The committee received testimony indicating that the consideration of an IFQ or other limited access program can cause considerable speculative entry into a fishery. A first step in developing an IFQ program should be to ensure that speculative entry is prevented by limiting new participants. Removing those participants with recent and limited activity in the fishery, and preventing the reentry of latent permits (those permits qualified for use, but not currently being used) would be primary goals of a moratorium. Historical participants with a long history and current participation would continue in the fishery. Once a moratorium is in place and speculative entrants have been removed, the subsequent IFQ program can be established. It might be advantageous to begin using a combination of catch history, stewardship, or other criteria measured after a moratorium has been established rather than prior to it. One advantage of using catch history after the establishment of a license moratorium as a criterion is that all the participants would be using the same qualifying years for the allocation and would have similar conditions under which they are fishing. An additional advantage could be that stewardship criteria may be easier to incorporate after a license limitation and could be used as a complement to catch history in making allocation decisions.
Establishing the criteria for determining initial allocation in the absence of speculative entry and with all fishermen operating under the same conditions could make the process of moving from an open-access regime to an IFQ program more lengthy. However, it is possible that defining all potential participants in the program first by limiting speculative entrants, and then gaining stakeholder support by developing criteria for measuring allocation for an IFQ program after this moratorium, could result in an improved transition. This mechanism would provide an opportunity for participants to improve their catch history, decrease bycatch rates, or make other adjustments in fishing practices to make them more likely to qualify for some, or a greater quantity of, the initial allocation.