80 Allocation of Non-Pollock Groundfish and Development of a Cooperative Program for the NonAmerican Fisheries Act Trawl Catcher Processor Sector
Purpose and Need
The Non-American Fisheries Act Trawl Catcher Processor sector (also referred to as the Head and Gut, or H&G trawl CP) had adverse effects on the fishery as a result of the management regime the fleet operated under. The H&G trawl CP targeted multiple species in such a way that encouraged a “race to fish,” or the maximization of harvest in as short a timeframe as possible to claim a larger share of the available quota. Among the numerous problems associated with the harvest strategy, the H&G trawl CP had the highest discard rate in the BSAI groundfish fisheries since at least 1995. Since non-cooperative vessels participated in a “race for fish,” individual vessels could be negatively impacted for attempting to reduce incidental catch, resulting in increased incidental catch rates. The Council decided to address the problems associated with the race to fish by facilitating the development of a cooperative, thus reducing bycatch, minimizing waste, and improving utilization of fish resources. Sector allocations and cooperatives would result in participants focusing less on maximizing harvest, and more on optimizing it, thus eliminating the race to fish and reducing associated consequences.
Analysis
A 307-page RIR analysis and a 51-page EA were prepared. Four alternatives were considered that compared number of factors: target species allocations, PSC allocations, eligibility, cooperative formation and allocation, excessive share limits, sideboards, and CDQ. Each alternative (aside from the status quo alternative) included varying degrees of new regulatory measures with Alternative 2 being the least number of new measures and Alternative 4 being the most. Alternative 4 (preferred) called for 100 percent allocation percentages for rock sole and flathead sole, and the phasing in of final allocation percentages for Atka mackerel and AI POP. The preferred alternative included sideboards for GOA fisheries but not BSAI. The RIR determined that the cost of implementation would be significantly less than the crab rationalization data collection program because AM80 is the first of its kind and would be able to draw from crab rationalization. Also, the number of AM80 eligible participants is significantly less. The analysis as a whole determined that AM80 would have both economic and ecological benefits with increased retention and utilization, greater incentive to avoid bycatch, and the elimination of the race to fish.
Regulation Summary
The primary function of AM80 was to facilitate the formation of harvesting cooperatives in the H&G trawl CP sector and establish a limited access privilege program (LAPP) to encourage participation in the voluntary cooperative. Catch limits, also known as sideboards, were established in the GOA for the AM80 fleet to limit the ability of AM80 vessels to expand their harvest efforts, thus preventing AM80 vessels from using the associated economic advantages in a way that could adversely affect other participants in the fisheries. AM80 also establishes a rationalized fishery for several fisheries in the BSAI, thus eliminating the race to fish.
Results
The Council prepared a 5-year review of the effects of AM80 in October 2014. Since AM80 was implemented there have been overall increases in total wholesale revenues in the BSAI and GOA groundfish fisheries. Overall retention has also increased from 74 percent before AM80 to 94 percent in 2012. With the reallocation of Pacific cod away from the AM80 fleet, industry reported that the shift from target species to incidental catch species has the potential to constrain harvest of other species.