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To the Florida Fish and Wildlife Conservation Commission,

Reef Relief continues to publicly oppose any type of harvest on the critically endangered Goliath Grouper. Goliath Groupers are a special sight to see while snorkeling. Their large presence complimented by their calm demeanor gives snorkelers and divers alike an experience to remember. When our younger coral camp participants snorkel with us, it is a very rare opportunity to see a goliath grouper, but when they do, their smiles and excitement is through the roof. Emotions aside, Goliath are an incredibly important species that deserves the protection it has been given since the 1990s.

Goliath groupers are experiencing several environmental and anthropogenic stresses that is preventing the population to fully recover from near extinction levels. According to the IUCN, juvenile goliaths spend the first 6 years of their lives in the mangrove forests until they are about a meter in length. These mangrove systems are a critical component for the initial life stage of these long-lived species but are disappearing at an alarming rate. According to FWC there has been a largest decline of mangrove ecosystems including 50% in the Tampa Bay, 60% in Charlotte Harbor, and 85% in Indian River Lagoon. According to the American Fisheries Society, the Florida Bay has experienced a 15% decline, 35% in the Ten Thousand Islands, 80% in Biscayne Bay, and 87% in Lake Worth. There simply aren’t enough habitat left for these fish to survive in.

Unfortunately, Goliath groupers are already being intentionally hunted and there has been several photo documented occasions of goliaths showing signs of injury caused by hooks and spear shafts. Goliaths are also a popular fish for catch and release. It is well known that the chance of mortality of any fish is heightened once released. Improper ventilation, exhaustion, predation, injury, pressure related issues such as “pop-eye” can cause mortality.

Even opening this limited hunt will lead to problems. The proposed slot size of 20”-36” are juveniles aged 1-5 which can only be found in the mangrove areas, which as discussed, are rapidly deteriorating. Highly reputable, REEF fish counts do not indicate a recovered population of this species nor do local reports and sightings match anecdotal data. Allowing 200 individual goliaths to be removed from the population will negatively affect the overall recovery of this species. It should also be noted that even juvenile goliath groupers have extraordinarily high tissue mercury concentrations, higher than any other grouper in the Western Atlantic and Gulf of Mexico (Malinowski et al., 2021).

The argument that the Goliath grouper is “eating all of our seafood” continues to be a false narrative. Using stable isotope analysis, scientists have found that Goliaths remain low on the food chain. Their diet focuses primarily on small crustaceans, other invertebrates, and even toadfish (Coleman and Koenig 2009). It is the unfortunate reality that humans are the ones causing the sharp decline in our marine resources, not goliath groupers. Goliath groupers are helping other fish populations as they have been documented to consume the invasive Indo-Pacific Lionfish (Mumby et al., 2011), a voracious species known for decimating populations of reef and juvenile fish.

We ask that you now consider the future of this population and the future divers and ocean enthusiasts for generations to come. As initially mentioned, these creatures are a beloved sight for all involved. Interactions with these gentle giants can give a snorkeler, adult or child, the experience of a lifetime and a story to share. We encourage the Florida Fish and Wildlife Conservation Commission to think of future generations in their actions and continue to protect not predate the endangered Goliath Grouper.

Sincerely,

Reef Relief

FWC will be meeting October 6th and 7th. Comments are due no later than October 1st at 5:00 PM EST.

To email your comments to all commissioners: https://myfwc.com/contact/fwc-office/senior-staff/commissioners/

For more information: https://myfwc.com/fishing/saltwater/rulemaking/saltwater-public-comments/?redirect=saltwatercomments