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Recreational Catch Shares

Recreational Catch Shares. Earl W. Comstock Comstock Consulting LLC earl.comstock@mac.com. Key Realities. Population growth means increasing demand for recreational angling Anglers are seafood consumers who will pay more to catch their own fish

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Recreational Catch Shares

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  1. Recreational Catch Shares Earl W. Comstock Comstock Consulting LLC earl.comstock@mac.com

  2. Key Realities • Population growth means increasing demand for recreational angling • Anglers are seafood consumers who will pay more to catch their own fish • Commercial catch shares result in job losses as fishers / processors consolidate • Job growth in coastal communities depends on increased recreational use Comstock Consulting LLC

  3. Key Realities (cont.) • Catch share programs tend to be in perpetuity – no examples yet of sunset • Catch share programs create a historical snapshot of fishery use and allocation • Absent mechanism for transfer between sectors, catch share programs increase allocation conflicts among sectors Comstock Consulting LLC

  4. Catch Share Policy Should • Allow the best use of the resource to change over time based on market forces • Create jobs in coastal communities • Allow full transferability between sectors • Provide guidance on leasing / legal issues • Support economic analysis of all uses • Provide templates for implementation Comstock Consulting LLC

  5. Problems Applying Catch Shares to Recreational Fisheries • Recreational anglers catch fish not pounds • Reducing participation is not the goal • Consolidation does not provide benefits • No economies of scale • Angler participation is transitory • Buying quota requires long time horizon • Privatization of public resource a concern • Management costs can be significant Comstock Consulting LLC

  6. Recreational Catch Shares • Must be transparent to anglers • Must address allocation issues • Must promote resource conservation • Should be tailored to each fishery • Should promote job creation Comstock Consulting LLC

  7. Transparent to Anglers • Anglers catch fish, not pounds • Too many anglers to allocate catch shares • Someone must hold angler catch shares • An angler pool is one approach • A pool allows anglers to fish as before Comstock Consulting LLC

  8. Non-Profit Entity • Holds recreational sector allocation as pool available to all anglers • Anglers purchase annual stamp to be able to access pool • Revenue from stamps used to purchase catch shares from commercial holders • Entity controls recreational harvest using bag limits, seasons, limit on stamps Comstock Consulting LLC

  9. Address Allocation Issues • Demand for recreational fish is growing • Catch share programs freeze historical snapshot • Absent mechanism to allow transfer between sectors, allocation fight remains • Recreational non-profit should buy out commercial catch share holders to increase recreational pot Comstock Consulting LLC

  10. Optimize Resource Use • Recreational entities will purchase quota for times when stocks are low • This results in the recreational sector holding too much quota when stocks high • To optimize use of resource, commercial quota holders should be allowed to fish excess recreational quota for free Comstock Consulting LLC

  11. Promote Conservation • Creating a recreational catch share pool can promote conservation • Non-profit entity would be responsible for keeping anglers within limit using bag limits, season lengths, and angler limits • Data collection can be improved through use of permit pricing to encourage anglers to submit catch data Comstock Consulting LLC

  12. Key Legal Issues • Creation of non-profit entity • Allocation of catch shares to entity • Ability to collect revenue from stamps • Ability to exclude anglers without stamps • Data collection on angler catch • Does 303A of MS Act apply • What other authority can NMFS use Comstock Consulting LLC

  13. Problems for Anglers • Lack of economic data / analysis on benefits from recreational fisheries • Lack of organization / funding among recreational anglers • Commercial opposition to sale of quota to recreational sector • Lengthy Council Process / Balance of Council representation Comstock Consulting LLC

  14. Conclusion • Recreational catch shares should be considered to address allocation issues • Templates and legal guidance are needed if recreational catch shares are desired • NOAA needs to provide resources for economic analysis of recreational fisheries • NOAA’s Catch Share Policy should endorse templates, guidance, and analysis Comstock Consulting LLC

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