If y’all have not heard, the State of LA is seeking approval of an Exempted Fishing Permit to test a catch share plan for pri rec anglers. A strong rumor has it that EDF helped develop, if not totally developed the proposal for LA. Pretty much every rec org has come out opposed. If this efp is allowed to proceed it could be devastating to the recreational sector as a whole. I sent the below to the Gulf Council as they will be discussing this next week at their meeting. The RA for the NMFS Sero, Dr Crabtree can approve the efp regardless of any opposition. I will keep all posted on the outcome.
I will be sending a similar letter to the SOC in a few days.
On behalf of the members of the Panama City Boatmen Association (PCBA) and the National Association of Charterboat Operators (NACO) I want to express our extreme opposition to the proposed EFP presented by the State of Louisiana. This proposal is an effort to explore a recreational catch share system, which the vast majority of all recreational anglers are adamantly opposed. This proposed EFP does not even attempt to properly address a true catch share system.
This proposal provides for a lottery to select 150 private recreational boat owners to participate in the program which will provide 25,000 pounds of the LA recreational projected annual harvest of 14% (1.098 million pounds) of the total Gulf recreational harvest. The 14% number was developed in the Council rejected proposed amendment 39. A key problem with LA using this number for the EFP that is restricted to private recreational anglers is the 14% includes all recreational anglers which includes charter/headboat for hire recreational anglers. The 25,000 pounds projected to be gifted to the 150 lottery winners will come out of the total recreational fishery. The charter/headboat for hire fishermen will not be eligible to participate but will lose access to 25,000 pounds of available red snapper. This proposal discriminates against LA charter/headboat for hire vessel owners.
In addition, the proposal will allow the 150 participants to fish under the LA state recreational red snapper season and be gifted approximately 20 red snapper +/- outside the state season. Other than gifting 20 red snapper +/- how will this EFP prove that anglers will support and the fishery can be better managed under the proposal? Frankly, anyone would support being able to land more fish than allowed under a state season, an EFP is not necessary to prove such a concept.
The use of a lottery to select 150 lucky participants only differs from having to pay for the right to have red snapper gifted exclusively by the fact the fish are provided without compensation. Use of a lottery, by definition, allows only those individuals fortunate enough to win. If such a system were to ultimately be the mechanism to select the lucky individuals those who are not selected will lose access to the fishery and have no opportunity to harvest red snapper. This type of management is only to reduce fishing capacity and will cause much social and economic harm to the many small family businesses who support recreational fishing activities. In addition it will be socially and economically destructive to the small local fishing communities in LA and eventually to the rest of the Gulf and the Nation. This proposal is contrary to the current goals of the Trump Administration which is to promote business opportunities and to eliminate regulatory restrictions.
Another reason this proposal is unrealistic and should be denied is the math of the fishery. LA proposes to provide 20 +/- red snapper to each of the 150 participants using only 25,000 pounds. This equates to an average size of 8 + pounds per red snapper. According to LA officials I have spoken to there are 15,000 to 20,000 LA offshore anglers licensed to fish off LA. Using the 1,098,000 million pounds that are projected for the LA allocation under A39 and should the proposed EFP become the program for LA anglers and assuming the number is 17,500 (the middle of 15,000 to 20,000), and all anglers would be provided a share, it would amount to approximately 8 red snapper per angler, less than half of those provided for in the EFP. Under a lottery system, in order to increase the number of red snapper to be close to 20 per angler, more than half of all LA offshore anglers would be eliminated from the fishery. While this may be the ultimate goal of the proposed EFP to reduce the number of anglers able to fish, it is not fair and will work to destroy the recreational fishery in LA, the Gulf, and eventually the Nation.
This proposal is not necessary to achieve the stated goals of the plan. There are many other less destructive ways to improve real time data collection without eliminating participants. Flexibility for anglers fishing time is restricted to a predetermined number of anglers selected by state managers. The rest of the anglers are eliminated. The simple fact is if you want to provide more flexibility to anglers in order to fish whenever they want, eliminate more than half and the rest will certainly be able to fish whenever. There are also other, less destructive means to provide fishery managers with real time harvest data.
This proposed EFP is ill-conceived and only serves to prove what is known, eliminate anglers and those few that are left will have unlimited access to the fishery. This proposed EFP must be rejected.
Sincerely,
Capt. Bob Zales, II
President
NACO and PCBA
I and many others will not be in attendance for the Council meeting beginning on Monday since we will be fishing for red snapper for the short 49 day season. The above is my testimony that would be stated if I was there.