I have it from a relieable source that the long over due halibut charter guide moritorium is going to be announced for its final public comment period this week. After which, it should become law. That would mean that last year was the "year prior to implementation" The permits should be good to go by 2010 if all falls into place.
By my simple understanding of this rule, you will have had to fished for halibut in 2004 or 2005 AND the year prior to implementaion which was 2008. If you have not done these things and you are in this business, you might be looking towards someone who will be getting a transferable permit or you will not be halibut fishing next year.
I will post the announcment when if shows up in the Federal Register.