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4 | 2/14/2012 10:57:02 | Van Hubbard | vanhubbard@captvan.com | on 3.1.2 Alt. 1 no action is ok. 2&3 eliminate most permit holders from Lee to Crtris Counties because we have not been allowed to sell kings but a few weeks every few years since 1986! alt 4 with 2009 control date eliminates most of us because we did get to fish and get some landings the Fall of 2010 because of oil spill in panhandle in 2010! 3.1.3 Spanish alt 1 no action because you have no moratorium on Spanish now!note our areas Spanish landings are soft because wenned to be able to also sell kings to sell enough to afford to fish! your management zones are so varried and inconsistant that it would be challenging to do any changes that are fair. already way to many problems with quotas and trip limits! consider some conformaty? please. 3.3 already limited number of permits No action required. action 5 A current rules are fine. b, cobia could be added to kingfish if you wnat to slow landings yet allow commercial fishermen to sell some. why eliminate income requirements and now? yes hardships need to be addressed! If someone is earning so much he can take time to fish let the needy fisherman have the few fish we can now sell! trip tickets can be considered but hard for some charter captains? 6. I understand Florida is considering a ban on gill nets in thiis state and most of gill netting is here I believe. this may remove your need for consideration? thank you all for your consideration and hard work. Captain Van Hubbard. Guide since 1976 and commercial fisherman since 1972. | Placida, Fl.33946 | Charter/Headboat For-Hire, Commercial Fisher | |||||||||||||||
5 | 3/23/2012 8:27:23 | Nicholas Patzig | pmsbigred1@yahoo.com | Action 1. no, their should be no action. Cobia already have management on them and no other regulations are required. Action 2. currently recreational king mackerel have been sold to prevent the waste of a resource when the customers leave on for-hire vessels. However the large problem is to the commercial fishers whos quota is charged with the catch when sold. A special saltwater products license for recreational vessels not selling those fish under a commercial fishing permit should not be counted against the commercial quota but should be counted against the recreational quota. furthermore federal commercial permits are currently required for king and spanish mackerel and their is no need for another permit for cobia. currently florida has a six per boat possession law for cobia both commercial sale and recreational catch this two could be adopted by the other coastal states. recreational tournament sales could be covered under the same salt water products license to cover the sales and take them off the recreational quota not the commercial quota. Action 3. the gill net sector should have been phased out by not allowing the transfer of those permits just as the fish traps are phased out. the condition of those fish caught are bad at best. the hook and line sector has a major problem that needs to be addressed. vessels that home port in other parts of the gulf and south atlantic have been allowed to fish in as many zones and subzones as they wish and catch that zones quota very quick not allowing the local fishermen who home port in that zone. If a zone regulatory is not eliminated then each vessels home zone quota should be the quota its fish are counted against not the zone that the vessel is encroaching in. i.e. if a vessel is home ported in key west and is fishing in the western zone the fish that boat catch and sold in louisiana will be counted against the west coast sub-zone so as to not penalize the local fishermen. but preferred alternative is to eliminate the zones all together that way no one will care if boats fish in your home waters and let the TAC fill but set the same trip limits at 500 lbs for all commercial vessels to prevent flooding the markets and driving down the ex-vessel price and wasting the resource to spoilage. Action 4. should be the more restrictive. as long as the more restrictive is 6 fish per boat commercial and recreational like florida law. Action 5. all income requirements should be eliminated. A fisherman needs the ability to sell what he catches. $5,000.00 in catch a year may not mean much to some people but it may mean a lot to that fisherman. And how else are you going to attract new participants when the old fishermen die or retire. they will need a way to start or they may have break downs or health issues. Action 6. Cast nets should be allowed but gill nets should be eliminated. | Fort Walton Beach, FL 32548 | Commercial Fisher | |||||||||||||||
6 | 4/9/2012 5:22:20 | Mason Bowen | fpfirelb@aol.com | I'm oppossed to the use of the 2009 control date proposed by Amendment 19 for different regions of the Gulf because, it would take My Right Away to access different areas of the King Mackeral fishery that I have been a part of all my life. Even though i live on the East Coast of Florida for six months of every year we are considered a gulf fishery. My King Mackeral permit wich i have held for years allows me to go where ever i need to provide a living for my family. The last couple of years that has included the pan handle. Do not talke My Right Away..!!! Sincerely, Mason Bowen | sebastian,fl 32958 | Commercial Fisher | |||||||||||||||
7 | 6/7/2013 8:04:03 | Ed Walker | Info@lighttacklecharters.com | My Name is Ed Walker. I am a king mackerel permit holder from Tarpon Springs, Fl. which is in the Eastern Gulf, northern Subzone. I am also on the CMP Advisory Panel. As you are likely aware fishermen from our area have been effectively shut out of the commercial king mackerel fishery for years. Our subzones quota is almost always filled before any fish migrate through our waters. This is due entirely to the start date of the season. Because of the season opening in July, commercial fishermen from the Western Zone are simply moving over the line into the northern fringes of our region immediately after they fill their zones quota, and smashing our entire zones tiny quota in a matter of weeks. The result is no participation for us year after year in our own waters. We desperately need your help. Our kingfish typically show up here in Mid-October and the quota is filled before that pretty much all the time. Because of this inequity in the sharing of the resource, we have had no opportunity to build catch history and by definition some might call our permits “latent”. A more accurate term for us would be “Forced Latency” as we are seldom open when there are fish here. IFQs based on catch history or elimination of “latent” permits would be extremely unfair to those of us essentially barred from participation year after year. What we are asking is the opportunity to fish in our own waters for some share of the quota that was intended to be allocated to us. There was support for moving the start date to October 1 at the AP meeting. It was voted on by stakeholders from across the Gulf and approved as the preferred option. Changing the staring date to October 1 would allow for more widespread participation across the entire region and a much longer season for everyone. The Council has been aware of our plight for several years and I believe that this is a solution to the problem faced by our beleaguered zone. Please consider adopting the APs preferred alternative to Action 2, in Amendment 19: Move the start date of the Eastern Northern Subzone to October 1. Thank you, Ed Walker 3219 Bluff Blvd, Holiday, Fl 34691 727-421-0346 ( I would welcome the opportunity to discuss this by phone) | Holiday, Fl 34691 | Private Recreational Angler, Charter/Headboat For-Hire, Commercial Fisher | |||||||||||||||
8 | 6/7/2013 9:49:19 | WAYNE THOMAS MARKHAM II | simplyhooked32@yahoo.com | Greetings, Captain Tom Markham here, I am a fisherman from Indian Rocks Beach, FL. I do not get to utilize the King Mackerel Fishery because my home region is always filled before the fish migrate into my local water. I am asking for your help. Kindly change the opening date of Eastern Northern Sub-zone to Oct 1st as recommended by CMP Advisory Panel (Amendment 19 action 2). Once you take action and change opening date to October 1st, it will be the answer with the share regions quota. Sincerely , Wayne Thomas Markham II 10833 Dorothy Lane Largo, FL. 33774 (727) 410 6094 Captain Tom Markham Simply Hooked FL. 8752LE | Largo, FL 33774 | Private Recreational Angler, Charter/Headboat For-Hire, Commercial Fisher, Other | |||||||||||||||
9 | 8/17/2013 10:40:32 | Nicholas Patzig | pmsbigred1@yahoo.com | Public comment and testimony on Amendments 19 and 20 coastal pelagics 6 Aug 2013. My name is Nicholas Patzig, I am CEO, CFO, COO and President of Patzig Marine Services Inc. I would like to thank the council for giving us an opportunity to address the fishermen's concerns. To begin I would like to give a bit of history. I started participation in th commercial King Mackerel fishery in 1966. For the next seven years all of the fish were sold mainly to restaurants as it was more lucrative to sell directly to the user than to a fish house, which served as a middle man, so the restaurants would pay a bit more to the fishermen and the restaurants knew they would be getting todays caught fish. I entered the U.S.Army in 1972 and was discharged in 1975 and served during the Vietnam conflict. I resumed my participation in the King Mackerel fishery in 1978 till present resulting in a combined 43 years also in that time I have performed (3) three studies for NOAA-NMFS. One Red Drum Stock Assessment, one Vermilion Snapper Discard Mortality study with video evidence and one Red Snapper Discard Mortality study with video evidence. I learned long ago that diversification is key and when one fisheries market is glutted and the ex-vessel price drops to an unacceptable level you don't keep catching at rock bottom prices you switch to another more rewarding fishery until the previous market becomes less glutted and the price comes back up. The Sustainable Fisheries Act was enacted while I was serving in the Army and the primary goal was to establish the 200 mile Exclusive Economic Zone (EEZ) due to encroachment of foreign vessels fishing in what the United States considered its waters. This is key because this is a similar situation we are now talking about. The Sustainable Fisheries Act has since morphed into a micro-management of all useable seafood and coral within 200 miles of the U.S. Governments jurisdictional waters and in some cases beyond if your vessel is U.S. flagged and fishing on the high seas. This has been, in several cases, to the detriment of the fishermen and the nations user groups. I recently read an article by AP in the local paper that said that only 9% of the nations seafood consumption came from the U.S. producers which if true means that 91% of the seafood consumed in this nation was from foreign nations. THAT IS ASTONISHING! CONCERNING AMMENDMENT 19 ACTION 1: Cobia permits should not be created because the largest percentage of Cobia are caught within 3 miles of the coast of Florida and if anyone should create a permit it should be Florida. Cobia come in cycles much like salmon a good migration every 3 or so years. If no spills disrupt their cycle, we have a really good year, much like this 2013 spring. This is when I fish for them commercially because although the King Mackerel are here also, due to the ever earlier closure of the northern gulf sub-zone, we must switch our effort. ACTION 2: If King and Spanish Mackerel and Cobia are caught and sold under a recreational bag limit and with a Florida SPL those fish sold should not be counted against the commercial quota. ACTION 3: Gillnet sector will eventually take care of itself. The quality of those fish are not good and sooner than later there won't be much of a market for those fish. In my opinion. Concerning participation in the King Masckerel hook and line sector, the only criteria should be years of participation not landings. Traveling boats is a relatively new sport. It started when IFQ's were being considered and this was an attempt for some boats to pad their landings to get a bigger piece of the pie. This would not be fair to the rest if the fishermen that are diversified and fish within their respective zones and don't take fish away from the resident fishermen if other zones. ACTION 4: Fishermen should only be required to follow the rule of the regulatory authority of the waters they a fishing in. ACTION 5: Income for Commercial permits should be from Commercial sales and not include charter income. This would insure commercial participation. ACTION 6: No Comment Concerning Ammendment 20 ACTION 1: If the council is not going to stop the traveling boats than there are only 1 of 3 changes that should be made. 1. All zones should be eliminated. The original 3 zones were created because it was thought that the fish from Louisiana did not come east of the mouth of the Mississippi river and thus there were two separate stocks of fish, east and west gulf and the Florida east coast had a mixing problem with the South Atlantic stocks. So there were 3 zones and 3 different TACs and three different trip limits until the Key West fishermen complained that the Gulf Eastern Zone, of which they were a part of, closed a few times before the fish showed up in the keys and the quota was caught and the zone was closed. So the Gulf Eastern Zone was divided, not equally, into 2 sub-zones, North and South and the Keys argued and received nearly 4 times the quota of the northern sub-zone 504,000 lbs to the south and 168,000 lbs to the north which changed the zones to an economic zone thus guaranteeing each zone that share of the TAC. The advent of the traveling boats, gaming the system for an IFQ advantage, caused the now encroachment of the economic zones and the loss of income to the resident boats. I've heard things like "you could travel too" and "we've been doing this for ever". Well they haven't been doing this forever and if the government had thought we could travel too then there would have been no need to create the sub-zones, they could have told the complaining key west boats they could travel also. That should be self-evident of the governments intent. Should the council insist on keeping the zones then each vessel, not permit because a vessel could buy another permit, should be required to pick a zone each year and not be allowed to game the system. Gaming the system should be reason for removal from the fishery. i.e. permitting by a family member and another permit or another entity or fleet with permits for each officer of the same entity, etc. 2. Another option is to eliminate all zones and go back to a Gulf wide quota including the Florida east coast zone and setting a reasonable 1250 lb trip limit to allow the fish to be used before they are wasted and keep the price up. This would make the traveling and residents alike and if the combined TAC is met and some areas don't get to fish then they will know how it is to not get to catch fish for 8 months of the year until the next fishing season the way it has been for the western zone and the northern sub-zone. 3. One other option is to link your vessels catch throughout the fishing year to your home ports zone i.e. where your residence and county your vessel is registered. This way the resident fishermen of the zone you may be fishing in at the time would not loose any of their quota to traveling fishermen. Again any gaming of the system would be cause for you to loose your fishing rights. | Fort Walton Beach, FL 32548 | Charter/Headboat For-Hire, Commercial Fisher | |||||||||||||||
10 | 8/18/2013 13:42:55 | Ira laks | Captainira@att.net | My name is Ira Laks. I am the owner operator of a dual permitted vessel. As an active participant in the King Mackerel commercial fishery, I believe we need a two-for-one permit reduction in the king mackerel commercial fishery and an annual average of at least 1,000 lbs of king mackerel from 2002-2011 to renew .If only one option is chosen I believe it should be the two-for-one option. I have heard council members say in meetings that they do not want to remove inactive permits, some council members said that they want fisherman to be able to use inactive permits as tools in their toolbox. The problem with that rational is that the councils have removed limited access permits from fisherman in other fisheries in the past due to inactivity and low landings. Myself and other active King Mackerel fisherman have had these permits removed from our toolboxes without any compensation. If it is now the position of the councils that fisherman should be able to retain inactive and limited landing king mackerel permits and these permits through sale or effort may become active to the detriment of current active king mackerel fisherman, the councils should reinstate any limited access permits removed from fishermen while holding their current king mackerel permit. How can you effectively manage the king mackerel fishery biologically,socially and economically if you have such a large variability in potential effort. Both the SAFMC and GMFMC have taken a leadership role in the ban of bag limit sales of federally managed species in the EEZ. The most important part of leadership is consistency and if bag limits of Cobia and tournament caught King and Spanish Mackerel are allowed to be sold it will be inconsistent with previous actions of the councils. I have listened to and read the minutes of council meetings as well as spoke to council staff in an attempt to understand why Cobia are excluded from the ban of bag limit sales. From the information I have read and heard, no practical or legal explanation have been sufficiently given for the sale of Cobia in the EEZ. As the holder of a Florida SPL with an RS endorsement, I could go on a recreational Headboat trip in the EEZ off the east coast of Florida and catch my bag limit of 2 Cobia and 2 King Mackerel. I would be able to sell my 2 Cobia to a whosale dealer but not my 2 King Mackerel, This would bring into play double counting issues in the Cobia fishery that I thought the councils were trying to avoid. Since a significant number of Cobia will be caught recreationally and sold commercially this should be addressed in the commercial allocation for Cobia. As to the sale of tournament caught fish, I think the councils should have to craft the guidelines for any tournament sales policy with alternatives and the ability of the citizens of United States to be able to comment on a specific tournament policy. In the draft amendment 19 book. North Carolina's tournament sales policy is used as an example. This is from the NCDENR Division of Marine Fisheries: Recreational Fishing Tournament License to Sell Fish The Recreational Fishing Tournament License to Sell Fish is a license available to fishing tournaments that sell fish and requires the designation of a tournament organizer. Proceeds from the sale of fish must be used for charitable, religious, educational, civic or conservation purposes - proceeds from the sale of fish cannot be used to pay for tournament expenses. This license is required for tournaments that sell fish plates or provide free fish plates to tournament participants. King and Spanish mackerel in the EEZ are a public trust resource of all the citizens of the United States. If the states are given the authority to convert a federal public resource into cash to benefit a select few, it will raise many ethical and legal objections. A few questions I have are: How many tournaments will be allowed to sell fish? Many fisherman pre fish the day before the tournament, will those fish be able to be sold? How many fish per boat will be able to be donated? Will it be just the fish weighed in or the bag limit for all on board? If its the bag limit for all onboard that can be donated, will that cause boats to catch more fish than they normally do in a desire to be charitable? Will organizations such as the SKA be able to take a charitable tax deduction on the cash donated to a charity? If so that would be of great financial benefit to them. Can wholesale dealers profit from the sale of these fish and who will decide which wholesale dealer is used? If the choice of wholesale dealers is left to the tournaments, it opens the door for quid pro quo relationships. If the number of tournaments who sell fish expand how will this effect the price commercial fisherman receive for their fish? How ironic would it be if money from the sale of tournament fish was donated to a conservation organization and they used that money to lobby to restrict commercial fishing. Can the town of Boca Raton hold a tournament and use the money from the sale of a federal public resource to build a dog park? Will religious groups be able to capitalize from this public resource to promote their beliefs? Sincerely , Captain Ira Laks | Jupiter fl 33478 | Charter/Headboat For-Hire, Commercial Fisher | |||||||||||||||
11 | 8/19/2013 13:28:01 | Charles Veach | Chipkw@hotmail.com | I am a commercial fisherman that catches King Mackerel in the Eastern zone, Southern Subzone. I believe the daily trip limit should remain at 1250 lbs. I live in Key West and I have tailored my business to fish for many species but Kingfish is the most important. Since I have put Kingfish as my number one target fish I have missed out on other opportunities. I lost my marine life license and received virtually no grouper quota. This is why keeping things status quo is so important to me. The prices of Kingfish have risen lately, especially towards the end of Lent. I feel that if the trip limit is raised to 3000 lbs. the season would close before the prices rise and make fishing truly profitable. Other fishermen believe that catching 3000 lbs would make the trips more profitable, this is not the case if prices are low. The 3000lb limit would also bring "trip" fish into the equation, thus flooding the market with poor quality fish. To me raising the limit would create a vicious cycle. If the limit was 3000 lbs more boats would come and fill the quota very quickly. Once closed, I would have to travel from my home and fish another areas quota and that would not be very profitable. Please leave the limit at 1250 lbs so I can stay at home with my family and fish the way that I have for the last 28 years. | Key West, FL 33040 | Charter/Headboat For-Hire, Commercial Fisher | |||||||||||||||
12 | 8/20/2013 15:10:10 | robert quinn | oceanexplorerbelmar@hotmail.com | I am a commercial fisherman that catches King Mackerel in the Eastern zone, Southern Subzone. I believe the daily trip limit should remain at 1250 lbs. I live in Key West and I have tailored my business to fish for many species but Kingfish is the most important. Since I have put Kingfish as my number one target fish I have missed out on other opportunities. I lost my marine life license and received virtually no grouper quota. This is why keeping things status quo is so important to me. The prices of Kingfish have risen lately, especially towards the end of Lent. I feel that if the trip limit is raised to 3000 lbs. the season would close before the prices rise and make fishing truly profitable. Other fishermen believe that catching 3000 lbs would make the trips more profitable, this is not the case if prices are low. The 3000lb limit would also bring "trip" fish into the equation, thus flooding the market with poor quality fish. To me raising the limit would create a vicious cycle. If the limit was 3000 lbs more boats would come and fill the quota very quickly. Once closed, I would have to travel from my home and fish another areas quota and that would not be very profitable. Please leave the limit at 1250 lbs so I can stay at home with my family and fish the way that I have for the last 28 years. | key west florida 33040 | Commercial Fisher | |||||||||||||||
13 | 10/28/2013 11:51:45 | Ira laks | Captainira@att.net | October 21, 2013 Gulf Of Mexico Fishery Management Council Having listened to the Mackerel committee and their report given to full council at your last meeting in August. I believe the councils preferred alternatives in amendment 20 A will cause direct economic harm to commercial Mackerel fishermen and for hire vessels that do not hold federal commercial Mackerel permits. My interpretation of main reasoning given by council members for preferred alternatives choices in action 1 is the 2% or 3% of the recreational quota was given to the commercial quota. After Speaking with council staff I was informed that it is 2% that was allocated. Since the council now knows the exact number of pounds that is set aside for bag limit sales. I believe it is incumbent on the council to provide accountability measures to assure that any significant overage of that 2% does not cause reduction in market price and commercial quotas to be reached much earlier then they would be without bag limit sales. The 2013 commercial king Mackerel quota for the northern Florida west coast sub-zone is 178,848 pounds. This sub-zone is located east of the Alabama /Florida state line and along Florida's west coast to the Lee/Collier county line. This area is over 650 miles of coastline that includes the highly populated Tampa metro area. 2% of 178,848 pounds of King Mackerel is 3,577 pounds. These are the specific number of King Mackerel per size class. 357 fish at 10 pounds per fish 178 fish at 20 pounds per fish 119 fish at 30 pounds per fish 90 fish at 40 pounds per fish 71 Fish at 50 pounds per fish One or two large fishing tournaments can easily sell the 3,577 pounds of king Mackerel allocated, not to mention the additional fish that will be sold from for hire trips in such a large area. I hope these numbers help illustrate the potential economic harm to commercial fisherman. If the council requires a vessel to hold federal commercial King Mackerel permit to sell bag limits on a for-hire trip and those fish are counted on the commercial quota. One could argue that those for-hire trips are actually a commercial trip with a trip limit of two per person. It can also be argued that the language of the preferred alternative would allow any passenger on those vessels with the appropriate state commercial licenses to be able to sell their bag limit. Permits are issued to vessels not people. In states were recreational fish sales are not allowed this would be particularly troublesome, because these fish would be harvested on vessel with a required commercial permit in order to be sold and therefor should be considered commercial harvested and allowed to be sold with appropriate state licenses. As the holder of a Florida Individual Crew Salt Water Products License with a Restricted Species Endorsement which covers all occupants on board of a commercially registered vessel, I could charter a vessel with a commercial King Mackerel permit and sell two King Mackerel for each passenger aboard. As to the sale of tournament caught fish, I think the councils should have to craft the guidelines for any tournament sales policy with alternatives and the ability of the citizens of United States to be able to comment on a specific tournament policy. In the draft amendment 19 book. North Carolina's tournament sales policy is used as an example. This is from the NCDENR Division of Marine Fisheries: Recreational Fishing Tournament License to Sell Fish The Recreational Fishing Tournament License to Sell Fish is a license available to fishing tournaments that sell fish and requires the designation of a tournament organizer. Proceeds from the sale of fish must be used for charitable, religious, educational, civic or conservation purposes - proceeds from the sale of fish cannot be used to pay for tournament expenses. This license is required for tournaments that sell fish plates or provide free fish plates to tournament participants. King and Spanish mackerel in the EEZ are a public trust resource of all the citizens of the United States. If the states are given the authority to convert a federal public resource into cash to benefit a select few, it will raise many ethical and legal objections. A few questions I have are: How many tournaments will be allowed to sell fish? Many fisherman pre fish the day before the tournament, will those fish be able to be sold? How many fish per boat will be able to be donated? Will it be just the fish weighed in or the bag limit for all on board? If its the bag limit for all onboard that can be donated, will that cause boats to catch more fish than they normally do in a desire to be charitable? Will organizations such as the SKA be able to take a charitable tax deduction on the cash donated to a charity? If so that would be of great financial benefit to them. Can wholesale dealers profit from the sale of these fish and who will decide which wholesale dealer is used? If the choice of wholesale dealers is left to the tournaments, it opens the door for quid pro quo relationships. If the number of tournaments who sell fish expand how will this effect the price commercial fisherman receive for their fish? How ironic would it be if money from the sale of tournament fish was donated to a conservation organization and they used that money to lobby to restrict commercial fishing. Can the town of Boca Raton hold a tournament and use the money from the sale of a federal public resource to build a dog park? Will religious groups be able to capitalize from this public resource to promote their beliefs? Sincerely yours, Ira laks captainira@att.net | Florida | Charter/Headboat For-Hire, Commercial Fisher, Other | |||||||||||||||
14 | 11/19/2013 5:20:40 | DG | drg@ufl.edu | test | Other | ||||||||||||||||
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