Alaska Halibut Catch Share Bad Idea
Anyone familiar with Alaska’s fisheries be it sport, subsistence or commercial clearly recognizes that there are some disturbing trends within the Pacific Halibut stock. Some of the finest minds in fisheries management and biology have been studying these trends to makes sense of what’s happening on the ocean floor and adjust management strategies accordingly, to help the stock begin to recover.
The problem isn’t that the total amount of halibut in the water is declining . . . the problem is that the halibut aren’t reaching the same size at age they were two decades ago. To use the impressive sounding lingo of fisheries managers the Total Biomass or Tbio is relatively robust, but the Exploitable biomass or Ebio (generally considered mature fish over 32” in length) is at historically low levels. Again, there are number of plausible working theories why this is occurring, but there are no definitive answers.
There’s no question that the commercial and charter fleets have both felt a significant sting as a result of the declining abundance in Ebio. The tension between these two sectors, on this issue particularly, arises from the fact that commercial fisherman and charter operators make their livelihoods from the halibut resource. Start tinkering with how people pay their mortgages and put food on the table, and people get testy – understandably.
An important distinction to keep in mind is that unlike commercial fisherman, charter operators don’t sell fish, they sell the opportunity for sport anglers to catch fish. This makes the charter sector dependent upon the interest of the sport angler to go fishing. A bad regulation for the charter sector equals a dramatic reduction in the level of interest for a sport angler. This was never more evident than in the 2011 season when the Southeast charter sector was limited to one halibut, no larger than 37” per angler, per day. As a result of that regulation, the Southeast charter sector caught less than half of their allocation for that year.
The Catch Sharing Plan (CSP) that the National Marine Fisheries (NMFS) Service is currently considering for implementation by the 2014 season is a fundamental change from how the Charter sector is currently managed under the Guideline Harvest Level (GHL). The most significant change from the GHL to the CSP is the allocation level for the charter sector—an allocation level that will make it increasingly difficult to maintain existing bag limits. In South central (Area 3A), it is foreseeable in the coming years that guided sport anglers will drop from two fish per day to one; and in Southeast (Area 2C) to be reduced to one fish of a maximum size—likely 40” or smaller.
Proponents of the plan argue that it is important for both the commercial and charter sectors to share equally when abundance decreases and will frequently throw around the “conservation” word in order to justify the plan.
The truth is, CSP doesn’t conserve one fish—it merely reallocates fish from the charter sector to the commercial sector.
In September 2012, agency staff said exactly that when the Environmental Assessment/Regulatory Impact Review (EA/RIR) stated:
“While the alternatives would affect harvest levels and charter fishing practices, total halibut removals would not be affected as any decreases in charter harvests would result in increased commercial harvests. . . Therefore, none of the proposed alternatives is expected to significantly impact the halibut stock. . . There may be an effect on the human environment, as there are winners and losers under any sector allocation.”
By June 2012, that became an inconvenient truth which they rephrased to say:
“No significant adverse impacts on the halibut stock are identified for the any of the alternatives considered. None of the alternatives considered, including the status quo alternative, would affect overall harvest levels of halibut by all sectors, fishing practices of individuals participating in the halibut fishery, or the health of the halibut stock. . . None of the alternatives considered is expected to affect the physical environment, benthic community, marine mammals, seabirds, or non-specified groundfish species.”
And then, all of a sudden, “conservation” becomes a hallmark of this miraculous plan. Again, in September 2012 no mention of conservation in that section of the report, but by June 2013:
“The proposed action alternatives address resource allocation issues and promote conservation in the halibut fisheries.”
Clearly, CSP is obviously bad for Alaska’s charter fishing fleet, but it doesn’t stop there. It reduces guided sport angler’s access to the halibut resource and will do untold economic harm to the coastal communities that are the home ports to the charter fishing fleet and the tens of thousands of sport anglers, who spend hundreds of millions of dollars annually, to fish our waters.
A 2008 study commissioned by the Alaska Department of Fish and Game (ADF&G) indicated that sport anglers spent $1.4 billion in Alaska that supported 15,879 jobs and provided $545 million in income.
An allocation plan that serves no conservation interest, limits access for sport anglers to the halibut resource and causes significant harm to an industry that is a major contributor to Alaska’s economy is a bad idea.
HOW TO ACT
The public comment period on the proposed rule is open until August 26th, 2013. Address comments to Glenn Merrill, Assistant Regional Administrator, Sustainable Fisheries Division, Alaska Region NMFS, Attn: Ellen Sebastian, and identified by FDMS Docket Number NOAA-NMFS-2011-0180. Comments may be submitted by any of the following methods:
* Electronic Submission: via the Federal e-Rulemaking Portal
* Mail: P.O. Box 21668, Juneau, AK 99802-1668
* Fax: 907-586-755
ABOUT THE AUTHOR
Mr. Hilyard is the Executive Director of the Southeast Alaska Guides Organization (SEAGO), which represents charter operators and lodge owners throughout Southeast Alaska. He is a 1996 graduate of the University of Alaska Fairbanks, currently serves on the Alumni Board of UAF and was recently selected as a 2013 recipient for the “Top 40 Under 40” award.