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TAC and PSC and EFH, Oh My!

Preparing for the December 2023 NPFMC Meeting The North Pacific Fishery Management Council (NPFMC) is meeting again December 4-12, 2023 online and in person in Anchorage. Find the meeting schedule and agenda on the NPFMC website here. Written comments are due Friday, December 1 at 12pm AKT.

AMCC will be there and continuing our advocacy to protect habitat, crab and communities that depend on bycaught species in decline. These issues are of significance to our mission and correspond to agenda items: (C3) Bering Sea and Aleutian Islands (BSAI) Groundfish specifications, (C4) Gulf of Alaska (GOA) Groundfish specifications, (C5) Essential Fish Habitat Fishery Management Plan Amendments and (D1) GOA Tanner crab protections.


This blog post explains a bit more about each issue and why we consider them priorities:




What amount of catch is "allowable?"


Agenda items C3 & C4: BSAI and GOA Groundfish specifications, respectively

Background: 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 meeting. The Council will review a suite of information including groundfish plan team reports, ecosystem status reports and stock assessment information to inform the decision.


What’s Happening at this Meeting: The Council will adopt the final BSAI and GOA groundfish specifications – commonly referred to as the TAC – for the upcoming two-year period (2024-2025). In addition, the Council will 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 is Advocating for and Why: Of note, among much, is the enormous amount of pollock TAC. AMCC continues to focus on what the current TAC levels cost us in bycatch of other non-target species like salmon, squid and herring - along with associated habitat impacts and unobserved mortality of crab with the known bottom contact of pelagic trawl gear. 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 the TAC for a single species.


The magnitude of the loss of salmon to Alaska Native peoples in Western Alaska was expressed to members of the Indian Senate Affairs committee during a hearing in Bethel in November 2023. Senator Lisa Murkowski chaired the meeting and representatives were able to hear from those who are suffering a loss of culture and food security with the decline of the salmon, which has sustained the region since time immemorial. The hearing can be found here.



Essential Fish Habitat: A big rug to sweep worries under


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 (FMP). Essential Fish Habitat is considered to be the majority of a single species' range, and the modeled "fishing effects" on species' EFH has never resulted in a finding, across the nation, of habitat disturbance that is "more than minimal and temporary." In February 2023, heeding the widespread concerns of fisheries advocates regarding the model's shortcomings and increased signs of habitat degradation, the Advisory Body to the Council passed a motion to initiate a request for public proposals to conserve and enhance habitat. Analysis indicated that all fishing activities combined have "minimal, but not necessarily temporary" effects on EFH. The Council ignored its Advisory Panel and set a plan to update technical components of the review process which are not likely to result in changed findings moving forward.


What’s Happening at this Meeting: The Council will review an analysis of EFH Fishery Management Plan (FMP) amendments proposed at the February 2023 NPFMC meeting; this agenda item is in both Initial and Final Review.


What AMCC is Advocating for and Why: Although the alternatives considered in this action are effectively decided, AMCC will continue advocating for updates to the EFH review process that are responsive to fisheries declines in the North Pacific. Within the Magnuson Stevens Act (MSA), Section 303 Contents of Fishery Management Plans 16 U.S.C. 1853 states under REQUIRED PROVISIONS: Any fishery management plan which is prepared by any Council, or by the Secretary, with respect to any fishery, shall— “identify other actions to encourage the conservation and enhancement of such habitat.” The Sustainable Fisheries Act established requirements for sustainable management plans that include “direct and indirect habitat losses which have resulted in a diminished capacity to support existing fishing levels,” which deserves additional focus as we have now seen in the complete loss of multiple commercially and culturally important fisheries in the Bering Sea. Healthy habitat is crucial for both survival and rebuilding in particular.



For the crab that thrive


Agenda item D1: GOA Tanner crab protections


Background: The Council will be reviewing a discussion paper on Tanner crab protections in the Gulf of Alaska (GOA) which includes information on Tanner crab sources of mortality, bycatch in groundfish fisheries and observer coverage in critical crab habitat around Kodiak island.


What’s Happening at this Meeting: The Council will determine if additional measures to protect Tanner crab in known areas of high crab abundance is warranted and what those measures should look like in a subsequent analysis.


What AMCC is 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 to the crab of this habitat. 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.

These same statistical areas are trawled with bottom trawl gear throughout the year, including the months of April and May when the crab is most vulnerable due to mating and molting. Should fisheries management allow bottom trawling for low value flatfish on top of these high value crabs which are of great importance to the Kodiak crab fleet? AMCC strongly believes management can do better than this, it’s time to protect these crabs.







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