Friday, September 22, 2017
ACA Comment letter on the Mixing of Guided and Unguided Halibut (NPFMC agenda item C2)
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.
C2 – Mixing Guided – Unguided Halibut
The first alternative under consideration is the status quo. The second alternative would prohibit the possession of guided and unguided halibut simultaneously on any vessel. Under the third alternative, if any halibut harvested using sport fishing guide services is possessed with halibut harvested not using sport fishing guide services in Area 2C or Area 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.
Support Alternative 1 – Status Quo
ACA would like to continue discussions on alternative enforcement methods, other than those proposed, that would have less economic impact to floating lodges, motherships and other potentially affected operations. The use of zip tie halibut tags for identification of guided caught halibut may still have merit for those operations that mix guided and unguided halibut. Most of charter record keeping is based on the honor system, so why should a tagging system be less trusted.
The analysis mentions a “benefit” to the guided sector allocation, as there would be a decrease in unguided removals, which are taken off the top before the total allowed catch is set under the Catch Sharing Plan. The analysis fails to mention that the assignment of unguided to guided removals will increase the guided catch by 100% for each pound of fish, versus only approximately 18% under the Catch Sharing Plan for every unguided fish removed.
Defining floating lodges, or for that matter a “floating dock” that many land based lodges use to process guided and unguided catches, as “fishing vessels” would also have further consequences not mentioned in the analysis. On Convention waters, fishing vessels are limited to a possession limit of two daily bag limits as well as skin and carcass requirements if there is a size restriction on the halibut. The economic impacts on floating lodges have not been analyzed under this broader definition. ACA recommends possibly adopting the US Coast Guard definition for a “vessel” as a watercraft capable of being used as a means of transport on water (more liberally defined as needing to have a means for propulsion).
The vaguely identified risk of misidentifying guided versus unguided catch created by anecdotal enforcement reports do not rise to the level of taking any action. While realizing it may take enforcement addition time to enforce, it does not warrant the potential economic impact to businesses that have operated under existing regulations for many years. Ultimately all fish are being accounted for, so taking no action will not negatively impact the halibut resource.