CCA Comments on Amendment 29 to the Gulf of Mexico Reef Fish Plan
Adoption of any amendment must be supported by the record. Even initial decisions, like who can participate in the plan, have to be supported by an analysis of the existing data and the impacts of the decision. It is simply not adequate to conclude at the outset that only the commercial sector can have an ITQ. The agency’s total focus on the commercial sector of this fishery dooms this amendment from being legally sufficient.
Read full comments here.