Chapter 2. Transfer Incidence

During the period from 1975 through 2022, 16,619 limited entry permits were issued in 79 permit types. However, not all permits are available for transfer. AS 16.43.2500 requires that CFEC develop hardship ranking systems, often called “point systems”, to allocate permits, and to determine point levels at which a person would experience only minor economic hardship if excluded from an initial permit allocation. Permanent permits issued to persons classified at minor economic hardship level are non-transferable.

Note that initial issuance refers to the issuance of a new permit whenever it occurred. Some permits for a fishery may be initially issued several years after the main body of permits has been issued. This is because some applicants are difficult to classify under a hardship ranking system, and a final determination of their standing may come only after an extensive hearing and adjudication process. In other cases, permits have been issued at a later date as the result of lawsuits brought against CFEC.

The majority of permits issued were fully transferable. Over time, there has been a net reduction in the number of permits, both transferable and non-transferable. The net reduction of transferable permits is due to the cancellation of some transferable permits and the net addition of permits that were converted from non-transferable to transferable status through the CFEC adjudication process. Similarly, the net reduction of non-transferable permits is due to the cancellation of non-transferable permits and the net conversion of non-transferable permits to transferable status through the CFEC adjudication process.

Permit Transfer Activity on Permanent Permits by Year

Two types of annual transfer rates are shown in Table 2-01. The first type is the ratio of the permits transferred for the first time (i.e., from initial issuees) to the number of transferable permits. If no new permits were issued, this ratio would decline over time because each year there would be fewer permits still held by initial issuees.

The second type of annual transfer rate reported in Table 2-01 is the ratio of all transfers to the sum of all available transferable permits. This provides a measure of the annual turnover rate for transferable permits.

Turnover Ratios by Permit Type, 1975 – 2022

In Table 2-02, permit types were divided into groups based upon the year(s) in which they were limited. A summary of transfer ratios is provided for each group. The first group consists of the original 19 salmon permit types for which permanent permits were first issued in 1975. The second group consists of the 6 Arctic-Yukon-Kuskokwim (AYK) salmon permit types for which permanent permits were first issued in 1976. The remaining limited herring, roe herring, shellfish, dive and sablefish permit types are also grouped by years of limitation. These permit type groupings appear in tables throughout this report.

The sum of annual permit counts represents the number of transferable permits at the end of each year, summed over the entire period. The summations are used to express rates of permit transfers by fishery. The rates can be compared to the all-years statewide summary rates presented in Table 2-01 to evaluate the relative turnover rate of individual fisheries.

Two measures of average annual transfer rates for individual permit types are shown in Table 2-02. The first transfer rate is calculated by dividing the cumulative total transfers from initial issuees in the fishery, by the sum of annual transferable permit counts over the same time period. The permit types limited in the most recent years have the highest rates of transfers from initial issuees, but this rate is expected to decline over time because each year there will be fewer initial issuees remaining in the permit type.

The second transfer rate is calculated by dividing all permanent transfers over the time by the sum of annual transferable permit counts over the same period. These transfer rates vary considerably by permit type.

The annual transfer rate within a permit type may vary considerably from year to year. This is demonstrated in Appendix B where the number of transferable permits, the number of transfers, and the transfer rates for each year are presented for individual permit types.

Chapter 2 Tables