Comment from David Goldstein, PWS Eco-Charters

Charter operators simply provide access and advice for halibut sport fishers. They do not catch fish. Put into basic words, if rules and regulations are needed for the sport/recreational halibut fishery, they should be applied uniformly across the entire sector...not to a portion of it. Applying stringent rules and regulations to one part of a sector just entices those affected to come up with ways to be defined in a less regulated part of that sector (bare boat charters, not registering as guides or charters, fishing for other species and "incidentally" catching halibut, etc., etc.). I believe this makes enforcement extremely difficult and costly...and just encourages innovative ways of "getting around the rules and regulations", thus defeating the implementation of the rules and regulations themselves. As for apportionment of the resource, there is a basic flaw in the present system. This ripples downstream and creates problems such as the proposed "one fish limit" in 2C. Again, simply put, the problem is that the present allocation system is rigid and basically unable to adjust allocation numbers to different sectors as demand rises and falls. Instead, reference in the halibut sport fishery is to a GHL that is woefully out of date and based on facts from years ago that have changed. The net result is that there is an increased demand for the resource and a higher economic impact from that resource.