Reef Fish Amendment 41 (Responses)
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10/6/2015 20:02:25joe nashcaptjoenash@gmail.comgulf shores, al. 36542Private Recreational Angler, Charter/Headboat For-HireI am for sector separation, any way we can get this would help with the electronic logbooks you will know at least how many fish were caught by both the commercial and for hire sector at any given time, a no brainer. I am for regional management for the RECREATIONAL anglers, this may help them get the target days they would like, but no regional management for the charter for hire, lets get separated now for good, we are not under the same rules now and never have been we have always been separated but recreational anglers never knew that. thank you for your time.
Headboat program should stay intact they showed good management, we would like the same opportunity.
10/20/2015 8:14:40William PenningtonWbrp@comcast.netCollinsville, Ms 39325Private Recreational AnglerI have a lot invested in a boat and a house on the coast(Dauphin Is) it is difficult formed to get in more than one or two trips a year for red snapper. The short season often encourages people to go out in marginal or unsafe weather conditions.
10/20/2015 9:06:51David Waltersdavid@rives.comMt. Brook, Al 35243Private Recreational AnglerPlease vote to reject this amendment. This is ridiculous. The commercial and charter boat businesses should not be allowed to own the red snapper.
10/20/2015 9:28:54Sam BowenBbowen@bnspc.comGulf Shores,AL,36542Private Recreational AnglerAmendments 41 and 42 should be rejected in total. As soon as the fishery is privatized the private angler will be excluded, as we will not have the time or resources to fight for our share of the red snapper. The Feds should manage it, though should be fair and equal division. Currently we have 10 days in a row, only maybe half will be fishable days and only one weekend. How can a working man find time to fish for snapper? Every day I fish all I can catch is red snapper because of the horrible mismanagement of this resource. Give us more weekend days and a longer season at the least, as there are no other fish for us to catch anymore.
10/20/2015 16:28:27stephen bowensrbowen@mysylacauga.comequality, AL 36026Private Recreational AnglerPlease do not pass more laws that will further prevent individual anglers from enjoying sport fishing. The season was 10 days only this year with a limit of 2 fish per person.
10/22/2015 18:26:11Capt Cliff CoxSweetjodyfishing@gmail.comDestin, Florida, 32540Charter/Headboat For-HireI am in favor of Amendment 41. The CFH sector needs it's own management plan
10/24/2015 21:06:39j denny kearleymckearley@bellsouth.netdaphne, al. 36526Private Recreational AnglerThis amendment and amendment #42 are significant in that new methods are being considered without the inclusion of private anglers, once again. The only new amendment that needs to be considered, is one that corrects the inequalities introduced in the original plan where 80% of the fish are given to a few thousand commercial and charter fishermen while millions of private anglers are left with a pittance. If an allocation method is to be considered, it should consist of tags being issued as license are purchased whether the are to be used on private or charter boats. I noticed that this is not one of the options. Also, if the council would like suggestions that are fair, please considered not allowing any charter or commercial fishermen to harvest fish within 20 miles of the shoreline. This would prevent over harvesting in this area and still allow the larger boats in the commercial and charter industry to have almost unlimited space.
I will wait with great anticipation to see these two proposals to show up on the docket.
11/1/2015 9:07:04Thomas Vordenbaumtmv36830@yahoo.comAuburn, Al 36830Private Recreational AnglerAs someone who has just retired and was looking forward to fulfilling his lifelong dream of moving to Orange Beach, Alabama and deep sea fishing, I ask that amendment 40 and 41 be rejected in its interity.

It is the individual that brings the most dollars to the gulf areas. By privatizing fisheries management so that it can be manipulated to the commercial fishermans best interest makes me second guess my decision to retire to the beach area.
11/9/2015 22:50:05Christopher Bartoninfo@reeldiversioncharters.comBradenton, FL 34212Private Recreational Angler, Charter/Headboat For-Hire, Commercial FisherI think the best management option for both charter and headboats regarding ARS, would be to develop an IFQ style system. This would allow the vessels to be able to fish for this species when they are most prevalent in their local waters. It would also allow a more accurate measurement of the amount of fish caught each year,
11/13/2015 10:40:40F J EickeCaptEicke@AOL.comOcean Springs MS 39564Private Recreational AnglerSeparating the "components" of the recreational sector is a fabrication from the MSA and the amendments to then consider allocation and management based on charter and headboat "components" is therefore ridiculous. When a federal agency violates the basic principles on which it functions (read: Gulf Council), other steps are needed to either rein-in the agency or eliminate them from management responsibilty for a public resource. State management is the answer since states have a record of successful management and now have the data-bases to do so in a responsible manner. Amendments dealing with Sector Separation and the follow-on that would allocate under this illegal provision are therefore beyond the pale and should be killed before they become policy - so we do not then have to live with policy that harms the public good and a vital public resource. The Gulf Council is about to kill the private recreational sector (including the charter captains although the influence on this group tells them otherwise).
12/12/2015 21:11:25michael shortgethookedcharters@yahoo.comgalveston, tx. 77554Charter/Headboat For-HireAll for Amendment 41. Let us (CFH) figure out the best way to run our own business.
2/16/2016 10:45:13thomas adams4tomadams@gmail.comport st joe, fl 32456Private Recreational Angler, Charter/Headboat For-HireThe things that should NOT PASS this hand picked ,red snapper CFH committee are

VMS required on every permitted cb
Required electronic trip reporting for every trip
Catch shares, IFQs for permitted CBs
Possible coops for CBs where local individuals will be responsible for quota distribution
Allowed intersector trading of red snapper between commercial and CB owners and allowed use of red snapper commercial quota owned by CB dual permit owners for charter use

Most of these issues, especially-- intersector trading and VMS for all Federally permitted charterboats, have been discussed at great lengths and have been told it would never happen in the CFH sector. I have 2 boats and know of 10 other boats in our area Mexico Beach, port St Joe that do not support any of the above actions that the ad hoc committee may talk about or support.

As we have done previously, there should be a vote by the permit holders not by this committee, or the Gulf Council.
3/17/2016 17:27:51F J EickeCaptEicke@aol.comOcean Springs MS 39564Private Recreational AnglerThere should be no [repeat NO] move to put the charter-for-hire or headboats under a system comparable to the IFQs in the commercial sector. This would result in the same diminution of the number of boats available to the public and likely an increase in charges from the boats holding such shares. The Gulf Council should never - eventhough it already has - assign a property right to a group that will concretize the allocation and deny new captains from entering the fishery. Such a move would virtually be establishing a multi-member monopoly and that is un-American in every sense.
4/11/2016 16:56:04Charles Turnercturner@elmore.rr.commontgomery, AL, 36022Private Recreational AnglerI do not agree with removing the sunset clause of amendment 40. There seems to be some movement in the commercial sector allowing recreational activities under the guise of commercial use. I feel charter and commercial should be combined if the original commercial allocations will be used to circumvent recreational restrictions.

I appreciate ya!

Chuck Turner
5/18/2016 9:41:03Kevin Lanierkclanier@gmail.comMexico Beach, fl. 32410Private Recreational Angler, Charter/Headboat For-HireSport Fisherman are one group. The resource belongs to the people and not the permits. There does not need to be a separate management plan for Charter/Head boats. I fail to see why you feel it is necessary to separate the 2. All Sport/Recreational fisherman should have equal access to all fish no matter what they choose to ride on. One plan for sport and one for plan for commercial. Instead of making things more complicated like government normally does. try making it simple.
5/26/2016 12:39:51David Patlovanydjpat@sbcglobal.netHouston, TX 77059Private Recreational AnglerAmendment 41 needs to be eliminated. Federally Chartered Guide Boats are NOT recreational fishermen. They are business owners that own a COMMERCIAL business. They are taking RECREATIONAL ANGLERS out onto public waters to fish for a public resource that is equally owned by ALL recreational anglers, whether they own a boat or not. ALL recreational anglers, whether they are on a private boat or a for-hire boat need to be managed under the SAME federal catch restrictions. Reserving a portion of the RECREATIONAL catch allowance for COMMERCIAL business operators is not legal. Let all recreational fishermen follow the same seasonal restrictions and fix the management of the red snapper fisheries so they are handled by individual states that are better equipped to manage local fishing pressures.
8/17/2016 18:02:51Gordon Burdettecaptgburdette@gmail.comOrange Beach Alabama 36561Charter/Headboat For-HireI want to send in this comment to show my SUPPORT FOR AMENDMENT NUMBER 41. I was unable to attend todays meeting in New Orleans, but did listen to WEBINAR as I always do. Thank you for all that y'all do and I also appreciate our nice Red Snapper Season 2016.
10/12/2016 7:01:24Eric haeckEhaeck@hawkinsserviceco.com33572Private Recreational AnglerHave to go out 30 plus miles on the west coast of Florida to catch ARS! Need more than 9 days. If a handful of commercial permit holders are making millions by selling their fishing rights then your system is broken.
2/8/2017 11:13:48Christopher Seabrook TX, 77586Private Recreational AnglerI do not agree with the laws on red snapper. The laws make it difficult for recreational anglers to want to go deeper offshore when the number 1 fish caught isn't able to be kept. We first need to abolish the sea lord gang. There is no other industry that let's 50 people have a monopoly of the resources gathered. I also think there needs to be tags that recreational anglers are given each year and we can use these tags at anytime in the year for recreational angler last year 9 days x 2 fish = 18 tags. Last year because of the tropical storm, I was only able to fish 1 day out of the 11 you so graciously gave us for the endangered red snapper. But this is how you want the recreational fisherman to be. I feel you are slowing trying to stop recreational fishing and have the snappers caught only by commercial fisherman. This is unacceptable.

Chris Wilke
3/22/2017 9:29:21Christopher 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.
4/1/17Shane Cantrellshane.cantrell@icloud.comGalveston, TXCharter/Headboat For-HireIntroduction Charter Fisherman’s Association (CFA), the largest federally-permitted for-hire industry association in the Gulf of Mexico, aims to establish an allocation based management plan to increase the stability of fishing businesses, provide access for the non-boat owning public, and ensure fishing occurs at sustainable levels while improving accountability. The charter f0r-hire (CFH) industry has unique characteristics and designing such a system will require novel solutions and approaches. The following identifies key aspects that should be addressed or considered in the design of an allocation based program, and, where possible, offers guidance on how to tackle them. When specific guidance could not be identified, we suggest lines of inquiry which could yield the necessary specifics. Our proposal is a compilation of positions and recommendations on the direction and design of Amendment 41 to the Gulf of Mexico Reef Fish FMP, informed by the meetings of the charter for-hire (CFH) Advisory Panel (AP), the recent joint AP meeting between the CFH AP and Headboat AP, Gulf Council discussions and presentations, and extensive discussions within the industry and with technical experts. Guiding statement: The CFH fishery should be managed under a catch share program that provides the best opportunity for active charter captains throughout the Gulf to have stable and profitable businesses and enhances customer access while ensuring the sector fishes sustainably and accountably. Program Goals 1. Increase fishing opportunities for anglers who use the federally managed charter for-hire fishing fleet. 2. Retain the character of the fishery and the number of active fishermen, avoiding consolidation and shareholding by non-active participants. 3. Reduce management uncertainty through improved catch and discard accounting. 4. Ensure fair and equitable allocation for all participating permit holders. 5. Promote fleet stability. 6. Enhance sustainability by improving catch monitoring, adhering to quotas, and reducing dead discards. 7. Contain sufficient flexibility for stakeholders and the Council to address social, economic, and environmental priorities that arise during the execution of the program (for instance, allowing for new entrants into the fishery, addressing discard concerns as stocks shift or expand in range, etc.) Program Type: Permit Fishing Quota (PFQ) Position: CFA recommends a PFQ-style system with limited tradability and with shares of fish assigned to the for-hire permit. Rationale: Many in the CFH industry are concerned about two issues that have arisen in Individual Fishing Quota (IFQ) programs: consolidation and shareholding/leasing by people who do not actually fish. To avoid these potential issues, we recommend pursuing a Permit Fishing Quota system. Since the shares in a PFQ system cannot be held separately from the permit they are assigned to, a shareholder would not be able to accumulate “investment” shares
and add them to a single permit, which would invite consolidation. This prohibition on accumulating shares also would help to prevent individual shareholders from acquiring more shares than they are able to fish solely in order to lease out the associated allocation for profit. Although there are additional measures that should be put in place in order to address these issues, we believe that a PFQ system is better aligned with the goals of preserving the character of the fleet and ensuring that the allocation-based system benefits the industry as a whole. We realize that tradability becomes more challenging under a PFQ system, but we encourage NMFS and the Council to continue to engage with the industry on what types, and the extent to which trading can occur to alleviate concerns over initial allocation, geographic needs of share distribution and the uncertainty about active vs. inactive permits. Single Species vs. Multi-species Program: Position: The CFH program should include multiple species of reef fish. Rationale: At the January 2017 joint meeting of the CFH and Headboat Advisory Panels, the most broadly-supported consensus item advisors issued was a need for the CFH program to include five species of reef fish that are instrumental to the CFH industry in the Gulf: red snapper, greater amberjack, gray triggerfish, red grouper and gag grouper. The reasons for this are varied, but most critically: 1. Geographic differences in targets. Fishermen across the Gulf region have different needs, variable access, and selective preferences for different species, largely dependent upon geography. A multispecies program for these key reef fish will enable fishermen to work within the CFH industry to access the fish they need and redistribute the fish they do not. 2. Equity across the for-hire fleet. The Landings History Vessels included in Amendment 42 are expected to have a multispecies program, which the CFH industry supports. However, a one- species program for one segment of the for-hire fleet and a multispecies program for the other subcomponent will create an unbalanced playing field, favoring those fishermen who participate in the program under Amendment 42. A multispecies program for the CFH and headboat subcomponents will foster a stable, fair, well-functioning for-hire industry in the Gulf. 3. Reduced bycatch/increased efficiency. One of the most challenging problems currently facing our industry is short seasons. Amberjacks closing on March 24 and trigger fish being closed all year are a perfect example. Under a multispecies program, fishermen will be able to manage our businesses to reduce the impact of these closed seasons and to target species that our customers want. We will also be able to keep and account for fish we catch. This will help prevent overfishing, provide more stable access and create a more satisfying experience for our customers. The CFH AP should be reconvened as soon as possible to discuss the contents of the Council’s Reef Fish Management for Federally Permitted Charter Vessels (White Paper), including the Annual Catch Limit Allocation (2.1) section. We request that the Council/NMFS incorporate data for gray triggerfish, greater amberjack, red grouper and gag into the initial allocation decision tool produced
for Amendment 41 in advance of the next CFH AP meeting, so that the CFH AP can assess the various per-permit initial allocation scenarios of the species other than red snapper. Eligibility Position: All federal reef fish permit holders are eligible to participate in the program. Rationale: From the beginning, CFA has operated on the principle that any program must be fair to all permit holders. We are committed to that principle and we urge the Council and NMFS to continue to develop Amendment 41 with that fairness in mind. Initial Allocation Distribution of initial allocations is always the most challenging aspect of any catch share program. For amendment 41 this is particularly the case due to the lack of per-vessel landings history. Regional recreational landings data is available to use as a proxy, but is inexact and in some cases does not reflect historical catch well. Its application alone would not be “fair and equitable” in the eyes of many in the industry. The Council presented a mixed approach to an initial distribution formula for red snapper, which includes regional data from MRIP, passenger capacity “tiers”, and equal distribution.1 Altering the weight given to each component of this formula did not substantially change the initial allocations; again, when diluted over the unknown number of inactive permits, the initial distribution is viewed as inadequate by many who depend upon red snapper. To address this issue, it is recommended that the Council and NMFS: 1. Continue to examine allocation formulas that take into consideration MRIP regional landings, tiered-passenger capacity, and biomass concentrations of reef fish species. 2. Explore cyclical redistribution. At the Joint AP meeting in January the advisors were split on the decision whether to launch the CFH program using an allocation formula for initial distribution followed by cyclical redistribution, or to first wait for electronic logbook (ELB) data to identify active vs. inactive permits prior to initial distribution of shares. CFA recommends proceeding with the CFH program exploring a variety of the proxies previously mentioned for initial allocation, followed by cyclical redistribution of shares based on the determination of “active” vs. “latent” (“latent reclamation”). If prior to the implementation of the CFH program the ELB program is implemented and active permit data becomes available through the submission of log book reports, this information should be taken into consideration in the initial distribution of shares. 3. Establish a mechanism for permit holders to trade in fish, so that CFH operators who depend heavily on one species of fish can trade their allocations of the other reef fish species for species and vice versa. In this way, regional needs for allocation can be addressed. A 1 Establishing employment in harvesting, investments and dependence on the fishery and participation of fishing communities, required to be considered under the Magnuson-Stevens Act (MSA), is similarly difficult for the CFH industry. Suggestions by the CFH Advisory Panel to utilize documents such as tax returns, state guide licenses, etc. to demonstrate investment and activity were rejected by NMFS.
mechanism that would allow the “barter” of allocation without the need for money to change hands is preferred. Share Maintenance Position: Shares should be redirected over time to active permits through latent reclamation and proportional cyclical redistribution, on cycles to be determined. Rationale: We strongly support cyclical redistribution of shares, intended to move quota off of latent permits and on to active permits and accommodate regional needs. Based on an initial assessment of the White Paper (and subject to more discussion by the CFH AP), we believe our position accomplishes several goals: 1. Latent reclamation will a. give active fishermen access to the fish they need; b. prevent inactive permit holders from perpetually leasing out allocation for profit; and c. facilitate the achievement of OY. Latent reclamation (as opposed to comprehensive reclamation) also does not unfairly divest active fishermen of shares. 2. Proportional cyclical redistribution works to direct fish where they need to go by a. redirecting the quantities of shares to those who fish the most; b. redirecting types of shares of particular species to those who target those species in the regions where they are available; c. increasing the shares of those who obtain allocation through leasing, which can accommodate new entrants and business expansion. Additional decisions need to be made, and should be explored by the Council, including: a. Establishing a threshold number of fish that would need to be landed in order to qualify a permit as an “active” for-hire permit; b. Establishing the reclamation percentage; c. Determining the appropriate timetable of cycles (set vs. progressive, intervals of years, etc.); d. Exploring the consideration of passenger capacity in redistribution; e. Creating an appeals process for inactive permits that did not fish due to documented health hardships, serious equipment failure, or other appropriate factors; f. Setting aside a small percentage of divested shares to establish a share reserve, for grievances in allocation, new entrants, shifting stock distributions, research, etc. Transferability Parameters Position: The CFH program should allow the transfer of allocation only, between eligible reef fish permits (White Paper Action 2.3, Alternative 2b). Rationale: The ability for fishermen to transfer or trade portions of their annual allocation can be useful for addressing bycatch, ensuring allocations can move to where the species is most needed, and for responding to unexpected business needs and problems which would prevent fishermen from fishing temporarily. Many CFH operators do have concerns about the possibility that shareholders in a CFH allocation-based program could decide not to fish, retain their shares, and perpetually lease allocation to active fishermen, which could make it difficult for new entrants or smaller businesses to grow their investments. CFA opposes such action and is encouraged by the clarification in the White Paper that, through proportional redistribution, those who obtain and use allocation by leasing from another permit holder would be able to
claim that use as landings history, and qualify for increased shares.2 To further address this concern, we request the Council to: 1. Clarify that permit holders that lease out allocation to other permit holders are not considered to have “landed” those fish, and so will not be credited with those landings for redistribution purposes (except in verified cases of hardship); 2. Explore allocation transfer maximums to restrict the amount of allocation each permit holder is allowed to temporarily transfer to another permit holder to a percentage of the overall allocation holdings each year. (For example, only 25% of a permit holders’ allocation could be transferred each year) 3. Develop a preference for barter or fish-trading over allocation transfer for cash. The White Paper makes clear that in a multispecies program, barter in species is possible using existing mechanisms. To further disincentivize perpetual leasing by inactive permit holders, NMFS should consider methods to make barter for species easier or more advantageous to fishermen. Appeals Process The Magnuson-Stevens Act requires that NMFS establish a process for appeals concerning initial allocation in a LAPP program3. The CFH industry recommends establishing appeals processes for each major decision point which impacts fishermen, including those related to the divestment and cyclical redistribution of shares and limits on leasing allocation. Appeals should be available to ensure that the program is meeting the social goals of the program. Share Caps The Magnuson-Stevens Act requires that LAPP programs include a percentage-based share cap to prevent any particular shareholder from acquiring an “excessive share” of the overall privileges.4 We strongly support this requirement but do not have enough information to suggest an appropriate number for this – it will need to be determined through modeling. A share cap should be set that is high enough to ensure that high-liners (those who catch the most fish) can ultimately continue to fish at their previous levels and expand within reason, but also prevent the risk of too much consolidation. We request that the NMFS and Council explore a range of permanent share cap options that will address the social and economic goals of the program to prevent consolidation and retain the social fabric of the fishery. Monitoring & Validation 2 “Transferability of shares and/or allocation could allow fishermen to trade shares or allocation for species not common in their area with fishermen in different areas where the species is common. Particularly with a cyclical program, transferability could allow fishermen to have more landings of a species, and therefore, receive more shares at the beginning of the next cycle, depending on how the cyclical program is designed. Thus, over time, allowing transfers would help accommodate regional differences in species distribution.” (Reef Fish Management for Federally Permitted Charter Vessels, 3/23/17, page 12). 3 16 U.S.C. 1853a, § 303A(c)(1)(I). 4 16 U.S.C. 1853a, § 303A(c)(5)(D).
1. Participants should be required to use a NMFS-approved reporting device. CFH program participants should report landings electronically in a time frame that enables NMFS to track catch and allocation usage. 2. Participants should be required to hail in and hail out. Hailing in and out ensures NMFS is alerted to fishing activity and that what a fisherman reports on the water can be validated at the dock by law enforcement. This is crucial to make sure that the allocation- based program is working as intended to keep the sector to its quota and keep the fishery sustainable. 3. Participants should be required to use a NMFS-approved landing site. In order to ensure catch reports can be validated, participants should be required to use NMFS- approved sites that are verified as accessible to law enforcement. Future decisions As the current version of Amendment 41 recognizes, several other decisions will need to be made, including the method for determining cost recovery fees, eligibility criteria for a referendum, how to manage quota adjustments, and accountability measures in the event the CFH industry were to exceed its quota. As these issues have not been thoroughly explored by the AP or the Council at this point, we recommend including these considerations in future CFH AP agendas and Gulf Council presentations for discussion and deliberation. Conclusion Status quo, derby management of the CFH industry can result in unstable, precarious businesses and reduce the viability of future investments by new entrants to the industry. While we commend the Gulf Council for its progress toward improving data collection in the for-hire industry during its most recent Council meeting, data collection alone does not go far enough. Charter operators need flexible, predictable access to the reef fish that are most important to the success of our businesses and the memorable experiences of our customers. An allocation-based management system for our sector is a proven way to stabilize our businesses, deliver quality, flexible access to our customers, and ensure sustainable fish stocks for our nation’s future.
5/2/2017 22:12:47Chad Heitmanchad.heitman@yahoo.comAlvin, TX, 77511Private Recreational AnglerSo, allowing recreational anglers to go out and fish for Red Snapper then have to pay Market Commercial Cost is right? Time to end all commercial for sell Red Snapper fishing. More of this is wasted in restaruants than anywhere. Basically this is strictly set up for the big Commercial fishing industry that rapes the resource. Seen this in Texas with the Red Drum. After commercial fishing for Red Drum was banned fish stocks are exploding. So, the issue is with the Commercial Industry. If people want fresh fish let them go catch it. Some want to and this Council is keeping them from doing that. Want to find where regulations start? Follow the money trail. Terrible abuse of the recreational fishermen!
5/4/2017 18:07:11TRENT FORDtford.fei@suddenlinkmail.comRussellville, AR 7802Private Recreational Angleri have been fishing the Gulf of Mexico for Red Snapper and other species for 30 years. I travel to Grand Isle for one week out of the year to offshore fish. The fact that the season has be cut to 3 days is absolutely asinine. My annual observations and those of my mates are that the snapper stock is a good as its been in at least the last 20 years. The fact that you have allowed the charter captains to have a 49 day season while the recreational fisherman get 3 is insane. i have read several of the studies conducted to make this determination and the math the use is not the same i learned in school . GIVE CONTROL TO THE STATE, THEY SEEM TO HAVE A CLUE.
5/23/2017 12:22:24Mark Vinsonlineslider10@gmail.comLeesburg Florida 34748Private Recreational AnglerAmendment 41 and 42 should be abandoned, this will basically put the recreational fisherman completely out of the water. As is stands now we the recreational fisherman can only keep two Red Snapper and they have to be at least 16 inchs were the commercial is allowed 400 to 500 lbs per trip. this is not about the fish it's about money, we all know that the commercial fisherman lively hood and about the needs but why is it when it comes to regular people just out to catch fish for fun or sport the rules are against them before you ever leave the dock. this State and Federal waters is so stupid it funny. If you live in the middle of the state as I do you have to go 30 miles off shore to get into 30 feet of water so fishing for Red Snapper is not happening in State Waters, only in Federal waters and for only 4 Days. So lets try to come up with a mandated season for Red Snapper that everyone can enjoy instead of just the Commercial Fisherman. I can't believe everyone on this council has know idea of what they are talking about but every time you get together something more ridiculous comes out. Maybe you should put some of these questionable rules out to the public to vote on and lets see where everyone stands on the issues. Maybe this will help you in the future of Fish management, and by the way I have never seen or had a Scientist on my Boat or in the area of the fisheries.
6/5/2017 8:16:10Ryab Bradleymscfuwebs@gmail.comLong Beach MississippiCommercial Fisher4.) Revised Draft Amendment 41 – Allocation-Based Management for Federally Permitted Charter Vessels (Tab B, 12a)
- MSCFU currently opposes any catch share (IFQ) program for charter vessels until the current commercial IFQ programs are modified to operate similarly to the way the charter vessel catch share program has been proposed. However, MSCFU applauds the Council and Council Staff for including language in this amendment that “continuously redistributes a portion of the shares to those participants landing catch share species on a set cycle”. This language is critical to the long-term success of any IFQ fishery and the lack of such provision in the commercial IFQ fishery has exposed potentially fatal flaws in the program in which shareholders have retired but continue to profit off of the “leasing” of shares even though they are no longer active in the fishery. New entrants must have the ability to utilize landing history to secure future allocations through a cyclical redistribution program. Also, there are concerns that individual fishing quota will be exchanged between the recreational and commercial sector and that could have the potential to undermine access to commercial individual fishing quota for small-share holders and new entrants operating under commercial fishing regulations whom have already been disproportionately impacted by the current IFQ programs since inception.
6/5/2017 8:18:42Ryan Bradleymscfuwebs@gmail.comLong Beach MississippiCommercial Fisher5.) Draft Amendment 42 – Federal Reef Fish Headboat Management (Tab B, No. 13)
- Similar to Amendment 41; MSCFU currently opposes any catch share (IFQ) program until the current commercial IFQ programs are modified to continuously redistribute a portion of the shares to those participants landing catch share species on a set cycle. Also, MSCFU questions the availability of recent landings history in the charter/ headboat sector to properly allocate shares.
6/22/2017 20:34:25Doyle
Mexico Beach,Florida 32410
Private Recreational Angler, Charter/Headboat For-Hire, Commercial Fisher
We have lost 6 days so far in our charter for hire business this federal season.. I would like to know if there is any consideration of giving us days to make up for the days of bad weather we have all missed.. Doyle Gaylor of Charisma Charters
8/9/2017 15:28:25Dylan Hubbard
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.
8/9/2017 16:02:42Jim
I 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.
6/6/17Steve Pappanintasticcharter@icloud.comMadiera Beach, FLCharter/Headboat For-HireAs a full time offshore charter owner/operator here in Madeira Beach Florida I would like to ask the council to exclude Gag and Red Grouper from 41. These species have been rebuilt and are not being overfished. In my opinion if they are not in any trouble they should be left out of the multi species part of 41.
Thank you for your consideration.

Captain Steve Papen
Fintastic Fishing Charters
6/6/17Erich Jaegermaverickfishingcharters@gmail.comPassagrille, FLCharter/Headboat For-HireI am a federally permitted charter boat owner/operator out of Passagrille Florida. Please consider removing red and gag from the multi species as this would ruin our business here in Pinellas county. We rely on these species day in and day out for our clients.

Captain Erich Jaeger
6/6/17Dan Haddoddoubleofishingcharters@gmail.comCharter/Headboat For-HireUnlike the large fish houses I am part of an under represented group of stakeholders the charter boat fleet we need a small but steady part of the total Catch we have a large impact on the tourism industry in Florida, the economic impact alone should be a consideration of where the Catch shares are allotted please consider the impact you have on a large voting block thank you Cptn Dan Haddon at www,
6/7/17Billy Noblebigsnookbilly@icloud.comFLCharter/Headboat For-HireSent from my iPhone
please do not include gag and red grouper in the multi species on amendment 41this will create an undue of substantiated hardship for the charter fleet in the southern Gulf of Mexico I beg of you to reconsider thank you for your time

Capt Billy Nobles
6/7/17Brandon Fraleyisheyecharters@yahoo.comFLCharter/Headboat For-HireTo whom it may concern,
My name is Capt. Brandon Fraley, I am the owner and operator of a federally permitted charter boat out of Clearwater Florida. My wife and kids rely on me to provide the majority of our yearly income. A huge portion of my business is charters targeting Gag and Red Grouper. Please consider removing them from the amendment. A shortened season would be catastrophic to my business and my family almost certainly causing us financial ruin or at the very least having to shut down my full time charter business. This is my 19th year in operation, I don't have any other options if charters stop coming.

Capt. Brandon Fraley
(727) 243-4082
6/7/17Brian Simmonsgotonesportfishing@yahoo.comFLCharter/Headboat For-Hireo whom this maybe concern,

My name is Capt. Brian Simmons owner operator of a federally permitted charter boat based of Maderia Beach, Florida called Got One Sportfishing.
Charter fishing is my only source of income to support my family and household. Over here on the West Coast our main portion of business is bottom fishing for Gag and Red Groupers. I would like to ask consider removing Gag and Red Grouper from the Amendment. Having such a short season for Gag and Red Groupers would be devastating to my business and also my family as I stated before this is my only source of income. This is my 5th year in business and adding those fish in the amendment would likely put me in financial harm or worse force me out of business. Thank you for your time.

Capt. Brian Simmons
6/7/17Lance Brooksfloridagrouper@aol.comFLCharter/Headboat For-HireMy name is Lance Brooks owner and operator of 3 federally permitted charter boats and 2 federal commercial reef vessels on the West coast of Florida. I vehemently oppose of adding red and gag grouper into the multi species of Amendment 41. The overwhelmingly silent majority would oppose this, in my opinion.
6/7/17Chad Hickmanchadhickman@embarqmail.comFLCharter/Headboat For-HireHi I'm Captain Chad Hickman. I'm a full time charter captain with offshore permits my business is Elcapitanos Offshore LLC. Operating out of the Tampa Bay Area. With that being said I want to make comments on amendment 41 and sector sector separation. If some of the proposals that I'm hearing about go through regarding red grouper and gag grouper it would kill my Business in the upcoming few years, by severely shortening seasons for those fish. I highly rely on these fish due to the fact that red grouper is open year-round and gag grouper is open for six months. With that being said the fishery for those fish are in very good standing in this area. Closing this down to me as a charter captain would put heavy strain on other species of fish that are even closer to shore and disrupting my client base who rely on these fish year after year. Please reconsider these actions.

Sense a VMS on charter boats is immanent... why can't this be implemented see what everybody catches in the next couple years in there areas then you can divvy out. Obviously certain areas of the gulf you catch different species more commonly than others... even though I am opposed to separating the fish quota. (Red Snapper commercial and recreational disaster)

Thanks for your time,
Captain Chad Hickman
6/7/17Bill Harmerseafarmerwd@gmail.comFLCharter/Headboat For-HirePlease do not include red and gag grouper within the multi species it would put gulf charters out of business .I believe that it is extremely important these species be removed from amendment 41 thank you
Captain Bill Harmer
6/7/17Jesse Mayerjamesgangcharters@yahoo.comFLCharter/Headboat For-HireIf grouper is not removed from this, it is going to truly hurt our charters boats!! It can be hard enough at certain times now. We depend on these species to be available as our fisheries are great.

Thx, Capt Jesse Mayer
James Gang Charters LLC
7/6/17Bill Fehlcc4eva@aol.comFLCharter/Headboat For-HirePlease do not include Gag and Red Grouper in the multi species of Amendment 41. You will put a lot of charters out of business. Large quantities of off shore clients won't book trips if these Grouper are closed almost all year. This part of Florida is a staple for these Grouper. You have already expanded the size for Gag Grouper which means less Grouper are being harvested.
Captain Bill Fehl Fishing Charters Inc
Sent from my iPhone
7/6/17Dylan 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 – 12b) Revised draft amendment 31 – Allocation-based management for federal permitted charter vessels
Chapter 2.1 – Action 1 – We propose Alternative 1 no action with an added option A that would make log book reporting mandatory like it is in the headboat industry. After a set amount of time like 3,5 or 7 years this could be reevaluated and by then there would be historical catch data to work from.
If alternative 2 is pursued, against our recommendation, we would highly recommend to the council that they utilize the headboat historical catch data to evaluated the geographic of the reported catch data because we feel there are many amberjack, red snapper, and trigger fish in the peninsula area of Florida they are not so concentrated in the northern gulf as we have heard discussed by the council. Working with the geographic data from the reported headboat landings before the initial distribution of PFQ or IFQ in the charter for hire sector would allow a more accurate distribution from the start, but allowing Alternative 1 no action then requiring reporting in our opinion is still the best course of action eliminating the guesswork completely once catch history can be established for this sector.
Chapter 2.2 – Action 2 – We suggest alternative 1 no action, if you are going to work through a complicated system such as this we feel it would need to be mandatory for the entire sector
Chapter 2.3 – Action 3 – We suggest alternative 2 with 2a-2e included if this type of management is going to be mandatory it should include all species listed. Also, it must follow the progression of Amendment 42 so they mirror each other per the Ad Hoc committee’s suggestions. If they don’t include the same species the public confusion will be insurmountable, and only make this a harder sell.
Chapter 2.5 – Action 5 – We suggest alternative 4 with option C we feel this would take into consideration historical landings by region while still distributing the quota equaling and all while weighing passenger capacity as main variable.
Chapter 2.6.1 – Adaptive management cycle we suggest alternative 2 with option b allowing a shorter cycle in the beginning spreading shares appropriately then it moves toward a more stable long-term system
Chapter 2.6.2 – Reclamation of shares we suggest alternative 3 with option A if the reclaimed shares are only those which are not being used
Chapter 2.6.3 – Redistribution of Reclaimed shares we suggest alternative 3 ensuring the unused shares are not given to someone while will once again not use them
Chapter 2.7 – action 7 – We suggest alternative 2 keeping the fishery for those are actively fishing it
Chapter 2.8 – action 8 – we suggest alternative 2 with added option A allowing a family to pass down their permit/endorsement with shares to a family member with federal permit
Chapter 2.9 – action 9 – We suggest alternative 2 ensuring active fisherman are the only ones eligible to receive the tags
Chapter 2.10 – action 10 – a cap is needed, but need more data specifically whether PFQ vs. IFQ because a PFQ cap could be much lower while an IFQ cap would need to be higher to accommodate a participant with multiple permitted vessels
7/6/17Steve Dossstevedossrealty@yahoo.comSt.Petersburg, FLCharter/Headboat For-HireIt is of great importance that gag and red grouper are removed from amendment. Thank you, Capt. Steve Doss, federal reef permit holder, St. Petersburg, Fl.
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