Debunking the halibut mythbuster
In a recent editorial on the halibut split, Andrew Jensen claims that the North Council spent a year incorporating the majority of charter sector concerns into a new catch sharing plan, or CSP. Jensen fails to note that allocation was the primary issue with the rejected CSP and that there were plenty of other issues identified during the first public comment period. To our knowledge, only two issues have been addressed in the revised CSP.
Allocation remains the primary issue with the CSP. When allocation alternatives are compared using the same metric, the revised allocations are worse than the allocations under the original CSP. Under the revised CSP, the Southcentral allocation is up to 30 percent less than the current Guideline Harvest Level, or GHL, at all but the highest abundance levels. NMFS omitted graphical comparisons of the GHL and CSP allocations from the proposed rule and analysis. (You can see Southcentral Alaska comparisons at www.alaskacharter.org.)
The public should know that in 2009 the GHL was affirmed by the U.S. District Court to be a fair and equitable allocation. The CSP allocation is far less than fair and equitable.
Jensen claims that the CSP is a plan to equitably share the conservation burden during times of low abundance, and to provide greater opportunity for both sectors at times of high abundance. The graph shows that at combined catch limits of 20 through 25 million pounds, the CSP allocation in Southcentral Alaska is constant at 3.5 million logbook pounds, with commercial fishermen receiving all the rest. So much for greater opportunity for guided anglers in times of high abundance.
Jensen suggests that the burden of conservation has been absorbed almost entirely by the commercial fleet. With 80 percent of combined guided and commercial harvest, it makes perfect sense that the commercial sector should bear 80 percent of the burden of conservation.
The guided sector has no problem with sharing the conservation burden when the allowable catch drops. In fact it has done so in both Southeast and Southcentral Alaska, where the GHLs have been reduced to their current levels of 788,000 pounds and 2.734 million pounds respectively. Because guided harvests have remained below the reduced GHL in Southcentral Alaska, there has been no need to drop guided daily bag limits below two fish.
Jensen notes that from 2004 to 2010, guided harvest in Southeast Alaska exceeded allocation by 3.4 million pounds. However he omits the fact that in 2011, Southeast Alaska guided anglers left half of their allocation in the water, while Southcentral Alaska guided anglers left 2.8 million pounds of their allocation in the water between 2003 and 2011.
Jensen also omitted the fact that for years the IPHC implemented a policy called SUFD that buffered commercial catch limits whenever they changed. In years when the biomass was decreasing, SUFD policy increased commercial catch limits, resulting in harvest that exceeded sustainable levels.
Between 2006 and 2010 in Southeast Alaska, commercial fishers harvested 7.7 million pounds over sustainable levels as a result of SUFD. The overharvest was not deducted from the following year’s harvest, but rather was buried in the annual biomass calculations. In 2011 the IPHC realized that mistake and suspended the portion of SUFD that resulted in the overharvest.
Jensen falsely claims that charter overages are deducted from the following year’s commercial harvest. In fact, from 2007 through 2012, the IPHC substituted the GHL for guided removals, lessening the impact of guided harvest overages by burying the overages in the annual biomass calculations, as it did with SUFD.
To achieve sustainable management of the resource, all sectors should be managed to their respective allocations, without policies allowing overharvest of the resource. Past overages of the GHL in Southeast Alaska are not the fault of guided anglers or the charter operators who take them fishing; the blame lies with the North Council and NMFS, who failed in their responsibilities to manage guided harvest within allocation.
Until the IPHC announces annual catch limits next January, nobody knows what the guided catch allocations will be. If any restrictions are necessary, a one fish limit is certainly on the short list of options.
Jensen states that commercial percentages of the total yield have fallen while guided percentages have increased. Let’s dispense with the smoke and mirrors and consider some nice and easy statistics: In 2013, guided catch limits in Southeast Alaska comprise 21 percent of the combined guided and commercial catch limits. In Southcentral Alaska, guided catch limits amount to 20 percent of the combined catch limits. We think an 80 percent share of combined catch levels is enough for commercial fishers.
For more information on the halibut CSP, including an unedited, footnoted version of this article and links to the proposed rule and its analysis, visit www.alaskacharter.org.
Rex Murphy is a consultant for the Alaska Charter Association.