North Pacific Fishery Management Council, We are the Gulf Ground Fish Fishermen's Association.

Our members include operators and crew from the drag, long line, and pot fishing fleet. We believe that we have been left out or are inadequately represented in Element 8 of the harvesters-only quota share program. We believe that exclusion will reduce our stake in the fisheries and have a serious negative impact on our sector of the fishing community.

Section 301 104-297 (8) of the Magnuson-Stevens Act states:
"Conservation and management measures shall, consistent with the conservation requirements of this act (including prevention of over-fishing and rebuilding of over-fished stocks) take into account the importance of fisheries resource to fishing communities and (b) to the extent possible minimize adverse impact on such communities.

"The "fishing communities" whose sustained participation and economic viability you have been entrusted with is defined in Sec. 3 definitions 16 The "fishing community" means a community which is substantially dependent on or substantially engaged in the harvest or processing of fisheries resources to meet social and economic need, and includes fishing vessel owners, operators, and crew and United States fish processors that are based in that community."

The Gulf Ground Fish Fishermen's Association contends that vessel-owner-only quota shares, as proposed, would severely impact our constituency of vessel operators and crews. The first two attempts at "privatizing" our natural resource (IFQs and AFA) have led to large scale consolidation of the harvesting sector and the retirement of many vessels that previously participated in the halibut, sablefish, Bering Sea Pollock, and Bering Sea fisheries. It is important not to overlook the lessons learned from the initial distribution of halibut/sablefish and AFA, and, particularly, the adverse effects it had on hired skippers and crewmembers. Having no leverage of any initial quota, the skipper/crew are currently working under circumstances that allow the boat owners (initial IFQ recipients) to charge unfair share of "quota rents", some exceeding 60% off the dock price. Rents in the IFQ fishery commonly run 50% off the top of the dock price. Without the leverage of IFQ stake skipper/crew will once again be subjected to substandard pay. The net result will be the continued exodus of experienced fishermen and their familiesfrom our coastal fishing communities.

We, as a group, wish to maintain our livelihoods, current level of income, and wish to continue to live in our communities. As stakeholders in these recources, we feel an equitable division will require 25% quota share pool for the operators and crew. That percentage reflets the stake the boat owners themselves have traditionally offered us fot the time pursuing the fisheries under review for the quota share process. It was our time, a considerable investment in the resource, as sub-contracted fishermen that allowed the owners' vessels to garner catch histories that, under the current NPFMC allocation method, will determine their quota share of the resource and our exclusion. The argument has been made that the burden of risk lies solely with those who own an interest in a fishing vessel and, therefore, they and they alone, should receive IFQ for the boat's fishing history. This is not the case; we encourage all of the Council members to visit our Fisherman Memorial while in Kodiak. We assure you that there is not a 97%-3% split of owners to skipper/crew on the plaques. By providing for operators and crew of our fishing community, the Council will better adhere to the mandates of the Magnuson-Stevens Act as stipulated in Sec. 304 104-297. Operator and crew quota shares will provide economic leverage in the hiring prospects of gulf ground fish fishermen. Such a quota will also provide opportunity for our expanded participation through the potential purchase of further quota shares in these traditional fisheries during the initial consolidation period. IFQs will allow us to realize a real return on our investment through amortization of both grand fathered and purchase shares. The Council would be remiss to exclude us as stakeholders from the quota share division and with our inclusion, the council will be more clearly in line with the purpose and policies of the Magnuson-Stevens Act.

It is our Association's position that failure to follow up on our proposals will have severe negative economic impacts on our sector of the fishing community and the communities at large.

Thank you for your attention, Alexus Kwachka: Spokesman, Gulf Groundfish Fishermans Association Island1@ptialaska.net

North Pacific Fishery Management Council
Subject: Public Testimony--fisheries "rationalization"

Gentlemen: You folks are hell-bent on dividing up all ground fish species among users on an IFQ basis. Many seemingly logical arguments have been presented to support this action, but once you have sifted through all this verbiage, the primary driving force behind this becomes abundantly clear. The word is GREED!

An IFQ system had been put in place for the halibut and black cod fisheries--the jury is still out (in my opinion) on what the long-term economic effect of this program will have on the economies of towns like Kodiak vs. what the economic effect had been if this program had not been implemented in the first place. One thing is certain: once one of these resource transfer programs has been implemented, there is no returning to the "pre-IFQ days". I'm against further initiation of IFQ programs in the ground fish fisheries in Alaska because it slams shut the door of opportunity on the next generation of young people attempting to enter the fishing industry. This program enriches a handful of fishermen who happened to "be here first" and totally cuts out fishermen who got into the fishery "a little late" or crew members and hired skippers who, in my opinion, have as legitimate a state holder interest in these fish as the boat owners have.

The ultimate absurdity in IFQ schemes is your recently passed processor share quota in the crab fisheries. What kind of nonsense is this? Under this program you are permanently transferring processing rights to public resources to foreign-owned corporations. Let us fast forward a few years when the crab stocks in Kodiak rebound to pre-70s level and (hypothetically) Bering Sea stocks become depleted--our Kodiak fishermen will have to deliver their Kodiak-caught crab to Dutch Harbor to be processed because our local canneries' quota share was based on some arbitrary formula concocted by you people in the 90s. How can you folks sleep at night when you are dreaming up baloney like this?

Before you implement any further IFQ schemes regarding ground fish, we ask that you conduct an economic impact study and publicize the results to towns such as Kodiak. Hopefully everyone will recognize these programs for what they are--the enrichment on a few at the expense of the general economies of towns like Kodiak and at the expense of the next generation of fishermen wanting to participate in these fisheries.

Very truly yours, Andy Lundquist
Business owner, halibut IFQ holder, minor grey cod fishery participant, and concerned Kodiak citizen.

Dear Council,
In the privatization of the fishing industry, 90% of the harvesters are overlooked. Crewmen are not listed on the fish ticket, making it more difficult to document their presence. As independent contractors, crewmen invest time, money, and effort just as skippers do. Skippers were considered for a tiny percentage of the BSAI crab rationalization. Crewmen are no less deserving on inclusion in the privatization of this once public resource. Villages with NO history of participation in the fisheries are awarded substantial amounts of harvesting rights. Owners, referred to as "harvesters", many of whom haven't actually fished in years, are awarded the lions' share of quota. In the Halibut and Black Cod fishery this led to widespread job loss and crew share reduction.

Inclusion of crewmen in the gulf rationalization might limit the financial damage that WILL occur with privatization.

The USCG documents vessel masters with affidavits; if thats good enough for document operators, it should be good enough for document crewmen. All crewmen are required to sign contracts, which are held by vessel owners. these contracts list the season fished and percentage paid. Such contracts should document crewmen's participations quite thoroughly.

A portion of the quota should be awarded to crewmen; a tax on the entire fishery, with the proceeds to be put into an account to be used for grants for crewmen to buy quota. This would protect not only the crew, but also the communities they live in.

Thank you, Steve Branson

To the Council, 
 I can't go head to head with you over the legality of this rationalization plan and any points I could think of to raise, you've already spent hundreds of paid hours anticipating. We are simply trying to catch up with the flurry of information and do what we can to save ourselves and our families by swaying or perhaps softening the blow of your decisions, with the knowledge of their effects on us as longstanding members of Kodiak's fishing community.

My husband and I are committed to this community financially as homeowners and taxpayers, along with donating time, ideas, and energy to Kodiak and her schools. Our children have volunteered and added to this community. They were all 4 born in Kodiak and have been raised as Kodiak kids. Decisions you are making at this level have affected us profoundly in the past - namely with the implementation of the halibut IFQ program. It's hard not to take it personally when it seems your decisions are again aimed at pushing us out of fisheries, out of business, and out of our community.

My husband has over 20 years invested in this industry. He has worked his way up at one point to small boat owner/operator with his own crew to support. Soon after, halibut IFQs were distributed. Receiving no halibut shares, as we both stayed on deck too many years, was a blow financially. For the last open halibut derby we took home almost $20,000.00 after paying our crew. Our 36 foot fiberglass boat was tied up permanently not long after. My husband has run several larger boats since. He fishes year round from Kodiak to Dutch Harbor, to Astoria with the 58 foot vessel he has run for the past 3.5 years. He was offered the option of buying this boat with sweat equity. This boat does not have a large number of halibut shares (and incidentally they have all had to be purchased). The income from these halibut shares amounts only to a nice bonus compared to what he has made traditionally off of halibut for the year.

My husband has supported our family almost entirely from pot grey cod seasons these last 5 years, reaching a million pounds some seasons. I believe part of Kodiak's current budget struggle stems from the IFQ program and the operators and crew who were seemingly ruthlessly cut out of the fishery. Income was lost and families moved. According to the "State of the Fleet" report for 2003, the number of individuals who currently hold halibut shares has dropped by well over 2000 compared to when they were first distributed. You cant say that this number doesnt represent a huge loss in halibut jobs for Alaska communities. Alaskan fishermen are fighting on so many levels at this point - why would you choose to break more of them?

I was in Dutch Harbor/Unalaska visiting my husband 2 years ago.  The port is a money maker with an overwhelmingly large catcher-processor fleet. It's not set up to be very user-friendly to smaller boats. It works for Dutch Harbor, but I would compare it to working at Prudoe Bay. You can make big money, but you sure wouldn't spend it there and not many people would consider calling to home.

In Kodiak we don't wallow in despair of our small boat fleet and pray for large multi-million dollar catchers to replace them. We revel as a community in our lively, diverse small boat industry and numerous family operations. I would hope your decisions here about our future will take that into consideration. We don't want what Dutch Harbor has. This plan must accommodate the operators and crew who have brought the products to shore. They have risked ALL year after year, season after season, to support loved ones and in many cases for "love of the game". They can't be excluded once again from the fisheries they have participated in and sometimes pioneered.
Thank you, Robin Clark