Framework Action to Set the 2013 Gag Recreational Fishing Season and Modify the February-March Shallow-Water Grouper Closed Season

Dear Chairman Boyd:

Please accept these comments on behalf of the Pew Environment Group regarding the Public Hearing Draft for the Framework Action to set the 2013 Gag Recreational Fishing Season and Modify the February-March Shallow-Water Grouper (SWG) Closed Season. Our primary concerns are the potential that this proposed action will result in exploitation of grouper spawning aggregations, particularly for the depleted gag grouper population, and the likely increase in gag discard mortality. Appropriate scientific analysis and review has not been conducted for these proposed actions, and the level and quality of recreational catch statistics available now may be insufficient to allow for seasonal management of gag. Therefore, we urge the Council to delay action on this Framework until more robust analysis can be completed and the Council's Science and Statistical Committee (SSC) can review this analysis and the proposed measures to ensure this Framework Action will not undermine the gag rebuilding plan.

Specifically, we recommend: