Motion for Compensated Reallocation
NORTH PACIFIC FISHERY MANAGEMENT COUNCIL
Motion for Compensated Reallocation between Commercial and Charter Sectors in Areas 2C and 3A halibut resource. Unless a mechanism for transfer between sectors is established, the Council will continue to serve as the arbitrator and the existing environment of instability and conflict will continue. The Council seeks to address this instability while balancing the needs of all who depend on the halibut resource for food, sport, or livelihood.
Action 2. Implement measures to allow compensated reallocation from the commercial
charter sector to the charter halibut sector
Element 1 Entity/Structures to provide for compensated reallocation
Option 1. government - common pool
Suboption 1. state
Suboption 2. federal
Option 2. regional (2C or 3A) private non-profit (PNP) charter associations/entities - common pool
Option 3. individual - private
Suboption 1. persons holding a sport fishing guide business license from the state
Suboption 2. persons holding a guided sport halibut moratorium license (upon implementation)
Element 2 Method for Purchase/Lease
Option 1. state – common pool
Suboption 1. loan
Suboption 2. bonding
Option 2. federal – common pool
Suboption 1. loan
Suboption 2. buyout program (similar to SE seine buyback program)
Option 3. regional private non-profit – common pool
Suboption 1. loan
Suboption 2. commercial bond
Option 4. individual - private
Suboption 1. loan
Element 3 Revenue Stream
Non-self assessment revenue streams will be for a defined period and end after the loan or bond is paid off, i.e. continuous open-ended revenue streams are to be avoided.
There needs to be a link between the charter business operators and the cost of increasing the charter pool. (If the charter business operators do not experience the cost of increasing the charter pool, there
will not be a feedback loop to balance the market system.)
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Option 1. state
Suboption 1. charter stamp
Suboption 2. self-assessment
option 1. fee is based on number of clients
option 2. fee is based on number of fish
Suboption 3. business license fee/surcharge
Option 2. federal
Suboption 1. federal halibut stamp
Suboption 2. moratorium permit fee
Suboption 3. self-assessment
option 1. Fee is based on number of clients
option 2. Fee is based on number of fish
Option 3. regional private non-profit – self assessment
Suboption 1. fee is based on number of clients
Suboption 2. fee is based on number of fish
Element 4 Sector Floor Ranges
The percentages are based on the combined commercial and charter catch limit. These are intended to establish a minimum amount that will always be available to each sector.
A. commercial: 60 – 75%
B. charter:
2C: 12 – 16%
3A: 13 – 15%
Note: These ranges should not be construed as endorsement of allocation ranges.
Element 5 Restrictions on transferability of commercial quota share
Option 1. Limits on purchase
A. entities purchasing for a common pool:
Suboption 1. limited annually to a percentage of the amount of QS transferred during
the previous year
option 1. during the first 3 years: 30 – 50%
option 2. after the first 3 years: 20 – 50%
Suboption 2. limitation would be based on block size. Block size restrictions may vary
based on vessel size class
(These suboptions are not intended to be mutually exclusive.)
B. individual: subject to the current ownership cap and block restrictions associated with
commercial quota share
Option 2. Limits on leasing
A. individual:
Suboption 1. an individual may not own or control more than the amount equal to the
current setline ownership cap converted to the number of fish in each area
(currently 1% of the setline catch limit in 2C or ½% in 3A)
Suboption 2. an individual may not own or control more than 2,000, 5,000, or 10,000
fish. (Note: examine this as a percentage of the catch limit once allocations are
established.)
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Element 6 Mechanics for converting commercial quota share into Guided Angler Fish (GAF)
1. An entity must meet the eligibility requirement under element 2 to participate in the Guided Angler Fish (GAF) program. (i.e., an entity must have a sport fishing guide business license and/or a halibut moratorium license, or be a designated charter association/entity or branch of the government, to participate in the GAF program.)
2. These qualifying entities may purchase commercial QS and request NMFS the issue annual IFQs generated by these shares as Guided Angler Fish.
3. Qualified entities harvesting GAF while participating in the guided sport halibut fishery are exempt from landing and use restrictions associated with commercial IFQ fishery, but subject to the landing and use provisions detailed below.
4. GAF would be issued in numbers of fish. The conversion between annual IFQ and GAF would be based on average weight of halibut landed in each region’s charter halibut fishery (2C or 3A) during the previous year as determined by ADF&G. The long-term plan may require further conversion to some other form (e.g., angler days).
5. Commercial fishermen who do not hold a sport fishing guide business license and/or
moratorium permit may lease up to 10% of their annual IFQs for use as GAF.
6. Commercial fishermen who hold QS and a sport fishing guide business license and/or a halibut moratorium license may convert all or a portion of their commercial QS to GAF on a yearly basis if they own and fish it themselves on their own vessel. Commercial and charter fishing may not be conducted during the same trip.
7. Subleasing of GAF would be prohibited.
8. GAF holders may request NMFS convert unused GAF into IFQ pounds for harvest in
compliance with commercial fishing regulations provided the GAF holder qualifies under the commercial IFQ regulations.
9. Unused GAF would revert back to pounds of IFQ at the end of the year and be subject to the underage provisions applicable to their underlying commercial QS.
10. All compensated reallocation would be voluntary based using willing seller and willing buyer.
Suboption. Pro-rata reduction and compensation.
11. Guided angler fish derived from commercial QS may not be sold into commerce, i.e., all sport regulations remain in effect.
12. Guided angler fish derived from commercial QS may not be used to harvest fish in excess of a
2 fish total bag limit on any given day.
8 comments:
Wow! Thats a lot to digest. Some things i like some I don't. We need to "Strike while the iron is hot".
Get in a room with the commercials and get the allocation agreed upon.
If it is an updated IFQ or a plan that allows for future growth in some fashion lets do it. It seems to me that the time is ripe for an agreement in principal for an allocation we can live with. A stake holders meeting that actually has stakeholders of the industry and not the wild eyed dreamers of a 50% 50% split and the lawsuiters who have nothing to lose and everything to gain by being as disruptive as possible to the process. We need to get to governor Sarah and NMFS and our federal representatives with a plan that benefits the stakeholders and not the malcontents that have much to much input into the process. Lets figure out what we can or can't live with and get on with it.
Exactly. Thanks.
This is a real important part of our committee's work, "Non-self assessment revenue streams will be for a defined period and end after the loan or bond is paid off, i.e. continuous open-ended revenue streams are to be avoided.
There needs to be a link between the charter business operators and the cost of increasing the charter pool. (If the charter business operators do not experience the cost of increasing the charter pool, there will not be a feedback loop to balance the market system.)"
This issue will kill most Government or Private Non Profit (PNP) organization buying and holding the purchased commercial Quota. The commercials don't want the 300,000 sport people being charged a fee that messes up the quota trading and the entry level commercial person trying to compete with our new found deep pockets. If the charter is not feeling the "cost" then he will not act responsibly, kinda like now....The individual business will be the most equal entity to the current commercial entity that should be the competitor in the open market for quota. We need to stay away from creating this big pool of money that creates so much fish in the charter sector that the ocean bottom will be sanitized of halibut. Nearshore depletion will be so bad we can't find water enough to float a boat. The individual Guided Angler Fish plan is the smart choice. Is that a new motto, "GAF, the Smart Choice"
Are you against a one-time purchase to get us over this little hump we are about to have? A one-time quota purchase shouldn't necessitate any link between charters and the cost of increasing the pool, i.e., why should I have to pay for their mistake in allowing the post control date guys in? A small buyback would be better yet so we could get the pool down to a sustainable size. Particularly with the half-day boats cleaning out all of our bailouts (and the future of the industry), this area just cannot take all of the pressure it is receiving."Unused GAF would revert back to IFQ" - can we sell em? Tell me if i'm missing something here, Bob.
Let those who can justify the debt take care of themselves. A one time purchase paid for by all of us will benefit all of us. Why should you pay your share of a purchase just so the half day boats can waste it at $89 a customer? If you are getting $200 then you can buy some for yourself and continue to get $200. Do you want to buy with your profits so another can do combos or early season discounts over you? Let them take care of themselves is my take.
All charter businesses are competing with each other, so let each charter business handle the need for more fish on their own. If they can't justify the investment then they should go find a job. If they think their fishing trip is only worth a discounted value, then let them figure it out. I don't owe anyone any part of my business, resource access, or profits. I like the "Free Market Competition" as long as it is not "Free" to some and not others. Let them all pay equally to get their fish and if they can buy it and still charge $89, so be it, but they won't.
The pool is another word for GHL, if we have a 1 time purchase and it goes into the pool then everyone gets a share as fast as they can fish it. We don't need to subsidize the Pool when some charters are using fish from the pool for $89 trips. The commercials don't want us to just keep feeding into the pool with all the customers paying in and we don't feel the cost ourselves. They want a connection between buying fish and paying for it. Better understood now?
I see your point. Let me have the maid squeeze another orange juice. I'm going to lay in the sun and think about this awhile. How are things up there, by the way?
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