RF Amend 36A - Commercial IFQ Program Modifications
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1/19/2017 13:32:03Test Tester
Testville, FL 55555Other
This is a test. This is a test. This is a test.
1/26/2017 19:32:58William Copeland
New Port RicheyCommercial Fisher
When 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.
2/1/2017 12:07:17Steven Craig Rash
APALACHICOLACommercial Fisher, Other
My 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
Water Street Seafood, Inc.
3/5/2017 13:19:40Jason Shaw4jshaw@gmail.com36576Private Recreational Angler
Generally 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.
3/6/2017 20:13:53robert j knapp
seminole fl 33777Commercial Fisher
Why 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

3/9/2017 9:40:03Scott Hickman Listodos@gmail.comLeague city Tx 77573Commercial Fisher
The 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.
3/12/2017 9:04:44William Copeland
New Port RicheyCommercial Fisher
36A Action 1: I agree with Alternative 2
3/12/2017 9:12:07William Copeland
New Port RicheyCommercial Fisher
36A 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.
3/12/2017 9:27:01William Copeland
New Port RicheyCommercial Fisher
36A 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.
3/12/2017 9:28:00William Copeland
New Port RicheyCommercial Fisher
36A Action 3: I agree with preferred Alternative 2
3/12/2017 9:29:48William Copeland
New Port RicheyCommercial Fisher
36A Action 4: I agree with Alternative 1
3/12/2017 9:43:10William Copeland
New Port RicheyCommercial Fisher
There 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.
3/12/2017 9:52:26William Copeland
New Port RicheyCommercial Fisher
There 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.
3/12/2017 10:02:17William Copeland
New Port RicheyCommercial Fisher
36A: 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.
3/12/2017 11:08:09Capt Bill Fehlcc4eva@aol.comSeminole, FL 33778
Private Recreational Angler, Charter/Headboat For-Hire, Commercial Fisher
Action 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
3/13/2017 9:12:35benjamin bateman
brandon fl 33511Commercial Fisher
Action 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.
3/13/2017 19:25:39Capt Gary Jarvisgjabd@aol.comdestin
Charter/Headboat For-Hire, Commercial Fisher
To 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
3/14/2017 16:27:40Jeff Sharnowski
Commercial 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
3/21/2017 0:00:30Rodolfo Uria
Tampa, FL, 33614Commercial Fisher
In 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.
3/22/2017 9:28:17
Christopher Dombkowski
Dayton, Ohio 45434 AND Cibolo Texas
Private Recreational Angler
I 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.
3/22/2017 9:39:18
Christopher Dombkowski
Dayton, Ohio 45434 AND Cibolo Texas
Private Recreational Angler
Management 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.
3/22/2017 22:39:52Christopher Barton
Cortez, FL
Private Recreational Angler, Charter/Headboat For-Hire, Commercial Fisher
I 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.

3/24/2017 18:26:54Amy Wirtzrbellies@hotmail.com
Tarpon Springs, FL 34689
I 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.
Form Responses 1