Wednesday, January 24, 2007

sample letter to the secretary

Secretary of State Condoleezza Rice
US Department of State
2201 C Street NW
Washington, DC 20520

January 21, 2007

Dear Dr. Rice,

On Friday, January 19, the International Pacific Halibut Commission voted to impose a 1 halibut limit on recreational anglers who fish from charter boats during portions of June and July in Alaska. I am a concerned US citizen who values my rightful access to this public trust resource and I am writing you to protest this action.

The IPHC has made a domestic allocation decision by restricting recreational charter harvest to the direct benefit of the longline sector. Additionally, by allocating 1 fish per day to charter recreational anglers and 2 fish per day to private recreational anglers, the IPHC has made an arbitrary allocation decision within the recreational sector.

The Guideline Harvest Level (GHL), which is advisory only in nature, has been turned by the IPHC into a hard allocation, complete with restrictive measures, without the protections and opportunities for public participation, and without regulatory review or environmental and economic impact analysis required of the Fisheries Management Council process.

By restricting charter recreational anglers while not restricting private anglers, the IPHC is violating the fair and equitable clause of the Halibut Act, in addition to discriminating between residents of different states, also a violation of the Halibut Act. (The vast majority of charter clients in Alaska are residents of other states.)

The IPHC claims their action comes from a biological concern because the Constant Exploitation Yield (CEY) was exceeded. The simple fact is that the projections used by the IPHC to estimate recreational removals were wrong. Despite the fact that the theoretical CEY was exceeded due to inaccurate projections, the IPHC admitted that the halibut stocks are healthy, and allocated 880 thousand pounds more than IPHC staff recommendations to the commercial sector. IPHC’s “biological concerns” are a weak excuse for the reallocation of the resource from the recreational sector to the commercial sector.

The IPHC has previously been advised by NOAA that domestic allocation decisions are the responsibility of the Fisheries Management Councils, and not IPHC. Please take immediate action on this issue by disapproving IPHC’s action, and reminding both the IPHC and the NPFMC of their respective responsibilities and limitations with respect to management of the species.


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