To: South Atlantic Council

The spawner recruit relationship in SEDAR 24 is completely wrong. The SEDAR 7 update from the Gulf of Mexico red snapper is the best science available on this topic and when you compare SEDAR 24 to SEDAR 7 it does not add up for the same species.

Example: From 1945 to 1970 the GOM red snapper produced age 0 classes of 25 million or more every year during that time period, 25 years in a row. Then from 1970 to 2008 it produced age 0 classes of 25 million to 110 million every year after, without exception. It never fell below the 25 million mark for those 39 years, not once. In fact, most years it was double or triple the historic age 0 class numbers.

In the Atlantic there is no age 0 fishing mortality that fishermen or scientists know of. Therefore age 1 classes from 1945 to 2009 should have a similar pattern(not size) in comparison to age 0 in the GOM.

According to SEDAR 24 In the SA from 1955 to 1970 the age 1 classes start at 637,000 and then drop every year to 263,000 by 1970. Then from 1970 to 2009 they fluctuate wildly from year to year with 32 years falling below 300,000. Of those 32 years, 23 fell below 200,00, and 5 fell below 100,000. This was derived without any data.

SEDAR 7 and the spawner recruit relationship in it, is the best science available on this subject. There is a huge amount of fishery independent data that backs up this science. SEDAR 24 has no data at all about age 0 fish and very little about age 1 fish. These are same species, different regions, one data rich in the GOM and no data in the SA.

How can this assessment be taken seriously by anyone that is a stakeholder? How can this council continue down this path trying to manage resources with science that does not resemble reality? How can this council allow one more person to have their life destroyed with science like this?
Please do something to make this right.

This council needs to reject SEDAR 24 and create an emergency rule reverting back to the 1997 assessment as the best science available. Then take SEDAR 24 away from the Beaufort Lab and complete a VPA using an independent scientific review after making corrections and collecting better data.

This is never going away.

Thank you,

David Nelson


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