Open Letter to the Florida Fish and Wildlife Conservation Commission (FWC)

July 3, 2017

FWC Commissioners and staff,

I urge FWC to continue the protection of Goliath Grouper and reject the limited take proposal.

Recently, an email from FWC staff on the potential killing of the critically endangered Goliath Grouper confirmed that FWC’s decisions to kill endangered species are not based on science. E-mails to and from FWC and NOAA are public record, so the message and email addresses are shown below accordingly.

FL unscientific letter
There are three key problems with this email.

First, the science denial is stated by the Director of FWC’s Fish and Wildlife Research Institute (FWRI). The FWRI mission statement is “Through effective research and technical knowledge, we provide timely information and guidance to protect, conserve, and manage Florida’s fish and wildlife resources.” The FWRI Director is a scientist who denies science.

Second, the decision to kill or not to kill (harvest) a critically endangered species currently protected (Goliath Grouper) IS a scientific question. Only scientific research can determine whether a species that previously reached commercial extinction has recovered to the point that it can be killed again without bringing the species back into the danger zone. Therefore, prior to even proposing the harvest, a solid scientific argument must be made based on evidence. If the science does not support the harvest, then the proposal to kill should not even exist.

Third, it seems FWC staff has a short memory span, or perhaps information gets lost in an alternate universe. For years, scientists doing research on Goliath Grouper have shared the information with FWC staff (FWC scientists and commissioners), attended workshops, meetings and been available for discussions. All this research shows Goliath Groupers are highly conservation dependent, and cannot withstand exploitation.

On a positive note, FWC disregard for scientific research is finally out in the open. This is not an isolated action. FWC lost all credibility when the Florida black bear hunt was approved in 2015, resulting in the killing of 298 bears in just two days of hunting. The bear hunt was not supported by scientific evidence  and included the killing of bear cubs and mother bears still nursing cubs

It is clear that FWC folded to the pressure of trophy hunting groups, ignoring the best available science. In order to please a handful of people, you cheated all Floridians because wildlife is part of our country’s heritage and ill-planned and unjustified hunts risk the loss of such heritage. The bear hunters must be so proud of killing bear cubs and nursing mothers and FWC was the enabler of such wildlife crime.

Now, you have the critically endangered Goliath Groupers in your crosshairs. The “limited take” proposal under review is not so limited. Basically you would allow, over a 4 year period, the killing of most of the breeding population in Florida for up to 400 breeders 

Every few years, FWC proposes to open a killing season for Goliath Groupers: in 2007, 2009, 2011, 2014 and now 2017. All past proposals were finally rejected in view of the scientific evidence and stakeholder opposition. But this time is different. This time, FWC is openly ignoring science right from the start.

Who is pressuring you for such ill-planned management of an endangered species?

I bet it’s the trophy fishing lobby. They must be itching to kill a magnificent fish, just to take a picture of the dead beast and let it rot in the sun. Because Goliath Groupers have such high levels of methyl mercury they are unsafe for human consumption. You must feel so proud to be enablers again of a new wildlife crime.

But here is the beauty of reality. You can’t block the sun with one finger. You can’t ignore the scientific evidence confirming that Goliath Groupers have not recovered to pre-exploitation levels, and cannot handle fishing pressure without entering again in a spiral towards extinction. For some unknown reason, FWC continues to believe the zombie myth (because it never dies) that Goliath Groupers eat everything in the reef, so they are blamed for decreasing fish and lobster stocks. The reality is that overfishing, not Goliath Groupers, is the reason for the declines. The scientific research is in your files. Read it. Stop denying science.

Finally, to give your ill-inspired killing proposal some degree of fairness, you have organized a series of Goliath Grouper Workshops so people can provide “input on goliath grouper management, including the possibility of a limited harvest in Florida state waters”. The long list of public workshops gives the appearance of a balanced survey design to get people’s input

But when the workshop locations are plotted on a map it seems your workshop strategy is biased. Because the people who will be most negatively affected by opening a harvest on Goliath Groupers, are the people who will have the least opportunities to provide face-to-face input.


Pins-FL Map FWC Workshops

Only 20 % of the workshops (Lake Worth, Stuart and Davie) can be realistically attended by the SCUBA dive businesses that rely heavily on recreational SCUBA divers who pay big money to see the Goliath Grouper spawning aggregations in East Florida between late August and early October, just when transition between the summer and winter seasons will leave these businesses in the doldrums. Will the comments collected in the workshops have the same weight that the comments collected online?

To summarize, Goliath Groupers are worth more alive than dead


Opening a fishing season (the “limited take”) will end 27 years of protection in only 4 years. In order to please trophy fishers, you risk cheating all Americans of our national treasure, because nowhere else in the world you can encounter a functional population of Goliath Groupers as in Florida. The take is not supported by scientific research. Do the right thing and stop this madness. Reject the limited take, and continue the ban on Goliath Grouper harvest.