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Could you support this Plan?

Tom HiltonTom Hilton Posts: 1,585 Captain
Here is a Plan that lays out what needs to be done and why, and as importantly how to fund it. I personally would be more than happy to pay $25 for an annual snapper stamp, similar to how I pay for a duck stamp each year. This would identify the universe of anglers who target reef fish and provide a target-specific pool from which to get more information.

I would think that $45 million per year would be more than enough to get the job done. I don't think the fishery would crash during a 3 year EFP with 6 month seasons/2 fish. As the sector separation boys are just now figuring out, not having a realistic catch history will come back to haunt you.

It’s time to take the blinders off and see what has actually happened over the last decade since the Hijack of our fisheries management in the 2006 Reauthorization of Magnuson - you may be surprised at what you see vs what you are being told.

In the years leading up to 2006, according to the scientific experts, our Gulf red snapper fishery was already on the rebound, even with our 194 day seasons and 4 fish bag limit!

Unfortunately, that was the same year that The Environmental Defense Fund’s Oceans Team was “instrumental in crafting and passing the 2006 Magnuson-Stevens Act which introduced a market approach to protecting our oceans...(Catch Shares in our commercial red snapper fishery)”. Each year since, our federal fisheries managers have worked in collusion with The Environmental Defense Fund to reduce our seasons/bag limits (based on highly questionable data) in an attempt to justify the end game; implementation of the so-called solution - Catch Shares in not only our Gulf of Mexico red snapper fishery, but eventually ALL of our federally managed fisheries.

Fast forward to 2017 - 10 years after the Hijack and take a look around. How has this push to privatize our fisheries worked for ALL stakeholders in our Gulf fisheries? I submit that it has been a dismal failure. The commercial red snapper industry has been consolidated into the hands of just a few people, and many of these IFQ shareholders don’t even fish anymore - they just lease their quota to other fishermen for the going rate of about $3.00/pound. They have access to the fish 365 days per year, and enjoy the bounty of the profits made from the harvest of our Public Trust Resources without paying one penny in Resource Rent to the nation unlike other industries that profit from the harvest of our Public Trust Resources. And, they use these same profits to fund lawsuits against their perceived competition - Gulf of Mexico recreational red snapper fishermen, to disallow them access to the commercial’s perceived assets (OUR fish) for 97% of the year.

The Gulf Council/NMFS allowing this to happen is a flagrant violation of our Public Trust.

The recreational fishing industry has literally been torn apart by EDF’s Sector Separation scheme - a scam deemed necessary by Gulf Council/EDF/NMFS in order to implement Phase 2 of the introduction of the “market approach to protecting our oceans”; Catch Shares for the for-hire corporations. Even after all the scheming and plotting by the EDF front groups over the years, Sector Separation is looking a LOT worse than advertised. Charter and headboat captains are looking to be locked into annual catch quotas that are but just a fraction of their historical landings, and could face even further reductions due to payback provisions if they exceed their artificially low quotas. Never mind that staying with seasons and bag limits would give their clients about 3 times the number of fishing days each year vs going to IFQs or PFQs - the EDF front groups believe that is just necessary collateral damage in order for there to be a transfer of ownership of OUR fish to private hands. This is BS.

Phase 3 of the “Plan” is to inflict Fish Tags on the private recreational anglers even though we only got an 11 day season in 2016 (a 97% DECREASE in access from 2006 levels). The Gulf Council recently formed a Private Recreational Angler Advisory Panel specifically for Fish Tag implementation! If they had implemented Fish Tags for the private recs during the 2016 red snapper season, we would have gotten 422,227 fish tags, or not even enough to give each red snapper fisherman in Florida 1 tag per year - the rest of us would be totally out of luck and totally shut out of the fishery. And this is happening when, due to the un-needed draconian regulations and resulting drastic reduction in access to the fish over the last 10 years, the red snapper populations are EXPLODING.

Enough of this foolishness - it’s time to focus on solutions that ACTUALLY WORK!

We have given Catch Shares and associated management measures 10 years and they have failed the LARGE MAJORITY of stakeholders in the fishery and caused BILLIONS of dollars in damages to Gulf coastal communities and businesses needlessly.

It’s time to take a look at a different course of action;

1) Reauthorize Magnuson prohibiting implementation of Catch Shares in any recreational fishery. Remove management of the Gulf fisheries (recreational AND commercial) from the control of NOAA Fisheries and give the management to the coastal states via HR 3094 or similar Congressional legislation.

2) Allow the states to manage the fish landed off of their coastlines out to 200 miles, and give them the power to set their own seasons/bag limits based on what the ecosystems, fisheries biomass, and level of effort found off of their coastlines will allow on a sustainable basis. Currently, fishermen in Texas are being managed by what is happening off of Florida - it’s absurd. It’s analogous to Texas deer hunters being managed by deer populations in Alabama - there is no scientific, ecological, nor economic rationale for managing the Gulf fisheries as a whole. There would be no need for 30B which unfairly penalizes for-hire businesses.

3) We need hit CTRL/ALT/DEL and revert to TANGIBLE pre-Hijack levels and start over for a 3 year trial period. Tangible pre-Hijack levels means 4.65 million pounds for the commercial red snapper fishery and reinstating our 194 day red snapper season - this is what we had in 2006 prior to the Hijack. The only difference would be that instead of a 4 red snapper limit per person, we would stay at the current 2 fish per day per person April 21st to October 31st each year. This level of harvest can be sustained for a 3 year trial period (2018-2020) as we gather the critically important biomass assessment and effort/landings data critical in making informed fisheries management decisions.

4) Each state would be responsible for implementing a mandatory recreational effort/landings system during this 3 year trial period that would track how many anglers are actually fishing offshore, what species they are targeting, and how many fish they are landing. Any state that wants to opt out of this mandatory requirement will be managed by the current failed federal fisheries management regime.

5) Each state would be responsible for implementing a viable assessment program to determine how many fish are actually swimming offshore of their coastlines. Unlike current assessment models, this would be required to include fish found swimming around oil platforms and artificial reefs. Current federal fisheries managers claim that these fish are already accounted for, but there is no realistic way to ascertain how many fish are actually swimming in the water by counting dead fish on the dock. Any state that wants to opt out of this mandatory requirement will be managed by the current failed federal fisheries management regime.

6) Each state would determine the amount of commercial fishing allowed offshore of their coastlines. Currently, there is a 48.5% commercial/51.5% recreational allocation split across the Gulf, but there is probably a 70% commercial/30% recreational split off of Texas/Louisiana. The determination whether or not this is in the best interests of each state (and their ecosystems) should be made at the state level - NOT the federal level where they have an obvious bias AGAINST recreational fishermen.

7) Require that commercial IFQ Sea Lords bid on leasing their quota directly from the state fisheries commissions each year by the fishermen ACTUALLY doing the fishing - the nation deserves a return on its investment in our Public Trust Resources. Enact a true 6% cap on allocation. Enclosed is a proposed Resource Rent Payment Schedule which illustrates how this could provide millions of dollars EACH YEAR that could be used to help the fisheries; better data, habitat enhancement, enforcement, management, etc. instead of going into private bank accounts which is currently the situation.

8) Prohibit leasing between fishermen which would take away the “legal defense fund” that the current system promotes and enables by providing “free money” through leasing their shares. If there is any leasing to be done, it should be between the commercial fisherman ACTUALLY DOING THE FISHING and the state fisheries commissions.

9) Require all recreational fishermen to purchase an annual $25 reef fish endorsement (or $5 per day for out of state fishermen) to go towards the collaborative fund between the states to be used for better data collection, enforcement, management, and habitat protection/enhancement. There would be no need for Sector Separation as ALL recreational fishermen would be grant equal access to the fishery.

10) Enact accountability programs between the states to ensure that each state manages their fish properly by not allowing overfishing to occur, protecting fish stocks while providing reasonable access to ensure that the fisheries are sustainable now and for generations to come!

Here is a breakdown of how this could be funded;

I’m not sure exactly how many recreational fishermen target reef fish, but I would venture to guess that there are probably around 1 million anglers here in the Gulf. This could raise $20-$25 million annually but let’s say an average of $22,500,000.

Here is an itemization of the species and poundage (gutted weight) in the 2017 Gulf IFQ program and the suggested price per pound resource rent to be paid by the commercial sector;

IFQ Species Poundage Suggested price per pound Total
Red Snapper 6,003,604 $2.00 $12,007,208
Gag Grouper 939,000 $1.00 $939,000
Red Grouper 7,780,000 $1.00 $7,780,000
Shallow Water Grouper 525,000 $1.00 $525,000
Deep Water Grouper 1,024,000 $1.00 $1,024,000
Tilefish 582,000 $1.00 $582,000




* This gives a whole new perspective (and energy) as to where we are at currently and where we are headed;

* Each sector (commercial/recreational) contributes roughly equally to the fund.

* Commercial fishermen are allowed to fish year round like they do now which is best for the consumer and their businesses.

* Recreational fishermen who fish on private boats and for-hire boats have their seasons restored to levels that provide equal and adequate access plus security for the for-hire businesses.

* Gulf coastal communities and businesses will enjoy the economic benefits of restoring our access to the tune of hundreds of millions of dollars annually.

* At the end of the 3 year trial period, results can be analyzed to determine what levels of harvest, season days, etc. that would be suitable offshore of each state to provide long term, sustainable fisheries for their fishermen for years to come!


  • drgibbydrgibby Posts: 1,525 Captain
    Sounds good to me.
  • FletchFletch Merritt Island, FLPosts: 2,461 Moderator
    It's great that you are passionate Tom. Some good ideas in there. If I could offer some constructive criticism...

    Chop your post down to a bullet-style list. Remove terms such as Sea Lords, Hijack, Absurd, Scam, etc.

    In short, edit it down to a level that the average Joe (as well as those in positions of influence) could digest much faster and without being offended. I think you will endear more people to your cause with such an approach.
    "Ninety percent I'll spend on good times, women and Irish whiskey. The other ten percent, I'll probably waste..."
    -- Tug McGraw on getting a raise

    Get Down Fishing Charters - Port Canaveral, Florida
  • TrippleTailIVTrippleTailIV Posts: 197 Officer

    I agree with Fletch, essentially, less is more. Let them bite on the idea, then you can explain why. Too many words puts people, especially politicians off. You just have to get in the door, then back up your ideas. And you have some good ideas here that I would hate to see lost. If you want to put this up for consideration, look up 'one-pagers with the google.

    As to your ideas, some are quite good; but who would be the central group to hold commercial quota? This may mean creating yet another bureaucracy that inevitably takes more money to do less. You're also looking a a major legal battle that will last years. I'd say leave the commercial guys where they are with the quota they have now. Then have all future ACL increases go to the rec angler for all species. I'd also impose a higher commercial landing fee (recovery fee?) on par with some sort of inflationary cost annually, but immediately raise by X percent to levels you've noted elsewhere.

    when you speak of allocation percentage, I think what you have there is just for red snapper. As I recall seeing somewhere here, red grouper has a 75:25 commercial to rec split and trigger has the opposite at 25:70 split. You might want to consider just using the 1st sentence of that point.

    I really like your idea of more dollars for research and landings. That is a key thing. I too would be willing to pay if I knew it was going for that and not into some general money pot.

    I'd also increase your timeline to 5 yrs. Two years to get the legislation and state programs online, then your 3 yrs of fishing. The good thing about this is the longer it is effect, the harder it is for it to go away.
  • Tom HiltonTom Hilton Posts: 1,585 Captain
    Thanks for the feedback - I agree on bullet points and removing potentially offensive language.

    I would like to see the same commercial shareholders maintain their current % of TAC, but reduce that TAC to the 2006 level of 4.65 million pounds - there are far less commercial operations now than in 2006 so the ones still in operation will still be getting more fish than they did in 2006. They can still fish year round but they need to be leasing the fish from the government, relative to their allotted %, and those funds directed to the Gulf States Marine Fisheries Commission as stated in HR 3094;

    ‘‘(a) FUNDING TO THE GULF STATES MARINE FISHERIES COMMISSION .—The Secretary shall provide all Federal funding to the Gulf States Marine Fisheries Commission for all necessary stock assessments, research, and management for the red snapper fishery."

    The law states that is in the jurisdiction of the fisheries managers whether or not to levy Resource Rent, so I do not believe the commercial entities would have a leg to stand on. If lack of funding for research, assessments, habitat enhancement, etc., is a major reason for it not getting done, then why is our Gulf Council allowing hundreds of millions of dollars in resource rent go uncollected over the last 10 years? They have the power to do it, they just are doing the bidding of the commercial interests at OUR expense.

    We need to get away from the idea of managing our recreational fisheries like they are commercial operations. Commercial fishermen sell their catch by the pound, so they should be regulated by the pound - I get that. Recreational fishermen have been regulated by seasons/bag limits for decades, and it works just fine - it should not matter how much the fish weighs. Our state fisheries managers have been managing speckled trout, redfish, flounder, ducks, doves, deer, etc. using seasons/bag limits - it's when there is a commercial value do the federal fisheries managers want to manage by the pound, as it makes it easier to commercialize the recreational fish through leasing, selling, etc. Manage our recreational fisheries by seasons/bag limits - it works - no need for a recreational poundage allocation at all.

    The health of the biomass would be regulated by annual assessments and if there are any changes needed, it can be done quickly, unlike today's antiquated fisheries management failure. For example, I was inquiring about the headboat landings for 2016 - they said they were still waiting on wave 6 data. What? How hard can it be to report the landings of a 44 day season 6 months ago for 67 boats? It's beyond ridiculous.

    The 5 year timeline is probably more realistic I agree.

    Again, thanks for the feedback - we all need a say in how we think we should be managed.

  • Docked WagesDocked Wages Posts: 2,918 Admin
    I agree with the intent of this plan and would probably support it.
    Mark P. Wilson
    Marine Surveyor, SAMS-SA, ABYC
    Wilson Yacht Survey, Inc
    Old Bahama Bay (Owner / Board of Directors) 

  • HuckleberryHuckleberry Posts: 180 Officer
    Just a question. For this to ever happen you will have to completely cut out the Gulf Council out of the equation right? I think I know the answer is Yes because I feel your talking about the Gulf States deal.

    The whole gulf states deal is based off of Biomass correct?
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