Comment from Gary Ault

RIN 0648-AK17 Pacific Halibut Fisheries; Guideline Harvest Levels for the Guided Recreational Halibut Fishery. I have owned and operated Inlet Charters in Homer Alaska for the past 22 years and I would like to show my support for keeping the Guideline Harvest Limit in place. As a whole the GHL has been an effective tool for monitoring the guided angler harvest of halibut and setting limits to harvest at times of lower abundance of the halibut resource. Because an increase in sport harvest meant less fish for commercial longliners, this was seen as a reallocation of fish from the commercial fishery to the recreational fishery. In 1997, to monitor the charter sector growth, the Alaska Department of Fish and Game required the registration of charter fishing boats and guides. The following year, a Saltwater Charter Logbook Program was implemented to record the harvest from these boats. As a result A GHL was implemented. In recent years the halibut population numbers have been down and the GHL has triggered reductions in allowable catch for the guided anglers as needed. It has done so in a reasonable, controlled fashion. The GHL should still be the preferred method of treatment for the guided recreational sector as all recreational anglers should have first access rights to this public trust fishery. However, The GHL should be revised to minimize significant economic impacts on a substantial number of small entities, consistent with the objectives of other applicable statutes. I would like to recommend the following: 1. Revise the GHL to include the entire recreational sector (guided and unguided). 2. Revise the GHL stair steps to reflect a combined allocation (guided and unguided) with a fair and equitable allocation based on cuitrrent harvest history in the fishery. 3. Allow for a minimum allocation (floor) that would preserve a one halibut, of any size, daily bag limit.