We’re writing to share a timely opportunity to support bycatch reductions, gear flexibility, community provisions and access opportunity.
We are asking our allies to submit comments to the North Pacific Fishery Management Council on the topic of Final Action on the Bering Sea/Aleutian Island Trawl Cod Cooperative program by 5pm AKST on Wednesday, September 29th.
It is important that the Council hear a wide range of input. While the Council’s decision is primarily about comprehensive management of Pacific cod caught by trawl vessels in the Bering Sea, program components impact diverse Alaskan fishing communities, habitats and resources including user groups harvesting halibut and crab. The full document contains a comprehensive review, including a preferred preliminary alternative (PPA) identified by the Council.
Policy makers on the North Pacific Fishery Management Council need to hear from the public that responsible management of our common goods includes use of all available tools to reduce waste and habitat impacts when developing a new catch share program. While there are many matters in the Bering Sea environment over which people have little control, decisions to reduce bycatch and provide flexibility through voluntary gear conversion from trawl to pot gear are not.
Keep reading to learn more, and click below to access the comment portal. Thank you for your help!
Click “Comment Now” Next to Agenda Item C4. Comments that have been submitted are not posted publicly until after the comment deadline has passed.
Background
The North Pacific Fishery Management Council is scheduled to take final action in October on a Pacific Cod Trawl Cooperative (PCTC) Catch Share program for trawl vessels in the Bering Sea/Aleutian Islands. At this meeting, the topic is agenda item C4.
The purpose and need statement driving development of the new program includes: a cooperative-based program intended to improve overall harvest, quality and value of the trawl sectors allocation of Pacific cod, allocation of quota shares to harvesters and processors based on history during the qualifying years, improving safety, minimizing bycatch and providing for sustained participation of fishery dependent communities. There are 14 elements and options shaping the final program.
Provide written comments to the Council, including background on who you are and why you care. Please consider these points for your comments:
Element 3: Prohibited Species Catch Limits (Bycatch Reduction)
Include meaningful reductions of halibut and crab bycatch
A 35% reduction of halibut bycatch, the maximum amount under consideration for use in the catch share program, is a reasonable and an expected outcome of this program to provide widespread benefits.
The program should benefit struggling Bering Sea crab stocks as well and there should be at least a 35% reduction of crab bycatch in the program.
National Standard 9 of the Magnuson-Stevens Act, which is the guiding legislation for the Council, states that a Council shall “take into account conservation and management measures that shall, to the extent practicable, minimize bycatch.” (Regarding the practicability standard of National Standard 9, the BSAI Pacific cod trawl fleet operated under a voluntary cooperative harvest plan for two seasons, 2020 and 2021, and successfully reduced halibut bycatch by an average of 75% – well beyond the reductions under consideration of 10% to 35%. Under the voluntary cooperative agreements, the fleet avoided fishing at night, stood down during periods of high bycatch, used gear modifications and coordinated with processors.)
The development of catch share programs provide significant opportunities to reduce bycatch of species important to other user groups.
Coastal communities are dependent on halibut and crab, and it is the responsibility of the State of Alaska and the Council to conserve these resources and their cultural, recreational and commercial values to Alaska halibut fishermen, processors, visitors and consumers alike.
Thousands of families, businesses and communities depend on the health of halibut and crab.
A comprehensive catch share program which includes additional tools and minimizing bycatch to the extent practicable is an objective of the program identified in the purpose and need statement.
Element 14: Gear Conversion
Allow for use of pots to harvest cooperative quota
This provides an option for harvest flexibility with many potential benefits to the Nation including: increased product value, harvest efficiency, reduced carbon footprint, lower bycatch, and more.
Bycatch rates of halibut in pots are substantially less than bycatch rates in cod trawls.
Voluntary gear flexibility through the gear conversion element meets the purpose and need statement driving the action and provides flexibility in a changing ocean climate.
Element 2: Allocation to LLP licenses
Leave C season unallocated
The trawl sector has not historically harvested this quota, and instead it has been regularly transferred to other sectors, particularly pot sectors. Leaving this season at status quo prevents additional negative downstream impacts of this program on other sectors.
Element 6: Aleutian Island Processor Provisions
Include provisions for Aleutian Islands harvest and processing that results in meaningful processing capacity in the Aleutian Islands
This is important to: take into account the importance of fishery resources to fishing communities in National Standard 8, support the ongoing harvest of important state and federal Aleutian fisheries, to promote safety and stability of such fisheries, many including smaller boats and to increase spatial distribution of Pacific cod and associated halibut bycatch which has significantly lower bycatch rates in the Aleutians.
