The Boat Company petitions for north Pacific trawl bycatch reductions
This month, in April 2022, The Boat Company, a conservation organization and eco-tour operator, petitioned Secretary of Commerce Gina Raimondo in April of 2022 to take regulatory action to address the bycatch of halibut, crab, salmon and sablefish in the North Pacific trawl fisheries. The Boat Company’s ecotours in Southeast Alaska include sport fishing for halibut or Chinook salmon and serve seafood such as sablefish harvested by Alaska commercial fishermen. The Boat Company’s charitable work focuses on Alaska conservation issues, particularly protecting fish, wildlife and their habitats. The Southeast Alaska communities where The Boat Company operates, like much of coastal Alaska, depend on large, diverse and locally owned small boat commercial and sport fleets which are vulnerable to reductions in access to fishery resources.
The Boat Company’s petition requests that the Department of Commerce undertake a rulemaking to revise the National Standard 9 guidelines. The 1996 Sustainable Fisheries Act added National Standard 9 which directs the National Marine Fisheries Service (NMFS) and Fishery Management Councils to minimize bycatch. The purpose of National Standard 9 was to stop what Alaska Senator Ted Stevens described as the “inexcusable amount of waste” in large part by the north Pacific trawl industry and bycatch impacts to fish species of high value to commercial, sport and subsistence fisheries, such as halibut, salmon and crab.
Since 1996, Bering Sea trawlers have taken over 900,000 Chinook salmon as bycatch. Many of these fish spawn in western Alaska where Native Alaskans have lost both commercial and subsistence fisheries even as annual bycatch numbers typically run in the tens of thousands. Gulf of Alaska trawlers killed an estimated half a million Chinook salmon while numerous stocks declined, causing closures of sport and commercial fisheries. Trawlers are responsible for at least 181 million pounds of halibut bycatch mortality since 1996. There are no limits to control the significant recent bycatch of large numbers of juvenile sablefish and mature chum salmon. Trawling effort is intensive in large portions of the Bering Sea once closed to foreign trawlers in order to protect red king crab and juvenile halibut habitat.
The current National Standard 9 guidelines rely on Fishery Management Councils to set priorities on when and where to minimize bycatch and to decide how much bycatch is too much. The Boat Company’s petition explains that the factors listed in the regulations do not provide clear direction to protect the interests of fisheries that target species taken as bycatch by the trawl industry. The North Pacific Fishery Management Council (NPFMC) and NMFS perceive bycatch management as presenting a choice in balancing “competing” requirements of the Magnuson-Stevens Act National Standards and set bycatch limits that are too high, or for some species, impose no limits at all. The rationale for inaction or limited action relies on comparisons of wholesale revenue losses for trawl companies caused by lower bycatch limits versus the additional earnings realized by crab, halibut or salmon fishermen through bycatch “savings” achieved by small cuts to the limits.
One of the primary concerns expressed in the petition is increasing proportion of high value fish species taken by the trawl industry as bycatch. Dozens of Alaska coastal communities depend on commercial, recreational or subsistence fisheries for culturally, economically and recreationally valuable species such as salmon, sablefish, halibut and crab. Changing conditions in the marine environment are increasing the vulnerability and reducing the abundance of many marine species, magnifying the impacts of trawl industry bycatch on other fishermen.
The petition requests that the regulations add provisions to identify thresholds at which North Pacific trawl bycatch cannot exceed harvests in directed fisheries such as when target fisheries for bycatch species are closed for conservation purposes or when trawl bycatch consumes a disproportionate share of the harvestable quota. The petition also requests that regulations direct NMFS and the NPFMC to comprehensively and cumulatively consider the impacts of trawl bycatch on the directed halibut, salmon, sablefish and crab fisheries when undertaking fishery management measures, including an accounting for the full external costs of trawl industry bycatch on other fishery resource users.
The petition focused on regulating trawl gear because it is responsible for the largest proportion of the bycatch mortality: (1) the majority of halibut bycatch; (2) significant numbers of Chinook and chum salmon each year that originate in Alaska rivers that are experiencing record low productivity for some stocks; (3) increasingly large numbers of sablefish and (4) significant bycatch of dwindling crab populations and unobserved crab mortality due to encounters with trawls on the sea floor. Trawl bycatch of these species includes a high proportion of juvenile fish, reducing future yields for fishermen who would otherwise harvest the bycaught species once mature.
The petition cites recent research identifying trawling as the most urgent and appropriate focus for bycatch management. Bottom trawling has the highest overall environmental impact in terms of any of the ten major fishing gears used in U.S. fisheries and has a disproportionate impact on marine biodiversity. It is highly non-selective and fish frequently die before hauled on deck for sorting. The high volume of fish taken in trawls exacerbates the risk of on-deck or post-discard mortalities. Bottom trawling is also the largest human cause of damage to global sea bed and coral habitats with effects comparable to forest clear-cutting. These disturbances degrade habitats used by fish for spawning, breeding, feeding or growth to maturity.
One of the main concerns expressed in the petition is the failure of NMFS and NPFMC bycatch management actions to recognize cumulative harms to sport, subsistence and commercial fisheries facing reduced availability of multiple target fish species and lower catches and revenues. Fisheries analysts recognize that trawl bycatch is a “negative externality,” meaning that the cost of bycatch is paid by society or other fishermen rather than the trawl companies responsible for the economic losses caused by taking high value fish species as bycatch. Recent economic studies referenced in the petition show that the value of locally owned, harvested and/or processed salmon, sablefish, halibut and crab caught in Alaska’s diverse fisheries is critical to coastal fishing communities because of direct and indirect jobs and other induced economic effects. The value chain is different for trawl industry economic outputs which mostly accrue to non-Alaska companies, workers in the Seattle area, and Asian countries that do primary or re-processing of trawl caught groundfish.
According to the petition, from 2017-2021 the trawl industry took nearly 232,000 individual Chinook salmon, nearly two million individual chum salmon, nearly 136,000 Bering Sea red king crab, over 5.7 million bairdi and opilio crab, 21.3 million round pounds of sablefish, and 21.5 million net pounds of halibut. Red king crab and Chinook salmon are Alaska’s most valuable fish species, worth roughly $80 per fish or crab if caught in directed fisheries. Halibut values are similar with prices projected to reach as much as $8.00 per pound in 2022, meaning that directed fishery losses to bycatch could exceed $30 million this year alone based on research showing how the numbers of juvenile halibut taken as bycatch would otherwise grow and contribute to the directed fisheries. Sablefish bycatch may have comparable economic impacts due to future growth and bycatch volumes. The large numbers of individual chum or snow/opilio crab are worth roughly $4 to $8 apiece. According to The Boat Company, these losses recur year after year, imposing a significant cost on Alaska’s fishing communities and other U.S. fishermen who target these species but NMFS and the NPFMC have never considered these cumulative costs together.
The socio-economic impacts of the bycatch vary between regions, the abundance of specific populations, whether the bycaught fish are juveniles or adults, the potential for natural mortality, or in the case of salmon, area of origin. For some populations such as Bering Sea king crab or Chinook salmon, conservation measures are necessary just to restore directed fishery harvests. For some of these species at lower abundance levels, in some years the only source of anthropogenic removals is trawl bycatch. For others, bycatch reductions would result in increased harvests for other fishermen and add millions of dollars circulating in Alaska coastal fishing community economies. A link to the 30-page petition is available here:
