Contrary to EDF criticism, I believe Mr. Gaines is providing a valuable public service by offering a different viewpoint from the continuous barrage of advocacy pieces and media releases from EDF (and Pew) on this subject. I also find Mr. Gaines is more often than not, right on target, at least with my views, when compared to what EDF is attempting to push down the throats of fishing communities; via a top-down management approach.

Furthermore, I find the comments submitted on Mr. Gaines’ articles on the catch share issue to be particularly interesting as they appear to be coming from real people who actually fish (or used to fish) for a living – the affected communities. These are people who (I believe) have not been given the same opportunity to express their viewpoints publicly because EDF (and Pew) dominate the media outlets with their slick professional advocacy campaigns that offer no other alternatives but their own. Achieving your stated goal of “an open and thorough exchange of information” includes the participation of people like Mr. Gaines, and not the lone voice of EDF or Pew.

Despite my search for information, there is still one catch share issue that bothers me. Perhaps the answer is so simple that I missed it. My question is whether the catch share management system, once implemented, is reversible? If so, what is the process? I am hoping that EDF could educate me and possibly others who may have the same concern.

John Gourley
Saipan, Northern Mariana Islands, USA

From Lee Crockett, Director, Federal Fisheries Policy, Pew Environment Group

I am responding to Kate Bonzon’s November 3 critical assessment of the Pew Environment Group’s recent report, Design Matters: Making Catch Shares Work (www.endoverfishing.org). The first thing I’d like to note is that we produced this report to stimulate a broader discussion of catch shares programs. While we have acknowledged the positive aspects of these programs in a variety of fora, in our view, much of the public discussion on catch shares has been overly one-sided, focusing intensively on their positive characteristics, without giving sufficient attention to their downsides. Catch share programs have been around for more than two decades, and we can learn much from what has worked and what has not by looking at their track record. If the nation’s marine fishery managers are going to consider instituting these programs on a much broader scale, it is important that they do so with a very sober, clear-eyed understanding of all of the management implications. As Edmund Burke said more than two centuries ago, "Those who don't know history are destined to repeat it."

Ms. Bonzon expresses disappointment that the Pew report does not provide new insights on catch shares and effective design. The purpose of the paper, however, was not to design a model catch share program, but rather to argue that any future design of these programs be well informed and guided by the prior experience of catch share regimes, both positive and negative. Based on that history, documented primarily by government and academic sources in the report, we suggest several overarching design principles that should guide the design, implementation and modification of catch shares programs going forward:

1. Science-based catch limits;
2. Robust monitoring;
3. Identification of explicit conservation, social and economic goals;
4. Permits issued for no more than 10 years;
5. Adequate enforcement; and
6. Fair and equitable allocation of quota shares.

As we document in our report, catch shares programs have been a mixed bag. Some have worked fairly well while others have had negative impacts on fishermen and their communities. In our view, these six design principles have broad application across the country. To go further and mandate a particular type of management system nationally ignores regional variability and the particular circumstances of each fishery. What may work in Alaska may not work in Florida. Moreover, as we’ve pointed out in our report, catch shares programs can create negative socio-economic impacts. In order to minimize such impacts wherever possible and to ensure that those impacts are fairly distributed across a fishery, the decision to move to a catch shares system in a particular fishery, and the design of such a system, should include input from the affected local fishing communities.

One of the most profound socio-economic impacts of catch shares programs is job loss. Reducing the number of fishing vessels and fishermen is usually one of the goals of a catch shares program in order to match fishing capacity with the number of fish that can sustainably be removed from the ocean. However, how those reductions are distributed across a fishery has implications for fishing communities and ongoing management. Unfortunately, most past catch shares programs have awarded quota shares based on how many fish a specific permit holder caught in the past. This may reward the largest fishermen at the expense of smaller, often family fishermen. Clearly, there are significant economic benefits for those fortunate enough to get enough quota to maintain a viable business, but what about those who don’t? Does anyone think that the success of those left in the fishery somehow assuages the problems of those left out? The simple fact is that catch shares programs create winners and losers. As we discussed in our paper, this fact must be addressed in the design and implementation of these programs.

The first and most important recommendation in our report is that catch shares must be based on science-based catch limits. This recommendation responds to claims by many catch share proponents that catch shares are better at achieving positive outcomes than catch limits or hard quotas. A catch shares program must have a catch limit in order to give managers the ability to accurately allocate quota among fishing entities. To ensure sustainability, a catch limit must be set so that overfishing does not occur and depleted fish populations can rebuild. If this limit is set too high, overfishing will occur or rebuilding will be delayed, regardless of whether it is associated with a catch shares program or not. Moreover, while all catch shares programs need catch limits, such limits can be associated with other fishery management tools such as time and length of fishing seasons, size and bag limits, etc. In her blog posting, Ms. Bonzon states “Pew is right that these are tough problems for fisheries, but they neglect to mention that catch shares are better at achieving positive outcomes than nearly any other management approach currently in use.” We do not necessarily agree with this point of view. While Ms. Bonzon does not provide a reference to support this statement she may be referring to a study published in Science (September 19, 2008) as evidence that catch shares programs enhance fisheries sustainability. While this study produced interesting results, two responses published in Science on January 16, 2009 paint a more nuanced picture by raising concerns about the impact catch shares can have on the larger ecosystem through bycatch of non-target ocean wildlife, habitat damage, increased targeting of species that are not in the catch share program and illegal fishing by fishermen who do not receive quota. The authors of both letters argue for a more comprehensive and diverse set of solutions to our ocean fisheries problems. We could not agree more.

Obviously we were heartened when Ms. Bonzon wrote that most people agree that catch shares should be designed for the unique needs of fisheries and the communities that depend on them. However, there are several instances where we disagree with the EDF criticism of the case studies contained in our report. One example of this is a statement by Ms. Bonzon that “catch shares for the commercial fleet are good for recreational fishermen.” As Dick Brame from the Coastal Conservation Association pointed out during a press briefing we hosted on November 3, recreational fishermen are very concerned that commercial catch shares programs will lock in the allocation of fish in a fishery between commercial and recreational fishermen. Once this occurs, Mr. Brame is concerned that the only way recreational fishermen could expand their share of the fish in a fishery would be for the government or the fishermen to buy quota from the commercial fishermen. Even if there were willing commercial fishermen sellers, where would the money come from? Plus, how equitable is it for recreational fishermen to have to buy quota that was given to commercial fishermen for free? These fundamental questions must be addressed when developing a catch shares program in a mixed fishery.

Second, Ms. Bonzon takes issue with our description of the Gulf red snapper fishery and the recently adopted red snapper catch shares program, indicating that we failed to note the success of the catch share program in restraining commercial catch. This is not correct. We noted in the report that the Gulf of Mexico Fishery Management Council developed a catch share program in the commercial fishery to help address certain problems, and then went on to indicate that the program had achieved the successes that EDF says we missed. Below is the relevant quote from our report:

“Since implementation, after a further reduction of the quota in 2008, the price paid to fishermen has increased 17 percent, while average landings, number of trips and days at sea have declined. Coupled with the reduction in minimum size, the ratio of landed to discarded fish has improved threefold to fourfold, reducing overall mortality by lowering the amount of discarded fish. Between 1996 and 2003, the red snapper fleet concentrated its fishing effort in an average of just 77 days to catch its quota. In the past two years, however, that same effort has been spread across an entire year. The IFQ program also provides a better system of accounting for fishing activity. In the past two years, annual landings have been just shy of the allowed commercial quota—a sharp improvement over the previous 17 years, when the quota was exceeded nine times.”

Third, EDF’s statement that the decrease of 11 percent in vessel owners in the surf clam/ocean quahog catch shares fishery is a “more accurate” reflection of consolidation paints an incomplete picture of the economic impacts that consolidation has inflicted on that fishery. We stated that the number of vessels in that fishery declined from 128 to 59 in two years, figures derived from a report written by the General Accountability Office (the investigative arm of Congress). A vessel decline of more than 50 percent in the fishery indicates that a number of owners owned multiple vessels, but it also suggests that there were significant job losses amongst the crew of those vessels that could no longer participate in the fishery.

In conclusion, we strongly believe that in order to maximize the benefits of catch share programs, while minimizing their negative impacts, attention needs to be paid equally to both when deciding whether they should be implemented in our nation’s fisheries. In the end, we both agree that “design matters.”

If properly constructed and with the help of entities, such as CQE's (Cape Cod Fisheries Trust), this doesnt signal the end of an era but the beginning of a rebuilding process and a sustainable industry. My organization, Nexii Inc. http://www.nexii.com, plans to support this industry in this crossover by helping CQE's and Fishery Associations raise capital to purchase quota and in the development of a functional electronic catch shares transactions platform where sector heads can effectively manage the transfer of quota, track transfers,track TAC and other key data and start to create a historical record of all transactions and activity within each sector and across various fisheries throughout the U.S. This is to be launched in May of 2010.