Agenda Item H.7.c Supplemental Public Comment MTC PowerPoint September 2012 Midwater Trawlers Cooperative
Why Status Quo was fair and equitable in 2008 Why Status Quo is the most fair and equitable option now
Amendment 20 Purpose and Need Despite a program completed in 2003 to reduce fishing capacity through the buy back of groundfish LE permits and associated vessels, management of the west coast LE Groundfish trawl fishery is still marked by biological, social, and economic concerns, similar to those cited in the U.S. Commission on Ocean Policy s 2004 report (2004). Many participants and observers view the trawl fishery as economically unsustainable under the current management regime.
Purpose Of Trawl IQ Program Create and implement a capacity rationalization plan that increases net economic benefits, creates individual economic stability, provides for full utilization of the trawl sector allocation, considers environmental impacts, and achieves individual accountability of catch and bycatch
What the judge ordered Reconsideration of initial allocation of whiting quota shares Judge Henderson did not mandate that a particular change be made
MSA Allocations must consider 1. Current and Historical Participation 2. Employment in the Harvesting and Processing Sector 3. Investments in and Dependence on the Fishery 4. Current and Historical Participation of fishing communities
1. Current & Historical Harvests Harvester allocation to current permits this recognizes recency and investment 18 permits traded hands after 2003 Status quo alternative is the current fishery and clearly recognizes current participants Moving the window period forward ignores historical participation
Recent Participation 23 permits had increased whiting landings after 2003 only 3 are suing for an increased initial allocation Permit Pacific Dawn Initial Allocation Shoreside Rank Initial Allocation Mothership Rank 1.991% 18 out of 55 3.00% 16 out of 36 Chellissa 1.734% 20 out of 55 0.00% N/A James Schones 1.504% 24 out of 55 0.00% N/A
Recent Participation No one is prevented from harvesting or processing whiting due to the initial allocation Da Yang Seafoods received no initial allocation and still processed a large amount of fish in 2011 and 2012
Latent Permits are Insignificant 15 permits with no post 2003 activity were allocated 4.3% of the shoreside quota share and 1.5% of the mothership sector allocation 6 of these permits were owned by entities who owned other active permits. These six permits accounted for 3% of the shoreside quota share and 0.5% of the mothership sector allocation, leaving 2.4% of the shoreside quota share and 1% of the mothership sector quota share that apparently had no fishing activity after 2003 Page 2 of the Supplemental Analysis Attachment 3
2. Employment in the harvesting and processing sector Status quo option considers employment in the processing sector by allocation of quota share to processors Status quo option considers employment in the harvesting sector by allocation of quota to harvesters Under any action alternatives resource shifts from one community to another possibly affecting employment in that community
3. Investments in and Dependence on the Fishery Allocating to current permits considers and recognizes current participation and investment in the fishery Status quo fishery took into account more recent investment by including 2004 for the processor allocation Considering only recent participation in the fishery discounts long-term investments and dependence
West Coast Seafood Processors Dependent on Diversification FISH MEAL CRAB SHORESIDE WHITING GROUNDFISH (NON WHITING) CANADIAN FISH SHRIMP SALMON SARDINES ALBACORE TRIBAL WHITING
Dependent on Diversification W.C. Black Cod Tiers W.C. Groundfish IQ Bering Sea Crab Co-op W.C. Crab W.C. Shrimp W.C. Shoreside Whiting IQ MS /CV Whiting Co-op GOA Pollock GOA Cod GOA Rockfish IQ MS/CV Pollock AFA Co-op Inshore Pollock AFA Co-op Bering Sea Cod
4. Current and Historical Participation of Fishing Communities Processors were allocated whiting in order to recognize and protect communities Company Port Community Initial Allocation 1 Trident Seafood Newport, OR 4.666% 2 Ocean Gold Seafood Westport, WA 3.865% 3 Pacific Coast Seafood Warrenton, OR 3.793% 4 Pacific Shrimp Newport, OR 2.853% 5 Point Adams Packing Warrenton, OR 1.993% 6 Jessie s Ilwaco Fish Ilwaco, WA 0.651% 7 Pacific Seafoods Eureka, CA 0.558%
Moving off status quo transfers fish from OR & CA to Washington Company Port Community Initial Allocation 1 Trident Seafood Newport, OR 4.666% 2 Ocean Gold Seafood Westport, WA 3.865% 3 Pacific Coast Seafood Warrenton, OR 3.793% 4 Pacific Shrimp Newport, OR 2.853% 5 Point Adams Packing Warrenton, OR 1.993% 6 Jessie s Ilwaco Fish Ilwaco, WA 0.651% 7 Pacific Seafoods Eureka, CA 0.558%
Includes: Catcher Processors Mothership CV s Shoreside CV s Shoreside Processors Tribes 69% 28% 3% Pacific Whiting Distribution 2012 By State Based on % of U.S. OY
Disruption to Existing Program Existing deals and arrangements based on Council decisions (permit purchases, etc.) could be rendered valueless (those 18 permits which traded hands after 2003) Fish moving out of communities in Oregon and California and migrating north to Washington Double-dip loss
Other Impacts of moving from status quo Control dates become meaningless here and elsewhere Making a change supported by a small minority alienates the majority of the industry Participants that don t like policy calls made by the Council continue to believe litigation is the answer
PCFFA Decision consider means just that substantial participants are not guaranteed an allocation The overall Groundfish ITQ program considered a reasonable range of alternatives and met NEPA requirements
Status Quo is the current 2012 Fishery Status Quo is the only fair and equitable choice