Re: Public Hearing Draft for Amendment 35 to the Reef Fish FMP (Greater Amberjack Rebuilding Plan)

On January 25, 2012, Chad Hanson and Holly Binns of the Pew Environment Group's Gulf of Mexico Fish Conservation Campaign offered their comments on the Public Hearing Draft for Amendment 35 to the Reef Fish Fishery Management Plan, with several specific recommendations:

  •  Ensuring the catch levels in the rebuilding plan (Action 1) are sufficient to end overfishing and rebuild the population.
  • The use of annual catch targets (ACT) and accountability measures (AMs) as described in Action 1 except that if the catch limit is exceeded the overage should be deducted from both the ACL and the ACT.
  • Ensuring that potential effort shift and intensification in both the recreational and commercial fisheries are adequately accounted for in the catch levels and management strategies.
  • Reconsideration of recreational minimum size limits (Action 2.1) as a means to rebuild the population per the Scientific and Statistical Committee's (SSC) review and discussion.