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.