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CCA VA ALERT

INFORMATIONAL ALERT ON WHICH YOU MAY WISH TO COMMENT
Saltwater Angler Registration Is Coming
What's Your Preference for How We Do It?

Since the federal proposed rule for saltwater angler registration was released in June, VMRC has been looking at ways Virginia can meet the federal requirements. Due to years of complaints about the accuracy of angler surveys, the feds want to develop and use a data base of registered anglers to reference when conducting surveys. Therefore, a national registry of saltwater anglers has been mandated. Anglers can either register with the federal government, which will be free in 2009 and 2010, but cost $15-25 per year beginning in 2011; or Virginia can collect the data needed by the feds through state licensing and/or registration programs and "exempt" Virginia anglers from direct federal registration and the associated federal fee.

According to recent surveys, there are an estimated 836,000 saltwater anglers fishing in Virginia. However, we do not know how many of them fish on charter boats or are under age 16. In addition, the survey currently in use (MRFSS) is not a 100% trusted data source. Charter boat customers will be exempted from the registry (they are counted by a special charter boat survey) as will children under age 16. The bottom line is we have no clear idea how many people will need to register. We can only guess it is approximately 325,000.
Currently, Virginia sells about 70,000 individual saltwater licenses and over 40,000 private boat licenses. The private boat license covers both the boat owner and anyone fishing on that boat, whether the owner is on board or not, so that license category includes a lot of unlicensed people. A private boat license like Virginia's that covers both the boat owner and anyone fishing on the boat, are specifically excluded under the new federal rule. CCA VA believes that any new license requirements adopted by VMRC should produce the following outcomes. First, license fees should accrue exclusively to The Virginia Saltwater Recreational Fishing Development Fund (VSRFDF). Second, any new fee structure should produce at least as much revenue as the current fee structure. Third, new rules should mitigate the impact of the loss of the private boat license. Lastly, compliance should be straightforward and simple for anglers.

FEDERAL REGISTER DOCUMENT ON ANGLER REGISTRY
http://www.st.nmfs.noaa.gov/mrip/aboutus/organization/downloads/Registry_Federal_Register_Notice.pdf

The new federal rule specifically excludes blanket boat licenses, and requires individual registration. It also prohibits exemptions for blanket licenses on public piers, and exemptions for fishing from private lands, which we have here in Virginia.

These requirements leave Virginia three basic options. We have listed the options below that VMRC has identified to meet the federal angler registration requirements.

Option 1
Do nothing at the state level and let anglers comply with the federal rule by registering directly with the feds.

CCA VA Analysis of Option 1:
This option is easiest for the state government, and costs the state government nothing. However, it will cost every Virginia saltwater angler $15-25 per year beginning in 2011, and that money goes to the federal treasury for general use, not the state or even to federal fishery programs. At $15-25 per registrant for the estimated 325,000 anglers; that is $4.8 million to $8.1 million that Virginia citizens and visitors would have to pay, in addition to the state individual or boat fishing license fees, which currently costs saltwater anglers about $2.5 million.

Option 2
Modify the existing state saltwater fishing licensing program to meet the federal registration standards. This basically means licensing every angler from age 16 to 59, and somehow reporting name and contact information for those over 59 within 2 years of starting the registration program.

CCA VA Analysis of Option 2:
This has an advantage to the state of allowing any license fees accrue to the state, but makes a lot of people get licenses that did not previously require them. In Virginia, that includes any person fishing on a private boat whose owner buys the boat license. The boat license would have to be eliminated under this option. Many more licenses would be sold, possibly resulting in more Wallop-Breaux grant money for Virginia, and certainly more money for the Virginia Saltwater Recreational Fishing Development Fund.

Using the estimate of 325,000 saltwater anglers and an individual license price of $12.50 (less $1 for dealer fees), this option could generate $3.7 million for the dedicated recreational fund each year, compared to $2.5 million generated by the current licensing program. That would provide $3.7 million for the VA Saltwater Fishing Tournament, Virginia Tagging Program, ramps, reefs, piers, education, outreach, research, and other programs beneficial to Virginia's saltwater anglers.

One feature that has been mentioned for this option is to create an inexpensive $2 "weekend pass," a three day license that could be obtained over the internet or by phone. This would help mitigate the cost of removing the boat license. Since the convenience of the boat license will be lost (boat guests will have to be licensed or registered and individual credentials checked by enforcement officers rather than the boat sticker), this is an interesting option. Also, a temporary saltwater recreational fishing license, which shall be valid for a stated period of time not to exceed ten consecutive days at a cost of five dollars would still remain in effect. At the present time, a license for out of state visitors and charter boat operators is being worked on.

Option 2A
This option is much the same as option 2 with an adjustment to the individual license price that makes the change "revenue neutral" or at least less expensive. The "weekend pass" could be combined with this option to make cost for infrequent guests even lower.

CCA Virginia Analysis of Option 2A:
A license price of $8 would generate about the same revenue as the current licensing program if there are 325,000 individual licenses sold. The weekend pass of $2 per person could easily be obtained over the internet or by telephone. A temporary saltwater recreational fishing license, which would be valid for a stated period of time not to exceed ten consecutive days at a cost of $5, would remain in effect.

Option 3
This option would create a hybrid system using individual licenses, boat licenses, and a free or low cost individual registration system at the state level. For Virginia, this would mean we could leave the existing licensing system unchanged, and require unlicensed anglers (like those fishing on private boats) to register and carry their annual registration number with them when they fish.

CCA Virginia Analysis of Option 3:
While this hybrid system would allow the private boat license to remain intact, it would create two systems. The existing system would be used for collecting data about licensees, and a second would have to be created for registrants. The registration system would have some costs. Similar programs already in place for hunters cost about 75 cents per registrant per year from one contractor. While it may be far less if the state does the processing in-house, it could still translate into hundreds of thousands of dollars in costs for Virginia. It is certain that any costs for registration system would come from the saltwater license fund, not general funds. At 50 cents per registrant, it could cost us $200,000 based on 400,000 saltwater anglers.

The private boat licensing program has been popular with anglers because of the convenience of "automatically" licensing guests, and because law enforcement does not have to board to check individual licenses. Regardless of the option selection, these benefits will disappear. Individual anglers will have to be licensed or registered, and the presence of a boat license will not satisfy registration for unlicensed guests. Unlicensed guests will have to register before fishing, and law enforcement officers will have to check individuals for a fishing license or proof of angler registration. This could be a confusing system with serious compliance issues due to that confusion.

CCA Virginia believes there are some significant opportunities we can consider as Virginia reacts to this federal mandate. We could restructure our licensing program, and generate more funds for angler supported projects. Creating a central angler registry that must be electronic and therefore legible, portable, and accessible will finally provide CCA Virginia and other angler advocates with the data needed to lobby effectively for angler issues.
And most important, we will finally provide the fisheries managers with some of the tools necessary to assure more rational and accurate assessments of angler effort and catch. This will hopefully create a better sense of fair treatment in the angling community.

For these reasons, CCA Virginia supports option 2A with an individual fishing license priced at $8, the weekend pass option at $2, and a temporary license up to ten days at $5. Also keep any new revenues in Virginia's Saltwater Recreational Fishing Development Fund. We also prefer this option because it uses one system: registration and licensing are integrated into a single system and available from the same venue. Licensees would be automatically placed in the registration database, and not be also required to "register" as a separate transaction. This is essential for the ease of compliance, and the resultant rate of angler compliance.
Send your comments by letter, fax, or email to:

Virginia Marine Resources Commission
2600 Washington Ave, 3rd Floor
Newport News, Virginia 23607
Attn: Jack Travelstead

Fax number 757-247-8101

E-mail to: [email protected]
Please include your name, address and phone number on emails. If using email, please copy [email protected] so CCA VA can monitor the results.
________________________________________________________________________________________________________
The preceding was provided as a public service by the Coastal Conservation Association Virginia (CCA VA). Feel free to forward it to your associates. If you have any comments concerning this issue, or would like to have your name added/removed from the distribution list, reply to this message. The purpose of CCA is to advise and educate the public on the conservation of marine resources. CCA VA is a 501(c)(3) charitable organization whose goal is to Conserve, Protect, and Restore marine resources for the benefit of all Virginians. Please visit our website located at Welcome to Coastal Conservation Association Virginia for more information.

Frank A. Kearney III Co-Chairman CCA VA Fisheries Management Committee [email protected]
Larry Snider Co-Chairman CCA VA Fisheries Management Committee [email protected]
 
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