Proposed Limited Entry on Charter For-hire Vessel Permits

From: Bob Zales 2 [mailto:This email address is being protected from spambots. You need JavaScript enabled to view it.]
Sent: Monday, December 05, 2016 10:53 AM
To: 'Gregg Waugh'
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Subject: proposed limited entry on charter for hire vessel permits
Importance: High

All,

I am President of the National Association of Charterboat Operators (NACO) and we represent for hire charter boat owners and operators from Alaska to Maine including Hawaii, the Great Lakes, and Caribbean Territories.  Many of you know me and the rest have heard of me and my over 26 years of active involvement in the fishery management process on all levels.  For anyone who does not know of my history here is a brief recap.

I was the charter boat representative working with the Gulf States Marine Fisheries Commission and helped develop the current “For Hire Survey” which was and is a dramatic improvement on how for hire recreational data is collected in the Gulf and South Atlantic.  I served on the working group that developed the current guidelines to build and place artificial reefs.  I was among the first 30 appointees to the Marine Protected Area Federal Advisory Committee where I served as Vice Chair during my last two years on the Committee.  We developed the original “Framework for the National System of MPAs of the United States of America”.  One of the most important panels I served was as Chairman of the Gulf of Mexico Fishery Management Council Ad Hoc Charter/Headboat Moratorium Advisory Panel.  Our recommendation for the current for hire charter/headboat limited entry program in the Gulf was the foundation of the current Gulf Moratorium on charter/headboat permits.

NACO has been and currently remains adamantly opposed to charter/headboat limited entry programs.  Our position was developed and has been reinforced several times since 2010.  I and others were first recruited by Drs. Hogarth and Crabtree in late 1999 to recruit and garner support for a limited entry program for charter and headboats in the Gulf in order to, in their words, “be able to maintain a 6 month season and 4 fish bag limit for recreational red snapper.”  They also told us that by creating a limited entry program we would not be reducing capacity, we would only cap capacity and this would ensure that our 6 month season and bag limit would be secure.  We were promised that the program would work to the benefit of the recreational sector as capping the number of charter and headboats would prevent expanding the fleet and prevent over harvesting.

The AP members worked hard to convince for hire vessel owners that the NMFS program would be good for them, even if they did not fish for red snapper as many for hire vessel owners and operators did not catch red snapper at that time as other reef fish were their targets.  After the Ad Hoc AP finished our work the council developed the current moratorium program.  Once the program was finally enacted, it was delayed due to NMFS mistakes, it was not long before many of us realized we had been duped, lied too!  The moratorium and capping of available permits did not work to maintain our season, indeed in 2007 we were restricted to 4 months and have seen a steady decline in the number of available days since with a reduction in the bag limit from 4 fish to 2.  The limited entry program has resulted in an additional stock market for fisheries along with IFQs as permits are traded back and forth for profit.   

Shortly after the moratorium program was implemented and I began to see how we were grossly misled and the program was working to eliminate for hire vessel owners from the industry I admitted  my mistake of advocating and support.  Working to develop the moratorium has turned out to be one of the biggest mistakes I have made in my fishery management activities.  This is why I fully support the NACO decision to oppose any form of limited entry and catch share program for recreational for hire charter and headboats.  The SAFMC will do a great service to the recreational for hire charter and headboats in their region and others by voting for status quo on proposed amendments 45, 31, and 11 and oppose limited entry.  Limited entry in the recreational for hire industry will only serve to destroy the for hire vessel industry and will work to eliminate access and opportunity for the many people who utilize recreational for hire vessels to recreationally fish. 

NACO strongly encourages you to OPPOSE any form of limited entry.

Thank you,

Capt Bob Zales, II

President

NACO 

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