Duncan Fields of Kodiak is a member of the North Pacific Fishery Management Council, which will begin shaping a ‘bycatch reduction’ program for trawl fisheries in the Gulf of Alaska.  It will inevitably include some form of catch shares.  Fields offered a seven step ‘primer’ on important considerations at ComFish 2014  — below is a synopsis:

Duncan Fields

Duncan Fields


What to Include in Any Catch Share Program – A 7 step primer  — 

I wanted to talk a little about some of the “big picture” decisional points that need to be discussed for any GOA rationalization program. If you are developing proposals – they should, at least include these elements.


  1. Who gets the fish —why and how?  — Vessel owners only – why. Directed species only, bycatch species only, or both? Why? Distributed by history only – (reward dirty fishing?), or an equal distribution to all qualified fishermen for some portion. Reasons for distribution to non-fisherman?  Justify proportion to non-fishermen.  Do you with-hold a portion of quota (initially or annually?) to reward operational goals.


  1. What is the access right?   — is it both QSand annual IFQ?   Long term, would it be better to separate the IFQ from the QS… should these be seen as two separate “rights”.  Should program only provide access to use of IFQ through co-ops — why?  Should program provide open access fishery opportunities?


Need to address issues of consolidation:  Decide caps on how much can be held or fished by individual and/or vessels. Develop qualifications to hold the access right (IFQ and/or QS) – vessel ownership %, history in fishery etc.  Must address active participation issues – boots on deck fishermen. Critical to address leasing issues – who can lease, should lease rates be limited? Clarify transfer issues —- freely transferable, limited transferability — consider transfer “taxes” of a portion of the IFQ/QS for specific goals.  How long is the access right?


  1. Who gets to process and why?   — Define a class of qualified processors —    Why should they be treated as “class” and why provide “preferred” access to process.  Should program address issues of processor capital Investment – i.e. processor quota. What are processor business planning needs. Address future processing opportunities and/or competitive markets.


  1. Community Interests to protect? ——- Consider community Infrastructure — investment in docks, water and electrical and all municipal services.  What are the communities’ interests in jobs, processing volume and local tax revenues.  How will program impact local businesses?  Should benefit from program have community residency component  — recipients/harvesters/both?  Provide for “New” community opportunities – value added, expanded processing, other fishery dependant coastal communities?


  1. Changes in current fishing practices?  Bycatch reduction & 100% monitoring – human and electronic observation!  (For me this is non-negotiable for any rationalization program. — must work toward a combination of human and electronic monitoring.) Does program address underutilized species and new fishing opportunities.  Does program encourage gear conversions – more efficient, less bycatch or just different gear type? How does program enhance habitat protections.  Does program provide some new spacial and/or seasonal fishing opportunities?  How may program change prosecution of fishery. (i.e. more use of pelagic trawls for rock fish – unintended consequences?).


  1. How does this change relationships? –   Fisherman\fisherman — sideboards to protect fishing “share” are not enough.  Appreciate capital transfer to IFQ/QS owner results in uneven “buying”  power or available “capital”.  Anticipate consolidation and competition for vessels, other fishing “rights”, money invested to compete in other fisheries (pot cod), markets, tendering contracts, etc.


Owner\Skipper\Crew – respective relationships based on short seasons and labor needs are changed.  Address how to maintain traditional crew shares/type jobs.  Address new crew entrant opportunities.  How to encourage ownership and “moving to wheelhouse”?


Recipient\processor – access “right” gives harvester new “leverage” for price and market.  Mechanisms to maintain respective negotiating positions? Is program sensitive to new market dynamics? How do market restrictions impact business planning and “competition” in the market place — for processing fish and selling fish?


Recipient\Processor\Communities — Is relationship just about geography? What more does fishery provide to community? (ROFERS haven’t worked.) How does consolidation impact community vendors and their availability for other fishermen?  Impacts on housing/services/utilities/ market  — hospital, KEA, fuel suppliers etc.  Does program inhibit or encourage product development/innovation and reprocessing?— provide incentives?


Recipient\Stakeholder\Public – The public has an interest is the use and disposition of the public resource.  How does program change public’s “value” from resource.  Is  “public” interest limited to conservation and habitat? What overall “public” value does program give from use of resource. Use MSA guidelines – but are these enough to capture the “publics” larger interests?


Programmatic Review:  (Probably should start with this concept.) Important to specify that program “ends” at specific date.  Three approaches do date — statute (sablefish/halibut, AFA) programmatic review and program continues absent Council action (amendment 80) or program actually ends unless Council takes action (rockfish).  Consider merits of each approach.  Perhaps look at  a “drop through” approach. Note, MSA indicates a 10 year programmatic life  —  but programs are difficult to change.  Recognize must get it RIGHT to start and then know that there will need to be significant changes so put in a firm end date to give notice to everyone that programmatic changes will be made.  #