Shannon
10-07-2008, 09:38 PM
I got this email yesterday,
AMENDMENT 16 –PROPOSED GROUPER CLOSURE
&
INTERIM RULE TALKING POINTS
OCTOBER 1, 2008
Mr. Bob Mahood, SAFMC Executive Director and Dr. Roy Crabtree, NOAA Regional Administrator are both on record as saying the basis for the Council’s decision to close the shallow water grouper fishery for four months is based on the 2001 Potts/Brennan paper presented to the SAFMC.
The Potts/Brennan paper is a simple Catch/Curve Analysis and does not constitute a stock assessment and is therefore wholly inadequate to justify a closure. Seven years later, with such major economic consequences at risk, we have been assured by a stock assessment scientist that this Catch/Curve analysis, even if conducted today, much less seven years ago, would not be approved as best available science for determining the overfished or overfishing status of a fishery.
The Science and Statistical Committee (SSC) essentially stated the same point in a 2005 report to the Council that only full stock assessments as conducted by the NMFS SEDAR process constitute the best available science. The implication being that the 2001 Potts/Brennan paper does not represent the best available science.
Moreover, if the Council and NMFS felt the Potts/Brennan paper carried such great weight, why have they not acted to reduce fishing mortality for black and red grouper or instituted a management plan during the past seven years?
In NMFS, Council and SSC discussions throughout 2004 and 2005, regarding grouper management, it was repeatedly stated gag and black grouper cannot be combined into a single aggregate because gags are a temperate water fish and blacks are a subtropical fish and they do not co-occur in any significant amount.
There has never been a South Atlantic SEDAR stock assessment on any of the species of grouper included in the proposed closure under the Interim Rule or Amendment 16 except for gag grouper.
In addition to the foregoing, the following required fishery management plan analyses are inadequate to justify a complete closure of the shallow water grouper fishery during our most valuable time of the year.
An OMB Regulatory Impact Review, an SBA Regulatory Impact Review and a Social Impact Assessment
We are asking the Secretary of Commerce to amend the Interim Rule and Amendment 16 to include gag grouper only and exempt the other species of shallow water grouper until the best available science has been acquired and properly acted upon.
AMENDMENT 16 –PROPOSED GROUPER CLOSURE
&
INTERIM RULE TALKING POINTS
OCTOBER 1, 2008
Mr. Bob Mahood, SAFMC Executive Director and Dr. Roy Crabtree, NOAA Regional Administrator are both on record as saying the basis for the Council’s decision to close the shallow water grouper fishery for four months is based on the 2001 Potts/Brennan paper presented to the SAFMC.
The Potts/Brennan paper is a simple Catch/Curve Analysis and does not constitute a stock assessment and is therefore wholly inadequate to justify a closure. Seven years later, with such major economic consequences at risk, we have been assured by a stock assessment scientist that this Catch/Curve analysis, even if conducted today, much less seven years ago, would not be approved as best available science for determining the overfished or overfishing status of a fishery.
The Science and Statistical Committee (SSC) essentially stated the same point in a 2005 report to the Council that only full stock assessments as conducted by the NMFS SEDAR process constitute the best available science. The implication being that the 2001 Potts/Brennan paper does not represent the best available science.
Moreover, if the Council and NMFS felt the Potts/Brennan paper carried such great weight, why have they not acted to reduce fishing mortality for black and red grouper or instituted a management plan during the past seven years?
In NMFS, Council and SSC discussions throughout 2004 and 2005, regarding grouper management, it was repeatedly stated gag and black grouper cannot be combined into a single aggregate because gags are a temperate water fish and blacks are a subtropical fish and they do not co-occur in any significant amount.
There has never been a South Atlantic SEDAR stock assessment on any of the species of grouper included in the proposed closure under the Interim Rule or Amendment 16 except for gag grouper.
In addition to the foregoing, the following required fishery management plan analyses are inadequate to justify a complete closure of the shallow water grouper fishery during our most valuable time of the year.
An OMB Regulatory Impact Review, an SBA Regulatory Impact Review and a Social Impact Assessment
We are asking the Secretary of Commerce to amend the Interim Rule and Amendment 16 to include gag grouper only and exempt the other species of shallow water grouper until the best available science has been acquired and properly acted upon.