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Charter Halibut Task Force!
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What is CHTF's Position on Individual Fishing Quotas (IFQs)?
The Halibut Act states
that if halibut fishing privileges are allocated among various United States fishermen, the allocation must be fair and equitable
to all, “reasonably calculated to promote conservation,
and carried out in such a manner that no particular individual, corporation, or other entity acquires an excessive share of
fishing privileges.” (16 U.S.C. § 773c(c)).
CHTF believes that
if Alaska wants to continue to benefit from the $1 billion economic impact recreational fishermen bring to the State, these
anglers deserve a larger share of the public halibut resource than the 10 percent that they have historically taken.
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The Charter Halibut Task Force
represents charter fishing operators from all areas of Alaska. Over the past decade,
many of CHTF’s members have been involved in deliberations at the North Pacific Fishery Management Council (NPFMC) and
with the State of Alaska on possible management measures that would affect guided recreational fishing for halibut.
In 2001, the NPFMC recommended an Individual Fishing Quota
(IFQ) program to award IFQs to charter operators, and some charter operators who are now CHTF members supported that program
at the time. However, the NPFMC in 2003 withdrew the IFQ recommendation, and the IFQ program was not put
in place.
Since 2003, many other options for managing guided
recreational fishing for halibut have been discussed and debated, and charter operators have developed a much greater understanding
about how the various options would impact guided recreational anglers and the charter
operators who serve them. Alaskan charter operators have also developed a much greater consensus about
how guided recreational fishing should and should not be managed.
CHTF supports a fair and equitable allocation for recreational anglers and does not support IFQs for charter operators
or anglers.
IFQs work well for commercial fishing operations,
where the IFQ holders directly catch the fish and the fish are sold into the commercial marketplace. The
IFQs are issued in pounds, the fish are sold in pounds, and transactions between IFQ holders are done in pounds.
Most importantly, each IFQ holder directly controls their ability to harvest the pounds they have been allocated or
purchase, and any reduction in the amount of pounds available affects all IFQ holders equally relative to the amount of IFQ
they hold. As a result, IFQs produce the desired conservation benefits because each IFQ holder equally
“shares the pain” and “shares the gain” of reductions or increases in stock abundance.
The same is not true for IFQs if they are issued to charter operators. Charter operators do not catch the
fish for which the IFQs are issued – recreational anglers do. Recreational anglers catch fish, not
pounds, and do not sell those fish in the marketplace. Recreational anglers fish for enjoyment and personal
consumption, not for profit as commercial fishermen do. It is the opportunity to catch fish and reasonably
predict the fishing experience they pay for in advance that is important to recreational anglers.
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Charter operators
do not control the number of recreational anglers. As a result, issuing IFQs to charter operators does
not accomplish the stewardship goals that are achieved by issuing IFQs to commercial fishermen. Instead,
IFQs become an inefficient and potentially wasteful means of allocating a scare public resource as charter operators seek
to guess each year how many clients they will have, how much they will catch, and thus how many pounds of fish to attempt
to purchase in advance for those clients. As charter operators guess wrong, as they inevitably will, recreational
anglers will be disappointed by operators who did not purchase enough IFQ, and fish will go unharvested when operators purchase
more IFQ than their clients actually catch. As a result, IFQs issued to charter operators become an inefficient
and costly form of limited entry for charter operators, with no conservation benefit.
There
are no conservation benefits because recreational angler demand will determine the number of fish that recreational anglers
catch. The only thing charter IFQs will determine is which charter operators remain in business to try
and serve whatever angler demand their IFQs allow them to. The license moratorium for charter operators
recommended by the NPFMC for which regulations are expected in fall 2008 will already serve as a limit on the number of charter
operators, and is much less costly and more equitable than an IFQ program. But neither a moratorium nor
IFQs will ensure that recreational harvest of halibut will not continue to reduce commercial IFQ allocations.
Recreational anglers who cannot find a charter operator due to a moratorium or IFQs will find other ways to catch halibut,
with the result that unguided recreational harvests will increase and cut the commercial quota.
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Charter Halibut Task Force
P.O. Box 8500
Ketchikan, AK 99901
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