First, I support expanding the harvest quota for Red Snapper for the 2011 season. I prefer more weekend days and liked the format used last year after the Deep Water Horizon sinking closed much of the Gulf. I would prefer the weekend days start sooner (August through November would be ideal). I would give up weekday fishing in June and July to facilitate this if necessary.
Second, even though this proposal does not address this issue, I believe that the current division of the Red Snapper resource between commercial and recreational sectors is unfair. By NOAA data, there are 312 commercial Red Snapper license holders in the Gulf of Mexico. Their license grants them a $45,000 entitlement to a public resource. This is just wrong. Any rational analysis would recognize that the maximum economic value of Red Snapper is derived through recreational harvest. I will run out of characters if I try to explain this, but others have done so repeatedly, even though the logic appears to fall on deaf ears. I do not believe that this shift of Red Snapper back into recreational fishermen's hands constitutes a "taking" from commercial interests, but if a court so rules, I support applying a federal license generating a dedicated revenue stream to pay for this "taking."
I support full disclosure of the revenue stream generated by commercial fisherment. I believe the sector is motivated to under-report to protect their selfish interest and standard accounting rules should apply across the board.
I am appaled that commercial interests balk at seeing a 12 hour reporting window closure expanded to 20 hours. Recreational Red Snapper Season for 2010 was proposed to be closed for 312 days. Close all commercial fishing, shrimping, oystering, crabbing, etc. for the month of December in order to true all accounts and generate accurate reporting data.
Thanks for the opportunity to comment.
NOAA-NMFS-2011-0018
Comment from Steve Hardt
This is comment on Proposed Rule
Fisheries of the Caribbean, Gulf of Mexico, and South Atlantic: Reef Fish Fishery of the Gulf of Mexico; Red Snapper Management Measures
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