RF Amend 36B - Commercial IFQ Program Modifications
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TimestampEnter your full nameemail addressCity, State, Zip CodeCheck all that applyComments
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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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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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6/7/2017 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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8/4/2017 12:42:39Eric Brazer
eric@shareholdersalliance.org
Commercial Fisher
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 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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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.com
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Gulf 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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