Dan Hull, Chairman
Chris Oliver, Executive Director
SUBJECT: title
Allocation Review Triggers - Discussion paper
end
STAFF CONTACT: David Witherell
ACTION REQUIRED: recommended action
Review discussion paper; action as necessary.
BACKGROUND:
In July 2016, NMFS issued a Fisheries Allocation Policy Directive 01-119 (further revised on 2/17), and two associated Procedural Directives. Collectively, these directives are intended to provide guidance to the Councils on reviewing fisheries allocations. The directives describe a mechanism to ensure fisheries allocations are periodically evaluated to ensure that OY is being achieved under current conditions. The policy and directives establish three steps in an allocation review process, with the first step occurring if a review trigger is met. Categories of triggers that can be used by a council to initiate an allocation review: public interest, time, or indicators. The councils are required to identify one or more triggers for each fishery with an allocation that meets the definition contained in the revised policy directive by August 2019.
A discussion paper was prepared to address the new requirements for triggering an allocation review. Potential trigger approaches were examined and a list of allocations meeting the definition was developed. The following is a summary of findings based on this discussion paper. The Council may wish to act on these findings to determine the allocation review policy for each fishery.
• There are 10 allocations that appear to meet the Fishery Allocation Review Policy definition, including all LAPP programs, the GOA Pacific cod sector allocation, the BSAI Pacific cod sector allocation, and the Halibut Catch Sharing Plan. These allocations were recommended by NMFS AKRO and HQ staff, and drawn from the possible universe of all NPFMC allocations.
• The Community Development Quota allocation will not be subject to periodic allocation reviews, as this allocation is outside of the Councils’ authority to change, and is exempt from LAPP/CSP reviews.
• All future LAPP reviews could explicitly include a section that evaluates the management goals and objectives to ensure they are relevant to current conditions and needs with respect to the allocation. This will ensure that all components of the required reviews are met, and thus the LAPP reviews will meet the allocation review policy.
• A time-based criteria for the remaining non-LAPP allocations (GOA and BSAI Pacific Cod Allocations and the Halibut Catch Sharing Plan), is the most straightforward way to ensure periodic reviews. A 10-year review frequency is suggested, as these are established fisheries with relatively stable performance. The depth of the analytical reviews can be scaled to the need for the review and likely improvement in fishery performance. Additionally, it is worth noting that:
o The Council has an adaptive, open and transparent process that provides the public opportunities for input. As such, the public can suggest an allocation be reviewed prior to the established frequency for review. The Council could then determine if it wishes to pursue an out-of-cycle allocation review, or some intermediate step in the review process (e.g., step 1a).
o After the first full allocation review of the GOA and BSAI Pacific Cod Allocations and the Halibut Catch Sharing Plan, the Council would be in a better position to further evaluate potential use and development of performance criteria for future allocation reviews.
Public interest-based criteria for triggers could also be a viable approach, at least for the Pacific cod sector allocations, as history shows the NPFMC process has been dynamic and responsive to changing conditions in the fishery. For example, the BSAI cod allocations have been revisited in Amendments 24, 46, 64, 77, and 85. If the Council wishes to establish a public interest trigger for these fisheries, staff could come back at a future meeting with additional justification and draft policy language for discussion.