Preferred Alternative 2. Set MFMT equal to FMSY (proxy = F30%SPR); set MSST equal to (1-M)*SSBMSY (proxy = (1-M)*SSB30%SPR); and set OY as the yield associated with:
Preferred Option a: 75 percent of FMSY (proxy = F30%SPR) when the stock is at
equilibrium

Action 7. Gray Triggerfish Rebuilding Plan
We support Alternative 2. Establish a constant F rebuilding plan for gray triggerfish defined by the constant FOY projection from the 2006 assessment. Directed TAC levels for the 2008 through 2012 would be set at the directed yield for each year; TAC for 2008 would be 0.5 mp, TAC in 2009 would be 0.58 mp, TAC in 2010 would be 0.66 mp, TAC in 2011 would be 0.73 mp, and TAC in 2012 would be 0.79 mp.

Action 8. Accountability Procedures for Gray Triggerfish
We support Alternative 1. No action.
Do not establish an accountability procedure for the gray triggerfish rebuilding plan.
The Council could address landings overages and implement management measures to constrain harvest to TACs specified in the preferred rebuilding plan by developing a regulatory amendment to the Reef Fish FMP.

Action 9. Modifications to Gray Triggerfish Allocations
We support Alternative 1. Status Quo
Maintain allocation of gray triggerfish TAC between the recreational and commercial fisheries as the average share during the years 1981 through 1987. The recreational fishery would receive 93 percent of the TAC and the commercial would receive 7 percent.

Action 10. Gray Triggerfish Regional Management.
We support Preferred Alternative 1.
No Action. Manage gray triggerfish on a Gulfwide basis. Implement Gulfwide management measures to reduce gray triggerfish landings by 49 percent overall to end overfishing and rebuild the stock.


Action 11. Gray Triggerfish Recreational Management Alternatives
We support ADDING Alternative 5. Increase size to 13” for a 42% reduction, which exceeds the required 40% reduction with no reallocation of the fishery.

Action 12. Gray Triggerfish Commercial Management Alternatives
We support NO REALLOCATION. We also support management by establishing a quota.

Meeting times and locations:
All meetings begin at 6:00 p.m. local time ending no later than 10:00.

September 12, 2007
Palacios Recreational Center
2401 Perryman
Palacios, Texas
361-972-2387

Edgewater Beach Resort
11212 Front Beach Road
Panama City, Florida
800-331-6338

September 13, 2007
Holiday Inn Emerald Beach
1102 S. Shoreline Blvd.
Corpus Christi, Texas
361-883-5731

September 17, 2007
Radisson Hotel
12600 Roosevelt Boulevard
St. Petersburg, FL 33716
727-572-7800

September 18, 2007
Sombrero Cay Club Resort
19 sombrero Blvd.
Marathon, Florida
305-743-2250

September 19, 2007
Clarion Hotel
12635 S. Cleveland Avenue
Ft. Myers, Florida
239-936-4300

For more info go to www.gulfcouncil.org

Good stuff Denny. The council likes to hear people supporting one of the alternatives that are being considered. They don't place a lot of emphasis on testimony to something that isn't on the table. Denny has done a good job of laying that out for us. 297 pages is a lot to read and, although you should read it, I can say that I agree with the alternatives chosen above.

There were 3 people at the hearing last night. CCA, me, and one OC guy. Hearing ran 1:15 with me taking up most of the time at the podium.

Don't forget guys, you can submit written comments to the council up until 10-18-07 and the council is strongly encouraging people to do so. So, if you can't make one of the hearings at least take the time to send a friggin' email. They want you to give a brief rundown of your experience and interest in the fishery. If you present any data then give a source. Then just tell them what you see out there and what alternative you support!

Right you are about sending comments, John.
One can email their comments to gulfcouncil@gulfcouncil.org.
One is also suggested to fax our state's recreational representative on the Council, who, by the way, VOTED TO GIVE AWAY OUR ALLOCATION!!
Mr. Bill Daughdril should be contacted. Request a response from him regarding his logic for supporting the reallocation. Let him politely know that you expect him to defend our allocation and make valid arguments to the Council for keeping the allocation the same.

NOTE NOTE NOTE
I edited the first paragraph of the FRA position (above) in action1.
I had the old text in there which was incoplete and incongruous.
Sorry

Please note, this is an error!

Captain and crew are excluded from retaining their catch. This achieves a 20% reduction, which is all the recreational sector needs to take.

Denny asked me to point out that this is a typo and a corrected version will be published soon. The impact of these citizens is minimal to the fishery, and whats more important, the FRA is opposed to any effort to remove their right to fish.

Revised position on Gulf issues:

GREATER AMBERJACK

Action 1. Modifications to Greater Amberjack Allocations –
We support Alternative 1 Status Quo No allocation change
The allocation shall remain at 84% recreational 16% commercial, which was set in amendment 1 in 1990.
The years used to set this allocation were 1981 thru 1987 and were chosen due to the fact that those years had the least amount of government regulations imposed on anglers in both the recreational and commercial sectors. This time period indicated a more natural state of fishing, as opposed to a later time period during which the social behavior of fisherman had been changed by regulations.

Action 2. Modifications to the Greater Amberjack Rebuilding Plan
We support the Preferred Alternative 2. Modify the rebuilding plan specified by Secretarial Amendment 2. It reads:
Directed TAC levels for the 2008 through 2012 would be set at the directed yield for
each year as defined by the constant FOY projection from the 2006 assessment. TAC for
2008 would be 1.9 mp, TAC in 2009 would be 2.5 mp, TAC in 2010 would be 3.1 mp,
TAC in 2011 would be 3.5 mp, and TAC in 2012 would be 3.7 mp.

Given that the assessment is so uncertain, this will allow us to maintain a sustainable harvest while we gather further information on the fish.

Action 3. Accountability Procedures for the Greater Amberjack Rebuilding Plan
We support Alternative 1. No action. Do not establish an accountability procedure for the greater amberjack rebuilding plan.

We are concerned that MRFSS ( Marine Recreational Fishing Statistical Survey) would be used as the landings figure by which the RA could adjust the quota. MRFSS is NOT an in season or even year to year reliable indicator of landings, as stated by the National Research Council’s 2006 report on MRFSS.

Action 4: Greater Amberjack Recreational Management Alternatives
We support none of the listed alternatives and ask that the following alternatives be considered as preferred. We oppose any reallocation of the fishery.
We support ADDING Alternative 6 - A one amberjack per day per angler limit, 30 inch minimum and making it the Preferred Alternative.

According to Stu Kennedy, Gulf Council staff biologist, this option would result in an 18% decrease in recreational harvest. With the 84% allocation to the recreational sector, we only need a 15% reduction for the recreational sector.

The recreational sector conserved while the commercial sector went over their quota unrestrained for years. The recreational sector should not be punished for conserving their sustainable resource. Fair is fair.

The recreational sector relies on the opportunity to fish as an economic driver. One fish per day per angler is the lowest acceptable limit for Greater Amberjack.

Action 5: Greater Amberjack Commercial Management Alternatives
We support NO REALLOCATION. We support the establishment of management measures which will constrain the sector to its quota.



GRAY TRIGGERFISH

Action 6: Thresholds and Benchmarks for Gray Triggerfish
We support Preferred Alternative 2.
It reads as follows: Set MFMT equal to FMSY (proxy = F30%SPR); set MSST equal to (1-M)*SSBMSY (proxy = (1-M)*SSB30%SPR); and set OY as the yield associated with:
Preferred Option a: 75 percent of FMSY (proxy = F30%SPR) when the stock is at
equilibrium

This is a fairly standard method of stock evaluation.

Action 7. Gray Triggerfish Rebuilding Plan
We support Alternative 2. Establish a constant F rebuilding plan for gray triggerfish defined by the constant FOY projection from the 2006 assessment. Directed TAC levels for the 2008 through 2012 would be set at the directed yield for each year; TAC for 2008 would be 0.5 mp, TAC in 2009 would be 0.58 mp, TAC in 2010 would be 0.66 mp, TAC in 2011 would be 0.73 mp, and TAC in 2012 would be 0.79 mp.

Action 8. Accountability Procedures for Gray Triggerfish
We support Alternative 1. No action.
Do not establish an accountability procedure for the gray triggerfish rebuilding plan.
The Council could address landings overages and implement management measures to constrain harvest to Total Allowable Catch as specified in the preferred rebuilding plan by developing a regulatory amendment to the Reef Fish FMP.



Action 9. Modifications to Gray Triggerfish Allocations
We support Alternative 1. Status Quo
Maintain allocation of gray triggerfish TAC between the recreational and commercial fisheries as the average share during the years 1981 through 1987. The recreational fishery would receive 93 percent of the TAC and the commercial would receive 7 percent.


Action 10. Gray Triggerfish Regional Management.
We support Preferred Alternative 1.
No Action. Manage gray triggerfish on a Gulfwide basis. Implement Gulfwide management measures to reduce gray triggerfish landings by 49 percent overall to end overfishing and rebuild the stock.

Action 11. Gray Triggerfish Recreational Management Alternatives
We support ADDING Alternative 5. Increase size to 13” for a 42% reduction, which exceeds the required 40% reduction with no reallocation of the fishery.

This is a small size increase and not a concern for anyone.

Action 12. Gray Triggerfish Commercial Management Alternatives
We support NO REALLOCATION. We support the establishment of management measures which will constrain the sector to its quota.

Hey thanks for taking the time to publish this. It sure helps to know what's goin on.

To be honest, I dont think there are a lot of people even looking at the triggers that much. Maybe the rest of the FRA is but when I spoke with the Council folks they actually asked me about triggers to which I told them I hadnt read much about it so I didnt have an educated opinion.
I think thats happening a lot. AJs are far more important but they are certainly drawing attention away from triggers so its likely they can slide in just about anything they want on it. It it very hard to believe that triggers can be all that overfished due to their feeding habits and size of thier mouths. Wouldnt be the first time a BS study was attempted to be used to stop fishing where not truly justified.

Ed,

At one of the Gulf Council meetings in Madeira beach they said part of the problem with triggers is they lay eggs and then sit on them, so when the trigger is caught and kept, not only does the Trigger die, but also the eggs it was sitting on.

Triggers are not a big deal to me, I could are less if I ever shoot another trigger.

Triggers make for some of the best ceviche meat their is.