Comment from Luke Fanning

Dear NMFS, We are writing to request that the proposed changes for increased observer coverage in the halibut fleet permanently exempt small vessels less than 36 feet. Where we fish in the protected waters of SE Alaska, it is not practical to employ observers on the small boat fleet. For example, our vessel is 28' long, with a cabin that can barely sleep two (myself and a deck hand). We use a bucket for a head and we eat all our food cold. It's a lot like camping, and there is physically no room to support an additional body. Because of our size, and the drastic reductions in halibut quota in recent years, it is neither practical, nor statistically valuable to collect information from such a small operation. Our quota has been cut back so far, that we now only make one halibut trip per year. The use of a video monitoring system would not be much better, as it would require us to invest in a complex video monitoring system (and the electrical capacity to install it). Effectively, this could force us out of the fishery, without generating any significant data whatsoever. Finally, there are many people who still fish their small halibut quota shares out of skiffs, which clearly can not support an observer. For these reasons, we request that NMFS employ a common sense approach to monitoring this fleet that permanently exempts the small boat fleet from the observer requirements. If that is not possible, please allow the use of observation skiffs to observe our operation, which would not require us to support human or electronic observers on board. We just don't have the space or machinery in place to support observations like the larger boats. Sincerely, Luke and Christine Fanning F/V Kelsie Dawn Juneau, Alaska