December 2, 2002
Robert Treanor Executive Director California Fish and Game Commission P.O. Box 944209 Sacramento, CA 94244-2090
Dear Mr. Treanor and Commissioners:
Re: December 6, 2002 Agenda Item 19
In 1990, the Little Hoover Commission wrote "Within California State government, an oft-repeated charge concerning the DFG's internal administrative capacity is the seeming inability of the DFG to provide timely, comprehensive and well-founded fiscal and program information. Whether requested by State control agencies, such as the Legislative Analyst and Department of Finance, or by the public, the DFG, it is claimed, has been unable to provide anything more than rudimentary budget, allocation and expenditure information. Further, critics claim DFG's management information system is not simply primitive, but has undercut DFG's ability to provide for the collection of taxes and fees, which, as previously noted, constitute the DFG's main revenue source."
With the Commission's adoption of the Nearshore Fishery Management Plan, the Commission and not the Legislature now set commercial nearshore permit fees as has been the case up to now. The Recreational Fishing Alliance is concerned over the DFG's proposed new commercial nearshore permit price of $500. We feel that figure has been pulled out of the sky, an arbitrary number not based upon the costs the department incurs while administering, enforcing and managing the commercials in the nearshore. I have spoken to DFG wardens and DFG economists, and they concur. The Department's own economist has come up with a $2000 permit, even before he spoke to the Enforcement Division heads. Our CPA's have come up with a figure in the $11,000 range.
The baseline costs for management of the nearshore finfish fishery before the adoption of the NFMP ran $3.782 million for Management, Enforcement, and Research. The NFMP calls for an additional $3.782 million for expenses relating to the administering of the NFMP. The total is $7,761,872.
2003 Allocation Total cabezon, greenling, sheephead, scorpionfish and NS rockfish statewide:
Commercial = 247.3mt(29%) Recreational = 603.6mt(71%)
29% of $7,761,872 = $2,250,942/200 permits = $11,254 per NS Permit
It does not pass the "straight face test" that the recreational sector is basically off the water until the 1st of July while the commercials livefishermen are fishing 10 months of the year. The fact that the Commission is now allowing PFMC(the same council that has managed the shelf into a 170 year closure), to manage the nearshore of the State of California, does not pass the "straight face test". But now, to add salt to the wound, the Department is proposing the recreational sector to continue to subsidize these 200 fishermen with our fish AND our money doesn't pass any kind of test. We ask the Commission to tell the Department go back and do their homework until it is right.
The Recreational Fishing Alliance, Northern California Chapter,
Randy Fry President