Charter Halibut Allocation/Reallocation: Initial Review

We had better get some input on this issue. 125% of the 2001-2005 avg charter harvest (GHL updated thru 2005) is the only equation relevant to the 21st century. A ten year old GHL is out of date and out of reality. Setting a harvest level with a flawed census that is only beneficial to the over burdensome commercial interests is the clasic case of the monopoly holders dictate the rules . This is a felonius assault on the free enterprise system. A federal governing board is held to the constitutional free enterprise system. Does anyone know a constitutional lawyer? Perhaps we think too small?
This is it, either you get onboard now with a linited entery with catch history verified or you are an old man fighting the system! What a noble cause! Been There Done That!!!!

Prefered Alternative

For discussion purposes by the Charter Industry

The following plan now before the Stakeholders and the North Pacific Fisheries Management Council is under consideration by the industry as our primary alternative for the long term solution for management of our industry.

There are certain options that we will discuss where options must be chosen.

The proposal follows:

ALTERNATIVE 6. Limited Entry Plan with Angler Days and charter allocation with limited access to commercial QS (purchase) and IFQ (leasing) for charter operators
10/26/07

Action: Implement an Angler Day Limited Entry Plan with charter allocation and limited access to commercial QS (purchase) and IFQ (leasing) for charter operators

Halibut Charter Limited Entry Permits

Element 1. Permits may be held by a U.S. citizen or a U.S. business with at least 75 percent U.S. ownership of the business. Businesses may receive multiple permits due to charter halibut activity by vessels reported by the businesses in ADF&G logbooks. Initial permit recipients may be “grandfathered” below the U.S. ownership level and above proposed use caps.

Element 2. Permit would be designated for Area 2C or Area 3A. If a business owner qualifies for a permit in both areas based on the history from a single vessel, he/she would be issued a separate permit for both areas. Only one permit could be used on any given trip.

Element 3. Permit would be issued to the holder of a Guided Sport Moratorium (GSM) Permit

Element 4. Permit applicant would be required to sign an affidavit attesting that all legal requirements were met.

Element 5. Permit would carry an Endorsement for Angler Days based on logbook history during qualification years to be determined prior to and including 2005 (the control date year for the moratorium).

Option 8.1. Actual Angler Days averaged over a period of qualifying years

Option 8.2. Classes of Permits based on a tight range of Angler Days averaged over a
period of qualifying years: Example:
A Class 750 Angler Days or more
B Class 600 - 749 Angler Days
C Class 450 - 599 Angler Days
D Class 300 - 449 Angler Days
E Class 150- 299 Angler Days
F Class 61 - 149 Angler Days
G Class 60 or less Angler Days

Option 8.3. Placeholder for other options
Permits issued under the military hardship provision would receive an Angler Day endorsement to be determined.
Note: Military (Morale, Welfare, and Recreational) boats are not required to meet the qualification requirements of the program, but harvests still count against the Allocation.

Element 6. Annual permit renewal criteria
Option 6.1. Does not require renewal
Option 6.2. Must be renewed annually.
Option 6.3. Not renewable, if permit holder lets it expire
Option 6.4. Emergency medical exception

Program Management

Element 7. Angler Days, Initial issuance, leasing, transfers.
Provide for share-based assignment predicated on Angler Days.
Evidence of participation for determining Angler Day Endorsements is ADF&G saltwater
logbook entry with bottomfish statistical area, rods, or boat hours.
Initial issuance: Award number of Angler Day units from ADF&G logbooks that correspond to:
Suboption 1. Total Angler Days during best year during 1998-2005
Suboption 2. Average Angler Days during best 3 years from 1998 – 2005
Suboption 3. Placeholder for other options
Permit Transfers: Permits and endorsements may be transferred and may be stacked, up to use caps.
Endorsement Transfers:
Suboption 1. Angler Days not transferable
Suboption 2. Angler Days fully transferable:
1. Permanent: must go through NMFS (RAM division)
2. In-season transfers: allowed between charter businesses
Permit Leases (in-season only; reverts to permit holder at beginning of next season)
Suboption 1. leasing is allowed limited to use caps
Suboption 2. not allowed, except for “unavoidable circumstance”
Endorsement leases:
Suboption 1. Allow leasing, limited to Angler Day endorsement caps
Suboption 2. Allow unlimited leasing
Notes:
1. Permit endorsement of an angler day for every client fishing bottomfish/halibut in a day
2. "Unavoidable circumstances" will be adjudicated on a case-by-case basis through the National Marine Fisheries Appeals Division, but includes medical emergencies, military exemptions, and constructive losses.

Element 8. Use caps and grandfather rights. The AFA 10% ownership rule for affiliation will be applied to determine the number of permits associated with an entity under the use cap.
Option 1. 5 Permits
Option 2. Placeholder for other options
Option 3. Grandfather rights below the U.S ownership level shall expire upon any
change in ownership of the business. Grandfather rights above ownership and/or use caps shall pass to successors to the business, until and unless elements of the business, i.e., vessels, are sold or spun off from the business. Grandfathered businesses may not increase capacity above the grandfathered level, however in the event of restrictions, step-downs etc. a grandfathered business may acquire additional capacity up to but not exceeding the original grandfathered level.
Note from previous Council analysis: A business that owns/controls permits in excess of the use cap maintains the grandfather status for those permits that remain in its control after other permits are sold, but the sold permits lose the grandfather status in perpetuity. Grandfathered permits that are sold in total when a business owner sells his entire business/fleet maintain that grandfathered status. Grandfathered status refers to permits, not to vessels.

Element 9. Supplemental individual use of commercial IFQ
This element implements measures to allow Permit holders to purchase or lease commercial IFQ in order to provide anglers with additional opportunities, not to exceed regulations in place for unguided anglers.
Provisions:
A. Permit holders may purchase commercial QS or lease commercial IFQ for conversion to GAF.
B. Permit holders harvesting GAF while participating in the guided sport halibut fishery are exempt from landing and use restrictions associated with commercial IFQ fishery, but subject to the landing and use provisions detailed below.
C. GAF would be issued in numbers of fish. The conversion between annual IFQ and GAF would be based on average weight of halibut landed in each region’s charter halibut fishery (2C or 3A) during the previous year as determined by ADF&G.
D. Subleasing of GAF would be prohibited.
E. GAF holders may request NMFS convert unused GAF into IFQ pounds for harvest in
compliance with commercial fishing regulations provided the GAF holder qualifies under the commercial IFQ regulations.
F. Unused GAF may revert back to pounds of IFQ at the end of the year and be subject to the underage provisions applicable to their underlying commercial QS.
G. GAF derived from commercial QS may not be sold into commerce, i.e., all sport regulations remain in effect.
H. GAF derived from commercial QS may not be used to harvest fish in excess of the non-guided sport bag limit on any given day.
I. Charter operators landing GAF on private property (e.g. lodges) and motherships would be required to allow ADF&G samplers/enforcement personnel access to the point of landing.

Element 10. Limits on Holding Quota Share and IFQ
A. Commercial IFQ, when purchased or leased and converted to GAF for use in the guided halibut (charter) fishery shall not exceed the following limits in total holdings:
Option 1. An individual or entity holding a Limited Entry Permit or multiple Limited
Entry Permits may not hold or control more IFQ and/or GAF in excess of an amount equal to the current setline ownership cap in each area (Currently1% of the setline catch limit in 2C or approximately 4,000 fish and 1/2% in 3A or approximately 6,500 fish.)
Option 2. An individual or entity holding Limited Entry Permit or multiple Limited Entry
Permits in Area 2C or Area 3A may not hold or control more GAF than:
i. 1,000 fish
ii. 2,000 fish
iii, 5,000 fish
iv. 7,500 fish
B. Holding GAF on charter Limited Entry Permits:
Option 1. An individual or entity holding a Limited Entry Permit or multiple Limited
Entry Permits in Area 2C may not hold or control more GAF per Limited Entry Permit than:
i. 200 fish
ii. 300 fish
iii, 400 fish
Note: In Area 2C a charter vessel is restricted to a maximum of six lines, regardless of the size or type of the vessel, or how many passengers the vessel carries.
Option 2. An individual or entity holding a Limited Entry Permit or multiple Limited
Entry Permits in Area 3A and operating a "six-pack" charter vessel may not hold or control more GAF per permitted six-pack vessel than:
i. 200 fish
ii. 300 fish
iii, 400 fish
Option 3. An individual or entity holding a Limited Entry Permit or multiple Limited
Entry Permits in Area 3A and operating a "super six-pack" charter vessel may not hold or control more GAF per permitted super six-pack vessel than:
i. 200 fish
ii. 400 fish
iii, 600 fish
Option 4. An individual or entity holding a Limited Entry Permit or multiple Limited
Entry Permits in Area 3A and operating a USCG Subchapter T "certified" charter vessel may not hold or control more GAF per permitted certified vessel than provided for in the following formula:
L x B x DBL x d = GAF
40
Where: L = documented vessel length
B = documented vessel breadth
DBL = daily bag limit for halibut
d = a range of multiples to be analyzed and to be determined by the Council at Final
Action which would approximate the number days that a charter operator might reasonably be allowed to extend his season in Area 3A, or alternatively, a multiple to simply determine a reasonable number of GAF that a certified vessel may hold that would correlate to the number of GAF allowed for a six-pack vessel in previous options. Suggested multipliers might range from 5, 10, 15 or 20.
The portion of the formula L x B is intended to represent a nominal number of
passengers the vessel might fish comfortably, as opposed to the number of passengers that a vessel might be certified to carry. (A vessel that is also engaged in tours could be certified to carry many more passengers than it would normally be able to fish.)
Example: Documented vessel length 40.4 feet
Documented vessel breadth 13.2 feet
Using 10 as the selected multiplier d
40.4 x 13.2 = 13 passengers x 2 fish x 10 = 260 fish (Approximately 5,000 lbs of IFQ)
Note: A similar formula using vessel dimensions for USCG Subchapter T certified charter vessels might also be used to determine a conversion to Angler Days.
(NOTE: Paragraph C. below is the same as the Council Interim Solution motion except for the additional text in bold.)
C. Commercial Quota Share Holders:
i. Commercial QS holders may lease up to 10% of their annual IFQs for use as
GAF on an individual basis.
ii. Commercial fishermen who hold QS and a Limited Entry permit:
Option 1. May convert all or a portion of their commercial QS to GAF on a yearly basis if they own and fish it on their own Limited Entry permitted vessel(s). Commercial fishermen using their IFQ as GAF will be subject to the same caps, limits and restrictions on the use of IFQ for GAF as charter-only operators. Commercial and charter fishing may not be conducted from the same vessel during the same day.
Option 2. May lease up to 10% of their annual IFQs for use as GAF on an individual basis.
D. Catch accounting
a. The current Statewide Harvest Survey or logbook data would be used to determine the
annual harvest.
b. A catch accounting system* will need to be developed for the GAF fish landed in the
charter industry.
* NOTE: Monitoring and enforcement issue:
In 2003, NMFS contracted with Wostman and Associates to design a data collection program compatible with guided sport operations, yet robust enough to monitor a share-based management plan.
This system was based on logbooks and telephone or Internet call in and reporting numbers of fish.
This system was designed with the technology available to charter operators.

Element 11. Community provisions for Area 2C and 3A communities previously identified under GOA FMP Amendment 66
Placeholder for CQE provisions
Note: Previous Council text from Moratorium motion:
A Community Quota Entity (CQE), representing a community in which 10 or fewer active charter businesses terminated trips in the community in each of the years 2004 and 2005 may request Limited
Entry permits:
Area 2C – use cap of 4 requested permits per eligible community.
Area 3A – use cap of 7 requested permits per eligible community.
Overall use caps for all CQEs in a management area are 2 times those selected for the qualifying CQE requested permit use cap for each area. (Staff note: result is overall use cap of 8 permits for each CQE in Area 2C and 14 permits for each CQE in Area 3A).
Provisions for CQE requested permits:
• Designated for the area in which the community represented by the CQE is located.
• Endorsed for 6 clients.
• Not allowed to be sold (i.e., permanently transferred).
• Under reporting requirements, the CQE must identify the recipient of the permit prior to issuance.
• The requested CQE permit must be used in the community represented by the CQE (the trip must originate or terminate in the CQE community).

what a frickin mess

1. Thanks to ? (you know who you are) for putting our industry in this mess!
2. The GHL is an interim motion with no long term solution.
3. The moratorium has not been signed by Sec. of Commerce. Same as "ol IFQ" plan.
4. Is NPFMC interim motion going to be long term ghl/moratorium solution?
5. How can a moratorium that will allow growth keep us from ghl overages & facing major
repercussions. The GHL is Fixed! Why should there be growth allowed under
moratorium? As is you can do more trips, take more people, do more doubles
-all you need is a permit. What a joke! What about the GHL! knock knock! anybody home?
6. New charters want it all at long term charters expense. Will i need to lease fish to fish
the same number of clients as i have in the past 20 years?
7. Is there still a Stakeholders Committe? Why & When do they meet again?
8. 20 years as a charter, 15 years attending Council meetings, No Solututions, at who' expense?
Why?

What is your take on this?

Check out the revised halibut motion at the address below or click on the heading in the "related sites" list at right and let me know how we can survive in this business.


http://www.fakr.noaa.gov/npfmc/current_issues/halibut_issues/Halibutmotion1207_rev.pdf

Fish board hearing slated

Fish board hearing slated
Testimony to be taken in Soldotna on Jan. 30
With 286 proposals on the docket for the Board of Fisheries (BOF) Upper Cook Inlet meeting, user group representatives expect hundreds from all facets of fishing to descend upon Anchorage beginning Feb. 1. "A good couple-hundred people or better will testify," said Jim Marcotte, executive director for the Board of Fisheries. "By the end of public testimony (the BOF) will have heard all sides of most issues." Board members will take testimony from representatives of the area's advisory committees and members of the public at its Anchorage meeting from Feb. 1 to Feb. 12 before beginning their deliberations. But for those who can't devote their time to a 12 day-long meeting or who can't make it to Anchorage the BOF will send three of its members to afford the public an opportunity to voice their opinions and concerns at a public testimony at 3 p.m. Jan. 30 at the Soldotna Sports Center.
Some 227 of the 286 proposals concern guided fishing, sport fishing, subsistence fishing and commercial fishing here on the Kenai Peninsula, particularly the Kenai and Kasilof rivers.

Homer Charter Association Meeting Feb 13

Notice to all interested charters. The Homer Charter Association will hold a regular meeting on february 13, 2008 at 7:00pm in the Homer Chamber of Commerce Building.
Topics for discussion will be the ongoing development of the charter halibut management proposals and the new and exciting requirement of the Transportation Workers Identification Credential (TWIC) that we all must be in possession of by September 23, 2008. Meeting announcements have been mailed along with membership forms. Mail in your dues of $125.00 or bring them with you. See you there

December 2007 Council Action

Check it out @
http://www.fakr.noaa.gov/npfmc/current_issues/halibut_issues/Halibutmotion1207.pdf

Charter Halibut Motion from NPFMC Meeting

C-1 Charter Halibut Management


AP Revisions to Halibut Stakeholder Revisions to Staff-Recommended Revisions to
October 2007 Council Motion

Charter Halibut Interim Measures: Initial Allocation and Future Reallocation
between charter sector and commercial sector in Area 2C and Area 3A

Alternative 1. No Action.

Alternative 2. Establish a catch sharing plan that includes sector accountability

Element 1. Initial allocation

Option 1: Fixed percentage. of combined charter and commercial catch limit.

Area 2C Area 3A based on:
a. 13.1 13.09% 14.00% 125% of the 1995-1999 avg charter harvest (current GHL formula)
b. 17.3 17.31% 15.4 15.44% 125% of the 2001-2005 avg charter harvest (GHL formula updated thru 2005)
c. 11.7 11.69% 12.70% Current GHL as percent of 2004
d. 15.1 15.14% 12.7 12.65% 2005 charter harvest

Option 2: Fixed pounds. to be deducted from a combined charter and commercial catch limit

Area 2C Area 3A based on:
a. 1.43 Mlb 3.65 Mlb 125% of the 1995-1999 avg charter harvest (current GHL)
b. 1.69 Mlb 4.01 Mlb 125% of the 2000-2004 avg charter harvest (GHL updated thru 2004)
c. 1.90 Mlb 4.15 Mlb 125% of the 2001-2005 avg charter harvest (GHL updated thru 2005)
Option: Stair step up and down. The allocation in each area would be increased or reduced in stepwise increments based on a change in the total CEY. If the halibut stock were to increase or decrease from 15 to 24 percent from its average total CEY of the base period selected for the initial allocation at the time of final action, then the allocation would be increased or decreased by 15 percent. If the stock were to increase or decrease from at least 25 to 34 percent, then the allocation would be increased or decreased by an additional 10 percent. If the stock increased or decreased by at least 10 percent increments, the allocation would be increased or decreased by an additional 10 percent.

Deferred to Interagency Staff regarding pros and cons of setting formulas v pounds in regulation

Option 3. 50% fixed/50% floating allocation. of a combined charter and commercial catch limit.

Area 2C Area 3A
50% of: and 50% of: 50% of: and 50% of:

a. 13.1 13% 1.43Mlb 14.1 14% 3.65Mlb
b. 15.9 16% 1.69Mlb 15.4 15% 4.01Mlb
c. 17.3 17% 1.90Mlb 15.4 15% 4.15 4.14Mlb *
*error discovered in the AP minutes

Element 2. Annual regulatory cycle

The initial charter allocation would be a common harvest pool for all charter limited entry permit holders. It would not close the fishery when the charter allocation is exceeded. Instead, the allocation would be linked to an annual regulatory analysis of management measures (delayed feedback loop) that take into account the projected CEY for the following year and any overages by the charter industry in the past year(s). This system would work best if there is not a time lag between the overage year and the payback year. The Council will not revisit or readjust the sector split. An allocation overage would trigger the regulatory process automatically, in contrast with current GHL management. Any underages would accrue to the benefit of the halibut biomass and would not be reallocated or paid forward. The Council assumes (and would request) that the International Pacific Halibut Commission set a combined charter and commercial sector fishery catch limit CEY and would apply the allocations between the two sectors that would be recommended by the Council in a type of catch sharing plan to the combined fishery catch limit CEY.

Element 3. Management toolbox.

Tier 1 measures will be utilized by the Council to try to manage the charter common pool for a season of historic length and a two-fish daily harvest limit. Tier 2 measures will be utilized if Tier 1 measures are inadequate to constrain harvest by the charter common pool to its allocation. Due to the delayed feedback loop in implementation of management measures, management measures will, in general, be more restrictive to ensure that the charter sector allocation is not exceeded. In providing predictability and stability for the charter sector, it is likely that charter fish may be left in the water.

Tier 1 management measures include:
• 1 trip per vessel per day
• No retention by skipper or crew
• line limits
• Second fish of minimum size
• Second fish at or below a specific length.

Tier 2 management measures include:
• Annual catch limits
• 1 fish bag limit for all or a portion of the season
• Season closure
Suboption: seasonal closures on a monthly or sub-seasonal basis

Element 4. Timeline. The current timeline for the proposal is as described below. [Staff should discuss what would be needed to implement February Council action for June (the same year)]

Example scenario 1: 4–year feedback loop
• Charter fishery ends 2007
• October 2008: Council receives ADF&G report on final charter halibut harvest estimates for 2007. If the ADF&G report indicates that an allocation overage occurred in 2007, the Council will initiate the analysis of management measures necessary to restrict charter halibut harvests to its allocations.
• December 2008: Council reviews staff analysis (possibly in the form of a supplement) that updates the previous year’s analysis with final 2007 harvest estimates.
• January 2009: IPHC adopts combined catch limits for 2009.
• February 2009: Council takes final action on management measures that would be implemented in year 2010.
• Winter 2009: NMFS publishes the rule that will be in effect for 2010.

Example Scenario 2: 3–year feedback loop (Staff response to Council request)
• Charter fishery, with in-season monitoring, ends 2007
• October 2007: Council receives ADF&G report on final charter halibut harvest estimates for 2007. If the ADF&G report indicates that an allocation overage occurred in 2007, the Council will initiate the analysis of management measures necessary to restrict charter halibut harvests to its allocations.
• December 2007: Council reviews staff analysis (possibly in the form of a supplement) that updates the previous year’s analysis with final 2007 harvest estimates.
• January 2008: IPHC adopts combined catch limits for 2008.
• February 2008: Council takes final action on management measures that would be implemented in year 2009
• Winter 2008: NMFS publishes the rule that will be in effect for 2009

Element 5. Supplemental individual use of commercial IFQ to allow limited entry permit holders to lease commercial IFQ in order to provide anglers with additional harvesting opportunities, not to exceed limits in place for unguided anglers

A. Leasing commercial IFQ for conversion to Guided Angler Fish (GAF).
1. A LEP (Limited Entry Permit) holder may lease IFQ for conversion to GAF for use on the LEP.
2. Commercial halibut QS holders may lease up to 1500 pounds or 10% (whichever is greater) of their annual IFQ to LEP holders (including themselves) for use as GAF on LEPs. A CQE may lease up to 100% of its annual IFQ for use as GAF on their own LEPs. Commercial halibut QS holders may lease up to 10% of their annual IFQs to LEP holders for use as GAF on LEP. Dual permit holders are constrained to leasing only 10% of their QS whether to themselves or someone else
3. LEP holder per vessel may not lease more than 200-400 fish.
Suboption: vessels with LEP w/endorsement for more than 6 clients may not lease more than 400-600 fish.
4. Commercial Halibut QS holders who also hold an LEP may convert all or a portion of their commercial QS to GAF on a yearly basis if they own and fish it on their own LEP vessel.
Suboption: allow commercial QS holders that holds 500 lb. to 1000 lbs. to lease up to 50 to 100% of their IFQs to the charter sector.
B. LEP holders harvesting GAF while participating in the guided sport halibut fishery are exempt from landing and use restrictions associated with commercial IFQ fishery, but subject to the landing and use provisions detailed below.
C. GAF would be issued in numbers of fish. The conversion between annual IFQ and GAF would be based on average weight of halibut landed in each region’s charter halibut fishery (2C or 3A) during the previous year as determined by ADF&G. The long-term plan may require further conversion to some other form (e.g., angler days).
D. Subleasing of GAF would be prohibited.
E. GAF holders may request NMFS convert unused GAF into IFQ pounds for harvest in compliance with commercial fishing regulations provided the GAF holder qualifies under the commercial IFQ regulations.
F. Conversion of GAF back to commercial sector
1. GAF holders may request NMFS convert unused GAF into IFQ pounds for harvest in compliance with commercial fishing regulations provided the GAF holder qualifies under the commercial IFQ regulations.
2. Unused GAF may revert back to pounds of IFQ at the end of the year and be subject to the underage provisions applicable to their underlying commercial QS.
G. Guided angler fish derived from commercial QS may not be used to harvest fish in excess of the non-guided sport bag limit on any given day.
H. Charter operators landing GAF on private property (e.g., lodges) and motherships would be required to allow ADF&G samplers/enforcement personnel access to the point of landing.
I. Commercial and charter fishing may not be conducted from the same vessel on the same day.

Element 6. Catch accounting system
1. The current Statewide Harvest Survey and/or logbook data would be used to determine the annual harvest.
2. A catch accounting system will need to be developed for the GAF fish landed in the charter industry.
3. As part of data collection, recommends require the collection of length measurements when supplemental IFQs are leased for use and compare to the annual average length to make sure that accurate removable poundage is accounted for and to allow length measurement information gathered to be used in the formulation of the average weight used in the conversion of IFQs to GAF.


Problem Statement: The absence of a hard allocation between the longline and the charter halibut sectors has resulted in conflicts between sectors and tensions in coastal communities dependent on the halibut resource. Unless a mechanism for transfer between sectors is established, the existing environment of instability and conflict will continue. The Council seeks to address this instability while balancing the needs of all who depend on the halibut resource for food, sport, or livelihood.


In establishing this catch sharing plan for the commercial and sport charter halibut sectors, the Council intends to create a management regime that provides separate accountability for each sector. The management of the commercial sector remains unchanged under the plan, and new management measures are provided for the sport charter sector.

These new measures for the sport charter sector are designed to address the specific need of the sport charter sector for advance notice and predictability with respect to the management tools and length of season that will be used to achieve the allocation allotted to that sector under the plan. In order to achieve the allocation, it is the Council’s intent that management tools and season length would be established during the year prior to the year in which they would take effect, an d that the tools selected and season length would not be changed in season.

The Council will evaluate its success in achieving the sport charter sector allocation each year, and will adjust its management tools as needed. In designing this regime for the sport charter sector the Council recognizes that providing advance notice and predictability may result in a charter harvest that does not precisely meet the sector allocation for that particular year. Therefore, the Council intends to adjust its management measures as needed to ensure that the sport charter sector is held at or below its allocation on average over a rolling five-year period. In meeting its conservation mandate while accommodating the charter industry’s need for predictability and stability, the Council will necessarily err on the side of conservation in the selection of management tools and season length, with the result that the sport charter sector may not be able to harvest its entire allocation.

One of the critical issues for successful implementation of a successful interim management regime for charter halibut operators is to shorten the feedback loop for collection of data regarding charter harvests. The Council has requested that staff include in their report a discussion of options for shortening the feedback loop, and the Stakeholder Committee would like to suggest three options for discussion and analysis in the staff report.
Any data collection option should be made as simple as possible, minimize inconvenience to clients, and be conducted in a machine readable or electronic format.

It is also the intent of the Stakeholder Committee in proposing these options that the real time collection of data should not be used for in-season management changes or in-season closures; rather it is the intent of the Stakeholder Committee that these options be used to shorten the data collection feedback loop to facilitate the timely advance adoption of management tools designed to achieve the charter sector allocation without in-season changes or in-season closures in order to maintain, to the extent possible, a season of historic length with a minimum two fish bag limit.
Option 1. Electronic Reporting. Each GSM permit holder would be assigned a unique reporting number and would use that number to electronically report the number of halibut caught by clients that day on a daily basis. The electronic reporting would be done either through an Internet website or a dial-in telephone system. As additional verification each client would sign the mandatory logbook next to the entry containing their name, license number, number and type of fish caught, and any other required information. Logbooks would continue to be submitted weekly.
Option 2. Harvest Tag. Uniquely numbered harvest tags would be distributed to each GSM permit holder at the beginning of the season and additional tags would be available throughout the season if needed. The number of harvest tags would be greater than the number of fish allocated to the charter sector for that year (i.e., the tags are not a management tool for restricting or closing charter fishing in-season). When a halibut is landed the harvest tag would be required to be inserted in the jaw and the harvest tag number recorded in the log book entry for the angler license number of the person who caught the fish. When the fish is processed the tag would be removed and mailed in using pre-addressed, stamped envelopes supplied for that purpose. GSM operators would pay a fee to cover the cost of the envelopes and tags. Harvest tags would preferably be bar coded to enable machine reading, with peel off bar code stickers for placement in the log book.
Option 3. Punch Cards. Each GSM permit holder would be issued a supply of uniquely numbered punch cards with punch outs equal to any daily bag limit for that year or six halibut (whichever is fewer). The cards would issued at the beginning of the season and additional cards would be available as needed (i.e., the cards are not a management tool for restricting or closing charter fishing in-season). Each day every client angler would be assigned a punch card and that punch card number would be entered in the log book next to the license number. As each halibut is landed by a client their respective card would be punched, and at the end of the day the client would sign the punch card in the space provided. The punch card would then be sealed in a supplied stamped and addressed envelope, which would be mailed by the permit holder. GSM permit holders would pay a fee to cover the cost of the punch cards and mailing envelopes. Any log book entry for which a signed punch card is not received would be corrected to read the maximum number of fish printed on a punch card (i.e., the daily bag limit or six fish).