Last week I quickly posted the NMFS's announcement of this policy experiment without much explanation and then ran off to Kentucky to visit friends and family. Several months earlier I had signed a letter of support [pdf], along with a number of economists, that provides a bit of explanation (I was sure that I had posted this letter back then but searching the archives has suggested otherwise):
As economists working in the field of environmental and natural resource economics, we are writing to offer our support for the Gulf Headboat Cooperative' s application for an exempted fishing permit ( EFP) to test a new approach to managing recreational for -hire fishing. We would like to offer our support from both the perspective of its merit in contributing to the state of knowledge in fisheries economics and in improving the quality of information for fisheries management in the Gulf of Mexico and beyond.
The objective of this pilot is to analyze how headboats adapt in a regime where, instead of being constrained by uncertainty about season closure, their catch allocation is secure, they have flexibility to book trips through the year, and they can plan, market, and fish accordingly. The pilot has substantial potential to improve the state of knowledge in both the academic and management communities of the effects of changes in management on the for-hire sector. Such knowledge is increasingly needed in mixed -use fisheries with a large recreational component. While there is a small amount of conceptual modeling in this area and some existing data outlining the current economic and social context of for -hire fisheries, there remains precious little policy experience to guide decision making. Experience in commercial fisheries demonstrates that fishing cooperatives can successfully meet the economic and biological objectives of fisheries management. However, extrapolation from commercial fisheries is of limited applicability given the unique economic structure and incentives reflected in this mixed commercial /recreational fishery and the headboat sector' s unique role in coastal economies. The state of knowledge would be greatly enhanced by purposeful, targeted data collection and evaluation in anticipation of important management changes.
The EFP reflects collaboration between fishermen and academic partners to establish exactly such a protocol. The impacts are of clear importance to owners, crew and clients of the for -hire sector and fisheries managers as well. An especially important aspect of the EFP is the fact that it leads to samples from the headboat fleet that are inside and outside of the pilot Cooperative. After control for selection effects, this allows those vessels that do not participate to serve as a control group for those that do. This creates the potential for researchers to compare the change in important performance metrics before and after the EFP for both groups of vessels.
Such a scenario is fairly rare in fisheries management and offers the potential for a far more robust contribution to knowledge than studies that focus on before /after impacts alone. In summary, the Gulf Headboat Cooperative pilot program presents a significant opportunity to expand the scientific foundations for sound management of the for -hire sector through thoughtful data collection and analysis. The data and research protocol presented within the EFP represent a framework to maximize the useful information from such a policy experiment while fostering collaboration between the for -hire sector and researchers. These features will enhance the credibility of the associated data and research in the academic community while facilitating the ongoing adaptive management of for -hire recreational fisheries in the Gulf of Mexico and beyond.
We urge you to approve the Gulf Headboat Cooperative EFP.
Here is a statement in opposition from the Coastal Conservation Association:
On behalf of the Coastal Conservation Association (CCA) and our 75,000 members in the Gulf of Mexico states, this letter conveys our unequivocal opposition to the proposed Exempted Fishing Permit (RIN 0648-XC528) that would allow a pre-selected subset of less than a dozen Gulf headboat operators to be gifted recreational quota to use for their individual harvest of red snapper and grouper for two years. Touted as an experiment to provide accurate and timely landings data, we believe that the primary goal of this EFP is to pave the way for allowing separate allocations of common property resources to the for-hire and private boat recreational fishing sectors and the ultimate creation of a catch shares program in the recreational sector. The application for this EFP has been careful to avoid the use of the terms “catch share” or “sector separation,” but it is clear that it tests a catch share that would depend on sector separation.
This EFP simply will not produce conservation gains nor will it enhance efficiency. Any “academic study” designed to quantify the stated goals of this EFP would be seriously affected by the non-random selection of the subject vessels. ...
Not only is this EFP flawed from a purely technical perspective, it is difficult to comprehend that such a program would be given serious consideration given the very high levels of political and popular opposition to sector separation and catch shares. ...
If memory serves, the Socioeconomic Panel of the SAFMC SSC has gone on record several times in favor of catch shares (i.e., what they used to call individual transferable quotas) in most any way, shape or form. Here is the most recent example [pdf] from the October 2012 meeting:
In the broadest terms, the SEP has significant concerns about the use of arbitrary rules to determine allocation between sectors. It would prefer to see transferability between sectors, in which one sector could purchase parts of the other's allocations.