Dear Flagler Sportfishing Club Members,
This is the statement which I gave at the Red Snapper Hearing for Amendment 59.
The amendment proposed by NOAA and NMFS is severely out of touch with the
realities on the ground. The science behind this proposal is flawed, and the agency has
not taken into account the feedback from anglers and divers who are directly affected by
the proposed closures. Reducing the American Red Snapper (ARS) fishing season to a
single day created serious safety concerns on the water, as highlighted by both the
Florida Fish and Wildlife Commission (FWC) and the U.S. Coast Guard (USCG). This
decision placed more strain on the Red Snapper population in a single day than a more
reasonable season and bag limit would. Similar to the existing FWC grouper/snapper
season. Gulf Coast regions from Texas to Florida have long contested these measures
and have proven their approach to be correct, resulting in extended seasons and
increased allowable catch.
The proposed amendment cites “dead discards” as the primary cause of overfishing,
referring to SEADR 41 (2017).
nder Amendment 59, Preferred Alternative 2, you propose a total of 71,000 landed ARS
with 438,000 dead discards, which amounts to only about 14% of the annual catch limit
(ACL) of 509,000 acceptable biological catch (ABC). After 2028, this would rise to
76,000 ACL landed fish and 475,000 dead discards, again constituting just 14% of the
551,000 ABC. Does this math make sense? Why are dead discards being allowed at
such a disproportionate rate compared to the landed catch? It simply doesn’t add up.
You claim that ARS is overfished, yet many anglers report that it is nearly impossible to
fish the bottom due to the abundance of Red Snapper. This suggests that the ARS is
one of the easiest fish to catch. Could this be due to overfishing, or is it because ARS
are so numerous they dominate the ocean floor? Divers have even reported that ARS
are so plentiful on wrecks that they are displacing other fish species. This shift in the
balance of the ecosystem could, if left unchecked, wreak havoc on the
Snapper/Grouper fishery.
In Northeast Florida, there was once a time when catching an ARS was a challenge.
Now, from Daytona to the Florida state line, you can catch them within three miles of
shore. With FWC’s year-round limit of two fish per day greater than 20 inches, one must
ask: are these fish counted in your acceptable biological catch? Additionally, why are
there such differing views on stock assessments for this species?
Since 2017, the recreational fishing season has been steadily reduced from nine days
to just one day in 2024, while commercial seasons have ranged from 70 to 40 days over
The past five years. With a recreational bag limit of just one fish and a 75-pound
commercial trip limit, one must question whether this decline in fishing opportunities
proves overfishing—or whether it actually points to an abundance of ARS. This
amendment does not reflect the realities of the fishery and needs to be reconsidered
with a more balanced and evidence-based approach.
In conclusion, the proposed amendment by NOAA and NMFS not only disregards the
input of local anglers and divers but also fails to reflect the reality of the ARS population
The math and assumptions behind the proposal raise serious concerns, particularly
regarding the disproportionate number of dead discards allowed compared to the
landed catch. The abundant ARS population, as reported by those directly interacting
with the fishery, suggests that overfishing is not the root cause of the current
challenges. Instead, a more balanced and scientifically accurate approach is needed,
one that considers the real-world experiences of the fishing community and the health of
the species. Until such an approach is adopted, this amendment will continue to miss
the mark, putting both the fishery and its stakeholders at risk. It is time to revisit the
management strategy to ensure sustainability, safety, and fairness for all involved.
Remember the fishing lies start here.
Capt. Mike Vickers Jr.
President
Flagler Sportfishing Club