Letters
This page is reserved for posting letters that our membership and interested parties may want to consider using to provide their input on the topic(s) covered in the suggested letter.
TODAY, as we sail to fish, a strong movement is under way to erode your opportunity to enjoy halibut fishing in Alaska. This effort is a continuing push by the commercial halibut fishing industry to restrict your access and catch, if you fish from a charter boat. Please bear in mind as you read this article, that YOU OWN THE HALIBUT RESOURCE. It is a federally owned fish that we all have equal right to. However, your rights are being methodically stripped from you by the commercial fishing industry.
Today, the recreational harvest constitutes less than a mere 10% of all of the halibut harvested each year. The commercial fishing industry takes 90% of all halibut harvested annually, and they want to ensure that your harvest is restricted even further by implementing a one fish daily bag limit, cutting our daily limit in half from the current two fish limit.
The commercial effort started in 1995, when the federal government gave selected commercial fishermen permits to harvest your halibut year after year, and authorized the commercial fishermen to sell their permits without any compensation to the public, who owns the resource. This resource handout has a current value approaching $1.5 billion.
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The issuance of fishing rights permits is known as Individual Fishing Quota (IFQ) program for the commercial fishermen. This action changed the whole dynamic of the commercial- recreational fishing relationship.
Prior to the IFQ program, all recreational anglers were treated equally, and the recreational fish “came off the top”. Recreational fishermen are recognized as having a higher priority to the resource over commercial fishermen. Unfortunately, this has been allowed to change.
In Alaska, harvest of the halibut resource is allocated by the North Pacific Fishery Management Council (Council, or NPFMC). The Council makeup is such that there was and remains support to segregate the recreational fishermen into two classes, those that are unguided, and those that are guided (fish from charter boats).
The intent of this action was to divide the recreational sector into a predominately “Alaska resident” angler, who could in fact provide their own access, and a non-resident class that had to rely on a charter fleet to provide safe access. It was believed by the commercial fleet that non-resident angler demand may increase at a faster rate than the resident angler, and consequently from the commercial fisherman’s perspective, the guided recreational angler must be limited and controlled in order to ensure the maximum amount of fish being available for the commercial harvest.
This action set up the potential for divisive community relationships by the commercial fishermen and the local residents asserting that the non-residents were taking “their fish” and that the charter operator was a common enemy. This apparent assertion challenges the intent of the Halibut Act of 1982.
The Halibut Act, a Federal law, directs that fishing privileges “shall not discriminate between residents of different States”.
With the recreational sector split, the commercial fishermen focused their energy on limiting the harvest of the guided recreational fishermen. This led to the implementation of the Guideline Harvest Limit (GHL), which was set forth in regulation, with no enforcement provisions for exceeding the GHL. The regulation directed the Secretary of Commerce to inform the Council when the GHL was exceeded, but was silent on any restrictive measures that would apply.
The GHL, since it was an advisory number only, had no provision for the number to increase, but it could decrease with a reduction of fish abundance as measured by the International Pacific Halibut Commission’s (IPHC) “Constant Exploitable Yield” (CEY) assessment.
The IPHC is an International commission established by Treaty with Canada in 1923 for the sole purpose of ensuring the halibut resource is protected from over fishing. At the time the GHL was established, the Constant Exploitable Yield (CEY) was calculated using the “Closed Area Assessment Model”.
The GHL in halibut harvest Area 2C, (southeast Alaska) was set too low by the NPFMC to accommodate the recreational angler demand for fishing. The GHL was being exceeded from the day it was implemented, and continues to be exceeded today. It is simply an unrealistically low number.
The commercial fishermen insisted that the GHL number should be treated as a hard allocation, when in fact it is not. They asserted that exceedence of the GHL was a de facto reallocation of commercial fish to the recreational sector. They got the IPHC to thinking that it was important that the GHL not be exceeded, even though it was an advisory number only. The IPHC believed that they needed to control the guided recreational harvest, not because it was a conservation issue, but because the commercial fishermen viewed this as a way of reducing and controlling the halibut harvest by the guided recreational angler. The IPHC is controlled by the commercial fishing industry.
In 2007, the IPHC proposed to reduce the daily bag limit to one fish in both halibut harvest areas Area 2C (southeast Alaska) and Area 3A (southcentral Alaska) for a prescribed period of the fishing season. The proposed action was taken as an allocation measure, which the IPHC is not supposed to do. Allocation of fishing privileges rests with the NPFMC.
The recreational fishing public took exception with the IPHC’s action, and protested vigorously to the Secretaries of State and Commerce, who have veto authority over the IPHC. The Secretaries concurred, and refused to approve the IPHC’s recommended one fish limit.
The National Marine Fisheries Service, in its effort to appease the commercial fishermen, implemented what is known as the “minnow rule” that applies to a recreational angler who uses a guide service in southeast Alaska. This action appears to be discriminatory in that for the first time in history, halibut recreational anglers are being treated differently based on their choice of means for accessing their resource.
If you, as a recreational angler, fish from a guided charter boat, you may retain two fish, one can be of any size, the second fish kept must be less than 32” if you are fishing in southeast Alaska.
This is in contrast to another recreational angler who is not guided and has no restriction on the size of fish he can retain. The limit is two of any size. This appears to challenge the Halibut Act’s intent of “shall not discriminate between residents of different States”.
The Secretary’s action of refusing to approve the IPHC’s attempt to reduce the bag limit was not taken lightly by the commercial fishermen, or the IPHC. In June of 2007, the Council (which is totally dominated by commercial fishermen) passed a motion to reduce the bag limit to one fish, and a four fish annual limit, if the CEY as calculated by the IPHC dropped below 9.2 million pounds.
The IPHC was in the process of changing its model from the Closed Area Assessment Model to a new Coastwide Model, which changes the way the Commission determines the CEY. Using the Closed Area Assessment, it was determined that the CEY would be 9.8 million pounds, which was greater than the trigger point of 9.2 million pounds that would lead to reduction in bag limits.
But, if the new assessment was used, a CEY of 6.51 million pounds could be derived, which would trigger recommending the bag limit reduction. And so the new assessment was implemented to ensure forcing the guided recreational angler to a one fish limit in southeast Alaska. This is a very serious case of changing the way to measure the amount of fish to achieve a very pointed purpose- reducing the bag limit to one fish, not as a conservation measure, but simply as a means to ensure stopping the recreational fisherman from seeking their public resource, because it becomes a very expensive venture when the bag limit is one fish per day.
On May 22nd the Secretary approved the one fish limit for southeast Alaska. If we don’t act, it will only be a matter of time before the same will apply here. We are launching a legal action to block implementation on based on several legal challenges.
This concerted effort to strip you of your fishing rights will continue, unless you along with all other recreational fishermen who value their freedom to fish for halibut, protest this blatant power play by the commercial fishermen.
Please take the time to write to any, or all of the following voicing your protest to the unfair treatment that you receive as a guided recreational angler. Loss of your rights, freedom and being a subject of discrimination needs to be stopped. Emails and faxes are the best forum to use. Mailed letters will be quarantined, and will take forever to see the light of day.
Mr. Doug Mecum
Administrator of the Alaska Region
National Marine Fisheries Service
PO Box 21668
Juneau, Ak. 99802-1168
Email-doug.mecum@noaa.gov
Governor Sarah Palin
PO Box 1110001
Juneau AK 99811-0001
Fax 907-465-8110
Email-sarah.palin@alaska.gov
Senator Ted Stevens
522 Hart Senate Office Bldg
Washington, DC 20510
(202) 224-3004, fax(202) 224-2345
Email-www.stevens.senate.gov/contact_fm.cfm
Senator Lisa Murkowski
709 Hart Senate Office Bldg
Washington, DC 20510
(202) 224-6665, fax:(202) 224-5301
Email-www.murkowski.senate.gov/contact.html
Congressman Don Young
2111 Rayburn HOB
Washington, DC 20515
(202) 225-5765; fax: (202) 224-5301
Email-www.house.gov/donyoung
Carlos Gutierrez, US Secretary of Commerce
14th & Constitution NW, Room 5516
Washington, DC 20230
Email-cgutierrez@doc.gov
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