Comment from N/A N/A

Document ID: NOAA-NMFS-2011-0122-0002
Document Type: Public Submission
Agency: National Oceanic And Atmospheric Administration
Received Date: May 25 2011, at 12:00 AM Eastern Daylight Time
Date Posted: May 27 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: May 23 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: June 22 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80e31900
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I believe this program should not be implemented. It is unnecessary because the the fishery is not in economic distress nor are there any problems with conservation or management. It is unfair because it will increase the cost of permits beyond the reach of new participants. The price of salmon has recovered from the record lows of early 2000's. If fact prices are historically very high for pink salmon. This data can be found here: http://www.adfg.alaska.gov/static/fishing/PDFs/commercial/84-09exvl.pdf Prices are expected to be higher in 2011 even with a predicted pink salmon catch of 55 million fish which is well above the 10 year average of 40 million fish. http://www.sf.adfg.state.ak.us/FedAidPDFs/sp11-03.pdf This combination of high prices and abundant catch points to the fact that there is no economic hardship being experienced by salmon permit holders. Fleet reduction therefore would not be helping a struggling sector of the economy. Alaska's salmon fisheries have been recognized by the Marine Stewardship Council as sustainable. http://www.msc.org/track-a-fishery/certified/pacific/alaska-salmon/alaska-salmon-1 Alaska's salmon fisheries are widely regarded as among the best managed in the world. Fleet reduction would do nothing to help conservation of the resource. In 2007 the average price of a permit was $59,700. In 2009 it was $72,800. This is an increase of almost 22%. http://www.cfec.state.ak.us/pmtvalue/X_S01A.HTM The buyback program of 2008 was a major factor in this increase. Permit prices have continued to increase and a southeast seine permit today (5/25/2011) is between $135,000 and $150,000. http://www.permitmaster.com/permits.php?order=fishery&category=Alaska This will obviously go up even more if there are less permits available. These prices are beyond what most crew members can afford or even borrow. There is simply no way now to get into this fishery without being born into it.

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