NOAA is asking for comments for the SAFMC’s Regulatory Amendment 15. The part I commented on is the council’s plan to allocate another 27,218 pounds of commercial Gag Grouper quota to dead discards. Please read my comments below and consider submitting comments at the link provided supporting a 50 pound By-catch Allowance with that 27,218 pounds of seafood rather than wasting it. www.regulations.gov/#!docketDetail;D=NOAA-NMFS-2013-0088
Public Comments to NOAA Regarding SAFMC RA15
I am Chris McCaffity, a commercial fisherman who is appalled by the waste of seafood resulting from unnecessary and avoidable Regulatory Discards. The Congressional hard deadlines forced fishery managers to rush regulations resulting in some tragic unintended consequences including over a MILLION pounds of dead discards every year in our fishery alone. The SAFMC should focus on reducing Regulatory Discards rather than planning ahead to create more by allocating another 27,218 pounds of commercial Gag Grouper quota to dead discards. That 27,218 pounds of gag quota should be set aside for a 50 pound By-catch Allowance after the quota is filled to avoid wasting seafood. A 50 pound By-catch Allowance would be low enough to keep fishermen from targeting gags while allowing us to keep those we accidentally catch while targeting other species. This would provide well over $100,000 dollars in additional income to fishermen and give consumers more access to these public resources. This model should be applied to every species that has long closures to limit waste, produce more revenue, and collect better data.
Thank you for your consideration of my comments. Please contact me if you have any questions. freefish7@hotmail.com
Come on guys, this is a common sense solution that is much better than just discarding thousands of dying grouper. Remember, your silence and apathy equals passive support for that waste. Please send NOAA a comment supporting the By-catch Allowance solution and encourage others to do the same by posting a reply on this thread.
C-rig, this is an example of the kind of common sense solutions we as fishermen can come up with. Scientists work on theories that often overlook the unintended consequences that occur in real world application. They are working with numbers, not real fish or fishermen that are directly impacted by their theories. Please be sure to send a comment supporting the By-catch Allowance and share any ideas you have on here. Fishermen across America have centuries of collective on-the-water knowledge we need to use to solve problems so we can have a responsible harvest of healthy fisheries with very little waste. We can get fishery managers to implement our solutions IF enough of us stand united in support of them.
How many gags have you guys caught? How many were actually undersized? When you let the undersized ones go, how many of them actually floated back up? “Dead discards” are a joke… I’ve never really tracked it, but I would guess that about 80-85% of the gags that we have hooked on R&R were LEGAL. Of the ones that are short, I don’t recall ever seeing more than one or two float back up. I bet that barotrauma mortality is less than 3-5% in real life for fish caught inshore of the big ledge, despite what the junk science says.
Giving a “bycatch allowance” only suggests that you do not believe in catch and release and would encourage people to target short fish. I would rather see size limits stand their ground because I know for a fact that they work.
This 50 pound By-catch Allowance with the 27,218 pounds allocated to dead discards after an early closure would be for fish over the legal size limit. There is already another 81,000 pounds allocated to dead discards of undersized fish. It does not matter if the discard mortality rate is real or perceived by those making the laws. Those are the numbers we have to work with. After an early closure, every gag regardless of size or depth caught would have to be discarded dead or alive. The 50 pound By-catch Allowance would allow fishermen to keep those fish we accidentally catch while targeting legal species without exceeding the quota. This has nothing to do with size limits. It has to do with limiting waste and making the most efficient use of our resources.
Does everyone think it is better to keep the 27,218 pounds of dead discards rather than using that share of the gag quota to allow for a 50 pound By-catch Allowance after an early closure?