RF Amend 36B - Commercial IFQ Program Modifications
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1/27/17Eric Brazerinfo@shareholdersalliance.orgGalveston, TXOtherOn behalf of the Gulf of Mexico Reef Fish Shareholders’ Alliance (Shareholders’ Alliance), please accept these comments on the following issues to be discussed at the Gulf of Mexico Fishery Management Council (Gulf Council) meeting in New Orleans, Louisiana this week.

Reef Fish Amendment 36B
We welcome the opportunity to have a deliberate discussion about the successes and shortcomings of the two IFQ systems in the Gulf of Mexico, as well as develop ideas for viable solutions that solve legitimate problems.

While the results of the Red Snapper Individual Fishing Quota (IFQ) Five Year Review are available, NMFS has yet to provide the results of the Grouper-Tilefish IFQ Five Year Review. If the results of Amendment 36B are intended to apply to both IFQ programs, makes the most sense to initiate this discussion after we receive the Grouper-Tilefish Five Year Review analysis so that the Gulf Council has enough information to make an informed decision.

When considering these discussions, we urge the Gulf Council to think through:
- Whether the “problem” is real or perceived and how to make this determination.
- The intended and unintended consequences (positive and negative) of modifications to the two
IFQ programs.
- The impact of changes on existing fishing businesses and the seafood supply chain.
- Whether the “solution” actually solves a defined, legitimate, and agreed-upon “problem.”
- Whether the IFQ programs are meeting their intended goals and objectives.
The Shareholders’ Alliance is committed to educating the Gulf Council and stakeholders throughout this process on the true impacts of IFQ changes to fishermen and fishing businesses in the Gulf.
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3/26/17Jeff Sharnowski
jsharnowski@yahoo.com
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 13:33:43Test1 Test2Test1@Testing.comTest, FL 55555DealerThis is a comment form TEST only.
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4/6/2017 22:03:41Nathan Kingnmking09@aol.comNiceville, FL 32578Private Recreational Angler, TaxpayerI am writing to encourage the Fishery Management Council to model the catch shares program after other resource allocation programs within the government, particularly FCC license auctioning process.

I applaud the Gulf Council for its efforts in attempting to improve upon the IFQ program. I believe the current IFQ program creates monopolies and does not allow fair participation for smaller commercial entities.I believe the IFQ program can be much more beneficial to the government and create a level playing field among all commercial intrests by modeling the allocation effort after the FCC frequency auctions.

The FCC auctions are based on the premise that the public resources are the Government's to control and business entities merely lease the rights to these resources. To encourage fairness in allocating these resources to private entities the leases are auctioned off every few years. This ensures the tax payers receive fair market value for the resource and there is equal opportunity for everyone to participate in the market. The following link describes the FCC auction process and how bidders are vetted.

http://wireless.fcc.gov/auctions/default.htm?job=about_auctions&page=1

I believe the Council should implement a very similar auction process for allocating catch shares so the government taxpayers are adequately compensated for this resource and to promote transparency in the process. Additionally, I believe that entities representing the recreational sector should have the right to participate in these auctions to increase the recreational quota. This would further increase the likelihood that far market value for this resource is obtained.

Some would argue this proposal would drive the up prices of commercial fish to unsustainable heights but, as seen in FCC auctions, this has not been the case.

I appreciate the council taking the time to review this proposal and am eager to see how the IFQ program is amended to promote a fair value for this resource and fair inclusion of all commercial fishermen.

Thank you,
Nathan King
Niceville, FL
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4/16/2017 11:33:19Donald Scott Collinsdscollins62@aol.comPort St. Joe Florida 32456Private Recreational AnglerThe current system that has created all these snapper Barons with large IFQ quotas has to be changed. People are selling of their quotas and making millions of dollars and don't even fish. The quota needs to be divided equally and the people with the quota need to be fishing not selling their shares.
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5/8/17William Copelandwillcope0929@gmail.comNew Port Richey, FLPlease find attached two documents. The first attachment contains some of the details on how I believe the current GOM red snapper (and grouper/tilefish as well) program violates the intent of the Magnuson-Stevens Act (MSA) and in several cases the letter of the law. The second attachment contains some of my proposals to address these issues. I believe the attached plan would create additional jobs in this fishery, create more stability in this industry, spread economic benefit to more areas along the Gulf coast, end a multi-million dollar welfare program, help small vessel owner-operators make a living, and bring the program more in line with the MSA. Further, I believe most of the plan could be implemented without the infamous referendum process.

I respectfully request you forward the attached documents to the appropriate NOAA staff, Gulf Council staff, and Gulf Council members for their review and consideration. I further request thoughtful feedback on my MSA issues and my plan to address these issues from all parties. I would also appreciate the opportunity to present this information at the next Gulf Council meeting.

Some overall thoughts about how to establish and run an IFQ program that would be fair for all. No private person, corporation, or other entity should ever receive permanent shares of a fishery. This in effect transfers ownership of a public resource to private individuals. Instead, allocation should be provided to actual FISHING VESSELS/FISHERMEN giving them the right to harvest fish. With that in mind, an “allocation bank” should be operated by NOAA Fisheries and all allocation should be issued by and leased from NOAA. Only properly licensed fisherman/fishing vessels participating in the fishery should be allowed to lease or receive allocation and they should all pay the same price for allocation. The fee for leasing allocation would be paid to NOAA fisheries for program operations and maintenance, and to provide funding for fisheries data collection. Certainly vessels with strong catch histories of a particular species should be able to lease more allocation during the fishing year than vessels who do
not. But, we should all have access and opportunity to lease allocation through NOAA, as well as the ability to trade allocation with other fishermen.

Proposed changes to the Individual Fishing Quota (IFQ) Programs for
Gulf of Mexico (GOM) Commercial Reef Fish including Red Snapper and Grouper/Tilefish

• The following proposed changes focus on
o Establishing a NOAA Fisheries reef fish allocation bank (RFAB) to provide small vessel owner operators better access to allocation and help reduce bycatch discard loss in the fishery.
o Eliminating from the fishery, shareholders who lease their allocation for profit (LFP) but don’t directly or actively participate in the fishery.

• NOAA will establish, operate, and maintain a RFAB for all reef fish share categories (RFSCs) to primarily provide better access to leasing of IFQ allocation for new entrants and small vessel owner operators.
o The RFAB will receive allocation “deposits” in 2 ways.
 The annual allocation (in pounds) to be distributed to shareholders will be capped for each
RFSC. All annual allocation above that amount will be put into the RFAB.
 NOAA will place a minimum 20% of all annual allocation in each RFSC in the RFAB
o The cost to lease allocation from the NOAA RFAB will be fixed at $ (pick a price) and will be paid to
NOAA Fisheries to cover program operations and provide funding for fisheries data collection.
o Allocation leased from the NOAA RFAB cannot be re-leased or transferred. It must be used for harvest only by the CRPV associated with the IFQ account when leased.
o Rules for determining eligibility to lease allocation from the RFAB follow:
 Only CRPVs with valid IFQ accounts may lease allocation from the RFAB.
 Shares and allocation in all valid IFQ accounts held by an individual, group of individuals in business together, or their associated corporations will be added together to determine their share portion and allocation levels (SPAL). Anyone moving shares or allocation to avoid determining an accurate SPAL will have their access to the RFAB terminated indefinitely.
 Any individual, group of individuals in business together, or their associated corporations with no shares in their SPAL for a RFSC may lease allocation from the RFAB for that RFSC.
 An individual, group of individuals in business together, or their associated corporations with shares in a RFSC cannot lease allocation from the RFAB for that RFSC until 90% of their originally issued SPAL for a RFSC is HARVESTED by the CRPVs associated with their IFQ accounts.
 When eligible, a CRPV/IFQ account can submit a request to lease allocation in that RFSC to the RFAB. Requests will be filled on a first come first served basis. Only one request per month for each RFSC in an IFQ account can be submitted. The allocation request must be for at least
200lbs of allocation with a maximum of 500lbs. (Somewhere in the 100 -1000lb range depending on RFSC)
 No single individual, group of individuals in business together, or their associated corporations
can lease allocation for a RFSC from the RFAB if they hold more than 1% of the shares in that RFSC in their SPAL or if by leasing the allocation it would give them more than 1% of the annual allocation in that RFSC in their SPAL.
o While I believe that selling shares or allocation violates the MSA section 303A, I suppose valid IFQ accounts can continue to buy, sell, and trade, shares and allocation between IFQ accounts as is currently done.

• Plan to address the LFP issue and end the multi-million dollar welfare and retirement program.
o This is critical – First, we have to temporarily ban the sale or transfer of IFQ shares. This temporary ban on share sales and transfer would not impact the fishery. Allocation is what keeps the fishery moving. This ban will ensure all program changes can be implemented without shareholder manipulation.
o Change the requirements to have an IFQ account. A valid IFQ account must meet the following criteria. All IFQ accounts not meeting the following criteria will be deemed invalid and closed:
 Only GOM CRPVs with active commercial reef permits (CRPs) can have IFQ accounts.
 Only a U.S. citizen, corporation, partnership or other entity can have an IFQ account or
GOM CRP.
 Only one IFQ account per CRPV and only one CRPV per IFQ account is permitted. If more than one IFQ account is linked to a CRPV, the account with the most shares will remain with that CRPV. All other IFQ accounts associate with that CRPV will be closed and all shares moved to the one remaining account. Exception: entities holding more than one CRPV may have one IFQ account in addition to their vessel linked accounts.
 CRPVs must have an IFQ account to receive shares and allocation.
o Return all IFQ shares and allocation from all invalid and closed IFQ accounts to NOAA immediately.
 If a reef permit becomes invalid, its’ IFQ shares and any associated allocation will return to
NOAA immediately.
 Each year, all shares associated with unclaimed IFQ will return to NOAA at year end.
o For each RFSC, in each IFQ account, all allocation that was leased out by that account over the past 3 years will be averaged and the average number of shares associated with this leased allocation will
return to NOAA.
• Plan to recapture shares and allocation from CRPVs/IFQ accounts that are not harvesting their allocation
o If a CRPV/IFQ account fails to harvest an average of at least 80% of its’ associated allocation for the 3 previous years, the average number of shares associated with the unharvested allocation will return to NOAA immediately.
 Example 1: We have an IFQ account with tilefish shares. Of the allocation issued from those shares, the CRPV harvests 60% of their tilefish allocation in year one, 70% in year two, and 65% in year three. So, 35% of their tilefish shares will be returned to NOAA.
 Example 2: We have an IFQ account with red snapper shares. Of the allocation issued from those shares, the vessel harvests 90% of their red snapper allocation in year one, 80% in year two, and 85% in year three. So, vessel retains all shares.
• Plan to reduce bycatch discard loss by redistributing recaptured shares and allocation
o Any single individual, group of individuals in business together, or associated corporations which hold more than 0.1% of the shares in a RFSC will not receive any of these recaptured shares or allocation.
o CRPVs which don’t have landings in at least 2 of the last 3 years in a GOM IFQ RFSCs will not receive redistributed shares or allocation in that RFSC
o All other active CRPVs with IFQ accounts and landings in 2 of the last 3 years will have these recaptured shares and associated annual allocation for all 6 GOM IFQ RFSCs put into their accounts as follows:
 These CRPV IFQ accounts will receive recaptured shares to bring their IFC accounts for each RFSC to 0.05%. A lower number can be used if there aren’t sufficient shares to redistribute. Any remaining shares will be distributed equally to all IFQ accounts.
 These bycatch shares can never be sold and the associated allocation can never be leased out
o Establish a separate RFSC for each type of tilefish. Redistribute tilefish shares based upon landings over the past 3 years.
• Plan to reduce the number of GOM CRPs. Anyone wishing to purchase and activate a GOM CRP must purchase and redeem two active CRPs to get one. That is a 2 for 1 exchange.
o When the old permits are redeemed/surrendered, all IFQ shares and allocation from the 2 redeemed permits will be placed on the new permit.
o There are no price controls on the purchase or sale of GOM commercial reef permits.
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5/8/17Stephen Pruski
stevepruski@sbcglobal.net
San Antonio, TXI do not understand why it is legal for this council to discriminate between citizens of our great country in relation to the red snapper and for that matter, any other fish. Will you please explain the following:
1) I do not understand how the quota system can ever work at this time if it is based on pounds because if
the fish species is recovering, then the size of the fish you catch each year will be larger, which will cause the quota to be reached faster, which causes the fishing days to be lowered even though the number of fish in the gulf will have increased.
2) It is totally discriminatory to punish people in one state for the actions of people in another. From the information I have read, red snapper are not a migratory fish. They do not move up and down the coast, also since the depth of the water at the federal/state line varies along the coast and this fish really only inhabits waters deeper than 50 feet, it is totally inequitable to manage the gulf as a whole if you are truly trying to protect the fish.
3) I do not understand at all why a commercial fisherman can pick which days out of the year they choose to fish but an average citizen is told when he can fish for the same fish. The recreational fisherman normally must work to be able to buy a boat, therefore, it is not always practical for him to be able to fish during the allotted days. The federal government is still getting their taxes from the recreational fisherman's job, so the tax argument related to commercial fishermen does not carry any weight with me. The only non-discriminatory way to deal with this issue is a true permit system like is already being done with other species. This way the recreational fisherman can buy his/her fish when he wants, like the commercial fisherman, they will just pay in fuel, repairs, bait, etc. so therefore, we are both buying our
fish, so it is odd that one fisherman is considered commercial and not the other when we are both buying fish.
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6/5/2017 8:14:09Ryan Bradleymscfuwebs@gmail.comLong Beach, MSCommercial Fisher2.) Options Paper – Amendment 36B – Commercial Reef Fish IFQ Modifications (Tab B, No. 11a) – Lasseter
- MSCFU currently supports the following alternatives and recommended actions:
(a) Actions 2.1: Program Participation
1.) Shareholders must possess a valid or renewable permit to obtain an IFQ account, maintain shares already held, obtain additional shares, transfer shares, or obtain and transfer allocation.
2.) All shareholders must possess a valid or renewable reef fish permit.
(b) Actions 2.2: Phase In Requirements
1.) A commercial reef fish permit must be obtained and linked to the shareholder account at the time of the final rule implementing this amendment. This is necessary to discourage shareholders whom are retired or no longer actively participating in commercial fishing activities/ business from attempting to obtain a permit and further driving up the price of a permit. These shareholders whom currently do not hold a permit would immediately lose all harvest privileges and right to own shares.
(c) Actions 2.3: Quota Redistribution/ Quota Set Asides
1.) All IFQ shares/species should be eligible for redistribution upon regular review of IFQ programs every 3-5 years and should be redistributed from inactive shareholders with no permit or recent landings and the total percentage of reclaimed shares shall be redistributed to active participants whom can demonstrate recent historic landings within the same 3-5 year review period and possess a reef fish permit. Shares should be redistributed in a manner that is proportionate to a qualified applicant’s landings in the same way initial shares were originally issued.
2.) Quota set asides should be implemented annually for each species managed under IFQ with 10-20% of the annual quota for each species being allocated for new entrants and small-shareholders to access shares directly from NMFS [Authorized under MSA Sec. 303A (c)(5)(C)]. Additionally, any funds retained by NMFS as a result could go toward covering the cost of IFQ programs.
Actions 2.3.1: Lease to Own Provision
1.) Instead of “lease to own”; the Council should consider “land to own” provisions. This would imply that those individuals or entities that possess a reef fish permit and who have accrued landing’s history would eventually receive equity for such landing’s history in the form of the issuance of shares directly from NMFS upon regular (3-5 years) review and redistribution of quota. A “Lease to own” provision could have further negative impacts on fishing dependent communities if enacted without provisions requiring participants to possess a reef fish permit and landings history. For example: Participants outside of the Gulf region whom act only as
brokers and have no landings history could wind up owning shares under such a “lease to own” provision.
(d) Actions 2.4: Distributing shares from Non-activated accounts
1.) *Other Alternative: Upon implementation of Amendment 36A; NMFS should transfer shares from non-activated accounts in to a quota bank or set aside for small-shareholders and new entrants to access directly from NMFS and should be distributed to eligible participants whom meet certain criteria on a first come first serve basis or lottery system with preference going to allocation-only participants.
(e) Actions 2.5.1: Restrictions on Share Transfers
1.) Restrict the transfer of IFQ shares to allow transfer only to entities that possess a commercial reef fish permit. This will essentially strengthen previous preferred actions/ alternatives, if passed and reduce complexities in tracking the transfer of shares. Only those entities that possess a reef fish permit will be eligible to receive shares. Currently, we oppose additional language to this alternative that would also require permit holders to have historical landings in recent years because this requirement would negatively impact new entrants.
Actions 2.5.2: Restrictions on Allocation Transfers
1.) Restrict the transfer of allocation to allow transfer only to entities that possess a commercial reef fish permit. This requirement puts all participants in line with preferred actions/ alternatives we have previously indentified. Additionally, this requirement ensures those individuals/ entities that possess a reef fish permit have direct access to needed quota and attempts to eliminate unnecessary broker-only transactions that drive up the price of quota. However, some concerns arise that brokers will seek out reef fish permits to be able to retain/transfer quota and this could further increase the market price of available reef fish permits. Although, if previously discussed actions/ alternatives are implemented this problem may be mitigated.
(f) Actions 2.6: Allocation Caps
- MSCFU currently has no position on the implementation of allocation caps; however, we strongly support initiatives that prevent any one particular person, corporation, or entity from acquiring an excessive share of the harvesting privileges.
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6/6/17Eric Brazereric@shareholdersalliance.orgShareholders Alliance
On behalf of the Gulf of Mexico Reef Fish Shareholders’ Alliance (Shareholders’ Alliance), please accept these comments on the following issues to be discussed at the Gulf of Mexico Fishery Management Council (Gulf Council) meeting in Naples, Florida this weekAmendment 36B.
While we appreciate the substantial work Gulf Council staff has put into developing this document, the Gulf Council has yet to come to agreement on and define the underlying “problems” that would compel such restrictions on leasing, ownership, and operations as have been proposed in the document. Many, if not all, of the proposed actions will have unintended (and intended) consequences that are likely to impose more harm and risk than anticipated. This has impacts on, among other things, the profitability of fishing businesses, the stability of the IFQ marketplace, and fishery rebuilding plans. Furthermore, if Amendment 36B is intended to develop alternatives that would apply to both IFQ programs, it is premature to advance this document before the 5 Year Review analysis for the Grouper-Tilefish IFQ program is complete. Finally, we believe that access to capital and bankability are two significant hurdles that young fishermen and replacement entrants face today, and we continue to ask the Gulf Council to work with NMFS to develop a federal IFQ loan program in the Gulf similar to those that exist in the Pacific Northwest region.
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6/6/17Jeff Sharnowskijsharnowski@yahoo.comGulf Council,
I listened to the webinar on 36B, I wish I could be there to give testimony tomorrow but I am unable to make it. So here is what I would like to say. It sounds like it’s RS-IFQ program you have a problem with. But they are catching most of all their quota, keep in mind that any IFQ system will never catch 100%. There are still too many fishermen wanting to fish for them. It even says so in the RS 5-year review.
“The conclusions of the RS-IFQ program 5-year review8 are:
Participant Consolidation and Overcapacity
Conclusion 1: The RS-IFQ program has had moderate success reducing overcapacity, however economic analyses indicate that additional reductions in fleet capacity are still necessary.”
Not every fisherman can fish for Red Snapper there is just not enough quota. That’s why the lease price is so high, supply and demand. It’s the free market working. But some fisherman can’t figure it out, so please explain it to them.
I also urge the Council to get a finance program working for the next generation fisherman. When I am ready to sell my shares, I would love to sell them to a fisherman just starting out, to invest in his or her fishing future. Not to the big shareholders for them to get bigger.
Thank you for your time,
Jeff Sharnowski
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6/7/2017 19:00:10Katie ThompsonKatieinpink1@yahoo.comTampa, FLWhen is the Gulf Council going to put an end to the Reef Fish IFQ shareholders retirement program. These people were GIVEN these shares (big mistake) and they somehow now believe that income from leasing these FREE shares should be their retirement program even after they quit fishing. They are private businessmen and should have 401ks just like everyone else who is self employed and wants a retirement account. If they aren't fishing, time for the Council
to give those shares to fishermen without shares who are fishing. One exception, if someone purchased shares at a fairmarket price as a business investment, they should be allowed to keep those shares and the income from those shares. Unless of course their holdings become so large it "creates" a monopoly leasing environment.
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6/7/2017 19:51:16Katie ThompsonKatieinpink1@yahoo.comI heard in public testimony today at the Gulf Council meeting that the 3% CRF paid by shareholders is higher than royalties paid to the US government by oil companies who lease oil rights on government land. WRONG WRONG WRONG. First, oil companies pay for the lease. And, according to the Federal Budget Office, they then pay 12.5% of all production to the US Treasury. When is the Gulf Council going to start correcting these large shareholders who make false statements on the public record? Even worse, the poor fishermen who leases the allocation has to pay the fee, not the shareholder. Time for the shareholders to pay the CRF up-front when they get their allocaiton.
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6/7/2017 20:37:22Katie Thompsonkthompsonarnp@gmail.comDuring public testimony today at the Gulf Council meeting I heard one of the large shareholder state that leasing red snapper allocation for $3.00/lb and selling those red snapper for $5.00lb was a 40% profit margin. He further stated how great that was. NOT SO. Can he really be that incompetent when it comes to business matters. First, the poor fisherman has to pay the 3% CRF, so we are down to $4.85/lb.
Then we have fuel, bait, ice, tackle, maintenance, crew shares ... It is a losing proposition to lease red snapper allocation. The only reason to do it is to reduce bycatch loss and at least get something for the fish.
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6/12/2017 20:36:25Warner Fosterjwkillntime@gmail.comPanama City, Fl. 32405Private Recreational AnglerThe Gulf Council should continue it's efforts to modify and or change the totally unfair IFQ system. The large IFQ share holders don't want any changes which may impact the Golden Goose they were given by the Government. Most everyone knows a lot them are getting rich off of a public resource and don't even fish and some don't own a commercial boat.The new commercial fishermen can only get the few scraps the IFQ holders will allow them. The new guys do all the work and take all the risk while the fat cats rake in money from leasing their IFQ shares. Major changes are needed and soon. Wish I knew how such a small number of IFQ holder have gotten so much power that the Commerce Department will not stand up to them.
Thank You,
Warner
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7/10/17William Copelandwillcope0929@gmail.comNew Port Richey, FLThe Florida Commercial Fisheries United Inc (FLCFU) was formed in June 2017. Our mission is to support the interests of Florida's commercial fishing industry, promote sustainable fisheries policies, and advocate on behalf of commercial fishermen, fishing businesses, and consumers of saltwater products.

The FLCFU hereby submits our comments relevant to the August 2017 GMFMC meeting. The majority of our comments are in regards to Amendment 36B – Modifications to Commercial IFQ Programs. Please consider the following actions and alternatives in priority order:

1. FLCFU supports using a Quota set aside to form a Reef Fish Allocation Bank (RFAB). A basic RFAB
operations plan is provided in attachment 1.
a. NOAA will establish, operate, and maintain the RFAB for all reef fish share categories (RFSCs). b. Consistent with Quota set aside in the Draft Options for Amendment 36B (Sec 2.3, pg. 29)
c. Consistent with the MSA sec 303A(c)(5)(C)
d. Consistent with General Accounting Office (GAO) Report 04-277 recommendations
e. Will provide better, more consistent, cost effective access to IFQ allocation for new entrants and
small vessel owner operators who don’t own shares
f. Will provide long term stability through reliable multi-generational access.
g. MOTION REQUESTED: In conjunction with Draft Options for Amendment 36B (Sec 2.3, pg. 29) we request the GMFMC make a motion for the Gulf Council Staff to develop a detailed options paper for implementing a RFAB for all species managed under IFQ.

2. FLCFU opposes any further actions to create or authorize an auction for commercial Red Snapper IFQ or any other IFQ allocation for that matter. Instead we support the RFAB described above. Please vote NO on any action to pursue such auctions for the following reasons.
a. An auction will not solve the underlying problems in the commercial Red Snapper IFQ program. b. An auction will create a new opportunity for individuals and corporations who do not hold a reef
permit and/or do not actively participate in the fishery to purchase shares.


3. FLCFU opposes any further actions to create or authorize a loan program for the purchase of IFQ from private shareholders in any current or future IFQ program under the management of the GMFMC. Please vote NO on any further actions to pursue a loan program for the purchase IFQ from private shareholders.
a. Loans will not solve the underlying problems in the commercial IFQ programs.
b. Loans will likely drive up share and allocation prices.

4. FLCFU supports “Adaptive Shares” for all IFQ managed species. See attachment 2 for details on adaptive share implementation.
a. Consistent with Options Paper – Amendment 36B – Commercial Reef Fish IFQ Modifications Motion: “In Section 2.3, to add an alternative for an adaptive management redistribution method based on cyclical redistribution, which depends on fishing participation”.
b. Keep the fishery fresh by providing shares and allocation to reef fishermen actively participating in the fishery and provide long term stability through reliable multi-generational access.

5. The FLCFU has several other suggestions associated with the Gulf of Mexico (GOM) Commercial Reef Fish IFQ Programs. However, in the interest of expediting Amendment 36B, we recommend the GMFMC make a MOTION to create Amendment 36C to address these additional items. See attachment 3 for details on additional item of interest.

Thank you for considering our comments and recommended actions for the August 2017 GMFMC meeting. If you have any questions, please contact me.
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7/17/17Ryan Bradley
MSCFUwebs@gmail.com
Long Beach, MSThe Mississippi Commercial Fisheries United, Inc.; as a representative of Mississippi’s
commercial fishing industry, hereby presents our concerns and recommendations for the August 2017
Gulf of Mexico Fishery Management Council meeting. The majority of our comments are in regards to “Amendment 36B – Modifications to Commercial IFQ Programs”. Please duly consider the following priorities, alternatives, and/or actions currently preferred by our member constituency:

1.) MSCFU currently opposes any further actions or attempts to create an auction for the commercial red snapper allocation. Please vote NO on any action to pursue such an auction. It is our opinion that an auction will not solve the underlying problems within the commercial Red Snapper IFQ program and will decrease the availability of shares for existing shareholders and allocation only participants. It is also unfair and inequitable to allow an open auction on a portion of the quota
that allows anyone and everyone to bid on shares of commercial red snapper regardless of fishery participation. Any type of redistribution of shares should consider and account for the value of recent historical landings.

2.) MSCFU currently opposes any further actions or attempts to create or authorize a loan program for the purchase of Individual Fishing Quota (IFQ) for any current or future IFQ program under the management of the Gulf of Mexico Fishery Management Council. Please vote NO on any further actions to pursue an IFQ loan program. It is our opinion that if a loan program were implemented to purchase quota, the cost to obtain quota would artificially increase as a direct result of the loan program. The implementation of a loan program; in our opinion, would further compound barriers to entry and increase operating cost for allocation only participants. Loans are already available from traditional financial institutions. Investments in the fishery must be profitable for all participants to increase investment and bankability of the fishery.

3.) MSCFU currently supports the formation of a “Reef Fish Allocation Bank (RFAB)” - See Draft Amendment 36B Options Paper (Sec 2.3, pg. 29). In accordance with Magnuson-Stevens Fishery Conservation and Management Reauthorization Act (MSRSA) 303A (c)(5)(C) – a set aside of allocation or harvesting privileges should be included in management measures
Reef Fish Allocation Bank (RFAB) Purpose: To provide for the sustained participation of fishing dependent communities; assist entry-level and small vessel owner-operators, captains, and crew to access the fishery through set-asides of harvesting allocations as authorized in the MSA; and strengthen the current commercial IFQ systems by ensuring the next generations of fishermen have equitable access to the fishery.

MSCFU Recommended RFAB Implementation, Operation and Access Criteria:

a. NOAA should establish, operate, and maintain a RFAB for all reef fish share categories
(RFSCs)
b. This will provide better, more consistent, cost effective access to IFQ allocation for new entrants and small vessel owner operators who don’t own shares providing long term stability through reliable multi-generational access.
c. Each IFQ reef fish share category (RFSC) will have an allocation set aside of at least 10-20% of the annual catch limit (ACL) from the commercial sector’s portion of the total allowable catch (TAC). More for species with TAC increases; less for species with no TAC increases.
d. The cost to lease allocation from the NOAA RFAB will be fixed relative to the cost of implementation, operation, and maintenance of such a RFAB. Cost to lease will be paid to NOAA Fisheries to cover program operations and provide funding for fisheries data collection.
e. Inactive shares and associated allocation discussed in Amendment 36A and 36B will be placed in the RFAB.
f. All future IFQ shares and allocation from invalid and closed IFQ accounts will be returned to
NOAA immediately and placed in the RFAB.
g. If a reef permit becomes invalid, all IFQ shares and associated allocation will return to
NOAA immediately and placed in the RFAB.
h. Each year, all shares and allocation associated with unclaimed IFQ will return to NOAA at year end and placed in the RFAB.
i. Rules, requirements, and procedures to lease allocation from the RFAB:
i. Must hold a valid Gulf of Mexico (GOM) commercial reef fish permit (CRFP).
ii. Must own a GOM commercial reef fish permitted vessel (CRFPV) with an associated valid IFQ account.
iii. Individuals, group of individuals in business together, closely related individuals, or their associated corporations who currently hold shares or receive any annual allocation distribution from NOAA for a RFSC CANNOT lease allocation from the RFAB for that RFSC.
iv. Allocation leased from the NOAA RFAB cannot be re-leased or transferred. It must be used only for harvest and only by the CRFPV associated with the IFQ account when leased.
v. All applicants must provide proof of commercial fishing by submitting either: (a) a financial statement showing a gross sales of any seafood from the Gulf of Mexico or adjacent Gulf States saltwater jurisdiction greater than 10% of the applicant’s earned income or (b) a catch history showing a minimum of $10,000.00 in gross sales of any seafood from the Gulf of Mexico or adjacent Gulf States saltwater jurisdiction’s for any consecutive 12-month period out of the past 36 months.
vi. When eligible, a CRFPV/IFQ account can submit a request to lease allocation in a RFSC to the RFAB. Requests will be filled on a first come first served basis. Only one request per month for each RFSC from a CRFPV/IFQ account can be submitted. Monthly requests in a RFSC cannot be submitted until all allocation leased from the RFAB for that RFSC has been harvested by the leasing CRFPV.
vii. Maximum allowable allocation per monthly request should be 0.01% of the TAC for each RFSC.

- MOTION REQUIRED: The Gulf Council should consider a motion to “instruct the Gulf Council staff to develop a detailed options paper for implementing a Reef Fish Allocation Bank for all species managed under Individual Fishing Quota programs.”

4.) MSCFU recommends the creation of Sub-Amendment 36C for the following priorities to be implemented after Amendment 36B has been approved (MOTION REQUIRED):

4.1.) Gulf of Mexico Commercial Reef Fish Permit (CRFP) Modifications:

a. All CRFP renewal applicants must provide proof of commercial fishing by submitting either: (a) a financial statement showing a gross sales of any seafood from the Gulf of Mexico or adjacent Gulf States saltwater jurisdiction greater than 10% of the applicant’s earned income or (b) a catch history showing a minimum of $10,000.00 in gross sales of any seafood from the Gulf of Mexico or adjacent Gulf States saltwater jurisdiction’s for any consecutive 12-month period out of the past 36 months.

i. Helps eliminate recreational fishermen buying into the commercial sector’s allocation so that commercial quota can be more fully utilized by commercial fishing dependent users.
ii. Consistent with MSA requirements on National Standards, has precedent, and is currently widely used as a management tool in various Gulf State’s commercial fisheries.

b. Implement “use it or lose it” provision for CRFPs. This provision would require that CRFPs
with “No Fishing Reporting Forms” filed in lieu of Trip Reports for any 6 consecutive
months during their reporting year will not be ineligible to renew those permits. A waiver can be granted due to loss of vessel. Permit holders would have one year to sell their permit or permit would become invalid.

c. To further reduce overcapacity in the GOM CRF fishery a “2-for-1” permit exchange requirement may be necessary. This would mean all new entrants would be required to purchase and turn in 2 CRFPs to get 1. All current permit holders would be grandfathered.

d. All IFQ accounts must possess a valid GOM CRFP and vessel to receive, give, hold, buy, sell, trade, or lease any IFQ shares or allocation.

4.2.) Cyclical Redistribution for Commercial IFQ Programs

a. Implement “Adaptive Shares” (Cyclical Redistribution) for all IFQ managed species. Shares and allocation would be based on current catch history. Review and redistribution of shares and associated allocation would occur every 3 - 5 years to accommodate participants that are landing IFQ species. Any proposed IFQ programs in the charter/ head boat sector should not be considered until cyclical redistribution is implemented in the commercial sector IFQ programs.

Please thoroughly consider the aforementioned concerns, solutions, and recommended actions for the August Gulf of Mexico Fishery Management Council meeting. These recommendations are put forth on behalf of the Mississippi Commercial Fisheries United, Inc. to encourage the implementation of
certain management measures for the Gulf of Mexico Reef Fish Fishery- Limited Access Privilege Programs such as the Red Snapper and Grouper/ Tilefish IFQ programs to promote the fair and equitable participation of current and future generations of fishermen. Please contact MSCFU Director Ryan Bradley if you have any questions or concerns.
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8/4/2017 12:42:39Eric Brazer
eric@shareholdersalliance.org
Commercial FisherDear Madam Chair,
On behalf of the Gulf of Mexico Reef Fish Shareholders’ Alliance (Shareholders’ Alliance), please accept these comments on the following issues to be discussed at the Gulf of Mexico Fishery Management Council (Gulf Council) meeting in San Antonio, Texas next week.
Amendment 36B.
We continue to be concerned that Amendment 36B remains, in effect, a “solution” in search of a problem. Caps, restrictions on leasing, “use it or lose it” mandates, auctions and reallocations will all impose constraints on the fishery that could have dire and controversial unintended consequences for existing and new fishermen. While a number of these actions and alternatives are already listed in the document, clear goals and objectives remain noticeably absent. The conversations being had by the Gulf Council to date suggest it’s challenging to articulate what some consider to be problems; and without a clear determination, effective responses will be elusive.
Complicating this conversation is the inclusion of the preliminary analysis of the Grouper/Tilefish IFQ 5 Year Review. We agree that it makes sense that Amendment 36B should apply to both IFQ programs in the Gulf, and would suggest that incorporating this Grouper/Tilefish analysis is recommended and challenging.
We propose that Amendment 36B be remanded back to the industry advisory panel (AP) process for more clarification in light of these challenges. It’s clear to us that some of the proposed alternatives in the document will have unintended consequences for fishing businesses and the seafood supply chain, and the AP process is most well-suited to identify and characterize these problems. To that end, we recommend that the Gulf Council appoint and convene a Grouper/Tilefish IFQ AP to 1) formally examine the results of the 5 Year Review, and 2) work with the Ad Hoc Red Snapper IFQ AP to ensure that Amendment 36B evolves into a more suitable document for Gulf Council discussion.
While not part of Amendment 36B per se, we continue to hear from young fishermen throughout the Gulf (and the nation, for that matter) that access to capital and bankability are two significant hurdles that young fishermen and replacement entrants face today. Therefore we ask the Gulf Council to continue working with NMFS to develop a federal IFQ loan program in the Gulf similar to those that exist in the Pacific Northwest region. Doing so will provide additional opportunity for new fishermen without taking away from existing fishermen, and will provide an ancillary benefit of enhancing the financial management skillset of these young businessmen and women.
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8/23/2017 7:00:41Scott McCunescott@fishntexas.comTXCharter/Headboat For-HireYour allocation policies are well known and they are NOT in the best interest of the local or regional economies in the case of many crossover fisheries (same species being fished commercially and recreationally)! The demographics show that the government is withholding many Red Snapper from the greatest conservationist group in the USA "The American Angler"! Your policies contradict the maximum economic and social benefits to the PUBLIC resources, I believe to maintain your established relationship with the commercial fishing interests! In addition, many, many tourist seafood restaurants in my town CANNOT serve local seafood because of contracts with their seafood vendors such as Sysco, so that local commercial fishery resource gets a fraction of the use that it should in our local economy!

Catch Shares DO NOT belong in a fishery that is recreational inclusive, period. NOAA needs to cut a huge percentage from the commercial TAC and give it to the recreational fisherman! Recreational only fisheries ARE healthy! Anyone who wants the IFQ bureaucratic crap in our recreational or Charter for Hire fishery Should expect a Fight!
I feel that as a charter captain I'm a recreational liaison, not a commercial fisherman… I still can't believe the amount of trouble/money the government goes through to manage a depleting fish stock…it seems as simple as Red fish and Speckled Trout…as technology, fishing pressure, popularity of cuisine changed commercial fishing was eliminated to save the species and the larger economy of the communities…why is that an off limits discussion from our government for Red Snapper, Amberjack and Grouper.... I'm sure there is a species, however I can't think of one off the top of my head that has been disrupted solely by recreational efforts, however I can think of many more that have made a significant come back due to the conservation nature and financial assistance of recreational anglers...it boils down to when you make money for fishing by any means (mass entrapment not Rod & Reel) to gather fish, no matter what restrictions are placed greed or the need to pay bills will make people do things that are illegal thus the down fall of the Red Snapper, Amberjack and Grouper… we had seen this happen in other fisheries to that are booming now after the any means available fishing (not single hook and single line) was banned…i.e.…Speckled Trout and Red Drum…the commercial fisheries quotas were established years ago when the fishery was more viable, technology was different, the world was different…the demographics have now changed and so should the quotas to reflect a more sustained use of the fish stock going to the growing recreational sector and not the stagnant or receding commercial industry who are just becoming big companies and will get bigger with catch shares and only a few people enjoying the fruits of profit from the mass resource…even though I am not and Snapper/Grouper fisherman I'm not for IFQ’s for single hook and line fisherman which included charter for hire which I already stated is basically only a liaison for the recreational fisherman so they can enjoy a little more of their sport …I believe if we let IFQ’s into our sector this type of government regulation will run rampant…therefore I'm trying to be proactive before it hits my fishery…I believe as the NRA one more regulation will lead two more and two more regulations will lead to 4 more and so on…recreational only fisheries are well managed for charter and private individuals and conservation within that group has excelled! They should stop wasting money on all the regulation meetings, data gathering for their own interpretation, politics and start putting that wasted money into reef building, stocking programs or whatever idea that actually help PRODUCE more fish!
Share the Gulf with recreational fisherman, people are being paid to rape the gulf with massive fish kill discards and cheating numbers for small entities commercial gain is stupid....the communities, tourists and the Gulf deserve MORE and recreational anglers provide that with lots of dollars spent in our communities! No crossover fishery (recreational and commercial target) deemed over fished should allow commercial fishing until the species are deemed stable...Period! Fisherman, it's a scam so somebody in a fancy restaurant somewhere outside of your state can eat the same type of fish you paid for dearly with new boats, hotels, fuel, equipment and time spent seeking them...and they think they RIGHT to your fish even though they aren't fisherman or hunters and vote Liberal!
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9/14/2017 8:21:45Robert Spaethrspaeth8@aol.comFloridaCommercial FisherThe Southern Offshore Fishing Association would like to comment on a couple of issues that the council is working on. We will be at the next meeting and gladly discuss in greater detail with the council members.
36b Red Snapper Grouper Tile fish 5year review,
At the last council meeting we testified that the Red Snapper and Grouper Tile IFQ review should be split . The reasons we gave, that the same harvest rates ,gear and area restrictions, distance to grounds , demand, lease, share prices and number of shareholders. One size does not fit all. Example: lease prices RS 3.25 RG 25 to 40 cents. Share price RS 30$ to 60$ , RG 5$ to 10$. The harvest rates of grouper vs Snapper is VERY different and results help in increasing demand for Red Snapper. The huge difference is the amount of days to catch Red Snapper VS Grouper. NMFS should have that information. The GrouperTile fish IFQ is working reasonable well according to our fishermen .
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9/29/2017 8:12:13Will Copelandflcfuinc@gmail.comCommercial FisherThe Florida Commercial Fisheries United Inc (FLCFU) was formed in June 2017. Our mission is to support the interests of Florida's commercial fishing industry, promote sustainable fisheries policies, and advocate on behalf of commercial fishermen, fishing businesses, and consumers of saltwater products. The FLCFU hereby submits our comments relevant to the October 2017 GMFMC meeting. Please consider the following actions and recommendations in priority order: FLCFU continues to support using a Quota set aside to form a Reef Fish Allocation Bank (RFAB). a. A basic RFAB operations plan is provided in attachment 1. b. NOAA will establish, operate, and maintain the RFAB for all reef fish share categories (RFSCs). c. Consistent with Quota set aside in the Draft Options for Amendment 36B (Sec 2.3, pg. 29) d. Consistent with the MSA sec 303A(c)(5)(C)
e. Consistent with General Accounting Office (GAO) Report 04-277 recommendations
f. Will provide better, more consistent, cost effective access to IFQ allocation for new entrants and small vessel owner operators who don’t own shares
g. Will provide long term stability through reliable multi-generational access.
Florida Commercial Fisheries United Inc
10283 Lakeview Dr
New Port Richey, FL 34654
727-457-3900
4. FLCFU opposes any further actions to create or authorize an auction of IFQ shares or allocation for any fish species.
5. FLCFU opposes any further actions to create or authorize a loan program for the purchase of IFQ from private shareholders in any current or future IFQ program under the management of the GMFMC.
6. FLCFU supports an accountable catch share program for the charter and head boat sectors, but only if it is run by NOAA Fisheries, not privatized in any way, and no permanent shares are issued.
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1/30/2018 8:26:05Rick Cainrickteina@hotmail.comHudson
Private Recreational Angler, Commercial Fisher
When is some conversation going to be on the red grouper population? There are many fisherman slowly dying due to the lack of red grouper. What has happened to them and why has there not been a cut back on the quota? We were forced to sell our commercial boat due to most of our quota being red grouper and there are none to be harvested. We hav even tried to lease our Red Grouper and can't even get .10 a pound. What is going on? Where did they go? All there are is American Red Snapper and Amberjack and you close Aj 27 days into the season, we just don't get it. There arent even any Red Snapper to lease and when you could find them they went for $3.75 and sell at market for $5.00 a pound. Hardly worth catching. Could you survive on that? What is going on with this fishery? It seems missmanaged smething has to be done or there will be no fishermen to fish anything or iother than Red Snapper s that your goal? I feel as though some of the red grouper that is harvested is in fact Red Snapper ever hear the saying red is red? The whole thing needs more monitoring. Someone needs to take responsibility for this fishing mess.
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2/21/2018 14:42:24JoAnn/Clyde Daughtryjdaughtry9@aol.com32358
Commercial Fisher, IFQ Shareholder
Fishing from Carrabelle, FL – During the IFQ qualifying years red snapper was a bycatch. That is no longer true. They are now the predominant fish on the reef. The recent observers we’ve had on our boat said all fishermen in our area are complaining about this issue. SOMETHING NEEDS TO BE DONE. The price of leasing snapper, even if you can get it, is way too high. The IFQ program can be congratulated for the snapper making a comeback however, in this ever evolving fishing industry, consideration needs to be applied to methods to alleviate the burden fishermen are now facing.

One thought that could be done for us is to create snapper multi such as you now have red and gag multi. Reduce the amount of quota from whichever pocket the fisherman has the most and apply that to a snapper multi. Another possibility is to again do the program that was in effect a few years ago – let fishermen purchase (credit card?) about 200 pounds per trip (wishfully no more that $2.50 per pound).

Another issue is the 3% recovery fee. If we get $5.50 per pound and have to pay $3.50 to lease, we pay 16 cents on top of that $3.50 lease amount. Since we only profit $2, we should only have to pay 6 cents recovery fee per pound. For the 406 pounds caught on our last trip, the recovery fee was $66.99 and would only be $24.36 with a savings of $42.69 if we only had to pay the fee on our actual profit. Either the person leasing should pay the 3% of the lease price or do as in the rest of business – pass the recovery fee on to the consumer such as a sales tax. However, we know that, if the person leasing has to pay the fee, they would just add that to the lease price.

Clyde and JoAnn Daughtry
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4/16/2018 12:06:44Eric Brazer
eric@shareholdersalliance.org
Galveston, TXShareholder's Alliance
Dear Madam Chair,

On behalf of the Gulf of Mexico Reef Fish Shareholders’ Alliance (Shareholders’ Alliance), please accept these comments on the following issues to be discussed at the Gulf of Mexico Fishery Management Council (Gulf Council) meeting in Gulfport, Mississippi this week.

Amendment 36B
The Gulf Council should be applauded for choosing a diverse group of fishermen and seafood suppliers to sit on the Ad Hoc Red Snapper/Grouper-Tilefish Individual Fishing Quota (IFQ) Advisory Panel (AP). We were encouraged to see this AP engage in a healthy and constructive dialog last week regarding, among other things, the performance of the two existing IFQ programs in the Gulf. Many of the AP’s motions passed unanimously or by a large majority, which is indicative of the effort spent by this group to address concerns raised by its members. We recommend that the Gulf Council take the AP’s motions seriously in its conversations this week. Should the Gulf Council chose not to support AP recommendations, we ask that a detailed rationale be provided for why this advice would be disregarded.

Resource Rents and Royalties
The commercial IFQ programs for red snapper and grouper-tilefish impose a cost recovery fee of 3%, the maximum allowed by the Magnuson-Stevens Fishery Conservation and Management Act (MSA), which generated over $800,000 per program in 20162,3 and is expected to have generated nearly $2 million in total in 2017. Imposing additional taxes on commercial IFQ fishermen, through auctions or other mechanisms, would have severe unintended negative consequences to the fishermen, seafood suppliers, and ultimately end consumers.

According to the Council Staff whitepaper on “Resource Rent and Royalty Payment Methods for the Red Snapper IFQ Program,” there are zero catch share programs in the US that have used auctions to distribute quota or shares, and there are zero instances under which collection of such “royalties” have been introduced subsequent to program implementation.4

To that end, we caution against the Gulf Council setting a national fishery precedent by imposing such taxes here and therefore we strongly recommend against the Council pursuing this further. Short of that, we would concur with the following unanimous recommendation made by the AP on this topic:
• To recommend to the Council to include, in developing the white paper on rents and royalties requested by the Council at its January 2018 meeting:
o a list of the goals and objectives of Amendment 26 and how imposing royalties would either advance or undermine those goals and objectives, and
o information on the likely effects of royalties on consumer prices for commercially caught red snapper, and on lease prices for allocation along with resulting impacts on new entrants and bycatch.

IFQ Loan Program / Fisheries Finance Fund
We are excited to learn from NMFS staff that a national loan program that would apply to the Gulf of Mexico is under development. The Federal Fisheries Finance Program already provides long term financing for the cost of construction or reconstruction of fishing vessels, fisheries facilities, and IFQ in the Northwest Halibut/Sablefish and Alaskan Crab Fisheries. Details of this program can be found through the Catalog of Federal Domestic Assistance.5

We continue to hear from young fishermen throughout the Gulf (and the nation, for that matter) that access to capital and bankability are two significant hurdles that young fishermen and replacement entrants face today. Therefore we concur with the AP’s recommendation and ask for the development of a federal IFQ loan program in the Gulf similar to those that already exist for fishermen in Alaska. Doing so will provide additional opportunity for new fishermen without taking away from existing fishermen, and will provide an ancillary benefit of enhancing the financial management skillset of these young businessmen and women. While some are concerned that implementation of this program would increase allocation scarcity and price, it’s our understanding that these fears didn’t materialize when this program was implemented in Alaska.
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6/12/18William Copelandflcfuinc@gmail.comNew Port Richey, FLNGOThe Florida Commercial Fisheries United Inc (FLCFU) is a non-profit corporation with the mission to support the interests of Florida's commercial fishing industry, promote sustainable fisheries policies, and advocate on behalf of commercial fishermen, fishing businesses, and consumers of saltwater products. The FLCFU hereby submits, in priority order, the following comments, concerns, and recommendations for your consideration:

FLCFU continues to recommend and support the formation of a Reef Fish Allocation Bank (RFAB).
The GMFMC acceptance of the IFQ Advisory Panel recommendation to form an RFAB is a very important step in the right direction. More details and a basic RFAB operations plan is provided in attachment 1.

FLCFU recommends a change in the allowable offload hours for commercial reef fish. Commercial reef fishermen should be permitted to offload any time of the day, not just between the hours of 8:00am and 6:00pm. It is ridiculous that commercial fishermen should have to plan their schedules and delay offloads just in case fisheries officials may want to observe.

FLCFU opposes any further actions to create or authorize a loan program for the purchase of IFQ from private shareholders in any current or future IFQ program under the management of the GMFMC.

Attachment 1

Reef Fish Allocation Bank (RFAB) Operations Plan

• NOAA will establish, operate, and maintain the RFAB for all reef fish share categories (RFSCs)
• The cost to lease allocation from the NOAA RFAB will be fixed relative to the cost of implementation, operation, and maintenance of the RFAB. Cost to lease will be paid to NOAA Fisheries to cover program operations and provide funding for fisheries data collection.
• Inactive shares and associated allocation discussed in Amendment 36A and 36B will be placed in the
RFAB.
• All future IFQ shares and allocation from invalid and closed IFQ accounts will be returned to NOAA
immediately and placed in the RFAB.
• If a reef permit becomes invalid, all IFQ shares and associated allocation will return to NOAA
immediately and placed in the RFAB.
• Each year, all shares and allocation associated with unclaimed IFQ will return to NOAA at year end and placed in the RFAB.
• Each IFQ RFSC will have an allocation set aside of 10% of the annual catch limit (ACL) from the
commercial sector’s portion of the total allowable catch (TAC).
• Rules, requirements, and procedures to lease allocation from the RFAB:
o Must hold a valid Gulf of Mexico (GOM) commercial reef fish permit (CRFP).
o Must own a GOM commercial reef fish permitted vessel (CRFPV) with an associated valid IFQ
account.
o Individuals, group of individuals in business together, closely related individuals, or their associated corporations who currently hold shares or receive any annual allocation distribution from NOAA for a RFSC CANNOT lease allocation from the RFAB for that RFSC until they have CAUGHT their allocation for the year.
o Anyone leasing their allocation in a RFSC CANNOT lease allocation for that RFSC.
o Allocation leased from the NOAA RFAB cannot be re-leased or transferred. It must be used only for harvest and only by the CRFPV associated with the IFQ account when leased.
o All applicants must provide proof of commercial fishing by submitting either: (a) a financial statement showing a gross sales of any seafood from the GOM or adjacent Gulf States saltwater jurisdiction greater than 10% of the applicant’s earned income or (b) a catch history showing a minimum of $8,000.00 in gross sales of any seafood from the GOM or adjacent Gulf States saltwater jurisdiction’s for any consecutive 12-month period out of the past 36 months.
o When eligible, a CRFPV/IFQ account can submit a request to lease allocation in a RFSC to the RFAB. Requests will be filled on a first come first served basis. Only one request per month for each RFSC from a CRFPV/IFQ account can be submitted. Monthly requests in a RFSC cannot be submitted until all allocation leased from the RFAB for that RFSC has been harvested by the leasing CRFPV.
o Maximum allowable allocation per monthly request should be 0.01% of the TAC for each RFSC.
• The RFAB will
o provide better, more consistent, cost effective access to IFQ allocation for new entrants and small vessel owner operators who don’t own shares
o provide long term stability through reliable multigenerational access
o provide allocation to all active reef fishermen to help reduce bycatch loss.

• The RFAB is consistant with
o the Quota set aside in the Draft Options for Amendment 36B (Sec 2.3, pg. 29)
o the MSA sec 303A(c)(5)(C)
o the General Accounting Office (GAO) Report 04-277 recommendati

Unfortunately, I will be unable to attend the June 2018 Key West Gulf Council meeting and will therefore be unable to discuss these issues with you in person at the meeting. Please contact me via phone or email if you would like to discuss anything in further detail.

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