Click on “Comment now” next to Agenda item C4. Comments that have been submitted are only published publicly after the comment deadline has passed.

Background

The North Pacific Fisheries Management Board is due to make a final decision in October on a Pacific Cod Trawl Cooperative (PCTC) catch-sharing program for trawlers in the Bering Sea and Aleutian Islands. At this meeting, the subject is item C4 on the agenda.

The statement of purpose and needs behind the development of the new program includes: a cooperative program to improve overall harvest, quality and value of trawl sectors allocation of Pacific cod , allocation of quota shares to fishermen and processors based on the history over the qualifying period years, improving safety, minimize bycatch and ensure the sustained participation of communities dependent on fishing. There are 14 elements and options that shape the final program.

Provide written feedback to the Board, including information about who you are and why you care. Please keep these points in mind for your comments:

• Element 3: Catch limits for prohibited species (reduction of bycatch)
• Include significant reductions in halibut and crab bycatch
• A 35% reduction in halibut bycatch, the maximum amount considered for use in the catch-sharing program, is a reasonable and expected result of this program to provide broad benefits.
• The program is also expected to benefit struggling crab stocks in the Bering Sea and there should be a reduction of at least 35% in crab bycatch in the program.
• National Standard 9 of the Magnuson-Stevens Act, which is the Council’s governing legislation, states that a Council shall “take into account conservation and management measures which shall, to the extent possible, minimize bycatch.” . (Regarding National Standard 9 feasibility standard, the BSAI Pacific Cod Trawler Fleet operated under a voluntary cooperative fishing plan for two seasons, 2020 and 2021, and was successful to reduce halibut bycatch on average by 75% – well beyond the envisaged reductions of 10% to 35%. Under voluntary cooperation agreements, the fleet avoided fishing at night, stopping during periods of high bycatch, used gear modifications, and coordinated with transformers.)
• The development of catch-sharing programs offers significant opportunities to reduce bycatch of species important to other user groups.
• Coastal communities depend on halibut and crab, and it is the responsibility of the State of Alaska and the Council to conserve these resources and their cultural, recreational and commercial values ​​for Alaskan halibut fishermen, processors, visitors and consumers.
• Thousands of families, businesses and communities depend on the health of halibut and crab.
• A comprehensive catch-sharing program that includes additional tools and minimizes bycatch to the extent possible is a program objective identified in the goal and requirement statement.

• Item 14: Gear Conversion
• Authorize the use of pots to harvest the cooperative quota
• This provides an option for harvest flexibility with many potential benefits to the nation including: increased product value, harvest efficiency, reduced carbon footprint, lower bycatch, etc.
• Halibut bycatch rates in traps are considerably lower than bycatch rates in cod trawls.
• The intentional flexibility of the equipment through the gear conversion element responds to the statement of purpose and need guiding action and provides flexibility in a changing ocean climate.

• Element 2: LLP Licensing
• Leave season C unallocated
• The trawl sector has not historically harvested this quota, but rather it has been regularly transferred to other sectors, notably trap sectors. Leaving this season to the status quo avoids additional negative impacts downstream of this program on other sectors.

• Element 6: Aleutian Islands Processor Provisions
• Include provisions for harvesting and processing from the Aleutian Islands which results in significant processing capacity in the Aleutian Islands
• This is important for: taking into account the importance of fishery resources for fishing communities in National Standard 8, supporting the ongoing harvest of important state and federal fisheries in the Aleutians, promoting the security and stability of these fisheries, many of which include smaller vessels and increase the distribution space of Pacific cod and associated halibut bycatch, whose bycatch rates are significantly lower in the Aleutians.