Public Hearing Draft for Amendment 37 to the Reef Fish Fishery Management Plan

Modifications to the Gray Triggerfish Rebuilding Plan Including Adjustments to the Annual Catch Limits (ACL) and Annual Catch Targets (ACT) for the Commercial and Recreational Sectors

Dear Chairman Boyd:

Please accept these comments on behalf of the Pew Environment Group regarding the Public Hearing Draft to Amendment 37 to the Reef Fish Fishery Management Plan (Amendment 37). As indicated by the 2011 update assessment and acknowledged by NOAA Fisheries Service, the rebuilding plan for gray triggerfish implemented in 2008 through Amendment 30A is not working. The update assessment found that overfishing is occurring at 4% above the sustainable fishing level. The population also remains overfished and is at 39% of the level at which it would be considered rebuilt. In response, the Gulf Council's Scientific and Statistical Committee (SSC) recommended reducing catch limits to rebuild the gray triggerfish population. We urge the Council to comply with this recommendation and finalize Amendment 37 at the October 2012 Council meeting so that the rebuilding plan can get back on track as soon as possible. We also encourage the Council to select preferred alternatives that have a high probability of achieving the recreational and commercial annual catch targets (ACTs) to avoid exceeding the annual catch limits (ACLs). This is critical to ensuring the population will recover within the 5 year timeframe laid out in the Amendment.

Specifically, we recommend: