COMMENTARY ON PROPOSED FISHERIES REGULATIONS
- The Delphi Club is a strong supporter of environmental conservation, particularly in relation to safeguarding the fragile habitat of bonefish and preventing the overexploitation of fish stocks. The club is a significant supporter of both local and international organisations who share these aims.
- The Delphi Club also fully recognises its responsibilities to operate to the benefit of local Bahamian communities. The major capital investment made in the Club and its significant and ongoing contribution to the local Abaco economy, despite very modest financial returns, demonstrate the seriousness of the Club’s intent in this regard.
- The several dozen bonefishing lodges of the Bahamas collectively represent a vitally important component of the Bahamian tourism industry – a component that offers one of the few genuinely world-class attractions in the Bahamas and one that can operate with minimal environmental footprint over an unusually long season. It is worth tens of millions of dollars to the national economy each year and requires very careful handling.
- In our view, the Consultation Draft dated June 17th, 2015 is fundamentally flawed in that it fails to identify or explain the problems that give rise to the proposition that further regulation is needed, or the scale of those problems. It surely behoves the drafters of any new regulatory proposal to explain clearly the detailed reasoning behind the proposals.
- We also consider a nine-day consultation period on a matter of such importance and sensitivity to be wholly inadequate and, if the perceived problems really do warrant regulation, we would urge the proponents to prepare and circulate a much more detailed assessment of the problems and the arguments for and against regulation. This should then be subject to careful consideration by all affected interests over an extended period.
- While accepting that there may indeed be localised issues in relation to misbehaviour by a small minority of anglers and there may also be more strategic issues in relation to intrusion by unlicensed boats and so-called mother-ships, we remain to be persuaded that these issues justify such draconian regulations as are currently mooted.
- Any new regulatory measures should take full account of the onerous bureaucratic and financial burdens already being borne by small fishing businesses, and recently added to (for many) by the imposition of VAT. To increase these burdens, as seems to be proposed, should require clear and robust justification. In our view, the existing bureaucratic burden already operates against prospects for long-term prosperity and no case has been made for adding to it.
- The bonefishing industry in the Bahamas cannot be looked at in isolation. There are many other countries (Belize, Cuba, Mexico, Turks & Caicos, USA, Venezuela, Seychelles, Mauritius, Hawaii, and Christmas Island, to name but a few) offering similar bonefishing experiences. And, when it comes to competing for the annual spending budget of the limited pool of travelling anglers, the bonefishing sector is also up against many other fishing destinations, competing intensely with with hundreds of lodges from Alaska to Tierra del Fuego, from New Zealand to Quebec.
- Any new regulatory proposals should:
- address how the perceived problem areas are dealt with in other countries;
- recognize that the Bahamas is already one of the most expensive bonefishing destinations in the world, with recent reputational damage arising from the introduction of VAT (the burden of which primarily falls on overseas visitors);
- do nothing to deter potential visitors or make them feel in any way unwanted or unvalued;
- ensure that the vast majority of potential visitors would regard the regulations as desirable, fair and effective.
- We believe that most of our international guests would have no problem in principle with paying a modestly-priced licence fee, so long as the bulk of the proceeds are demonstrably being used for the protection of the bonefishing resource. But the administration of any such scheme would need to be straightforward and the funds applied with total transparency.
- A central thrust of the draft is the attempt to draw a distinction between Bahamians and non-Bahamians. In our view, great care needs to be taken to avoid giving any impression of distasteful and out-dated discrimination. The need to provide local employment and encourage local enterprise should be balanced against the need to attract outside visitors – and investment – so as to be able to offer the best possible tourism experience and garner an enduring flow of high-quality income. If, for whatever reason, it is deemed that anglers must have a permit or licence to go flats fishing, then the requirement should apply to all anglers, irrespective of their nationality. Any hint of short-term self-interest, xenophopia or narrow-minded protectionism would seriously damage the reputation and long-term prospects of the Bahamian bonefishing sector and thus act against the overall common good.
- We understand that one of the issues that may have prompted a desire in some quarters for new regulations is that of unguided or so-called DIY fishing. In our experience this is not a major problem. Certainly, it would be extremely damaging to prohibit all such fishing. Many of the anglers that engage in this have paid a lot of money to come and stay in the Bahamas. Many also do a mix of guided and unguided fishing. They pay locally for accommodation, food & drink. And most anyway soon discover that they are better off tapping into expert local assistance. But some anglers do simply like to get lost on their own and commune in a private way with their environment; they are not in any sense bad people. Unless there is evidence that unguided anglers are causing serious damage (which we strongly doubt) or are failing to contribute to the local economy (which we also doubt), the practice should be tolerated in a country that currently needs all the tourist traffic it can get.
- Another issue that may underlie the new proposals is that of foreign-owned mother-ship operations, where large boats, perhaps with a fleet of satellite skiffs, enter Bahamian waters to exploit the bonefishing resource without contributing in any way to the local economy and often using non-Bahamian guides. We have encountered this problem and we do accept that it is potentially serious and should be addressed. We have had skiffs from a US mother-ship following our boats and using GPS tracking to discover and record the secret places favoured by our Bahamian guides. This is not acceptable from any perspective, being unfair on those who have endured the local licensing process and built up special knowledge and experience.
- We suspect, however, that the mother-ship issue (and probably other issues too) could be addressed within the context of existing licensing requirements. The real problem, we suggest, is not a shortage of regulations but a lack of will and/or resources to enforce the existing requirements.
- While the proposition that import duty concessions might be made for certified fishing lodge operators is of course welcome, this should in no way be connected with, or offered as compensation for, the introduction of regulations the need for which remains unproven. Such concessions should in our view be an automatic entitlement of anyone who has been through the onerous approvals process required by the Hotel Licence and Business Licence legislation.
- A ban on commercial fishing in the flats for certain species would be welcome from our perspective and would provide useful marketing material for the Bahamas. But commercial crab fishing seems a legitimate pursuit that often takes place in flats areas and should perhaps be exempted. Any ban, however, is only as good as the enforcement regime and, based on our experience of other fishery regulations, current enforcement is woefully inadequate. We therefore question whether this new regime would emerge as anything other than a paper exercise.
- At a time when a high proportion of Bahamian bonefishing guides are entering the twilight of their career, there seems to be an alarming shortage of young new entrants to the profession. Despite the generally high rates of pay, it seems not to be attracting the same level of interest as it used to. In that context, there is a need to be very careful not to erect further barriers to entry into the profession. By all means let there be training schemes available, but the draft regulations seem unduly prescriptive.
- In summary, we remain to be convinced of the need for new regulations along the lines proposed. We feel the market-sensitive issues require much more careful and detailed consideration. And we have serious doubts about ultimate enforceability.
The Delphi Club, Abaco
PO Box AB-20006, Marsh Harbour, Abaco, The Bahamas
Tel: 1-242-366-2222. E: email@example.com
THE DELPHI CLUB is an eight-bedroom boutique hotel & fishing lodge located at Rolling Harbour in South Abaco. It is owned by Delphi Club (Bahamas) Ltd [DCBL], a Bahamian-registered company. DCBL is owned by 38 international shareholders, although majority control rests with Peter Mantle and his family.
The Delphi Club opened for business in the summer of 2009. Built from scratch in a remote part of Abaco, the lodge targets upscale international anglers and their partners, predominantly from Europe and North America.
Total capital investment in DCBL was $6,000,000. Three quarters of the funding came from shareholders and the balance from a local bank.
The Club has a turnover of more than $1,000,000 per annum, but it has yet to record a profit after six years of trading. It employs fourteen people, all but two of whom are Bahamian, and it is also the primary source of income for a team of six Bahamian freelance fishing guides.
The Club is a significant contributor to the economic wellbeing of Abaco, especially to the local communities of Crossing Rocks and Cherokee.
PETER MANTLE, 63, is the managing director and majority shareholder of DCBL. With joint British and Irish nationality, he is a law graduate from Cambridge University in England and is both a qualified chartered accountant and an experienced journalist. He has devoted the past thirty years to the development of world-class fishing lodges in Ireland and the Bahamas. He is a permanent resident of the Bahamas.
This report just in from Max: “Took an afternoon walk on the Club beach, saw 3 huge tarpon cruising the shoreline. So ran to get my rod, found them, hooked up the biggest of the three – 80-100lbs. Jumped him three times, and lost him. Gutted!”
We’ve had another nice review in the Angling Report. Click on Lodge/Reviews in the toolbar above to read it.
The Bahamas are world-renowned for bonefishing. The annual economic value of the fishery exceeds $140 million. Yet the fishery will remain healthy only if the habitats remain healthy.
Proposals to create National Parks for habitat protection for Grand Bahama Island and Abaco are now on the desk of the Prime Minister of the Bahamas. We are asking you to support the efforts of the Bonefish & Tarpon Trust and its Bahamas collaborators to get this done.
Below are links to two petitions: the first to support the Grand Bahama parks, the second to support the Abaco parks. Please sign them both, and pass it on.
Grand Bahama – http://bahamasparks.org
Abaco – http://www.thepetitionsite.com/266/809/008/ask-the-bahamas-government-to-protect-bonefish-habitat-in-abaco/
The biggest bonefish taken by a Club guest in the past six years was caught yesterday by Club member Bob Rusby, from Sheffield, England. Bob was wading at Casuarina Point on Cherokee Sound. The fish measured 32 inches in fork length, making it at least 11lbs and possibly 13lbs, depending on which chart you rely on.
Tragically, Bob did not have a camera with him, so no pics…