Bristol Bay Salmon Fishery

Restructuring Study

 

Summary of Town Meetings to

Obtain Public Input

 

Naknek and Dillingham, Alaska

June 18 and 20, 2002

 

 

Executive Summary

 

The Bristol Bay Economic Development Corporation (BBEDC) is sponsoring a study to evaluate options to improve the economic sustainability of the Bristol Bay sockeye salmon fishery.  The BBEDC hosted public meetings in Naknek and Dillingham, Alaska, in June 2002, to describe the Bristol Bay Salmon Fishery Restructuring Study, and to hear the public’s ideas about improving the fishery. 

 

The restructuring study will evaluate the potential effects of six to eight options for restructuring or improving the Bristol Bay fishery.  It will examine the economic and biological impacts of each option, as well as social, legal and political implications.  The study will not recommend a “preferred” option or set of options, but will provide information to BBEDC, people involved in the Bristol Bay fishery and decision makers to consider.  The study will be completed in January 2003.

 

A total of 240 people attended the Naknek and Dillingham meetings – including fishermen from all gear groups and districts, processors, and community members.  Meeting participants shared their views about the current fishery (status quo) and about options for restructuring or improving the fishery. 

 

The public is encouraged to provide comments on the study and restructuring options through a questionnaire, email and the project web site at www.bbsalmon.com

 

Major points made at the meetings include:

 

·       Status Quo – There was agreement at both the Naknek and Dillingham meetings that the status quo is not an acceptable situation for people involved in the fishery.  Many fishermen can no longer afford to fish.  Concerns included the excessive number of permits, declining catches, low prices, poor marketing and quality, the need for improved infrastructure to lower costs, and low fish returns. 

 

 

Fishermen were concerned that some options for restructuring the fishery (such as vessel sharing or fishing alternate days) would reduce their opportunity to catch fish and earn income, without significantly reducing their costs.  The restructuring study should clearly show how fleet reduction options would likely affect a fisherman’s equity, fixed costs and net income.

 

 

People questioned whether the Bristol Bay fishery could be effectively managed through an IFQ system, given the short time period and uncertainty of annual salmon returns.  The study would need to evaluate whether the fishery could be managed under an IFQ system, and discuss possible criteria and options for allocating quotas. 

 

 

 

 

 

 

1.0     Introduction

 

The Bristol Bay Economic Development Corporation (BBEDC) is sponsoring a study to identify and evaluate options to restructure the Bristol Bay sockeye salmon fishery.  The BBEDC hosted public meetings in Naknek, Alaska on June 18, and in Dillingham, Alaska on June 20, 2002, to: 

·       Describe the Bristol Bay Salmon Fishery Restructuring Study, and

·       Hear the views of people involved in the fishery about the current situation and options for improving the fishery’s economic sustainability.

One hundred and sixty people attended the meeting in the Naknek school auditorium.  Eighty people attended the Dillingham meeting at the Curyung Tribal Council building.

Robin Samuelson, Director of BBEDC and a life-long Bristol Bay fisherman, welcomed the public to both the Naknek and Dillingham meetings.  Mr. Samuelson invited all parties – including fishermen from all districts and gear groups, processors, community members and others – to work together to create a fishery that will provide long-term economic benefit to the people involved in the fishery and the Bristol Bay region.  The BBEDC, which represents 17 communities, funded the $300,000 study to help the region analyze options for improving the fishery and craft a plan that can be taken to the Governor, Congress and other decision makers.  The BBEDC and study team have no preconceived idea about the result of the study and will not recommend a preferred option.  Instead, the study will analyze a number of options and present the advantages and disadvantages of each.  The process is open and public input is needed and welcome. 

 

 

2.0     Description of the Restructuring Study

 

At each public meeting, Michael Link, Project Manager, described the Bristol Bay Restructuring Study, introduced the study team, and answered questions about the project’s intent and design.[1]  The study, to be completed in January 2003, is being done in response to the problems facing the Bristol Bay sockeye fishery.  The fishery has declined from a 20-year average landed value of $200 million received by fishermen, to an average of less than $40 million in the last five years.  The projected landed value for 2002 is $24 million.  The decline is due to recent low fish returns coupled with low prices for fish due to market forces, including competition with farmed salmon and other factors.

 

The study will evaluate the potential effects of six to eight options, including actions that could:

·       Decrease the cost of catching and processing fish,

·       Increase the price paid for fish, or

·       Increase the amount of fish available to harvest. 

The study will evaluate the economic and biological impacts of each option, and analyze the social, legal and political implications of each.  The study will not recommend a “preferred” option or set of options.  Instead, it will provide information for the BBEDC, people involved in the fishery and decision makers to consider as they decide what action to take, if any, to improve the fishery.  The study team is working with an Advisory Panel, which includes representatives of each river system in Bristol Bay and government agencies that work with the fishery.  Many of the options being considered would require changes in current statutes or regulations.  Upon completion of the study, the BBEDC will decide what steps to take to improve the economic sustainability of the fishery.

 

The public is urged to participate in the project, through public meetings, questionnaires, email, and the project web site.[2]  Public input is being requested in July 2002, to ensure that the study can be completed by January 2003.  An executive summary of the report will be mailed to all permit holders.  The full report will be posted on the web site.

 

 

3.0     Summary of Comments at Public Meetings

 

At the Naknek and Dillingham meetings, public input was taken through oral and written comments and informal, one-on-one conversations.  People were asked:

·       What is working and not working about the existing situation (status quo)?

·       What restructuring or other options should be considered to improve the fishery, and why?

·       What restructuring or other options should not be considered, and why?

·       What issues or concerns should be addressed when options are analyzed?

The public discussions at the Naknek and Dillingham meetings are summarized below. 

 

 

          3.1     Status Quo – Comments on the Existing Situation

 

There was agreement at both the Naknek and Dillingham public meetings that the status quo is not an acceptable situation for people involved in the fishery.  Concerns included:

 

·       There are too many boats competing for a reduced resource.  The race for fish is costly, inefficient, and often unsafe and rancorous – and it leads to poor handling of fish and lower fish quality.

 

·       Prices are too low for fishermen to make a living in the current fishery.  Many people can no longer afford to fish.

 

·       Marketing is very poor and has not responded to current conditions in the world salmon market – particularly the threat from farmed salmon.

 

·       Product quality needs to be significantly improved.

 

·       New infrastructure is needed to allow fishermen to more effectively handle and market their catch; support value-added processing; and lower costs.

 

·       Fish returns are alarmingly low.  Many people attending the Naknek meeting were especially concerned about the Kvichak River return.

 

 

3.2     Naknek Meeting – Public Comments

 

A.  Comments on the Restructuring Study

 

People offered the following comments at the Naknek meeting about the intent and design of the Bristol Bay Salmon Fishery Restructuring Study:

 

·        Several people asked why the Advisory Panel does not include representatives of fishermen and processors from outside Alaska.  In response, Robin Samuelson committed that the study will comprehensively and fairly consider how the status quo and any restructuring options would affect all participants in the fishery – local and non-local.  The analysis must be fair, or there will be no hope of support from the Governor, State Legislature or Congressional in its implementation.  Michael Link stated that the study team members are independent professionals who are committed to conducting a complete and unbiased analysis.

 

·        The study team should look at how restructuring has worked in other fisheries to find successful precedents and potential pitfalls. 

 

·        It is important that the results of the study be communicated to all decision makers in Alaska, to educate them about the problems in Bristol Bay and possible options for improving the situation.

 

·       The study should list the references used in the analysis.

 

B.  Comments on Restructuring Options

 

There was strong interest at the Naknek meeting in changing the salmon fishery to make it more sustainable and provide more economic benefit for those involved.  However, people emphasized that simply restructuring or reducing the fleet would not be enough to ensure the long-term sustainability of the fishery.  Product quality and marketing must also be improved to raise prices.

 

Reducing the Fleet

 

Meeting participants expressed general support for reducing the number of vessels and fishermen in the fleet.  Consolidating the fleet could reduce harvesting costs and increase catch size and income for remaining fishermen.  However, people noted that fleet reduction would need to be equitable and provide compensation to those leaving the fishery.  Options discussed for reducing the fleet included permit buy backs, and ways to reduce or consolidate fishing effort of existing permit holders.

 

Buy Backs

 

It was recommended that the study explain how a buy back could work, including how permits would be valued, who would fund the buy back, and who would receive an offer.  Participants in the fishery would need this information before they could decide whether or not to support this option.

 

If a buy back is pursued, there was strongest support for a government-funded buy back that would compensate permit holders for lost equity.  Several people felt that the State of Alaska had issued too many permits and had caused overcrowding in the fishery.  They felt the State has a responsibility to compensate permit holders if they reduce the number of permits to a more sustainable level.  One person questioned what the State had done with the fee of $50 per permit that was intended to fund State buy backs of unused permits.

 

People stated that a buy back should fairly compensate fishermen for their loss of equity and opportunity – not just buy permits at the current, low market price.  One person suggested that permits be bought back from outside fisherman first, to favor local involvement in the fishery in the future.  Another suggested that the State retire permits that were purchased with state loans and have been in default.

 

If government funding is not available for a buy back, people were concerned that the fishermen would be taking on further debt to fund a buy back program.

 

Permit Stacking or Exclusive Group Fishing

 

Meeting participants were concerned about options that would reduce the fleet or fishing opportunities without compensation.  Permit stacking (e.g., two permit holders sharing a vessel) or “exclusive group” fishing (e.g., fishing every other day)[3], were viewed by many people as reducing equity and fishing opportunity without fair compensation.  Several members of the audience fished in the San Francisco Bay “odd-even” herring fishery.  In their view, the value of their permit and their opportunity to earn money fishing had been cut by half, without compensation.

 

In contrast, some people spoke in favor of permit stacking or vessel sharing, noting that fishing costs are reduced by sharing vessels, gear and labor.  Vessel sharing would allow permit holders to team up on the best-equipped boat, which could improve fish quality. 

 

The restructuring study must show how permit stacking or exclusive group fishing could affect the fishermen’s costs and income, so that people can make an informed decision about this option.  The study team was urged to look at other fisheries where these restructuring options have been implemented, to see the long-term effects on the economics of the fishery and individual fishermen’s net incomes.

 

Fishing Cooperatives

 

One person suggested that villages or native corporations organize fishing cooperatives to reduce the number of boats in the fishery and reduce costs.  A cooperative could encourage and support local participation in the fishery.

 

Fish Allocation by Quota (IFQs)

 

Several people spoke in favor of establishing an individual fishing quota (IFQ) system for the Bristol Bay salmon fishery.  If fishermen were more certain of their share of the catch, it would calm down the “race for fish.”  An IFQ system might make it possible to change regulations that make the fishery inefficient, such as the 32’ boat limit and gear restrictions.  Removing these inefficiencies could reduce fishing costs.  Allowing fishers to “stack” their IFQs and share vessels could further reduce costs.  An IFQ might also make it easier for fishers to process their own fish.  Under the current system, fishers have to fish competitively and have no time for processing. 

 

In response, people questioned whether it would be possible to manage the Bristol Bay salmon fishery through an IFQ system, given the short time period in which fish return and the year-to-year uncertainty of the returns.  The study team would need to look at other IFQ fisheries and consult with ADF&G managers to determine whether an IFQ could work in Bristol Bay.  Since the Bristol Bay fishery is a very short intense season and returns are difficult to predict, it might be necessary for ADF&G to update IFQs very frequently, thereby reducing much of the benefits they offer. 

 

People also questioned how quotas would be allocated.  If catch history was used as the most important criteria for determining an IFQ, there was a concern that many local fishermen who had participated in smaller fisheries might not receive an adequate quota.  Others felt that basing quota shares on catch history rewards those who heavily capitalized their fishing capacity and punishes those who managed to avoid the temptation to overcapitalize.  One participant felt that IFQs make it difficult for younger fishermen to join the fishery.  Another was concerned that corporations would purchase IFQs and individual fishermen would be driven out of the industry.

 

 

 

Alternative Fishing Gear or Methods

 

A few meeting participants spoke about fish traps.  They noted that fish traps would be a cost effective way to fish in Bristol Bay, and that high quality, live fish could be delivered for processing.  However, others felt that running a fish trap would not be a satisfying job for most people now fishing in Bristol Bay.

 

Improve Economics With/Without Changing Fishery Structure

 

Meeting participants were emphatic that simply changing the structure of the fishery will not be enough to sustain it.  Improvements in marketing, product quality and infrastructure are extremely important and should be pursued – even if other restructuring options are never implemented.

 

Marketing

 

People spoke at length about the need to market wild Bristol Bay sockeye salmon in new markets in the U.S. and abroad.  Consumers need to be educated about the superior quality of wild salmon when compared to farmed salmon.  Since wild salmon is more expensive, it must be marketed to people who are willing to pay more for high quality, healthy food.  Wild salmon must be made available in markets throughout the U.S., where only farmed salmon in now sold. 

 

Quality

 

To command a higher price, Bristol Bay salmon need to be of the highest quality.  Fishermen stressed the need for improved fish handling and storage (slush bags or refrigerated sea water).  They suggested that processors should pay a premium for high quality salmon.  Currently, processors pay premiums for high volume, which results in poor handling and lower quality.

 

Infrastructure for Value-Added Processing

 

It was suggested that a local cold storage and ice machine be built to help fishermen improve the quality of their fish, and process and market their own fish.  One person suggested that the Alaska Seafood International (ASI) facility might pick up fish from Bristol Bay for processing, if there was a cold storage available. 

 

New infrastructure could also encourage value-added processing of fish.  One person complained that the Alaska Department of Environmental Conservation’s (DEC) regulations regarding processing facilities make it very difficult for a fisherman to process their own fish.

 

It was suggested that low interest loans or grants be provided to improve boats (e.g., add RSW), build infrastructure for storage and processing, and produce and market value-added products.

 

Price

 

One person requested that the study team show how wholesale prices compare with prices paid to fishermen, to see if there are any options for increasing landed values.

 

Fishing Association

 

Several people spoke in favor of Bristol Bay fishermen organizing and working together to support improvements in prices and other aspects of the fishery.  Organization of a Bristol Bay marketing association was mentioned.

 

Increase Number of Fish Available to Catch

 


More fish, alone, will not create a sustainable fishery in Bristol Bay.  However, many people felt that steps should be taken to improve fish productivity in the bay.  People were especially concerned about the Kvichak River run, which has declined from a very significant (though seasonally variable) salmon run to a level that can no longer support a commercial fishery. 

 

A number of people commented on ADF&G’s management of the fishery.  Some felt that ADF&G should work more closely with local people to find ways to increase fish harvest, while still meeting escapement.  However, one fisherman who has fished commercially in other countries commended ADF&G’s management.

 

Other suggestions for improving returns included enhancing fish runs in Bristol Bay and improving natural productivity in the river systems.  Some people were concerned about interception of the bay’s salmon in other commercial fishing areas, by-catch by trawlers,[4] threats to ocean survival, and predation on Bristol Bay salmon by beluga whales.


 

Economic Subsidies or Protections

 

Subsidies

 

Federal or state government subsidies were suggested, to help fishermen make the transition to a restructured fishery.  People noted that other agricultural sectors are heavily supported by subsidies. 

 

Tariffs and Controls

 

Support was also expressed for tariffs on imported farmed salmon to reduce its price advantage, and prohibiting the “dumping” of extremely low cost farmed salmon on the American market.

 

 

3.3     Dillingham Meeting – Public Comments

 

As in Naknek, people attending the Dillingham meeting had many ideas for making changes to improve the economic sustainability of the Bristol Bay salmon fishery.  Their specific comments are summarized below.

 

A.  Comments on the Restructuring Study

 

Meeting participants thanked BBEDC for sponsoring the restructuring study.  The only specific comment about study design was a suggestion that the study present an analysis of the current cost structure in the fishery, including capital costs for fishing (boats, gear), processing, and shipping.

 

B.    Comments on Restructuring Options

 

Participants at the Dillingham meeting agreed with those in Naknek that steps must be taken to make the Bristol Bay salmon fishery economically sustainable.  People offered comments on options for restructuring the fishery.  However, they also emphasized that quality and marketing must be improved, regardless of whether other changes to the fishery are made. 

 

Reducing the Fleet

 

Buy Backs

 

The option of a government buy back of limited entry permits to reduce the fishing fleet was discussed.  People felt that a permanent (rather than temporary) buy back would be needed to make the fishery sustainable.  One participant at the meeting estimated that the fishery should be reduced to about 1,000 drift net permits (from the current 1,950).[5] 

 

It was suggested that the State retire permits that were purchased with state loans and have been in default.  However, a buy back of less active or retired permits would not have the desired effect of reducing current fishing vessel numbers.

 

A buy back could significantly change the character of the “fishing community” – depending upon whose permits were bought back.  One person felt that permits should be bought back from outside fishers first.  In his opinion, fishing jobs in Bristol Bay are essential to support local people, families and communities, while “outside” fishermen may have more options.  

 

There was concern expressed that if fishermen (rather than the government) had to fund the buy back, each fisherman would accrue debt that would be difficult to pay back. 

 

Some questioned whether a reduced fishing fleet would be able to catch the returning sockeye in the short three-week season.  ADF&G managers were confident that fewer boats could catch a larger harvest.  But, if the processing sector consolidated further, there might not be enough processing capacity in a high return year.

 

Permit Stacking or Exclusive Group Fishing

 

Fishermen questioned whether permit stacking (e.g., two permit holders sharing a vessel) or “exclusive group” fishing (e.g., fishing every other day) would actually reduce costs and help boost their net income.  The study should look at other fisheries where these options have been used.  It would be important for Bristol Bay fishermen to fully understand the cost advantages of these restructuring options before deciding whether or not to support the changes.

 

Fishing Cooperatives

 

Fishing cooperatives were suggested as a way to reduce the fleet and save costs.  While some felt that it would be frustrating to be a non-fishing “shareholder” in a cooperative, others thought that it might be a responsible business decision and a legitimate way to use one’s equity in a fishing permit and gear.  It was suggested that the restructuring study report on how the Chignik cooperative’s experience and success in 2002.

 

Fish Allocation by Quota (IFQs)

 

The study team asked people at the Dillingham meeting for their opinion on using an IFQ system to manage the fishery.  In response, it was suggested that catch history not be the only criteria used to determine the quota.  One person was concerned that high-volume fishermen who had not followed the rules in the past would be rewarded.  Others were concerned that people working in smaller fisheries, such as Togiak, would not be awarded sufficient quota.  Some people suggested that criteria favor local participation in the Bristol Bay fishery.

 

People suggested that IFQs should be “stackable,” so fishermen could save costs by sharing vessels and gear.  It was noted that an IFQ system may give fishermen the ability to use more efficient gear and methods.  Each fishing district in Bristol Bay should be able to decide whether or not to be managed through IFQs.

 

People questioned whether it would be possible to manage the Bristol Bay salmon fishery through IFQ, given the short time period in which fish return and the year-to-year uncertainty of the returns.  Robin Samuelson stated that an IFQ program would be very complicated and time-consuming to develop.  It took six years to develop an IFQ system for halibut and sablefish.  An IFQ system for the bay’s salmon fishery would be even more complex.

 

 

 

 

Alternative Fishing Gear or Methods

 

A few fishermen stated that using alternative gear instead of gill nets might improve fish quality.  Conversely, one person was concerned that changing gear (e.g., to seiners) would simply increase capitalization of the fishery, with no guarantee that new capital investments would be recovered.

 

 

Improve Economics With/Without Changing Fishery Structure

 

People attending the Dillingham meeting agreed with those in Naknek – that simply restructuring the fleet to reduce harvesting costs would not make the fishery economically sustainable.  Improved marketing and quality, and value-added processing, are needed to bring prices up.  

 

Marketing

 

Meeting participants strongly urged more effective marketing of wild salmon to increase demand and price.  There are niches for wild salmon that need to be exploited – particularly in the U.S.  Consumers need to be educated about the superior quality of wild salmon when compared to farmed salmon.  Some participants suggested that the Alaska Seafood Marketing Institute should be better funded. 

 

It was suggested that fishermen should have a stronger role in marketing their own catch.  Currently, most fishermen rely on processors to purchase and market their catch. 

 

One person thought that funds that are being spent for training and education programs in the Bristol Bay region should be spent, instead, on rebuilding the fishery through marketing.

 

Transportation of fish from Bristol Bay is difficult and hinders effective marketing.  The Jones Act, which prohibits a foreign tramper from stopping at two consecutive U.S. ports, makes it impossible to transport fish from Bristol Bay to the U.S.  Changes to the Jones Act are needed, or other vessels or transportation used, to allow salmon to be marketed in the U.S.

 

There is a need to expand options for shipping salmon from Bristol Bay, particularly in the late season.  The potential of using the Alaska Seafood International (ASI) plant in Anchorage was mentioned, but Bristol Bay fishermen have found it difficult to get the fish there for processing.

 

 

Quality

 

Meeting participants emphasized the need to improve quality of the fish immediately, through improved salmon handling and storage (especially slush bags).  It was noted that BBEDC is working to improve salmon quality through its slush bag pilot program.  Quality guidelines agreed to by fishermen and processors should be considered.

 

Fishermen noted that there is currently no incentive to improve quality.  Processors do not pay a premium for high quality salmon, and fishermen do not know which of their fish will be canned and which might be sold as fillets (that need to be handled more carefully).  It was suggested that processors should pay a premium for high quality salmon, rather than for high catch volumes. 

 

Several participants commented that fish caught in the rivers are lower quality than fish from the bay.  Shallow water sets collect sand and drag fish on the bottom. 

 

Infrastructure for Value-Added Processing

 

Several fishermen were interested in processing and marketing their own fish to ensure its high quality and to increase their income.  One person commented that the Alaska Department of Environmental Conservation (DEC) regulations for fish processing facilities make it difficult for a fisherman to process their fish or produce any value-added product.

 

It was suggested that a local cold storage and ice machine would help fishermen improve the quality of their catch, and process and market their fish.  One person suggested that a “state of the art” custom processing facility be built in the region. 

 

It was mentioned that processors might also need financial support to retool, to produce higher quality, value-added salmon products.

 

Landed Price

 

There was considerable discussion of how landed price is determined and whether the processors could give fishermen more certainty about price before and during the season.  Fishermen are uncertain about whether to upgrade their boats and gear to improve fish quality, if they are unsure they will recover their investment.  One processor noted that it is difficult for them to ensure a set price, because they do not know what they will be paid for fish in the winter market.

 

Some fishermen felt that processors are overcapitalized and have to pay low prices for fish to ensure they can cover their fixed costs.  Others commented that processors who market farmed fish as well as wild salmon do not have an incentive to help promote consumption of wild salmon.

 

Fishing Association

 

Many people spoke in favor of Bristol Bay fishermen organizing and working “in unity” to support improvements in price, quality, marketing and other aspects of the fishery.  One person described an association of fishermen in South Africa that offered grant-funded subsidies as an incentive to join the association. 

 

It was suggested that a joint fishermen/processors association would be most effective at improving product quality and marketing.  A joint association might help overcome the inherent mistrust felt among fishermen, and between fishermen and processors. 

 

Increase Number of Fish Available to Catch

 

Concern was expressed that ocean trawlers may be destroying offshore habitat and feed essential to salmon survival.

 

Comments were also made about ADF&G’s management of the fishery.  One person noted that in-river fishing might be damaging to smolts.  Another felt that too many permits are allocated to drift net fishermen, rather than set netters.  A concern with over escapement in the Nushagak district was mentioned, and the potential to harvest late run fish that contribute to that escapement.  Finally, it was suggested that the cost-recovery fishery be moved from Middle Bluff (which is a mixed-stock area), to other areas where managers expect escapement levels to be reached.

 

Economic Subsidies or Protections

 

Subsidies or Government Support

 

It was suggested that the federal or state government provide a subsidy to help Bristol Bay fishermen as the fishery is restructured.  One person suggested that the government buy Alaskan salmon to use in food programs.

 

Tariffs and Controls

 

Meeting participants supported placing tariffs on imported farmed salmon to reduce its price advantage.

 

Competition with Other Alaskan Fisheries

 

It was noted that Bristol Bay salmon compete in the marketplace with other Alaskan salmon, including hatchery produced chums in southeast and Prince William Sound.  Statewide fish policy, which promotes and subsidizes hatchery production, affects the market for Bristol Bay salmon.  It was suggested that the study team evaluate the state regulations and policies that create this intra-state competition and conflict.

 



[1] See www.bbsalmon.com to view a Power Point presentation describing the study.  Study team members attending the meetings were:  Michael Link, Project Manager, LGL Limited; Bob Waldrop, consultant; and Marcus Hartley (Naknek) and Scott Miller (Dillingham) of Northern Economics.  Jan Caulfield of Sheinberg Associates facilitated the meetings. 

 

[2]  Web site: www.bbsalmon.com; email the study team: bbsalmon@lgl.com

[3] Fisheries that allow people to fish every other day were referred to as “A-B” or “odd-even.”

[4]  Robin Samuelson responded that the North Pacific Fishery Management Council has taken effective steps to limit by-catch and provide 100% observer coverage for foreign trawlers.

[5] The extent of any buy back would be determined by an “optimum numbers study” prepared by the State of Alaska, Commercial Fisheries Entry Commission (CFEC).