Coastal Conservation Association Comments for
Scoping Hearings on Proposed Days-at-Sea
Pilot Program for Charter-for-Hire
CCA has examined the scoping document and concluded that this effort is yet another attempt to explore separation of the private boat recreational and charter industries. Such separation carries no benefit for either sector. We do not understand why the Council believes it might be necessary to have different rules for kids who ride their bicycles to the candy store and those who ride a taxi there. The Council needs to stop responding in a knee jerk and unpredictable fashion to the continued complaints of the few and stay on track to solve the problems that face the many: the private boat angling sector.
We also would point out that the scoping document incorrectly states that while the cap on new charter permits requested by that industry has held those numbers relatively steady the private boat sector continues to increase effort. This is not the case as is evidenced by the MRIP records of Gulf of Mexico EEZ effort between 2000 and 2012 shown in the table below.
The primary objection that CCA has with sector separation is the lack of any apparent benefit to be had at any level for recreational anglers, the states, or for state budgets. There continue to be vague references to better data but there is no new way to track catches on for-hire vessels. If the sectors were separated today, the same data gathering systems (the Marine Recreational Fishery Statistical Survey or the new Marine Recreation Information Program) would continue to provide catch estimates for private and for-hire sport vessels. Any new data collection efforts could be implemented without separating the sector.
Economically, NOAA has funded bio-economic studies that show that for the period 2009 to 2032, recreational anglers will contribute $9.1 billion of the value in the Gulf of Mexico shrimp and reef fish fisheries while the recreational for-hire fishery will contribute $0.83 billion. We hope that the Council will factor in these figures when considering sector separation.
Other economic figures should also be examined in this debate. The NOAA Fisheries Service Office of Science and Technology looked at Economic Impacts and Expenditures from Saltwater Sportfishing by Gulf State in 2009. That information indicates that here in Texas, angler expenditures came to almost $103 million while for-hire expenditures totaled about $27 million. Gulf-wide, angler expenditures came to over $1 billion. For-hire expenditures came to about $208 million.
For state governments and their marine resource management agencies, private boat anglers supply the vast majority of license fees that support state fisheries programs. Charter/for-hire vessels supply a much smaller percentage of revenues. From a political standpoint, we suspect sector separation will create deep political conflicts for state governments as they grapple with how to spread fishing opportunities between private boat and charter/for-hire/headboat sectors.
Looming over all these points is the trend over the past decade towards increased red snapper catch by the private vessel sector relative to for-hire catches. We do not know why this trend has occurred but do not believe the Council should impose government action to reverse what has occurred naturally. We also do not think the Council should impose government action to support the increasing private vessel catch trend. We believe these dynamic changes should occur without artificial influence by managers, and without the outdated encumbrance of sector allocations that are set in stone.
Before this Council lets the concept of sector separation - under any guise- come into existence against almost universal opposition, CCA encourages it to first reallocate fisheries according to modern factors like economic, social and conservation criteria, rather than outdated catch history. There is a very good chance that reallocating red snapper would solve many of the problems faced by the CFH sector without creating so many new problems.
This Council faces many real management challenges, and CCA appreciates the demands of those challenges on its time and resources. We hope that the Council will elect to focus its energies on those core issues and set aside the distraction of sector separation.