# ![](media/image1.wmf){width="2.033333333333333in" height="1.038888888888889in"}Southeast Alaska Fishermen's Alliance

9369 North Douglas Highway

Juneau, AK 99801

Phone 907-586-6652

Fax 907-523-1168 Website: http://www.seafa.org E-mail: seafa@gci.net

January 20, 2009

Sue Salveson, Assistant Regional Administrator

Sustainable Fisheries Region, NMFS AK Region

Attn: Ellen Sebastian

PO Box 21668

Juneau, AK 99802

RE: RIN 0648-AX17

Southeast Alaska Fishermen's Alliance (SEAFA) supports the proposed rule
for a one halibut daily bag limit for Area 2C charter clients, further
restrict the fish to a maximum size and retain the requirement for
keeping the carcass. Implementation of this regulation is long overdue
with the 2C charter sector exceeding the GHL allocation for five
consecutive years. The preliminary estimate is that the charter fleet
exceeded their GHL by 206% in 2008. The NPFMC has repeatedly stated
their intent to manage to the charter GHL, the October 2008 NPFMC
meeting being the last occasion where they reconfirmed their commitment.
Under the new catch sharing plan recommended by the NPFMC at their Oct.
2008 meeting, it is likely that a one halibut daily bag limit with a
maximum size limit would be implemented at these low levels of abundance
for 2009. The GHL has stepped down again for 2009 from .933 Mlbs to .788
Mlbs.

Now that the IPHC has adopted catch limits and CEYS for the individual
regulatory areas for the 2009 season, the final rule should clearly
state the GHL that will be in place for the 2009 season is .788 million
pounds.

On page 78277 of the proposed rule it describes the Guideline Harvest
Level (GHL) as a benchmark for monitoring the charter vessel fishery
which appears to contradict the action being taken in the proposed rule
which defines the GHL as "*mean\[ing\] the level of allowable harvest by
the charter vessel fishery."* This should be corrected for the final
rule. SEAFA fully believes that when the GHL was adopted in 2000 and
finalized in 2003 it was meant as an upper end allocation for the
charter fleet with stair step down clauses for sharing the burden of
conservation in times of low abundance. The GHL when implemented was
125% of the charter fleets historical harvest at the time it was
recommended. The extra 25% allocation was to provide for some growth in
the industry but not unlimited continual growth.

The GHL was established to prevent the reoccurring reallocation from the
commercial sector. To not uphold the GHL as an allocation is unfair and
inequitable to the commercial sector. The commercial sector is reeling
under the impact of 3 years of significant decreases in catch limits in
area 2C. Many small fishing businesses will no longer be able to hire
crew and instead there will likely be consolidation of several quota
share holders going on one boat to fish the annual IFQ because the
poundage is so low as to make it uneconomical or feasible to fish on
their own boats. Many of the small processors around Southeast are being
affected also by the lowered quotas and facing less production going
through the plant to cover overhead costs. This in turn is affecting
other fisheries, such as the upcoming crab season the processor would
usually service but instead are saying that they can't afford to cover
the overhead to open the plant earlier without the additional
production.

Many of the fishermen who have bought into the halibut fishery recently
will be facing financial devastation as many have used their boat and
other fishing permits or their homes as collateral for the quota share
and with a lowered quota of 19% for 2009 and the lowered price that is
being advanced, these fishermen will not be able to make their payments.
Some fishermen are already in the position that they can't sell their
quota share and even cover the existing loan nor can they make enough in
the fishery to cover the loan payment let alone the expenses necessary
to fish the IFQ's.

SEAFA believes that the current GHL is an allocation that is fair and
equitable and the public record has been built during the public process
that created the GHL and also during the October 2008 council meeting
when creating the catch sharing plan and all the other meetings during
the 15 years that this issue has been on the table. It is also
appropriate to manage the charter sector differently than the unguided
angler. A charter client has the benefit of the knowledge and skill of
the charter operator which provides for a higher harvest success rate as
well as this was the sector that was growing while the other sectors
were staying stable at the time the GHL was developed.

With the GHL defined as "*mean\[ing\] the level of allowable harvest by
the charter vessel fishery"* the NMFS has an obligation under the
reauthorization of Magnuson Stevens Act and the new final rule on
National Standard 1 to prevent over-fishing, fisheries must be managed
to their allocation level. Implementing management measures of at least
a one halibut daily limit for charter clients in 2C is critical to
meeting the IPHC management target set for that fishery.

The IPHC uses a precautionary method of determining the annual
management targets using a "slow up -- fast down" (SUFD) policy. This
policy leaves more fish in the water in the long run than setting catch
limits exactly to the yearly CEY. The GHL stair steps down is the
equivalent to the SUFD policy for the commercial sector. The stair step
down was created to allow the biomass to change by 15% before dropping
to the next level. This was implemented on the charter's request to
provide a more stable fishery before management measures were changed.

Not managing a sector to their GHL or catch limit creates a long-term
conservation concern especially when the stocks are already showing
signs of distress or decline. In Southeast Alaska, the IPHC has pointed
to the declining catch per unit of effort (CPUE) for the survey, for
commercial catches, the amount of fish caught per hook set or hours
fished for the recreational sector, slowed growth rates, and poor stock
structure (the over-harvest of older females from the resource).

SEAFA supports the in depth comments submitted by the Halibut Coalition
and fully supports the proposed rule for a one fish daily bag limit for
2C charter clients for implementation prior to the start of the charter
season.

Thank you for considering our comments on the proposed rule. Southeast
Alaska Fishermen's Alliance is a multi-gear group representing our
members involved in the salmon, crab shrimp and longline fisheries of
Southeast Alaska. We have members who hold halibut quota share in every
regulatory area of Alaska.

Sincerely,

Kathy Hansen (email signature)

Kathy Hansen