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To: Florida Fish and Wildlife Conservation Commission

Re: Reef Relief statement regarding the proposed Goliath Grouper rules

Reef Relief publicly opposes any type of harvest on the critically endangered Goliath grouper.

The Goliath grouper suffered a massive population decline and reach commercial extinction by the late 1980s, thus a U.S federal and state ban was placed in 1990. Because of this, Goliaths have begun to slowly recover their population and reestablish spawning aggregations. The current harvest proposal would allow for 100 permits (one fish per permit) issued via lottery system for a fee with a size limit between 47 and 67 inches, the size of a sexually mature Goliath grouper. This current proposal would effectively wipe out the majority of Florida’s breeding population, causing a detrimental long-term effect on the population. We believe this species is important for the overall health of the coral reef systems.

The current argument made by critics are that Goliath groupers are “overeating” and “responsible” for the decline of other marine species, popular among recreational fishing, such as spiny lobster, black grouper, and snapper. In a study by leading Goliath grouper researcher Dr. Chris Koenig using stable isotope analysis of stomach content, their diet was predominately small crab, shrimp, and smaller bottom dwelling fish. Dr. Sarah Frias-Torres has published data showing that overfishing is the cause of decline for these other species, not the Goliath grouper.

Goliath groupers are still facing other threats such as loss of habitat. Juveniles rely on mangroves as protection from predation. Since hurricane Irma we have experienced significant damage to this nursery extending from the Florida Keys through the Florida Everglades. Poor water quality is also harming the fish. Goliath groupers provide no nutritional value for human consumption due to containing unsafe levels of mercury according to the U.S Food and Drug Administration and the U.S Department of Health.

Goliath groupers hold a bigger monetary value alive than dead as divers from all over the world visit our state to view these animals in the wild. According to Dr. Sylvia Earle’s alliance Mission Blue, one spawning aggregation generates about half a million dollars a year for a single dive business.

The current argument to place a harvest on the Goliath grouper lacks any scientific credibility. Plus, the removal or reduction in the number of predators has been scientifically proven to be detrimental to a healthy coral reef ecosystem. Reef Relief stands with the scientists in support of keeping this fish protected.

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