(b) (1)
The total number of commercial manta ray viewing operation permits shall not exceed twenty-four for any one manta ray viewing zone. Beginning on the anniversary of the effective date of this section, the department shall not issue any additional commercial manta ray viewing operation permits for a particular manta ray viewing zone unless the number of valid permits for that zone decreases to less than twenty-four. If the number of commercial manta ray viewing operation permits for a manta ray viewing zone has reached the limit set by this subsection, all subsequent permit applications shall be issued in accordance with the requirements of 13-231-60 and 13-234-23.
Why is the DLNR reducing the number of permits for this activity?
How did they determine that 24 is the appropriate number per site?
Until we see some justification based on facts, I oppose arbitrary rulemaking, and rulemaking based on “feelings”.
I propose that all permit holders are allowed to continue to participate in commercial manta viewing activities, and that no new commercial manta viewing permits are issued. I also propose that the DLNR uses permit fees to fund non-biased studies, by a researcher appointed and approved by both DLNR and industry representatives. Based on the outcome of those studies, we can then determine what the appropriate user load of these sites is, and adjust the number of permits accordingly.
Proposed edit:
The total number of commercial manta ray viewing operation permits shall be limited to commercial operating permit holders where the words “manta ray” or “manta rays” appear within the list of approved activities, provided the commercial permit holder has actively conducted manta ray viewing operations within the past year. Beginning on the anniversary of the effective date of this section, the department shall not issue any additional commercial manta ray viewing operation permits for a particular manta ray viewing zone unless the number of valid permits for that zone decreases to less than twenty-four. If the number of commercial manta ray viewing operation permits for a manta ray viewing zone has reached the limit set by this subsection, all subsequent permit applications shall be issued in accordance with the requirements of 13-231-60 and 13-234-23.
My goal is for all approved manta ray activity providers to be able to continue running manta ray tours. “Approved” means the commercial permit lists the words “manta ray” on the permit, in some variation of snorkel or scuba tours.
The total number of commercial manta ray viewing operation permits shall not exceed the number Commercial Operations Permits (COP) that list manta ray snorkeling/scuba as a described activity on the COP under section 19: Restrictions/Activity for the four consecutive years.
Again, I’d be okay with language from the past year to four years.