RFA Letter to NMFS

RE: Charter Vessel Halibut Comments
Dear Ms. Salveson:

As a recreational fisherman, I object to the proposed regulations to reduce the guideline harvest level for Pacific halibut in the guided sport charter sector in Area 2C. The recreational halibut fishery in this area is critically important to the local economy and brings non-resident anglers from across the entire nation to Alaska. As it is currently written, the proposed rule will modify the daily bag limit from 2 fish per day to 1 fish any size and 1 fish smaller than 32 inches and stands to severely disrupt this important historic fishery. My opposition to this action is outlined in the following points.
1) Proposed rule is a misuse of guideline harvest limit (GHL). GHL’s set forth in 50 CFR 300.65(c)were established to monitor the halibut charter fleet not to restrict its activity or growth. Downward adjustments to GHL’s are only to be taken when there is a decline in Pacific halibut abundance.
2) Proposed rule is based on incomplete data. NMFS is using data developed through Alaska’s Statewide Harvest Surveys (SWHS) to support the proposed rule. At this time, SWHS data from the 2006 season are preliminary projections and will not be finalized until August of 2007. It is not appropriate for NMFS to take such drastic action using incomplete data.
3) Proposed rule will discriminate against non-resident anglers. The vast majority of non-resident anglers that travel to Alaska to fish for halibut do so in Area 2C. The proposed regulations will disproportionately affect the non-resident anglers that fish this area and damage the traditional charter fleet supported by these fishermen.
4) Proposed rule fails to take into consideration growth of the sector. When GHL’s were implemented, levels were set to accommodate growth in this sector. Since the GHL was put into effect in 2003, it has been exceeded every year; hence, it was never set appropriately and set to be exceeded.
Growth of the charter fleet harvest in Area 2C has increased, on average, less than 1% annually with only higher increases in recent years. This gradual and expected increase is consistent with discussion during the development of GHL’s.
5) Proposed rule fails to impose restrictions on commercial fishing sector. Under the proposed rule, fishing reductions will only be implemented on the charter sector of the fishery. The recreational halibut fishery is far more valuable than commercial halibut landings yet the guided sector is restricted
to an allocation less than 20% of the poundage allocated for commercial bycatch. A more efficient approach would impose management measures to reduce waste in the form of commercial bycatch and use the savings to accommodate the natural growth of the guided sector harvest.

Thank for your consideration,