June 22, 2001

Mr. Wayne Swingle, Executive Director

Gulf of Mexico Fishery Management Council

The Commons at Rivergate

3018 US Highway 301, Suite 1000

Tampa, Florida 33619-2266

Dear Wayne:

Southeastern Fisheries Association (SFA), speaking on behalf of 450 companies involved in all phases of the seafood industry endorse the following actions concerning the red grouper longline fishery.

1. A May 15 to June 15 seasonal closure for grouper longline fishing in the Gulf of Mexico. We prefer the closure to start at the 15th of the month so that the fishermen can have income for at least two weeks of each month in order to meet their financial responsibilities. Closing for this time period would reduce mortality by at least 10%.

2. Enact a trip limit of 6,000 pounds. This results in a 2% reduction in mortality. 

3. There are already two closed areas for grouper fishing established last year that has resulted in a 3.5% reduction in mortality.

4. There is already a one month closed season enacted last year that resulted in an 8% reduction in fishing mortality. 

This red grouper longline industry proposal results in a 23.5% reduction in mortality which should satisfy the requirements of the GOMFMC red grouper rebuilding plan.

Several SFA members suggested that the size limits for red grouper be removed in order to completely stop regulatory discards resulting in zero bycatch for longline fishing. This could be accomplished by setting a Total Allowable Catch for longline vessels and a trip limit of say 8,000 pounds. Longline participants could not participate in the grouper fishery after the longline TAC had been reached. This concept could be further developed over time with the final result of the red grouper longline fishery not ending up as a derby fishery like the red snapper fishery. Down the line the number of trips a longline vessel could make per year would be another possibility among many more that might come from the fishermen themselves under Council guidance.

SFA hopes the Council will not be swayed by those elements within the commercial fishing sector who do not use longlines and have stated the only solution is to ban longlines inside 50 fathoms. That would not be a solution, it would be an arbitrary and capricious action aimed at the only segment with the foresight and stamina to challenge the initial science placed before the Council. Had the original NMFS science been correct, the Council would be looking at a TAC in the vicinity of 1.5 million pounds for both commercial and recreational fishermen.

SFA hopes the Council requires all participants in this fishery to share a fair and equitable percentage of the burden as required under law. 

I look forward to seeing you in Duck Key and to testifying at the Gulf Council meeting.

Sincerely yours,

Bob Jones

Executive Director