This chapter examines the effects of permit transfers (change of permit holder) and migration of permit holders (permit holder changes place of residence). We provide both statewide and fishery-specific information.
Limited entry permits are allocated based upon an individual’s past participation and economic dependence on the fishery. To allocate permits among qualified applicants, CFEC develops hardship rankings, or “point systems” that measure each individual’s relative position in the fishery. The Limited Entry Act also requires CFEC to determine levels within the point system where persons would experience only “minor economic hardship” if excluded from an initial permit allocation. Persons who receive permanent limited entry permits and who are ranked at or below the minor economic hardship level receive non-transferable permits, while persons who are ranked above the minor economic hardship level receive transferable permits.
In most fisheries, the majority of permits issued came as transferable permits to persons ranked above the minor economic hardship level. The counts of permits issued as transferable and non-transferable permits can be found in Table 3-01..
This report measures changes in permit distribution by classifying permit holders based upon where they reside. Steve Langdon was the first to divide permit holders who were residents of Alaska into those who resided in places that were ‘local’ and those that were ‘nonlocal’ to the permit type1. He further defined Alaskan places as ‘rural’ or ‘urban’. Non-Alaskan permit holders were grouped as a single ‘nonresident’ category. Langdon’s conceptual categories are a useful way to examine the geographic distribution of permits. The resident types used in this report are:
An example of how this classification works could be a permit holder who lives in Dillingham and holds two limited entry permits. If one permit is for the Bristol Bay drift gillnet fishery, it will be classified as a permit held by an Alaska Rural Local (ARL) because Dillingham is a rural community and is local to Bristol Bay. If the other permit is for the Cook Inlet herring seine fishery, then that permit will be classified as one held by an Alaska Rural Nonlocal (ARN) because Dillingham is rural, but not local to Cook Inlet.
Urban and rural designations in this publication are based upon information from U.S. Census 2010. Because editions of this report prior to 2012 used Census 2000 criteria, some changes have occurred in the rural/urban designations2. In general, there are now more Alaska places designated as rural, and consequently more permits issued to persons classified as rural residents. For more detailed information concerning urban and rural classification rules, please see Appendix A.
The local/nonlocal distinctions are generally based on the regulatory boundaries of each fishery. The Upper and Lower Yukon and Kuskokwim River fishery areas are based on their immediate river drainages. The Bristol Bay area extends inland up the Nushagak River and includes Lake Iliamna, Lake Clark and the Tikchik Lake system. For a complete description of the local/nonlocal decision rules, please see Appendix A.
Resident type classifications prior to 1978 were based on the address information provided to CFEC during the issuance, renewal, and transfer of permits. Some nonresident applicants used an Alaska address, and were consequently classified as residents. After 1978, in an effort to improve the accuracy of CFEC residency data, permit renewal and transfer forms included a sworn declaration of residency. In addition, permit holders claiming Alaska residency were required to provide a valid Alaska address. Before 1982, permit renewal forms included space for only one address. The address listed may have been a temporary mailing address near the fishing grounds. As a result, a number of fishermen could have been misclassified as local to the permit type. The first edition of this report (1983) estimated the percentage of transfers involving permit holders who used an ‘in care of’ address at 2%. Since that time, there have been major permit file data corrections which included replacing temporary mailing addresses with permanent addresses. This suggests that the number of misclassified fishermen is relatively small. Beginning in 1982, permit renewal forms included space for both a permanent and a temporary mailing address. For this report, Alaska residency was designated for each individual using the last sworn declaration of residency and provided address from the permit holder among all the permanent permits the individual renewed that year. Permit holders who declared Alaska residency but provided out-of-state addresses were assigned the Alaska Data Missing resident type.
The number of permits in each resident type can change for three reasons:
To examine the geographic changes in permit distribution attributed to transfer activity, transfers have been divided into two groups:
Decreases in the number of permits held by Alaska residents are countered by increases in the number of nonresident permits. Migrations, which refer to the relocation of permit holders, have changed the resident/nonresident balance to a greater degree than permit transfers.
Cancellation most often occurs on non-transferable permits when a permit holder dies. Cancellation can also occur when the permit holder does not renew a permit for two consecutive years, or when a permit holder fails to meet the terms from a DCCED or CFAB loan. In this report, the number of cancelled permits also includes permits that were administratively removed or reconsidered through CFEC’s adjudication process. Many of the cancelled permits have been in the salmon hand troll fishery where a large number of non-transferable entry permits were issued.
Some cancelled permits are voluntarily relinquished under the special circumstances of a buyback program. Generally, permit buyback programs are established to reduce effort in the fishery, to increase economic efficiency, and/or to conserve the fishery resource. There have been four federally-funded buyback programs of CFEC permits. A.S. 16.43.310 authorizes CFEC to establish its own buyback programs in order to achieve the optimum number in a fishery. To date, CFEC has not established any buyback programs.
A buyback first occurred in 1999 when the U.S. National Park Service administered a program to buy and permanently cancel 10 Southeast Alaska Dungeness crab permits. Nine permits were transferable (3 D9AA, 4 D9BA, and 2 D9CA), and one was non-transferable (D10A). This buyback removed permits for persons who had substantial fishing history in the marine waters of Glacier Bay National Park. It was part of a larger effort to phase out commercial fishing in the park. Each of the permit holders contractually agreed to allow their permits to lapse by not renewing them.
The second buyback program occurred in 2008 when 35 permanent transferable Southeast salmon purse seine permits (S01A) were bought and retired under the Southeast Revitalization Association (SRA) fleet consolidation program. The buyback was administered by the SRA and the Alaska Sustainable Salmon Fund (under Alaska Department of Fish and Game) using federal grant funds from the Pacific Coastal Salmon Recovery Fund. The goals of the buyback were to reduce effort, promote economic efficiency, and increase flexibility in conservation and management of the fishery.
The third buyback program occurred in 2012 with another round of buybacks in the Southeast salmon purse seine fishery that permanently retired 64 more S01A permits. The 2012 buyback was administered solely by the SRA and was financed with a federal loan to be repaid by the remaining permit holders.
The fourth buyback program occurred in 2018-2019, also in the Southeast salmon purse seine fishery and administered by the SRA. CFEC retired 36 S01A permits and the National Marine Fisheries Service (NMFS) reimbursed permit holders with the remaining loan monies.
The following tables present data germane to evaluating the effects of permits transfers, migrations, and cancellations on the distribution of permanent limited entry permits (both transferable and non-transferable).
Table 3-01 presents the distribution of permits by resident type for transferable permits and all permits (both transferable and non-transferable) at initial issuance. Recall that a non-transferable permit is a permanent limited entry permit that remains with the initial issuee and cannot be transferred. A transferable permit is a permanent limited entry permit that can be freely transferred.
Table 3-02 presents the distribution of permits by resident type for transferable permits and for all permits (both transferable and non-transferable), at year-end 2022. This table excludes permits which were cancelled by the CFEC and not reinstated (summed over the entire period 1975-2022).
Table 3-03 presents the cross-cohort and intra-cohort transfers for the years 1975-2022 for all permit types combined. Cross-cohort transfers are transfers between persons of different resident types while intra-cohort transfers are transfers between individuals of the same resident type. Cross-cohort transfers result in a change in the distribution of permits between the resident types while intra-cohort transfers do not.
Table 3-04 presents the total number of permit transfers as well as the number and percent of intra-cohort and cross-cohort transfers by permit type. Cross-cohort transfers are transfers between persons of different resident types while intra-cohort transfers are transfers between individuals of the same resident type. Cross-cohort transfers result in a change in the distribution of permits between the resident types while intra-cohort transfers do not. The number of transfers includes permit foreclosures and subsequent transfers of those permits; they are counted as cross-cohort transfers.
Table 3-05 presents the net shifts in resident types, by permit type, due to transfer activity. Recall that a transfer means that the permit has changed hands through gift, sale, or trade. Changes in permit distributions are counted in net terms. A net increase in permits means that after accounting for all permit transfers, the residency group gained permits. A net decrease in permits means that after accounting for all transfers, the residency group has fewer permits. A dash mark in this table signifies a permit type where no transfers have taken place since initial issuance. A zero indicates that there have been transfers in the permit type, but there was no net change as a result of those transfers.
Table 3-06 presents the number of cross-cohort migrations of permit holders by year, for the years 1976–2022. Recall that migrations refer to the relocation of permit holders. Cross-cohort migrations are migrations of permit holders from one resident type to another. Cross-cohort migrations result in a change in the distribution of permits among the resident types.
Table 3-07 presents the net shifts in resident types due to migration of permit holders by permit type. Recall that migration refers to the relocation of permit holders. Changes in permit distributions as a result of migration are counted in net terms. A net increase in permits means that after accounting for all migrations of permit holders, the residency group gained permits. A net decrease in permits means that after accounting for all migrations of permit holders, the residency group has fewer permits. A dash mark in this table signifies a permit type where no migrations have occurred. A zero indicates that there have been migrations, but the migrations resulted in no net change.
Table 3-08 summarizes the net changes in permit holdings by resident type for the years 1975-2022. A breakout by resident type summarizes the net changes due to transfers, migrations, and cancellations. Changes in permit holdings are counted in “net” terms. A net increase in permits means that after accounting for all activity (transfers, migrations, or cancellations) of permit holders, the residency group gained permits. A net decrease in permits means that after accounting for all activity (transfers, migrations, or cancellations) of permit holders, the residency group has fewer permits.
Table 3-09 summarizes the net changes in permit holdings due to transfers, migrations, and cancellations, by permit type and resident type for the years 1975-2022.
Langdon, S. “Transfer Patterns in Alaskan Limited Fisheries” January 17, 1980.↩︎
The 2004-2012 editions of this report used Census 2000 criteria to designate rural and urban classifications. Rural and urban classifications for the 1991-2003 editions used Census 1990 population figures and the 1983 – 1990 editions used Census 1980 figures.↩︎