We are asking the North Pacific Fishery Management Council to restate that an objective of the Pelagic Trawl Gear definition is to prevent trawl operations on the sea bed, and to prioritize initiating revisions to the performance standard which provide enforceable accountability to this objective.

Please take the opportunity to share written comments here under agenda items C2 and D1 which are both related to the issue of pelagic trawl gear and how it is intended to be used, by February 2 at noon AKT. Scroll down to agenda items C2 and/or D1 and select “submit comments.” You can type directly into a text box or attach a document.

PROCESS: Agenda item (C2) Bristol Bay Red King Crab (BBRKC) closures will be discussed first, while item (D1) Pelagic Trawl Gear will appear after the BBRKC discussion concludes. Pelagic gear definition and sea floor contact is a key theme in both agenda items.

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

Overall
 

• To effectively limit contact with the seafloor by pelagic trawl gear, the Council should consider a revised gear performance standard that includes modern technology integration to quantify bottom contact, including camera and sensor technologies. Until this concept is proven to be effective and enforceable, the Council should list pelagic trawl under the definitions of “bottom contact gear” and “mobile bottom contact gear." This will serve to protect critical habitat, maintain consistency with other Council objectives and bring the definition of Pelagic Trawl Gear into alignment with the definitions in Alaska state waters and fisheries off the West Coast.

• The Bering Sea Aleutian Island Fishery Management Plan (FMP) for groundfish states non-living structures may be more affected by pelagic trawl footropes than by bottom trawl footropes because of the continuous contact and smaller, more concentrated surfaces over which weight and towing force are applied.

 

(C2) BBRKC Initial Review Section 8 Discussion: Trawl Gear Performance Standard pg 179
 

• The current pelagic trawl performance standard is not an effective tool to assess or limit seafloor contact.

• Section 8.4, Council Direction (from the Office of Law Enforcement) states: “If, however, the Council is interested in achieving the operative objective of the performance standard, ‘by discouraging or preventing trawl operations on the sea bed,’ based on the information in this analysis, the current pelagic trawl performance standard is not an effective tool to limit seafloor contact and an enforceable trawl performance standard is needed. Noting the substantial bottom contact by the gear type currently reported/defined as pelagic by the Fishing Effects model, the Council should clearly articulate objectives specific to seafloor contact.”

• A clarification to the purpose and need statement is needed in order to clarify new objectives to deter seafloor contact (as stated in the original objectives) and protect habitat beneficial to recruitment, and reduce unobserved mortality of BBRKC.  

• These objectives may then be analyzed for potential modifications to the performance standard, gear definitions, electronic monitoring, spatial management or other management measures. 

• Office of Law Enforcement states:  Enforcement of any performance standard for pelagic trawl is fully reliant on the definition of the gear type. A gear definition that is enforceable is preferred to enable real-time enforcement.  

• Modify the existing standard for the Bering Sea/Aleutian Islands and Gulf of Alaska. Simple and uniform regulations promote understanding and voluntary compliance and avoid inadvertent noncompliance.

 

(D1) Pelagic Trawl Gear Definition
 

• The State of Alaska has a clear definition for pelagic gear in that it is defined as not having contact with the seafloor. 

• Bottom protection devices (discs, bobbins and rollers) were excluded from pelagic trawls in 1990 to discourage bottom contact while fishing with the gear type and to distinguish pelagic trawls from bottom trawls.

• The definition was later refined in 1993, further defining what does (or does not) constitute pelagic trawl gear and providing a performance standard intended to limit bottom contact for pelagic trawl gear, but not prohibiting bottom contact.

• The use of floatation could support feasibility and adoption of camera and/or sensor technology to detect and quantify seabed contact and make practicable the consideration of threshold gear restrictions (such as 10% threshold in GOA).

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Oral comments can also be provided in person or via remote testimony through the agenda items on the Council's website. To access the meeting virtually, visit the Council's website here.

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For more information, please email Marissa or Michelle at marissa@akmarine.org or michelle@akmarine.org.