With another round in Alaska's halibut war shaping up between commercial fishermen and charter-boat operators, the staff of the National Marine Fisheries Service has written a 333-page indictment of what is wrong with management of the big flatfish in the North Pacific.
"The Regulatory Amendment for a Catch Sharing Plan For the Pacific Halibut Charter Sector and Commercial Setline Sector in International Pacific Halibut Commission Regulatory Area 2C and Area 3A" -- as federal regulators call their hefty tome -- was not intended as such as indictment, but that is what it ended up becoming. It is a long-winded, redundant, hard-to-fathom testament to what the agency didn't do in terms of assessing economic impacts associated with changes in the halibut fishery, and what it plans to do to benefit commercial fishermen.
Where other U.S. resource agencies focus on generating revenue for the cash-strapped U.S. Treasury by making money off public resources -- be it oil, gas, minerals, timber range land, or even scenery -- the Fisheries Service is focused on increasing revenue for the fishermen with whom it long ago formed an alliance.
According to the latest plan the agency is putting before the North Pacific Fisheries Management Council -- an organization dominated by commercial fishing interests -- the new halibut management scheme could net commercial fishermen additional "revenue of about $977,000 to $1.16 million" in Southeast Alaska and "about $1.3 million to $4.1 million" in Southcentral Alaska at current halibut prices. (The Council will be meeting in Anchorage starting Wednesday.)
The fund-raising approach here is sort of the polar opposite of that of another federal agency, the U.S. Forest Service, which charges commercial operations money just to take pictures of federal lands in Alaska. That agency took the TV show "NAPA's North to Alaska" to court when it failed to pay for permits to film in the Tongass and Chugach National Forests. Show host Larry Csonka, the former NFL football star, was subsequently ordered to pay $5,000 in fines and $3,887 in restitution, plus film a public-service announcement for the Forest Service to make up for his crimes.
The Fisheries Service is trying to squeeze money out of a public resource, too, but not for the public or even the government.
Is the goal job elimination?
The revenue here is going to fewer than 1,500 fishermen. According to the federal agency's plan, the $2.28 million to $5.3 million would be split between the 1,431 fishermen who now hold permits to halibut quota. That is down from the 3,073 fishermen who held quota when the federal government approved a limited entry plan for the halibut fishery that gave them the quota in the mid-1990s.
The number of fishermen has shrunk as small operations have generally sold out to bigger operations. Though this amounts to a significant loss of jobs in coastal Alaska communities, the plan says, "this was neither an unexpected, nor undesirable outcome of the IFQ (individual fishing quota) program."
Job elimination would appear to be a goal of the National Marine Fisheries Service and North Pacific Fisheries Management Council, though it is never clearly stated as such. Still, they are cutting jobs.
The duo last year combined to reduce the number of halibut charter businesses in the state by instituting a limited entry-permit program that put out of business any charter operators who'd started fishing after 2004. That sank at least 327 small businesses. Now the Fisheries Service and the Council are back for more.
Early on in their latest plan, the regulators concede the changes they are proposing in halibut fisheries around the Gulf of Alaska from Ketchikan north to Dutch Harbor have nothing to do with conservation. These are, instead, economic changes that would shift halibut from charter boats -- and the people who fish from them -- to commercial fishermen, who have been struggling as the number of halibut in the North Pacific has declined and catch quotas have repeatedly shrunk to prevent overfishing.
That this allocation scheme has nothing to do with conservation is something the plan repeats over and over in that convoluted form of English some call "bureaucratize."
From the plan summary:
While the (fishing) alternatives would affect harvest levels and charter fishing practices, total halibut removals would not be affected as any decreases in charter harvests would result in increased commercial harvests....Therefore, none of the proposed alternatives is expected to significantly impact the halibut stock.
From body of the text on page 112, where the early conclusion is repeated in one of its many and multiple ways:
The proposed alternatives address allocation of the Pacific halibut resource between the commercial setline and charter sectors. While the proposed alternatives would affect harvest levels and fishing practices of individuals participating in both sectors, overall halibut removals would not be affected.
And yet despite these repeated declarations, the plan has nothing to do with harvests or conservation or the environment in anyway; the report devotes pages upon pages to analyzing how the non-changes will affect the natural environment. The answer to all of that analysis is, of course: It won't.
That leaves an objective reader wondering if a whole bunch of this plan isn't just about trying to exhaust and discourage the average citizen from participating in the process.
How many average Alaskans, let alone average Americans (the fish offshore are a federal resource belonging to everyone) have the time or energy to sit down and force themselves through 333 pages of acronym-loaded ramblings about the non-effects of the plan on the short-tailed albatross or the life history of Pacific halibut to get to the real issue at hand: economics.
Because at the end of all those pages, this isn't a plan about resource management; this is a plan about dividing up the bucks to be made off a public resource.
Show me the money
As an economic plan, the CSPFTPHCSACSSIIPHCRA2C3A (to shorten the title into one of those catchy NMFS/NPFMC acronyms) falls on its face. When it finally gets around to addressing the key issues at about page 191, it notes the potential new revenue coming to the commercial fishery and then begs off on what happens to the tourism economy of which the charter businesses are a key part.
As to the effects the plan might have on the hundreds of charter-boat operators involved in halibut fishing -- as well as the tourism-dependent communities like Homer, which count in significant part on those charters to draw tourists to town -- the plan says this:
Losses to the charter sector would also arrive, but those losses may not be as proportionately related to the pounds of halibut lost in 2012. Charter revenue is determined by client demand for halibut charter trips. Client demand is related to their expectations of the trip attributes and general economic conditions....
Estimating the loss to the charter operator, let alone all other sectors, is complex. Those losses may more than offset the gains to the commercial sector, but because of the limited information available and the assumptions that would be required, those estimates are not generated.
Translation? "Homer, Seward, Kodiak, Deep Creek, etc., take note. This reallocation might gut the tourism segment of your communities, or it might not. But we can't really be bothered with trying to figure that out."
Instead of trying to sort out the economic pluses and minuses of various management possibilities based on the allocation of the halibut catch, the plan regurgitates some percentages of total catch tossed about by commercial fishermen years ago, and goes from there. No attempt is made to define what the best number would be in terms of economic return to coastal communities or the state of Alaska.
Keith Criddle, an economics professor at Utah State University in 2004, wrote a lengthy study published by the American Fisheries Society that calculated Alaska would stand to benefit most if about 30 percent of the halibut catch went to charter businesses.
The study, "A Simulation-Optimization Model of the North Pacific Commercial and Sport Fisheries for Pacific Halibut," concluded there is a higher "marginal net benefit" for fish caught by the clients of charter businesses than for commercial fish, or in simple language -- a charter-caught fish brings Alaska more bang for the pound than a commercial caught fish.
Do the Council and the Fisheries Service care? It would appear not.
Charter operators growing tired
For the charter industry, the best of the four alternatives -- aside from the legally required "no action" alternative -- in the Fisheries Service plan sets the maximum charter percentage at 21.8 percent for Southeast and 20.7 percent for Southcentral.
The plan the Fisheries Service wants the Council to endorse -- what it calls the "2012 PPA (2008 PA adjusted for allocation and log books)" -- would set the charter maximum at 18.3 percent for Southeast and 17.2 percent for Southcentral. The percentage would shrink as the allowable quota of halibut increased, but with the quota going up the reduced percentage of catch would still result in a larger number of halibut available to charter anglers.
The PPA is the "preliminary preferred alternative" for 2012. The plan is replete with these acronyms seemingly intended to make the package as difficult as possible to understand for the average reader. There are IFQs and CHPs and GAFs and LEPS to help fisheries managers divvy up the CEY set by the IPHC for the FCMZ. Confused? That appears to be the idea.
Charter boat operators tired of all this appear about ready to settle and go with the plan the North Pacific Fisheries Management Council has been trying to shove down their throats since 2004. The catch percentages are a few points higher now than on the last go around, and they vary with stock availability so that if halibut populations -- which are now depressed for reasons unknown -- begin to rebound, the charters will be allowed more fish.
The general public seems generally uninterested in the whole thing.
The plan doesn't affect unguided anglers, who tend to watch fishery decisions the most closely, and the limit on the number of charter operators already in place is probably destined to have as much or more of an effect on charter costs as the allocation in the near future. Some anglers who used to charter have already been priced out of the fishery. About half of the others, at least in Southcentral Alaska, are tourists from other states who might as well be on the moon when it comes to this sort of regulation.
Average folks count on the government to take care of them. The government's attitude here seems to be that charter prices may go up, but so what? And if more commercial halibut becomes available to consumers, that's a good thing, even if they restructuring of the fishery has made halibut so expensive most Americans can't afford it; it's now cheaper to eat steak or salmon.
Damping down tensions
The North Pacific Fisheries Management Council begins meeting in Anchorage on Wednesday. It will likely have a plan hammered out by week's end. The Council's advisory panel and scientific committee are already meeting downtown at the Hilton. Sign-up sheets for those wishing to comment on the latest plans are available at the hotel, according to staff, who warn that you must sign up before any hearings start and should be aware that meetings are sometimes scheduled on "short notice." A draft agenda for the meeting can be found here.
The agenda even includes a list of "commonly used acronyms." There are 38 on that list. Left off are many of those associated with the halibut charter fishery, such as the CSP (catch sharing plan), the CCL (combined catch limit), the TCEY (total constant exploitation yield), the CEY (constant exploitation yield), and probably more. One needs to understand these to grasp what the Council says is the pressing problem and why the government must enact these new regulations to solve it:
The absence of a hard allocation between the commercial longline and chart halibut sectors has resulted in conflicts between sectors and tensions in coastal communities that are dependent on the halibut resource. Unless a mechanism for transfer between sectors is established, the existing environment of instability and conflict will continue. The Council seeks to address this instability while balance the needs of all who depend on the halibut resources for food, sport or livelihood.
This statement might almost make one fearful of riots in Seward and Homer. Don't worry, the feds are here to help.
Their plan is basically to damp down the tensions by taking catch away from the charter fleet and giving it to the commercial fleet, but then allowing the charter fleet to lease some of that public resource back from commercial fishermen if charter anglers are put on a one-fish limit.
The leasing would be what the plan refers to as GAF -- guided angler fish -- which charters would be able to sell to fat-cat clients who have extra cash to spend on top of the standard charter fee. This would solve a problem that existed from 1998 through 2006, according to the NMFS, when charter halibut rates grew "at an annual average rate of 6.8 in Area 2C (Southeast) and 4.1 percent in Area 3A (Southcentral)."
And since 2006? Well, the plan summary makes no mention of the next six years, but if you dig through the plan the numbers are there.
The charter halibut fishery peaked in Southeast in 2008 and has fallen every year since. The catch is now about half of what it was at the peak. The charter halibut fishery in Southcentral topped out at 4 million pounds in 2007 before falling and stabilizing at under 3 million pounds. The catch was 3.4 million in 2008, just over 2.7 million in 2009, just under 2.7 million in 2010, and about 2.8 million in 2011.
Sport fishery biologists who have looked at the catch data since 1995 say it almost appears the charter fishery in particular -- and the sport fishery in general -- is density- and size-dependent, In other words, if the halibut population is large and more halibut are available to be caught, as was the case in the late 1990s and well into the new millennium, more and bigger halibut will get caught and the poundage in the sport catch will go up. But if the halibut are small and there are fewer available, as is now the case, the poundage caught in both the charter and sport fisheries will fall.
All of which is largely irrelevant to the Council, because it's not worried about conservation; it's worried about allocation. And in terms of allocation, its goal is simple: It wants to make sure the charter business stays small in Alaska.
The commercial fishery long ago dictated the magic number -- 20 percent of the catch. It's tiny compared to the allocation off the West Coast, where the non-treaty harvest is split between Washington anglers with 36.6 percent, Oregon and California anglers with 31.7 percent, and the commercial fishery with 31.7 percent.
Commercial fishermen in Alaska live in fear of that sort of allocation developing in the state, and thus have an understandable desire to cap the sport fisheries now.
The NMFS staff would never be so honest as to just come out and say this, however.
Instead, they say their plan is intended to "allow the charter sector to increase its allocation by compensating the commercial section for any future reallocations above the level set at initial allocation by using a market-based approach (Translation: Charters will be required to lease publicly owned fish from commercial fishermen if they want to give anglers a crack at more fish when bag limits fall). (And) the sector allocations are intended to stop the uncompensated de facto reallocation from the commercial sector to the charter sector." (Translation: When the charter harvests were increasing in the late 1990s and early to mid-2000s, they were taking a tiny bite out of the profits of the commercial fishery, and that is unacceptable.)
This is your government at work.
And the crime here is not so much what it wants to do -- the halibut plan might, in fact, be a good one -- but that it tries to hide the black and white of what it wants to do in a salad of confusing words, or what might simply be called a big, stinky pile of bullshit.
Contact Craig Medred at craig(at)alaskadispatch.com
The views expressed here are the writer's own and are not necessarily endorsed by Alaska Dispatch. Alaska Dispatch welcomes a broad range of viewpoints. To submit a piece for consideration, e-mail commentary(at)alaskadispatch.com.