charter fisherman's Association

CFA letter to SERO for rules clarification

10 Sep 2020 1:11 PM | Gary Jarvis (Administrator)

Dr. Roy Crabtree

Regional Administrator

National Marine Fisheries Service

9721 Executive Center Drive North

St. Petersburg, FL 33702

 

Roy,

        Hope all is well and look forward to the days when we can all get together under more normal circumstances. The board of Directors here at the Charter Fisherman’s Association have instructed me to reach out to SERO, the NMFS and Gulf Council Chairman to get some crucial information on the status and implementation of the SEFHIER program. I am also tasked in this letter with letting all those involved in the development and implementation with SEFHIER to share our concerns that we may have once we get a clearer picture of what the final product is going to look like. As I write this letter, I realize the challenges of implementing an Industry led self-reporting data program that had never been done before. Our Board members and I have participated in numerous ELB pilot programs including a rights-based management EFP that had such a system. With that experience we are aware of the challenges the SEFHIER program has and will face as this moves forward. And although as a organization, we have worked tirelessly to get a ELB system on our fleet vessels, we know that the delays have been frustrating for us and those of you in the agency. And now, to exasperate the situation and most likely add to further delays all of us have had to change our daily lives and ability to go to work and preform our duties due to the Covis-19 pandemic. This present shelter at home /work at home and no face to face meetings has put us all at a disadvantage on being able to communicate freely on this program. So, for us at CFA we have taken a position of patient and to do our due diligence by continuing to work with you on the SEFHIER program that will lead to good results once this system is in place.

With this letter I am including a copy of the summary reports that stemmed from the many workshops that were held to get industry input , questions, concerns and solutions offered to create a well-supported, enforceable and successful electronic self-reporting system for the charter for hire industry. Also attached is the 2019 power point presentation we all got that was approved and sanctioned by the agency to share with all the stakeholders at those workshops. The concerns we are having is what has become of the information presented on slides 16 thru 20 of the presentation and will be the basis of my questions.

Based on slide 16 has any of this changed? If yes how? And if yes why?

Slide 16

  •        An account must be set-up with Atlantic States Coastal Cooperative Statistics Program (ACCSP)
  •        Reports can be made using a tablet or mobile phone app
  •        Reports can also be made using VMS

Approved app/VMS vendors will be listed on the NOAA Fisheries Southeast Electronic Technologies website: https://www.fisheries.noaa.gov/southeast/southeast-electronic-reporting-technologies

Next Question is based on slides 17,18   where in that presentations and the assumptions we had was that our industry would have a choice of two types of vessel monitoring and electronic reporting. Are there two options and cost associated with those options still available? If not, why? And if that is no longer true, how do you plan on addressing the lack of options or capabilities of a single system due to the unique aspects of the CFH industry both in vessel type and geographical challenges when it comes to data transfer? As you can see if you review the workshop summaries there are some who will favor the VMS based technology verse the GPS data logger cell phone reporting application. Either way for industry buy in which is crucial for compliance, accuracy in the self-reported data and for this system to be exceptional these 2 options are an absolute must.

Expected to be approved for Gulf of Mexico permit holders/slide 17

eTRIPS/mobile (ACCSP)

       a tablet-based program

       a mobile phone-based program is expected to launch March 2019

       Hail-out capability will be added in March 2019

       Requires internet connection

       24/7 helpdesk

       VESL (Bluefin Data)

VMS Expected to be approved for Gulf of Mexico permit holders:

Federal Permit Holders Must /slide 18

       Have NMFS approved hardware/software with GPS capabilities that is permanently affixed to the vessel and that, at a minimum, archives vessel position data and transmits it to NMFS

       Pings once per hour

       VMS will meet the requirements (vendors must be approved for for-hire program)

       Southeast Fisheries Science Center is testing 7 archival GPS units

       Results will be available in June/July

       NMFS will begin review and approval process

       Types of Units       Solar or Powered by the vessel

       Range of cost Unit: $150-800      Monthly: $10-40

So, in closing I hope that you and your staff can give us the status of these concerns, be able to give us a update on the next expected stage of development.  I think as we get  closer to the implementation of SEFHIER into the CFH sector that we work to improve our level of communication with the SEFHIER program directors and developers to assist us and them in clearing up any confusion among our membership and industry across the board. CFA since we introduced sector separation in Aug of 2008 has been the Bell cow for higher levels of accountability in the CFH sector and one of the key corner stones of that plan was verifiable self-report catch effort and landings recorded before unloading our catch using electronic log books. The technology available now verses then has increased in unmeasurable bounds. Our efforts to continue to support and push for better data collection and the science that it will enhance remains high on our mission statement list. I look forward to your response to our concerns and a better level of communication on our part to be part of a solutions-based team involving the NMFS, SERO, gulf council and Charter fisherman’s Association.

Captain Gary Jarvis

Executive Director

Charter fisherman’s Association

 

 

 


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