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APPENDIX III

This appendix provides more information and tables regarding entities who received an initial QS allocation in an area but who were not credited with participation in that area over the 1991 to 1994 time period. It is divided into two sections:

1.
Information Showing Non-participating Entities in Tables of Frequency of Years Fished.

The main body of the report provides detailed information on fishing operations that participated over the 1991 to 1994 time period. These fishing operations were divided into two groups: 1) operations where either the vessel owner or the permit holder could be associated with an initial allocation of QS, and 2) operations where neither the vessel owner nor the permit holder could be associated with an initial QS allocation.

The main focus of the report are the "leftout" operations and the vessel owners and permit holders associated with them. The report also compares and contrasts the participation of "leftout" fishing operations with the 1991 to 1994 participation of fishing operations associated with initial QS allocations. These comparisons are done on a species and area basis.

There were entities who received an initial QS allocation for a species and area who were not credited with 1991 to 1994 fishing participation for that species and area under the methodology used in the report. This fact is noted at several places in the report and explicit counts of these entities are provided in Sections III.B.3 for halibut and IV.B.3 for sablefish.

This section of the appendix provides a table of frequency of years fished that includes entities who received an initial QS allocation for an area but who were not credited with participation in that area over the 1991 to 1994 time period.

1.A
Results for Halibut - Frequency of Years Fished Including Non-participants.

Table A-1a below provides information on the frequency of years fished over the 1991 to 1994 time period for both participating and non-participating entities that received an initial halibut QS allocation. The table excludes entities who only received swappable QS for an area. The table is comparable to Table III.B-2a in the report, which provides the same information for participating entities only.

The "0" years fished category indicates the number of non-participating entities and is the only difference between Table A-1a and Table III.B-2a in the report. Entities with 0 years fished in Table A-1a are those that appear in the "-100%" percent change category in Table III.B-3b in the report. They are entities that received an initial QS allocation in an area but were not credited with having participated in that area over the 1991-1994 time period. This number ranged from 24.6% of the total initial QS recipients in Area 2C (519 entities) to 58.2% of the initial QS recipients (39 entities) in Area 4D.

Although this number can be quite large, it would be false to view all these entities as "retirees" from the fishery. Many of these "0 year" entities participated in other areas during the 1991 to 1994 time period, and many appear to be casual participants whose initial QS allocation is quite small. Also, assigning specific 1991 to 1994 catch records to initial QS recipients was a complex process. The decision rules that were necessary to make these assignments did not credit participation to some entities who appear to have participated during the gap years. All these topics are explored in greater detail in subsequent sections of this appendix.

The frequency tables in the body of the report compare participants only over the 1991 to 1994 time period. The "leftout" definition used in the report was confined to participants during this time period who had not received an initial QS allocation. Other fishing operations, vessel owners, or permit holders who participated over the 1984-1990 time period in an area were also "leftout" in the sense that they did not receive an initial QS allocation for the area. It is likely that some of these entities also did not participate over the 1991 to 1994 time period.

For this reason, the reader should be cautious about comparisons of the frequencies of participating and non-participating entities in Table A-1a with similar frequency tables on leftout fishing operations, vessel owners, or permit holders who participated over the 1991 to 1994 time period. Including non- participants in one table but not in the others may not be a parallel comparison. This report examines the 1991 to 1994 time period but does not examine the 1984 to 1990 qualification period.

With these caveats noted, a comparison with Table III.C-v3a in the report shows that when non-participating entities are included in the calculations, the percentage of entities with an initial QS allocation who participated in multiple years was higher than the percentage of leftout vessel owners who fished multiple years in 5 of the 8 halibut areas. (2C, 3A, 4A, 4B, and 4C).

Similarly, a comparison with Table III.D-p3a in the report shows that when non-participating entities are included in the calculations, the percentage of entities with an initial QS allocation who participated in multiple years was higher than the percentage of leftout permit holders who fished multiple years in 5 of the 8 halibut areas. (2C, 3A, 4A, 4B, and 4C).


Table A-1a. All entities that received QS allocations: their credited years of participation over the 1991-1994 time period and their year combinations, by management area.


1.B
Results for Sablefish - Frequency of Years Fished Including Non-participants.

Table A-1b below provides information on the frequency of years fished over the 1991 to 1994 time period of both participating and non-participating entities with an initial sablefish QS allocation. The table excludes those entities who only received swappable CDQ compensation QS for an area. The table is comparable to Table IV.B-2a in the report and provides the same information for participating entities only. Again, the report was comparing participants.

The "0" years fished category indicates the number of non-participating entities and is the only difference between Table A-1b and Table IV.B-2a in the report. Entities with 0 years fished in Table A-1b are those that appear in the "-100%" percent change category in Table IV.B-3b in the report. They are entities that received an initial QS allocation in an area but were not credited with having participated in that area over the 1991-1994 time period. This number ranged from 33.3% of the total initial QS recipients in Southeast (211 entities) to 52.7% of the initial QS recipients (68 entities) in the Aleutian Islands.

Although this number can be quite large, it would be false to view all these entities as "retirees" from the fishery. Many of these "0 year" entities participated in other areas during the 1991 to 1994 time period, and many appear to be casual participants whose initial QS allocation is quite small. Also, assigning specific 1991 to 1994 catch records to initial QS recipients was a complex process. The decision rules that were necessary to make these assignments did not credit participation to some entities who appear to have participated during the gap years. All these topics are explored in greater detail in subsequent sections of this appendix.

The frequency tables in the body of the report compare participants only over the 1991 to 1994 time period. The "leftout" definition used in the report was confined to participants during this time period who had not received an initial QS allocation. Other fishing operations, vessel owners, or permit holders who participated over the 1984-1990 time period in an area were also "leftout" in the sense that they did not receive an initial QS allocation for the area. It is likely some of these entities also did not participate over the 1991 to 1994 time period.

For this reason, the reader should be cautious about comparisons of the frequencies in Table A-1b with similar frequency tables on leftout fishing operations, vessel owners, or permit holders who participated over the 1991 to 1994 time period. Including non-participants in one table but not in the others may not be a parallel comparison. This report examines the 1991 to 1994 time period but does not examine the 1984 to 1990 qualification period.

With these caveats noted, a comparison with Table IV.C-v3a in the report shows that when non-participating entities are included in the calculations, the percentage of entities with an initial QS allocation who participated in multiple years was higher than the percentage of leftout permit holders who fished multiple years in 5 of the 6 sablefish areas. (Southeast, Central Gulf, Western Gulf, Aleutian Islands, and Bering Sea).

Similarly, a comparison with Table IV.D-p3a in the report shows that even when non-participating entities are included in the calculations, the percentage of entities with an initial QS allocation who participated in multiple years was higher than the percentage of leftout permit holders who fished multiple years in 5 of the 6 sablefish areas. (Southeast, Central Gulf, Western Gulf, Aleutian Islands, and Bering Sea).


Table A-1b. All entities that received QS allocations: their credited years of participation over the 1991- 1994 time period and their year combinations, by management area.


2.
Additional Information About Entities Who Received an Initial QS Allocation in an Area but Who Were Not Credited With 1991 to 1994 Harvest For That Area.

In the main body of the report, sections III.B.3 for halibut and IV.B.3 for sablefish compared initial QS recipients' 1991 to 1994 fishing performance with their initial QS allocation. This was done on a species / area basis. When the authors calculated the "percent change" variable, they had to assign actual catch observations from 1991 to 1994 catch records to specific entities and initial allocations on the initial allocation file. Without a specific assignment, the "percent change" variable could not be calculated.

The authors emphasized in the methodology section that the effort to assign 1991 to 1994 catch observations to specific entities required several assumptions and the "data" reported in the tables should be considered as estimates. The results of the effort were the tables on the "percent change variable" that were discussed in the report. The authors chose to develop and present these estimates for each species by area since the QS issued for each IFQ program are specific to an area and each IFQ program is managed by area.

The tables indicate that some initial QS recipients took a larger fraction of the 1991 to 1994 harvest for a particular area than their fraction of the QS issued for that area. Some of the persons in this category may be those who feel that they received "too little" QS because none of their 1991 to 1994 participation counted toward an initial allocation.

The tables also indicate that other initial QS recipients harvested a smaller fraction of the 1991 to 1994 total harvest for an area than their fraction of the area's initial QS allocation. Among these persons, some were not credited with any 1991 to 1994 harvest in an area for which they were issued QS.

In sections III.A.5 and IV.A.5, historical annual permit holder turnover rates by area in both the sablefish and halibut fisheries were discussed. The tables showed that turnover rates had been relatively high and that the results with respect to non- participating initial QS recipients in an area were not inconsistent with those rates.

It is important not to characterize all entities as "retirees" from the fishery if they were not credited with 1991 to 1994 participation in an area where they received an initial QS allocation. Many of the entities who received an initial QS allocation in an area but who were not credited with 1991 to 1994 participation in that area received only small amounts of QS. Also, many of these entities may have been participating in a different area during the 1991 to 1994 time period. And lastly, note that the methodology for assigning a 1991 to 1994 catch observation to a particular initial QS allocation required many assumptions and therefore the results reported in the percent change variable should be regarded as reasonable estimates only.

The following sub-sections examine each of these points in more detail. Again, these materials are presented to demonstrate that it would be false to characterize all of the entities as "retirees" from the fishery.

II.A.
Initial QS Amounts of Entities Who Received an Initial QS Allocation For an Area But Who Were Not Credited With 1991 to 1994 Participation For That Area.

Results for Halibut

Table A-2a-1 examines halibut QS recipients in each IPHC area who were not credited with 1991 to 1994 participation for that area. The table translates each person's initial QS into 1995 IFQ for the area and then provides counts of persons who fall into each of the IFQ categories.1 All of the persons in this table fell into the "percent change" category of "-100%" in the report.

The table indicates that substantial portions of these QS recipients who did not fish over the 1991 to 1994 time period were issued relatively small amounts of QS. The small amount of QS suggests that they did not have large amounts of credited participation in the area prior to 1991.

In Areas 2C, 3A, and 3B over 50% of the entities in this category had 1,000 pounds or less of 1995 IFQ..2 In Areas 4B and 4D over 50% of the entities in this category had 5,000 pounds or less of 1995 IFQ and in Areas 4A and 4C over 50% of these entities had 2,500 pounds or less.

These data indicate that many of the entities who received an initial allocation of QS for an area but who were not credited with 1991 to 1994 participation in the area were likely part-time or casual participants in that area prior to the 1991 to 1994 time period, as evidenced by the small amount of QS they received.


Table A-2a-1. QS recipients who were not credited with 1991-1994 participation in an area where they received QS: the number of entities and their QS translated to 1995 IFQ pounds. This table excludes entities that received swappable CDQ QS in an area.


Results for Sablefish

Table A-2a-2 examines sablefish QS recipients in each management area who were not credited with 1991 to 1994 participation for that area. The table translates each person's initial QS into 1995 IFQ for the area and then provides counts of persons who fall into each of the IFQ categories.3 All of the persons in this table fell into the "percent change" category of "-100%" in the report.

The table indicates that substantial portions of these sablefish QS recipients who did not fish over the 1991 to 1994 time period were issued relatively small amounts of QS. Their small amount of QS suggests that they did not have large amounts of credited participation prior to 1991.

In all areas except the Western Gulf, over 30% of these entities had sablefish QS worth less than 1,000 pounds of 1995 IFQ. In the Central Gulf, over 50% of these entities had sablefish QS worth less than 2,500 pounds of 1995 IFQ. In all areas, over 50% of these entities had sablefish QS worth less than 5,000 pounds of 1995 IFQ.

These data indicate that many of the entities who received an initial allocation of sablefish QS for an area but who were not credited with 1991 to 1994 participation in the area were likely part-time or casual participants in that area prior to the 1991 to 1994 time period, as evidenced by the small amount of QS they received. The table also indicates that some of these entities had relatively large amounts of initial QS. The percentage of entities that were allocated QS worth more than 10,000 pounds of 1995 sablefish IFQ ranged from 18.6% in the Bering Sea to 33.7% of the entities in the Western Gulf.


Table A-2a-2. QS recipients who were not credited with 1991-1994 participation in an area where they received QS: the number of entities and their QS translated to 1995 IFQ pounds. This table excludes entities that received swappable CDQ QS in an area.


II.B.
Participation in Other Areas or For Other IFQ Species During the 1991 to 1994 Time Period

In the report, Section III.B.3 for halibut and IV.B.3 for sablefish provided estimates of the relative performance of initial QS recipients for an area during the 1991 to 1994 time period compared to their QS allocation for the area. As noted above, large numbers of persons who had received an initial allocation of QS for an area were not credited with participation over the 1991 to 1994 time period. These were the persons who fell into the "-100%" percent change category.

However, many of these persons did participate in other areas or in the other IFQ fishery during the 1991 to 1994 time period and hence should not be characterized as "retirees" from the fisheries. These results are shown below:

Results for Halibut

Column 1 of Table A-2b-1 shows the entities who received halibut QS for an area but who were not credited with 1991 to 1994 participation in that area.4 This number often represents a substantial portion of the total number of entities who were issued intial QS in the area.

Column 2 of the table shows the number and percentage of these entities by area who were credited with participation in some other halibut area(s) during the 1991 to 1994 time period. As can be seen, substantial percentages of these entities were participating in other areas during the "gap" time period. These percentages range from 16.1% in Area 4E to 68.1% in Area 3B. The percentage exceeds 50% in Areas 3B, 4A, 4B, 4C, and 4D (five of the eight areas) and exceeds 60% in Areas 3B, 4A, and 4B (three of the eight areas).

Column 3 of the table shows the number and percentage of these entities by area who were credited with either sablefish or halibut participation over the 1991 to 1994 time period. As can be seen, these numbers and percentages are similar, ranging from 16.1% in Area 4E to 69.0% in Area 3B.

This table demonstrates that many of the entities who received QS for an area but who were not credited with 1991 to 1994 participation for that area were participating in other areas during the gap time period.


Table A-2B-1. QS recipients that did not fish during 1991-94 in the area where they received initial QS: Counts of those entities, and the num- ber and percentage of those entities that fished in some other area for that species, and the number and percentage that fished for any QS species.


Results for Sablefish

Column 1 of Table A-2b-2 shows the entities who received sablefish QS for an area but who were not credited with 1991 to 1994 participation in that area.5 This number often represents a substantial portion of the total number of entities who were issued intial QS in the area.

Column 2 of the table shows the number and percentage of these entities by area who were credited with participation in some other sablefish area(s) during the 1991 to 1994 time period. As can be seen, substantial percentages of these entities were participating in other areas during the "gap time" period. These percentages range from 29.3% in the Central Gulf area to 65.8% in the West Yakutat Area The percentage exceeds 50% in all areas except Southeast (40.8%) and the Central Gulf (four of the six areas).

Column 3 of the table shows the number and percentage of these entities by area who were credited with either sablefish or halibut participation over the 1991 to 1994 time period. As can be seen, these numbers and percentages are even higher, ranging from 55.3% in the Central Gulf to 77.4% in the West Yakutat area.

This table demonstrates that many of the entities who received QS for an area but who were not credited with 1991 to 1994 participation for that area were participating in other areas during the gap time period.


Table A-2b-2. QS recipients that did not fish during 1991-94 in the area where they received initial QS: Counts of those entities, and the num- ber and percentage of those entities that fished in some other area for that species, and the number and percentage that fished for any QS species.


II.C.
Entities Who Received an Initial QS Allocation For an Area Who Were Not Credited for 1991 to 1994 Participation in the Area But Who Appear on 1991 to 1994 Catch Records For The Area.

The methodology section of the report mentions that the task of assigning a 1991 to 1994 catch observation to a specific entity on the NMFS's initial allocation file was not straightforward and required complex matching exercises and several assumptions. The details of the methodology are described in Chapter 2 of the report.

Since the ITQ program allocated QS to vessel owners and to lease holders (usually permit holders, in the case of a lease), the authors had to consider both the vessel owner and the permit holder in assigning a 1991 to 1994 catch observation to an entity on the initial allocation file. Since most initial QS recipients were vessel owners, the authors assigned a catch observation to the vessel owner if the vessel owner had an initial QS allocation for that species and area. If the vessel owner did not have an initial QS allocation for the species and area, but the permit holder did, then the catch observation was assigned to the initial QS allocation of the permit holder.

This procedure was believed to come closest to mimicking the initial allocation process under the NPFMC's IFQ programs, which used catch prior to 1990. However, the reader is warned, both here and in the main body of the report, that the process of assigning a 1991 to 1994 catch observation to a specific initial allocation would be different if different decision rules had been used.

In many cases, the vessel owner and permit holder on 1991 to 1994 catch observations were two different entities. In some of these cases, both the vessel owner and the permit holder had an initial QS allocation for the species and area of that catch observation. In such cases, the authors assigned the 1991 to 1994 catch observation to the vessel owner in accordance with the methodology.

A single 1991 to 1994 harvest observation could not be assigned to both the vessel owner and the permit holder of an operation that received an initial QS allocation. Splitting the catch observation between the two would have been an option, but the authors believed that assigning the catch to the vessel owner would come closer to the decision rules used under the NPFMC's IFQ program for crediting catch during the pre- 1991 qualification period.

Nevertheless, in some of these cases where the vessel owner and permit holder on the 1991 to 1994 catch observation were different entities, and both had received an initial QS allocation, one of the entities (usually the permit holder) did not receive credit for 1991 to 1994 participation for the species and area because the methodology assigned the catch to the initial allocation of the other entity (usually the vessel owner). The tables below provide more information on this subset of entities.

Results for Halibut

Table A-2c-1 below provides information on this particular subset of entities for the halibut fishery. Again, these are entities who received an initial allocation of halibut QS for an area, who were not credited with 1991 to 1994 participation in the area under the methodology used in the study, but who did appear on a 1991 to 1994 catch record(s) for the species and area. These persons represent a subset of the entities with a percent change of "-100%" in the area.

As can be seen, the numbers of these persons are small but significant in IPHC areas 2C, 3A, 3B, 4A, and 4B. While the number of persons represent only a small fraction of the entities assigned to the "-100%" percent change category in each area, such persons clearly should not be characterized as persons who retired from the fishery before the 1991 to 1994 time period.

For informational purposes, the table divides these persons into initial QS categories in each area and translates those QS amounts into 1995 IFQ. As can be seen, most of these persons had relatively small amounts of QS.


Table A-2c-1. Permit holders and vessel owners from operations that fished during 1991-1994 in areas where they received QS, but who were not credited with participation in that area during 1991-1994 because the catch observation was assigned to a different entity. The table shows the number of entities and their QS translated to 1995 pounds of IFQ.


Results for Sablefish

Table A-2c-2 below provides information on this particular subset of entities for the sablefish fishery. Again, these are entities who received an initial allocation of sablefish QS for an area, who were not credited with 1991 to 1994 participation in the area under the methodology used in the study, but who did appear on a 1991 to 1994 catch record(s) for the species and area. These persons represent a subset of the entities with a percent change of "-100%" in the area.

As can be seen, the numbers of these persons are small but significant in the Southeast, West Yakutat, and Central Gulf sablefish areas. While the number of persons represent only a small fraction of the entities assigned to the "-100%" percent change category in each area, such persons clearly should not be characterized as persons who retired from the fishery before the 1991 to 1994 time period.

For informational purposes, the table divides these persons into initial QS categories in each area and translates those QS amounts into 1995 IFQ. As can be seen most of these persons had relatively small amounts of QS.


Table A-2c-2. Permit holders and vessel owners from operations that fished during 1991-1994 in areas where they received QS, but who were not credited with participation in that area during 1991-1994 because the catch observation was assigned to a different entity. The table shows the number of entities and their QS translated to 1995 pounds of IFQ.


2.D.
Summary

This section of the appendix has taken a closer look at the entities who received an initial allocation of QS for an area but who were not credited with 1991 to 1994 harvest for that area. The number of these entities was estimated and reported in Section III.B.3 for halibut and Section IV.B.3 for sablefish which discuss the "percent change" variable.

Although the number of these entities may appear to be large, one should not assume all of these entities are retirees from the fishery. This section has shown that many of these entities were issued only small amounts of QS in the area and hence were likely part-time or casual participants in the area prior to 1991. Moreover, many of these entities participated in other areas or for the other IFQ species during the "gap" time period. Lastly, under the methodology employed in this study, some of these entities who were credited with no participation in an area actually appear on catch records during the 1991 to 1994 time period.