The North Pacific Fishery Management Council is meeting in Seattle from February 5-12, 2024 and we need you to write a comment and/or testify to protect Tanner crab!

Alaska Marine Conservation Council and Tanner crab fishermen are asking the North Pacific Fishery Management Council to move the Gulf of Alaska Tanner Crab Protections discussion paper (also located here) to an “Initial Review”. It is important that they hear directly from organizations and individuals about the importance of this fishery to Kodiak and coastal communities in the Gulf of Alaska (GOA).

Please take the opportunity to share written comments here under agenda item D2, GOA Tanner crab protections, by February 2 at noon AKT. Scroll down to agenda item D2 and select “submit comments.” You can type directly into a text box or attach a document.

Written testimony can be 3-4 sentences, highlighting just a couple of ideas, or you can submit several pages. Points to consider for comments:

​

• Share information about the fisheries you participate in, your homeport and your dependence on commercial fishing.

• If you participated in the 2024 fishery, highlight your recent participation in the Tanner crab fishery and share some insight on the importance of the fishery to the community-based fleet.

• Highlight how the commercial Tanner crab fishery provides an important source of revenue to Alaska fishermen and Alaska communities in the winter and helps to maintain small boat fishermen during a time when there are limited fishing opportunities.  

• Highlight the economic value of the directed crab fishery. While prices are down globally for many species, crab remains viable and the value is of increased significance for the fishermen.

• The fishery is designed to benefit community-based fishermen and to minimize the impact on crab stocks with low pot limits and daylight only fishing which minimizes exposure of the crab to cold winter nights.

• In 2023, approximately 130 boats harvested over 5 million pounds of crab worth over 18 million dollars. 

• In 2024, approximately 135 boats harvested nearly 3 million pounds of crab worth over 10 million dollars.

• Recruitment events in the Kodiak Tanner Crab Fishery provide for multiple years of harvest opportunity which fishermen should be able to count on.

• Since the fishery re-started in 1997, the fishermen have championed conservation with threshold limits for openings, conservative quotas and limited pot pulls.

• As Tanner crab fishermen, we have worked to conserve the resource for the past 26 years and we’re asking the Council to consider regulatory changes that would require other fishermen to share the responsibility of protecting these iconic species in their preferred habitat.

• The Council has enacted numerous protections for crab in the Bering Sea Aleutian Island region, it is long past due to establish meaningful crab protections from the impacts of bottom trawling in known crab habitat.

​

About the Areas:

​

• Statistical areas 525702 and 525630 on the Eastside of Kodiak Island represent known Tanner crab habitat and associated abundance which is supported by annual ADF&G trawl survey data. 

• From 2013-2023 an average of 49% of all mature female Tanner crab, 47% of all mature male Tanner crab and 41% of all legal male Tanner crab abundance in the Kodiak District was estimated from statistical areas 525702 and 525630. Roughly 30% of total mature Tanner crab abundance was estimated in the single federal waters statistical area 525702. (See graphic below.)

• These statistical areas represent some of the highest density of Tanner crab in the State of Alaska and quite possibly the world, these crabs spend their entire life cycle in the Eastside region.

• Subsequent analysis should include statistical area 535632 in the Southeast Section of the Kodiak District. This region lies between State water closure area 535634 and 525630 and State of Alaska survey data found on page 18 of the Gulf of Alaska Tanner Crab Protections discussion paper shows high abundance of Tanner crab of both sexes in all stages of life. The proximity of the Tanner crab in this region to previously identified areas of concern warrant further exploration of the importance of this area to Tanner crab. In addition, this statistical area is within the Horse’s Head type 3 closure area which is only triggered by Red King Crab recruitment events despite the area’s importance to Tanner crab.

• Tanner crab are more vulnerable during molting and mating. It is common for ADF&G to see large-scale Tanner crab molting events around Kodiak from February until early May and mating aggregations occur toward the end of that timeframe in mid-May.

• In the spring there is an increased biological importance as the crab are concentrated together.

• There is a summer ADF&G trawl survey and a directed Tanner crab winter fishery with a strong correlation, AD&G crab biologists know with 100% confidence where the crab are and the value to the crab of this habitat.

• The habitat features, including infauna, in areas with longstanding crab abundance are important features to support the crab population and the biodiversity of the habitat must be protected. These unique features are subject to structural changes with ongoing bottom trawl effort.

• April is a slow month for the trawl fleet between the prosecution of pollock and Pacific Ocean Perch fisheries and these same statistical areas, 525702 and 525630, are used by the trawl fleet for flatfish fisheries.

• In 2019-2023 the Shallow water flatfish grouping of Flathead Sole and shallow water flatfish contributed to most of the Tanner crab bycatch estimates with 84% attributed to statistical areas 525630 and 525702 as compared to all of the Central Gulf of Alaska.

• Total Tanner crab bycatch (in numbers caught) in the groundfish catch in statistical areas 525630 and 525702 was highest with non-pelagic trawl and lowest with pot gear.

• In 2019-2023, statistical areas 525630 and 525702 were subject to non-pelagic trawl efforts targeting arrowtooth and shallow water flatfish for 12 months out of the year.

• The trawl fishery is a low-value, high-volume federally managed fishery impacting a much higher value State managed fishery that has over 130 participants.

• There are areas outside the statistical areas with high abundance of Tanner crab where the non-pelagic trawl fleet can pursue their harvest.

• MSA National Standard 9 regarding reduced bycatch encourages the Council to reduce bycatch to “the extent practicable”.  It IS practicable to avoid fishing low value flat fish on top of the highest densities of Tanner crab in the State of Alaska to protect these high value Tanner crab.

• While it is important to develop Electronic Monitoring protocols and/or 100% observer coverage for trawl vessels as a means of helping to better assess Tanner crab and other bycatch interactions in these areas, it’s not enough just to “monitor” the bycatch.  The crab need protection!

• Kodiak Tanner fishermen wish to work together with both the State of Alaska and the National Marine Fisheries Service in a proactive manner and establish measures to protect Tanner crab in regions with high abundance. We know where the crab is, let’s do something to protect them.

 

Oral comments can also be provided in person or via remote testimony through the agenda item D2 on the Council's website. GOA Tanner crab protections is currently scheduled to come before the advisory panel on February 8 and the Council on February 11. To access the meeting virtually, visit the Council's website here.

For more information, please call, email or text Theresa Peterson or Julie Kavanaugh:

theresa@akmarine.org - cell phone (907) 539-1927

jkavanaugh9382@proton.me - cell phone (907) 942-0058
 

See the attached graphic below which illustrates the number of Tanner crab per kilometer towed in the ADF&G Trawl survey conducted in 2022 with statistical areas 525630 and 525702 overlaid: