Halibut
One-Fish Daily Limit: Is it an Allocation Issue or a Conservation Issue?
The
following cites from the Environmental Assessment / Regulatory Impact Review (EARIR) that is the legal support for the final
rule that state there is no conservation impact. NMFS has stated, for example that:
- “The
environmental analysis (EA) concluded that none of the alternatives would affect the health of the halibut stock since the
IPHC sets limits on total halibut removals. Regardless of the amount of halibut biomass taken by a sector, no adverse
impacts on the halibut resource would be expected because the IPHC factors in most resource removals in the halibut stock
assessment when setting annual catch limits.” (EA/RIR/IRFA at page xi.)
- “The proposed alternatives will not have any effect on the halibut
resource.” (EA/RIR/IRFA at page xii.)
- “The exploitable biomass for the coastwise projection and Area 2C projection
is expected to increase during the next ten years.” (EA/RIR/IRFA at 14.)
- “The
proposed alternatives address resource allocation issues. They would affect harvest levels and fishing practices of
individuals participating in the charter halibut fishery, but not the health of the halibut stock.” (EA/RIR/IRFA
at 20.)
Additionally, Comment 79 from page 50 of the Secretary’s One-Fish
Rule (available at www.charterhalibut.org) reads:
Comment 79: The IPHC does not view this as a conservation
issue. The IPHC would never allow an overharvest of the Total CEY if there were a conservation issue. It should
be very clear that due to the conservative nature of IPHC harvest calculations, overharvest of the Total CEY by 60 to 85 percent
is possible without resulting in a conservation issue. The proposed rule deals with a pure allocation issue and does
not present any resource conservation questions.
Response: NMFS
agrees. The healthy status of the halibut stock is evidence that IPHC policies are conservative and successful.
Also,
even a partial review of the final rule shows that NMFS references its prior statements and states that "This final rule
is not expected to significantly impact the sustainability of the halibut stock." See page 9 in the response to Comment
5.
Over
the last 10 years, charter fishing accounted for only 6.2 percent of the total halibut caught off the coast of Alaska. By
comparison, that is over 12 times less than the 75.8 percent that the commercial halibut fleet harvests,
and less than half the 14.6 percent allocated for bycatch (halibut caught incidentally by commercial fisheries targeting other
species of fish). If this were a true conservation issue, I’m sure NPFMC would be going after the halibut by-catch
as well.
