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April 1, 2007

North Pacific fishery Management Council
605 W 4th Avenue, Suite 306
Anchorage, AK 99501-2252

To: Members of the North Pacific Fishery Management Council:

Re: 18-month Review of the Bering Sea and Aleutian Islands Crab Management

Food & Water Watch is pleased to have the opportunity to comment on the 18-month review of the Bering Sea and Aleutian Islands crab management program, which will be discussed during the current Council meeting. The North Pacific Fishery Management Council specifically requested a review of the following:

a) the distribution of benefits between harvesters and processors arising under the harvest share/processor share allocations and arbitration system, and,
b) the distribution of landings of different harvest share types.

Food & Water Watch would like to request that a fuller, more comprehensive analysis of the crab rationalization program be conducted, which takes into account the environmental and socio-economic impacts of the program. Through this review, the writers specified that 18-months is not enough time to truly evaluate the costs or benefits of the program, but we believe 18 months is certainly enough time to review the environmental and socio-economic impacts.

Food & Water Watch would like to comment on several findings within the 18-month review. The writers indicated, that within share based management systems, participants change their behavior. According to this report, the participants are still fishing at the same time, compromising safety, in order to respond to the processors’ demand. It is apparent, therefore, that since the processors hold their own quotas, they are able to dictate both the price and fishing season. Furthermore, the report indicates that the intention of the program is to “achieve the greatest market benefits from fisheries” by extending the fishing season, but that complicates deliveries, indicating that since the processors have a share, they dictate when the deliveries are made, impacting the level of safety for the crew which, originally, the crab rationalization program was intended to rectify and evidently has not.

In the section analyzing the 90/10 A share/B share division, the writers found that the prices were lower since the rationalization program was implemented, compared to previous years. One of the reasons presented for the lower prices is the decrease in U.S and Japanese demand, plus an influx of crabs from Russia. Food & Water Watch finds this reasoning to be biased in favor of the processors, which have greater control over pricing then in any previous year due to their quotas shares, and we encourage the Council to further investigate the processors control over price.

In regards to the timeline for arbitration under the “application of the 90/10 A share/B share allocations and the arbitration system,” Food & Water Watch recommends that rather than change the opening season, extend the deadline for arbitration. Furthermore, any results from arbitration results should be made public.

The writers of the review indicate that the fishermen have increase costs, due to the fees that must be paid to both the cooperatives and the arbitration system. Since cooperative membership is voluntary, concern was outlined that some fishermen may be “free loaders” since they reap the benefits of the fees paid to the cooperatives. Food & Water Watch recommends that the processors, rather than the fishermen cover the costs for arbitration.

Overall, Food & Water Watch did not find any significant findings in the 18-month review and we encourage the North Pacific Fishery Management Council to request a fuller, more compressive review of the Bering Sea and Aleutian Islands crab rationalization program. Thank you for considering out comments.

Sincerely,
Andrianna Natsoulas
Director, Wild Oceans Campaign
Food & Water Watch