11 February 2012
Alaska Board of Fisheries
c/o ADFG, Boards Support Div.
PO Box 115826
Juneau, AK 99811
Re: Southeast Finfish Board of Fisheries Meeting
Dear Board of Fisheries Members:
The Southeast Alaska Seiners Association (SEAS), founded in Ketchikan in 1968, represents the entire purse seine fleet in Southeast Alaska and maintains a dues paying membership of 110-125 seiners plus an additional 45-60 local Southeast business members. SEAS would like to submit the following comments on a suite of proposals for the 2012 cycle.
There are 3 areas we'd like to focus on:
USAG-SEAS aggreement. In early January, SEAS and USAG (United SE Gillnetters) submitted an agreement to not subject the Board to proposals that the two groups had submitted that were untoward each other group. SEAS would like to offer an apology to the department staff time and any other inconvenience our withdrawn proposals might have caused. SEAS is pleased that we could arrive at a detente' or compromise with USAG and feel strongly that these proposals were largely allocative in nature and that it should not necessary to spend valuable Board time in light of the agreement between two traditional Board of Fish enemies. The SEAS proposals and USAG proposals are as follows:
SUPPORT WITHDRAWAL of Proposals 289, 290, ,291, 295, 296, 297, 298, 323, 324, 332, 333, 336.
SEAS supports withdrawal of these proposals as part of the SEAS -USAG agreement. These are all SEAS or USAG proposals and both groups have withdrawn their support from all of the above proposals.
RPT Agreement and Proposals:
SEAS supports the RPT agreement going forth, with the proviso that the 6 year terms be reduced to 3 year terms for Deep Inlet and Anita Bay. SEAS also supports all other terms and references and proposals that the RPT references.
Support Proposals 334-335 with the proviso that the sunset is reduced to 3 years.
Other proposals Supported/ Opposed
Support Proposal 341- as is, to stay troll-seine only in the SE Cove SHA. Gunnuk needs to be contributing to the region and is attempting to do so through this proposal
Support Proposal 340 to clean up the problems created by early season contraction of the Anita Bay King Salmon harvest area. This should have been taken out of cycle last year, in our opinion. The time is ripe for correcting this disastrous early season line. The siting of a release site for kings without an opportunity to harvest them for a month or so after they've arrived is just plain poor management practice.
Support Proposal 342 to allow NSRAA to advance 21st century versions of cost recovery that will enable ADFG management flexibility on years of decent northend returns. SEAS believes that prices to fishermen will increase under a fishery without cost recovery.
Support Proposal 288 to allow seiners to have the extra gear on board for emergency rip ups or gear replacement. All other gear groups in Alaska, from Trawlers, gillnetters, longliners, crab pot fishermen, shrimpers and trollers are able to carry spare gear so that they don't lose fishing time. Seiners couldn't deploy both nets, unlike other gear types who are allowed to carry spare gear, but need to be treated fairly. Often a seiner is fishing in Chatham and his spare net is sitting in a warehouse in Ketchikan.
Oppose Proposals 285 and 286 which seek to extend the 58 foot length limit. SEAS has consistently polled on this issue and there is less support for a change than there was last cycle and considerably less support than there was a decade ago. 70% of our members oppose these proposals at this time. While SEAS is sympathetic to changes to increase our fleet's opportunity as evidenced by our support of Proposal 288, we cannot support a change that a supermajority of the fleet opposes.
Thank you for consideration of our comments
Dan Castle, President, SEAS