Coastal Conservation Association Comments to the South Atlantic Fishery Management Council On Amendment 47 to the Snapper-Grouper Fishery Management Plan For-Hire Permit Moratorium

Posted on July 23, 2018

Thank you for the opportunity to comment on Amendment 47 to the Snapper-Grouper Fishery Management Plan, the For-Hire Permit Moratorium. Coastal Conservation Association is the largest marine resource conservation group of its kind in the country, with more than 125,000 members united in our efforts to ensure the health and proper conservation of our marine resources and anglers’ access to them.

Some of the stated reasons for implementing the proposed permit moratorium are to:
1. Reduce competition
2. Professionalize the For-Hire Sector
3. Enhance enforcement of marine resource regulations
4. Improve compliance with reporting requirements

While it could be argued that limited entry may achieve all these objectives, we believe these objectives can be met without limited entry. Thus, CCA is opposed to a permit moratorium and possible future such effort controls in the For-Hire Sector of the South Atlantic Snapper-Grouper Fishery (hereafter referred to as For-Hire Sector).

We do not believe there is a sufficiently compelling biological or enforcement reason to take such action. Demographic trends indicate that people will continue to relocate to America’s coastlines for a variety of reasons, including lifestyle, climate and recreational opportunities. A not insignificant portion of the people moving to the Southeast can be expected to take advantage of the region’s renowned marine resources and engage in recreational fishing. For the non-boat owning public, the for-hire industry is the primary means of accessing marine fisheries.

With this in mind, we believe the Council should in general promote and increase access to the region’s fisheries when possible, not arbitrarily restrict it to solve management challenges. We understand that the region’s fishery resources are finite and cannot sustain ever-increasing harvest pressure. However, we believe the standard harvest controls of seasons, creel limits and size limits are more appropriate than arbitrary limitations on the size of the For-Hire Sector. If the size of the For-Hire Sector is fixed and not allowed to expand based on future demand, we believe there will be negative impacts on the recreational anglers who are the customers on those vessels. These will include higher trip prices, reduced choices of when and where one can fish and an overall deterioration of customer service.

As for desires to “professionalize the for-hire fleet,” we would argue that present requirements to operate within the For-Hire Sector are already achieving this objective and, in addition, this
implies the current For-Hire Sector members are somehow not professional. We are unaware of any systemic indications that the For-Hire Sector is in need of further training, but if this need exists then surely the place to address it is in the existing U.S. Coast Guard licensing and training requirements rather than a limited entry program. Furthermore, it would seem that a desire to reduce competition is in direct contradiction to a desire to professionalize the fleet as competition often brings out the best in a business.

Of the stated reasons for implementing a moratorium on permits in the For-Hire Sector, only the last two come close to rising to the level of sufficiently compelling reasons. One of the problems often brought up is the inability of a federally-licensed for-hire sector operator to fish in state waters when the federal season for a given species is closed. Somehow a permit moratorium or other effort control will alleviate this problem? If this is indeed a real problem, cannot this conflict be eliminated in another manner?

It is alleged that NOAA Fisheries Law Enforcement cannot enforce a permit suspension or revocation due to the current open-access system within the For-Hire Sector. It is difficult to believe that all an offender who has had his or her federal permit revoked has to do to continue fishing is simply go buy another federal permit. Automobile drivers who have had a driver’s license revoked cannot simply go to the DMV and get another one. We support significantly strengthening enforcement measures and fines to deter repeat offenders in the For-Hire Sector. Additionally, we believe that non-transferable permits assigned to individuals rather than vessels or corporations would be more easily tracked in databases to prevent serial abusers from acquiring new permits. If it is indeed necessary to limit the number of permits in the For-Hire Sector to improve enforcement, then the only way we could support such a measure is for such permits to be non-transferable.

Improving compliance with catch/effort reporting requirements is indeed a worthy goal but it is not clear why a permit moratorium and limiting the size of the For-Hire Sector is necessary to do so. All measures that could be enacted to require reporting in a limited entry scenario can be enacted in an open-access scenario. Again, zealous and effective enforcement of reporting requirements is the key to achieving this objective not limiting effort.

Establishing a permit moratorium and limiting the size of the For-Hire Sector appears to be a solution in search of a problem. We strongly encourage the Council to fully explore other options to address the issues of concern. Recreational anglers very much appreciate the services of the For-Hire Sector. It is an important component of the marine recreational fishery as it not only provides an essential access point to the region’s offshore fisheries, but also provides the local knowledge and expertise needed for anglers to have a satisfying experience while fishing.

We want to see a vibrant, dynamic for-hire sector in our marine recreational fisheries that has growth capacity to meet increasing demand while providing the highest quality of service to its customers. We look forward to working with the Council and the for-hire sector in federally-managed fisheries industry to identify and eliminate barriers to a secure and prosperous future.

In closing, CCA does not believe that a moratorium on the issuance of permits is in the best interest of the For-Hire Sector of the South Atlantic Snapper-Grouper Fishery or overall for-hire sector. We also do not believe that such a moratorium and possible future effort controls are in the best interest of the recreational anglers who rely on the for-hire sector to access healthy marine resources.