
Heather Mann
359:15 - 360:35
"Section 303, and I do have an attachment if you can put it up, um, does say that when establishing a limited entry, a limited access privilege program, a council shall develop a methodology methodology and the means to identify and assess management, data collection, analysis, and enforcement costs directly related to the program. Yet during the development of Amendment 122, I do not recall the council ever developing or debating a methodology for identifying recoverable costs, allocating those costs among participants, or determining how OLE costs would be attributed to the the program."
“Section 303, and I do have an attachment if you can put it up, um, does say that when establishing a limited entry, a limited access privilege program, a council shall develop a methodology methodology and the means to identify and assess management, data collection, analysis, and enforcement costs directly related to the program. Yet during the development of Amendment 122, I do not recall the council ever developing or debating a methodology for identifying recoverable costs, allocating those costs among participants, or determining how OLE costs would be attributed to the the program.”
What methodology was used to determine what costs were directly related to and in support of the PCTC program? These are all reasonable questions, and unfortunately we have not got clear answers. As someone who was directly involved in the development of this PCTC program, I have another concern, and Glenn talked a little bit about this before, but Section 303, and I do have an attachment if you can put it up, um, does say that when establishing a limited entry, a limited access privilege program, a council shall develop a methodology methodology and the means to identify and assess management, data collection, analysis, and enforcement costs directly related to the program. Yet during the development of Amendment 122, I do not recall the council ever developing or debating a methodology for identifying recoverable costs, allocating those costs among participants, or determining how OLE costs would be attributed to the the program. The council did spend years discussing allocations, structures, processor participation, sideboards, ownership caps, many other important elements of the program, but we did not have a comparable process devoted to developing the cost recovery methodology contemplated by MSA.