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SOUTH ATLANTIC CHARTER BOAT ASSOCIATION
COMMENTS AND PROPOSALS FOR CONSIDERATION BY THE
SOUTH ATLANTIC FISHERY MANAGEMENT COUNCIL
SAFMC AMENDMENT 15B
MARCH 3-7, 2008
JEKYLL ISLAND, GEORGIA
INTRODUCTION
The SOUTH ATLANTIC CHARTER BOAT ASSOCIATION was organized on Wednesday, February 20, 2008 to protect the rights and heritage of the charter fishing industry in the South Atlantic region of the United States and already represents over two-thousand Captain, Mate and Associate members from many different fishing associations in the state of Florida. We are growing rapidly and in time hope to represent professional associations encompassing the states of North Carolina, South Carolina, Georgia and Florida. Member associations include the Islamorada Charter Boat Association, Key Biscayne Charter Fleet, Key West Charter Boat Men’s Association, Lighthouse Point Saltwater Sportsmen’s Club, South Florida Sport Fishermen and West Palm Beach Fishing Club. Our mission is to provide reasonable and accurate representation for active charter/headboat operators in the four states under the jurisdiction of the South Atlantic Fishery Management Council and other governing federal and state agencies.
The collective members of the SOUTH ATLANTIC CHARTER BOAT ASSOCIATION have a long standing record of marine conservation, cooperation in marine research and partnering with the South Atlantic Council in fisheries management. Our past actions include but are not limited to: Extensive tagging and satellite tagging studies of king mackerel and billfish of all types, support for the removal of fish traps from state and federal waters, working to establish marine protected areas, cooperation and development of both state and federal marine sanctuaries, deep water marine protected areas, youth and general public education programs, and general recommendations for the sound management of various marine species including prudent implementation of spawning closures and modifications to the size and bag limits on numerous species in the snapper/grouper complex, and generally demonstrated a kindred spirit of conservation and cooperation in working with various state and federal agencies.
AT ISSUE
During the week of March 3-7, 2008, the South Atlantic Council will meet in Jekyll Island, GA to consider a number of fisheries management issues contained in Amendment 15B. One of the proposals in 15B is a provision to stop the sale of recreationally caught snapper and grouper by charter and headboat operators. If approved, this provision of 15B would have an enormous financial and economic impact on the charter/headboat industry.
The sale of fish by charter/headboat operators is an historical practice in existence longer than the National Marine Fisheries Service. It was then and continues to be a valid method of supplementing income in what is still a very seasonal business.
Perhaps the most perplexing part of this “No Sale” provision is simply, Why?” In the section labeled Economic/Social Effects of the Council’s Preferred Alternative 2, it states:
“Preferred Alternative 2 is expected to result in unquantifiable positive economic benefits for vessels holding the Federal commercial snapper grouper permit since pressure from the recreational and non-Federally permitted commercial sector motivated by sales will be eliminated, thereby reducing the possibility of accelerated closure and avoiding the adverse economic impacts of protracted closure. Due to avoidance of the adverse economic impacts associated with extended closure, Preferred Alternative 2 is expected to result in an increase in net economic benefits to the status quo.”
This section should have been labeled Economic/Social Affects NOT Effects, because it will have a serious negative impact on charter/headboat operators, fish houses, marinas, restaurants, hotels and the towns where they live and operate.
From the Council’s own narrative Alternative 2 will result in “unquantifiable” positive economic benefits for commercial fishermen and “is expected to result in an increase in net economic benefits to the status quo.” It sounds like a pretty rosy picture for commercial fishermen and all of it at the expense of charter/headboat operators. Since this is “unquantifiable,” how do we know this will result in an increase in net economic benefits? Why would charter/headboats bring about accelerated or extended closures anymore rapidly than the commercial sector? In fact wouldn’t you expect it to be the other way around?
More importantly, it appears the Council is not even remotely concerned about a closure, since all of the snapper/grouper stocks presently taken and resulting in commercial sales by charter/headboats will simply be fair game for commercial fishermen. The “No Sale” provision will do nothing to reduce fish mortality.
We have seen it too many times. This will only serve as a first step in what most likely will become a much broader process. First, the right to sell snapper and grouper will be eliminated. Then, in no time, it will expand to include, king mackerel, dolphin fish and most anything else that is legally marketable. All the while, our collective pleas for reasonable and rational spawning closures, variations in minimum size limits and appropriate bag limits on snapper. grouper, amberjack and other species in the snapper/grouper complex will have fallen on deaf ears.
Council approval of a “No Sale” provision could also prove to be discriminatory in nature because it excludes only one sector, the chartrer/headboat industry from the sale of recreationally caught fish. And that is in spite of the fact that charter/headboat licensing requirements exceed those of purely commercial operators. We are required to have commercial permits, commercial licensing, city and/or county operating permits, commercial insurance, waste disposal plans, charter pelagic species permits, dolphin/wahoo permits, federal charter/recreational fishing permits and unlike anyone else, we are required to have a valid United States Coast Guard license.
ECONOMIC IMPACT
While nothing has been as hard hit in the U.S. economy as the housing market and sub-prime mortgage markets, the trickle down economic damage continues to have a dramatic affect on the charter/headboat fishing industry. The battle to maintain working waterfronts is especially brutal in the South Atlantic states. Developers anxious to take advantage of the last real estate boom bought up working waterfront marinas and properties as fast as they could get the financing. Many were converted to fancy condominiums and ocean front enclaves for the well-to-do and still others are now cordoned off by padlocked, chain link fences with red lien stickers and court orders plastered on signs nearby. The loss of working waterfronts has been significant and the impact on small coastal communities has been particularly disturbing. With increased demand has come increased dockage fees at most every marina along the eastern seaboard.
Sky-rocketing property values and unbearable tax loads are also wreaking havoc on working men and women in coastal communities as they struggle to handle the burden. Insurance costs have exploded for vessel operators in tropical cyclone prone areas and that includes all of the Council’s jurisdiction. Marine fuel at close to $4.00 per gallon and astronomical pricing of oil, lubricants and other maintenance related items are providing the one-two punch putting many charter/headboats out of business or forcing them to raise prices resulting in less bookings and smaller profit margins.
With the economic slow-down now taking more of a national turn and impacting all Americans we are seeing less business at charter/headboat docks with many operators reporting business declines of as much as 40 to 50%. This is no time to be adding additional financial burdens on the industry.
PROPOSALS
Charter/headboat operators have been selling fish since the first charter customer stepped on a commercial vessel and headed out to sea and left the catch or a portion of it to the crew as a bonus for a good day of fishing. Previous Councils and fisheries management organizations have recognized this right and that is exactly why appropriate language and licensing was developed to ensure this practice would carry-on to future management regimes and future generations of charter/headboat operators.
We ask the Council to consider the following proposals:
1. Unanimously support Alternative 1 (no action). Allow species in the snapper grouper management unit taken from the South Atlantic EEZ, up to the allowed bag limit, to be sold to a licensed dealer if the seller possesses a state-issued license to sell fish.
2. Postpone any vote on the “No Sale” provision of Amendment 15B until sufficient research has been completed to make “unquantifiable” results and statistics “quantifiable” and determine a valid allocation for charter/headboat sales. This is easily done with appropriate identifiers on trip tickets since all sales are considered commercial in nature. It is incumbent on the Council to get some real numbers to work with here and conduct an economic impact assessment, as well, before taking action.
3. Industry Preferred Alternative. Endorse Alternative 3 from the Council’s South Atlantic Snapper Grouper Summary dated October 2007. Which states, “Require a Federal charter/headboat snapper grouper permit or Federal commercial snapper grouper permit to sell snapper grouper species from the South Atlantic EEZ up to the bag limit of snapper grouper species.” This permit would be made available at reasonable cost to the participating members of the charter/headboat industry.
4. Support an alternative establishing an allocation of snapper and grouper within the management plan reflecting the portion of sales by charter/headboat operators and allowing for its continuance.
Endorsement of the Industry Preferred Alternative would allow the chater/headboat industry to continue to sell snapper grouper up to the bag limit and afford the Council an opportunity to begin developing a reliable data base of commercial sales by the industry. Statistics for the charter/headboat industry are woefully inadequate and do not reflect the true picture of the valuable role it plays in the overall fishing industry. This alternative would also enable the Council to develop a factual allocation for the charter/headboat sector.
IN CLOSING
The men and women and the organizations represented by the SOUTH ATLANTIC CHARTER BOAT ASSOCIATION have been leaders in fishery conservation and fishery management in the Council’s jurisdiction. We voluntarily imposed a 20” minimum size limit on ourselves for dolphin fish years before the Council voted to do so. In South Florida and the Keys we led the charge in establishing the East Hump Deep Water Marine Protected Area and worked diligently with government regulators to establish marine reserves, special preservation areas and the Florida Keys National Marine Sanctuary. We have been catching and releasing billfish for decades! In reality the Council has received no better support from any one group in the interests of conservation and protecting the fishery than the charter/headboat industry and we deserve better treatment.
The members of the SOUTH ATLANTIC CHARTER BOAT ASSOCIATION invite you to view our website at www.sacba.net. There, you can review petitions and comments signed and sent in by our members including captains, mates, commercial fishermen, recreational anglers, boat manufacturers, bait and tackle shops, marina owners and operators, restaurateurs and hotel operators, all dependent in some way on the success of the charter/headboat industry to maintain profitable operations and as a source for legally caught and sold fresh fish products.
We will continue to work with the Council to develop sound and reasonable management plans. However, we cannot sit idly by and watch our businesses be nickel-dimed into oblivion with over-reaching and unsubstantiated regulation. We urge all of the Council members to support Industry Preferred Alternative 3, as defined by the Council in the South Atlantic Snapper Grouper Summary dated October 2007.
Respectfully submitted,
SOUTH ATLANTIC CHARTER BOAT ASSOCIATION
Capt. Bill Kelly
Capt. Bill Kelly wrote this report with collaboration, input and research from the following individuals:
Capt. Ray Rosher, Charter Boat Miss Britt, Miami, FL
Mr. Bill Combs, Florida Wildlife Photos, New York, NY
CONTACTS
Capt. Bill Kelly
129 Tequesta St.
Plantation Key, FL 33070
305-394-5333 C
keyskelly@aol.com
Capt. Ray Rosher
9490 SW 109 Terrace
Miami, FL 33176
305-992-4130
rosherr@bellsouth.net
Industry Updates & Information
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