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

Good afternoon, Chairman Gill and members of the Council. My name is Chad Hanson, with the Pew Environment Group. Thank you for the opportunity to address you about the Greater Amberjack Rebuilding Plan.

Greater amberjack has been overfished since at least 1998. The rebuilding plan put in place in 2003 has failed to rebuild the population. Since that time, the Council's scientific advisors have recommended increasing the recreational size limit to where at least 50% of the females are mature, a standard fisheries management rule of thumb. That point for greater amberjack is just short of 35 inches. We strongly recommend increasing the recreational minimum size limit to 34 inches as a tradeoff to keep the fishery open year round, at least until the stock assessment late next year.

It is widely recognized that at the current size limit of 30 inches, only about 2% of the female amberjack are sexually mature. At 34 inches, maturity increases to about 30%. We've known for more than a decade that we need to allow amberjack to get bigger in order to reproduce and rebuild. And it is widely acknowledged that the population cannot be rebuilt by continuously harvesting mostly immature fish. We don't need to wait until the next assessment -- the science tells us that we need to act now.

At a minimum, the Council should increase the size limit to 32 inches as an interim measure, with the expectation that the minimum size limit for the recreational fishery needs to be readdressed after the next assessment and raised high
enough to allow the species to rebuild. Even a bump to 32 inches would allow about 10% of the females to reproduce.

Some have expressed concern with increased discard mortality with an increase in size limit. Newer science shows that the assumed 20% discard rate from the last stock assessment may actually be too high, and the actual discard mortality rate is likely much lower. Research from the Florida Fish and Wildlife Conservation Commission and the University of Florida indicates discard mortality rates in the Gulf may be less than 5%, and newer data from the South Atlantic points to a rate near 14%. The Gulf data was referenced in the 2011 assessment update.

Some have expressed concern with increased discard mortality with an increase in size limit. Newer science shows that the assumed 20% discard rate from the last stock assessment may actually be too high, and the actual discard mortality rate is likely much lower. Research from the Florida Fish and Wildlife Conservation Commission and the University of Florida indicates discard mortality rates in the Gulf may be less than 5%, and newer data from the South Atlantic points to a rate near 14%. The Gulf data was referenced in the 2011 assessment update.

Even if the discard mortality rate has not been overestimated, as the latest science seems to indicate, the total or overall mortality rate is lower with an increase in size limit to either 34 or 32 inches. At 34 inches, this would allow the Council to re-open the recreational amberjack fishery in the months of June and July. As the species recovers, adjustments may be needed, but in the interim, you can both increase access to the resource for recreational anglers and do the right thing biologically for this fish by going to 34 inches.

Also for Amendment 35, we support the use of an annual catch target to provide a buffer from the annual catch limit. The ACL adjustment is strongly recommended in National Standard 1 Guidelines if catch limits are exceeded, and re-adjusting the ACT is necessary so that management uncertainty levels correspond to that new ACL. However, the ACT should be recalculated using the Council's ACT Control Rule rather than a doing a straight adjustment based on the amount that landings exceed the ACL. Using the ACT Control Rule to adjust the ACT allows for flexibility to adapt to changing fishery and data conditions. This approach also provides consistency across management plans as is intended by the Generic ACL Amendment, and the NS 1 guidelines.

Thank you for the opportunity to address you this afternoon. As always, we look forward to continue working with the Council to ensure our fisheries resources are managed sustainably.