The recent proposed and upcoming complete closure of all bottom fishing in all or part of the South Atlantic Ocean and Gulf of Mexico is but yet another over reach of our Federal Government that they claim is based on Science.

The truth is their science is based solely on the desires of management of the National Marine Fisheries Council, a cabal of Washington bureaucrats whose goal is to create long term job security for themselves by over regulating a problem that no longer exists. The National Marine Fisheries Council gathered information back in 2009 and 2010 indication that the American Red Snapper stock was being depleted by over fishing. They developed and implemented a rebuild plan regulating and restricting the harvest of these fish to allow for their recovery to sustainable numbers.

Studies in 2017 and 2021 indicated that red snapper were currently recovering and are on track with their rebuild plan scheduled to expire by 2044 with the population restocked. They then in the same report claimed that the red snapper were being over fished due to being caught by anglers targeting other species of reef fish and further restrictions were necessary.

Their “Scientists and Statisticians” also claim that the numbers of dead red snapper releases “far outnumber the fish removed from the population by harvest”. This claim according to their documentation appears to be based on data from a 2002 and 2004 study compiled by Burns et al. The study claimed that the mortality rate is 64% but does not identify how this percentage was derived. How do they know that 64% of the fish released back into the ocean don’t survive? That is a very specific number. How can they scientifically prove this percentage?

This data for these estimates were gathered pre J hook prohibition and pre-mandatory venting and descending device requirements that were implemented to improve mortality rates. Apparently that had no effect in reducing the percentage of mortality. It appears that these are the statistics currently still in use although the publication acknowledges that the information was gathered from commercial log books only, and they have no independent scientific data on recreational fishing mortality. The document states, commercial fish mortality is believed to be higher based on other studies conducted. On a spread sheet identified as SEDAR 73 landings and dead releases, used as a part of the new “ Decision Document they show recreational dead releases for snapper being 519,470 fish and the commercial dead release being 48,070 fish for fiscal year 2019. There is currently no requirement of recreational fishermen to report their catch or released snapper, mortality data or fishing depths so where are these” statistical” numbers coming from? They factually can not be based on scientific data. They do not specify where they obtained their information but if it was gathered from the dock surveys conducted during the recreational snapper season the numbers are already proven to be inaccurate as some catches were recorded as many as 4 times.

With the prohibition of J hooks and the mandating of venting and descending devices why are they claiming the mortality rates are increasing? Are they suggesting the procedures they mandated are causing a higher mortality rate? Further, if the mortality rates were really a concern why does N.O.A.A. schedule the recreational snapper season in the middle of their peak breeding season, June to August? Would you not want to protect them during their peak breeding time when the fish are congregated?

Why do they admit to “ A recurring statistical problem in that there are so many red snapper that discards in bycatch are causing the fishery to be over fished.” They state that red snapper in Florida are at record high levels.( Even with the 65% mortality of released fish?) N.O.A.A. was calling for the 2021 and 2022 surveys conducted during the recreational snapper season be expanded into Georgia and South of Cape Canaveral Florida due to the spread of the species into new areas. Why are they expanding their historic geographical area if they are not over populating past carrying capacity already? How could this be if as they claim 65% of the released catch die? N.O.A.A. currently claims the red snapper population will not be stable until 2044? Are they scheduled to receive funding through 2044? If they were to admit that the red snapper population was now stable what would happen to their funding for this project?

Florida Fish and Wildlife officials agree that the “ Science” that N.O.A.A.’s Scientific Statistical Committee is currently using is flawed and has initiated its own “Scientific Survey” that began in August, 2024 and was scheduled to run for 12 months to gather more accurate scientific data by true methods and practices excepted by the scientific community. I have personally observed their data collection process and methods. They are trying to hold to true scientific methodology. I have been certified in court as an expert witness in the Scientific Method.

Recently the Fisheries Council butted heads with their own Advisory Council when the council reported that it was their opinion that the red snapper population had already recovered and they dis-agreed with the South Atlantic Fisheries Council that there needed to be “ PUNITIVE ACTIONS “against the recreational fishermen closing all or large portions of the South Atlantic to all bottom fishing. The advisory council felt they were trying to solve a problem that no longer existed based on their experience and observations in the ocean, unlike the councils speculations from behind their desks in Washington.

There is definitely some degree of mortality in released red snapper from recreational fishing. I am confident it is no where near 65% as the National Marine Fisheries claims. My guess is as good or probably better than theirs and is based on actual observations while in the ocean fishing, my estimate is around15% mortality.
As a 45+ year captain in the waters off of Central Florida I will attest to the fact that the over population of sharks and Goliath Grouper contributes to the highest percentage of the mortality rates of released snapper, significantly more than barotrauma of gill damage from swallowed hooks, but this issue is ignored by the Council as if it does not exist. Relaxing the restrictions on harvesting these fish are not even considered by the council is part of a solution to relieve the mortality issue.

To close I find it extremely suspicious that the National Marine Fisheries Service and N.O.A.A. are urgently trying to close all reef fishing immediately after Florida Fish and Wildlife initiates a survey that is being conducted using the true Scientific Method and is gathering accurate information based on verifiable data, personal observations by their biologists that are out there on the boats recording footage and laboratory analyses. Shutting down this project in the name of preserving reef fish is their way of eliminating rebuttal witnesses to their crimes. The only story ( statistics) told is the one the National Marine Fisheries tell.