Reef Fish Amendment 42 (Responses)
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10/2/15Chad HansonOtherOn behalf of The Pew Charitable Trusts (Pew), please accept these comments on management and accountability of key fisheries in the Gulf of Mexico. It’s important to maintain the conservation and legal requirements of the Magnuson-Stevens Fishery Conservation and Management Act (MSA) while providing sufficient access to fishing and the ability to operate stable businesses. At the October 2015 meeting, the Council has the opportunity to create management systems suitable to the needs of the red snapper recreational fishery while promoting conservation of the resource. Additionally, important decisions are needed to complete the for-hire electronic reporting requirements and monitoring program. Lastly, it is imperative that the Council set the stage for recovery of gag and gray triggerfish – two of the most important and popular species in the Gulf of Mexico. The main points on these specific issues are summarized below, followed by additional details.

• We encourage moving forward on the electronic reporting amendment for the for-hire fleet, in conjunction with Amendments 41 and 42. However, some key issues remain to be addressed on the electronic logbook amendment, which we detail below.

The Council’s proposed electronic logbook (ELB) program for the Gulf’s for-hire fleet will complement Amendments 41 and 42, which are aimed at providing maximum flexibility and also accountability for the for-hire fleet. Similarly, data collection programs under development at the state level should support regional management of the private recreational fishery. Amendment 39 offers more flexible management for the private recreational fishery, while maintaining accountability by ensuring the conservation requirements of the MSA remain in place and taking advantage of these state-based data collection programs. Therefore, to best promote conservation, accountability, and flexibility for both recreational components of the red snapper fishery, we strongly urge the Council to remove the federal for-hire vessels from the regional management plan by adopting Alternative 2 in Action 2 of Amendment 39 as the preferred alternative. Also, working with the industry participants, we encourage the Council to continue developing Amendments 41 and 42 in conjunction with the ELB amendment.

Implementing Electronic Logbooks for the For-Hire Fishery

We are pleased with the progress made to date on developing an electronic reporting and monitoring program for federally permitted for-hire vessels in the Gulf of Mexico. Based on our observations and communications, industry leaders and participants strongly support ELB. We support the Council’s preferred actions in the electronic reporting amendment on trip level reporting and using “NMFS-approved electronic devices” to track fishing effort and location. To achieve implementation in 2017, the Council must address several key issues.

At the August 2015 meeting, the Council approved a motion that addressed many of these issues and asked the technical subcommittee for details of the program. Hopefully, this process is well under way. However, to facilitate moving this amendment forward, the Council should discuss and resolve the issues listed below at the October meeting:

1. Specify how data at the trip level for charter and headboats is to be used to determine whether catch estimates for federally managed species should be produced daily, weekly, or within some other time frame.

2. Specify what “NMFS approved hardware and software” will be allowed and used in the ELB program.

3. Specify what “NMFS approved electronic devices” are to be allowed and used in the
ELB program.

4. Determine what agency or entity will be the lead on designing and implementing the program and the intended use of the data.

5. After resolving the above issues, develop detailed cost estimates and resource needs for implementing the ELB program in the Gulf.

6. Determine potential available funding sources according to program needs.

Addressing these issues should be instructive for development of the ELB program and beneficial to the technical subcommittee as they develop the data protocols and standards reference document. These are also questions that are likely to be asked by the fishermen who would be subject to any new requirements.

While developing the ELB amendment, it’s important to recall the importance and benefits of an electronic monitoring and reporting program. A well-designed ELB program coupled with management strategies such as those under development in Amendments 41 and 42 can provide maximum flexibility and accountability. It can also improve data used for catch monitoring and stock assessments for all federally managed species caught by the federal for-hire fleet, not just red snapper. Specifically, the data obtained through the ELB program offers many benefits that will:

• Improve catch monitoring, which should also reduce the uncertainty regarding retained and discarded catch in stock assessments.

• Allow for responsive in-season management.

• Lead to stability in the for-hire fleet in conjunction with properly designed management plans.

• Increase user confidence in the data and management.

A successfully designed program requires balancing the tradeoffs of data needs with associated costs and constraints. Additionally, industry support and compliance is crucial for a successful program. Therefore, it is imperative that the details of the program be addressed and documented as soon as possible and that the Council sends a strong message to the for-hire industry by showing full support for development and expedient adoption of the ELB amendment.

Thank you for considering these comments. We look forward to continuing to work with the
Council and stakeholders on these and other important issues.
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10/4/15Eric Brazerinfo@shareholdersalliance.orgGalveston, TXOn behalf of the Gulf of Mexico Reef Fish Shareholders’ Alliance (Shareholders’ Alliance), please accept the following comments on the following issues to be discussed at the Gulf of Mexico Fishery Management Council (Gulf Council) meeting in Galveston, Texas this week.

Reef Fish Amendment 41 and 42
• We support moving forward with Amendment 41 and 42 to develop charter/for-hire and headboat red snapper and reef fish management plans. Doing so will afford these groups the opportunity to develop accountable management plans that work for their businesses and promote sustainable harvesting.

Thank you for the opportunity to comment.
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10/7/15Shane Cantrell
shane.Cantrell@iCloud.com
Galveston, TXCharter/Headboat For-HireWe, the Charter Fisherman's Association, thanks the Gulf Council for joining our fishermen in Galveston and hope everyone has enjoyed their time in the great state of Texas. We appreciate many of you joining us at the Fishermen's Social with the Lighthouse Charity Team as well.

Our organization represents federally permitted charter captains and their customers across the Gulf of Mexico as well as across the country. We are the largest organization of federally permitted vessels in the region and have the following recommendations for the Council's consideration:

Amendments 41 and Amendment 42
We look forward to working with the council in January with the feedback from scoping meetings over the next few weeks to continue developing those Amendments respectfully with the council.
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10/20/2015 8:31:27William PenningtonWBRP@Comcast.netCollinsville, Ms 39325Private Recreational AnglerPrivate recreational fisherman have a lot invested to be left out. This seems to bean attempt to divide recreational fishermen so the commercials & charters win and individual rec fishers are almost left out. It isn't right for the commercial guys to have over half the harvest. If I had my way commercial fishing would be left out all together. They are the ones depleting the stocks.
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10/20/2015 9:07:35David Waltersdavid@rives.comMt. Brook, Al 35243Private Recreational AnglerVote "NO".
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10/20/2015 9:36:41Sam BowenBbowen@bnspc.comGulf Shores,AL,36542Private Recreational Angler42 should be rejected. Just another way the for hire an commercial fishermen can screw over recreational fisherman. The only fish you can catch on any reef now is red snapper. They are horribly over populated, yet I only have 2 days I can legally catch them because I have to work during the week. I have stopped reef fishing because there is nothing but red snapper present and I am tired of wasting gas to throw back snapper. Just give us more weekend days and longer season. No reason I should not be able to keep a couple of snapper to feed the family. I have two young boys as well who love to fish, but will not go with me anymore because they say not worth it if we can't keep them anymore.
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10/20/2015 16:31:27stephen bowensrbowen@mysylacauga.comequality, AL 36026Private Recreational AnglerPlease do not further restrict individual sport fishing further.
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10/22/2015 18:32:47Capt Cliff CoxSweetjodyfishing@gmail.comDestin, Florida, 32540Charter/Headboat For-HireI am in favor of Amendment 42. I am on the headboat advisory panel and also participating in a very successful pilot program which has been used as reference to model a fmp for the headboats. Individual Fish Quotas are the way of the future if we want to stop overfishing and properly manage the resource. It works!
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1/14/16Chad HansonOtherOn behalf of The Pew Charitable Trusts (Pew), please accept these comments on management and accountability of recreational fisheries in the Gulf of Mexico. It is important to maintain the conservation and legal requirements of the Magnuson-Stevens Fishery Conservation and Management Act (MSA) while providing sufficient access to fishing and the ability to operate stable businesses. At the January 2016 meeting, the Gulf Council can take significant steps to implement data collection and management systems that have the potential to more effectively meet the needs of stakeholders, while promoting sound conservation of the resource. With that in mind, we urge the Council to:

• Continue to move forward with Amendments 41 and 42 to establish new management programs for the for-hire fleets that have the potential to improve accountability, reduce discards1, and provide more stability to these businesses.

We further encourage the Council to continue developing Amendment 41 for charter vessels and Amendment 42 for headboats with industry input and support. Implementing strategies for the separate components of the recreational fishery has the potential to more effectively maintain catch within sustainable limits for each component; better align fishing opportunities to the needs of each sector; reduce the 20% accountability buffer for each facet; and ultimately, keep the red snapper rebuilding plan on track.

Approve Electronic Logbooks for the For-Hire Fishery

We support approval of the generic plan amendment modifying charter and headboat reporting requirements with all of the current preferred alternatives. This action would require all federally permitted for-hire vessels to submit trip and catch information electronically prior to returning to the dock. “Trip level” reporting offers the most accurate and timely application of electronic logbooks, as it reduces “recall bias”2 and provides for a strong validation component of the data program. Law enforcement officers and biological samplers can effectively check the electronic logbook data for each trip to ensure accuracy. A well-designed electronic logbook program, coupled with management strategies under development in Amendments 41 and 42, can provide maximum flexibility and accountability. It can also improve data used for catch monitoring and stock assessments for all federally managed species caught by charter vessels and headboats, not just red snapper. Specifically, the data obtained through the electronic reporting program may:

• Improve catch monitoring, which should also reduce the uncertainty regarding retained and discarded fish in stock assessments.

• Allow for responsive in-season management.

• Lead to stability in the for-hire fleet in conjunction with properly designed management plans offered in Amendments 41 and 42.
Increase user confidence in the data and management.

However, many practical details remain undefined. We urge the council and staff to continue working with NOAA Fisheries staff and other technical experts, as well as representatives from the for-hire industry and other stakeholders, to develop data elements and protocols that will ensure this system works well to monitor and manage the for-hire fishery.

Conclusion

We urge the Council to remove the charter for-hire sector from Amendment 39 before taking final action, and to continue developing Amendments 41 and 42. In addition, we encourage adoption of the generic plan amendment requiring electronic logbook reporting for the for-hire industry with the current preferred alternatives. Thank you for considering these comments. We look forward to continuing to work with the Council and stakeholders on these and other important issues.
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1/24/16Eric Brazerinfo@shareholdersalliance.orgGalveston, TXOtherOn behalf of the Gulf of Mexico Reef Fish Shareholders’ Alliance (Shareholders’ Alliance), please accept the following comments on the following issues to be discussed at the Gulf of Mexico Fishery Management Council (Gulf Council) meeting in Orange Beach, Alabama this week.

Reef Fish Amendments 41 and 42.
• We support the Gulf Council continuing to move forward with Amendment 41 and 42 to develop charter/for-hire and headboat red snapper and reef fish management plans. Doing so will afford these groups the opportunity to develop accountable management plans that work for their businesses and promote sustainable harvesting.
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1/25/16Randy & Susan BoggsCharter/Headboat For-HireWe are encouraged with the Council’s development of Amendment 42 to the Reef Fish FMP, which would implement a new approach for managing headboat fishing in the Gulf of Mexico. As participants in the Gulf Headboat Collaborative pilot program, we saw first hand that there is a better way to manage headboats that improves economic stability, reduces discards, and increases access for recreational anglers. We want to realize these benefits going forward and urge the Council to move forward on Amendment 42 as expeditiously as possible.

After reviewing the January 2016 draft of Amendment 42, we have a number of suggestions based on our experience managing and fishing in the Gulf Headboat Collaborative and our long history as headboat operators reporting to the Southeast Region Headboat Survey (“SRHS”).

Program Structure and Transferability of Quota Shares

We support individualized allocations instead of a cooperative structure for Amendment 42. While a cooperative structure worked for the Gulf Headboat Collaborative pilot program, managing it took extensive time and resources and extending that structure to the rest of the headboat fleet may not be feasible. Individualized allocations would achieve the same benefits but with more efficiency and without the need for cooperative management. Looking ahead, nothing would prevent individual headboat operators from pooling individual allocations and forming cooperatives of their own, if that is how they want to operate.

To maximize flexibility and efficiency, quota shares and annual allocation should be fully divisible (disconnected from the vessel permit and able to be transferred in any quantity) and transferable within the universe of vessels currently participating in the SRHS.

Currently there are 68 vessels with federal for-hire permits that participate in the SRHS. Going forward, at least for some initial period of time after implementation of Amendment 42, holding one of those 68 permits should be required to participate in the Amendment 42 headboat fishery, to hold headboat quota shares, and to utilize headboat annual allocation. The 68 SRHS vessel permits would continue to be freely transferable, however, so that any new entrant could acquire one of those permits to engage in the headboat fishery and, once acquired, could accumulate quota shares or annual allocation from one of the other permit holders. Continuing to report to the SRHS should be a requirement for holding one of the 68 SRHS permits.

The Council could decide in the future whether to continue this structure or to broaden transferability options. At least for the first few years of the program, however, an incremental approach that limits the program to the current universe of permits tied to vessels that report to SRHS is preferable. This will minimize disruption while operators gain experience with the new system.

Quota transferability provides a number of benefits. By being able to acquire a desired quantity of quota shares, headboat operators can better plan their future operations and increase business stability. A permit holder wishing to buy or sell shares will have more operational flexibility if the shares are divisible without having to buy or sell all of them in a single lot along with a permit. This is why we strongly reject the permit fishing quota alternative.

As for annual allocations, if a vessel breaks down or an operator will not be able to utilize its allocation for some other reason, transferability helps ensure that allocation is not wasted but can be used to take anglers fishing. Our experience with the Gulf Headboat Collaborative pilot program showed us how transferability can keep headboats fishing year-round. Transferability also helps prevent overages and reduce discards. A major purpose of this type of program is to increase stability for headboat operators. In turn, this benefits their recreational angler customers and means fewer fish are wasted. These goals are best achieved without tying operators’ hands through cumbersome restrictions on transferability of shares and allocation. The Council could enact measures to ensure that operators do not acquire an excessive share.

The program structure and transferability rules described above could be added into the document for consideration with minor revisions to Action B2 (Transferability of Shares) and corresponding additions to other sections. Specifically, we recommend adding a new alternative to Action B2 that would require a SRHS vessel permit (i.e., one of the reef fish charter/headboat permits tied to a vessel that currently reports to SRHS) to receive shares through transfer.

Initial Allocations

Because SRHS vessels have such good historical landings data, we support basing an initial allocation on catch history over some period of time. However, the range of allocation alternatives currently in the draft document would only consider catch history going back to
2011. Section 303a(c)(5) of the MSA requires that allocations consider both current and historical harvests. Thus, to ensure that the Council is considering an appropriate range of alternatives, we suggest adding alternatives that would also consider allocations based (in some part) on earlier years. For example, in Amendment 40 the Council considered landings going back to 1986, and ultimately selected an alternative that factored in those historical landings but that also placed greater weight on more recent landings. Amendment 42 should contain a similar range of allocation alternatives.

Species to Include

Amendment 42 should cover reef fish species for which there are recreational sector allocations
(red snapper, gag, red grouper, grey triggerfish, and amberjack). The quality of SRHS vessel

landings data would permit individual allocations for all these species and we see no reason to exclude any of them.

Thank you for considering our comments. We look forward to working with the Council in developing this important amendment.
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1/25/16Robert E. JonesAustin, TXOtherThank you for the opportunity to comment on Gulf of Mexico fisheries. Here are our comments and recommendations on recreational reef fish issues before the Council this week:

Continue progress on allocation-based management plans in Amendment 41 and 42.

Amendment 42:

The Gulf Headboat Collaborative pilot program demonstrated that an allocation-based management plan for headboats can be a significant improvement over status quo. Allocated the same proportion of red snapper and gag their customers would normally catch in derby seasons, headboats participating in the pilot
program:
Spread out their allocations of red snapper and gag over the year to allow year-round fishing and improved economic stability for headboat operators;
• Provided more than twice as many anglers (+100%) with opportunities to fish for red snapper and gag;
• Significantly reduced discards of red snapper and gag (by 43% and 59%, respectively);
• Successfully stayed under catch limits and facilitated superior monitoring and enforcement by using daily electronic logbooks, vessel monitoring systems, and quota transferability within the pilot program.
The headboat pilot program was a success for headboat businesses, their angler customers, and conservation. While the two year pilot expired on December 31, 2015, the Council now has an opportunity to build on this success and extend a similar management approach to all 68 Gulf of Mexico headboats participating in the Southeast Region Headboat Survey (i.e., Beaufort Survey).

We recommend that the Council move forward Amendment 42 as quickly as possible with these features:
• Species to include: Amendment 42 should develop a multispecies allocation-based management approach, consistent with recommendations from the Council’s Reef Fish Headboat Advisory Panel. At a minimum this should include the five major reef fish species for which there are recreational allocations (red snapper, red grouper, gag, greater amberjack, and gray triggerfish). These species are important to headboat businesses and their angler customers, and many are facing the same management challenges as recreational red snapper.
• Initial allocations: Headboats have reported their landings through trip-level logbooks for many years,
so it will be straightforward to establish initial allocations based on their own landings histories.
• Structure: Quota shares and allocation should be distributed to individual headboat operators with for- hire reef fish permits. A cooperative structure made sense for 19 headboats in a pilot program, but going forward on larger scale individual allocations and accountability will make management and enforcement more simple, effective, and efficient.
• Transferability: Shares and allocation should be freely transferable and divisible among permitted
headboats. Quota transfers allowed pilot program headboats the flexibility to reduce discards and extend fishing seasons over the year. Amendment 42 should extend these benefits to all Gulf of Mexico headboats.

Amendment 41:

The benefits demonstrated by the headboat pilot program should also be extended to the charter component of the recreational reef fish fishery. Amendment 41 lays out four goals: increased flexibility, reduced management uncertainty, improved economic conditions, and increased fishing opportunities for charter customers. These goals are critical to reversing the failure of status quo management and are the right guideposts for developing a successful management plan for the charter for-hire component.

We recommend that the Council move forward Amendment 41 with these considerations:

Management approach: The two fishing quota programs listed in Action 1, Alternative 2 (Individual Fishing Quota and Permit Fishing Quota) are likely to provide the most benefits to participants and the most efficient management for regulators and law enforcement. A cooperative structure is impractical given the large number of charter operators across the Gulf, and stand-alone tag management would forfeit the predictability and efficiency of individual allocations.
• Initial allocations: Given the lack of vessel-level landings history, Amendment 41 lays out several equitable means of distribution. We do not recommend one alternative over any other, but the Council should consider all of the implications of weighting allocations by estimated regional landings from prior years. Weighting allocations by estimated regional landings may result in uneven initial allocations across the Gulf, but not doing so may mean that initial allocations are less representative of recent fishing trends.
• Transferability: For any initial allocation scenario selected, quota transferability will be advantageous to rebalance fishing opportunities, extend fishing seasons, and reduce discards. The Gulf Headboat Collaborative pilot program demonstrated clear benefits of quota transferability. We recommend that Amendment 41 provide these benefits to the charter component.

We recommend that the Council reconvene the reef fish headboat and red snapper charter for-hire advisory panels before the April 2016 Council meeting to provide more detailed guidance on these management options.

Thank you for considering our comments and recommendations.
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3/31/2016 18:24:58William GouldingSgoulding6@comcast.netNaples,FL 34110Charter/Headboat For-HireWhy will you not review the moratorium on pelagic and reef licenses? It is way overdue and very unfair to those of us not holding licenses in 1997. It is not fair to the 6 pack charters that are limited to 9 miles, especially unfair to charters that do spearfishing. There is no visibility until you get 10 miles out and it's only 40 foot depth at that. I think it is a restraint of trade and the same guys keep making the money. Just not right.
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9/26/2016 16:32:32ECHO ECHOMAKO2242@YAHOO.COM77471Private Recreational AnglerMORE GOVERNMENT JOBS REALLY??? $$$$ OFF THE BACKS OF WORKING PEOPLE WHO JUST WANT TO FISH THIS ENTIRE FEDERAL CRAP IS TOTALLY OUT OF CONTROL AND OUT OF TOUCH WITH WHATS HAPPENING $$$$$$
I HOPE TRUMP SHUTS YALL DOWN PERIOD
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10/14/16Randy & Susan BoggsCharter/Headboat For-HireWe commend the Gulf Council for continuing to make progress on Amendments 41 and 42 and urge the Council to move forward towards final approval of these amendments as quickly as possible. Our comments this week are specific to Amendment 42. For many years the headboat industry in the Gulf has struggled with shortened fishing seasons and Amendment 42 will provide us with needed flexibility while increasing fishing opportunities for our recreational angler customers. As the pilot program carried out by the GulfHeadboat Collaborative demonstrated, management measures like those being considered in Amendment 42 can improve business stability for headboats, increase access for anglers, and reduce discards. We offer these comments on the current draft of Amendment 42.

Eligibility to Participate in Amendment 42

Since its inception it has been clear that Amendment 42 would apply to the vessels that have reported landings to the Southeast Region Headboat Survey (SRHS). These vessels are unique because they have catch history showing what each individual vessel landed over the past several years. This catch history documents the current and historical harvests of these vessels, and serves as a proxy for their investments in and dependence upon the fishery, all of which are factors that the Magnuson-Stevens Act requires to be considered when implementing a program like Amendment 42. Also, our documented catch history ensures that any allocations reflect the same proportion offish we would land anyway.

At the last Council meeting there was some discussion about how to address vessels that began participating in the SRHS for the first time in 2016, and other vessels that once were but no longer are reporting to SRHS. We urge the Council to extend initial participation in Amendment 42 to those vessels that reported landings to SRHS at any point in time from 2011 through the published control date of December 31, 2015. Our understanding is that there are approximately 71 vessels that meet that description. Vessels that started reporting to SRHS in 2016 do not have landings history prior to the control date that could be considered in the various allocation alternatives, and so would presumably have no quotas at the outset of the program. At the same time, allowing vessels that did report landings to SRHS at some point in the recent past should be afforded the opportunity to participate in the Amendment 42 program if they choose to do so.

Allocation of Quotas to the Amendment 42 Program

The percentage of the for-hire recreational sector quotas that will be allocated to the Amendment 42 program should be determined solely by the landings history of those vessels that ultimately decide to participate in Amendment 42, and not by all reported landings to SRHS over the years. In other words, the same allocation years used in Action 5 (Allocation of ACL to the Landings History Vessel Program) should also be used in Action 7 (Initial Apportionment of Shares). To the extent that the Council adopts an opt-out provision that would allow any vessel eligible for Amendment 42 to opt out prior to the effective date, any landings history associated with vessels that opt-out should be excluded from the total quotas apportioned to the Amendment 42 program.

IFQ vs. PFQ Program

We continue to believe that the Council should select and IFQ program (Action 1, Alternative 2) and move the PFQ alternative (Action 1, Alternative 3) to the "considered but rejected" portion of Amendment 42. The PFQ alternative dispenses with the ability to transfer shares and annual allocations in various quantities, which would erect a barrier to maximizing efficient use of fishing privileges for no perceptible management benefit. In developing Amendment 42, we are looking for maximum flexibility. An IFQ program achieves that, and this IFQ program can and should be set up to keep quotas within the headboat fishery.

Referendum for Amendment 42

The referendum for Amendment 42 should be limited to those approximately 71 vessels (specifically, the owners of the for-hire permits on those vessels) that are eligible to participate in the program. Expanding the referendum to anyone else who would not be regulated by Amendment 42 makes no sense, and would be inconsistent with MSA requirements as NOAA General Counsel has already determined. However, it must be made abundantly clear that voting "yes" in the referendum does not lock-in a vessel to participating in Amendment 42 ifthere is an opt-out provision. Any vessel could still choose to opt out of the program after the referendum.

New Entrants

We strongly support a pathway for new entrants to participate in the Amendment 42 program in the future after initial implementation. At least for the first few years after implementation of Amendment 42, any person with a for-hire permit who commits to operating a headboat as a headboat (e.g., charging primarily by the head), reporting to SRHS and complying with other monitoring requirements for Amendment 42 vessels should be eligible to acquire an endorsement or headboat permit in the future. Acquiring such an endorsement or headboat permit would then authorize the holder to acquire shares or annual allocation from existing participants in the program. Even more flexibility as to new entry or quota usage and transferability could be adopted in the future.

Moving Forward with Amendment 42

The Council has made tremendous progress in developing Amendment 42 over the past year and a half. We strongly urge the Council to keep moving forward with Amendment 42. Some have suggested delaying Amendment 42 to coincide with Amendment 41 or combining the two amendments together. Taking such action would be a grave mistake in our view. There is no reason to hold back Amendment 42 and delaying needed relief for headboats just because there might be some additional issues to work out in Amendment 41. In addition, since the vessels eligible for participating in Amendment 42 have documented catch history while charter boats do not, there are very good reasons for regulating these differently situated vessels under different amendments that by necessity use different allocation criteria. The two amendments should remain separate and move forward on separate tracks.

Thank you for considering our views.
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12/14/2016 9:54:04Capt tom Adams4tomadams@gmail.comport st joe. fl 32456Private Recreational Angler, Charter/Headboat For-HireAlt 1 only There is no way you nan make special seasons for headboats without doing the same for charterboats All headboats and charterboats are only taxis taking recreational fishermen out to fish They have the same permits and should be treated the same as all federally permitted charterboats. all with the same season and the same chance to make a living
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1/25/17Shane CantrellGalveston, TXCharter/Headboat For-HireThe Charter Fisherman's Association is the largest federally permitted charter for-hire organization in the region. Our organization is focused on working respectfully within the fishery management process toward realistic solutions to problems facing the recreational fishery and charter for hire industry. We appreciate the opportunity to provide input and comments on a variety of fishery issues before the Gulf Council:

Amendment 41 and Amendment 42 - Charter and Headboat Management

Following the October Gulf Council meeting, there were some differences identified between the charter and headboat management amendments that needed to be addressed before moving forward. The primary differences were in species composition and development/implementation timelines. These were discussed at great length in the joint CFH/Headboat Advisory Panel meeting by members of a broad panel; but through these discussions, the group was able to develop and arrive at a few very good consensus statements. The Charter Fisherman’s Association supports moving forward with 2 multi-species, allocation based management amendments to be passed and implemented at the same time. Council staff needs direction from the council to move forward with development of both amendments according to the AP consensus statements for further discussion at the April council meeting. Next steps for Amendment 41 should include conversion of the program to include not only red snapper, but gray triggerfish, greater amberjack, gag grouper and red grouper, consistent with Amendment 42. The Council and NMFS staff also presented, at the joint AP meeting, ideas for “cyclic redistribution” of shares that are not used initially being allocated, to make sure fish ultimately go to those who are actively fishing as charter for-hire operators. The panel seemed very interested in this strategy, and we recommend “cyclic redistribution” as outlined by staff should be included in the Amendment 41 document for further analysis and consideration. We encourage the Council staff to work with NMFS to develop a suite of alternatives that address the details of how this redistribution could be operationalized

Thank you for your consideration of these comments.
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3/22/2017 9:28:57Christopher Dombkowskidaiwafan25@yahoo.comDayton, Ohio 45434 AND Cibolo TexasPrivate Recreational Angler, Charter/Headboat For-HireI would like to see a quota split for the head/for hire boats. I believe that 50% of the quota should come from the commercial side and 50% should come from rec angler side to satisfy the fact that their endeavors are indeed from both angles. They are making monetary income off the public resource while still providing a recreational opportunities. This would allow charters and headboats a longer snapper season so they should be interested in this as well it would be a major win for them as well as helping to satisfy/ease the burden on the rec angler side of some of the issues at hand.
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6/7/17Dylan Hubbarddhubbard@hubbardsmarina.comFLCharter/Headboat For-HireTo start, a little background on us and our company. At Hubbard’s Marina, we operate two federally permitted head boats with 50+ passengers and four charter boats all with federal permits, two of those are multi passenger USCG inspected charter vessels. Hubbard’s Marina carries around 60,000 anglers on average per year for near shore and offshore deep sea vertical line fishing. Typically fishing depths of 10-1,000 foot off the central west coast of Florida as a family owned and operated business since 1928.

The following are our recommendations to the council regarding what has been discussed this far at the meeting. (Tab B – 13) Draft Amendment 42 – federal reef fish headboat management
Not discussed during this meeting, allowing time for Amendment 41 to catch up. However, we again urge the council to ensure Amendments 41 and 42 move together and mirror one another not only in the timeline but also by allocation and species included.

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7/31/2017 8:00:10Tom Adams
4tomadams@gmail.com
Prot St. Joe, FL
Charter/Headboat For-Hire
Pleas postpone all actions on headboats and charterboats You do not have data from ALL the states and if you wait a few months You will have much added data and much more complete data. Also most charterfishermen are still very busy and cannot attend. Also it is not being held in a centrally located area. also the main season will be over by the next meeting after august and you can get a lot more input from a lot more permit holders It is an extremely bad idea to vote on any actions or amendmentd that concern charterboats and /or heaboats until later this year.



This attempt to take final action on two such important issues that will forever affect the vessel owners and sector is ill-conceived and borders on complete irresponsibility at best and shows the NMFS/Council agenda to force a style of management on fishers at worst. The facts that the majority of the vessel owners affected do not want such management, the extremely late production of the documents to be finalized that will have less than 4 weeks to review and study in order to provide any type of reasonable comment, and the lack of complete data to review shows the fast track of the NMFS/Council agenda that completely ignores the will of those affected most. So all understand, the proposed referendums are not simple proposed regulations that may change yearly or seasonally like most regulations that affect what we are able to harvest, when and how. The most important decision a person who enters the for hire charter/headboat business will make is to enter the business or not. The next most important decision that person will make will be to support or not a catch share program that will affect that business for ever. Trying to make such an important decision on the proposed document in such a short period of time and based on incomplete data is, frankly, plain irresponsible. As members of the Council, the staff, the staff of the NMFS, and others working on this agenda, surely you would not make such an important decision that will affect you and your family’s future on such a presentation.



The final action proposed for the referendums must be moved to the Biloxi Oct meeting to be fair to the vessel owners who will be affected the most. We strongly urge the NMFS/Council, as we have in the past, to eliminate further discussion on this issue and move to working on more important management issues.


As an owner of a state permitted boat and a federally permitted boat I am requesting an OPPORTUNITY to be there. It is impossible for MOST charter business owners to attend the August meeting. Thanks
22
7/31/2017 8:00:38Tom Adams
4tomadams@gmail.com
Port St. Joe, FL
Charter/Headboat For-Hire
Pleas postpone all actions on headboats and charterboats You do not have data from ALL the states and if you wait a few months You will have much added data and much more complete data. Also most charterfishermen are still very busy and cannot attend. Also it is not being held in a centrally located area. also the main season will be over by the next meeting after august and you can get a lot more input from a lot more permit holders It is an extremely bad idea to vote on any actions or amendmentd that concern charterboats and /or heaboats until later this year.



This attempt to take final action on two such important issues that will forever affect the vessel owners and sector is ill-conceived and borders on complete irresponsibility at best and shows the NMFS/Council agenda to force a style of management on fishers at worst. The facts that the majority of the vessel owners affected do not want such management, the extremely late production of the documents to be finalized that will have less than 4 weeks to review and study in order to provide any type of reasonable comment, and the lack of complete data to review shows the fast track of the NMFS/Council agenda that completely ignores the will of those affected most. So all understand, the proposed referendums are not simple proposed regulations that may change yearly or seasonally like most regulations that affect what we are able to harvest, when and how. The most important decision a person who enters the for hire charter/headboat business will make is to enter the business or not. The next most important decision that person will make will be to support or not a catch share program that will affect that business for ever. Trying to make such an important decision on the proposed document in such a short period of time and based on incomplete data is, frankly, plain irresponsible. As members of the Council, the staff, the staff of the NMFS, and others working on this agenda, surely you would not make such an important decision that will affect you and your family’s future on such a presentation.



The final action proposed for the referendums must be moved to the Biloxi Oct meeting to be fair to the vessel owners who will be affected the most. We strongly urge the NMFS/Council, as we have in the past, to eliminate further discussion on this issue and move to working on more important management issues.


As an owner of a state permitted boat and a federally permitted boat I am requesting an OPPORTUNITY to be there. It is impossible for MOST charter business owners to attend the August meeting. Thanks
23
8/9/2017 15:27:38Dylan Hubbard
dhubbard@hubbardsmarina.com
St. Petersburg, FL
Charter/Headboat For-Hire
We still hold to the fact that we would demand not to see this type of Allocation based management in the for-hire sectors in any way, it is overwhelmingly opposed by the nearly 80 federal permits we represent. As we have stated in previous public comments.
24
8/9/2017 16:01:52Jim McKayjdale_us@yahoo.comI disagree very much with the idea of the federal gov gifting a select group of individuals or corporations America's public resources as it is being considered im Ams 41 & 42. I do believe if these resources are sold or bartered they are considered a commercial comedy and therefore should come from the commercial quota. Anyway you look at it this resource will be the selling fact of the charter trips or bartered between other captains.
Do the right thing and not pass Ams 41 & 42.

Thanks Jim McKay.
25
8/9/2017 16:01:58Jim McKayjdale_us@yahoo.comI disagree very much with the idea of the federal gov gifting a select group of individuals or corporations America's public resources as it is being considered im Ams 41 & 42. I do believe if these resources are sold or bartered they are considered a commercial comedy and therefore should come from the commercial quota. Anyway you look at it this resource will be the selling fact of the charter trips or bartered between other captains.
Do the right thing and not pass Ams 41 & 42.

Thanks Jim McKay.
26
9/26/2017 7:37:10Bob Zales bobzales2@gmail.comPanama City Beach, FL
Charter/Headboat For-Hire
On behalf of the members of the National Association of Charterboat Operators (NACO) and the Panama City Boatmen Association (PCBA) I strongly encourage the Gulf Council to permanently table any and all actions on the above subject matter. These proposed actions, that have consumed thousands of tax dollars, months of staff time, and have caused stakeholders to spend countless personal money and time are unnecessary, completely unfair to the federally permitted small family business owners across the Gulf of Mexico, and will only serve to reduce fleet capacity eliminating vessel owners and crews creating chaos within the industry and among those who wish to utilize our services. Let me explain.

According to NMFS/Council data contained in several amendments regulating the Gulf Reef Fish Fishery, in particular RF Amendment 40 (Sector Separation), when the current moratorium on Gulf charter/headboat federal permits was under development as of August 2000 there were 1650 federally permitted charter/headboat vessels. The number of permitted vessels steadily dropped from 1650 in 2000 to 1519 in '08, 1473 in '09, 1432 in '10, 1396 in '11, 1378 in '12, and 1368 in '13. As of 10-24-16 there are 1247. Between 2000 and 16 years later in 2016 the # of vessels fell by 403, with the majority of that drop between 2000 and 2008 (131) which was the time of transition from open access to restricted access (which included many last minute issued permits due to speculation) and from 2013 to 2016 (121) the period of time during the whole sector separation movement to impose catch shares on the fleet. From 2008 thru 2013 the reduction of vessels was only 151 which can be considered a natural reduction due to many factors such as an excess of permits placed on inactive vessels, owners getting out of the business due to retirement age, death, or change of occupation.

I provide these numbers due to the proposed allocation plan where vessel reduction is proposed to increase the catch shares per vessel left in the fishery over time (1 year to 3 year increments). The minimum reduction of permits due to various reasons over time will not result in a substantial increase in the proposed catch shares to be provided to the vessels, meaning the initial shares allocated will not increase as some propose. The only substantial increase that can occur will be due to others leaving the business or permanently exiting the fishery which will result in a few owning the majority of the shares and thus being able to control the fishery over those who will have few shares to use. This will create an unfair competitive advantage in business, will consolidate the fishery to certain areas, will harm those fishing communities who depend on a vibrant charter fishery, those supporting businesses who support it, and the anglers who wish to charter the few remaining vessels.

The AHRS charter for Hire AP has recommended that the original species of fish to be included in the propose catch share program only include red snapper, greater amberjack, and trigger fish, eliminating both gag and red grouper. One reason for this recommendation is simple and is easily verified by the AP discussion which is to gain a positive vote for the proposed referendum since over 700 voting vessel owners are more likely to vote for the referendum if it only contains red snapper, amberjack, and trigger fish since the over 700 will still be able to fish for both gag and red grouper for most of each year under the current size and bag limits. Another reason provided by some is that both gag and red grouper are not over fished as are the other 3 species. This is now a useless argument since the NMFS has now released a federal register notice (dated today 9-25-17, for review, APPROVAL, and IMPLEMENTATION, Reef Fish Amendment 44 Revised Reef Fish Minimum Stock Size Thresholds). This Amendment will modify the current MSST for several reef fish species in the Gulf and according to the FR “If this MSST definition is approved, NMFS expects that the Gulf red snapper and gray triggerfish stocks would be reclassified as not overfished, but rebuilding, because the biomass for these two stocks is currently estimated to be greater than 50 percent of BMSY.” This means that red snapper and triggerfish would be in the same class as gag and red grouper thus making the argument that gag and red grouper should not be included in the catch share program since they are not overfished mute. If red snapper and triggerfish will soon not be classified as overfished they should be removed from the catch share program.

Removing gag and red grouper from the proposed catch share program is an end around effort to weight the vote for the positive outcome sought by the NMFS and some Gulf Council members. If this proposed catch share system and allocation based management plan is to go forward then all 5 species, originally included in the plans, must remain in the proposals. By having all 5 species included the vote will appear to be more fair, especially if red snapper and triggerfish are soon to be considered not overfished. As a side note, currently in every proposed Congressional bill to reform the MSA a weighted referendum vote for any proposed catch share program is eliminated allowing only one vote for one permit. The efforts of the past by the NMFS to skew catch share program votes by artificially weighting them has clearly met the ire of Congress and should be applied to any future catch share votes.

According to an email sent to most people on my list (see below), using the NMFS/Council data you can see that if the red snapper for hire charter harvest numbers are equally divided among the 1247 permitted vessels they each receive only 1747 pounds. Depending on the average size of the fish this relates to 250 to 291 red snapper per boat. Even using the extremely complicated formula developed by NMFS/Council staff to use a 25%/25%/50% scenario the most poundage for a COI passenger vessel that carries more than 6 people is around 3,000 pounds. While some areas of the Gulf may love to have those numbers, in the areas of the northern and eastern Gulf where the historical catch and effort have been, those numbers will not sustain a viable fishery. Management is not and should not be tasked with creating equality in fishing operations. Fair and historical business competition is the cornerstone of American society. It is not the job of Government to make all business equal eliminating such competition. The proposed plans above remove the American business model and move to make all charter fishing equal in every area. Historical participation, working years creating experience and knowledge of the fisheries and business, suffering through natural and manmade disasters and high and low economic times become meaningless as this proposed plan makes all participants equal whether they fished 1 year or 50 years.

In the majority areas of the Gulf where the majority of the federally permitted vessels operate, fishing operations and business is best during the historical tourist season of the middle of May thru the middle of August. This period is when most tourist and anglers plan to come to the Gulf to seek recreation and access and opportunities to fish, This period is the most productive in the number of tourist and the dollars they add to local communities across the Gulf. This is the period for the best weather and the most species of fish are available to seek. Our members fully support a fixed number of days for a season over any catch share program. Many of you hear the scare tactics by some that if a catch share program is not established and Amendment 40 sunsets so sector separation will disappear that the for hire charter fleet will revert back to the days of 1 to 2 weeks of fishing. This is a blatant lie and is used to only scare people of their future. The only reason A40 (sector separation) was needed was to begin the development of a catch share program for the for hire sector. A40 was not necessary for the NMFS to manage the federally permitted for hire charter, headboat, or private recreational anglers with different seasons, bag limits, or size limits. All 3 sectors of the recreational fishery could have and can be managed as they are today without A40.

No where in the MSA does it specifically state or imply that the recreational fishery, including the charter fishery, must be managed as 1 unit. In fact, National Standard 4 addresses this issue as it states " (4) Conservation and management measures shall not discriminate between residents of different States. If it becomes necessary to allocate or assign fishing privileges among various United States fishermen, such allocation shall be (A) fair and equitable to all such fishermen; (B) reasonably calculated to promote conservation; and (C) carried out in such manner that no particular individual, corporation, or other entity acquires an excessive share of such privileges." It is clear that the recreational quota can be allocated differently and fishing privileges such as a different season can be done as long as such is done fairly and equitably.

I respectfully submit that the statements above provide the rationale for the Council to permanently table all included in the subject line above. I will be available to answer any questions during the Council meeting and during my testimony.

Thank you,

Capt Bob Zales, II
President
NACO & PCBA
27
9/28/2017 11:34:01Steve and Anita Rosstiaross60@gmail.comPanama City Beach, FL agree and stand with Bob Zales II as stated in his email to you and quoted below:

"Since the publication of the Federal Register notice on 9-25-17 to modify the MSST level and how it will significantly change the status of red snapper and triggerfish there is no rush to approve any catch share program and referendum for the charter/headboat fishery in the Gulf. If the Council is not willing to completely table these proposals at this time, at least table further discussion until the FR is approved and we learn more on the future management of red snapper and triggerfish. With the much improved status of both species and the real possibility they will both be considered no longer overfished or under going overfishing the proposed catch share programs and referendums are unnecessary."

Please send something asap. Thanks,
Bob


I would also like to add: Any Catch Share Program would put our Small Charter Business OUT OF BUSINESS based on your Catch Share Referendum!! We prefer the Derby Style Season!!
Thank you,
28
9/28/2017 11:34:30Steve and Anita Rosstiaross60@gmail.comPanama City Beach, FL agree and stand with Bob Zales II as stated in his email to you and quoted below:

"Since the publication of the Federal Register notice on 9-25-17 to modify the MSST level and how it will significantly change the status of red snapper and triggerfish there is no rush to approve any catch share program and referendum for the charter/headboat fishery in the Gulf. If the Council is not willing to completely table these proposals at this time, at least table further discussion until the FR is approved and we learn more on the future management of red snapper and triggerfish. With the much improved status of both species and the real possibility they will both be considered no longer overfished or under going overfishing the proposed catch share programs and referendums are unnecessary."

Please send something asap. Thanks,
Bob


I would also like to add: Any Catch Share Program would put our Small Charter Business OUT OF BUSINESS based on your Catch Share Referendum!! We prefer the Derby Style Season!!
Thank you,
29
10/03/2017Jeff LandryBaton Rouge, LACharter/Headboat For-Hire
Gulf of Mexico Fishery Management Counc il Reef Fish Management Committee
Via e-mail: gulfcouncil@gulfcouncil.org

RE: Objection to Reef Fish Management Plan, Amendments 41 and 42 Dear Council and Committee Members:
I write to express my opposition to the proposed Reef Fish Management Plan Amendments 41 and 42. I am Attorney General of the State of Louisiana, constitutionally charged to serve as the State's chief legal officer and to participate in any proceeding as necessary for the assertion or protection of any right or interest of the State. La. Const. Art. IV, §
8. The State of Louisiana' s rights and interests impacted by the amendments proposed by the Council are the preservation of fair and equal access to red snapper and the safeguarding of the public ownership of this important natural resource. These rights and interests are threatened by the proposed Amendments.

Congress recognizes the immense value of the red snapper and other fish in United States waters to the food supply, economy, health, and recreational opportunities of the Nation. 16
U.S.C. l 80l (a)(l ). Louisiana recognizes this value also, and requires protection, conservation, and replenishment of these and all natural resources of the State. La. Const. aIt. IX, § 1.

While it is not disputed that the red snapper stock in the Gulf of Mexico was overfished in years past, that stock is and has been rebuilding, through the efforts of this Council, the federal government, and the states. Rebuilding the red snapper stock necessitated limiting the amount of red snapper that could be caught, and in so doing, Congress split this quota between the recreational and commercial sec tors. 16 U.S.C. 1883(d). This Council further split the recreational sector quota between for-hire and private angling component. I disagree with this sector separation, for reasons explained below. And with the adoption of Amendments 41 and 42 further subdividing the for-hire quota between charter vessel and headboat sub-components, the Council would exacerbate the problems created by sector separation.

First, subdividing the recreational quota effectively walls off a substantial part of the recreational quota from the public, reducing purely recreational fishing opportunities available to the public in favor of providing a protected quota to businesses that profit from this public resource , leaving this portion of the public resource available to the individual recreational fisherman only by paying for it. While the for-hire industry no doubt serves the public interest by providing fishermen the option to hire fishing boats or spots on fishing boats, a management plan forcing them to take this option to access 42.3% of the recreational quota does comparably

Page2

more harm to that interest. Congress did not require this sector separation, and I urge the Council to repeal it.

Further, sector separation takes a static approach to managing a dynamic issue - the result is that even where one sector is under capacity, that portion of the fishery is not available to another sector, even though landing data can easily support more adaptive management between commercial, charter and recreational fishing.

The proposed Amendments, which would further subdivide this sheltered quota, also further isolate it from individual recreational fishing opportunities apart from those available through a pay-to-fish enterprise. The Amendments also encourage more complete use of the for­ hire quota, which in the past has gone partially unused. Unused quota from the for-hire sector has been available to purely recreational anglers, at least partly mitigating the impact to the public of the sector separation. The proposed amendments instead increase the harmful impact to private angling. Congress rightly mandated protection of recreational fishing, by whatever means fishermen choose to access the fish, and this protection is not afforded by sector separation.

Second, Amendments 41 and 42 functionally grant what amounts to "ownership" of the red snapper in the Gulf of Mexico to charter and headboat permit holders. Not only is giving private entities ownership of this essential public resource entirely inappropriate and inconsistent with public resources, it is contrary to the stated will of Congress.

"An individual fishing quota or other limited access system authorization shall not create, or be construed to create, any right, title, or interest in or to any fish before the fish is harvested." 16 U.S.C. 1853a(b)(3)(D).

The IFQ program established under Amendment 42 would grant perpetual, transferrable shares in the red snapper stock to selected individuals that need not even themselves fish under their catch share. Short of forfeiture for actual wrongdoing, these catch shares would be permanent, which is the very essence of a property right, in direct violation of Congressional intent. It is no stretch to anticipate that granting such property rights in the red snapper will lead to sharecropping, as has occurred in the commercial sector.

The Amendment 41 PFQ program is less objectionable than Amendment 42's IFQ scheme because the permits would not be transferrable and it provides for periodic reallocations of unused catch shares. Though having fewer indicia of ownership of the public resource, this proposed amendment still grants ownership of catch shares and should be rejected. At the very least, Amendment 42 should be structured as a PFQ program like Amendment 41, rather than an IFQ program.

Third, both Amendments 41 and 42 provide the opportunity to obtain catch shares only to those already in the business, essentially creating a monopoly in their favor. This is particularly egregious since there has been a moratorium on for-hire permits since 2003 that has prevented others from entering the industry without paying their predecessors. Worse, the catch share caps favor the biggest of the current fishermen most by locking in their advantage. And proceeding

Page 3

with the Amendments would require referenda placing the decision in the hands of the very people who would benefit from it - an obvious and obnoxious conflict of interest. The Council should not give up its authority to manage the red snapper resource by passing these Amendments and thereby placing that authority in private hands.

Fourth, the Amendments limit competition and opportunity for other for-hire businesses by imposing an additional cost on new entrants that the current participants would never pay. Worse, that cost is payment to a private person for the right to fish the public' s fish. By contrast, Congress actually required measures to assist entry level fishermen. 16 U.S.C. 1853a(c)(5)(C). Under Amendment 42, the Advisory Panel recommended consideration of set asides for new fishermen , but given the treatment under Amendment 41, it appears likely still to require payment to existing fishermen.

Fifth, as to the Amendment 42 IFQ program, even if the granting of property rights in the red snapper stock were proper, principles of adaptive management warrant periodic reallocation, rather than one-time perpetual allocation based on some historical lookback period. Catch shares should not be locked in place forever, based on fishing effort dating back decades. Nearly real­ time catch reporting, such as Louisiana has with its LA Creel program, could provide the information needed for adaptive management and adjustments to allocation without need for lookback. In this way, Amendment 41 is less objectionable, because it at least recognizes the need for adaptive management, even the reallocations provided are only partial. Any IFQ or PFQ catch shares should periodically sunset and be reallocated on a basis that is fair and compliant with MSA.

Sixth, even if perpetual property rights were properly granted, such rights have obvious economic value and should not merely be given away. Congress required consideration of auctions for any limited access privilege programs. 16 U.S.C. 1853a(d). The Amendment Advisory Panel does not address this, other than to note that other IFQ programs have been enacted. Congress affirmatively required consideration of auctions, and failure to seek payment for giving away this natural resource should not be allowed.

Historically, there has been little overfishing in the for-hire sector, and certainly not recently. Nor has there been a " race to fish" or derby-style fishing in the for-hire sector, or concern for overcapitalization or problems with need for more stability in the industry. The for­ hire seasons have been far longer than the private angling seasons. There is no need for additional sector-separation within the recreational sector. Given the constitutional, statutory, economic, social, and fairness problems with Amendments 41 and 42, I urge the Committee and the Council to reject both.

Jeff Landry, Attorney General, State of Louisiana
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10/4/2017 9:50:28Joe Nash
captjoenash@gmail.com
Orange Beach, Alabama
Charter/Headboat For-Hire
Joe Nash from Orange Beach, Al. charter for hire. I am in support of keeping sector seperation and a management plan for Charter for hire, also electronic logbooks should be mandatory.
Amberjacks open Aug 1 2018..
Support Amendments 41 and 42
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10/4/2017 11:15:11Pam Anderson
pamheartsofhope@aol.com
Panama City Beach, FL
Charter/Headboat For-Hire
Madam Chair and Council Members;
Good Afternoon, I am Pam Anderson, Operations Manager of Capt. Anderson's Marina and the fishery rep on our Bay County Govt. Affairs Committee. This year is Capt. Anderson's Marina's 60th anniversary being at its present location, but forefathers started taking passengers for hire in 1935.
To address the summary of the Headboat Reef Fish Advisory Panel, I am the one that made the motion to have the headboat component continue with Seasons, size limits, and bag limits. Without set seasons fishing customers do not have a specific time to ask for vacations, to access their preferred species. Without size limits, smaller fish are not allowed to continue to grow the stock. Bag limits keep us within our ACL's, as has been shown in recent years. We do not need further restrictions in order for the headboat component to be accountable. We have provided needed data since 2000 or earlier.
With the catch share program, our 60 passenger headboat would have had 15 days with 1 fish per angler, according to the estimated allocations in 2015, instead of 2 trips of 60 passengers, 2 snapper each for 49 days. Those requesting that limitation either are banking on others failing in this business, giving themselves more allocation, or want intersector trading so they can purchase and lease shares. Either way is not good for the industry. Another note is this panel is not representative of a fair balance of headboat operators' viewpoints. This group is not representative of the true opinion of the overall headboat component.
One more thing I would like to say about the votes taken during this meeting. For those of us who do not want a catch share program, we participated in the discussions and choices of different alternatives, simply as a way of saying, 'If we are forced into this type of program, these choices would be the lesser of the evils.
Our captains need fair and consistent access when customers can fish. Access has been a significant problem in recent years. Our customers will not buy tickets if they believe there is no chance of catching and keeping some of the species they desire. That is why, in Red Snapper season, our boats are full, running every day the weather permits, and why they drop to less than half full without Red Snapper-due to accessibility. Many cancel trips to Panama City Beach if last minute closures are implemented as they were for amberjack earlier this year.
We need to offer targeted species when our customers have the opportunity to be on vacation, or on a special weekend, or during school breaks. This is why it is so important to have access to at least some of these target species in spring and fall seasons as well as in the summer.
Captains have to be good at their jobs to keep customers happy day after day. Most of the captains at Capt. Anderson's Marina are exceptional. Folks trust us to tell them the truth and do their best to provide a fun experience for their families, friends, and business associates.
We all need to continue to be conservationists, providing for our future business. Most anglers do that every day. Many of our guys, along with others in the community, are working together to provide more habitat through our artificial reef programs. This industry would not have survived without our being the conservationists we are. Red Snapper are plentiful.
I am grateful our scientists have shown this in the MSST document for Red Snapper and Triggerfish. We cannot continue down this current road of excess regulations and needlessly continuing negative economic impacts to our boats, our marinas, or our communities.
We need for you to stop catch shares now. Thousands across the Gulf have responded to the catch share agenda, saying 'no' to this insidious program that privatizes our natural resource and harms businesses, picking winners and losers in the industry.
We need for you to provide greater access to red snapper, triggerfish, and, even amberjacks. The reason we 'overfished' the weight limit of amberjacks is due to a mistake of this Council. The Council chose to increase the size limit of AJs by 4 inches in one year which caused overfishing the ACL -bigger fish weigh more. We did not catch MORE fish, we caught heavier fish. If we had gradually raised the size limit, one year at a time, the 'overfishing' would not have occurred. We would not have to be considering these drastic measures that might give us more access to AJs if the Council would have listened to our common sense fishermen. Choosing winners and losers in this fishery is obviously still an unstated purpose of this Council, whether through catch shares or other means. Amberjack closures are one of those other means. By shutting down the spring season for AJs, this Council is continuing to eliminate opportunity to fish, opportunity to offer access to a target fishery when anglers want to access it., costing and most likely, eliminating more businesses and jobs.
You have proven you can get the data you need to eliminate a lot of the uncertainties being discussed here by continuing to improve data collection by the subcomponents of the recreational sector, and requiring harvest data be collected, as it is in the headboat component. Possibly a little more information would improve the outcome, so implement that.
All can be done without eliminating businesses and jobs if you so choose.
Thank you for this opportunity to speak.
Respectfully,
Pam Anderson, Operations Manager
Capt. Anderson's Marina
Panama City Beach, FL 32408
pamheartsofhope@aol.com
850-234-3435

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10/4/2017 14:08:43Dylan Hubbard
dhubbard@hubbardsmarina.com
Madiera Beach, FL
Charter/Headboat For-Hire
My family business has been fishing central west coast of Florida for nearly 90 years and four generations. Today we operate 6 federally permitted vessels including two 65+ passenger head boats and four federally permitted charter vessels. On top of these permits, I am also here today to represent the Florida Guides association as their Offshore Director. Finally, I am a CCA life member as well. Referendum requirements for am 41 and 42
We still hold to the fact that we would demand not to see this type of Allocation based management in the for-hire sectors in any way, it is overwhelmingly opposed by the nearly 80 federal permits we represent. As we have stated in previous public comments. Also, it will create chaos and would add an additional hardship on the businesses involved in the CFH and headboat industry. We are very happy with our seasons and ability to access our fishery especially if we have the reliable season for amberjack mentioned previously. There are no ‘problems’ to address in the CFH or headboat industries so why are we working on a super complex, time consuming and expensive fix to a problem that is not there.
We would also like to comment that as far as AMs 41 and 42 are concerned we feel the both the CFH and Headboat APs were heavily weighted in support of these amendments and did not show a true cross section of the industry. Due to this, we would urge the council to consider this when weighing AP preferred and their ‘support’ for these allocation based management systems. For example, the Co-Chair of the head boat AP, my father, voted No to every motion made during the meeting except for the first to show his opposition to the idea of AM 42.
33
01/23/2018Shane Cantrellshane.cantrell@iCloud.comGalveston, TXCharter/Headboat For-HireMrs. Leanne Bosarge, Chairwoman
Gulf of Mexico Fishery Management Council
2203 North Lois Ave
Tampa, FL 33607
Dr. Roy Crabtree, Southeast Regional Administrator
National Marine Fisheries Service
263 13th Avenue South
St. Petersburg, FL 33701
Dear Chairwoman Bosarge,
The Charter Fisherman's Association is the largest federally permitted charter for-hire
organization in the region. Our organization is focused on working respectfully within the
fishery management process toward realistic solutions to problems facing the
recreational fishery and charter for hire industry. We appreciate the opportunity to
provide input and comments on a variety of fishery issues before the Gulf Council: Amendment 41 and Amendment 42 - Charter and Headboat Management
The current arrangement of recreational fishing seasons by species will provide short
term relief for some anglers and business owners, but it is not a long term solution for
coastal economies and American fishing businesses. Amendments 41 and 42 have
been and continue to be grassroots, industry led efforts to create a brighter future for
the CFH community. This immense effort has presented unique opportunities and
challenges addressed by council members, council staff and agency personnel; but
there are also some items that need to be addressed at this meeting in order to develop
these programs further:
1 See attached letter from CFA to Gulf Council dated April 4, 2017.
• The multi-species program in Amendment 41 needs defined allocations for ACLs according to the same timeline used in Amendment 40 as this was a fair and
balanced compromise to the entire recreational fishery.
• Incorporating gray triggerfish and greater amberjack into the Amendment 41 decision
tool would provide CFH business owners the ability to compare proposed allocation
alternatives objectively.
Thank you for your consideration of these comments.
Sincerely,
Shane Cantrell
Executive director
Charter Fisherman’s Association
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01/24/2018Bob Zalesbobzales2@gmail.comCharter/Headboat For-HireAll,
Once again, on behalf of the Gulf Members of the National Association of Charterboat Operators and
the Members of the Panama City Boatmen Association I am requesting that the proposed actions to
create catch share programs for the Gulf Charter/Headboat For Hire Fleet be permanently tabled and all
discussion be stopped. I sent y’all a request to end the discussion and table all proposed actions on
September 25, 2017 and the rationale I provided in that request is still relevant today. In addition we
now have the final proposed amendments that provide additional rationale to end all further discussions on catch shares for the charter for hire fleet.
Both A41 and 42 are so complex and complicated that no one can fully understand what the end results
for each vessel owner will be. Each amendment provides a scenario for the percentage of quota to be
divided using various sets of past year’s harvest. Should one scenario be selected in one amendment
and another scenario in the other amendment the allowed quota will be different for each. Both charter
and headboats fish for the same species yet the preferred option for the charter fleet only includes red
snapper, trigger fish and amberjack while the headboat sector includes gag and red grouper as
well. This in itself creates an unfair advantage to fish for certain species for one group over
another. As I pointed out in the 9-25-17 email, gag and red grouper were included for the charter boats
but because charter boat owners south of the Panhandle of Florida fully understood they would lose the
ability to harvest those species as they have historically have and would not support A41 caused the ad
hoc AP to suggest removal of those species.
Without going into more detail, all one has to do is read both proposed amendments and try to fully
understand what their future in the charter and headboat business will be. There are too many
unknowns contained in these amendments to fully understand how many pounds of each species will be
allocated to each vessel. There is a scenario for assigned units such as 1 unit for a vessel that carries up
to 6 passengers and 2 units for a vessel that carries up to 24 passengers and 3 units for a vessel that
carries 25 or more passengers. Where did the passenger break for each unit come from? There are
uninspected vessels that carry only 4 passengers, some carry up to 6, the USCO crewing requirements
are based on vessels that carry up to 25 passengers and 26 or more passengers as an additional
deckhand is required on a vessel that carries 26 or more passengers. In other words the units available
are based on arbitrary passenger capacity with no logical basis or requirement.
There are a variety of more examples of the complications and confusions for understanding the real
impacts of these proposals for vessel owners. Also, the fact that every species covered by these
proposals are either not undergoing over fishing and not over fished or are rebuilding with increasing
quotas. The red snapper recreational fishery season has steadily increased in available days to fish and
continues to expand. The charter and headboat fisheries depend on the tourist season in order to
successfully operate and prosper. The tourist season is based on a multitude of factors such as summer
break from schools and good weather periods. While being able to offer some species on any day of
the year sounds great, the fact is that the current fishing seasons are the most profitable and provide
access and opportunity to most of the recreational fishing public.
The bottom line is that A4l and 42 are completely unnecessary as current management by fishing
seasons is working and improving. It is past time to eliminate further discussion on these proposals and
to spend management time and money on more important issues. I will be available to answer any
questions or concerns at the meeting.
Thanks,
Bob
Capt. Bob Zales, II
www.fishpc.com
PH 850-763-7249
Fax 850-763-3558
35
01/25/2018Pam Andersonpamheartsofhope@aol.comPanama City Beach, FL 32408Charter/Headboat For-HireLadies and Gentlemen;
As owners of a headboat and Capt. Anderson’s Marina, home to 5 headboats and 34 charter boats, we are in complete agreement with Bob Zales and NACO and PCBA.
It was said when discussion of catch share programs came up in 200B-9, when comments on them were taken in August,2012 and October, 2013, and since then, the majority of the for-hire industry and the private recreational industry and anglers (95% of respondents) did not want catch share programs in the Gulf of Mexico recreational fishery. We still don’t. Countless hours and funds have been put into the research and development of these programs, as well as hours wasted in Gulf Council meetings.
It is time to move on, and know that our fisheries are rebounding as they should after having been restricted for so long. We all agree that harvest data and independent data research need to move forward. It is time to consider the negative economic impacts on our industry catch shares imposes-an unnecessary scheme to reduce access instead of improve access for the recreational anglers.
As I stated in numerous public comments over the years, “remember National Standard 1”. It dictates fishery management is supposed to be ‘for the United States fishing industry ~ If a program is ‘for’ the industry, it does not eliminate legitimate businesses in the industry. Management shou/d consider fully the economic impacts of regulations on the industry and work to improve the fishery while protecting the industry from economic harm.
Excerpt from MSA:
(a) IN GENERAL.—Any fishery management p/an prepared, and any regulation promulgated to implement any such p/an, pursuant to this title shall be consistent with the following national standards for fishery conservation and management 98-623
(1) Conservation and management measures shall prevent overfishing while achieving, on a continuing basis, the optimum yield from each fisheiy for the United States fishing industry.
If you want to truly manage our fishery ‘for the fishing indust&? you will work to grow the Gulf fishery to meet the demands of the Nations consumers and anglers; continue to work toward better data. Implement artificial reef programs that provide the much-needed additional habitat for a growing fishery. Focus on eliminating things that deter growth of the fishery like removal of derelict oil rigs that have become thriving habitat and implementing lionfish removal programs.
Always remember that recreational fishing and commercial fishing are inherently different and need to be managed differently. Recreational fishing is all about access, whether for one fish or 10. If the season is closed there is no access and boats stay at the dock, limiting economic progress. Commercial fishing is all about supply and demand of a product. If you limit their access, you cause their market prices to rise, enhancing economic impacts. (By doing so with red snapper and grouper catch shares, you have eliminated businesses which is not good, thus increasing the demand for product from those left in the industry. It wasn’t good for those put out of business, but was a windfall for those remaining.)
Please stop discussion and/or consideration of Amendments 41 & 42.
Thank you for your consideration of these matters.
Sincerely,
Pam Anderson, Operations Manager,
Capt. Anderson’s Marina
5550 N. Lagoon Drive
Panama City Beach, FL 32408
850-234-3435
www.captandersonsmarina.com
36
01/29/2018Randy/Susan Boggsreelsurprisecharters@gmail.comJanuary 29, 2018
Ms. Leann Bosarge, Chair
Gulf of Mexico Fishery Management Council
2203 N Lois Avenue, Suite 1100
Tampa, FL 33607

Dear Ms. Bosarge:
We are writing to provide the Council with our recommendations for Reef Fish Amendment 42. First, we ask that the Council exclude the for-hire sector from regional management plans, including state-based EFPs currently before the Council. After the success of our headboat pilot program, we are making good progress in the Council with Amendments 41 and 42. We would like the Council to move these two amendments forward to public hearings as soon as possible.

For the Council’s consideration, we provide our recommendations for each action in Amendment 42 below, which generally track the Headboat Advisory Panel’s recommendations.

Action 1, Type of Recreational Management:
We recommend Alternative 2: Manage the reef fish species in the headboat management program by establishing an individual fishing quota program (IFQ).
IFQ allows for maximum flexibility through being able to transfer any amount of shares and allocation. Shareholdings should be limited to Amendment 42 participants through other actions in the Amendment. The PFQ program adds constraints but without any clear benefits. The PFQ would make it harder for new entrants and smaller operators to build a business in this fishery and would prevent efficient use of shares and allocation.

Action 2, Species to Include:
We recommend Preferred Alternative 2 with all sub-alternatives a-e: Include red snapper, greater amberjack, gray triggerfish, gag, and red grouper.
Headboat operators across the Gulf depend on all five species and more. Including multiple species will provide the most flexibility and success for the headboat sector.

Action 3, Participation at the Onset of the LHV Program:
We recommend Alternative 1, No Action: Any vessel that meets the control date, has a valid or renewable federal reef fish for-hire permit, and is still participating in the Southeast Region Headboat Survey (SRHS) must participate in the program.
The opt out alternative makes things too confusing. None of this is really mandatory. While all current LHV would start out in the program, any operator could opt out immediately by
transferring or relinquishing their endorsement. This would then make the vessel eligible to fish under the recreational season for other for-hire operators.

Action 4, Landings History Vessel Endorsement or Permit:
We recommend Preferred Alternative 2: Establish an endorsement for LHV.
An endorsement is preferable to having a separate “headboat” permit because it allows for greater flexibility. A LHV operator who wants to stop fishing under Amendment 42 could sell or relinquish their endorsement and fish under the federal recreational regulations and seasons. With a split permit, that operator could sell the headboat permit but would then need to find another for-hire permit that corresponds with its USCG Certificate of Inspection. This adds unnecessary burden. The endorsement alternative also allows new entrants the opportunity to get into the Amendment 42 fishery by acquiring an endorsement if they already have a reef fish for-hire permit.

Action 5, Allocation of Annual Catch Limit to the LHV program:
We recommend Alternative 5: For each species, allocate a portion of the recreational ACL to the LHV Program based on 50% average from 1986-2013 and 50% average from 2006-2013 (excluding 2010 from both time series).
The APs for both Amendments 41 and 42 have agreed on this alternative and we support it. If the Council allows opting out of the LHV Program, we would also support Alternative 6, where landings from vessels opting out of the program would be subtracted from the LHV allocation.

Action 6, Units of Measure for Quota Distribution and Reporting:
We recommend Alternative 3: LHV quotas are distributed in pounds and reported in numbers of fish.
NMFS would monitor landings weights and true up any variation toward the end of the year. This approach worked very well for us in the headboat pilot program and we support continuing it through Amendment 42. Additionally, we would trade quotas in units of pounds so there would be no problem with regional differences in fish size.

Action 7, Initial Apportionment of Shares:
•For Action 7-1, we recommend Preferred Alternative 4: Apportion initial shares amongeligible participants based on the year with the highest landings by vessel for each speciesduring the most recent five years (2011-2015). This lets all participants base initialallocations on their best recent year prior to the control date.
•For Action 7-2, we recommend Preferred Alternative 2a: Distribute ALL initial sharesproportionally based on average landings during the time interval selected in Action 7-1.This means initial allocations would be based on our catch histories. We do not supportequal distributions of initial shares. We also do not support auctions for headboat quotaallocations.

Action 8: Transferability of Shares:
We recommend Preferred Alternative 2: Require a valid reef fish for-hire permit with LHV endorsement to receive shares through transfer.
We support quota transferability and believe that requiring a for-hire reef fish permit with headboat endorsement will keep quota among Amendment 42 headboats and qualifying vessels wanting to join the fishery.

Action 9, Maintenance of Shares:
We recommend Preferred Alternative 2: Require a reef fish for-hire permit with LHV endorsement to hold shares.
Similar to Action 8, requiring a for-hire reef fish permit with headboat endorsement would keep quota among the headboats and qualifying vessels wanting to join the Amendment 42 fishery.

Action 10, Transferability of Annual Allocation:
We recommend Alternative 2: Require a reef fish for-hire permit with LHV endorsement to receive annual allocation through transfer.
We want to be able to transfer both quota shares and annual allocation for maximum flexibility. Similar to Action 8, we want to keep shares and allocation among Amendment 42 headboats and qualifying vessels wanting to join the fishery.
Action 11, Share Ownership Caps:
We recommend Preferred Alternative 2: In each share category, no person shall own more shares than the maximum percentage issued to the recipient of the largest shares at the time of initial allocation.
Share caps are important for preventing fleet consolidation. There are different ways of setting caps. We support this one, where the maximum anybody could hold is capped at the highliner’s initial allocation.

Action 12: Allocation Caps:
We recommend Alternative 2: At any point in time, a person’s total holdings (from all accounts)
cannot be more than the maximum holdings attributed to a person.
This would mean nobody could lease in and land more than the share ownership cap (Action 11)
at any one time.

Action 13, Retaining Annual Allocation before a Quota Reduction:
We recommend Alternative 1, No Action. We do not see a need for this action in Amendment
42.

Action 14, Cost Recovery Fees:
We recommend Alternative 2, Option a: For each participant, cost recovery fees will be based
on the total value obtained by multiplying a standard price per pound (or per fish) of a given
species by the number of pounds (or of fish) harvested by the participant during the specified
time period. Option a would mean the average commercial ex-vessel price from the previous
year.
We support this alternative because it is the most straightforward and would be the most
predictable for our purposes. It is not clear that cost-recovery is required here (because the ex
vessel value of fish harvested in the recreational for-hire fishery is zero); nevertheless, we
support contributing to some part of management costs for Amendment 42.

Action 15, New Entrants:
We recommend Preferred Alternative 4: At the beginning of each calendar year, vessels with
valid for-hire reef fish permits that are not participating in the LHV program are eligible to apply
for an endorsement if the vessels are selected to participate in the SRHS.
This would allow qualified headboats to acquire shares and/or allocation to join the Amendment
42 fishery. Consistent with the AP, we recommend this be limited to vessels that carry over 49
passengers.

Action 16, Set Aside for New Entrants:
• For Action 16-1, we recommend Alternative 2, Option a: Establish a 1% set aside for
the LHV program. This would be a one time set aside.
• For Action 16-2, we recommend Alternative 2: Set aside shares would be distributed to
those who become eligible as new entrants by the time of apportionment of set aside
shares. This seems necessary if there are to be fair allocations to qualified new entrants.
• For Action 16-3, we recommend Alternative 3: No new entrant may receive more shares
than the minimum distributed during initial apportionment to an individual recipient. This
would ensure that new entrants do not receive initial allocations greater than allocations
of some headboat operators with reported catch histories. If the number of new entrants is
small, they could receive large allocations and that would not be fair to some headboat
operators with longstanding participation in the SRHS.

Thank you for this opportunity to present our comments and recommendations.
Sincerely,
Randy and Susan Boggs
37
01/31/2018Dylan Hubbarddhubbard@hubbardsmarina.comMadeira Beach, FL 33708Charter/Headboat For-HireLetter to the Gulf of Mexico fishery management council
January 31st, 2018
By: Capt. Dylan Hubbard, Hubbard’s Marina – MREP graduate

Hello, my name is Captain Dylan Hubbard and my family business has been fishing central west coast of Florida for nearly 90 years and four generations, plus I am a recent MREP graduate. We operate 6 federally permitted vessels both charter and head boats, and I represent the Florida Guides association as their offshore director.
AMs 41 and 42
We still hold to the fact that we would demand not to see this type of Allocation based management in the for-hire sectors in any way, it is overwhelmingly opposed by the nearly 80 federal permits we represent at the Florida guides association and also, by much of the recreational anglers who are the end users of our CFH and Headboat industries. As we have stated in previous public comments.
We would also like to comment that as far as AMs 41 and 42 are concerned we feel the both the CFH and Headboat ad hoc APs were heavily weighted in support of these amendments and did not show a true cross section of the industry. We would urge the council to consider this when weighing AP preferred and their ‘support’ for these allocation-based management systems.
38
2/2/2018 7:19:50Daryl Carpenter
reelscreamersft@aol.com
Louisiana
Charter/Headboat For-Hire
Amendment 41 and 42 - It is our understanding that this may come up in the form of a motion at some point during this meeting. I offer my comment and support in that AM 41 and 42 should be tabled at this time as it is apparent that the State sponsored management plans and EFPs are destined to move forward. AM 41 and 42 still have many issues and a lack of widespread support. Continuing to expel energy working on these amendments seems senseless as we move forward with State Management plans.
39
02/09/2018Randy Boggsreelsurprisecharters@gmail.comCharter/Headboat For-HireFebruary 9, 2018
Ms. Leanne Bosarge, Chairwoman
Gulf of Mexico Fishery Management Council
2203 North Lois Ave
Tampa, FL 33607

Dear Ms. Bosarge and Members of the Council:
As Manager of the former Gulf Headboat Collaborative, I write to correct two mischaracterizations about the Collaborative that have been asserted on the record at recent Council meetings.
As you are aware, the Collaborative operated under an EFP in 2014 and 2015 to test an allocation-based approach of managing the headboat industry. By all measures this pilot program was a success, in that we doubled the number of anglers we took fishing, reduced discards by approximately 50%, and increased profitability. We continue to urge the Council to approve Amendment 42 so that we achieve these improvements over the long-term.
At recent Council meetings, it has been suggested that the Collaborative did not provide a study about “angler impacts” that was allegedly owed to the Council and NMFS. This is incorrect. The Collaborative’s research partner, Professor Joshua Abbott with Arizona State University, provided a socioeconomic study about the Collaborative to NMFS in 2016 and also presented it to the Council at its August 2016 meeting. This socioeconomic study was described in sections 2.1 and 2.4 of our EFP application, and was required by Section D of the EFP itself. The Collaborative fully complied with its commitments. We did not commit to providing a study about “angler impacts.” We understand Professor Abbott is conducting related research on angler preferences, but that was not a requirement of our EFP.
In addition, it has been suggested on the record that anglers fishing on Collaborative vessels under the EFP were unsatisfied because on some vessels they were limited to catching one red snapper or gag. This suggestion is absurd.
Some Collaborative vessels chose to stretch out allocations across a much larger number of anglers and trips. And from my own personal experience running headboats for decades, I can assure the Council that anglers on my vessels were absolutely thrilled at the opportunity to fish for red snapper and gag throughout the entire year. These fisheries are usually closed. From my observations, anglers certainly preferred being able to go fishing and keep one fish over staying at home for nearly the entire year. We were able to expand our customer base to serve a much wider variety and larger number of anglers. People that are normally shut out of the fishery were able to have a great experience.
For example, retired “snowbirds” are usually gone when the red snapper season opens in June. We were able to take them fishing for the first time in years. We also offered different types of trips that appealed to more anglers – like tourists who visit the Gulf coast outside of June, or locals who don’t want to compete for space during the derby seasons. Anglers appreciated the
flexibility we were able to offer. Other Collaborative members all reported similar stories on their boats.
With allocation-based management, we had the potential to provide year-round access to our fisheries. The Collaborative showed that this worked, because anglers wanted it. We were maxed out. If anglers did not like it, they could have voted with their feet. Instead, they were extremely satisfied with the improved access we were able to provide. We think this is a much better idea than the government telling us exactly which weeks or days a select few anglers can go fishing.
Thank you for the opportunity to correct the record.
Sincerely,
Randy Boggs
40
4/2/2018 11:14:47Gary Bahngrbahn@gmail.comOrange Beach, AL
Private Recreational Angler
My wife and I spend 3 months each winter down in Orange beach from Dec to March 1st. I enjoy fishing the shore line and also going out on Charter boats, to catch some of the nicer eating fish that the golf has to offer. Past few years we have been limited on taking Trigger fish and Amberjack, and No Red Snapper. A few years ago they did have a Red Snapper program that allow us to get a few of them, at that time I was not able to part take of that season. I am hoping that Amendment 42 would allow us a chance to catch some of these types of fish again. As you know we contribute a lot to the economy of Gulf shores and Orange Beach. So please pass on our concerns and comment to the members of the committee.
41
4/3/2018 7:32:06George McClanahan
geomcclanahan@sbcglobal.net
Orange Beach, AL
Private Recreational Angler
I know you are receiving emails regarding amendment 42 and I appreciate every thing you are doing to help us avid fishermen who go to Orange Beach and Gulf shores every year. Anything that can be done to let us keep some of our catch in January and February will be appreciated.

Thanks again
(Missouri snowbird)
42
4/3/2018 7:36:52Steve Perkins
steve.perkins1229@yahoo.com
Orange Beach, AL
Private Recreational Angler
I am part of the Snowbird group which represent’s all the Snowbirds that come down to the Gulf to fish. Now we don’t bring our boats down to fish the big ocean so we depend on the Charter boats to take us out but we don’t have a chance to fish for Red Snapper and even on our time down there for my favorite Triggerfish. I know the council relented to give us time in January but what about February when the weather is better just saying....now this email is really about Amendment 42 we desperately need to give us a chance for the Charter boats to regulate to Red Snapper season..you give the private boat owners 47 days in the summer with no regards to us..now you have to know what the Snowbirds bring to the Gulf states especially Orange Beach / Gulf Shores area where we go and put into the community over $130 million employ over 65,000 people plus money into our condo’s we rent.. with more being built to house all the Snowbirds ... but we can’t fish for Red Snapper... please consider our plight and hope you can bring this very important issue up to the council members..now I know there is a big push for the recreational fishermen by a certain group but without us snowbirds the Gulf communities would be dead in the water.. we couldn’t possibly deplete the the fishery in the time we are there with weather permitting fishing...Charter boats do a better job of regulating the fishing & Red Snapper.... thank you for your time and hope you understand our plight...
43
4/5/2018 8:17:30Rusty Reardonjjrj58@hotmail.comGulf Shores, AL
Private Recreational Angler
I am one of the Snowbird Fishermen who flock to Alabama Gulf Shores / Orange Beach area to enjoy the warm southern hospitality we receive during our stay and periodically interested in catching Red Snapper and Trigger fish during January and February. We believe how we support the economy of those areas during the winter months that other wise would be a ghost town into a thriving community of "Young at Heart" "Silver Haired" retirees. Just think how we keep "Urgent Care" facilities and restaurants in business. We are not asking to take more than our share of Red Snapper and Trigger fish, just a very small share of the many tons you allocate for the warmer months. So we support the passage of Amendment 42.

Emily, I'm confident you have the ability to share our perspective to the committee members in a way that makes it a fair and reasonable request to open up a modest season of Red Snapper and Trigger Fish during the months of January and February.
44
4/16/2018 12:07:52Eric Brazer
eric@shareholdersalliance.org
Gavleston, TXOther
Reef Fish Amendments 41 and 42
We support the continued development of these amendments. Tabling or postponing these proposals leaves the
charter/for-hire fleet without any viable alternatives for a stable fishery. These fishermen have been coming to this Gulf Council for years asking a solution and we question why the Gulf Council would take this opportunity away from them before they’ve had a chance to vote on it. This is especially relevant as Florida, Alabama and Mississippi do not seek authority to manage the for-hire component through their Exempted Fishing Permit (EFP) process and Texas is expected to follow suit very shortly (presently, only one state – Louisiana - would make for- hire participation in their EFP voluntary). We therefore ask that you continue to move Amendments 41 and 42 forward, advance them towards a referendum, and let the fishermen make this final decision once and for all.
45
4/16/2018 14:58:00Benjamin Kelleymisskelley29@aol.comPanama City Beach, FL
Charter/Headboat For-Hire
AMENDMENTS 41 AND 42

These two amendments have wasted a ton of money and time for me and for the Council Meetings. My boat over the last three years has averaged 976 red snappers per year. There is no way a plan where I only get 30 percent of the fish that I am currently catching will keep me in business much less get a vote from me. I will totally oppose these two amendments in an extreme fashion and will politic to make sure they never get passed. Amendment 41 and 42 will ultimately put many boats out of business and will do nothing to help the fishery. I think it is way past time to permanently table these amendments and get on with something that is much more important.

PLEASE PERMANENTLY TABLE AMENDMENTS 41 AND 42
46
4/18/2018 9:46:32Bob Zales IIbobzales2@gmail.comFL
Charter/Headboat For-Hire
I will not be present to provide my comments for public testimony so am providing them here. I will be at the meeting all day Wednesday should any of you have any questions.

After having communication with several fed permitted for hire vessel owners who were advocating for and pushing for for hire IFQs/catch shares I understand most have now determined that IFQs/catch shares will not work for the best interest of the fed permitted charter for hire sector. All know this has been my and those I represent position from the beginning of the process. The cfh sector is best served by fishing a set season with bag and size limits. Here is my particular example.

The federal season for the cfh sector has been between 45 and 49 days for each of the past 3 years. I have landed an average of 930 red snapper for each of those 3 years. Under the excel model tab b-12(a)1 for red snapper I would receive between 2550 and 3300 pounds, depending on the criteria selected which when divided by the 2016 average weight of 7.6 pounds provides only 335 to 434 red snapper, a 60%+ reduction in my current harvest. Under the model projections for trigger fish I would receive 26 fish and under amberjack I would receive between 17 and 30 fish. A catch share/IFQ system that only provides these small amounts will not work for my business. I am clearly much better off fishing a set season with the current bag and size limits. I submit that the vast majority of the cfh fleet is affected in the same way which is why those who once supported IFQs/catch shares now realize such management is not best for their business. For these reasons and all reasons I have provided in the past I strongly recommend that the council end all discussion and work on A41/42 and begin to concentrate your time, staff time, and financial resources on other important fishery issues.
47
4/18/2018 21:36:47Joseph BernhardJoeskfc@gmail.com34293
Charter/Headboat For-Hire
I have two headboats permits and operate an eighteen passenger headboat. The current Red Snapper fishery is horrible for me and my customers. It would be so much better if we could choose the days during the year that we go Red Snapper fishing for alot of reasons, ie.... not everyone can come and fish for them during June / July. June and July we have many people that want to go out and catch grouper, white grunts, sand perch etc... you know grandpa and the grandkids on vacation here they do not want to go out 80 miles, they want to just go fishing, so we have to loose their business in order to take the Red Snapper trips. Also, if we could pick our days, I would not need 50 days, 35 or 40 would be fantastic ie.. two or three trips a month would be great and much more productive. Another issue, I dont but I know headboats that do go out and catch Red Snapper during off season and we all know alot of them die. They do it cause they want the money and from a point of view I understand it. Please consider allowing us to choose our days to fish for Red Snapper with some kind of quota, days allowed, etc.... thank you for taking the time to read this.
48
4/19/2018 8:07:40Stan Phillips
destinfishinginfo@gmail.com
Destin, FL
Charter/Headboat For-Hire
Council members,
I am a federally permitted charter boat owner/operator in Destin, FL.
I would like to ask the council not to table amendments 41 and 42 at this time, and at least explore the option of including the other 4 major reef fish ( gag grouper, red grouper, trigger fish and amberjack) into a sector allocation scenario. Finally, I would urge the council to consider a Carry-over provision for the permitted for hire fishery.
Thanks for your consideration
49
4/19/2018 11:36:12Susan Boggsgonefishn@gulftel.comOrange Beach, AL
Charter/Headboat For-Hire
This represents 20 headboat permit holders and 28 headboats from all Gulf five states. This is 41% of the Gulf Beaufort Survey headboats. As we continue to build support, we will update this letter and forward a copy to the Council. As federally-permitted headboat operators who have reported our catches to NMFS for many years, we strongly urge the Council to move forward promptly on Amendment 42 to the Reef Fish FMP. Amendment 42 would implement a new approach for managing headboat fishing in the Gulf of Mexico. The recent Gulf Headboat Collaborative pilot program proved there is a better way to manage our fishery that increases angler access, reduces discards, and improves economic stability. We want to adopt this new approach as soon as possible.

We ask that the Council move forward with Amendment 42 so we can take more people fishing, better conserve fish stocks, and improve our businesses.

Joe Bernhard Miss Venice Sarasota, FL

Randy Boggs Gulf Winds II, Reel Surprise Orange Beach, AL

Rich Castellano Sundance II, Viking GulfStar Tarpon Springs, FL

Chaz Corradini Thunder Hernondo Beach, FL

Cliff Cox Sweet Jody Destin, FL

Chad Haggert Double Eagle II, Double Eagle III Clearwater, FL

Bill Little Fish’N-Express Port St. Jo, FL

Ricky McDuffie Miss E Orange Beach, AL

Greg Mercurio Yankee Capts Stock Island, FL

Charlie Paprocki Jubilee, Treasure Island Panama City Beach, FL

George Pheiffer Emerald Spirit Orange Beach, AL

Ed Schroeder Cavalier, New Buccaneer Galveston, TX

Eric Spaulding Gulf Queen, Super Queen Clearwater, FL

Lynn Swafford Zeke’s Lady Orange Beach, AL

Skipper Thierry Escape Dauphin Island, AL

Steve Tomeny Louisiana Golden Meadow, LA

Jay Trochesset Silver Dollar Biloxi, MS

Johnny Williams Capt. John, Texsun II Galveston, TX

Kelly Windes Destin Princess, Destiny Destin, FL

Gary Zink Eddy Lee Z Cortez, FL
50
4/20/2018 7:25:10Dylan Hubbard
dhubbard@hubardsmarina.com
FL
Charter/Headboat For-Hire
Hello, my name is Captain Dylan Hubbard and my family business has been fishing central west coast of Florida for nearly 90 years and four generations. We operate 6 federally permitted vessels both charter and head boats, and I am here today representing my family business and my family’s business history alone. It’s not easy loosing time away from work, my family, and my dog to follow this council around the gulf but my family’s long history fishing the Gulf is worth protecting to me and makes me more driven to get through these meetings and stand up here today. I have recently completed part of the MREP program this past fall and will be attending the science portion of the program this coming week. If you haven’t had a chance to join the program, I would strongly encourage you to do so and I hope it continues to grow and flourish.

AMs 41 and 42
Why bother pushing these back to the APs when they both are heavily weighted in glaring support for these amendments. I feel the proposal from Jim Greene was more realistic and more equitable than the AMs 41 and 42
51
4/20/2018 7:44:08Greg Ballinfo@joinGPBA.orgGalveston, TXNGO
Thank you for the opportunity to introduce the Galveston Professional Boatmen’s Association to the Gulf Council; we look forward to working constructively towards solutions for fishermen while providing the often overlooked or underrepresented perspective from professional fishermen in Texas. This association is dedicated to growing Galveston fishing opportunities, ensuring conservation and sustainability of our fishery resources, and enhancing the cultural heritage of our fishing communities. Our broad-based, growing membership represents a range of fishery stakeholder groups and interests. We appreciate the opportunity to formally address the Gulf Council.
The federally permitted charter fleet has demonstrated the ability to be constrained within their subcomponent allocation for multiple years and should be allowed to do so moving forward with the removal of the sunset provision on sector separation as well. Additionally, GPBA would like to see the council continue development and refinement of Amendment 41 and 42 for improved management of the federally permitted fleet. Despite concerns raised by some permit holders, these amendments offer the best and most comprehensive opportunity for improved management of the for-hire fishery to date. Further exploration and review of the decision tool by the appropriate advisory
panels should provide critical input and development direction for the council to consider this fall.
52
4/20/2018 7:58:59Tom Ardfairwater2@icloud.comOrange Beach, AL
Charter/Headboat For-Hire
I am the owner of 4 federally permitted charter boats, 2 six passenger and 2 multi-passenger vessels. I was unable to make the meeting public comment in Mississippi today so I wanted to express some of my concerns.
Amendments 41,42: I'd like to see these both of these catch share amendments go away. 41 will not work for my business and if 42 went forward it would be detrimental to my business having a head boat catching red snapper year around. I would lose business to Head Boats that are in my marina and fish right next to me. Remember head boats and charter boats take the same customer, they drive up in the same cars and go fishing on the boats they choose. With them having red snapper year around would be a unfair economic advantage to this group. I want to keep all Charter Fishing opportunities to be fair for all and I prefer seasons given in Amendment 40.
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Capt Ed Livelylivelyonefishing@aol.comCharter/Headboat For-Hiretable am 41 and 42 til stock assessment is complete
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