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Viewpoints: Letters / Opinions

Misinformation about halibut catch sharing plan

By Tom Gemmell


July 27, 2013

There has been a lot of misinformation going around about the halibut catch sharing plan (CSP).  In an effort to correct this the Halibut Coalition prepared a commentary on Mr Medred's article in the Alaska Dispatch published on July 20 and other online publications. 

Let’s look at some of the claims made by Mr. Medred in the context of the 313 page analysis ( ) accompanying the June 28 proposed rule to establish the catch sharing plan (CSP). This document contains information the Council used in arriving at its decision on allocation and how to manage the charter fleet in a sustainable manner.

CLAIM 1. The 2012 catch sharing plan would limit Alaska charter anglers to a single fish.

FACT. The existing 2003 Guideline Harvest Level artificially tied the charter allocation to the average 1999-2000 abundance while the commercial sector was tied to the current level of abundance. It is the Council’s intent that both sectors be tied to the current level of abundance, that both sectors share the allowable harvest on a percentage basis, and that both sector’s allocation float with abundance.

For Area 3A (North Gulf) the charter allocation, under the GHL program from 2008-2012 was down only 15%, while the biomass was down 32% and commercial catches have dropped 46%. The biomass is at a cyclic low and it is not reasonable that the charter sector should not share in the conservation burden with the commercial sector when stocks are down.

Again for Area 3A, the 2012 preliminary charter harvest was 2.4 million pounds; the GHL was 3.1 million pounds. Using the CSP to hind cast, the charter allocation would have been 2.3 million pounds -- a difference of 100,000 pounds less than actual harvest. Would this have triggered a one fish bag limit in Area 3A under the CSP? No!

Under the annual management process, the Council, after consultation with the charter sector and consideration of ADFG harvest projections, would more likely have allowed two fish, with the 2nd fish of possibly reduced size. Or, they could have used a “reverse slot limit” to control the harvest. In Area 2C (Southeast) the “reverse slot” limit is being used to allow the possibility of a trophy size fish while keeping the harvest within allocation.

CLAIM 2. State fisheries managers have said the plan is certain to reduce the limit for charter anglers from two fish per day to one next summer.

FACT. Mr. Medred fails to support this statement as anything but conjecture. Which state official said this and what was their rationale? Key information is not yet available to make this determination.

First, the projected 2014 charter harvest (without management measures) is not available. ADFG will not have the preliminary information on 2013 harvest –number of fish and average weights - until November. This preliminary data is considered in conjunction with final harvest numbers from 2012 and earlier to project ahead for 2014.

Second, the International Pacific Halibut Commission (IPHC) has not even made preliminary harvest recommendations for 2014. Although stocks are at a cyclic low, the IPHC needs to consider a whole raft of information being collected during their surveys and catch per unit of effort data from the commercial sector. IPHC staff recommendations won’ even be public until December 4-5 and the Commissioners won’t make a decision until January 17.

CLAIM 3. One-fish-per-day limits devastated charter businesses in Southeast Alaska.

FACT. Of the six plaintiffs in 2009 who filed suit to block a one fish bag limit in Area 2C, at least five are still in business. One of the plaintiffs has expanded his business since 2009. The one who no longer has a business license still has a charter halibut permit and may have been affected by other factors—anyone remember a recent recession?

For 2011 in Southeast (includes Yakutat), ADFG (2012) reported that charters had 111,120 saltwater angler days and caught 39,100 large Chinook, 1,247 small Chinook, 171,660 coho, 996 sockeye, 68,005 other salmon, 51,794 halibut, 5,381 lingcod, 113,176 rockfish, and 5,127 sablefish. Of the total 461,667 fish caught (i.e. angler experiences), 11% were halibut. Given these numbers, it appears Southeast charters are promoting an experience that includes more than just halibut.

Independent of a one-fish-per-day limit, small businesses, unfortunately, are prone to failure. A June 5, 2013 Business Insider article reported that generally 50 to 70 percent fail within the first 18 months. I don’t think either charter or commercial are immune from this reality. Read more.

CLAIM 4. The sport catch (presumably Area 3A) has remained generally stable near a guideline harvest level of in the range of 3 million pounds.

FACT. In Area 3A, the charter harvest peaked at 4.002 million pounds in 2007 (pre-recession) when the GHL was 3.65 million pounds and through 2012 has declined 41%. The charter harvest declined to 2.793 million pounds in 2011 (final number) when the GHL was 3.65 million pounds. The preliminary harvest estimate for 2012 showed further declines to 2.735 million pounds when the GHL was 3.103 million pounds. The decreased GHL for 2012 was the first decrease in GHL since 2003 – a period of time when overall biomass declined significantly

CLAIM 5. The 17.5 percent limit on the sport charter harvest (In Area 3A under the CSP) would force the reduction in the limit to one fish.

FACT. At low abundance (<10 million pounds combined commercial/charter catch limit) the charter percentage increases to 18.9% to accommodate charter concerns. At this level of abundance the Council has decided the commercial sector will bear a greater conservation burden.

If management measures are needed in the future in Area 3A, it will be because of lower abundance not the percentage allocations at various stock levels.

Table 2-45 of CSP the analysis, shows that compared to the GHL, the CSP poundage would only have been lower by 0.7% to 15.9% from 2008-2012 in Area 3A. Contrast this to a 46% reduction in commercial quota in the same period.

See CLAIM 2 above.

CLAIM 6. Pay more for a 2nd fish.

FACT. The guided angler fish is optional and is designed as a mechanism so that if charter demand ever exceeds their quota, there is a mechanism for compensated reallocation. In it worth noting that several charter associations are developing proposals to collect fees from charter clients and then use the funds to purchase quota share from the commercial sector to establish a “common pool” to augment the normal charter allocation. See CATCH website at . Over the years, some charter proponents have said a charter caught fish is more valuable to the economy than a commercial fish – guided angler fish provides an opportunity to see if this works in a real market.

Claim 7. Buy fish that was given to commercial sector.

FACT. Fish management 101: resources go to current commercial users based on historical catch. No one gets anything for free. Both commercial fishermen and charter operators were allowed access to the fishery based on years of blood, sweat, and labor. The Council heard the charter sector's demands for a two fish minimum, guarantee of year round season, no in-season management changes, and saw an opportunity to meet some of their "needs" with the guided angler fish option.

Tom Gemmell
Executive Director
Halibut Coalition
Juneau, Alaska

Received July 25, 2013 - Published July 27, 2013


Medred article:

NMFS Press Release on Comment Extension:

Draft Analysis for Secretarial Review!documentDetail;D=NOAA-NMFS-2011-0180-0003



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