Sport anglers and commercial fishermen, make sure YOUR voice is heard!
Please go to http://halibutcoalition.org/ to show your support for sustainable wild halibut stocks! I just donated $20.00 to the cause through paypal.
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Please read below for information on this issue:
The Halibut Coalition urges NMFS to implement the CSP without further delay. The CSP marks 18 years of public discourse on halibut charter management that engaged hundreds of people from all sectors of the halibut fishery: subsistence, sport, and commercial fishermen; consumers; processors and distributors; and coastal communities. The CSP will allow halibut fishery managers to achieve important conservation and management goals. It will provide a measure of stability to the halibut fishery. Finally, the CSP will establish a market-based mechanism to resolve the allocation conflict that has consumed the Council and torn apart coastal fishing communities.
The almost two decades of testimony and analysis surrounding the development of the CSP have resulted in an extensive and complete factual and legal record supporting the CSP – a record that fully demonstrates the CSP is fair and equitable, takes into account present participation in the fishery, and promotes conservation. Among those facts are the following.
The GHL and CSP were developed by committees dominated by the charter industry.
When the charter industry decided at the last minute to oppose the CSP to which it had previously agreed, the industry did so based on the assertion the CSP was neither fair nor equitable. The charter industry’s “fair and equitable” alternative proposed raising the then-existing Area 2C charter catch from 913,000 pounds to 4.9-5.7 million pounds, between 70%-80% of the total harvest, effectively putting the commercial fleet out of business.
The status quo GHL management program has resulted in the Area 2C charter industry exceeding its quota by 22%-115% and by lesser amounts in Area 3A. The commercial sector has never exceeded its quota since the IFQ program was established.
The IPHC has stated that charter overfishing is a threat to resource conservation.
In Area 2C since 2005, the halibut resource has declined 62% and the commercial quota has been cut 76%. The charter industry’s quota was reduced by only 55% but the charter industry offset those reductions by overfishing its quota by an average of 52%. While the resource has been declining, the charter industry in Area 2C increased its harvest by 93% between 1997 and 2008.
Charter overfishing has resulted in direct reductions to the Area 2C commercial fleet to offset the charter overharvest. These reductions have an ex-vessel value to commercial fishermen of $15 million which translates to a $46.5 million economic loss using standard multipliers.
Charter overfishing causes localized depletion because it is concentrated in nearshore areas. The charter industry admitted the existence of localized depletion in testimony on the charter limited entry program.
Localized depletion means the least fortunate among us, those who live near, at, or below the poverty level, and who depend on subsistence fishing, cannot find the resources to feed their families.
The commercial processing sector has seen significant declines in the amount of halibut available for processing, caused in part by charter overfishing, with a corresponding impact on jobs and community wages.
Alaska’s coastal communities which depend on halibut and other commercial fish landing taxes to support essential government services have suffered a dramatic loss of income as commercial quotas have been cut to compensate for charter overfishing.
The CSP awards the charter industry a percentage of the allowable harvest that is equal to, or greater than, the GHL percentage in both Areas 2C and 3A.
Had the CSP been in place in lieu of the GHL since 2004, the charter industry would have received more fish in both Areas 2C and 3A.
The CSP allows the charter industry to increase its allocation by providing a mechanism for the industry to acquire more fish from the commercial fleet.
The CSP makes substantial concessions requested by the charter industry, mostly at the expense of the resource or the commercial fleet. Among those concessions are:
-percentage allocations equal to or greater than the GHL allocations;
-a program that allows the charter industry to increase its harvest by leasing commercial quota;
-no in-season harvest management changes;
-allowing the charter industry to exceed its annual harvest limit by approximately 20% with no new regulations to limit harvest;
-management measures limited to bag and size limits with season limits and fishery closures taken off the table as possible management measures;
-an increase in the charter industry’s allocation percentage when halibut abundance is low so that the commercial fleet bears the conservation burden; and
-a more flexible management system so that charter allocations can rise more quickly when halibut abundance increases.
Despite these facts, the charter industry protests. Ignoring the fact that if the CSP had been in place since 2004 instead of the GHL, the charter industry would have received more fish, the industry asserts that their 2011 allocations, had the CSP been in place, would have been less than their GHL allocations. This argument captures the essence of the charter industry’s attitude and the exact nature of the problem confronting fishery managers. The facts are that:
-the difference between the 2010 CSP and the GHL Area 2C allocation to the charter industry would have been only 8,000 pounds;
-while the commercial fleet has seen its quota cut by 73% between 2007 and 2011, the charter industry quota was cut by only 45%, and none at all in the last three years even though the resource has continued to decline and commercial quotas have been slashed to conserve the resource;
-in Area 3A, the commercial quota was cut 45% between 2007 and 2011 for conservation reasons, but the charter quota was never reduced; and
-in 2011, the commercial quota in Areas 2C and 3A was reduced from 2010 levels by 47% and 38%, respectively, while the charter quota under the GHL was not cut by one pound.
A fair and equitable allocation would have reduced the quota for each sector by equal amounts. But the charter industry does not want fair and equitable. It wants what is unfair and inequitable – that the charter industry not bear its share of the responsibility for conserving the resource – a conservation need caused in part by years of overfishing by the charter industry – overfishing that has inflicted enormous harm on the resource, commercial fishermen, subsistence fishermen, processors, and coastal communities.
There are clearly net national benefits to implementing our national policy of preventing overfishing. There are national benefits to not inflicting economic loss on the commercial fleet (and dependent processors and coastal communities) when the IPHC is forced to reduce the commercial quota to offset charter overfishing and to conserve the resource. There is clearly a net national benefit to ensuring that the least fortunate among us, subsistence fishermen, do not lose access to the resource due to localized depletion caused by charter overfishing. And in considering net national benefits, one cannot forget that the charter industry would have received more fish if the CSP had been in place since 2004 instead of the GHL. This means the benefit to that industry would have been, and will be, greater under the CSP.
The facts and the law are clear. The CSP can and must be implemented for the 2012 season.