Coastal Conservation Association (CCA)

Coastal Conservation Association
IFQ Testimony

The current IFQ program being addressed by the Council will allocate and give exclusive rights of access to more than half of all the Gulf grouper to a limited number of commercial interests. CCA is opposed to locking up an important natural resource in a small number of individuals until there is a reallocation of the resource that fairly and equitably distributes the benefits of the fishery.

Even among existing IFQ programs, we have become aware of a number of problems. The recently implemented red snapper IFQ program is not generating the revenues required to fund its administrative support and appears to be exacerbating discard mortality in the commercial sector. Testimony given by the National Marine Fisheries Service and members of the public at the last Council meeting indicated that harvesters and dealers are artificially lowering the ex-vessel price paid for IFQ caught fish in order to reduce associated payments for administrative support.

In testimony before the Florida Fish and Wildlife Commission, Bob Spaeth said that the Florida longline fleet was releasing dead between 1,000 and 1,500 pounds of red snapper on each grouper trip. Apparently the IFQ shares (purchased or leased) necessary to eliminate such bycatch mortality are not available. This appears to demonstrate that the economic efficiency envisioned by the Council when it adopted the red snapper IFQ plan has not been realized.

We strongly suggest that NMFS and the Gulf Council correct the deficiencies in the existing IFQ program before considering another program that could create the same problems.

Robert Hayes, CCA Legal Counsel, states that, “On the argument that the U.S. federal government is the steward of the resources for all its citizens and the commercial fishermen is providing consumers access to that resource: the U.S. is the steward of all of its resources – sunfish, ducks, deer, and striped bass – all of them. The concept that a private commercial enterprise is necessary to provide the public with the enjoyment of those resources by selling them to consumers so they can eat them was rejected by the federal government and state wildlife managers before 1900. There is no basis in any federal common law, any wildlife law or the constitution for such proposition. Anybody making this argument should be asked to provide some authority for it.”