Help Protect Bristol Bay
Red King Crab

RE: Emergency Action Request: Close the Red King Crab Savings Area to Pelagic Trawl Gear


Mr. Jon Kurland

Regional Administrator, Alaska Region

National Marine Fisheries Service

P.O. Box 21668

Juneau, AK 99802-1668

Dear Mr. Kurland,

The undersigned request emergency action to close the Red King Crab Savings Area to pelagic trawl gear. This action is justified to prevent serious damage to crab and their habitat, and to preserve a significant economic opportunity that otherwise might be foregone if the iconic Bristol Bay Red King Crab stock is not allowed to recover.  


The Red King Crab Savings Area was identified as an important area for crab and their habitat and bottom trawling was prohibited within it. However, since its implementation in 1995, pelagic trawling for other species has been permitted in this area, and the sector has increased their efforts within it in recent years. Particularly concerning, is the increased effort in the area when crab are molting and mating, their most sensitive life phases, during January through June.  


A discussion paper presented to the North Pacific Fishery Management Council in April of this year states that seafloor contact of pelagic gear from the Catcher-Processor fleet ranges from 70-90% during the molting and mating season, and upwards of 100% beginning in July - an increase from estimates previously used by the National Marine Fisheries Service. This data, combined with the critical status of the Bristol Bay Red King Crab stock and the significantly increased effort of the pelagic trawl sector in the Red King Crab Savings Area since 2014, underscores the nature of this situation as both unforeseen and recently discovered. In addition to these rapidly evolving factors independently, their compounding impacts constitute an unaddressed, unforeseen emergency requiring action. 


Pelagic trawl gear does not have any of the critical seafloor mitigating gear requirements like rolling discs or bobbins that is required of bottom trawl gear. Instead, it utilizes a foot rope made of heavy chain or cable, which contacts the bottom and any species or habitat structures there. The unmitigated contact by pelagic trawl gear has the potential to create significant habitat damage and crab mortality. 


It has been demonstrated that trawling along the seafloor reduces habitat complexity, alters seafloor communities and reduces habitat productivity. Sea whips, which have been historically found in the Red King Crab Savings Area, are slow-growing soft corals that provide essential vertical habitat in soft-sediment seafloor ecosystems, and the density of sea whip groves correlates with the density of fishes observed within them. Substantial changes in species composition and distribution can be expected with repeated habitat disturbance of seafloor habitat. Recovery for slow-growing species like sea whips and sponges require years of respite, and a long-term closure of the Red King Crab Savings Area to pelagic trawl gear is a necessary adjustment to ensure the original intent of the protected area.


Pot sectors, on the other hand, have reduced effort in the savings area drastically in recent years in response to the crab crisis. Even with this reduced effort in the area, “fixed gear”, like pot and longline gear, results in minimal habitat impacts in the Eastern Bering Sea at 3% or less, and fixed gear effort in the savings area is near zero. A focus on mobile bottom contact gear with the largest footprint in both the savings area and the Eastern Bering Sea makes sense.


The undersigned ask for your support in protecting the future of Alaska’s fisheries and place-based ways of life, both deeply rooted in connection to a healthy ocean. We support immediate emergency action to close the Red King Crab Savings Area to pelagic trawl gear to prevent serious damage to crab and their habitat and to help them recover.




Thank you for your submission!