Sent on Monday, April 14. I encourage all Recreational Fisherman that are interested in fairness and a level playing field to send something similar to their elected officials. It's time to change the game!
Dear Messrs. Brady, Cornyn, Cruz, and Perry,
You may recall that as a Recreational Fisherman, I requested your help on the Red Snapper issue back in January. I received an acknowledgement of my request but not your position on the issues I raised. Given recent actions by NMFS, I am again urgently requesting your help and asking for your position on the issues. And, if you agree that NMFS is misguided, incorrect, or unfair in their actions, what action can be taken to correct the inequities at either the state or federal level?
As a Recreational fisherman I have a problem with the following inequities that I understand exist and that NMFS:
· Considers Red Snapper to be an overfished stock yet allows the Commercial sector to continue to harvest them - 51% of the Total Allowable Catch (TAC)
· Has a different set of standards for the Commercial sector than the Recreational sector (e.g. “gutted” weight used to determine weight towards their TAC vs ”whole” weight for the Recreational Sector; discard mortality rate included in Recreational TAC but not for the Commercial sector (and Commercial sector discard mortality rate is considerably higher than Rec sector))
· Uses flawed science to determine the economic benefit of the Commercial vs Recreational sector
· Receives an adverse court decision (filed by Commercial fisherman) wherein the courts require NMFS to have better accountability in the recreational sector and their solution is to reduce the 2014 season from 40 to 11 days (or shorter if Florida allows fishing in their state waters) rather than developing a timely and accurate accountability process/system?
· Alleges the court dictated what type of measurement criteria to use and therefore were “required” to quit using one estimating model and to use one less favorable with respect to Recreational landings – if court did dictate, they are overstepping their bounds and should be challenged! How does a judge know what modeling techniques are better than others?
· Claims they are responding to the Court decision by “gifting” (my interpretation) a select group of Alabama “Charter for Hire” fisherman a certain percentage of the public resource to obtain RS all year instead of the 11 days like everyone else; this follows a similar decision gifting RS (a public resource) to 13 Headboat owners to harvest RS all year… for a 2 year duration!
· Also states that they intend to go further and set up Individual Fish Quota’s (IFQs) for all Charter For Hire fisherman so that they also receive exclusive rights to a public resource (Red Snapper)!
· May be circumventing the intent of Magnuson – Stevens Act by setting aside a percentage of the TAC to “collaboratives” that can catch fish 365 days a year instead of during the 11 day season like the rest of us! This is the same effect as an IFQ but they let the “collaborative” decide the amount of RS a specific boat/owner receives instead of setting it themselves. In so doing, and by simply calling it a “collaborative” instead of an IFQ, I believe they are circumventing the need for a referendum that may be required by Magnuson-Stevens?
I would like to see the TAC re-distributed based on a more equitable model that takes into account that the Recreational sector pays an inordinate amount of fees (license, permits, taxes) to support the fisheries management, an economic model that truly recognizes the Recreational Sector’s economic benefit, and considers the number of Gulf Coast Recreational Anglers relative to the number of commercial fisherman.
In addition, I believe that after further study if a commercial sector should be deemed viable, the commercial permits/IFQs should be drawn in a lottery as this is a public resource and all citizens should have an equal chance to participate in it. Those select few commercial fisherman that currently “own” IFQs often lease or sell them for substantial sums of money. That should be stopped – they either fish or lose the right.
Thank you for your time and interest in this situation. I look forward to your response. Time is of the essence as June 1 is the scheduled date of the Red Snapper season.
Dear Messrs. Brady, Cornyn, Cruz, and Perry,
You may recall that as a Recreational Fisherman, I requested your help on the Red Snapper issue back in January. I received an acknowledgement of my request but not your position on the issues I raised. Given recent actions by NMFS, I am again urgently requesting your help and asking for your position on the issues. And, if you agree that NMFS is misguided, incorrect, or unfair in their actions, what action can be taken to correct the inequities at either the state or federal level?
As a Recreational fisherman I have a problem with the following inequities that I understand exist and that NMFS:
· Considers Red Snapper to be an overfished stock yet allows the Commercial sector to continue to harvest them - 51% of the Total Allowable Catch (TAC)
· Has a different set of standards for the Commercial sector than the Recreational sector (e.g. “gutted” weight used to determine weight towards their TAC vs ”whole” weight for the Recreational Sector; discard mortality rate included in Recreational TAC but not for the Commercial sector (and Commercial sector discard mortality rate is considerably higher than Rec sector))
· Uses flawed science to determine the economic benefit of the Commercial vs Recreational sector
· Receives an adverse court decision (filed by Commercial fisherman) wherein the courts require NMFS to have better accountability in the recreational sector and their solution is to reduce the 2014 season from 40 to 11 days (or shorter if Florida allows fishing in their state waters) rather than developing a timely and accurate accountability process/system?
· Alleges the court dictated what type of measurement criteria to use and therefore were “required” to quit using one estimating model and to use one less favorable with respect to Recreational landings – if court did dictate, they are overstepping their bounds and should be challenged! How does a judge know what modeling techniques are better than others?
· Claims they are responding to the Court decision by “gifting” (my interpretation) a select group of Alabama “Charter for Hire” fisherman a certain percentage of the public resource to obtain RS all year instead of the 11 days like everyone else; this follows a similar decision gifting RS (a public resource) to 13 Headboat owners to harvest RS all year… for a 2 year duration!
· Also states that they intend to go further and set up Individual Fish Quota’s (IFQs) for all Charter For Hire fisherman so that they also receive exclusive rights to a public resource (Red Snapper)!
· May be circumventing the intent of Magnuson – Stevens Act by setting aside a percentage of the TAC to “collaboratives” that can catch fish 365 days a year instead of during the 11 day season like the rest of us! This is the same effect as an IFQ but they let the “collaborative” decide the amount of RS a specific boat/owner receives instead of setting it themselves. In so doing, and by simply calling it a “collaborative” instead of an IFQ, I believe they are circumventing the need for a referendum that may be required by Magnuson-Stevens?
I would like to see the TAC re-distributed based on a more equitable model that takes into account that the Recreational sector pays an inordinate amount of fees (license, permits, taxes) to support the fisheries management, an economic model that truly recognizes the Recreational Sector’s economic benefit, and considers the number of Gulf Coast Recreational Anglers relative to the number of commercial fisherman.
In addition, I believe that after further study if a commercial sector should be deemed viable, the commercial permits/IFQs should be drawn in a lottery as this is a public resource and all citizens should have an equal chance to participate in it. Those select few commercial fisherman that currently “own” IFQs often lease or sell them for substantial sums of money. That should be stopped – they either fish or lose the right.
Thank you for your time and interest in this situation. I look forward to your response. Time is of the essence as June 1 is the scheduled date of the Red Snapper season.
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