Chapter 5. Permit Transfer Survey Results

When limited entry permits are transferred, CFEC requires the two parties involved in the transfer (transferor and transfer recipient) to complete a “transfer survey”. The transfer survey allows the CFEC to monitor the broad transfer characteristics and transfer patterns of limited entry permits. The survey also allows CFEC transfer officers to evaluate the validity of a transfer. In order for a transfer recipient to receive an entry permit, the transfer recipient must be physically capable of actively participating in the fishery, have reasonable access to the necessary gear, and intend to fish the upcoming season. Permits cannot be leased, pledged, mortgaged, attached, distrained or transferred with any retained right of repossession or foreclosure, nor can permits be encumbered in any way, or on any condition requiring a subsequent transfer. Both parties involved in the transfer must sign an affidavit that attests to the validity of the survey and of all documents concerning the transfer.

The survey collects a variety of information from the transferor and the transfer recipient. In particular, the survey collects information on whether the transfer was a gift, sale, or trade; the source of permit financing; the relationship between the transferor and transfer recipient; how the permit was located; and the permit sale price. The transfer survey has been the source of information for CFEC estimated permit values, which are used by the Department of Commerce, Community, and Economic Development (DCCED) and the Alaska Commercial Fishing and Agriculture Bank (CFAB) for fishing loan purposes.

Historic Transfer Survey Completion

During the period spanning 1975 to 1979, the CFEC sent the survey to all transferors and transfer recipients, but its completion was voluntary and anonymous. During this period of voluntary compliance, completed surveys represented between 44–50% of all transfers1. The anonymity of survey respondents did not allow the surveys to be tied with other CFEC data, which made the survey data somewhat less useful. As a result of these limitations, survey information from 1975 to 1979 is not included in this report but can be found in the first edition of this report which was published in 1983.

In 1980, the CFEC modified the transfer survey in both form and requirements. In that year, completion of the survey was made mandatory and survey questions were expanded to include questions about the relationship between the transfer parties. The survey could then be tied to other CFEC data. In late 1983, the survey was expanded to include information from the transferor.

Even though the survey was made mandatory in 1980, strict enforcement of this rule did not occur until 1981. There were 140 transfers in 1980 and 15 transfers in 1981 without completed surveys. Note that in every year some transfers occurred for which a transfer survey was not completed. This accounts for the slight differences in the totals columns between Table 2-01 and the tables in this chapter. The majority of transfers without surveys occur on DCCED or CFAB foreclosed permits. Overall, the surveys represent almost every transfer since 1980.

Relationships of Transfer Participants

Beginning in 1980, transfer recipients were required to explicitly indicate their relationship to the transferor on the transfer survey. Tables 5-01 and 5-02 present the results of the transfer survey questions concerning the relationship between the transferor and the transfer recipient. Table 5-01 organizes the time-series information by permit type, while Table 5-02 organizes the information by the resident type of the transfer recipient.

There are four relationship categories:

  1. Friend/Partner: this category includes those who indicated that the transferor was either a “personal friend” or “business partner”. The friend category was reworded from “friend” to “personal friend” in October of 1983. This action may have contributed to the decrease in the “friend” category and concomitant increase in the “other” category after the wording change.
  2. Immediate Family: this category includes all those who indicated that the transferor was a member of their immediate family.
  3. Other Relative: this category includes all those who indicated that their relationship to the transferor was “other relative”.
  4. Other: transfer recipients may mark “other” on the survey form if they feel their relationship to the transferor does not fit into the categories above. The “other” category has a space to explain the nature of the relationship. The reported “other” category in this document includes those who indicated that the transferor had no relationship to themselves (“none” category). The foreclosed permits that were subsequently transferred are included in this category.

Permit Acquisition Method: Gift, Sale, Trade, and Other

Under the Limited Entry Act’s terms of free transferability, permanent limited entry permits may be sold, traded, gifted or inherited, thus enabling new participants to enter a fishery. The transfer survey includes a question about how the transfer recipient acquired the permit. Tables 5-03 and 5-04 present the results of the transfer survey’s question on the acquisition method. Table 5-03 organizes the time-series information by permit type, while Table 5-04 organizes the information by the resident type of the transfer recipient.

There are four acquisition method categories:

  1. Gift: a transfer between individuals where no remuneration is received between parties. Permits transferred as part of an inheritance are also classified as gifts. Gifts accounted for only 21.5% of all transfer survey responses in the 1975-1979 period. The increase in gift responses may be a result of efforts to enforce the Limited Entry Act’s prohibitions against leasing permits. Therefore, some of the ‘gift’ responses may actually represent lease arrangements or carry reciprocal expectations.
  2. Trade: a transfer between individuals where a permit is traded for other items of material value. The items and their values are required to be documented on the transfer survey.
  3. Sale: a transfer between individuals where a monetary transaction occurs for the permit. For sales transactions, the survey asks for the sale price and type of financing used.
  4. Other: a transfer recipient may mark “other” on the survey form if they feel that their method of acquisition does not fit into the categories of permit purchase only, combined purchase, gift, trade, or inheritance. The “other” category has a space to explain the nature of the acquisition method.

Estimated Permit Values

Permit values are derived from the June monthly CFEC Permit Value Report (PVR). Table 5-05 presents time-series data on the mean permit values by permit type. The figures represent the estimated mean value of arms-length sales transactions in June of the respective year. If fewer than four transactions occur in the previous three months, values from previous years are included to calculate the mean. All of the prices are in the current year’s dollars, having been adjusted for general price inflation. For details on permit value estimation, see the permit value estimation methods summary.

To maintain restrictions on confidential data, permit values cannot be shown in some cases. A pair of asterisks indicate these instances. The method of calculating the annual mean value of arms-length transactions was standardized in 1987. Prior to 1987, different methods were used. As a result, permit values prior to 1987 are not displayed in Table 5-05 but can be viewed in the CFEC pre-1987 permit value portal.

There are several limited permit types that do not appear in Table 5-05 because there have been insufficient sales transactions to estimate the permit value. Four of these permit types are non-transferable permits which means that they cannot be sold. The permit types where all permits issued were non-transferable permits are as follows.

  1. Southeast Dungeness crab ring net (D10A)
  2. Cook Inlet Dungeness crab ring net (D10H)
  3. Southeast Dungeness crab diving gear (D11A)
  4. Southeast shrimp otter trawl (P07A)

Permit values are confidential when there have been fewer than 4 permit sales. In Table 5-05, there are multiple permit types where the permit value is confidential. A pair of asterisks indicates confidential permit values.

Financing of Permit Purchases

If the transfer recipient marked that the permit was acquired through a sales transaction, they must specify which source of financing was used. Beginning in 1990, the method of evaluating the survey responses was changed.

Finance source data from 1980 to 2020 is evaluated in the following manner:

  1. Survey respondents may mark “other” on the survey form if they feel their source of financing does not fit into the categories of personal resources, DCCED loan, CFAB loan, other bank loans, or loans from the transferor or a processor. A review of the comments associated with the surveys marked “other” revealed that a large number of these involved unique methods of self-financing or loans from relatives or friends. Because of the strong association of the “other” financing with that of the personal resources financing, those responses are combined and classified under a “Self/Other” category thus eliminating the non-descriptive “other” category for the purposes of this report.
  2. For surveys where two finance sources were indicated, and one of those sources was “Self/Other,” the finance source reported in tables of this study is that of the alternate (other than the “Self/Other” category). The self-financing associated with permits financed by multiple methods is primarily in the form of a down payment or interim financing. The “Self/Other” category is intended to be representative of permit purchases that are primarily financed by personal resources rather than simply purchases involving a down payment as many financing methods commonly involve a down payment.
  3. Surveys involving three finance sources as well as the remainder of the two finance source surveys (i.e., those surveys that did not indicate “Self/Other”) are reported under the category of “Other Combination” financing in subsequent tables of this study.

Tables 5-06 and 5-07 present the results of the transfer survey’s permit financing question. Table 5-06 organizes the time-series information by permit type, while Table 5-07 organizes the information by the resident type of the transfer recipient.

There categories of permit financing reported are as follows:

  1. Self/Other: permit purchased with personal resources or “other” means. The transfer survey has “other” as an option with an accompanying space for explanation.
  2. Bank: permits financed through bank loans. Copies of promissory notes must be submitted with the survey.
  3. DCCED: permits financed with Department of Commerce, Community, and Economic Development (DCCED) loans.
  4. CFAB: permits financed with Commercial Fishing and Agriculture Bank (CFAB) loans.
  5. Transferor: permits financed through a transferor (seller) provided loan. The agreement between parties must be submitted with the transfer survey.
  6. Processor: permits financed through a fish processor loan.
  7. CDQ: permits financed with Community Development Quota (CDQ) program loans.
  8. Combination: permits financed using some combination of the preceding six financing methods.

Foreclosures on Permit Loans

By Alaska Statue, DCCED or CFAB are the only two lending entities that can accept a CFEC entry permit as collateral on a loan (A.S. 16.10.333). Table 5-8 reports time-series data on the number of permit loans foreclosed upon by DCCED or CFAB. Nonresidents are not eligible for DCCED or CFAB loans. As such, the nonresident permit loan foreclosures likely represent individuals who were Alaska residents when they received their loans and subsequently changed their residency status prior to foreclosure.

Chapter 5 Tables

Transfer survey results from 1980 to 2020 are presented in the following tables.

Table 5-01. Relationships of Transferors to Transfer Recipients, by Permit Type and Year

Table 5-01 CSV download

Table 5-01 presents the relationships of transferors to transfer recipients by permit type and year. The table provides the number and percentage of each relationship category. Statewide averages are shown in the “All Permit Fisheries” permit type at the end of this table. The transfer survey information for the foreclosed permits is not included in this table. The subsequent transfer of the foreclosed permits from DCCED or CFAB back to individuals are counted in the “other” category.

Table 5-02. Relationships of Transferors to Transfer Recipients by Resident Type of the Recipient

Table 5-02 CSV download

Table 5-02 presents the relationship of transferor to the transfer recipient by the resident type of the transfer recipient (resident type definitions are provided in Chapter 3). Transfer survey information for the foreclosed permits is not included in this table. The subsequent transfer of the foreclosed permits from DCCED or CFAB back to individuals are counted in the “other” category. The 1981 Yakutat salmon set gillnet fishery includes one survey in which the relationship was not indicated.

Table 5-03. Transfer Acquisition Methods by Permit Type and Year

Table 5-03 CSV download

Table 5-03 presents time-series data on the transfer acquisition methods reported in surveys from 1980 to 2020. The table displays both the number and percentage of acquisition categories. Statewide averages are presented in the “All Permit Fisheries” permit type at the end of this table. The transfer survey information for the 345 foreclosed permits is not included in this table. The subsequent transfer of the foreclosed permits from DCCED or CFAB back to individuals are counted in the “other” category. The 1981 Yakutat salmon set gillnet fishery includes one survey in which the relationship was not indicated.

Table 5-04. Transfer Acquisition Methods by Residency Type of Transfer Recipient

Table 5-04 CSV download

Table 5-04 reports transfer acquisition methods by the resident type of the transfer recipient. The table displays both the number and percentage of acquisition categories. Statewide averages are presented in the “All Permit Fisheries” permit type at the end of this table. Residency definitions are provided in Chapter 3.

Table 5-05. Permit Values by Permit Type and Year

Table 5-05 CSV download

Permit values are derived from the June monthly CFEC Permit Value Report (PVR). Table 5-05 presents time-series data on the mean permit values by permit type. The figures represent the estimated mean value of arms-length sales transactions in June of the respective year. If fewer than four transactions occur in the previous three months, values from previous years are included to calculate the mean. All of the prices are in the current year’s dollars, having been adjusted for general price inflation. For details on permit value estimation, see the permit value estimation methods summary. To maintain restrictions on confidential data, permit values cannot be shown in some cases. A pair of asterisks indicate these instances. The method of calculating the annual mean value of arms-length transactions was standardized in 1987. Prior to 1987, different methods were used. As a result, permit values prior to 1987 are not displayed in Table 5-05 but can be viewed in the CFEC pre-1987 permit value portal. The ‘Permit Sales’ column represents the number of arms-length sales transactions that occurred in that year. The ‘Begin’ and ‘End’ columns provide information on the temporal spread of transactions used to calculate the permit value, representing the month and year of first sales transaction used to calculate the year’s permit value and the month and year of the last sales transaction used to calculate the year’s permit value. Permit types with fewer than four sales are excluded from this table.

Table 5-06. Sources of Permit Financing by Permit Type and Year

Table 5-06 CSV download

Table 5-06 provides time-series data about sources of permit financing by permit type and year. This table only includes surveys where respondents indicated they purchased their permit. There are eight sources of permit financing reported in this table: self/other, bank, DCCED, CFAB, transferor, processor, CDQ, and combination. Averages for statewide sources of permit financing can be found in the “All Permit Fisheries” permit type at the end of this table.

Table 5-07. Sources of Permit Financing by Resident Type of Transfer Recipient

Table 5-07 CSV download

Table 5-07 presents time-series data about sources of permit financing organized by the resident type of the transfer recipient. Resident type definitions are provided in Chapter 3. This table only includes surveys where respondents indicated they purchased their permit. There are seven sources of permit financing reported in this table: self/other, bank, DCCED, CFAB, transferor, processor, and combination. Averages for statewide sources of permit financing can be found in the “All Permit Fisheries” permit type at the end of this table.

Table 5-08. Number of Foreclosures on Permit Loans by Resident Type and Year

Table 5-08 CSV download

Table 5-08 enumerates the total number of permits foreclosed on by DCCED or CFAB. Included are counts by resident type. Note that while DCCED and CFAB loans are only available to Alaska residents, some permit holders will change domicile after they obtain a permit. Resident type definitions are provided in Chapter 3. This table only includes surveys where respondents indicated they purchased their permit.

Endnotes


  1. CFEC “Changes in the Distribution of Permit Ownership in Alaska’s Limited Fisheries, 1975-1981”. February 1983. Page 15.↩︎