2 THE PREDICTED AND THE ACTUAL INITIAL ALLOCATION OF QS

2.1 Introduction

This chapter compares the actual initial distribution of sablefish QS through 1995 1 with the distribution predicted using the best available data prior to the program. The NPFMC analyzed potential impacts of the sablefish IFQ program prior to adopting their plan. The probable initial distribution of QS was one of the topics explored.

To analyze the initial QS distribution and other issues, NPFMC and NMFS research staff constructed a data file from 1984-1990 sablefish catch data and sundry sources on vessel ownership. The staff estimated who owned the vessel at the time sablefish landings occurred.

Estimates of the initial QS distribution from these data were reported in NPFMC reports and staff analyses.2 Sometimes the estimates were shown in terms of IFQ assuming 1991 TACs. While most persons expected these estimates to represent reasonable "ball park" figures, no one expected the estimates to be completely accurate because there were many places where errors could arise, even with the best available data.

There could be many reasons why the actual initial QS distribution might vary from earlier predictions. The following paragraphs provide a few examples:

1. The computerized sablefish catch file could contain data errors on amount of catch, location of catch, and the vessel used in making the landing. These types of errors would be discovered during the initial allocation process.

2. The NPFMC adopted a rule which allowed a leaseholder, rather than the vessel owner, to receive credit for sablefish caught during the qualification years. There was no way to predict from existing records where leases might exist. The issue of credit for a leaseholder rather than a vessel owner for initial QS purposes could only be resolved by evidence presented during the initial allocation process.

3. The available data on vessel ownership could be inaccurate. Again, issues on which entity actually owned a vessel at the time a landing occurred could be raised and resolved with evidence presented during the initial allocation process.

4. The predictions made on the initial distribution of QS were made prior to the NPFMC's adoption of a rule to award CDQ compensation QS in non-CDQ areas to compensate QS recipients in the Bering Sea and Aleutian Islands whose available IFQ was reduced due to CDQ allocations. The actual distribution of QS includes all CDQ compensation QS. Thus if no other factor had changed, CDQ compensation QS would have increased the number of QS holders in Southeast, West Yakutat, Central Gulf, and Western Gulf over the number predicted in the earlier analyses.

5. The predictions of the initial distribution of QS assumed that everyone who appeared to be eligible would apply. The actual distribution reflects those who actually applied and were issued QS. To the extent that some eligible entities did not apply, numbers of initial QS recipients would have been lower.

6. The predictions of the initial distribution of QS by resident type were based on available address data at the time the data file was created for the earlier NPFMC's analyses. The actual initial distribution of QS by resident type is based upon the address of the QS recipients at the time of initial allocation. Even if the person who owned a vessel was the same on both files, the person's address could be different at two points in time that are several years apart.

As can be seen, there are many reasons why predictions from the data available prior to the IFQ program could vary somewhat from the actual initial allocation. The list of reasons provided above are only examples and do not exhaust the possible reasons for potential differences between the actual and predicted distributions.

This chapter will examine the actual initial distribution of QS from several perspectives and compare it with the distribution that would be predicted using the data used in the earlier NPFMC studies.3 The authors will highlight the similarities and differences between the distributions as shown in the tables. However, where differences exist, no attempt will be made to explain the precise reasons for the differences.

2.2 Predicted and Actual Distribution by Management Area and QS Size Category

Table 2.2-1 compares the actual initial distribution of sablefish QS with the distribution predicted using the earlier data prepared for NPFMC analyses. It is organized by sablefish management area and QS size category. As can be seen, at this level of disaggregation the distributions are quite similar.

The actual number of QS recipients was higher than what was predicted in the Southeast, West Yakutat, and Western Gulf areas. In these areas, the number and percentage of persons with less than 5,000 QS units was much higher than predicted from the earlier data. This may be partially due to the fact that a number of persons issued CDQ compensation QS for these areas were not counted in the earlier analyses.

The actual number of QS recipients was lower than predicted in the Central Gulf, Aleutian Islands, and Bering Sea areas. This may be partially due to some entities not applying for QS, or partnership agreements where multiple persons agreed to have the QS issued to only one partner.

2.3 Predicted and Actual Distribution by Management Area and Vessel Category

2.4 Predicted and Actual Distribution by Management Area and Area of Residence

Table 2.4-1 compares the actual initial distribution of sablefish QS by management area and resident category of the QS holder with the distribution predicted by the data used in earlier NPFMC analyses.4 All entities receiving QS were placed into 1990 Alaskan Census Areas or an "Outside Alaska" area based upon the address of the entities on the respective data files.

The table shows the amount and percentage of QS and the amount and percentage of QS recipients that fall into each resident category. It also shows the number and percentage of the quota shares that fall into each resident category. These figures are reported for both the actual initial QS distribution and the predicted distribution from the earlier NMFS data.

The amount and percentage of sablefish QS that was issued to entities from the "Outside Alaska" resident category were greater in most sablefish management areas than would have been predicted from the earlier NMFS data.

In all management areas, the percentage of the area's QS issued to entities from the "Outside Alaska" resident category was higher than had been predicted. For example, the Southeast area predictions based upon the earlier data suggested that approximately 20.0% of the area's QS would be issued to entities from "Outside Alaska." In actuality, 35.7% of the Southeast area's QS was issued to entities from "Outside Alaska." In the other areas, the difference between predicted estimates and actual allocations was less than 10%.

Similarly, in all sablefish management areas, the amount and percentage of QS recipients in an area who were from "Outside Alaska" were greater than would be predicted using the best available data prior to the IFQ program. The largest percentage difference in predicted vs. actual number of initial recipients occurred in the West Yakutat management area, where predictions estimated that 32.9% of the initial allocants would be in the "Outside Alaska" category. The actual number of initial QS recipients in this area from "Outside Alaska" represented 44.3% of the total persons. Some of these differences can likely be explained by CDQ compensation. Historically, a large percentage of the persons who fished the Aleutian Islands and Bering Sea were nonresidents of Alaska. Initial QS recipients from these areas received QS in other areas under the rules for CDQ compensation, thereby increasing the number of nonresidents in those areas.

Within Alaska, the actual initial allocations appear to follow a pattern where entities from census areas that are more "local" to a sablefish management area tend to have been issued a significant portion of QS for that area. This roughly follows fishing patterns that existed during the qualification years.

Nevertheless, the persons who reside in Alaska were predicted to receive a greater portion of the total QS than they were actually issued. This pattern generally holds true in all management areas, and is counter-balanced by the increase in predicted nonresidents.

2.5 Predicted and Actual Distribution by Area of Residence

Table 2.5-1 is organized by resident type, and again uses the data from previous NPFMC analyses to compare the number of persons predicted to receive an initial allocation of sablefish QS with the number of persons that actually were issued QS. The resident categories are divided into the Alaska Census Areas plus an "Outside Alaska" category.

The table is meant to be a succinct summary of the number of entities holding QS by resident type; however, the reader should be cautious when interpreting the table. A person may be issued sablefish QS in multiple management areas, and QS from one area will not be worth the same sablefish IFQ as QS from another area. The table does not take into account the types of QS held, or the 1995 IFQ associated with the types and amounts of QS.

In Table 2.5-1, the unique number of entities are added and percentages are calculated for each resident category that received any type of sablefish QS. An overall total unique number of entities receiving QS is also provided.

The data indicate that in most resident categories, the number of entities who actually received any type of sablefish QS was less than the number of entities that was predicted by the NMFS data used in the earlier NPFMC analyses. As noted before, there may be many reasons for these differences.

The "Outside Alaska" resident category shows the most dramatic difference between the actual and predicted initial allocation. Three hundred twenty-four different entities from the Outside Alaska resident category received some type of initial allocation. This represents approximately 31.1% of all entities that received an initial allocation. This compares to a prediction of 284 entities from the Outside Alaska resident category, or 25.3% of all initial QS recipients, using the NMFS data from the earlier analyses.

In most of the Alaskan census areas slightly fewer persons than predicted actually received some type of initial sablefish QS allocation. The initial QS recipients from most Alaska census areas also represented a smaller percentage of the overall total than predicted by the earlier data. The few exceptions to this generalization do not represent substantial changes.

2.6 Predicted and Actual Distribution by Census Area and Management Area

Table 2.6-1 provides information on the predicted and actual distribution of sablefish QS by resident category and management area. Again, the predictions were made using the NMFS data that was used in the earlier NPFMC studies.

For each resident category, the table provides data on the number of persons who received QS in each management area and the amount of QS which they received in that management area. The table also provides the percentage of QS recipients in each management area who were from the resident category and the percentage of QS in each management area that was issued to persons from that resident category.

Note that Table 2.6-1 differs from Table 2.5-1 in that Table 2.5-1 reports the unique number of persons by resident type, whereas this table will count a person more than once if they received QS in more than one management area.

Table 2.6-1 is really another view of information provided in Table 2.4-1. Table 2.6-1 highlights the data by resident category. For each resident category the table shows the sablefish areas where persons from the category received their QS. The table indicates that persons from census areas local to a particular management area tended to receive a significant portion of the QS from that management area. This is true of both the distribution predicted from the earlier data and the actual initial QS distribution. Again, the reader should bear in mind that QS can be worth a different amount of IFQ by area and year depending upon the total QS in the area and the TAC available to the IFQ fishery.

However, the data also indicate that some of the census areas that were local to a management area received a lower portion of the initial allocation of QS from that management area than would be predicted from the earlier data. In contrast, persons from outside Alaska took a greater portion of the initial allocation of sablefish QS than predicted in all areas.

<Back to Table of Contents>