4.1 Overview of the Chapter
The previous chapter provided an overview of the changes in the distribution of QS holdings and QS holders from initial issuance through year-end 1995 by resident category, type of entity, size of QS holding, QS block status, and initial issuees versus new entrants. The chapter focused upon the net results of 1995 transfer transactions. This chapter provides more details on these transfer transactions and includes a review of the 1995 impact of program rules such as the CDQ compensation QS swaps and the sweep-up of small blocks. This chapter provides summary data on the following topics:
4.2 CDQ Compensation QS Swaps Across Catcher Vessel Categories
Under the new sablefish IFQ program, portions of the Aleutians and Bering Sea area sablefish TACs are set aside each year for Community Development Quotas (CDQs) under the Western Alaska Community Development Program. By regulation, 20% of the TAC is set aside in each area.1 These CDQ portions of the TAC are allocated among eligible western Alaskan communities in accordance with Community Development Program plans approved by the Governor of Alaska, in consultation with the NPFMC, and by the United States Secretary of Commerce.
In making these CDQ allocations, the NPFMC decided that they also wanted to "compensate" entities who received initial sablefish QS allocations in the Aleutians and Bering Sea areas for the reduction in their annual IFQs due to the CDQ allocations. The NPFMC chose a one-time compensatory mechanism whereby initial QS recipients in these CDQ areas would be awarded "CDQ compensation QS" in the sablefish non-CDQ areas. The non-CDQ sablefish areas are Southeast, West Yakutat, Central Gulf, and the Western Gulf.2
The complex formula utilized for doing this partially compensated initial QS recipients in CDQ areas for their losses and implicitly taxed QS recipients in non-CDQ areas. The addition of compensatory QS to the QS pool in non-CDQ areas reduced the IFQ value of a unit of QS in each of these areas.
The objective of the compensatory mechanism was to make all initial QS recipients share on an equal percentage basis the average loss in IFQ due to the CDQ allocations in Western Alaska areas. The formula for the CDQ compensation QS allocation was designed to serve that function.3
CDQ compensation QS in non-CDQ areas was a form of compensation that many recipients could not fish readily. If someone received CDQ compensation QS, they would receive a portion of the compensatory QS in each of the sablefish non-CDQ areas.4 Often the person had not fished previously in these non-CDQ areas and often the CDQ compensation QS was too small to be "fishable" by itself.
For these reasons, the NPFMC expected that the "compensation" would often occur with a sale of the CDQ compensation QS to another entity who could make better use of it. The NPFMC debated how to treat the CDQ compensation QS with respect to the other rules governing the IFQ program.
Under the rules for regular QS, if the amount initially allocated would be worth less than 20,000 pounds of hypothetical "IFQ" under the 1994 TAC, then the QS would be issued as a "block" and would have to be transferred as a block.5 It was anticipated that much of the CDQ compensation QS would be in small amounts that might well be hard to sell if they were placed into blocks.
The NPFMC eventually settled upon a rule that would combine CDQ compensation QS in a non-CDQ area with any regular QS initially issued to the entity for that area. If the recipient's regular QS was unblocked the additional CDQ compensation QS would also be unblocked.
If the recipient's regular QS would have been issued in a block then the CDQ compensation QS was to be rolled into the block, unless the addition of the CDQ compensation QS put the entity over the blocking limit for the area. When the addition of the CDQ compensation QS put the person over the blocking limit, then all of the person's QS for the area was to be combined and issued as unblocked.6
Alternatively, if a person was issued CDQ compensation QS in an area for which the person was not initially issued any other regular QS, then the CDQ compensation QS was left unblocked. During 1995, an additional rule was added for persons who had received catcher vessel CDQ compensation QS in an area when the person held no regular QS for that area. This rule made such catcher vessel CDQ compensation QS "fishable" across catcher vessel categories and tradeable across catcher vessel categories upon the first permanent transfer.
The ability to transfer this type of CDQ compensation QS between catcher vessel categories has been referred to as "swap-ability." The addition of this rule was meant to facilitate transfers so that "compensation" could occur. Persons with "swappable" CDQ compensation QS for a catcher vessel category can have it transferred and swapped to the catcher vessel category designated by the transfer recipient. The rights to "swap" this type of CDQ compensation QS expire upon the first transfer or on February 24, 1997, whichever occurs first.7
4.2.2 Summary of 1995 Swaps of CDQ Compensation QS
As noted above, persons initially issued CDQ compensation QS in a catcher vessel category for an area where they received no regular QS have the right to swap the QS to another catcher vessel category upon permanent transfer. The "swap" converts the original CDQ compensation QS to the catcher vessel category designated by the transfer recipient. The NMFS-RAM division started allowing some swaps during 1995 after it became clear that the regulation would be approved.
The tables in this section provide details on swaps that occurred during 1995. The reader should be aware that there appear to be some errors on the NMFS-RAM initial allocation file and current file with respect to blocking factors and "swappable" CDQ compensation. NMFS has been notified of the errors but the problems remain unresolved as of this writing. It is possible that further editing will be done on the NMFS files before any updates of this report. As a result, some of the data herein may change in future reports.
The authors had to estimate which initially allocated CDQ compensation QS segments were "swappable" based upon the current IFQ program regulations. The amount of CDQ compensation QS that was swappable may also change as corrections are applied to the NMFS data. For these reasons, these data should be considered preliminary.8
Table 4.2.2-1 provides summary data by area and vessel category on the transactions involving "swappable" CDQ compensation QS during 1995. The large catcher vessel category contains vessels greater than 60 feet length overall (LOA) The small catcher vessel category contains vessels less than or equal to 60 feet LOA. Note that CDQ compensation QS and swappable CDQ compensation QS can only exist in the non-CDQ areas of Southeast, West Yakutat, Central Gulf, and the Western Gulf.
The table indicates the amount of "swappable" CDQ compensation QS that was initially issued by area and vessel category. Within each area, the table provides the amount of QS that was swapped out of each vessel category, swapped into each vessel category, and the net change in each vessel category due to swaps. These data include the number of swaps involved and the percentage of the initially issued swappable CDQ compensation QS that was swapped from each vessel category.
As can be seen, there was only one swap transaction. This involved the swap of 5,687 QS from the large vessel class to the small vessel class in the West Yakutat area. About 22% of the West Yakutat swappable large vessel QS was swapped. There were no swaps in the other non-CDQ areas.
Table 4.2.2-1 also provides information on the initially issued swappable CDQ compensation QS that was transferred without being swapped. By regulation, these QS shares also lose the right to be swapped upon the first transfer.
In addition, the table provides the amount of swappable CDQ compensation QS that still remained at the end of 1995 by area and vessel category and the percentage that this remaining amount represents of the initially issued swappable CDQ compensation QS for that area and vessel category. The percentage remaining varies from 49.4% for large vessels in West Yakutat to 100% for large and small vessels in the Central Gulf and small catcher vessels in the Western Gulf. By regulation, the rights to "swap" expire upon the first transfer or on February 24,1997, whichever comes first.9
The swap and subsequent transfer of swappable CDQ compensation QS, or the transfer of such QS, decreased the amount of available swappable CDQ compensation QS during 1995. These transactions also reduced the number of persons who still hold swappable CDQ compensation QS.
Table 4.2.2-2 provides a succinct summary by area of the changes in swappable CDQ compensation QS from initial issuance though year-end 1995. It also shows the number of persons who held swappable CDQ compensation QS at initial issuance and the number who still held it at year-end 1995. Again, under the current regulations of the IFQ program, the privilege to "swap" this type of CDQ compensation QS will expire if not used by February 24, 1997.
4.3 QS Transfers
4.3.1 QS Permanent Transfer and Lease Rates
This section looks at the volume and rate of permanent QS transfers and seasonal QS leases during 1995.
Table 4.3.1-1 shows the amount of QS in each area, the amount of QS permanently transferred in 1995 and the ratio of these permanent QS transfers to the QS outstanding. This ratio will be called the "QS transfer rate." It also shows the amount of QS leased during 1995 and the ratio of the QS leased to the total QS outstanding. This ratio will be called the "QS lease rate."10
As can be seen, the QS transfer rates ranged between 5.42% in the Western Gulf to 9.03% in Southeast. In contrast, the QS lease rates show much stronger contrasts and a clearer pattern.
Lease rates in the three easterly areas range from 1.69% to 2.70%, while rates in the three western areas range from 10.57% to 21.58%. The low lease rates are much lower than the corresponding low transfer rates, while the high lease rates are much higher than the corresponding high transfer rates. The lease rates in the western areas are much higher than the transfer rates in those areas despite restrictions on leasing under the IFQ program. Under program rules, only 10% of a person's catcher vessel QS for an area can be leased in a year, and QS in blocks cannot be separated for lease purposes.11
Table 4.3.1-2 provides similar information for QS holders. The table shows the original number of QS holders in an area, and the number and percentage of holders who permanently transferred some amount of QS during 1995.12 This will be called the "QS holder transfer rate." The table also provides the number of QS holders who leased some of their QS during 1995 and the percentage of original QS holders who leased QS during 1995. This percentage will be called the "QS holder lease rate."
The QS holder transfer rate was relatively high in the eastern management areas and tended to fall from the eastern to the more western areas. The highest rate was 20% in the Southeast management area, and the lowest, at 8%, was in the Bering Sea. Note that the rates were lowest in the two western areas.
The number of QS holders involved in lease transactions was low in all areas, ranging from eight persons in each of the three westerly districts -- the Western Gulf, Aleutians, and the Bering Sea -- to 13 persons in the Central Gulf. Two percent of persons leased in the three easterly areas -- Southeast, West Yakutat, and the Central Gulf -- while 6% leased in the Aleutian Islands and the Bering Sea.
Tables 4.3.1-3 and 4.3.1-4 show similar information by management area and vessel class. As these tables show, there were distinctly different patterns of permanent transfer and lease activity for freezer vessels and catcher vessels during 1995.
At least some transfers took place in every area and vessel class combination. QS transfer rates ranged from 0.3% among the freezer vessels in the Western Gulf to 37.4% among the small catchers in the Aleutians. Transfer rates were always highest among small catchers and next highest in five of the six management areas for large catchers. Small vessel catcher QS transfer rates were higher in the three western management areas than they were in the eastern management areas.
In stark contrast, almost all of the leasing activity that occurred during 1995 was in the freezer vessel category. The percentage of leased freezer vessel QS ranged from 19.3% in the West Yakutat and Central Gulf areas to 39.4% in the Aleutians. Only two of the twelve catcher groupings in all areas indicate QS leasing, and these involved relatively small amounts of QS.
The person transfer rates are summarized in Table 4.3.1-4. The person transfer rates do not have as great a range as the QS transfer rates; the lowest person transfer rate is 5% for Bering Sea large catchers, and the highest is 21% for Southeast small catchers. Person transfer rates for small catcher vessels were higher in the three eastern management areas than they were in the three western management areas; this is the opposite pattern to that seen for QS transfer rates. Person lease rates show a pattern very similar to that of QS lease rates; almost no holders of catcher vessel QS were involved in leasing and leases were concentrated among freezer QS holders.
4.3.2 Consolidation of QS Holdings Due to Transfers
The sablefish IFQ program was implemented in a fishery that had not been previously placed under limited entry. As such, the fishery had a considerable annual turnover of participants, and many entities were initially allocated small amounts of QS.
At the beginning of the program, it was anticipated that there would be some consolidation of QS as small quota holdings would be transferred to more full-time operations. While the NPFMC felt that some consolidation was desirable, they added many features to the program to ensure that consolidation would not result in radical changes in the fleet. These features include limitations on the amount of QS an entity can use, constraints on the amount of IFQ that can be fished from a vessel, restrictions on the entities who are eligible to receive QS by transfer, restrictions on transfers across vessel categories, constraints on the leasing of QS, and "blocking" of QS worth less than 20,000 pounds of IFQ.13
The two tables in this section provide information on the consolidation of QS due to 1995 transfers. Table 4.3.2-1 provides summary data by sablefish IFQ management area. The table shows the amount of QS initially issued in the area, the number of initial QS holders in the area, and the average QS per QS holder. The values of these variables are inclusive of 1995 "swap" transactions.14
Table 4.3.2-1 also shows the number of transfer transactions, the number of QS transferors, the number of QS transfer recipients, the year-end number of QS holders, the average QS holdings at year-end 1995, and the percentage change in the number of QS holders due to transfers. These variables are shown for each sablefish IFQ management area.
As can be seen, 1995 transfer transactions resulted in consolidation of QS holdings in all of the management areas. In each area the number of QS holders declined and the average QS holdings increased as the net result of QS transfer activity. The percentage decrease in the number of QS holders in these areas due to 1995 transfer activity ranged from approximately 1% in the Bering Sea area to 7% in the Southeast area.
Table 4.3.2-2 provides similar information broken out by both sablefish IFQ management area and vessel category. Here the counts of QS in a vessel category and the number of QS holders in a vessel category again reflect initial issuance plus any 1995 "swap" transactions across vessel categories within an area.15
Table 4.3.2-2 shows that the number of QS holders in the freezer vessel category either stayed constant or increased and the average QS per QS holder either stayed constant or declined as the net result of 1995 transfer activity. This was more than offset in each area by the decline in the number of catcher-vessel QS holders and the increase in the average QS holdings per QS holder due to 1995 transfer activity.
4.3.3 Sweep-up Consolidations
This section examines the sweep-up provisions in the sablefish IFQ program and examines the impacts of sweep-ups during 1995.
Under the IFQ program's QS "block" rules, no person can hold more than two blocks in an IFQ area, and persons who hold unblocked quota in an IFQ area can hold only one block of QS. Many blocks that were issued were very small, and in some cases they were probably too small to make a fishing trip worthwhile. While the blocking rules were added to try and make a portion of the QS unattractive to the full-time fleet, some of the blocks that were initially allocated were so small that they were not particularly attractive to the part-time fleet either. Proponents of the block proposal anticipated this problem, and the NPFMC included a "sweep up" provision for very small blocks in the program rules.
Under the sweep-up rules existing in 1995, blocks of QS that translated into less than 3,000 pounds of a hypothetical IFQ for sablefish within a regulatory area and vessel category could be consolidated into a larger QS block of up to 3,000 pounds of the hypothetical IFQ.16 For example, a person with a 2,500 pound block and a person with a 400 pound block could, through transfer and consolidation, create a new 2,900 pound block.
RAM data suggest that there are a significant number of blocks of sablefish QS that fall into a range that would make them sweepable under this provision. The data also show that the sweep-up provisions did not have large impacts during 1995.
Table 4.3.3-1 provides data on the number of persons who were initially issued sweepable blocks, the number of sweepable blocks initially issued and the QS units associated with those sweepable blocks. The table also provides year-end 1995 data ("current") for the number of persons who held sweepable blocks, the number of sweepable blocks, and the QS units associated with those sweepable blocks. The change from initial issuance to year-end 1995 in the number of persons with sweepable QS blocks, the change in the number of sweepable QS blocks, and the change in the amount of sweepable QS are also included in the table.17 These data are provided by management area.
The number of persons holding sweepable QS blocks and the number of sweepable blocks declined slightly during 1995. Note that sweep-up transactions do not decrease the amount of sweepable QS. Sweep-ups that occurred resulted in new combined blocks that were still worth less than 3,000 pounds of the hypothetical IFQ as noted above.18
Table 4.3.3-2 provides summary information on the sweep-up transactions by area. As can be seen, there were a total of only 15 sweep-up transactions and all of these transactions occurred in Southeast, West Yakutat, and the Central Gulf. The total amount of sweepable QS involved in these transactions was quite small relative to the amount of sweepable QS in each area, and the number of sweepable blocks involved was small relative to the number of sweepable QS blocks in each area.
An oddity on the RAM database is that a person must first hold QS before they can execute a sweep-up transaction. Thus for a person who holds no QS but wants to purchase and sweep-up one or more blocks, the first transaction computerized for the person is entered as a "transfer" and not as a "sweep-up." Subsequent transactions associated with the entire sweep-up are entered individually as sweep-up transactions.
Thus for some persons, the data in Table 4.3.3-2 does not show the transfer of the first block involved in the sweep-up. If a person already held a block of sweepable QS then the purchase of additional blocks to combine in the sweep-up would be entered as sweep-up transactions in the database.
At their April 1996 meeting, the NPFMC voted to increase the size of the sweep-up limit to increase the number of economically fishable blocks. The new sablefish sweep-up limit will be 5,000 pounds of sablefish. This will be converted to QS equivalents using the 1995 TACs. If approved by the Secretary of Commerce, this new limit would take effect in 1997.19
Table 4.3.3-3 puts the sweepable QS into perspective with the total QS and the total blocked QS in an area at of the end of 1995. As can be calculated from the table, the percentage of total QS that is blocked ranges widely from 8.3% in the Central Gulf to 62.6% in the Bering Sea. The percentage of persons who hold blocked QS is much higher, from 54.9% in Southeast to 94.9% in the Bering Sea.
In contrast, the percentage of the QS that is sweepable at the end of 1995 is small, ranging from 0.7% in the Aleutians area to 15% in the Bering Sea area. However, the percentage of QS holders who hold sweepable QS is again relatively large, ranging from 22.9% in the Southeast area to 68.8% in the Bering Sea area. This again demonstrates, as do other tables in the report, that a high percentage of sablefish QS holders hold small amounts of QS.
Table 4.3.3-4 provides another look at sweepable QS as of the end of 1995. The data indicate that a large percentage of the persons who hold sweepable QS blocks in an area hold no other blocks for the area.
4.3.4 Changes in the Holdings of QS by Resident type Due to Transfers and Sweep-ups
The initial distribution of QS and the changes in that distribution are topics of interest for those who have been concerned about the potential consequences of the new IFQ program. Earlier sections examined this topic using Alaska census areas as resident categories. Other sections broke out the analysis into five resident types, including nonresidents of Alaska (N) and four Alaska resident types: Alaska Rural Local (ARL), Alaska Rural Nonlocal (ARN), Alaska Urban Local (AUL), and Alaska Urban Nonlocal (AUN). This section uses those same five resident types to examine changes in QS holdings that resulted from transfers and sweep-ups.
The five resident categories were established by classifying Alaska communities as local or nonlocal to sablefish areas. The following rules were used:
Tables 4.3.4-1 and 4.3.4-2 provide summaries of net changes in QS holdings and the number of persons with QS, by IFQ area and resident type, due to permanent transfer of the QS.20 These tables provide another perspective on the distribution of QS ownership and changes in QS ownership.
Table 4.3.4-1 provides data on changes on QS holdings by management area and resident type. For each IFQ area and resident type, the table provides data on the amount of QS initially issued to the resident type, the year-end 1995 amount of QS held by the resident type, QS transferred away from the resident type, QS transferred to the resident type, and the net change in QS held by the resident type during 1995.
The table also provides data on the percentage of the area's QS initially issued to the resident type, the year-end 1995 percentage of the area's QS held by the resident type, the percentage of the area's "transferred QS" that was transferred away from the resident type, the percentage of the area's "transferred QS" that was transferred to the resident type, and the net percentage change in the amount of QS held by the resident type during 1995.
The table indicates that nonresidents received the highest percentage of the QS initially issued in every management area except for the Southeast area. In the Southeast area, Alaska residents received the highest percentage of the QS. Alaska urban locals (AULs) received about 45% of the QS in Southeast. Transfers during 1995 did not change the relative rankings of the resident types in any area, and the resident type which received the highest percentage of QS in an area at initial issuance still held the highest percentage of the area's QS at year-end 1995.
Table 4.3.4-2 provides similar data on changes in the number of QS holders by resident type. For each IFQ area and resident type, the table provides data on the number of persons from the resident type who received an initial QS allocation, the year-end 1995 number of persons holding QS from the resident type, the number of QS transfer transactions from the resident type and the number of transferors involved, the number of QS transfer transactions to persons of the resident type and the number of transfer recipients involved, and the net change in the number of QS holders during 1995.
The table also provides data on the percentage of the area's QS holders classified in the resident type at initial issuance, the year-end 1995 percentage of the area's QS holders classified in the resident type, the percentage of the area's transferred QS that was transferred away from the resident type, the percentage of the area's QS transferors who were from the resident type, the percentage of the area's QS transfer recipients who were from the resident type, and the net percentage change in the number of QS holders by resident type during 1995.
The distribution of QS holders by resident type in Table 4.3.4-2 differs somewhat from the distribution of QS holdings by resident type in Table 4.3.4-1 due to differences in average QS holdings. The percentage of nonresident QS holders in each area is less than the percentages of QS held by nonresidents. This is due to larger average nonresident holdings.
The decline in the number of QS holders during 1995 only altered the rank order of the percentage of QS holders by resident type in one area. In the Central Gulf, transfers made Alaska urban locals (AULs) the largest group of QS holders and reduced nonresidents to the second largest.
4.4 QS/IFQ Lease Transactions
The volume of QS leases during 1995 was briefly covered in earlier tables in this report. This section provides a more detailed examination of formal leasing activity during 1995.
As noted above, the sablefish IFQ program rules allow for some leasing of QS. Holders of freezer vessel QS are free to lease all of their holdings during a year. Holders of catcher vessel QS may lease up to 10% of their QS for any management area and vessel class during a year. This QS could be leased to one or more persons. All leases expire on December 31 of the year in which they were made. The rules only provide that sablefish catcher QS may be leased in the years 1995, 1996, and 1997. The regulations providing for leases expire at the start of 1998.21
Table 4.4-1 provides information on sablefish QS leases during 1995 by IFQ area and vessel category. The table shows the amount of QS and the number of QS holders in each vessel category after 1995 QS swaps have been applied. It also shows the number of leases, the number of lessors, the number of lessees, the total amount of QS leased, the average amount of QS leased, and the percentage of total QS leased for each area and vessel category.
As noted earlier, very little catcher vessel QS was leased but substantial portions of the freezer vessel QS were leased. The percentages of leased freezer processor QS ranged from 19.3% in the West Yakutat and Central Gulf areas to 39.4% in the Aleutians area. There were a total of 77 lease transfers during 1995.
The rules of the IFQ program may help account for the small number of formal catcher vessel QS leases. First, as noted above, no one may lease more than 10% of their catcher vessel holdings in any given management area and vessel class. Second, as described below, the interaction of the blocking rules and the leasing restrictions made it hard to lease catcher vessel QS blocks.
Also, there may be ways to lease QS informally without the need of a formal lease transaction. For example, the hired skipper rules may have provided some operations an alternative means to lease all of their QS during 1995. Moreover, some fishermen may have sold their QS with the tacit understanding that they could repurchase it at the end of the season.22
Freezer vessels are not constrained as much by leasing restrictions. While they cannot break up a block of freezer vessel QS for leasing purposes they can lease the entire block since they don't face the 10% restriction on the amount of QS that they can lease. Table 4.4-2 shows the 1995 leases of blocked QS only. No blocked catcher vessel QS was leased; however, there were leases of blocked freezer vessel QS. Leases of blocked QS were usually a small part (2% or less) of total blocked freezer vessel QS. The Bering Sea freezer category was an exception; 17.1% of this QS was leased.
The IFQ program rules which allow only limited leasing of catcher vessel QS represent a compromise designed to balance two program objectives. Opponents of leasing wanted to keep QS in the hands of active fishermen rather than absentee QS holders. They also thought that the ability to lease QS might dampen the volume of QS sales and make it more difficult for new persons to enter the fishery as QS owners. Proponents of QS leasing wanted to maintain operational flexibility for fishermen in a dynamic environment.23 The 10% rule sought to balance both sets of concerns.
The leasing limitation can interact with the rules governing blocking of QS to restrict the amount of blocked quota that may be leased. As noted earlier, blocked QS must be transferred on an all or nothing basis. Blocks may not be broken up to allow some of the QS to be leased. Thus, a person who only held one block of QS in an area could not lease that block or any part of it. A person with two blocks would not be allowed to hold any unblocked QS. This person would only be in a position to lease QS if one block was no more than 10% of the person's total QS holding.24
As noted above, there are informal ways to lease QS that would not result in a formal lease transaction. These methods might lead to a de facto lease transfer of more than 10% of person's QS for an area and catcher vessel category. Regulations provide that: "An individual who receives an initial allocation of catcher vessel QS does not have to be aboard the vessel and sign IFQ landing reports if that individual owns the vessel on which IFQ sablefish or halibut are harvested, and is represented on the vessel by a master employed by the individual who received the initial allocation of QS." This provision is not extended to persons who were initial issuees of QS in the Southeast management area.25
The regulation does not indicate a minimum percentage ownership to qualify as an owner under this regulation. There have been reports that some catcher vessel QS holders have purchased small shares in the vessel of another person, and have filed paperwork to allow the other person to fish as the QS holder's "employee."
As noted above, persons might also be able to circumvent this regulation by selling their QS with a tacit understanding that the QS would be transferred back to the individual QS holder at the end of a specific period of time. Examination of RAM computer records shows that only one return transfer of 387 QS units occurred in 1995.26 This is not a complete check on the extent of this type of activity, since some return transfers may take place in subsequent years.
Table 4.4-3 provides information on the extent to which lessees (persons who receive leased QS) were initial QS recipients or new QS holders. A large portion of the leased QS went to persons who were not initial QS recipients. New persons constituted over 50% of the persons leasing QS in all management areas and vessel classes in which leases occurred.
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