Alaska Charter Association

To Protect the Rights and to Conserve the Resources of Alaska's Sport Fishery
Council Releases RQE Anaysis
The North Pacific Fishery Management Council released today the analysis of the Charter - Recreational Quota Entity or RQE.  The creation of this entity would provide a means to lessen restrictive harvest measures (bag limits) for guided recreational anglers.  This would be accomplished through shifting halibut removals from the commercial to guided recreational sector by means of an open market, "willing buyer" and "willing seller", purchase of IFQ by the RQE.  Please read the RQE analysis ( Part 1 and Part 2) and offer your comments before the deadline 5:00 pm (AST) on Tuesday, March 29, 2016.  Comments should be emailed to npfmc.comments@noaa.gov. Remember to reference Agenda Item C9-Charter Halibut RQE -Initial Review.
 
We also encourage you to testify in person.  The meeting will be held in Anchorage at the Downtown Hilton.  Special hotel rates are available, just mention the NPFMC meeting.  Please see the Council Agenda and Schedule. The AP (Advisory Panel) will be taking up the RQE agenda item on Thursday, April 7th, 8:00am and the Council is scheduled to hear comments on Saturday, April 9th, 1pm.
 
It is very important that the Council receive your comments to show that the recent restrictive harvest measures have negatively impacted your clients and business.  Without your show of interest or concern, the Council will assume our sector can live with the regulations no matter how harsh they are.  This is an opportunity we all need to get behind for the future of our industry.
 

Comment letters
We realize the 186 page analysis is very technical in nature and might be difficult for some to wade through. The ACA will be releasing a technical review and analysis of this document in the coming weeks.  In the meantime, it is important for your letters to provide support for the problem statement. The commercial sector will argue there is no problem and allocation issues were settled with the adoption of the CSP (Catch Sharing Plan). 
 
Here are some questions you can ask yourself to help with your comment letter.
 
How have recent bag limits effected my clients and business and would the RQE have the potential to remedy this?
 
Would the RQE program be better than the GAF program, which is the only means offered under the CSP (Catch Sharing Plan) to temporarily shift allocations between sectors?

Be sure you mention in your letters, the type of business you operate, location, and years in business.  Be as brief and to the point as possible.
More points ...
Here are some specific issues the commercial sector has with the RQE based on their past testimony. You may wish to add your comments to refute these arguments as well.
 
Conservation:   All the charter fleet wants to do is take and take more, with no concern for conservation.  More allocation means more fish coming out of the water.
 
This action would not disrupt the conservation goals of the Council or the IPHC.  It shifts allocation between sectors with no additional removals that would impact the resource.  These removals have already been determined as sustainable.
 
IFQ Program Goals: This action would change the goals of the IFQ program and not preserve the historic makeup and traditions of the commercial longline sector. The charter fleet will buyout the commercial sector.
 
This action would not change the goals of the IFQ program. The RQE would just be added to the program as a qualified participant, much like the rural coastal communities where added under the CQE (Community Quota Entity) program back in 2002. 
 
Consolidation of the fleet, for reasons of efficiency and/or economic profitability, has been going on since the beginning of the program. The restrictions on how much quota could ultimately be transferred to the RQE would prevent any major disruption to the commercial fleet dynamics.
   
Entry Level Participation in the IFQ Program:
A buyer such as the RQE, with deep pockets, would raise the market prices of QS beyond the reach of new entrants in the fishery. There should be restrictions on purchasing "D" shares.
 
The cost of "D" shares are already too high for new entrants. Young fishermen who want to earn a living commercial fishing usually gain experience in other fisheries first or if fortunate enough get a job as a deck hand on a Class "C" vessel.  With their earnings, they buy Class "C" shares and fish them on the vessel they work on until they can buy their own vessel.
Do you find most of your time is being spent in damage control brought on by regulations that continue to decreased fishing opportunities for your clients and you don't have time to attend important meetings that may further impact your future? You need an organization like ACA to inform, educate, and represent you at these important fisheries meetings. Please help support us with your $150 membership. Please join us Today!