Comment from Robert Simonds

Document ID: NOAA-NMFS-2011-0087-0053
Document Type: Public Submission
Agency: National Oceanic And Atmospheric Administration
Received Date: December 02 2011, at 12:00 AM Eastern Standard Time
Date Posted: December 9 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: December 1 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: December 19 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80f79dbb
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I am commenting today in opposition to the proposed ban on "for hire" vessel sales of Dolphin. This proposed rule upends a long standing policy which has been vitally important to the economic well being of the "for hire" Charter Boat industry for many years. The income from bag limit sales of Dolphin on Charter Boats serves as a form of gratuity, an insentive to perform well, and helps keep the cost of charters more reasonable to the client. This proposed regulation has nothing to do with conservation. This proposal is simply about book keeping. NMFS and the regional councils are attempting to categorize all fishing and user groups into two categories-either Commercial or recreational with the result that the "for hire" industry is negatively impacted. We have already lost the right to sell bag limit quantities of Snapper and Grouper and a loss of the bag limit sale of Dolphin would be another economic blow we cannot afford. The "for hire" industry is a large and important component of the fisheries landscape but we do not fall neatly into the category of either Commercial or recreational. It's time the Councils understood our particular status and protected our traditional rights.

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