By Shannon Carroll
This month, the North Pacific Fishery Management Council (Council) wrapped up its final meeting of 2016 by pulling the plug on the Gulf of Alaska Trawl Bycatch Management Program. Citing an impasse in discussions between the State of Alaska and members of the trawl and processing sectors, the Council passed a motion tabling further action on the agenda item. The program, which has been under development for several years, was designed to provide groundfish fishermen with the “tools” to harvest target species while operating under reduced halibut and Chinook bycatch limits.
From the beginning of the Walker administration, the State of Alaska and the groundfish sector differed over the whether a catch share-type program was the right tool for the job. After a contentious meeting in Kodiak this past June, AMCC was optimistic that a middle ground – one that would bring greater stability to the groundfish sector while also addressing community concerns regarding past catch share programs – could be reached. Nonetheless, members of the Council likened the current impasse to being stuck on a sandbar, and in a 8-3 vote decided that it was better to take a step back from the proposed program.
Despite tabling the action, the Council initiated several discussion papers involving the Gulf of Alaska trawl fishery. These analyses will evaluate, among other things, modifying season start dates and sea lion closures in the groundfish trawl fishery, current protections and stock information for Tanner crab, and the hurdles to implementing abundance-based halibut bycatch management in the Gulf of Alaska. While AMCC sees value in these efforts, we remain hopeful that the Council will continue working towards a comprehensive management structure that fits the unique characteristics of the Gulf of Alaska.
Looking beyond the Gulf of Alaska trawl fishery, and into 2017, AMCC will continue to engage on issues at the Council that affect the sustainability of federal fisheries and impact the next generation of fishermen. At the February meeting in Seattle, the Council’s abundance-based halibut bycatch working group will be hosting a workshop to update and gather input on its effort to develop an abundance index for halibut. While this process has proven more complicated than we initially expected, AMCC continues to support moving towards a policy that establishes halibut bycatch caps based on the abundance of the stock. The Council will likely review the working group’s efforts during its April meeting in Anchorage. Also during the February meeting, the Council will hear recommendations from the Halibut/Sablefish IFQ Committee. These recommendations stem from the 20-year review of the Halibut/Sablefish IFQ program.
Finally, the Council will continue work on the Bering Sea Fishery Ecosystem Plan (FEP)—a tool that will hopefully lead to a more comprehensive understanding of the Bering Sea ecosystem and its relationship to Council management actions. The Council recently appointed members to the Bering Sea Ecosystem Team, which will be the lead on developing the FEP. The team is expected to report to the Ecosystem Committee in February, and to the Council in April.
AMCC continues to champion the Council’s efforts to implement ecosystem-based measures through the Bering Sea Fishery Ecosystem Plan. We greatly appreciate the work that has gone into the FEP development thus far and look forward to ensuring that the FEP includes defined ecosystem-level goals and measurable objectives and outcomes.
Shannon Carroll is AMCC’s Fisheries Policy Director. He can be reached at 907.277.5357 or via email.
AMCC seeks a science consultant with expertise in population dynamics modeling, fisheries stock assessment, and fisheries management strategy evaluation to analyze two management actions being developed by the North Pacific Fishery Management Council (Council). A successful applicant will have a:
- PhD in fisheries science, with a specialization in fisheries population dynamics modeling, fisheries stock assessment, and fisheries management strategy evaluation;
- A background in fisheries management and policy, with preference for experience with the Council and IPHC processes;
Sufficient time and capacity to dedicate to project in the timeframe identified and ability to attend the Workgroup workshop on September 12 (in Seattle);
- An appreciation for the social, biological, and economic dimensions of fisheries management.
All proposals shall be submitted as soon as possible but no later than July 31, 2016 (note deadline was extended from July 15th). Proposals should be submitted via email to Shannon Carroll (firstname.lastname@example.org).
FOR IMMEDIATE RELEASE: June 27, 2016
Shannon Carroll, Fisheries Policy Director
Alaska Marine Conservation Council
907.382.1590 // email@example.com
Jen Leahy, Communications Manager
Alaska Marine Conservation Council
907.787.9257 // firstname.lastname@example.org
Peterson and Laukitis confirmed to North Pacific Fishery Management Council
Two long-time commercial fishermen from the Gulf of Alaska appointed
Anchorage, AK — Alaskans Theresa Peterson and Buck Laukitis were confirmed today by Secretary of Commerce Penny Pritzker to serve a three-year term on the North Pacific Fishery Management Council (Council). Peterson, a Kodiak resident, will replace long time Council member Duncan Fields, also of Kodiak, who served three consecutive terms. Laukitis resides in Homer and replaces Dave Long of Wasilla.
“I am honored to serve on the Council and look forward to the opportunity to give back to a fishing industry that has provided so much for me and my family,” said Peterson. “Many of us here in Alaska today had a chance to get into the fishing industry; we stayed and raised our families in coastal communities throughout the state. I want the next generation of fishermen to have similar opportunities to commercial fish and work their way up to ownership. Small boat fishermen are the fabric of maritime communities around the state and their voices must be heard in the Council arena along with large scale fisheries.”
The Council is one of eight regional councils established by the Magnuson-Stevens Act (MSA) to manage federal fisheries (3-200 miles from shore). The MSA is designed to encourage local level participation and representation through the regional council structure. The Council also works closely with the Alaska Department of Fish and Game and the Alaska Board of Fisheries to coordinate management program in state and federal waters.
The Council is made up of 11 voting members and four non-voting members. The 11 voting members include seven stakeholders that are familiar with the fishing industry, marine conservation, or both. Five of those seats are designated for Alaskans and are appointed by the governor. The selection is then confirmed by the commerce secretary. Peterson and Laukitis were Gov. Walker’s preferred candidates.
Peterson has participated in a variety of state and federal fisheries, including pot fishing, set-netting, seining, driftnetting, and long-lining, in addition to subsistence fisheries. She and her husband own and operate a small commercial boat and salmon set-net site in Kodiak. She has been a steadfast advocate for small-boat, independent fishing businesses, who many believe comprise the heart of Alaskan fishing communities.
Peterson is a multi-term member of the Council’s Advisory Panel, as well as an outreach coordinator for Alaska Marine Conservation Council (AMCC). As a member of the Advisory Panel, she works to improve participation of small scale and community sectors and encourages community members to engage in the process to influence policy making decisions which reflect Alaskan coastal community values.
“The Council process benefits from input from coastal community members who live with the outcome of the management decisions. I have long felt that small scale fishermen were the most underrepresented group in the Council arena and I am encouraged by an Alaskan administration that supports broad representation on the Council,” said Peterson.
Laukitis also has a long history of engagement in Alaskan fisheries. As a long-time commercial fisherman, he brings a direct understanding of the importance of sustainable fisheries management. He is the owner and operator of two fishing vessels that fish for salmon, halibut, and cod in the Gulf of Alaska and Bering Sea/Aleutians Islands. Fishing is a family business for Laukitis; his wife, two daughters, and son-in-law all work in the family fishing business.
Laukitis brings a comprehensive understanding of the federal fisheries management process. He served as vice president of AMCC’s board of directors for eight years, representing the organization at congressional hearings surrounding the reauthorization of the MSA in the mid-90s. Laukitis was also president of the Homer-based North Pacific Fisheries Association, where he represented the organization before the Council and International Pacific Halibut Commission on a wide range of issues.
“As the owner of two vessels and a nearly year-round fishing business, Buck understands what fishermen need to keep their vessels working and profitable. His experience in Alaskan fisheries and fisheries policy, as well as his commitment to the resource, make him highly qualified to serve on the Council,” said Kodiak commercial fisherman Darren Platt.
Founded in 1994, Alaska Marine Conservation Council is a community-based, nonprofit organization committed to protecting the long-term health of Alaska’s marine ecosystems and sustaining the working waterfronts of our state’s coastal communities. Our members include fishermen, subsistence harvesters, marine scientists, business owners, conservationists, families, and others who care deeply about Alaska’s oceans.
By: Shannon Carroll, Fisheries Policy Director
Earlier this month, the North Pacific Fishery Management Council (Council) met in Kodiak for its third meeting of the year. Though the Council took up other issues, including a 10-year review the Bering Sea crab rationalization program, it devoted much of its time to the Gulf of Alaska trawl bycatch management program.
During the three days devoted to the issue, the Council heard from nearly 75 stakeholders. Testimony largely focused on community concerns regarding the proposed program. Trawl vessel owners and processors continued to stress the importance of the trawl fishery to Kodiak, and reiterated the need for tools that would allow them to reduce bycatch and harvest under-fished flatfish. Other stakeholders, including community members and salmon and halibut fishermen, highlighted the need for 100% observer coverage, entry opportunities, and protective measures to mitigate the kinds of community impacts associated with past catch share programs.
These impacts include excessive consolidation, out-migration of wealth and access, and the loss of support services. The Council also received a presentation on the Community Fishing Association (CFA) concept by AMCC staff and other community members.
At the conclusion of public testimony, Alaska Department of Fish and Game Commissioner, Sam Cotten, made a motion to establish three overarching goals for the program: (1) bycatch management, (2) increased groundfish utilization, and (3) maintaining opportunities to enter the fishery by—potentially—limiting any groundfish harvest privileges that might be allocated. The purpose of the motion, according to Commissioner Cotten, was to ensure that access to the fishery remains a top priority in the development of the new program. Permanently allocating a public resource to current participants, he noted, effectively locks out the next generation and benefits larger corporations with access to the most capital.
After a lengthy discussion, and one amendment, the Council passed Commissioner Cotten’s motion. The Council also passed a motion adopting the stakeholder-proposed changes to the CFA alternative. These changes included a more defined board governance structure, community eligibility definition, and specific goals and objectives.
The Council will next review the program during its December meeting in Anchorage.
For more info on Gulf of Alaska trawl bycatch management:
The Council bid Duncan Fields farewell
It was fitting that Duncan’s last meeting was held in his hometown of Kodiak. In his nine years on the Council, Duncan has been a tireless advocate for Alaska’s coastal communities and small boat fishermen. We at AMCC will certainly miss him.
Read more here: Fields’ voice never louder as he ends nine-year council run
The North Pacific Fishery Management Council is holding its June meeting in Kodiak, where it will be once again be reviewing the Gulf of Alaska Trawl Bycatch Management Program. The long-term health of Gulf communities depends on a management plan that protects the role of independent, community-based fishermen, and the health of all Gulf fisheries. AMCC believes the Gulf Trawl Bycatch Management Program should allow for viable entry opportunities, community protections, and meaningful reductions to bycatch. Additional information about the program is available through the Council’s agenda.
If you wish to comment on the management plan, the deadline for written comments is 5:00 pm (AST) on Tuesday, May 31. Comments should be emailed to email@example.com.
Read on for full details…
Recognizing the importance of minimizing Chinook and halibut bycatch, the North Pacific Fishery Management Council (Council) has recently taken action to set or lower limits on bycatch in the Gulf of Alaska. At the same time, the Council has also taken the position that the current management structure does not provide the trawl fleet with the tools necessary to meet existing bycatch reductions, or further reduce bycatch beyond current levels.
As a result, the Council has been looking at implementing a new management program for the Gulf of Alaska trawl fisheries. In addition to the status quo, the Council is currently considering three options (alternatives):
- Alternative 2 is a traditional catch share program that would allocate pollock and cod as target species, and halibut and Chinook as bycatch to harvester-processor cooperatives, based on the qualifying catch history of the trawl members’ LLP licenses. Allocated fishing privileges would be transferable, somewhat similar to the halibut IFQ fishery.
- Alternative 3 would annually allocate halibut and Chinook bycatch to harvester-processor cooperatives, based on equal shares, some measure of dependency and engagement in the fishery, or some combination of the two. This bycatch quota could be traded within a cooperative, but is not transferable without also selling the vessel or license.
- Alternative 4 would allocate a specified percentage of quota to a Community Fishing Association (CFA). Quota allocated to the community is then used to address community goals of keeping a local fleet, providing a viable point of entry for new entrants, equitable crew compensation, and vessel/owner residency.
The Council Needs to Hear From You
During the June meeting in Kodiak, the Council will be looking for community input on the Gulf Trawl Bycatch Management Program. Hearing from community members about what they would like to see in the new program will go a long way in ensuring that community protections, bycatch reductions, and future access measures are included in the final action.
Written Comment: If you wish to comment, the deadline for written comments is 5:00 pm (AST) on Tuesday, May 31. Comments should be emailed to firstname.lastname@example.org.
Public Testimony: There will be two opportunities to testify at the June Council meeting:
- The Advisory Panel will begin hearing the GOA Trawl Bycatch Management Program agenda item on the afternoon of Thursday, June 9th. The Advisory Panel will be meeting in the Elks Lodge.
- The Council will begin hearing the same issue on the morning of Saturday, June 11. The Council will be meeting in the Pavilion Room of the Convention Center.
If you’d like more information on submitting written comments or offering public testimony, contact Shannon Carroll, at email@example.com.
By: Shannon Carroll, Fisheries Policy Director
Last June, the North Pacific Fishery Management Council (Council) promised to take further action on halibut bycatch in the Bering Sea. Over the course of the past several meetings, the Council has followed through on that promise, developing a draft strategic plan for halibut issues, strategies for improved communication with the International Pacific Halibut Commission (IPHC), and a framework for an abundance-based halibut bycatch policy.
During the April Council meeting in Anchorage, the Council voted to continue evaluating an abundance-based approach to halibut bycatch in the Bering Sea. This followed a presentation by the abundance-based bycatch workgroup—which consists of Council, National Marine Fisheries Service, and IPHC staff—as well as testimony by halibut stakeholders, including AMCC. The workgroup’s current focus is determining an index for halibut abundance that can, among other things, be used to effectively capture the impact of bycatch removals on Bering Sea halibut. The workgroup will continue analyzing various indicators used to measure halibut abundance and will be holding a public workshop sometime in August. Abundance-based halibut management will likely be on the agenda again in October.
AMCC appreciates the Council and workgroup’s continued effort find a long-term solution to halibut bycatch in the Bering Sea. A robust, scientifically-sound abundance index is a key step in this process. We look forward to continuing to providing input on this effort.
More on the full range of issues covered in the April meeting can be found in the Council’s newsletter.
The next NPFMC meeting will be held June 6-14 in Kodiak. At that time, the Council will be hearing community and stakeholder testimony on the the Gulf of Alaska Trawl Bycatch Management program.
For more information on Council actions and upcoming meetings, visit npfmc.org.
By: Shannon Carroll, Fisheries Policy Director
Here is the latest news for the North Pacific Fishery Management Council’s work on halibut bycatch.
Halibut Management Framework
Since June 2015, The North Pacific Fishery Management Council (Council) has been working to develop a Halibut Bycatch Framework (Framework). The goal of the Framework is to serve as a strategic planning device for future halibut management actions along with improving and increasing communications with the International Halibut Commission (IPHC).
The Framework is often described as a “living document,” with the intention to continue refining and adjusting the document to fit ongoing Council needs. After receiving input from stakeholders, including AMCC, during the October and December Council meetings, the five halibut management objectives:
- Manage halibut bycatch in the groundfish fisheries and harvests in the commercial, guided and non-guided recreational, and subsistence fisheries consistent with the Council’s Magnuson-Stevens Act conservation objectives.
- Manage halibut bycatch to balance the objectives of directed users and bycatch users in both the Bering Sea and Aleutian Islands (BSAI) and the Gulf of Alaska (GOA).
- Pursue an abundance based approach to managing halibut bycatch and directed harvests in coordination with the IPHC.
- Provide for the sustained participation of historic participants and fishery dependent communities.
- Maintain monitoring and catch accounting programs for halibut users in the BSAI and GOA in order to provide the data necessary for management needs.
The Framework has also led to more formalized communication with the IPHC, including the formation of a Halibut Management Committee and likely development of a Joint Council/IPHC Committee that would meet on an annual basis. The Council will be reviewing the Framework again during the April Council meeting in Anchorage, so stay tuned for news regarding that review process.
Abundance-Based Halibut Bycatch Management in the Bering Sea
AMCC has been working with other halibut user groups to push for a halibut management structure that links both catch and bycatch limits to halibut abundance levels. This is in contrast to the existing structure, where bycatch limits are fixed, regardless of halibut abundance. An abundance-based management structure would help both the IPHC and Council better share the responsibility of halibut conservation. Currently, the IPHC manages only the directed fishery and cannot make reductions to bycatch limits during times of low abundance. Were the Council to adopt abundance-based management, it would have an additional tool to protect halibut stocks at periods of low abundance.
The Council has recognized the potential value of this approach and has formed an interagency workgroup comprised of staff from the Council, the IPHC, and the National Marine Fisheries Service. This workgroup has been tasked with developing alternative approaches to abundance-based management and will be providing advice to the Council during either the April or June Council meeting.
Stay tuned for more halibut bycatch updates following the April Council Meeting!
By: Hannah Heimbuch, Community Fisheries Organizer
The North Pacific Fishery Management Council (Council) met for its final meeting of 2015 in Anchorage this month, setting groundfish harvest numbers for the coming year, while also diving into a wide range of other topics. Bycatch, along with abundance- and ecosystem-based management, continued as major themes for the Council.
In other bycatch conversations, the Council reviewed a roadmap outlining the analytical process for the development of a Gulf of Alaska Trawl Bycatch Management Program. After revising and adding to the range of alternatives under consideration in October, Council and National Marine Fisheries Service (NMFS) staff produced a work plan which lays out proposed steps to develop a Draft Environmental Impact Study by the end of 2016. Throughout this ongoing bycatch management initiative, AMCC has advocated for measures built into the program that protect community access to fishing rights, and options for the continued reduction of bycatch. We appreciate and look forward to the analysis of the new alternative introduced by Commissioner Cotten which would only apportion Chinook salmon and halibut to voluntary inshore cooperatives based on their members vessels. This is a new and innovative approach to provide for a cooperative style management without allocating the target species and thus the associated fishing rights.
As the need for information and options around bycatch management continues to increase, the Council is also exploring the potential of abundance-based halibut bycatch limits. The Council voted to initiate a workgroup, collaborating with NMFS and the International Pacific Halibut Commission, to evaluate options for moving bycatch management away from fixed limits, and toward limits that fluctuate with abundance (much like harvest). AMCC supports a move toward a bycatch management system that is more responsive to both conservation needs and balance between sectors, particularly in times of low abundance. The Council also tasked the workgroup with evaluating bycatch of juvenile halibut in terms of their long-term potential spawning potential. This is another important consideration, recognizing the stock-wide impact of removing large numbers of juvenile halibut, as seen in the Bering Sea/Aleutian Islands groundfish fisheries.
Finally, the Council has also advanced the topic of ecosystem-based management after hearing staff reports and a discussion paper on a Bering Sea Fishery Ecosystem Plan (FEP). Going forward, Council staff is tasked with developing the core FEP, and taking steps toward forming a Bering Sea FEP team and plan for public outreach. The Council has long been a leader in implementing ecosystem-based fishery management measures into its fishery management policies and the FEP is an important step in furthering that tradition.
For more information on Council actions and upcoming meetings, visit npfmc.org.
Halibut Bycatch Updates
For more than a year, dual concerns regarding declining halibut stocks and community access in the Bering Sea have been a hot button issue for both the International Pacific Halibut Commission (IPHC) and the North Pacific Fishery Management Council (the Council). Despite committed efforts by a diverse array of stakeholders, the precarious state of the Bering Sea halibut fishery remains uncertain heading into the end of 2015.
International Pacific Halibut Commission (IPHC)
During its December interim meeting, the IPHC will be releasing its 2015 stock assessment and 2016 harvest decision table. The stock assessment provides managers with the status of halibut throughout its range in the North Pacific, while the harvest decision table guides the Commission’s decision-making as it sets the annual catch limits for 2016. These reports will play a significant role in whether the fishermen in the Bering Sea will have a directed fishery in 2016.
The IPHC is also in a state of transition: in the coming months, the Commission will be hiring a new Executive Director to oversee the IPHC. Additionally, President Obama will make appointments for the two U.S. public seats on the Commission by early 2016. Our hope is that whoever fills these roles will effectively advocate for coastal communities and conservation of the resource, while also bridging the communication and decision making gap between the IPHC and the Council.
More at: www.iphc.int
North Pacific Fishery Management Council (the Council)
The Council’s December meeting is fast approaching and it is filled with halibut bycatch agenda items. The Council will first take action on 2016 catch limits for the Bering Sea/Aleutian Island groundfish fisheries, where it may consider reducing catch limits for fish with high rates of halibut bycatch. Although an unorthodox approach in some ways, a reduction in groundfish catch limits could provide short-term relief to both the resource and the halibut-dependent communities of the Bering Sea.
With long-term solutions in mind, the Council will also take up two agenda items that could provide significant improvements to halibut management. First, it will continue public scoping on its draft Halibut Management Framework. The draft framework could provide for more regular and meaningful communication between the Council and the IPHC, as well as enhance avenues for stakeholder input. Next, the Council will be reviewing a discussion paper on abundance-based management for halibut bycatch. AMCC fully supports the Council’s efforts to move toward abundance based management, provided the new management approach contains appropriate conservation and community safeguards.
Proposed Bycatch Rule
The National Marine Fisheries Service is seeking public comments on the proposed rule that would implement the Council’s bycatch recommendations from this past June. Comments are due December 28, 2015. This is your opportunity to tell the National Marine Fisheries Service that the Council did not go far enough in reducing bycatch.
You may submit comments on the proposed rule via the Federal e-Rulemaking portal. Go to www.regulations.gov/#!docketDetail;D=NOAA-NMFS-2015-0092, click the “Comment Now!” icon, complete the required fields, and enter or attach your comments.
After a busy summer season, the North Pacific Fishery Management Council (the Council) was back together again for its October meeting in Anchorage, with strong focus on observer plans and electronic monitoring, as well as groundfish and halibut bycatch management.
The Council sent the annual deployment plan for groundfish observers in the partial coverage fleet forward, with specifications that would change how observers are dispersed among the groundfish fleet, if approved during final action in December. The change would assign observers based on gear type, with 14% coverage rates recommended for the pot and longline fleet and 29% for the trawl fleet. This is a positive change, as deciding observer time based on gear type will allow for more of the total catch to be observed, and give the industry more data to work with when making major harvest decisions.
Electronic monitoring (EM) is set to enter its first round of field trials, following Council approval of an EM pre-implementation plan for 2016. The Council has been discussing EM as a tool for monitoring fishing vessel activities, such as catch and bycatch, to expand the tools already available in the observer program — particularly for vessels that have difficulty accommodating observers. These initial trials will be run out of the ports of Homer and Sitka, on select pot and longline vessels that have volunteered for the program. We look forward to the results of these trials and the important data-gathering tools that EM could offer our fisheries as the program develops.
The Council unanimously approved an initial review motion modifying Bering Sea Aleutian Islands (BSAI) trawl observer coverage to allow vessels to opt into the 100% coverage pool. Previously, some vessels opted to carry 100% coverage so that a switch from a partial observer fishery to a full coverage fishery did not require them to stop to pick up another observer and to maintain confidence in bycatch rates at the vessel-level within the coops. However, this choice has frequently resulted in those vessels paying double fees. AMCC supports the motion, as it removes the duplicate fee, and will hopefully result in more boats opting into the 100% coverage category.
The council has taken another step in the ongoing exploration of Gulf of Alaska Trawl Bycatch Management options, voting forward a set of alternatives for staff analysis following a full day of reports, testimony, and discussion. The alternatives explore a variety of ways to manage bycatch among Gulf trawl fisheries and individual vessels. Commissioner Cotten introduced a new alternative which would apportion Chinook salmon and halibut bycatch to inshore fishing coops — on a voluntary basis — based on their members’ vessels. The alternatives maintain an option for Community Fishing Associations (CFAs), which have the potential to anchor quota to Gulf communities and to mitigate some of the adverse impacts of catch share programs. The Council also included options for further reduction of halibut and salmon bycatch. AMCC is pleased that the Council is moving forward with analysis of a broad suite of options, and that a CFA option is among those being considered. We look forward to a robust discussion following the next step of analysis, and the opportunity to weigh all of the material and find what is the best way to manage bycatch for sustainable and diverse fisheries and fishing communities in the Gulf.
On the halibut bycatch front, the Council passed a motion indicating its intent to consider reducing the total allowable catch (TAC) for targeted groundfish species that have high bycatch rates. Final action on groundfish TACs will be in December. The Council also unveiled its draft Halibut Management Framework, which is, among other things, intended to develop a framework for improving coordination between the International Pacific Halibut Commission and the Council. Although the Council responded to initial feedback during the October meeting, the framework will undergo further public and council review prior to the December meeting.
The Council will continue to analyze a Gulf of Alaska Chinook salmon bycatch reapportionment and may take final action in December. The proposed alternatives would provide NMFS in-season managers the authority to move allowable bycatch between the Pollock and other groundfish sectors (non-pollock/non-rockfish). The proposed action will not increase the overall cap beyond the 32,500 current limit. However, combining the two caps creates a different scenario, and options to limit Chinook salmon reapportionment are important elements to consider in the action going forward. While AMCC supports actions that give the fleet tools for keeping bycatch below the cap while still executing target fisheries, we continue to prioritize maintenance or reduction of current bycatch levels.