Friday, September 22, 2017

ACA Comment letter on Annual Registration of Charter Halibut Permits (NPFMC agenda item C1)

For reference, visit the North Pacific Fishery Management Council for the agenda, and each item has links to the discussion papers from Council Staff, public comment etc.

Agenda: 


C1 – Charter Halibut Permit Renewal

The measures under consideration include implementing an annual
renewal process for the Charter Halibut Permit (CHP), which is a component of the
Charter Halibut Limited Access Program. The information collected in an annual
registration process would update and/ or expand on the CHP data, providing more
complete and useful information on the charter halibut users.


ACA Position

Support Alternative 2.  Implement an annual registration process for transferable and non-transferable charter halibut permits (CHP). A CHP holder must submit the following information to NMFS on an annual basis to register a CHP:
• CHP number,
• CHP holder name (individual or non-individual entity), and
• CHP holder address.
If a CHP is not registered with NMFS, the CHP would not be valid for use during
the applicable fishing year.

Option 1.  CHP ownership (e.g., ownership holdings for the CHP by individual(s), partners, or a corporate entity).


Non–Support for Alternative 2. Options 2 and Option 3.


ACA believes there is merit in updating CHP ownership and contact information as this information may have changed from original issue and having this done annually is prudent.  However, gathering information as to how one intends to use a permit, goes beyond the intended purpose of a limited access program.  If there is a need to further restrict access to the guided halibut fishery, then this problem statement needs to precede any action to identify who, what, and when such permits should be restricted.

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