Tuesday, December 21, 2010

To: South Atlantic Council

Deep Sea Fishing Daytona Beach

The most recent science on red snapper was much improved from SEDAR 15 and allowed this council keep deep sea fishing legal in the entire South Atlantic with no closed areas inside of 240 feet. However, the emergency closure that was a product of SEDAR 15 has led to a continued closure of fishing for red snapper. This closure is completely unnecessary in regards to this species and should be lifted immediately.

Even with the improvements to SEDAR 24 the latest science still lacks any fishing independent data. SEDAR 24 is completely dependent on fishing dependent data. According to Dr. Andrew Cooper, landings data can only tell scientists the health of the landings and not the health of the stock itself.

Currently there are new data streams being created that are fishing independent. One is the use of underwater cameras, and they are "Very promising" according the NMFS scientists that I have talked to. The other is the fishing independent long line and it is also very promising, red snapper are being caught in every depth zone from 60 feet out to 240 feet by heavy fishing equipment that should not catch any red snapper inside of 150 feet(300 pound test leaders).

These new promising data streams will be available for an update assessment in 2013. This is three years away and is too long to keep red snapper closed. The headboat fishing and charter fishing businesses that depend on red snapper will not survive these three years. They should not be put out of the fishing business by science that has no fishery independent data.

This council should open red snapper fishing as soon as it is feasibly possible until these new data streams can be incorporated into the science. These people should not be put out of the fishing business because they have to wait for three years for this data to come available. There is no threat that red snapper are going to become extinct in the next three years and in fact the early evidence is that they are thriving(cameras and long line). There is a threat that many fishing businesses will be lost and people will continue to lose their fishing jobs if red snapper fishing continue to be closed.

Why would this council want to continue to destroy fishing businesses and put people out of work when there is no real threat to opening this species for three years until the update? If this closure of red snapper fishing continues there is a real threat to many fishing businesses being destroyed. The fishery might be a little healthier but there will be few fishing businesses left to take advantage of this mismanagement.

At the June meeting or sooner this council should pass an emergency rule to have an emergency opening of this species to save jobs and fishing businesses while data is collected over the next three years before the update. If the update shows that a closure of the species is still warranted then we will all accept it gladly.

Thank you for your time and Happy Holidays!

Thank you,

David Nelson


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