Gulf Council Action on Permit Moratorium
At its August meeting, the Gulf of Mexico Fishery Management Council took some important if not complicated steps forward with Amendment 17 to the Shrimp Fishery Management Plan (FMP).  This Amendment is being developed by the Gulf Council for the purpose of addressing the upcoming October 2016 expiration of the current moratorium on the issuance of Federal permits for vessels to operate in the shrimp fishery in the US Exclusive Economic Zone (EEZ).
At the August meeting, the Council considered an Options Paper prepared by Council staff that covered a wide range of alternatives – ranging from allowing the moratorium to expire and provide open-access to the fishery, to placing various floor and caps on the number of permits to be maintained in the fishery.
Some of the important considerations underlying these alternatives are –
1)      The number of valid (or renewable) permits in the fishery has progressively declined from 1,933 when the moratorium was implemented in 2007, to 1,470 as of December 31, 2014. This is a decrease of 463 permits, or 24%.
2)      With the decline in permits and associated fishing effort, the catch per unit effort (CPUE) – the catch rate – by individual shrimp boats is, on average, at a much higher level today than it was prior to the moratorium. This has substantially improved the cost efficiency of shrimp vessel operations.
3)      Since the moratorium began there has been a progressive decline in the total pounds of shrimp landed by vessels fishing in Federal waters and how that production relates to Maximum Sustainable Yield and Optimum Yield, and the needs of the shoreside processing sector.
Prior to the development of the Options Paper, SSA Executive Director John Williams advanced a proposal at the February 2015 meeting of the Council’s Shrimp Advisory Panel that would extend the moratorium for an additional 10 years through October 2026, as well as put both a floor and cap on the number of valid permits maintained in the fishery at the number that existed at the end of 2014. This proposal included a mechanism for NMFS to place expired permits into a reserve pool and to reissue those permits if and when the total number of valid permits in the fishery is below that 2014 floor.
In this respect, Mr. Williams’ proposal was intended to strike a reasonable balance between various competing objectives including – maintaining a minimum level of participation in the shrimp fishery, maintaining high levels of CPUE and associated improvements in shrimp vessel economic efficiency, and address the decline in total landings. Click here to read Mr. Williams’ proposal with explanation.
The proposal also included provisions setting a minimum vessel size for such permits to be attached to. This was for the purpose of preventing speculators from purchasing permits and attaching them to skiffs and to promote the active participation of permit holders in the fishery.
This proposal was adopted unanimously by the Shrimp Advisory Panel as its formal recommendation to the Council, and its elements were subsequently included in the Council Options Paper considered at the August meeting.
After extensive deliberations by the Council’s Shrimp Committee Chaired by Leann Bosarge, and the full Council itself, the Council decided to split Amendment 17 into 2 parts – Amendment 17A and Amendment 17B. This was decided in large part because of the increasing scope and complexity of new alternatives added by Council members to the Options Paper during the August meeting – all of which require extensive analysis by Council staff.
Consequently, Amendment 17A will focus on the upcoming October 2016 expiration of the moratorium itself. *   Alternatives under consideration include allowing the moratorium to expire (open access), extend the moratorium for an additional 5 years, and the Council’s preferred alternative, to extend the moratorium for an additional 10 years.
Because Amendment 17A is silent on the complex policy questions regarding the number of permits to be maintained in the fishery, the Council believes it can be finalized in time for the expiration of the current moratorium next year.   The policy regarding the number of permits to be maintained in the fishery will be addressed subsequently in Amendment 17B. Alternatives to be considered will include the elements of the proposal made by Mr. Williams and adopted by the Shrimp AP as its recommendation to the Council.
The Council intends to consider and adopt a new draft Amendment 17A at its October meeting and to have that draft subsequently circulated for Public hearings and comment. Final Council action on Amendment 17A will likely take place either at its January 2016 meeting or at the latest its April 2016 meeting. From there it must go through an extensive agency process of administrative review and regulatory implementation to be completed by the October 2016 moratorium expiration.
At its October meeting the Council will also likely review a draft options paper for Amendment 17B. Again, because of the scope and complexity of the alternatives now included in this Amendment addressing the policy of if and how to maintain a target number of permits in the fishery – and what that target number should be – the process for finalizing Amendment 17B may take years. In the meantime, it can be expected that the total number of valid permits in the fishery will continue to decline.
SSA will continue to participate actively in the Amendment 17 A and Amendment 17B processes both through its members and staff on the Shrimp AP, and working directly with the agency, Council members and staff.
* Amendment 17A will also include a measure to address the royal red shrimp endorsement associated with Federal shrimp permits. See the Council’s Option Paper for explanation.
New Information Available on Status of Individual Shrimp Permits
In response to the Council’s discussions at its August meeting, NMFS has updated its data profile on federal shrimp permits in an effort to improve transparency and facilitate the efforts of prospective shrimp permit buyers to identify potential permit sellers.
Currently, shrimp permit holders must renew their permits each year for their permit to be considered valid and eligible to fish. However, the agency provides an additional 1 year grace period for permit holders to renew their expired permits before the permit will be considered permanently terminated.  The owner of a permit that is expired but renewable during that one year grace period may be interested in selling that permit.
The following link now clearly provides the status of all federal shrimp permits including if they are valid and if they are expired but still eligible to be renewed and/or transferred to a new owner/purchaser.

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