Public_Comment_Display


2	Fishery Management Issue Under Consideration
3	Amendment 59: Requirements for Participation in Individual Fishing Quota Programs
4	Submit Date	Email	Name	City	State	Zip	Affiliation	Comment
5	6/24/2024	eric@shareholdersalliance.org	Eric Brazer	Galveston	Texas	77550	NGO	https://drive.google.com/file/d/1SHbgWJ5UaQH0WUb7vKCOEK3kZlweHDwZ/view?usp=drive_link
6	8/20/2024	eric@shareholdersalliance.org	Eric Brazer	Galveston	Texas	77550	NGO	https://drive.google.com/file/d/1K7SZizvT8n3F6FI5v8Z-LLTmqEXAvSgz/view?usp=drive_link
7	8/20/2024	jsharnowski@yahoo.com	Jeff Sharnowski	Madeira Beach	Florida		Commercial	My name is Jeff Sharnowski please read the attachments to know my background and previous comments. To the new members welcome, this is about the IFQ system. I implore you to do your due diligence on the IFQ subject, there are bureaucrats on the council with fantasy like expectations on what they believe is happening and will happen in the fishery. You will hear phrase like “give it back to the fisherman on the water” please read Dr. Crabtree’s comment on this from the June 2017 meeting. If you’re talking about owner operators, you can help them. But ask the right questions, just how many are there? Does anyone even know? If not, exactly who are we trying to help? I was also told by a council member that there will be some “pain” involved in this process, it's really easy to dish out the pain when you’re not the one feeling it. Lowering the lease fees is an admirable notion, but will what you do here actually do this? Or are we pricing new fisherman out? Why is it so high anyway? Is possible it is because of supply and demand? How do we lower the demand? The fact is you can never control it, government entities have tried this before it just does not work. Let the free market the council has created work itself out. The lease fee is never going away that genie has left the bottle, when an owner buys shares, they half to recoup that cost and taking it from the boats share of the catch won’t do it. Ask to show proof on how a goal is to be accomplished, or will it turn out to be another unintended consequence? I would like to return to the fishery when the Red Grouper quota returns to an amount that I can actually make money. Until that happens I can’t!!! So, you’re going to either force me to get back into the fishery before its profitable for me or cell my shares to the highest bidder, and I highly doubt it will be a smaller fishing entity. In conclusion the program works, anyone getting into this fishery after 2010 knew exactly what they were getting into. If they didn’t do their due diligence, it’s on them. Any type of “if you don’t use it, you’ll lose it” will create another derby style fishery. Also, the phrase you hear “reclaimed shares” has already accrued. From this point forward they will always be sold never reclaimed. Remember ASK QUESTIONS!!! Thank you for your time I have much more to say on this subject please email me to get my phone number I would enjoy talking to you any time weekends or nights.
8	8/22/2024	jsharnowski@yahoo.com	Jeff Sharnowski	Madeira Beach	Florida		Commercial	Just to be clear I'm not in favor of keeping the shares in-perpetuity, but not all of my shares were given to me I bought some on the open market. I was investing in my fishing business; I am still able to fish if you read "My Background" attachment it's in there. Why I got out and why I'm not currently fishing, because it's just not feasible with the Red Grouper quota this low. I fished those qualifying years, why should I be forced to sell my quota just because I made a business decision not to get another boat when until the Red Grouper recover? I am still young enough to do the thing I loved most and because I'm a smart businessperson you are going to make me sell? The Council needs to let this play out, get rid of the investors we never wanted them in the first-place talk to Dr. Crabtree. I guess I'm just pissed that people got into the fishery without getting fully invested by getting their own quota. I want to get back into fishing, but I don't need a government entity telling me I should no matter if I can make money at it or not. I will make money at it again if you don't steal it from me.
9	8/22/2024	jsharnowski@yahoo.com	Jeff Sharnowski	Madeira Beach	Florida		Commercial	Well, I guess congratulations are in order. You have final admitted in open council that what you are doing is NOT going to make a difference. But if it makes YOU feel good, I guess that is all that matters. What the "fisherman" at the dock you're talking to don't realize is quota and allocation isn't going to increase for them and the lease price isn't going down because you made everyone get a permit. It will probably have the opposite effect. But you will have done "Something". What will happen is you're going to make the quota dry up for a lot of the smaller fisherman and people that just lease. Then again maybe it's a good thing, help get rid of the complainers who are just hanging on hoping it will go back to a non IFQ system. My advice is listen to people like Scott Hickman and Jason Delacruz. Also just get rid of the allocation brokers.
10	8/22/2024	captedwalker@gmail.com	Ed Walker	Tarpon Springs	Florida		Charter/Headboat (Federal For-Hire), Council Member	Thanks Mr. Sharnowski. I appreciate your input on this difficult subject. I too am a relatively small IFQ shareholder. I have some grouper quota and some red snapper. All together it isn’t enough for me to make a full time living as a commercial fisherman so I understand where you are coming from. I fish the winter months, catch most of the quota I own, and then do other things like charter fish at other times of the year. I put a lot of thought into AM59 and AM60 and I often talk to the commercial guys around the docks about it. Currently my views are this; encouraging some of the very large shareholders who do not fish to cash out their holdings, for large sums of money, is a good thing for the industry as a whole. If shareholders continue to believe that there is a never ending cash flow by taking shares with them when they retire, or hoarding more than they need, eventually all shares will be “on the couch” and all of us fishermen will be relegated to be renters. If some hundreds of thousands of pounds of quota shares go back into the market, supply will go way up, and perhaps demand will thin out a bit, and prices will likely come down or stabilize. In fact I think we may even end up with even more positive results than anticipated if we move this thru. Either way I believe shares belong in the hands of people who fish and participate in fisheries, same as it did in the first 5 years of the program - fishermen only- no investors, no retired fishermen, and no speculators. PBP- Permit Boat Participation. Shares sitting on the sidelines is the problem and it’s time it was addressed. A majority of the commercial fishermen that contact me and the ones I chat with around the docks agree. If I quit commercial fishing it will apply to me and my shares too. I accept that. If a shareholder like me does not catch even 20 percent of his annual quota is he still a commercial fisherman? Should I be issued 100 percent year after year to rent to another guy who makes $2 a pound while I make $4? A majority of folks I talk to say no. This is my personal opinion and not that of the Council. Capt. Ed Walker
11	8/22/2024	mm@pelicanpointbiloxi.com	Michael McDermott	Biloxi	Mississippi		Council member, Atty, Marina Owner	Fellow Council Members, We have heard several public comments on Amendment 59 pertaining to the proposed permit and activity requirements. The comments coming from shareholders have either expressed an indifference to the proposed changes or an indication that they would reduce opportunities for fishermen. I tend to agree with their sentiments. The permit requirement might be effective in forcing out investors that control a relatively small numbers of shares. Investors that have hundreds of thousands or millions of dollars invested in shares will acquire a permit, it is my understanding they are traded for around 20-30k. I do not believe it will have any appreciable effect on putting shares in the hands of fishermen, any shares that are forced into the market will be acquired by investors that acquire or already hold a permit. The activity requirement will simply change the business model from a leasing structure to joint venture type scenario. Instead of the fisherman leasing the allocation from the shareholder for a price per pound the fisherman or the fisherman’s operating entity will become a member of the entity holding the shares. The fisherman will continue to land the fish, however they will be landed under the shareholder’s entity and that entity will then become “active” for purposes of the program. The revenue would then be divided in the same way it is now. Using the numbers that were given in today's example the shareholder would receive roughly 75% of the ex vessel price with the fisherman receiving 25%. Of course if we were to impose an activity and a permit requirement the shareholder would kill two birds with one stone here as he would receive the benefit of the fisherman’s permit, after shuffling some paperwork at SERO, and his activity. This scenario assumes the shareholder wants to maintain a “status quo” relationship with the fisherman and not use the additional leverage he has received by the implementation of the activity requirement. If the shareholder is unwilling to enter into a joint venture type relationship with the fisherman he might require the fisherman to lease his boat and crew to the shareholder’s entity for a fixed day rate. The day rate might actually net the fisherman less than the leasing structure did. If the shareholder becomes unsatisfied with the fisherman’s efficiency he contracts with a new fisherman that can harvest the quota in fewer days or for a lower day rate, leaving the fisherman with a boat outfitted for a specialized fishery that he can no longer participate in. If enough fishermen find themselves locked out of the fishery shareholders will acquire their boats at severely discounted rates and hire the same crews that once owned the boats to harvest the allocation. Shareholders might find they can harvest a given amount of allocation with fewer boats or multiple shareholders could merge into one entity and use the same boats to harvest multiple shareholder’s allocation. In these scenarios many boats might be taken out of service. Other terms used for this are “consolidation” “decapitalization” and “vertical integration” sophisticated terms for taking working men and women off the water. These are goals of many commercial FMP’s that in my observation are catastrophic for fishermen and fishing communities. I offer these thoughts with the caveat that Mississippi does not enjoy a large IFQ fishery and I am a recreational representative on the council, for these reasons I have not been vocal on the subject. With that being said I am a voting member of the council and I do feel an obligation to move the council in a direction that is consistent with our goals. I do not feel that what I have heard of these proposals will move the council in the direction we desire. Many have identified the above scenarios as “loopholes” in the policies. I disagree. I believe these policies will exacerbate the type of behavior we seek to prohibit. Michael
12	8/22/2024	joe.spraggins@dmr.ms.gov	Joe Spraggins		Mississippi		MDMR MS State Representative	Responding to Michael McDermott letter: I agree. I think we should listen to the fishermen yesterday. They do not want a boat to be a requirement. Most don’t want to buy in and want to continue buying from the ones that own them
13	9/4/2024	mdtryon82@outlook.com	Mark Tryon	Gulf Breeze	Florida	32563	Private Recreational Angler, Commercial	This council should commission a white paper to analyze the consequences intended and unintended of proposed actions in this amendment. At this point I have a few comments as an IFQ shareholder since the inception of the program in 2007. A reef fish permit was originally required to participate in the program. The Gulf Council, not the fisherman decided for whatever reason to do away with this requirement. At the last council meeting a young woman asked the council why they did away with the requirement and was not given an answer. At this point mandating a permit requirement will surely increase the demand and price for permits. This council claims to be interested in helping new entrants. Increasing the cost of a reef permit clearly negatively impacts new entrants by increasing start-up costs. Landing requirements may penalize fisherman who are negatively impacted by what this council likes to describe as localized depletion. Red Snapper anglers in the eastern gulf are currently experiencing this phenomenon. Overfishing in Florida by the recreational sector has severely depleted the red snapper stock. This negative development has coincided with the advent of state management of the resource. More and more recreational anglers are targeting red snapper in Florida waters. To compound matters the state has been consistently adding recreational fishing days even though it is obvious to all that the stock is experiencing a drastic decline. For years preceding state management, I was able to easily catch 50 percent of my annual allocation. Now it is unlikely that I will catch 25 percent. My landings per trip have declined significantly since the advent of state management. 74 pounds of red snapper on my last 13 hour rod and reel commercial day trip is disastrous evidence of the decline. In summary I urge this council to proceed with caution in regard to the development and implementation of amendment 59.
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