2.0 MANAGEMENT ALTERNATIVES

**Action 1. Measures to revise the red snapper rebuilding plan and end
overfishing of red snapper by 2009 or 2010.**

On March 12, 2007, the United States District Court for the Southern
District of Texas, Houston Division, issued a ruling on legal challenges
to the current red snapper rebuilding plan contained in Amendment 22 to
the Reef Fish FMP. The Court ruled the rebuilding plan in Amendment 22
had less than a 50 percent chance of rebuilding red snapper by 2032 and,
therefore, required a new rebuilding plan be established within 9 months
of the ruling (i.e., December 12, 2007).  However, the Council had
already initiated Joint Amendment 27/14 to further reduce harvest and
bycatch of red snapper and to maintain the rebuilding trajectory
approved in Amendment 22 based on the findings of SEDAR 7 (2005) that
indicated red snapper were undergoing overfishing and the stock was
still overfished.

The following alternatives describe four red snapper rebuilding plans
and management measures associated with each rebuilding plan to
constrain recreational harvest within the allocated quota. With the
exception of quota reductions, no measures are proposed to further
constrain commercial harvest because the commercial fishery operates
under an IFQ program; quota shares are reduced proportionally based on
the number of shares a fisherman possesses at the time of the quota
reduction. Recreational management measures necessary to achieve various
TACs are summarized for each alternative. The length of the recreational
fishing season specified for each alternative is based on allowing
captain and crew to retain bag limits of red snapper while under
charter. If captain and crew are prohibited from retaining bag limits of
red snapper (see Action 3) then the length of the recreational fishing
season will be longer (see Table 2.1).

Reductions in TAC for each of the alternatives in this action are based
on baseline levels of directed red snapper fishery landings and fishing
effort during 2001-03 and assume no post-hurricane reductions in fishing
effort/landings. Table 2.1 summarizes the length of the fishing season
for each of the alternatives in Action 1 if a 10 or 25 percent reduction
in post-hurricane fishing effort/landings is assumed and the captain and
crew red snapper bag limit is set to zero (Preferred Alternative 2 in
Action 3). Similar reductions in commercial red snapper landings are not
assumed because the fishery is operating under an IFQ program as of
January 1, 2007.

**Alternative 1. No Action -- Do not revise the rebuilding plan approved
in Amendment 22 to the Reef Fish Fishery Management Plan. Maintain a
constant 9.12 MP TAC until 2032; the commercial quota would remain at
4.65 MP and the recreational quota would remain at 4.47 MP. Review and
adjust the rebuilding plan and directed fishery management measures, as
necessary, based on periodic stock assessments and Magnuson-Act mandates
(e.g., annual catch limits). The 16-inch minimum size limit, 4-fish bag
limit, and recreational fishing season from April 21 through October 31
(194 days).**

**Alternative 2. Revise the red snapper rebuilding plan in Reef Fish
Amendment 22 by reducing TAC to 7.0 MP between 2008 and 2032; the
commercial quota would be 3.57 MP and the recreational quota would be
3.43 MP. Review and adjust the rebuilding plan and directed fishery
management measures, as necessary, based on periodic stock assessments.
Management measures to achieve the 3.43 MP recreational quota would
be:**

> **Option a. 4-fish bag limit, 16-inch minimum size limit, and:**
>
> **Suboption i. May 15 -- September 30 recreational fishing season (139
> days).**
>
> **Suboption ii. Gulfwide weekend openings. Recreational fishing season
> May 15 -- August 31 plus 8 consecutive weekends after August 31 (125
> days).**
>
> **Suboption iii. Texas weekend openings. In the EEZ off Texas,
> recreational fishing season May 15 -- August 31 plus 8 consecutive
> weekends after August 31 (125 days). In the rest of the EEZ, May 15 --
> September 30 recreational fishing season with no weekend openings (139
> days).**
>
> **Suboption iv. Western Gulf weekend openings. In the EEZ west of the
> Mississippi River, May 15 -- August 31 recreational fishing season
> plus 8 consecutive weekend openings after August 31 (125 days). In the
> EEZ east of the Mississippi River, May 15 -- September 30 recreational
> fishing season with no weekend openings (139 days).**
>
> **Option b. 3-fish bag limit and:**
>
> **Suboption i. 16-inch minimum size limit and May 15 -- October 15
> recreational fishing season (154 days).**
>
> **Suboption ii. 15-inch minimum size limit and June 1 -- October 15
> recreational fishing season (137 days).**
>
> **Option c. 2-fish bag limit and:**
>
> **Suboption i. 15-inch minimum size limit and May 15 -- October 15
> recreational fishing season (154 days).**
>
> **Suboption ii. 13-inch minimum size limit and May 15 -- September 15
> recreational fishing season (124 days).**
>
> **Suboption iii. 15-inch minimum size limit and Gulfwide weekend
> openings. Recreational fishing season May 15 -- August 31 plus 12
> weekend openings after August 31 (133 days).**
>
> **Suboption iv. 15-inch minimum size limit and Texas weekend openings.
> In the EEZ off Texas, May 15 -- August 31 recreational fishing season
> plus 12 consecutive weekends after August 31 (133 days). In the rest
> of the EEZ, May 15 -- October 15 fishing season with no weekend
> openings (154 days).**
>
> **Suboption v. 15-inch minimum size limit and western Gulf weekend
> openings. In the EEZ west of the Mississippi River, May 15 -- August
> 31 recreational fishing season plus 12 consecutive weekend openings
> after August 31 (133 days). In the EEZ east of the Mississippi River,
> May 15 -- October 15 recreational fishing season with no weekend
> openings (154 days).**

**Preferred Alternative 3. Revise the red snapper rebuilding plan in
Reef Fish Amendment 22 by reducing TAC to 5.0 MP between 2008 and 2010;
the commercial quota would be 2.55 MP, and the recreational quota would
be 2.45 MP. After 2010, TAC would correspond to the level of catch
associated with fishing at rate that produces MSY (proxy = 26 percent
SPR). Review and adjust the rebuilding plan and directed fishery
management measures, as necessary, based on periodic stock assessments.
Management measures to achieve the 2.45 MP recreational quota would
be:**

> **Preferred Option a. 2-fish bag limit, 16-inch minimum size limit,
> and:**
>
> **Preferred Suboption i. June 1 -- September 15 recreational fishing
> season (107 days).**
>
> **Suboption ii. May 1 - July 31 recreational fishing season (92
> days)**
>
> **Option b. 2-fish bag limit, 16-inch minimum size limit and:**
>
> **Suboption i. May 15 -- August 15 recreational fishing season (92
> days)**
>
> **Suboption ii. Gulfwide weekend openings. July 1 -- July 31
> recreational fishing season plus 6 weekends immediately prior to July
> 1 and 7 weekends immediately after July 31 (57 days).**
>
> **Suboption iii. Texas weekend openings. In the EEZ off Texas, July 1
> -- July 31 recreational fishing season plus 6 weekends immediately
> prior to July 1 and 7 weekends immediately after July 31 (57 days). In
> the rest of the EEZ, May 15 -- August 15 recreational fishing season
> with no weekend openings (92 days).**
>
> **Suboption iv. Western Gulf weekend openings. In the EEZ west of the
> Mississippi River, July 1 -- July 31 recreational fishing season plus
> 6 weekends immediately prior to July 1 and 7 weekends immediately
> after July 31 (57 days). In the rest of the EEZ, May 15 - August 15
> recreational fishing season with no weekend openings (92 days).**
>
> **Option c. 2-fish bag limit, 15-inch minimum size limit and May 15 --
> August 10 recreational fishing season (88 days).**
>
> **Option d. 2-fish bag limit, 14-inch minimum size limit and:**
>
> **Suboption i. May 15 -- July 31 recreational fishing season (77
> days).**
>
> **Suboption ii.** **June 1 -- August 15 recreational fishing season
> (76 days).**

**Suboption iii. May 1 -- July 9 recreational fishing season (71
days).**

**Option e. 2-fish bag limit, 13-inch minimum size limit and June 1 --
July 31 recreational fishing season (61 days).**

**Option f. 1 fish bag limit, 14-inch minimum size limit and:**

**Suboption i. June 1 -- September 30 recreational fishing season (122
days).**

**Suboption ii. May 1 -- August 10 recreational fishing season (102
days).**

**Option g. 1 fish bag limit, 16-inch minimum size limit, and:**

**Suboption i. May 15 -- October 15 recreational fishing season (154
days).**

**Suboption ii. May 1 -- September 15 recreational fishing season (138
days).**

**Alternative 4.** **Revise the red snapper rebuilding plan in Reef Fish
Amendment 22 by reducing TAC to 3.0 MP between 2008 and 2010; the
commercial quota would be 1.53 MP, and the recreational quota would be
1.47 MP. After 2010, TAC would correspond to the level of catch
associated with fishing at rate that produces MSY (proxy = 26 percent
SPR). Review and adjust the rebuilding plan and directed fishery
management measures, as necessary, based on periodic stock assessments.
Management measures to achieve the 1.47 MP recreational quota would
be:**

> **Option a. 2-fish bag limit, 16-inch minimum size limit, and**
>
> **Suboption i. August 1 -- September 15 recreational fishing season
> (46 days).**
>
> **Suboption ii. Gulfwide weekend openings. August 1 -- August 31
> recreational fishing season plus 2 weekends immediately prior to
> August 1 and 2 weekends immediately after August 31 (39 days).**
>
> **Suboption iii. Texas weekend openings. In the EEZ off Texas, August
> 1 -- August 31 recreational fishing season plus 2 weekends immediately
> prior to August 1 and 2 weekends immediately after August 31 (39
> days). In the rest of the EEZ, August 1 -- September 15 recreational
> fishing season with no weekend openings (46 days).**
>
> **Suboption iv. Western Gulf weekend openings. In the EEZ west of the
> Mississippi River, August 1 -- August 31 recreational fishing season
> plus 2 weekends immediately prior to August 1 and 2 weekends
> immediately after August 31 (39 days). In the rest of the EEZ, August
> 1 -- September 15 recreational fishing season with no weekend openings
> (46 days).**
>
> **Option b. 2-fish bag limit, 15-inch minimum size limit, and August 1
> -- September 8 recreational fishing season (39 days).**
>
> **Option c. 2-fish bag limit, 14-inch minimum size limit, and August 1
> -- September 4 recreational fishing season (35 days).**
>
> **Option d. 2-fish bag limit, 13-inch minimum size limit, and August 1
> -- August 31 recreational fishing season (31 days).**

**Table 2.1. Length of the recreational red snapper fishing season for
alternatives in Action 1 if captain and crew are allowed or are
prohibited from retaining bag limits of red snapper while under charter
(see Action 2; Note: the change in fishing season length for various
alternatives in some cases exceed 3-7 days. This is because closed
seasons summarized in Action 1 were analyzed in 15-day increments and
reductions in harvest for some alternatives are slightly greater than
necessary to meet specified TACs. As a result, when alternatives in
Action 1 are combined with a zero captain and crew bag limit, the season
can be extended in some instances longer than 3-7 days).**

![](media/image1.wmf)

**Red Snapper Allocation**

Since 1990, the red snapper fishery has been managed under an overall
TAC, which is allocated between the commercial (51 percent) and
recreational (49 percent) sectors. This allocation was established in
Amendment 1 to the Reef Fish FMP and is based on average commercial and
recreational landings during 1979-1987 (GMFMC 1989). All of the
rebuilding plans and alternatives in Action 1 continue to allocate the
TAC and quotas based on this allocation ratio, resulting in equal
proportion reductions to the commercial and recreational quotas.

**2008 Commercial Quota**

Interim regulations published on April 2, 2007, reduced the red snapper
TAC from 9.12 MP to 6.5 MP through September 29, 2007.  This temporary
reduction in TAC will expire after that time unless extended on an
interim basis for another 186 days.  The Council intends to further
reduce the red snapper TAC in 2008 to end overfishing and rebuild the
red snapper stock in compliance with the red snapper rebuilding plan. 
The Council\'s preferred red snapper TAC for 2008 is 5.0 MP (Action 1;
Alternative 3).  The Council is requesting NMFS implement this TAC
adjustment for the 2008 fishing year on or before January 1, 2008, to
ensure the amount of red snapper allocation issued to the commercial red
snapper IFQ fishery does not exceed the commercial quota defined by the
Council\'s preferred TAC for 2008 (51% of 5.0 MP, or 2.55 MP).  If NMFS
is unable to publish a final rule on or prior to December 1, 2007, to
implement this TAC adjustment for the 2008 fishing year, then the
Council requests NMFS issue only 2.55 MP of red snapper allocation to
the commercial red snapper IFQ fishery at the start of the 2008 fishing
season.  This will reduce the likelihood that NMFS would be required to
retract red snapper allocation from the commercial red snapper IFQ
fishery during the 2008 fishing year. 

**ABC and TAC**

Allowable biological catch (ABC) refers to a range of catches for a
species or species group that will produce the desired biological
results given a set of biological stock parameters and management
targets. Historically, the Council's Reef Fish Stock Assessment Panel
recommended ABC levels for red snapper. However, with the implementation
of the Southeast Data, Assessment, and Review (SEDAR) process, the SEDAR
panel now is tasked with reviewing the adequacy and appropriateness of
management benchmarks. During review of the red snapper stock
assessment, the SEDAR panel indicated it was not possible to specify an
ABC for red snapper without guidance from the Council on the level of
assumed shrimp bycatch reduction (SEDAR 7 2005).

Total allowable catch (TAC) is a level of catch that is set by managers
at or below the maximum ABC. The level of TAC is selected after
considering the biological, ecological and socioeconomic implications of
catch levels within the ABC range. The level of risk (i.e., failure to
attain management targets without a future reduction in TAC being
needed) should also be considered. In general, TACs set near the upper
end of the ABC range carry a greater risk of not ending overfishing and
rebuilding the red snapper stock than TACs set at a lower catch level.

The current 9.12 MP TAC has been in effect since 1996. Amendment 22 to
the Reef Fish FMP (GMFMC 2004a) revised the rebuilding plan for red
snapper based on the results of the 1999 stock assessment (Schirripa and
Legault 1999). The revised rebuilding plan maintained the initial TAC at
9.12 MP and set management targets to end overfishing by 2009 or 2010
and rebuild the stock to B~msy~ by 2032. The Council specified in
Amendment 22 (GMFMC 2004a) that the rebuilding plan would be reviewed
and revised, as necessary, after periodic stock assessments.

The 2005 stock assessment indicates all TACs under consideration, even
the no action 9.12 MP, will allow spawning biomass to increase over the
short term. However, TACs greater than 7 MP will not end overfishing in
the timeframe specified by the rebuilding plan (Thompson 2005). The
following discussion focuses on the effects of various rebuilding plans
and TACs that would end overfishing by 2009 or 2010 and rebuild red
snapper to B~msy~ by 2032, in accordance with the Council's currently
approved rebuilding plan (GMFMC 2004a). The level TAC can be set at over
the next three years is dependent on numerous factors, including the
amount shrimp trawl bycatch mortality, directed fishery bycatch and
closed season bycatch can be reduced. In general, the greater the
reduction in closed season, directed fishery, and shrimp trawl dead
discards, the higher directed TAC can be set.

The maximum ABC for red snapper that would end overfishing within the
timeframe set by the Council's rebuilding plan is 7 MP. However, a 7 MP
TAC would require all sources of fishing mortality (i.e., directed
fishery, closed season bycatch, and shrimp trawl bycatch) be reduced by
74 percent in order to end overfishing (Thompson 2005). Based on
management measures considered in this amendment and revised rebuilding
plans developed by the SEFSC (Chester 2007; SERO 2007), bycatch is
unlikely to be reduced across all sources by 74 percent; especially
closed season discards (Chester 2007, SERO 2007, Crabtree 2006).
Therefore, if TAC is set at 7 MP and all sources of fishing mortality
are not reduced by 74 percent, overfishing would continue beyond 2009 or
2010. This would result in slower than expected rebuilding progress and
require implementation of additional measures to end overfishing.
Beginning in July 2009, the reauthorized Magnuson-Stevens Act will
require the Council to immediately end overfishing if it has not already
done so.

# Rebuilding Plans

The Council considered three alternative rebuilding plans in addition to
no action (Alternative 1). The red snapper rebuilding plan is being
revised in accordance with a March 12, 2007, District Court order, which
requires the Secretary of Commerce to establish a new red snapper
rebuilding plan within 9 months of the Court ruling. The revised
rebuilding plan must ensure that there is at least a 50 percent
probability of ending overfishing and rebuilding red snapper to the
biomass at MSY. In revising the red snapper rebuilding plan, the Council
is not considering changes to the timeframe for ending overfishing or
rebuilding the stock. As specified in Amendment 22 to the Reef Fish FMP,
overfishing must end between 2009 and 2010 and the stock must be rebuilt
to B~msy~ by 2032 (GMFMC 2004a).

Table 2.2 summarizes red snapper rebuilding plans for each of the
alternatives in Action 1. Two types of rebuilding strategies were
considered during SEDAR 7 (2005): 1) a 'linked' rebuilding strategy,
which requires proportional reductions in fishing mortality across all
sources (i.e., directed fishery, closed season bycatch, and shrimp trawl
bycatch) and 2) a 'delinked' rebuilding strategy, which allows
disproportional reductions in fishing mortality across all sources.
Under a 'delinked' rebuilding strategy, decisions are made by fishery
managers regarding the extent to which bycatch can be practically
reduced by available management tools (e.g., circle hooks, dehooking
devices, lower size limits, etc.). Under a 'linked' rebuilding strategy,
reductions in fishing mortality, including bycatch, are assumed to be
achievable, even if they cannot practically be achieved with available
management tools. **Alternatives 1** (9.12 MP TAC) and **2** (7 MP TAC)
are based on 'linked' rebuilding strategies, whereas **Preferred**
**Alternatives 3** and **Alternative** **4** are based on 'delinked'
rebuilding strategies. In addition to the rebuilding plans considered
herein, the Council reviewed and considered a myriad of other rebuilding
plans, which are summarized in Thompson (2005), Crabtree (2006), and
Chester (2007). The success of each of these TACs and rebuilding
strategies in ending overfishing and rebuilding red snapper is
contingent, in large part, on how much bycatch can be practically
reduced.

Figure 2.1 and Table 2.2 compare TACs and estimated discards resulting
from two 'linked' rebuilding plans (**Alternatives 1** and **2**) and
two 'delinked' rebuilding plans (**Alternatives 3** and **4**). In
general, the 'linked' strategy results in faster stock recovery, but
requires much greater reductions in closed season bycatch and shrimp
trawl discards over the long-term. Because higher TACs are allowed under
a 'linked' rebuilding strategy, more open season directed fishery
discards are estimated to occur when compared with the preferred
'delinked' rebuilding plan (**Preferred Alternative 3**). Over the
long-term, closed season and shrimp trawl discards must be maintained at
levels lower than those assumed under 'delinked' rebuilding strategies
in order to rebuild the stock to 26 percent SPR (proxy for B~msy~). If
bycatch can be successfully reduced to levels necessary under the
'linked' rebuilding plans (**Alternatives 1** and **2**), stock recovery
(B/B~msy~ \> 1.0) would be much faster and occur well in advance of the
2032 rebuilding deadline. However, based on rebuilding projections
conducted by the SEFSC in January through March 2007 (Chester 2007; SERO
2006) and bycatch management alternatives considered in this amendment
(i.e., lower size limits, gear restrictions, etc.), it is impractical to
assume bycatch can be reduced to the extent required in **Alternatives
1** and **2** in order to end overfishing and rebuild the stock. Because
sufficient bycatch reduction cannot be achieved to satisfy the
assumptions of the 'linked' rebuilding strategies, maintaining TAC at
9.12 MP or setting TAC at 7 MP would not end overfishing by 2009 or 2010
(SERO 2007 in reference to Crabtree 2006) as required by the
Magnuson-Stevens Act and as specified by approved red snapper rebuilding
plan. Even if realistic assumptions are made about reductions in bycatch
(i.e., 'delinked' rebuilding strategies), TACs no greater than 5 to 5.5
MP could be implemented from 2008 through 2010 to end overfishing (Table
2.3).

'Delinked' rebuilding strategies require lower TACs over the short-term,
because the rebuilding plan does not assume closed season bycatch and/or
shrimp trawl bycatch are reduced to the extent estimated under a
'linked' rebuilding strategy. Rebuilding plans summarized in
**Alternatives 3** and **4** make reasonable assumptions about how much
bycatch can be practically reduced. In general, the more shrimp trawl
bycatch and/or closed season bycatch allowed, the lower TAC must be set.
Additionally, the higher TAC is set, the greater the number of open
season discards estimated to occur. The rebuilding plan summarized in
**Preferred Alternative 3** assumes fishing mortality on red snapper
resulting from shrimp trawl bycatch will be reduced by 74 percent
beginning in 2007, while **Alternative 4** assumes fishing mortality on
red snapper from shrimp trawl bycatch will be reduced by 50 percent.
Actions 6 and 7 in this amendment summarize measures proposed to cap
shrimp effort and restrict effort if this cap is exceeded.
**Alternatives 3** and **4** also assume fishing mortality will be
reduced during the closed season by 10 percent owing to implementation
of the commercial red snapper IFQ system and the requirement to use
circle hooks for the harvest of all reef fish (see Action 5). Directed
fishery bycatch is associated with the preferred minimum size limits
selected in Actions 1 and 4; i.e., directed fishery bycatch was assumed
to correspond to the bycatch resulting from a 13-inch commercial minimum
size limit and 16-inch recreational minimum size limit.

In addition to the alternatives described above, several other red
snapper rebuilding projections were conducted by the SEFSC in January
through March 2007 (Chester 2007; SERO 2007); these projections did not
assume fishing mortality could reduced proportionally across all
sources - they are 'delinked' rebuilding strategies. Rather, the
projections include reasonable assumptions about how much bycatch can be
reduced in various fisheries and during the closed season. Because
closed season bycatch cannot be sufficiently reduced as required by a
'linked' rebuilding strategy, all projections indicate TAC would have to
be set much lower than 7 MP in order to end overfishing by 2009 or 2010
(SERO 2007 in reference to Crabtree 2006). Table 2.3 summarizes the
results of these projections. Projection runs 1 and 7 in Table 2.3
correspond to rebuilding plans summarized for **Preferred Alternative
3** and **Alternative 4**, respectively. All other projection runs
summarized in Table 2.3 represent additional information the Council was
presented with while selecting the range of alternatives to revise the
red snapper rebuilding plan.

All rebuilding projections summarized in Table 2.3 include updated
directed fishery landings and shrimp effort through 2005, end
overfishing by 2009 or 2010, depending on the level TAC is set at over
the next two to three years (2008-2009 or 2008-2010), and rebuild the
red snapper stock to the Council's rebuilding goal (26 percent SPR,
which is a proxy for B~msy~) by 2032.

![](media/image2.wmf){width="5.995833333333334in"
height="5.100694444444445in"}**Figure 2.1. Estimated red snapper TAC
(mp) and directed fishery discards (numbers), closed season discards,
and shrimp trawl discards for four rebuilding strategies: 1) delinked'
74 percent shrimp, 5.0 MP TAC (same as projection run #1 in Table 2.3,
2) 'delinked' 50 percent shrimp, 3.0 MP TAC (same as projection run #7
in Table 2.3), 3) 'linked' 7 MP constant TAC, and 4) 'linked' 9.12 MP
constant TAC.**

The following inputs and assumptions were used for the projections
summarized in Table 2.3:

1.  Directed fishery landings in 2006 were set equal to directed fishery
    landings in 2005;

2.  Shrimp fishing mortality in 2006 was set at 60 percent less than the
    2001-2003 baseline shrimp fishing mortality rate;

3.  After 2006, the shrimp fishing mortality rate was either capped at
    50 or 74 percent of the 2001-03 baseline shrimp fishing mortality
    rate;

4.  TAC for the directed fishery was set at 6.5 million pounds (mp) in
    2007;

5.  Commercial directed fishery discards correspond to those estimated
    under a 13-inch minimum size limit;

6.  Recreational directed fishery discards correspond to those estimated
    under either a 14-inch or 16-inch minimum size limit;

7.  The fishing mortality rate associated with closed season discards
    was set 10 percent less than the 2001-2003 baseline fishing
    mortality rate owing to implementation of the IFQ program;

8.  The release mortality rate for recreational discards during both the
    open and closed season was reduced by 0, 5, or 10 percent owing to
    circle hooks, venting tools, and dehooking devices; and,

9.  TAC in 2008-2009 or 2008-2010 corresponds to the level of catch
    necessary to end overfishing and was contingent on the level at
    which shrimp effort was capped (see #3 above). After 2009 or 2010,
    TAC was increased at a constant rate to rebuild the stock to 26
    percent SPR by 2032.

If the Council requires circle hooks, venting tools, and dehooking
devices (see Action 5) and these gears result in small reductions in
recreational release mortality rates then TACs could be increased by an
additional 100,000 to 150,000 pounds, regardless of the minimum size
limit selected or any additional reductions in bycatch associated with
circle hooks and other gears. Reducing the recreational minimum size
limit from 16 to 14 inches total length would allow TAC to increase by
100,000 to 160,000 pounds over the short-term (next 2-3 years). Over the
long-term (through 2032), lower size limits would result in slightly
lower TACs than higher size limits.

Maximum sustainable yields range from 10.2 to 17.8 MP for the projection
runs summarized in Table 2.3, and are largely contingent on the amount
shrimp fishing mortality is reduced (i.e., greater reductions in shrimp
fishing mortality result in greater MSY). Similarly, the more closed
season bycatch can be reduced, the greater MSY.

**Table 2.2 Yield and spawning potential streams for proposed red
snapper rebuilding plans.**

![](media/image3.wmf)

**Table 2.3.** **Summary of total allowable red snapper catches ending
overfishing by 2009 or 2010 and the estimated maximum sustainable yield
for various red snapper rebuilding scenarios. Projection runs 8-18
(highlighted in gray) were interpolated from projection runs 1-7.**

![](media/image4.wmf)

[Discussion]{.underline}: As described in the purpose and need for this
amendment, reductions in red snapper directed fishing mortality and
bycatch mortality are needed for the stock to rebuild. **Action 1**
examines changes to the TAC, commercial quota, recreational quota, and
various recreational management measures. Section 5.1 examines the
effects of the various **Action 1** alternatives relative to each other
within the physical, biological/ecological, socioeconomic, and
administrative environments. Important factors to this discussion
include:

-   The Council's red snapper rebuilding plan specifies overfishing will
    end by 2009 or 2010 and red snapper will be rebuilt to B~MSY~ by
    2032 (GMFMC 2004a). No revisions to these timeframes are proposed in
    this amendment.

-   Recovery of red snapper in the western Gulf is more sensitive to
    reductions in shrimp trawl bycatch (and to a lesser extent
    commercial fishing mortality), whereas recovery of red snapper in
    the eastern Gulf is more sensitive to reductions in recreational
    fishing mortality and bycatch.

-   A 74 percent reduction in total red snapper fishing mortality (both
    the directed and shrimp trawl fisheries) from baseline levels
    (2001-03) is required to end overfishing of red snapper by 2010.

-   The maximum ABC that would end overfishing of red snapper by 2009 or
    2010 is 7 MP. In order to end overfishing under a 7 MP TAC, fishing
    mortality across all sources, including closed season bycatch, must
    be reduced by 74 percent.

-   Preferred bycatch reduction management alternatives discussed in
    this amendment are not expected to reduce closed season bycatch to
    the extent necessary to end overfishing under a 7 MP TAC.

-   Red snapper rebuilding plans summarized in Table 2.3, which
    incorporate reasonable assumptions about bycatch reduction based on
    available management tools, indicate TACs ranging from 5 to 5.5 MP
    are necessary to end overfishing in accordance with the Council's
    rebuilding plan.

-   The more bycatch is reduced, the higher TAC can be set.

-   Smaller recreational minimum size limits reduce the number of red
    snapper discarded dead, but increase landings and catch rates. To
    compensate for increases in recreational landings resulting from
    lower minimum size limits, more restrictive bag limits and closed
    seasons must be imposed to constrain landings within specified
    recreational quota levels.

-   Reducing the recreational minimum size limit from 16 to 15, 14, or
    13 inches slows stock recovery over the long-term, although changes
    in spawning potential and the rate of stock recovery are very small
    for recreational size limits ranging from 13 to 15 inches TL (Figure
    4.2.1). The more the recreational size limit is reduced the slower
    the stock recovers in the long-term. Eliminating the minimum size
    limit would greatly slow stock recovery (see Figure 4.2.1).

-   In the short-term (next 5-10 years), lower recreational minimum size
    limits would allow slightly higher TACs, although differences in
    recovery relative to no action are negligible. These results are
    consistent with Porch (2005), who indicated stock recovery would be
    slightly faster for 13-15 inch minimum size limits over the
    short-term, but slightly slower over the long-term (through 2032).
    Lowering the minimum size limit is expected to result in a slightly
    lower TAC over the long-term than if a higher minimum size limit is
    maintained.

-   Adverse economic impacts increase as TACs are reduced.  Higher bag
    limits and longer open seasons, result in lower adverse economic
    impacts than shorter open seasons and lower bag limits.  Anglers
    generally prefer reducing the red snapper bag limit to reducing the
    length of the fishing season, unless the bag limit becomes too
    restrictive.

-   Impacts to the administrative environment increase with higher TACs
    and/or greater assumptions about the success of bycatch reduction
    measures. TACs greater than those summarized in Table 2.3 are
    unlikely to end overfishing and therefore additional management
    actions may be needed in the future to end overfishing. Fishing
    seasons that include weekend openings and weekday closing are
    complicated and likely to reduce regulatory compliance. Implementing
    different regulations in the eastern versus western Gulf would
    require a line of demarcation, which causes some enforcement
    problems and angler confusion near the line.

-   Impacts to the physical environment are expected to be small since
    most fishing occurs on artificial structures and the primary gear
    used is hook-and-line.

[Comparison of Physical, Biological, and Ecological
Consequences]{.underline}

The 2005 red snapper stock assessment (SEDAR 7 2005) continues to
indicate red snapper are undergoing overfishing and overfished. Red
snapper fishing mortality rates are too high in both the directed and
shrimp fisheries (SEDAR 7 2005). In comparison to previous assessments,
the directed fishery now contributes to a greater portion of fishing
mortality than previously thought because of higher juvenile natural
mortality rates (age-0 and age-1) and higher directed fishery release
mortality rates of regulatory discards. Shrimp trawl bycatch of red
snapper still remains a significant source of mortality in the western
Gulf and actions are being considered in this amendment to further
reduce shrimp trawl bycatch of red snapper (see **Actions 6** and
**7**).

**Action 1** considers four rebuilding plans for red snapper. Constant
TACs are being considered for at least the next three years (2008-2010)
and are intended to end overfishing in the directed fishery. NMFS
implemented a temporary rule for the 2007-fishing season that
establishes a 6.5 MP TAC. All TACs under consideration, even the no
action 9.12 MP, will allow spawning biomass to increase. However TACs
greater than 7.0 MP will not end overfishing by 2009 or 2010, and TACs
greater than 5-5.5 MP are not expected to end overfishing between 2009
and 2010 because adequate reductions in bycatch would not be achieved.

**Alternative 1 (no action)** would maintain the current rebuilding plan
and hold TAC constant at 9.12 MP until 2032 (Table 2.2). This TAC would
result in no changes to the commercial quota or recreational management
regulations over the short- or long-term. The rebuilding plan associated
with a constant 9.12 MP TAC assumes shrimp trawl, directed fishery, and
closed season discards would decline throughout the timeframe of the
rebuilding plan. However, based on rebuilding projections conducted by
the SEFSC in January through March 2007 (Chester 2007; SERO 2007) and
management alternatives under consideration in this amendment, bycatch
is projected to actually increase as the stock rebuilds. Although a 9.12
MP TAC would result in some stock recovery, it would not reduce
recreational dead discards and would continue to allow overfishing after
2009 or 2010. Over the long-term, maintaining TAC at 9.12 MP would
result in faster than expected stock recovery when compared to the
Council's rebuilding benchmark (F~MSY~ = F~26%SPR~); however, stock
recovery would only be faster if reductions in bycatch summarized in
Figure 2.1 are achieved. Based on management measures considered in this
amendment and revised rebuilding plans developed by the SEFSC (Table
2.3), bycatch is unlikely to be reduced across all sources to the levels
summarized in Figure 2.1. Of the four alternatives considered in
**Action 1**, **Alternative 1** would reduce fishing mortality the
least, has the lowest probability of ending overfishing over the next
three years, and would result in no additional recreational management
measures to reduce the number of red snapper discarded dead. Preliminary
information from the SEFSC indicates the rebuilding plan under
**Alternative 1** has less than a 50 percent chance of ending
overfishing by 2010 unless shrimp and closed season discard rates are
reduced by substantially more than 74 percent.  **Alternative 1** has a
greater than 50 percent chance of allowing rebuilding by 2032 if shrimp
and closed season discard rates are both reduced by 74 percent or more
relative to 2001-2003 levels. Because fishing mortality across all
sources, including closed season bycatch, will not likely be reduced by
this amount the probability of ending overfishing will be less than 50
percent.

**Alternative 2** would revise the red snapper rebuilding plan and
reduce the TAC to 7 MP and hold it constant until 2032 (Table 2.2).
Relative to **Preferred Alternative 3**, TAC would not increase over
time as the stock rebuilds. By 2011, TAC for the preferred rebuilding
plan (**Preferred Alternative 3**, Table 2.2) would exceed the constant
7 MP TAC for **Alternative 2** and would remain well above the 7 MP TAC
throughout the remainder of the rebuilding plan. This TAC is the maximum
ABC that could be taken from the red snapper stock to end overfishing
within the timeframe specified by the Council's rebuilding plan. The
commercial quota would be 3.57 MP and the recreational quota would be
3.43 MP. **Alternative 2** would only end overfishing of red snapper in
2009 or 2010 if all sources of mortality can be reduced proportionally
by 74 percent. Based on projections conducted by the SEFSC in January
through March 2007 (Chester 2007; SERO 2007), bycatch is unlikely to be
reduced to levels necessary to end overfishing under a 7 MP TAC (Chester
2007; SERO 2007 in reference to Crabtree 2006); therefore, lower TACs
are needed. Over the long-term, **Alternative 2** would result in faster
than expected stock recovery when compared to the Council's rebuilding
benchmark (F~MSY~ = F~26%SPR~); however, stock recovery would only be
faster if reductions in bycatch summarized in Figure 2.1 are achieved.
Rebuilding over the next three years would be expected to occur at a
slower rate when compared to the Council's rebuilding benchmark (F~MSY~
= F~26%SPR~). **Alternative 2** would reduce fishing mortality more in
2008 than **Alternative 1**, but less than **Alternatives 3 and 4.**
Over the long-term, **Alternative 2** has a greater probability of
ending overfishing than **Alternative 1**, but a lower probability than
**Preferred** **Alternative 3** and **Alternative 4**. Preliminary
information from the SEFSC indicates the rebuilding plan under
**Alternative 2** has a slightly greater than 50 percent chance of
ending overfishing by 2010 if shrimp and closed season discard rates are
reduced by 74 percent or more.  **Alternative 2** has a greater than 50
percent chance of allowing rebuilding by 2032 if shrimp and closed
season discard rates are both reduced by 74 percent or more relative to
2001-2003 levels. Because fishing mortality across all sources,
including closed season bycatch, will not likely be reduced by this
amount the probability of ending overfishing will be less than 50
percent.

**Alternative 2** includes 11 options and/or suboptions. Options and
sub-options for **Alternative 2** include various bag limit, size limit,
and open season combinations. Sub-options under **Option 2(a)** would
maintain the four fish bag limit and 16-inch size limit, but would
reduce the length of the open season to 125-139 days. **Suboptions
2(a)(ii) -- 2(a)(iv)** would establish 8 weekend openings either
Gulf-wide, in the western Gulf, or off Texas, following a core fishing
season. Sub-options under **Option 2(b)** would reduce the bag limit to
three fish, maintain the 16-inch minimum size limit or reduce it to
15-inches, and reduce the length of the open season to 137-154 days.
Suboptions under **Option 2(c)** would reduce the bag limit to two fish,
reduce the minimum size limit to either 13 or 15-inches TL, and reduce
the length of the open season to 124-154 days. **Suboptions 2(c)(iii) --
2(c)(v)** would establish 12 consecutive weekend openings either
Gulf-wide, in the western Gulf, or off Texas, following a core fishing
season. All management measures included in **Options 2(a), 2(b), and
2(c)** are estimated to achieve at least a 23 percent reduction in
harvest.

**Preferred Alternative 3** would revise the red snapper rebuilding plan
and reduce the TAC to 5 MP from 2008 through 2010 (Table 2.2). After
2010, TAC would be increased consistent with a fishing mortality rate
that produces MSY. The commercial quota would be 2.55 MP and the
recreational quota would be 2.45 MP. **Preferred Alternative 3** would
end overfishing between 2009 and 2010, consistent with the Council's
rebuilding plan (Chester 2007). **Preferred** **Alternative 3** would
permit the Gulf-wide red snapper stock to attain the expected F~26%SPR~
biomass trajectory by 2009 or 2010. **Preferred Alternative 3** would
require shrimp trawl fishing mortality be reduced by 74 percent and
closed season red snapper fishing mortality be reduced by a minimum of
10 percent. Directed fishery bycatch is associated with the preferred
minimum size limits selected in Actions 1 and 4 (i.e., directed fishery
bycatch was assumed to correspond to the bycatch resulting from a
13-inch commercial minimum size limit and 16-inch recreational minimum
size limit). Over both the short- and long-term, **Alternative 3** has a
higher probability of ending overfishing than **Alternatives 1** and
**2**. The probability of **Preferred** **Alternative 3** ending
overfishing would be similar to the probability of **Alternative 4**
ending overfishing if the Council selects a 50 percent reduction in
shrimp fishing mortality in conjunction with **Alternative 4**; however,
**Alternative 4** (3 MP TAC) has a greater probability of ending
overfishing if the Council selects shrimp trawl fishing mortality
reductions greater than 50 percent. When fully rebuilt, MSY would be
17.2 MP (Table 2.1.3). Preliminary information from the SEFSC indicates
the preferred rebuilding plan has at least a 50 percent probability of
end overfishing and rebuilding the stock to B~msy~. Because TAC is 0.3
MP lower than the maximum TAC allowed over the next three years (Table
2.3, projection run #1) and the rebuilding plan does not take into
account reductions in release mortality resulting from circle hooks, the
probability of ending overfishing is estimated to be higher than 50
percent. Additionally, adjusting the rebuilding plan after subsequent
stock assessments will increase the probability of successfully
rebuilding red snapper.

**Preferred Alternative 3** includes 15 options and/or suboptions.
Options and sub-options for **Preferred Alternative 3** include various
bag limit, size limit, and open season combinations. All options for
**Preferred Alternative 3** would reduce the bag limit to either one or
two fish. **Preferred Option 3(a)(i)** would maintain the 16-inch size
limit and reduce the length of the open season to 107 days. **Option
3(a)(ii)** would maintain the 16-inch size limit and start the fishing
season on May 1, which would allow for a 92-day fishing season. **Option
3(b)** would maintain the 16-inch size limit and reduce the length of
the open season to 57-92 days. **Suboption 3(b)(i)** would establish a
May 15 -- August 15 fishing season Gulfwide. **Suboptions 3(b)(ii-iv)**
would allow harvest only on weekends before and after a core July
fishing season. This would result in the shortest fishing season because
a majority of red snapper are landed by recreational anglers on weekends
(SERO 2006d). Six consecutive weekend openings prior to July 1 and 7
consecutive weekend openings after July 31 would extend the fishing
season from mid-May to late September. **Option 3(c)** would reduce the
minimum size limit to 15-inches TL and establish an 88-day fishing
season. **Option 3(d)** would reduce the minimum size limit to 14-inches
TL and **Suboptions 3(d)(i-iii)** would reduce the length of the open
season to 71-77 days. **Option 3(e)** would reduce the minimum size
limit to 13 inches TL and establish a 61-day fishing season. **Option
3(f)** would reduce the bag limit to one and the minimum size limit to
14-inches TL, and **Suboptions 3(f)(i-ii)** would reduce the length of
the fishing season to 102-122 days. **Option 3(f)** would reduce the bag
limit to one and maintain the 16-inch TL minimum size limit.
**Suboptions 3(f)(i-ii)** would reduce the length of the fishing season
to 138-154 days. All management measures included in **Options 3(a-g)**
are estimated to achieve at least a 45 percent reduction in harvest and
therefore would benefit red snapper stock recovery.

**Alternative 4** would revise the red snapper rebuilding plan and
reduce the TAC to 3 MP from 2008 to 2010 (Table 2.2). After 2010, TAC
would be increased consistent with a fishing mortality rate that
produces MSY. The commercial quota would be 1.53 MP and the recreational
quota would be 1.47 MP. **Alternative 4** would end overfishing between
2009 and 2010, consistent with the Council's rebuilding plan (Chester
2007). **Alternative 4** would permit the Gulf-wide red snapper stock to
attain the expected F~26%SPR~ biomass trajectory by 2009 or 2010.
**Alternative 4** would require shrimp trawl fishing mortality be
reduced by a minimum of 50 percent and closed season red snapper fishing
mortality be reduced by a minimum of 10 percent. Directed fishery
bycatch is associated with the preferred minimum size limits selected in
Actions 1 and 4 (i.e., directed fishery bycatch was assumed to
correspond to the bycatch resulting from a 13-inch commercial minimum
size limit and 16-inch recreational minimum size limit). Over both the
short- and long-term, **Alternative 4** has the highest probability of
ending overfishing of any of the alternatives if the Council selects a
74 percent shrimp trawl fishing mortality goal. Relative to **Preferred
Alternative 3**, **Alternative 4** would have a similar probability of
ending overfishing if the Council selects a 50 percent shrimp trawl
fishing mortality reduction goal. Preliminary information from the SEFSC
indicates the proposed rebuilding plan has at least a 50 percent
probability of end overfishing and rebuilding the stock to B~msy~.
Because TAC is 0.27 MP lower than the maximum TAC allowed over the next
three years (Table 2.3, projection run #7) and the rebuilding plan does
not take into account reductions in release mortality resulting from
circle hooks, the probability of ending overfishing is estimated to be
higher than 50 percent. Additionally, adjusting the rebuilding plan
after subsequent stock assessments will increase the probability of
successfully rebuilding red snapper.

**Alternative 4** includes 7 options and/or suboptions. Options and
sub-options for **Alternative 4** include various bag limit, size limit,
and open season combinations. All options for **Alternative 4** would
reduce the bag limit to two fish. **Option 4(a)** would maintain the
16-inch size limit and reduce the length of the open season to 39-46
days. **Suboption 3(b)(i)** would establish an August 1 -- September 15
fishing season Gulfwide. **Suboptions 4(a)(ii-iv)** would allow harvest
only on weekends before and after a core August fishing season. This
would result in the shortest fishing season because recreational anglers
land a majority of red snapper on weekends (SERO 2006d). Two consecutive
weekend openings prior to August 1 and 2 consecutive weekend openings
after August 31 would extend the fishing season from mid-July to
mid-September. **Option 4(b)** would reduce the minimum size limit to
15-inches TL and establish a 39-day fishing season. **Option 4(c)**
would reduce the minimum size limit to 14-inches TL and establish a
35-day fishing season. **Option 4(d)** would reduce the minimum size
limit to 13 inches TL and establish a 31-day fishing season. All
management measures included in **Options 4(a-d)** are estimated to
achieve at least a 67 percent reduction in harvest and therefore would
benefit red snapper stock recovery.

In general, sub-options with lower size limits will reduce dead discards
the most, but will lower yield-per-recruit and result in slightly slower
stock recovery over the long-term. The current 16-inch minimum size
limit represents the greatest source of regulatory discards by the
recreational fishery. To compensate for the increase in landings and
fishing mortality associated with lower size limits, additional
management measures are necessary to maintain landings within the
specified recreational quota. These additional management measures will
partly diminish the benefits of lowering the size limit, because they
increase dead discards and shorten the open season when size limits
would be effective. Lower bag limits and higher size limits allow for
longer fishing seasons. Establishing weekend openings after a core
season reduces the number of allowable days for fishing because effort
is higher and more red snapper are landed on weekends.

Porch (2005) evaluated various minimum size limits for red snapper and
found the 16-inch recreational minimum size limit resulted in the
fastest recovery for the stock over the long-term, although size limits
as low as 13-inches TL were found to only slightly slow stock recovery
over the long-term (see Figure 4.2.1). Over the short-term, lowering the
minimum size limit may slightly speed up stock recovery, allowing for
higher TACs at lower minimum sizes. Based on recreational minimum size
limits ranging from 6 to 16 inches TL, YPR analyses indicate 16 inches
maximizes YPR assuming current fishing selectivities and discard
mortality rates (Figure 2.2). In the western Gulf, where recreational
release mortality rates are higher (40 vs. 15 percent), there was little
difference in YPR (SERO 2006b).

![](media/image5.wmf){width="5.995833333333334in"
height="2.3944444444444444in"}

**Figure 2.2. Yield-per-recruit for various recreational minimum size
limits by region. YPR is based on selectivities from the 2005 stock
assessment and assumed released mortality rates of 15 and 40 percent for
the eastern and western Gulf, respectively.**

As discussed above, the probability of **Alternatives 1** through **4**
ending overfishing and rebuilding the red snapper stock is contingent on
whether or not fishing mortality (including bycatch mortality) can be
adequately reduced. Numerous alternatives to reduce bycatch are
considered in this amendment, or were considered, but eliminated from
further consideration (see Appendix A). None of the proposed bycatch
reduction measures summarized in Actions 1, 4, and 5 are expected to
reduce bycatch to levels necessary under a 'linked' rebuilding strategy.
Because closed season and directed dead discards cannot be sufficiently
reduced to target bycatch reduction levels, **Alternatives 1** (9.12 MP
TAC) and **Alternative** **2** (7 MP TAC) would not end overfishing.
TACs proposed in **Preferred Alternative 3** and **Alternative 4**
assume bycatch in the directed fishery and during the closed season
would only be partially reduced due to the implementation of the
commercial IFQ program, gear requirements, and a lower commercial
minimum size limit. Both **Preferred Alternative 3** (5 MP TAC) and
**Alternative 4** (3 MP TAC) would end overfishing, as long as the
assumptions above are met and shrimp trawl fishing mortality is reduced
by 74 percent. A lesser reduction in shrimp fishing mortality (50
percent) in combination with **Alternative 4** would also end
overfishing.

**Alternatives 2-4** are all expected to have some negative impacts on
other reef fish species due to effort shifting. Impacts on other species
would be greatest for alternatives with lower TACs and shorter red
snapper fishing seasons. Species likely to be impacted the most include:
vermilion snapper, gray triggerfish, and gag, which all co-occur with
red snapper. Currently, vermilion snapper is not overfished and is not
undergoing overfishing and both gag and gray triggerfish are
experiencing overfishing.

**Alternatives 1-4** are not expected to significantly effect the
physical environment since most fishing for red snapper occurs over
artificial structures and the primary gear used is hook-and-line.
Impacts to the physical environment are largely associated with
reductions in fishing effort. The lower TAC is set and the more
restrictive management measures are set, the more effort will likely be
reduced, thereby benefiting the physical environment through less
gear-habitat interactions. **Alternative 1** is expected to have the
greatest impacts on the physical environment, followed by **Alternatives
2, 3,** and **4**, respectively.

**Action 2. Post-hurricane reduction in directed fishery effort assumed
for Action 1 TAC alternatives.**

**Alternative 1. Do not take into consideration any potential
post-hurricane reductions in directed fishery effort and landings when
evaluating alternative TACs and management measures in Action 1.**

**Alternative 2. Assume a 25-percent reduction in post-hurricane fishing
effort and landings when evaluating alternative TACs and management
measures in Action 1.**

**Alternative 3. Assume a 10-percent reduction in post-hurricane fishing
effort and landings when evaluating alternative TACs and management
measures in Action 1.**

[Discussion]{.underline}: The 2005 hurricane season was the busiest and
costliest on record. There were 28 named storms, including 15
hurricanes, four of which reached category 5 strength. Along the Gulf
coast from the Florida Panhandle to Texas, where red snapper primarily
are caught, five named storms (Tropical Storm Arlene and Hurricanes
Cindy, Dennis, Katrina, and Rita) made landfall. Hurricanes Katrina
(landfall August 29, 2005) and Rita (landfall September 24, 2005) were
the most devastating of these storms, impacting an area stretching from
eastern Texas to western Alabama and resulting in significant physical
and economic damage to coastal communities. Direct losses to the fishing
industry and businesses supporting fishing activities included: loss of
vessels, loss of revenue due to cancelled fishing trips, and destruction
of marinas and other fishery infrastructure (Walker et al. 2006).

Because of the social, economic, and physical impacts resulting from
last year's hurricane season, the Council approved a motion at their
June 2006 meeting to consider a 25-percent reduction in fishing effort
and landings (**Alternative 2**) when analyzing recreational management
measures in Action 1. At the March 2007 Council meeting, the Council
also approved a motion to consider a 10-percent reduction in fishing
effort and landings (**Alternative 3**) when analyzing recreational
management measures in Action 1. Similar reductions in effort are not
assumed for the commercial fishery since an IFQ program was implemented
in 2007 and the only change to management measures being considered in
Action 1 is a lower quota. The Council is considering a smaller minimum
commercial size limit in Action 4. Although this alternative will likely
increase the rate of harvest, allowing the quota to be met faster, IFQ
shareholders would be restricted to harvesting only their share of the
commercial quota specified in Action 1. The IFQ will also allow
commercial fishermen impacted by last year's storms the opportunity to
sell or lease their shares to other fishermen who may have a greater
likelihood of using the shares.

Preliminary MRFSS effort estimates for 2006 indicate charter trips in
federal waters of the exclusive economic zone (EEZ) were up 9 percent
relative to the 2001-03 average effort level and up 3 percent relative
to 2002-2005 average effort level. In contrast, private trips in the EEZ
during 2006 were down 15 percent relative to the 2001-03 average effort
level and 17 percent relative to the 2002-05 average effort level. For
all areas fished (state and federal waters), charter trips in 2006 were
up by 13 percent relative to the 2001-03 average effort level and 11
percent relative to the 2002-05 average effort level, whereas private
trips were up 2 percent relative to 2001-03 average effort level and
down 2 percent relative to 2002-05 average effort level.

Preliminary 2006 MRFSS red snapper landings in numbers of fish were 2
percent less than average MRFSS red snapper landings during 2001-03 and
4 percent less than average MRFSS red snapper landings during 2002-2005.
In terms of pounds landed, the weight of MRFSS red snapper landings was
19 to 20 percent less than 2001-03 and 2002-05 average landings levels.
On average, the weight of each red snapper landed in 2006 was less than
the average weight of each red snapper landed during the prior four to
five years.

**Alternative 1** would maintain the status quo baseline for fishing
effort (2001-03). No reductions in fishing effort would be assumed and
the Council would need to select one of the management alternatives
summarized in Action 1 for reducing red snapper harvest. This
alternative would have the same impacts on the physical environment as
those described in Action 1. Reductions in fishing effort will result in
less gear (hook-and-line, anchors, spears) interactions with habitat,
resulting in minor benefits to the physical environment. **Alternative
1** would be the most precautionary management approach for selecting
management measures in Action 1. Assuming no change in fishing effort
occurs, impacts to the biological environment would be the same as those
described for various management alternatives in Action 1. However, if
reductions in fishing effort occur, but are not accounted for when
analyzing management measures in Action 1, there would be an increased
likelihood necessary reductions in fishing mortality would be achieved.
Not accounting for reductions in fishing effort that may occur would
also potentially allow for faster than expected rebuilding progress,
thereby ending overfishing sooner than expected. **Alternative 1** would
have no effect on the administrative environment. Management
alternatives summarized in Action 1 are expected to reduce recreational
landings to levels that approximate the annual quota, potentially
requiring no in-season management changes and allowing the recreational
fishery to operate under a fixed season length.

**Alternative 1**, which would use baseline effort levels in the
evaluation of management measures considered under Action 1, does not
affect previously estimated changes in net fishing effort and in
economic values. Conclusions derived from the previous comparative
evaluation of economic impacts associated with the different management
scenarios considered in Action 1 still apply.

**Alternatives 2** and **3** would assume a 25-percent and 10-percent
reduction in fishing effort and landings, respectively, when analyzing
management measures in Action 1 for reducing red snapper fishing
mortality. NOAA Fisheries Service, in developing interim regulations for
2007, assumed a 10 percent reduction in landings would occur from
hurricane impacts. As described above, preliminary landings and fishing
effort information indicate some declines have occurred since Hurricane
Katrina. However, the magnitude of reductions varies by fishing sector
and it is unknown how long post-hurricane reductions in landings and
fishing effort may continue into the future. Table 2.4 summarizes the
length of the recreational fishing season if the Council assumes either
a 10 or 25-percent reduction in landings/fishing effort and prohibits
captain and crew from retaining bag limits of red snapper (see Action
3).

If a 10 percent or 25-percent reduction in effort/landings does occur,
then benefits to the physical environment would occur regardless of any
changes to management measures. Benefits to the physical environment
would largely be due to lower fishing effort and less gear interactions
with habitat. However, because most red snapper are harvested with
hook-and-line gear and the recreational red snapper fishery accounts for
only a small fraction of the overall reef fish fishery harvest, any
benefits are expected to be small. If a 10 percent or 25-percent
reduction in fishing effort occurs in the short-term (next few years),
benefits to the biological environment would include decreases in
landings and discards. If these decreases in landings and discards allow
target reductions in fishing mortality to be achieved, then rebuilding
progress would continue to be made, allowing overfishing to end
consistent with the timeframe specified in the rebuilding plan. If
however, the reduction in effort is less than 10 percent or 25-percent,
or diminishes overtime, then negative impacts to the biological
environment would occur. Negative direct impacts would include landings
and discards exceeding levels needed to rebuild the red snapper fishery,
which would result in quota overages. **Alternatives 2** and **3** are
not expected to greatly affect the administrative environment if in fact
specified percent reductions in fishing effort occur. However, if
reductions in effort and landings are less than 10 or 25-percent or
diminish over time, then the Regional Administrator would be required to
close the recreational fishery once the quota is projected to be met
(Sec. 407(d) M-SFCMA). This would result in negative effects to the
administrative environment by requiring additional staff time to monitor
the quota and issue quota closure notices.

**Alternative 1**, which would assume historic baseline effort levels in
the evaluation of management measures considered under Action 1, does
affect previously estimated changes in net fishing effort and in
economic values. Though it could potentially establish stricter than
required management measures thereby limiting short term economic
benefits, **Alternative 1** would be consistent with a precautionary
approach to management. **Alternative 2**, which assumes a 25-percent
reduction in post-hurricane fishing effort, may establish management
measures that could jeopardize the rebuilding of the resource and
significantly delay its recovery. While it would potentially increase
short- term benefits derived from the fishery, it could impose sizeable
long term adverse economic benefits. **Alternative 3**, which assumes a
10-percent reduction in post-hurricane fishing effort may also establish
management measures that could jeopardize the rebuilding of the resource
and significantly delay its recovery. However, the effects on rebuilding
and time of recovery would be less than that of **Alternative 2**.

**Alternative 1** does not consider any potential reduction in effort
and landings. By not assuming any reduction, the season should not have
to close early because the TAC was met sooner than expected. By not
considering any possible reductions, there is a greater chance the TAC
will not be met during the year.

**Alternative 2** assumes a 25 percent reduction in fishing effort and
landings. If there is not a 25 percent reduction, the TAC may be met
sooner requiring an early closure of the fishery. If effort and landings
have indeed been reduced by 25 percent then fishermen would benefit from
a longer fishing season.

**Alternative 3** assumes a 10 percent reduction in fishing effort and
landings. If there is not a 10 percent reduction, the TAC may be met
sooner requiring an early closure of the fishery. If effort and landings
have indeed been reduced by 10 percent then fishermen would benefit from
a longer fishing season.

[]{.mark}

**Table 2.4. Length of the recreational red snapper fishing season for
Alternatives 2-4 in Action 1 if captain and crew are prohibited from
retaining bag limits of red snapper while under charter (see Action 3)
and either a 10 or 25 percent post-hurricane reduction in
landings/effort is assumed (Action 2). (Note: the table does not include
season lengths for alternatives in Action 1 that have weekend openings
and weekday closings).**

![](media/image6.wmf)

**Action 3. Establish separate bag limit restrictions for the captain
and crew of for-hire vessels**

**Alternative 1. No action -- The captain(s) and crew of a for-hire
vessel may retain the same daily bag limit of red snapper as allowed for
each passenger.**

**Preferred Alternative 2. The red snapper bag limit for captain(s) and
crew of for-hire vessels is zero.**

[Comparison of Physical, Biological, and Ecological
Consequences]{.underline}

**Alternative 1** would allow captains and crew to continue to retain
recreational bag limits of red snapper while under charter. It is
estimated captain and crew on for-hire vessels account for approximately
2 percent of the annual red snapper harvest, which is equivalent to an
additional 3-7 fishing days (SERO 2006a). If the red snapper bag limit
is reduced (see **Action 1**), captain and crew could and potentially
would supplement the catch of their clients and negate some of the
reductions expected from a lower daily bag limit. Continuing to allow
captain and crew to retain a daily bag limit of red snapper may increase
the potential harvest by recreational for-hire anglers and prevent
necessary reductions in harvest from being achieved. The amount of fish
they catch adds to the TAC and reduces the amount of fish for
non-working, recreational fishermen. If the captain and crew keep a
share, the number of days in the fishing season is shortened to meet the
TAC.

**Alternative 1** is not expected to result in any additional impacts to
the physical environment caused by gear interactions. No impacts to the
administrative environment are expected since regulations would not
change and there would be no additional burden on enforcement. Because
reductions in TAC will be achieved through management measures
considered in **Action 1** (or a combination of alternatives in Action 1
and **Alternative 2** below), **Alternative 1** will not directly affect
progress made toward rebuilding red snapper. However, because the
primary objective of setting the captain and crew bag limit to zero
would be to extend the fishing season, **Alternative 1** may increase
closed season discards because a longer closed season would be necessary
to achieve reductions in landings.

**Preferred Alternative 2** would reduce the captain and crew bag limit
to zero, which would reduce red snapper landings by approximately 2
percent and allow the fishing season to be extended. Table 2.1.1 shows
the length of the fishing season for various alternatives in **Action
1** if the captain and crew bag limit is set to zero. If the red snapper
bag limit is reduced (see **Action 1**), **Preferred Alternative 2**
increases the likelihood reductions from lower red snapper bag limits
are achieved, because captain and crew would no longer be able to
supplement the catch of their clients. **Preferred Alternative 2** would
also increase consistency among regulations and make them more equitable
among user groups. NMFS recently implemented Amendment 18A to the Reef
Fish FMP, which prohibits commercial fishermen from retaining bag limits
of reef fish while possessing commercial quantities of reef fish. Also,
a regulatory amendment to the Reef Fish FMP was recently implemented in
summer 2006 that prohibited captain and crew from retaining bag limits
of grouper while under charter.

**Preferred Alternative 2** is expected to result in benefits to the
physical environment through reduced effort and less gear interactions
with habitat. However, because for-hire captain and crew harvest
represents a small fraction of the overall reef fish fishery, any
benefits to the physical environment are expected to be immeasurably
small. Reductions in landings resulting from a zero captain and crew bag
limit in combination with management alternatives considered in **Action
1** will directly benefit the biological environment by reducing red
snapper mortality rates in the directed fishery. Closed season discards
will also be slightly reduced because the season would be extended by a
few additional days (see Table 2. 1).

[Comparison of Socioeconomic and Administrative
Consequences]{.underline}

[]{.mark}

**Alternative 1** would maintain the status quo and continue to allow
for-hire captains and crew to keep a bag limit while conducting a
for-hire trip. The additional harvest from this source of mortality,
however, would be expected to require more severe restrictions on the
general angling public in order to accomplish required harvest
reductions and fishery recovery goals. **Preferred Alternative 2** would
eliminate this source of mortality, and be expected to allow more
liberal restrictions for the fishery as a whole, and increase the
likelihood of achieving recovery goals. Although captains and crew would
be expected to experience a more restrictive household food budget,
although not quantified, the benefits associated with less restrictive
measures for anglers and greater success associated with meeting
recovery goals are expected to exceed these costs. Neither alternative
is expected to greatly effect the administrative environment, because
bag limits are routinely used to restrict harvest and similar
regulations exist for other reef fish species.

In the social environment, **Alternative 1** would benefit captain and
crew because they could continue to keep the bag limit. The amount of
fish they catch adds to the TAC and reduces the amount of fish available
for non-working, recreational fishermen. If the captain and crew keep a
share, the number of days in a fishing season is shortened to meet the
TAC. **Preferred Alternative 2** would prevent the captain and crew from
keeping red snapper. Captain and crew will not be able to supplement
their food budget with fish they can keep under current rules. The
amount of fish the captain and crew kept previously will be available to
non-working, recreational fishermen. The fishing season can be open a
few days longer without the captain and crew keeping a share.
**Preferred** **Alternative 2** may have negative impacts for captain
and crew because they can no longer keep fish and it may make it harder
for captains to retain crewmembers who may consider fishing and keeping
red snapper one of the benefits of the job.

**Action 4. Reduce the red snapper minimum size limit in the commercial
fishery**

Alternative 1. No action. Maintain the 15-inch TL commercial minimum
size limit for red snapper.

**Preferred Alternative 2. Reduce the minimum size limit in the
commercial red snapper fishery to 13 inches TL.**

**Alternative 3. Eliminate the commercial red snapper minimum size
limit**

[Discussion]{.underline}: As described in the purpose and need for this
amendment, reductions in red snapper bycatch (regulatory discards) are
needed in all sectors of the red snapper fishery for the stock to
recover over the long term and to reduce overfishing in the short term.
**Action 4** examines changing minimum size limits for the commercial
fishery as a method to reduce discards in the directed red snapper
fishery. Section 5.4 examines the effects of the various **Action 4**
alternatives relative to each other within the physical,
biological/ecological, socioeconomic, and administrative environments.
Important factors to this discussion include:

-   Discards in the commercial red snapper fishery are highest for
    vessels using bandit gear (84 percent), followed by handline (15
    percent) and longline (1 percent) (Poffenberger and McCarthy, 2004).

-   Logbook data indicates all reported discarded red snapper were
    regulatory discards (Poffenberger and McCarthy, 2004).

-   Red snapper discarded during open seasons (likely undersized) were
    numerically greater (SEDAR 7, 2005) but overall weighed less than
    fish discarded during the closed seasons (undersized- and
    legal-sized fish).

-   One study (Wilson et al., 2004) found over half of undersized red
    snapper released during the open period were 13 inches or greater
    (61 percent), and 86 percent were 12 inches or greater.

-   Porch (2005) estimated the number of regulatory discards based on
    size would decrease by 42 percent if the commercial size limit were
    reduced to 13 inches, and by 61 percent if reduced to 12 inches.

-   Based on the range of size limits analyzed (12- to 15-inches total
    length), analyses suggest YPR is maximized for the western Gulf at
    12 inches assuming an 82 percent discard mortality rate, while YPR
    is maximized at 15 inches for the eastern Gulf assuming a 71 percent
    discard mortality rate (although the difference in YPR between 12
    and 15 inches is negligible) (SERO, 2006b).

-   Most of the commercial catch occurs in the western Gulf (SEDAR 7,
    2005).

-   Stock recovery occurs at a slightly faster rate if the minimum size
    is reduced (Porch 2005).

-   Economic consequences of reducing the minimum size limit must
    consider the level of TAC established in **Action 1**.

**Alternative 1** (no action) would not reduce discard rates in the
commercial red snapper fishery. Some reductions will occur through Reef
Fish Amendment 26, which has established an IFQ program beginning
January 1, 2007. This program allocates IFQ shares to individual
fishermen and allows fishermen to fish their shares when they want.
Thus, regulatory discards associated with closed seasons would cease.
Some discards would still occur from the 15-inch minimum size limit and
from fishermen targeting reef fish after using all of their annual
allocation of IFQ shares.

**Preferred Alternative 2** sets the size limit at 13 inches TL. Wilson
et al. (2004) and Porch (2005) examined the size distribution of
undersized red snapper caught by the commercial fishery. Their estimates
of the number of fish caught between 13 and 15 inches was between 62 and
41 percent, respectively. Thus selecting this alternative would reduce
the number of discards from the current 15-inch minimum size limit.

**Alternative 3** eliminates the minimum size limit for red snapper.
Porch (2005) indicated red snapper less than 12 inches were not
considered marketable and would unlikely be retained by the commercial
fishery. Wilson et al. (2004) estimated 14 percent of undersized fish
measured from commercial catches at sea were less than 12 inches. Thus,
this measure would not completely eliminate discards, although the
number of discards would be less than **Preferred Alternative 2**. Porch
(2005) and Wilson et al. (2004) estimated the number of commercially
caught red snapper between 12 and 15 inches was 61 percent and 86
percent, respectively.

Effects of these alternatives on the physical environment should be
minimal (see Section 5.3.1). Impacts result from gear interacting with
bottom structure. Hook-and-line and longline gear, the predominate gear
types of the fishery, minimally interact with the bottom compared to
other gears such as trawls and traps. Effects from gear are related to
fishing effort, thus alternatives reducing effort would have less of an
impact on the physical environment. **Alternatives 2 and 3** would be
more favorable to the physical environment than **Alternative 1**
because they would allow fishermen to keep more fish and should result
in an overall decrease in fishing effort.

**Alternative 3** (no size limit) would be most beneficial to the
biological environment because stock rebuilding would occur more quickly
than the current 15-inch size limit. Porch (2005) reported the current
15-inch size limit contributes little towards stock rebuilding. This is
because benefits derived from harvesting a larger fish are nullified by
the high discard mortality rates associated with the commercial fishery.
In a comparison between a 15-inch and 12-inch minimum size with
recreational harvest parameters held constant, stock recovery occurred
faster at the smaller size limit. Porch (2005) did not examine the
effects of a commercial 13-inch size limit (**Preferred Alternative 2**)
under similar recreational conditions; however, the effects should be
intermediate to **Alternatives 1 and 3**.

Reducing the commercial red snapper size limit from the current 15-inch
minimum is expected to result in increased economic benefits to the
fishery and associated industries. These benefits are expected to accrue
to increased operational efficiency of commercial vessels and to a
potential price premium for smaller fish. This expectation holds
regardless of the TAC. In the short term, **Alternative 3** is expected
to result in slightly greater economic benefits than **Preferred
Alternative 2**. However, perceptions of inequity between no commercial
minimum size limit (**Alternative 3**) and the current minimum size
limit in the recreational sector (16 inches) may result in
unquantifiable future adverse economic impacts that erode the benefits
attributable to increased commercial vessel efficiency. Thus, overall,
the economic benefits of **Preferred Alternative 2** are expected to
exceed those of **Alternative 3**. For the preferred TAC (5.0 MP,
**Preferred** **Alternative 3**) and minimum size combination (13
inches, **Preferred** **Alternative 2**), the commercial fishery is
projected to consist of 22-52 vessels and generate approximately \$14.5
million in net revenue. These net revenues are approximately 0.08
percent greater than under the status quo minimum size limit.

**Alternative 1** maintains the 15-inch TL minimum size limit and would
not have any short-term effects on the social environment. **Preferred
Alternative 2** would reduce the minimum size limit to 13-inches TL.
This would allow fishermen to keep more of the fish they catch and would
reduce bycatch of fish that are too small to be kept now. **Preferred**
**Alternative 2** may lead to commercial fishermen filling their IFQ
shares more quickly, which could impact the fishermen and communities
dependent on the fishery. **Alternative 3** would eliminate the
commercial red snapper minimum size limit and would reduce the waste of
fish that are now less than 15 inches. Commercial fishermen will benefit
from being able to keep all of the fish they catch, making the fishery
more efficient by requiring less time fishing, and less expenditure on
fuel and bait. Overall, **Preferred Alternative 2** would benefit the
participants in the fishery, while reducing potential user conflicts
associated with the entire elimination of the minimum size limit

**Alternatives 2 and 3** would result in some minor adjustments to the
Reef Fish FMP and fall within the scope and capacity of the current
management system and are not expected to significantly affect the
administrative environment. Because **Alternative 3** would eliminate
the commercial minimum size limit, one less regulation would need to be
enforced, reducing the administrative burden on red snapper management
and enforcement.

**Action 5. Modify fishing gear restrictions**

**Alternative 1. No action. Do not implement further fishing gear
modifications to reduce bycatch in the directed red snapper fishery.**

**Preferred Alternative 2. Require the use of non-stainless steel circle
hooks when using natural baits, and require the use of venting tools and
dehooking devices when participating in one of the following EEZ
fisheries:**

**Option a. Commercial red snapper fishery**

**Option b. Recreational red snapper fishery**

**Option c. Both commercial and recreational red snapper fisheries**

**Preferred Option d. All commercial and recreational reef fish
fisheries**

**Alternative 3. Require a minimum hook size when participating in one
of the following EEZ fisheries:**

**Option a. Commercial red snapper fishery**

**Option b. Recreational red snapper fishery**

**Option c. Both commercial and recreational red snapper fisheries**

**Option d. All commercial and/or recreational reef fish fisheries**

> **The minimum required hook size would be:**
>
> **Suboption i. A hook with an outside diameter of at least 2.5 cm and
> a hook point to shank (gap) measurement of no more than 1.0 cm.**
>
> **Suboption ii. A hook with an outside diameter of at least 2.8 cm and
> a hook point to shank (gap) measurement of 1.1 cm.**
>
> **Suboption iii. A hook with an outside diameter of at least 3.3 cm
> and a hook point to shank (gap) measurement of 1.2 cm.**
>
> **Suboption iv. A hook with an outside diameter of at least 3.7 cm and
> a hook point to shank (gap) measurement of 1.4 cm.**

[Discussion]{.underline}: Section 5.5 examines the effects of the
various Action 5 alternatives relative to each other within the
physical, biological/ecological, socioeconomic, and administrative
environments. Factors considered in this discussion include:

-   For many species, circle hooks reduce hooking mortality rates more
    than J-style hooks (Cooke and Suski 2004).

-   Reduction in release mortality associated with the use of circle
    hooks results primarily from the tendency of circle hooks to
    jaw-hook fish (Cooke and Suski 2004).

-   Some studies indicate catch rates and mean length at capture for red
    snapper are greater for circle hooks compared to J-hooks (Sullivan
    et al. 1999; Henwood et al. 2006); however, Powers and Shipp
    (personal communication.), found similar mean length at capture, but
    lower catch rates for red snapper caught with circle hooks compared
    to J-hooks.

-   More red snapper caught with rod-and-reel gear die from hook
    mortality caused by J-hooks than all other causes combined,
    including depth, stress, and handling (Burns et al. 2002).
    Additionally, Burns (personal communication.) has shown tag return
    rates for red snapper caught on circle hooks to be greater than
    J-hooks.

-   Preliminary data suggest that venting increases survival in red
    snapper caught in deep water (Burns and Porch, personal
    communication).

-   Ease of hook removal is a major contributor to release survival
    (Cooke and Suski 2004).

-   Venting, when properly executed, increases survival of released
    fish.

-   Large hooks in general result in some size selectivity towards
    larger fish; however, they do hook smaller fish as well (Cooke and
    Suski 2004).

-   There is no industry standardization of hook size.

**Alternative 1** (no action) would not require any additional gear or
gear modifications for the directed red snapper fishery or reef fish
fishery to reduce bycatch or bycatch mortality. Anecdotal information
suggests circle hook use is common in the commercial fishery and some
sectors of the recreational fishery. Dehooking devices are required in
the commercial and for-hire fisheries through Amendment 18A; however,
this requirement is aimed at protected species, such as sea turtles. The
extent these sectors would also use dehookers to assist in releasing
fish is unknown. Selecting various gears to reduce bycatch should
provide long-term benefits to the stock.

**Preferred Alternative 2, Preferred Option d** would require the use of
circle hooks, venting tools, and dehooking devices when harvesting reef
fish from the EEZ. Cooke and Suski (2004) reviewed studies on circle
hook effectiveness to determine the usefulness of circle hooks for
fisheries management. Overall, they found mortality rates were lower for
circle hooks than J-style hooks. Hooking depth, anatomical hooking
location, amount of bleeding, and ease of hook removal were identified
as major contributors to mortality. These factors were thought to be
reduced by the use of circle hooks. Circle hooks typically hook fish
around the maxilla for red snapper (SEDAR 7, 2005), and are less likely
to be swallowed. Burns (personal communication) has shown that tag
return rates for fish caught on circle hooks are greater than fish
caught on J-hooks (8.6 percent return vs. 7.97 percent, respectively)
suggesting greater survival.

Testimony provided to the Council indicates commercial red snapper
fishermen primarily use circle hooks already, therefore requiring these
hooks only in this fishery (**Preferred Alternative 2, Option a**) would
do little to reduce discard mortality by the directed fishery. Requiring
their possession in the recreational fishery (**Preferred Alternative 2,
Option b**) would reduce discard mortality for some sectors where circle
hooks are not typically used. Requiring the possession of circle hooks
in both the recreational and commercial red snapper fisheries
(**Preferred Alternative 2, Option c**), or the entire reef fish fishery
(**Preferred Alternative 2, Preferred Option d**), would further
decrease discard mortality of red snapper and/or other reef fish
species. This would be particularly important over the long term during
red snapper closed seasons when all caught red snapper are released.

**Preferred Alternative 2** would also require the use of venting tools
when harvesting red snapper from the EEZ. Venting, when properly
executed, increases survival of released fish. Preliminary data from a
15-year study conducted at Mote Marine Lab (Burns and Porch, personal
communication) suggests that venting increases survival in red snapper
caught in deep water. A venting tool can be any hollow, sharpened
instrument that allows gases to escape. Ice picks and knives are not
suitable because simply puncturing the fish is undesirable and can
result in mortal injury (Florida Sea Grant 2005). The Sea Grant/Novak
Venting Tool designed and developed by Florida Sea Grant in cooperation
with Mote Marine Laboratory, can be purchased from Aquatic Release
Conservation, Inc. Alternatively, a venting tool can be created out of a
hypodermic needle syringe with the plunger removed, or by cementing a
16-gauge needle into a hollow wooden dowel (Florida Sea Grant 2005)
(Figure 2.3).

![](media/image7.png){width="2.9694444444444446in"
height="3.0722222222222224in"}

**Figure 2.3. Two examples of venting tools described by Florida Sea
Grant (2005).**

To properly vent a fish with an expanded swimbladder, protocols
developed by Florida Sea Grant (2005) have the fisherman holding the
fish gently but firmly on its side and inserting the venting tool at a
45-degree angle approximately one to two inches from the base of the
pectoral fin (Figure 2.4.). The tool should be inserted deep enough to
release the gases, which, when done properly, is accompanied by an
audible sound of gas escaping with a noticeable deflation of the body
cavity. For fish extremely bloated, gentle pressure on the fish's
abdomen, using the hand holding the fish, aids deflation (Florida Sea
Grant 2005).

![](media/image8.png){width="3.3340277777777776in" height="1.875in"}

**Figure 2.4. Anatomical location for inserting a venting tool into a
fish with an over expanded swimbladder (Florida Sea Grant, 2005).**

A third requirement of **Preferred** **Alternative 2** would be
dehooking devices. Dehooking devices are any device intended to remove a
hook embedded in a fish in order to release the fish with minimum
damage. Several devices may be used to remove hooks depending on the
depth and location of hooking (Figure 2.5). Cooke and Suski (2004)
identified ease of hook removal as a major contributor to mortality;
therefore, the use of dehookers to remove hooks and lines would likely
reduce serious injury and post-release mortality of targeted species,
and other incidentally caught species.

![](media/image9.png){width="2.6020833333333333in"
height="1.8319444444444444in"}![](media/image10.wmf){width="2.4319444444444445in"
height="1.8125in"}

**Figure 2.5. Some examples of dehooking devices that can be used to
remove fishing hooks. The type of dehooking device used depends on
hooking location and depth.**

**Options a-c** in **Alternative 3** specify a minimum hook size to be
used in the directed red snapper fishery, while **Alternative 3, Option
d** expands the requirement to all reef fish fisheries. Specifications
for hook size are given under the various sub-options instead of
traditional manufacturers' sizing to eliminate confusion caused by the
discrepancies found between manufacturers' hook sizes. As seen in Table
2.5, there is a wide discrepancy between manufacturers' hook sizes in
relation to the outside diameter and hook point to shank measurements.

Cooke and Suski's (2004) review found large hooks in general result in
some size selectivity towards larger fish; however, they do hook smaller
fish as well. Specifically for red snapper, Gledhill and Driggers (
2006), found the mean length at capture was greater when caught with
circle hooks (Mustad 15/0) compared to J-hooks. They also found a
significant difference in fish length between circle hook sizes (Mustad
11/0 versus Mustad 15/0), with larger hooks catching larger fish. Thus
selecting a minimum hook size could possibly reduce the number of
undersized fish discarded. Suboption iv would require the largest
minimum hook size, and therefore is expected to reduce discards the most
relative to the other suboptions.

**Table 2.5. Manufacturer hook size and outside diameter and hook point
to shank measurements.**

  ------------------------------------------------------------------------
  **Manufacturer hook   **Hook     **Outside diameter **Hook point to
  size**                Style**    (cm)**             shank (cm)**
  --------------------- ---------- ------------------ --------------------
  Owner - 2/0           Circle     2.25               1.05

  Owner - 3/0           Circle     2.5                1.15

  Owner - 4/0           Circle     2.6                1.3

  Owner - 5/0           Circle     2.95               1.5

  Owner - 7/0           Circle     2.8                1.65

  Owner - 8/0           Circle     2.95               1.9

  Owner - 9/0           Circle     3.2                2

  Eagle Claw - 2/0      Circle     1.8                1

  Eagle Claw - 3/0      Circle     2.05               1.2

  Eagle Claw - 4/0      Circle     2.3                1.4

  Eagle Claw - 5/0      Circle     2.55               1.45

  Gamakatsu - 2/0       Circle     1.95               1.2

  Gamakatsu - 3/0       Circle     2.05               1.4

  Gamakatsu - 4/0       Circle     2.2                1.5

  Gamakatsu - 5/0       Circle     2.4                1.6

  Mustad - 10/0         Circle     2.5                1

  Mustad - 11/0         Circle     2.8                1.1

  Mustad - 12/0         Circle     3.3                1.2

  Mustad - 13/0         Circle     3.7                1.4
  ------------------------------------------------------------------------

The intended effects of the gear modifications in **Preferred
Alternative 2 and Alternative 3** are to reduce bycatch and discard
mortality, which would be expected to decrease effort in the fishery,
thereby benefiting the physical environment compared to **Alternative
1**. **Preferred Alternative 2** is expected to benefit the physical
environment because circle hooks snag the bottom less often due to their
design. **Alternative 3** would require a minimum hook size while
fishing for red snapper and/or reef fish. Specifying a minimum hook size
reduces the capture of undersized fish, but would not greatly benefit
the physical environment unless the size of the hook increases or
decreases interactions with bottom habitat.

Though anecdotal evidence suggests circle hook use is widespread in the
commercial sector, and increasing in popularity in the recreational
sector, it appears mandatory use of circle hooks in all fisheries would
benefit the biological environment of red snapper by reducing acute and
long-term mortality caused by J-hook usage. Also, it is believed that
venting, when properly executed, could increase survival of released
fish. The use of venting tools may also reduce predation on red snapper
and other bycatch species. The use of dehooking devices to remove hooks
and lines would likely reduce serious injury and post-release mortality
of sea turtles, marine mammals, targeted species, and other incidentally
caught species. Larger hooks result in some size selectivity towards
larger fish, which would reduce the number of fish discarded as
regulatory discards and would allow for a quicker stock recovery time.
Thus, **Preferred Alternative 2 and Alternative 3** are both expected to
be more beneficial to the red snapper stock than the current regulations
for gear requirements.

**Alternative 1** would not impose any additional gear requirements or
restrictions on either the red snapper or reef fish fisheries and would
not, therefore result in any direct or indirect short-term economic
impacts to participants in the directed fisheries or associated
businesses. The gear requirements and restrictions considered by
**Preferred Alternative 2 and** **Alternative 3** have the intended
purpose of reducing bycatch and bycatch mortality, with attendant gains
in long-term stock conditions and economic benefits. Each alternative
comes with attendant costs, through new gear purchases, though such
costs are not expected to be substantial.

Continued mortality associated with the absence of gear modifications
would be expected, however, to result in slower recovery and more
restrictive harvest allowances than would otherwise be possible, with
attendant loss in economic benefits. Continuation of the status quo
through Council action would, therefore, be expected to delay
rebuilding, where applicable, and reduce allowable harvests and
associated economic benefits to the directed fisheries and associated
businesses. From the long-term perspective, the expected impacts of the
hook specification, dehooking gear, and venting gear alternatives are
largely indistinguishable when considered for application to a specific
fishery. However, the expected benefits of potentially applying the
requirements to all reef fish fisheries (**Preferred Alternative 2,
Preferred Option d** and **Alternative 3, Option d** are expected to
exceed the benefits when compared with such requirements being applied
only to the red snapper fishery or a sector thereof (**Options 2(a-c)**
and **Options 3(a-c)**).

**Alternative 1** would not have any direct or indirect effects on the
social environment in the short run because it maintains the status quo.
**Preferred Alternative 2 and Alternative 3** require the use of certain
gear for the red snapper and reef fish fisheries that will help to
protect and preserve the species. Although fishermen will be required to
purchase new hooks, venting tools and dehooking devices, this action
will have minimal impacts on the fishermen and fishing communities while
allowing the fishery to be rebuilt.

All alternatives would require adjustments to the Reef Fish FMP, which
fall within the scope and capacity of the current management system.
**Alternative 1** would continue current gear requirements while
**Preferred Alternative 2 and Alternative 3** would modify these
requirements. Defining and enforcing these requirements would increase
the administrative burden of red snapper and/or reef fish management.

**Action 6. Establish a Target Reduction Goal for Juvenile Red Snapper
Mortality in the Shrimp Fishery of the northern and western Gulf of
Mexico**

**Alternative 1: No Action - do not establish a target reduction goal
for the shrimp fishery of the northern and western Gulf of Mexico**

**Alternative 2: Establish a target reduction of shrimp trawl bycatch
mortality on red snapper 50 percent less than the benchmark years of
2001-2003.**

**Alternative 3: Establish a target reduction of shrimp trawl bycatch
mortality on red snapper 60 percent less than the benchmark years of
2001-2003.**

**Preferred Alternative 4: Establish a target reduction of red snapper
shrimp trawl bycatch mortality on red snapper 74 percent less than the
benchmark years of 2001-2003.**

**Alternative 5: Establish a target reduction of red snapper shrimp
trawl bycatch mortality on red snapper 74 percent less than the
benchmark years of 2001-2003 and then adjust it to the appropriate
percent as determined by the red snapper stock assessment updates.**

[Discussion]{.underline}: The 2005 assessment for red snapper indicated
a need for a 74 percent reduction in shrimp trawl bycatch mortality,
beginning in 2007, compared to levels of effort and mortality
experienced during the 2001-2003 period to end overfishing between 2009
and 2010. Fishing mortality during the 2001-2003 time period was
estimated at 0.617 for the western Gulf of Mexico, and that includes the
contributions attributable to BRDs; therefore fishing mortality needs to
be reduced to 0.160 (Figures [2.5 and 4.1.4]{.mark}). The most commonly
used BRD, the Fisheye positioned greater than 10.5 feet from the codend
tie-off, was expected to reduce mortality by 44 percent from the
mortality level during the 1984-1989 time period. In previous red
snapper assessments, this magnitude of bycatch reduction was expected to
be sufficient for the stock to rebuild, assuming it was achieved from
1998 onward. However, recent evaluations of the Fisheye BRD indicate it
is reducing F by only approximately 11 percent. Given that the target
level of reduction from BRDs was not achieved, even greater reductions
are now required. Based on a new BRD certification criterion to be
established in 2007, new and more effective BRDs will be certified for
use in the fishery. The BRDs most likely to be used by the industry
reduce mortality on juvenile red snapper by greater than 20 percent
(Table 2.6); therefore, the new BRDs should reduce mortality from shrimp
trawls by at least an additional 10 percent over the contribution of the
current industry standard, the Fisheye. However, BRDs by themselves,
will not meet the new reduction needs to achieve rebuilding of the red
snapper stock. Consequently, a target reduction goal and measures to
achieve this goal need to be established.

![](media/image11.wmf){width="3.625in" height="2.4458333333333333in"}

**Figure 2.5. Shrimp Trawl Bycatch F-values (Red Snapper)**

**Table 2.6. Performance and Average Price of Bycatch Reduction Devices
Tested in the Gulf of Mexico**

+-----------------+----------+----------+----------+-------+--------+
| **BRD TYPE**    | **R      |          |          | **S   | **A    |
|                 | EDUCTION |          |          | hrimp | verage |
|                 | CRI      |          |          | L     | P      |
|                 | TERION** |          |          | oss** | rice** |
|                 |          |          |          |       |        |
|                 |          |          |          | **(   | **per  |
|                 |          |          |          | Perce | Unit** |
|                 |          |          |          | nt)** |        |
+-----------------+----------+----------+----------+-------+--------+
|                 | Pe       | Pe       | Pe       |       |        |
|                 | rcentage | rcentage | rcentage |       |        |
|                 | R        | R        | R        |       |        |
|                 | eduction | eduction | eduction |       |        |
|                 |          |          | in Total |       |        |
|                 | in Red   | in CPUE  | Finfish  |       |        |
|                 | Snapper  | on Red   | Bycatch  |       |        |
|                 |          | Snapper  | (by      |       |        |
|                 | (Ages    |          | weight)  |       |        |
|                 | 0 - 1)   | (Ages 0  |          |       |        |
|                 | M        | -- 1)    |          |       |        |
|                 | ortality |          |          |       |        |
+-----------------+----------+----------+----------+-------+--------+
| Fisheye Legal   | **26.6** | **26.6** | **22.8** | **    | \$45   |
|                 |          |          |          | 6.3** |        |
| 8.5'-10.5'      | (5.5 -   | (5.5 -   | (18.0-   |       |        |
|                 | 47.8)    | 47.5)    | 27.5)    | (4.0- |        |
|                 |          |          |          | 8.7)  |        |
+-----------------+----------+----------+----------+-------+--------+
| Fisheye Legal   | **10.8** | **8.8**  | **13.5** | **    | \$45   |
| 10.6'-12.5'     |          |          |          | 1.6** |        |
|                 | (-1.3 -  | (1.1 --  | (11.1--  |       |        |
|                 | 22.9)    | 16.5)    | 15.9)    | (-0.4 |        |
|                 |          |          |          | -3.6) |        |
+-----------------+----------+----------+----------+-------+--------+
| Fisheye -- All  | **9.4**  | **6.2**  | **17.0** | **    | \$45   |
|                 |          |          |          | 1.2** |        |
|                 | (3.3 -   | (0.1 -   | (16.1-   |       |        |
|                 | 15.5)    | 12.2)    | 17.9)    | (0.4- |        |
|                 |          |          |          | 2.1)  |        |
+-----------------+----------+----------+----------+-------+--------+
| Jones Davis     | **52**   | **40.0** | **58.0** | **    | \$425  |
|                 |          |          |          | 4.0** |        |
|                 | ( \* \*  | (30.     | (53.0    |       |        |
|                 | )        | 0--50.0) | --63.0)  | (0.0  |        |
|                 |          |          |          | -     |        |
|                 |          |          |          | -9.0) |        |
+-----------------+----------+----------+----------+-------+--------+
| Modified Jones  | **30.6** | **24.1** | **33.1** | **    | \$200  |
| Davis           |          |          |          | 3.2** |        |
|                 | (25.6    | (18.6    | (30.3    |       |        |
|                 | -35.7)   | -29.6)   | --36.0)  | (1.4  |        |
|                 |          |          |          | -4.9) |        |
+-----------------+----------+----------+----------+-------+--------+
| Extended Funnel | **25.1** | **17.4** | **26.6** | **    | \$350  |
|                 |          |          |          | 2.2** |        |
|                 | (11.8    | (6.5 --  | (21.7    |       |        |
|                 | --38.4)  | 28.2)    | -31.6)   | (-1.7 |        |
|                 |          |          |          | -6.0) |        |
+-----------------+----------+----------+----------+-------+--------+

Source: Dan Foster, NMFS -- 95% confidence interval in parentheses;

\*\* based on Goodyear model: confidence interval not available.

The following summary discussion is based on several factors discussed
elsewhere in this document:

-   Shrimp fishing effort has a strong correlation to the levels of red
    snapper mortality attributable to the shrimp fishery (Figure 2.6 and
    Table 2.7), and is a more appropriate tool to manage red snapper
    mortality than bycatch quotas or restrictions on the number of
    federal shrimp vessel permits (see [Figure 4.1.3]{.mark}).

-   Juvenile red snapper are more common in the 10-30 fathom depth
    strata (Section 3.2.1).

-   Shrimp fishing effort in 2005 in areas where red snapper are
    abundant was reduced by 50 to 60 percent from the baseline 2001-2003
    period (Figure 3.2.1.3 and Table 2.7).

-   The number of vessels participating in the offshore shrimp fishery
    is expected to continue declining until at least 2012, and has been
    further reduced by the impacts of Hurricanes Katrina and Rita
    (Section 3.2).

The effort declines illustrated in Tables 3.2.1 and 3.2.2 are
anticipated to continue given the current economic environment, but they
may not be permanent. To that end, **Alternative 1** (No action) may not
ensure consistent reductions in bycatch mortality on juvenile red
snapper in the shrimp fishery over the time of the current rebuilding
program. In addition, as noted above, although reducing bycatch
mortality on juvenile red snapper through the use of BRDs is a practical
action, it does not appear (Table 2.6) that current technology will have
the potential, in the near future, to develop BRDs that meet the overall
reduction goals. Therefore, the Council is considering additional
measures to reduce bycatch in the shrimp fishery, recognizing additional
bycatch mortality reduction may continue to occur from continued effort
reductions.

In developing alternatives for an interim rule to begin reducing fishing
mortality from the directed red snapper and shrimp fisheries, NMFS
established a target reduction goal of 50 percent for the shrimp
fishery. This target was based on initial estimates of fishing mortality
on juvenile red snapper attributable to shrimp effort in areas where red
snapper are abundant (Figure 3.2.1.3). Initial estimates suggested
effort was down by 58 percent in these areas, which translated to a 52
percent reduction in fishing mortality on juvenile red snapper.
**Alternative 2** in this amendment would maintain the target
established in the interim rule. It does not meet the 74 percent target
mortality reduction level recommended by the 2005 red snapper stock
assessment to end overfishing between 2009 and 2010, and it would likely
result in TAC for red snapper having to be set at approximately 2.8 MP
for 2008 and 2009. Nevertheless, a 50 percent reduction target would
allow the industry some additional flexibility in achieving OY, as it is
currently defined for the fishery.

**Figure 2.6. Juvenile Red Snapper F vs. Shrimp Effort in the 10-30
Fathoms in the Gulf of Mexico.**

![](media/image12.wmf){width="4.439583333333333in"
height="4.016666666666667in"}

Subsequent analyses of 2005 shrimp effort data revised the reduction
estimates (Table 2.7), suggesting effort and fishing mortality was
reduced by approximately 60 percent from the benchmark 2001-2003 period.
In addition, as noted in Section 3.2, effort is expected to continue
declining in the near future. For example, of the 1,800 shrimp trawl
vessels active during 2005, the U.S. Coast Guard has documented that
nearly 150 of those vessels were either damaged or stranded. Assuming
equal effort among vessels, this would equate to a 5-10 percent
reduction in effort from the 2005 level attributed to attrition in the
fishery. Preliminary estimates of effort in 2006 support these
assumptions. Data for the first two trimesters of 2006 suggest total
effort in the western Gulf may be down by an additional 10 percent, and
effort in the 10 to 30 fathom area of the western Gulf may be down by as
much as 35 percent from the levels of effort documented for 2005 (Nance,
personal communication). Assuming these preliminary estimates hold true,
F in 2007 would be approximately 74-75 percent below the 2001-2003
average.

**Table 2.7. Juvenile Red Snapper F vs. Shrimp Effort in the 10-30
Fathoms in the Western Gulf of Mexico**

![](media/image13.wmf){width="5.991666666666666in"
height="4.595138888888889in"}

**Alternative 3** would establish a target mortality reduction of 60
percent from the benchmark years; this reduction level reflects the
level of effort reductions associated with 2005, and in the near future,
it is expected that fishing mortality will remain below this level. As
previously stated, the revised BRD criterion is expected to further
reduce bycatch mortality by an additional 10 percent. Furthermore, The
Council also expects effort and participation in the fishery to continue
to decline due to potential reductions in permits from the
implementation of the shrimp vessel permit moratorium and the current
external economic factors. As mentioned above, in the discussion for
**Alternative 2**, early estimates of 2006 shrimp effort support the
expectation of continuing declines. These declines are detailed in the
Regulatory Impact Review section, and are anticipated to continue at
least through 2012. As discussed in **Action 8**, NMFS annually would
develop effort estimates, and either the Council or NMFS would then
consider management actions to keep shrimp effort below the selected
threshold, if needed.

**Preferred Alternative 4**, as well as **Alternative 5**, would
establish a target aligned with the recommended 74 percent reduction in
red snapper fishing mortality from the benchmark years of 2001-2003.  As
noted in the discussion for **Alternative 2**, the fishery is likely to
meet a 74 percent reduction in the 10-30 fathom depth strata of the
western Gulf of Mexico, based on preliminary effort estimates for 2006,
along with anticipated benefits of improved BRDs in 2007 or 2008. 
Nevertheless, although limited expansion of the fishery is anticipated
in the near future, actions may be needed in the future to maintain
these reductions in effort in areas where red snapper are abundant, such
as those identified in **Action 7.**  As noted below, this reduction in
effort, which only affects the ability of the fishery to utilize a
portion of the shrimp grounds for a limited time frame during the year,
should not preclude the fishery the opportunity to achieve OY, as
currently defined, on a continuing basis.

There would be no direct biological impacts from setting a target
reduction goal for red snapper bycatch mortality in the Gulf shrimp
fishery. This is an administrative action that would allow managers to
monitor a specific portion of the total shrimp effort in the northern
and western Gulf that has a direct impact on juvenile red snapper. If
the target effort level is being exceeded to the point where managers
determine further actions are needed, there would be indirect effects
only in the sense that this action would serve as the basis for future
actions. Any biological impacts would result from options presented in
**Action 8**. Such impacts would be identified and discussed in a
regulatory amendment or in supporting documents for action delegated to
the RA, depending on the Council's choice of a preferred option.

**Alternative 3,** **Preferred Alternative 4**, and **Alternative 5**
could result in a long-term restriction of effort in the mid-shelf
regions of the western Gulf of Mexico, compared to the baseline
2001-2003 period, or the documented level of effort in 2005.  The
fishery in the 20-50 fm depth zone is primarily for brown shrimp. 
Because of economic issues facing the shrimp fishery today, brown shrimp
landings are below the Council's designation of OY.  However, these
proposed effort restrictions in the mid-shelf region should not prevent
the fishery from achieving OY as it is currently defined.  It would not
preclude the fishery from targeting brown shrimp in waters deeper than
30 fathoms, or inshore of 10 fathoms.  And depending on the length of
any time-area closure, such as proposed in Action 7, the areas in the
mid-shelf area would also be open probably most of the year.

Since this is an administrative action, none of the alternatives would
be expected to result in any direct adverse economic or social impacts
in the short-term or long-term. **Alternatives 1, 2, and 3** would also
not be expected to result in any indirect short-term adverse economic
and social impacts. **Alternative 1** would not establish a benchmark on
which to base subsequent effort control. Current effort reductions are
believed to be within the benchmarks that would be established by
**Alternatives 2 and 3** and, hence, no additional restriction on the
shrimp fishery would be required at this time. However, increases in or
changes in the spatial distribution of effort in the shrimp fishery
could require future effort restrictions under **Alternatives 2 and 3**,
particularly if these changes increase effort in areas where juvenile
red snapper are abundant. Thus, **Alternatives 2 and 3** could
indirectly cause adverse economic and social impacts in the long-term.
Whether and to what extent these restrictions mirror those considered
under **Action 7** cannot be determined at this time. But, if so, the
discussion for **Action 7** provides a range of potential impacts. Due
to shrimpers exiting the fishery and the damage caused by the hurricanes
of 2005, as partially reflected by preliminary effort data for 2006, it
is also possible that the target established by **Preferred Alternative
4 and Alternative 5** will be achieved in 2007 and thus no additional
restrictions on the shrimp fishery would be required in 2008. However,
if the bycatch target is not achieved, measures may be required in the
future which could impact fishermen and communities that depend on the
fishery. Thus, **Preferred Alternative 4 and Alternative 5** could
potentially result in indirect adverse economic and social impacts due
to the effort restrictions that would need to be placed on the fishery,
the range of which is described under **Action 7**. The need for future
actions will be assessed in reports based on the preferred alternatives
selected in **Action 7** and **Action 8**.

[]{.mark}

**Action 7. Consider establishing shrimp fishing restrictions to reduce
effort to achieve a fishing mortality reduction target for juvenile red
snapper in the northern and western Gulf of Mexico established in Action
6**

**Alternative 1**. **No action -- do not consider establish fishing
restrictions for the Gulf shrimp fishery**

**Preferred Alternative 2:** **Establish if necessary a seasonal closure
beginning on the same start date as the closure of the EEZ off Texas in
the 10 to 30-fathom zone of selected areas within statistical zones
10-21 in the Gulf of Mexico. The need for the closure and its extent and
duration will be determined based on the annual evaluation of the level
of shrimp effort and associated red snapper mortality, taking into
consideration mortality reductions associated with improved BRDs and
other gear improvements. Any closure would be implemented in accordance
with the framework outlined in Action 8.**

**Alternative 3:** **Establish if necessary a seasonal closure within
the January 1 through April 30 timeframe in the 10 to 30-fathom zone of
selected areas within statistical zones 10-21 in the Gulf of Mexico. The
need for the closure and its extent and duration will be determined
based on the annual evaluation of the level of shrimp effort and
associated red snapper mortality, taking into consideration mortality
reductions associated with improved BRDs and other gear improvements.
Any closure would be implemented in accordance with the framework
outlined in Action 8.**

**Alternative 4:** **Establish if necessary a seasonal closure within
the October 1 through November 30 timeframe in the 10 to 30-fathom zone
of selected areas within statistical zones 10-21 in the Gulf of Mexico.
The need for the closure and its extent and duration will be determined
based on the annual evaluation of the level of shrimp effort and
associated red snapper mortality, taking into consideration mortality
reductions associated with improved BRDs and other gear improvements.
Any closure would be implemented in accordance with the framework
outlined in Action 8.**

[Discussion]{.underline}: The same four factors bulleted at the
beginning of the discussion section for **Action 6** apply to **Action
7.** The statistical zones referred to in the Alternatives are
illustrated in Figure 2.7.

**Figure 2.7. Diagram of the various statistical zones across the Gulf
of Mexico, used for record keeping purposes in regard to fishery
landings**.

![](media/image14.jpeg){width="5.99375in" height="2.7416666666666667in"}

Because of the relatively high bycatch of juvenile red snapper in the
shrimp trawl fishery, managers have, on several occasions, considered
alternatives to minimize such bycatch through area and seasonal
closures. It should be noted that the Council rejected broad time-area
closures and bycatch reduction options for the shrimp fishery in
Amendment 1 to the Reef Fish FMP in 1990, and again in Amendment 9 to
the Shrimp FMP in 1998 and again in Amendment 10 to the Shrimp FMP in
2004. Any seasonal closure intended to reduce the catch of juvenile red
snapper would have to assume a consistent and proportional relationship
across years for shrimp effort, shrimp and red snapper distribution, and
juvenile red snapper recruitment. In addition, to be effective the
seasonal or area closure must include the time period just prior to the
migration of these juvenile red snapper from shrimp grounds to areas of
greater relief.

More importantly, depending on the amount of effort allowed, there could
be a change in the fishing behavior of the shrimp fleet and a
redistribution of effort around a closed area. Shrimp effort could be
expected to move to state and nearshore federal waters if a closure as
with **Preferred Alternative 2** and **Alternatives 3 and 4** is
implemented. This is particularly true off Louisiana and northeast Texas
where white shrimp (that occur closer to shore) are dominant in the fall
and early winter months, after the high brown shrimp effort period of
July and August. Finally, the impacts of Hurricanes Katrina and Rita may
have reduced effort due to vessel damage and loss to the extent that any
reasonable cap on effort to control the level of bycatch may not be
reached, and a closure may not be needed, or it could be reduced in
scope.

As noted above, any season or area closure must provide the ability for
the affected size/age class of red snapper to escape the shrimp fishery.
Closed areas would be most effective if they are large (for
enforceability and to effectively address the broad distribution of red
snapper in the northern and western Gulf) because juvenile red snapper
are associated with the shrimp grounds for 14 months or longer. The
geographic scope of the closure would also need to include documented
areas where juvenile red snapper are found to be consistently abundant
across years. As discussed in detail in Sections 3.2 and 4.1, recent
evaluations of catch and bycatch data (Gallaway et al. 1998; Gallaway et
al. 1999) indicate substantial portions of the total juvenile red
snapper bycatch occurs in shrimp trawls fished in the mid-shelf depth
zones of the northern and western Gulf of Mexico (west of Cape San Blas,
Florida). Juvenile red snapper occur infrequently inside of 10 fathoms
(Branstetter 1997; Gallaway et al. 1998). Gallaway et al (1998, 1999)
found the greatest densities of juvenile red snapper catches occurred in
the areas between 10 and 25 fathoms. Therefore, the Council is not
considering closures in the entire EEZ of the northern and western Gulf.

**Alternative 1** (No Action) would not provide for the establishment of
a time/area closure and would allow the shrimp fishery to continue, with
the only anticipated reductions in red snapper mortality being
associated with any further declines in effort because of external
factors. While these declines are anticipated, they are not assured; at
least, not in the long term. If fishing effort and bycatch mortality
levels in 2007 do not meet the 74 percent reduction target **(Action 6,
Preferred Alternative 4 and Alternative 5)** or if effort increases in
the future and exceeds the target, the choice of **Alternative 1** would
not provide the Council with an immediate means to address the issue.
Additional action, through a plan amendment or other action by NMFS
(interim rule or emergency action) would be needed to return fishing
effort and thus bycatch mortality to the threshold level.

**Preferred Alternative 2** would provide for a potential closure in the
northern and western Gulf (Statistical Subzones 10-21) within the 10-30
fathom zone in conjunction with the beginning of the Texas Closure,
which closes the entire EEZ off Texas from typically May 15 to July 15.
This depth range is where red snapper are known to be most abundant and
the area that contains the most suitable juvenile red snapper habitat
(see Figures 3.2.1.1 and 3.2.1.2). It is important to emphasize that
while the starting date of the potential closure considered under this
alternative is set to coincide with the beginning of the Texas closure,
no ending date is specified. In other terms, this alternative could
potentially result in a short closure, i.e., a few days or result in a
closure lasting up to a full year. Similarly, within the 10-21
statistical zones, the scope of the closure could be limited to a few
statistical zones or cover the entire area (from Mobile Bay to
Brownsville).

Assuming the area closure coincided with the Texas Closure (ca. 60
days), it would provide approximately a 17.5 percent reduction in effort
in the 10-30 fathom zone from Mobile Bay to Brownsville (Table 2.7). As
noted under the discussions for **Alternative 3** for **Action 6**,
effort in 2006 for the 10-30 fathom depth range may be 35 percent less
than it was in 2005. If so, fishing mortality reductions may be meeting
the target reduction goal of 74 percent, and a closure associated with
the beginning of the Texas Closure might be of very limited duration or
areal scope.

The potential seasonal closure considered under **Preferred Alternative
2** would encompass the beginning of the time red snapper reach
biological age 1, attain a size of approximately 120-150 mm, and begin
emigrating off the shrimp grounds to areas of high relief (see Figures
4, 5, and 6 in Gallaway and Cole 1999). While the overall abundance and
catch rate of red snapper are not particularly high during the Texas
closure, almost all the red snapper caught are age 1 fish. A closure
during this time period would allow a large number of them to migrate
off the shrimp grounds to their sub-adult habitats. The age 0 fish on
the grounds at this time are very small because spawning occurs in the
Spring, and small (ca. 50 mm) juvenile red snapper are just beginning to
settle on the shrimp grounds at this time. This new age class is not as
vulnerable to trawl gear, being of a size where they can pass through
the webbing of the net. Recent analyses by NMFS suggests as many as 65
percent of small Age-0 red snapper may pass through standard sized
(1-7/8") mesh bags used by the fishery.

Shrimp trawl mortality in the 10 to 30 fathom depth zone has a
significant linear relationship with annual fishing effort in 10 to 30
fathoms (Figure 2.6). The 2005 red snapper stock assessment considered
the mouth of the Mississippi River as a dividing line to separate the
Gulf of Mexico into a western and eastern zone. Approximately 11 percent
of the total effort expended in the 10-30 fathom zone in statistical
subzones 10-21 (Mobile Bay to Brownsville) comes from statistical
subzones 10-12 (east of the Mississippi River), and primarily from
statistical subzone 11. While this fishing effort is substantial, the
impact of a 10-30 fathom closure in this area on juvenile red snapper
mortality is low (Figure 3.4.1.2); recreational fishing mortality is the
dominating impact in this eastern area. Reductions in effort and in
shrimp trawl mortality in the western Gulf (statistical subzones 13-21)
would provide the vast majority of the potential benefits of a closure
because reductions in effort are commensurate with reductions in fishing
mortality (Figure 3.4.1.2).

Closures established under the provisions of **Preferred Alternative 2**
could alleviate fishing mortality problems stemming from shifts in
fishing effort to Louisiana mid-shelf regions during the Texas Closure
each year. In past years, substantial amounts of effort have been
redirected to the Louisiana shelf area (Table 2.8). A closure of the
mid-shelf area off Louisiana beginning with the start of the Texas
Closure could provide the potential to reduce red snapper mortality from
direct reductions in effort (Table 2.7.2) in the areas where red snapper
are abundant. The alternative would not prohibit all shrimping off
Louisiana; substantial portions of the shelf are inshore of the
10-fathom contour and are fished during this time period, and
substantial effort occurs seaward of the 30-fathom contour as well
(Gallaway et al. 1999). Thus, none of the proposed closures should
preclude the fishery from achieving OY as it is currently defined.

**Table 2.8. Nominal effort (24-hr days fished) by sub-region in the
10-30 fathom depth zone of the Gulf of Mexico for 2005 compared to
average annual effort for the benchmark 2001-2003 period.**

  --------------- ----------- ----------- ----------- ----------- ------------
  **2001-2003**   **Stat      **Jan -     **May -     **Sept -    **Annual**
                  Zones**     Apr**       Aug**       Oct**       

  Florida         1 - 9       8,542       5,722       4,409       18,673

  FL-AL-MS        10 -- 12    603         3,150       2,515       6,268

  Louisiana       13 -- 17    3,117       25,342      5,948       34,407

  Texas           18 -- 21    6,201       15,680      17,938      39,820

                                                                  

  **2005**                                                        

  Florida         1 - 9       7,356       4,055       3,494       14,905

  FL-AL-MS        10 -- 12    799         2,864       917         4,580

  Louisiana       13 -- 17    1,641       10,489      1,282       13,412

  Texas           18 -- 21    1,028       7,889       6,900       15,817
  --------------- ----------- ----------- ----------- ----------- ------------

**Table 2.9. Percent of total shrimp effort for 2003-2005 per month in
the 10 to 30 fathom depth zone for Statistical Zones 10-21 (Mobile Bay
to Texas), 10-12 (east of the Mississippi River), and 13-21 (west of the
Mississippi River).**

+--------------------+---------------+---------------+---------------+
| MONTH              | Area 10-21    | Area          | Area 13-21    |
|                    |               |               |               |
|                    |               | 10-12         |               |
+--------------------+---------------+---------------+---------------+
| January            | 3.4           | 10.9          | 2.3           |
+--------------------+---------------+---------------+---------------+
| February           | 3.6           | 3.1           | 3.7           |
+--------------------+---------------+---------------+---------------+
| March              | 2.0           | 1.5           | 2.1           |
+--------------------+---------------+---------------+---------------+
| April              | 1.4           | 0.7           | 1.5           |
+--------------------+---------------+---------------+---------------+
| May                | 4.5           | 4.1           | 4.6           |
+--------------------+---------------+---------------+---------------+
| June               | 9.4           | 12.1          | 9.1           |
+--------------------+---------------+---------------+---------------+
| July               | 12.0          | 11.5          | 12.1          |
+--------------------+---------------+---------------+---------------+
| August             | 25.6          | 11.0          | 27.7          |
+--------------------+---------------+---------------+---------------+
| September          | 11.6          | 16.0          | 11.0          |
+--------------------+---------------+---------------+---------------+
| October            | 10.1          | 12.3          | 9.8           |
+--------------------+---------------+---------------+---------------+
| November           | 8.0           | 5.8           | 8.3           |
+--------------------+---------------+---------------+---------------+
| December           | 8.4           | 10.9          | 8.0           |
+--------------------+---------------+---------------+---------------+

**Alternative 3** would provide for a potential closure in the northern
and western Gulf of Mexico within the 10-30 fathom zone during January
through April of the year. This is a time period when limited shrimp
effort occurs in the Gulf of Mexico (Table 2.9). While this alternative
brackets potential closures between January 1 and April 30, it neither
provides a definite starting date nor indicates a specific ending date.
As in **Preferred Alternative 2**, the scope of potential closures could
include a limited number of statistical zones or cover the entire
northern and western Gulf. Assuming a complete four-month closure for
the entire area (Statistical Zones 10-21) would approximate a 10.4
percent reduction in effort in the 10-30 fathom zone where juvenile red
snapper are more abundant.

Biological impacts resulting from **Alternative 3** would be primarily
determined by the timing of the proposed closure. As noted in the
introductory discussion for **Action 7**, an area-season closure needs
to ensure the target species has the ability to disperse from the area
before the closure ends. In the case of a winter trimester closure, the
majority of the red snapper on the shrimp grounds at this time are
biologically age-0 (age 1 as of January 1 for stock assessment
purposes), and at a size less than 120 mm in length. A closure during
this period would reduce fishing mortality on these individuals, but the
fish would still be on the shrimp grounds when the closure ends, May 1.
Individuals off Texas would again be protected with the May 15 start of
the Texas Closure, but individuals off Alabama, Mississippi, and
Louisiana would be susceptible to potentially intensified fishing
effort, particularly concentrated off Louisiana during June (Table 2.8).

On the positive side, shrimp trawls have a distinct size selectivity.
Trawls are towed at approximately 3 knots; fish greater than 150 mm in
length can swim faster than 3 knots and have a greater opportunity to
successfully avoid the trawls. By June, when this effort shift to
Louisiana waters would occur, many of the fish would be approaching this
size. But, with an intensified trawling effort during May through July,
particularly off Louisiana, increased numbers of surviving juveniles
would be susceptible to capture.

**Alternative 4** would provide for a potential closure in the northern
and western Gulf of Mexico within the 10-30 fathom zone between October
and November. This is the time period when heavy shrimp activity occurs
in this region as brown shrimp complete their offshore migrations. As
with **Alternative 3**, **Alternative 4** does not specify starting and
ending dates but provides a set time interval for a potential closure.
Assuming the entire area was closed for the two-month period, it would
approximate an 18 percent reduction in shrimp trawl effort in the 10-30
fathom depth zone of the northern and western Gulf of Mexico. The
primary difference between **Preferred Alternative 2** and **Alternative
4** is the timing of the closure. The potential biological benefits of a
closure as with **Preferred Alternative 2 and Alternative 4** are
similar. **Preferred Alternative 2** focuses on the early phase of the
time period when Age 1 red snapper are emigrating off the shrimp
grounds, and attaining a size to avoid capture, whereas **Alternative
4** focuses on the late phase of the emigration period. Plus,
**Alternative 4** potentially would provide protection for the next age
class, which has begun to dominate the overall bycatch by this time.
However, the benefits of increasing the survival of age 0 fish during
the fall, while they remain on the shrimp grounds for another 9 months,
may not be substantial, primarily due to the high natural mortality rate
on age 0 fish.

Seasonal closures during peak shrimping periods, such as provided for
under **Preferred Alternative 2 and Alternative 4**, could cause some
relocation of effort by the shrimp fleet. Fishermen would not be allowed
to fish in the closed offshore waters, and some could opt for fishing in
shallower waters inshore of the closure area. Travel to areas offshore
of the closed area would be costly under current fuel prices.
Branstetter (1997) and NMFS (1998) have documented that finfish bycatch
levels are higher in nearshore waters (inshore of 10-15 fathoms) than
for offshore areas. Branstetter (1997) noted finfish to shrimp ratios
(in biomass) were 7.6:1 off Louisiana inshore of 10 fathoms compared to
3.3:1 offshore of 10 fathoms. Similarly, off Texas, finfish to shrimp
biomass ratios were 4:1 for waters inshore of 10 fathoms, and 3.3:1
offshore of 10 fathoms. Therefore, shifts in effort to nearshore waters
during a closure would increase the overall bycatch of finfish, assuming
there is no reduction in overall effort for the closure period. This
issue may be ameliorated to some extent in that many of the common
nearshore fishes can be excluded at relatively high rates from the use
of BRDs.

**Alternative 1** would not be expected to result in any direct adverse
economic and social impacts since no effort restrictions would be
imposed on the shrimp fishery. However, if status quo effort reductions
in the fishery are not sufficient to achieve target goals, continuation
of this alternative may result in more severe future restrictions,
resulting in potentially greater adverse economic impacts than the
adoption of effort restrictions at this time. Each of the alternatives
that could enact effort controls would be expected to result in greater
adverse economic impacts in the future relative to **Alternative 1**.
Among these alternatives, **Alternative 3** would be expected to result
in the least adverse economic impacts on the shrimp fishery, affecting
fewer vessels, fewer pounds of shrimp, and less shrimp revenues. Ranking
of **Preferred Alternative 2** and alternative **4** is less clear.
However, since **Preferred Alternative 2** would be expected to
potentially result in more firms exiting the industry than **Alternative
4**, the adverse economic impacts associated with **Preferred
Alternative 2** would be expected to exceed those of **Alternative 4**.
Longer term benefits derived from expected improvements to the red
snapper stock are expected to outweigh these adverse impacts.
**Preferred Alternative 2**, which is expected to have the largest
impact on red snapper mortality reduction, is expected to result in
greater long-term benefits. Greater positive impacts associated with
**Preferred Alternative 2** are attributable to the specified starting
date of a potential closure, which would coincide with the movement of
age 1 snapper from shrimp grounds to larger structures.

**Action 8. Establish a framework procedure to adjust shrimp fishing
effort in the northern and western Gulf of Mexico**

**Alternative 1. No action -- do not establish a framework.**

**Preferred Alternative 2. Establish a framework procedure to adjust the
effort target and closed season for the shrimp fishery in the Gulf of
Mexico within the scope of the preferred alternatives identified in
Actions 6 and 7.**

> **Option a. The SEFSC will provide an annual report to the Council on
> the previous year's assessment of shrimp effort for the 10- to
> 30-fathom area in the Gulf (statistical subzones 10-21). The Council
> may recommend the area and duration of a closure for the subsequent
> year.**
>
> **Preferred Option b. The SEFSC will conduct an annual assessment of
> the previous year's shrimp effort for the 10- to 30-fathom area in the
> Gulf (Statistical Subzones 10-21) and determine the area and duration
> of a closure and report this to the Regional Administrator for
> administrative action in the subsequent year.**
>
> **Option c. A shrimp effort assessment team of scientists, appointed
> by the Council, will provide an annual report to the Council on the
> previous year's assessment of shrimp effort for the 10- to 30-fathom
> area in the Gulf (statistical subzones 10-21). The Council may
> recommend the area and duration of a closure for the subsequent
> year.**

[Discussion:]{.underline} **Preferred Alternative 4** in **Action 6** in
combination with **Preferred Alternative 2** in **Actions 7** **and 8**
establish a target red snapper mortality reduction, as well as a
time/area closure and procedure that would provide managers with the
ability to address future changes in the shrimp fishery of the Gulf of
Mexico through potential closures in specified areas to reduce shrimping
effort and thus bycatch mortality on juvenile red snapper in a timely
manner. The purpose of such closures would be to maintain an effort
control on the shrimp fishery and thus maintain a level of bycatch
reduction that allows the red snapper stock to rebuild in compliance
with the rebuilding plan and end overfishing between 2009 and 2010.

The information regarding the level of effort for a given calendar year
would not be available for analysis until some time in the middle of the
following year. For example, information regarding 2007 would be
available during the end of the first semester in 2008. Thus, there
would be limited time to take effective action during 2008. Any action
would be implemented during the 2009 fishing year. In effect, future
actions will be in response to conditions experienced two years prior.
The SEFSC report, and its recommendations, should take this time lag
into consideration, given the current economic uncertainties surrounding
the shrimp fishery. It is difficult to determine what the current (2007)
status of the fishery is or what it will be in the near future; however
the number of participants and the associated effort and bycatch are
expected to continue to decline through at least 2012 due to economic
factors related to competition with imports and high operating expenses
(Travis and Griffin 2004). Should this decline be realized in subsequent
years, there may not be a need to establish additional closures as with
**Action 7, Preferred Alternative 2**. On the other hand, if the
preferred target of a 74 percent reduction in bycatch mortality from the
2001-2003 baseline average is not being achieved at the time that this
action is implemented or if in the future, the economic climate improves
or other factors cause an increase in effort such that the target is no
longer being achieved, **Preferred Alternative 2** provides a mechanism
for implementing closures based on the criteria established in **Action
7, Preferred Alternative 2**. Under **Option a or Preferred Option b**
of **Preferred Alternative 2**, the SEFSC would conduct analyses of
effort in Statistical Subzones 10-21 and develop an annual report of
effort and bycatch mortality relative to the target 74 percent
reduction. With **Option a**, the report would be provided to the
Council for its review and consideration of regulatory actions to
implement a closure conforming with the guidelines established by
**Action 7, Preferred Alternative 2**, if needed, in the following year.
**Preferred Option b** would assign authority to the RA of the SERO,
NMFS to determine the area and duration of a closure, if needed, for the
coming year within the guidelines established by **Action 7, Preferred
Alternative 2**. Under **Option c** the Council would appoint a Shrimp
Effort Assessment Team (SEAT) of scientists that would review the
SEFSC's analyses of effort and develop a report to the Council. The
Council in turn would review the SEAT report and determine the need for
and the location/duration of any closure in conformance with the
guidelines established by **Action 7, Preferred Alternative 2**.

If a closure is determined to be needed, **Preferred Option b** would
provide the most expedient means of implementation in that the SEFSC's
report would be submitted to the RA who in turn would implement the
closure through a similar procedure as has been used to implement the
Texas Closure in the past. **Option c** would provide the least
expedient means of implementing a closure in that the SEFSC's report
would have to be reviewed by the SEAT and then the Council before
regulatory action could be initiated. **Preferred Option b** would
provide a middle of the road approach with regard to the expediency of
implementing a closure.

**Alternative 1** would not establish a framework procedure to
potentially implement additional closures within the guidelines
established by **Action 7, Preferred Alternative 2**. Not establishing a
framework action would render the preferred alternatives in **Action 6**
and **Action 7** moot because there would be no other means of
implementing a closure other than a separate amendment, or an emergency
or interim rule action by the RA. This action could benefit the shrimp
fishermen in that they would be able to continue to shrimp without the
potential for further restrictions, at least in the short term. On the
other hand, if there is no framework procedure to quickly adjust effort
to meet the bycatch reduction target in the future, there may be a
higher mortality on juvenile red snapper, and it may be more difficult
to end overfishing and continue to rebuild the red snapper stock in
accordance with the established rebuilding plan. This would be
detrimental to the recreational and commercial red snapper fishery and
the people who depend on it since there may be a need for further
reduction on the directed red snapper fishermen. It could also impact
fishermen and fishing communities that depend on the shrimp fishery if
this lack of action results in the need for further reductions in the
future to reduce the amount of bycatch of juvenile red snapper.

**Action 8** is an administrative action. Hence, no direct short-term or
long-term adverse economic impacts would be expected to result from
either **Alternative 1** or **Preferred Alternative 2**. The adoption of
a framework procedure for addressing effort in the shrimp fishery would
generally be expected to facilitate faster corrective action, reducing
both the cost of action and pace at which benefits for the action would
be received. Thus, **Preferred Alternative 2** would be expected to
result in greater indirect economic benefits than **Alternative 1**.
Impacts to the administrative environment would occur as a result of the
SEFSC's analysis of effort and the development of the appropriate
reports to support the potential actions as contemplated by **Option a,
Preferred Option b, or Option c**. Economic and social impacts would
result from the determination of the area and duration of a closure, if
needed, based on the guidelines established by **Action 7, Preferred
Alternative 2** and would be evaluated in the appropriate analyses based
on the Council's choice of **Option a, Preferred Option b, or Option
c.**