Photo credit: KUCB, Unalaska/Dutch Harbor, AK
By Dennis Moran, President
October 7, 2021
“If your only tool is a hammer, every problem looks like a nail.”- Zen Master or maybe Mark Twain.
As we get close to the North Pacific Fishery Management Council’s final action cutting the Amendment 80 sector’s halibut – yet again – we should pause and reflect on what this will accomplish. There are problems with halibut management, to be sure. The Pribilof Island community-based fleet needs bigger halibut allocations in times of low abundance. There is too much waste in the groundfish fleets forced by crushingly outdated regulations. Let’s try to solve these halibut problems rather than just cutting Amendment 80 halibut and acting surprised in another 4 years when the Pribilof Island community-based fleet comes back to the Council pleading that they still need fish and that the last round of cuts failed to even make a dent in the problems. This has been the cycle about every 4-5 years since the halibut stock scientists realized they had allowed large overharvest of halibut in the Bering Sea: the Pribilof Island directed halibut fleet pleads to the Council that it doesn’t have enough fish; the Seattle and Arizona halibut fleet owners jump on the bandwagon and demand that the Council must make cuts to the Amendment 80 fleet or else the whole council system is corrupt if they don’t; the Council makes cuts and then the cycle starts again. Maybe it’s time to consider the possibility that a halibut cut to the Amendment 80 fleet is not the right tool. Maybe it’s time to consider solving the Bering Sea halibut problems with some other tools.
The challenges arise out of the fact that there are two competing user groups for halibut in the Bering Sea, 1) the directed fishery users, represented by the community-based Pribilof Island directed halibut fleet (“PI Fleet”) and 2) the Amendment 80 fleet (“A80” Fleet). The PI community fleet consists of approximately 15 ships, 75 crew, they fish with hooks, can legally harvest only halibut longer than 32 inches and are required by law to throw back shorter fish as “bycatch.” The PI Fleet crews depend on the fishery to provide earnings for their families on St. Paul Island. The A80 fleet consists of 19 ships, 2,285 crew, fish with nets, legally harvest species like yellowfin sole, cod, atka mackerel, rock sole, etc. and are required by law to throw back 100% of the halibut they catch, regardless of size. The 2,285 A80 crew also depend on the fishery to provide earnings for their families in Alaska, Washington and over the United States. Both fleets are allocated a fixed halibut quota measured in weight- pounds or metric tons. Both fleets are required to stop fishing when they reach their quotas. Where they differ is that the PI fleet tries to harvest its halibut quota but the A80 fleet tries NOT to harvest its halibut quota because that shuts down their fishing for all the other species too.
What are the specific problems? First, there is a problem with the Pribilof Island fleet fishing in Bering Sea areas 4CDE getting low harvest allocations during times of low abundance – they simply need more fish when the amount of large fish in the Bering Sea is low. Second, there is the problem of waste – it is a waste to require the A80 fleet to throw away dead halibut that could and should be used for food like all the other fish commercially harvested. Third, due to the byzantine halibut management structure, cutting the A80 halibut allocation gives the PI fleet barely any increase in their directed halibut quota and will severely damage the A80 fleet. But cutting is the only tool the North Pacific Council has ever used on this issue, so cut it will, and those cuts will not solve any of these three problems, not even one, and this time around the cuts will create new problems for the Alaska communities in the form of dramatically reduced landing tax revenue caused by the contraction in A80 harvest.
What would solve the problems?
1. Problem of a PI fleet that needs additional halibut during periods of low abundance. Create a path for A80 to transfer fish to the PI fleet with a private, enforceable contract. In years of low halibut abundance, where Area 4CDE halibut allocation is below 1,500,000 lbs., regulations already exist that permit the A80 fleet to lease directed halibut quota share from other, absentee Seattle or Arizona based owners for example, and distribute that fish to the PI fleet CDQ groups so that they can distribute it to the ships in their fleet. All that needs to be done is for the A80 owners and the PI CDQ group to negotiate a private contract. This will cost A80, but will reduce the harm to the A80 crew earnings far more than Council based halibut cuts. A80 companies stand ready to work out a deal with the PI fleet to build this structure.
2. Problem of halibut waste. The only place halibut is wasted like this is in the US North Pacific and Eastern Bering Sea and Gulf of Alaska. The only reason halibut is wasted like this is because the US halibut laws require it. Halibut is commercially harvested by trawl catcher processors, sensibly and sustainably all over the world including the Russian Bering Sea, Eastern Canada, Greenland, North Atlantic and Barents Sea. Laws requiring waste are wrong environmentally, morally, and commercially. They are relics of a fossilized 1923 US-Canada treaty and a less ecologically enlightened past. What might have made sense in 1923 doesn’t make sense in 2021. NOAA can amend the federal regulations by deleting the word “halibut” from 50 CFR 679.21 and let A80 manage halibut like it manages cod, with fixed quotas that permit retention and fishing stops when the quota is exhausted. Managing halibut like cod would 1) eliminate the waste, 2) potentially increase the food production by roughly 3.5 million halibut meals, 3) increase annual crew pay to the 2,285 A80 crew by $3.7m (roughly $1,638.00 per person) and 4) increase the annual landing tax paid to the State of Alaska and local communities by roughly $435,000. That’s a win, win, win, win solution.
3. Problem of cutting halibut allocation to A80. One of the great management success stories is how A80 has already reduced the fleetwide halibut bycatch rate by 49% since 2007, to a point where it constitutes less than 0.4% of the total catch. That bycatch ratio is lower than almost all the other gear types, including crab pot, cod and halibut longline. There is no room, now, for additional cuts without causing massive contraction in A80 harvest and landing tax revenue to Alaska communities, damage to the A80 companies, their crews and their families from which they are unlikely to recover. Data from North Pacific Council’s latest Economic study shows this next round of proposed cuts will have the following effects on crews and Alaska communities (est.):
a. A 20% cut to A80 increases annual halibut crew shares by $435.00/person in the 75 crewmember PI fleet ($32,625.00), but it decreases A80 crew shares by an average of $7,631.00/person in the 2,285 person A80 fleet ($17,430,140.00 total) and contracts Alaska State Landing Tax by roughly $627,773.00. Half of the landing tax goes to the local communities, which in this case is principally Dutch Harbor/Unalaska. So, increasing the PI crew share $435/person costs Dutch Harbor/Unalaska roughly $313,886.00 in lost landing tax revenue.
b. A 25% cut to A80 increases the annual halibut crew shares by $544.00 for 75 PI crew ($40,800) but decreases the A80 crew shares by an average of $10,354.00/person for 2,285 A80 crew ($23,660,559.00 total) and contracts Alaska State Landing Tax by roughly $851,780.00. The $544.00 PI crew share increase costs Dutch Harbor/Unalaska roughly $425,890.00 in lost landing tax revenue.
c. A 40% cut to A80 increases the halibut crew shares by $871/person for 75 PI crew ($65,325) but decreases A80 crew share by an average of $15,391.00 for 2,285 crew ($35,168,530.00 total) and contracts Alaska State Landing Tax by roughly $1,266,067.00. That’s a reduction of $633,033 in lost tax revenue to the local Alaska communities, almost all of which would come from the City of Unalaska. The $851/person crew share increase costs Dutch Harbor/Unalaska roughly $633,033.50 in lost landing tax revenue.
Zen Master warns us against a common foolishness. Look at the problems, then look into the tool belt and see if there are other tools besides the hammer that might actually solve the problems. Or maybe Zen Master is telling us something about human nature, that we just like pounding on things with hammers. We’ll see.