Coastal Conservation Association Testimony
Gulf of Mexico Fishery Management Council
Reef Fish Amendment 30A
Amberjack and Gray Triggerfish 

CCA is a grassroots organization with almost 100,000 members in 17 state chapters across the country dedicated to the conservation, promotion and enhancement of the present and future availability of coastal resources for the benefit and enjoyment of the general public. CCA has been active in local, state and federal fishery management issues for more than 30 years.  

The Gulf Council has found that the harvest of both gray triggerfish and amberjack need to be modified in order to correct problems within those fisheries. Regarding gray triggerfish, CCA recommends a change in length from a 12-inch total length to a12-inch fork length to solve the overfishing problem. 

The state of affairs surrounding amberjack is more complicated. The Gulf of Mexico Fishery Management Council has found that Gulf greater amberjack are overfished and that the catch levels must be reduced to generate a recovery.  CCA does not disagree with this conclusion. However, we believe that the significant factors that led to overfishing were the lack of a commercial quota and any effort to hold that sector within its allocated share.  Today, commercial landings have risen to 32 percent of the total catch, double its allocation that was assigned in 1990. 

CCA recommends maintaining status quo on the allocation and increasing the recreational minimum size to 30 or 31 inches with the bag limit remaining at 1. Most importantly, the Council should set a commercial quota that is enforced at no more than 294,000 pounds a year.  

To support this recommendation, we submit the following points: 

• The only reason that the recreational share of this fishery has fallen to 68 percent today was the failure of the National Marine Fisheries Service and the Gulf Council to control commercial harvest.
   
• The regulations implemented in 1990 were supposed to yield a 45 percent reduction in commercial and recreational landings.  According to the data included in the public hearing documents, in the four years following implementation of those regulations commercial landings dropped only 22 percent.  In the same years, recreational landings were reduced by 42 percent.  Why was this failure to attain the conservation goal allowed to continue in the commercial sector? Why should the commercial sector benefit from that failure today?
   
• There has never been a re-allocation of resources from the commercial to the recreational sector in the history of the Gulf Council’s operations.
   
• The allocation of Gulf amberjack does not need to be changed; it needs to be enforced. There is no sense of fairness or good governance in forcing the recreational sector to suffer from the lack of controls over the commercial fishery.