I will post some of my public comments regarding fishery issues on this page.
SAFMC Meeting Public Comments
I am Chris
McCaffity, a commercial fisherman and fisheries advocate who has been offering
simple solutions to mitigate many of the negative impacts related to rushed
Magnuson-Stevens Act hard deadlines have been met, we should take some time to “Stop
and Review” so we can learn what is working well and what isn’t. We should
think about ways to greatly reduce the MILLIONS of pounds of dead regulatory discards
that resulted from the rush to meet those congressional deadlines. We should
consider ways to enhance our fisheries rather than just restricting access to
them so we can feed more people, create more recreational opportunity, and
generate more revenue without overfishing. We should acknowledge advances in
satellite technology that already monitor Marine Protected Areas. We need to
discuss offshore energy production and offer suggestions like artificial reefs
and hatcheries as mitigation options. We should also have plans in place to
avoid a repeat of the gulf’s ongoing Idle Iron tragedy. Stakeholders should be
allowed to decide how our Total Allowable Catch limits will be managed. We
should try techniques that have proven effective in other areas like using female
lionfish pheromones as bait for trapping male lionfish.
respectfully ask the South Atlantic Fishery Management Council and everyone
else reading these comments to support a Stop and Review policy before any more
fishery laws are passed.
It is time to
focus more on enhancing our fisheries than restricting access to them in
wasteful ways. We should work toward a common goal of healthy fisheries that
are responsibly harvested with very little waste. Our fisheries should be a
model that others around the globe will want to follow.
for your thoughtful consideration. I am always happy to answer any questions. firstname.lastname@example.org
February 2015 NC Marine Fisheries Commission
Meeting Public Comments
I am Chris McCaffity, a commercial fisherman and fisheries
advocate from Morehead City.
It is hard to fathom why some commissioners and Division of
Marine Fisheries staff seem so eager to declare failure and give up on properly
managing our River Herring fishery. Closing this historic fishery will do
little more than take the focus off of rebuilding these mismanaged stocks. Please
consider supporting these solutions as an alternative to abolishing our state’s
Lift the moratorium and set a reasonable quota that will
support a by-catch fishery that limits waste, collects data, and feeds people.
This quota should be based on naturally occurring and hatchery supported
herring stocks. Otoliths from all harvested herring should be checked to learn
what percentage of hatchery releases returned. The Division of Marine Fisheries
should work with the Edenton National Fish Hatchery to release millions more
herring every spring. We should also work to improve the habitat where herring
With a growing number of recreational anglers and seafood
consumers we need to think about solutions that allow more harvest without
overfishing. Stocking natural seafood has proven to be a very effective way to
enhance many different fisheries. We should establish Hatchery Supported Quotas
for both sectors as an alternative to more restrictions. Stocking programs
could be funded with license fees, fundraisers, and existing taxes already
earmarked for promoting recreational fishing and domestic seafood. Hatcheries
and habitat enhancement are the perfect union of aquaculture and wild-caught
seafood that lives free and self-sufficient until harvested. We could create
more recreational opportunity and feed more people while generating more
revenue and protecting this public resource for future generations.
Stocking would be a great alternative to closing the
Speckled Trout fishery after as few as four fish are documented to be affected
by cold-stun events. A dip-net fishery during cold-stun events would show how
many trout should be stocked. If we cannot harvest stunned trout because
fishery managers say they will survive, there is no need for a prolonged
closure. If they think most of the floating trout will die, why not count and
There are some federal fishery issues the commission could
help with. During the last South Atlantic Fishery Management Council meeting
there was a discussion about allowing NC to manage a portion of some quotas.
This solution could allow consumers to access a much more dependable supply of
local seafood while reducing regulatory discards by properly managing quotas to
avoid extended closures.
It would also be helpful if the commission formally opposed outdated
Vessel Monitoring Systems in light of the new satellite surveillance technology
that monitors Marine Protected Areas across the globe. Offshore energy
production is another issue that needs to be considered. We do not want to see
a repeat of the gulf’s Idle Iron tragedy and hatchery funding should be a
Thank you for your thoughtful consideration of these
solutions. I am always happy to answer questions. email@example.com
Open Letter to Public Officials and Concerned Citizens
Officials and Concerned Citizens,
Please take a few minutes to read this letter regarding
fishery management and think about these solutions former Speaker Tillis
suggested we offer as alternatives to a gamefish bill.
It is important for us to think
about the big picture and how we can manage our fisheries to maximize benefits
for all user groups while protecting the resource for future generations.
Stocking natural seafood has a proven record of success. Rotating what is
stocked based on need and season would allow most species to thrive at the
highest levels our resource can sustain even as we harvest more. Habitat
improvements would help the resource support more marine life. These
sustainable solutions would feed more people while creating more recreational
opportunity and generating more revenue. This would be the perfect union of
aquaculture and wild-caught seafood that lives free and self-sufficient until
Advances in technology could greatly
improve our fishery management system. A website should be set up where
stakeholders can log in with our license number and a password to have
discussions and hold votes on how our license fees will be used and each
sector’s quotas will be managed. These votes should be binding when a 2/3
majority of participating stakeholders agree on an issue. We should seriously consider
using most of our license fees for dredging, hatcheries, and habitat
North Carolina’s historic River Herring
fishery could be a wonderful example of how hatcheries and habitat enhancement
can rebuild mismanaged stocks even as harvest continues. This will be the first
spring in 10,000 years that River Herring will not be harvested from NC waters
unless enough concerned citizens and public officials ask the Division of
Marine Fisheries to allow this ancient tradition to continue as we work to
rebuild stocks. The Edenton National Fish Hatchery started stocking millions of
herring three years ago. The first year’s spawn will start returning this
spring. Hatchery staff says they could stock many more herring if NCDMF will
work with them. Quotas could be based in part on a percentage of stocked
Thousands of concerned citizens have signed petitions in
support of enhancement and allowing NC’s River Herring fishery to continue. It
is time to shift the fishery management focus away from restricting access to
our public resources to enhancing them for everyone’s benefit.
Thank you for reading this and your thoughtful consideration
of some positive solutions. I am happy to answer your questions and/or discuss
any fishery issues. firstname.lastname@example.org
2014 NC Marine Fisheries Commission Meeting Public Comments
I am Chris
McCaffity. These comments will provide more detail about the vision for
enhancing our fisheries that I laid out at the last meeting.
This is the
Visioning Project summary. Start by
figuring out how much of each species can be harvested sustainably. Let each
sector decide how to manage their share of quotas with a 2/3 majority vote from
participating license holders. Run hatcheries at full capacity rotating what is
raised based on need and season. Take practical steps to improve water quality.
Enhance habitat with things like artificial reefs. Educate fishermen about how
to release illegal fish so they have the best chance of survival. Reward
fishermen and consumers with higher quotas as stocks reach desired levels. In
the end we should make full use of all harvested seafood.
have goals, caps, or quotas on most of the seafood we harvest. This is the
baseline for formulating fishery management plans. Those target harvest levels
are usually split between recreational and commercial fishermen based on
historical landings and other factors. These two user groups are required to
buy licenses. A portion of those fees should be used to set up an official
website where each sector can log in with our license number and a password to
discuss issues and hold votes. We should be allowed to decide how license
revenue will be used and how our quotas will be managed with a 2/3 majority
vote of participating license holders. Dredging, hatcheries, and habitat
enhancement should be the top three things our fees fund.
stipulations for hatcheries should be that only natural and native seafood can be
stocked. We should not introduce invasive species or genetically modified frankenfish.
grass beds and building artificial reefs would increase the total biomass enhanced
areas could support. This would not only benefit the seafood we want to eat, it
would help turtles, dolphins, and other marine life.
and habitat enhancement could be the perfect union of aquaculture and
wild-caught seafood that lives free and self-sufficient until harvested. We
could feed more people while creating more recreational opportunity and
generating more revenue.
regulatory discards and discard mortality should be a high priority. Quotas
should increase as dead discards decrease and stocks approach Optimum Yield.
tons of seafood is wasted every year. We need to think about ways to use scraps
from cleaned seafood. We need to think about using underutilized species
without overfishing those stocks. We need to think about practical and profitable
ways we can make wise use of all harvested seafood.
solutions could be applied to almost any fishery including our state’s oldest
one for River Herring. Dr. Daniel has correctly stated in the past that closing
a fishery is a failure of management. Look at the long closure of our Bay
Scallop fishery with no benefit to anyone or the resource. We could rebuild Bay
Scallop stocks to historical highs within a few years if we replanted the grass
beds that were killed by red tide back in the 1980s and stocked ideal habitat
with seed scallops. We could quickly rebuild River Herring stocks without
destroying this culturally important fishery by stocking herring and working to
improve the environment they spawn in. The Edenton National Fish Hatchery
stocked several million Blueback Herring over the past few years and those fish
will start returning next spring. Hatchery staff says they could stock millions
more. Quotas could be partially based on a percentage of stocked fish.
ask the North Carolina Legislature, Department of Environment and Natural
Resources, Division of Marine Fisheries, and Marine Fisheries Commission to
allow the River Herring fishery to continue as we take steps to rebuild Alewife
and Blueback Herring stocks. Thousands of concerned citizens have signed
petitions in support of preserving our freedom to harvest and eat NC herring. Please
do not let this ancient spring tradition fade away without making every effort
to keep it going.
I would also
like to encourage fishery managers to work with willing fishermen to stock
native oysters in open areas. Each fisherman could spread thousands of tiny
oysters in the areas they work on the last day of every season.
We should be
stocking shellfish, shrimp, crabs, and a variety of finfish including sturgeon
and sawfish. Our waters could be healthier while producing much more seafood
and recreational opportunity if we focused more on enhancing our fisheries than
restricting access to them.
Thank you for your thoughtful consideration of
these comments and for hopefully allowing the 10,000 year old River Herring
fishery to continue. Send questions to: email@example.com
September 2014 SAFMC Meeting Public Comments
As the water cools and fall fishing heats up commercial snapper/grouper fishermen will be forced to discard almost every species of fish we catch. The entire South Atlantic fleet will be targeting a few kinds of legal seafood which will cause those quotas to be filled faster. All these closures contribute considerably to the MILLION+ pounds of projected dead discards being deducted from our quotas every year. Most of this wanton waste is avoidable by simply managing each quota to avoid a total closure with low by-catch allowances. Most allowances should be triggered once a percentage of a quota has been landed. Split seasons would help avoid long periods of low limits. Openings could be planned so reduced limits coincide with spawning seasons. Some species with low quotas should only be managed as by-catch fisheries. We should target fish with higher limits while keeping most of our by-catch. This would greatly reduce regulatory discards while providing consumers with a consistent supply and wider variety of local seafood.
We should work to limit discards while encouraging fishermen to release illegal fish so they have the best chance of survival. The Pacific Fishery Management Council is rewarding responsible fishermen with higher quotas as fewer fish are allocated to dead discards based on voluntary use of descending devices. The use of by-catch allowances, circle hooks, and descending devices should significantly increase our quotas which will further reduce regulatory discards.
Please think about how quotas can be managed to have as many positive benefits and few negative impacts as possible for fish, fishermen, and consumers. Keep in mind that appropriate by-catch
allowances would negate the need for other possession limits. Shouldn’t managing existing quotas to avoid extended closures and excessive discards be one of the council’s primary goals?
March 2014 SAFMC Meeting Public Comments
Please take the time to read these comments regarding some important issues the council should be and is considering.
It is important for us to learn from successes and failures in our own fisheries and others. One notable success has
been on the west coast with fishermen’s voluntary use of Descending Devices to greatly increase survival rates of fish suffering from barotrauma. The success has been so great that the Pacific Fishery Management Council will be
considering reducing discard mortality allocations this month for several species with a similar life history and anatomy of many deepwater species off our coast. Promoting the use of Descending Devices would be a great way to
collect data on and protect Warsaw Grouper and Speckled Hind without closing any more traditional fishing grounds. Descending Device use is also a solution that could allow fishermen to keep some of the 500,000+ pounds of Red Snapper currently being allocated to dead discards every year. Using these devices should return some of the 100,000+ pounds of our annual Gag Grouper Total Allowable Catch being allocated to dead discards. Most of this tragic waste of
our resources is easily avoidable by simply managing quotas to avoid extended closures and releasing illegal fish so they have the best chance of survival. The vast majority of west coast fishermen were willing to use Descending Devices once they learned how effective and easy to use they are. Higher quotas will be a great reward for doing the right thing. This west coast success could be replicated in our commercial and recreational fisheries by taking these three simple steps.
1. Establish a South Atlantic Recreational Reef Fish Permit or work with states to include a box that fishermen can check on the fishing license application saying they bottom fish in federal waters. This will define the universe of anglers while providing contact info.
2. Request or require all recreational and commercial fishermen to have an approved Descending Device when bottom fishing in federal waters.
3. Set up a reporting system for fishermen to record what species and how many they released with Descending Devices each trip.
Here are some links to information about Descending Device use in deepwater Pacific fisheries similar to ours.
I hope everyone will take the time to check out these links to important information about positive solutions that reward
responsible fishermen for doing something simple to help their fisheries.
I would also like to comment on Amendment 29. PLEASE manage our commercial Gray Triggerfish quota with split seasons aligned with Vermilion Snapper and By-catch Allowances that avoid total closures and Regulatory Discards. PLEASE keep in mind that By-catch Allowances are NOT intended to continue a targeted fishery, but rather to avoid closures and waste.
Finally, I ask the council to table any amendments like RA17 that could negatively impact our freedom to fish until
after the Visioning Project is completed.
Marine Fisheries Commission Meeting Public Comments
I am Chris
McCaffity. I would like to start by formally withdrawing my request for a
resolution supporting the NC Fisheries Visioning Project. I do ask that the commission
hold off on passing any new laws that could further restrict our freedom to
fish and/or access local seafood until the project is complete and a final plan
is submitted at the August 2014 MFC meeting.
thing almost everyone I talk with about the Visioning Project agrees on is that
they are not happy with the way our fisheries are being managed. Many mention
some version of the same sad joke that they need a lawyer to go fishing with
them to make sure the ever-changing list of fishery laws are being followed. Many
reluctant anglers say they don’t think it is worth the expense or hassle of
going fishing with such restrictive laws and the threat of heavy fines, seizure
of their property, or even imprisonment if they accidentally violate one. We
really need to think about if this is how we want to manage our fisheries or if
a simple set of common-sense regulations could be just as or more effective. We
should also think about enhancing our fisheries rather than passing more laws
that restrict our freedom to fish and eat local seafood.
There is a
very real chance this commission could pass a law that would totally ban all
harvest of River Herring since the fishery was not being executed as intended. This
appears to be the result of poor communication and coordination so I am
coordinating efforts with those involved to ensure this year’s fishery will be
conducted as intended. During talks with herring fishermen some of them offered
solutions to help keep their fishery going. One solution is to establish a
by-catch allowance for co-occurring fisheries to collect better data and reduce
waste. Another solution is to open the season one week before the festival with
higher possession limits and daily electronic reporting until the quota is met.
Almost everyone thinks the size and possession limits on Striped Bass should be
relaxed to ease predatory pressure on herring. There are ways we can keep this
fishery alive if those charged with managing it want it to continue. The
Edenton National Fish Hatchery released 2,280,000 herring last year and could
release many more in the future with a little coordination between hatchery
staff, DMF, and fishermen. I ask the commission to keep the 4,000 pound quota
in place until herring stocked in 2012 start returning next year. Lift the
moratorium in 2015 and start setting annual quotas at 10% of the herring
stocked three years prior. That quota should be split equally between
recreational and commercial fishermen with reporting requirements. If this ancient
fishery is abolished, it is not likely to come back. Even if it does, the
tradition and fishermen associated with it will be gone. Please do not give up
on properly managing this fishery that has existed for thousands of years.
Trout management is also on the agenda. Most people seem content to support the
regulations that were in place before the cold-stun closure until the new stock
assessment is completed. I’ll reluctantly go along and ask that limiting waste
be a priority in the future.
important issue the commission will be considering is how to reduce by-catch in
the shrimp fishery. I believe there are ways we can greatly reduce by-catch and
turn what remains into useful by-product. One of my concerns is that a mandate
for an arbitrary 40% reduction in by-catch with an assumed baseline to gauge
any success is a recipe for failure. Maybe it is time to allow shrimpers to
experiment with different ideas to reduce by-catch? Maybe scientists and
fishermen should work together on experiments with things like visual and audio
stimuli that might scatter fish without affecting shrimp? Maybe we could
cultivate new fisheries to help spread out effort? Maybe some shrimpers could
harvest the invasive Hydrilla for cattle feed like they did in Florida rather
than poisoning it? Those poisoned plants settle to the bottom where they rot
and create hypoxic zones that negatively impacts the surrounding ecosystem.
talk about a request for an Incidental Take Permit (ITP) for turtle
interactions in the Pound Net Fishery. This would be the latest in a long list
of harassing proposals by a small group of sportsmen who seem obsessed with
hurting commercial fishermen. Do you think we should get ITPs for boating
interactions or recreational fisheries that interact with turtles? Please be
careful about entertaining extremist agendas that could backfire in a major
The ITP for
gillnets requires costly observers and commercial fishermen are facing license
fee increases to fund them. That money should be dedicated to observer coverage
with close stakeholder oversight. Commercial fishermen should not be required
to take observers on our boats as lawsuits become a very real issue with our
jobs being one of the most dangerous. I recommend the observer funds be used to
pay existing Law Enforcement Officers to observe gillnet fishermen from DMF
boats or exempt fishermen of any liability for injury to observers.
not support arbitrarily increasing the Fishing Mortality threshold for Striped
Mullet from 30 to 35%. This is just the first step toward creating unnecessary
I urge the
commission not to support any Joint Law Enforcement Agreement with the federal
government for many reasons including liability lawsuits and state’s rights
issues. Two better options are to push for state by state allocations of
federal quotas as is done with Summer Flounder and extending state waters out
nine miles as is current law in the Gulf of Mexico.
laws being voted on by this commission should have to pass with a 2/3 majority
vote. This would help ensure that any new laws would have to be well thought
out and benefit all user groups. It could also encourage more discussion about
ways to enhance our fisheries rather than always focusing on restricting the public’s
freedom to access our public resources. I want to remind everyone that
fishermen are not just numbers in equations or pawns in a cruel game some
people are playing with our families, food, and freedom. We are human beings
who deserve to be treated like you would want to be if the roles were reversed.
We should work together toward what should be a common goal of responsibly
harvested healthy fisheries.
Please read the public comments below and consider sending an email to the South Atlantic Fishery Management
Council saying you support the freefish7 vision for sustainable fisheries and clean energy. firstname.lastname@example.org
South Atlantic Fishery Management Council Visioning Project Public Comments
I am Chris McCaffity, a commercial fisherman from North Carolina. These are my public comments regarding a vision for our snapper/grouper fishery based on decades of on-the-water experience as well as knowledge gained from discussions with fishery managers, environmentalists, and fellow fishermen. These solutions are intended to achieve multiple goals of feeding more people, producing renewable energy, creating jobs, and advancing liberty. My hope is that this vision of clean energy and responsibly harvested healthy fisheries will be a model for other resource managers across the globe to follow. My prayer is that God will give me the words to define these ideas well enough to be easily understood so that we may wisely use and pass on to future generations the gifts of seafood, energy, and freedom He gave us.
I have a vision of independent fishermen responsibly harvesting quotas based on accurate data and sound science rather than “fatally flawed data” and questionable equations where fishermen seem to be seen as the most reviled variables.
I have a vision of reasonable quotas managed with possession limits so that everything we catch is legal to keep at the same time as we target species with higher quotas and limits.
I have a vision of a one mile wide continuous Marine Protected Area running parallel to the coast with thousands of energy and data collection platforms marking the shipping lanes and monitoring the MPA.
I have a vision of Artificial Reef habitat enhancing areas of barren seafloor as the perfect union of aquaculture and wild-caught seafood that lives free and self-sufficient.
I have a vision of Community Seafood Processing Facilities in each state where fishermen will always have a place on the water to unload our catches to be documented, inspected, and processed.
I have a vision of private industry, government agencies, environmental organizations, and independent fishermen working together to responsibly and sustainably harvest seafood and energy from our oceans.
I have a vision of ending world hunger with a renewable source of protein that lives free and self-sufficient until harvested and of promoting world peace with an abundant affordable source of energy.
We can collect much better data by working together as liaisons and properly managing quotas to avoid the Regulatory Discards that inject unknown variables into stock assessment equations. Those equations and data collection methods should be peer reviewed and approved by fishermen, fishery managers, and environmental organizations so everyone agrees with the results.
We can manage seasonal quotas with possession limits to avoid multiple extended closures. Some fish would have higher limits than others based on the amount of quota available. Fishermen could target species with higher limits while still being allowed to keep most of the others with lower limits that are accidentally caught. This would almost eliminate the Regulatory Discards that are wasting tons of seafood every year.
We can incorporate Marine Protected Areas and the need to monitor them with energy production platforms that collect solar, tidal, wind, and wave energy. Nature’s awesome power can be harnessed and used to create clean burning hydrogen gas which can be stored indefinitely and easily delivered for green energy production.
We can design Artificial Reef habitats and place them in appropriate areas to support the kind of seafood we want to harvest or protect. Artificial and natural reefs along with platform structures within the mile wide continuous MPA along the east coast could in time create a thriving eco-system rivaling Australia’s Great Barrier Reef.
We can build Community Seafood Processing Facilities that double as museums to preserve the commercial fishing heritage of the area they are located. Marine Patrol Officers could be on site to ensure possession limits were being followed. Rather than forcing fishermen to waste seafood or face heavy fines, overages could be donated to soup kitchens and food pantries. Each state’s Department of Agriculture could inspect and label our catches as different species of wild-caught seafood from that area with an expiration date. Scraps from cleaned seafood could be processed into feed pellets for pond-raised species and farm animals.
We can create new jobs and revenue by feeding people safe sustainable seafood and producing an almost endless supply of clean energy that would drastically improve the lives of millions across the globe. Advances in technology along with critical thinking, human ingenuity, and application of the Golden Rule can unleash the kind of peace, prosperity, and individual liberty the human spirit yearns for.
We need to think about these ideas and those of others before taking any new actions. The Congressional hard deadlines to end overfishing have been met. There is no mandate or need to rush the next round of fishery management decisions. Our Country is out of money and we are enslaving future generations with trillions of dollars in debt. Our Constitutional Rights and God-given freedoms are being violated and restricted with regulations that are rushed to appease powerful special interest groups rather than being well-thought-out so they will benefit and advance the liberty of all mankind. We owe it to today’s citizens and all of posterity to make wise decisions regarding our freedom, renewable resources, and how limited funds are allocated.
Thank you for your time and consideration of my comments. Please contact me to discuss any of
these solutions. email@example.com
Please consider sending the South Atlantic Fishery Management Council a copy of these comments along with a statement of support if you agree with the solutions. firstname.lastname@example.org
December 2013 SAFMC Meeting Public Comment
I am Chris McCaffity, a commercial fisherman and advocate for the responsible harvest of healthy fisheries. These
are my public comments regarding the Visioning Project, Regulatory Amendment 17, and Amendments 22, 29, and 31. I would like to start with a Japanese proverb. “Vision without action is a dream and action without vision is a nightmare.” The laws that were rushed to meet Congressional hard deadlines without a clear vision using “fatally flawed data” have resulted in a nightmare of wasted seafood, financial devastation, and even death. The Visioning Project provides a wonderful opportunity to rebuild confidence in the council process.
Managing a multi-species fisheries boils down to figuring out how much of each species can be harvested without
overfishing, splitting each fish’s Acceptable Biological Catch between sectors, and then managing individual quotas with appropriate possession limits so they are filled but not exceeded while avoiding total closures. Some seafood should have higher possession limits than others based on the amount of quota available. Fishermen could target fish with higher limits while still keeping most of what we catch with lower limits. Quotas should be managed to make
discards rare while encouraging fishermen to release illegal seafood so it has the best chance of survival. We should also try to use every part of every kind of seafood we harvest and create markets for underutilized species. Once quotas are established and properly managed, we should look at ways to enhance habitat so it produces more seafood and recreational opportunities while protecting our renewable resources for future generations.
It is extremely sad how bad our commercial quotas are being mismanaged. Why is the council planning ahead to waste hundreds of tons of seafood every year rather than managing quotas with appropriate possession limits to avoid multiple extended closures and excessive discards? Stakeholders should be able to decide how we want our share of each species’ quota to be managed with a 2/3 majority vote of participating permit holders. We did an exercise in the Marine Resource Education Program using Robert’s Rules in a mock council vote. That vote was anything but thoughtful or deliberate. The most aggressive person dominated a rushed and chaotic process. We should think
things through to find solutions that follow all MSA mandates including the ones to limit waste, make efficient use of our resources, and promote safety.
The Visioning Project should include ideas for working together on collecting better data to improve the confidence levels in new stock assessments. We should work on reducing the discard mortality rates used in stock assessments by promoting proper release techniques. We should be working together to enhance our fisheries by creating new artificial reef habitat in areas they will have the most benefit. We should work together toward what should be everyone’s common goal of sustainable fisheries that are responsibly harvested with very little waste. We should learn from past mistakes while forming a positive vision for the future.
My comment on RA17 is that we should enhance existing Marine Protected Areas with appropriate artificial reef habitat
rather than rushing to close more traditional fishing grounds based on “fatally flawed data”. We should be releasing Warsaw Grouper and Speckled Hind suffering from barotrauma with decent assist devices to greatly improve survival rates. We should start a tagging program to collect much-needed data for credible stock assessments. Please listen to the elected officials and American citizens speaking out against RA17’s MPAs.
My comment for Amendment 22 is that we should focus on drastically reducing the amount of our quotas that are allocated to dead discards every year by reducing regulatory discards and improving survival rates for what must be discarded. The council should also consider a tagging program for released fish to collect better data about abundance, distribution, and mortality.
My comment for Amendment 29 is that Gray Triggerfish should not have a size limit and the quota should be managed with split seasons that open with Vermilion Snapper. Appropriate possession limits should be used to avoid extended closures and excessive regulatory discards. Quotas for data poor stocks should be set at an average of the last ten years landings.
Here is an example of how the existing commercial Gray Triggerfish quota could be managed so it is filled without long
Split the annual Gray Triggerfish quota into two seasonal quotas that align with Vermilion Snapper. Each season should start with a 500 pound possession limit until 75% of the quota has been landed. The final 25% of each seasonal quota should be used for a 100 pound by-catch allowance to avoid total closures and unnecessary discards. Any overages should be deducted from the next season and any leftover quota should carry over. This management plan should be applied to almost every quota in a multi-species fishery. The lower by-catch allowances will make it much easier to avoid overages while providing consumers with a dependable supply of fresh local seafood. The primary possession limit should increase as this stock quickly rebuilds. I want to stress that reduced possession limits for the final 25% of a quota should be considered as by-catch allowances that are intended to avoid total closures and regulatory discards. The reductions are not intended to continue a targeted fishery. By-catch allowances could also be used during spawning seasons to limit waste while protecting spawning aggregations. This solution would also limit gaps and uncertainty in stock assessment data.
My comment for Amendment 31 is that Blueline Tilefish should have a quota separate from the deepwater complex and be managed with appropriate possession limits to avoid total closures.
I would like to close by asking the council to make reducing regulatory discards and discard mortality rates as well as
collecting better data top priorities for the Visioning Project.
Thank you for considering my comments. Anyone have any questions? email@example.com
These public comments were solicited by the Bureau of Ocean Energy Management (BOEM) and tie into the previous comments to the South Atlantic Fishery Management Council (SAFMC). The National Environmental Policy Act (NEPA) requires different government agencies with overlapping jurisdiction to coordinate efforts and consider input from stakeholders that would mitigate any negative impacts of proposed regulations. Please send a copy of the comments along with a statement of support to these BOEM employees and the SAFMC. Thank you!
Public Comments Regarding Offshore Energy Production
I am Chris McCaffity, a commercial fisherman from Morehead City, North Carolina. I have been working on solutions that incorporate offshore energy production, Marine Protected Areas (MPAs), and the need to monitor them with a responsible harvest of sustainable fisheries. Please consider these solutions with an open mind before rushing to do something that will have long-lasting impacts and will be hard to reverse in favor of better options in the future.
One problem with offshore energy is delivering it efficiently while a primary obstacle to producing clean burning hydrogen gas is the amount of fossil fuel it takes to produce it. Hydrogen is the most abundant element in the universe and is our sun’s fuel without which there would be no life. Hydrogen is produced from water and water vapor is the only emission when it is burned. Hydrogen can be stored indefinitely and easily delivered.
Fishery managers are planning to create new MPAs and want to require more fishermen to install unconstitutional spy devices on our boats to make sure we don’t fish in them.
This is my vision for solving these problems with a few simple solutions that benefit everyone.
Create a one mile wide MPA along our east coast on the inshore side of the shipping lanes with thousands of energy production and data collection platforms marking the lanes and MPA. Video cameras could be placed on the platforms to monitor the closed areas and negate the need for Vessel Monitoring Systems. The platforms could be equipped with a wide variety of data collection instruments. They could collect solar, ocean current, wind, and wave energy to power those instruments and be used in the production of hydrogen gas. The platforms would act as artificial reef habitat that along with other manmade and natural reefs would in time create a thriving
eco-system within this 2,000+ mile long continuous MPA rivaling Australia’s Great Barrier Reef. This sanctuary would be the perfect union of aquaculture and wild-caught seafood that lives free and self-sufficient until some of it moves into open areas to be harvested. The spawn of species within this MPA would also spread out to other areas. The increased bio-mass of seafood would yield higher quotas for fishermen and feed more people.
Each platform could employ multiple people while also providing jobs for local captains running crew boats and hydrogen transport vessels. Citizens and state legislatures could control the platforms off their coast. States could pay the federal government a leasing fee while deciding how to use the gas and revenue. The clean burning gas could be used in community energy production sites that utilize wastewater for steam to turn electricity producing turbines rather than dumping it into our waterways. This would give the public an alternative to the one big corporate energy monopoly that controls our access to electricity in each area. This would also make it easier for communities to get power back quickly after natural or manmade disasters. This model for clean energy and sustainable fisheries could quickly become a reality with a little critical thinking, human ingenuity, and a cooperative effort between private industry, government agencies, environmental organizations, and concerned citizens.
These solutions could be applied globally and greatly improve the lives of millions. Renewable green energy and an abundant source of seafood could help to end world hunger and bring about the kind of peace, prosperity, and individual liberty the human spirit yearns for. Isn’t helping all mankind worth a little extra time, effort, and thought?
Thank you for considering my comments. Please contact me if you are interested in discussing these solutions. firstname.lastname@example.org
Public Comments Regarding Regulatory Amendment 18
I am Chris McCaffity, a commercial fisherman who has been offering positive solutions that would limit waste in our fisheries while allowing fishermen to work in safer conditions providing consumers with a dependable supply of safe American seafood. I would like to thank the South Atlantic Fishery Management Council for listening to some of
these solutions and the members who took time to discuss management options with me. I have tried to incorporate the information council members shared about limitations they face into new solutions. I believe most fishermen and council members have a common goal of healthy fisheries that can be responsibly harvested forever with very little waste. It is how we can achieve that goal with as many positive benefits and as few negative impacts as possible that
needs to be discussed. Please keep an open heart and mind as you read my preferred alternatives and comments.
2.1.1 Action 1: Revise the Annual Catch Limit (ACL, including sector ACLs) and Optimum Yield (OY) for Vermilion
I support: Alternative 2. Revise ACL (including sector ACLs) for vermilion snapper for 2013 through 2016 as shown
below and set ACL=ABC=OY. The acceptable biological catch (ABC) and ACL values for 2013 onwards are based on landed catch only; discards are accounted for in specifying the ABC in terms of landed catch and not total kill. The values for 2016 would remain until modified.
I oppose: The 2012 Commercial ACL for Jan-June is reduced by 11,000 lb gw for post quota bycatch mortality (PQBM) and July-Dec by 24,000 lb gw PQBM.
It is totally unacceptable that much more than 35,000 pounds of Vermilion Snapper was wasted and fishermen lost hundreds of thousands of dollars in revenue last year from this one species. The tragic waste of seafood can be
avoided by removing size limits and avoiding multiple extended closures with proper possession limits for every species the council manages. The poundage that is deducted from the annual Total Allowable Catch for Size Limit Regulatory Discard Mortality along with the poundage allocated to Post Quota Regulatory Discard Mortality should be set aside for a By-catch Allowance of 100 pounds after each species’ primary quota is landed. This would eliminate almost all Regulatory Discards while allowing fishermen to earn more money in safer conditions providing consumers with a dependable supply and wide variety of seafood including Vermilion Snapper all year.
2.2.1 Action 2: Modify the commercial trip limit for vermilion snapper.
I support: Alternative 3. Reduce the commercial trip limit for vermilion snapper to 1,000 lbs gw. When 75% of the
commercial ACL has been met or projected to be met, reduce the commercial trip limit to 500 lbs gw.
I oppose: One thing to consider here is that there has been considerable discussion that trip limits below 1,500 lbs may not be economically feasible for some fishermen, particularly those off Georgia who need to make long trips offshore to reach areas where vermilion snapper occur.
Total closures are not economically feasible for ANY fishermen. The council needs to manage every commercially important species with proper possession limits and By-catch Allowances so it is legal to keep some of everything all year. All fishermen including those with long-range vessels could target fish with higher limits while still keeping other species with lower limits. Big boats could put a trip together with 500 pounds of some fish, 1,000 pounds of others, and a few hundred pounds of Snowy Grouper and Red Porgy until they had 3 or 4,000 pounds of fish. Targeting one or two legal species at a time floods the market and drives down prices while giving consumers limited options for lesser quality seafood that takes longer to move.
2.3.1 Action 3: Modify the commercial fishing seasons for vermilion snapper.
I oppose all three options presented in this amendment. The Vermilion Snapper fishing seasons should be modified to open on April 1st and October 1st. These would be safer opening dates for fishermen and allow us to have high limits at peak periods.
2.4.1 Action 4: Modify the recreational closed season for vermilion snapper.
I support: Alternative 2. Remove the recreational season closure for vermilion snapper.
2.5.1 Action 5: Revise the Annual Catch Limit (ACL, including sector ACLs), Optimum Yield (OY), and Annual Catch Target (ACT) for Red Porgy.
I support: Alternative 1. No action. For red porgy, retain the current ACLs, OY, and recreational ACT:
I support keeping the 120 fish commercial limit during the open season and allowing a 20 fish By-Catch Allowance during the spawning season to avoid excessive Regulatory Discards.
I oppose the Red Porgy size limit that yields lower quotas due to the high discard mortality rate of undersized fish. Size limits cause the stock to truncate and reduce the average size of breeding fish resulting in a weaker gene pool. Removal of wasteful size limits along with a By-catch allowance during the spawning season would allow us to keep more of the Total Allowable Catch rather than allocating tons of it to dead Regulatory Discards.
I oppose the Maximum Sustainable Yield baseline for Red Porgy that is artificially high due in part to a mix up with Scup landings data. The higher landings in early years were also a result of roller rigs the council correctly banned resulting in much lower landings from that point on. If these issues are not addressed, the Red Porgy stock will NEVER fully “recover”. Another thing to consider is the overabundance of Smooth Dogsharks and Black Sea Bass as well as invasive Lionfish that are eating too many juvenile Red Porgy. We need to cultivate markets for Smooth Dogsharks and Lionfish while increasing the quota for Black Sea Bass. We can also increase the ecosystem’s Maximum Sustainable Yield for Red Porgy and other co-occurring species by creating Artificial Reef habitat.
Thank you for considering my comments. Please send any questions or comments to Chris at. email@example.com
Here is a link to Regulatory Amendment 18. http://www.safmc.net/LinkClick.aspx?fileticket=XeuGATXjt1o%3d&tabid=763
You can send these comments through September 2013.
Public Comments Regarding Regulatory Amendment 14
My name is Chris McCaffity. I am a commercial fisherman who has been offering positive solutions that would mitigate many of the severe negative impacts of regulations that were rushed to meet arbitrary hard deadlines in the reauthorized Magnuson-Stevens Act. I want to thank the South Atlantic Fishery Management Council for setting up Regulatory Amendment 14 to correct some of the unintended consequences of those rushed regulations by responsibly managing several important quotas. RA14 gives council members a chance to greatly reduce the tons of dead Regulatory Discards that occur during prolonged closures while securing a dependable supply of safe American seafood for consumers. RA14 offers a chance to maximize the value of reduced quotas while allowing fishermen to work in safer conditions. RA14 provides a chance to collect accurate data to use in credible stock assessments. There is also a chance the council could take actions in RA14 that will just exchange one problem for another or even make matters worse. I respectfully ask everyone to keep an open heart and mind as I explain how and why quotas of commercially important snapper/grouper species should be properly managed.
The South Atlantic snapper/grouper fishery is a multi-species fishery. Many different species of fish live around structure on the seafloor. We can target certain kinds of fish, but we will always catch some of the others. Those non-target species are a bonus unless they are illegal and must be discarded dead or alive. By the time I give these public comments more fish will be illegal to keep than will be legal and more early closures will follow soon after. Many discarded illegal bottom fish suffer from barotrauma. Some of the decompressed fish that are too bloated for venting to help will float off and bake in the sun for hours as seagulls peck out their bulging eyes before they die. Many other discarded fish slowly die after their vital organs are damaged and protective slime is wiped off while they are held firm enough to remove the mandated circle hook that often breaks a fish’s jaw if it is not removed correctly. The key to stopping most of this waste and abuse is to avoid a total closure of any species by responsibly managing quotas with split seasons and possession limits. The seasons should begin when conditions are best so the possession limits are highest during that time. The possession limits should be adjusted to levels that fill the quotas without any long closures after a predetermined amount of each quota has been landed.
Here is an example of how the commercial quotas for Amberjack, Black Sea Bass, Gray Triggerfish, and Vermilion Snapper should be responsibly managed with Regulatory Amendment 14.
Split each annual quota into two seasonal quotas beginning in April and October with a 1,000 pound possession limit. There should be a 100 pound by-catch allowance during the April Amberjack spawning season so fishermen will not target them but can keep the ones we accidentally catch. This is how the possession limits should be adjusted after approximately half of each seasonal quota has been landed. Any remaining quota should carry over to the next season and any overages could be deducted.
1. Reduce the possession limit to 100 pounds if there are five months left in the season.
2. Reduce the possession limit to 300 pounds if there are four months left in the season.
3. Reduce the possession limit to 500 pounds if there are three months left in the season.
4. Keep the possession limit at 1,000 pounds if there are two months left in the season.
5. Increase the possession limit to 1,500 pounds if there is only one month left in the season.
Managing quotas like this would allow fishermen to target fish with high possession limits while still keeping the ones we accidentally catch with lower limits. This plan would be easy to implement and enforce. It could be applied to all snapper/grouper species with minor adjustments to the possession limits according to the poundage of each quota. It would follow the Magnuson-Stevens Act mandates to limit waste, make efficient use of our resources, and promote the safety of fishermen at sea. It would achieve any honorable goals of catch shares without all of the well documented negative impacts associated with allocating private ownership of our public resources. We could show fishery managers around the globe how they can feed more people while protecting stocks of seafood and traditional artisanal fisheries as well as the independent fishermen who are being regulated into extinction.
I want the council and everyone else to understand why it is important to split annual quotas into two seasonal quotas beginning in April and October. The split seasons will keep possession limits from being low for more than five months. The spring and fall are when most fish bite the best and the weather is usually safer. Starting seasons in the dead of winter or middle of summer forces fishermen to work in extreme weather when many fish are lethargic due to hot or cold water. April and October openings would be the fairest and safest for fishermen from Key West to Wanchese.
The looming closure of a dangerous winter derby fishery for Vermilion Snapper played a key role in the death of Alan Nelson as 20 to 25 knot northeast winds blew against the strong Gulf Stream current and built steep seas that knocked him overboard. The 10 to 15 knot NOAA weather forecast that encouraged Alan’s captain to stay a little longer was wrong. Mr. Nelson and his innocent baby that he was trying to support paid the price for a missed forecast and a mismanaged unnecessarily low quota that was based on “fatally flawed data”. Alan’s body was never found. He died alone on a cold dark winter night in one of the worst ways imaginable. What is even worse than drowning in a raging black sea, is that Alan will miss all the joys of raising his beautiful daughter and a sweet little girl will never know her loving father.
I respectfully ask the SAFMC to include the solutions offered in these comments in Regulatory Amendment 14. This amendment is the place to correct some of the mistakes that have caused countless fish to be discarded and cost at least one fisherman his life and one daughter her daddy. Fishing has always been and will always be a dangerous job,
but mismanaged quotas do not have to greatly increase our chances of injury or death. Captains of commercial fishing vessels are responsible for the safety of our crew regardless of the laws we must obey. I pray this council will immediately begin to properly manage our quotas so that we may responsibly harvest America’s seafood in a safer and more sustainable way. I pray the council members will treat us as they would want to be treated if the roles were reversed. I pray God will bless this council with wisdom, courage, and compassion as they write laws that will have long lasting impacts on the lives, livelihood, and liberty of those they serve.
I do not dispute that management measures the council has taken will rebuild stocks from decades of mismanagement. I just believe we can manage existing and future quotas without all of the Regulatory Discards, financial devastation, compromised safety, Constitutional violations, and loss of our God-given freedom. We simply need to use sound science, common sense, and remember the Golden Rule.
Please send any questions or comments to Chris at. firstname.lastname@example.org Thank you.
Thanks to public opposition we stopped the unconstitutional Vessel Monitoring System part of CEBA3 from becoming law. The SAFMC has created Amendment 30 trying to force Orwellian Vessel Monitoring Systems on us again. Please send the council an email opposing VMS. Thank you. email@example.com
Public Comments Regarding Comprehensive Ecosystem-Based Amendment 3
My name is Chris McCaffity. I am a commercial snapper/grouper fisherman who is deeply concerned about the negative impacts associated with CEBA3’s Orwellian Vessel Monitoring System. CEBA3 offers the South Atlantic Fishery Management Council a chance to help the fish, fishermen, and consumers they serve. Unfortunately, the council appears to be using CEBA3 to violate the Constitutional Rights of a small minority group without enough money, power, or numbers to stop this attack on our liberty.
The SAFMC wants to force commercial fishermen through CEBA3 to buy expensive and intrusive Vessel Monitoring Systems to track where we are fishing and keep us out of Marine Protected Areas. We already report where we fish when submitting logbooks. Marine Protected Areas are only closed to bottom fishing at this time. We can legally target pelagic species within MPAs. This alone negates the need for OVMS. Please have mercy on the fishermen who have
suffered severe financial hardship as a result of reduced quotas that are not being managed properly. We do not need another expense added to the list of higher costs related to using more time, bait, and fuel as we discard and run
from abundant fish that are illegal to feed people.
The SAFMC also wants to use CEBA3 to collect data about how many fish are being discarded and wasted due to the mismanagement of unnecessarily low quotas that are based on “fatally flawed data”. The council should be focused on creating a near full retention fishery instead of calculating how much seafood is being wasted as a result of mismanaged quotas. The council should be managing quotas in a multi-species fishery so that fishermen can keep some of everything we catch while targeting species with higher quotas and possession limits. Multiple extended closures create tons of Regulatory Discards that waste our resources, deny consumers access to local seafood, and compromise the safety of fishermen since we must stay at sea longer and in worse weather as we discard much of what we catch.
I pray council members will honor their oath to uphold and defend our Constitution from enemies foreign and domestic. I pray they will not violate our Fourth Amendment Rights by forcing OVMS on us. I pray those with the power to inflict harm on us will remember the Golden Rule as they vote. Please think about how you would like it if big brother forced everyone to pay some corporate or government bureaucracy to spy on our cars to make sure we obeyed all of the traffic laws. The public would rise up and say no to this attack on our freedom, privacy, and Constitution. Could that be why the council is not following Advisory Panel recommendations to require OVMS on ALL recreational and commercial vessels bottom fishing in federal waters? Would there be too many people impacted which might cause a public outcry loud enough to stop this? Maybe that’s why the council seems focused on violating the Constitutional Rights of a small minority group that cannot stop them. Would the council be so eager to advance this agenda if commercial fishermen had a Constitutional attorney willing to fight this all the way to our Supreme Court? Just because you can get away with something does not make it right.
CEBA3 is a good example of the “evils of bureaucracy” Joseph Pew warned us about when he started his PEW charity. These “evils” are unleashed on those a bureaucracy was created to help when otherwise good people are willing to collectively do the kind of harmful things to their fellow man that they would never dream of doing individually and feel absolved of any personal responsibility for their actions.
Here are some positive solutions that should be included in CEBA3.
1. Enhance existing Marine Protected Areas with Artificial Reef habitat.
2. Some fishermen have started using underwater video cameras to document what is actually under their boats. The council should start a voluntary program asking fishermen to send a video camera down at three locations during a trip. Data like water temperature, time, date, and location could be recorded with each video. We should be working together as liaisons rather than having a relationship that is more akin to tyrannical rulers and powerless subjects.
3. Require anyone caught bottom fishing in a MPA to have their vessel monitored rather than treating all of us
like criminals. We should not be considered guilty until proven innocent through spy equipment that we are forced to install, maintain, and pay for the monthly spy fee.
4. Incorporate future offshore windmills and oil rigs into MPAs. The platforms could have video cameras to
monitor MPAs above and below the surface. We should be looking into using these energy production and data collection platforms to mark the shipping lanes along the east coast. We need to THINK about how we can solve problems in ways that have as many positive benefits and as few negative impacts as possible. I know we can do better than we are now with the billions of dollars controlled by eco-charities, oil companies, and the multiple government agencies involved in this issue. Everyone could benefit with proper planning.
5. Start managing quotas so that everything is legal to keep at the same time. This would almost eliminate the tons of Regulatory Discards occurring during multiple extended closures while giving consumers a dependable supply of safe American seafood.
The Congressional deadlines to end overfishing have been met. Now the council should be focused on properly managing existing quotas and collecting accurate data to use in credible stock assessments before rushing to
pass anything else that will negatively impact fishermen.
I respectfully ask every voting SAFMC member to vote AGAINST any and all Vessel Monitoring Systems. Please do not put another unnecessary financial burden on beleaguered fishermen. Please have mercy on us and treat us as you would like to be treated if the roles were reversed. Thank you!
This is an ongoing issue. Please send the SAFMC an email saying you support the freefish7 MPA solutions. Thank you. firstname.lastname@example.org
Public Comments Regarding Marine Protected Areas
My name is Chris McCaffity. I am a commercial fisherman who believes Marine Protected Areas (MPAs) could be good
for our fisheries IF done properly. Unfortunately, I have ZERO confidence in the South Atlantic Fishery Management Council (SAFMC), National Marine Fisheries Service (NMFS), or National Oceanic and Atmospheric Administration (NOAA) to set them up correctly. The continued gross mismanagement of our fisheries under the control of these bureaucracies requires me to oppose MPAs or any other actions until they collect accurate data to use in credible stock assessments and properly manage quotas of commercially important species.
Once quotas are properly managed and based on sound science and accurate data rather than questionable equations using “fatally flawed data” this is the way I would like to see MPAs created and monitored.
1. MPAs should be limited to a few small key areas that will have as many positive benefits and as few negative impacts as possible.
2. Equal areas of new Artificial Reefs (ARs) should be created to offset any MPAs. MPAs could even be ARs designed to support certain species and placed in appropriate areas.
3. Create Data Collection Platforms (DCPs) on MPAs to monitor them rather than forcing fishermen to buy expensive and intrusive Orwellian Vessel Monitoring Systems (OVMS) and then forcing us to pay some corporate or government bureaucracy to spy on us.
The DCPs could be powered by wind, wave, solar, and tidal energy. They could have cameras above and below the water to constantly monitor each MPA. They could collect all kinds of data at various levels of the water column. The platforms would be Artificial Reefs that will increase the total bio-mass each MPA can support. They would provide a visual marker for fishermen to avoid or seek as safe refuge in case of emergency. DCPs could be paid for with funds from the Saltonstall-Kennedy tax on imported seafood and by reallocating millions of dollars NOAA is squandering every year advancing unwanted catch share schemes. Maybe some environmental groups involved in our fisheries would be willing to provide staff and grants to help operate the DCPs. This plan for setting up and monitoring MPAs would help preserve our fisheries while providing much needed data and protecting our Constitutional Rights. I would also like to see incidental take tags for Warsaw Grouper and Speckled Hind to collect data for setting up MPAs.
I have included the Sustainable Seafood and Regulatory Discard Reduction Plan for properly managing existing and future quotas. Please use this as a guide to solving problems created in the councils rush to meet hard deadlines in the Magnuson-Stevens Act before writing new laws.
Please contact me if you have any questions about incidental take tags, DCPs, OVMS, or what it would take to get my support for MPAs. email@example.com Thank you.
Sustainable Seafood and Regulatory Discard Reduction Plan
My name is Chris McCaffity. I am a commercial fisherman who has been offering positive solutions that would greatly
reduce the amount of Regulatory Discards in our snapper/grouper fishery. Tons of fish are being discarded every year that die and go to waste rather than feeding hungry people. Most of this waste is avoidable. It is very troubling that many fishery managers, environmentalists, and fellow fishermen will not support simple solutions to solve this problem. Some of them have different agendas the Regulatory Discards help to advance. Some people do not support any solutions I offer because they disagree with my view that most size limits do more harm than good. Some people do not like that I discuss fishery issues with PEW and other eco-charities. Some fishermen do not think it matters what we say because the fishery managers are going to do what they want anyway. Their silence and apathy passively supports the gross mismanagement that wastes our resources, destroys our businesses, and denies us access to American seafood. We don’t have to agree on every issue to work together on others. I respectfully ask everyone reading this plan to publicly support it or offer a better solution. A wise Marine once told me this. “If you are going to complain, you need to offer a solution.”
The main source of Regulatory Discards in our commercial snapper/grouper fishery comes from quotas that were drastically reduced based on “fatally flawed data” and are not being properly managed to avoid early closures. The long closures force us to discard thousands of fish and compromise our safety at sea as we must stay longer and in worse weather to catch enough legal fish to pay the bills. Since December of 2009 I have been promoting the idea that quotas should be managed with possession limits that are adjusted after a predetermined amount of a quota has been landed to a level that fills it without a long closure. This common sense plan incorporates suggestions from individuals involved in managing, catching, and selling seafood.
1. Split the Annual Catch Limit (ACL) for commercially important snapper/grouper species into two seasonal quotas beginning in April and October.
2. Manage each seasonal quota with Trip Poundage Limits (TPLs) that are adjusted after half of a quota has been landed to a level that fills it without a long closure.
3. Require fishermen and dealers to file electronic logbooks within 72 hours of unloading.
Here are a few examples of how the TPLs should be set up and adjusted to avoid early closures. Any overages should be deducted from the next season and any remaining quota should carry over. The seasons should start when conditions are best so the TPLs are high during that period. The TPLs should be raised when quotas are increased as stocks rebuild and new assessments are done. Reducing Regulatory Discards should allow us to start keeping more of the Total Allowable Catch immediately. This would help to keep TPLs higher longer and feed more people without killing any more fish than we do now.
Gag Grouper and Red Grouper: The first season would begin on April 1st with a 100 pound TPL on each species due to the spawning season. The TPLs would be raised to 1,000 pounds on May 1st. Each TPL would then be adjusted to a level that fills the seasonal quota without a long closure after half of the quota has been landed.
This is how the adjustments should be made.
1. The TPL would be reduced to 300 pounds if there are four months left in the season.
2. The TPL would be reduced to 500 pounds if there are three months left in the season.
3. The TPL would remain at 1,000 pounds if there are two months left in the season.
4. The TPL would increase to 1,500 pounds if there is only one month left in the season.
The second season would begin on October 1st with a 1,000 pound TPL. The spawning season would require a 100
pound TPL from January through March to keep fishermen from targeting shallow water grouper. The 100 pound TPLs for three months should keep the quotas from being filled early and negate the need for further adjustments.
Vermilion Snapper, Black Sea Bass, and Trigger Fish: The first season would begin on April 1st and the second on October 1st with a 1,000 TPL for each species. This is how the adjustments should be made after half of each seasonal quota has been landed.
1. The TPL would be reduced to 100 pounds if there are five months left in the season.
2. The TPL would be reduced to 300 pounds if there are four months left in the season.
3. The TPL would be reduced to 500 pounds if there are three months left in the season.
4. The TPL would remain 1,000 pounds if there are two months left in the season.
5. The TPL would increase to 1,500 pounds if there is only one month left in the season.
Snowy Grouper: The first season would start on April 1st and the second on October 1st with a 500 pound TPL. This is how the adjustments should be made after half of each seasonal quota has been landed.
1. The TPL would be reduced to 100 pounds if there are five months left in the season.
2. The TPL would be reduced to 200 pounds if there are four months left in the season.
3. The TPL would be reduced to 300 Pounds if there are three months left in the season.
4. The TPL would remain 500 pounds if there are two months left in the season.
5. The TPL would increase to 1,000 pounds if there is only one month left in the season.
Wreck Fish: The 2,000,000 pound quota was not being caught due to a catch share scheme that consolidated that fishery into the hands of two permit holders. The council arbitrarily reduced that quota to 225,000 pounds rather than allowing other permit holders to catch those fish. I propose this compromise. Allocate 775,000 pounds of the Wreck Fish quota to the rest of the snapper/grouper permit holders. This would boost the market for Wreck Fish and take some of the pressure off of inshore species while still cutting the previous quota in half. The first seasonal quota would begin on April 1st and the second on October 1st with a 2,000 pound TPL. This is how the adjustments should be made after half of each seasonal quota has been landed.
1. The TPL should be reduced to 500 pounds if there are five months left in the season.
2. The TPL should be reduced to 1,000 Pounds if there are four months left in the season.
3. The TPL should be reduced to 1,500 pounds if there are three months left in the season.
4. The TPL should remain 2,000 pounds if there are two months left in the season.
5. The TPL should increase to 3,000 pounds if there is only one month left in the season.
This plan would allow fishermen to target species with high TPLs while still keeping the ones we accidentally catch with lower TPLs. It would greatly reduce the number of Regulatory Discards while providing consumers with fresh local seafood all year. This common sense approach to managing quotas would achieve any honorable goals of catch shares without destroying independent artisanal fishermen in favor of large corporate industrial fishing operations.
The hard deadlines to end overfishing in the Magnuson-Stevens Act have been met. The South Atlantic Fishery Management Council should not take any further action until they have properly managed the quotas they set using “fatally flawed data” and collected accurate data to use in credible stock assessments. Any future management measures should focus on enhancing our fisheries rather than restricting our freedom to access a dependable supply of safe American seafood. One way to enhance our fisheries is with Artificial Reefs that are the perfect union of aquaculture and commercially or recreationally harvested wild fish.
We should all have a common goal of healthy fisheries that can be responsibly harvested forever with very little waste. We can achieve that goal if we work together using accurate data, sound science, common sense, and remember the Golden Rule.
Thank you for taking the time to read this. Please send any questions or comments to Chris at. firstname.lastname@example.org
I welcome a debate or discussion about TPLs, MPAs, catch shares, size limits, or any other fishery issues with anyone. We need to have open and honest discussions about how our seafood should be managed with as few negative impacts and as many positive benefits as possible. We need to make wise use of our renewable resources and show other fishery managers by example how they can reduce Regulatory Discards, feed more people, and produce more revenue while insuring stocks of sustainable seafood for future generations.
June 2013 SAFMC Meeting Public Comments
I am Chris McCaffity, a commercial fisherman who believes it is important to offer positive solutions that limit waste, feed more people, produce more revenue, and protect our fisheries for future generations.
I would like to start by asking the council not to pass Amendment 30’s Vessel Monitoring System law. Passing Amendment 30 against overwhelming public opposition would jeopardize your Visioning Project’s good-will intentions and those of NMFS’ Marine Research Education Program. Both are intended to get stakeholders more involved in the management process. We need to use these outreach programs to discuss better ways to monitor closed areas and collect data without the negative impacts of VMS.
Next, I would like to touch on Regulatory Amendment 14. The commercial Triggerfish quota should be split into two six month seasons that align with Vermilion Snapper openings to avoid excessive Regulatory Discards. Triggerfish should have a 1,000 pound possession limit until 75% of a quota has been landed. The possession
limit should be reduced to 300 pounds for the final 25% of a seasonal quota to avoid extended closures like
we could see this year. Triggerfish have tough mouths that are usually damaged when removing circle hooks resulting in high discard mortality rates. Please do not mandate the waste of more seafood with size limits for Triggerfish. The Black Sea Bass size limit should revert back to the science-based eight inches to reduce Regulatory Discards. Black Sea Bass should have a 1,000 pound possession limit until 75% of the commercial quota has been landed and reduce it to 300 pounds for hook and line only to extend seasons. Triggerfish, Black Sea Bass, Vermilion Snapper, and most fish should have some kind of By-catch Allowance after the primary quotas are filled to avoid dead discards. Half of the poundage allocated to dead discards along with 10% of each seasonal quota should be set aside for By-catch Allowances after closures. This model should be applied to every species with closures of more than a few weeks. Fishermen could target species with higher possession limits while still being allowed to keep most of what we accidentally catch with lower limits. We need to be working
toward full retention fisheries with quotas that are managed to avoid total closures of most species.
Regulatory Amendment 15 allocated another 27,218 pounds of Gag Grouper quota to dead discards. That is almost 10% of the annual commercial gag quota in addition to the 81,000 pounds already being deducted for other dead discards. We should be looking at ways to reduce Regulatory Discards by doing things like setting aside the 27,218 pounds for a 50 pound By-catch Allowance after the primary quota has been landed to avoid
A positive alternative to closing more areas to fishing would be for the council to focus on enhancing existing Marine Protected Areas with artificial reef habitat rather than rushing to close more areas. The argument against artificial reefs has been that they congregate fish and make them easier for fishermen to catch. I would argue that is not a bad thing as long there are quotas and possession limits in place to avoid overfishing. Artificial reefs would take pressure off of natural habitat while also benefitting non-target species. This would be the perfect union of aquaculture and wild-caught seafood that lives free and self-sufficient until harvested. Artificial reefs would also be perfect for protecting marine life in closed areas.
The Visioning Project provides an opportunity for stakeholders to get involved in the management process. It would be helpful if anyone interested in taking part would submit a vision of what they would like
to see for the future of our fisheries. We should have open and honest discussions about how we can achieve our goals within the Magnuson-Stevens Act mandates and in ways most of those participating would support. There are no Congressional mandates or timelines preventing us from taking our time and doing this right. We need to think things through and look at the big picture. We need to put any amendments not related to reducing Regulatory Discards on hold while focusing on creating a vision for the future of our fisheries that has as many
positive benefits and few negative impacts as possible for fish and fishermen as well as seafood dealers and consumers.
In closing, I respectfully ask the council not to pass Amendment 30’s VMS law or close any more areas. Please
focus on properly managing quotas to avoid extended closures and excessive Regulatory Discards as we work on the Visioning Project.
Thank you for considering my comments. Feel free to ask me any questions. email@example.com
May 2013 Marine Fisheries Commission Meeting Public Comments
I am Chris McCaffity, a commercial fisherman who is deeply concerned about the future of our fisheries in North
Carolina and America. I am concerned about the tons of dead discards being wasted every year. I am concerned about 91% of our seafood being imported from foreign nations that have very little if any regulation. I am concerned about NOAA’s recent document stating that many recreational fisheries will be catch and release only within a decade as dead discards fill quotas. I am concerned that independent food producers are being
driven out of business. I am concerned that we are losing our freedom to fish and eat fresh local seafood.
A wise Marine once told me that if you are going to complain about something, you need to offer a solution to solve the problem. I propose that the Marine Fisheries Commission begin a Visioning Project modeled after the one being led by Dr. Michelle Duval for the South Atlantic Fishery Management Council. We need stakeholders and concerned citizens to offer positive solutions that follow the Fisheries Reform Act. We need to have open and honest discussions about the future of our fisheries and how we want to see them managed. We need to discuss ways we can maximize the value of our commercial and recreational fisheries while limiting waste and feeding more people. We also need to discuss ways to reduce pollution and fish kills.
Here are some examples of things we should discuss in a Visioning Project.
1. Establish separate commercial and recreational quotas.
2. Allow two licensed commercial fishermen working together to each keep their legal possession limits to reduce regulatory discards and amount of gear in the water.
3. Require single barbless hooks for catch and release fisheries to decrease discard mortality rates.
4. Allow a minimum of one fish and up to 10% of a catch to be undersized or over the limit.
5. Remove size limits and restrict releases to legal bag limits during July and August when water temperatures are high and oxygen levels are low resulting in higher discard mortality rates. Use this as a promotion to lure
fishermen who want to eat the seafood they catch.
6. Offer fishing license wavers for Veterans on Veteran’s Day and Dads taking their kids fishing on
Father’s Day to promote tourism.
7. Consider how portable aerators could break down pollutants and be moved to areas with low oxygen levels or creeks during cold-stun events to limit fish kills.
8. Look at ways to process scraps from cleaned and unmarketable seafood into feed pellets for pond-raised species so we make the most efficient use of our resources.
9. We could promote culinary and heritage tourism based on fresh seafood that is sustainably harvested by local independent fishermen.
These are just a few ideas that could limit waste while promoting tourism and securing our supply of local seafood. It is important that we realize our seafood is a renewable source of food that should be managed so we make the most efficient use of what can be sustainably harvested. We can come up with many more solutions that would yield positive results through a MFC Visioning Project that taps into fishermen’s centuries of collective on-the-water knowledge. Recreational and commercial fishermen should work together with fishery managers and scientists as liaisons rather than having more of an adversarial relationship that many feel we have now.
I respectfully ask this commission to begin a Visioning Project and ask the NC Legislature to wait until it is completed before voting on any bills related to fishery management including HB-983.
I would also like to ask the commission to publicly comment on a few South Atlantic Fishery Management
1. Please oppose Vessel Monitoring Systems before the June meeting.
2. Please support aligning opening dates of co-occurring snapper/grouper species to reduce regulatory discards like we are seeing with Black Sea Bass this month.
3. Please support enhancing existing Marine Protected Areas with artificial reef habitat before
rushing to close more areas to recreational and commercial fishing.
I believe almost everyone has a common goal of responsibly harvested healthy fisheries. It is how we achieve that goal that needs to be discussed. I am willing to offer ideas and discuss them. I hope others will think about and offer solutions for our fisheries that have as many positive benefits and few negative impacts as possible. We don’t have to agree on every issue to come up with a plan most open-minded people can support.
Thank you for considering my comments. Feel free to ask me any questions.