Comment from Judy Brakel

I have two major concerns with the proposed regulation. 1) Because the IPHC and NPFMC manage halibut only on the basis of very large areas such as 2C and 3A, the proposed leasing of commercial IFQ by charter LEP holders will very likely result in leases gravitating to a few 'hot spots' within those large regulatory areas. This will lead to over-harvests in those areas until they are no longer places with good populations of halibut. The current regulatory system has no means of preventing local depletions. For example, the Icy Strait-Glacier Bay-Cross Sound area has especially large halibut and is drawing more and more charter and private sport fishers. I am concerned that this area of abundance will soon be depleted and there seems to be no regulatory strategies that we can advocate to prevent depletion. 2) The distinction between charter and private sport fishers has many holes in it. As a NMFS enforcement person acknowledged this spring, 'There are a thousand holes in these regulations.' These are mostly between what is charter and what is sport fishing. The subregion described above has an especially large number of "self-guided" fishing lodge clients and other operations that take advantage of the situation. One such lodge has 60 clients per week. Another just started a "self-guided" component, and a new (or re-organized) lodge advertised itself as a self-guided operation this year. Already the "private sport fishing" sector's catch was almost as large as that of the charter component, and the two together are as large as the the commercial catch in the subregion described above. The Catch Sharing Plan does nothing to reduce this problem and will likely exacerbate it. One start on reducing this problem would be for the NPFMC to adopt the same definition of "guided fishing" as the definition used by the State of Alaska.