Here's an interesting bit of news from the Alaska Charter Association regarding the 37 inch maximum size limit that the IPHC is proposing for SE Alaska. I've always believed that the NPFMC and the IPHC are like the fox guarding the henhouse and this another prime example. Two councils dominated by commercial fishing interests that set the halibut allocations for both the commercial and recreational sectors. I wonder which way they're going to lean
Here's the latest intel.
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IPHC Does a Go Around to Set US Domestic Regulations
Juneau, Alaska - February 18, 2011
The International Pacific Halibut Commission (IPHC) is the governing body that establishes the total allowable catch (TAC) for Pacific halibut in each management area in the United States and Canada. Once the TAC is established each year, it should remain that each perspective country assign harvest privileges amongst the various user groups domestically, not the IPHC. This year the IPHC is demanding a maximum size limit of 37 inches for the already reduced bag limit of one halibut per day for charter clients in Southeast Alaska. All it takes is the Secretary of State and Secretary of Commerce to sign off on the recommendation and it will become law.
This action would circumvent the US regulatory process provided to the citizens of the United States through the US Administrative Procedure Act (APA). This Act requires that all proposed regulations go through a process of analysis, economic impact review, and an opportunity for public comment. Up to now, halibut regulations went through this process at the North Pacific Fishery Management Council (NPFMC), whose responsibility is to manage Alaska's federal fisheries. Because the IPHC is an international body, it does not have to conform to the requirements of the APA. This action will be unprecedented and conflicts with the treaty setting up the IPHC. Three of the six commissioners of the IPHC are from Canada. Do we want a foreign country, the Canadians in this case, dictating how we manage our resource? Will the IPHC set bag limits next in Southcentral Alaska, if halibut harvested by charter anglers there exceeds their allocation due to the influx of anglers fleeing the extreme restrictions in Southeast Alaska?
The National Marine Fisheries Service (NMFS) may attempt to implement this regulation for the IPHC, claiming the 37 inch size restriction was already analyzed in the Catch Sharing Plan (CSP) that went through the NPFMC in 2008, thus meeting the APA requirements. The truth is the adopted CSP did not go through proper analysis. The adopted CSP had little similarity to the original CSP options that went out for public comment. Neither NMFS nor the NPFMC have solicited public comment on the CSP finally recommended by the NPFMC. The 37 inch size restriction has not received an in-depth economic analysis. In fact, a recent analysis done by the Alaska Department of Fish and Game showed a 37" halibut size limit for Southeast Alaska, given the same guided angler demand as in 2010, would result in a harvest 171,000 pounds under the GHL. If allowed to happen, this would result in millions of dollars of lost revenue to local communities!
IPHC Executive Director Bruce Leaman, in a email correspondence recently stated that the IPHC 37 inch recommendation is in response to, "...the chronic overruns of the charter GHL (Guideline Harvest Level) in this area (Southeast Alaska) and consequent effect on the Commission's achievement of its harvest goals". In a paper by Dr. Steven Hare of the IPHC, entitled "Potential Modifications to the IPHC Harvest Policy," Dr. Hare concludes that the IPHC's "Slow Up, Fast Down" (SUFD) policy, which is more accurately described as "slow up, half down" because SUFD results in commercial fishermen taking only half of the recommended reduction in their allocation for any given year, combined with additional halibut added to the commercial quota by the IPHC, has resulted in the less than 2,000 commercial IFQ holders exceeding the IPHC's target harvest level by 9.99 million pounds in Southeast Alaska in the last four years alone. In contrast, the "chronic overruns" by several hundred thousand anglers fishing in Southeast Alaska in those same four years amounted to only 2.93 million pounds -- less than 1/3 as much. The IPHC finally admitted the adverse SUFD impact in January 2011 and changed the SUFD policy to "Slow Up, Full Down."
Another analysis by Dr. Hare, provided in the IPHC's stock assessment for 2010, shows that the IPHC's older closed area stock assessment model, which was used through 2007, resulted in an over allocation by the IPHC to the commercial IFQ holders in Southeast Alaska of nearly 60 million pounds of halibut. This amount dwarfs the 4 million pound total "overrun" by charter anglers in Southeast Alaska since a guideline harvest level was set in 2003. We need to get things into perspective. Why take such punitive measures on the charter anglers this year, after allowing a 60 million pound over harvest by the commercial fleet?
This 37 inch size restriction for Southeast Alaska charter businesses will be the final nail in the coffin on an important contributor to the State's 1.4 billion dollar tourism industry. Southeast guided anglers, who have become educated to the value they receive for their travel dollar in today's economy, will quickly go elsewhere to fish or decide not to come at all. This is not the time for punitive actions, especially when the IPHC is not concerned about the conservation of halibut stocks.
The Alaska Charter Association and the Southeast Alaska Guides Organization plan on submitting to the NPFMC this fall a long term solution to the allocation battle between the charter and commercial sectors. We need time to bring forth this solution. Help stop this draconian measure from being implemented. Write to Secretary of State Hillary Rodham Clinton and Secretary of Commerce Gary Locke, today. We have only days to act!
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