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.) 

North Council's preferred alternative on CHP registration

Here's the motion that passed at the October NPFMC meeting regarding an annual registration of Charter Halibut Permits:

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.
  • CHP holder phone number and/or CHP holder email address.
    If a CHP is not registered with NMFS, the CHP would not be valid for use during the applicable fishing year.
    Options for additional requirements could include (options are not mutually exclusive):
    Option 1. CHP ownership (e.g., ownership holdings for the CHP by individual(s), partners, or a corporate entity). 

Thursday, October 19, 2017

RQE Rule Published in Federal Register

NOAA has published the proposed rule for the Recreational Quota Entity, a buyback program for compensated reallocation of Pacific halibut.

Comments are due on or before November 17, 2017

Fisheries of the Exclusive Economic Zone Off Alaska: 0648-BG57

Authorize Recreational Quota Entity to Participate in the Halibut IFQ Program

FR Document: 2017-20894

Citation: 82 FR 46016

Abstract: NMFS issues a proposed rule that would authorize formation of a recreational quota entity (RQE) that could participate in the Pacific Halibut and Sablefish Individual Fishing Quota Program in International Pacific Halibut Commission Regulatory Areas 2C and 3A in the Gulf of Alaska. The RQE would be authorized to purchase and hold a limited amount of commercial halibut quota share that would yield additional pounds of recreational fishing quota on an annual basis to augment the amount of...

DATES: Submit comments on or before November 17, 2017.

FOR FURTHER INFORMATION CONTACT: Kurt Iverson, 907–586–7228.

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.


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.

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.

ACA Position

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.

Saturday, September 16, 2017

House Committee Flowchart on the Magnuson Stevens Act Reauthorization

The House Committee on Natural Resource put together a useful flowchart to explain the MSA and the changes being considered under the Congressional effort to reform the act that sets the basic ground rules for our nation's marine fisheries - this might be a little hard to read, but you can go to a larger version of the image by clicking here and clicking on the image to expand it.

Wednesday, September 13, 2017

RFA Executive Director Testifies on Magnuson Reform

Recreational Fishing Alliance   
Contact:  Jim Donofrio / 888-564-6732  
For Immediate Release
September 12, 2017     
RFA Executive Director Testifies on Magnuson Reform
Senate Holds Final Legislative Hearing On MSA
On Tuesday, September 12, 2017 Jim Donofrio, executive director of the Recreational Fishing Alliance testified before the Senate Commerce Committee's Subcommittee on Oceans, Atmosphere, Fisheries, and Coast Guard on the reauthorization of the Magnuson-Stevens Fishery Conservation and Management Act (MSA).  Today's hearing is the third and final legislative hearing held in the Senate on MSA reauthorization. The RFA has been in the vanguard demanding reform of this critically important legislation to make it more fair and responsive to recreational fishermen and the multi-billion dollar recreational fishing industry.
"Congress must be made to realize that managing fisheries requires a balance between resource conservation and economic considerations," Donofrio said. "Quite simply, while the system under the current provisions in the MSA has been successful in rebuilding some key fish stocks it has been a dismal failure at translating that success into socioeconomic benefits to fishermen and the recreational fishing industry. It is unnecessarily costing the nation thousands of jobs and billions of dollars in lost economic opportunity." 
In his testimony, Donofrio told Senators that we have been asking for your help since MSA was reauthorized in 2007 when amendments were made to the law that created a systemic management problem on a national scale and which is most acutely felt in the recreational sector.

Looking back at original intent of MSA (public law 94-265) signed into law on April 13, 1976, the primary objective of the law was to promote domestic commercial and recreational fishing under sound conservation and management principles. Unfortunately, this noble objective was altered in the 1996 and 2007 reauthorizations and currently, management can only be described as a failure, a total imbalance with recreational fishermen and the recreational fishing industry losing out.
"The needs of fish have been put at an inordinate level of priority while the needs of the fishing community and industry have been made an afterthought.  This is not sound resource management and we are asking that the Senate, along with the House,  pass MSA reauthorization bills as soon as possible to restore a balance to the management of our nation's marine resources," continued Donofrio.
The RFA has been and continues to advocate for MSA reform. It foresaw the impending economic train wreck that the law would spawn even before it was signed into law in 2007.  Now that the inevitable is occurring in fisheries like black sea bass, red snapper and others around the nation a coalition of recreational fishing groups and industry associations have joined together to promote reform through the passage of the Modernizing Recreational Fishing Management Act. Donofrio's testimony before this Senate Subcommittee is another in a long series of steps taken demanding action.
RFA and other organizations are pushing hard to pass Modern Fish Act bills in the House and Senate.  In the House, two bill have been introduced, HR 200 introduced Rep. Don Young from Alaska and HR 2023 introduced by Rep. Garrett Graves from Louisiana. HR2023 is the preferred bill as it addresses issues specific to the recreational sector.  A markup hearing is expected in early fall and there is hope that a bill could be passed out of the House by the end of the year.  Today's hearing in the Senate is the final legislative hearing on the MSA reauthorization.  Action in the Senate is expected to quicken once a House bill is released. 
Also testifying at today's hearing and speaking on behalf of the recreational fishing community were Phil Faulkner, President of Nautic Star Boats and Chris Horton of the Congressional Sportmen's Foundation.  Both speakers enforced the message that recreational anglers support and rely on sound, science-based conservation but that a balance must be struck to ensure that anglers also have a reasonable opportunity to harvest fish.   
To read Jim's full testimony click here!

About Recreational Fishing Alliance
The Recreational Fishing Alliance is a national, grassroots political action organization representing recreational fishermen and the recreational fishing industry on marine fisheries issues. The RFA Mission is to safeguard the rights of saltwater anglers, protect marine, boat and tackle industry jobs, and ensure the long-term sustainability of our Nation's saltwater fisheries. For more information, call 888-JOIN-RFA or visit
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Friday, September 1, 2017

Despite ADN story, charter fishery no threat to rockfish

"We Alaskans pride ourselves on our fishing opportunities and scenic beauty, and take pleasure in sharing them with the world. The guided sportfishing sector shares the joy of wild Alaska with millions of visitors and residents every year. Yet, on Aug. 4, Alaska Dispatch News published the provocatively titled Outdoor article "Is the Alaska charter fishery threatening rockfish?"

In short, no.... click here to read the full article on ADN's website.

Wednesday, August 30, 2017

Reauthorization of the Magnuson-Stevens Fishery Conservation and Management Act: NOAA and Council Perspectives

U.S. Sen. Dan Sullivan (R-Alaska), chairman of the Subcommittee on Oceans, Atmosphere, Fisheries, and Coast Guard, convened a hearing titled “Reauthorization of the Magnuson-Stevens Fishery Conservation and Management Act: NOAA and Council Perspectives” on August 1, 2017. This hearing was the first in a series to examine the state of our nation’s fishery laws and guide the reauthorization of the Magnuson-Stevens Fishery Conservation and Management Act.


- Mr. Christopher Oliver, Assistant Administrator for the National Marine Fisheries Service, National Oceanographic and Atmospheric Administration

- Dr. John Quinn, Chair, Council Coordination Committee and Northeast Fishery Management Council

You can watch the video archive of the hearing here.


Fish politics can be a little overly serious sometimes, so here’s this:

Witherell named Executive Director of North Council

The North Pacific Fishery Management Council announced the appointment of David Witherell as its Executive Director, taking over the helm from Chris Oliver who moved on to be the Assistant Administrator for NOAA Fisheries. Mr. Witherell has worked for the Council for 25 years, and has been the Deputy Director since 2002. Council Chairman Dan Hull noted that “David brings a long history of Council experience and proven leadership skills as Deputy Director. We’re very pleased and fortunate that he has accepted the Executive Director position for the North Pacific Council.”

"Oliver, who has lived in Alaska since 1990 and been the executive director of the council since 2001, officially took the post of assistant administrator at the National Marine Fisheries Service effective June 19.

"The move places him in the top job at the federal agency within the National Oceanic and Atmospheric Administration that regulates and enforces fisheries occurring in federal waters, which are between 3 and 200 miles off U.S. coasts.

"As administrator, he will oversee NMFS’ 3,200 employees, five regional offices, six science centers and 24 labs and fish stations. NMFS works with the eight regional fisheries councils across the country to develop recreational and commercial fisheries policies, providing research and recommendations for conservation and management."


Rep. Frank Pallone and Sen. Bob Menendez make the rounds in Atlantic Highlands talking with recreational fishermen, while back in DC their fellow congressmen are tackling fisheries reform.

U.S. Senate Takes Up Fisheries Reform

“In early July, the recreational fishing and boating community praised the Senate introduction of the Modern Fish Act by Senators Roger Wicker (R-MS), Bill Nelson (D-FL), Roy Blunt (R-MO), Brian Schatz (D-HI), John Kennedy (R-LA) and Joe Manchin (D-WA). Supported by the American Sportfishing Association, National Marine Manufacturers Association, Recreational Fishing Alliance, Coastal Conservation Association, Congressional Sportsmen's Foundation, International Game Fish Association and other groups, the new bill in the U.S. Senate (S.1520) would improve public access to America's federal waters, promote conservation of our natural marine resources and spur economic growth within the recreational fishing community.”

Read the rest of the article in The Fisherman Magazine.

Sunday, July 16, 2017

Don Young taking a lead on the Re-Authorization of the MSA:

Subcommittee Review on the Performance of the Magnuson-Stevens Act:
On Wednesday, July 19, 2017 at 10:00 AM (AK), 2:00 PM (Eastern) the Subcommittee on Water, Power and Oceans will hold an oversight hearing titled “Exploring the Successes and Challenges of the Magnuson-Stevens Act (MSA).

WHEN: Wednesday, July 19 @ 10:00 AM (AK), 2:00 PM (Eastern)

WHERE: 1324 Longworth House Office Building or live streamed here.

As Chairman Emeritus of the House Natural Resources Committee and an original author of the 1976 MSA, Congressman Young has been selected to lead MSA reauthorization efforts in the U.S. House. Young is the sponsor of H.R. 200, the Strengthening Fishing Communities and Increasing Flexibility in Fisheries Management Act, which provides a number of modest but necessary updates to our nation’s fisheries management policies.

Wednesday, June 28, 2017

NOAA opens public comment period on Sec. 4(b) in Executive Order 13795 focused on Natl. Marine Sanctuaries and Marine Natl. Monuments

National News:

NOAA is soliciting comment on National Marine Sanctuaries and Marine National Monuments designated or expanded since April 28, 2007, during a 30-day public comment period, which opened on Monday, June 26, 2017.  NOAA is seeking comments to assist the Secretary of Commerce in his review under Section 4(b) of the Presidential Executive Order (EO) 13795 "Implementing an America-First Offshore Energy Strategy" signed April 28, 2017. There are a total of six National Marine Sanctuaries and five Marine National Monuments under review (please see the table below).

​NOAA is asking for comments on the criteria outlined in Section 4(b)(i) of Executive Order 13795:

  1. An analysis of the acreage affected and an analysis of the budgetary impacts of the costs of managing each National Marine Sanctuary or Marine National Monument designation or expansion;
  2. An analysis of the adequacy of any required Federal, State and tribal consultations conducted before the designations or expansions; and
  3. The opportunity costs associated with potential energy and mineral exploration and production from the Outer Continental Shelf, in addition to any impacts on production in the adjacent region.
You may submit comments identified by docket ID NOAA-NOS-2017-0066 by one of the following methods:
  • Electronic submissions: Beginning Monday, June 26, the option to submit all electronic public comments via the Federal eRulemaking Portal at enter NOAA-NOS-2017-0066 in the "Search" box, click the "Comment Now!" icon, complete the required fields, and enter or attach your comments.
  • Mail: EO 13795 Review, National Oceanic and Atmospheric Administration, Silver Spring Metro Campus Building 4 (SSMC4), Eleventh Floor, 1305 East West Highway, Silver Spring, MD 20910.

​Thank you for your interest in the Greater Farallones National Marine Sanctuary. For more information, please visit the websites below or contact Willilam Douros 
    National Marine Sanctuaries and Marine National Monuments Under Review Pursuant to EO 13795, Sec. 4(b)
Size in Acres
Federal Register Citation
Channel Islands National Marine Sanctuary …………..


May 24, 2007
72 FR 29,208 (May 24, 2007)
Cordell Bank National Marine Sanctuary ………………....
March 12, 2015
80 FR 13,078 (March 12, 2015)
Greater Farallones National Marine Sanctuary ……….…..
March 12, 2015
80 FR 13,078 (March 12, 2015)
Marianas Trench Marine National Monument ………......
Commonwealth of the Northern Mariana Islands/Pacific Ocean
January 6, 2009

74 FR 1,557 (January 12, 2009)
Monterey Bay National Marine Sanctuary ………………..…
November 20, 2008
73 FR 70,488 (November 20, 2008)
National Marine Sanctuary of American Samoa …………..
American Samoa
July 26, 2012
77 FR 43,942 (July 26, 2012)
Northeast Canyons and Seamounts Marine National Monument ……………..…..
Atlantic Ocean
September 15, 2016
81 FR 65,161 (September 21, 2016)
Pacific Remote Islands Marine National Monument ……..….
Pacific Ocean
Designation; Expansion
January 6, 2009; September 25, 2014
74 FR 1,565 (January 12, 2009); 79 FR 58,645 (September 29, 2014)
PapahānaumokuākeaMarine National Monument …………
August 26, 2016
81 FR 60,227 (August 31, 2016)
Rose Atoll Marine National Monument………………....
American Samoa
January 6, 2009
74 FR 1,577 (January 12, 2009)
Thunder Bay National Marine Sanctuary  …. ………………..
September 5, 2014
79 FR 52,960 (September 5, 2014)

  1 All of Rose Atoll Marine National Monument is contained within National Marine Sanctuary of American Samoa.


Maria Brown

Greater Farallones National Marine Sanctuary
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(415) 530-5355

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