After years of no restrictions on the number of boats, divers, and fishermen visiting Cozumel's reefs, studies were undertaken to look for ways to mitigate the damage being done by so much traffic. A design was developed that established a underwater park, divided into zones. These different zones were delineated according to the different levels of activities that could be undertaken in each zone. Some zones were allowed to sustain more activity, some less, and these zones could be modified in the future according to the way the reefs responded to these activities. In addition to the studies regarding activity zones, other studies were undertaken to determine how many divers and boats these zones could accommodate. An upper limit was established and a plan implemented to issue permits for operators. A set number of permits was made available that would limit the park operators to this number to insure the maximum level of activity permissible on the reefs was not exceeded. Once these permits were issued, the maximum possible number of boats/divers was fixed and no more permits were supposed to be issued (although a few more apparently were).
Permits are allowed to be traded, sold or transferred. It doesn't matter to the park who has a permit, it only matters that whoever has a permit obeys the park rules and that the number of permits (and therefore the amount of activity) does not exceed the amount allowed for a healthy reef, as established by the previously mentioned studies.
The excuses that non-permitted operators are putting forward to try to get new permits issued above the limits established are self-serving and not in the interest of the health of the reefs. There are previously-issued permits available for trade or purchase. Just because the non-permitted operators don't want to offer enough to entice one of these permit holders to sell them their under-utilized permits, it doesn't mean that they should have a right to have a permit issued beyond the establish limit allowed.
That being said, the limit on the number of permits was established based on the amount of activity that could take place without negatively impacting the reefs. If this maximum amount of park activity is not being reached due to unused or under-utilized permits, the park should set a minimum use level for each permit. If this minimum use level is not being met, the permit should be revoked and re-issued. Use it or loose it.
