Re C2 GOA Rockfish Program – Refining Alternatives for Analysis
A Catch Shares Program Designed in Restraint of Trade
Dear Secretary Locke, Chair Olson and members of the NPFMC:
GSNA is a U.S. owned company that operates a small processing facility in Kodiak, and again we would like the Secretary and Council to discontinue the flawed package of Alternatives and restore competition to the GOA Rockfish and related fisheries.
Designed to bridge the Rockfish Pilot Program’s final season (2010) immediately into a permanent two-pie Catch Share regime, the C2 package of alternatives is being rushed through to serve particular interests. This program is not being designed by a proper public process, but rather primarily at the hands of the Alaska Groundfish Data Bank (“AGDB”) and trawl interests in conjunction with the larger processors, all of which are wrongfully combined in linked cooperatives — now ruled in violation of law.
This arrangement did not only exclude small processors such as GSNA and severely harm our profits, fishermen, customers and workforce. Especially due to its 3-year extension in MSAR 2007, the ‘rockfish demonstration’ program acted as a de facto government subsidy to our competitors — a means of wealth transfer to specific competitors in advance of designing a permanent program to continue restraint of trade. As such, it provided the funds for those included parties to not only lobby the Council and Congress at GSNA’s expense, but to sit in a prominent position today while designing these new alternatives, often behind closed doors.
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