under antitrust legislation are considered unacceptably liberal for most fisheries (Millikin, 1994). For those programs in which transferability is allowed, the quota shares seem to transfer fairly actively (wreckfish being an exception), although the ability to purchase IFQs may be more difficult for those who do not have adequate access to capital.

Most evaluations of existing IFQ programs have questioned the adequacy of catch monitoring and enforcement (e.g., Matthews, 1997, for halibut and sablefish). Problems with enforcement increase in direct proportion to the geographic extent of the fishery, the number of fishing units in the fishery, the number of landing or sale points, and the ability to sell the fish in a retail market without processing. The use of dealers who must be registered with the fishery management program with exclusive ability to purchase IFQ fish is common (e.g., halibut, sablefish, wreckfish). Few programs have adequate internal, long-term monitoring built into the program itself, and most rely on periodic, specialized evaluations and assessments. The New Zealand ITQ program is an exception, with ongoing monitoring and enforcement activity built into it. In the Alaskan halibut and sablefish programs, enforcement actions have decreased over time (Table 3.2), although enforcement activities have increased since the implementation of IFQs (Appendix H).

Most of the existing IFQ programs provide for minimal, if any, cost recovery for administration of the program. The New Zealand program is a notable exception, in which the attributable and avoidable costs are fully recovered from quota holders. As noted above, most programs essentially give the originally issued