Thursday, December 27, 2012

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.

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