Coastal Conservation Association
Comments on The Gulf of Mexico
Fishery Management Council

Red Snapper Rebuilding Plan
(Amendment 22)

• CCA generally supports development of this formal rebuilding plan for red snapper. However, we do believe that the current estimate of maximum sustainable yield (MSY) for the Gulf red snapper fishery (41.13 million pounds) is overly optimistic and urge the Council to have this value carefully reconsidered during the coming stock assessment in 2004.

• CCA supports the proposed time frame for rebuilding the stock (32 years) and the proposals to set annual harvest limits by five year intervals.

• Because 99.5% of all red snapper bycatch is taken by the Gulf shrimp fishery, dramatic reduction of shrimp trawl bycatch should receive the highest priority from the National Marine Fisheries Service.

• Again, we note that shrimp trawl bycatch must be reduced to afford the hope of a healthy resource in the future. Amendment 22 notes this problem but does not propose any new regulations to further reduce shrimp trawl bycatch. We ask that the Council vigorously pursue this issue in Amendment 14 to the Shrimp Fishery Management Plan. We support a hard bycatch quota for the shrimp fleet to reduce juvenile red snapper bycatch.