NOAA Technical Memorandum NMFS-NWFSC-115

Allocation of Fishery Harvests 

under the Magnuson-Stevens 

Fishery Conservation 

and Management Act

Principles and Practice

February 2012

U.S. DEPARTMENT OF COMMERCE

National Oceanic and Atmospheric Administration

National Marine Fisheries Service

Northwest Fisheries Science Center
NOAA Technical Memorandum

NMFS-NWFSC Series

The Northwest Fisheries Science Center of the National 

Marine Fisheries Service, NOAA, uses the NOAA Technical 

Memorandum NMFS-NWFSC series to issue scientific and 

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Alaska Fisheries Science Center, which has since been split 

into the Northwest Fisheries Science Center and the Alaska 

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Memorandum series is now used by the Alaska Fisheries 

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Reference throughout this document to trade names does not 

imply endorsement by the National Marine Fisheries Service, 

NOAA.

This document should be referenced as follows:

Plummer, M.L., W. Morrison, and E. Steiner. 2012. 

Allocation of fishery harvests under the Magnuson-Stevens 

Fishery Conservation and Management Act: Principles and 

practice. U.S. Dept. Commer., NOAA Tech. Memo. NMFSNWFSC-115, 84 p.
NOAA Technical Memorandum NMFS-NWFSC-115

Allocation of Fishery Harvests 

under the Magnuson-Stevens 

Fishery Conservation 

and Management Act

Principles and Practice

Mark L. Plummer, Wendy Morrison,* and Erin Steiner

Northwest Fisheries Science Center

2725 Montlake Boulevard East

Seattle, Washington 98112

*NMFS Office of Sustainable Fisheries

Domestic Fisheries Division

1315 East West Highway

Silver Spring, Maryland 20910

February 2012

U.S. DEPARTMENT OF COMMERCE

National Oceanic and Atmospheric Administration

National Marine Fisheries Service
Most NOAA Technical Memorandums

NMFS-NWFSC are available at the 

Northwest Fisheries Science Center

Web site, http://www.nwfsc.noaa.gov

Copies are also available from the

National Technical Information Service

5285 Port Royal Road

Springfield, VA 22161

Phone orders: 1-800-553-6847

E-mail orders: orders@ntis.fedworld.gov

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iii

Contents

List of Figures...............................................................................................................................................v

List of Tables..............................................................................................................................................vii

Executive Summary.....................................................................................................................................ix

Acknowledgments........................................................................................................................................xi

1. Introduction..............................................................................................................................................1

2. Allocation and the MSA ..........................................................................................................................3

3. Allocation Decisions in Theory ...............................................................................................................6

3.1. Efficiency of Harvest Allocations ....................................................................................................7

3.1.1. Economic Concepts of Value....................................................................................................8

3.1.2. Determining the Efficiency of Harvest Allocation....................................................................9

3.1.3. An Example of an Analysis of Allocation Efficiency.............................................................15

3.1.4. Conclusions Regarding the Analysis of Efficiency.................................................................20

3.2. Fairness for Harvest Allocation Decisions.....................................................................................21

3.3. Summary.........................................................................................................................................22

4. Allocation Decisions in Practice............................................................................................................23

4.1. FMP Allocations Among Commercial and Recreational Fisheries................................................23

4.2. Analyses of FMP Allocations (Examples) .....................................................................................35

4.3. FMP Allocations in the Context of FMP Objectives......................................................................36

5. Conclusions............................................................................................................................................42

References...................................................................................................................................................43

Appendix A: The Formal Analysis of Allocative Efficiency.....................................................................49

The Efficient Allocation of Allowable Harvest......................................................................................49

Changes in the Efficient Allocation........................................................................................................50

Reallocation when the Initial Allocation is Inefficient...........................................................................51

Appendix B: Analyses in Support of Allocation Decisions (Excerpts)......................................................59

Gulf of Mexico Fishery Management Council.......................................................................................59

Gulf of Mexico Fishery Management Council and South Atlantic Fishery Management Council........62

Mid-Atlantic Fishery Management Council...........................................................................................64

New England Fishery Management Council..........................................................................................64
iv

South Atlantic Fishery Management Council.........................................................................................65

Appendix C: Management Objectives for FMPs with Allocation Decisions .............................................71

Appendix D: Bibliography of Additional Sources......................................................................................81
v

List of Figures

Figure 1. For each sector, the total economic value of harvest increases with an increase in the 

amount harvested, but at a decreasing rate .................................................................................................11

Figure 2. Although a greater value can be achieved by allocating all of the harvest to Sector B instead 

of Sector A, the maximum total value is achieved by allocating 30% of the harvest to Sector A and 

70% to Sector B..........................................................................................................................................12

Figure 3. If harvest is allocated equally across Sector A and Sector B, the marginal value of increasing 

Sector B’s allocation exceeds the marginal value of decreasing Sector A’s allocation..............................13

Figure 4. If Sector A is commercial harvesters, a decrease in the cost of harvest could increase the 

marginal value of that sector’s harvest, which would then change the efficient allocation to one that 

allocated more harvest to Sector A and less to Sector B.............................................................................14

Figure 5. A reallocation of harvest from Sector A to Sector B is efficient if a factor changes in a way 

that increases Sector B’s marginal value of harvest....................................................................................14

Figure 6. If the ACL is set at 350 instead of 250, the efficient allocation is one that gives 41% of the 

harvest to Sector A and 59% to Sector B....................................................................................................17

Figure 7. Carter et al. estimated the commercial sector’s marginal value for red grouper harvest............19

Figure 8. While Carter et al. estimated the marginal value curve for the commercial sector in their 

analysis, the marginal value of the recreational sector is represented only by a single point, which is 

the mean WTP for recreational fishermen ..................................................................................................19

Figure A-1. If an ACL is allocated without regard to efficiency, the marginal value of harvest across 

sectors will likely not be equal....................................................................................................................54

Figure A-2. If the initial allocations act as a constraint on efficient allocations of any increase in the 

ACL, these additional allocations may involve granting 100% of the increase to one sector....................55

Figure A-3. If the additional allocation is as high as 75 units, the marginal value of harvest for Sector 

B will fall to a level that is just equal to the marginal value of Sector A’s harvest ....................................56

Figure A-4. Increases in the ACL above 75 units produce sufficient additional units to enable both 

sectors to receive increases in their allocation and achieve an efficient overall allocation ........................57
vi
vii

List of Tables

Table 1. Total and marginal values of harvest...........................................................................................10

Table 2. Sector and aggregate values of harvest allocation .......................................................................11

Table 3. Total and marginal values of additional harvest ..........................................................................15

Table 4. Sector and aggregate values of additional harvest allocation ......................................................16

Table 5. Sector and aggregate values of harvest allocation .......................................................................16

Table 6. FMPs without a significant recreational fishery ..........................................................................24

Table 7. FMPs with recreational harvest but no current allocation ...........................................................25

Table 8. FMPs with recreational allocations for at least some species......................................................25

Table 9. Commercial and recreational allocations.....................................................................................26

Table 10. Commercial and recreational allocation analyses......................................................................37

Table 11. FMP management objectives that reference commercial or recreational sectors, efficiency, 

or fairness....................................................................................................................................................40

Table A-1. Efficient and constrained allocations of ACL..........................................................................57

Table C-1. Fisheries Management Plan management objectives...............................................................71
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ix

Executive Summary

Under the Magnuson-Stevens Fishery Conservation and Management Act (MSA), a 

fishery management plan (FMP) may restrict harvest below the level that would occur in the 

absence of active management. In such a case, the allocation or the distribution of fishing 

privileges among identifiable, discrete user groups or individuals becomes an important 

consideration in the development of the plan. Allocation is at the heart of recent management 

actions such as the creation of catch shares, the imposition of restrictions on certain types of 

gear, and the consideration of how harvest should be distributed between different sectors of a 

fishery. In particular, allocation is an active policy issue when limited harvests must be divided 

between commercial and recreational fishing sectors. This technical memorandum focuses on 

the latter case, although the general descriptions of how allocation can be analyzed 

systematically apply to any of the cases mentioned.

The MSA addresses allocation by setting certain standards that a FMP must meet. These 

standards highlight two general criteria: that the plan considers efficiency in making the 

allocation and that the allocation is fair and equitable. These two criteria draw on very different 

aspects of social science. While economics provides a precise technical framework for analyzing 

the efficiency of the allocation of fishery harvest or any other resource, a similarly precise 

framework does not exist to answer the question of whether an allocation is fair. Nevertheless, 

understanding the context in which fairness can be considered is important, so we discuss how 

efficiency and fairness can be analyzed in principle.

While the analysis of efficiency and fairness is straightforward in theory, it is difficult in 

practice. We document the allocation of harvest limits between commercial and recreational 

sectors as practiced by the fishery management councils that operate under the MSA. More than 

three-fourths of the FMPs promulgated by the councils have no relevant allocation decisions 

because both commercial and recreational do not play a significant role in the fishery or are not 

actively managed by the plan. For example, of the New England Fishery Management Council’s 

eight plans, seven do not have a significant recreational fishery; thus allocation between 

commercial and recreational sectors is not (at present) an important issue for those plans. 

Similarly, the Western Pacific Fishery Management Council has no FMPs that actively manage a 

recreational sector. We do not consider these fisheries in this memorandum, nor do we consider 

plans that have a significant recreational sector but do not have (at this time) what we have 

defined as an allocation for that sector.

Instead we focus on the 11 plans that have an active recreational sector and have 

allocated allowable harvest between commercial and recreational sectors. For these plans, we 

document the council decisions that created allocations between commercial and recreational 

sectors in the fishery, and review the analyses that have been conducted to support the council’s 

decision-making process. Finally, we briefly discuss the management objectives that govern the 
x

FMPs covered here. These objectives provide a context within which allocation and other 

management decisions are made.

This technical memorandum offers no recommendations regarding the practice of making 

an allocation decision under the MSA or analyzing such a decision. Instead, our discussion of 

the principles of efficiency and fairness, as well as the many other documents and articles that 

have similar discussions, can be viewed as resources for future considerations of fishery harvest 

allocations. Similarly, the compilation of FMP allocations and analyses is a useful 

documentation of past and current practices, which can provide a basis for assessing the 

desirability of any potential changes in these practices or the need for broader data gathering or 

research to support future decisions.
xi

Acknowledgments

This memorandum has benefited from the assistance of numerous people. The following 

provided early assistance in identifying the fishery management plans that became the focus of 

our compilations: Eric Thunberg, NMFS Office of Science and Technology; James Hilger, Cindy 

Thomson, Dale Squires, and Stephen Stohs, Southwest Fisheries Science Center; Lew Queirolo, 

NMFS Alaska Regional Office; Scott Steinback, Northeast Fisheries Science Center; Stephen 

Holiman, NMFS Southeast Regional Office; and Steve Freese, NMFS Northwest Regional 

Office. Others provided vital help in checking the accuracy of those compilations: Chuck Tracy

and Jim Seger, Pacific Fisheries Management Council; John (Jack) McGovern, NMFS Southeast 

Regional Office; José L. Montañez, Mid-Atlantic Fisheries Management Council; Susan Gerhart, 

NMFS Southeast Regional Office; and Tom Nies, New England Fisheries Management Council. 

Still others provided more extensive review and comments: Rita Curtis, NMFS Office of Science 

and Technology; Dan Holland and Carl Lian, Northwest Fisheries Science Center; Dan Huppert, 

University of Washington; David Carter and Juan Agar, Southeast Fisheries Science Center; and

Galen Tromble and Jason Blackburn, NMFS Office of Sustainable Fisheries.
xii
1. Introduction

Under the Magnuson-Stevens Fishery Conservation and Management Act (MSA), a 

fishery management plan (FMP) may restrict harvest below the level that would occur in the 

absence of active management. In such a case, the allocation or distribution of fishing privileges 

among identifiable, discrete user groups or individuals becomes an important consideration in 

plan development (50 CFR Ch. VI, §600.325(c)(1)). Allocation is at the heart of recent 

management actions such as the creation of catch shares (e.g., NOAA 2010), the imposition of 

restrictions on certain types of gear (e.g., GMFMC and NMFS 2009), and the consideration of 

how harvest should be distributed between different sectors of a fishery (e.g., NPFMC 2010). In

particular, allocation is an active policy issue when limited harvests must be divided between 

commercial and recreational fishing sectors. This technical memorandum focuses on the latter

case, although the general descriptions of how allocation can be analyzed systematically apply to 

any of the cases mentioned.

The MSA addresses allocation by setting certain standards that a plan must meet. These 

standards, reviewed in more detail below, focus on two general criteria: that the plan considers 

efficiency in making the allocation and that the allocation is fair and equitable. These two 

criteria draw on very different aspects of social science. While economics provides a precise 

technical framework for analyzing the efficiency of the fishery harvest allocation or any other 

resource, a similarly precise framework does not exist to address whether an allocation is fair and 

equitable. Nevertheless, understanding the context in which fairness and equity (hereafter 

fairness) are considered is important, so this technical memorandum covers both criteria.

There is substantial literature on allocation efficiency in the context of fisheries. Edwards 

(1990) provides a guide to how economists analyze the efficiency of harvest allocations, 

focusing on the division between commercial and recreational fisheries. His guide also discusses 

the differences between economic values and economic impacts. Economic values are the 

foundation for the benefits and costs of making management decisions such as harvest 

allocations, while economic impacts are a more restricted way of assessing particular effects 

(e.g., changes in employment and income) of management decisions. Edwards (1991) covers 

similar material, in the same context of commercial and recreational harvest allocations, as do 

Bishop and Samples (1980), Sutinen (1980), Easley and Prochaska (1987), Easley (1992), and 

Green (1994).

The literature on fairness in the allocation of fisheries harvests is less substantial, but 

several discussions provide a good background. Bromley (1977) points out that the issue of 

allocation fairness (or distributions of fishing rights) is just as important as efficiency for the 

practical matter of making real world policy decisions. Loomis and Ditton (1993) and Copes 

(1997) express similar views. More general but useful treatments of the issue are in Hausman 

and McPherson (1996) and Dietz and Atkinson (2010).

This technical memorandum is broadly divided into three parts. In the first part, we 

discuss the management context of allocation decisions—that is, under what circumstances does 
2

an allocation decision take place and which parts of the MSA govern such a decision. In the 

second part, we discuss the theoretical basis for considering allocation decisions using the 

criteria of efficiency and fairness. As noted above, the first is amenable to a technical approach, 

and so we present an extended analytical framework for assessing the efficiency of an allocation 

decision. For the second, we discuss the issues relevant to an allocation’s fairness, but do not 

attempt to reduce the discussion to a similarly analytical framework. The third part of the 

memorandum reviews allocation decisions that have been made under the MSA for 11 FMPs. 

We also review the types of socioeconomic analyses that have been undertaken to support these 

decisions.
3

2. Allocation and the MSA

The MSA seeks to conserve and manage fishery resources in U.S. coastal waters. The act

established a system of regional fishery management councils that were charged with preparing 

and implementing FMPs (16 U.S.C. 1852−1853). A common feature of these plans is a 

restriction on the allowable harvest for a fishery below the level that would occur in the absence 

of active management. Such a restriction creates an important management question: How 

should the allowable harvest be allocated across potential harvesters? Here, we review the MSA 

sections that address this question.

The issue of allocation is most prominently addressed in National Standard 4, one of 10 

standards that govern the development of FMPs under the MSA. National Standard 4 states:

Conservation and management measures shall not discriminate between residents 

of different states. If it becomes necessary to allocate or assign fishing privileges 

among various United States fishermen, such allocation shall be (A) fair and 

equitable to all such fishermen; (B) reasonably calculated to promote 

conservation; and (C) carried out in such manner that no particular individual, 

corporation, or other entity acquires an excessive share of such privileges (16 

U.S.C. 1851, §301(a)(4)).

The issue of allocation is also directly covered by other parts of the MSA. Contents of Fishery 

Management Plans, Required Provisions states:

Any fishery management plan ... shall ... allocate ... any harvest restrictions or 

recovery benefits fairly and equitably among the commercial, recreational, and 

charter fishing sectors in the fishery (§303(a)(14)).

Contents of Fishery Management Plans, Discretionary Provisions states:

Any fishery management plan ... may ... establish a limited access system for the 

fishery in order to achieve optimum yield if, in developing such system, the 

council and the secretary take into account ... the fair and equitable distribution of 

access privileges in the fishery (§303(b)(6)(F)).

Limited Access Privilege Programs, Requirements for Limited Access Privileges states:

In developing a limited access privilege program to harvest fish, a council or the 

secretary shall establish procedures to ensure fair and equitable initial allocations, 

including consideration of (i) current and historical harvests; (ii) employment in 

the harvesting and processing sectors; (iii) investments in, and dependence upon, 

the fishery; and (iv) the current and historical participation of fishing communities

(§303A(c)(5)(A)).

And Action by the Secretary, Rebuilding for Overfished Fisheries states:

For a fishery that is overfished, any fishery management plan, amendment, or 

proposed regulations ... shall ... allocate both overfishing restrictions and 
4

recovery benefits fairly and equitably among sectors of the fishery

(§304(e)(4)(B)).

In each case, while the MSA requires that allocations be fair, the statute does not specify further 

how allocations should be made nor does it prescribe how the fairness of an allocation should be 

assessed.

While not addressing allocation explicitly, other parts of the MSA touch on the issue by 

specifying general requirements for FMPs. For example, National Standard 5 states:

Conservation and management measures shall, where practicable, consider 

efficiency in the utilization of fishery resources; except that no such measure shall 

have economic allocation as its sole purpose (§301(a)(5)).

National Standard 8 states:

Conservation and management measures shall, consistent with the conservation 

requirements of this Act (including the prevention of overfishing and rebuilding 

of overfished stocks), take into account the importance of fishery resources to 

fishing communities by utilizing economic and social data that meet the 

requirements of paragraph (2), in order to (A) provide for the sustained 

participation of such communities, and (B) to the extent practicable, minimize 

adverse economic impacts on such communities (§301(a)(8)).

Finally, the regulations implementing the MSA discuss at some length the allocation of 

fishing privileges in the context of National Standard 4 (§600.325, Allocations). The regulations 

recommend that a FMP contain a description of existing allocations in a fishery and any 

allocations made in the FMP as well as an analysis of any such allocations, but without defining 

the nature of the analysis that should be conducted. In addressing the fairness of an allocation, 

the regulations state that the allocation should be “rationally connected” to the FMP’s 

management objectives, including achievement of the FMP’s optimum yield, and may impose a 

hardship on one group if it is outweighed by the total benefits received by another group or 

groups. The regulations also state that the preservation of the status quo is not a prerequisite of 

satisfying the standard of “fair and equitable” if a new allocation would “maximize overall 

benefits” (§600.325(c)(3)(i)(B)).

In addition to the fairness of the allocation, the regulations for National Standard 4 list 

“promotion of conservation” (§600.325(c)(3)(ii)) and “avoidance of excessive shares” 

(§600.325(c)(3)(iii)) as factors to be considered, as well as other factors such as (but not limited 

to) “economic and social consequences of the scheme, food production, consumer interest, 

dependence on the fishery by present participants and coastal communities, efficiency of various 

types of gear used in the fishery, transferability of effort to and impact on other fisheries, 

opportunity for new participants to enter the fishery, and enhancement of opportunities for 

recreational fishing” (§600.325(c)(3)(iv)).

The regulations covering National Standard 5 address allocation in the context of 

considering an efficient utilization of fishery resources (§600.330, Efficiency). Creating or 

amending an allocation purely for economic reasons is prohibited, as the need for such an action 

must be connected to the broader objectives of the FMP. Given the satisfaction of these broader 
5

objectives, however, the regulations support management measures (including allocations) that 

“result in as efficient a fishery as is practicable or desirable” (§600.350(b)(1)).

In summary, the allocation issue is an important element of developing and amending 

FMPs under the MSA. The two criteria addressed in this memorandum, efficiency and fairness, 

are cited in the statute and regulations implementing the MSA. Two national standards (4 and 5) 

cover the two criteria, suggesting that addressing and analyzing these issues should play an 

important role in setting allocations for fishery harvests.
6

3. Allocation Decisions in Theory

Under open access conditions, a fisheries harvest is not allocated in any direct or 

deliberate way. Open access conditions provide no incentive to adjust effort across or within 

various sectors to achieve a globally efficient outcome because there is no means of capturing 

the potential benefits of such adjustments (Anderson 2004). For fisheries that have overall limits 

on harvest, a variety of allocation decisions must be addressed. The impetus for the original 

MSA was controversy over foreign fishing, thus the act addressed the allocation of harvest 

between foreign and domestic harvesters (16 USC 1853, §303(a)). Within the domestic 

harvesting sector, there is the broad division between recreation and commercial harvesters; 

within these sectors, there is further division based on gear types, states, regions, and so on.

When harvest limits are imposed on a fishery, a multitude of allocation decisions are 

made, even if the imposition merely uses historical data to create limits that mirror past behavior. 

These types of decisions are similar to other government policy decisions. Promulgating a 

regulation under the MSA or other statutes involves such a policy decision, in which case the 

federal government typically considers a number of alternatives. If the choice among them is not 

constrained in ways that make only one feasible, an important policy question is then: Which 

alternative is best? A common approach to answering this question is to assess the benefits and 

costs that accrue to individual members of society, and aggregate these individual effects. Then 

the best alternative is the one that maximizes the difference between the two, or the net aggregate 

benefits.

Because this simple approach includes the aggregation of individual benefits and costs 

across members of society, it inherently involves social judgments about those individuals. A 

simple unweighted aggregation effectively treats each individual as equal from a social 

perspective. Other aggregation schemes are possible, however, which address the issue of social 

“weights” for individual members of society more explicitly and consider the distribution of a 

policy’s effects. These considerations then become part of the policy decision making process.

In the context of analyzing a policy such as a harvest allocation, the issues of efficiency 

and fairness can be divided along the lines expressed above. Efficiency concerns the aggregate 

benefits and costs of a policy while fairness concerns the individual effects and the distribution 

across individuals of those benefits and costs. In general and for the MSA in particular, both 

issues play a role in determining from a social perspective which policy among several 

alternatives is best (Zerbe 2001).

In this section, we consider how the efficiency and fairness of a harvest allocation can be 

analyzed in principle. Efficiency is the foundation for benefit-cost analysis, the standard 

approach economists use to analyze policy actions. As such, it is often considered in a formal 

framework. Below we present such an approach by way of a series of examples. Fairness is 

central to much public policy and management, but is less commonly considered using a formal 

or quantitative approach. Our discussion follows those practices and as a result presents the 
7

efficiency criterion in greater detail than that of fairness. This disparity does not reflect, 

however, the relative importance—in theory or practice—of the two criteria.

3.1. Efficiency of Harvest Allocations

In general, efficiency refers to how well resources are utilized in production or 

consumption. An efficient allocation of resources is one that maximizes the value of those 

resources (again, in production or consumption). The efficiency of a policy can be assessed in 

terms of how the policy changes the state of the world in ways that affect the allocation of 

resources and whether those changes increase the value of the resources affected.

Economists have developed different ways of conducting such an assessment. A 

particularly stringent approach is to apply a criterion known as Pareto efficiency (Pareto 1896). 

In general, a state of the world is Pareto efficient if there is no potential change (i.e., a policy that 

changes the state of the world) that will benefit one or more individuals without harming one or 

more other individuals. A Pareto improvement is a change to an existing state that makes at least 

one person better off and makes no one worse off (Hausman and McPherson 1996).

Because the effects of government policies almost always produce a mixture of winners 

and losers, it is rare that a policy can satisfy the Pareto improvement condition. Such a failure 

does not mean the policy is inefficient, however. If a policy generates winners and losers, the 

problem is then how to weigh the winners’ benefits against the losers’ costs. If the benefits that 

accrue to the winners are somehow judged to be greater than the costs borne by the losers, the 

policy will then be more efficient than the status quo.

To address this case, economists use what is called the potential Pareto improvement

criterion. This criterion adds up individual benefits and costs, and asks whether the net 

aggregate effect is positive. Unlike the stricter Pareto improvement criterion, a potential Pareto 

improvement can judge a policy to be more efficient than the current state of the world even if 

there are individual winners and losers.1

 From its perspective, the distribution of benefits and 

costs lies outside the analysis. Only efficiency is judged by this criterion, so a simple 

approach—calculate a simple, unweighted aggregation of individual benefits and costs—is 

usually adopted.

Assessing the efficiency of a harvest allocation, then, is based on measuring the benefits 

and costs that accrue to individuals. We begin by presenting a brief review of the basis for such 

a measurement. Determining the efficiency of harvest allocations is simple in principle but 

difficult in practice. We illustrate this distinction first with a simple theoretical example of 

harvest allocation between two sectors; following this, we present an example of conducting 

such an analysis for an actual fishery, taken from Carter et al. (2008).

 1 This criterion is embedded in a more technical set of criteria known as the Kaldor-Hicks criteria (Kaldor 1939, 

Hicks 1939). Its development was an attempt to separate the aggregate value of benefits and costs (the economic 

efficiency of a policy) from the distribution of those benefits and costs (the fairness of the policy) (Zerbe 2001).
8

3.1.1. Economic Concepts of Value

Focusing on efficiency and adopting a stance of assessing the benefits and costs of a 

policy change require a metric common to benefits and costs and across all individuals. The 

standard practice is to use a monetary metric that captures the economic value of the policy’s 

effects. Economic value is based on the willingness of individuals to make trade-offs and applies 

to market and nonmarket settings. As noted in Lipton et al. (1995), “economic value is a 

measure of what the maximum amount an individual is willing to forgo in other goods and 

services in order to obtain some good, service, or state of the world. This measure of welfare is 

formally expressed in a concept called willingness-to-pay (WTP).” For analyzing the efficiency 

of a policy such as a harvest allocation, WTP is a measure of an individual’s willingness to trade 

other valuable goods for the effects of the policy change. The WTP monetary metric creates an 

accounting framework for assessing the net social benefits of a policy, one in which individual 

effects can be aggregated simply by adding them together.2

For analyzing the allocation of a fishery’s harvest, economic value reflects how various 

individuals or sectors place a monetary value on their share of the harvest. For the commercial 

harvest sector, WTP is based on market factors such as the consumer demand for seafood, the 

cost of harvesting, processing, marketing seafood, and so forth.

3

 An important consideration is 

the fact that seafood passes through a series of potentially independent stages from harvest to 

final consumption. The economic value of allocating harvest to the commercial sector then 

depends on the value or WTP at each of these stages. For harvesters, processors, wholesale and 

retail seafood firms, and other stages of supply, WTP is determined broadly by producer surplus, 

or “the excess of what producers earn over their production costs for the total quantity of a good 

sold” (Lipton et al. 1995).

4

 At the final stage in which seafood products are consumed, WTP is 

also determined by consumer surplus, or “the excess of what consumers are willing to pay over 

what they actually do pay for the total quantity of a good purchased” (Lipton et al. 1995).

The measurement of these values is difficult in theory and in practice, as discussed later 

in this subsection.5

 For our purposes here, however, we compress all the commercial stages 

from harvest to final retail sale into one, thus a commercial harvester represents the full set of 

commercial enterprises and their corresponding WTPs. The total economic value of harvest in 

 2 In most cases, WTP is determined in part by income, with higher levels of income associated with higher WTP, 

other determinants being equal. Income distribution can therefore affect the levels of WTP across individuals, thus

using WTP as a metric to measure efficiency does not entirely escape judgments about fairness (Hausman and 

McPherson 1996).

3 A fishery sometimes encompasses multiple species, which can complicate the estimation of economic values for 

the purpose of allocating one of those species. In such a case, and especially if harvest effort captures those species 

simultaneously, some or all of the costs of harvesting will be impossible (or at least not easy) to allocate to 

individual species.

4 Individuals who participate in commercial fisheries can enjoy what is known as a worker satisfaction bonus, or a 

nonmonetary benefit from their participation in the fishery, a phenomenon not unique to fisheries (Anderson 1980b, 

Pollnac and Poggie 1988, Smith 1981). This benefit may be part of the WTP for commercial harvest, which 

complicates estimating that value from market data.

5 See Just et al. (2004) for an overview of the theoretical issues involved in measuring these values in a market 

setting.
9

the commercial sector is then the sum of the consumer WTP (or consumer surplus) and the 

harvesters’ WTP (or, more generally, producer surplus).6

For recreational fishing, there may in fact be a commercial aspect if fishing occurs 

through charter boats or other commercial ventures that supply a recreational fishing experience. 

In this case, these commercial operators can be treated as part of the supply chain, while their 

customers are the “final consumers” for the recreational harvest.

7

 Recreational fishing can take 

place in a nonmarket setting, in which case the fisherman is the producer and the consumer. The 

concept of WTP still applies, again with the complication that its measurement often takes place 

for a recreational fishing trip rather than by unit of harvest. Nevertheless, it is possible to gauge 

how WTP varies with a trip’s harvest amount, so the value of recreational fishing where there are

no market transactions can still be incorporated into an efficiency analysis of allocation.

An important assumption implicit to this discussion is that the economic values in play 

are limited to the sectors that harvest the fishery resource. If the fish population has value in situ

and harvest somehow affects this value, or if the harvest itself affects other resources with 

economic value, then a broader consideration that includes these other sectors is necessary. 

Harvest levels that threaten the viability of a species or harvesting techniques that damage the 

habitat of nonharvested species are examples where such considerations may be warranted.

3.1.2. Determining the Efficiency of Harvest Allocation

In this subsection, we examine the question of what conditions make an allocation 

efficient. From the previous subsection, we note that economic value is the basis for assessing 

efficiency, measured by WTP (which we hereafter call economic value). Here we use an 

extended numerical and graphical example of allocating a harvest between two fishery sectors to 

illustrate how an efficient allocation is achieved. We then extend the example to show how 

reallocation may be warranted when the conditions that underlie the initial allocation change. 

Appendix A provides a more formal treatment of these conditions.

For the purposes of this example, we assume there are two distinct types of harvesters 

(simply, Sector A and Sector B) and that the fishery has an annual catch limit (ACL) that will be 

allocated between the two sectors. We also assume that the net economic value for varying 

amounts of harvest by each sector has been determined (later, we discuss the data needed to 

make this statement come true). An important additional assumption, common for any type of 

economic analysis, is that each sector’s total economic value increases with an increase in its 

harvest level, but at a decreasing rate.

8

 This rate is the marginal economic value, or the 

difference in the total economic value for successive amounts of harvest. This assumption 

 6 Edwards (1990) and Lipton et al. (1995) provide more extensive discussions of these concepts in the context of 

natural resources in general and fisheries in particular, respectively.

7 Commercial operations such as charter boats typically charge for a fishing trip, not by a quantity of fish harvested, 

which is how allocation occurs. This complicates the estimation of the WTP for a recreational harvest amount. 

Carter and Liese (2010) overcame this problem by using market prices for charter trips and estimating how those 

prices varied with changes in harvest rates and fish sizes. Their analysis produced an estimate of the WTP of charter 

customers for an additional harvest amount.

8 This assumption is not necessary, as it may be that the marginal value of harvest for one or more of the sectors is 

constant (or, although much less likely, increasing). In such a case, the efficient allocation may be more extreme 

and may even produce a result that allocates all of a harvest to one sector.
10

means that the marginal economic value is positive but decreasing as the harvest amount 

increases. Table 1 and Figure 1 illustrate these assumptions and form the basis for our numerical 

example. (Table 1 lists the total and marginal economic value in increments of 10 units of 

harvest, but the marginal economic value is based on single unit increments.)

Now suppose the ACL is set at 250 units of harvest. What is the most efficient allocation

of that ACL? The most efficient allocation is that which maximizes the total net benefits, or for 

this example, the sum of the total economic value for the two sectors. Table 2 lists the individual 

sector and aggregate values as the allocation ranges from 100% for Sector B to 100% for Sector 

A. At the extremes, a 100% allocation to Sector B generates more value than a 100% allocation

to Sector A, but the maximum aggregate value is achieved when the allocation between A and B 

is 30%:70%. Figure 2 illustrates these results.

Table 1. Total and marginal values of harvest.

Total value ($) Marginal value ($)

Harvest Sector A Sector B Sector A Sector B

10 3,450 6,150 341 606

20 6,800 12,100 331 586

30 10,050 17,850 321 566

40 13,200 23,400 311 546

50 16,250 28,750 301 526

60 19,200 33,900 291 506

70 22,050 38,850 281 486

80 24,800 43,600 271 466

90 27,450 48,150 261 446

100 30,000 52,500 251 426

110 32,450 56,650 241 406

120 34,800 60,600 231 386

130 37,050 64,350 221 366

140 39,200 67,900 211 346

150 41,250 71,250 201 326

160 43,200 74,400 191 306

170 45,050 77,350 181 286

180 46,800 80,100 171 266

190 48,450 82,650 161 246

200 50,000 85,000 151 226

210 51,450 87,150 141 206

220 52,800 89,100 131 186

230 54,050 90,850 121 166

240 55,200 92,400 111 146

250 56,250 93,750 101 126

260 57,200 94,900 91 106

270 58,050 95,850 81 86

280 58,800 96,600 71 66

290 59,450 97,150 61 46

300 60,000 97,500 51 26
11

Figure 1. For each sector, the total (net) economic value of harvest increases with an increase in the 

amount harvested, but at a decreasing rate.

Table 2. Sector and aggregate values of harvest allocation (ACL = 250). Boldface indicates the most 

efficient allocation.

A:B allocation 

of ACL (%)

Sector A 

value ($)

Sector B 

value ($)

Aggregate 

value ($)

0:100 0 93,750 93,750

10:90 8,437 90,000 98,438

20:80 16,250 85,000 101,250

30:70 23,438 78,750 102,188

40:60 30,000 71,250 101,250

50:50 35,938 62,500 98,438

60:40 41,250 52,500 93,750

70:30 45,938 41,250 87,188

80:20 50,000 28,750 78,750

90:10 53,438 15,000 68,438

100:0 56,250 0 56,250

What are the conditions that make this allocation efficient? The answer lies in what 

economists sometimes refer to as the equimarginal principle. Simply, the equimarginal principle 

considers the change in aggregate economic value that occurs when a small amount of the 

harvest allocation is transferred from one sector to another, say, from A to B. If the value of that 

transfer for sector A (which counts as a cost) is less than it is for sector B (which counts as a 

benefit), the reallocation will increase the aggregate economic value and therefore produce a 

more efficient allocation.

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

90,000

100,000

0 50 100 150 200 250 300

Total value ($)

Harvest amount

Sector A value

Sector B value
12

Figure 2. Although a greater value can be achieved by allocating all of the harvest to Sector B instead of 

Sector A, the maximum total value is achieved by allocating 30% of the harvest to Sector A and 

70% to Sector B.

Does this mean that all of sector A’s allocation should be transferred to sector B? In 

general, the answer is no. To see this, suppose harvest is initially allocated 50%:50% (Figure 3). 

The marginal value of harvest for sector A and B is $225 and $375, respectively. Moving one 

unit from A to B would then have a benefit of $375 (Sector B’s marginal gain) and a cost of 

$225 (Sector A’s marginal loss). This change in the allocation would therefore produce an 

increase in the aggregate total value of $150. Further changes in the same direction would 

continue to increase the aggregate total value as long as the benefit (sector B’s marginal value) 

exceeded the cost (sector A’s marginal value). Because the former decreases as more is 

transferred while the latter increases, these transfers will eventually have a negative effect on the 

aggregate total value. Where this point is just reached—that is, where the net change just 

reaches zero—the aggregate total value will be maximized. This point is where the marginal 

value for sector B is equal to the marginal value for sector A.

In principle then, the efficient allocation of an ACL can be determined by deriving each 

sector’s marginal economic value for harvest, then finding the allocation that equates that 

marginal value across all sectors.9 The particular solution or efficient set of allocations is 

dependent on the factors that underlie the economic value of each sector’s harvest. These factors 

include commercial prices and harvest costs when the sector is commercial, determinants of 

recreational fishermen’s WTP for their trips and catch, and so forth. When these factors change, 

the efficient allocation of harvest also changes, often in a predictable fashion.

 9 Appendix A treats the general case of efficient allocation of an ACL across n harvest sectors.

0

20,000

40,000

60,000

80,000

100,000

120,000

0% 20% 40% 60% 80% 100%

Total value ($)

Sector A allocation (250 units)

Sector A value

Sector B value

Aggregate value
13 

Figure 3. If harvest is allocated equally across Sector A and Sector B, the marginal value of increasing 

Sector B’s allocation exceeds the marginal value (cost) of decreasing Sector A’s allocation. A 

more efficient allocation can be achieved by transferring harvest from A to B, but the gains from 

doing so will diminish. The most efficient allocation is achieved at 30%:70% allocation.

Suppose, for example, Sector A consists of commercial harvesters and the cost of fuel 

decreases, decreasing the cost of commercial harvest. This would increase the value of sector 

A’s harvest for any given amount, and so the efficient allocation between sector A and B would 

change in a predictable direction, say, from 30%:70% to 40%:60% as illustrated in Figure 4. 

Now suppose Sector B consists of recreational harvesters and the opportunities for participating 

in other recreational fisheries become more limited. In that case, recreational fishing in the 

fishery under consideration would likely become more valuable in the sense that the marginal 

and total WTP for any level of recreational harvest would increase. This would consequently 

increase the efficient share for Sector B, say, from 30%:70% to 20%:80% as illustrated in Figure 

5. 

Finally, an increase in the ACL will, under almost any circumstances, increase the 

amount of harvest allocated to each sector, but the allocation shares in percentage terms are 

likely to change, depending on how the marginal values in each sector respond to an increase in 

harvest. A simple way of viewing this is to focus on the additional ACL, and ask the question: 

Given an efficient allocation of the original ACL, what is the efficient allocation of ∆ACL, the 

increase in the ACL?10

Suppose the ACL is adjusted upward by 100 units. Table 3 lists the increase in the total 

value for each sector using their current allocation and current total value as a baseline, and the 

 

10 Appendix A considers this case more formally, as well as the case where the original allocation of an ACL is not 

efficient but a change in the ACL presents an opportunity to improve the allocation efficiency.

0

100

200

300

400

500

600

700

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%100%

Marginal value ($)

Sector A allocation

Sector A marginal value

Sector B marginal value

MVB = $375

MVA = $225 MVB = MVA
14 

Figure 4. If Sector A is commercial harvesters, a decrease in the cost of harvest could increase the 

marginal value of that sector’s harvest, which would then change the efficient allocation to one 

that allocated more harvest to Sector A and less to Sector B.

Figure 5. A reallocation of harvest from Sector A to Sector B is efficient if a factor changes in a way that 

increases Sector B’s marginal value of harvest.

0

100

200

300

400

500

600

700

0% 20% 40% 60% 80% 100%

Marginal value ($)

Sector A allocation

Sector A marginal value

Sector A' marginal value (new)

Sector B marginal value

0

100

200

300

400

500

600

700

800

0% 20% 40% 60% 80% 100%

Marginal value ($)

Sector A allocation

Sector A marginal value

Sector B marginal value

Sector B marginal value (new)
15

Table 3. Total and marginal values of additional harvest. Boldface indicates the most efficient allocation.

Total value ($) Marginal value ($)

Sector A Sector B Sector A Sector B

Value of initial 

harvest 23,438 78,750 — —

Value of additional 

harvest Total additional value ($)

Marginal value 

of additional harvest ($)

Sector A Sector B Sector A Sector B

1 274 274 274 274

5 1,362 1,350 271 266

10 2,700 2,650 266 256

15 4,012 3,900 261 246

20 5,300 5,100 256 236

25 6,562 6,250 251 226

30 7,800 7,350 246 216

33 8,530 7,986 243 209

35 9,012 8,400 241 206

40 10,200 9,400 236 196

45 11,362 10,350 231 186

50 12,500 11,250 226 176

55 13,612 12,100 221 166

60 14,700 12,900 216 156

65 15,762 13,650 211 146

67 16,180 13,936 209 142

70 16,800 14,350 206 136

75 17,812 15,000 201 126

80 18,800 15,600 196 116

85 19,762 16,150 191 106

90 20,700 16,650 186 96

95 21,612 17,100 181 86

100 22,500 17,500 176 76

marginal value at each increased amount of harvest. Increasing the harvest in each sector 

produces an increase in the total value above the initial harvest levels, but the marginal values 

are different. In this example, giving 100% of the additional harvest to Sector A produces more 

value than giving 100% to Sector B. But using the equimarginal principle, the most efficient

allocation is found by dividing the additional harvest (67%:33%), as shown in Table 3 and Table 

4 (boldfaced cells). One can also simply conduct the analysis of an efficient allocation over 

again; Table 5 and Figure 6 illustrate the new efficient allocation for an ACL of 350 units.

3.1.3. An Example of an Analysis of Allocation Efficiency

In this subsection, we present an example of an analysis that addresses the economic 

efficiency of a commercial-recreational harvest allocation. The example covers the Gulf of 

Mexico red grouper (Epinephelus morio) fishery, which is part of the Gulf of Mexico FMP for 
16

Table 4. Sector and aggregate values of additional harvest allocation (ACL = 350). Boldface indicates 

the most efficient allocation.

A:B allocation of 

additional ACL (%)

Sector A 

value ($)

Sector B 

value ($)

Aggregate 

value($)

0:100 0 17,500 17,500

10:90 2,700 16,650 19,350

20:80 5,300 15,600 20,900

30:70 7,800 14,350 22,150

40:60 10,200 12,900 23,100

50:50 12,500 11,250 23,750

60:40 14,700 9,400 24,100

67:33 16,180 7,986 24,166

70:30 16,800 7,350 24,150

80:20 18,800 5,100 23,900

90:10 20,700 2,650 23,350

100:0 22,500 0 22,500

Table 5. Sector and aggregate values of harvest allocation (ACL = 350). Boldface indicates the most 

efficient allocation.

A:B allocation of 

additional ACL (%)

Sector A 

value ($)

Sector B 

value ($)

Aggregate 

value ($)

0:100 0 96,250 96,250

10:90 11,638 97,650 109,288

20:80 22,050 96,600 118,650

30:70 31,238 93,100 124,338

40:60 39,200 87,150 126,350

41:59 39,168 68,586 126,354

50:50 45,938 78,750 124,688

60:40 51,450 67,900 119,350

70:30 55,738 54,600 110,338

80:20 58,800 38,850 97,650

90:10 60,638 20,650 81,288

100:0 61,250 0 61,250

Reef Fish (Reef Fish FMP),

11 and is taken from Carter et al. (2008). The example replicates the 

basic approach outlined in the previous section, but underscores the challenges in bringing even 

a simple theoretical framework to life with data.

In 1984 the Gulf of Mexico Fishery Management Council implemented the Reef Fish 

FMP to protect and rebuild declining reef fish stocks. Through the late 1990s, the Reef Fish 

FMP was amended several times, including establishment of quotas covering shallow water 

groupers and deep water groupers.12 In October 2000 NOAA declared the red grouper resource 

 11 The harvest of red grouper takes place in a multispecies fishery. 12 The shallow water grouper complex occurs primarily in the eastern Gulf of Mexico. Red, gag (Mycteroperca 

microlepis), black (M. bonaci), scamp (M. phenax), yellowfin (M. venenosa), yellowmouth (M. interstitialis), rock 

hind (Epinephelus adscensionis), and red hind (E. guttatus) groupers comprise the shallow water grouper complex. 
17

Figure 6. If the ACL is set at 350 instead of 250, the efficient allocation is one that gives 41% of the 

harvest to Sector A and 59% to Sector B.

to be overfished and undergoing overfishing, which resulted in the development of Secretarial 

Amendment 1. This amendment became effective in July 2004 and established a rebuilding plan 

for red grouper that relied on a two-tier commercial shallow water grouper quota. Under the 

two-tier quota system, the shallow water grouper fishery (which includes red grouper) would 

close when either the aggregate shallow water grouper quota of 8.8 million pounds or the red 

grouper quota of 5.31 million pounds was reached.13

For red grouper, the amendment used the then recent catch history for the commercial 

and recreational sectors as a baseline from which to set harvest reductions. For the period 1999–

2001, the commercial-to-recreational harvest ratio was 81%:19%. Using this as a baseline, the 

council decided to reduce each sector’s allocation by the same percentage. Since Secretarial 

Amendment 1, subsequent amendments have further constrained red grouper and other Gulf of 

Mexico reef fish harvests.

 

[Footnote 12 continued.] Their affinity for reef and hard bottom areas makes them susceptible to fixed gears such as 

longlines, vertical lines, and traps. Red grouper is the most important component of the shallow water grouper 

complex, followed by gag and black grouper. In 2004 the commercial fleet landed about 10.3 million pounds of 

shallow water groupers (whole weight) with a dockside value of $22.1 million. Red grouper accounted for 65.8% of 

the landings and 60.2% of the revenues, and gag grouper accounted for 29.6% of the landings and 34.5% of the 

revenues. Black grouper accounted for approximately 5% of the landings and revenues. Longlines alone accounted 

for about 60% of total red grouper landings. Vertical line and traps were responsible for about 25% and 13% of red 

grouper landings, respectively. The deep water grouper complex consists of snowy (Epinephelus niveatus), 

yellowedge (E. flavolimbatus), speckled hind (E. drummondhayi), warsaw (E. nigritus), and misty (E. mystacinus) 

groupers. Harvesting Nassau (E. striatus) and goliath (E. itajara) groupers is banned. 13 All quotas are expressed as gutted weight (pounds).

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

0% 20% 40% 60% 80% 100%

Total value ($)

Sector A allocation (350 units)

Sector A value

Sector B value

Aggregate value
18

The issue of allocation has come to the forefront recently for other fishery management 

actions considered by the Gulf of Mexico Fishery Management Council. To address this issue, 

Carter et al. (2008) developed a framework for analyzing allocation efficiency, using red grouper 

as a case study. Their approach was to apply the equimarginal principle to commercial and 

recreational fisheries for red grouper as they stood in 2003. Given an overall total allowable 

catch of 6.21 million pounds, the problem they addressed was to identify the allocation that 

maximized the aggregate economic value of harvest. As illustrated in the previous subsection, 

each sector ideally would be represented by schedules of total and marginal economic values 

associated with varying levels of harvest. The efficient allocation would then occur where the 

marginal value of harvest is equal across sectors.

For the commercial sector, the estimation of economic values faced several challenges:

• Because the grouper is jointly caught with several other species, the estimation of 

economic benefits had to explicitly consider how the allocation of red grouper would also 

affect the economic benefits derived from the suite of other jointly caught species, not 

simply the grouper;

• Data on harvest costs were not available; and

• Data on nonharvest commercial sectors (processing, wholesale, etc.) were not available.

Using available data, they were able to estimate commercial harvest values for the 

vertical and longline fleets with trip level data that included landings and prices by species, area 

fished, area of landing, and fishing effort. Ideally, the economic value of commercial harvest 

would also include estimates of values up the supply chain, including consumer surplus for final 

consumer demand, but data were insufficient to create a full set of such estimates. In the case of 

final consumer demand, this seems less problematic, as they found that seafood demand for red 

grouper at that wholesale level was very elastic, which means that potential changes in consumer 

surplus from changes in commercial harvest would be small (Just and Hueth 1979). Given these 

limitations, they were able to estimate a marginal economic value curve for commercial harvest 

(Figure 7).

For recreational fishing, Carter et al. (2008) used data on charter boat pricing and

recreational harvest rates and other characteristics of recreational fishing sites to estimate 

recreational WTP for additional catch (see also Carter and Liese 2010). Their method and 

available data limited the results to a single point, however, reflecting a mean WTP (across all 

recreational anglers) of the current harvest level.

Using the estimated marginal value schedule for commercial harvesters and the single 

estimated marginal WTP for recreational harvesters, Figure 8 illustrates how a reallocation of the 

red grouper harvest could increase efficiency. Using 2003 as the base year, the overall harvest of 

6.21 million pounds was approximately divided between commercial and recreational harvesters 

in the ratio 79.5%:20.5%, or 4.94 million pounds and 1.28 million pounds, respectively. Taking 

the two curves as exact representations of the respective economic values, the marginal 

economic value is higher for recreational fishing ($1.21) than for commercial fishing ($1.14). 

Reallocating some of the commercial harvest to the recreational sector would therefore increase 

the aggregate economic value and so improve efficiency.
19 

Figure 7. Carter et al. (2008) estimated the commercial sector’s marginal value for red grouper harvest. Commercial marginal WTP ($/lb) Recreational marginal WTP ($/lb)

2003 commercial harvest (millions of lb)

4.77 4.94

Commercial demand for quota

Point estimate of 

recreational 

demand for quota

E 

Figure 8. While Carter et al. (2008) estimated the marginal value curve for the commercial sector in their 

analysis, the marginal value of the recreational sector is represented only by a single point, which 

is the mean WTP for recreational fishermen.

0.00

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

0 2 4 6 8

Price ($/lb)

Quota (millions of lb gutted weight)
20

Because the recreational sector’s economic value is only estimated for the base case (a 

single point), however, the precise amount to reallocate to maximize efficiency cannot be known, 

as it depends on the shape and the slope of the marginal economic value curve for the 

recreational sector. A number of linear possibilities are shown in light shading around point E in 

Figure 8. The maximum reallocation would correspond to the case of a flat marginal economic 

value curve. Based on the estimated commercial marginal economic value curve, a flat 

recreational curve implies that the most that would be efficiently reallocated from the 

commercial to the recreational sector would be about 168,000 pounds, given the conditions that 

existed in 2003. Caution should be used, however, in drawing conclusions from this example as 

presented above. The 95% confidence interval for estimated recreational marginal economic 

value point ranges from $0.30 to $2.12, which spans the estimated marginal economic value for 

the commercial sector at its current allocation ($1.14).14 For that reason, it is difficult to draw 

strong conclusions about whether a reallocation would be justified in this case on the grounds of 

efficiency.

3.1.4. Conclusions Regarding the Analysis of Efficiency

Identifying the precise, efficient harvest allocation that achieves the maximum aggregate 

economic value is easy to demonstrate in principle, but difficult in practice. Nevertheless, a few 

important points are salient:

• The data requirements for a fully realized analysis of allocation efficiency are daunting. 

As noted above, both commercial and recreational sectors consist of multiple stages from 

harvest to final consumption. In principle, data sufficient to estimate producer surplus at 

each stage and consumer surplus at the final stage are needed to capture the economic 

values being generated across all these stages. These requirements can be eased if a few 

assumptions common for this type of economic analysis are made. For example, an 

increase in commercial harvest will typically produce changes in the amounts of labor,

fuel, ice, fishing equipment, and so forth. The subsequent changes in producer surplus in 

those markets, however, are typically viewed as negligible as long as they are 

competitive markets (Edwards 1990). And because harvest allocations are typically 

species specific, changes in the commercial harvest of one species may have modest 

effects in the retail and even wholesale markets for seafood if other species or products 

are good substitutes for that species. In that case, those markets can be excluded from the 

analysis. Even with these possibilities, the data requirements for analyzing just the 

primary commercial and recreational harvest stages are substantial.

• Whether data are rich or sparse, the equimarginal principle for an efficient allocation of 

harvest limits is still relevant. Using that principle and whatever data are available, it 

may be possible to conclude that a current allocation is inefficient and know which 

direction one should move, but it may also be difficult to identify the new, efficient 

allocation precisely.

• A change in ACL will move allocated harvest amounts for all sectors in the same 

direction, but keeping harvest shares the same may or may not be efficient (assuming the 

initial allocation was efficient).

 14 Similar confidence intervals could not be calculated for the estimates of marginal WTP in the commercial sector.
21

3.2. Fairness for Harvest Allocation Decisions

Efficiency considerations impose a common, unweighted, monetary metric on all 

consequences stemming from an allocation decision. This enables an analysis to reach a bottom 

line: Does the decision increase net aggregate benefits? If the answer is yes, the decision 

improves the efficiency of the fishery harvest. Consideration of the fairness of an allocation 

decision does not entail a similar objective analysis. Identifying the types of information that 

inform a determination of fairness is straightforward, but how a decision maker uses that 

information and assesses fairness is ultimately a policy issue.

In the context of public policy, fairness inherently involves considering the welfare of 

individuals vis-à-vis the welfare of other individuals. For efficiency, the WTP of each individual 

is taken as an accurate accounting of that individual’s welfare and weight in the broader 

calculation of social welfare. For a consideration of fairness, however, a WTP measure is not 

necessarily the same as a measure of an individual’s welfare (Farrow 1998). Two individuals 

can have the same income or experience the same change in income yet have different levels or 

subsequent changes in welfare. Incorporating fairness into an analysis of a policy’s effects must 

therefore account for the difference between the WTP and the more general welfare of a policy.

A social welfare function is a way of accounting for individual welfare measures and 

analyzing the fairness of an allocation policy. Such a function can give meaning to the 

statement, for example, that one distribution of income is better (from a social perspective) than 

another (Boadway and Bruce 1984). One way of incorporating fairness into an analysis of social 

welfare focuses on the distribution of income and disparities that exist in that distribution. A 

social welfare function could, for example, combine a measure of income levels such as average 

income with a measure of income disparities such as the dispersion of incomes (Boadway and 

Bruce 1984).

15 Another approach is to assign particular weights to individuals or groups of 

individuals, then sum the weighted incomes to produce a measure of the social value of a 

particular income distribution or distribution of incomes changes (Mishan and Quah 2007). 

Combining income levels or changes and the dispersion of income or income changes in a social 

welfare function then enables a decision maker to assess which policy is “best” while explicitly 

accounting for the policy’s effects on efficiency and fairness.

Because a social welfare function accounts for the possibility of trade-offs between 

efficiency and fairness, it is entirely possible for measures of efficiency and measures of social 

welfare to rank projects differently. The most efficient allocation may be deemed unfair, at least 

compared to a different (and feasible) allocation. The allocation that is fairer, however, will then 

be less efficient. It can even be the case that a social welfare function’s allowance for the 

fairness of a policy’s distribution results in a best policy being one that has negative net 

aggregate benefits compared to the status quo (Freeman 2003).

 15 An example commonly used in the analysis of poverty and other aspects of income inequality is the Gini 

coefficient (Gini 1921). The coefficient reflects the difference between the actual distribution of income and one in 

which every individual has the same income. It ranges between zero (each individual has an equal income) and one 

(one individual has all the income while all others have none). The Gini coefficient can also be used as an index of 

the inequality of changes in income.
22

Unlike the theoretical framework for efficiency, however, there is no objective way of 

assessing social welfare and constructing a social welfare function because these tasks inherently 

involve “someone making prior value judgments” (Boadway and Bruce 1984, see also Hausman 

and McPherson 1996). Moreover, even the components of a social welfare function are a matter 

of policy choice. Possibilities include the individual welfare generated by an actual bundle of 

resources (Dworkin 1981a); the bundle of resources itself, independent of differences across 

individuals in the welfare associated with those bundles (Dworkin 1981b); the opportunities an 

individual has to achieve various levels of welfare (Arneson 1990); the capabilities an individual 

has to achieve various levels of welfare (Sen 1987, 1992); and so forth.

Baumol (1980, 1986) has developed a formal framework for incorporating fairness 

considerations into economic analysis. He introduced the concept of “superfairness,” a

distribution of resources such that each group with a share of the resource prefers its own share 

to that received by any other group (Baumol 1980). He also defined the concept of “incremental 

superfairness,” a change in the distribution of a resource such that each group affected by the 

change prefers its own increment to that of any other group. This latter concept is intended to 

address the fairness of changes in distribution independent of the fairness of the initial 

distribution. This is an important qualification for actions such as harvest allocations, for the 

management of fisheries cannot (in most cases) address the broader social fairness of the 

distribution of income unaffected by those actions.

In conclusion, the consideration of the second allocation criterion, fairness, is difficult to 

place in an objective, formal framework, thus our treatment of this criterion is significantly 

briefer than the treatment of efficiency. The disparity does not reflect the relative importance of 

the two criteria, only the ease with which each is examined in such a framework. Because the 

distribution of a policy action’s effects is central to the determination of the policy’s fairness, 

however, documenting those distribution effects is an obvious way of addressing that issue in the 

context of making an allocation of fishery harvest. It is straightforward, then, to describe the 

distribution of a given allocation and so pose the question: Is this particular distribution fair and 

equitable? Answering that question is fundamentally a policy task, however, not a scientific one.

3.3. Summary

Under the MSA, allocation decisions are expected to address the issues of efficiency and 

fairness. As seen above, efficiency is amenable to a formal, quantitative analysis, although 

gathering the data needed to conduct such an analysis is challenging; fairness is more difficult to 

analyze in that way, but can at least be addressed by documenting how a decision affects a 

fishery’s individual sectors.

It is not within the purview of this technical memorandum to recommend particular 

approaches to considering efficiency and fairness and incorporating these considerations into a 

particular council’s allocation decisions. In the following section, we document how they have 

been considered in practice.
23

4. Allocation Decisions in Practice

In this section, we document the practice of allocating harvest limits between commercial 

and recreational sectors. This issue is relevant, of course, only when both sectors play a 

significant role in a fishery and are actively managed by an FMP. This is not the case, however,

for more than three-fourths of the FMPs covered in this technical memorandum. Of the New 

England Fishery Management Council’s eight FMPs, for example, seven do not have a 

significant recreational fishery, thus allocation between commercial and recreational sectors is 

not at present an important issue for these FMPs. Similarly, the Western Pacific Fishery 

Management Council has no FMPs that actively manage a recreational sector. Table 6 lists the 

FMPs that do not have a significant recreational fishery, which means the issue of commercialrecreational allocation is not an active one.

In other cases, a FMP can have a recreational sector but management might not at this 

time involve what we have defined as an allocation for that sector. In most cases, limits on

recreational per trip harvests, size of harvest, or other constraints are in place, but the FMP does 

not attempt to assess total recreational harvest and allocate some proportion of an overall 

allowable harvest to the recreational sector. Table 7 lists the FMPs that fall into this category. 

The remaining 11 FMPs have an active recreational sector and have allocated allowable harvest 

between commercial and recreational sectors. These FMPs are listed in Table 8.

Below, we first give an overview of the allocation decisions we have compiled. We 

gathered information from publicly available documents on all regulatory actions that constituted 

what we defined as a commercial-recreational allocation decision: a regulation establishing or 

amending a FMP that 1) created or continued a limit on allowable harvest and 2) allocated that 

limit to commercial and recreational sectors either explicitly (e.g., by specifying a commercialrecreational ratio or sector-specific limits) or implicitly (e.g., by specifying a limit on one sector). 

We then discuss the types of analyses that have supported these decisions. (In Appendix B we 

give excerpts of several of these analyses.) For our purposes, we defined analysis as a 

calculation that demonstrated a change in an economic characteristic of the fishery. Finally, we 

briefly discuss the management objectives that govern the FMPs that are included in our set of 

allocation decisions. These objectives provide a context within which allocation and other 

management decisions are made. In particular, we note where an FMP explicitly contains an 

objective that references the commercial or recreational sector.

4.1. FMP Allocations Among Commercial and Recreational 

Fisheries

We documented 26 regulations that address fisheries allocations between commercial and 

recreational fisheries, 25 of which were completed between 1983 and the end of 2010, and one of 

which is in progress as of this writing (Table 9). Some regulations provide allocations for one 

species (i.e., Atlantic bluefish [Pomatomus saltatrix]), while others allocate across multiple 
24

Table 6. FMPs without a significant recreational fishery.

Council FMP

Caribbean Fishery Management Council Corals and reef associated invertebrates of Puerto 

Rico and the U.S. Virgin Islands

Gulf of Mexico Fishery Management Council Gulf of Mexico coral and coral reefs

Red drum fishery of the Gulf of Mexico

Mid-Atlantic Fishery Management Council Atlantic surfclam and ocean quahog fisheries

Spiny dogfish

New England Fishery Management Council Atlantic deep sea red crab

Atlantic herring fishery

Atlantic salmon fishery

Atlantic sea scallops

Monkfish fishery

Skates

Small mesh multispecies fishery

North Pacific Fishery Management Council Arctic fisheries

Bering Sea/Aleutian Islands king and tanner crab

Groundfish fishery of the Bering Sea and Aleutian 

Islands area

Scallop fishery off Alaska

Pacific Fishery Management Council Coastal pelagic species

South Atlantic Fishery Management Council Comprehensive ecosystem based FMP

Coral, coral reefs, and live/hard bottom habitats of 

the South Atlantic region

Golden crab fishery of the South Atlantic region

Pelagic sargassum habitat of South Atlantic region

Shrimp fishery of the South Atlantic region

Western Pacific Regional Fishery Management 

Council

Bottomfish and seamount groundfish fisheries of the

Western Pacific region

Coral reef ecosystem of the Western Pacific

Crustacean fisheries of the Western Pacific region

Pelagic fisheries of the Western Pacific region

Precious corals fishery of the Western Pacific region

species (Amendment 1 to the Gulf of Mexico Reef Fish FMP addresses nine species and two 

species groups). Overall, we documented allocations for 36 different stocks of fish (30 species).

Of the 26 regulations, all but one either created or modified existing allocation ratios. 

Only one regulation (Amendment 23 to the Reef Fish FMP) rescinded a commercial-recreational 

allocation in its entirety. Vermilion snapper (Rhomboplites aurorubens) was originally allocated 

67%:33% to the commercial and recreational sectors, respectively, in Amendment 1. Through 

time, however, the catch evolved to a ratio of 79%:21%. The council decided that returning to 

the original allocation would have too much of an impact on the commercial fishery, so they 

approved regulations that did not designate allocations.
25

Table 7. FMPs with recreational harvest but no current allocation.

Council FMP

Caribbean Fishery Management Council Queen conch resources of Puerto Rico and the U.S. 

Virgin Islands

Shallow water reef fish fishery of Puerto Rico and 

the U.S. Virgin Islands

Spiny lobster fishery of Puerto Rico and the U.S. 

Virgin Islands

Gulf of Mexico Fishery Management Council Shrimp fishery of the Gulf of Mexico

Stone crab fishery of the Gulf of Mexico

International Pacific Halibut Commission Pacific halibut

Mid-Atlantic Fishery Management Council Tilefish

North Pacific Fishery Management Council Groundfish fishery of the Gulf of Alaska

High seas salmon fishery off the coast of Alaska, 

east of 175° east longitude

Pacific Fishery Management Council U.S. West Coast fisheries for highly migratory 

species

South Atlantic and Gulf of Mexico fishery 

management council joint efforts

Spiny lobster fishery of the Gulf of Mexico and 

South Atlantic

Table 8. FMPs with recreational allocations for at least some species.

Council FMP

Gulf of Mexico Fishery Management Council Reef fish resources of the Gulf of Mexico

Mid-Atlantic Fishery Management Council Atlantic bluefish

Atlantic mackerel, squid, and butterfish fisheries

Summer flounder, scup, and black seabass fisheries

New England Fishery Management Council Northeast multispecies fishery

NMFS Highly Migratory Species Division Atlantic highly migratory species

Pacific Fishery Management Council Pacific coast groundfish

West Coast salmon

South Atlantic and Gulf of Mexico fishery 

management councils joint efforts

Coastal migratory pelagic resources of the Gulf of 

Mexico and South Atlantic

South Atlantic Fishery Management Council Dolphin and wahoo

Snapper-grouper fishery of the South Atlantic region
26 

Table 9. Commercial and recreational allocations.

Fisheries 

Management 

Plan Regulation Fishery

Allocation ratio 

(commercial % to 

recreational %) Categorya/Noteb Basis for allocation

Gulf of Mexico Fishery Management Council

Reef fish 

resources of the 

Gulf of Mexico

Amendment 1 

(1990) 

Greater amberjack 14:86 Y/L Historical catch 1979–1987. These years 

represent the longest time period of 

documented commercial and recreational 

annual harvests.

Gray snapper 32:68 Y/L

Groupers in aggregate 65:35 Y/L

Jewfish 36:64 Y/L

Lane snapper 25:75 Y/L

Mutton snapper 43:57 Y/L

Red Snapper 51:49 Y/L

Sea basses 3:97 Y/L

Snappers in aggregate 49:51 Y/L

Vermillion snapper 67:33

(allocation later 

removed)

Y/L

Yellowtail snapper 55:45 Y/L

Secretarial 

Amendment 1 

(2004) 

Red grouper 81:19

(allocation later 

changed) 

Y/SQ The ratio 1900–2000 was 76%:24%, close to 

the 1986–1989 ratio (75%:24%). In recent 

years (1999–2001), however, it has shifted to 

81%:19% due to management changes and a 

strong 1996 class year that boosted 

commercial catch more than recreational 

harvest. The current amendment does not 

attempt to address the question of singlespecies grouper allocations. Instead, it 

applies the same percentage reductions to 

each sector, thus effectively maintaining 

allocations at current levels.

Amendment 23 

(2004) 

Vermillion snapper Removed 

allocations

RE Current catch 79%:21%. Returning to 

allocation from Amendment 1 would reduce 

commercial catch by 37%. Options chosen 

by the council do not designate commercial 

and recreational allocations.
27 

Table 9 continued. Commercial and recreational allocations.

Fisheries 

Management 

Plan Regulation Fishery

Allocation ratio 

(commercial % to 

recreational %) Categorya/Noteb Basis for allocation

Reef fish 

resources of the 

Gulf of Mexico

continued 

Amendment 

30A (2008) 

Gray trigger 21:79 Y/SQ This is not an official allocation. Historic 

landings (2000–2004) had a ratio of 

21%:79%. The proposed rule reduces 

landings by 60% for both sectors retaining 

the historic ratio. Council created an ad hoc 

committee to examine fair and equitable 

ways to allocate in the future.

Greater amberjack 27:73 Y/L Close to historical average 1981–2004 (was 

29%:71%). The council reduced recreational 

landings proportionally less than commercial 

landings because of perceived inequities in 

the effects of previous management decisions 

and greater amberjack’s value as a 

recreational sport fish.

Amendment 

30B (2009) 

Gag grouper 39:61 Y/L Interim allocation based on 1986–2005 (the 

longest and most robust time series 

available). In addition, these data show how 

the fishery has been shared over time. The 

council created a committee to examine 

future allocation issues.

Red grouper 76:24 Y/L

Gulf of Mexico Fishery Management Council and South Atlantic Fishery Management Council

Coastal 

migratory 

pelagic 

resources of the 

Gulf of Mexico 

and south 

Atlantic

FMP (1983) King mackerel 24:76

(allocation later 

changed) 

Unk Allocations (as pounds) were provided. 

Catch was set for above the current harvest. 

No detail provided on how the allocations 

were determined.

Amendment 1 

(1985) 

King mackerel, Atlantic 

group 

37.1:62.9 Unk No discussion provided on how the initial 

allocations were determined. The 

amendment states this is a temporary 

allocation and gives the method for changing 

future allocations: use the “longest numbers 

of years beginning in 1979 for which 

concurrent recreational and commercial data 

are available.”
28 

Table 9 continued. Commercial and recreational allocations.

Fisheries 

Management 

Plan Regulation Fishery

Allocation ratio 

(commercial % to 

recreational %) Categorya/Noteb Basis for allocation

Coastal 

migratory 

pelagic 

resources of the 

Gulf of Mexico 

and south 

Atlantic

continued 

King mackerel, Gulf 

group 

32:68 Y/NE Historical catch (1975–1979 was 30%:70%). 

Moved 2% of allocation from recreational to 

commercial to account for recreational fish 

sold. Amendment states this is a temporary 

allocation and gives the method for changing 

future allocations: use the “longest number of 

years beginning in 1979 for which concurrent 

recreational and commercial data are 

available.”

Amendment 2 

(1987) 

Spanish mackerel, 

Atlantic group

76:24

(allocation later 

changed)

Y/R Catch 1979–1985 (most recent time period 

with catch data).

Spanish mackerel, Gulf 

group

57:43 Y/R

Amendment 4 

(1989) 

Spanish mackerel, 

Atlantic group

50:50

(allocation later 

changed) 

Y/B Council noted that the 76%:24% allocation 

was from a time when resources were 

overfished and recreational participation was 

low. Limited data from early 1970s suggests 

50%:50% split.

Catch 

specifications 

(1999) 

Spanish mackerel, 

Atlantic group

55:45 Y/SQ TAC was decreased. Allocation changed to 

allow commercial to catch similar amount as 

last year since recreational does not use full 

allocation.
29 

Table 9 continued. Commercial and recreational allocations.

Fisheries 

Management 

Plan Regulation Fishery

Allocation ratio 

(commercial % to 

recreational %) Categorya/Noteb Basis for allocation

Mid-Atlantic Fishery Management Council

Atlantic 

bluefish

Amendment 1 

(2000) 

Bluefish 17:83 Y/B Average catch 1981–1989 (most recent years 

prior to regulations that may have impacted 

landings). Note: if 17% of the total allowable 

landings (TAL) was less than 10.5 million lb, 

then the quota could be increased up to 10.5 

million lb if the recreational sector was 

projected to land less than 83% of the TAL 

for the upcoming year. The transfer 

stipulation is intended to provide higher 

commercial fishing opportunities when 

possible.

Atlantic 

mackerel, 

squid, and 

butterfish 

fisheries

Amendment 11 

(proposed) 

Atlantic mackerel 93.8:6.2 Y/NE Amendment 11 will designate an allocation 

for the recreational mackerel fishery that 

would form the basis of ACL/AM measures 

in the future. The recreational fishery would 

be allocated the percentage of the ABC that 

corresponds to the proportion of total U.S. 

landings that was accounted for by the 

recreational fishery from 1997 to 2007 from 

MRFSS database times 1.5. Percentage 

would be 6.2%, which translates to an 

allocation of 9,672 mt under the current ABC 

(6.2% of 156,000 = 9,672), and an allocation 

of 2,938 mt under the council’s 

recommended 2011 mackerel ABC (47,395 

mt).
30 

Table 9 continued. Commercial and recreational allocations.

Fisheries 

Management 

Plan Regulation Fishery

Allocation ratio 

(commercial % to 

recreational %) Categorya/Noteb Basis for allocation

Summer 

flounder, scup, 

and black 

seabass 

fisheries

Amendment 2 

(1993) 

Summer flounder 60:40 Y/B Average catch 1980–1989. The time period 

for allocation purposes was bounded by 

reliable recreational landings data availability 

(1980) and before stock and landings 

declined to lowest historical levels (1990). 

The states deemed the years used for 

allocation purposes fair and equitable.

Amendment 8 

(1996) 

Scup 78:22 Y/B Average catch 1988–1992. Years prior to 

1988 were not used because of problems with 

the data, while changes in regulations in early 

1993 suggested not using that year’s data.

Amendment 9 

(1996) 

Black seabass 49:51 Y/B Average catch 1983–1992. Years prior to 

1983 were not used because of problems with 

the data, while changes in regulations in early 

1993 suggested not using that year’s data.

New England Fishery Management Council

Northeast 

multispecies 

fishery

Amendment 16 

(2010) 

Gulf of Maine cod 66.3:33.7 Y/SQ Catch from 2001–2006. The allocations were 

set in order to maintain the (then) current 

catch ratios, which the council said would not 

unduly burden either sector. The allocations 

were also based on the recommendation of 

the recreational advisory council and 

assessments by the Groundfish Assessment 

Review Meeting. Framework 44 specified 

the amounts of harvest based on this ratio for 

the years 2010–2012.

Gulf of Maine haddock 72.5:27.5 Y/SQ

NMFS Highly Migratory Species Division

Atlantic highly 

migratory 

species

FMP (1999) Bluefin tuna ≈80:20 Unk FMP assigns 19.7% and 77.8% of allocation 

to recreational and commercial fishing, 

respectively. This leaves 2.5% in reserve that 

can be transferred to any category if needed.
31 

Table 9 continued. Commercial and recreational allocations.

Fisheries 

Management 

Plan Regulation Fishery

Allocation ratio 

(commercial % to 

recreational %) Categorya/Noteb Basis for allocation

Pacific Fishery Management Council

Pacific coast 

groundfish

Ongoing Pacific coast groundfish Determined 

biennially

Unk Determined biennially.

West Coast 

salmon

1984 

framework 

adjustment 

Chinook (N of Cape 

Falcon)

Varies with TAC 

(allocation method 

was later changed)

Y/B Allocation was based on historic catch 

between 1971–1975. This time period was 

selected because it is the base period used for 

comparisons in the previous FMP analyses 

and it avoids the impacts of the change in the 

sport (1976) and troll (1977) Chinook size 

limits.

Coho (N of Cape Falcon) Varies with TAC 

(allocation method 

was later changed)

Unk Cannot determine how this allocation was 

calculated. The allocation gives more fish to 

commercial than allocation based on historic 

catch between 1966 and 1978.

Coho (S of Cape Falcon) Varies with TAC 

(allocation method 

was later changed)

Y/B Allocation was based on historic catch 

between 1966 and 1978 for TAC > 700,000. 

Below 700,000 allocations deviate from 

historical catch. This time period was chosen 

because it was prior to the period of increased 

regulation which altered historic patterns. It 

also encompasses the period of increased 

effort and significant contribution of hatchery 

fish to the catch.

Amendment 7 

(1986) 

Coho (S of Cape Falcon) Varies with TAC N/SR Determined by group composed of 

commercial and recreational fishermen. 

Change needed to “provide a more stable 

recreational season.”

Amendment 9 

(1988) 

Chinook (N of Cape 

Falcon)

Varies with TAC N/SR Working group from council’s SAS created 

the alternatives. Council’s emphasis was on

increasing the stability of the recreational 

fishery.
32 

Table 9 continued. Commercial and recreational allocations.

Fisheries 

Management 

Plan Regulation Fishery

Allocation ratio 

(commercial % to 

recreational %) Categorya/Noteb Basis for allocation

West Coast 

salmon

continued 

Coho (N of Cape Falcon) Varies with TAC N/SR Working group from council’s SAS created 

the alternatives. Council’s emphasis was on 

increasing the stability of the recreational 

fishery.

South Atlantic Fishery Management Council

Dolphin and 

wahoo 

FMP (2004) Dolphin and wahoo 13:87 but nonbinding Y/M Based on average 1994–1997 catch. This 

period accurately captured the relatively 

recent commercial participation in the fishery 

and addressed the goals and objectives of the 

FMP. Cap on commercial fishery at 13% 

was non-binding.

Snappergrouper fishery 

of the south 

Atlantic region

Amendment 

13C (2006) 

Black seabass 43:57 Y/SQ Allocations (as pounds) were provided with a 

3-year step down. All 3 years contained 

same 43%:57% split. Discussion mentions 

decreasing commercial and recreational catch 

equally (35% by year 3 based on 2001–2003 

and 2000–2003 for commercial and 

recreational, respectively). Year 1 represents 

current catch.

Amendment 

15B (2009) 

Red porgy 50:50 Y/SQ The alternative chosen was closest to status 

quo (1999–2003 landings were 49%:51%). 

Council mentioned that the TAC may have to 

be adjusted if commercial were allocated > 

50% (due to higher discard mortality in 

commercial versus recreational).

Snowy grouper 95:5 Y/L Historical landings 1986–2005 (longest time 

series available). Shorter time frames were 

not utilized because unrealistic spikes in 

recreational landings overly influenced the 

results.
33 

Table 9 continued. Commercial and recreational allocations.

Fisheries 

Management 

Plan Regulation Fishery

Allocation ratio 

(commercial % to 

recreational %) Categorya/Noteb Basis for allocation

Snappergrouper fishery 

of the south 

Atlantic region

continued 

Amendment 16 

(2009) 

Gag grouper 51:49 Y/SQ Allocation was based on landings from 1999 

to 2003. This time period was chosen 

because it reflects recent catch. In addition, 

reductions are equal (35% and 37% for 

commercial and recreational, respectively).

Vermillion snapper 68:32 Y/L Historical landings 1986–2005 (longest time 

series available). Council noted that results 

did not change much if different time frames 

were analyzed.

Amendment 

17B (2010) 

Combined red, black, gag 

grouper 

50.5:49.5 N/C Commercial and recreational catch limits 

provided (in pounds), but no allocation listed. 

Catch limits equate to allocation of 

50.5%:49.5%. Pounds are expected catch 

resulting from implementing amendment 16.

Golden tilefish 97:3 Y/SQ Based on formula sector allocation = (0.5 × 

average catch 1986–2008) + (0.5 × average 

catch 2006–2008). Allocation would mirror 

historic harvest. Allocation of 50%:50% was 

also considered, but would adversely impact 

commercial and provide limits above what 

could be caught recreational. a

Category:

N = not based on catch history, 

Unk = unknown how allocation was decided, and 

Y = based on catch history. 

b

Note:

B = based on time before regulations impacted catch, 

C = based on expected catch, 

L = based on longest time period, 

M = met objectives of fishery,

NE = based on a time period but no explanation provided as to why those were years chosen, 

R = based on most recent time period, 

RE = removed allocations, 

SQ = retain current allocations (status quo), and

SR = increased stability of recreational fishery.
34

For most of the regulations, the rationale for the final decision was similar across all 

stocks within that regulation. For six regulations, however, the reason behind the allocation 

decision differed for the different stocks covered in the regulation. Therefore, we consider each 

part of these regulations as a different allocation decision, creating in total 32 such decisions. As 

mentioned, one decision removed an allocation, so is not considered further here. In five cases, 

we were unable to determine the rationale behind the allocation decision.

Of the 26 remaining decisions, most (23) created allocations that matched historical or 

current catch ratios. Only three amendments provided a different rationale. Amendment 7 and 

Amendment 9 to the Pacific Salmon FMP provide allocations that were designed to provide 

more stability to the recreational fishery. The allocation (in pounds) of the combined catch of 

red, black, and gag grouper (Amendment 17B to the South Atlantic Snapper Grouper FMP) was 

created to match the expected catch resulting from management measures implemented in 

Amendment 16.

The 23 allocation decisions that were based on historical or current catch can be further 

divided into 5 categories: 8 created allocations that match the status quo (retain current 

allocations), 6 were based on the catch ratios averaged across the longest (5 decisions) or most 

recent time period (1 decision) with commercial and recreational catch data available, 6 were 

based on historical catch ratios before the implementation of regulations that would impact catch,

1 was based on the years that best met the objectives of the fishery, and 2 were based on a 

specific historical catch ratio but with no explanation of why that time period was utilized.

Only seven fish stocks had an official change in allocation through time (five from the 

Gulf of Mexico and two on the West Coast). As mentioned, Gulf of Mexico vermilion snapper 

had its official allocation removed. Of the other six fish stocks, four contained changes that 

increased the allocation to the recreational fishermen. Only one increased the allocation to 

commercial fishermen at the expense of recreational fishermen. The final allocation was first 

modified to increase the recreational allocation, followed by a later amendment to lower 

recreational allocation.

The allocations of West Coast coho salmon (Oncorhynchus kisutch) and Chinook salmon

(O. tshawytscha) have been modified (Amendment 7 and Amendment 9 to the Pacific Salmon 

FMP) to increase the allocations to recreational fishermen. For both of these stocks, a working 

group composed of both commercial and recreational fishermen was formed to determine the 

best allocation. Both groups agreed to increase the recreational allocation in order to provide a 

more stable recreational season. When the Gulf of Mexico Fishery Management Council was 

forced to reduce catch on greater amberjack (Seriola dumerili) (Amendment 30A of the Reef 

Fish FMP), it chose to reduce recreational landings proportionally less than commercial landings 

(increasing the recreational percent allocation), because of perceived inequities in the effects of 

previous management decisions. Red grouper was initially allocated in a 2004 secretarial 

amendment that applied the same percent reduction to commercial and recreational fishermen 

and subsequently maintained the status quo. Five years later, Amendment 30B created an 

interim allocation based on 20 years of historical catch, increasing the recreational allocation 

from 19% to 24%. The Gulf of Mexico Fishery Management Council created a committee to 

examine future allocation decisions.
35

The final two fisheries with a change in allocation through time include king mackerel 

(Scomberomorus cavalla) and Spanish mackerel (S. maculatus), both managed within the 

Coastal Migratory Pelagics FMP. In the original FMP, king mackerel was considered one stock 

across the south Atlantic and Gulf of Mexico. Allocations were provided (in pounds), but we 

could find no information detailing how these numbers were determined. Amendment 1 to the 

FMP split king mackerel into gulf and Atlantic stocks and revised allocations with an increased 

share to commercial (decreased allocation to recreational) for both stocks. The allocation 

decision for the gulf stock was based on historical catch, but no information was found on how 

the allocation for the Atlantic stock was determined.

The allocation for the Atlantic stock of Spanish mackerel has been changed twice. The 

original allocation (76%:24%) was created in 1987 and based on the most recent time period 

with catch data (1979–1985). In 1989 the council determined that 1979–1985 represented a time 

period when the resources were overfished and recreational participation was low. The 

allocation was therefore adjusted to match the limited data available from the 1970s, creating a 

50:50 split between commercial and recreational fisheries. Finally in 1999 in response to 

reductions in total catch, the allocation was adjusted (55%:45%) to retain commercial catch at 

levels close to the 1998 catch. This adjustment moved the allocation that was currently not being 

used by the recreational fishermen to commercial fishermen.

4.2. Analyses of FMP Allocations (Examples)

Using the set of allocation decisions listed in Table 9, we searched the documentation 

pertaining to a specific amendment or other regulatory action for some form of analysis in 

support of the decision. In most cases, we found information that we could characterize as an 

analysis in the biological, economic, social, and administrative effects sections of the regulatory 

document (such as the FMP and its amendments) that contained the allocation action or some 

other type of council document. Occasionally we found a reference to an analysis in an 

appendix, but in general the economic piece of the effects section indicated that the available 

data were insufficient for analysis. The economics sections are usually brief and we therefore 

have included excerpts of these sections in Appendix B.

In general, the regulatory documentation provides few formal considerations of 

efficiency or fairness and few examples of a quantitative analysis of efficiency. As noted in 

subsection 4.1, most allocation decisions we documented have been based on historical catch 

levels rather than on an explicit analysis of efficiency or fairness. Still, we found 10 examples of 

a quantitative analysis covering some aspect of the allocation decision, most of which we have 

excerpted below. In these cases, although analyses were often performed using measures such as 

net present value for the commercial allocation alternatives and consumer and producer surplus 

for the recreational allocation alternatives, we found no occasion where the two separate analyses 

were brought together to provide a recommendation for the most efficient allocation.
36

Table 10 lists the analyses we found and tabulates various characteristics of the analyses 

(if any) that support each decision covered in subsection 4.2. In each case, we considered the 

following:

• Was an analysis included as a separate document?

• Was an analysis conducted of all the alternatives considered in the regulatory action?

• Was a quantitative analysis performed?

• Did the regulatory action explicitly use the analysis in the decision for selecting a 

preferred alternative?

• Was poor data availability cited as reason for incomplete analysis?

4.3. FMP Allocations in the Context of FMP Objectives

Under the MSA, fishery management councils establish management objectives as part of 

the process of developing a FMP (50 CFR Ch. VI, §600.325(b)). The process of establishing 

these objectives should “balance biological constraints with human needs, reconcile present and 

future costs and benefits, and integrate the diversity of public and private interests” (50 CFR Ch. 

VI, §600.325(b)(1)). The objectives are used as a context with which to “judge the consistency 

of an FMP’s conservation and management measures with the national standards” (50 CFR Ch. 

VI, §600.325(b)(2)).

A few of the FMPs have an objective that covers commercial and recreational sectors (in 

the same objective), but almost always in the context of reducing or minimizing potential 

conflicts between the two sectors. Nearly all FMPs contain at least one objective that covers one 

sector or the other separately, and most contain one or more objectives that address efficiency 

(usually in terms of optimizing or maximizing economic or other values) or fairness.

In Table 11 we list the management objectives that have the characteristics described 

above. In Appendix C we list the management objectives for the 11 FMPs for which we have 

documented allocation decisions.
37 

Table 10. Commercial and recreational allocation analyses.

Fisheries 

Management 

Plan Regulation Fishery

Analysis 

included as a 

separate 

document

Analysis of all 

alternatives

Quantitative 

analysis 

performed

Explicit use 

of analysis in 

decision

Poor data 

availability 

cited as reason 

for incomplete 

analysis

Gulf of Mexico Fishery Management Council

Gulf of Mexico 

reef fish resources

Amendment 1 

(1990) 

Greater amberjack, gray 

snapper, groupers in 

aggregate, jewfish, lane 

snapper, mutton snapper, red 

snapper, sea basses, snappers 

in aggregate, vermillion 

snapper, yellowtail snapper

NFa Yb NF NF NF

NF Y NF NF NF

NF Y NF NF NF

Secretarial 

amendment 1 

(2004)

Red grouper NF NF NF NF NF

Amendment 23 

(2004)

Vermillion snapper NF Y NF NF NF

Amendment 30A 

(2008)

Gray trigger and greater 

amberjackc NF NF NF NF NF

Amendment 30B 

(2009) 

Gag grouper and red grouper NF NF Y NF NF

Gulf of Mexico Fishery Management Council and South Atlantic Fishery Management Council

Coastal migratory 

pelagic resources 

of the Gulf of 

Mexico and south 

Atlantic

Amendment 1 

(1985)

King mackerel, Atlantic 

group

NF NF Y NF Y

Amendment 1 

(1985)

King mackerel, Gulf group NF NF Y NF Y

Amendment 2 

(1987)

Spanish mackerel, Atlantic 

and Gulf groups

NF Y Y NF NF

Amendment 4 

(1989)

Spanish mackerel, Atlantic 

group

NF NF NF NF Y

Catch specifications (1999) Spanish mackerel, Atlantic 

group 

NF NF NF NF NF
38 

Table 10 continued. Commercial and recreational allocation analyses.

Fisheries 

Management 

Plan Regulation Fishery

Analysis 

included as a 

separate 

document

Analysis of all 

alternatives

Quantitative 

analysis 

performed

Explicit use 

of analysis in 

decision

Poor data 

availability 

cited as reason 

for incomplete 

analysis

Mid-Atlantic Fishery Management Council

Atlantic bluefish Amendment 1 

(2000)

Bluefish NF NF NF NF NF

Atlantic mackerel, 

squid, and 

butterfish fisheries

Amendment 11 

(2010) 

Atlantic mackerel NF NF NF NF Y

Summer flounder, 

scup, and black 

seabass fisheries

Amendment 2 

(1993)

Summer flounder NF NF NF NF NF

Amendment 8 

(1996)

Scup NF NF NF NF NF

Amendment 9 

(1996) 

Black seabass NF NF NF NF NF

New England Fishery Management Council

Northeast 

multispecies 

fishery

Amendment 16 

(2010) 

Gulf of Maine cod and 

haddock 

NF Y NF NF Y

NMFS Highly Migratory Species Division

Atlantic highly 

migratory species

FMP (1999) Bluefin tuna NF Y Y NF NF

Pacific Fishery Management Council

Pacific coast 

groundfish 

Biennial decision Pacific coast groundfish Section 6.2.3 of the Pacific Coast Groundfish FMP (nonbiological issues—the 

socioeconomic framework) describes the types of analyses that are expected to 

support a management action that addresses allocation decisions.

West Coast 

salmon

1984 framework 

adjustment 

Chinook (N of Cape Falcon), 

coho (N and S of Cape 

Falcon)

NF Y NF NF NF

Amendment 7 

(1986)

Coho (S of Cape Falcon) NF Y NF NF NF

Amendment 9 

(1988)

Chinook and coho (N of Cape 

Falcon)

NF Y Y Y NF
39 

Table 10 continued. Commercial and recreational allocation analyses.

Fisheries 

Management 

Plan Regulation Fishery

Analysis 

included as a 

separate 

document

Analysis of all 

alternatives

Quantitative 

analysis 

performed

Explicit use 

of analysis in 

decision

Poor data 

availability 

cited as reason 

for incomplete 

analysis

South Atlantic Fishery Management Council

Dolphin and 

wahoo

FMP (2004) Dolphin and wahoo NF NF NF NF NF

South Atlantic 

region snappergrouper fishery

Amendment 13C 

(2006)

Black seabass Y Y Y NF Y

Amendment 15B 

(2009)

Red porgy and snowy grouper Y Y Y NF Y

Amendment 16 

(2009)

Gag grouper and vermillion 

snapper

Y Y Y NF Y

Amendment 17B 

(2010)

Combined red, black, gag 

grouper, and golden tilefish

Y Y Y NF Y

a NF = not found.

b Y = yes.

c Council removed the actions that addressed allocations for greater amberjack and gray triggerfish.
40

Table 11. FMP management objectives that reference commercial or recreational sectors, efficiency, or 

fairness.

FMP Management objectives

Gulf of Mexico Fishery Management Council

Gulf of Mexico 

reef fish 

resources 

(GMFMC 2004)

Management Objective (FMP/amendment)

4. Minimize conflicts between user groups of the resource and conflicts for space 

(original FMP).

6. Reduce user conflicts and nearshore fishing mortality (modified Objective 4) 

(Amendment 1).

11. Maximize net economic benefits from the reef fish fishery (Amendment 1).

15. Optimize net benefits to the fishery (modified Objective 11) (Amendment 8).

Gulf of Mexico Fishery Management Council and South Atlantic Fishery Management Council

Coastal migratory 

pelagic resources 

of the Gulf of 

Mexico and south 

Atlantic

(GMFMC 1992)

The current FMP through Amendment 5 lists 7 plan objectives:

4. Minimize gear and user group conflicts.

5. Distribute the TAC of Atlantic migratory group Spanish mackerel between 

recreational and commercial user groups based on the catches that occurred during 

the early to mid 1970s, which is prior to the development of the deep water runaround gill net fishery and when the resource was not overfished.

8. Optimize social and economic benefits of the coastal migratory pelagic fisheries.

Mid-Atlantic Fishery Management Council

Atlantic 

mackerel, squid, 

and butterfish 

fisheries

(MAFMC 2010)

2. Promote growth of the U.S. commercial fishery, including the fishery for export.

4. Provide marine recreational fishing opportunities, recognizing the contribution of 

recreational fishing to the national economy.

6. Minimize harvesting conflicts among U.S. commercial, U.S. recreational, and 

foreign fishermen.

New England Fishery Management Council

Northeast multispecies fishery 

(Amendment 16) 

(NEFMC 2009)

Goal 2: Create a management system so that fleet capacity will be commensurate 

with resource status so as to achieve goals of economic efficiency and biological 

conservation and that encourages diversity within the fishery.

Goal 3: Maintain a directed commercial and recreational fishery for northeast 

multispecies.

Goal 5: Provide reasonable and regulated access to the groundfish species covered 

in this plan to all members of the U.S. public for seafood consumption and 

recreational purposes during the stock rebuilding period without compromising the 

Amendment 13 objectives or timetable. If necessary, management measures could 

be modified in the future to insure that the overall plan objectives are met.

NMFS Highly Migratory Species Division

Atlantic highly 

migratory species

(NMFS 1999)

Consistent with other objectives of this FMP, manage Atlantic HMS fisheries for 

continuing optimum yield to provide the greatest overall benefit to the nation, particularly with respect to food production, preserving traditional fisheries, providing 

recreational opportunities, and taking into account marine ecosystem protection.

Pacific Fishery Management Council

Pacific coast 

groundfish

(PFMC 2008)

Goal 2: Economics. Maximize the value of the groundfish resource as a whole.

Objective 6. Within the constraints of the conservation goals and objectives of the 

FMP, attempt to achieve the greatest possible net economic benefit to the nation 

from the managed fisheries.

Objective 12. When conservation actions are necessary to protect a stock or stock 

assemblage, attempt to develop management resources that will affect users 

equitably.
41

Table 11 continued. FMP management objectives that reference commercial or recreational sectors, 

efficiency, or fairness.

FMP Management objectives

Pacific Fishery Management Council (continued)

West Coast 

salmon (PFMC 

2003)

1. Establish ocean exploitation rates for commercial and recreational salmon 

fisheries that are consistent with requirements for stock conservation objectives 

within Section 3.1, specified ESA consultation or recovery standards, or council 

adopted rebuilding plans.

3. Seek to maintain ocean salmon fishing seasons which support the continuance of 

established recreational and commercial fisheries while meeting salmon harvest 

allocation objectives among ocean and inside recreational and commercial fisheries 

that are fair and equitable, and in which fishing interests shall equitably share the 

obligations of fulfilling any treaty or other legal requirements for harvest 

opportunities. Note: In its effort to maintain the continuance of established ocean 

fisheries, the council includes consideration of maintaining established fishing 

communities. In addition, a significant factor in the council’s allocation objectives 

in Section 5.3 is aimed at preserving the economic viability of local ports or specific 

coastal communities (e.g., recreational port allocations north of Cape Falcon).

South Atlantic Fishery Management Council

Dolphin and 

wahoo (SAFMC 

2003)

The overall goal of the fishery management plan for the South Atlantic, MidAtlantic, and New England councils’ areas of jurisdiction is to adopt a precautionary 

and risk-averse approach to management which in the first instance attempts to 

maintain the status quo. This will require that current catch levels not be exceeded 

and that recent conflict between sectors of the fishery (commercial longliners and 

recreational fishermen) be resolved. Status quo should reflect trends (average catch 

and effort levels) in the fishery over the last five years 1993 through 1997.

Owing to the significant importance of the dolphin/wahoo fishery to the recreational 

fishing community in the Atlantic, the goal of this fishery management plan is to 

maintain the current harvest level of dolphin and insure that no new fisheries 

develop. With the potential for effort shifts in the historical longline fisheries for 

sharks, tunas, and swordfish, these shifts or expansions into nearshore coastal waters 

to target dolphin could compromise the current allocation of the dolphin resource 

between recreational and commercial user groups. Further, these shifts in effort in 

the commercial fishery, dependent on the magnitude (knowing that some dolphin 

trips may land more than 25,000 pounds in a single trip) could result in user conflict 

and localized depletion in abundance.

Objectives identified by the councils and addressed by this fishery management plan 

are as follows:

3. Minimize conflict or competition between recreational and commercial user 

groups. If commercial longlining effort increases, either directing on dolphin and 

wahoo or targeting these species as a significant bycatch, conflict or competition 

may arise if effort shifts to areas traditionally used by recreational fishermen.

4. Optimize the social and economic benefits of the dolphin and wahoo fishery. 

Given the significant importance of dolphin and wahoo to the recreational sector 

throughout the range of these species and management unit, manage the resources to 

achieve optimum yield on a continuing basis.
42

5. Conclusions

Allocation decisions invoke considerations of both efficiency and fairness. While the 

effects of a decision can be documented in ways that inform each of these issues, the former is 

more easily analyzed in principle than the latter, at least in terms of widely accepted and formal 

frameworks. What is easy in principle is far more difficult in practice, however, as the data 

needed to analyze efficiency are extensive and costly to gather.

Still, even without the necessary data, the equimarginal principle, which is at the heart of 

an efficiency analysis, can provide some insights into establishing an efficient allocation and 

considering how that allocation might change in light of changing conditions in a fishery. 

Fairness is more difficult to analyze formally, of course, but the close connection between the 

distribution of policy effects and the fairness of a policy suggest some ways of gathering 

information that can inform an allocation decision on this issue as well. At the very least, 

assessing historical patterns of harvest can be viewed as one way of assessing the distributional 

effects of harvest restrictions and allocations.

As noted, this technical memorandum offers no recommendations regarding the practice 

of making an allocation decision under the MSA or analyzing such a decision. Instead, our 

discussion of the principles of efficiency and fairness, as well as the many other documents and 

articles that have similar discussions including those listed in Appendix D, Bibliography of 

Additional Sources, can be viewed as resources for future considerations of fishery harvest 

allocations. Similarly, the compilation of FMP allocations and analyses provides a useful 

documentation of past and current practices, which can provide a basis for assessing the 

desirability of any potential changes in these practices or the need for broader data gathering or 

research to support future decisions.
43

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49

Appendix A: The Formal Analysis of 

Allocative Efficiency

The problem of efficiently allocating a fixed amount of harvest, H, can be expressed as a 

constrained maximization problem. In this appendix, we explore this problem with a more 

formal framework than the one presented in the text. We first lay out the formal problem of 

allocating harvest. We then consider how the solution to this initial problem is affected by 

changes in the underlying conditions that produced that solution. Finally, we illustrate how an 

initial allocation that is inefficient affects the problem of efficiently allocating an increase in the 

allowable harvest.

The Efficient Allocation of Allowable Harvest

A decision maker allocates H with the objective of maximizing the social value, V(H), of 

the harvest. The allocation is across n possible harvesters, with hi the amount allocated to the i

th

harvester, and Vi(hi) the value placed on that amount by that harvester. We assume that 

/ 0 i V hi ∂ ∂> and 2 2 / 0 i Vh i i ∂ ∂<∀ . Because we treat each harvester as equal, we have 

( ) ( )

1

n

i

i

i

VH V h == ∑ , where

1

n

i

i

h H

=

∑ = . (Alternatively, we could address the issue of fairness by 

assigning individual weights, wi, to each harvester or including a measure of dispersion as a 

direct argument in the social value function.) The problem is then one of choosing an allocation, 

{hi}, to maximize V(H).

Formally, the constrained maximization can be expressed thusly:

{ } 1 1

max ( ) ( ) . . i

n n

i

i i h i i

V H V h st h H = == ∑ ∑ = (1)

This problem can be solved by using a Lagrange multiplier framework, standard for problems in 

microeconomics and mathematical optimization.16 The Lagrangian, L, for this problem is

( )

1 1

( )

n n

i

i i

i i

Vh H h λ = = = +− ∑ ∑

(2)

where λ is the Lagrange multiplier associated with the harvest constraint in equation 1.

The solution to equation 1 is derived by solving the following system of equations, which 

constitute the first order conditions for a maximum:

 16 Silberberg and Suen (2001), p. 128−150, provide an introduction to the use of this framework in microeconomics.
50

0

i

i i

V i

h h

λ ∂ ∂ = −= ∀

∂ ∂



(3)

1

0

n

i

i

H h

λ =

∂ =− = ∂ ∑  (4)

The sufficient second-order conditions for a maximum are met if the second derivatives 

of the Lagrangian satisfy certain conditions on their signs. In this case, the additively separable 

form of the value function, V(H), and the assumption that 2 2 / 0 i Vh i i ∂ ∂<∀ assure that these 

conditions are met.

The system of equation 3 and equation 4 can be solved in principle to give the optimal

harvest allocations, {hi*}. This allocation depends on factors that affect the individual harvest 

value functions as well as the total harvest, H. Thus the optimal individual allocations can be 

expressed as a function of these factors, or hi* = hi*(αi

,H), where αiis a vector of factors that 

affect the i

th sector’s harvest value, Vi

(hi), or Vi(hi, αi).

Equation 3 can be used to derive the equimarginal principle:

, i j MV MV i j = = ∀ λ (5)

where / i i MV V h =∂ ∂ i . This corresponds to the condition described above, where the efficient 

allocation equates the marginal value of harvest across all sectors.

Changes in the Efficient Allocation

We can use this framework to illustrate how a reallocation of harvest can be analyzed 

should the circumstances that supported the original (efficient) allocation change. First, consider 

a factor, α

i

j ∈ αi

, that affects an individual’s value function, where we assume that / 0 i i V α j ∂ ∂> , 

/ 0 i i MV α j ∂ ∂> , and / 0 k i MV j ∂ ∂ = ∀≠ α k i (the last assumption is that α

i

j affects the value of 

the i

th individual harvester only. It is then straightforward to show that 

*

0 i

i

j

h

α

∂

>

∂ (6)

*

0 k

i

j

h k i

α

∂ < ∀≠

∂ (7)

Because H is fixed, this translates into a larger percentage share for sector i and a smaller 

percentage share for other sectors.

Similarly, it can be shown that
51

*

0 i h i

H

∂ > ∀

∂ (8)

*

0

H

∂λ

<

∂ (9)

This implies that an increase in the allowable harvest should be allocated to all sectors (assuming 

the initial allocation was efficient). To see how individual shares of the allowable harvest 

change in percentage terms, substitute hi* and λ* into equation 3 and rearrange to get the identity

( ( )) ( ) i * * MV h H H i ≡ λ (10)

Now differentiate both sides with respect to H and rearrange to get

* *

i

i

i

h H

H MV h

∂ ∂∂ λ = ∂∂ ∂ (11)

Note that *

i ∂ ∂ h H , or the rate at which the additional harvest allocated to sector i changes with 

respect to a change in H, is negatively related to / i MV hi ∂ ∂ , or the absolute value of the slope 

of the marginal value curve for sector i.

Reallocation when the Initial Allocation is Inefficient

Finally, consider the case where an existing allocation was made in a way that produces a 

set of inefficient shares. If the allowable catch limit (ACL) is increased, say, as the result of a 

rebuilding effort, one approach would be to consider the allocation problem anew and simply 

create an efficient set of harvest allocations without regard to the previous set. This could result 

in a decreased allocation for some sectors, however, so we consider the case where the initial set 

of allocations acts as a constraint on the reallocation. In essence, we use a strict Pareto 

improvement standard in that we examine allocations of the additional ACL that make at least 

one sector better off and no sector worse off.

For this case, start with the initial ACL, H0, and the initial (inefficient) allocation, {hi

0

}, 

where 0

0

1

n

i

i

h H

=

∑ = . Now suppose an increase in allowable harvest is proposed from H0 to H1. 

How should this increase be distributed if efficiency is the goal but the strict Pareto improvement 

standard acts as a constraint? In such a case, the allocation problem becomes

0

1 { } 1 1

max ( ) ( ) . . and i

n n

i

i i i i h i i

V H V h st h H h h i = == ∑ ∑ = ≥∀

(12)

Because the initial allocation, {hi

0

}, was not efficient, the equimarginal principle, which 

is the condition for a maximum in equation 3, will not in general be met for initial allocation, so 

that
52

( ) ( ) i j 0 0 MV h MV h i j ≠ (13)

Assuming that such an equality does not exist by happenstance, the index of n sectors can 

be ordered by the marginal value of the sector’s current allocation so that sector 1 has the highest 

MV and sector n has the lowest MV, or

( ) ( ) ( ) ( ) 10 20 1 0 0

1 2 1

n n MV h MV h MV h MV h n n

− > >> >  − (14)

Note that this ordering provides a guide to a pattern of underallocation and overallocation 

of the initial ACL. For some m in the index set, we have

( ) ( ) ( ) ( ) 1 0 0 * 10 0

1 1

mm n MV h MV h MV h MV h m mn λ + >> > > >>   + (15)

where λ* is the value associated with the efficient allocation of H0 from equation 5. Because

/ 0 i MV hi ∂ ∂< , this sequence implies that hj

0 < hj* (underallocation) for j ≤ m, and hk0 > hk*

(overallocation) for k > m.

The order established in equation 15 also acts as a guide to the distribution of any 

increase in the ACL. The condition

( ) ( ) 1 0 0

1 , 1 i MV h MV h i > > i (16)

implies that it is efficient to allocate at least some of the additional ACL, ∆ACL, to sector 1, and 

that it may be efficient to allocate all of ∆ACL to that sector. To see this, consider what happens 

if all of ∆ACL is given to sector 1. If the inequality in equation 16 still holds at h1 = h1

0 + 

ΔACL, then that allocation is efficient.

For what levels of ∆ACL is it efficient to allocate additional harvest to other sectors? 

Suppose ∆ACL = ∆ACL2 is just large enough to make MV1(h1

0 + ΔACL2) = MV2

(h2

0

). Any 

∆ACL ≥ ∆ACL2 means that some of the additional harvest should also be allocated to sector 2, 

otherwise MV1

(h1

0 + ΔACL) would fall below MV2

(h2

0

) and transferring harvest from sector 1 to 

sector 2 would increase the value of the total harvest.

For ∆ACL ≥ ∆ACL2, then, the standard efficiency framework can be applied to these two 

sectors alone, in terms of allocating the additional harvest, ∆ACL:

1 2

0 0

11 1 2 2 2 1 2 ,

max ( ) ( ) . .

h h

V V h h V h h s t ACL h h

∆ ∆

= +∆ + +∆ ∆ =∆ +∆

(17)

Let {∆hi

(2)} be the solutions to this maximization problem, where the superscript “2” 

indicates that the maximization takes place over two sectors, and let hi

(2) = hi0 + ∆hi(2) be the 

optimal total harvest allocation in each of the two sector that receives additional harvest.
53

As higher levels of ∆ACL are considered, the pattern of expanding the set of sectors that 

receive additional harvest allocations can be derived inductively, following the order established 

in equation 15. Suppose ∆ACL = ∆ACL3 is just large enough to make

1 0 (2) 2 0 (2) 3 0

11 3 22 3 3 MV h h ACL MV h h ACL MV h ( ( )) ( ( )) ( ) +∆ ∆ = +∆ ∆ = (18)

For ∆ACL ≥ ∆ACL3, some of the additional ACL should then also go to sector 3, and the 

maximization problem in equation 17 expands to cover the third sector.

Eventually, as higher levels of the additional allowable harvest are considered, the 

maximization problem will eventually encompass all n sectors. Let ∆ACL = ∆ACLn be the 

additional harvest needed to achieve the following set of equalities:

1 0 ( 1) 1 0 ( 1) 0

1 1 1 1 ( ( )) ( ( )) ( ) n nn n MV h h ACL MV h h ACL MV h n nn n n

− − − +∆ ∆ = = +∆ ∆ =  − − (19)

Then for ∆ACL ≥ ∆ACLn, all n sectors receive at least some of the additional harvest. This is 

because the initial set of allocations no longer constrains the choice of an efficient allocation for 

the new, total ACL. In that case, the efficient set of allocations is identical to that produced by 

solving equation 3 and equation 4 without any initial allocation constraints.

Figure A-1 through Figure A-4 present an example for the simple case of two sectors. 

Initially, the ACL = 250, which is distributed equally across Sector A and Sector B (Figure A-1). 

This equal allocation is inefficient because MVB

(125) > MVA(125), so Sector B has an 

underallocation and Sector A has an overallocation. Now suppose a rebuilding effort enables the 

ACL to be increased by 25 units. If the initial allocations are treated as a constraint, allocating 

all of the additional 25 units to Sector B is the most efficient action, because MVB(150) > 

MVA(125) (Figure A-2). If ∆ACL is at least 75 units, then it becomes efficient to allocate some 

of the additional harvest to both sectors because MVB

(125 + 75) = MVA(125), thus using the 

terminology above, ∆ACL2 = 75 (Figure A-3). If ∆ACL is deemed higher than 75 units, both 

sectors receive a share and the new allocation will satisfy the equimarginal principle (Figure 

A-4).

In the case of an initial (inefficient) allocation that acts as a constraint, then the allocation 

of an increase in the ACL can vary dramatically from the allocation that occurs when it takes 

place de novo (Table A-1). If the initial ACL of 250 units had been allocated efficiently, the 

allocation ratio would be 30%:70%. For higher levels of the ACL, the ratio would continuously 

shift in favor of Sector A because MVA falls less rapidly than MVB, reaching 41%:59% for an 

ACL of 350 units. If the initial ACL had been allocated equally (and inefficiently) and this 

distribution was deemed a constraint on future allocations, the allocation ratio would move in the 

opposite direction. From an initial allocation of 50%:50%, Sector B would receive 100% of any 

increase in the ACL, pushing the ratio to 45%:55% for an ACL of 275 and 42%:58% for an ACL 

of 300. At an ACL of 325, allocating 100% of the increase to Sector B would in fact achieve an 

overall efficient allocation of 38%:52% (Table A-1). Beyond this point, the allocation of the 

increase in the ACL returns to the pattern established by the overall efficient allocation, and 

Sector A would receive higher shares (Table A-1).
54

Figure A-1. If an ACL is allocated without regard to efficiency, the marginal value of harvest across 

sectors will likely not be equal. If an ACL is allocated equally across these two sectors, the 

marginal value of Sector B’s harvest is higher than the marginal value of Sector A’s harvest.

0

100

200

300

400

500

600

700

0 25 50 75 100 125 150 175 200 225 250 275 300 325

Marginal value ($)

Sector allocation (250 units)

Sector A

Sector B

MVB(hB

0) = $375

MVA(hA

0) = $225
55 

Figure A-2. If the initial allocations act as a constraint on efficient allocations of any increase in the ACL, 

these additional allocations may involve granting 100% of the increase to one sector. In this case, 

an increase of 25 units is allocated solely to Sector B because that sector’s marginal value of 

harvest is higher than Sector A’s even after the new allocation.

0

100

200

300

400

500

600

700

0 25 50 75 100 125 150 175 200 225 250 275 300 325

Marginal value ($)

Sector allocation (275 units)

Sector A

Sector B

MVB(hB

0 + ΔACL) = $325

MVA(hA

0) = $225

ΔACL 

MVB(hB

0) = $375
56 

Figure A-3. If the additional allocation is as high as 75 units, the marginal value of harvest for Sector B 

will fall to a level that is just equal to the marginal value of Sector A’s harvest. Granting 100% of 

this increase will produce an allocation that is efficient, in that it satisfies the equimarginal 

principle.

0

100

200

300

400

500

600

700

0 25 50 75 100 125 150 175 200 225 250 275 300 325

Marginal value ($)

Sector allocation (325 units)

Sector A

Sector B

ΔACL2

MVB(hB

0 + ΔACL2) = $225

MVA(hA

0) = $225

MVB(hB

0) = $375
57 

0

100

200

300

400

500

600

700

0 25 50 75 100 125 150 175 200 225 250 275 300 325

Marginal value ($)

Sector allocation (350 units)

Sector A

Sector B

ΔACLA

MVB(hB

0 + ΔACLB) = $175

MVA(hA

0+ΔACLA) = $175

ΔACLB 

Figure A-4. Increases in the ACL above 75 units produce sufficient additional units to enable both sectors 

to receive increases in their allocation and achieve an efficient overall allocation.

Table A-1. Efficient and constrained allocations of ACL. 

Efficient allocation (units) Constrained allocation (units)

ACL Sector A Sector B Sector A Sector B

250 75 175 125 125

275 92 183 125 150

300 108 192 125 175

325 125 200 125 200

350 142 208 142 208

Efficient allocation (% share) Constrained allocation (% share)

ACL Sector A Sector B Sector A Sector B

250 30 70 50 50

275 33 67 45 55

300 36 64 42 58

325 38 62 38 62

350 41 59 41 59
58
59

Appendix B: Analyses in Support of Allocation 

Decisions (Excerpts)

In this appendix, we present examples of how fishery management councils have 

analyzed the allocations described in subsection 4.1, FMP Allocations Among Commercial and 

Recreational Fisheries. These analyses are typically contained within the official documents 

supporting the fishery management plan (FMP) amendment or other regulatory action, rather 

than presented as a stand-alone document. The purpose of these excerpts is to provide examples 

of the types of approaches taken by the councils. We do not include all of the allocation 

decisions covered in subsection 4.2, Analysis of FMP Allocations (Examples), instead including 

what we think is a representative sample.

Gulf of Mexico Fishery Management Council

Reef Fish Resources of the Gulf of Mexico, Amendment 1 (1990): greater amberjack (Seriola 

dumerili), gray snapper (Lutjanus griseus), groupers in aggregate, goliath grouper fka jewfish 

(Epinephelus itajara), lane snapper (Lutjanus synagris), mutton snapper (L. analis), red snapper

(L. campechanus), sea basses, snappers in aggregate, vermilion snapper (Rhomboplites 

aurorubens), yellowtail snapper (Ocyurus chrysurus).

This amendment created allocations for several species based on the commercial and 

recreational catch during the period 1979–1987. There was no quantitative analysis of the 

alternatives considered. An excerpt follows.

The proposed allocation based on the historical percentage harvested by each user 

group during 1979–1987 provides the best available basis for allocating reef 

resources because it represents the longest time period of documented commercial 

and recreational annual harvests. It is the goal of the council to allocate reef 

resources so that the net benefits to the nation are maximized. Therefore 

alternative allocation procedures will be regularly reviewed relative to the goal to 

maximize net benefits. Other allocation methods may be developed in subsequent 

years based on other periods or criteria, but since they may involve significant 

impacts on the respective user groups, the council intends that such allocation 

changes be made only by plan amendment, thus affording the fullest possible 

public review (GMFMC 1989, p. 227).

Reef Fish Resources of the Gulf of Mexico, Secretarial Amendment 1 (2004): red grouper

(Epinephelus morio).

This amendment involved a reduction in the harvest level for red grouper, which was 

accomplished by applying an approximately equal percentage reduction to commercial and 

recreational allocations at their then current levels (81% commercial, 19% recreational). A 
60

quantitative analysis of the total effects of the harvest reduction was provided (see excerpt 

below), but not of the marginal effects for the given allocation. Excerpts follow.

The Proposed Commercial Scenario reduces the overall shallow water grouper 

commercial quota to account for the required reduction in the red grouper 

component of the overall quota. Additionally, the proposed quota reduction 

alternative is estimated to result in a 9.4% reduction in red grouper landings and 

6% reduction in gag and black grouper landings, or 8.5% reduction in shallow

water grouper landings. Based on 1999–2001 average landings, these percent 

reductions translate to reductions of 556,000 pounds or $1.33 million for red 

grouper only, 130,000 pounds or $312,000 for gag only, or 754,000 pounds or 

$1.8 million for the entire shallow water grouper fishery. Assuming the 1999–

2001 average distribution of catches by gear type remains the same, longline 

vessels would bear approximately 90% of red grouper reductions and 83% of gag 

reductions, or 89% of all shallow water grouper reductions. Vertical line vessels 

would bear none of the red grouper reductions and 17% of the gag reductions, or 

5.5% of all shallow water grouper reductions. Fish trap vessels would bear 10% 

of red grouper reductions and none of the gag reductions, or 5.5% of all shallow

water grouper reductions.

The Proposed Recreational Scenario reduces the allowable bag limit for red 

grouper to two fish of the five fish grouper aggregate and is expected to reduce 

recreational harvest by 9%. This alternative is specific to red grouper such that 

the reaction of anglers to potential reduction in red grouper harvest may not be in 

terms of outright trip cancellations. Anglers can switch to other species on a trip 

once the bag limit is met. In any event certain reductions in consumer surplus 

may arise from this management action, since angler flexibility is being 

constrained (GMFMC and NMFS 2004b).

For the purpose of determining some general estimates on the magnitude of 

impacts of this scenario, it is assumed that the reduction in harvest due to the 

reduced bag limit is comparable to reductions in target trips. Considering, 

however, that trip cancellations are unlikely, the consumer surplus reduction 

under a bag limit change may be deemed less than that under closed seasons, even 

if the amount of harvest reduction happens to be the same. If a 9% reduction in 

red grouper harvest were to translate to the same percent reduction in red grouper 

target trips, losses in consumer surplus would amount to $2.2 million. This 

amount is likely to be an overestimate, since as shown in Table 6.14 a two fish red 

grouper bag limit would affect only 6,100 catch trips and catch trips generally 

exceed target trips as shown in Table 6.8. If the $213 per trip consumer surplus 

were applied to catch trips affected by the two fish bag limit for red grouper, 

consumer surplus loss would only amount to $1.3 million. A comparable 

reduction in for-hire vessel revenues cannot be estimated for the reason that the 

bag limit change may not result in trip cancellations. Anglers may lose some 

benefits from the bag limit change but are still likely to take charter or headboat 

trips (GMFMC and NMFS 2004b, p. 70).
61

Reef Fish Resources of the Gulf of Mexico, Amendment 30B (2009): gag grouper

(Mycteroperca microlepis), red grouper.

This amendment established an interim allocation based on commercial and recreational 

catch over the period 1986–2005. The council created a committee to examine future allocation 

issues. A quantitative analysis of the alternatives was conducted for the commercial and 

recreational sectors. This analysis utilized a simulation model for the commercial sector and 

estimates of economic values for the recreational sector. Excerpts follow.

The aggregate economic value associated with each alternative is determined by 

summing estimated commercial and recreational economic values. For the 

commercial sector, the economic value corresponding to each alternative was 

derived based on a simulation model developed by Waters. The simulation model 

is detailed in subsection 5.3.3.1.

For the recreational sector, the economic value corresponding to each alternative 

is derived by summing its constituting components, that is, the producer surplus 

derived by charter operators, the producer surplus enjoyed by headboat operators, 

and consumer surpluses derived by anglers on headboats, private, and charter 

vessels. It is assumed that changes in total allowable catch (TAC) do not affect 

the relative proportion harvested by each subsector. In other terms, when 

expressed in percentage points, harvest levels for anglers on headboats, private, 

and charter vessels remain constant, regardless of the recreational TAC. Based on 

a 2001–2005 average, private anglers, anglers on charter vessels, and anglers on 

headboats harvested 73.2 percent, 24.3 percent, and 2.5 percent of the red grouper 

recreational quota, respectively. Relative proportions of gag grouper harvested in 

the recreational sector by private anglers, anglers on charter vessels, and anglers 

on headboats are estimated at 74.3 percent, 22.5 percent, and 3.2 percent, 

respectively (GMFMC and NMFS 2008b, p. 230).

The evaluation of economic impacts expected to result from recreational 

management measures considered in this amendment relies on computed changes 

in economic values. Changes in economic values resulting from recreational 

management measures are composed of producer surplus changes affecting 

charter boat and headboat operators, consumer surplus changes experienced by 

for-hire consumers, and consumer surplus changes in the private recreational 

sector. Expected changes in consumer and producer surpluses were estimated 

based on methods and assumptions detailed in the evaluation of alternative gag 

and red grouper allocations (subsection 5.5.3.1). Therefore, the same limitations 

apply. However, it is worth reemphasizing that these estimated changes in 

economic value are approximations for the welfare changes expected to result 

from management alternatives considered. These estimates are exclusively 

presented for the purpose of ranking the management alternatives under 

consideration (GMFMC and NMFS 2008b, p. 272).

It should be noted that this analytical approach may overestimate or underestimate 

actual impacts. The analysis relies on actual historic trip records. Models of how 

fishing behavior might change in response to increased restrictions for individual 

species are not available for shallow water grouper or other gulf species. As a 
62

result, while changes in grouper harvests and revenues on historic trips can be 

examined to identify which trips would remain profitable, it is not currently 

possible to identify how fishing behavior might change, targeting substitute 

species in order to maintain revenues. In essence, the current model can only 

eliminate trips, or allow them to occur with decreased revenues, but neither more 

trips nor trips with substituted revenues can be modeled at this time. The model 

can also underestimate impacts if observed fishing activities reflect more 

restrictive regulations than what are proposed. For example, the quota for red 

grouper was filled and the fishery closed during the latter months of 2004 and 

2005. Observed trips during the closure would not have recorded landings of red 

grouper, and there may have been fewer recorded trips than if the red grouper

fishery were open. Therefore, the full benefits of a proposed larger quota would 

not be calculated in the model because there would not be observed trips to 

harvest the larger quota during these months. Since this limitation applies to all 

of the management measures on the commercial sector, it is not expected to affect 

ranking of the alternatives. Caution is necessary, however, if an attempt is made 

to compare these values with those generated for the recreational sector.

For each management alternative considered including the baseline, discounted 

net operating revenues were calculated and summed over the policy period. For 

purposes of economic analysis, policy period is defined as the years 2008–2013. 

Most provisions in this amendment consider this timeframe as the period during 

which management measures affecting harvest and participation would apply. 

Those measures could last longer or shorter depending on future council 

decisions, but for this amendment the years 2008–2013 compose the relevant 

period. The model used logbook records, including the economic add-on survey, 

supplemented by ALS ex-vessel price information and Bureau of Labor Statistics 

data on price indices. The baseline scenario refers to the model run using the no 

action alternative for all actions in this amendment (GMFMC and NMFS 2008b, 

p. 215).

Gulf of Mexico Fishery Management Council and South Atlantic 

Fishery Management Council

Coastal Migratory Pelagic Resources of the Gulf of Mexico and South Atlantic, 

Amendment 2 (1987): Spanish mackerel (Scomberomorus maculatus)/Atlantic group; Spanish 

mackerel/Gulf group.

This amendment created an allocation based on the commercial and recreational catch 

during the period 1979–1985. There was no quantitative analysis of the economic effects of the 

alternatives. Excerpts follow.

Allocation of TAC within each migratory group of Spanish mackerel is to be 

divided between commercial and recreational fishermen based on the average 

ratio of the catch for the period 1979−1985.

This allocation uses the average ratio of catches from 1979–1985, the most recent 

period for which comparable catch statistics are available, to allocate the TACs 
63

(set in Action 2) between recreational and commercial fishermen. The decrease 

in TAC to restore the fishery requires a limitation of catch. In order to distribute 

the catch fairly, allocations are made for recreational and commercial users.

The allocations are to be revised with TAC adjustments using fixed ratios to 

assure that each group receives its fair share. The present value of the 

commercial fishery under this action is $29.45 million using an ex-vessel price of 

$0.30 per pound as a proxy for average value and a discount rate of 10%. This 

compares favorably with the present value of $18.6 million for the unregulated 

fishery (GMFMC and SAFMC 1987, p. 14).

Coastal Migratory Pelagic Resources of the Gulf of Mexico and South Atlantic, 

Amendment 4 (1989): Spanish mackerel/Atlantic group.

This amendment revised the previous allocation based on more recent commercial and 

recreational catch data. There was no quantitative analysis of the economic effects of the 

alternatives due to the absence of readily available economic data. Excerpts follow.

The councils know of no economic data readily available with which to 

quantitatively evaluate the benefits and costs of the proposed change in allocation. 

Recent work on the Gulf of Mexico king mackerel fishery provides information 

on the impacts of increased catches and changes to bag limits for Gulf king 

mackerel, and more importantly develops a methodology which can now be used 

to conduct the same type of analyses for Gulf and Atlantic migratory groups of 

Spanish mackerel and Atlantic migratory group king mackerel. The councils 

strongly recommend that these analyses be conducted by the National Marine 

Fisheries Services ... information as soon as it is available which will greatly 

assist in the determining the impacts of our regulations (GMFMC and SAFMC 

1989, p. 9).

An economic assessment of the king and Spanish mackerel fisheries was prepared 

in March 1987 by NMFS. While this document presents some general economic 

information about Spanish mackerel it does not provide an analysis of the impacts 

of quota and bag limits. The councils strongly recommend that these analyses be 

redone by the NMFS Southeast Region economists as soon as possible. The 

councils will of course make use of this information as soon as it is available, 

which will greatly assist in the determining the impacts of our regulations.

On the recreational side, the methodology to analyze benefits from doubling their 

allocation has been developed but work in this area has not been conducted

(GMFMC and SAFMC 1989, p. 11).

The councils concluded that the 50/50 allocation results in benefits greater than 

costs and maximizes the net socioeconomic benefits available from the Atlantic 

migratory group Spanish mackerel resource (GMFMC and SAFMC 1989, p. 8).
64

Mid-Atlantic Fishery Management Council

Atlantic Bluefish, Amendment 1 (2000): bluefish (Pomatomus saltatrix).

This amendment established a de facto allocation by limiting the commercial catch to 

20% of the allowable harvest, a figure based on harvest data during the period 1981–1989. No 

quantitative analysis of the economic effects of the allocation was conducted. An excerpt 

follows.

The base period, 1981 to 1989, was chosen by the council and commission as the 

preferred allocation period because it represents the years prior to the regulations 

that may have affected recreational and commercial landings (i.e., prior to the 

approval of the Bluefish FMP in 1990). Given these considerations, the council 

and commission considered that this period would result in the most fair 

allocation of the resource (MAFMC 1998, p. 160).

New England Fishery Management Council

Northeast Multispecies Fishery, Amendment 16 (2010): Gulf of Maine cod (Gadus morhua); 

Gulf of Maine haddock (Melanogrammus aeglefinus).

This action established an allocation for two fisheries based on commercial and 

recreational catch data from the period 2001–2006. While no quantitative analysis was 

conducted, a qualitative assessment of the alternatives was presented. Excerpts follow.

The Proposed Action would make an explicit allocation between commercial and 

recreational user groups for stocks where the allowable catch limit (ACL) was not 

fully harvested and where the recreational catches exceeded 5% of total catch. 

Based on available data these two criteria would be met for only GOM cod and 

for GOM haddock. The resulting ACL would depend on the selected years used 

to calculate commercial and recreational shares. The economic impacts of the 

proposed option are difficult to assess. For this reason, a qualitative assessment is 

offered below.

The proposal to create a specific allocation of groundfish for the recreational and 

commercial components of the groundfish fishery may prove to constrain catches 

of each of those user groups. The economic impacts, when compared to No 

Action, depend in larger measure on which time period is used to determine the 

allocations. If the period used is FY 1996–2006, the share for the commercial 

component is larger than if the period used is FY 2001–2006. Obviously, the 

reverse is true for the recreational fishery. Choosing the longer period means that 

recreational fishing harvest will need to be reduced when compared to recent 

activity, resulting in a decline in benefits (both monetary and otherwise) for this 

component when compared to No Action.

The economic impacts on the recreational groundfish fishery will depend on the 

likelihood that recreational catches will trigger accountability measures and on the 

nature of the accountability measures themselves. Given a set of management 

measures, the likelihood that an AM would be triggered would be lower the larger 
65

the ACL. Thus economic benefits to the recreational fishery would be largest if 

the years selected for calculating the share are 2001–2006. These years would 

result in the largest recreational share which would also mean a higher ACL and a 

lower probability that accountability measures would be needed.

One advantage to choosing an allocation period—regardless which specific period 

is chosen—is that each component can be individually evaluated for compliance 

with catch limits. If a component exceeds its catch limit, appropriate measures 

can be introduced to control catch with less likelihood that the other component 

will also be subject to more restrictive measures. A disadvantage is that if a 

component does not catch its allocation, the only benefit is the contribution of the 

uncaught catch to rebuilding as there are no provisions to transfer the uncaught 

catch between components. This would be difficult in any case because of the 

delays in catch reporting for recreational fishermen (NEFMC 2010, p. 683).

South Atlantic Fishery Management Council

Dolphin and Wahoo FMP (2004): mahi mahi, fka dolphin (Coryphaena hippurus) and wahoo

(Acanthocybium solandri).

The FMP created a de facto, nonbinding allocation by capping the commercial harvest at 

13%, an allocation based on harvest data for the period 1994–1997. No quantitative analysis of 

the economic effects of the allocation was conducted. The council noted that maintaining the 

current allocation would have a “possible positive social impact” by reducing potential conflicts 

between the commercial and recreational sectors. An excerpt follows.

Setting commercial and recreational sector allocations at levels that are reflective 

of historical landings will have no negative social impact on either the 

commercial or recreational participants. A possible positive social impact is that 

the potential conflict between the two sectors will be reduced, as this action does 

not change the status quo (SAFMC 2003, p. lxvi).

Snapper-Grouper Fishery of the South Atlantic Region, Amendment 15B (2009): red porgy

(Pagrus pagrus), snowy grouper (Epinephelus niveatus).

This amendment established an allocation for two fisheries based on commercial and 

recreational catch for the periods 1986–2005 (snowy grouper) and 1999–2003 (red porgy). No 

quantitative analysis of the economic effects was conducted because data and other limitations 

were judged to make such an analysis unfeasible. The council operated under the assumption 

that “adverse effects are compounded the greater the deviation from the status quo” (SAFMC 

and NMFS 2008a, p. xxxviii). Excerpts follow.

The alternative allocation ratios for snowy grouper were generated through the 

examination of sector harvests for different harvest years rather than an attempt to 

identify the allocation that maximized net benefits because application of the 

maximum benefit analysis is not possible at this time with available data. 

Because the alternatives are not the result of benefit maximization analyses, 

comparison of the alternatives is reduced to a simple benefit-cost analysis which, 
66

since any reallocation to one sector occurs at the expense of the other, consists of 

comparing the costs to the sector receiving the reduced allocation with the 

benefits to the sector receiving the increased allocation. The benefits of a new 

allocation would consist of the increase in consumer surplus to recreational 

anglers or consumers of purchased fish and increased profits for the suppliers of 

recreational access (for-hire vessels, gear suppliers, etc.), and entities in the 

commercial sector production chain (commercial vessels, distributors, retailers, 

etc.) that accrue to the sector that receives an increased allocation. The costs of a 

new allocation would consist of the decrease in these variables to the sector that 

receives a decreased allocation.

Current economic models of the snapper-grouper fisheries, as used and discussed 

in Amendment 15A, produce estimates of consumer surplus to recreational 

anglers and net operating revenue (returns to owner and captain/labor) to for-hire 

and commercial vessels. Due to data deficiencies, however, these models 

generate estimates of the potential costs and benefits of reallocation that 

inadequately characterize the potential impacts. For the recreational sector, a 

demand curve for snowy grouper or appropriate similar species does not exist due 

to insufficient data. A demand curve demonstrates how the value of each 

subsequent fish or pound of fish harvested (or any product/service consumed/used 

by an individual) is reduced relative to the previous fish or pound. This is 

referred to as the concept of declining marginal value. Because a demand curve 

has not been estimated, a fixed value must be used, resulting in overestimation of 

the consumer surplus. In addition to the absence of a demand curve, insufficient 

information on angler behavioral change exists to accurately model how trip 

demand would change with changes in fish biomass. The model currently allows 

unfettered behavioral change by allowing effort to increase with increased catch 

rates or harvest quotas as biomass improves under the snowy grouper rebuilding 

plan. Operationally, allowing effort to increase in this manner functionally 

assumes the relationship “provide the fish and they will come.” While such 

behavior is expected to be true to a point, effort expansion would not be expected 

to be continuous. Further, it is logical to expect that as catch rates and biomass 

increases, catch limits, specifically bag limits, would be increased such that some 

of the increased allowable harvest, and possibly a significant portion, would be 

harvested by base effort rather than new effort. Thus, while the value to base trips 

would still increase, resulting in increased benefits, due to improved fishing 

quality, the increase in value would not be as great as if these fish were harvested 

on new trips since new trips would generate increases in consumer surplus to 

anglers and producer surplus for for-hire operators and others in the recreational 

industry. Because the model assumes linear expansion of recreational effort, the 

estimates of changes in net recreational benefits overstate what is likely to occur.

Similar problems exist for the commercial sector. Theoretically, changes in 

consumer surplus also occur as product supply to the market changes. However, 

the commercial reef fish market is dominated by species substitution and imports, 

such that market prices for domestic harvests are generally assumed to remain 

unchanged with changing harvest quantities. If this assumption is not correct, an 

impact assessment would underestimate the costs of reduced commercial 
67

allocation. Information on the profit situation for distributors and retailers of 

commercially caught fish is not currently available, so impacts of any reallocation 

on this sector cannot be quantified. Additionally, behavioral changes in the 

commercial sector cannot be modeled. The commercial model uses only the 

records of actual trips taken and does not allow fishermen to change fishing 

patterns (take more trips or target different species) in response to management 

changes or increased/decreased availability of catch. The model only allows a 

given trip to be taken, with historic, reduced, or increased harvests, or be 

cancelled entirely, with the loss of all harvests for that trip (as well as cancellation 

of associated trip costs). No new trips can be generated, however, nor can target 

behavior be shifted to increase the harvest of other species in response to greater 

restrictions on a given species. Absent the ability of adaptive behavior in the 

commercial sector, the quantitative results likely understate benefits and overstate 

losses.

In light of these issues, quantitative assessment of the expected impacts of the 

allocation alternatives has not been attempted. Qualitatively, it is difficult to 

identify the best allocation alternative. No alternative to the status quo would 

benefit one sector while having no impact on the other sector. In fact, since each 

alternative to the status quo would increase the recreational snowy grouper 

allocation at the expense of the commercial sector, in all instances the recreational 

sector would be expected to gain economic benefits while the commercial sector 

would lose benefits. If it is believed that adverse effects are compounded the 

greater the deviation from status quo, large changes in the allocation from the 

status quo would not be recommended. As such, Preferred Alternative 2 and 

Alternative 3 may be preferable to Alternative 4 since they would result in only 

marginal changes in the allocation, 1 and 3 percentage points, respectively, 

whereas Alternative 4 would impose an 8 percentage point change (8.33% total 

change) in the allocation. While none of the allocation alternatives to the status 

quo (96% commercial/4% recreational based on landings between 1999 and 2003) 

would be neutral to either sector, lower overall adverse social impacts to the 

affected sectors and associated industries and communities may be expected to 

accrue to those alternatives that result in the lowest allocation away any individual 

sector (SAFMC and NMFS 2008a, p. 4-2 to 4-4).

Snapper-Grouper Fishery of the South Atlantic Region, Amendment 16 (2009): gag 

grouper.

This amendment established an allocation to accommodate a reduction in catch, with the 

allocation based on commercial and recreational catch during the period 1999–2003. A 

quantitative analysis of the economic effects was conducted for the commercial and recreational 

sectors and for all alternatives, although the council noted that the set of alternatives did not 

necessarily contain the allocation that maximized net benefits. Excerpts follow.

These alternatives were generated through an examination of sector harvests for 

different harvest years rather than an attempt to identify the allocation that 

maximized net benefits, or in the present case minimized net losses, because 
68

application of the maximum benefit analysis is not possible at this time with 

available data (SAFMC and NMFS 2008b, p. 4-21).

Estimates of economic effects on the commercial sector were derived using a 

simulation model developed by Waters. A more detailed description of the model 

can be found in Appendix H. Estimates of net operating revenues were generated 

by subtracting trip costs from total revenues. Trip costs were predicted based on 

gear specific cost functions. If trip revenues exceeded trip costs after accounting 

for the expected effects of proposed regulations on trip-level harvests, then shortterm economic losses were measured as the resulting reduction in trip revenues. 

Conversely, if the combination of proposed alternatives would cause trip revenues 

to fall below trip costs, then the trip was recorded as not taken and losses were 

measured as a reduction in net operating revenues, which included the loss in 

revenues from all species minus the savings of trip costs not incurred (SAFMC 

and NMFS 2008b, p. 4-21 to 4-22).

In the absence of a recreational fishery model comparable to that for the 

commercial sector, estimates of economic impacts on the recreational sector were 

generated by measuring potential changes in producer and consumer surplus using 

available information. Some of this information was taken from other fisheries 

outside of the South Atlantic council’s area of jurisdiction. The major parameters 

used in calculating producer surplus are for-hire net revenues per angler per trip to 

captain and crew of $150 for charter boats and $67 for headboats. These values 

are based on the for-hire survey conducted in the Gulf of Mexico. Another 

parameter used in calculating producer surplus is a keep elasticity of 1.46 that is 

taken to represent the percent change in target trip demand relative to the percent 

change in the keep rate. This value was generated by a study of the gulf red 

snapper fishery. For consumer surplus estimation, the major parameter used is the 

value of a one fish change in the harvest per target trip of $3.03. This value is 

based on a recreational demand study conducted for reef fish in the Southeast.

The focal point of estimating consumer and producer surpluses is the 2001–2006 

average target trips for gag and other species. It should be pointed out at this 

stage that for the 2001–2006 period, target effort differed substantially from catch 

effort, as noted in the discussion of the affected environment. In fact, target effort 

for gag and other species registered at very low levels especially when taking into 

account area distribution. At any rate, target effort is used since it presents a more 

reasonable proxy for demand for gag trips than catch effort. Target effort was 

represented by target trips for gag and other species.

Producer surplus was proxied by the net operating revenue of for-hire vessels, or 

more specifically by the net revenue to captain and crew per individual passenger 

trip. The estimated value of one fish was used to calculate consumer surplus. To 

estimate a change in producer surplus, the projected percent change in catch rate 

was first translated into a percent change for target trip demand via the keep rate 

elasticity. The percent change in target trip demand was then applied to target 

trips to arrive at the change in target trips. This latter value was subsequently 

multiplied by the corresponding producer surplus for charter boat and headboat to 

arrive at the change in charter boat and headboat producer surplus. Estimating the 
69

change in consumer surplus followed a similar procedure except that the 

estimation proceeded in determining the change if demand for fish with the latter 

multiplied by consumer surplus per fish. To do this, catches in pounds were 

converted to catches in number of fish using the 2001–2006 gag average weight. 

For more details on the estimation of consumer and producer surplus, please see 

Appendix I (SAFMC and NMFS 2008b, p. 4-25).

Snapper-Grouper Fishery of the South Atlantic Region, Amendment 17B (2010): golden 

tilefish (Lapholatilus chamaeleonticeps).

This amendment established an allocation based on the average commercial and 

recreational catch during two periods, 1986–2008 and 2006–2008. An excerpt follows.

The council concluded balancing long-term catch history with recent catch history 

is the most fair and equitable way to allocate golden tilefish. Specifying 

allocations for recreational and commercial sectors allows the council to meet the 

new Magnuson-Stevens Act requirements. The council also concluded the 

preferred alternative best meets the goals and objectives of the Snapper Grouper 

FMP as amended (SAFMC and NMFS 2010, p. 191).
70
71

Appendix C: Management Objectives for FMPs 

with Allocation Decisions

Under the Magnuson-Stevens Fishery Conservation and Management Act (MSA), fishery 

management councils establish management objectives as part of the process of developing a 

fishery management plan (FMP). In establishing these objectives, a council is expected to 

balance the biological and human interests in the fishery, address the costs and benefits of 

management over time, and integrate the diversity of public and private interests. The council 

can then use the management objectives to judge management measures under consideration in 

light of the national standards listed in the MSA.

In Table C-1, we list all of the management objectives for the 11 FMPs that have 

allocation decisions discussed in this technical memorandum. The table provides a complete 

listing even though not all of the FMPs have objectives that relate directly to the issue of 

commercial-recreational allocation.

Table C-1. Fisheries Management Plan (FMP) management objectives.

FMP Management objectives

Gulf of Mexico Fishery Management Council

Reef fish 

resources of the 

Gulf of Mexico 

(GMFMC 2004)

Management objective (FMP/Amendment)

1. Rebuild the declining reef fish stocks wherever they occur within the fishery 

(original FMP November 1984).

2. Establish a fishery reporting system for monitoring the reef fish fishery (original 

FMP).

3. Conserve reef fish habitats and increase reef fish habitats in appropriate areas and 

provide protection for juveniles while protecting existing and new habitats (original 

FMP).

4. Minimize conflicts between user groups of the resource and conflicts for space 

(original FMP).

5. Stabilize long-term population levels of all reef fish species by establishing a 

certain survival rate of biomass into the stock of spawning age to achieve at least 20 

percent spawning stock biomass per recruit* (Amendment 1 January, 1990. 

Identified as the primary objective of the Reef Fish FMP).

6. Reduce user conflicts and nearshore fishing mortality (modifies Objective 4) 

(Amendment 1).

7. Respecify the reporting requirements necessary to establish a database for 

monitoring the reef fish fishery and evaluating management actions (modifies 

Objective 2) (Amendment 1).

8. Revise the definitions of the fishery management unit and fishery to reflect the 

current species composition of the reef fish fishery (Amendment 1).

9. Revise the definition of optimum yield (OY) to allow specification at the species 

level (Amendment 1).

10. Encourage research on the effects of artificial reefs (Amendment 1).
72

Table C-1 continued. Fisheries Management Plan (FMP) management objectives.

FMP Management objectives

Reef fish 

resources of the 

Gulf of Mexico 

(GMFMC 2004)

continued

11. Maximize net economic benefits from the reef fish fishery (Amendment 1).

12. Avoid to the extent practicable the derby type of fishing season (Amendment 8, 

July 1995).

13. Promote flexibility for the fishermen in their fishing operations (Amendment 8).

14. Provide for cost-effective and enforceable management of the fishery 

(Amendment 8).

15. Optimize net benefits to the fishery (modifies Objective 11) (Amendment 8).

Gulf of Mexico Fishery Management Council and South Atlantic Fishery Management Council

Coastal migratory 

pelagic resources 

of the Gulf of 

Mexico and south 

Atlantic

(GMFMC 1992)

The current FMP through Amendment 5 lists 7 plan objectives:

1. The primary objective of this FMP is to stabilize yield at MSY, allow recovery of 

overfished populations, and maintain population levels sufficient to ensure adequate 

recruitment.

2. Provide a flexible management system for the resource which minimizes 

regulatory delay while retaining substantial council and public input in management 

decisions and which can rapidly adapt to changes in resource abundance, new 

scientific information, and changes in fishing patterns among user groups or by 

areas.

3. Provide necessary information for effective management and establish a 

mandatory reporting system for monitoring catch.

4. Minimize gear and user group conflicts.

5. Distribute the total allowable catch of Atlantic migratory group Spanish mackerel 

between recreational and commercial user groups based on the catches that occurred 

during the early to mid 1970s, which is prior to development of the deep water runaround gill net fishery and when the resource was not overfished.

6. Minimize waste and bycatch in the fishery.

7. Provide appropriate management to address specific migratory groups of king 

mackerel.

8. A new objective is proposed as follows: Optimize the social and economic 

benefits of the coastal migratory pelagic fisheries.

Mid-Atlantic Fishery Management Council

Atlantic bluefish 

(MAFMC 1998)

Atlantic 

mackerel, squid, 

and butterfish 

fisheries 

(MAFMC 2009)

The major goal of the management plan is to conserve the bluefish resource along 

the Atlantic coast. The council and commission have adopted five major objectives 

to achieve this goal:

1. Increase understanding of the stock and of the fishery.

2. Provide the highest availability of bluefish to U.S. fishermen while maintaining, 

within limits, traditional uses of bluefish.

3. Provide for cooperation among the coastal states, the various regional marine 

fishery management councils, and federal agencies involved along the coast to 

enhance the management of bluefish throughout its range.

4. Prevent recruitment overfishing.

5. Reduce waste in both the commercial and recreational fisheries.

The objectives, as described in the FMP as currently amended, are listed below. 

The purposes of Amendment 11 described above (4.1) primarily serve FMP general 

management objectives/goals 3, 4, and 6.

1. Enhance the probability of successful (i.e., the historical average) recruitment to 

the fisheries.
73

Table C-1 continued. Fisheries Management Plan (FMP) management objectives.

FMP Management objectives

Atlantic 

mackerel, squid, 

and butterfish 

fisheries 

(MAFMC 2009)

continued

2. Promote the growth of the U.S. commercial fishery, including the fishery for 

export.

3. Provide the greatest degree of freedom and flexibility to all harvesters of these 

resources consistent with the attainment of the other objectives of this FMP.

4. Provide marine recreational fishing opportunities, recognizing the contribution of 

recreational fishing to the national economy.

5. Increase understanding of the conditions of the stocks and fisheries.

6. Minimize harvesting conflicts among U.S. commercial, U.S. recreational, and 

foreign fishermen.

Summer 

flounder, scup, 

and black seabass 

fisheries

(MAFMC 2007)

The objectives of the FMP are to:

1. Reduce fishing mortality in the summer flounder, scup, and black seabass

fisheries to ensure that overfishing does not occur.

2. Reduce fishing mortality on immature summer flounder, scup, and black seabass 

to increase spawning stock biomass.

3. Improve the yield from the fishery.

4. Promote compatible management regulations between state and federal 

jurisdictions.

5. Promote uniform and effective enforcement of regulations.

6. Minimize regulations to achieve the management objectives stated above.

New England Fishery Management Council

Northeast multispecies fishery 

(original FMP) 

(NEFMC 1985)

Northeast multispecies fishery 

(Amendment 16) 

(NEFMC 2010)

The objective of the Northeast Region Multi-species FMP is to control fishing 

mortality on juveniles (primarily) and on adults (secondarily) of selected finfish 

stocks within the management unit for the purpose of maintaining sufficient 

spawning potential so that year classes replace themselves in the stock on a longterm average basis; and to similarly reduce fishing mortality for the purpose of 

rebuilding those stocks where it has been demonstrated that the spawning potential 

of the stock is insufficient to maintain a viable fishery resource; and further to 

promote the collection of data and information on the nature, behavior and activity 

of the multi-species fishery, and on the effectiveness of the management program.

The goals and objectives of this amendment remain as described in Amendment 13:

Goal 1: Consistent with the national standards and other required provisions of the 

Magnuson-Stevens Fishery Conservation and Management Act and other applicable 

law, manage the northeast multi-species complex at sustainable levels.

Goal 2: Create a management system so that fleet capacity will be commensurate 

with resource status so as to achieve goals of economic efficiency and biological 

conservation and that encourages diversity within the fishery.

Goal 3: Maintain a directed commercial and recreational fishery for northeast 

multispecies.

Goal 4: Minimize, to the extent practicable, adverse impacts on fishing communities 

and shoreside infrastructure.

Goal 5: Provide reasonable and regulated access to the groundfish species covered 

in this plan to all members of the public of the United States for seafood 

consumption and recreational purposes during the stock rebuilding period without 

compromising the Amendment 13 objectives or timetable. If necessary, 

management measures could be modified in the future to insure that the overall plan 

objectives are met.
74

Table C-1 continued. Fisheries Management Plan (FMP) management objectives.

FMP Management objectives

Northeast multispecies fishery 

(Amendment 16) 

(NEFMC 2010)

continued

Goal 6: To promote stewardship within the fishery.

Objective 1: Achieve, on a continuing basis, OY for the U.S. fishing industry.

Objective 2: Clarify the status determination criteria (biological reference points and 

control rules) for groundfish stocks so they are consistent with the national standard 

guidelines and applicable law.

Objective 3: Adopt fishery management measures that constrain fishing mortality to 

levels that are compliant with the U.S. Sustainable Fisheries Act.

Objective 4: Implement rebuilding schedules for overfished stocks and prevent 

overfishing.

Objective 5: Adopt measures as appropriate to support international transboundary 

management of resources.

Objective 6: Promote research and improve the collection of information to better 

understand groundfish population dynamics, biology and ecology, and to improve 

assessment procedures in cooperation with the industry.

Objective 7: To the extent possible, maintain a diverse groundfish fishery, including 

different gear types, vessel sizes, geographic locations, and levels of participation.

Objective 8: Develop biological, economic and social measures of success for the 

groundfish fishery and resource that insure accountability in achieving fishery 

management objectives.

Objective 9: Adopt measures consistent with the habitat provisions of the 

Magnuson-Stevens Act, including identification of essential fish habitat and 

minimizing impacts on habitat to the extent practicable.

Objective 10: Identify and minimize bycatch, which include regulatory discards, to 

the extent practicable, and to the extent bycatch cannot be avoided, minimize the 

mortality of such bycatch.

NMFS Highly Migratory Species (HMS) Division

Atlantic HMS 

(NMFS 1999)

The management objectives of the FMP for Atlantic HMS are described below. 

They apply to tuna, swordfish, and sharks. They are not listed in any particular 

order.

• Prevent or end overfishing of Atlantic tuna, swordfish, and sharks and adopt the 

precautionary approach to fishery management.

• Rebuild overfished fisheries in as short a time as possible and control all 

components of fishing mortality, both directed and incidental, so as to ensure the 

long-term sustainability of the stocks and promote stock recovery of the 

management unit to the level at which the maximum sustainable yield (MSY) can be 

supported on a continuing basis.

• Minimize, to the extent practicable, economic displacement and other adverse 

impacts on fishing communities during the transition from overfished fisheries to 

healthy ones.

• Minimize, to the extent practicable, bycatch of living marine resources and the 

mortality of such bycatch that cannot be avoided in the fisheries for Atlantic tuna, 

swordfish, and sharks.

• Establish a foundation for international negotiation on conservation and 

management measures to rebuild overfished fisheries and to promote achievement 

of OY for these species throughout their range, both within and beyond the 

exclusive economic zone. OY is the MSY from the fishery, reduced by any relevant 

social, economic, or ecological factors.
75

Table C-1 continued. Fisheries Management Plan (FMP) management objectives.

FMP Management objectives

Atlantic HMS 

(NMFS 1999)

continued

• Provide a framework, consistent with other applicable law, to take necessary 

action under International Commission for the Conservation of Atlantic Tunas 

compliance recommendations.

• Provide the data necessary for assessing the fish stocks and managing the fisheries, 

including addressing inadequacies in current collection and ongoing collection of 

social, economic, and bycatch data about HMS fisheries.

• Consistent with other objectives of this FMP, manage Atlantic HMS fisheries for 

continuing OY so as to provide the greatest overall benefit to the nation, particularly 

with respect to food production, providing recreational opportunities, preserving 

traditional fisheries, and taking into account the protection of marine ecosystems.

• Better coordinate domestic conservation and management of the fisheries for 

Atlantic tuna, swordfish, sharks, and billfish, considering the multi-species nature of 

many HMS fisheries, overlapping regional and individual participation, 

international management concerns, historical fishing patterns and participation, and 

other relevant factors.

• Simplify and streamline HMS management while actively seeking input from 

affected constituencies, the general public, and the HMS advisory panel.

• Promote protection of areas identified as essential fish habitat for tuna, swordfish, 

and sharks.

• Reduce latent effort and overcapitalization in HMS commercial fisheries.

• Develop eligibility criteria for participation in the commercial shark and swordfish 

fisheries based on historical participation, including access for traditional swordfish 

handgear fishermen to participate fully as the stock recovers.

• Create a management system to make fleet capacity commensurate with resource 

status so as to achieve the dual goals of economic efficiency and biological 

conservation.

Pacific Fishery Management Council

Pacific coast 

groundfish

(PFMC 2008)

Management goals

Goal 1: Conservation. Prevent overfishing and rebuild overfished stocks by 

managing for appropriate harvest levels and prevent, to the extent practicable, any 

net loss of the habitat of living marine resources.

Goal 2: Economics. Maximize the value of the groundfish resource as a whole.

Goal 3: Utilization. Within the constraints of overfished species rebuilding 

requirements, achieve the maximum biological yield of the overall groundfish 

fishery, promote year-round availability of quality seafood to the consumer, and 

promote recreational fishing opportunities.

To accomplish these management goals, a number of objectives will be considered 

and followed as closely as practicable:

Conservation

Objective 1. Maintain an information flow on the status of the fishery and the 

fishery resource which allows for informed management decisions as the fishery 

occurs.
76

Table C-1 continued. Fisheries Management Plan (FMP) management objectives.

FMP Management objectives

Pacific coast 

groundfish

(PFMC 2008)

continued

Objective 2. Adopt harvest specifications and management measures consistent 

with resource stewardship responsibilities for each groundfish species or species 

group. Achieve a level of harvest capacity in the fishery that is appropriate for a 

sustainable harvest and low discard rates, and which results in a fishery that is 

diverse, stable, and profitable. This reduced capacity should lead to more effective 

management for many other fishery problems.

Objective 3. For species or species groups that are overfished, develop a plan to 

rebuild the stock as soon as possible, taking into account the status and biology of 

the stock, the needs of fishing communities, recommendations by international 

organizations in which the United States participates, and the interaction of the 

overfished stock within the marine ecosystem.

Objective 4. Where conservation problems have been identified for non-groundfish 

species and the best scientific information shows that the groundfish fishery has a 

direct impact on the ability of that species to maintain its long-term reproductive 

health, the council may consider establishing management measures to control the 

impacts of groundfish fishing on those species. Management measures may be 

imposed on the groundfish fishery to reduce fishing mortality of a non-groundfish 

species for documented conservation reasons. The action will be designed to 

minimize disruption of the groundfish fishery, in so far as consistent with the goal to 

minimize the bycatch of non-groundfish species, and will not preclude achievement 

of a quota, harvest guideline, or allocation of groundfish, if any, unless such action 

is required by other applicable law.

Objective 5. Describe and identify EFH, adverse impacts on EFH, and other actions 

to conserve and enhance EFH, and adopt management measures that minimize, to 

the extent practicable, adverse impacts from fishing on EFH.

Economics

Objective 6. Within the constraints of the conservation goals and objectives of the 

FMP, attempt to achieve the greatest possible net economic benefit to the nation 

from the managed fisheries.

Objective 7. Identify those sectors of the groundfish fishery for which it is 

beneficial to promote year-round marketing opportunities and establish management 

policies that extend those sectors’ fishing and marketing opportunities as long as 

practicable during the fishing year.

Objective 8. Gear restrictions to minimize the necessity for other management 

measures will be used whenever practicable. Encourage development of practicable 

gear restrictions intended to reduce regulatory or economic discards through gear 

research regulated by exempted fishing permit.

Utilization

Objective 9. Develop management measures and policies that foster and encourage 

full utilization (harvesting and processing), in accordance with conservation goals, 

of the Pacific coast groundfish resources by domestic fisheries.

Objective 10. Recognizing the multi-species nature of the fishery and establish a 

concept of managing by species and gear or by groups of interrelated species.
77

Table C-1 continued. Fisheries Management Plan (FMP) management objectives.

FMP Management objectives

Pacific coast 

groundfish

(PFMC 2008)

continued

Objective 11. Develop management programs that reduce regulations-induced 

discard or which reduce economic incentives to discard fish. Develop management 

measures that minimize bycatch to the extent practicable and, to the extent that 

bycatch cannot be avoided, minimize the mortality of such bycatch. Promote and 

support monitoring programs to improve estimates of total fishing-related mortality 

and bycatch, as well as those to improve other information necessary to determine 

the extent to which it is practicable to reduce bycatch and bycatch mortality.

Social factors.

Objective 12. When conservation actions are necessary to protect a stock or stock 

assemblage, attempt to develop management measures that will affect users 

equitably.

Objective 13. Minimize gear conflicts among resource users.

Objective 14. When considering alternative management measures to resolve an 

issue, choose the measure that best accomplishes the change with the least 

disruption of current domestic fishing practices, marketing procedures, and the 

environment.

Objective 15. Avoid unnecessary adverse impacts on small entities.

Objective 16. Consider the importance of groundfish resources to fishing 

communities, provide for the sustained participation of fishing communities, and 

minimize adverse economic impacts on fishing communities to the extent 

practicable.

Objective 17. Promote the safety of human life at sea.

West Coast 

salmon (PFMC 

2003)

Fishery objectives

The following objectives guide the council in establishing fisheries against a 

framework of ecological, social, and economic considerations:

1. Establish ocean exploitation rates for commercial and recreational salmon 

fisheries that are consistent with requirements for stock conservation objectives 

within Section 3.1, specified U.S. Endangered Species Act consultation or recovery 

standards, or council adopted rebuilding plans.

2. Fulfill obligations to provide for Indian harvest opportunity as provided in 

treaties with the United States, as mandated by applicable decisions of the federal 

courts, and as specified in the October 4, 1993 opinion of the Solicitor, Department 

of Interior, with regard to federally recognized Indian fishing rights of Klamath 

River tribes.

3. Seek to maintain ocean salmon fishing seasons which support the continuance of 

established recreational and commercial fisheries while meeting salmon harvest 

allocation objectives among ocean and inside recreational and commercial fisheries 

that are fair and equitable, and in which fishing interests shall equitably share the 

obligations of fulfilling any treaty or other legal requirements for harvest 

opportunities. (Note: In its effort to maintain the continuance of established ocean 

fisheries, the council includes consideration of maintaining established fishing 

communities. In addition, a significant factor in the council’s allocation objectives 

in Section 5.3 is aimed at preserving the economic viability of local ports or specific 

coastal communities (e.g., recreational port allocations north of Cape Falcon.)
78

Table C-1 continued. Fisheries Management Plan (FMP) management objectives.

FMP Management objectives

West Coast 

salmon (PFMC 

2003) continued

4. Minimize fishery mortalities for those fish not landed from all ocean salmon 

fisheries as consistent with OY and the bycatch management specifications of 

Section 3.4.

5. Manage and regulate fisheries so that the OY encompasses the quantity and value 

of food produced, the recreational value, and the social and economic values of the 

fisheries.

6. Develop fair and creative approaches to managing fishing effort and evaluate and 

apply effort management systems as appropriate to achieve these management 

objectives.

7. Support the enhancement of salmon stock abundance in conjunction with fishing 

effort management programs to facilitate economically viable and socially 

acceptable commercial, recreational, and tribal seasons.

8. Achieve long-term coordination with the member states of the council, Indian 

tribes with federally recognized fishing rights, Canada, the North Pacific Fishery 

Management Council, Alaska, and other management entities which are responsible 

for salmon habitat or production. Manage consistent with the Pacific Salmon Treaty 

and other international treaty obligations.

9. In recommending seasons, to the extent practicable, promote the safety of human 

life at sea.

Conservation objectives: see Table 3-1 from document.

South Atlantic Fishery Management Council

Dolphin and 

wahoo (SAFMC 

2003)

The overall goal of the fishery management plan for the South Atlantic, MidAtlantic, and New England councils’ areas of jurisdiction is to adopt a precautionary 

and risk-averse approach to management which in the first instance attempts to 

maintain the status quo. This will require that current catch levels not be exceeded 

and that recent conflict between sectors of the fishery (commercial longliners and 

recreational fishermen) be resolved. Status quo should reflect trends (average catch 

and effort levels) in the fishery over the last five years 1993 through 1997.

Owing to the significant importance of the dolphin/wahoo fishery to the recreational 

fishing community in the Atlantic, the goal of this fishery management plan is to 

maintain the current harvest level of dolphin and insure that no new fisheries 

develop. With the potential for effort shifts in the historical longline fisheries for 

sharks, tunas, and swordfish, these shifts or expansions into nearshore coastal waters 

to target dolphin could compromise the current allocation of the dolphin resource 

between recreational and commercial user groups. Further, these shifts in effort in

the commercial fishery, dependent on the magnitude (knowing that some dolphin 

trips may land over 25,000 pounds in a single trip), could result in user conflict and 

localized depletion in abundance.

Objectives identified by the councils and addressed by this fishery management plan 

are as follows:

1. Address localized reduction in fish abundance. The Councils remain concerned 

over the potential shift of effort by longline vessels to traditional recreational fishing 

grounds and the resulting reduction in local availability if commercial harvest 

intensifies.

2. Minimize market disruption. Commercial markets (mainly local) may be 

disrupted if large quantities of dolphin are landed from intense commercial harvest 

or unregulated catch and landing by charter or other components of the recreational 

sector.
79

Table C-1 continued. Fisheries Management Plan (FMP) management objectives.

FMP Management objectives

Dolphin and 

wahoo (SAFMC 

2003) continued

3. Minimize conflict or competition between recreational and commercial user 

groups. If commercial longlining effort increases, either directing on dolphin and 

wahoo or targeting these species as a significant bycatch, conflict or competition 

may arise if effort shifts to areas traditionally used by recreational fishermen.

4. Optimize the social and economic benefits of the dolphin and wahoo fishery. 

Given the significant importance of dolphin and wahoo to the recreational sector 

throughout the range of these species and management unit, manage the resources to 

achieve OY on a continuing basis.

5. Reduce bycatch of the dolphin fishery. Bycatch is a problem in the pelagic 

longline fishery for highly migratory species. Any increase in overall effort, and 

more specifically shifts of effort into nearer shore, non-traditional fishing grounds 

by swordfish and tuna vessels, may result in increased bycatch of non-target species. 

In addition, National Standard 9 requires that: “Conservation and management 

measures shall, to the extent practicable, A) minimize bycatch and B) to the extent 

bycatch cannot be avoided, minimize the mortality of such bycatch.” Therefore, 

bycatch of the directed dolphin fishery must be addressed. Appendix C (FSEIS for 

HMS Regulatory Amendment 1) contains data on dolphin-wahoo pelagic longline 

fishery analysis. The data presented on page C-66 and in Table C-4 indicate that 

pelagic longlines targeting dolphin do in fact result in a bycatch of HMS species.

6. Direct research to evaluate the role of dolphin and wahoo as predator and prey in 

the pelagic ecosystem.

7. Direct research to enhance collection of biological, habitat, social, and economic 

data on dolphin and wahoo stocks and fisheries.

South Atlantic 

region snappergrouper fishery

(SAFMC and 

NMFS 2008b)

The council’s objectives for the snapper-grouper fishery are shown below. These 

were last updated in Snapper Grouper FMP Amendment 8 (SAFMC 1997).

1. Prevent overfishing.

2. Collect necessary data.

3. Promote orderly utilization of the resource.

4. Provide for a flexible management system.

5. Minimize habitat damage.

6. Promote public compliance and enforcement.

7. Mechanism to vest participants.

8. Promote stability and facilitate long-rub planning.

9. Create market-driven harvest pace and increase product continuity.

10. Minimize gear and area conflicts among fishermen.

11. Decrease incentives for overcapitalization.

12. Prevent continual dissipation of returns from fishing through open access.

13. Evaluate and minimize localized depletion.
80
81

Appendix D: Bibliography of Additional Sources

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Bell, F. W. 1988. Economic theory and efficient allocation of fishery resources. In Marine fishery 

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State.

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fisheries of the Miramichi River. Can. J. Agr. Econ. 44:165–71.

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24:206–220.

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FL, 19 May 1988. Southern Rural Development Center Pub. No. 111. Mississippi State 

University, Mississippi State.

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82

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Mississippi State.

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competing user groups in Virginia. Virginia Institute of Marine Science, 2000-05, Gloucester Pt., 

VA.

MAFMC (Mid-Atlantic Fishery Management Council) in cooperation with the Atlantic States Marine 

Fisheries Commission, the National Marine Fisheries Service, the New England Fishery 

Management Council, and the South Atlantic Fishery Management Council. 1991. Amendment 

2 to the Fishery Management Plan for the Summer Flounder Fishery, vol. 1. MAFMC, Dover, 

DE. Online at http://www.mafmc.org/fmp/pdf/SFSCBSB_Amend_2.pdf [accessed 18 February 

2011].

MAFMC (Mid-Atlantic Fishery Management Council) in cooperation with the Atlantic States Marine 

Fisheries Commission, the National Marine Fisheries Service, the New England Fishery 

Management Council, and the South Atlantic Fishery Management Council. 1996a. Amendment 

8 to the Summer Flounder Fishery Management Plan: Fishery Management Plan and Final 

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MAFMC (Mid-Atlantic Fishery Management Council) in cooperation with the Atlantic States Marine 

Fisheries Commission, the National Marine Fisheries Service, the New England Fishery 

Management Council, and the South Atlantic Fishery Management Council. 1996b. Amendment 

9 to the Summer Flounder Fishery Management Plan: Fishery Management Plan and Final 

Environmental Impact Statement for the Black Sea Bass Fishery. MAFMC, Dover, DE. Online 

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Environ. Econ. Manag. 6:127–139.
83

NMFS (National Marine Fisheries Service). 2010. NOAA catch share policy. Online at http://www

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of total allowable catch among commercial and recreational sectors in the Gulf of Mexico red 

grouper fishery: Charter boat model (draft). Southeast Fisheries Science Center, Social Science 

Research Group, Miami, FL.

NOAA (National Oceanic and Atmospheric Administration). 1987. Coastal migratory pelagic resources 

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Mexico, and South Atlantic; Reef fish fishery of the Gulf of Mexico; Amendment 30A. Federal

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Mexico, and South Atlantic; Snapper-grouper fishery off the southern Atlantic states; 

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0019-02, 9 April 2010] 75(68):18262–18353.

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Register [Docket No. 921230-3020, 22 January 1993] 58(13):5658–5660.

Rockland, D. B. 1988. User conflicts and blackened economic analysis: A case history of the red drum 

fishery in the Gulf of Mexico. In Marine Fishery Allocations and Economic Analysis: 

Proceedings of a Regional Workshop, Tampa, FL, 19 May 1988. Southern Rural Development 

Center Pub. No. 111. Mississippi State University, Mississippi State.

SAFMC (South Atlantic Fishery Management Council) and NMFS (National Marine Fisheries Service). 

2006. Final snapper grouper amendment 13C. SAFMC, North Charleston, SC. Online at 
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http://www.safmc.net/Portals/6/Library/FMP/SnapGroup/SG%20Amend%2013C%202-23-

06%20FINAL.pdf [accessed 18 February 2011].

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Carolina red drum fishery. Nat. Resour. Model. 11:241–71.

Schuhmann, P. W. and J. E. Easley Jr. 2000. Modeling recreational catch and dynamic stock 

adjustments: An application to commercial-recreational allocation. Land Econ. 76:430–447.

Sharma, K. R., and P. Leung. 2001. Economic impacts of catch reallocation from the commercial fishery 

to the recreational fishery in Hawaii. N. Am. J. Fish. Manag. 21:125–134.

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