Monday, January 23, 2012

Fleet Consolidation/ The List



By Southeast Revitalization Association

The Southeast Revitalization Association (“SRA”), pursuant to Title 50 of the

Code of Federal Regulations, Section 600.1107(e)(1) submits the following

Reduction Plan (“Plan”)1 to implement a fishing capacity reduction program

(“program”) for the Southeast Alaska Purse Seine Salmon Fishery (“fishery”).


The program was established under the Consolidations Act of 2005 (Section 209

of Title II of Division B of Public Law 108-447). This federal law was subsequently

amended by Section 121 of Public Law 109-479 (the Magnuson-Stevens

Reauthorization Act of 2006) codified at 16 U.S.C. §1801 et seq. The authority

for the SRA to conduct this program is Alaska Statute 16.40.250.

Based on these federal and state measures the National Marine Fisheries

Service (“NMFS”) established regulations in the Federal Register, Vol. 76, No.

194, October 6, 2011, to administer and implement the program.

The purpose of the program and this Plan is to permanently reduce the number

of limited entry fishing permits issued by the Alaska Commercial Fisheries Entry

Commission (“CFEC”) for the fishery thereby promoting economic efficiency and

improving the conservation and management of the fishery.

The regulations established by NMFS divide the program into six phases. The

SRA has certain unique roles relating to three of these phases: (1) Enrollment;

(2) Bid Selection; and (3) Plan Submission.

1 This Plan is generally modeled under portions of “Harvester Proponents’ Implementation Plan”

as provided under the Magnuson-Stevens Act, Section 312(e).



Under the enrollment phase the SRA is required to perform four separate duties

in preparation for submittal of the Plan.


On November 29 and 30, 2011, the SRA, pursuant to 50 CFR §600.1107 (c)(1),

sent a copy of the bid documents by certified mail to each holder of a valid entry

permit issued by CFEC to operate in the fishery.2


Pursuant to §600.1107(c)(3), the SRA specified a bid closing date of December

28, 2011.


The SRA contracted with the independent accounting firm of Elgee, Rehfeld,

Mertz, LLC in Juneau, Alaska, to assist in the Enrollment phase of the program,

including the collection and compilation of all bids and other supporting

documentation submitted by permit holders wishing to relinquish their permits.

Pursuant to §600.1107 (c)(2)(v)(A)&(B) the accounting firm also made an initial

determination whether the bid application conformed with the prescribed

requirements and notified bidders of non-conformity, if any.


The accounting firm received a total of seventy (74) conforming bid applications

during the prescribed enrollment period.3 Each of the bid applications was

recorded by date of receipt, permit holder’s name, permit number and bid

amount. The information and related documentation was transmitted to the SRA.

2 See affidavit of Rachel Agent marked as Exhibit A.

3 Three (3) of the bid applications were received be the accounting firm on December 29, 2011.

However, all documentation was executed within the enrollment period and the SRA deemed

these bids were timely received. This determination was also based, in part, on the aggregate

bid amount not exceeding the maximum loan ceiling.



Under the bid selection phase the SRA is required to perform five separate duties

in preparation for submittal of the Plan.


Pursuant to §600.1107(d)(3), the SRA ranked the 74 bids by using a reverse

auction format. The SRA ranked the bid with the lowest dollar amount first and

successively ranked each additional bid with the next lowest dollar amount. The

individual bid amounts ranked from a low of $175,000 to a high of $350,000. The

74 bids were in the aggregate amount of $15,817,980.


Consistent with §600.1107(d)(1)(i), the SRA, in consultation with CFEC,

examined each of the 74 bid applications for consistency, including the validity of

the permit and whether any authorized party held a security interest in the permit.


Pursuant to §600.1107(d)(4), the SRA accepted sixty-four (64) ranked bids with

an aggregate bid amount of $13,133,030, or an average of $205,204.4 As

required under §600.1107(d)(4)(e), SRA certifies that each of the ten (10) bid

applications not accepted contained a bid amount higher than $240,000.5


Pursuant to §600.1107(c)(4) the SRA, via certified mail, notified each of the 64

accepted bidders that their bid had been accepted and the effective date for their

agreement to relinquish a permit.

Pursuant to §600.1107(d)(4) the SRA transmitted to CFEC the Conditional Notice

form restricting the renewal and transfer of each of the 64 permits for which a bid

was accepted. The SRA also notified each of the non-accepted bidders by

regular mail.

4 See schedule of accepted bids marked as Exhibit B.

5 These 10 non-accepted bids totaled $2,684,500, or an average of $268,450, ranging from a low

of $248,000 to a high of $350,000. The SRA maintains acceptance of one or all of these bids

would be an excessive deviation from current fair market values, and, therefore, not costeffective.

See Section IV(A)(2)(a)(i) of the Plan. Moreover, the SRA maintains that acceptance

of bids in excess of $240,000 would result in a crucial segment of permit holders voting in the

referendum against the Plan.



Pursuant to §600.1107(e)(2), approval of the Plan requires a finding that the Plan

is (1) consistent with applicable provisions of federal law, and (2) will provide

increased harvesting productivity for post-reduction participants in the fishery.

The Plan satisfies both requirements as set forth below.


There are two separate federal laws authorizing this program: 1) the amended

Consolidated Appropriation Act of 2005 and 2) portions of the Magnuson-

Stevens Act codified at 16 U.S.C. 1801 et seq. Both of these laws are further

identified in Section 1 of the Plan.


The Plan is consistent with the amended Consolidated Appropriations Act of

2005 for the following reasons: (1) total program costs identified under the Plan

do not exceed $23,476,500; (2) the Plan provides the assessment (or industry

fee) cannot exceed a maximum three percent (3.0%) of the value of the fishery;

and (3) the SRA with the submittal of this Plan has fulfilled its respective role and

duties relating to the development and implementation of the program.


The enabling legislation, the Consolidated Appropriations Act of 2005,

authorizing this program waives many of the fishing capacity reduction program

requirements of the Magnuson-Stevens Act. There were a variety of reasons for

this waiver. Unlike other industry financed capacity reduction programs

undertaken by NMFS, this program involves no federal fishing permits. More

importantly, this program does not retire fishing history and places no restrictions

on the accepted bidder or how the vessel, if any, to which the relinquished permit

applies can be used in the future.

The enabling legislation does, however, provide that the program meet the

requirements of the Magnuson-Stevens Act, §312(b)(1)(C) and (2), which are:

1. Cost-Effectiveness;

2. Capability of repaying the loan; and

3. Achieving the maximum sustainable reduction in capacity at the least cost.



Cost-effectiveness is not defined is these regulations or the Magnuson-Stevens

Act, which complicates evaluation of this requirement. Typically, a costeffectiveness

analysis is a comparison of the relative cost-efficiencies of two or

more alternative ways achieve the objective—in this case improving the

harvesting productivity for the remaining permit holders participating in the

fishery. The SRA does not have a range of alternatives from which to select the

most cost-effective approach; and NMFS considered no other alternative other

than a no action alternative. By definition this program and the related Plan

provides only one approach to achieve a sustainable reduction in fishing

capacity. Without an alternative method, the analysis of cost-effectiveness

hinges solely on the question of whether the number of permits relinquished and

related costs under the Plan is worth doing.

The SRA maintains the answer to this fundamental question requires a two-part

analysis. First, is the total amount of accepted bids rationally related to the

current fair market value of permits? Secondly, is the reduction in fishing

capacity sufficient to warrant the cost and duration of the loan?


According to advertisements in commercial fishing trade journals and permit

broker websites, the current offering price for a permit ranges from $130,000 to

$135,000.6 State of Alaska records show for the period 2007-2010 the average

permit price has increased from $59,700 to $87,400.7 The SRA expects the

average 2012 permit price published by the State of Alaska will closely

approximate the average accepted bid amount of $205,204.

The recent increase in permit values is a function of four factors: (1) relatively

stable salmon production; (2) rising prices for Alaska salmon especially pink and

chum salmon; (3) reduced number of inactive permits8; and, (4) the upward

speculation fueled by the potential approval and ultimate implementation of the

subject Plan.

The present fair market value is predicated on a total of 379 permits. If the Plan

is approved and subject to a successful referendum, 315 permits or 83.1% of the

existing permit total will remain eligible to participate in the fishery. The SRA

maintains this reduction will result in a substantial increase in the fair market

value of the remaining permits to a level equal or greater than the average

accepted bid amount.

6 Pacific Fishing Magazine, December 2011 and websites of vessel/permit brokers, Dock Street

Brokers and GSI Company, based in Seattle , Washington.

7 See CFEC Basic Information Table—

8 The SRA previously purchased 35 permits under a 2008 State of Alaska program with federal

grant funds. The average accepted bid amount was $82,020.



(a) Loan Terms

The Plan will utilize a principal loan amount of $13,133,030. The loan will bear

interest at an estimated initial rate of 5.125% per annum. 9 The final interest rate

will be fixed at the end of the 2012 federal fiscal year and will not vary over the

remainder of the loan term. The SRA maintains this very favorable interest rate,

which will be the lowest ever provided under a NMFS funded reduction program,

is a major factor supporting the cost effectiveness of the program. As authorized

under the enabling legislation, the loan shall be amortized over a forty (40) year

term. The annual debt service would be $778,513.

The SRA concedes this analysis is limited in scope and is inherently

complicated.10 The three key components employed by the SRA in projecting

the duration of the loan are (1) future harvest volumes; (2) species composition;

and (3) ex-vessel price. Each of these components can and do vary from year to

year, especially harvest volumes. The SRA has attempted to consider each of

these components and the related commonalities in making its projection.

(b) Prior Harvest Volumes and Future Harvest Projections

The SRA maintains the recent 12 year period 2000-2011 is the most appropriate

measurement of time to project future harvest for the duration of the loan period.

The average annual harvest during this period was approximately 175 million

pounds. Annual harvest during this period ranged from a low of 95 million

pounds, to a high of almost 264 million pounds this past fishing season. The

SRA projection was favorably influenced by poundage falling below 100 million

pounds in only two of the years. This indicates that although annual production

may fluctuate, the collapse of the Southeast salmon populations is highly


9 The interest rate is the U.S. Treasury’s cost of borrowing equivalent maturity funds plus two

percent. A thirty (30) year treasury, which is the nearest equivalency, currently is paying 3.125%.

10 The volatility of such projections is most clearly evidenced by the 2005 report on projected exvessel

earnings for the fishery prepared by the McDowell Group in Juneau, Alaska and funded by

NOAA Fisheries, Alaska Region. This report projected a 40-year average pink and chum exvessel

price of $0.16 and $0.21, respectively.


Year Total Pounds

2000 141,311,987

2001 251,148,561

2002 171,339,251

2003 212,141,903

2004 207,090,560

2005 226,693,325

2006 96,076,388

2007 185,269,369

2008 95,024,646

2009 139,056,463

2010 112,494,356

2011 263,981,481

TOTAL 2,101,628,290

Annual Average 175,135,690

(c) Prior Harvest Composition by Specie and Future Composition Projections

In terms of poundage, pink salmon are the single largest component of harvest in

the fishery. Chum salmon comprise the second largest component followed by

sockeye, coho and chinook salmon. Estimating the future harvest composition is

challenging given that pink salmon harvest is based on production within literally

thousands of watersheds throughout the Southeast region, while most chum

production comes from enhanced hatchery-reared fish. For consistency

purposes, the SRA draws upon the most recent 12 year average (2000-2011) to

project the following future harvest composition by specie and poundage.11

Pink Chum Sockeye Coho Chinook

76.0% 20.0% 2.0% 1.6% 0.4%

Based on these projections the SRA estimates the annual harvest will be

distributed as set forth in the following table:

Specie Percentage Poundage

Pink 76.0% 133,300,000

Chum 20.0% 35,000,000

Sockeye 2.0% 3,500,000

Coho 1.6% 2,800,000

Chinook 0.4% 700,000

TOTALS 100.0% 175,000,000

11 See 2010 Alaska Fish & Game Annual Management Report; Table 1, page 58. See also Fish

& Game 2011 salmon harvest estimates by gear in the Southeast Alaska fisheries.


(d) Ex-Vessel Price Projections

Unlike the future harvest and species composition projections set forth above,

the SRA maintains it is not appropriate to consider the most recent 12 year

average to project future ex-vessel prices. Alaska salmon prices have seen

considerable appreciation during the last five years (2007-2011), especially pink

and chum. Over this time period the ex-vessel price of pink and chum in the

fishery have increased from $0.21 and $0.39 to $0.45 and $0.90, respectively.12

This increase has occurred despite record harvest levels.13 The SRA maintains

the reason for this continued upward trend despite an increasing supply is that

Alaskan pink and chum salmon are the most cost-effective salmon options in the

world market.14

The traditional high-value species make up only four percent (4%) of the harvest.

During the last five years the ex-vessel price per pound of sockeye has average

$1.25 while the coho and Chinook price has averaged $1.00 and $3.00 per

pound, respectively.15

Based on these averages and future market conditions, the SRA maintains that

the ex-vessel price per pound for the fishery will stabilize for the duration of the

loan period at the following levels. The SRA projection further assumes inflation

will have a zero impact on ex-vessel values.16

Pink Chum Sockeye Coho Chinook

$0.40 $0.75 $1.25 $1.00 $3.00

(e) Projected Ex-Vessel Value of the Fishery

Based on the foregoing, the SRA projects the average annual value of the fishery

for the duration of the loan period will be $80,430,000 as set forth in the following


12 See Alaska Department of Fish & Game website Information by Fishery.

13 The 2009 Russian pink salmon harvest reached a record 924 million round pounds. For

context, Alaska’s average harvest of pink salmon for the period 2007-2011 was 386 million

pounds The 2011 Russian pink harvest is estimated at nearly 900 million pounds with a 395

million pound harvest in Alaska.

14 There are growing markets for frozen pink and chum salmon, particularly pin-boned fillets and

other value-added products. Shifting demographics and better access to food information is

driving consumers to buy salmon. Consumers emphasize cost and ease of preparation, which is

a favorable position for frozen pink and chum salmon from Alaska. Alaska Seafood Marketing

Institute, Seafood Market Bulletin, Summer 2011.

15 See footnote 11.

16 This is a very conservative component of the projection given inflationary trends and the rise in

commodity prices and demand for salmon in the world’s developed nations.


Specie Poundage Price Ex-Value

Pink 133,300,000 $0.35 $46,655,000

Chum 35,000,000 $0.70 $24,500,000

Sockeye 3,500,000 $1.25 $4,375,000

Coho 2,800,000 $1.00 $2,800,000

Chinook 700,000 $3.00 $2,100,000

TOTALS 175,000,000 $80,430,000

(f) Projected Annual Assessment or Industry Fee

Based on the projected ex-vessel prices and a maximum three percent (3.0%)

assessment, the fishery will on average annually generate $2,412,900.

(g) Projection of Loan Amortization and Pay-Off

Annual assessment revenue of $2,213,012, which is almost $200,000 less than

the amount estimated by SRA for the fishery, will allow for repayment of the loan

in six (6) years, or by October 2018.17 The projected amortization schedule is set

forth in the following table:18

Date Payment Principal Interest Balance

06/01/2012 -0- -0- -0- $13,133,000

10/01/2012 -0- -0- $224,355 $13,357,355

10/01/2012 $2,213,012 $2,213,012 -0- $11,144,343

10/01/2013 $2,213,012 $1,628,256 $584,756 $9,516,087

10/01/2014 $2,213,012 $1,713,692 $499,320 $7,802,395

10/01/2015 $2,213,012 $1,803,611 $409,400 $5,998,784

10/01/2016 $2,213,012 $1,898,249 $314,763 $4,100,534

10/01/2017 $2,213,012 $1,997,852 $215,160 $2,102,682

10/01/2018 $2,213,012 $2,102,682 $110,330 -0-

TOTALS $15,491,084 $13,357,35519 $2,133,729

17 Pink salmon are the single largest harvest component in the fishery. The year-to-year harvest

of pink salmon varies widely and the variation has a predictable pattern based on the two-year life

cycle of the fish. The harvest in odd-numbered years is typically much stronger than in evennumbered

years, owing to the abundance of the parent year fish. For example, the offspring of

the large pink salmon numbers that spawned in 2011 will return to the spawning grounds in 2013,

their off-spring return in 2015. The first year of the assessment will be 2012—an even numbered

year. Consequently, the 2012 harvest poundage and ex-vessel value of the fishery will likely fall

below the average projected under the Plan. For this reason, the amortization schedule applies a

number less than the SRA projection to offset this likely first year shortfall.

18 The schedule assumes reduction payments will be received by accepted bidders on June 1,

2012 and the first year assessment will be transmitted by October 1, 2012.

19 This principal amount includes$224,355 in additional interest from the projected date of the

reduction payments to transmittal of the 2012 assessment.


iii. Summary

The SRA maintains reduction in fishing capacity is necessary. The Plan is costeffective

for two overriding reasons: (1) The average price of the 64 accepted

bids is reasonably related to current market valuations and the fair market price

the SRA maintains will exist post-implementation of the Plan. (2) The projected

duration and cost of the loan, considering the interest rate and current value of

the fishery, is consistent with the reduction in fishing capacity achieved under the



The Magnuson-Stevens Act, §312(b)(ii)(C) requires a showing that the program

is “prospectively capable of repaying any debt obligation” incurred under the

Plan. This requirement is fully satisfied considering the projected loan

amortization and pay-off analysis contained in Section IV(A)(2)(a)(ii)(g) of the

Plan. In fact, reducing the rate from 3.0% to only 0.97% would still generate an

annual assessment sufficient to repay the loan within the prescribed term.20

Moreover, the Plan utilizes only 55.9% of the maximum loan ceiling.


The Magnuson-Stevens Act, §312(b)(2) requires the program to achieve the

maximum sustained reduction in a minimum period of time. The SRA maintains

this requirement is satisfied by the very nature of the program and that fishing

permits are permanently relinquished. Unlike other federal capacity reduction

programs, under this Plan there is no buyback of fishing history or quota and

there is no restriction on the vessel, if applicable, to which the relinquished permit

applies. Therefore, each permit, including currently inactive or latent permits,

constitutes additional, if not equal, fishing capacity. The only constant

measurement of fishing capacity in the fishery is the fishing permit. By definition,

therefore, relinquishing 64 of the 379 permits is equal to a 16.9% permanent and

sustainable reduction in fishery capacity.21The Plan does not immediately

achieve maximum sustainable reduction in capacity. To achieve that objective,

without consideration of cost-effectiveness, the SRA would need to accept the

ten (10) non-accepted bids described in Section III(C) of the Plan. 22

20 This reduced rate would generate an annual assessment of $778,513. See Section

IV(A)(2)(a)(ii)(a) of the Plan.

21 CFEC may issue additional permits in the future if the fishery becomes too exclusive. This

would require CFEC to conduct an “optimum number” study before any decision could be made

on whether the fishery had become too exclusive. The SRA thoroughly considered this possibility

before electing to submit the Plan.

22 The Plan provides for a $13,133,030 loan amount. The remaining $10,343,470 would be

available for future reduction payments as part of a later, separate Reduction Plan. See 50 CFR

Section 600.1107(f)(1). The Plan does not consider what percentage of additional reduction can

be achieved with the remaining funds.




As is the case with cost-effectiveness, increased harvest productivity is not

defined in these regulations or the Magnuson-Stevens Act. As a rule, harvest

productivity would be defined as the volume or pounds of salmon harvested in

the fishery divided by the fishing time required to harvest the salmon. Under

such a definition productivity would be measured by the volume of fish available

and the efficiency of the harvesting vessel. There is no question that the size and

design of today’s purse seine vessel is resulting in greater “harvest” efficiency.

However, the “productivity” of the vessel is more closely related to the volume of

fish available to harvest rather than the number of permits participating in the

fishery. For these reasons, the term “increased harvest productivity” may not

properly capture the primary objective of the program. Rather, the pivotal

question is whether after implementation of the program will the individual permit

holder participating in the fishery have the opportunity to catch a relatively

greater percentage of the available salmon harvest?

This can be a complicated and somewhat subjective question since it requires

future forecasting in an industry that is historically fraught with uncertainty. The

SRA again starts from the proposition that each fishing permit represents a

potentially equal increment of fishing capacity.23 The SRA analysis also

considered a review of participation in the fishery for the 1997-2011 time period

as set forth in the following table combined with a projection of future

participation. 24

Year Permits Issued Permits Fished

1997 415 351

1998 415 377

1999 415 359

2000 415 356

2001 414 345

2002 413 273

2003 416 235

2004 414 209

2005 415 232

2006 414 230

2007 415 237

2008 380 212

2009 379 256

2010 379 235

2011 379 277

23 This proposition is further supported by the program containing no limitation or restriction on

the rights of an accepted bidder to relinquish a permit and then purchase another permit to

participate in the fishery.

24 See CFEC Basis Table Information, footnote 7.


Participation has trended upwards since 2005 with greater increases occurring in

the odd number years. Participation increased by 2.2% from 2005 to 2007; 8.0%

from 2007 to 2009 and 8.2% from 2009 to 2011. This increased participation is

directly related to rising ex-vessel prices. However, other factors are promoting

increased participation.

There is an ever growing demand for wild Alaska salmon. Not until 2008 did

salmon processing companies and other buyers stop restricting their purchases

of pink and chum salmon in the fishery. The SRA assumes this was in response

to processing capacity limitations or depressed prices resulting from oversupply.

Today these same processing companies and new entrants are increasing

processing capacity. There is now excess processing capacity in the fishery.

Consequently, these companies are aggressively seeking to introduce more

harvesting capacity into the fishery reasoning the need to have more harvesting

vessels to maintain their current share of the available harvest.25

Fishermen are diversifying. Participation in multiple fisheries has become a

simple economic fact. Fishermen generating solid revenue in one fishery are

constantly analyzing the cost and benefit of investing and participating in a new

fishery. SRA maintains many fishermen with no prior participation in the fishery

are preparing to invest and periodically participate in the fishery.

The fishery is biologically strong. For the past 20 years, escapements have been

at historical high levels for pink salmon. Harvest is rarely constrained by poor

escapement. Today, annual production is dependent mostly on over-wintering

and climate ocean conditions. Although salmon runs will fluctuate, the collapse

of a stock is unlikely because of intense in-season management requiring

adequate escapement before commercial harvest. Moreover, freshwater rearing

habitat is intact and will remain that way given the Alaska’s current regulatory


The SRA maintains that within the next 3-5 years every now inactive or latent

permit will be owned by an active fishermen or otherwise controlled by a

processing company or other fishery related entity. The SRA cannot maintain

with certainty that reducing the total number of permits by 16.9% will result in an

immediate increase in the percentage of harvest taken by those remaining

participants in the fishery. The SRA does, however, maintain that the 16.9%

reduction will lessen the possibility that latent permits will be activated thus

minimizing further reductions in harvest levels or percentages to be enjoyed by

remaining participants in the fishery.

25 This can take variety of forms. Processing companies are now offering loans to new

fishermen seeking to enter the fishery or providing financing to existing participants for vessel

improvements. Companies are now more closely examining regional salmon forecasts and

encouraging fishermen to operate in areas where they believe more production is available.

Companies may also encourage or require participation in the fishery as a condition to offering

those fishermen markets in other regions or for other seafood harvest.



CFR TITLE 50, SECTION 600.1107(c)(1) and (4)




Rachel Agent being first duly sworn upon oath, deposes and says:

I am over the age of 18 years and presently employed by Seine Management

Services, Inc., (SMS) a Washington corporation doing business at 1900 West

Nickerson Street, Suite 320, Seattle, Washington 98119. SMS has entered into

a contract with the Southeast Revitalization Association (SRS) to provide certain

clerical and administrative services relating to the development of a fishing

capacity reduction program for the Southeast Alaska purse seine salmon fishery.

On or about November 29th and 30th, 2011, I placed in an envelope a true and

correct copy of each of the following documents:

1. Bid--Appendix A

2. Relinquishment Contract—Appendix B

3. Conditional Notice —Appendix C

4. Conditional Relinquishment—Appendix D

5. Self-addressed return envelope

6. Explanatory letter to complete the documents.

The SRA provided me with the foregoing documents and instructions to contact

the Alaska Commercial Fisheries Entry Commission (CFEC), which provided me

with the current name and address of each of the 379 permit holders. The CFEC

provided me with an electronic version of the names and address from which I

generated mailing labels.

Our postage supplier, Pitney-Bowles, provided me 378 sequentially numbered

certified mailing labels starting with 91 7108 2133 3939 3866 8750. I placed a

single label on 378 separate envelopes. I deposited 375 of the envelopes with

sufficient postage for certified mailing in the United States Mail. I deposited two

(2) envelopes with sufficient postage for mailing to two (2) permit holders who are

Canadian residents. I personally delivered the remaining envelope to a dual

permit holder.

On January 20, 2012 the SRA supplied a list of the 64 permit holders identified in

Exhibit B of the Plan and a letter notifying of acceptance and the effective date of

the Bid agreement.. I and my co-workers deposited the letters with sufficient

postage for certified mailing in the United States Mail to each of these 64 permits

holders at the address listed in their bids. The SRA also provided us with a list of



CFR TITLE 50, SECTION 600.1107(d)(4)

Last Name First Name Permit No.



1 Krigbaum Michael S01A58031W 175,000

2 Jensen Douglas S01A59714N 180,000

3 DeGroen Johnny S01A58505S 185,000

4 Michael Mercury S01A55386C 185,000

4 Reimnitz Hartmut S01A578995 185,000

6 Zuanich Michelle S01A57849F 185,000

7 Veerhusen Daniel S01A56638X 189,000

8 Hansen William S01A55442A 191,000

9 Svensson John S01A56492N 191,000

10 Gruenheit Michael S01A55083V 193,000

11 Jolibois Timothy Larry S01A56018A 194,000

12 Spearin James S01A59372G 194,973

13 Jurlin Marie S01A58547R 195,000

14 Nash Paul S01A57907M 195,000

15 Reifenstuhl Ivan S01A55171A 195,000

16 McGee Gary S01A56559 196,000

17 Christensen Dale S01A60803V 196,500

18 Finney Paul S01A64933S 197,000

19 Haldane Robert S01A56620L 197,000

20 Kvernvik Carolyn S01A55231R 197,000

21 McLean John S01A56270P 197,000

22 Tarabochia Dominick S01A56600P 197,000

23 Wills Charles S01A58070V 197,000

24 Zuanich Michelle S01A568811 197,000

24 Beritich Mitchell S01A58923M 197,200

26 Barrett Davis S01A58501W 197,202

27 Marrese Andrew S01A57909W 197,202

28 Markusen Kenneth S01A55584K 198,000

29 Scudder Bradley SO1A56000N 198,000

30 Schonberg Peter S01A56601I 199,000

31 Bill David S01A58338U 199,500

32 Manos Andrew S01A59222I 199,990

33 Nugent Matthew S01A55689G 199,999


34 Hanson Jeff S01A57976 200,000

35 Johns Justna S01A55403 200,000

36 MacDonald Clifford S01A55545L 200,000

37 Olney Virginia S01A57720 200,000

38 Suydam Antril S01A57910N 200,000

39 Kohlase Ernest S01A56199V 201,500

40 Mann Bruce SO1A56187 205,000

41 Haltiner Fred S01A55617L 207,000

42 Marvin-Denkinger Victoria S01A58429X 209,000

43 Krieger Kenneth S01A59613M 209,000

44 Rocheleau Rick S01A58478 209,000

45 Menten Erik Keller S01A57726X 209,500

46 Fanning Christine S01A60909J 209,800

47 Wallace Bruce S01A55827B 214,000

48 Thorstenson Peder S01A59806J 215,000

49 Alfieri Joe S01A60791I 220,000

50 Sorensen Paige S01A58511U 223,000

51 Demmert Nicholas S01A56948W 223,875

52 Wamser William S01A60071B 224,000

53 Buschmann Ronn S01A55479D 224,500

54 Dontos Larry S01A59705K 224,900

55 Botsford Wallace S01A63175B 224,989

56 Manos Thomas S01A60642C 225,000

57 Schonberg Mart S01A56882A 225,000

58 Alfieri Anthony S01A55646M 229,000

59 Maricich Timothy S01A59569W 229,900

60 Selivanoff Douglas S01A57856A 230,000

61 Pfundt Michele S01A56392F 235,000

62 Peterman Chad S01A55986F 237,000

63 Haynes Bradley S01A574950 237,500

64 Blair Andrew S01A59085F 240,000

TOTAL 13,133,030

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