In June of this year, NOAA Director Jane Lubchenco announced the formation of a catch shares task force, whose members were tasked with exploring the implementation of catch shares in commercial and recreational fisheries nationwide as a means of ending over-fishing, rebuilding fisheries and improving the economics of fishing and fishing communities.

Lubchenco is a former Pew board member and also served on the board of the Environmental Defense Fund, which has advocated strongly for catch shares.

In its paper titled "Design Matters," the Pew Environmental Group examined four catch-share fisheries, including two in Alaska, and warned that without careful design and implementation, they can create as many problems as they solve.

Lee Crockett, director of federal fisheries policy at the environmental group, said NOAA's apparent tunnel vision with regard to catch shares prompted a great deal of concern.

"This management tool is one of the focal points of the Obama administration's ocean fisheries management efforts," Crockett said. "We do not support making catch shares the default management system in every sector of every fishery in the United States. We feel that this one-size-fits-all approach is inappropriate, and ultimately harmful to sound fisheries management because it ignores local variability."

Alaska's two main catch share, or IFQ programs, are a contrast in how to and how not to design a program. The halibut/sablefish program was designed with specific environmental and socio-economic goals in mind, including maintaining an Alaska-based, owner-operated small boat fleet, eliminating safety and resource issues created by the derby-style race for fish, improving product quality and increasing product availability and value.

Linda Behnkin, a Sitka halibut fisherman who helped design the program, said those goals were largely achieved, although the program is slipping in some areas.

"I think the program has been very successful in meeting conservation goals; it's been successful to a large degree in meeting the economic goals that we established," Behnkin said. "The shares are still mostly held by coastal Alaska residents, they're mostly fished, especially in the halibut fishery, by a mix of boats from skiffs to halibut schooners, and the people who run the boats are primarily owner-operated, although we are seeing an increasing number of hired skippers and absentee ownership."

The crab fishery was not so carefully designed, according to Behnkin.

"A lot less attention (was) paid to socio-economic impacts of the fishery, and no effort to make the fishery owner-operated or transition to Alaska-based owner-operated fishery," she said. "As a result, the ... socio-economic impacts have been very substantial and devastating in some communities, with the fleet ...within one year reduced by half, and the number of jobs cut to almost a third."

Behnkin pointed out that processor quotas, wherein harvesters are required to sell 90 percent of their catch to specific processors, have had negative conservation and safety ramifications as a result of fishermen being told when they have to fish.

The Pew paper points out additional problems with the crab rationalization program.

"More recently leasing fees in the crab rationalization program have affected crew compensation. Because vessel owners can deduct the cost of lease fees from profit before paying the crew, reports of a decline in earnings have surfaced despite equal effort levels," it states. "Absentee ownership is also a problem, and some quota holders lease their shares at rates substantially higher than the actual value. Managers therefore are considering alternatives to require that shares be held by active participants in the fishery."

In order to avoid these pitfalls, the Pew paper says a properly designed catch-share program must include the following:

n Science-based annual catch limits that include all fish killed as a result of fishing (target fish landed and non-target fish - or bycatch - discarded at sea).

n Adequate monitoring of the target fish catch and bycatch .

n Identification of explicit conservation, social and economic goals that the program intends to achieve and metrics for measuring attainment of those goals.

n Permits issued for no more than 10 years and regular review and evaluation of program performance with opportunities to modify and improve the program, as required by section 303A of the Magnuson-Stevens Fishery and Conservation Management Act.

n Adequate enforcement, including validation of catch and discard reporting and, to the extent possible, real-time management with the authority to close the fishery as soon as the quota is reached.

n Fair and equitable allocation through a transparent and open process, including mechanisms to accommodate recreational anglers, working fishermen and coastal communities; ownership caps so that one entity does not hold an excessive share of the quota; and opportunities for new fishermen.

An executive summary and a link to the full paper can be found at www.endoverfishing.org/DesignMatters.html.

Cristy Fry has commercial fished in Homer since 1978. She also designs and builds gear for the industry. She currently longlines for halibut and gillnets salmon in upper Cook Inlet aboard the F/V Realist. She can be reached at realist468@gmail.com.