Comment from David Goldstein

The Charter Halibut Permit program is flawed. There has been no obvious attempt to fix the problems. Essentially appeals have been limited to the issuance or non-issuance of a permit...with no course to appeal client endorsement numbers. This is flat wrong. Appeals for any aspect of the program need to be allowed. I have a 5 client endorsement for my CHP, but using a convoluted approach, can have all 12 clients I can legally carry catch and retain their limits of halibut. I shouldn't have to waste their time, my fuel, go through considerable paperwork and inconvenience to make this happen. I have a legitimate reason for requesting a change in my endorsement number from 5 to what my boat can carry, 12. However, unless I go to court and challenge NMFS's actions, there is currently no obvious way to easily remedy NMFS's error. The CHP program was obviously put together by people who don't know the charter business. Hence, several other serious problems have surfaced. None have been addressed. NMFS seems content to implement programs with obvious problems...then move on to other things...and NOT fix the problems! This is patently wrong. Simply put, there needs to be a review of the CHP regulation to make it fair and responsive to fixing problems. Please see the attached file... Thanks for the time to comment, David Goldstein PWS Eco-Charters