Probaly should have put this on the "other thread", but it seems to be getting lost.

Hello Mr. Travelstead,

I’m writing to oppose the Limited Entry Guide License proposal as it is written.

It is my understanding that the intended purposes of this measure are as follows:
1. Allow VA Charter boats greater access to MD waters, much in the way that MD charters have access to VA waters.
2. Identify the number of MD charter boats that fish VA waters.
3. Create an enforcement tool to address out-of-state boats fishing over the three mile line.
I’ve also been told that there are additional reasons that were not stated at the Finfish meeting on November 19, 2008:
1. To help manage the winter Striped Bass fishery.
2. To promote professionalism amongst VA’s charter fleet.
3. To initiate NC Charter operations to push NC towards reciprocity.
4. To increase public safety
5. To insure the health of VA’s charter industry.
6. Allow VA Charter Boats access to MD’s spring trophy season.
(If there are additional perceived benefits, please bring them to my attention before the 11/25/08 meeting.)

While most of these reasons are very valid, I feel strongly that the negative impact of the proposed Limited Entry Guide License far outweighs the benefits. I’d like to address each of the issues individually:
1. Currently there are (correct me if I’m wrong) ~30 VA Charter Boats that have access to MD waters. And, another 12 permits have been offered by the state of MD without ANY action from VA, bringing the total to 42 boats that will have access to MD waters. Considering the total number of boats registered in the Northern Neck and the Eastern Shore’s bayside is ~50 boats, the delta of those that will still be left out is ~10 boats. It’s also been stated, per your presentation at the Finfish Committee meeting, that MD will assess the impact of the VA boats on their fishery and may renege on the agreement if it’s considered to be detrimental to their resource. To me, this makes the issue moot. First, the number of operations affected by doing nothing is not that great. Secondly, MD has stated that they may renege (and based on past actions, certainly will) if they feel too many VA boats are fishing their waters.
2. I feel that a better, less limiting means, of attaining this goal is to institute an “Open” entry guide license for any charter operation fishing in VA waters. This would give an accurate count on the number of MD boats fishing VA waters, while giving the enforcement tool that’s needed to address those fishing beyond the three mile line. It will also be FAR less detrimental to VA residents who want to enter into the charter boat industry, address the issues with multiple-boat owners, and alleviate the negative economic impact on marina, restaurant, hotel and shop owners who benefit from MD boats operating out of VA beach during the winter striped bass fishery. Another benefit of this option is the revenues generated from out-of-state license sales being applied to a department that is already underfunded.
3. See above.
Response to each “Additional Reason”:
1. The management of the striped bass fishery, in my opinion, should be done through managing the resource… not by managing the industry. If this measure is passed, and estimated 20 MD boats will no longer participate in this fishery. The number of fish harvested by them pales when compared with the total harvest.
2. This justification/reason was presented by Bob Pride, not by you. And, it’s my opinion, that this assertion is VERY wrong. Limiting the competition in ANY industry will not promote professionalism. Competition promotes professionalism and a better product for the consumer.
3. I feel that penalizing the NC charter operations to do the state’s bidding with NC is the wrong action to take. This is something that should be done from Richmond, not by the VMRC.
4. I’ve never heard of any instance to support the need for greater safety in the charter industry. And I strongly feel that a measure such as this would have absolutely no positive impact on safety. If anything, it will promote the opposite if charter operations have less competition.
5. While this will surely help VA Charter operations, I feel strongly that there’s a better way to go about it… a way that will not affect local economies or a person’s ability to enter the profession. By instituting an “Open” Entry Guide License, out-of-state charters will no longer be free to fish over the three mile line. It will level the playing field with VA Charter Boats. If, on a level playing field, VA operators can’t compete with out-of-state operators (who have the additional expense of out-of-state guide permits, lodging, meals, etc.), then maybe it’s time for the VA operators to re-evaluate their operations. I strongly agree that something has to be done to help them compete better… and keeping out-of-state operators inside the three mile line will do just that.
6. I’m not sure how many boats, outside of the ones who already have access, and those who are located geographically near MD will re-locate for this fishery. After talking to captains I know in Tidewater and the Eastern Shore, my answer would be “few, if any”. It was stated that they just didn’t have the clients that would want to travel to MD to catch striped bass at that time of year. And, that their efforts would be more productive if they solicited charters to fish for the wide array of VA species available at that time… and there are many. If this is doubted at all, please refer to the VA Saltwater Fishing Tournament results, or the tagging program’s results for the month of April.

Mr. Travelstead, over the past 2 years I’ve spent over $2,000.00 (not counting boat payments on a rig that was purchased with the intent of chartering) preparing to enter the charter industry as a means of helping to support my family… the same way my Grandfather did, and his father before him, and so on. The way the current Limited Entry Guide License is written, I will not be able to do that without considerable added expense and time.

While a Limited Entry Guide License may be in Virginia’s future, I feel strongly that with the way the proposal is currently written, now is not the time. I feel that even if it is passed as written, it will provide absolutely NO guarantee that MD will honor reciprocity if they feel it damages their resource. By passing an “Open Entry” Guide License, the majority of the goals will have been met, additional revenues will be generated, and it will allow the time needed to fully evaluate the impact of a Limited Entry proposal. Tom Powers’ proposal of Limited Growth Guide License is another option that I feel should be discussed at greater length, and one that will also have far less negative impact.

Kindest regards,