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|04-12-2010, 11:31 AM||#1|
Join Date: Oct 2007
Anybody Coming to the Gulf Council Meeting in Galveston?
Here are some thoughts that I have regarding the issues at hand;
The Gulf Council found its groove a few years back when they instituted a 6 month season/4 snapper limit/9.12 million pound TAC, which actually has proven to have been successful in rebuilding the snapper population, as evidenced by the current plethora of snapper out there - also, the data they are using to set the ACL for 2010 is 2-1/2 years old I believe (2007 data). However, since the recreational TAC was tied directly to the shrimper bycatch, our limits/seasons were cut back drastically in 2007 to mirror the mandated 74%reduction in bycatch.
Now, the shrimper bycatch has been reduced by more than the directed amount, and I believe, since our TAC is directly tied to that shrimper bycatch, then should it not be mandated that we return to the 6 month season/4 fish bag limit/9.12 million pound TAC? If it's tied in one direction then it should also be tied in the other direction, right? If not, why not? This is especially poignant since overfishing has been deemed halted for snapper.
Then, we would actually be in a much better situation than before - cfh boats can actually make a living doing what they do, recreational fishing would resume as it should, and with it, the great economic engine it fuels would be jump-started. And, all of this will happen WITHOUT the previous shrimper bycatch supposedly killing 80% of the juvenile snapper. Bingo.
Also, and this is VERY important - the resumption of the 6 month season/4 fish limit/9.12 million pound TAC will do something else that has been in essence totally shut down since the draconian regs took hold, and very little talk about it; people will see that it makes sense to start placing more habitat out there AGAIN. Since the 2 fish limit/2month season has been in place for the last 3 years, fishermen can no longer justify placing any more habitat, and why should they? Why should they invest thousands of their own dollars to help the NMFS rebuild the fishery when all they can catch is 2 fish per day 2 months out of the year? There is no incentive at present to invest in the growth of the fishery, as catching 2 fish/day in 2 month seasons is a very easy accomplishment these days. The NMFS has inadvertantly (?) shut down the biggest component that has helped rebuild the fishery - artificial reef placements. That needs to be jump started also, and on a Gulf-wide scale, especially when faced by the removal of the oil platforms each year. There needs to be a plan in place to mitigate the loss of this very important Essential Fish Habitat, and the best way to do that is with artificial reefs.
The NMFS needs to comply with Congressional mandates to improve the data collection system instead of pushing catch shares which are not mandated by Congress, the MSA, or any other legal requirement. They should take the $18 million stolen from the cooperative research and fisheries reseach to put into catch share promotion and put it back where it would actually make a difference; research and data collection.
There should be a push for state-issued snapper stamps/endorsements so that 100% of the fishermen targeting snapper can be identified - this includes all private recs and all persons fishing on cfh boats or headboats. The monies raised from this stamp/endorsement could be used to pin down the number of fish harvested by this known number of fishermen fishing.
The CFH and headboats need to go to electronic logbooks to document how many fishermen are catching how many fish on their boats, and this data can be made available, to the pound, in almost real time to the NMFS.
The NMFS needs to provide consistency in their own regs in the recreational fishery - daily bag limits are by the fish and the annual ACL is by the pound. They need to set the ACL in terms of numbers of fish instead of pounds of fish - this translates directly to how many fish can be caught by how many fishermen without the the ambiguous extrapolation of average pounds per fish guesstimate. K.I.S.S.
NOAA needs to listen to the participants in the fishery instead of the non-user enviro groups - the sentiment is overwhelmingly AGAINST sector separation and/or catch shares by private recreational, cfh captains, and commercial fishermen alike. Fishermen across the board believe that regs are being enacted based on politics instead of science, with disasterous results for the fishermen, coastal economies, and the fishery itself. The fishermen are on the front line of conservation for the fishery. Fishermen also believe that the NMFS is not responsive to their concerns. That is a BIG problem for the NMFS if they are planning to inflict this sector separation/catch share fiasco REGARDLESS of what the user groups think. There will be, in my opinion, widespread non-compliance - just look at liquor prohibition failure or the drug war that we are losing so badly.
There should be clear, viable projections of any change to our fishery - just look at what happened in 2008...they figured reducing the season from 194 days to 122 days, reducing the bag limit from 4 to 2, would acheive a 45% reduction in harvest. They then proceeded to cut the season by almost 50% more to 64 days which should have resulted in a +_ 90% reduction in harvest, right? Wrong. Somehow it resulted in a 50% OVERAGE supposedly because Texas, Alabama, and Florida did not kowtow to the unconstitutional federal demands to adopt federal regs in STATE waters. That happens in fairy tales, and should not be happening in our government oversight which should be sans malice.
We have asked SOS proponents to provide their projections of what they expect to acheive through sector separation, whichIS a Catch Share Program. If you go to http://saveoursector.com/Plan.aspx, you will see the #1 item on thelist is "Secure Our Allocation. The official definition of catch share from the NOA site is; <P align=left>?Catch share? is a general term for several fishery management strategies that allocate a specific portion of the total allowable fishery catch to individuals, cooperatives, communities, or other entities.
SOS supporters have repeatedly denied that sector separation is a form of catch share. They have also repeatedly refused to provide any numbers whatsoever regarding projected effects of catch shares, which are supposedly an "insurance policy" to prevent overfishing. It's kinda like a 2 bit insurance salesman trying to sell you a policy without telling you what you get in return. They claim to know the "real" numbers which would make it a great policy, but don't feel it's important for you, the person paying for it, to know the details. There's an old saying that you should read the fine print on your policy - the problem here is that the page is blank...no print at all. What a JOKE. The actual name for this concept should be CATCH PARE, as the catch allowed by all sectors under this concept will be reduced dramatically. Pare; "to reduce or remove by or as by cutting; diminish or decrease gradually".
Take the 2008 season as an example again. Data shown is from the NMFS; http://sero.nmfs.noaa.gov/sf/pdfs/FI...20analysis.pdf<DIV align=left>I know it's only 1 year's worth of data, but it's NMFS figures - not mine. One VERY NOTABLE FIGURE is; private/rental landings accounted for 57.7 percent of total landings in 2008. HEY - THE PRIVATE RECS ACCOUNTED FOR ALMOST 60% OF THE LANDINGS!</DIV>
"Gulf of Mexico recreational red snapper landings for 2008 totaled 3.67 mp, or approximately 1.22 mp ww over the recreational quota. MRFSS accounted for 3.06 mp, or 83.7 percent of the overall landings (Table 3). Headboat landings accounted for 0.41 mp or 11.1 percent of the overall landings (Table 4). Texas Parks and Wildlife landings accounted for 0.19 mp or 4.9 percent of the overall landings (Table 5).
Charter landings accounted for 31.1 percent of the total recreational red snapper landings in 2008, private/rental landings accounted for 57.7 percent of total landings in 2008, and headboat landings accounted for 11.1 percent of total landings. West Florida accounted for 57.4 percent of overall landings, while Alabama, Louisiana, Texas, and Mississippi represented 17.6, 14.7, 9.8, and 0.5 percent of the landings, respectively.
State water landings represented 34.8 percent of overall red snapper landings, while 65.2 percent of landings came from federal waters."
To put the above numbers in perspective using the figures that NMFS provided for 2008, IF there was sector separation/catch shares at that time, with no alleged overages because everyone is "accountable", here's what would have happened;
According to the NMFS, in 2008, 34.8% of the snapper were caught in state waters.<DIV align=left>2,450,000 * .348 = 852,600 state snapper
2,450,000 * .652 = 1,597,400 federal snapper</DIV><DIV align=left></DIV><DIV align=left>Federal waters
1,597,400 * .111 = 177,311 pounds headboats
177,311/80 headboats in the Gulf = 2,216 pounds per boat per year
2,216/4.4 pounds (2008 NMFS data) = 504 fish/year allowed per boat
504/2 fish per person = 252 limits/year/boat or 252 snapper customers
252 * $80/person = $20,160 gross for the entire snapper year per boat
</DIV><DIV align=left>1,597,400 * .311 = 496,791 pounds CFH boats
496,791/1,200 active permitted CFH boats = 414 pounds per boat per year
414/4.4 pounds = 94 fish per boat per year
94/2 fish per person = 47 limits/year / 5 limits per trip avg = 9.4 snapper trips per year, or less than one per month if allowed to fish year round
10 trips x $1,500 trip = $15,000 gross for the entire snapper year per boat if sector separation/catch shares are in place in 2008
</DIV><DIV align=left>OR, withNO sector separation/catch shares, you would have had the option to run up to 65 legal snapper trips during that short season (let's say, 50 trips due to weather, etc.) 50 trips x $1,500 trip = $75,000 gross just for snapper trips. Hmmm...$15,000 or $75,000? Which one is most beneficial to a business?</DIV><DIV align=left></DIV><DIV align=left>And remember that sector separation/catch shares do not stop at snapper - this concept would extend across the board to most, if not all species targeted by CFH/private rec vessels.
</DIV><DIV align=left>I'm fighting for all CFH captains here in addition to all private recs, as what is illustrated to happen to the CFH/headboat vessels above would be similarly inflicted on all private recs. We need to stay together to fight this fight.
</DIV><DIV align=left>The CFH boats that could not (understandably) stay in business due to the above scenario would leave the fishery, and the remaining CFH boats will divvy up their portion, or the commercial guys could purchase their quota shares and put it in the commercial sector. Is that REALLY where we want to go?
</DIV><DIV align=left>Just say NO! to Sector Separation and/or Catch Shares!</DIV><DIV align=left></DIV><DIV align=left>Tom Hilton</DIV>
|04-13-2010, 09:14 AM||#2|
Ruby Red Lip
Join Date: Nov 2009
Location: Bonita Springs
RE: Anybody Coming to the Gulf Council Meeting in Galveston?
Good stuff, Tom.
Give 'em hell.
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