Online Comment for Proposed Charter-for-Hire Days-at-Sea Pilot Program
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3/11/2013 12:12:06Ritch DeVoeryd22@bellsouth.netRecreational is recreational, whether on a private boat, a charter boat or from a pier. If one isn't allowed to fish on a given day, then no should be. This is nothing more than giving preferential treatment to a small portion of the entire group. This idea is for business/economic reasons only and as such, should be counted as commercial. This plan is of benefit to very few at the expense of very many. We should all have the ability to fish when we want.Gainesville, FL 32653Private Recreational Angler
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3/18/2013 20:48:16Jack Hexterj.hexter@verizon.netSimply, IT SUCK!!!!!!!. Catch Shares, by any other name, is still Catch Shares, which limit fishermen, not fish. Correct the science!!!!!New Port Richey, FL 34654Private Recreational Angler
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3/20/2013 11:34:20Ritch DeVoeryd22@bellsouth.netNO! If I can pay a charter captain $2,000 to fish on his boat for a certain species on April 28, why can't I give my neighbor some gas and bait money and fish on his boat that same day? Recreational is recreational. Access should be the same regardless of who I fish with. As a "private" family fisherman that can only get out two Saturday's a month at the very most (and then I'm hoping for decent weather), I want MY days at sea as well. Give me thirty days to use at my discretion to fish for red snapper or gag grouper or what ever else is being given to the for profit guys. Equal access!!!!!!!!Gainesville, FL 32653Private Recreational Angler
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3/25/2013 3:44:29Captain Henry HauchCaptain_Henry@ACME-Ventures-Fishing.comTo: Gulf of Mexico Fishery Management Council

From: Captain Henry, ACME Ventures llc

While I am a Federally Permitted Captain and CFH operation in the South Atlantic, I am a Recreational Angler in the GOM. As such I have both the insight of the problems faceing the CFH industry and the concerns of the Recreational Angler. The issues we face in the CFH, SA region is really one and the same, with Fish stocks growing at tremendous rates, while access continues to be cut. Denying this is denying the obvious, despite continued attempts by the NMFS to provide data to support their veiw. In the end the math simply does not add up.
As to the proposed DAS 'Pilot'. It has to be a resounding NO to this scheme. This is afterall exactly what it is, a 'Scheme'. Any claim of it being primarily for conservation purposes is blatently a lie, so what do that leave? It is what it is, primarily for Economic Purposes, of which this clearly violates the spirit and intent of the NS and MS. It also brings great Socio-Economic inequalities into the picture by giving great favortism to one group of recreational Anglers over another. This is the jist of it, these are all 'Recretional' Anglers, whether fishing on a Charter Boat of a freinds Private Boat. To give one a special access over another is fair how? Its not! Speaking as a CFH Captain and business owner, I want my business to be profitable also. Despite the over regulated fisheries, and poor weather, we have no problem booking charters. I am looking at 125 this year, and thats with the fact that Red Snapper and Black Sea Bass, our 2 most abundant fish are all but closed in our waters. I am not asking for a free handout to gain special access to the public resource. My customers deserve better than the NMFS is giving them for sure, but to stick it to one Recreational Angler so that another Recreational Angler can fish and help profit a private business is plain wrong.
A dangerous precident was set in New England with their "Pilot" program a few years back. Remember how this "Pilot" was converted to an full FMP, without a Stakeholder referendum? See how this turned out? Why should we expect the NMFs/NOAA not to do the same again. There is really nothing that a 'Pilot' DAS program could determine that cannot be determined from behind a desk. Afterall, the NMFS uses computer models to 'Determine' the stock levels of fish despite many cases where no data exist! So where exactly would these fish come from, and WHO would be the ones included in this? Surely not the same groups pushing for it? Surely not from the Recreational Anglers ACL?
If a DAS was to make its way in as a FMP, what would happen to the ACL? Would it be seperated? Remember this issue has already been addressed, and remember the 97% opposed to the idea? Do our voices really count? DAS is by definition a form of Catch Shares, and this too has been clearly voiced by fishermen from across the GOM. So WHY really is this being pushed forward, and WHO initiated this? Seems that most people that know anything about the fisheries know that the problem with the steadily decreased access to our fisheries has little to do with Too few Fish, or Too Many Fishermen, but rather with Politic;s and brinksmanship within the NMFS and NOAA. EDF has bragged about getting 'Their Members' Appointed to the Councils and AP's so as to advance their goals of getting Catch Shares as the preferred chioce for all fishing sectors. I have not see the Councils refute this, so........ Why exactly is this being advanced when the latest ARS Stock Assesment has yet to be released? Is it because its predetermined what the outcome will be?
The Public has been clear already. DAS is simply a new name on an old issue. What will happen when the Public again clearly says NO? Give it a new name and try again? Perhaps the time and money spent trying to help a few business owners profit should be spent on correcting the court ordered fix of the recreational data system, which NMFS just acknowledged is not done? While the Councils has to answer to the NMFs reguardless of how ludicrous their proposals are, they ultimatly have to answer to the Fishery Stakeholders, and do whats best for BOTH the Fishermen and Fisheries. We have seen far too little from this in recent years, and the clear voice of the majority seems to keep falling on deaf ears. So again NO, to the DAS Scheme. Unlike the small groups pushing for this, we in the majority have a great solution to addressing the many management issues, if only the Councils and NMFS is willing to listen. Rec data collection programs have been brought to the table, as has science showing the real health of fisheries such as ARS. Is the Council ready to start listening?
Captain Henry
Private Recreational Angler, Charter/Headboat For-Hire
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4/1/2013 8:08:09Jason Descantjdescant@gmail.comAll recreational fisherman should be allowed "days at sea" not just those that pay someone to take them out. This program is sector separation and should be labelled accordingly. If a days at sea program pilot is approved it should include all recreational fisherman not just those riding on a charter captains boat. Do not let sector secretion begin with this "pilot".33755Other
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4/1/2013 15:22:38John Hexterj.hexter@verizon.netDays at Sea is just another name for Catch Shares which is an abomination. It has failed everywhere it has been tried, And just where are the fish that are going to be caught during Days at Sea going to be counted against, It's damn sure not going to be the commercial sector. We are now at 21 days and loosing fast. Tell me why I have to charter a boat to catch the fish that were originally allotted to me after the paltry 21 days are ovrNew Port Richey, FL 34654Private Recreational Angler
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4/1/2013 22:09:22Mike Guerinomegaman66@cox.netI am totally against this program. It is wrong to give away to a select few something that does not belong to them. Never has belonged to them. Charter Capt. take recreational fisherman fishing sometimes. They do not have a right to the fish that the recreational fisherman have caught.

Past fish caught by recreational fisherman in no way should entitle them ownership of said fishing rights. This is wrong and I do not support this in any way.

What you are pushing despite what the public and congress has told you not to do is WRONG!
16119 Shetland Ave.Private Recreational Angler
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4/2/2013 4:47:57jason todd bonurasuprapaint@hotmail.comit is ridiculous to think that charter boats would be allowed half of the recreational catch. if thats the case then one of them can buy my boat and pay for my storage fee . all of this snapper crap is getting out of hand. the fish belong to all the people . covington la 70433Private Recreational Angler
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4/2/2013 5:28:28Christopher C. Pratkacpratka@earthlink.netwhy there is no Plan on the table that encompasses ALL recreational fishermen, irregardless of what platform they are fishing upon?

Why do all the plans on the table at the council level involve sector seperation?

Why this is being pushed now, BEFORE the results of the benchmark assessment.
Pearland TxPrivate Recreational Angler
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4/2/2013 5:49:35Chase Livingstonduck112688@yahoo.comPlease Dont allow for the Charter capatains to recieve half the quota. Why cant the Recreational Fisherman have the right to fish for red snapper!!! Us weekend warriors can some times only fish the weekends and thtas what we do when we want to get away from work. Please let us have our fishing back!louisianaPrivate Recreational Angler
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4/2/2013 6:20:11DALE VIATORdale.viator@nrgenergy.comI HAVE BEEN FISHING IN THE SMI AREA FOR OVER 10 YEARS AND GOING TO THE SAME PLATFORM AND LIMITING OUT ON RED SNAPPER WITHIN THE FIRST HOUR, ALL THE FISH ARE 10 TO 15 LBS EACH. THIS IS THE MOST NON-COMPLIANT LAW IN THE FEDERAL WATERS WE ARE NORMALY 6-8 MEN ON MY BOAT FOR THE VERY VERY SHORT SNAPPER SEASON.NEW IBERIA, LA. 70563Private Recreational Angler
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4/2/2013 6:55:02Capt. Darrell Hingledarrell_hingle@yahoo.comAfter attending the meeting last night in Galveston, I came home and read through the materials and have the following comments. Let me start by saying I am a CFH captain and have had my reef fish permits since 1998 and have participated in this death spiral of a fishery every year since. We need a new and seperate fmp that will allow the cfh group to be successful.

1. I think the participants should be voluntary both active and control group. The program should last multiple seasons, half way through the term of the study the groups should switch. If not willing to do this then you shouldn't be allowed to participate in the study.

2. It should be angler trip driven.

3. I think that the council should get the historic percentage that cfh has caught since the permits have been required and use a portion of that as a "quota" to work from.

4. as for seasonal restrictions, I thought that during the discussion of regional management it was said that one sticking point was the fact thaty according to MSA when the quota was met the entire gulf had to be shut down, meaning for that program, if Alabama or Florida started in January and Texas started in june, Texas may not get to fish that year. Now relate that to this program, If MSA says season has to start june 1, gulf wide and you say we are projected to meet our quota in 27 days, how would the pilot program continue into the closed season without an exempted fishing permit?

5. I think the transferability should be handled on a case by case basis.

6. Enforcement: VMS would handle the participants end, the feds/ game wardens would have to be responsible for making sure things are right at the dock. Consequences for violations should be SEVERE. If caught with red snapper outside of program window, 1st offense, removal from program and substantial fine, 2nd offense surrencder your permit. We are supposed to be professionals and should be held to a higher level of accountability than private recs.

7.VMS and dock side surveys for validation.

8. I am in favor of a days at sea program and would participate in the program. I want all the days I can get. I think that it would do nothing but help my business grow, being able to have days when weather is calm and safe to fish vs the "derby style" fishing we are now having to do in order to survive.

Thank You,

Capt. Darrell Hingle
Hingle's Guide Service
Galveston, TX
f/v Catillac

Hitchcock, Tx, 77563Charter/Headboat For-Hire
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4/2/2013 6:57:28Robert Marc Wilkersoncaptainmarc25@yahoo.comI would support a days at sea program for the charter for hire fleet in the Gulf of Mexico Freeport TX 77541Charter/Headboat For-Hire
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4/2/2013 7:07:51Steven Gaudetsgaudet14@gmail.comThis amendment is terrible and should not be adopted. How can you honestly think it is a good idea to give a hand full of people the "right" to half of the snapper?Houma, La 70360Private Recreational Angler
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4/2/2013 7:21:43Michael Deatondeaton888@yahoo.comThe red snapper season should be open to every person that have a license through out the season.Baton Rouge, La, 70810Private Recreational Angler
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4/2/2013 7:23:19John WatsonYellogrits@gmail.com Fisherman on charter boats are recreational fisherman! No special deals - No special programs like 'days at sea". Recreational fisherman should fish the established season.
No -to "days at sea" and No- to recreational catch share programs.
Pensacola, FL 32503Private Recreational Angler
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4/2/2013 7:34:26jeremey charbonnetjeremey@doctornetwork.comthis is a really bad idea. recreational fisherman do not get enough limits as it is.slidell, LA 70461Private Recreational Angler
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4/2/2013 7:36:01shane kesslerPSDMEDIC@AOL.COMThe fish of the Gulf of Mexico are for everyone not just a select few charter captains. You take away the right for regular people like to take my boat and go fish away. The charter captains will stave cause i wont use them and you can take this one to the bank also there will be more people catching and keeping snapper illegally than ever before.Pineville, La. 71360Private Recreational Angler
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4/2/2013 8:35:55Ray Weldonrwacesfull@gmail.comAbsolutely NO to the CFH Days at Sea Pilot Program. The Gulf Council heard a resounding NO from virtually all of the recreational fishing sector concerning sector separation and catch shares. The same still applies. This is catch shares and sector separation and just calling it a different name. MRFSS has not been corrected and is not completely up and running as it was supposed to be years ago. The data that would be used to gift the CFH fleet would be based on data congress has already determined needs to be corrected. This is the same bad data that continues to plague the recreational sector. There is no way to enforce the days at sea program and get any better data without a substantial increase in police presence. This is being pushed by a minority in the charter fleet who hope to gain substantially from intersector trading. The gifting of a public resource to charter captains so that they can retire and lease their quota is unacceptable. There is no provision for that payment back to the public for the gift of the resource. This is not for the benefit of the fish. Why should the private boat owning fishermen have fish taken from and given to charter captains to sell? This does not benefit the recreational anglers on board those vessels or on private boats. This is renaming sector separation and catch shares to Days at Sea just to hide it from the less informed public to get it through without getting the same backlash that given with sector separation and recreational catch shares. This will also force a lot of smaller part time charter captains out of the fishery. This should NOT be allowed!San Antonio, Texas, 78260Private Recreational Angler
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4/2/2013 8:58:07Michael Bergeronmlbergeron2@gmail.comI am opposed to this legislation. River Ridge, La, 70123Private Recreational Angler
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4/2/2013 9:00:49John Baquetjohnb17@cox.netI am Opposed the Charter-for-Hire Days-at-Sea Pilot Program. "Catch Shares" by any other name is still "Catch Shares." This would ultimately allow only a select few the right to fish for Red Snapper, and ultimately disenfranchise the poor and middle class who cannot afford to pay $600 for a charter. This attempt to keep legal and law abiding recreational fisherman from fishing has become obscene. Off the coast of Louisiana is it difficult to fish for anything but Red Snapper because the Red Snapper are so prolific; from 1 lb to 20 lbs. This is just a new means of putting a tax on fishing, when we already have to purchase multiple permits and licenses to fish. Baton Rouge, LA 70810Private Recreational Angler
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4/2/2013 9:14:32gary h parsonsparsonskg@cox.netFormer for hire, currently private recreationalNiceville, Fl 32578Other
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4/2/2013 9:16:18Buddy Bradhammotheroceancharters@msn.comI am against the days at sea program we all are recreational fishermen and dont need a sector separation so that a few can fish on days that are not open to the entire recreational fishing groupst Petersburg fl 33714Private Recreational Angler, Charter/Headboat For-Hire
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4/2/2013 9:30:59Jason McNeilmcneiljs@bellsouth.netPlease do not allow this to happen. I fish out of grand isle during the summer with my family and want to continue this tradition. Charters are not the majority fisherman and should not be allowed more than any recreational fisherman. My future voting and money will go elsewhere if this happens.
Respectfully,

Jason McNeil
Shreveport,La, 71115Private Recreational Angler
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4/2/2013 9:34:39Keith J Adamskja767@comcast.net I will not support this rule to let Charter/ Headboat for hire to take half or more of my Red Snapper quota. Who pays more taxes a few Charter boat Captains or thousands of Private Fisherman. I guess these Gulf Council folks don't know how to run a business so they had to screw up this situation.Houma, LA 70360Private Recreational Angler
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4/2/2013 9:35:59gary h parsonsparsonskg@cox.netFormer for hire, currently private recreational, conservation chair for Audubon.

You already know the answer. Of course the CFH would like more flexibility in allocating their snapper trips and their portion of the TAC. I am sure your volunteers will give you a completely unbiased study. I too would like a piece of the action. I have averaged 0.01 percent of the TAC for the last 10 years so just give me my 300lbs/yr and I will use it as I see fit including putting it in my will so my son and grandsons can use it too. Unless of course they want to sell it. I also promise to reduce my bycatch and stop high grading and doing catch and release. I know that is a really bad practice because it encourages depredation by dolphins and snappers are really poor candidates for C&R cause they have such a high release mortality rate. Mostly we hook our snapper on top to avoid this but they don't know any better and go down to the bottom despite our best effort to stop them. They are so damn big!!!!

When you figure out what you really want to do, please run this by us again in plain english and with a modicum of statistic soundness. Thank you for your concerns over our fish.

Niceville, Fl 32578Private Recreational Angler, Charter/Headboat For-Hire, NGO
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4/2/2013 11:29:03William Ericson-NeilsenWjn186@yahoo.comPlease do not take an already limited fishery that can be enjoyed by all and give part of it to a select few individuals who will auction off the right to fish it.New Orleans, la 70124Private Recreational Angler
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4/2/2013 16:02:15Thomas v. Brunellbrunelloutdoors@bellsouth.netI cannot support such a program that would give privileged rights to a select few, while taking away from the general public. No one user group has more right or privilege to our natural resources, Slidell La. 70460Private Recreational Angler
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4/3/2013 6:47:26Rick Linnricklinn@mmaequipment.comRegarding the days at sea proposal, I strongly oppose this proposal in it's current form.

The way it reads, this proposal allows for recreational fisherman to pay a charter boat to fish on any given day though out the year, while continuing to restrict the recreational fisherman. Why should the recreational fisherman with a boat or with friends and family only be allowed to fish within a very short window, not to mention giving up some of that limited quota to the charter boats? I honestly think this is illegal and discriminatory.

I believe that the days at sea would be a good proposal if it included all recreational fisherman, not just those who can pay for a charter boat.
Freeport, Texas 77541Private Recreational Angler
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4/3/2013 13:58:34Brad Yatesycolonialgroup@yahoo.comI am in favor of pilot program or AT LEAST SOMETHING. I think this is an issue that needs addressing and soon. The season has dwindled to point that it is affecting and threatening the charter business as a whole. I think much can be learned from the way the commercial side transpired and how it operates today. Transferability is something I am also in favor of and look forward to implementation. Waxahachie, TX. 75168Private Recreational Angler, Charter/Headboat For-Hire
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4/3/2013 14:42:07Timothy J Smithsmith3265@bellsouth.netI STRONGLY oppose Days at Sea. You cannot give special access to a portion of the recreational group. It is the same as sector separation. Please do not implement this.

Timothy
MobilePrivate Recreational Angler
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4/3/2013 14:43:22Miranda Sutherlandmirandapattersonsutherland@yahoo.comI STRONGLY oppose Days at Sea. You cannot give special access to a portion of the recreational group. It is the same as sector separation. Please do not implement this.

Mobile, AL 36606Private Recreational Angler
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4/4/2013 6:32:11charles weaverhweaver@sswce.comthis will increase the catch and profitability of the charter fleet at the expense of the recreational angler so i am opposed . i would love the opportunity to fish for snapper based on days at sea even if the days were far less than 27. even a two or three fish per boat limit and a longer season would help. we have so many snapper we catch them regardles of whether we are fishing for grouper, triggerfish or whatever. even with venting tools, many dont make it.

dont we need to be keeping the smaller fish and returning the larger? too many people fish all day and cull from their fish box as they catch larger fish, which are the breeding stock
regarding transferability of permits, it will hurt our area as we have so many snapper i see more trips here as the result.
auburn al, 36830Private Recreational Angler
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4/4/2013 18:55:31John Warren beaugh Jrj_beaugh@hotmail.comNeed program that we all report our catch.need new stock assessment data.
Gulf council say they never hear from the Rec fishermen . We all have 8 to 5 jobs not that easy to get off to go to meetings have some meeting on sat and watch the Rec fishmen turn out. For years Texas and fla state water open and they still had the same fed season that we la miss ala all had . La open state waters and then the gulf council wants to punish la and give us 9 day fed season cum on. God created all men equal
So why is the council treating some people better than others.Rec fishermen are hard working tax paying people we deservea hour fair share of the fishere in the gulf. So let's
All come together and cum with a plan. The one we have is not working bad data and it
Either Roy way are the highway
Opelousas la 70570Private Recreational Angler
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4/6/2013 13:38:12Andre L. Thomasthomasblackbear@bellsouth.netAs a recreational fisherman I do not want our public resource to be allocated to any private sector group for any reason. It should be assigned to the public first, then the private sector, commercial fisherman, can use what is left.Hammond, LA, 70403Private Recreational Angler
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4/6/2013 21:13:55Matthew Dillahuntymatthewdillahunty@gmail.comAs sector separation was tabled, there is only one recreational sector not two as you state in the introduction. I am against separation of the recreational sector as I was before it was tabled by the Council. Do not try to backdoor sector separation and gift any portion of our recreational fishery to anyone.
There is no need to try any new management schemes until you correct the data issue, as you were mandated to do by Congress.
It is not your job, nor should it be, to make individual business owners businesses profitable, that is their job as the business owners. This document clearly states this as the objective of the council. Charter operators can fish for Red Snapper year round, as any recreational angler can. They should not be granted special privileges any more than my business should.
In case you misinterpreted any of the following statements. I AM AGAINST ANY DAYS AT SEA PILOT PROGRAM OR ANY OTHER FORM OF SECTOR SEPARATION.
St Petersburg, FL 33716Private Recreational Angler
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4/9/2013 15:14:03Rick Linnricklinn@mmaequipment.comI oppose the days at sea as proposed. This proposal should also be available for the “non-profit recreational” fisherman as well as the “recreational for profit /charter” fisherman. I to would love to wait for that perfect weather day to go offshore. Further being a Texas residence it appears were only going to get 12 days offshore. Being June in the NW Gulf it means wind and lots of winds. I would say that at least twenty five percent (25%) of these 12 days will be weather blowouts. The recreational “non-profit” fisherman spend a lot of money into local economies as well and should not be discriminated against.Katy, Texas. 77493Private Recreational Angler
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4/13/2013 9:49:50Ricky Perkinsrebait1@gmail.comNo,how can this even be close to being fair? The CFH guys take recreational anglers fishing . Their clients should have no more access to the fishery than a recreational fisherman that owns his own boat. Why don"t you start doing something that helps all recreational fisherman instead of just picking the CFH and commercial guys, and quit treating us like we are unimportant. Chatom, Alabama 36518Private Recreational Angler
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4/15/2013 4:23:24Michael p Mixon Captainprestonmixon@hotmail.comI thinks you guy need to manage and stop making deal with the share holder alliance
And other entities that are not for the fish
But for the money
77554Charter/Headboat For-Hire, Commercial Fisher
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4/18/2013 8:41:13Debbie WilhiteCaptjack@zebra.netI feel this pilot program should be considered , approved and stidued as an alternate FMP for the CFH.


The current management program needs to offer some flexibility to the charter for hire for the following two reasons

1st.... Provide safety at sea. Derby Fishing when applied to groups who have to fish for a living is never the best approach. Derby Fishing has been tried in the commercial fisheries so having the same risk now being applied to the CFH is following the same disastrous plan as when the commercial were forced under it. It didn't work then and for the same reasons it not the right to the CFH.

2nd. ….Provide Economic Stability. Having the CFH days reduce each year in the red snapper fisheries has reduced the income of these boats by 30% or more. Most normal businesses could not sustain and continue in business if they suffered this kind of loss. These business might be able to whittle down these losses if they had a flexible schedule to choose when to fish. The ability to plan for the future can be achieved . The CFH has a moratorium in place for some time now and there is no new growth into the industry only loss of permits and our group are older now and another career at this time is not an option so we need to continue to look at programs that offer some type of stability to prevent any future reduction of this group of permit holders.

The best approach or plan that I would like to support is “days at sea” be measured in not days but numbers of fish. This would offer the most flexibility and economic stability when compared to days or trips etc. This way you could market your business to achieve the optimum income using the minimum use of the resource.

But again first and utmost it would provide safety at sea for both groups who make a living on the water....the commercial and charter fisherman and their crews.
Gulf Shores Al 36542Charter/Headboat For-Hire
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4/22/2013 10:00:32Todd Zbeczbec@hotmail.comOnce again stick it to the recrational angler. You all at the gulf council really suck asstampa floridaPrivate Recreational Angler
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5/1/2013 9:41:19Mark Tryonmdtryon@bellsouth.netI am not sure why this program would only require a one hour notification of landing when the commercial IFQ has always been 3 hours. Gulf Breeze,Fl,32563Commercial Fisher
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7/20/2013 11:43:11Capt'n Don WHITECOTTON Twamontg@aol.comNeed to do days at sea to protect public from being at risk for bad days at seas due to weather. This would allow us to take passenger on best days of sea conditions. It's not a fun experience for them to be out in rough seas.Pcb,Fl 32407Private Recreational Angler, Charter/Headboat For-Hire
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11/15/2013 14:30:42Brian Wyattbrianw847@gmail.comAbsolutley NO. Captians of For-Hire vessels that are pushing this Should be
Ashamed Of themselves. Karma Will Eventually Catch Up..
Recreational days at sea IS THE SEASON SET. Period. So If Joe Blow The Captain can Go, I should be able to Go as well.. Period.. Amazing Something this Ludacrist would even be up for Discussion.
Can We find Out WHO actually Dreamed this One up?
Totally Un-believable...pffft.
Port Mansfield Texas78598Private Recreational Angler
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4/3/2014 8:53:28Candy Hansardcandy@valp.netI oppose this program and I oppose sector separation that this program is designed to test. It is wrong for fishery managers to make a few winners and millions of losers by discriminatory allocations.

Charter boats are transportation for recreational fishermen and this program treats private recreational fishermen and the un-gifted charter operators unfairly by allowing 17 boats in the entire GOM to fish year round AND to take 5.3% of the entire RS fishery leaving just 43.7% of the RS fishery for millions of recreational fishermen (private and charter transported) the combined Gulf states. This is wrong.

The charters that "think" this will program will include them in the future need to do the math. According to the GC, in 2011, the entire GOM chater industry harvested 19.4% of the gulf red snappers...now, just 17 boats have 5.3% of the entire gulf RS quota? Do the math: That means that those 17 boats now have the exclusive rights to 27% of the charter landings! Do you really think there will be a thriving charter industry if this passes? If you're not one of the already chosen ones already, you probably will be among the losers if this scheme is adopted by the Gulf Council.

Sector separation will make a few of the chosen charter operators very wealthy but will put most charter operators out of business and will most certainly put a lot of boat manufacturers, boat sellers, marina owners, bait & tackle shops. that rely on the private sector, out of business too.

I strongly oppose this program and sector separation.
3Private Recreational Angler
47
4/28/2014 13:42:27Michael Vollemlv@kwikool.comI understand the recreational fishermen and their opposition to this program as it seems that this is another way to take their resource away as it has been taken from all of us little by little. with the exception of maybe the commercial guys.

the problem with the days at seas isn't that charters get a portion of the fish its that charter users, who also get their recreational limits will get an unfair share of the resource.

There is a need to change the way we do business and I recommend the following

1. limit number of fish by zones. the gulf is a big place and for example snapper in Texas may be more abundant than in Florida wit less pressure. so Texas should get more fish. and there are more grouper in fla than in Texas. so grouper limits should be lower in Texas than in fla

2. In stead of having limited seasons give fishermen an allotment of fish. tags or some other method of showing fish allowed per fisherman. So all recreational fishermen would be treated equal regardless if they use a charter or not. if they had tags or way to show they haven't caught their fish for the year, then you wouldn't need days at sea. just available tags for each fisherman.


Houston, Texas 77045Private Recreational Angler, Charter/Headboat For-Hire
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4/28/2014 14:53:07Warner Fosterjwkillntime@gmail.comBAD BAD idea. Only the selected privileged few will be happy. The remaining will be disgruntled. The disgruntled group may commit acts such as targeting Red Snapper out of season letting them lie on the deck before throw them back. The privileged few would be taking fish which belong to all. allowing the privileged few to fish the best weather days means they will catch lot of fish. The Panama City area is blessed with some great weather but not in June. We usually experience only one day a week with less than three foot seas. If the good day falls on the Sabbath or a work day, we can only hope for a good day the next week.

If you decide to adopt this proposal, my comments are:
1. Transferability Provision;
There should not be any such provision. Right now under other rules allotments/quotas are being sold to the highest bidder. Therefore, a person who is luck enough to get an allotment/quota, even though they don't want to fish, sell it to someone who may already have a allotment/quota. The seller assumes on risk yet reaps money as a rewards.
2. Enforcement;
Any vessel which is selected should be required to report by VMS. All participating vessels should be required to report to a specific location for inspection and no one should be allowed to exit the vessel (except for medical emergencies) until released. The person conducting the inspection should also interview all passengers in an attempt to ascertain weather any illegal activities went on during the trip. Such illegal activities may include, stowing illegal fish, improper tackle, drug usage, improper care and handling fish, etc.
The penalty for any violation should as a minimum result in the loss of their permit.






32405Private Recreational Angler
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