After five years of work and delay, final action to reduce Bering Sea halibut bycatch is scheduled for December 2021.
The Council’s comment period on Abundance-Based Management of Bering Sea halibut bycatch caps is now open and will be open through November 30th. You have three options for commenting: 1) sign onto this letter 2) submit your own comments; 3) sign up to testify to the Council via their virtual platform (likely December 9th or 10th); 4) sign onto this letter, submit your own comments, AND sign up to testify!
If you are submitting your own comments or preparing to testify, please read the letter that is linked above for background information, then include in your comments:
1) The heading : AGENDA ITEM C-2
2) your name, where you live, and your connection to the halibut fishery
3) your request that the Council correct the analysis (or Environmental Impact Statement) for this action to include the impacts of bycatch on the Gulf of Alaska halibut fisheries and communities
4) your strong support for Alternative 4—the only alternative that comes close to restoring equity in the halibut fishery.
5) anything else you want to add from the letter or your own experience/knowledge/concern about bycatch and the need to reduce it.
You can submit your comments here
To listen/testify to the Advisory Panel and the Council, join the adobe connect link starting December 2nd (AP) and December 9th (Council) and sign up to testify under Agenda Item C-2.
NOTE: The list for public testimony closes once testimony begins; be sure to sign up BEFORE public testimony starts!
REMEMBER- what happens in the Bering Sea has an immediate and a long term effect on halibut stocks in the Gulf of Alaska! Please do not expect someone else to take care of the halibut resource and your fishery! Sign the letter and write your own comments TODAY.
SEE BELOW FOR TEXT OF SIGN ON LETTER:
November 30, 2021
Simon Kinneen, Chairman
North Pacific Fishery Management Council
Anchorage, Alaska
Submitted electronically
Regarding: C2 – Halibut Abundance-Based Management
Dear Mr. Kinneen and members of the Council:
We, the undersigned Alaskans, strongly support meaningful reduction in halibut bycatch, and for the upcoming Council meeting, that means we strongly support Alternative 4 – the only of the four abundance-based management (ABM) of halibut bycatch alternatives before the Council that would provide any meaningful reduction to halibut bycatch and therefore any meaningful benefit for Alaska’s halibut fisheries.
Never before have Alaskans from all regions and sectors come together in this way to support Council action to protect our fisheries and communities.
BACKGROUND
Alaska is famous for its bountiful fisheries resources, including salmon, halibut, crab, sablefish, and herring. It is also well-known for its sustainable stewardship of fisheries resources. For more than half a century, with inevitable fluctuations, the resources off our shores have been successfully managed, and have provided food and livelihoods for our people and communities.
However, one of the most iconic and valuable of our resources – Pacific halibut – is facing a crisis that threatens the way of life for commercial and sport halibut fishermen, and the economic driver for halibut-dependent communities throughout coastal Alaska.
The Bering Sea (BS) halibut fishery has been crippled by the devastating direct effects of bycatch by large factory trawlers that come north from Seattle to fish for various groundfish species, which are processed at sea and primarily exported to Asia. Bycatch and discard of halibut during those BS groundfish fisheries also affects the availability of halibut to all users throughout the species’ range.
Halibut stocks have declined substantially over the past 30 years. As halibut stocks declined, bycatch mortality consumed a larger and larger share of the available halibut. Bycatch mortality – dead halibut – is “taken off the top” by the managers at the International Pacific Halibut Commission (IPHC), and the commercial and sport (“directed”) halibut fisheries get whatever is left.
This is unfair to Alaska and Alaskans.
Bycatch limits must be reduced for Alaska-based commercial and sport fisheries to survive. The future of halibut IFQ holders, sport charter operations, and communities hangs in the balance.
HERE ARE THE FACTS:
Every Alaskan pays the price for bycatch.
Since 2015, trawlers have killed and discarded more than 3.1 million halibut in the Pribilof Island area of the Bering Sea (Area 4CDE). This is eight times more halibut than the Pribilof Island halibut fishery landed, based on mean weight. At an average price of $5.10 per pound, this amounts to $56 million in ex-vessel revenue lost by local halibut fishermen and fishing communities in the Pribilof Island area alone.
For 2021, the IPHC projects that bycatch will account for 63% of all halibut removals in Area 4CDE, based on the 3-year average of bycatch mortality. The directed fishery landings will receive only 35%.
If bycatch users take their current full limit, bycatch would account for 97.5% of halibut removals in Area 4CDE. The directed fishery would receive just 1.7%. This means bycatch users would receive more than 5 million pounds of halibut, leaving only 90,000 pounds for the halibut fishermen.
There is a net migration of halibut from the Bering Sea to the Gulf of Alaska, hence halibut bycatch directly affects all who depend on halibut in the Gulf as well as the Bering Sea.
The recent average annual catch limit for the entire Southeast Alaska commercial halibut fishery is LESS than the annual Bering Sea halibut bycatch.
In Southcentral ports like Homer and Kodiak, commercial and sport harvest of halibut has declined by more than 50% since 2010 to conserve the halibut resource, while halibut bycatch limits have stayed the same.
Sport charter operations in all areas of Alaska have reduced allowable halibut size, or lost one or more charter days per week, with each lost day representing thousands in lost revenue to that small business alone, along with associated tax income to the community, and related local expenditures by the businesses and their clients.
Each time an Alaska business or community loses income as a response to halibut stock changes, those businesses and communities financially subsidize the trawl fleets, whose halibut bycatch is guaranteed. This subsidy is inequitable, unsustainable and is not supported by Alaska’s fishermen, fishing businesses and communities.
Bycatch savings through implementation of an ABM program may provide meaningful differences in annual allocation to the sport sector.
ACTION NEEDED
NPFMC is currently considering an ABM system for the Amendment 80 sector (bottom trawlers) that would tie bycatch limits to halibut abundance, with final action on Halibut ABM at its December meeting. ABM means that as the halibut resource rises or falls, the limits on bycatch by the bottom trawl sector would rise or fall, as the catch limits do for the directed halibut fisheries.
We strongly support Alternative 4 – the only alternative being considered that would provide any meaningful benefit to the directed fishery.
Alternatives 2 and 3 do relatively little to reduce the bottom trawlers’ bycatch limits at low levels of halibut abundance, and offer insignificant improvement from the status quo.
Meaningful ABM creates badly needed conservation incentives. These incentives are lost entirely under the current non-constraining PSC limits because groundfish trawlers feel no effects from low abundance — and have no incentive to reduce halibut bycatch or take steps to conserve the halibut resource — because the impacts of low abundance are borne entirely by halibut commercial and sport fishermen.
We ask — and expect — the State of Alaska to use its leadership position at the NPFMC to select Alternative 4.
Alaskans believe in wise resource management and protecting the fisheries that Alaskans rely on. We ask that the State of Alaska take a leadership position in advancing these principles and selecting Alternative 4.
Sincerely,
[Alaska Stakeholders]