Posted December 21, 2023
The North Pacific Fishery Management Council (NPFMC) met December 4-12, 2023 online and in person in Anchorage. AMCC was there to continue our advocacy to protect critical fish habitat in the Bering Sea and Aleutian Islands (BSAI) and Gulf of Alaska (GOA) as well as communities that depend on bycaught species in decline.
These issues corresponded to agenda items: (C3) BSAI Groundfish specifications and (C4) GOA Groundfish specifications, (C5) Essential Fish Habitat Fishery Management Plan Amendments and (D1) GOA Tanner crab protections.
This blog post provides background about each issue, what was planned for this meeting, what AMCC was advocating for and why we consider them priorities. It also includes AMCC’s summary of the meeting results and anticipated next steps.
Agenda Items (C3) and (C4): BSAI and GOA Groundfish Specifications
Background: Each year, the total allowable catch (TAC) for the Bering Sea and Aleutian Islands (BSAI) and the Gulf of Alaska (GOA) for the following year’s harvest is set at the December NPFMC meeting. The Council reviews a suite of information including groundfish plan team reports, ecosystem status reports and stock assessment information to inform its decision.
What was planned for the December 2023 meeting: The Council intended to adopt the final BSAI and GOA groundfish specifications - commonly referred to as the TAC - for the upcoming two-year period (2024-2025) as well as to recommend gear and target fishery apportionments of prohibited species catch (PSC) (aka bycatch) limits for halibut, red king crab, Tanner crab, opilio crab and herring.
What AMCC advocated for and why: AMCC continued to focus on what the current TAC levels cost in bycatch of other non-target species like salmon, squid and herring. With the ongoing decline of Western Alaskan Chinook and chum salmon and the resulting effects on subsistence users in the region, we believe bycatch is one of the cumulative stressors and must be recognized when setting a single species TAC. AMCC requested that, in future TAC-setting, a column be added to the TAC sheets to show the associated PSC rates for the groundfish targets. This would increase overall understanding of the harvest implications in a more clear and transparent manner. AMCC provided an example of how to include PSC data in our comment letter here.
Summary of the meeting results: In setting TACs, final Council determinations are expected to be based on both the biological condition of groundfish stocks and socioeconomic considerations. Notably, however, there is no direct mechanism for incorporating ecological factors that affect non-target species caught as bycatch, or which rely on target species as prey.In response to public testimony regarding increased fishing pressure on juvenile sablefish (with trawl harvest increasing 11,000% in five years, likely causing the increase in orca entanglements for this fleet) and market collapse due to the flood of small fish brought to shore, the Bering Sea TAC for sablefish was set at a level equal to 2023 - a win considering there was pressure to further increase the take. The pollock TAC was not set to its maximum amount but remains alarmingly high, particularly considering indicators of declining prey availability for pollock and continued declines in species that depend on pollock as forage fish. TAC and PSC specifications for the 2024 and 2025 fishing years in the BSAI are available here. TAC and PSC specifications for the GOA, including guideline harvest levels (GHLs) for groundfish fisheries in state waters, can be found here.
Anticipated next steps: AMCC will continue to support a groundfish specifications process that recognizes broader ecosystem and community impacts, including associated PSC rates with groundfish harvests. AMCC recognizes a precautionary, ecosystem-based fishery management approach in the TAC-setting process is essential for sustainable fisheries.
Agenda Item (C5): Essential Fish Habitat Fishery Management Plan Amendments
Background: Every five years the Council undertakes a review of the Essential Fish Habitat (EFH) components in each Fishery Management Plan. EFH is considered to be the majority of a single species' range, and the modeled "fishing effects" on species' EFH has never - across the nation - resulted in a finding of habitat disturbance that is "more than minimal and temporary."
What was planned for the December 2023 meeting: In the last stage of the 5-year review, the Council was to review a final analysis of EFH Fishery Management Plan (FMP) technical amendments proposed at the February 2023 NPFMC meeting; this agenda item was in both Initial and Final Review.
What AMCC was advocating for and why: Since the 2005 EFH 5-year Review, it has been determined by the National Marine Fisheries Service that fishing activities do have long term effects on habitat but are not detrimental to fish populations or their habitats. AMCC disagrees with the final part of this conclusion, in large part due to the dearth of region-specific evidence informing susceptibility and recovery rates which are used in the Fishing Effects Model, and therefore we requested updates accordingly for the next 5-year Review cycle. Analysis stated plainly that “considerable scientific uncertainty remains regarding the consequences of such habitat changes for the sustained productivity of managed species.” Even more plainly, the effectiveness of this process hinges upon determining impacts to habitat, but information from the National Marine Fisheries Service and the NPFMC process has been insufficient in describing what habitat components exist, how they are vulnerable and how they contribute to fisheries.
Summary of the meeting results: The technical amendments proposed in February 2023 were adopted, which advance some helpful understanding of species with FMPs. However, habitat impacts from Fishing Effects continue to be modeled using arbitrary recovery and susceptibility rates.
Anticipated next steps: AMCC will continue to elevate the importance of habitat in upcoming NPFMC agenda topics including the Pelagic Trawl Gear Regulatory Definition/Revisions (February 2024), Bristol Bay Red King Crab Savings Area (February 2024), GOA Tanner crab (February 2024) and the continuation of the EFH Review process, among other avenues. Without healthy habitat, there are no healthy fisheries. This is at the forefront of all our advocacy.
Agenda Item (D1): GOA Tanner Crab Protections
What was planned for the December 2023 meeting: The Council was scheduled to review a discussion paper which included information on Tanner crab sources of mortality, bycatch in groundfish fisheries and observer coverage in critical crab habitat around Kodiak island. Unfortunately the agenda item and discussion was postponed due to data errors in the discussion paper. The statistical areas of concern outlined below are discrete regions and databases are not designed to gather comprehensive information in relatively small areas. The challenges are compounded by the “rule of three” for commercial fishing data which requires three separate contributors, or fishing vessels, to fishery data. The intent of this rule is to prevent the identification of a single vessel or two in fisheries data. While this rule does protect unique vessels and their data, it does affect overall data to inform management decisions and may warrant further discussion of the need for data confidentiality rules with technological advancements in the modern day fishing industry.
What AMCC was advocating for and why: For nearly two decades, AMCC has worked with Kodiak Tanner crab fishermen in support of measures to protect Tanner crab from the impacts of bottom trawling in essential crab habitat.
The proposed areas for protections off the Eastside of Kodiak Island (statistical areas 525702 and 525630) overlap with local knowledge maps illustrating areas of importance from fishermen, Alaska Department of Fish and Game survey data and directed crab fishermen harvest - all of which illustrate the long standing knowledge of the value of this habitat to the crab. We know these areas are important. 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 area’s 525702 and 525630
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Anticipated next steps: The discussion on GOA Tanner crab protections has been tentatively rescheduled for February 2024 as requested by crab fleet representatives. While this meeting is in Seattle, and will pose a challenge to attend in person, Tanner crab fishermen supported Council review of the discussion paper at the first available opportunity and noted the opportunity to call in and testify as an important component of this recommendation.
Mark your calendars! February 5-12, 2024 is the next scheduled meeting of the NPFMC online and in person in Seattle. To stay up to date on this meeting, visit the NPFMC website here and watch for updates from AMCC in our monthly enews. Sign-up at www.akmarine.org.