Monday, February 5, 2018


From Our Friends at NACO:

"We ask that you fax a request yourselves asking to have the House version match the Senate version so that we can do away with this unnecessary burden."

NACO's Letter to Coast Guard 


"The 2010 Coast Guard Authorization Act included a new requirement for USCG Inspected Passenger carrying vessels to provide and keep onboard new logbooks to include a dozen types of entries from maintaining crew working hours to providing injury and damage reports. These logbooks were intended for vessels on an international voyage and travel from an Atlantic to Pacific port but the language was applied to all USCG COI Passenger vessels. The 2010 requirement created an unnecessary and burdensome regulation for small family business operations and the USCG has yet to implement rulemaking on the 2010 Act."

Wednesday, January 31, 2018

Deadlocked: IPHC Fails to Agree on Halibut Catch Limits for 2018

"Worst Meeting Ever," says Commission Chair

ACA Board members Richard Yamada and Mike Flores have been in Portland, Oregon all week working at the International Pacific Halibut Commission's annual meeting.

There is a great deal of scientific concern abut the recruitment of juvenile fish into the Pacific Halibut stock. The Science team at the IPHC recommended significant reductions in harvest levels coast-wide. 

The Commission is made up with 3 Canadian representatives along with 3 Americans. There are several advisory boards including one from the processor industry and another from the directed fisheries called the Conference Board. 

Serious Conservation Concerns

Although fishermen are seeing good fishing now, the IPHC's stock surveys show that there is a serious decline in new year-classes of fish. Too much fishing at this point could dig a deep hole and risk "eating the seed corn." 

The Canadians resisted significant reductions despite the serious conservation concerns. They disagreed with the way the IPHC "apportions" or allocates fish between countries and regions. 

Six major commercial and recreational fishing associations, including the ACA, recommended taking the advice of the scientists and biting the bullet before it bites us. The Conference Board majority adopted recommended measures that are predicted to have a 93% chance of even lower stock levels next year. Canada sought catch levels for its fishermen that have a 99% chance of lower levels next year.

Sean McManus, of the Deep Sea Fishermens Union, warned against too much fishing pressure. "The fishermen who support higher levels of fishing than recommended aren't going to be around to take responsibility when the stock collapses. They won't blame themselves, they'll blame you" (the Commission.)


On the last day of the session, the Commission was unable to reach an agreement on the catch limits. When no agreement is reached, the regulations revert to the status quo of last year's regulations. That would cause grave risk to the overall resource, as many fishermen testified in public comment. 

The US agreed to take a reduction that would go halfway down to the science recommendations (which used to be called "The Blue Line.") Emotions were strained and Commissioners seemed near a breaking point on Friday. Canadian Commissioner Ryall made an emotional appeal to increase British Columbia's share of the overall allocation.

If the regulations are not approved by March 24th, according to NMFS Staffer Rachel Baker, the Secretary of Commerce can publish the US-suggested catch limits in the federal register as long as they are lower limits than the status quo (2017) regulations.

US Side Approves US Catch Limits

The Commissioners did set "suggested" catch limits for the charter sector in areas 2C and 3A. Assuming catch limits of 810,000 pounds for 2C and 1.79 million pounds for 3A, the regulations for 2018 would be as follows: 


2C: Reverse slot limit, U38-O80, and a one fish daily bag limit with no annual limit.

3A: One fish any size, second fish 28 inches or less. Four fish annual limit. Vessel and permit trip limits. Closed all Wednesdays, Tuesdays closed July 10 - August 14.

The Commissioners agreed to have a conference call in February. Hopefully they can put a stamp on an agreement. 

Terms of US Commissioners end March 31st. The Trump Administration is expected to make appointments before then. Nominations for the US seats on the Commission are being accepted now.


International Pacific Halibut Commission in Session

Wednesday, November 29, 2017

IPHC Reveals Need for Drastic Cuts in 2018 Catch Limits

The IPHC (International Pacific Halibut Commission) held its Interim meeting in Seattle, where the 2018 Reference Catch Table was released. It was based on an average past harvest SPR (Spawning Potential Ratio) of 46%. Simply put, this means we would have a fishing intensity to leave a potential of 46% of the females left in the fishable stock available to contribute to future stocks. In 2017, while the Commission aimed at 45%, the end result was closer to 38%. With this reference harvest rate (in the past this was known as the Blue Line), Area 3A charter allocation under the CSP (Catch Sharing Plan) is 1.7 Mlbs. a reduction of 10% from last year and Area 2C is .69 Mlbs. a 25% drop from last year.

What does this mean for charter regulations for 2018? For Area 3A, harvest measures would need to be more restrictive to reduce harvest by 18.6% (this includes accounting for an overharvest of allocation from last year). This might mean closing more days of fishing, decreasing annual limits, or moving to a one fish daily bag limit including these restrictions. For Area 2C, a reduction of 25% in allocation from last year might mean reducing the lower slot to 35” with an annual limit of three fish or 40” with an annual limit of two. The Charter Management Implementation Committee (CMIC) will meet December 4th in Anchorage to make their recommendation to the North Council.

Why such a drastic reduction in catch limits? Ian Stewart, lead scientist for the IPHC, explained while the current stock abundance has been stable as well as catch effort (a metric used to measure stock abundance), the number of fish being caught per unit of effort has sharply declined. He explained this indicates we are currently fishing on larger and older fish from a past large recruitment year class. The fish following this year class are smaller and fewer and thus the reason for a declining future outlook of halibut abundance. Of course the Commissioners at their January meeting will need to decide the level of harvest and risk they want to take for 2018. They may decide to take a position below or above the SPR of 46%. The CMIC will have to give recommendations for each of these potential outcomes as well.

Friday, October 20, 2017

ADF&G Informational Handout for Charter Management Implementation Committee October 10, 2017

Mixing of Guided and Unguided Halibut Final Council motion

The Council recommends releasing the analysis for public review after making the following revisions to the purpose and need, alternatives, and analysis. The preliminary preferred alternative is shown in bold.

Purpose and Need

Different regulations apply to guided and unguided (i.e., chartered and non-chartered) halibut fishing trips. Possessing halibut harvested from both guided and unguided trips on the same fishing vessel at the same time presents challenges for accountability and enforcement that cannot be adequately addressed by current regulations. Mixed guided and unguided halibut can occur on multi-day fishing vessels and mothership charter fishing and floating lodges, and to a lesser extent on fishing vessels that are owned by self-guided fishing operations that also provide sport fishing guide services to their clients. The potential for mixing guided and unguided halibut exists on every fishing vessel floating lodge and mothership that services halibut harvesters. The number of these operations and the associated halibut harvests remain unknown. The mixing of guided and unguided halibut could expand in the future as charter operators look for ways to maximize halibut harvests for guided and unguided anglers on their fishing vessels.
Once guided and unguided halibut are mixed aboard a fishing vessel, it is difficult to determine which halibut were harvested under the guided regulations and which halibut were harvested under the unguided regulations. The current regulatory structure allows guided and unguided halibut to be mixed on a fishing vessel but does not provide the regulated public or authorized officers with a mechanism to ensure compliance with the more restrictive guided halibut regulations. A regulatory change could ensure proper accounting of guided and unguided catch.

Alternative 1: Take no action

Alternative 2: Prohibit the possession of guided and unguided halibut simultaneously on any fishing vessel
Alternative 3: If halibut harvested using sport fishing guide services is possessed with halibut harvested not using sport fishing guide services on Convention waters in Area 2C or 3A, the IPHC annual management measures for guided sport fishing for the area that the halibut was harvested apply to all halibut onboard the fishing vessel.
Suboption 3.1: Include “other fishing facility” as well as “fishing vessel”. The Council recommends that the analysis be revised to:
  1. Include the revisions suggested by staff and the Enforcement Committee, except the recommendation to include a new suboption 2.1.
  2. An expanded discussion of the changes in guided and unguided halibut fishery management measures that led to an increase in multi-day, and mothership and floating lodge operations and increasing potential for mixing halibut caught by guided and unguided anglers.
  3. An expanded discussion of the regulatory history of current prohibitions on mixing halibut in the commercial, subsistence, and sport fisheries.
  4. Available information on mothership and floating lodge sport halibut operations in areas 2C and 3A (i.e., number of operations identified, description of services offered, whether operation holds CHPs, etc.)