RF Amend 36A - Commercial IFQ Program Modifications
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1/19/2017 13:32:03Test Testertestingmode@tester.comTestville, FL 55555OtherThis is a test. This is a test. This is a test.
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1/26/2017 19:32:58William Copelandwillcope0929@gmail.comNew Port RicheyCommercial FisherWhen is the Gulf Council going to correct the totally biased and unfair mistake they made in the original distribution of IFQ shares, especially red snapper?

Your vessel statistics don't tell the story. 20 people control over 50% of the red snapper shares. I have an active reef permit with no IFQ shares. I should have been allocated my fair share when you activated my permit. If I don't catch close to my share allocation after a couple years you could adjust then and redistribute. This is the only fair thing to do. You have to give me the chance to succeed. Your biased and unfair policies were voted on in a biased and unfairly manner and continue unfair. You give 10's of millions of dollars to a select few kings and leave the rest of us serfs scurrying for the crumbs.
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2/1/2017 12:07:17Steven Craig Rashstevenrash@waterstreetseafood.comAPALACHICOLACommercial Fisher, OtherMy name is Steven Rash and I have owned and operated Water Street Seafood in Apalachicola for over 30 years. Water Street Seafood employs 60 people and processes and distributes seafood to customers all over the country. One of our main markets is the Gulf Coast. Water Street Seafood buys fish from over 20 boats and from many other fish dealers on the Gulf coast to distribute to the restaurants on the Gulf coast. Locally harvested grouper and Red Snapper are our two most popular products. Tourists and visitors come to the Gulf coast to enjoy our local seafood and Snapper and grouper are the top two items that the restaurants need to offer our visitors.
The IFQ programs implemented in the Red Snapper and grouper/tilefish fisheries have stabilized our supply and access to these fish. Water Street seafood has invested millions of dollars to insure we have quotas for our boats. Any restrictions on the use of the shares and allocations would have a disastrous effect on Water Street Seafood. The system is working and there is no need to change it now. Market prices for shares and allocations have been established.
If restrictions are imposed on the use and transfer of shares and/or allocations Water Street Seafood itself stands to lose millions of dollars and dozens of jobs will be lost at Water Street Seafood. In addition, our fishermen will lose millions of dollars in quota value as well as many jobs. Hundreds of jobs will be at risk in the restaurants and markets that depend on the commercial fishermen and the snapper and grouper they produce.
The total value of the Red Snapper and Grouper/Tilefish shares is almost $400M and up to $25M worth of allocation changes hands each year. Please do not destroy this with uneeded restrictions on a system that is working.

Thank You,
Steven C. Rash
President
Water Street Seafood, Inc.
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3/5/2017 13:19:40Jason Shaw4jshaw@gmail.com36576Private Recreational AnglerGenerally speaking, It seems the commercial industry is happy with the current rules. Meanwhile, the recreational section is in complete outrage. That says all you need to hear in my mind.

We are the common person trying to catch fish to feed our families. We are the common person trying to teach/pass on this great experience to our children.
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3/6/2017 20:13:53robert j knapprobknap2000@yahoocomseminole fl 33777Commercial FisherWhy not give the active permit holders that are leasing quota a percentage of any quota that is increased ,Any quota that is not used should be allocated to to active permit holders that are actively fishing it Why is it there is not a provision for permit holders that can not afford to buy quota that are leasing to be allocated based on their history and percentage of their history of leasing? Deep water quota has been decreased due to high lease fees that is why the effort is not there to fish for it Give back what was taken Use it or lose it when it comes to any ifqs and redistribute to active catching boats go back to fair and equitable The system was set up for a person to individually catch it if they cant give it back and be fair and equitable


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3/9/2017 9:40:03Scott Hickman Listodos@gmail.comLeague city Tx 77573Commercial FisherThe current ifq system
is working well. I would like the latent account shares to be distributed to new participants who are currently only fishing lease allocation to give them more of a stake in the fishery.
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3/12/2017 9:04:44William Copelandwillcope0929@gmail.comNew Port RicheyCommercial Fisher36A Action 1: I agree with Alternative 2
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3/12/2017 9:12:07William Copelandwillcope0929@gmail.comNew Port RicheyCommercial Fisher36A Action 2.1: I agree with Alternative 2 Option 2a and Alternative 3 Option 3a. Maybe you should go farther. If an account with shares hasn't been accessed in the last three years, those shares should be returned to NOAA.
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3/12/2017 9:27:01William Copelandwillcope0929@gmail.comNew Port RicheyCommercial Fisher36A Action 2.2: I agree with the concept in Alternative 4, but it should be landings in 2016 and 2017, not 2015 to be more current. I do not agree with your preferred Alternative 2 because it just gives more money/fish to the existing shareholders. Time to help out the guys who always have to lease allocation to harvest IFQ fish.
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3/12/2017 9:28:00William Copelandwillcope0929@gmail.comNew Port RicheyCommercial Fisher36A Action 3: I agree with preferred Alternative 2
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3/12/2017 9:29:48William Copelandwillcope0929@gmail.comNew Port RicheyCommercial Fisher36A Action 4: I agree with Alternative 1
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3/12/2017 9:43:10William Copelandwillcope0929@gmail.comNew Port RicheyCommercial FisherThere should be an action 5. NOAA fisheries should withhold a portion, say 10-20% of the red snapper allocation each year to lease to vessels without red snapper IFQ shares to help cover bycatch loss. Limits should be placed on how much and how often an account holder can lease this allocation. Only reef permit holders with IFQ accounts should be able to lease this allocation. This allocation can never be leased or transferred and must be issued to a specific vessel.
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3/12/2017 9:52:26William Copelandwillcope0929@gmail.comNew Port RicheyCommercial FisherThere should be an action 6: Only reef permit holders should be allowed to have IFQ accounts. This is a managed US government fishery requiring a commercial GOM reef permit to harvest these fish, and therefore only commercial reef fishermen should be allowed to participate in the IFQ program.
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3/12/2017 10:02:17William Copelandwillcope0929@gmail.comNew Port RicheyCommercial Fisher36A: There should be an Action 7: All IFQ accounts that have a lease for profit history should be closed and there shares returned to NOAA for redistribution. FISHERMEN need this allocation to make a living. Time to stop the stay-at-home lease-for-profit carpetbaggers. They are taking money from all the other hard working fishermen's pockets.
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3/12/2017 11:08:09Capt Bill Fehlcc4eva@aol.comSeminole, FL 33778Private Recreational Angler, Charter/Headboat For-Hire, Commercial FisherAction 1
Alternative 1: No action
Action 2.1
Alternative 2
Option 2A
Alternative 3
Option 3A
Action 2.2
Alternative 2
Businesses that are actually fishing in this industry should have the opportunity to harvest all species that are being regulated. I would like to have the option to sell or trade shares of species that I don't intend or have the capability to harvest for species that can maximize my percentage of the quota system.
Action 3
Alternative 1:No action
Action 4
Alternative 1:No action
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3/13/2017 9:12:35benjamin batemancapt_ben_bateman@hotmail.combrandon fl 33511Commercial FisherAction 1 : No Action.

it is rare that a commercial reef fish boat lands with no IFQ species

Action 2.1 : No Acton.

taking what is not yours is stealing. if NMFS wanted to take non active accounts shares NMFS should have made that a rule when NMFS started this IFQ system.

Action 2.2 : No Action

our country does enough redistributing as it is.

Action 3 : No Action

NMFS wants to give the regional administrator the power to take allocation during a fishing year? how much more power is the NMFS going to take away from the fishermen? why doesn't NMFS allow the fishermen to keep their allocation even to the following year if they do not catch it. let the allocation roll over year after year.

Action 4 : No Action

NMFS requires a vessel to notify NMFS when they leave. NMFS requires the vessel to notify NMFS with an approximate amount of catch they have 3 hrs before they land. NMFS requires that the vessel land at a designated landing zone. NMFS only allows fish to be unloaded between 6am and 6pm to a designated IFQ dealer. NMFS then takes 3% of the IFQ fish final sale from the fisherman's paycheck for "monitoring" fees.

with every new rule NMFS implements the fishing process becomes more and more inefficient in an already difficult profession.
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3/13/2017 19:25:39Capt Gary Jarvisgjabd@aol.comdestinCharter/Headboat For-Hire, Commercial FisherTo keep this simple and to the point I support these actions in Amendment 36 Action 1 Alt #3 all reef fish hail in
Action 2 Alt #2A effect final date & #3A effect final date. Action 2.2 Alt #2 equally amoung all sharholders, On action 3 Alt #1 No Action and lastly Action 4 Alt #1 no action. Thank You
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3/14/2017 16:27:40Jeff Sharnowskijsharnowski@yahoo.comCommercial Fisher, Other The Grouper IFQ program is achieving the goals set by the Magnuson Stevens Act and Gulf Council. Rebuilding of our fishery, eliminating the derby race for fish, improving safety at sea, and reducing discards. It is the best system that gives the Gulf Council the ability to control not going over the quota. It is a bit disconcerting as I listen to the webinars that some on the Council don’t know the difference between a share and an allocation. And your voting? A little history may be in order for you, ask about the derby days and boat conditions of the past vs now, much safer.
Yes, the fleet has been consolidated and it needed to be. Take a look back at all the illegal fishing there was compared to now. To many fisherman to few fish made some bad actors in our fishery.
In an IFQ program there will always be haves and have nots, lets concentrate on the have nots give them some skin in the game. I urge you to implement an (IFQ Finance Program) that allows the smaller fisherman to buy Shares. Being able to use them as collateral would help new participants enter the fishery with some skin in the game. I know you can barrow against a stock portfolio, why not against Shares? It’s because banks can’t put a hold on them, but you the Gulf Council can make it happen.
I hope you read this in open council, let the little guys know there is a way for them to obtain shares. Every industry evolves the trick in succeeding is to change with it. Use it to your advantage, the days of buying a boat and permit then going fishing are gone and not coming back. Remember when you didn’t need a permit, think those days are coming back? Buy Shares and invest in your fishing future. Think it can’t be done? I did it, borrowed (not from a bank they would not do it I borrowed against a CD) $35,000 for 5,000lbs of Red Grouper Shares, paid it off in less than 3 years with interest rod and reel fishing in SW FL.
36A I support
Action 1: Alternative 2
Action 2.1: Alternative 2 Option 2a
Action 2.2: Alternative 2
Action 3: Alternative 1 (No Action)
Remember that these are business and business don’t like uncertainty, if you are going to lower the quota that probably means the fisherman aren’t catching the fish. By lowering the quota, it will increase allocation prices and fisherman will not hit the quota you lower it to anyway.
Action 4: Alternative 1
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3/21/2017 0:00:30Rodolfo UriaRodolfo0707@yahoo.comTampa, FL, 33614Commercial FisherIn the matter of the upcoming changes to the regulations of the IFQ program would really positively impact fisherman as myself. I can not comprehend why we have to lease IFQ from other people that don't even fish themselves. We as fishermen have many expenses and risk our lives every day at sea. It is completely unfair how this program is currently managed. I believe that all IFQ allocations should belong to people that have the reef permit and no one else. People should not be allowed to separate the allocations from the permits because those people are robbing our rights, time and money without even going fishing or having expenses. I believe that Action 1 should stay with alternative 1. Action 2.1 should be preferred alternative 2 and a preferred alternative 3. For action 2.2 I would prefer alternative 4. For action three I would prefer alternative 1. For action 4 I would prefer alternative 1. Please do the right thing and give the IFQ shares back to the reef permit holders and take it way from the people that are sitting at home watching TV and leasing these allocations and making crazy amounts of money without doing anything.
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3/22/2017 9:28:17Christopher Dombkowskidaiwafan25@yahoo.comDayton, Ohio 45434 AND Cibolo TexasPrivate Recreational AnglerI 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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3/22/2017 9:39:18Christopher Dombkowskidaiwafan25@yahoo.comDayton, Ohio 45434 AND Cibolo TexasPrivate Recreational AnglerManagement of allocations needs to be reviewed under current climate conditions. The original allocations were set under the historical data gathered well before the shortening of seasons and stated depletion of stocks. The current situation with stated stock levels being low is allowing a small trust of commercial anglers a stronghold on nearly 50% of a public interest. Furthermore regulation on this public interest with an indefinite hold when a letter has been released stating that the last stock survey was highly inaccurate leaves the rec angler whose overall population interest and monetary contribution to both the marine sporting economy as well as the funding of all programs involved with the sustaining of these government programs is exponentially greater than that of the trust of the IFQ. It needs to be recognized that a reallocation is in order in that a small trust of commercial anglers should not have a strong hold of near half the standing yearly biomass of any such game fish and that a 25% take is and should be deemed acceptable till which time stock levels are determined to be sustainable to open seasonal fishing.
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3/22/2017 22:39:52Christopher Bartoninfo@reeldiversioncharters.comCortez, FLPrivate Recreational Angler, Charter/Headboat For-Hire, Commercial FisherI have a simple solution. Divide all shares/allocation equally amongst permit holders. For the sake of ease, lets say there are 100 permits and 1000 pounds of allocation available each year. Then each permit holder gets 100 pounds to do with what they want. This would have eliminated derby fishing when the IFQ program was established.
For the upcoming unused IFQ great giveaway round 2, have you contacted the shareholders that have unused shares/allocation since the program inception? I doubt it, or the shares/allocation would have been used or sold.

The only people that should be allowed to hold or lease shares and and allocation are permit holders.

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3/24/2017 18:26:54Amy Wirtzrbellies@hotmail.comTarpon Springs, FL 34689OtherI currently operate Pelican Point Seafood in Tarpon Springs, FL. Over the years the IFQ programs has been in effect, fishermen and dealers have learned how to work around this system. Action 1: noted the ARS IFQ additional program efforts may be necessary to deter fishermen from illegally landing IFQ species. I fully agree that more efforts must be made. Not only fishermen, but dealers are assisting this effort of illegally harvesting fish. This may be caused due to economic hardships, incentives for fishermen to fish for them, etc. There needs to be better ways of enforcing landings (times mainly, noted in Action 4). Action 4: I do not feel requiring dealers to notify in advance prior to offload will help solve this problem. It may only cause frustration on dealer, fishermen, and individuals waiting for the fish. More often than not, the dealer will be held up for an hour until their time is right to offload. More so because fishermen are never on time or land as planned and so on. As the saying goes, time is money. Fishermen do not always seem to understand this on the dealers aspect or the urgency for the fish. Fishermen and dealers know the system and will continue to hide fish, offload fish prior to the notification, etc. The notification will not stop them. It will only give them another obstacle to overcome. We cannot have an officer at every dock for every offload, but there has to be a better way to make it harder to illegally harvest fish. I do not have a solid solution, but I do not agree with more requirements that really don't solve the issues. If there is anything I can help with I am happy to do so. Use our dock as a tool if needed, let us help improve the efforts! Hopefully there is a better system we can collectively agree upon.
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3/26/2017 16:21:02Jeff Sharnowskijsharnowski@yahoo.comCommercial Fisher, Other After listening to the Webinar (36A) on March 22, 2017 @ 6pm.

I would like to request The Counsel put an extra box on the “Submit your Comment here!” Form especially on 36B (*Required). If they check “Commercial Fisher” add a box something like. “Did you buy your boat and permit, before or after the implementation of the IFQ program”. If they say before there should be a “date box”. Because I can see a few years before the program started getting a permit and not knowing the catch history or if the if the IFQ program would pass. But after, any one complaining after should have made a better business plan.

When I bought my boat (1999) I did my research, I asked questions. I knew all about the business part of Commercial Fishing. The Regulations, boat expenses, fishing expenses, were I was getting my supplies, what species and how many I could catch, who was going to buy my fish and approximately at what price. So, I could figure out when I would break even and make a profit. The only thing that was a mystery was if I could find and catch the fish.

If you bought your boat and permit after the implementation of the IFQ program. In your business plan, here are a few extra questions you should have asked and answered.
Where can I get the Allocations, I need?
Can I lock in enough Allocations to keep me fishing the whole year?
Is it better to lease Allocations or buy Shares?
If I buy Shares how many years will it take to pay them off vs leasing Allocations?
i.e. (What would be the equivalent in Shares, with the money spent on Allocations)

The Gulf Council should know if these new boat/permit owners did their due diligence, or if there just ignorant in what it takes to be a Commercial fisherman business owner. Fact is business fail all the time from being ignorant and it is not a defense. New business owners should know what they’re getting into.

Again, (from my last letter) I urge you to implement an (IFQ Finance Program) that allows the smaller fisherman the ability buy Shares (give the lender the ability to put a hold on them, use them as collateral). When I decide to sell my Shares, I don’t want to sell them to the big guys so they can get bigger. But I may be forced to, and to the ignorant people that say “just give them back” well, I paid good money for Shares so that I could fish all year long. It’s not a good business plan for me to give my money away. Would you?

In closing we need more info on the people giving comments, when did they enter the Commercial Fishery? Is there really something wrong, or were these people blindsided by their lack of due diligence. 36B Writers, do your due diligence go back and read Amendment 29… Thank you for your time, and please read this in open Council.


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3/27/2017 16:45:50Nicholas j Rellonrello2@gmail.comSouth Padre Island Texas 78597Charter/Headboat For-HireHow do I become a member
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3/27/2017 19:49:34Jeff Sharnowskijsharnowski@yahoo.comHi Jeff,

Thanks for sending your comments. I’ll modify the form so it allows the options for: IFQ Shareholder and Commercial fisherman separately. I’ll also forward your comments to the full council in both 36A and 36B.





Your Chum,
Emily Muehlstein
<*)))>< ~~~ ><(((*>
Public Information Officer
Gulf of Mexico Fishery Management Council
www.gulfcouncil.org
(813)348-1630 ext.238

That's a start but I'm not sure you get the point. I believe The Gulf Council needs to know when they entered the fishery i.e. when they bought their permit?
Because if they entered after the implementation of the IFQ program they should have known all about the program. A little bit of knowledge is a dangerous thing, and being ignorant and it is not a defense. You need Shares or at least Allocation to fish. How can you start a business knowing you don’t have enough product to sell? The ones that got the initial Shares fished in those qualifying years. The ones that didn’t get enough to fish all year either sold out, leased Allocation or like me went out borrowed money and got the Shares needed to fish all year.

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3/28/2017 9:04:40Bob Bryantbob.bryant@subocorp.comSt. Petersburg, FL, 33710Private Recreational Angler, Charter/Headboat For-HireBelow is my "BLUEPRINT" for success for the American people in the management of THEIR resource for commercial use. Please enter these comments into the record for Amendment 36A

1. Eliminate the current “Sea Lord” IFQ system. No person or company should be “GIVEN” exclusive rights to any portion of a shared ownership public trust resource. Nothing in the Magnuson/Stevens Act (MSA) gives NMFS the power to “bestow” any form of ownership rights on anyone. In fact the National Standards try hard to prevent just that scenario, by requiring fair and equitable treatment.
2. Create a PFQ (Purchased Fishing Quota) whereby the vessel owner/operator establishes what he feels he can harvest for the year.
a. His history will be reviewed and he will be assigned how many pounds he is eligible to purchase that year.
b. The owner/operator will then purchase his quota at 30% the 3-year running average of the x-dock price (example if the price has been $4.50 per pound it will cost him $1.35 per pound to purchase his quota).
c. The purchase is made from the federal government and revenue is placed in the fishery management regions operating budget to accommodate administrative and research cost.
d. Only direct harvester are eligible to purchase quota form NMFS.
e. In season quota can be sold to other operators, but cannot exceed 125% of the original purchase price (for example if the quota was purchased for $1.35 per pound, the maximum that it can be resold for during that season is $1.69 per pound).
f. Unfilled quota is returned to NMFS and adjustments are made to the quota purchaser’s allocated limits.
g. Previous year’s unfilled quota will be made available to “new entrants” to allow them to build catch history for future purchases. New entrants will pay 125% of the current year’s set quota price in the first year of quota purchase.
h. Set a 20 (120 feet) fathom limit on all federal commercial reef fishing activity for the entire Gulf of Mexico.
3. Safety & Health
4. All vessels will be required to undergo a safety and health inspection on a quarterly basis.
5. All commercial vessels in the program will be required to be operated by a USCG licensed captain with the credential required for the vessel tonnage being operated.
6. There will be a licensed captain or STWC certified crew member for every 5 crew members on board.
Now these ideas are not revolutionary, nor are they excessive or burdensome. Any company that wants to gain access to a public resource on public lands (or water) pays for that right from the federal government. As a part of that bid/purchase the company is expected to meet certain guidelines and safety precautions.
Commercial fishers are a part of our country’s food supply system. We need to make sure that number 1 the resource owners (the American People) are compensated for their resource and number 2 that the resource is harvested in a sustainable and safe manner and that it is transported to market in a healthy and safe manner.
The Systems need to be managed in the best interest of the American people, not the best interest of a select chosen few!
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3/28/2017 9:29:15Susan Macken/Jorge Hernandezmacken.susan@yahoo.comApalachicola, FL 32320Commercial FisherAction 1: All of our trips involve IFQ species so this potential change won't impact us personally. If additional hail-in requirements are needed for improved monitoring of IFQ species, we support Preferred Alternative 2.

Action 2.1: We support Preferred Alternative 2, Preferred Option 2a and Preferred Alternative 3a. Red snapper and grouper/tilefish accounts that have never been activated should be closed and the associated allocation returned to the commercial sector.

Action 2.2: We support Alternative 4 with one adjustment -- base allocation on 2016/2017 landings rather than 2015 landings. Alloocation in inative accounts should be provided to GOM reef permit holders who are currently fishing with leased quota.

Action 3: We support Preferred Alternative 2, Option 1.

Action 4: We support Preferred Alternative 1.
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3/28/2017 14:10:53Matthew Peterschallengeronefisheries@gmail.comFort Walton Beach, FloridaCommercial FisherCommercial reef fish permit holder without shares.

Acton 1, Action 2 – Anyone landing reef fish should have to hail in and out.

Action 2.1, Alternative 2 and 3 - If the accounts haven’t been used the shares should be given back to NMFS.

Action 2.2, Alternative 4 – Quota should be distributed to allocation-only account holders for bycatch. The shareholders that initially got the fish, especially the bigger ones are already taken care of. The smaller fishermen who were pushed out during initial allocation distribution should have a chance at share distribution to save wasteful discards. There are many fishermen out there who have to throw back fish they don’t own shares or allocation for and this would reduce that.

Action 3, Alternative 1 – The fish stocks have recovered and they should continue to stay that way in the future.

Action 4, Alternative 1 – The hail in and out for the commercial vessels is efficient enough. There is not reason to add the extra burden on the fish house especially since the boats have already made landings notification. It will waste time.
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4/1/2017 4:18:14Jake ShugartJ.shugart@yahoo.comLouisiannaCommercial FisherThis council needs to do something to help the real fishermen holding Reef Fish Permits including those with little or no IFQ, It has turned into a sharecropper fishery for most permit holders, and at $3.50 to $4.00 a lb just to lease I am not going to support the few Fish Lords holding the majority of these fish. Maybe at least when shares become available permit holders should get those shares even if it is just a few pounds it is still better than nothing.
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4/3/2017 12:16:13Rex Lee Reid Rex1961@bellsouth.net PCB FL 324 13 Private Recreational AnglerCan you not issue tags for each recreational fisher so we can catch and keep them when we want too? I think it is stupid to catch a ton when in season and keep smaller fish when I would rather catch and keep the say 3 lbs and up fish when I catch them thru out the year.
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5/18/2017 13:07:17Warner Fosterjwkillntime@gmail.comPanama City, Fl. 32405Private Recreational AnglerFrom the beginning the IFQ program was flawed. The opportunity to start fixing the IFQ program is now. The IFQ holders who do not fish and own a commercial boat should forfeit their IFQ shares. The forfeited IFQ shares should be spread out among those who are forced to lease shares, fish and own a commercial boat through a lottery not an auction. It should be illegal for IFQ holders to will sell or transfer their IFQ shares to anyone who does not fish and own a commercial boat.
Thank You,
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8/7/2017 18:14:23Matt Manning
matthmanning@yahoo.com
Valrico, FL 33596Private Recreational Angler
I demand that any final actions be moved to the Biloxi meeting in October because the new council members will not be able to vote at the august meeting and they need to have their say, that is why they were appointed to the council so please let them weigh in!
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8/7/2017 18:14:48Matt Manning
matthmanning@yahoo.com
Valrico, FL 33596Private Recreational Angler
I demand that any final actions be moved to the Biloxi meeting in October because the new council members will not be able to vote at the august meeting and they need to have their say, that is why they were appointed to the council so please let them weigh in!
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