Trident response to Kodiak Daily Mirror tendering article

Reprinted from the Kodiak Daily Mirror
by Paul Padgett/Trident Seafoods Corp.
Apr 15, 2013
To the Editor:

You recently published an article in the Kodiak Daily Mirror titled “Kodiak acts on tender issue." Please allow me to present a different perspective.

Trident tendered approximately 7 million pounds of pollock from GOA area 620 to our Akutan plant. This fish was caught by vessels that regularly fish for Trident out of Kodiak and Sand Point. That amount represents about one and a half processing days for the Kodiak processing community, not the eight to 10 days claimed. One and a half days also does not add up to “millions” in lost wages and tax revenues. It is also interesting to note that the seven million pounds is a small fraction of the hundreds of millions pounds landed annually in Kodiak and the value of that 7 million pounds is an even smaller fraction of the value of all fish landed annually in Kodiak. The event is being viewed disproportionally to its actual impact.

Trident also purchased approximately 7 million pounds of cod out of the very western end of GOA area 620 and processed it in our Sand Point plant. The fish was caught within 50 miles of Sand Point and well over 300 miles from the town of Kodiak. One hundred percent of this fish was caught by Sand Point fishing vessels that regularly fish for Trident, and historically have delivered fish from that area to Sand Point. It seems somewhat naïve to expect that fish would be delivered to Kodiak or to assume that the fish belongs to Kodiak. It is also important to note that the area 620 trawl cod fishery had been open since Jan. 20, affording ample opportunity for Kodiak based vessels to participate and take the quota. However, a number of Kodiak trawlers, with Bering Sea LLPs, elected to fish cod and/or pollock in the Bering Sea during January and February. Many of these vessels have markets with Trident in Akutan (and also Sand Point) and we have always welcomed their participation. The Sand Point vessels did not start targeting area 620 cod until around March 1.

Finally, in an Olympic fishery like GOA pollock, Trident strives to maximize the fishing opportunities for its fleets. Sometimes, this means moving fish from one area to another as, for example, PWS salmon being run back to Kodiak for processing due to a bigger than anticipated return. Cordova fishermen and residents have no objection to this, and, unlike the individual quoted in your article, no one remotely suggests the action is “theft”.

Thank you for the opportunity to comment.

Paul Padgett

Trident Seafoods Corp.

Kodiak pollock, cod processors say Trident's western Alaska operations diverting jobs, revenues

 [Kodiak Daily Mirror] by James Brooks - April 1, 2013

A change in the way pollock and cod are processed in the Gulf of Alaska could end up costing Kodiak millions in lost tax revenue.  On Tuesday night, Alaska Pacific Seafoods plant manager Matt Moir told the Kodiak City Council that fishermen in the recent pollock ‘B' season skipped their traditional deliveries to Kodiak in favor of dropping off fish at tenders headed west.  “Fourteen million pounds of seafood that normally gets delivered to this town went west to Akutan and Sand Point,” Moir told the council.  That seafood included 17 percent of Kodiak's normal allotment of pollock from the area and 41 percent of Kodiak's trawl-caught cod. Moir estimated that without the seafood, he reduced his processing — and thus, hiring — time by a week to 10 days.

“This is activity that is not normal in this fishery,” said Josh Keaton, who monitors the Gulf of Alaska for the National Marine Fisheries Service.  The fisheries service divides the Gulf into different areas for ease of regulation. The area in question, 620, stretches from the south end of Kodiak Island west to a line east of the Shumagin Islands.

Most of the fish in area 620 are caught in the area's eastern third by Kodiak fishermen and are taken back to Kodiak. The quota for the area is used mainly by these fishermen, though historically a few smaller fishing boats have taken fish from the west side of the area and delivered it to places like Sand Point.

“In the past, tenders have not been used in the 620 pollock fishery, except by smaller vessels that have come from the communities out west,” Keaton said.  This year, fishermen bucked that trend.  Instead of delivering to Kodiak, big boats took their fish west, to tenders that then ferried the cargo to western processing plants. Normally, that doesn't make sense. Tenders are prohibited east of 157 degrees west longitude, a measure designed to protect Kodiak deliveries. The trip west is longer, which means fish are in worse shape when they reach shore.

Keaton declined to say which fishermen were choosing to skip Kodiak, citing confidentiality rules. Industry experts, however, identified Trident Seafoods as the main source of both the fishermen and the tenders delivering west.

Trident Seafoods spokesman Joe Plesha said Trident's shift was driven by interest from independent fishermen who sell fish to the company.  “We've actually lost boats sometimes because we don't have the capacity to handle the boats that fish for us,” he said. “This is a way for us to frankly provide a market for those fishermen.”

The fishermen in question mostly operate large boats that travel to different fisheries as far removed as the Bering Sea and the Pacific Northwest. This year, many of those independents decided to fish for pollock near Kodiak. “It was somewhat unique in that respect because they were there all at once,” he said. “They all happened to want to participate in the pollock fishery that happened a couple-three weeks ago.”

According to Trident-provided information, the company's Star of Kodiak seafood processing plant can take in 1.1 million pounds of pollock per day. Its Sand Point plant can take in 1.2 million pounds of pollock a day, and its Akutan plant can process 3 million pounds of seafood daily.  “We couldn't do all of that production in Kodiak,” Plesha said.

In past years, pollock fishermen near Kodiak have formed voluntary cooperatives to slow the pollock season and space out deliveries to Kodiak processors. In the cooperatives, fishermen divided pollock quota among themselves, reducing the time pressure to get fish to dock.

In the past two years, however, the federal North Pacific Fishery Management Council has begun debating a catch share strategy that would formally assign individual quotas to fishermen. In other fisheries, those quotas have been based on a fisherman's history in the region.

Keaton said that if fishermen this year were trying to establish a history, it's no sure thing. Last year, the North Pacific council set a cutoff date after which no history would be considered in the drafting of a new program.
If a fisherman is trying to establish a history now, “it's kind of a long shot; there's no guarantee,” Keaton said.

But with millions of dollars on the line, even a long shot could pay off if the cutoff date slips. If some fishermen think it's worth the gamble, the city of Kodiak will be caught in the middle.

“There's a lot of people in Kodiak who are hot over this,” Keaton said. “It's tax revenue to the city of Kodiak, it's jobs.”

Contact Mirror editor James Brooks at editor@kodiakdailymirror.com.  © Kodiak Daily Mirror 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; 

http://www.adfg.alaska.gov/FedAidPDFs/SP13-03.pdf

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

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.

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.