Comment from Kent Hall

I am writing to comment on the proposed rule for a halibut catch sharing plan (CSP) in Alaska. I oppose the CSP as written for the following reasons. 1) The proposed CSP for guided sport anglers and it’s predecessor the guided sport guideline harvest level (GHL) were crafted without compliance to the Magnuson/Stevens Fishery Conservation Act, which provides for “fair and balanced” representation on the fishery management councils. 2) The CSP is based on the guided sport GHL, which had already been exceeded in 2003, the first year of implementation. 3) The guided sport GHL, by design, was not allowed to float with abundance, ie rise when abundance went up and decline as stocks declined. Guided sport anglers were only allowed to share the pain, not the gain. Doesn’t this violate the provisions of the Halibut Act to treat allocations “fair and equitable”? 4) Longline harvesters were rewarded with the harvest of all the increase from 2003 to 2007. Doesn’t this violate the intent of the fair and equitable clause of the Halibut Act? 5) As stocks declined, longline harvesters were given additional quota as economic “buffers”. No such buffer was given nor even considered for the guided sport sector and their GHL. Doesn’t this also violate the intent of the fair and equitable clause? 6) The NMFS arbitrarily converted the GHL from guideline to hard allocation without public pnotice or participation. Doesn’t this violate the NMFS policy for regulation? 7) The guided sport levels of harvest in the proposed rule are significantly lower than the previous levels of the GHL. No reason nor public input was given for this reduction. 8) The proposed rule intends to incorporate a recreational fishery, ie the guided sport fishery for halibut in Alaska, into the commercial longline fishery. It’s like trying to meld apples and oranges. 9) The proposed rule only provides for one method of moving fish from one sector to the other. Longliners will be allowed to lease pounds of f