Friday, October 3, 2014

Community protection in the face of more rationalized fisheries.

The North Pacific Fishery Management Council meets October 8 – 14 in Anchorage, in part to discuss the proposed Gulf of Alaska Trawl Bycatch Management program that would establish catch shares for the trawl caught pollock and cod in federal waters 3 – 200 miles offshore Alaska. Any program to rationalize these fisheries must be inclusive, taking into account the dependency on the fishery and investments made by communities, fishermen, vessel owners and local seafood processors, while maintaining opportunity for future generations.

According to the NPFMC’s Ecosystem Based Fishery Management approach, coastal community protections will be included in any limited entry programs such as catch share programs. Fishing communities are specifically mentioned in the Council’s Ecosystem vision and value statements. National Standard (8) for Fishery Conservation and Management states that any fishery management measures must provide for fishing communities sustained participation in the fishery and to minimize adverse economic impacts on communities.

One complaint with this proposed bycatch management program is that it seems to be more about allocation of the fishing resource and much less about reducing bycatch of prohibited species halibut and Chinook salmon. The Aleutians East Borough is opposed to options in the proposal to allocate target species other than cod or pollock, allocations that would not result in bycatch reductions and would lock out future opportunities for local fishermen.

The Council is looking at several options to mitigate negative impacts from the proposed program including vessel use caps and processor caps to limit consolidation in the fishery. The plan also considers regionalized delivery, active participation requirements and other options to protect communities. Setting aside some amount of quota for adaptive management or for a Community Fishing Association is also still on the table.

Western Gulf pollock fishermen are working on solutions and have recently developed a voluntary catch plan, that equally divides the quota and available bycatch between the vessels signed up to fish. Some fishermen continue to ask for a later opening date for the Pacific cod trawl season that they say would result in better-sized fish and less bycatch. Experience is the best answer to the bycatch problem according to one WGOA fisherman, noting that outside vessels new to the area end up catching a large portion of the bycatch. There are mixed feelings among fishermen about a full-blown catch share plan for the trawl fisheries.

The Borough Assembly set forth nine goals in a January 2013 Resolution, and in a recent letter from Mayor Stanley Mack for the Assembly to the NPFMC, reaffirmed support of these goals for fisheries management programs in the Gulf of Alaska:

1. Provide effective controls of prohibited species catch and provide for balanced and sustainable fisheries and quality seafood products.

2. Maintain or increase target fishery landings and revenues to the Borough and AEB communities.

3. Maintain or increase employment opportunities for vessel crews, processing workers and support industries.

4. Provide increased opportunities for value-added processing.

5. Maintain entry level opportunities for fishermen.

6. Maintain opportunities for processors to enter the fishery.

7. Minimize adverse economic impacts of consolidation of the harvesting or processing sectors.

8. Encourage local participation on harvesting vessels and use of fishing privileges.

9. Maintain the economic strength and vitality of AEB communities.

The Aleutians East Borough stands for creating opportunity in our communities, one reason we continue to push for new state fisheries, like the Dutch Harbor Sub-district fishery. This new state-waters Pacific cod fishery in the Bering Sea from mid-Unalaska Island to mid-Unimak Island has provided increased opportunity for local fishermen, without harm to other fishers. Hopefully the Alaska Board of Fisheries will elect to expand the guideline harvest level and fishing area for the Dutch Harbor Sub-district fishery. The Board’s Walleye Pollock Workgroup meets October 6th in Anchorage to look at the merits of a proposal to establish a state-waters pollock fishery.

The AEB believes fishery management at all levels should be about providing more opportunity, for processors, fishermen and support industries. Gains in efficiency must be balanced with continued growth and prosperity. Sustainable fisheries and sustainable local fishing communities go hand in hand and as the current bycatch management proposal takes shape, it must include protections for communities, fishermen, processors and future generations.

Tuesday, September 16, 2014

Observer Program Changes for 2015

The National Marine Fisheries Service (NMFS) Annual Deployment Plan (ADP) for the Observer program, reviewed each October by the North Pacific Fishery Management Council (NPFMC), calls for significant changes for small vessel participants in the Observer program.

NMFS proposes to use the trip-selection pool only to assign observers to vessels and will no longer use  the vessel-selection method for smaller vessels in 2015.  Since only single trips will be selected, the proposed method is expected to reduce the impact on smaller vessels.

The proposal calls for two categories within the trip-selection pool.  The small vessel trip-selection pool is comprised of catcher vessels (CV) that are fishing hook-and-line or pot gear and are greater than or equal to 40 ft, but less than 57.5 ft in length.  These vessels were in the “vessel-selection” pool for 2013 & 2014.  The other category, the large vessel trip-selection pool is made up of three classes of vessels: 1) all CVs fishing trawl gear, 2) CVs fishing hook-and-line or pot gear that are also greater than or equal to 57.5 ft, and 3) catcher-processor vessels exempted from full coverage requirements.  These vessels were in the “trip-selection” pool for 2013 and 2014.

The small vessel trip-selection pool vessels are likely to be selected for an observer 12% of trips compared to a 24% probability for the large vessel trip-selection participants. The selection rate for the former vessel-selection pool is the same as 2014, but large vessel trip-selection vessels will see a 50% increase in coverage rates compared to 2014.

Conditional releases will not be granted to the large vessel trip-selection pool vessels in 2015, and only granted to vessels in the small vessel trip-selection pool that do not have sufficient life-raft capacity to accommodate an observer.

Vessels selected to participate in Electronic Monitoring (EM) Cooperative Research will be in the no selection pool, not subject to observer coverage, while participating in such research.

The Observer Advisory Committee to the NPFMC will review the ADP at a meeting this week in Seattle.  The draft ADP is available through a link under item C1 of the NPFMC agenda, found here:  http://legistar2.granicus.com/npfmc/meetings/2014/10/894_A_North_Pacific_Council_14-10-06_Meeting_Agenda.pdf
.

Tuesday, March 12, 2013

Salmon forecasts for Alaska 2013

ADF&G Salmon Forecasts for 2013

The 2013 estimated forecast for the South Alaska Peninsula pink salmon total run is 7.3 million fish, and the harvest is expected to be 5.7 million, which is considered an average harvest by ADF&G.  A harvest of less than 5 million pink salmon for the region is considered weak or poor and 5 to 7. 2 million harvest is considered average.  More than 7.2 million is a strong harvest and a harvest of greater than 9.3 million pinks is described as excellent.


The 2013 Nelson River estimated total run of sockeye is forecast at 327,000. That’s below the 10-year average of 462,000, but above the 2012 total run result of approximately 220,000 sockeye.  The Bear Lake late run sockeye is estimated at a total run of 328,000 for 2013. Again, that is below the 10-year average of 451,000, but well above the 2012 run of 116,000.


The total estimated run for Bristol Bay Sockeye is 26,030,000 fish, which would result in a total commercial harvest of 17.53 million sockeye; 16.59 million in Bristol Bay and 940,000 in the South Peninsula area.


Chignik has a total estimated run 3,814,000 sockeye, 2.767 million in the early Black Lake run and 1.047 in the late Chignik Lake run.  A total commercial harvest for Chignik sockeye expected to be 3.214 million; 2.581 million for Chignik, 452,000 for the Cape Ignik Section and 181,000 in the Southeastern District Mainland area.


Other forecasts for salmon around the state are relatively stable, the A-Y-K fall chum salmon forecast estimated total run is 1,043,000 and the Copper River Sockeye total run is expected to be 1.84 million.  Upper Cook Inlet sockeye total run is forecast to be 6.7 million.  Pink runs look healthy statewide: Prince William Sound total pink run looks to be 6.2 million, the total Kodiak Management Area pink harvest is expected at 17 million, and the Southeast Alaska pink salmon harvest is expected to be excellent in 2013 at 54 million fish.



Information compiled from: 
ADFG Special Publication 13-03, February 2013, Run Forecasts and Harvest Projections for 2013 Alaska Salmon Fisheries and Review of the 2012 Season; 

Thursday, February 7, 2013

Governor Appoints Reed Morisky of Fairbanks to Board of Fisheries

Reed Morisky of Fairbanks has been appointed to the Alaska Board of Fisheries. Reed's appointment if effective immediately and his seat expires June 30, 2014. Here's the link to the press release from the Governor's office: http://gov.alaska.gov/parnell/press-room/full-press-release.html?pr=6370

Wednesday, January 30, 2013

Fisheries Update

January GOA Fisheries:

Directed fishing for Pacific cod using hook and line, pot and jig gear, opened January 1, 2013, and trawl gear cod fishing opened on January 20th. The 2013 Gulf-wide total allowable catch (TAC) for cod is 60,600 metric tons (mt) down from 65,700 mt in 2012. In the Western Gulf, (Area 610) the A-season allocation for Pacific cod using pot gear is 4,095 mt. Twenty-eight vessels have reported catch so far. NMFS closed the WGOA pot gear Pacific cod fishery at noon on Monday, January 28th.

Directed fishing for pollock using trawl gear also opened January 20, 2013 in the Gulf of Alaska. So far, six vessels have reported pollock catch in Area 610. Only two vessels have reported pollock catch in Area 620. The A season pollock allocation is 4,292 mt for Area 610; 16,433 mt for Area 620; and 5,998 mt for Area 630. NMFS ended directed fishing for pollock in Area 630 on January 22, 2013 to prevent the fleet from exceeding the 630 A-season allowance.

The state Tanner crab fishery opened at noon on January 15th. The Eastern section of the South Peninsula District had a guideline harvest level (GHL) of 230,000 pounds. The Western section and the Chignik District were closed. The Kodiak district GHL was set at 660,000 lbs. In the South Peninsula District - Eastern section, all waters between 161° and 162° west longitude (Pavlof Bay and Jude Island) closed at noon January 16th, and Beaver, Balboa & Stepovak Bays (all waters north of 55° 20’ N) closed at 6 p.m. on January 22nd. The remaining open waters of the Eastern Section of the South Peninsula District closed to Tanner crab fishing at 6:00 p.m. on Saturday, January 26.

Halibut:

The International Pacific Halibut Commission (IPHC) annual meeting was held last week in Victoria, BC, and most sessions were available via internet / webinar. Last Friday, the Commission adopted the 2013 Pacific halibut catch limits by area. The 2013 limits are a reduction of 7% for all areas combined, and a reduction of 15% for Area 3B.

IPHC • 2012 Catch Limits • 2013 Catch Limit • Percent change •

Area 2A • 989,000 pounds • 990,000 pounds • less than 1% change •
Area 2B • 7,038,000 pounds • 7,038,000 pounds • zero change •
Area 2C • 2,565,000 pounds • 2,970,000 pounds • 16% increase •
Area 3A • 11,918,000 pounds • 11,030,000 pounds • 7% reduction •
Area 3B • 5,070,000 pounds • 4,290,000 pounds • 15% reduction •
Area 4A • 1,567,000 pounds • 1,330,000 pounds • 15% reduction •
Area 4B • 1,869,000 pounds • 1,450,000 pounds • 22% reduction •
Areas 4CDE • 2,465,000 pounds • 1,930,000 pounds • 22% reduction •
Total • 33,480,000 pounds • 31,028,000 pounds • 7% reduction •

Dr. James Balsiger was elected Commission Chair for 2013/2014. The IPHC is currently seeking nominations for 2 vacant U.S. seats on the Commission. Details on the IPHC nominations can be found at: http://alaskafisheries.noaa.gov/newsreleases/2013
/iphc011513.htm

Salmon:

The next Board of Fisheries meeting runs February 26th – March 4th at the Sheraton Hotel in Anchorage. At this meeting, the Board will take up proposals dealing with the Alaska Peninsula / Aleutian Islands (AP/AI) salmon fisheries. The Board met in Naknek in December 2012 to discuss Bristol Bay salmon. Earlier this month, the Board met in Anchorage to discuss Arctic-Yukon-Kuskokwim (AYK) salmon proposals. At each Board meeting since the initial release of the Western Alaska Salmon Stock Identification Program (WASSIP) reports from October, the Board has received additional presentations on the salmon genetic study. At the AYK salmon meeting this month, the department also showcased large posters that make the genetic study information somewhat easier to understand. Many AEB fishermen who have been reading the WASSIP reports recently and the just-released Southeastern District Mainland (SEDM) genetic study, may gain insight from viewing the new WASSIP posters. They are now kept at the Anchorage Department of Fish and Game office at 333 Raspberry Road, and are available as PDF documents at: http://www.adfg.alaska.gov/index.cfm?adfg=wassip.posters

The WASSIP reports are available at:
http://www.adfg.alaska.gov/index.cfm?adfg=wassip.reports

The SEDM study can be found at:
http://www.adfg.alaska.gov/FedAidPDFs/SP12-31.pdf

Public comments to the Board of Fisheries submitted by February 12th will be included with the Board AP/AI meeting materials. Comments should include the specific proposal number addressed and the comment author’s name.

Comments can be faxed by 2/12/13 to FAX (907) 465-6094.

NPFMC:

The AEB is closely monitoring two items on the February agenda of the North Pacific Fishery Management Council (NPFMC) meeting in Portland. Agenda item C-3(c) is a placeholder for Western Gulf of Alaska (WGOA) trawl issues, following a new discussion paper on Central Gulf Trawl Catch shares: http://www.fakr.noaa.gov/npfmc/PDFdocuments/catch_shares/CGOATrawlCatchShare213.pdf

AEB fishermen are planning to present ideas on new management regimes for the WGOA to the Council in Portland. The AEB Assembly passed Resolution 13-16 in January to provide comments to the NPFMC in support of the following goals for fisheries management in the WGOA and CGOA:

AEB Goals for Fisheries Management Programs in the Central and Western Gulf of Alaska:

• Provide effective controls of prohibited species catch and provide for balanced and sustainable fisheries and quality seafood products.
• Maintain or increase target fishery landings and revenues to the Borough and AEB communities.
• Maintain or increase employment opportunities for vessel crews, processing workers and support industries.
• Provide increased opportunities for value-added processing.
• Maintain entry-level opportunities for fishermen.
• Maintain opportunities for processors to enter the fishery.
• Minimize adverse economic impacts of consolidation of the harvesting or processing sectors.
• Encourage local participation on harvesting vessels and use of fishing privileges.
• Maintain the economic strength and vitality of AEB communities.

BSAI Crab ROFR:

Another important NPFMC February agenda item is C-4(a) Final Action on Bering Sea Aleutian Islands (BSAI) Crab Rights of First Refusal (ROFR). ROFR’s are part of the community protection measures in the Crab Rationalization program, giving eligible crab communities the right to purchase the right to process crab, in the event of a sale by the company owning those rights. However, these measures have been criticized as weak protection for communities since implementation of the program in 2005. Six actions regarding the sale of processing quota share (PQS) are being considered in the package:

Action 1: Increase the ROFR holder’s amount of time to exercise the right.
Action 2: Remove provisions under which the ROFR lapses if the PQS is used outside the community.
Action 3: Apply the ROFR to only the PQS, instead of all of a seafood processor’s assets.
Action 4: Require community consent to move quota outside the community.
Action 5: Require additional notices by the PQS holder to the ROFR holder and to NMFS.
Action 6: Issuance of newly created Bristol Bay King Crab PQS, (0.55 % of the PQS in that fishery) to Aleutia Corporation.

The NPFMC meetings are streamed live at a link found at:
http://www.fakr.noaa.gov/npfmc/ .

Gulf of Alaska Coastal Communities Coalition

GOAC3 had their Annual Membership meeting and a Board of Directors meeting on Tuesday, January 29th. During the meeting, the group submitted comments to the NPFMC that the GOA Trawl Catch Shares discussion should look at ‘bycatch only shares’ as a way to provide more tools to harvesters and to mitigate community concerns about fleet consolidation.

The Board agreed to send letters to Governor Parnell supporting the reappointment of Sam Cotten and Duncan Fields to the NPFMC for a final term. The Board also named AEB Mayor Stanley Mack to the GOAC3 Executive Committee.

Thursday, December 27, 2012

NMFS Provides Presentation to AEB Fishermen on New Observer Program

The new year is ringing in an expanded observer program for commercial fishermen in previously unobserved fisheries off Alaska. These fisheries pertain to all sectors of the groundfish fishery, including vessels less than 60 feet length overall and the commercial halibut sector. However, it’s not surprising that there’s still confusion surrounding the restructured federal fisheries program. NMFS has hosted a number of outreach workshops to help alleviate some of the concerns and questions that fishermen, processors and industry representatives have.

Earlier this month, NMFS observer chief Martin Loefflad conducted a presentation at the North Pacific Fishery Management Council. Last month, Loefflad and Glen Campbell, both from NMFS, made a similar presentation at the AEB Fishermen’s Meeting in Seattle. Loefflad began by providing the nuts and bolts of how the program will operate.

The program is basically split into two parts. One part (full coverage) applies to large catcher processors, AFA catcher vessels, and other large boats. They would be required to have 100 percent observer coverage. They have an observer on board all the time.

The other group is partial coverage. The costs of this program are going to be covered by the federal government the first year. After that, costs will be paid by a fee that will be put in place for processors to pay. Small vessel operators will pay into that program.

Two groups will fall under the partial coverage program: trip selection and vessel selection.

Trip selection applies to all catcher vessels of any length fishing with trawl gear and to hook-and-line and pot gear vessels that are greater than or equal to 57 ½ feet in length. About 15 percent of a vessel operator’s trips will be observed under trip selection. Loefflad said fishermen who are part of the trip selection group can log in online or on the phone beforehand. In addition, they can log up to three trips ahead of time. These trips can be edited as changes occur.

Campbell said with the online system, fishermen will have a username and password.

“So you’ll need to log when your expected leave date is, what port you think you’re leaving from, and your expected return date,” he said. “These dates are kind of place holders if you’re essentially picked for observer coverage.”

Campbell said an email will go to the observer provider, letting the contractor know that a specific fisherman has been picked for observer coverage. Communication between the provider and vessel operator can begin at that point.

“So let’s say you’re picked for an observer, and you’re leaving on the first. But weather comes up,” Campbell added. “The observer, by regulation, has to stay by your boat for at least 48 hours before they can be released. So you actually don’t need to realize that trip until the third. Now if the trip is not realized on the third, you can simply call the provider. The provider will cancel that trip, and then the next logged trip will automatically be observed.”

Loefflad said about one thousand letters went out to vessel owners. About 500 were identified as falling under the trip selection observation program.

“So what if you operate a vessel but you don’t own the boat? The vessel owner needs to either go on the site or call the call center and they need to create what we call ‘captains accounts’”, said Campbell. “The captain can then log his own trip. But the registered owner is ultimately responsible for everything that happens with that vessel. So the owner can log trips or he can create accounts for all his captains.”

One of the biggest questions is what is a trip? According to Loefflad, there are two different definitions. One is for fishermen delivering to tenders. The other is for fishermen who are not delivering to tenders (to a shoreside processors instead.

“So if you’re not delivering to a tender, a trip is defined as when you leave the port and return to port to make a delivery. That’s a trip,” he said. “Not everyone will get picked to have an observer on board. But if you do and you’re delivering to tenders, you just keep that observer on until you get back to port.”

“If you make at least one delivery to a tender and then return to a port that has a shoreside processor,” Campbell added, “that’s a trip.”

The vessel selection pool applies to catcher vessels, fishing with hook-and-line and pot gear that are less than 57 1/2 feet in length and, for the first year, greater than or equal to 40 feet in length. Vessel owners in this pool will not be required to log trips. However, a handful of vessels, randomly selected by NMFS, will be required to take observers for every groundfish or halibut fishing trip that occurs during a specified two-month period. Owners of these selected vessels will be contacted by NMFS at least 30 days in advance of the two-month period.

Every year in June, NMFS is required to present a report to the North Pacific Fishery Management Council to discuss what officials from the observer program have learned. Loefflad says at that point, the Council can start providing input as to how NMFS can implement changes to make the program work more efficiently in future years.

“We are committed to making this program work,” said Loefflad, “so there is some flexibility built into the program.”

Contact Information: North Pacific Groundfish Observer Program – Partial Coverage:

NOAA Data Technician Office

(800) 304-4846, option #1

(907) 586-7163

AIS, Inc. (Observer Provider)

(855) 247-6746 (855-AIS-NPGO)

Observer Program (Seattle Office)

(206) 526-4195 (Martin Loefflad, Director)

(206) 526-4194 (Patti Nelson, Deputy Director)

Observer Declare and Deploy System (ODDS)

http://odds.afsc.noaa.gov

ODDS support

Odds.help@noaa.gov

What Should Rationalization of Alaska Trawl Fisheries in the Western Gulf Look Like?

In February, the North Pacific Fishery Management Council is expecting to hear more from Western Gulf (WG) fishermen interested in being included in a proposed catch share program (a.k.a. rationalization or limited access program) for the Gulf of Alaska trawl fisheries. So far, the Council has only considered tailoring the program for the Central Gulf (CG) trawl fisheries. However, during the December meeting, fishermen who take part in the Western Gulf trawl fishery testified that they would like that particular fishery to be included in the proposed catch share program. They also requested that a control date be included to prevent a race for fishing history. The Council suggested that supporters put forward options that would be appropriate for the Western Gulf fisheries at the February Council meeting.

The proposed catch share program was born out of bycatch limits on halibut and Chinook salmon. Currently, there are hard caps on both of these species during the directed effort on pollock and groundfish. Once these limits (hard caps) are reached, fishing must come to a grinding halt. Kodiak trawlers are concerned they that they’ll have a tough time harvesting their allowable catch as a result of these limits, so they advocated for a new management program. That system could give ownership rights to vessel owners and skippers based on their participation history.

Many fishermen and those in the industry are worried that if one part of the Gulf is rationalized (the Central Gulf – Area 620 and 630), it will have consequences for the remaining part (the Western Gulf – Area 610). For example, if just the Central Gulf is rationalized, Central Gulf quota holders could fish the open access fishery (Western Gulf) until that total allowable catch (TAC) is reached and then go back to the Central Gulf to fish their individual quota. That means Western Gulf fishermen would then have to compete with fishermen who normally would be in the Central Gulf at that time. One possible option would be implementing sideboards. However, that isn’t an easy solution either. The fleet would be limited to their history in the Western Gulf. So if the Central Gulf fleet typically caught 20% of the Western Gulf TAC, then once that figure was reached, those fishermen would have to stop fishing in the Western Gulf. Other scenarios to consider include fishermen who have history in both the Central Gulf and the Western Gulf. They could then be compelled to either give up their CG quota or be restricted to the sideboard limit. If the WG were to be rationalized at a later date, some of the decisions made may not be reversible.

Other considerations include how processors and fishermen would be affected, depending on where they are located. There are about 7 processors in Kodiak. In the Aleutians East Borough (AEB), located in the Western Gulf, there are three (one in King Cove and another processor based in Sand Point and Akutan. A third processor is in False Pass). Approximately 75 percent of the Central Gulf fleet is non-resident. At least half of the participants in the Western Gulf are residents. A concern of the processors is that in the Central Gulf, if the fish are controlled by a co-op, the fishermen end up getting all or almost all of the profit. The processors in Kodiak, on the other hand, have invested in plants, have resident employees, pay taxes and contribute to the local economy. For that reason, without some protections, some plants feel that they could go belly up and those that make it may receive just enough to stay in the game.

Other major differences concern the fleets. The Western Gulf is home to a local fleet with 3 – 5 vessels from King Cove and 10 – 15 from Sand Point. There are 98 trawl LLPs that are eligible to fish in the Western Gulf. Recent activity shows an average of about 18 vessels under 60’, 3 – 8 vessels over 60’ and one vessel over 125’ (in 2008 only). In this case, the major difference between the CG and the WG is that most of the participating vessels and a greater percentage of the participating vessels are locally owned or at least home ported in WG communities.

Elements of the program include:

1. Duration. How long will the program last? Limited access privileges can be removed because they do not award any rights of compensation and don’t create any ownership of a fish before it’s caught. If there is a specific expiration date, people can plan around that. In addition, the Council could make changes without disruption.

2. Which species would be included? It has been assumed that pollock, cod and other groundfish will be included, but that isn’t set in stone. Quota would most likely be issued as a percentage of the TAC or whatever species are included.

3. Eligibility to acquire/hold privileges. The law restricts shares to be acquired or held by persons who substantially participate in the fishery. How the term “substantially participate” is defined is up to the Council. Furthermore, the term “person” may include corporations, fishing communities, regional fishing associations, partnerships, CQEs and individuals, and it must be defined. Another issue that must be resolved is whether processors should be allowed to hold privileges.

4. Transferability. To whom can you transfer and what is transferable? That issue still needs to be resolved. It’s still not clear whether leasing will be allowed. Decisions surrounding any limits on transferability will be made after assessing feedback from stakeholders and goals/objectives that are put in place. Some economists have suggested that there be no limits in order to allow the most flexibility which would end up providing maximum economic performance of the fishery. Others recommend that no transferability be allowed because that would benefit individuals rather than the general public. A middle ground may include some limits that preclude major changes to community structure, excessive consolidation or other social disruptions.

5. Initial allocations. Initial allocations are subject to legal restrictions. Federal law, specifically the Magnuson-Stevens Act (MSA), provided standards for fair and equitable initial allocations, including:

a) Current and historical harvests

b) Employment in the harvesting and processing sectors

c) Investments in and dependence upon the fishery

d) The current and historical participation of fishing communities

e) Cultural and social framework of the fishery

f) Help, where appropriate, with entry-level opportunities

g) Prevent excessive share holdings

There are many other issues that must be taken into consideration as this process moves forward, including:

• State waters. Presently, a large percentage of pollock is taken inside 3 miles and is under the jurisdiction of the State of Alaska. The same is true for Pacific cod. What isn’t clear yet is whether the state will speak up for that jurisdiction.

• Community quotas: There is some interest in quota allocation to communities similar to the CDQ program. Those opposing it say there’s too little quota to get the desired results. In addition, they say it would hurt local fishermen who have historically harvested the fish. Those in favor say that some communities can only survive with the community quotas, and they deserve consideration when conferring fishing rights. Others have suggested that some level of community ownership could prevent quota from leaving the community.

The Council is in the beginning stages on this proposal and welcomes suggestions and feedback from all interested parties.