Dear Council:
1. Accumulation limits – Before fleet diversity can be obtained accumulation limits must be addressed. In a business where there is zero possibility for new entrants, unless you have rich purchasing power, there must be disincentives for stockpiling quota. The desire to buy quota by those with hefty bank accounts has made it attractive for small business owner operators to exit the business at inflated prices.
Brian’s fishing boat |
2. Fleet diversity – The small boat fleet in New England is shrinking quickly. Landings are down by boats < 50’ by percentage that inarguably suggest they are the victims in catch share management (since landings are up by boats greater than 50’). This didn’t happen under days at sea management because it was affordable for boats to lease within their size criteria.
- Consider penalties for excessive leasing of quota, except where conservancy and affordable prices are the goal.
- Consider quota set asides for various geographic areas, boat sizes, gear types or date/seasons.
- Permit holder to declare pre-season if you are going to fish or lease the quota. If you choose all lease out of quota, a percentage of the quota goes to set aside for permit banks or redistribution amongst the fleet.
- If at the end of a fishing year a permit holder has quota left over, a percentage of that quota is deducted from the next fishing year and redistributed to permit banks.
Brian fishing with his dad many years ago. |
Currently if a consumer purchases fish harvested by a New England fisherman, there is no certainty that the fisherman earned a cent. I think this can be addressed through accumulation limits and fleet diversity.
NOTE FROM NAMA:
Thank you Brian for sharing your comments. We encourage everyone who, like Brian believes fleet diversity matters, to submit your own comments as part of a public comment period. Click HERE for help on e-mail comments. Every comment counts!