creases in the costs of development of regulations for a new program, additional evaluation by the NMFS General Counsel, and increases in staff time required at the regional councils and among NMFS and Coast Guard staff for administration, monitoring, and enforcement. Another cost of such systems is the cost of data collection, management, and distribution. Efforts to include a wider range of potential participants in the development and implementation of IFQ programs will require additional meetings and other activities that could add to the development costs of a program.

In particular, the enforcement of an IFQ program may be more costly than for an open-access fishery. Because IFQ programs rely on the accurate reporting of individual catch and landing data, unless these data are already collected in existing management systems, new enforcement and monitoring activities may be needed. Depending on the nature of the fishery, these costs could be significantly greater than for an existing management regime. In general, fisheries with a large number of participants with small vessels, landing at numerous ports in regions with easy access to markets for unprocessed product (e.g., New England fisheries, Gulf of Mexico shrimp) will be the most difficult to monitor and enforce. Fisheries with these characteristics would require greater increases in expenditures to provide adequate monitoring and enforcement. Moreover, the same conditions that facilitate misreporting or cheating in an IFQ fishery are likely to encourage similar behavior in other non-IFQ management regimes. It is difficult to determine the appropriate level of monitoring and enforcement for a given fishery, although regional councils and fishermen in the region are likely to be able to determine what types of monitoring and enforcement programs would have to be designed for a given fishery.

A preliminary analysis of the cost of the existing management of the Alaskan halibut and sablefish IFQ programs follows. These programs were chosen because data are more readily available and more detailed than for either the SCOQ or the wreckfish IFQ programs. Based on data provided by the NMFS RAM Division, the NMFS Enforcement Division, and U.S. Coast Guard responsible for overseeing IFQ enforcement, it is clear that there were significant new expenditures for personnel, contractual services related to the establishment and maintenance of computer technology, and the computerized transaction terminals that were used in this IFQ program. Table H.6 provides the actual and projected costs of the RAM Division, Office of Administrative Appeals (OAA), and NMFS enforcement for the Alaskan halibut and sablefish IFQ programs. It should be kept in mind that in some cases, enforcement personnel also provide services to non-IFQ fisheries so that the numbers presented in Table H.6 are maximum numbers. In the case of the RAM Division, the tasks assigned to personnel also include other limited access management programs, and some of the personnel costs indicated here would include expenditures for activities other than IFQ management.



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