Sunday, April 1, 2007

Moratorium Passes -3A GHL goes to analysis

This is a preliminary report on the moratorium information in brief. I will pass on the complete Council Motion when I have an electric copy for ease of production. In a Nutshell this is what is covered in the moratorium.

Based on 5 or more trips in 2004 or 2005, and in the year prior to implementation (you have to still be active with more than 5 trips) you will get a permit. If you have less than 15 trips your permit may not be transferrable, but you can fish it forever or until you die (like we will probably have to do), or until a Permanent Solution supercedes it, like IFQ’s.
We are hoping it will pass through approval in time for implementation in 2009.
We now have to follow it into NMFS Juneau office and then on to Washington DC. to make sure it doesn’t get pigeon-holed somewhere. I will inform you where and when we need letters sent in support.
A moratorium permit is for Area 2C or 3A so you have to stay where you are at, or sell your 3A when you move to Sitka and buy a 2C permit. (Who would ever want to do that?)
The permit will be issued to the guide Business owner.
You cannot lease your permit to another person.
Your permit will be endorsed for the maximum number of halibut clients you carried on any trip in 2004 or 2005 and the minimum number is 4 people.
You can accumulate up to 5 permits in a business, those original businesses that have over that number will be grandfathered in but if any permits are sold from that business the permits sold will lose their grandfather rights and the rest of the permits will be still grandfathered. That business with the remaining grandfathered permits cannot then buy more permits up to their original number again, once any permits are sold the remaining number is limited up to the use cap of 5 permits.
Each business who reported 5 bottomfish trips during 2004 or 2005 and the year prior to implementation would be issued a permit based on the number of trips summed for all vessels in his best year (2004, or 2005) unless an unavoidable circumstance occurred. A business would be limited to the number of permits equal to the highest number of vessels used in any year during the qualifying period.
CQE program – the council allows communities with less than 10 active charter businesses in 2004 and 2005 to request up to 4 permits in 2C or 7 permits in 3A. These permits will not be transferable. They must be used in that community.

In my rough math (I am no Rex Murphy) I figure that of the total 662 boats in area 3A, 561 boats qualified for moratorium permits with 51 not qualifying and of the 561 boats qualified 90 will be non transferable. Some day we will have only 431 boats in area 3A
In 2C there are 761 boats total, 689 boats qualified and some day there will be only 562.

So we have a moratorium passed and now we wait until it is written and then approved in DC. by the Secretary of Commerce. This action passed the council with no dissention. A strong message.

The GHL analysis was revised for 2C to include more restrictions and should get final action in June at the Council meeting in Sitka. The council began an analysis for 3A and it may or may not have a review in June (more likely in October in Anchorage). We may see the GHL restrictions implemented here in 3A as early as 2008 under Emergency Rule by NMFS. In 2C they are proposing an Emergency Rule for implementation in June 2007 which will hold 2C charters closer to the GHL. Also in 2C the Total Catch for charters may be reduced due to the “Stair-Step Down” clauses in the GHL which takes more fish from the charters and makes the GHL restrictions even more harsh. We need to start thinking about what we want for 2008 Emergency Rule in this area, I testified against the analysis initiation now but then I had other officers (Tim Evers, Larry McQuarrie) in the Halibut Charter Coalition of Alaska testify that we had a change of heart (at lunch) to support beginning an analysis only because to start the analysis now will give us more time to prepare for it when it does happen. Kinda had to decide if we want to keep denying it is coming or if we want to know now so we can get ready. The latter became our choice of poison.

The Halibut Charter Coalition of Alaska of which Homer Charter Association is a sponsoring association, did not prepare any position on an allocation change and the stakeholder’s committee had a position but not enough according to Greg Sutter. We did not think there was much chance to see the council support another allocation adjustment beyond the Advisory Panel’s recommendation (the Stakeholder Committee’s recommendation I add) so we did not testify in any support outside the AP’s recommendation except to move it up some, no numbers were developed by us. We talked to several council members and commercial players and were told there was not much support beyond the AP’s recommendation which was moving 2C’s percentage of the combined commercial/charter catch level from 13% to 16% and to adjust 3A’s combined catch level from 14% to 15%. There was talk about making the GHL a floor, no less than what is is now, and there was Greg’s position for 2C’s to go to 18.2% and 3A’s to go to 15.3%. We know it ended up with Ed Rasmuson's approved motion to set up the Allocation Initial Review at the Oct 07 meeting and Final Review at the Dec 07 meeting. Under Element 1 they also added a Formula of 125% of average harvest of 2001-2005, translated to %: Area 2C = 17% and Area 3A = 15% (about exactly what we figired we were gonna get). Under Element 3 they also added something about the Commercial/Charter Working Group Recommendations on Compensated Reallocation, the work we took part in added below.

I was placed on a work group made up of 4 commercial and 4 charter members (2 from ACA and 2 from HCCA) to draft a start to the discussion of how to develop a recompensation program for any future reallocation from the commercial quota holders to us and in what ways we can do it. Attached is the outline we created for your review but I know we will have more work to do in explaining it and then it goes to the “Stakeholders Committee” and then to the Advisory Panel, and then to the council so it will not be black and white by then, probably black and blue if we can hold it together at all. This opportunity to look into the ways to create a program that lets us buy more fish, how we do it, and how we pay for it was right up our ally, We have kept informed of the workings of the group that met with the government loan program administrators and we do have some experience with the commercial IFQ program for both the program itself and the loans available in the federal government through our involvement on the original charter IFQ committee back in 2000.

The commercial group really wanted us to agree that after this council makes the allocation adjustment discussed above there will be full compensation to the commercial fleet from now on. we cannot make an agreement for you but the message was clear, they don’t want to see any more quota “Taken” from them in the future. We will probably see this one last adjustment of allocation and then that is it. How we buy more and then pay of it is still wrapped around either an individual IFQ “new charter program will be Guided Angler Fish or (GAF)” with individual ownership or a group or pool GAF with no individual ownership. We are still in the game.

I feel that with the regrouping of the original charter players of Tim Evers, Larry McQuarrie, and myself we made a real strong impression at this meeting. HCCA (DCCA and the Prince of Wales “Prince” and HCA) members are recognized as informed, reasonable, and credible and no other charters can claim the long history of involvement like we can. We missed John Goodhand, he was laid up in Fairbanks with a bad back, making his contribution via the phone, but Ken Larson from the Prince William Sound Charterboat Owners Association more than made up for John with his involvement. Ken kept all Valdez, Whittier, and Seward charters represented and was essential to us by his word processing, tireless energy, and mental support throughout this endeavor.

I want to thank Sean and Gerri Martin, Gary Ault, Mike Swan, Joe Svmberski, Mike Coates, Roark Brown, Chuck and Joanne Collins for taking time out of their schedules and attending, testifying and supporting the others and especially the team of Tim Evers, Larry McQuarrie, and myself. We arranged a meeting with the Director of Sport Fish, Kelly Hepler and some of his staff for informal discussions with the charter members present which was real informative, other conversations were made possible with the Commissioner of F&G with Chuck & Joanne Collins while in the council meeting which always impresses those decision makers when they hear “Your “ stories and concerns about the impacts of their decisions. This is how it works, and I really do thank you all for your continued support of my efforts, I always learn a lot from you during those discussions and it helps keep my energy up when I feel overwhelmed. Many council people were expressing surprise and gratitude for my involvement again. I forget how much headway we have made for this industry and even though I have my issues as a result of my involvement it was good to be “Back on the floor”. I have established a lot of credibility and many realize my knowledge of the industry is extensive. Thank you all for your support in every way.


mark said...

John's back is probably hurt from all of those big fish they catch in Valdez. I could have a beer with Sutter and eventually forgive the damage he has done if I don't hear his name involved in this again ( tho it was necessary, he'll probably never forgive my vitriol ). Your sounding a little like a politico, Bob, but overall...HOORAY! ( I have said that before and ACA stepped in and screwed it up for us )

CaptBob said...

Like I said before if my math is correct (I am no Rex Murphy) I figure that of the total 662 boats in area 3A, 611 boats qualified for moratorium permits with 51 not qualifying and of the 611 boats qualified 90 will be non transferable. Some day we will have only 521 boats in area 3A. That is if Tim Evers told me these numbers correctly. My math is not my strongest point, and he has the only current Moratorium Analysis for reference.