MRAG-MSC-F28-v2.01 March 2019

8950 Martin Luther King Jr. Street N. #202 St. Petersburg, Florida 33702-2211 Tel: (727) 563-9070 Fax: (727) 563-0207 Email: [email protected]

President: Andrew A. Rosenberg, Ph.D.

Bering Sea and Aleutian Islands and Gulf of Alaska Pollock

3rd MSC Re-assessment

Announcement Comment Draft Report

May 16, 2019

Conformity Assessment Body (CAB) MRAG Americas, Inc.

Erin Wilson (team leader), Amanda Stern-Pirlot, Jodi Bostrom, Don Bowen, Assessment team Jake Rice, Paul Knapman

Fishery client At-Sea Processors Association

Assessment Type 3rd Re-assessment

1 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Document Control Record Document Draft Submitted By Date Reviewed By Date ACDR EW, JR, DB, JB 13 May 2019 ASP 14 May 2019

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1 Contents

1 Contents ...... 3 2 Glossary ...... 5 3 Executive summary ...... 5 3.1 Changes since previous assessment ...... 5 3.1.1 Principle 1 ...... 5 3.1.2 Principle 2 ...... 5 3.1.3 Principle 3 ...... 5 4 Report details ...... 6 4.1 Authorship and peer review details ...... 6 4.2 Version details ...... 7 5 Unit(s) of Assessment and Certification and results overview ...... 8 5.1 Unit(s) of Assessment and Unit(s) of Certification ...... 8 5.1.1 Unit(s) of Assessment ...... 8 5.1.2 Unit(s) of Certification ...... 8 5.1.3 Scope of assessment in relation to enhanced or introduced fisheries ...... 9 5.2 Assessment results overview...... 9 5.2.1 Determination, formal conclusion and agreement ...... 9 5.2.2 Principle level scores...... 9 5.2.3 Summary of conditions ...... 10 5.2.4 Recommendations ...... 10 6 Traceability and eligibility ...... 10 6.1 Eligibility date ...... 10 6.2 Traceability within the fishery ...... 10 6.3 Eligibility to enter further chains of custody ...... 12 6.4 Eligibility of Inseparable or Practicably Inseparable (IPI) stock(s) to enter further chains of custody 13 7 Scoring ...... 13 7.1 Summary of Performance Indicator level scores ...... 13 7.2 Principle 1 ...... 14 7.2.1 Principle 1 background ...... 14 7.2.2 Catch profiles ...... 15 7.2.3 Total Allowable Catch (TAC) and catch data ...... 17 7.2.4 Principle 1 Performance Indicator scores and rationales ...... 18 ...... 18 ...... 20 ...... 22 ...... 27 ...... 31 ...... 35 7.3 Principle 2 ...... 40 3 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

7.3.1 BSAI ecosystem ...... 40 7.3.2 GOA ecosystem ...... 40 7.3.3 Primary and secondary species ...... 41 7.3.4 ETP species ...... 51 7.3.5 Habitats ...... 66 7.3.6 Ecosystem ...... 69 7.3.7 Scoring elements ...... 69 7.3.8 Principle 2 Performance Indicator scores and rationales...... 72 ...... 72 ...... 74 ...... 76 ...... 78 ...... 80 ...... 82 ...... 84 ...... 86 ...... 89 ...... 91 ...... 93 ...... 95 ...... 97 ...... 98 ...... 100 7.4 Principle 3 Background ...... 103 7.4.1 Principle 3 Performance Indicator scores and rationales ...... 115 ...... 115 ...... 118 ...... 120 ...... 121 ...... 123 ...... 127 ...... 129 8 References ...... 131 9 Appendices ...... 137 9.1 Assessment information ...... 137 9.1.1 Previous assessments ...... 137 9.1.2 Small-scale fisheries ...... 137 9.2 Evaluation processes and techniques ...... 138 9.2.1 Site visits ...... 138 9.2.2 Stakeholder participation ...... 138 9.2.3 Evaluation techniques ...... 138 9.3 Peer Review reports ...... 139 9.4 Stakeholder input ...... 140

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9.5 Conditions – delete if not applicable ...... 141 9.6 Client Action Plan ...... 141 9.7 Surveillance ...... 142 9.8 Harmonised fishery assessments ...... 143 9.9 Objection Procedure – delete if not applicable ...... 145

2 Glossary View the MSC-MSCI Vocabulary. Insert an optional glossary or list of acronyms used. Note that any terms defined here shall not contradict terms used in the MSC-MSCI Vocabulary.

3 Executive summary 3.1 Changes since previous assessment To be drafted at Announcement Comment Draft Report stage To be completed at Public Certification Report stage

MRAG Americas was contracted by the At-Sea Processors Association to undertake a reduced reassessment for the Bering Sea and Aleutian Islands (BSAI) and Gulf of Alaska (GOA) pollock (Gadus chalcogrammus) fisheries. The BSAI and GOA Alaska pollock fisheries are currently certified under the Marine Stewardship Council (MSC) and Responsible Fisheries Management (RFM) Standards. This is their third reassessment against the MSC standard; they have been certified for 15 years. There are 2 total Units of Assessment (UoAs), one in the BSAI and one in the GOA (detailed below in Section 5).

No issues were identified, and no changes in the fishery occurred that would result in a change in certification from the last surveillance.

The reassessment of the fishery will be conducted by Erin Wilson (team leader) and Paul Knapman covering Principle 3, Jake Rice covering Principle 1, Jodi Bostrom and Don Bowen covering Principle 2 of the components of the MSC Standard, respectively.

The reassessment site visit will take place in Seattle, WA the week of June 19th, 2019, and will be held in conjunction with the MSC and RFM reassessment and/or surveillance activities for AK flatfish, and Pacific cod fisheries, and also with the full assessment of the BSAI , Pacific Ocean Perch and Northern Rockfish and Gulf of Alaska Pacific Ocean Perch, Northern Rockfish and Dusky Rockfish.

Although early in the assessment, it appears that the Alaska BSAI and GOA pollock fisheries continue to meet the MSC standard for sustainable fisheries. Further information, peer review, and stakeholder input will support the final determination.

3.1.1 Principle 1 There have been no substantive changes to stock status for any of the BSAI or GOA pollock stocks since the previous full MSC assessment (MRAG Americas 2016). In addition, there have been no substantive changes to harvest strategies, control rules, information collection, or stock assessment methods in this intervening period that would affect the certification of these fisheries. Updates to stock status and associated parameters are given in the Principle 1 background section of this report, however most details also present in MRAG Americas (2016) are not repeated here; rather they are incorporated by reference.

3.1.2 Principle 2 There have been no substantive changes to Principle 2 since the last surveillance and reassessment activities.

3.1.3 Principle 3 There have been no substantive changes to management for the BSAI or GOA pollock fisheries since the last surveillance and reassessment activities.

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4 Report details 4.1 Authorship and peer review details To be drafted at Announcement Comment Draft Report stage Peer reviewer information to be completed at Public Comment Draft Report stage

Ms. Erin Wilson (team leader). Erin Wilson joined MRAG Americas Inc. in 2015, where she currently works as a Senior Fisheries Consultant. She has served as a team member for several MSC assessments and conducts routine audits for the International Seafood Sustainability Foundation (ISSF). Prior to joining MRAG Americas, she spent 2 years working at the Oregon Department of Fish and Wildlife (ODFW) as a Natural Resource Specialist and Biological Technician for the Oregon Marine Reserves. She has collaborated on a multitude of projects that focus on marine science and conservation in both a biological and social science aspect. She received a M.Sc. in Marine Resource Management from Oregon State University and a B.S. in Zoology (with a marine emphasis) and a Spanish minor from Colorado State University. In addition, Erin has passed MSC v1.3, v2.0, v2.1 and ISO 19011 training.

Ms. Amanda Stern-Pirlot. Amanda is an M.Sc graduate of the University of Bremen, Center for Marine Tropical Ecology (ZMT) in marine ecology and fisheries biology. Ms. Stern-Pirlot joined MRAG Americas in mid-June 2014 as MSC Certification Manager (now Director of the Fishery Certification Division) and is currently serving on several different assessment teams as team leader and team member. She has worked together with other scientists, conservationists, fisheries managers and producer groups on international fisheries sustainability issues for over 15 years. With the Institute for Marine Research (IFM-GEOMAR) in Kiel, Germany, she led a work package on simple indicators for sustainable within the EU-funded international cooperation project INCOFISH, followed by five years within the Standards Department at the Marine Stewardship Council (MSC) in London, developing standards, policies and assessment methods informed by best practices in fisheries management around the globe. Most recently she has worked with the Alaska pollock industry as a resources analyst, within the North Pacific Fisheries Management Council process, focusing on bycatch and ecosystem-based management issues, and managing the day-to-day operations of the offshore pollock cooperative. She has co-authored a dozen publications on fisheries sustainability in the developing world and the functioning of the MSC as an instrument for transforming fisheries to a sustainable basis.

Paul Knapman. Paul is an independent consultant based in Halifax, Nova Scotia, Canada. Paul began his career in fisheries nearly 30 years ago as a fisheries officer in the UK, responsible for the enforcement of UK and EU fisheries regulations. He then worked with the UK government’s nature conservation advisors (1993-2001), as their Fisheries Programme Manager, responsible for establishing and developing an extensive programme of work with fisheries managers, scientists, the fishing industry and ENGOs, researching the effects of fishing and integrating nature conservation requirements into national and European fisheries policy and legislation. Between 2001-2004 he was Head of the largest inshore fisheries management organisation in England, with responsibility for managing an extensive area of inshore fisheries on the North Sea coast. The organisations responsibilities and roles included: stock assessments; setting and ensuring compliance with allowable catches; developing and applying regional fisheries regulations; the development and implementation of fisheries management plans; acting as the lead authority for the largest marine protected area in England. In 2004, Paul moved to Canada and established his own consultancy providing analysis, advisory and developmental work on fisheries management policy in Canada and Europe. He helped draft the management plan for one of Canada’s first marine protected areas, undertook an extensive review on IUU fishing in the Baltic Sea and was appointed as rapporteur to the European Commission’s Baltic Sea Regional Advisory Council. In 2008, Paul joined Moody Marine as their Americas Regional Manager, with responsibility for managing and developing their regional MSC business. He became General Manager of the business in 2012. Paul has been involved as a lead assessor, team member and technical advisor/reviewer for more than 50 different fisheries in the MSC programme. He returned to fisheries consultancy in 2015. Paul has passed MSC v1.3, v2.0, v2.1 and ISO 19011 training and has no Conflict of Interest in relation to this fishery.

Dr. Don Bowen. William Don Bowen is a Ph.D. graduate of the University of British Columbia, Vancouver, B.C. He has been a research scientist at the Bedford Institute of Oceanography, Dartmouth and an Adjunct Professor of Biology at Dalhousie University, Halifax, Nova Scotia for more than 25 years. He is best known for his research on the ecology, energetics and population dynamics of North Atlantic phocid seals, based largely on his collaborative studies at Sable Island. His interests also include mammalian life histories, population assessment, ecological interactions with fisheries, conservation and ecosystem change. Has published over 200 scientific papers, including 155 journal articles and book chapters and two books. He has served on the USA recovery team of the Hawaiian monk seal, and as chair of the UK Special Committee on Seals. He has broad national (Natural Science and Engineering Research Council, DFO) and international (National Academy, NSF, NRC, NMFS, NERC, NRPB) experience as a science advisor and served as member of the Board and Editor of Marine Mammal Science for five

6 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019 years. He has considerable experience as an MSC assessor and reviewer of more than 30 groundfish, pelagic, and invertebrate fisheries certifications in the Pacific, Atlantic and Southern Oceans.

Dr. Jake Rice. Dr. Jake Rice is Chief Scientist for the Department of Fisheries and Oceans, Canada. He previously served as Director of Peer Review and Science Advice and held senior DFO Science positions in Pacific and Newfoundland Regions. He received BSc. from Cornell (1970 Conservation) and Ph. D. from University of Toronto (1974 - Ornithology). He has more than 270 publications in the scientific and technical literature, primarily on the ecosystem approach to integrated management. He is a member of the Group of Experts for the UN Regular Process for Global Marine Assessments, and a Lead Authors for the chapter on Drivers, Trends and Mitigation, for the next IPCC Assessment Report. He has been active as an expert or delegate to many UN meetings and agencies (FAO, CBD, GEF, UNEP, UNESCO-IOC, ICP, BBNJ etc.).

Ms. Jodi Bostrom. Ms. Jodi Bostrom joined MRAG Americas as a Senior Fisheries Consultant and MSC Fisheries Program Manager in mid-2015. Prior to joining MRAG Americas, she spent five years working at the Marine Stewardship Council (MSC) in London as a Senior Fisheries Assessment Manager. Among many other things, she developed the MSC’s benthic habitats policy and the Consequence Spatial Analysis (a risk-based framework for assessing habitat impacts in data-deficient situations) as part of the MSC Standard revision. Prior to the MSC, Jodi spent 11 years with the National Academy of Sciences’ Ocean Studies Board in Washington, DC. She received an M.Sc. in Environmental Science at American University in 2006 and a B.Sc. in Zoology at the University of Wisconsin in 1999. Jodi’s main areas of work at MRAG Americas are serving on MRAG Americas’ MSC fisheries assessment teams and reviewing MSC assessment reports for technical quality and compliance. She has particular experience in the Principle 2 components of the MSC Standard.

Peer Reviewers TBD

4.2 Version details Table 1 Fisheries program documents versions

Document Version number

MSC Fisheries Certification Process Version 2.1

MSC Fisheries Standard Version 2.01

MSC General Certification Requirements Version 2.3

MSC Reduced Reassessment Reporting Template Version 2.1

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5 Unit(s) of Assessment and Certification and results overview 5.1 Unit(s) of Assessment and Unit(s) of Certification 5.1.1 Unit(s) of Assessment

Table 2.Unit(s) of Assessment (UoA)

UoA 1 Description

Species Alaska pollock (Gadus chalcogrammus)

Stock Bering Sea and Aleutian Islands (BSAI)

Geographical area Eastern Bering Sea and Aleutian Islands in the US 200 mile EEZ off Alaska

Harvest method / gear Midwater trawl

Client group At-Sea Processors Association

Other eligible fishers All pollock catchers and catcher-processors fishing in the BSAI

UoA 2 Description

Species Alaska pollock (Gadus chalcogrammus)

Stock Gulf of Alaska (GoA)

Geographical area Gulf of Alaska in the 200-mile EEZ off Alaska

Harvest method / gear Midwater trawl

Client group At-Sea Processors Association

Other eligible fishers All pollock catchers fishing in the Gulf of Alaska

5.1.2 Unit(s) of Certification To be drafted at Client and Peer Review Draft Report stage To be completed at Public Certification Report stage The report shall include a justification for any changes to the proposed Unit(s) of Certification (UoC).

Reference(s): FCP v2.1 Section 7.5

Table X – Unit(s) of Certification (UoC)

UoC X Description

Species

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Stock

Geographical area

Harvest method / gear

Client group

Other eligible fishers

UoC X Description

Species

Stock

Geographical area

Harvest method / gear

Client group

Other eligible fishers

UoC X Description

5.1.3 Scope of assessment in relation to enhanced or introduced fisheries MRAG Americas, Inc. has determined that these fisheries are within scope of the MSC and do not include enhanced or introduced species, explosives or poison, or unilateral exemptions.

5.2 Assessment results overview 5.2.1 Determination, formal conclusion and agreement To be drafted at Final Draft Report To be completed at Public Certification Report The report shall include a formal statement as to the certification determination recommendation reached by the assessment team on whether the fishery should be certified.

The report shall include a formal statement as to the certification action taken by the CAB’s official decision-makers in response to the Determination recommendation.

Reference(s): FCP v2.1 Section 7.21

5.2.2 Principle level scores To be drafted at Client and Peer Review Draft Report The report shall include scores for each of the three MSC principles in the table below.

Reference(s): FCP v2.1 Section 7.17

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Table X - Principle level scores

Principle UoA 1 UoA 2 UoA 3 UoA 4

Principle 1 – Target species

Principle 2 – Ecosystem impacts

Principle 3 – Management system

5.2.3 Summary of conditions To be drafted at Client and Peer Review Draft Report The report shall include a table summarising conditions raised in this assessment. Details of the conditions shall be provided in the appendices. If no conditions are required, the report shall include a statement confirming this.

Reference(s): FCP v2.1 Section 7.18

Table X – Summary of conditions

Performance Related to previous Condition number Condition Indicator (PI) condition?

Yes / No / NA

Yes / No / NA

Yes / No / NA

5.2.4 Recommendations To be drafted at Client and Peer Review Draft Report stage If the CAB or assessment team wishes to include any recommendations to the client or notes for future assessments, these may be included in this section.

6 Traceability and eligibility 6.1 Eligibility date As these fisheries are currently certified, and the reassessment is expected to be completed before the current certificate expires, the product should remain continuously eligible. The traceability and segregation systems in the fishery have been and continue to be appropriately implemented.

6.2 Traceability within the fishery

BSAI Pollock

NOAA Fisheries, Alaska Region, manages U.S. fisheries in the Exclusive Economic Zone (EEZ) of the waters off Alaska. Management includes Recordkeeping and Reporting procedures to promote the goals and objectives of fishery management plans, the Magnuson-Stevens Fishery Conservation and Management Act, and other applicable laws. Traceability of broad-scale fishing activity within this fishery is provided by the statutory requirements to record all fishing in through eLandings and through monitoring of vessel activity by fisheries enforcement bodies and satellite monitoring equipment (VMS), as the start of rigorous monitoring and traceability of the flatfish landings; eLandings is the Interagency Electronic Reporting System for reporting commercial fishery landings in Alaska. eLandings is used to

10 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019 report landings and/or production data for groundfish, Individual Fishing Quota (IFQ)/ Community Development Quota (CDQ) halibut and sablefish, and IFQ/CDQ crab and Community of Adak golden king crab. Further traceability is provided by the client’s own internal systems that record the date and time of fishing activities, and the date and time of packaging. At-sea landings consist of catcher vessels delivering to motherships, and catcher-processors that handle their own catch. Flow scales on all at-sea processors result in a high accuracy of total landings. At-sea processing results in boxes of frozen product, labeled with species, product weight, vessel, and date. The boxes proceed through the supply unopened until purchased. Landings onshore go to landing facilities, which require Chain of Custody, for sorting and processing. The American Fisheries Act (AFA) lists three motherships and 19 catcher/processors as eligible to participate in the BSAI pollock fishery. No other at-sea processing vessel is permitted to participate in the directed BSAI pollock fishery. Each of those vessels, or the company that owns and operates such vessels, hold MSC CoC certification. The AFA further identifies by name and vessel number specific harvesting vessels that can deliver to inshore BSAI processing facilities. Each of those facilities holds MSC CoC certification and is identified in federal regulation annually. All of the fish landed from this fishery can be traced back through MSC CoC record keeping requirements and federal fishery reporting requirements to particular fishing activities. Onshore processed product and at-sea processed product for which MSC CoC has been established is shipped from Akutan, Dutch Harbor, or “roadsteads” defined by regulation either as foreign-flag or U.S.-flag merchant ships. Observers provide round weight species composition of the catch, and the processing records document the product weights (e.g., fillets, blocks, H&G, oil and meal). Product recovery rates convert processed fish to round weight equivalents. All of the fish landed from this fishery can be traced back to particular fishing activities.

Nearly 100% of the catch had observer coverage in 2018, with similar coverage in earlier years. As all landings must be recorded, observer coverage is high, and all licensed fishing vessels may participate in the fishery, the likelihood of vessels fishing outside the UoC or the opportunity for substitution of certified fish with non-certified fish is negligible. Risk of substitution in the fishery is very low given that vessels fish only in the UoC where VMS and observer coverage is required. Risk of substitution at point of landing is controlled by the government required Product Transfer Report (PTR), which can be reconciled against the eLandings report. Risk of mixing at point of landing is controlled by the government required PTR, which is required to be reconciled during CoC audits given that CoC starts at the offload from the fishing vessel. At-sea processed product is frozen in boxes that are not opened at landing, and unprocessed onshore landings are sorted and recorded at processing facilities that require CoC.

Table 3. – Traceability within the fishery

Factor Description

Will the fishery use gears that are not part of the Unit of Certification (UoC)?

If Yes, please describe: No - If this may occur on the same trip, on the same vessels, or during the same season; - How any risks are mitigated. Will vessels in the UoC also fish outside the UoC geographic area?

No If Yes, please describe: - If this may occur on the same trip; - How any risks are mitigated. Do the fishery client members ever handle certified and Yes, there is a very small proportion of the catch and non-certified products during any of the activities landings that is either not pollock or other certified stocks. covered by the fishery certificate? This refers to both at- sea activities and on-land activities. Management measures exist to mitigate any risk of mixing

fish of different species both on board vessels and during - Transport at-sea or shoreshide processing except where exempted - Storage under IPI exemptions (e.g. fishmeal/oil processing). All - Processing product is packed on board with harvest location and other - Landing traceability information recorded and displayed on labelling. - Auction Vessels are subject to 100% observer coverage at all

times. If Yes, please describe how any risks are mitigated.

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Does transhipment occur within the fishery?

If Yes, please describe: - If transhipment takes place at-sea, in port, or No. both; - If the transhipment vessel may handle product from outside the UoC; - How any risks are mitigated. Are there any other risks of mixing or substitution between certified and non-certified fish? No.

If Yes, please describe how any risks are mitigated.

6.3 Eligibility to enter further chains of custody To be drafted at Announcement Comment Draft Report stage To be completed at Public Certification Report stage

Traceability of product to the point of offload and sale is excellent, and BSAI and GOA pollock may enter the MSC certified CoC. In the BSAI management area, approximately half the landings are processed at sea as surimi and as headed and gutted, frozen fillet blocks minced products, and individually frozen fillets. Other products that qualify for MSC CoC products include fish oil and fish meal. The BSAI pollock not processed at sea is landed at on-shore processing facilities with the same general product forms produced as in the at-sea processing sector. Chain of custody for unprocessed on-shore landings starts upon landing to a processing facility. CoC for at-sea processors starts on board at delivery to the factory for vessels operating as catcher/processors or in mothership capacity.

In the GOA area, all licensed pollock fishing vessels in the GOA may participate in the fishery. GOA pollock taken in the directed pollock fishery or as incidental catch in MSC certified GOA groundfish fisheries are landed on shore unprocessed and processed into the same type of product forms as in the BSAI pollock fishery. A small portion of GOA pollock taken as incidental catch by at-sea processors in the MSC certified groundfish fisheries is either frozen round, or headed and gutted, then frozen. All such non-pollock groundfish at-sea processors are on the certificates for the GOA Pacific cod and/or flatfish and have MSC CoC certification procedures in place.

Through agreement with the Alaska pollock client between MSC clients for the Pacific cod and Alaska flatfish certifications, incidental catch of pollock in those groundfish fisheries is eligible to be marketed as MSC certified. All of the participants in the Pacific cod and flatfish certifications hold MSC CoC certification, ensuring that incidental catches of pollock by those parties conform to the same rigorous CoC requirements as directed harvests in those fisheries. All licensed pollock fishing vessels in the BSAI may participate in the fishery. The APA, its members, and following companies are members of the Client Group for the MSC BSAI pollock fishery:

Alyeska Seafoods Company; American Seafoods Company; Arctic Fjord, Inc.; Arctic Storm, Inc.; Coastal Villages; Glacier Fish Company; Golden Alaska Seafoods; Icicle Seafoods; Ocean Peace, Inc.; Peter Pan Seafoods; Premier Pacific Seafoods; Starbound LLC; Supreme Alaska Seafoods; Trident Seafoods Corporation; UniSea; Westward Seafoods.

CoC for any at-sea processing of GOA pollock in the Pacific cod or flatfish fisheries starts with receipt of the product from the fishing vessel, accompanied by a government required landing report (fish ticket, eLanding, or equivalent). The activity of processing at sea is included within the scope of the fishery certificate. Storage, transport, and further processing must fall under the CoC of the receiving company. The APA and the following companies are members of the Client Group for the MSC GOA pollock fishery:

Trawl: Alyeska Seafoods Company; Icicle Seafoods; International Seafoods; North Pacific Seafoods; Ocean Beauty Seafoods; Pacific Seafood Group; Peter Pan Seafoods; Trident Seafoods Corporation; UniSea; Westward Seafoods.

The APA has a certificate sharing agreement with the Alaska Seafood Cooperative (AKSC) for allowing the pollock fishery to land certified flatfish, and for allowing the flatfish fisheries to land certified pollock. The APA has a certificate sharing agreement with the Alaska Fishery Development Foundation for allowing the pollock fishery to land certified Pacific cod, and for allowing the Pacific cod fisheries to land certified pollock. Certificate sharing agreements are available from the MSC webpages for flatfish and pollock. The Pacific cod and flatfish fisheries have excellent traceability (https://www.msc.org/track-a-fishery/fisheries-in-the-program/certified/pacific/gulf-of-alaska-pacific- 12 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019 cod/reassessment-downloads-folder/20150618_PCR_COD050.pdf; https://www.msc.org/track-a-fishery/fisheries-in- the-program/certified/pacific/gulf-of-alaska-flatfish/reassessment-downloads-folder/20151028_PCR_FLA049.pdf). The members of the Pacific cod and flatfish client groups are well identified, so that pollock only from eligible companies may enter the supply chain under MSC CoC.

6.4 Eligibility of Inseparable or Practicably Inseparable (IPI) stock(s) to enter further chains of custody The BSAI Pollock fishery uses small amounts of uncertified fish in fish meal and fish oil, in the range of 0.08 % and 0.24 % of the total catch of target and IPI species. The fishery received a variation from MSC on 3 March 2011 that allows for IPI stocks to enter further chains of custody.

7 Scoring 7.1 Summary of Performance Indicator level scores BSAI GOA Principle Component Weight Performance Indicator (PI) Weight Pollock Pollock Score Score 1.1.1 Stock status 1.000 Outcome 0.333 1.1.2 Stock rebuilding 0.000 NA NA 1.2.1 Harvest strategy 0.250 Harvest control One 1.2.2 0.250 rules & tools Management 0.667 Information & 1.2.3 0.250 monitoring Assessment of 1.2.4 0.250 stock status 2.1.1 Outcome 0.333 Management Primary 2.1.2 0.333 0.200 strategy species Information/ 2.1.3 0.333 Monitoring 2.2.1 Outcome 0.333 Management Secondary 2.2.2 0.333 0.200 strategy species Information/ 2.2.3 0.333 Monitoring 2.3.1 Outcome 0.333 Two Management 2.3.2 0.333 ETP species 0.200 strategy Information 2.3.3 0.333 strategy 2.4.1 Outcome 0.333 Management Habitats 0.200 2.4.2 0.333 strategy 2.4.3 Information 0.333 2.5.1 Outcome 0.333 Ecosystem 0.200 2.5.2 Management 0.333 2.5.3 Information 0.333

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Legal &/or 3.1.1 customary 0.333 framework Governance 0.500 Consultation, roles and policy 3.1.2 0.333 & responsibilities Long term 3.1.3 0.333 objectives Fishery specific 3.2.1 0.250 Three objectives Decision making 3.2.2 0.250 Fishery processes specific Compliance & 0.500 3.2.3 0.250 management enforcement system Monitoring & management 3.2.4 0.250 performance evaluation

7.2 Principle 1 7.2.1 Principle 1 background Life history and fishing history

Pollock life histories in the BSAI and GoA are described in MRAG Americas (2016a) and (2016b).

BSAI Pollock The following excerpt is taken directly from Ianelli et. al. (2018) with references to tables indicating the tables in the source document:

Historically, EBS pollock catches were low until directed foreign fisheries began in 1964. Catches increased rapidly during the late 1960s and reached a peak in 1970–75 when they ranged from 1.3 to 1.9 million t annually. Following the peak catch in 1972, bilateral agreements with Japan and the USSR resulted in reductions. During a 10-year period, catches by foreign vessels operating in the “Donut Hole” region of the Aleutian Basin were substantial totaling nearly 7 million t (Table 1). A fishing moratorium for this area was enacted in 1993 and only trace amounts of pollock have been harvested from the Aleutian Basin region since then. Since the late 1970s, the average EBS pollock catch has been about 1.2 million t, ranging from 0.810 million t in 2009 to nearly 1.5 million t during 2003– 2006 (Table 1). United States vessels began fishing for pollock in 1980 and by 1987 they were able to take 99% of the quota. Since 1988, U.S. flagged vessels have been operating in this fishery. The current observer program for the domestic fishery formally began in 1991 and prior to that, observers were deployed aboard the foreign vessels since the late 1970s. From the period 1991 to 2011 about 80% of the catch was observed at sea or during dockside offloading. Since 2011, regulations require that all vessels participating in the pollock fishery carry at least one observer so nearly 100% of the pollock fishing operations are monitored by scientifically trained observers. Historical catch estimates used in the assessment, along with management measures (i.e., ABCs and TACs) are shown in Table 2.

GOA Pollock

The following text is excerpted directly from Dorn et. al (2018) with table, figure and other references available in the source document:

The commercial fishery for pollock in the GOA started as a foreign fishery in the early 1970s (Megrey 1989). Catches increased rapidly during the late 1970s and early 1980s (Table 1.1). A large spawning aggregation was discovered in Shelikof Strait in 1981, and a fishery developed for which pollock roe was an important product. The domestic fishery for pollock developed rapidly in the GOA with only a short period of joint venture operations in the mid-1980s. The fishery was fully domestic by 1988.

The pollock target fishery in the GOA is entirely shore-based with approximately 90% of the catch taken with pelagic trawls. During winter, fishing effort targets pre-spawning aggregations in Shelikof Strait and near the Shumagin

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Islands (Fig. 1.1). Fishing in summer is less predictable, but typically occurs in deep-water troughs on the east side of Kodiak Island and along the Alaska Peninsula.

Since 1992, the GOA pollock Total Allowable Catch (TAC) has been apportioned spatially and temporally to reduce potential impacts on Steller sea lions. The details of the apportionment scheme have evolved over time, but the general objective is to allocate the TAC to management areas based on the distribution of surveyed biomass, and to establish three or four seasons between mid-January and fall during which some fraction of the TAC can be taken. The Steller Sea Lion Protection Measures implemented in 2001 established four seasons in the Central and Western GOA beginning January 20, March 10, August 25, and October 1, with 25% of the total TAC allocated to each season. Allocations to management areas 610, 620 and 630 are based on the seasonal biomass distribution as estimated by groundfish surveys. In addition, a harvest control rule was implemented that requires suspension of directed pollock fishing when spawning biomass declines below 20% of the reference unfished level.

7.2.2 Catch profiles

BSAI Pollock

The following table from Ianelli et. al. (2018) shows the catch history for BSAI pollock from 1964-2018:

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Table 4 Source: Ianelli et al. (2018)

GOA Pollock

The following table from Dorn et. al (2018) shows the catch history for GOA pollock from 1964-2018:

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Table 5 Source: Dorn et. al (2018)

7.2.3 Total Allowable Catch (TAC) and catch data

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Table X – Total Allowable Catch (TAC) and catch data BSAI pollock

TAC Year 2018 Amount 1,364,341 mt

UoA share of TAC Year 2018 Amount 100%

UoA share of total TAC Year 2018 Amount 100%

Year (most Total green weight catch by UoC 2018 Amount 1,346,615 mt recent) Year (second Total green weight catch by UoC 2017 Amount 1,343,217 mt most recent)

Table X – Total Allowable Catch (TAC) and catch data GOA pollock

TAC Year 2018 Amount 161,492 mt

UoA share of TAC Year 2018 Amount 100%

UoA share of total TAC Year 2018 Amount 100%

Year (most Total green weight catch by UoC 2018 Amount 151,768 mt recent) Year (second Total green weight catch by UoC 2017 Amount 186,157 mt most recent)

7.2.4 Principle 1 Performance Indicator scores and rationales

The stock is at a level which maintains high productivity and has a low probability of PI 1.1.1 recruitment overfishing Scoring Issue SG 60 SG 80 SG 100 Stock status relative to recruitment impairment It is likely that the stock is It is highly likely that the There is a high degree of a Guide above the point where stock is above the PRI. certainty that the stock is post recruitment would be impaired above the PRI. (PRI). BSAI-Y BSAI-Y BSAI-Y Met? GOA-Y GOA-Y GOA-Y Rationale

BSAI Stock:

The Limit Reference Point for the Eastern Bering Sea (EBS) stock component is not defined in the assessment report, but for US stocks managed as Tier 1 values of B25% are used in harvest control rules to guide the rate at which fishing mortality should be curtailed as much as possible. In practice, for the EBS stock component the OFL serves the function of a limit reference point for this stock, in that when SSB is estimated to fall below this value, the stock is considered to be overfished and rebuilding becomes the management priority for the stock.

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For the Aleutian Island (AI) stock, for the Tier 3 assessment models the B20% were used as proxies for limits, to give an added degree of precaution, Moreover, catches in AI are controlled by regulation and kept below 19,000 or the estimated ABC whichever is less.

The current female spawning biomass is 2,725,000 mt and Bmsy is 2,280,000 mt. Total age 3+ biomass is currently estimated at 9,110,000 mt. The current biomass is 36% above Bmsy and the 2018 biomass was 56% above Bmsy.

The current catches are constrained to well less than the max Allowable Biological Catches (ABC) due to the BSAI Optimal Yield (OY) rules (capping total removals from the BSAI for all fisheries at 2 million mt). Based on pollock stock biomass alone, the recommended ABC for 2019 would have been 2,163,000 mt but because of OY, the TAC was set at 1.36 million mt.

According to Figure 46 in Ianelli et. al. 2018, in the recent past, the stock fell below Bmsy between 2008 and 2010 and has been above this level (estimated annually) every year since. Hence there is a high degree of certainty that the stock is above the PRI and the SG 80 and SG100 is met for this scoring issue.

GOA Stock: The current female spawning biomass is 345,352 mt and B35% (a proxy for Bmsy) is 194,000 mt. Total age 3+ biomass is estimated at 1,126,750 mt. The maxABC recommendation for 2018 was 161,492 mt and this was the TAC set. Catches were roughly 10,000 t below this.

The Limit Reference Point for the GOA stock component is not defined in the assessment report, but for US stocks managed as Tier 3 values of B25% or B20% (depending on details of life history) are used in harvest control rules to guide the rate at which fishing mortality should be curtailed as much as possible. In practice the OFL serves some important functions of a limit reference point for this stock, in that when SSB is estimated to fall below this value, the stock is considered to be overfished and rebuilding becomes the management priority for the stock

According to Figure 1.36 in Dorn et. al. (2018), the stock has been fluctuating above Bmsy with fishing mortality well below the Overfishing Limit (OFL) for the past approximately 20 years. Hence there is a high degree of certainty that the stock is above the PRI and the SG 80 and SG100 is met for this scoring issue.

Stock status in relation to achievement of Maximum Sustainable Yield (MSY) The stock is at or fluctuating There is a high degree of around a level consistent with certainty that the stock has b Guide MSY. been fluctuating around a post level consistent with MSY or has been above this level over recent years. BSAI-Y BSAI-Y Met? GOA-Y GOA-Y Rationale

BSAI Stock: The current female spawning biomass is 2,725,000 mt and Bmsy is 2,280,000 mt. Total age 3+ biomass is currently estimated at 9,110,000 mt. The current biomass is 20% above Bmsy and the 2018 biomass was 56% above Bmsy.

The current catches are constrained to well less than the max Allowable Biological Catches (ABC) due to the BSAI Optimal Yield (OY) rules (capping total removals from the BSAI for all commercial groundfish fisheries at 2 million mt). Based on pollock stock biomass alone, the recommended ABC for 2019 would have been 2,163,000 mt but because of OY, the TAC was set at 1.36 million mt.

According to Figure 46 in Ianelli et. al. 2018, in the recent past, the stock fell below Bmsy between 2008 and 2010 and has been above this level (estimated annually) every year since. Hence there is a high degree of certainty that the stock has been fluctuating around a level consistent with Bmsy or above over recent years and the SG100 is met.

GOA Stock: The current female spawning biomass is 345,352 mt and B35% (a proxy for Bmsy) is 194,000 mt. Total age 3+ biomass is estimated at 1,126,750 mt. The maxABC recommendation for 2018 was 161,492 mt and this was the TAC set. Catches were roughly 10,000 t below this.

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According to Figure 1.36 in Dorn et. al. (2018), the stock has been fluctuating above Bmsy with fishing mortality well below the Overfishing Limit (OFL) for the past approximately 20 years. Hence there is a high degree of certainty that the stock has been fluctuating around a level consistent with Bmsy or above over recent years and the SG100 is met.

References

Ianelli, J.N., S. Kotwicki, T. Honkalehto, A. McCarthy, S. Stienessen, K. Holsman, E. Siddon, and B. Fissel. 2018. “1. Assessment of the Walleye Pollock stock in the Eastern Bering Sea.” Stock Assessment and Fishery Evaluation Report for the Groundfish Resources of the Bering Sea/Aleutian Islands Region. North Pacific Fishery Management Council, 605 West 4th Avenue, Suite 306, Anchorage, Alaska. https://www.fisheries.noaa.gov/webdam/download/87442184

Dorn, M., Aydin, K., Fissel, B., Palsson W., Spalinger, K., Stienssen, S., Williams K, and Zador, S., 2018. Assessment of the walleye pollock stock in the Gulf of Alaska. In Stock Assessment and Fishery Evaluation Report for Groundfish Resources of the Gulf of Alaska. Prepared by the Gulf of Alaska Groundfish Plan Team, North Pacific Fishery Management Council, P.O. Box 103136, Anchorage, AK 99510. North Pacific Fisheries Management Council, Anchorage, AK. https://www.afsc.noaa.gov/REFM/Docs/2018/GOA/GOApollock.pdf

Stock status relative to reference points Type of reference point Value of reference point Current stock status relative to reference point Reference point BSAI Stock: B25% BSAI Stock: 1,348,500 mt BSAI Stock: used in scoring GOA Stock: B20% GOA Stock: 119,200 mt FSSBcurrent/FSSB25%=2.0 stock relative to (200%) PRI (SIa) GOA Stock: 2.9 (290%) FSSBcurrent/FSSB20%= Reference point BSAI Stock: Bmsy BSAI stock: 2.28 million mt BSAI stock: used in scoring GOA Stock: B35% (B40% as female spawning stock FSSBcurrent/FSSBmsy=1.2 stock relative to management trigger). biomass (120%) MSY (SIb) GOA stock: 194,000 mt female GOA stock: spawning biomass FSSBcurrent/FSSB35%=1.8 (180%)

Draft scoring range and information gap indicator added at Announcement Comment Draft Report Draft scoring range Both stocks ≥80

Information gap indicator Information sufficient to score PI

Where the stock is reduced, there is evidence of stock rebuilding within a specified PI 1.1.2 timeframe Scoring Issue SG 60 SG 80 SG 100 Rebuilding timeframes A rebuilding timeframe is The shortest practicable specified for the stock that is rebuilding timeframe is the shorter of 20 years or 2 specified which does not a Guide times its generation time. exceed one generation time post For cases where 2 for the stock. generations is less than 5 years, the rebuilding timeframe is up to 5 years. Met? N/A N/A

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Rationale

Not Applicable for either the BSAI or GOA.

Rebuilding evaluation Monitoring is in place to There is evidence that the There is strong evidence that determine whether the rebuilding strategies are the rebuilding strategies are rebuilding strategies are rebuilding stocks, or it is rebuilding stocks, or it is effective in rebuilding the likely based on simulation highly likely based on b Guide stock within the specified modelling, exploitation rates simulation modelling, post timeframe. or previous performance that exploitation rates or previous they will be able to rebuild the performance that they will be stock within the specified able to rebuild the stock within timeframe. the specified timeframe. Met? N/A N/A N/A

Rationale

Insert sufficient rationale to support the team’s conclusion for each Scoring Guidepost (SG).

References

List any references here, including hyperlinks to publicly-available documents.

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range NA

Information gap indicator NA

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

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PI 1.2.1 There is a robust and precautionary harvest strategy in place

Scoring Issue SG 60 SG 80 SG 100

Harvest strategy design The harvest strategy is The harvest strategy is The harvest strategy is expected to achieve stock responsive to the state of the responsive to the state of the management objectives stock and the elements of the stock and is designed to Guide a reflected in PI 1.1.1 SG80. harvest strategy work achieve stock management post together towards achieving objectives reflected in PI 1.1.1 stock management objectives SG80. reflected in PI 1.1.1 SG80. BSAI-Y BSAI-Y BSAI-Y Met? GOA-Y GOA-Y GOA-Y Rationale

BSAI Stock The harvest strategy for EBS pollock has been explored in past assessments, and general reviews, with simulations including the main sources of uncertainty (Fissel et al. 2012, Goodman et al. 2002, Deroba et al. 2015). The general framework used by NMFS and the NPFMC to set Overfishing Levels (OFL), a smaller Allowable Biological Catch (ABC) (to take account of uncertainties and introduce greater precaution in decision-making, plus an overall cap on total groundfish harvest OY) are considered to control harvests effectively. The ABCs depend on the state of the stocks and are designed to achieve management objectives reflected by stock target and limit reference points (NMFS 1998,1999).

For the Alaska groundfish fisheries, the species-stock ABCs from the assessments are the first limit in a series of limits that eventually determines the managed groundfish harvests (Witherell et al. 2000), with a total cap on groundfish removals from BSAI providing a second tier of restrictions on total harvest.

The framework of OFLs based on biologically based overfishing reference points, lower ABCs to take account of uncertainties and the aggregate cap on harvests work together and should prevent the stock from being fished to the point where the corresponding limit reference point is violated. The strategy should move the stock towards the target reference point when it is between the target and limit reference points and receiving average or better recruitment.

When it is receiving poor recruitment, it may lose some ground relative to the target reference point, but fishing is systematically managed to reduce exploitation well before the limit is passed. Thus, the SG 100 is met for this stock component.

For the AI component the harvest strategy is fundamentally the same but has been superseded by a regulation that limits harvests to 19,000 mt or the ABC, whichever is less. Thus, the harvest strategy maintains the responsiveness to stock status at low SSB but restricts the amount by which harvests can increase as stock status increases. Hence it is at least as precautionary as for EBS, and more cautious due to uncertainties about assessment accuracy as estimates of stock status increase. Thus, the SG 100 is also considered to be met for this stock component.

GOA Stock The harvest strategy for GOA pollock has been explored in past assessments, general reviews, and with detailed stock-specific simulations including the main sources of uncertainty, part of a Ph.D. thesis within the past decade (A‘Mar et al. 2009a, 2009b, 2010).

The general framework used by NMFS and the North Pacific Council to set OFLs, a smaller ABC (to take account of uncertainties and introduce greater precaution in decision-making), plus an overall cap on total groundfish harvest are considered to control harvests effectively. The ABCs depend on the state of the stocks and are designed to achieve management objectives reflected by stock target and limit reference points (NMFS 1998, 1999).

The framework of OFLs based on biologically based overfishing reference points, lower ABCs to take account of uncertainties should prevent the stock from being fished to the point where the corresponding limit reference point is violated. The strategy should move the stock towards the target reference point when it is between the target and limit 22 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019 reference points and receiving average or better recruitment. When it is receiving poor recruitment, it may lose some ground relative to the target reference point, but fishing is systematically managed to reduce exploitation well before the limit is passed, Thus the SG60, SG80 and SG100 are met for this stock component.

Harvest strategy evaluation The harvest strategy is likely The harvest strategy may not The performance of the to work based on prior have been fully tested but harvest strategy has been experience or plausible evidence exists that it is fully evaluated and evidence Guide argument. achieving its objectives. exists to show that it is b post achieving its objectives including being clearly able to maintain stocks at target levels. BSAI-Y BSAI-Y BSAI-Y Met? GOA-Y GOA-Y GOA-Y Rationale

BSAI Stock The harvest control rule has been evaluated both in a general way (NMFS 1995, 2009), and with thorough investigations of the control rules for EBS pollock and other stocks with similar life histories (Goodman et al. 2002, Deroba et al. 2015). In addition, the exploration of scenarios in the annual assessments (Ianelli et al. 2018 and preceding ones) documents that the control rule should perform in a precautionary manner relative to target and limit reference points.

The power of the harvest strategy to manage BSAI pollock harvests successfully in a variable environment was established during assessments in the mid-2000s, when 5 of the 7 year-classes from 1999-2006 were below average to poor and the other two year-classes in that period were barely average. The cause of below average to poor recruitments was documented to be in large part due to environmental conditions that began to reverse in the second half of the 2000s (Stabeno et al. 2013, Heintz et al. 2013, Siddon et al. 2013).

Nevertheless, the harvest strategy successfully managed to reduce exploitation during this period such that the stock never reached a level where recruitment would likely be impaired due to limited spawning biomass. Thus, it performed in practice in a precautionary manner when challenged; under present conditions there is high confidence that the harvest strategy functions in a precautionary manner. This meets the SG 60, SG80 and SG100.

GOA Stock The harvest control rule has been evaluated both in a general way (NMFS 1999, 2005, 2009), and with thorough investigations of the control rules for GOA Pollock and other stocks with similar life histories (A’Mar 2009a, 2009b, 2010, DeRoba et al. 2015) in addition the exploration of scenarios in the annual assessments (Dorn et al. 2018 and preceding ones) documents that control rules should perform in a precautionary matter relative to target and limit reference points.

The power of the harvest strategy to manage GOA Pollock harvests successfully in a variable environment was established over the past decade. As demonstrated in figure 1.30 of Dorn et al. 2014, over most of the 2000s, the productivity of the stock, as measured by an index of log (recruits/spawning biomass), has been lower than during the preceding three decades, consistent with the presence of unfavorable oceanographic conditions (see 1.1.1 and 1.1.2 for references). The drop-in stock productivity begins at a time of maximum female spawning biomass and clearly precedes a decline in SSB, which did commence once the stock productivity dropped. Nevertheless, the harvest control rule managed the decline in spawning biomass particularly in the mid-2000s, to keep the stock above the limit reference point even after several consecutive years of poor recruitment and allowed rapid and secure improvement in spawning biomass as soon as stock productivity improved. Thus, the harvest control rule has been challenged in the real world and shown to be robust, meeting the SG 60, SG80, and SG100 levels.

Harvest strategy monitoring c Monitoring is in place that is Guide expected to determine post whether the harvest strategy is working.

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BSAI-Y Met? GOA-Y Rationale

BSAI Stock Full at-sea monitoring of the offshore fleet is conducted by the observer program and dockside monitoring. Hence the catch documentation is considered very reliable. Discards are managed and included in the reporting scheme for the fisheries. Moreover, the eastern Bering Sea shelf monitoring survey has excellent coverage of the normal range of the Eastern Bering Sea pollock, providing annual fishery independent estimates of stock status. There have been some years when surveys suggest the EBS component extends outside the US EEA and into waters of the Russian Federation. However, practices have been in place in some years for exchange of survey information, and these uncertainties are included in the assessment.

The EBS surveys are augmented by the less frequent survey of the small Aleutian Island component of the stock. The annual data on catches and from surveys are combined in the assessment to provide annual time series of stock status. The trajectory of stock status and exploitation rate, measures of B (age 0+, age 3+ and female spawning) and F provide sufficient feedback to evaluate whether the harvest control rules are working. Hence the SG 60 is fully met.

GOA Stock At-sea monitoring of the offshore fleet is conducted by the observer program, which underwent significant restructuring in 2012/2013. Coverage varies among vessel types but the mode of allocation of observers to vessels is designed to ensure unbiased estimates of catch. Performance review in 2014 (NMFS 2015) indicated that implementation is meeting the intent of the program, and coverage has reached nearly a quarter of GOA Pollock trips (NMFS 2015). Catch is reported through an electronic reporting system (eCatch). Hence the catch documentation is considered very reliable. Discards are managed and included in the reporting scheme for the fisheries. The research surveys give excellent coverage of the normal range of the GOA pollock, providing biennial fishery independent estimates of stock status (triennial up to the early 1990s). Targeted trawl and acoustic surveys are also conducted in areas where Pollock abundance may be highly concentrated by show high spatial and inter-annual variability, such as the Shumagin, Chirikof, and Kodiak areas.

The annual data on catches and biennial and other data from surveys are combined in the assessment to provide annual time series of stock status. The trajectory of stock status and exploitation rate, measures by B (age 0+, age 3+ and female spawning) and F provide sufficient feedback to evaluate whether the harvest control rules are working. Hence the SG 60 is fully met.

Harvest strategy review The harvest strategy is Guide d periodically reviewed and post improved as necessary. BSAI-Y Met? GOA-Y Rationale

BSAI Stock The general performance of the harvest is evaluated as part of the annual assessment process and the consultations that follow the assessment.

In addition, the entire assessment approach was reviewed by the Center for Independent Experts in 2011 as part of its review of the 2010 Biological Opinion of NOAA (CIE 2012). The comments from the CIE review focused on the biological opinion regarding impacts of Bering Sea and Aleutian Island fisheries on sea lions, and not the NMFS approach to assessments and the harvest control rule as such. However, because the approach to application of the general OFL/ABC quota setting system is entrenched in the approach to assessment and critical to the overall issue of fisheries management in the Bering Sea, the CIE review of the assessments had to consider the effectiveness of the harvest strategy for the stock itself as well as for Steller sea lions.

GOA Stock The general performance of the harvest is evaluated as part of the annual assessment process and the consultations that follow the assessment. The specific assessment methods and general approach are reviewed annually by the

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GOA Plan Team. Those reviews commonly recommend that modifications of harvest strategies be explored during the assessment to test for robustness of performance in the face of specific sources of uncertainty.

In addition, the entire assessment approach was reviewed by the CIE in 2011 as part of its review of the 2010 Biological Opinion of NOAA (CIE 2012). The comments from the CIE review focused on the biological opinion regarding impacts of pollock fisheries on sea lions, and not the NMFS approach to assessments and the harvest control rule as such. However, because the approach to application of the general OFL / ABC quota setting system is entrenched in the approach to assessment and critical to the overall issue of fisheries management in the GOA, the CIE review of the assessments had to consider the effectiveness of the harvest strategy for the stock itself as well as for Stellar Sea Lions. Review occurs regularly, meeting the SG100.

Shark finning It is likely that shark finning is It is highly likely that shark There is a high degree of e Guide not taking place. finning is not taking place. certainty that shark finning is post not taking place. Met? NA NA NA

Rationale

Pollock are not sharks.

Review of alternative measures There has been a review of There is a regular review of There is a biennial review of the potential effectiveness the potential effectiveness the potential effectiveness and practicality of alternative and practicality of alternative and practicality of alternative f Guide measures to minimise UoA- measures to minimise UoA- measures to minimise UoA- post related mortality of unwanted related mortality of unwanted related mortality of unwanted catch of the target stock. catch of the target stock and catch of the target stock, and they are implemented as they are implemented, as appropriate. appropriate. Met? NA NA NA

Rationale

There is no unwanted catch of pollock in the pollock fishery. All pollock is retained and landed.

References

A'mar, Z. T., Punt, A.E., and Dorn, M.W. 2009a. The impact of regime shifts on the performance of management strategies for the Gulf of Alaska walleye pollock (Theragra chalcogramma) fishery. Canadian Journal of Fisheries and Aquatic Sciences. 66: 2222-2242.

A'mar, Z. T., Punt, A.E. and Dorn, M.W. 2009. . The evaluation of two management strategies for the Gulf of Alaska walleye pollock fishery under climate change. ICES Journal Of Marine Science. 66: 1614-1632.

A'mar, Z. T., Punt, A, E., and Dorn, M.W. 2010. Incorporating ecosystem forcing through predation into a management strategy evaluation for the Gulf of Alaska walleye pollock (Theragra chalcogramma) fishery. Fisheries Research. 102: 98-114.

Cadrin S., et al. 2015. Simulation testing the robustness of stock assessment models to error: some results from the ICES strategic initiative on stock assessment methods. ICES Journal of Marine Science 72:19-30.

CIE 2012. Center for Independent Experts (CIE) Review of the November 2010 Biological Opinion on the Bering Sea and Aleutian Islands and Gulf of Alaska Groundfish Fisheries. Available at https://alaskafisheries.noaa.gov/protectedresources/stellers/esa/biop/final/cie/review.htm

Dorn, M., Aydin, K., Fissel, B., Palsson W., Spalinger, K., Stienssen, S., Williams K, and Zador, S., 2018.

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Assessment of the walleye pollock stock in the Gulf of Alaska. In Stock Assessment and Fishery Evaluation Report for Groundfish Resources of the Gulf of Alaska. Prepared by the Gulf of Alaska Groundfish Plan Team, North Pacific Fishery Management Council, P.O. Box 103136, Anchorage, AK 99510. North Pacific Fisheries Management Council, Anchorage, AK.

Fissel, B., Dalton, M., Felthoven, R., Garber-Yonts, B., Haynie, A., Himes-Cornell, A., Kasperski, S., Lee, J., Lew, D., and Seung, C. 2014. “Stock Assessment and Fishery Evaluation Report for the Groundfish Fisheries of the Gulf of Alaska and Bering Sea/Aleutian Islands Area: Economic Status of the Groundfish Fisheries Off Alaska, 2013”. Economic and Social Sciences Research Program, REFM, AFSC, NMFS, NOAA 7600 Sand Point Way N.E., Seattle, Washington.

Goodman, D. Mangel, M., Parkes, G., Quinn, T., Restrepo, V., Smith, T. and K. Stokes. 2002. “Scientific Review of the Harvest Strategy Currently Used in the BSAI and GOA Groundfish Fishery Management Plans.” North Pacific Fishery Management Council, 605 West 4th Avenue, Suite 306, Anchorage, Alaska.

Ianelli, J.N., S. Kotwicki, T. Honkalehto, A. McCarthy, S. Stienessen, K. Holsman, E. Siddon, and B. Fissel. 2018. “1. Assessment of the Walleye Pollock stock in the Eastern Bering Sea.” Stock Assessment and Fishery Evaluation Report for the Groundfish Resources of the Bering Sea/Aleutian Islands Region. North Pacific Fishery Management Council, 605 West 4th Avenue, Suite 306, Anchorage, Alaska.

National Marine Fisheries Service (NMFS). 2005. Final environmental impact statement for essential fish habitat identification and conservation in Alaska. National Marine Fisheries Service, Alaska Region. P.O. Box 21668, Juneau, AK 99802-1668.

NMFS 2009. Magnuson-Stevens Act Provisions; Annual Catch Limits; National Standard Guidelines. Final Rule. Federal Register 74:3178-3213.

NMFS. 1999. “Environmental Assessment for the Amendment 56 to the Fishery Management Plan for the Groundfish Fishery of the BSAI Area and Amendment 56 to the Fishery Management Plan for Groundfish of the Gulf of Alaska.” NMFS Alaska Region Office, P.O. Box 21668, Juneau, Alaska. NMFS (National Marine Fisheries Service). 2015. North Pacific Groundfish and Halibut Observer Program 2014 Annual Report. National Oceanic and Atmospheric Administration, 709 West 9th Street. Juneau, Alaska 99802.

Thompson G.G. 1999. Optimizing Harvest Control Rules in the Presence of Natural Variability and Parameter Uncertainty.

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range Both Stocks ≥80

Information gap indicator Information sufficient to score PI

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

26 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

PI 1.2.2 There are well defined and effective harvest control rules (HCRs) in place

Scoring Issue SG 60 SG 80 SG 100 HCRs design and application Generally understood HCRs Well defined HCRs are in The HCRs are expected to are in place or available that place that ensure that the keep the stock fluctuating are expected to reduce the exploitation rate is reduced as at or above a target level exploitation rate as the point the PRI is approached, are consistent with MSY, or a Guide of recruitment impairment expected to keep the stock another more appropriate post (PRI) is approached. fluctuating around a target level taking into account the level consistent with (or ecological role of the stock, above) MSY, or for key LTL most of the time. species a level consistent with ecosystem needs. BSAI-Y BSAI-Y BSAI-Y Met? GOA-Y GOA-Y GOA-Y Rationale

BSAI Stock The current HCR for the EBS pollock fishery specifies a maximum F of Fmsy for any stock with an automatic reduction in fishing rates when biomass is lower than the target reference point, and the rate of reduction proportional to the deviation of SBB from Bmsy. The HCR also specifies a de facto zero directed fishing mortality with spawning stock biomass less than the B20% level.

The current HCR for the AI pollock biomass is similar to that for the EBS component, but with B40% instead of BMSY. In addition, however, harvests are currently limited to at most 19,000 mt, and less than 2,000 mt of pollock were harvested in each year on average since 2010 (entirely in non-pollock-directed fisheries).

For EBS and AI pollock stocks, the B20% threshold is slightly more conservative than the one-half of BMSY minimum stock-size threshold (MSST) recommended in the MSFCMA and the NMFS National Standard Guidelines (NSG; NMFS 1998, Restrepo et al. 1998).

Therefore, well-defined harvest control rules are in place that ensure exploitation rate reduction as necessary and expected to keep the stock fluctuating at or above a target level consistent with Bmsy most of the time, meeting SG60, SG80 and SG100.

GOA Stock The current HCR for the GOA pollock fishery specifies a maximum F of F40% for the stock, with an automatic reduction in fishing rates when biomass is lower than the target reference point (B40%), and the rate of reduction should be proportional to the deviation of SBB from B40%. The HCR also specifies a de facto zero directed fishing mortality when spawning stock biomass is less than the B20% level. Therefore, well-defined harvest control rules are in place that ensure exploitation rate reduction as necessary and expected to keep the stock fluctuating at or above a target level consistent with Bmsy most of the time, meeting SG60, SG80 and SG100.

HCRs robustness to uncertainty The HCRs are likely to be The HCRs take account of a robust to the main wide range of uncertainties Guide uncertainties. including the ecological role b of the stock, and there is post evidence that the HCRs are robust to the main uncertainties. BSAI-Y BSAI-Y Met? GOA-Y GOA-Y

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Rationale

BSAI Stock The current HCR for the EBS pollock fishery specifies a maximum F of Fmsy for any stock with an automatic reduction in fishing rates when biomass is lower than the target reference point, and the rate of reduction proportional to the deviation of SBB from Bmsy. The HCR also specifies a de facto zero directed fishing mortality with spawning stock biomass less than the B20% level.

The current HCR for the AI pollock biomass is similar to that for the EBS component, but with B40% instead of BMSY. In addition, however, harvests are currently limited to at most 19,000 mt, and in the last five years no pollock were harvested in directed fisheries, and less than 2,000 mt of pollock on average were harvested as bycatch in each year since 2010 (Barbeaux et al 2018).

For EBS and AI pollock stocks, the B20% threshold is slightly more conservative than the one-half of BMSY minimum stock-size threshold (MSST) recommended in the MSRA and the NMFS National Standard Guidelines (NSG; NMFS 1998, Restrepo et al. 1998).

An elaborate set of performance criteria are used to guide final decisions about stock status, before the control rule is applied to the results. Some simulations are explicitly linked to specific parts of the harvest control strategy, whereas other parts of the harvest control strategy are informed by multiple scenarios, and possible different scenarios in different years, depending on their performance in the assessment (Ianelli et al. 2018). Environmental uncertainty itself is not a parameter in the harvest control strategy, but its manifestation through possible impacts on the stock productivity parameters, which are reconsidered in each assessment, are fully considered.

Hence the design of the HCR does take account of a wide range of uncertainties and meets the SG 100.

GOA Stock The current HCR for the GOA pollock fishery specifies a maximum F of F40% for the stock, with an automatic reduction in fishing rates when biomass is lower than the target reference point (B40%), and the rate of reduction should be proportional to the deviation of SBB from B40%. The HCR also specifies a de facto zero directed fishing mortality when spawning stock biomass is less than the B20% level.

For pollock stocks, where Bmsy can be estimated reliably (particularly EBS Pollock), the B20% threshold has been found to be slightly more conservative than the one-half of the BMSY minimum stock-size threshold (MSST) recommended in the MS-FCMA and the NMFS National Standard Guidelines (NMFS 1998, Restrepo et al. 1998).

An elaborate set of performance criteria are used to guide final decisions about stock status, before the control rule is applied to the results. These include testing mode estimates to survey and catch data on age composition, and to survey biomass estimates. Some simulations conducted as part of the assessment are explicitly linked to specific parts of the harvest control strategy, whereas other parts of the harvest control strategy are informed by results of multiple scenarios, and possible different scenarios in different years, depending on their performance in the assessment (Dorn et al. 2018). Environmental uncertainty itself is not a parameter in the harvest control strategy, but its manifestation through possible impacts on the stock productivity parameters, which are fully reconsidered in each assessment. Hence the design of the harvest control rule does take account of a wide range of uncertainties and meets the SG80 and SG100.

HCRs evaluation There is some evidence that Available evidence Evidence clearly shows tools used or available to indicates that the tools in use that the tools in use are c Guide implement HCRs are are appropriate and effective effective in achieving the post appropriate and effective in in achieving the exploitation exploitation levels required controlling exploitation. levels required under the under the HCRs. HCRs. BSAI-Y BSAI-Y BSAI-Y Met? GOA-Y GOA-Y GOA-Y Rationale

BSAI Stock

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The strongest evidence that the harvest control rules are effective in achieving the exploitation levels required under the harvest control rules is that stock survived the environmental challenges of the 2000s in a condition to be able to take advantage of more favorable environmental conditions that subsequently returned to the eastern Bering Sea. The particular circumstances are described in the justification for the scoring in 1.2.1.

The HCR was in place throughout that period of decline and resulted in quotas being reduced at a rate sufficient to reduce exploitation rate on the stock as spawning biomass decreased. A decline in the stock could not be prevented by management during this period, but the magnitude of decline was managed sufficiently well that even at its nadir it did not reach the limit reference point. Adjustments being considered for the HCR to ensure the ABC is sufficiently far below the BMSY to account for additional uncertainties would make the HCR even more cautious.

During the period of reduction in quota, catch monitoring remained strong enough that the catch and discard figures are considered reliable. A second line of evidence that the HCRs are effective is that strong retrospective patterns do not appear to be present (1.A.23, Ianelli et al. 2018).

Hence evidence is available and does indicate fairly strongly that not only is the quota setting process effective in setting harvest levels that should reduce exploitation, the fishery compliance with the management plan is high enough that the intended reductions are realized.

For AI, the targeted fishery has not been prosecuted for several years, due to both economic considerations by the harvester, and regulatory restrictions by NPFMC and NMFS. With the 19,000 cap on all removals in regulation, and bycatches under 3000 t in all years in the 2010s, the de facto HCR for this stock is keeping harvests well below any biologically based ABC, and allowing stock growth even in a time of generally low productivity by the stock. Thus SG 100 is met for this stock.

GOA Stock The strongest evidence that the harvest control rules are effective in achieving the exploitation levels required under the harvest control rules is that stock survived the environmental challenges of the 2000s in a condition to be able to take advantage of more favorable environmental conditions when they returned to the GOA. This was a rigorous test, in that the evidence is strong in that the productivity of the stock per spawner declined by 50% or more and the low productivity persisted for over a decade (Dorn et al. 2018). The particular circumstances are described in the justification for the scoring in 1.2.1, but the harvest was successfully managed throughout this challenge to keep catches within the annual quotas, and the quotas consistent with the annual scientific advice.

Variants of the current HCR were in place throughout that period of decline. A decline in the stock could not be prevented by harvest management during this period, but the magnitude of decline was managed sufficiently well that even at its nadir the stock did not reach the limit reference point, whereas in the earliest part of the time series, before any form of the current HCR was adopted, the stock did fall below the (current) B20% reference point and fishing mortality did rise above the F80% Bmsy reference point (Dorn et al 2018).

During the period of reduction in quota, catch monitoring remained strong enough that the catch and discard figures are considered reliable. A second line of evidence that the HCRs are effective is that strong retrospective patterns do not appear to be present (Dorn et al. 2018). This suggests that the level of unreported catch or discarding had to be sufficiently low that patterns in the catch data reliably reflect patterns in the stock.

Hence evidence is available and does indicate fairly strongly that not only is the quota setting process effective in setting harvest levels that should reduce exploitation, the fishery compliance with the management plan is high enough that the intended reductions are realized. Thus SG60, SG80, and SG100 are met for this stock.

References

See references under 1.1.1. and 1.2.1.

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80

Information gap indicator Information sufficient to score PI

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Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

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PI 1.2.3 Relevant information is collected to support the harvest strategy

Scoring Issue SG 60 SG 80 SG 100

Range of information Some relevant information Sufficient relevant A comprehensive range of related to stock structure, information related to stock information (on stock stock productivity and fleet structure, stock productivity, structure, stock productivity, composition is available to fleet composition and other fleet composition, stock Guide support the harvest strategy. data are available to support abundance, UoA removals a the harvest strategy. and other information such as post environmental information), including some that may not be directly related to the current harvest strategy, is available. BSAI-Y BSAI-Y BSAI-Y Met? GOA-Y GOA-Y GOA-Y Rationale

BSAI Stock The information used in the annual assessment includes data from catches by all fleet sectors, foreign (in the years before extension of national jurisdiction), joint venture, and domestic since 1964. Size and age composition of the catch has been provided by on-board observers and port sampling (depending on the fishery) for the entire time series. Since 1991, discard data by gear type are also available. Intensity of observer coverage increased in 1999 and is considered to provide reliable data on catches, discards, and sampling for aging structures. Effort data are available by season and fishery type, allowing fishery dependent CPUE values to be calculated.

The annual EBS trawl survey provides fishery independent catch numbers, weights, lengths and ages annually since 1970 and with consistent gears and survey design since 1982. In 1987 the survey coverage expanded further north in the EBS, covering an area where pollock catches have been highly variable, consistent with hypotheses that distribution of pollock is sensitive to water temperatures. Maturity data, stomachs for diet analyses, and other biological data are also collected from the survey catches. Intensity of sampling depends on the research questions being given priority from year to year, but basic biological sampling is conducted annually.

Pollock are distributed in the water column as well as near and the seafloor, and correspondingly acoustic surveys have been conducted triannually from 1977 to 1994 and generally biannually in even years thereafter. In addition to giving calibrated estimates of biomass of Pollock in the water column, mid-water trawl samples are taken during the survey to get estimates of size and age composition of the population being ensonified.

There have been directed studies of most life history parameters for EBS pollock, including growth rates (Siddon et al. 2013a,b, Bacheler et al. 2012, Heintz and Vollenweider 2010) reproduction (see section 3.3.b for extended list of references), maximum age and fecundity (Spencer and Dorn 2013), and position in the food web (Holsman and Aydin 2015, Siddon et al. 2014s, Jones et al. 2014, Boldt et al. 2012, Urban 2012) Stock structure has been investigated using both genetic methods (Yanagimoto et al. 2012, Shubina at al. 2009) and other indicators (Grant et al. 2010); A great deal of additional information on life history aspects of pollock has been presented to this assessment panel and is used in the assessments, and much of it is available as primary publications. In addition, physical oceanographic parameters are collected during both bottom and acoustic surveys, so catches can be related to factors such as temperature and salinity.

For the AI stock component, similar reporting and sampling of commercial catches has been conducted over the same time periods, although the low level of commercial harvest in more recent years has limited the quantity of such data. Research bottom trawl surveys, with full sampling of catches for length composition, aging structures and biological parameters were conducted in 1980, 1983, and 1986 jointly with Japan, and with NMFS in 1991, 1994, 1997, 2000, 2002, 2004, 2006, 2010, 2012, 2014, 2016 and 2018. The AI bottom trawl survey planned for 2008 was canceled due to budgetary constraints. Partial acoustic surveys were also conducted in 2006 and 2007, and a more complete

31 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019 acoustic survey in 2008. However, a consistent hydroacoustic time series has not been developed for the AI stock component. In summary, substantial information is available for assessment of the status of BSAI pollock, meeting the SG 100 standard.

GOA Stock The information used in the annual assessment includes data from catches by all fleet sectors, foreign (in the years before extension of national jurisdiction), joint venture, and domestic since 1970. Catches form the Japanese fleet are available 1963 to 1970 but are not routinely used in the assessment, although they do provide some historical perspective on some population parameters. Size and age composition of the catch has been provided by on-board observers and port sampling (depending on the fishery) starting in 1975. Since 1991 discard data by gear type are also available, and discards are estimated as 13% of recorded catches for the earlier years (using the average discard rates in 1991 and 1992). Intensity of observer coverage has increased since the restructuring of the observer program in 2012/2013, and reliability observer program data has been tested and found to be high (NMFS 2015). Observer coverage is considered to provide reliable data on catches, discards, and sampling for aging structures. Effort data are available by season and fishery type, allowing fishery dependent CPUE values to be calculated. A small state-managed pollock fishery in Prince William Sound reports catches, but it is assumed to always catch its allocation from the ABC, which is deducted from the ABC when estimating quota for the federally managed fishery. The biennial Alaska fisheries Science Center bottom trawl survey (triennial before 2001) provides fishery independent catch numbers, weights, lengths and ages annually since 1984 with consistent gears and survey design, fishery independent biomass estimated are provided by standard stratified random survey expansions of survey CPUE. Maturity data, stomachs for diet analyses, and other biological data are also collected from the survey catches. Intensity of sampling depends on the research questions being given priority from year to year, but basic biological sampling is conducted with each survey. In addition, acoustic surveys to assess the biomass of pollock in the Shelikof Strait area have been conducted annually since 1981 (except 1982, 1999, and 2011), to quantify pollock up in the water column as well as near the seafloor. These surveys, conducted in pre-spawning and spawning period of the winter may also survey areas adjacent to Shelikof Strait, depending on availability of vessel time. These surveys give calibrated estimates of biomass of pollock in the water column, and mid-water trawl samples are taken during the survey to get estimates of size and age composition of the population subject to the acoustic survey.

The Alaska Department of Fish and Game has also conducted an annual stratified random bottom trawl survey for crab and groundfish since 1987. The surveys cover primarily nearshore areas from Kodiak Island to Umiak Pass. Only covering a part of the range of pollock, they provide a relative index of changes in pollock abundance, and age composition has been estimated from otolith samples analyzed in even years.

A variety of other surveys in parts or all of the GOA, primarily using various bottom trawl gears and hydroacoustic surveys, have been conducted. These surveys are used to provide historical perspectives on GOA Pollock, but are rarely part of evaluation of model fits to population reconstructions.

There have been directed studies of most life history parameters for GOA pollock, including growth rates (Mazur et al. 2007, Dougherty et al. 2007, 2012, Wilson et al. 2011, 2013). reproduction (see section 3.3.b for extended list of references), maximum age and fecundity (Spenser and Dorn 2013), , and position in the food web (Adams et al. 2007, MacKenzie and Wynne 2008, Giachas et al. 2010, Urban 2012, Marsh et al. 2012, 2015, Paquin et al. 2014, Holsman et al. 2015) Stock structure has been investigated using both genetic methods (Mulligan et al. 1992, Olsen et al. 2002, Yanagimoto et al. 2012, Shubina et al. 2009) and other indicators (Bailey et al. 1997, 1999, 2000; FitzGerald et al. 2004, Cianelli et al. 2007, Grant et al. 2010, Durant et al. 2013); A great deal of additional information on life history aspects of pollock has been presented to this assessment panel and is used in the assessments, and much of it is available in primary publications. This meets the SG100 standard.

Monitoring Stock abundance and UoA Stock abundance and UoA All information required by removals are monitored and removals are regularly the harvest control rule is at least one indicator is monitored at a level of monitored with high b available and monitored with accuracy and coverage frequency and a high degree Guide sufficient frequency to consistent with the harvest of certainty, and there is a support the harvest control control rule, and one or good understanding of post rule. more indicators are inherent uncertainties in the available and monitored with information [data] and the sufficient frequency to robustness of assessment support the harvest control and management to this rule. uncertainty.

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BSAI-Y BSAI-Y BSAI-Y Met? GOA-Y GOA-Y GOA-Y Rationale

BSAI Stock: The justification for scoring issue a) applies with equal relevance to scoring issue b. In addition to all the biological information and fishery dependent data on catches that are discussed above, the size of all fleet components is known and updated annually, and detailed monitoring of fleet operations also allows the spatial distribution of effort on very precise space and time scales to be monitored. There is a good understanding of the uncertainties associated with the data sources, with scientific publications on the accuracy and precision of many of the survey-based abundance and biological parameters (e.g. Natcheler et al. 2012, Hulson et al. 2013, Kotwicki and Lauth 2013, Spencer and Dorn 2013, Barbeaux et al. 2018). All major uncertainties are taken into account in the assessments which trigger the application of the harvest control strategy.

GOA Stock: The justification for scoring issue a) applies with equal relevance to scoring issue b. In addition to all the biological information and fishery dependent data on catches that are discussed above, the size of all fleet components is known and updated annually, and monitoring of fleet operations also allows the spatial distribution of effort to be monitored. There is a good understanding of the uncertainties associated with the data sources, with scientific publications on the accuracy and precision of many of the survey-based abundance and biological parameters (e.g. Brodziak et al. 2011, DeRoberts et al. 2008, Hollowed et al. 2000, Kastele and Kimura 2006, Lee et al. 2009, Somerton et al. 2011, Spencer and Dorn 2013, VanKirk et al. 2011, Williams et al. 2011). All major uncertainties are taken into account in the assessments which trigger the application of the harvest control strategy, thus meeting the SG60, SG80, and SG100 levels.

Comprehensiveness of information

Guide There is good information on c all other fishery removals post from the stock. BSAI-Y Met? GOA-Y Rationale

BSAI Stock: Bycatches of pollock in other fisheries in the Bering Sea for Pacific cod, various flatfish and crab are fully quantified by on-board observers, dockside monitoring and trip reports, and included in assessments. Most fisheries have a low bycatch of pollock, with regulatory incentives to avoid unwanted bycatch. Consequently, there is high confidence that there is good information on pollock removals in other Alaska fisheries, meeting the SG 80 standard.

GOA Stock: Bycatches of pollock in other fisheries in the GOA for Pacific cod, various flatfish, and rockfish are quantified by on- board observers with a deployment pattern that gives statistically reliable estimates of catches and bycatches, and trip reports, and included in assessments.

Most fisheries have a low bycatch of Pollock, with regulatory incentives to avoid unwanted bycatch. Consequently, there is high confidence that there is good information on pollock removals in other Alaska fisheries, meeting the SG 80 requirements.

References

Adams, C. F., Pinchuk, A.I. and Coyle, K. O. 2007. Seasonal changes in the diet composition and prey selection of walleye pollock (Theragra chalcogramma) in the northern Gulf of Alaska. Fisheries Research. 84: 378-389.

Bailey, K.M., P.J. Stabeno, and D.A. Powers. 1997. The role of larval retention and transport features in mortality and potential gene flow of walleye pollock. J. Fish. Biol. 51(Suppl. A):135-154.

Bailey, K.M., T.J. Quinn II, P. Bentzen, and W.S. Grant. 1999. Population structure and dynamics of walleye pollock, Theragra chalcogramma. Advances in Mar. Biol. 37: 179-255.

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Bailey, K.M., Quinn, T.J., Bentzen, P., et al. 2000. Population structure and dynamics of walleye pollock, Theragra chalcogramma. Pp 179-255. In Southward, A.J., Tyler, P.A., and Young, C.M. (eds) Advances in Marine Biology Book Series. Volume: 37 Springer.

Brodziak, J., J. Ianelli, K. Lorenzen, and R.D. Methot Jr. (eds). 2011. Estimating natural mortality in stock assessment applications. U.S. Dep. Commer., NOAA Tech. Memo. NMFS-F/SPO-119, 38 p.

Ciannelli, L. Bailey, K. M.; Chan, K.-S.; et al. 2007. Phenological and geographical patterns of walleye pollock (Theragra chalcogramma) spawning in the western Gulf of Alaska. Canadian Journal of Fisheries and Aquatic Sciences. 64: 713-722.

De Robertis, A., Hjellvik, V., Williamson, N. J., and Wilson, C. D. 2008. Silent ships do not always encounter more fish: comparison of acoustic backscatter recorded by a noise-reduced and a conventional research vessel. – ICES Journal of Marine Science, 65: 623–635.

Dougherty, A. B., Bailey, K. M., and Mier, K. L.. 2007. Interannual differences in growth and hatch date distributions of age-0 year walleye pollock Theragra chalcogramma (Pallas) sampled from the Shumagin Islands region of the Gulf of Alaska, 1985-2001. Journal of Fish Biology. .71: 763-780.

Dougherty, A.; Bailey, K.; Vance, T.; et al. 2012. Underlying causes of habitat-associated differences in size of age-0 walleye pollock (Theragra chalcogramma) in the Gulf of Alaska. Marine Biology 159: 1733-1744.

Durant, J. M.. Hidalgo, M., Rouyer, T. et al. 2013. Population growth across heterogeneous environments: effects of harvesting and age structure. Marine Ecology Progress Series 480: 277286

FitzGerald, J.L., Thorrold, S.R., Bailey, K.M., et al. 2004. Elemental signatures in otoliths of larval walleye pollock (Theragra chalcogramma) from the northeast Pacific Ocean. Fishery Bulletin 102: 604-616.

Gaichas, S.K.; Aydin, K. Y.; and Francis, R. C. 2010. Using food web model results to inform stock assessment estimates of mortality and production for ecosystem-based fisheries management. Canadian Journal of Fisheries and Aquatic Science. 67: 1490-1506.

Grant, W. S., Spies, I., and Canino, M.F. 2010. Shifting-balance stock structure in North Pacific walleye pollock (Gadus chalcogrammus). ICES Journal of Marine Science. 67: 1687-1696.

Hollowed, A.B.; Ianelli, J.N. and Livingston, P.A. 2000. Including predation mortality in stock assessments: a case study for Gulf of Alaska walleye Pollock. ICES Journal of Marine Science 57: 279-293

Holsman, K. K. and Aydin, K. 2015. Comparative methods for evaluating climate change impacts on the foraging ecology of Alaskan groundfish. Marine Ecology Progress Series 521: 217-235

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80

Information gap indicator Information sufficient to score PI

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

34 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

PI 1.2.4 There is an adequate assessment of the stock status Scoring Issue SG 60 SG 80 SG 100 Appropriateness of assessment to stock under consideration The assessment is The assessment takes into appropriate for the stock and account the major features Guide a for the harvest control rule. relevant to the biology of the post species and the nature of the UoA. BSAI-Y BSAI-Y Met? GOA-Y GOA-Y Rationale

BSAI Stock The EBS pollock assessment has been done as a statistical age-structured assessment since 1996, implemented with the Stock Synthesis 2 platform of Methot (2005). The model continues to be adapted with details specific to the stock being added or revised each year. It operates on the Automatic Differentiation Model Builder (ADMB) modeling foundation (Fournier et al. 2012). The modelling platform estimates model parameters as well as statistically characterizes the uncertainty associated with parameter estimates. It derives quantities such as time series of spawning and total biomass, year-class strengths and fishing mortality. There has been particular attention paid to the functional form of fisheries and survey selectivity (Ianelli et al. 2014a, Williams et al. 2011), with multiple formulations used each year to explore uncertainties about how well these data sources reflect true abundance of the various sizes of pollock. There are also multiple formulations conducted to explore the sensitivity of the assessment to the various sources of data, and the effects of environmental conditions on productivity parameters.

For several years each assessment has actually comprised multiple formulations and scenarios, as dictated by the assessment Plan Team each year. These always include specific formulations / scenarios to directly inform setting OFL and ABC fishing levels, but other scenarios exploring different options for pollock stock dynamics are always included. The suite of formulations found to have acceptable statistical properties all contribute to conclusions about stock status and uncertainties, with the “assessment” comprising the full suite of acceptable formulations, even though in the end a single representation of stock trajectory and present status is accepted. Multiple projections are often done, reflecting different assumptions about near-future fisheries behavior, stock dynamics, and environmental conditions.

These models are considered state-of-the-art for stock assessment, and account for uncertainties in almost all input data series and model parameters or vectors estimated. They are being internationally used in a project to set, among other things, best practice guidance for stock assessment practices globally (Deroba et al. 2015).

The assessment of the status of Aleutian Island stock has been conducted separately since 1997 (Ianelli et al. 1997), although there is inconclusive evidence for how separate the dynamics of the stock components are (Barbeaux et al. 2018). The current AI pollock stock assessment model has been developed within the NOAA fisheries stock assessment Toolbox model AMAK and is a catch-at-age model with the standard Baranov catch equation. The population dynamics follows numbers-at-age over the period of catch history with natural and age-specific fishing mortality occurring throughout the 14-age-groups that are modelled (ages 2-15+). Age-2 recruitment in each year is estimated as deviations from a mean value expected from an underlying stock-recruitment curve. In the model, a single fishery (which includes both targeted catch and bycatch from other fisheries) is represented and a single summer bottom trawl survey index of abundance is used.

Hence the assessments are appropriate for the stock and the harvest strategy and take account of the major aspects of the species biology and the fisheries, meeting the SG 100 standard.

GOA Stock The GOA Pollock assessment has been done as a statistical age-structured assessment since 1996, implemented with the Stock Synthesis 2 platform of Methot (2005). The model continues to be adapted with details specific to the stock being added or revised each year. It operates on the ADMB modelling foundation (Fournier et al. 2012). The modelling platform estimates model parameters as well as statistically characterizes the uncertainty associated with parameter estimates. It derives quantities such as time series of spawning and total biomass, year-class strengths 35 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019 and fishing mortality. The age effect was modeled using a double-logistic function with time-varying parameters (Dorn et al. 2014).

There has been attention paid to the functional form of fisheries and survey selectivity, with multiple formulations used each year to explore uncertainties about how well these data sources reflect true abundance of the various sizes of Pollock. There are also multiple formulations conducted to explore the sensitivity of the assessment to the various sources of data and the effects of environmental conditions on productivity parameters (references in 1.2.3b).

For several years each assessment has comprised multiple formulations and scenarios, as dictated by the assessment Plan Team each year. These always include typically seven specific formulations / scenarios to directly inform setting OFL and ABC fishing levels, but other scenarios exploring different options for Pollock stock dynamics are always included. The suite of formulations found to have acceptable statistical properties all contribute to conclusions about stock status and uncertainties, with the “assessment” comprising the full suite of acceptable formulations, even though in the end a single representation of stock trajectory and present status is accepted. Multiple projections are often done, reflecting different assumptions about near future fisheries behavior, stock dynamics, and environmental conditions.

These models are considered state-of-the-art for stock assessment, and account for uncertainties in almost all input data series and model parameters or vectors estimated. They are being used internationally in a project to set, among other things, best practice guidance for stock assessment practices globally (Deroba et al. 2015). Hence the assessments are appropriate for the stock and the harvest strategy and take account of the major aspects of the species biology and the fisheries, meeting the SG80 and SG100 requirements.

Assessment approach The assessment estimates The assessment estimates stock status relative to stock status relative to Guide b generic reference points reference points that are post appropriate to the species appropriate to the stock and category. can be estimated. BSAI-Y BSAI-Y Met? GOA-Y GOA-Y Rationale

BSAI Stock Yes, the assessment estimates stock status relative to reference points that are appropriate and can be estimated. See Ianelli et al 2018.

GOA Stock Yes, the assessment estimates stock status relative to reference points that are appropriate and can be estimated. See Dorn et al 2018.

Uncertainty in the assessment The assessment identifies The assessment takes The assessment takes into major sources of uncertainty. uncertainty into account. account uncertainty and is c Guide evaluating stock status post relative to reference points in a probabilistic way. BSAI-Y BSAI-Y BSAI-Y Met? GOA-Y GOA-Y GOA-Y Rationale

BSAI Stock As described in the justifications for 1.2.4a the assessment of both EBS and AI stock components of pollock take into account all major sources of uncertainty in stock and fishery dynamics. Particular attention is paid to spatial changes in stock distribution (Natcheler et al. 2013, Pfeiffer and Haynie 2012, Kotwicki and Lauth 2013, Baker and Hollowed 2014) and to environmental effects on productivity (Stabeno et al. 2013, Litzow et al. 2014), but analytically in the alternative model formulations and scenarios explored, and in interpretation of results.

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For both stock components the assessments update all biomass and fishing mortality reference points and estimate stock status probabilistically relative to those reference points. Hence it meets the SG 100 standard.

GOA Stock As described in the justifications for 1.2.4a, the assessment of GOA pollock takes into account all major sources of uncertainty in stock and fishery dynamics. Taking those sources of uncertainty summarized in justifications 1.2.3b and 1.2.4a into account, in Dorn et al 2014, uncertainties were included directly or estimated indirectly for most input data sets, including: • Fishery total catch (1970-2018) • Fishery age comp. (1975-2018) • Shelikof acoustic survey age comp. (1992-2018) • NMFS bottom trawl survey biomass. (1990-2017) • NMFS bottom trawl survey age comp. (1990-2017) • ADFG trawl survey biomass (1989-2018) • ADFG survey age comp. (2000, 2002, 2004, 2006, 2008, 2010, 2012, 2014, 2016) • Recruit process error (1970-1977, 2013-2018) The assessments update all biomass and fishing mortality reference points and estimate stock status probabilistically relative to those reference points. Hence it meets the SG60, SG80, and SG100 requirements.

Evaluation of assessment The assessment has been tested and shown to be Guide robust. Alternative d post hypotheses and assessment approaches have been rigorously explored. BSAI-Y Met? GOA-Y Rationale

BSAI Stock The assessment has been tested with various simulation studies in most years since the late 2000s, as reported in the annual SAFE documents cited below. Every assessment in recent years has included at least several different formulations, as the annual recommendations of the plan team requested, and assessment authors explored. Illustratively, a list of the main issues explored in the 2014 assessment included: Exploring multiple hypotheses for the form of the stock recruit relationship and addressing uncertainty about recruitment in projections, alternative formulations of weights-at-age to explore cohort effects, exploring the use of survey as well as fishery weights at age in the assessments, to examine possible effects of fishery location, and adding a correction parameter for survey efficiency to see if changing temperature profiles affect the relative efficiency of the bottom trawl survey. In addition, the assessment always explores multiple hypotheses for fishery selectivities and core life history parameters. Many of these apparently technical tweaks to the assessment model reflect efforts to test different hypotheses about stock or fishery dynamics now and in the past.

With regard to completely different approaches to the assessment, the current Stock Synthesis assessment framework is just that; a framework allowing the user substantial flexibility in details of model formulation (Methot and Wetzel 2013). Hence within the overall stock synthesis framework certainly multiple approaches can be explored. Moreover, it has been very thoroughly considered by both NMFS (and other international) experts and by the North Pacific Fisheries Management Council SSC and found to be among the state of the art methods for fisheries stock assessment, as has been accepted by NMFS as a solid starting point for stock assessments. There has been extensive inter-comparison of the performance of stock assessment methods (a few examples include Patterson and Kirkwood (1995), National Academy of Science (1998), Restrepo et al. (2000), Patterson et al. (2001), Methot (2009), Schirripa et al. (2009)). As long as flexible assessment methods such as Stock Synthesis are used, and assessments take advantage of their flexibility, which is certainly the case for EBS pollock, the advantages of occasionally applying completely different assessment methods is small and the costs in development of comparably complete fully alternative formulations would be very high. Therefore, the assessment has been tested and alternative formulations have been explored, meeting the SG100.

GOA Stock 37 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

The assessment has been tested with various simulation studies in most years since the last 2000s, as reported in the annual SAFE documents cited below. Every assessment in recent years has included at least several different formulations, as the annual recommendations of the Plan Team and assessment authors are explored.

With regard to completely different approaches to the assessment, the current Stock Synthesis assessment framework is just that; a framework allowing the user substantial flexibility in details of model formulation (Methot and Wetzel 2013). Hence within the overall stock synthesis framework certainly multiple approaches can be explored. Moreover, it has been very thoroughly considered by both NMFS (and other international) experts and by the North Pacific Fisheries Management Council SSC, and found to be among the state of art methods for fisheries stock assessment, as has been accepted by NMFS as a solid starting point for stock assessments. There has been extensive inter-comparison of the performance of stock assessment methods (a few examples include Patterson and Kirkwood (1995), National Academy of Science (1998), Restrepo et al. (2000), Patterson et al. (2001), Methot (2009), Steffanson (2009). As long as flexible assessment methods such as Stock Synthesis are used, and assessments take advantage of their flexibility, which is certainly the case for GOA pollock, the advantages of occasionally applying completely different assessment methods is small and the costs in development of comparably complete fully alternative formulations would be very high.

Peer review of assessment Guide The assessment of stock The assessment has been e status is subject to peer internally and externally post review. peer reviewed. BSAI-Y BSAI-Y Met? GOA-Y GOA-Y Rationale

BSAI and GOA Stocks The assessments receive peer review at three levels. The first is internal, in that the NMFS Plan Team meets with the assessment staff before, during, and after the assessment is prepared. The first meeting is to scope the options and scenarios that should be explored in the annual assessment, based on the assessment of the previous year(s) and feedback about how the previous year’s fishery has unfolded. Meetings between the assessment staff and the Plan Team occur in a somewhat ad hoc manner during the development of the assessment, depending on what issues may arise during preparation of the assessment. As the assessment nears completion a meeting with the Plan Team is held to review results and presentation material, to be sure that the assessment is ready for presentation to the NPFMC – SSC. In a narrow sense only the final meeting of the Plan Team and assessment staff might be considered “peer review” of the assessment, but in fact just as “assessment” is both a process and a product, in a slightly broader sense all the meetings between the Plan Team and the assessment staff can be considered part of an internal peer review process, since all of the meetings have the coverage and quality of the assessment as their primary concern.

Once the assessment document is complete, each one receives a thorough and largely external review by the SSC of the NPFMC. All technical aspects of the assessment and the coverage of issues by alternative model formulations and scenarios are reviewed by the SSC. They can request re-runs or deletion or addition of analyses, as they consider necessary to have a sound assessment as a basis for subsequent consultation and decision-making. The make-up of the SSC includes both employees of NMFS and independent experts in ecological, economic and social sciences. However, none have a direct involvement in preparation of the assessment, and all participants are expected to act in their expert capacities rather than as institutional representatives. Thus, the SSC review can be considered an external review of the assessment.

Finally, the Center for Independent Experts (CIE) conducted a major review of BSAI and GOA assessments for all the major stocks in 2011 (CIE 2012). That review, with over 100 recommendations potentially affecting the BSAI and GOA pollock assessment was wholly at arm’s length to both NMFS and NPFMC as the producer of and client of the assessments. It was conducted by leading international experts in stock assessment in an ecosystem context, is a recent and wholly external review of the assessments.

Thus, the BSAI and GOA Pollock assessments receives both internal and external review on a regular basis and meets the SG 100 standard.

References

38 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

CIE 2012. Center for Independent Experts (CIE) Review of the November 2010 Biological Opinion on the Bering Sea and Aleutian Islands and Gulf of Alaska Groundfish Fisheries. Available at https://alaskafisheries.noaa.gov/protectedresources/stellers/esa/biop/final/cie/review.htm

Dorn et al 2018. Assessment of the walleye pollock stock in the Gulf of Alaska. In Stock Assessment and Fishery Evaluation Report for Groundfish Resources of the Gulf of Alaska. Prepared by the Gulf of Alaska Groundfish Plan Team, North Pacific Fishery Management Council, P.O. Box 103136, Anchorage, AK 99510. North Pacific Fisheries Management Council, Anchorage, AK.

Fournier, D. A., H. J. Skaug, J. Ancheta, J. Ianelli, A. Magnusson, M. N. Maunder, A. Nielsen, and J. Sibert. 2012. AD Model Builder: using automatic differentiation for statistical inference of highly parameterized complex nonlinear models. Optimization Methods and Software 27:233-249.

Methot, R. D. 2005. Technical description of the Stock Synthesis II Assessment Program. Unpubl. manuscr. National Marine Fisheries Service, Northwest Fisheries Science Center, 2725 Montlake Blvd. East, Seattle, WA 98112-2097. 54 p.

Methot, R. D. 2009. Stock assessment: operational models in support of fisheries management.In The Future of Fishery Science in North America, pp. 137–165. Ed. by R. J. Beamish, and B. J. Rothschild. Fish and Fisheries Series, 31. 736 pp.

Methot, R. D., and C. R. Wetzel. 2013. Stock Synthesis: a biological and statistical framework for fish stock assessment and fishery management. Fisheries Research 142:86-99.

National Research Council (NRC). 1998. Improving Fish Stock Assessments. National Academy Press, Washington, D.C. 177 pp.

Patterson K. R., and G. P. Kirkwood. 1995. Comparative performance of Adapt and Laurec-Shepherd methods for estimating fish population parameters and in stock management. ICES Journal of Marine Science, 52 (2): 183-196.

Restrepo, V. R., Patterson, K. R., Darby, C. D., Gavaris, S., Kell, L. T., Lewy, P., Mesnil, B., Punt, A. E., Cook, R. M.,

O’Brien, C. M., Skagen, D. W., and G. Stefánsson. 2000. Do different methods provide accurate probability statements in the short term? ICES CM 2000/V: 08:19pp.

Shepherd, J. G. 1999. Extended survivors’ analysis: An improved method for the analysis of catch-at-age data and abundance indices ICES Journal of Marine Science, 56: 584–591.

Schirripa, M. J., Goodyear, C. P., and Methot, R. M. 2009. Testing different methods of incorporating climate data into the assessment of US West Coast sablefish. ICES J. Mar. Sci., 66: 1605–1613.

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80 both stocks

Information gap indicator Information sufficient to score PI

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

39 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

7.3 Principle 2 7.3.1 BSAI ecosystem1

The characteristics of the Bering Sea and Aleutian Islands ecosystems are described in the following documents: Final Alaska Groundfish Fisheries Programmatic Supplemental Environmental Impact Statement (PSEIS) (NOAA 2004); Final Environmental Impact Statement (EIS) for Essential Fish Habitat (EFH) (NOAA 2005), and Appendix C, Ecosystem Considerations (Zador [ed.] 2013; Muto et al. [ed.] 2018; Zador and Ortiz [ed.] 2018). Several models to describe and understand the structure and functioning of these ecosystems have also been developed (Aydin and Meuter 2007, Aydin et al. 2007).

The Bering Sea is a large semi-enclosed, high-latitude body of water comprising 44% continental shelf, 13% continental slope, and 43% deep-water basin. The Eastern Bering Sea (EBS) is one of the most biologically productive areas of the world, supporting approximately 300 species of fish, 150 species of crustaceans and mollusks, 70 species of seabirds, and 29 species of marine mammals in an area of some 785,000 km2.

The dominant circulation begins with the passage of North Pacific water (the Alaska Stream) into the EBS through the major passes in the Aleutian Islands. There is a net water transport eastward along the north side of the AI and a northward flow at the continental shelf break and at the eastern perimeter of Bristol Bay. Eventually EBS water exits northward through the Bering Strait, or westward and south along the Russian coast, entering the western North Pacific via the Kamchatka Strait. There is a permanent cyclonic gyre around the deep basin in the central Bering Sea. Three oceanographic fronts, the outer shelf, mid-shelf, and inner shelf, follow along the 200, 100, and 50 m bathymetric contours, respectively; resulting in four oceanographic domains along the broad EBS shelf. The inner shelf is one well-mixed layer most of the time as temperature, salinity, and density remain constant with depth in the near-surface mixed-layer, which varies from approximately 10 to 30 m in summer to approximately 30 to 60 m in winter. On the middle shelf, a two-layer temperature and salinity structure exist because of downward mixing of wind and upward mixing due to relatively strong tidal currents. On the outer shelf, a three-layer temperature and salinity structure exist due to downward mixing by wind, horizontal mixing with oceanic water, and upward mixing from the bottom friction due to relatively strong tidal currents. The vertical physical system also regulates the biological processes that lead to separate cycles of nutrient regeneration.

An unusual physical characteristic of the Bering Sea shelf is the annual ice cover. In summer, the ice edge retreats into the Chukchi and Beaufort Seas whereas, in winter, much of the shelf is covered. The sea ice affects exchanges with the atmosphere and inhibits the transfer of freshwater and heat. The creation and melting of the sea ice alter the horizontal and vertical density gradients influencing the mixing and transport of nutrients and organisms within the euphotic zone. The ice edge also serves as both source and sink of freshwater that can affect productivity. Sea ice is also important in influencing bottom temperatures. Thus, the extent of sea ice is related to the distribution and abundance of temperature-sensitive bottom-dwelling species.

The Aleutian North Slope Current in the Bering Sea, and the Alaska Coastal Current and Alaskan Stream in the North Pacific are the three primary currents in the Aleutian Islands. Both bottom and pelagic habitats are subject to strong currents and tidal movements. The patterns of water density, salinity, and temperature in the Aleutian Islands are very similar to the Gulf of Alaska. Along the edge of the shelf in the low-salinity Alaska Stream protrudes westward. On the south side of the central Aleutian Islands, nearshore surface salinities are higher as the higher salinity EBS surface water occasionally mixes southward through the Aleutian Islands. The narrow shelf west of Samalga Pass allows the Alaskan Stream to approach the islands and is the primary influence for the oceanic marine environment of these areas. East and west of Samalga Pass, the community structure, diets, and distributions for demersal fish, corals, seabirds, and marine mammals differ. For example, Samalga Pass has a major influence on the population structure of Steller sea lions (Fritz et al. 2013). West of Samalga Pass, cold-water corals and sponge communities are a dominant feature of benthic communities on the steep rocky slopes of the Aleutian Islands.

7.3.2 GOA ecosystem2 The characteristics of GOA ecosystem are described in the following documents: Final Alaska Groundfish Fisheries PSEIS (NOAA 2004); Final EIS for EFH (NOAA 2005), and Appendix C, Ecosystem Considerations (Zador [ed.] 2013;

1 This section has not been updated from the previous Public Certification Report. It will be updated following the site visit when more up-to-date information has been collected. 2 This section has not been updated from the previous Public Certification Report. It will be updated following the site visit when more up-to-date information has been collected.

40 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Zador and Yasumiishi [ed.] 2018). Several models to describe and understand the structure and functioning of these ecosystems have also been developed (Aydin et al. 2007; Gaichas and Francis 2008; Gaichas et al. 2011, 2012).

The GOA is a relatively open marine system with land masses to the east and the north and a continental shelf area (160,000 km2) which is less than 25% of that in the eastern Bering Sea. Commercially harvested species are more diverse in the GOA than in the eastern Bering Sea.

The dominant circulation in the GOA is characterized by the cyclonic flow of the Alaska gyre, consisting of the eastward-flowing Subarctic Current system at approximately 50° N and the Alaska Coastal Current (Alaska Stream) system along the northern GOA. Large seasonal variations in the wind stress affect the location of the Alaska Stream and nearshore eddies. The variations in these nearshore flows and eddies affect much of the region’s biological variability.

7.3.3 Primary and secondary species

Observer data of non-target species are summarized below split across area and UoAs. These tables include a wide range of fish, seabird, and benthic species. MSC (2014) defines primary species as a species that is caught but is not the target species, that is within scope of the MSC program (i.e., not an amphibian, reptile, bird, or marine mammal), and that has management tools and measures in place. MSC (2014) defines secondary species as a species that is caught but is not the target species and is not considered primary or is out of scope but not an endangered, threatened, protected (ETP) species3. MSC (2014) states that a “main species” is one where the catch of that species by the UoA is 5% or more by weight of the total catch of all species by the UoA or where that species is classified as less resilient and its catch is 2% or more by weight of the total catch of all species by the UoA. Further, “less resilient” is when the productivity of the species indicates that it is intrinsically of low resilience (which can be determined by the productivity part of the Productivity Susceptibility Analysis) or when its resilience has been lowered by anthropogenic or natural changes to its life history. Non-ETP out-of-scope species are always considered main secondary.

UoA 1 – BSAI pollock

Based on the definitions above and the data provided in Table 4, this UoA has no main primary species and one secondary species – northern fulmar (see pink row). The species highlighted in blue are those with prohibited species catch (PSC) limits. NPFMC and NOAA Fisheries have adopted measures to limit the catch of certain species that are taken incidentally in the groundfish fisheries, which include these UoAs. While not ETP species under the MSC definition, they have been designated as “prohibited species” in fishery management plans (FMPs) since they are target species in other, fully utilized fisheries. Therefore, they are considered ETP in this assessment.

3 An ETP species is one that is recognized by national ETP legislation; a species listed in a binding international agreement (refer to MSC 2014 for the list of relevant binding international agreements); or an out-of-scope species that is listed in the IUCN Red List as vulnerable, endangered, or critically endangered.

41 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Table 6 Catch data (2014-2018) for the BSAI pollock UoA (in green). Species highlighted in blue are classified as PSC, and the species highlighted in pink is main secondary species. Source: observer data

Primary, % of Total Secondary, Five-Year Average Species ETP, or Habitat Main? 2014 2015 2016 2017 2018 Average Catch Pollock NA (P1) NA 1243759.81 1277205.85 1306347.12 1317962.64 1333592.86 1295773.66 98.07% Alaska plaice Primary No 318.20 98.64 40.87 47.64 104.50 121.97 0.01% Alaska Primary No 570.87 677.54 385.01 374.73 391.77 479.98 0.04% Aleutian skate Primary No 8.54 5.80 9.47 5.30 5.18 6.86 0.00% Arrowtooth flounder Primary No 757.75 402.65 305.15 208.13 281.16 390.97 0.03% Atka mackerel Primary No 117.03 192.39 68.74 63.88 558.02 200.01 0.02% Bairdi tanner crab* ETP NA 12521.91 8872.36 2293.28 7235.11 2238.03 6632.14 NA Benthic urochordata Secondary No 1.80 1.47 0.91 0.57 1.35 1.22 0.00% Bering flounder Primary No 0.58 2.52 0.32 0.07 0.07 0.71 0.00% Big skate Primary No 26.27 2.68 2.57 4.97 3.48 8.00 0.00% Bigmouth sculpin Secondary No 40.68 48.87 22.91 7.70 8.42 25.72 0.00% Bivalves, unidentified NA NA 0.03 0.03 0.04 0.01 0.02 0.03 0.00% Black rockfish Primary No 0.15 0.04 0.08 0.03 0.09 0.08 0.00% Brittle star, unidentified NA NA 1.59 0.18 0.15 0.20 0.13 0.45 0.00% Butter sole Primary No 0.56 0.50 3.13 0.94 9.99 3.02 0.00% Chinook salmon* ETP NA 12472.86 13119.74 19673.93 27572.25 11169.77 16801.71 NA Corals bryozoans, unidentified Habitats Yes 0.05 0.18 0.02 0.02 0.05 0.06 0.00% Dover sole Primary No 0.00 0.06 0.20 0.00 0.10 0.07 0.00% Dusky rockfish Primary No 10.50 18.63 17.37 7.56 11.11 13.04 0.00% Eelpouts Secondary No 7.74 10.63 22.72 18.32 4.03 12.69 0.00% English sole Primary No 0.00 0.00 0.00 0.00 0.04 0.01 0.00% Fflatfish, unidentified NA NA 0.05 0.09 0.01 0.15 0.19 0.10 0.00% Flathead sole Primary No 2553.10 2257.29 1629.80 956.58 1038.64 1687.08 0.13% Golden king crab* ETP NA 148.00 0.00 106.00 64.00 616.00 186.80 NA 42 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Great sculpin Secondary No 58.61 24.27 25.72 42.66 32.69 36.79 0.00% Greenland turbot Primary No 40.71 40.70 28.91 18.44 30.37 31.83 0.00% Harlequin rockfish Primary No 0.00 0.50 3.06 1.35 0.29 1.04 0.00% Hermit crab, unidentified NA NA 0.29 0.12 0.18 0.02 0.05 0.13 0.00% Herring ETP NA 159.46 1488.83 1431.70 965.34 474.24 903.92 0.07% Invertebrate, unidentified NA NA 1.08 0.31 0.02 0.30 0.03 0.35 0.00% Kamchatka flounder Primary No 168.81 55.96 91.90 28.89 36.14 76.34 0.01% Longnose skate Secondary No 0.76 0.00 0.21 0.19 0.00 0.23 0.00% Misc. crabs NA NA 0.46 0.25 0.40 0.13 0.13 0.27 0.00% Misc. crustaceans NA NA 0.50 0.17 0.05 0.10 0.16 0.20 0.00% Misc. deep fish NA NA 0.00 0.00 0.02 0.01 0.00 0.00 0.00% Misc. fish NA NA 43.65 90.05 75.14 48.06 50.67 61.51 0.00% Misc. invertebrates (worms, etc.) NA NA 0.01 0.00 0.00 0.00 0.00 0.00 0.00% Non-chinook salmon* ETP NA 194593.57 183488.32 288060.81 424019.31 262187.56 270469.91 NA Northern fulmar* Secondary Yes 51.00 112.00 84.23 109.00 41.54 79.55 NA Northern rockfish Primary No 99.52 123.92 158.09 63.74 80.25 105.10 0.01% Octopus, unidentified NA NA 2.09 10.71 24.97 7.53 4.59 9.98 0.00% Opilio tanner crab* ETP NA 19454.52 8339.49 1165.24 3392.00 5142.71 7498.79 NA Osmerids, other NA NA 0.30 2.66 0.59 0.18 0.09 0.76 0.00% Pacific cod Primary No 5213.12 8303.00 4981.32 5955.53 4272.80 5745.15 0.43% Pacific hake Primary No 0.00 0.00 0.01 0.00 0.02 0.01 0.00% Pacific halibut ETP NA 239.10 152.24 116.45 85.27 55.81 129.77 0.01% Pacific Ocean perch Primary No 1300.19 2519.76 3335.79 4818.26 4186.62 3232.12 0.24% Pacific sleeper shark Primary No 23.69 20.15 20.12 23.50 14.34 20.36 0.00% Pandalid shrimp Primary No 0.07 0.06 0.03 0.02 0.08 0.05 0.00% Plain sculpin Secondary No 13.37 3.44 0.54 2.63 1.13 4.22 0.00% Polychaete, unidentified NA NA 0.00 0.00 0.00 0.00 0.11 0.02 0.00% Red king crab* ETP NA 368.42 0.00 439.00 186.32 565.23 311.79 NA Redbanded rockfish Primary No 0.00 0.00 0.01 0.01 0.00 0.00 0.00% Redstripe rockfish Primary No 0.00 0.00 0.00 0.00 0.14 0.03 0.00% 43 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Rex sole Primary No 197.69 109.43 188.13 124.26 147.47 153.40 0.01% Rock sole Primary No 4359.27 1709.26 1141.32 1825.95 1150.62 2037.29 0.15% Rockfish, unidentified NA NA 0.01 0.11 0.01 0.01 0.01 0.03 0.00% Rougheye rockfish Primary No 2.92 0.50 2.85 11.09 2.76 4.02 0.00% Sablefish Primary No 1.26 0.08 18.80 101.77 448.89 114.16 0.01% Salmon shark Primary No 51.05 30.69 37.42 68.72 47.14 47.00 0.00% Sculpin, unidentified NA NA 20.98 30.08 12.93 10.41 14.54 17.79 0.00% Sculpin, unidentified NA NA 2.90 1.75 1.70 2.34 0.81 1.90 0.00% Scypho jellies Secondary No 12767.60 4950.85 2203.16 6156.89 7943.86 6804.47 0.51% Sea anemone, unidentified NA NA 1.74 2.36 0.98 1.06 1.28 1.48 0.00% Sea pens, whips Habitats Yes 3.38 2.13 1.13 0.95 1.01 1.72 0.00% Sea star Secondary No 29.96 41.57 54.87 12.31 22.95 32.33 0.00% Shark, other NA NA 0.55 1.22 0.36 0.52 1.12 0.75 0.00% Shortraker rockfish Primary No 1.93 5.74 7.37 36.62 28.13 15.96 0.00% Skate, other NA NA 203.98 136.90 63.30 123.23 188.25 143.13 0.01% Snails, unidentified NA NA 1.57 1.34 0.37 0.57 0.64 0.90 0.00% Spiny dogfish Primary No 0.05 0.26 0.64 0.05 0.06 0.21 0.00% Sponge, unidentified Habitats Yes 2.34 0.42 0.26 0.04 0.62 0.74 0.00% Squid, unidentified NA NA 1478.47 2205.83 1164.16 1887.11 1644.17 1675.95 0.13% Starry flounder Primary No 8.70 10.63 11.17 33.17 11.75 15.08 0.00% State-managed rockfish Primary No 0.00 0.36 0.08 0.00 0.00 0.09 0.00% Thornyhead rockfish Primary No 3.88 5.52 36.61 8.07 6.47 12.11 0.00% Urchins, dollars, cucumbers Secondary No 0.17 0.10 0.37 0.02 0.07 0.14 0.00% Warty sculpin Secondary No 1.97 0.82 0.52 0.69 1.28 1.06 0.00% Whiteblotched skate Secondary No 2.25 0.93 1.39 0.40 1.69 1.33 0.00% Yellow Irish lord Primary No 52.19 77.72 60.45 15.22 4.05 41.93 0.00% Yelloweye rockfish Primary No 0.00 0.00 0.20 0.00 0.00 0.04 0.00% Yellowfin sole Primary No 1953.55 863.19 895.16 623.38 788.44 1024.75 0.08% Yellowtail rockfish Primary No 0.00 0.00 0.00 0.00 0.01 0.00 0.00% Total Catch** 1276742.48 1304064.95 1325141.77 1342875.45 1357751.59 1321315.25

44 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Notes: * Number of individuals instead of tons ** Does not include species with individual numbers instead of weight

45 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

UoA 2 – GOA pollock

Based on the definitions above and the data provided in Table 5, the UoA has no main primary species or main secondary species. The species highlighted in blue are those with PSC limits, and these species are considered ETP for this assessment.

46 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Table 7 Catch data (2014-2018) for the GOA pollock UoA (in green). The species highlighted in blue are classified as PSC. Source: observer data

Primary, % of Total Secondary, Five-Year Average Species ETP, or Habitat Main? 2014 2015 2016 2017 2018 Average Catch Pollock NA (P1) NA 135243.58 159438.06 171398.31 181157.42 151768.28 159801.13 96.36% Alaska plaice Primary No 0.33 0.90 0.00 0.58 0.00 0.36 0.00% Alaska skate Secondary No 4.87 1.01 0.71 1.16 0.73 1.69 0.00% Aleutian skate Secondary No 0.00 1.69 1.11 0.00 0.00 0.56 0.00% Arrowtooth flounder Primary No 2462.63 1671.44 1235.48 1184.69 2320.17 1774.88 1.07% Atka mackerel Primary No 3.49 25.26 169.54 33.30 36.78 53.67 0.03% Bairdi tanner crab* ETP NA 2064.49 2343.04 3440.92 3014.73 5373.54 3247.34 NA Big skate Secondary No 171.05 62.58 100.36 114.59 88.62 107.44 0.06% Bigmouth sculpin Secondary No 5.46 4.11 3.96 9.47 0.00 4.60 0.00% Bivalves, unidentified NA NA 0.38 0.00 0.00 0.00 0.00 0.08 0.00% Brittle star, unidentified NA NA 0.00 0.00 0.00 0.06 0.00 0.01 0.00% Butter sole Primary No 93.38 38.31 29.72 16.75 47.93 45.22 0.03% Chinook salmon* ETP NA 10883.03 13612.42 20891.34 21392.03 14820.27 16319.82 NA Corals bryozoans, unidentified Habitats Yes 0.00 0.02 0.18 0.00 0.00 0.04 0.00% Darkblotched rockfish Primary No 0.00 0.00 0.00 0.00 0.27 0.05 0.00% Dover sole Primary No 35.30 15.05 24.10 1.61 4.44 16.10 0.01% Dusky rockfish Primary No 13.14 14.99 23.17 12.12 38.68 20.42 0.01% Eelpouts Secondary No 0.00 0.68 0.00 0.00 0.00 0.14 0.00% English sole Primary No 18.09 10.21 1.81 1.39 18.15 9.93 0.01% Flatfish, unidentified NA NA 0.00 0.00 0.11 0.00 0.00 0.02 0.00% Flathead sole Primary No 353.69 438.55 308.81 181.35 283.58 313.20 0.19% Flounder, unidentified NA NA 0.00 0.00 0.71 0.53 0.00 0.25 0.00% Golden king crab* ETP NA 0.00 0.00 551.08 7.69 5.16 112.78 NA Great sculpin Secondary No 2.29 12.80 5.95 8.61 8.83 7.70 0.00% Greenlings, unidentified NA NA 0.00 0.00 0.00 0.00 1.28 0.26 0.00% Harlequin rockfish Primary No 0.00 0.00 0.22 0.00 0.00 0.04 0.00%

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Hermit crab, unidentified NA NA 0.00 0.00 0.00 0.02 0.00 0.00 0.00% Herring ETP NA 4.59 78.21 147.27 5.41 40.22 55.14 0.03% Longnose skate Secondary No 179.75 87.38 46.69 33.12 34.85 76.36 0.05% Misc. crabs NA NA 0.00 0.01 0.00 0.00 0.00 0.00 0.00% Misc. fish NA NA 73.61 56.68 16.85 18.77 47.83 42.75 0.03% Non-chinook salmon* ETP NA 1421.22 909.46 1975.29 4413.31 8029.24 3349.71 NA Northern rockfish Primary No 14.88 16.56 15.69 5.17 53.31 21.12 0.01% Octopus, unidentified NA NA 7.22 3.87 4.64 0.09 5.56 4.28 0.00% Opilio tanner crab* ETP NA 0.00 0.00 172.12 0.00 0.00 34.42 NA Osmerids, other NA NA 75.28 13.28 8.78 0.89 23.69 24.39 0.01% Pacific cod Primary No 3287.26 1712.22 853.36 612.04 600.39 1413.05 0.85% Pacific halibut ETP NA 137.24 168.34 226.67 109.10 289.96 186.26 0.11% Pacific Ocean perch Primary No 530.71 175.52 681.93 1266.00 1598.20 850.47 0.51% Pacific sleeper shark Primary No 6.33 11.99 37.40 0.64 7.27 12.73 0.01% Pandalid shrimp Primary No 0.04 0.17 0.50 0.13 0.22 0.21 0.00% Redbanded rockfish Primary No 0.00 0.92 0.00 0.00 0.00 0.18 0.00% Rex sole Primary No 270.70 145.90 113.40 67.31 126.11 144.69 0.09% Rock sole Primary No 132.41 289.13 221.25 231.56 209.09 216.69 0.13% Rougheye rockfish Primary No 21.55 11.77 44.11 2.92 9.40 17.95 0.01% Sablefish Primary No 30.41 129.97 89.04 46.48 317.38 122.66 0.07% Salmon shark Primary No 144.04 368.99 79.35 10.28 3.75 121.28 0.07% Sculpin, unidentified NA NA 4.18 5.58 2.92 4.64 0.46 3.56 0.00% Sculpin, unidentified NA NA 0.00 1.40 0.52 0.00 2.18 0.82 0.00% Scypho jellies Secondary No 23.09 169.62 157.38 14.48 13.43 75.60 0.05% Sea anemone, unidentified NA NA 0.00 0.55 2.43 0.00 0.23 0.64 0.00% Sea star Secondary No 6.21 1.11 3.34 0.81 43.29 10.95 0.01% Shark, other NA NA 2.16 6.00 0.55 3.61 0.00 2.46 0.00% Shortraker rockfish Primary No 0.91 5.26 174.08 0.52 0.25 36.20 0.02% Silvergray rockfish Primary No 0.00 0.00 0.00 0.00 0.92 0.18 0.00% Skate, other NA NA 12.14 15.06 2.68 3.46 2.69 7.21 0.00%

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Snails, unidentified NA NA 0.01 0.06 0.20 0.00 0.04 0.06 0.00% Spiny dogfish Primary No 13.38 35.41 49.62 49.04 58.10 41.11 0.02% Sponge, unidentified Habitats Yes 1.16 0.20 0.08 0.00 0.00 0.29 0.00% Squid, unidentified NA NA 65.40 355.89 161.95 15.40 8.83 121.49 0.07% Starry flounder Primary No 2.86 19.05 12.19 107.64 0.97 28.54 0.02% State-managed rockfish Primary No 0.05 0.00 5.50 0.06 1.90 1.50 0.00% Thornyhead rockfish Primary No 42.22 24.17 72.65 3.43 2.58 29.01 0.02% Urchins, dollars, cucumbers Secondary No 0.11 0.01 0.03 0.00 0.00 0.03 0.00% Yellow Irish lord Primary No 27.04 2.93 7.52 3.13 4.24 8.97 0.01% Yelloweye rockfish Primary No 0.04 0.67 0.23 0.00 0.18 0.22 0.00% Yellowfin sole Primary No 0.00 0.00 0.02 0.00 0.00 0.00 0.00% Total Catch** 143524.62 165649.57 176545.04 185339.79 158125.29 165836.86

Notes: * Number of individuals instead of tons ** Does not include species with individual numbers instead of weight

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Seabirds

Some 71 species of seabirds occur over waters off Alaska and could potentially be affected by direct and indirect interactions with these UoAs. Thirty-eight of these species regularly breed in Alaska and occur in the waters of the EEZ. More than 1,600 seabird colonies have been documented, ranging in size from a few pairs to 3.5 million birds. Breeding populations of seabirds are estimated at approximately 50 million birds (USFWS 2018).

Seabirds are caught incidentally in all types of fishing operations. Many factors contribute to the abundance and distribution of birds at sea, but many species are attracted to fishing vessels in order to forage on bait, offal, discards, and prey disturbed by the fishing operation. NOAA Fisheries’ Alaska Region Catch Accounting System manages Alaska fisheries’ catch data, using information gathered via the North Pacific Observer Program. “Observers identify each bird in their sample to the most accurate species or species group that they can. Species identification is verified for bird specimens collected through an AFSC-managed necropsy program. This program provides birds collected by observers from bycatch and ship strikes to a vendor to necropsy and verify the species identification” (Eich et al., 2018). Seabird bycatch estimates are updated annually.

As noted by Eich et al. (2018) when discussing seabird bycatch attributed to trawl gear, standard observer sampling does not account for all mortality, rather only numbers reported from the standard observer sample, i.e., birds caught in the net and brought aboard the vessel. Efforts to better understand the amount of cryptic mortality related to trawl vessels are ongoing.

Few seabirds are taken in the pelagic trawl fishery in the BSAI. Of those taken, essentially all are Northern Fulmars (Table 6). Although there is considerable interannual variation, the overall trend in bycatch has been relative stable since 2012.

Table 8 Seabird bycatch in the BSAI pollock trawl fishery. No seabirds are taken in the GOA. Source: Eich et al. (2018) Species 2012 2013 2014 2015 2016 2017 Average Northern Fulmar 90 123 51 112 84 109 181 Shearwaters 12 1 3 6 9 0 8 Storm Petrels 0 0 0 0 0 0 0 Gulls 0 3 0 0 3 0 3 Kittiwakes 0 0 0 0 0 0 1 Murres 0 3 3 0 6 1 3 Auklets 0 4 0 0 0 0 1 Cormorants 0 0 0 3 0 0 0 Other Birds 0 0 0 0 0 0 0 Unidentified Birds 0 0 0 6 6 0 6 Total 102 134 57 127 108 110 203

Northern fulmar

As stated in Tables 4 and 5, the BSAI UoA caught, on average, 181 northern fulmars. “Average annual mortality for northern fulmar since 2007 has been 4,110 birds. When compared to estimates of the total population size in Alaska of 1.4 million birds (Denlinger, 2006), observed fisheries account for an annual mortality of 0.29%” (Eich et al., 2018). Therefore, the UoA’s impact is relatively low.

Seabird management and information

NOAA Fisheries has several current regulations and measures in place to reduce and/or avoid seabird bycatch (https://www.fisheries.noaa.gov/alaska/bycatch/seabird-bycatch-alaska), though most are focused on longline gear. The regulations cover recordkeeping and reporting requirements, gear limitation, and specifications of seabird- avoidance gear for vessels based on the season, gear and the type of gear used. Requirements of vessels to report seabirds incidentally taken to the Observer Program are also outlined in the regulations.

Sharks

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Sharks are primary species, though not main, in the UoAs because they are a managed stock complex. Therefore, shark finning must be considered. According to NOAA, shark finning in the United States has been prohibited since 2000. “The Shark Finning Prohibition Act of 2000 amended the Magnuson-Stevens Act to prohibit any person under U.S. jurisdiction from engaging in the finning of sharks, possessing shark fins aboard a fishing vessel without the corresponding carcass, and landing shark fins without the corresponding carcass. On January 4, 2011, the Shark Conservation Act of 2010 was signed into law, amending the High Seas Driftnet Fishing Moratorium Protection Act and the Magnuson-Stevens Act. The Shark Conservation Act required that all sharks in the United States, with one exception, be brought to shore with their fins naturally attached” (NOAA Fisheries, 2019).

Cumulative impacts on primary and secondary species4

The MSC Fisheries Certification Requirements (MSC 2014) require consideration of the cumulative impact on primary and secondary species. That is, in a full assessment, these UoAs would need to consider of other MSC UoAs’5. If a main primary species is below its point where recruitment would be impaired (PRI), there needs to be evidence of recovery or an effective strategy in place between all MSC UoAs that categorize the species as main. If a main secondary species is below its biologically based limit and the catch of that species is “considerable”6, there needs to be evidence of recovery or an effective strategy in place between all MSC UoAs that have considerable catch of the species.

There are several likely relevant MSC UoAs. Table 7 shows the likely breakdown of main primary and main secondary species for those UoAs.

Table 9 Likely main primary and secondary species for the relevant MSC UoAs. Main primary Main secondary MSC UoA species species Auklets, northern fulmar, shearwaters*, BSAI Atka mackerel None storm petrels* Gulls*, northern fulmar, and BSAI flatfish Pacific cod, pollock shearwaters* BSAI Northern rockfish None Auklets Unknown at this Unknown at this BSAI Pacific cod time time BSAI Pacific Ocean perch None Auklets GOA dusky rockfish None Northern fulmar GOA flatfish Pacific cod Northern fulmar GOA northern rockfish None Northern fulmar Unknown at this Unknown at this GOA Pacific cod time time GOA Pacific Ocean perch None Northern fulmar Note: * Exact species unknown at this time; more information needed to determine whether they are secondary or ETP

7.3.4 ETP species There are a some ETP species that interact with these UoAs. Table 8 lists these species and the management measures that require their protection. The ESA was established in 1973 and carries out the provisions in the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). The ESA aims to conserve endangered and threatened fish, wildlife, and plant species and is administered by the U.S. Fish and Wildlife Service (USFWS) and the National Oceanic and Atmospheric Administration’s NMFS. Regarding fishing activities, the

4 This section has not been updated since the 2015 pre-assessment. Once more is known about the exact primary and secondary species for these UoAs and the species’ protection status, more accurate information will be included. 5 MSC (2014) defines “MSC UoAs” as “those UoAs that are in assessment or certified at the time the UoA announces its assessment or reassessment on the MSC website.” 6 MSC (2014) defines “considerable” catch as “those where main secondary species comprises more than 10% of the catch by weight of the UoA.”

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USFWS allows a certain level of “incidental take” (IT) of a listed species in cases where “an action may adversely affect a species but not jeopardize its continued existence” (USFWS 2017). Table 10 The protection measures and status (where relevant) of the ETP species encountered by these UoAs. Sources: https://www.fisheries.noaa.gov/national/marine-mammal-protection/list-fisheries-summary-tables, https://www.afsc.noaa.gov/publications/AFSC-TM/NOAA-TM-AFSC-354.pdf, https://www.fisheries.noaa.gov/find- species, https://ecos.fws.gov/ecp0/profile/speciesProfile?spcode=A0FS, https://www.iucnredlist.org/species/22694497/132556442, https://www.iucnredlist.org/species/22694502/132557429, https://www.iucnredlist.org/species/3590/45224953, https://www.iucnredlist.org/species/15106/45228501, https://acap.aq/en/acap-species/307-acap-species-list/file

Protection Measure and Status NOAA CITES IUCN Red Species UoAs PSC ESA MMPA ACAP Appx. I List Marine mammals Bearded seal (Alaska) BSAI Threatened LOF Beluga whale (Eastern Chukchi Sea, EBS, Bristol Bay, unknown stock) BSAI X Dall’s porpoise (Alaska) All LOF Fin whale (northeast Pacific) GOA Endangered LOF X Vulnerable Harbor seal (Alaska) BSAI LOF Humpback whale (central North Pacific) BSAI LOF X Humpback whale (western North Pacific) BSAI Endangered LOF X Northern elephant seal (North Pacific) GOA LOF Northern fur seal (eastern Pacific) BSAI LOF Vulnerable Ribbon seal (Alaska) BSAI LOF Ringed seal (Alaska) BSAI Threatened LOF Spotted seal (Alaska) BSAI LOF Steller sea lion (western US) All Endangered LOF Endangered Fish and crustaceans Bairdi tanner crab All X Chinook salmon All X Golden king crab All X Herring All X Non-chinook salmon All X Opilio tanner crab All X Pacific halibut All X Red king crab BSAI X Seabirds Short-tailed albatross All X Vulnerable Steller’s eider All Threatened Vulnerable

CITES is a multilateral treaty established to protect endangered plants and . It was drafted at a meeting of members of the International Union for Conservation of Nature (IUCN) and became effective in 1975. It aims to ensure that the international trade of wild animals and plants does not threaten the survival of these species, and it extends varying degrees of protection to more than 35,000 and plant species. Each CITES-protected species is assigned an appendix, which specifics the extent of the threat and the trade controls applied to that species. CITES Appendix I, the highest level, includes the species that are threatened with extinction and are, or may be, affected by trade.

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The Marine Mammal Protection Act (MMPA) was enacted in 1972 in response to increasing concerns that human activity was causing significant declines in some marine mammal populations. All marine mammals in U.S. waters are protected by the MMPA, which is implemented by NMFS, USFWS, and the Marine Mammal Commission. NMFS performs various conservation and management actions, including: • Development and implementation of conservation plans for depleted species • Development and implementation of take-reduction plans to minimize commercial fishing bycatch • Coordination of the Marine Mammal Health and Stranding Response Program and investigation of unusual mortality events • Collaboration with other nations to ensure that international trade does not threaten marine mammals • Investigation and prosecution of MMPA violations Required by the MMPA, NMFS publishes its List of Fisheries (LOF), which classifies commercial fisheries into one of three categories (I, II, and III) based on the level of incidental marine mammal mortality or serious injury that occurs. Category I and II mean there are “frequent interactions” and “occasional interactions”, respectively. Category III means there is a “remote likelihood of/no known interactions”. The classification dictates whether fishers are subject to actions, such as observer coverage and take-reduction plan requirements.

The MMPA limits the number of each marine mammal species that can be killed as part of fishing activities. This is the potential biological removal (PBR) level, which is defined as “the maximum number of animals, not including natural mortalities, that may be removed from a marine mammal stock while allowing that stock to reach or maintain its optimum sustainable population” (https://www.fisheries.noaa.gov/insight/glossary-marine-mammal-protection-act- definitions).

The Agreement on the Conservation of Albatrosses and Petrels (ACAP) is a multilateral agreement that was introduced in 2004. It seeks to protect albatrosses and petrels by coordinating international activities to mitigate known population threats. There are currently 13 member countries, and while the United States is not one of them, the MSC requirements state that ACAP shall be considered, nonetheless. ACAP currently covers 31 species of albatrosses, petrels, and shearwaters.

The IUCN Red List of Threatened Species was introduced in 1994 with the goal of providing information and analyses on the status, trends, and threats to species in order to inform and catalyze conservation action. To achieve this goal, The IUCN Red List aims to: • Establish a baseline for monitoring species status changes • Provide a global context for the establishment of local level conservation priorities • Monitor, on a continuing basis, the status of a representative selection of species that covers all major ecosystems Table 9 provides interaction data and relevant catch limit information for the ETP species encountered by the UoAs. In some cases, additional information is needed, and once it is available, each of those ETP species will be discussed in more detail below. Table 11 ETP species encountered by the UoAs, the catch limits set for these species, and the level of impact the fishery has on each species. Sources: observer data, https://www.afsc.noaa.gov/publications/AFSC- TM/NOAA-TM-AFSC-354.pdf, https://www.fisheries.noaa.gov/national/marine-mammal-protection/marine- mammal-stock-assessment-reports-species-stock

National and/or International Limits Yes/No (and UoAs within Species Type) Annual Limit UoAs Catch (and Year)* Limit? Marine mammals Bearded seal (Alaska) Yes (PBR) 8,210 BSAI: 0 (2015) Yes Beluga whale (Eastern Chukchi Sea, EBS, Bristol Bay, Unknown stock) Yes (PBR) ** BSAI: 0 (2015) Yes BSAI: 0 (2015) Dall’s porpoise (Alaska) Yes (PBR) Undetermined GOA: 0 (2015) Yes Fin whale (northeast Pacific) Yes (PBR) 5.1 GOA: 0 (2015) Yes Harbor seal (Alaska) Yes (PBR) *** BSAI: 0 (2015) Yes Humpback whale (central North Pacific) Yes (PBR) 83 BSAI: 0 (2015) Yes Humpback whale (western North Pacific) Yes (PBR) 3 BSAI: 0 (2015) Yes 53 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Northern elephant seal (North Pacific) Yes (PBR) 4,882 GOA: 0 (2015) Yes Northern fur seal (eastern Pacific) Yes (PBR) 11,602 BSAI: 0 (2015) Yes Ribbon seal (Alaska) Yes (PBR) 9,785 BSAI: 0 (2015) Yes Ringed seal (Alaska) Yes (PBR) 5,100 BSAI: 0 (2015) Yes Spotted seal (Alaska) Yes (PBR) 12,697 BSAI: 0 (2015) Yes BSAI: 1 (2015) Steller sea lion (western US)2 Yes (PBR) 320 GOA: 5 (2015) Yes Fish and crustaceans BSAI: 2283 (2018) Bairdi tanner crab Yes (PSC) ?# GOA: 3247 (2018) ?# BSAI: 11,170(2018) Chinook salmon Yes (PSC) ?# GOA: 16,320 (2018) ?# BSAI: 616 (2018) Golden king crab Yes (PSC) ?# GOA: 113 (2018) ?# BSAI: 474.24 tons (2018) Herring Yes (PSC) ?# GOA: 55.14 tons (2018) ?# BSAI: 262,188 (2018) Non-chinook salmon Yes (PSC) ?# GOA: 3350 (2018) ?# BSAI: 5,143 (2018) Opilio tanner crab Yes (PSC) ?# GOA: 34 (2018) ?# BSAI: 55.81 tons (2018) Pacific halibut Yes (PSC) ?# GOA: 186.26 tons (2018) ?# Red king crab Yes (PSC) ?# BSAI: 565 (2018) ?# Seabirds Short-tailed albatross ?# ?# ?# ?# Steller’s eider ?# ?# ?# ?#

"Catch" means fatal interaction (i.e., mortally wounded or killed by gear or fatal removal from gear) Year = most recent year (2015 or after) with data * Catch in number of individuals unless stated otherwise; used most recent year with data ** See Table 10 below. *** See Table 11 below. # Information will be updated when made available.

Marine mammals

Bearded seal

In the Pacific, the bearded seal (Erignathus barbatus nauticus) is found from the Arctic Ocean (85°N) south to Sakhalin Island (45°N), inhabiting seasonally ice-covered seas. There are two subspecies: E. b. barbatus (Laptev Sea, Barents Sea, North Atlantic Ocean, and Hudson Bay [Rice 1998]) and E. b. nauticus (remaining portions of the Arctic Ocean and the Bering and Okhotsk Seas [Ognev 1935; Scheffer 1958; Manning 1974; Heptner et al. 1976]). The Alaska stock’s distribution is shown in Figure 1.

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Figure 1 Approximate distribution of the bearded seal population in Alaska (dark gray), combining summer and winter distribution. Source: Muto et al. 2018 The most recent stock assessment (2012) estimated the population in U.S. waters to be 299,174 (Muto et al. 2018). According to the 2018 LOF, the BSAI pollock UoA is a Category II, meaning they have occasional interactions with this stock. Various human impacts (e.g., fishing) have known effects on the species. With regards to fishing, trawls, longlines, and pots have been linked to mortalities. The PBR for U.S. portion of the Bering Sea is 8,210, though this is not a PBR for the entire stock because a reliable stock assessment of the entire stock is not available. The UoA had no observed interaction in 2015 (Table 9). Therefore, it likely has a negligible impact on the population.

Beluga whale (Eastern Chukchi Sea/EBS/Bristol Bay/unknown stock)

The beluga whales (Delphinapterus leucas) is distributed throughout seasonally ice-covered arctic and subarctic waters of the Northern Hemisphere (Gurevich 1980; Figure 2). Since the UoA’s interaction is on an unknown stock, Table 10 shows the population size estimate and PBR for all five stocks. According to the 2018 LOF, the BSAI pollock UoA is a Category II, meaning they have occasional interactions with this stock. Various human impacts (e.g., fishing) have known effects on the species. With regards to fishing, trawls have been linked to mortalities. This UoA had no observed interaction in 2015 (Table 9). Therefore, it likely has a negligible impact on the population.

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Figure 2 Approximate distribution for the five beluga whale shocks with summering areas in dark gray, wintering areas in lighter gray, and the autumn migration area for the Eastern Chukchi Sea and Beaufort Sea stocks hashed. Source: Muto et al. 2018

Table 12 Population size and PBR for the five beluga whale stocks. Source: Muto et al. 2018 Stock Last stock Population PBR assessment estimate Beaufort Sea 2017 39,258 Undetermined Bristol Bay 2017 1,926 Undetermined Cook Inlet 2017 312 0.57 Eastern Bering Sea 2017 6,994 Undetermined Eastern Chukchi Sea 2017 20,752 244

Dall’s porpoise

Dall’s porpoise (Phocoenoides dalli) is throughout the North Pacific Ocean (Figure 3). The most recent stock assessment (2015) estimated the Alaskan stock population to be 417,000 (Muto et al. 2018). According to the 2018 LOF, the BSAI pollock UoA is a Category II, meaning they have occasional interactions with this stock, and the GOA pollock UoA is a Category III, meaning a remote likelihood of/no known interactions. Various human impacts (e.g., fishing) have known effects on the species. With regards to fishing, trawls, longlines, and gillnets have been linked to mortalities. The PBR for the stock is undetermined since the data are too old to produce a reliable number. However, the UoAs had no observed interaction in 2015 (Table 9). Therefore, it likely has a negligible impact on the population.

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Figure 3 Approximate distribution for Dall’s porpoise in Alaskan waters (dark gray). Source: Muto et al. 2018

Fin whale

Within the U.S. Pacific Ocean, fin whales (Balaenoptera physalus) are found off the coast of North America and in the Bering Sea in the summer (Figure 4). “In 2013 and 2015 dedicated line-transect surveys of the offshore waters of the Gulf of Alaska recorded, respectively, 171 and 38 sightings (Rone et al. 2017). These surveys provided fin whale abundance estimates of 3,168 fin whales (CV = 0.26) in 2013 and 916 (CV = 0.39) in 2015. The marked differences in these estimates can be partially explained by differences in sampling coverage across the two cruises (Rone et al. 2017)” (Muto et al. 2018). Therefore, abundance estimates in the EBS and GOA cannot be considered representative of the entire northeast Pacific stock (Muto et al. 2018).

Figure 4 Approximate distribution of fin whales in the eastern North Pacific (dark gray). Striped areas show where previous vessel surveys occurred. Source: Muto et al. 2018

According to the 2018 LOF, the GOA pollock UoA is a Category III. Various human impacts (e.g., fishing) have known effects on the species. With regards to fishing, gear entanglement has been linked to mortalities. Using the provisional population estimate of 3,168, the PBR stock is 5.1, though this PBR is likely biased low for the entire stock. The UoA had no observed interaction in 2015 (Table 9). Therefore, it likely has a negligible impact on the population.

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Harbor seal

The harbor seal (Phoca vitulina richardii) has a wide distribution, inhabiting coastal and estuarine waters from Baja California to the Bering Sea. “In 2010, NMFS and their co-management partners, the Alaska Native Harbor Seal Commission, identified 12 separate stocks of harbor seals based largely on genetic structure; this represents a significant increase in the number of harbor seal stocks from the three stocks (Bering Sea, Gulf of Alaska, Southeast Alaska) previously recognized” (Muto et al. 2018). Figure 5 shows all stocks in Alaskan waters.

Figure 5 Approximate distribution of the harbor seal stocks in Alaskan waters (light gray). Source: Muto et al. 2018

For reporting purposes, the observer data and 2018 LOF use the overarching “Alaska stock” label. Therefore, the assessment team has chosen to mention population estimates and PBRs for all stocks (Table 11). According to the 2018 LOF, the BSAI pollock UoA is a Category II with regard to interactions with these stocks. Various human impacts (e.g., fishing) have known effects on the species. Gillnets have been linked to mortalities. The BSAI pollock UoA had no observed interaction in 2015 (Table 9). Therefore, it likely has a negligible impact on the population.

Table 13 Most recent stock assessment, population estimate, and PBR for all Alaska stocks Stock Last Stock Population PBR Assessment Estimate Aleutian Islands 2011 6,431 173 Bristol Bay 2011 32,350 1,182 Clarence Strait 2011 31,634 1,222 Cook Inlet/ Shelikof 2011 27,386 770 Strait Dixon/Cape Decision 2011 18,105 703 Glacier Bay/Icy Strait 2011 7,210 169 Lynn Canal/Stephens 2011 9,478 155 Passage North Kodiak 2011 8,321 298 Pribilof Islands 2011 232 7 Prince William Sound 2011 29,889 838

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Sitka/Chatham Strait 2011 14,855 555 South Kodiak 2011 19,199 314

Humpback whale (central North Pacific)

The humpback whale (Megaptera novaeangliae) is found worldwide in all oceans. In the winter, they congregate in subtropical and tropical waters in the Northern and Southern Hemispheres. In summer, they feed in coastal and inland waters in the North Pacific, ranging from Point Conception, California; north to the GOA and the BS; and west along the AIs to the Kamchatka Peninsula and into the Sea of Okhotsk and north of the Bering Strait (Figure 6).

Figure 6 Approximate distribution of the humpback whale in the eastern North Pacific (dark gray). The dotted line represents where the eastern North Pacific and western North Pacific stocks overlap. Source: Muto et al. 2018 The most recent stock assessment (2017) estimated the stock population to be 10,103 (Muto et al. 2018). According to the 2018 LOF, the BSAI pollock UoA is a Category II, meaning they have occasional interactions with this stock. Various human impacts (e.g., fishing) have known effects on the species. With regards to fishing, trawls, longlines, and pots have been linked to mortalities. The PBR for the stock is 83. The UoA had no observed interaction in 2015 (Table 9). Therefore, it likely has a negligible impact on the population.

Humpback whale (western North Pacific)

Figure 7 shows the range of the western North Pacific stock of the humpback whale. The most recent stock assessment (2017) estimated the population at 865 (Muto et al. 2018). According to the 2018 LOF, the BSAI pollock UoA is a Category II, meaning it has occasional interactions with this stock. Various human impacts (e.g., fishing) have known effects on the species. With regards to fishing, longlines and pots have been linked to mortalities. The PBR for this stock is 3, and the UoA had no observed interactions in 2015 (Table 9). Therefore, it likely has a negligible impact on the population.

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Figure 7 Approximate distribution of the humpback whale in the western North Pacific (dark gray). Source: Muto et al. 2018

Northern elephant seal

The northern elephant seal (Mirounga angustirostris) is found throughout the eastern Pacific Ocean from the coast of Baja California to the Gulf of Alaska and the Aleutian Islands and westward to about the International Dateline (Le Boeuf et al., 2000; Figure 8). Since all age classes are not on shore at the same time, it is not possible to count individuals directly to obtain the total population size. Therefore, the population is estimated by counting the number of pups born and multiplying by the inverse of the expected ratio of pups to total animals (McCann 1985). Based on the number of elephant seals at U.S. rookeries in 2010, Lowry et al. (2014) determined that 40,684 pups were born and applied a multiplier of 4.4 to extrapolate from total pup counts to a population estimate of 179,000 elephant seals (Carretta et al., 2016).

Figure 8 Range of northern elephant seals in the eastern North Pacific. Source: Carretta et al., 2016 Various human impacts (e.g., marine debris, vessel strikes, fishing) have known effects on northern elephant seals. According to the 2018 LOF, the GOA pollock UoA is a Category III with regard to interactions with northern elephant seals. With regards to fishing, trawl gear has the most impact due to entanglement. However, the PBR for this stock is 4,882, and the UoA had no observed interaction in 2015 (Table 9). Therefore, it likely has a negligible impact on the population.

Northern fur seal

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The northern fur seal (Callorhinus ursinus) ranges from southern California to the Bering Sea and west to the Okhotsk Sea and Honshu Island, Japan (Figure 9). In the summer, the majority of the worldwide population breed on the Pribilof Islands. The eastern Pacific stock is significantly larger than the California stock, making up nearly 99% of the total population (Gelatt et al., 2015).

Figure 9 Approximate distribution of northern fur seals in the eastern North Pacific (dark gray shaded area). Source: Muto et al. 2018

Using the estimated number of pups on Sea Lion Rock, St. Paul, St. George, and Bogoslof Islands (i.e., rookery locations) and multiplying by an expansion factor of 4.47, the most recent stock assessment (2017) estimated the eastern Pacific stock population at 637,561 (Muto et al. 2018). The 2018 LOF classified the BSAI pollock UoA as a Category II with regard to the northern fur seal. Various human impacts (e.g., marine debris, fishing) have known effects on fur seals. With regards to fishing, interactions with gillnet and trawl gear can cause entanglement deaths. The PBR for this stock is 11,602, and the UoA had no observed interactions in 2015 (Table 9). Therefore, it likely has a negligible impact on the population.

Ribbon seal

The ribbon seal (Histriophoca fasciata) has been found in the North Pacific Ocean and adjacent parts of the Arctic Ocean. In Alaska, they range from the North Pacific and Bering Sea to the Chukchi and western Beaufort Seas (Figure 10, Muto et al. 2018). The most recent stock assessment (2014) estimated the Alaska resident population at 184,000 (Muto et al. 2018). According to the 2018 LOF, the BSAI pollock UoA is a Category II with regard to interactions with ribbon seals. With regards to fishing, trawl gear has been linked to mortalities. The PBR for this stock is 9,785, and the UoA had no observed interactions in 2015 (Table 9). Therefore, it likely has a negligible impact on the population.

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Figure 10 Approximate combined summer and winter distribution of the ribbon seal (dark gray shaded areas) in Alaskan waters. Source: Muto et al. 2018

Ringed seal

The ringed seal (Pusa hispida hispida) is found seasonally in all ice-covered areas in the Northern Hemisphere (Figure 11). Genetic studies have differentiated five subspecies of ringed seals: P. h. hispida in the Arctic Ocean and Bering Sea; P. h. ochotensis in the Sea of Okhotsk and northern Sea of Japan; P. h. botnica in the northern Baltic Sea; P. h. lagodensis in Lake Ladoga, Russia; and P. h. saimensis in Lake Saimaa, Finland (Ognev 1935, Müller-Wille 1969, Hyvärinen and Nieminen 1990, Rice 1998, Amano et al. 2002).

Figure 11 Approximate winter distribution of the ringed seal (dark gray shaded areas). Source: Muto et al. 2018 There is not a reliable population estimate for the entire Alaska stock though research programs have developed new survey methods, resulting in partial abundance estimates. Data collected from the U.S. portion of the Bering Sea in 2012 calculated an abundance estimate of about 170,000 ringed seals, but this estimate does not account for availability bias. Therefore, the actual population of ringed seals in the U.S. portion of the Bering Sea is likely much larger – by a factor of two or more (Moreland et al. 2013, Conn et al. 2014, Muto et al. 2018). According to the 2018 LOF, the BSAI pollock UoA is a Category II with regard to interactions with ringed seals. With regards to fishing, trawl and longline gear have been linked to mortalities. The PBR for ringed seals in U.S. portion of the Bering Sea is 5,100.

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A PBR for the entire stock cannot be estimated reliably since the stock-wide population is unknown. The UoA had no observed interaction in 2015 (Table 9). Therefore, it likely has a negligible impact on the population.

Spotted seal

The spotted seal (Phoca largha) is found along the continental shelf of the Bering, Chukchi, and Beaufort Seas and the Sea of Okhotsk south to the western Sea of Japan and northern Yellow Sea (Figure 12). There are eight main breeding areas, and genetic studies (along with geographic barriers) have led to the grouping of these breeding areas into three distinct population segments (DPSs): the Bering DPS, the Okhotsk DPS, and the Southern DPS (Shaughnessy and Fay 1977, Boveng et al. 2009). The Alaska stock is defined as the portion of the Bering DPS within U.S. waters.

Figure 12 Approximate distribution of the spotted seal in the Bering DPS (dark gray shaded areas). Source: Muto et al. 2018

Again, there is not a reliable population estimate for the entire Alaska because the proportion of the Alaska stock that occupies U.S. vs. Russian waters of the Bering Sea in the spring is unknown (Boveng et al. 2009). However, Conn et al. (2014) calculated an abundance estimate of approximately 461,625 spotted seals in the U.S. portion of the Bering Sea. This estimate was not calculated in the standard manner for proper extrapolation of the PBR (i.e., Bayesian vs. Equation 1 from the PBR guidelines [Wade and Angliss 1997]). Using Equation 1, the population estimate is 423,237, resulting in a PBR for the Alaska stock of 12,697 (Muto et al. 2018). According to the 2018 LOF, the BSAI pollock UoA is a Category II with regard to interactions with spotted seals. With regards to fishing, trawl and longline gear have been linked to mortalities. The UoA had one observed interaction in 2015 (Table 9). Therefore, it likely has a negligible impact on the population.

Steller sea lion

The Steller sea lion (Eumetopias jubatus) is found along the North Pacific Rim from northern Japan to California (Figure 13). The most recent stock assessment (2016) estimated the Steller sea lion western U.S. stock population at 53,303, which includes pups and non-pups (Muto et al. 2018). Data collected through 2016 show strong evidence that that the western stock population in Alaska was at its lowest in 2002 and 2003 and have increased at over 2% per year between 2003 and 2016. However, the stock is still classified as endangered on the ESA list and IUCN Red List. According to the 2018 LOF, the BSAI pollock UoA is a Category II, and the GOA pollock UOA is a Category III. Fishing gear entanglement has been linked to mortalities. The PBR for this stock is 320. The BSAI and GOA UoAs, respectively, had 1 and 5 observed interactions in 2015 (Table 9). Therefore, the UoAs likely have a negligible impact on the population.

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Figure 13 Approximate distribution (cross-hatched area) and major U.S. haulouts and rookeries (black dots) of the Steller sea lion (both eastern and western U.S. stocks). Source: Muto et al. 2018

Critical habitat has been designated (50 CFR 226.202 on Aug. 27, 1993) for Steller sea lions as a 20-nm buffer around all major haul-outs and rookeries, as well as associated terrestrial, air, and aquatic zones, and three large offshore foraging areas. No-entry zones around rookeries (50 CFR 223.202) have also been designated. A suite of fishery management measures has been designed to minimize competition between fishing and the endangered population of Steller sea lions in critical habitat areas. A recovery plan was developed for Steller sea lions in 1992 with a revised recovery plan (NFMS 2008) being issued in 2008.

“The 1988 amendments [to the MMPA] also required the Secretary to implement emergency regulations to prevent further taking of Steller sea lions if more than 1,350 were taken during a calendar year. In addition, NMFS may place observers on Category I and II vessels to 1) obtain reliable estimates of incidental serious injury and mortality of marine mammals; 2) determine the reliability of reports submitted by vessel owners and operators; 3) identify changes in fishing methods or technology that may decrease incidental serious injury or mortality if necessary; 4) collect biological samples that may otherwise be unobtainable for scientific studies; and 5) record data on bycatch and discard levels of all species” (NMFS 2008).

Fish and crustaceans

As discussed above, these “prohibited species” have PSC limits, which are measures to limit the incidental catch of these species in these UoAs. While not ETP species under the MSC definition, they have been designated as “prohibited species” in FMPs so they are considered ETP in this assessment. Following the site visit and collection of more information, these species will be discussed in more detail. However, with regard to management and the utilization of unwanted catch, there is a donation permit program in place (https://alaskafisheries.noaa.gov/fisheries/prohibited-species-donation-permits).

Salmon – Three ESA-threatened salmon stocks that migrate to Alaskan waters include Lower Columbia River Chinook salmon, upper Willamette River Chinook salmon, and Lower Columbia River Chinook, spring. About 90% of the Chinook salmon bycatch is taken in the pollock fishery. Coded-wire tag recoveries from salmon bycatch in the BSAI pollock fishery between 1984 and 2012 revealed that few wild Chinook from the lower Columbia or upper Willamette rivers are taken by the pollock fishery (NMFS 2013). Most (97%) of the CWT recoveries are from hatchery salmon. Results from collected samples should be considered as minimum estimates of the number of ESA-listed evolutionarily significant units (ESU) in the GOA and BSAI groundfish fisheries until adequate numbers of CWTs are recovered from inside the observers’ samples, where the total number of fish sampled is known.

NMFS conducted a review in 2010 and early 2011 of 27 of the 28 currently listed Pacific salmonid ESUs/DPSs of West Coast Pacific salmon. Based on this evaluation, no change in the listing status of the three stocks migrating to Alaskan waters was recommended (Ford [ed] 2011). Given the small number of Chinook estimated to have been taken in the Pollock fishery, the BSAI pollock fishery is highly unlikely to pose a threat to ESA-listed salmon ESUs in the Pacific Northwest.

BSAI - A high number of non-Chinook salmon (nearly all made up of chum salmon) was taken in the 2017 BSAI pollock fishery. At 424,018 fish, this was the highest catch since 2011 and almost three times the average bycatch for 64 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019 the period 2011 to 2016. However, in 2018, the number of non-Chinook taken in The BSAI fishery declined to 263,188. Chinook salmon bycatch in the BSAI also declined to 11,170 compared to the 2017 bycatch of 19,674 fish; above the average of 14,725 for the previous six years (Mary Furuness, NMFS Alaska Regional Office, Catch Accounting System, 2018). The recent bycatches of Chinook arel well below the allowable limits established by Amendment 91 and the lower catch limit established in Amendment 110 of 45,000 fish (Balsiger 2018).

Updated genetics work on Chinook salmon bycatch in the BSAI Pollock fishery has been completed for the 2016 fishing year (Guthrie et al. 2018). Results indicate that 60% of the 1,488 samples from the “A” season originated from Alaska river systems flowing into the Bering Sea (all regions north of the Aleutian Islands except for Russia) with the Coastal Western Alaska region contributing the most (39%), followed by the North Alaska Peninsula (17%), and Upper Yukon (2%). The other major contributors were British Columbia (26%), West Coast US (9%), and Coastal Southeast Alaska (4%). For the “B” season, over 81% of the 422 samples originated from regions south of the Aleutian chain with the British Columbia region contributing the most (37%), followed by the West Coast US (30%), Coastal Western Alaska 17%, Coastal Southeast Alaska (7%) and Northwest GOA (6%) regions.

Stock compositions from the analysis of the 2016 “A” season Chinook salmon bycatch showed that most samples continued to originate from river systems directly flowing into the Bering Sea, but were lower than in previous years, with an increase from GOA, BC, and West Coast US. The Coastal Western Alaska region continued to be the largest contributor in the 2016 “A” season but was lower than in all previous years. The 2016 “B” season stock composition estimates from Coastal Western Alaska continued to drop as observed across 2011-2015, a 57% decline since 2011 (Guthrie et al. 2018).

Whittle et al. (2018) estimate stock origin of Chum salmon taken in the 2016 pollock fishery. Most of the 114 chum salmon samples from the A-season were from Northeast Asia (37%) and Eastern GOA/Pacific Northwest (PNW) (37%) stocks. Based on the analysis of 2,701 chum salmon collected throughout the B-season, the largest stock groups in the catch were Eastern GOA/PNW (35%) and Northeast Asia (31%), followed by Western Alaska (19%), Southeast Asia (9%), Upper/Middle Yukon (5%), and Southwest Alaska (< 2%) stocks. The Chum salmon caught in the Bering Sea in 2016 shared general patterns of stock distribution with those from past years. However, during the B season more of the bycatch was from Northeast Asia and less from Eastern GOA/Pacific Northwest than in 2015. Adult equivalency (AEQ) estimates of Chinook salmon taken in the pollock fishery were applied to the latest available genetics data (by A and B seasons) to estimate AEQ to regional origins. These estimates are compared with the recent run-size estimates provided by the Alaska Department of Fish and Game. Results indicate that the ratio of AEQ relative to regional run strengths for coastal west Alaska and Yukon river stocks remains low since Amendments 91 and 110 went into effect (NPFMC June 2018 Meeting, D3 Corrected BSAI Salmon AEQ Update [from April 2018] – Update on Chinook salmon mortality due to bycatch in the EBS pollock fishery).

GOA – Fewer Chinook salmon were taken in the COA pollock fishery in 2018 (16,320 fish) compared to the 2017 bycatch of 21,392. Thus, in both years the bycatch was within the limit of 25,000 Chinook salmon set by Amendment 93 in 2012 (Balsiger 2016). The bycatch of non-Chinook salmon also declined in 2018 (3,350 fish) compared to 4,413 fish in 2017. However, both years exceeded the average of 1,077 during the period 2011-2016.

Updated genetics work on Chum salmon in the GOA pollock fishery have been completed for the 2016 fishing year. In 2016, Chum salmon samples were collected in the GOA primarily from the pollock trawl fishery, which caught about 56% of the chum salmon PSC in the GOA. The stock composition estimates of the 2016 GOA samples were nearly identical to the 2014-2015 estimates, with more than 90% of the contribution from Eastern GOA/PNW stocks (Whittle et al. 2018).

The estimated stock origin of Chinook salmon taken in the 2016 GOA Pollock fishery are given in Guthrie et al. (2018). The bycatch from Pollock trawl fishery was the largest component of the salmon bycatch in the GOA in 2016. The stock composition results indicate that 99.9% of the 4,962 samples from the GOA originated from GOA/Pacific coastal regions, with the British Columbia group contributing the most (42%), followed by the West Coast US (40%), and Coastal Southeast Alaska (15%). These bycatch data continue to show that most of Chinook salmon that are encountered are derived from river systems that flow into the GOA and the Eastern Pacific Ocean.

Seabirds

There are three species of seabirds listed as threatened or endangered in the BSAI (Table ETP). The Short-tailed albatross (Phoebastria albatrus) is a long-lived species with a low reproductive rate and is listed as endangered. Torishima Island and Minami-kojima Island, Japan are the only two breeding colonies that remain active today. Short- tailed albatrosses forage widely across the temperate and subarctic North Pacific, and can be seen in the Gulf of Alaska, along the Aleutian Islands, and in the Bering Sea. The world population is currently estimated to be about 1700 birds and is increasing. The Biological Opinion for the Short-tailed albatross (USFWS 2003) allows for an

65 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019 incidental take of four birds in each 2-year period for the demersal longline fishery. This take is based on numbers of birds observed rather than the estimate of total take derived from the observed take. The recovery plan states that the major threat of over-exploitation that led to the species’ original endangered status no longer occurs.

In 1997, the Alaska-breeding population of Steller’s eiders (Polysticta stelleri) was listed as threatened under the Endangered Species Act (ESA) based on: abandonment of significant portions of their former nesting range in Alaska and a reduction in the number of Steller’s eiders nesting in Alaska (particularly the Y-K Delta (http://www.fws.gov/alaska/fisheries/endangered/pdf/Stei_Gen_Factsheet_03-04-14.pdf). This species is declining in abundance and is listed as Vulnerable by the IUCN. Population sizes are only imprecisely known, but about 370,000 individuals overwinter in the North Pacific. The threatened Alaska breeding population is thought to include hundreds on the Arctic Coastal Plain, and possibly dozens on the Y-K Delta. Steller's eiders are diving ducks that spend most of the year in shallow, near-shore marine waters and overwinter in the eastern Aleutians and Kenai Peninsula. Shooting, lead poisoning and predation are listed as the major threats to recovery. Based on observed data this species appears to rarely interact with the cod fishery as none have been recorded by the AFSC seabird bycatch program.

Cumulative impacts on ETP species

The MSC Fisheries Certification Requirements (MSC 2014) require consideration of the cumulative impact on ETP species. That is, where there are national and/or international limits for ETP species, the combined effects of the MSC UoAs on the population/stock are considered. Once the other MSC UoAs’ impacts are known, cumulative impacts on the relevant species will be considered.

7.3.5 Habitats7

NMFS and the NPFMC recognize that habitat is essential for maintaining productivity of fishery resources. Because fishing gear has the potential to disturb habitat, regulations have been implemented to protect areas that could be irreversibly damaged by fishing. Large areas of the North Pacific have been permanently closed to groundfish trawling to reduce potential adverse impacts on sensitive habitat and to protect benthic invertebrates. Fishery closures established in nearshore areas to reduce interactions with Steller sea lions may also have ancillary benefits of reducing habitat impacts (NPFMC 2014). In 2005, NOAA published the Final EIS for EFH in Alaska which identified EFH for fisheries managed by the NPFMC, recommending an approach to identify Habitat Area of Particular Concern (HAPC) and specifying an objective to minimize to the extent practicably possible the adverse effects of fishing on EFH (NOAA 2005). As a result, all FMPs now include a description and identification of EFH, adverse impacts, and actions to conserve and enhance habitat. HAPCs are specific sites within EFH that are of ecological importance to the long-term sustainability of managed species, are rare, or are susceptible to degradation or development. HAPC proposals may be solicited every five years, coinciding with the EFH five-year review or may be initiated at any time by the NPFMC. Current HAPCs in BSAI and GOA are mapped here: https://alaskafisheries.noaa.gov/sites/default/files/hapc_ak.pdf.

In 2010, NMFS conducted a five-year review of EHF (https://alaskafisheries.noaa.gov/habitat/efh-review). The review concluded that “while recent research provided incremental improvements to our understanding of habitat types, sensitivity and recovery of seafloor habitat features, these new results were consistent with the sensitivity and recovery parameters and distributions of habitat types used in the prior analysis of fishing effects for the EFH EIS. None of this new information revealed significant errors in the parameters used in that analysis; rather, it marginally increased support for their validity” (NMFS 2010). In 2015, NMFS and the NPFMC initiated another five-year review, which will utilize additional modeling techniques to understand and quantify better the fisheries’ impacts to EFH.

For the purposes of an MSC assessment, the main habitats are those that are commonly encountered and the vulnerable marine ecosystems (VMEs). The commonly encountered habitats in the BSAI and GOA areas vary from deep, rocky bottoms to shallow rises or banks. With regard to VMEs, NMFS and the NPFMC have designated EFHs and HAPCs within the UoAs’ fishing areas.

BSAI

The following HAPCs have been designated in the BSAI management area: 1) Bowers Ridge Habitat Conservation Zone (Bowers Ridge and Ulm Plateau; bottom contact gear prohibited), 2) Alaska Seamount Habitat Protection Area (Bowers Seamount, mobile bottom contact gear prohibited), 3) skate egg concentration areas, and 4) four areas designated as the Aleutian Islands Coral Habitat Protection Areas where no contact with the bottom is permitted.

7 This section has not been updated from the previous Public Certification Report. It will be updated following the site visit when more up-to-date information has been collected.

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Details of these areas are provided on the NPFMC website (http://www.npfmc.org/habitat-protections/habitat-areas-of- particular-concern-hapc/) and the BSAI FMP (NPFMC 2014). NOAA’s Deep Sea Coral Research and Technology Program is funding research in Alaska to examine the location, distribution, ecosystem role, and status of deep-sea coral and sponge habitats to identify additional areas with may need protection.

Bering Sea

The eastern Bering Sea sediments are a mixture of mud (clay and silt), sand, and gravel. Sand and silt are the primary components over most of the seafloor, with sand predominating in waters <60 m deep. The proportions of finer-grade sediments increase with increasing depth and distance from shore. This grading is particularly noticeable on the southeastern Bering Sea continental shelf in Bristol Bay and immediately westward. Generally, nearshore sediments in the east and southeast on the inner shelf (0 to 50 m depth) are sandy gravel and gravelly sand. These give way to plain sand farther offshore and west. On the middle shelf (50 to 100 m), sand gives way to muddy sand and sandy mud, which continues over much of the outer shelf (100 to 200 m) to the start of the continental slope. Sediments on the central and northeastern shelf (including Norton Sound) are not as extensively mapped, and although sand appears dominant, there are concentrations of silt both in shallow nearshore waters and in deep areas near the shelf slope due to the large input of fluvial silt from the Yukon River and northerly current.

In June 2007, the Council adopted precautionary measures to conserve benthic fish habitat in the Bering Sea by “freezing the footprint” of bottom trawling by limiting trawl effort only to those areas more recently trawled. Implemented in 2008, the measures prohibit bottom trawling in a deep slope and basin area (47,000 nm2) and three habitat conservation areas around St. Matthew Island, St. Lawrence Island, and an area encompassing Nunivak Island-Etolin Strait-Kuskokwim Bay. In 2008, the Council also established the Northern Bering Sea Research Area that includes the shelf waters to the north of St. Matthew Island (85,000 nm2) and is closed to bottom trawling (Figure 14).

Figure 14 Closed areas in the BSAI and GOA (from https://www.npfmc.org/habitat-protections/)

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In 2006/2007, the Council requested information from the AFSC on the Pribilof, Pervenets, and Zhemchug canyons for consideration as HAPC designation. The NPFMC postponed taking action at that time, as scientific information was not available to establish the dependence of managed species on habitat features of the canyons, under the EFH mandate. The Council has received proposals to preserve the Pribilof and Zhemchug canyons as candidates for management measures to provide EFH protection for deep-sea corals, sponges, and other benthic habitat important to FMP-managed species.

In 2013, the Council reviewed new information from the Alaska Fisheries Science Center and a discussion paper prepared by Council staff. The Council has adopted a Bering Sea Canyons motion to evaluate further whether and how to protect deep-sea coral in the Pribilof Canyon (http://www.npfmc.org/bering-sea-canyons/). The April 2014 motion acknowledged the need to determine whether and how the NPFMC should recommend amendment of the BSAI Groundfish and Crab FMPs to protect known, significant concentrations of deep-sea corals in the Pribilof Canyon and the adjacent slope from fishing impacts under the appropriate authorities of the Magnuson-Stevens Act. Consistent with the Council’s adopted policy for incorporating the ecosystem approach to fisheries management and the authorities of the Magnuson-Stevens Act, the Council initiated action to investigate where and how to protect coral in these areas.

According to an October 2015 motion, “scientific evidence does not suggest there is a risk to the deep-sea corals present in the Pribilof and Zhemchug canyons and adjacent slope areas under current management. This conclusion is based on both the coral abundance model developed by NMFS and the recent stereo camera survey. The evidence shows low occurrence and density of deep- sea corals, lack of substrate to support corals, and low vulnerability of existing deep-sea corals in these areas to fishery impacts.” This motion was issued following the review of survey data presented in Rooper et al. (2015).

Aleutian Islands

The Aleutian Islands are the tip of a submerged volcanic mountain chain that stretches over 1,600 km forming a partial geographic barrier to the exchange of northern Pacific marine waters with eastern Bering Sea waters. The Aleutian Islands continental shelf is narrow compared with the eastern Bering Sea shelf, ranging in width on the north and south sides of the islands from about 4 km or less to 42 to 46 km; the shelf broadens in the eastern portion of the Aleutian Islands arc. Bathymetry changes dramatically over short distance, from the depths of the Aleutian Trench (greater than 7,000 m deep) to sea level. Unlike the soft bottom sediments of the Bering Sea, bottom habitats are highly complex, with primarily rough, rocky bottom (rock, boulders, and corals) steep slopes and drop-offs, and few areas of fine sediments. Two distinct bottom-type zones are evident. East of Samalga Pass, the Aleutian Islands rise from shallow continental shelf covered by glacial deposits, whereas west of Samalga, steep rocky slopes to the north and south surround a mostly submerged mountain range resting on the Aleutian ridge.

In February 2005, the Council adopted several new closure areas to conserve EFH. To minimize the effects of fishing on EFH and more specifically to address concerns about the impacts of bottom trawling on benthic habitat (particularly on coral communities) in the Aleutian Islands, the Council took action to prohibit all bottom trawling in the Aleutian Islands, except in small discrete “open” areas. Over 95% of the management area is closed to bottom trawling (277,100 nm2). Additionally, six Habitat Conservation Zones with especially high-density coral and sponge habitat were closed to all bottom-contact fishing gear (longlines, pots, trawls). These “coral garden” areas, which total 110 nm2, are essentially marine reserves. To improve monitoring and enforcement of the Aleutian Island closures, a vessel monitoring system is required for all fishing vessels in the Aleutian Islands management area.

Additionally, the Council adopted several new HAPCs. The Alaska Seamount Habitat Protection Area encompasses all 16 seamounts in federal waters off Alaska, named on NOAA charts, of which one occurs in the Aleutian Islands (Bowers). Bottom-contact fishing is prohibited in this HAPC. The Aleutian Islands Coral Habitat Protection Area designates six areas where submersible observations of high-density coral have been made. All bottom-contact gear (longlines, trawls, pots, dinglebar gear, etc.) is prohibited in these areas. Additionally, the relatively unexplored Bowers Ridge is also identified as a HAPC. As a precautionary measure, the Council prohibited mobile fishing gear that contacts the bottom within this 5,286 nm2 area. Refer to Figure 16.

GOA

The GOA seabed includes gravels, silty mud, and muddy to sandy gravel, as well as areas of boulders and hardrock. The shelf, between Cape Cleare (148° W) and Cape Fairweather (138° W), is relatively wide (up to 100 km). The dominant shelf sediment is clay silt that comes primarily from either the Copper River or the Bering and Malaspina glaciers. Sand predominates nearshore. Most of the western GOA shelf (west of Cape Igvak) consists of steep and sharply dissected slopes. The shelf consists of many banks and reefs with numerous coarse rocky bottoms and

68 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019 patchy bottom sediments. Near Kodiak Island the shelf consists of flat relatively shallow banks cut by transverse troughs of bedrock outcrops and coarsely fragmented sediment interspersed with sand bottoms.

In February 2005, bottom trawling for all groundfish species was prohibited in 10 designated areas along the continental shelf of the GOA. The GOA Slope Habitat Conservation Areas, which are thought to contain high relief bottom and coral communities, total 2,086 nm2. Additionally, the Council adopted several new HAPCs. The Alaska Seamount Habitat Protection Area encompasses all 16 seamounts in federal waters off Alaska, named on NOAA charts, 15 of which are in the GOA (Brown, Chirkikof, Marchand, Dall, Denson, Derickson, Dickins, Giacomini, Kodiak, Odessey, Patton, Quinn, Sirius, Unimak, and Welker). Bottom-contact fishing is prohibited in all of these HAPCs, an area which totals 5,329 nm2.

In Southeast Alaska, three sites with large aggregations (“thickets”) of long-lived Primnoa coral are also identified as HAPCs. These sites in the vicinity of Cape Ommaney and Fairweather grounds total 67 nm2. The GOA Coral Habitat Protection Area designates five zones within these sites where submersible observations have been made, totaling 13.5 nm2. All bottom-contact gear (longlines, trawls, pots, dinglebar gear, etc.) is prohibited in this area. Refer to Figure 16.

Habitat recovery

“Various studies (e.g., Collie et al. 2000, Hiddink et al. 2006, Kaiser et al. 2006) show that recovery rates are slowest within stable, muddy or structurally complex habitats when compared to sandy sediment communities that show little change after two to three bottom trawl passes a year. Less abundant, more vulnerable long-lived species are likely to recover more slowly. It can take an organism anywhere from a few months to many decades to recover (Hutchings 2000, Kaiser et al. 2006, Hill et al. 2011)” (MSC in prep).

Cumulative habitat management

The MSC Fisheries Certification Requirements (MSC 2014) require cumulative management of VMEs. That is, these UoAs need to consider what other MSC UoAs as well as non-MSC fisheries have done to protect VMEs. These UoAs need to comply with its management requirements as well as protection measures put in place by other MSC UoAs/non-MSC fisheries. Since the other MSC UoAs and non-MSC fisheries are all under the same management as these UoAs, it is assumed that they are all following the closed area requirements. However, once more information is collected, this topic will be revisited.

7.3.6 Ecosystem8

The NPFMC has been committed to the development and implementation of ecosystem-based management (EBM) for some time. The principles and goals of EBM are described in the BSAI FMP (NPFMC 2014) and the GOA FMP (NPFMC 2015). The NPFMC Ecosystem Committee provides advice to the NPFMC on ecosystem issues in the North Pacific in the light of national ecosystem discussions and suggests new ways for the NPFMC to engage in EBM. The current status and objectives of the NPFMC EBM are described at http://www.npfmc.org/wp- content/PDFdocuments/membership/EcosystemCommittee/EBFMstatus.pdf. The NPFMC has developed an Aleutian Islands Fishery Ecosystem Plan (http://www.npfmc.org/wp- content/PDFdocuments/conservation_issues/AIFEP/AIFEP12_07.pdf). The Plan is a strategic policy and planning document intended to be an educational tool and resource that can provide the NPFMC with both an “early warning system” and an ecosystem context for fishery management decisions affecting the Aleutian Islands area.

The NPFMC has initiated the development of a Bering Sea Fishery Ecosystem Plan (http://www.npfmc.org/bsfep/) to provide a synthesis of ecosystem information relevant to fisheries and help managers consider the ecosystem perspective in fishery decision making. In 2006, the NPFMC signed a Memorandum of Understanding with 10 federal agencies and four state agencies to create the Alaska Marine Ecosystem Forum (AMEF) (http://www.npfmc.org/alaska-marine-ecosystem-forum/). The AMEF seeks to improve coordination and cooperative understanding between the agencies on issues of shared responsibilities related to the marine ecosystems off Alaska’s coast. There is no known plan for a GOA Fishery Ecosystem Plan.

7.3.7 Scoring elements

8 This section has not been updated from the previous Public Certification Report. It will be updated following the site visit when more up-to-date information has been collected.

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UoAs Component Scoring elements Designation Data-deficient BSAI Primary None GOA Primary None BSAI Secondary Northern fulmar Main No

BSAI and GOA ETP Bairdi tanner crab Main No

BSAI and GOA ETP Chinook salmon Main No

BSAI and GOA ETP Golden king crab Main No

BSAI and GOA ETP Herring Main No

BSAI and GOA ETP Non-chinook salmon Main No

BSAI and GOA ETP Opilio tanner crab Main No

BSAI and GOA ETP Pacific halibut Main No

BSAI ETP Red king crab Main No

BSAI ETP Bearded seal (Alaska) Main No Beluga whale (Eastern Chukchi Sea, EBS, Bristol Bay, unknown BSAI ETP stock) Main No Dall’s porpoise BSAI and GOA ETP (Alaska) Main No Fin whale (northeast GOA ETP Pacific) Main No

BSAI ETP Harbor seal (Alaska) Main No Humpback whale BSAI ETP (central North Pacific) Main No Humpback whale BSAI ETP (western North Pacific) Main No Northern elephant seal GOA ETP (North Pacific) Main No Northern fur seal BSAI ETP (eastern Pacific) Main No BSAI ETP Ribbon seal (Alaska) Main No

BSAI ETP Ringed seal (Alaska) Main No

BSAI ETP Spotted seal (Alaska) Main No Steller sea lion BSAI and GOA ETP (western US) Main No

BSAI and GOA ETP Short-tailed albatross Main No

BSAI and GOA ETP Steller’s eider Main No Main (commonly BSAI and GOA Habitat Rocky bottom encountered) No

70 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Main (commonly BSAI and GOA Habitat Muddy bottom encountered) No Main (commonly BSAI and GOA Habitat Sandy bottom encountered) No Main (commonly BSAI and GOA Habitat Gravelly bottom encountered) No

BSAI and GOA Habitat Corals Main (VME) No BSAI Habitat Sea pens and whips Main (VME) No BSAI and GOA Habitat Sponges Main (VME) No

BSAI Ecosystem BSAI Main No GOA Ecosystem GOA Main No

71 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

7.3.8 Principle 2 Performance Indicator scores and rationales

The UoA aims to maintain primary species above the point where recruitment would be PI 2.1.1 impaired (PRI) and does not hinder recovery of primary species if they are below the PRI Scoring Issue SG 60 SG 80 SG 100 Main primary species stock status Main primary species are Main primary species are There is a high degree of likely to be above the PRI. highly likely to be above the certainty that main primary PRI. species are above the PRI OR and are fluctuating around a OR level consistent with MSY. If the species is below the PRI, the UoA has measures If the species is below the a Guide in place that are expected to PRI, there is either evidence post ensure that the UoA does not of recovery or a hinder recovery and demonstrably effective rebuilding. strategy in place between all MSC UoAs which categorise this species as main, to ensure that they collectively do not hinder recovery and rebuilding. Met? All UoAs – Yes All UoAs – Yes All UoAs – Yes

Rationale

All UoAs There are no main primary species in these UoAs. Therefore, SG60, SG80, and SG100 are met.

Minor primary species stock status Minor primary species are highly likely to be above the PRI.

Guide OR b post If below the PRI, there is evidence that the UoA does not hinder the recovery and rebuilding of minor primary species. Met? All UoAs – No

Rationale

Without current information, it is not known whether or not all minor primary species are highly likely to be above PRI; therefore, none of the UoAs meet the SG100.

References

Observer data

72 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80

Information gap indicator Information sufficient to score PI

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

73 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

There is a strategy in place that is designed to maintain or to not hinder rebuilding of PI 2.1.2 primary species, and the UoA regularly reviews and implements measures, as appropriate, to minimise the mortality of unwanted catch Scoring Issue SG 60 SG 80 SG 100

Management strategy in place There are measures in place There is a partial strategy in There is a strategy in place for the UoA, if necessary, that place for the UoA, if for the UoA for managing are expected to maintain or to necessary, that is expected to main and minor primary Guide not hinder rebuilding of the maintain or to not hinder species. a main primary species at/to rebuilding of the main primary post levels which are likely to be species at/to levels which are above the PRI. highly likely to be above the PRI.

Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs There are no main primary species in these UoAs. Therefore, SG60 and SG80 are met. SG100 is not met since the strategy does not consider all primary species.

Management strategy evaluation The measures are considered There is some objective Testing supports high likely to work, based on basis for confidence that the confidence that the partial Guide plausible argument (e.g., measures/partial strategy will strategy/strategy will work, b general experience, theory or work, based on some based on information directly post comparison with similar information directly about the about the fishery and/or fisheries/species). fishery and/or species species involved. involved. Met? All UoAs – Yes All UoAs – Yes All UoAs – Yes

Rationale

All UoAs There are no main primary species in these UoAs. Therefore, SG60, SG80, and SG100 are met.

Management strategy implementation There is some evidence that There is clear evidence that the measures/partial strategy the partial strategy/strategy is is being being Guide implemented implemented c successfully. successfully and is post achieving its overall objective as set out in scoring issue (a). Met? All UoAs – Yes All UoAs – Yes

Rationale

All UoAs There are no main primary species in these UoAs. Therefore, SG60, SG80, and SG100 are met.

74 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Shark finning It is that shark finning is It is that shark There is a Guide likely highly likely high degree of d not taking place. finning is not taking place. certainty that shark finning is post not taking place. Met? All UoAs – Yes All UoAs – Yes All UoAs – Yes

Rationale All UoAs Shark finning in the United States has been prohibited since 2000. “The Shark Finning Prohibition Act of 2000 amended the Magnuson-Stevens Act to prohibit any person under U.S. jurisdiction from engaging in the finning of sharks, possessing shark fins aboard a fishing vessel without the corresponding carcass, and landing shark fins without the corresponding carcass. On January 4, 2011, the Shark Conservation Act of 2010 was signed into law, amending the High Seas Driftnet Fishing Moratorium Protection Act and the Magnuson-Stevens Act. The Shark Conservation Act required that all sharks in the United States, with one exception, be brought to shore with their fins naturally attached.” With regard to these UoAs, sharks are not retained, and none of the vessels have fishmeal plants.

Review of alternative measures There is a review of the There is a regular review of There is a biennial review of potential effectiveness and the potential effectiveness the potential effectiveness practicality of alternative and practicality of alternative and practicality of alternative e Guide measures to minimise UoA- measures to minimise UoA- measures to minimise UoA- post related mortality of unwanted related mortality of unwanted related mortality of unwanted catch of main primary catch of main primary species catch of all primary species, species. and they are implemented as and they are implemented, as appropriate. appropriate. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs The UoAs have reviewed alternative measures to minimize unwanted catch, particularly with regard to seabirds. Not all primary species have been considered on a biennial basis. Therefore, all UoAs meet SG60 and SG80 but not SG100.

References

Observer data

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80

Information gap indicator Information sufficient to score PI

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

75 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Information on the nature and extent of primary species is adequate to determine the PI 2.1.3 risk posed by the UoA and the effectiveness of the strategy to manage primary species

Scoring Issue SG 60 SG 80 SG 100 Information adequacy for assessment of impact on main primary species Qualitative information is Some quantitative information Quantitative information is adequate to estimate the is available and is adequate available and is adequate to impact of the UoA on the to assess the impact of the assess with a high degree main primary species with UoA on the main primary of certainty the impact of the respect to status. species with respect to status. UoA on main primary species with respect to status. Guide OR OR a post If RBF is used to score PI If RBF is used to score PI 2.1.1 for the UoA: 2.1.1 for the UoA: Qualitative information is Some quantitative information adequate to estimate is adequate to assess productivity and susceptibility productivity and susceptibility attributes for main primary attributes for main primary species. species. Met? All UoAs – Yes All UoAs – Yes All UoAs – Yes

Rationale

All UoAs Quantitative information on primary species in the BSAI and GOA pollock fishery from the Observer Program and updated stock assessments are available on an annual basis (NMFS 2014a). Observer coverage is essentially 100% in the BSAI fishery and 21% in the GOA fishery. The catch data show that there are no main primary species in the BSAI and GOA fisheries. Current information on the status of minor primary species is needed before the SG100 can be evaluated.

Information adequacy for assessment of impact on minor primary species Some quantitative information Guide is adequate to estimate the b impact of the UoA on minor post primary species with respect to status. Met? All UoAs – No

Rationale

All UoAs There is not adequate information to know how the UoAs’ impact on the status of all minor primary species. Therefore, more and current information will be needed before the SG100 can be evaluated.

Information adequacy for management strategy Information is adequate to Information is adequate to Information is adequate to c support measures to manage support a partial strategy to support a strategy to manage

Guide main primary species. manage main primary all primary species, and species. evaluate with a high degree post of certainty whether the strategy is achieving its objective.

76 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs There are no primary main species in either the BSAI or the GOA pollock fisheries. Therefore, the information is adequate to support the strategy, meeting SG80. The strategy does not consider all minor primary species so SG100 cannot be evaluated without additional information.

References

Observer data

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80

Information gap indicator Information sufficient to score PI

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

77 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

The UoA aims to maintain secondary species above a biologically based limit and does PI 2.2.1 not hinder recovery of secondary species if they are below a biological based limit Scoring Issue SG 60 SG 80 SG 100 Main secondary species stock status Main secondary species are Main secondary species are There is a high degree of likely to be above biologically highly likely to be above certainty that main based limits. biologically based limits. secondary species are above biologically based limits. OR OR

If below biologically based If below biologically based limits, there are measures in limits, there is either place expected to ensure that evidence of recovery or a the UoA does not hinder demonstrably effective recovery and rebuilding. partial strategy in place such that the UoA does not hinder a Guide recovery and rebuilding. post AND Where catches of a main secondary species outside of biological limits are considerable, there is either evidence of recovery or a, demonstrably effective strategy in place between those MSC UoAs that have considerable catches of the species, to ensure that they collectively do not hinder recovery and rebuilding. BSAI UoAs – Yes BSAI UoAs – No BSAI UoAs – No Met? GOA UoAs – Yes GOA UoAs – Yes GOA UoAs – Yes Rationale

BSAI The UoA has one known main secondary species – northern fulmar. The UoAs’ impact is low relative to the species population. This quantitative information is available and adequate to assess the UoAs’ impact with a high degree of certainty. Therefore, SG100 is met for northern fulmar. In addition to fulmars, there are three species of shearwaters that range throughout the North Pacific – Pink-footed, Sooty, and Short-tailed. According to information from the IUCN, although Sooty shearwaters are thought to be declining globally, numbers in North America are increasing and the global population is perhaps over 20 million individuals. Pink-footed shearwaters are listed as Vulnerable by the IUCN with numbers in the range of 150,000 individuals, but the population trend in unknown. Short-tailed shearwaters are thought to be increasing with numbers likely to exceed 23 million individuals. Given the low bycatch of these species in the UoAs, it is high degree of certainty that shearwaters are above biologically based limits and thus the SG100 is met. For gulls more specific catch data are needed to determine which species are impacted, each species’ rate of impact, and whether or not any of these species are ETP instead of secondary. Overall, the catch numbers are relatively low so, if they are secondary species, at least SG60 is met. Again, more information is needed to know if SG80 or SG100 is met. The overall SI score for these UoAs is 60.

GOA The UoAs has no main secondary species. Therefore, SG100 is met.

Minor secondary species stock status b Guide Minor secondary species are post highly likely to be above 78 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

biologically based limits.

OR

If below biologically based limits’, there is evidence that the UoA does not hinder the recovery and rebuilding of secondary species Met? All UoAs – No

Rationale

All UoAs It is not known whether or not all minor secondary species are highly likely to be above biologically based limits; therefore, none of the UoAs meet the SG100.

References

Observer data

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range 60-79

Information gap indicator More information sought

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

79 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

There is a strategy in place for managing secondary species that is designed to maintain PI 2.2.2 or to not hinder rebuilding of secondary species and the UoA regularly reviews and implements measures, as appropriate, to minimise the mortality of unwanted catch Scoring Issue SG 60 SG 80 SG 100 Management strategy in place There are measures in place, There is a partial strategy in There is a strategy in place if necessary, which are place, if necessary, for the for the UoA for managing expected to maintain or not UoA that is expected to main and minor secondary hinder rebuilding of main maintain or not hinder species. a Guide secondary species at/to levels rebuilding of main secondary post which are highly likely to be species at/to levels which are above biologically based highly likely to be above limits or to ensure that the biologically based limits or to UoA does not hinder their ensure that the UoA does not recovery. hinder their recovery. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs There are regulations and measures to reduce and/or avoid seabird bycatch. The regulations cover recordkeeping and reporting requirements, gear limitation, and specifications of seabird-avoidance gear for vessels based on the season, gear, and the type of gear used. Requirements of vessels to report seabirds incidentally taken to the Observer Program are also outlined in the regulations. These regulations and measures can be considered a partial strategy at least. NOAA has in place several seabird management measures that are relevant to these species as well as northern fulmar so SG60 and SG80 are met. The strategy does not consider minor species so SG100 is not met.

Management strategy evaluation The measures are considered There is some objective Testing supports high likely to work, based on basis for confidence that the confidence that the partial b Guide plausible argument (e.g. measures/partial strategy will strategy/strategy will work, post general experience, theory or work, based on some based on information directly comparison with similar information directly about the about the UoA and/or species UoAs/species). UoA and/or species involved. involved. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs The recent seabird bycatch estimates for these UoAs show a continued low rate of bycatch. Therefore, it can be concluded that the measures are likely to work. SG60 and SG80 are met, but more information is needed to know if SG100 is met.

Management strategy implementation There is some evidence that There is clear evidence that the measures/partial strategy the partial strategy/strategy is c Guide is being implemented being implemented post successfully. successfully and is achieving its objective as set out in scoring issue (a). Met? All UoAs – Yes All UoAs – No

80 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Rationale

All UoAs The recent seabird bycatch estimates for these UoAs show a continued low rate of bycatch. Therefore, it can be concluded that the measures are likely to work. SG60 and SG80 are met, but more information is needed to know if SG100 is met.

Shark finning

Guide It is likely that shark finning is It is highly likely that shark There is a high degree of d not taking place. finning is not taking place. certainty that shark finning is post not taking place. Met? NA NA NA

Rationale

There are no secondary shark species in these UoAs; therefore, this SI is not scored. Review of alternative measures to minimise mortality of unwanted catch There is a review of the There is a regular review of There is a biennial review of potential effectiveness and the potential effectiveness the potential effectiveness practicality of alternative and practicality of alternative and practicality of alternative e Guide measures to minimise UoA- measures to minimise UoA- measures to minimise UoA- post related mortality of unwanted related mortality of unwanted related mortality of unwanted catch of main secondary catch of main secondary catch of all secondary species. species and they are species, and they are implemented as appropriate. implemented, as appropriate. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs The UoAs have reviewed alternative measures to minimize unwanted catch, but not all secondary species have been considered on a biennial basis. NOAA regularly review mitigation measures with regard to seabird bycatch. Therefore, all UoAs meet SG60 and SG80 but not SG100.

References

Observer data

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80

Information gap indicator More information sought to score SG100

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

81 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Information on the nature and amount of secondary species taken is adequate to PI 2.2.3 determine the risk posed by the UoA and the effectiveness of the strategy to manage secondary species Scoring Issue SG 60 SG 80 SG 100 Information adequacy for assessment of impacts on main secondary species Qualitative information is Some quantitative information Quantitative information is adequate to estimate the is available and adequate to available and adequate to impact of the UoA on the assess the impact of the UoA assess with a high degree main secondary species with on main secondary species of certainty the impact of the respect to status. with respect to status. UoA on main secondary species with respect to status. OR OR a Guide post If RBF is used to score PI If RBF is used to score PI 2.2.1 for the UoA: 2.2.1 for the UoA:

Qualitative information is Some quantitative information adequate to estimate is adequate to assess productivity and susceptibility productivity and susceptibility attributes for main secondary attributes for main secondary species. species. Met? All UoAs – Yes All UoAs – Yes All UoAs – Yes

Rationale

BSAI Adequate information is available to support the measures that are in place since the UoA’s catch of these species is relatively low. Changes in the Observer program and the development of better methods of estimating population level bycatch from observer data combined with annual updates indicate that information is adequate to support a strategy to manage all secondary species with a high degree of certainly. Therefore, the SG100 is met.

GOA The UoA has no main secondary species so SG100 is met.

Information adequacy for assessment of impacts on minor secondary species Some quantitative information Guide is adequate to estimate the b impact of the UoA on minor post secondary species with respect to status. Met? All UoAs – No

Rationale

All UoAs While the UoAs’ impact on all secondary species is known (i.e., the catch data lists all species caught and the number/weight of each), there is not adequate information to know the UoAs’ impact on the status of all secondary species. Therefore, SG100 is not met.

Information adequacy for management strategy c Information is adequate to Information is adequate to Information is adequate to Guide support measures to manage support a partial strategy to support a strategy to manage post main secondary species. manage main secondary all secondary species, and species. evaluate with a high degree 82 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

of certainty whether the strategy is achieving its objective. Met? All UoAs – Yes All UoAs – Yes All UoAs – Yes

Rationale

BSAI Adequate information is available to support the measures that are in place since the UoAs’ catch of these species is relatively low. Changes in the Observer program and the development of better methods of estimating population level bycatch from observer data combined with annual updates indicate that information is adequate to support a strategy to manage all secondary species with a high degree of certainly. Therefore, the SG100 is met.

GOA The UoA’s impact and the species’ status are known. Therefore, the UoA has no main secondary species so SG100 is met. Insert sufficient rationale to support the team’s conclusion for each Scoring Guidepost (SG).

References

Observer data

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80

Information gap indicator More information sought to score SG100

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

83 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

The UoA meets national and international requirements for the protection of ETP species PI 2.3.1 The UoA does not hinder recovery of ETP species Scoring Issue SG 60 SG 80 SG 100 Effects of the UoA on population/stock within national or international limits, where applicable Where national and/or Where national and/or Where national and/or international requirements set international requirements set international requirements set a Guide limits for ETP species, the limits for ETP species, the limits for ETP species, there effects of the UoA on the combined effects of the is a high degree of certainty post population/ stock are known MSC UoAs on the population that the combined effects of and likely to be within these /stock are known and highly the MSC UoAs are within limits. likely to be within these limits. these limits. Met? All UoAs – Yes All UoAs – No All UoAs – No

Rationale

All UoAs Marine mammals All marine mammals have set limits (i.e., PBRs). The UoAs are well below each of the marine mammals’ PBRs. These species all have extensive ranges – some the entire North Pacific and others even larger. Therefore, most of these species have been divided into smaller stocks or populations for management purposes because of their large ranges. Given this, it is impractical to quantify whether all MSC-related mortality is within a fishery-specific PBR limit since it is not a population-wide limit. These facts plus the fact that the UoAs have extremely low rates of interaction with each of the marine mammals mean that it can be said that it is highly likely that all MSC UoAs are cumulatively within these limits. Therefore, the marine mammal scoring element meets SG60 and SG80. SG100 is not met since it cannot be said with a high degree of certainly that the MSC UoAs are collectively within limits without addition and current information.

Fish and crustaceans PSC limits are in place for these species; however, at the time of this report, these limits were not known by the assessment team. Based on the last surveillance report, there are unlikely to be any substantive issues. Therefore, SG60 is met. SG80 and SG100 cannot be assessed without additional and current information.

Seabirds The Biological Opinion for the Short-tailed albatross (USFWS 2003) allows for an incidental take of four birds in each 2-year period for the demersal longline fishery. This take is based on numbers of birds observed rather than the estimate of total take derived from the observed take. Evidence indicates that both UoAs are within current limits. Thus, SG100 is met. Steller’s eider has been taken in the UoAs since the beginning of the time series in 2007.

Direct effects Known direct effects of the Direct effects of the UoA are There is a high degree of Guide UoA are likely to not hinder highly likely to not hinder confidence that there are no b recovery of ETP species. recovery of ETP species. significant detrimental post direct effects of the UoA on ETP species. Met? All UoAs – Yes All UoAs – No All UoAs – No

Rationale

All UoAs Marine mammals Most marine mammal populations do not have long-term trend data. Catch data and observer coverage show that the UoAs had little or no fatal interactions with marine mammals. When there has been an interaction, the UoA has been well below the PBR for that species. Given the extremely low rates of interaction and the fact that population

84 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019 decreases have not been the result of the UoAs in the past, there is a high degree of confidence that there are no significant detrimental direct effects of the UoAs on these species, meeting SG60, SG80, and SG100.

Fish and crustaceans PSC limits are in place for these species; however, at the time of this report, these limits were not known by the assessment team. Based on the last surveillance report, there are unlikely to be any substantive issues. Therefore, SG60 is met. SG80 and SG100 cannot be assessed without additional and current information.

Seabirds Overall, trawl gear is known to have a direct effect on seabirds with regard to entanglement. Kittiwake and Laysan albatross are known ETP species for these UoAs. The catch numbers for these UoAs are relatively low relative to estimated population size so the SG60 and SG80 are met.

Indirect effects Indirect effects have been There is a high degree of Guide considered for the UoA and confidence that there are no c are thought to be highly significant detrimental post likely to not create indirect effects of the UoA unacceptable impacts. on ETP species.

Met? All UoAs – No All UoAs – No

Rationale

All UoAs More and current information are needed to score this SI adequately. Therefore, neither SG80 nor SG100 are met at this time.

References

Observer data, https://www.fisheries.noaa.gov/national/marine-mammal-protection/list-fisheries-summary-tables, https://www.afsc.noaa.gov/publications/AFSC-TM/NOAA-TM-AFSC-354.pdf, https://www.fisheries.noaa.gov/find- species, https://ecos.fws.gov/ecp0/profile/speciesProfile?spcode=A0FS, https://www.iucnredlist.org/species/22694497/132556442, https://www.iucnredlist.org/species/22694502/132557429, https://www.iucnredlist.org/species/3590/45224953, https://www.iucnredlist.org/species/15106/45228501, https://acap.aq/en/acap-species/307-acap-species-list/file, https://www.fisheries.noaa.gov/national/marine-mammal- protection/marine-mammal-stock-assessment-reports-species-stock

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range 60-79

Information gap indicator More information sought

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

85 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

The UoA has in place precautionary management strategies designed to: - meet national and international requirements; - ensure the UoA does not hinder recovery of ETP species. PI 2.3.2 Also, the UoA regularly reviews and implements measures, as appropriate, to minimise the mortality of ETP species

Scoring Issue SG 60 SG 80 SG 100 Management strategy in place (national and international requirements) There are measures in place There is a strategy in place There is a comprehensive that minimise the UoA-related for managing the UoA’s strategy in place for mortality of ETP species, and impact on ETP species, managing the UoA’s impact Guide are expected to be highly including measures to on ETP species, including a likely to achieve national and minimise mortality, which is measures to minimise post international requirements for designed to be highly likely mortality, which is designed to the protection of ETP species. to achieve national and achieve above national and international requirements for international requirements for the protection of ETP species. the protection of ETP species. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs There is a strategy in place to manage the UoAs’ impacts on ETP species. This strategy is designed to minimize ETP species mortality by the UoAs and is highly likely to achieve national and international requirements and to ensure the UoAs does not hinder recovery. The FMP outlines how it manages interactions with ETP species and works to limit such interactions, including measures that have established conservation zones and have implemented gear restrictions and time/area closures to reduce bycatch of ETP species. The BSAI and GOA FMPs also states that the UoAs shall follow the numerous requirements laid out by the ESA and MMPA. Therefore, SG60 and SG80 are met. While there arguably is a comprehensive strategy in place, it is not designed to achieve above national and international requirements so SG100 is not met.

Management strategy in place (alternative) There are measures in place There is a strategy in place There is a comprehensive that are expected to ensure that is expected to ensure the strategy in place for b Guide the UoA does not hinder the UoA does not hinder the managing ETP species, to post recovery of ETP species. recovery of ETP species. ensure the UoA does not hinder the recovery of ETP species. Met? NA NA NA

Rationale

Not applicable since there are national and international requirements in place for most ETP species. Therefore, all ETP species are assessed under SI a since either SI a or b is scored.

Management strategy evaluation The measures are There is an objective basis The strategy/comprehensive considered likely to work, for confidence that the strategy is mainly based on c based on Guide plausible measures/strategy will work, information directly about the argument (e.g., general based on information directly fishery and/or species post experience, theory or about the fishery and/or the involved, and a quantitative comparison with similar species involved. analysis supports high fisheries/species). confidence that the strategy 86 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

will work.

Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs There is an objective basis for confidence that the strategy will work. The UoAs have had little or no bycatch of the ETP species, showing that the strategy has worked and will likely continue to work. Further, the strategy is based on information directly about the fishery and the ETP species involved. Measures, such as gear modifications and area closures, are done with the UoAs and species in mind to ensure intended bycatch minimization and/or recovery goals are met. Therefore, SG60 and SG80 are met. SG100 is not met since a quantitative analysis has not been done to support the confidence level.

Management strategy implementation There is some evidence that There is clear evidence that the measures/strategy is the strategy/comprehensive d Guide being implemented strategy is being implemented post successfully. successfully and is achieving its objective as set out in scoring issue (a) or (b). Met? All UoAs – Yes All UoAs – Yes

Rationale

All UoAs Overall, the UoAs continue to have minimal interaction with ETP species. Therefore, there is some evidence (instead of clear evidence) that the strategy is being implemented successfully. SG80 is met. There is also a long-term decline the species and numbers in the bycatch of the pollock trawl fishery providing clear evidence the strategy be being implemented and is achieving objectives as set out. SG100 is met.

Review of alternative measures to minimize mortality of ETP species There is a review of the There is a regular review of There is a biennial review of potential effectiveness and the potential effectiveness the potential effectiveness Guide practicality of alternative and practicality of alternative and practicality of alternative e measures to minimise UoA- measures to minimise UoA- measures to minimise UoA- post related mortality of ETP related mortality of ETP related mortality ETP species, species. species and they are and they are implemented, as implemented as appropriate. appropriate. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs The NPFMC has regular meetings when they discuss management measures; therefore, SG60 and SG80 are met. SG100 is not met since the regularity of the meetings and the review process cannot be confirmed.

References

Observer data, https://www.fisheries.noaa.gov/national/marine-mammal-protection/list-fisheries-summary-tables, https://www.afsc.noaa.gov/publications/AFSC-TM/NOAA-TM-AFSC-354.pdf, https://www.fisheries.noaa.gov/find- species, https://ecos.fws.gov/ecp0/profile/speciesProfile?spcode=A0FS, https://www.iucnredlist.org/species/22694497/132556442, https://www.iucnredlist.org/species/22694502/132557429, https://www.iucnredlist.org/species/3590/45224953, https://www.iucnredlist.org/species/15106/45228501, https://acap.aq/en/acap-species/307-acap-species-list/file, https://www.fisheries.noaa.gov/national/marine-mammal- protection/marine-mammal-stock-assessment-reports-species-stock 87 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80 Information sufficient to score PI but additional Information gap indicator information could increase score

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

88 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Relevant information is collected to support the management of UoA impacts on ETP species, including: PI 2.3.3 - Information for the development of the management strategy; - Information to assess the effectiveness of the management strategy; and - Information to determine the outcome status of ETP species Scoring Issue SG 60 SG 80 SG 100 Information adequacy for assessment of impacts Qualitative information is Some quantitative information Quantitative information is adequate to estimate the is adequate to assess the available to assess with a UoA related mortality on ETP UoA related mortality and high degree of certainty the species. impact and to determine magnitude of UoA-related whether the UoA may be a impacts, mortalities and OR threat to protection and injuries and the recovery of the ETP species. consequences for the of ETP species. Guide If RBF is used to score PI status a 2.3.1 for the UoA: OR post Qualitative information is adequate to estimate If RBF is used to score PI productivity and 2.3.1 for the UoA: susceptibility attributes for Some quantitative information ETP species. is adequate to assess productivity and susceptibility attributes for ETP species. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs The catch data show that the UoAs’ impacts on these species are relatively low. The UoAs’ impact on the known ETP species is also relatively low. Therefore, it can be concluded that the UoAs meet the SG60 and SG80. SG100 is not met since more and current quantitative information is needed to confirm the species and the magnitude of impact.

Information adequacy for management strategy Information is adequate to Information is adequate to Information is adequate to support measures to measure trends and support support a comprehensive manage the impacts on ETP a strategy to manage strategy to manage impacts, b Guide species. impacts on ETP species. minimize mortality and injury post of ETP species, and evaluate with a high degree of certainty whether a strategy is achieving its objectives. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs With annual data collection and analysis and a high level of observer coverage for all relevant ETP species, it can be concluded that the information is adequate to measure the UoAs’ catch trends and support the strategy for managing the UoAs’ impacts. Therefore, SG60 and SG80 are met. Further evaluation is needed to determine if there is a comprehensive strategy to support the SG100 level.

References

89 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Observer data, https://www.fisheries.noaa.gov/national/marine-mammal-protection/list-fisheries-summary-tables, https://www.afsc.noaa.gov/publications/AFSC-TM/NOAA-TM-AFSC-354.pdf, https://www.fisheries.noaa.gov/find- species, https://ecos.fws.gov/ecp0/profile/speciesProfile?spcode=A0FS, https://www.iucnredlist.org/species/22694497/132556442, https://www.iucnredlist.org/species/22694502/132557429, https://www.iucnredlist.org/species/3590/45224953, https://www.iucnredlist.org/species/15106/45228501, https://acap.aq/en/acap-species/307-acap-species-list/file, https://www.fisheries.noaa.gov/national/marine-mammal- protection/marine-mammal-stock-assessment-reports-species-stock

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80 Information sufficient to score PI but Information gap indicator additional information could increase score

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

90 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

The UoA does not cause serious or irreversible harm to habitat structure and function, PI 2.4.1 considered on the basis of the area covered by the governance body(s) responsible for fisheries management in the area(s) where the UoA operates

Scoring Issue SG 60 SG 80 SG 100 Commonly encountered habitat status The UoA is unlikely to The UoA is highly unlikely There is evidence that the reduce structure and function to reduce structure and UoA is highly unlikely to Guide of the commonly encountered function of the commonly reduce structure and function a habitats to a point where encountered habitats to a of the commonly encountered post there would be serious or point where there would be habitats to a point where irreversible harm. serious or irreversible harm. there would be serious or irreversible harm. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs Based on available information, it appears that the commonly encountered habitats would include mud, sand, gravel sediments, and rock. Several studies show stable, muddy or structurally complex habitats recover more slowly than sandy sediment. However, the commonly encountered habitats in this area all recover within 5-20 years. Therefore, it is highly unlikely that serious or irreversible harm is occurring. SG60 and SG80 are met. SG100 is not met since there is not clear evidence available at this time.

VME habitat status The UoA is unlikely to The UoA is highly unlikely There is evidence that the reduce structure and function to reduce structure and UoA is highly unlikely to b Guide of the VME habitats to a point function of the VME habitats reduce structure and function post where there would be serious to a point where there would of the VME habitats to a point or irreversible harm. be serious or irreversible where there would be serious harm. or irreversible harm. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs The VME habitats in this area appear to be HAPCs that are monitored (but not closed) due to high skate egg concentration and may also include corals, sponges, and sea pens/whips (as per catch data). The VME habitats are closed to trawling so it is highly unlikely that serious or irreversible harm is occurring. Therefore, it is highly unlikely that serious or irreversible harm is occurring. SG60 and SG80 are met. SG100 is not met since there is not clear evidence available at this time.

Minor habitat status There is evidence that the UoA is highly unlikely to c Guide reduce structure and function post of the minor habitats to a point where there would be serious or irreversible harm.

Met? All UoAs – No

Rationale

91 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

There is not sufficient evidence with regard to minor habitats so none of the UoAs meet SG100.

References

Observer data

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80 Information sufficient to score PI but Information gap indicator additional information could increase score

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

92 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

There is a strategy in place that is designed to ensure the UoA does not pose a risk of PI 2.4.2 serious or irreversible harm to the habitats

Scoring Issue SG 60 SG 80 SG 100 Management strategy in place There are measures in There is a partial strategy in There is a strategy in place for Guide place, if necessary, that are place, if necessary, that is managing the impact of all a expected to achieve the expected to achieve the MSC UoAs/non-MSC fisheries post Habitat Outcome 80 level of Habitat Outcome 80 level of on habitats. performance. performance or above. Met? All UoAs – Yes All UoAs – Yes All UoAs – Yes

Rationale

All UoAs As required under the MSA (2007) the Council adopted an environmental impact statement (EIS) for essential fishery habitat (EFH) in 2005, updated the EIS in 2010, and again in 2015. The EFH identifies and designates EFH, determines sensitive areas as habitat areas of particular concern (HAPC), and evaluates fishing impacts and determines measures to minimize, to the extent practicable, adverse impacts of fishing on habitat. The NMFS and the NPFMC together have instituted measures and have adopted a strategy to protect sensitive habitat (BSAI FMP, GOA FMP, NPFMC 2014, Table ES-2). Elements of this strategy include the determination of EFH for pollock, estimates of the impact of pollock trawling on benthic organisms in various habitats, including canyons, and the identification of HAPC to protect corals and seamounts. These habitat areas are closed to bottom contact. There are also closed areas/seasons to trawling and bottom contact gear to protect marine mammals, herring, salmon, halibut, and crab species. The Northern Bering Sea Research Area was implemented in 2008 and prohibited bottom trawling in the northern part of the Bering Sea. These ongoing measures provide evidence that the strategy is being implemented (http://www.npfmc.org/habitat-protections/). When new habitat issues arise, such as with the Bering Sea canyons, the Council strategy requires evaluating available information and requiring new scientific inquiry as necessary. The Council’s 2013 discussion paper on canyons (NPFMC 2013) showed that little of the BSAI pollock fishery takes place in the canyons being considered for protection as sensitive habitat, which demonstrates low risk of adverse impacts while research continues. In the GOA, there are also closed areas/seasons to trawling and bottom contact gear, such as the Sitka Pinnacles Marine Reserve and Slope Habitat Conservation Areas, to protect marine mammals, herring, salmon, halibut, and crab species. Therefore, the strategy is being implemented (http://www.npfmc.org/habitat- protections/). The SG60, SG80 and SG100 levels are met.

Management strategy evaluation The measures are There is some objective Testing supports high considered likely to work, basis for confidence that confidence that the partial Guide based on plausible argument the measures/partial strategy strategy/strategy will work, b (e.g. general experience, will work, based on based on information directly post theory or comparison with information directly about about the UoA and/or similar UoAs/habitats). the UoA and/or habitats habitats involved. involved. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs Research and management actions demonstrate that identifying sensitive areas and implementing measures to protect them will succeed. The measures implemented to protect sensitive habitat are likely to work and there is an objective basis for confidence that the Councils strategy will work. The measures implemented to protect sensitive habitats (e.g., closed areas for seamounts and corals; gear restrictions to minimize impacts; and research to improve knowledge) are likely to work and there is an objective basis for confidence that the Councils strategy will work. Closed area/season management of fishing impacts is widely practiced in other parts of the world and there is a long

93 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019 history of experience of such measures from the Alaska pollock fishery in the GOA. VMS (Loefflad et al. 2014) and Observer data provide a basis for testing that the strategy is working. SG60, SG80 and SG100 are met.

Management strategy implementation There is some quantitative There is clear quantitative evidence that the evidence that the partial c Guide measures/partial strategy is strategy/strategy is being post being implemented implemented successfully and successfully. is achieving its objective, as outlined in scoring issue (a). Met? All UoAs – Yes All UoAs – No

Rationale

All UoAs VMS and observer data provide at least some quantitative evidence that the partial strategy is being implemented successfully. SG80 is met. More information is needed to determine whether or not there is clear quantitative evidence (SG100).

Compliance with management requirements and other MSC UoAs’/non-MSC fisheries’ measures to protect VMEs There is qualitative There is some quantitative There is clear quantitative d evidence that the UoA evidence that the UoA evidence that the UoA complies with its complies with both its complies with both its

Guide management requirements to management requirements management requirements and

post protect VMEs. and with protection measures with protection measures afforded to VMEs by other afforded to VMEs by other MSC UoAs/non-MSC MSC UoAs/non-MSC fisheries, fisheries, where relevant. where relevant. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs Since the other MSC UoAs and non-MSC fisheries are all under the same management as these UoAs, there is at least some quantitative evidence that they are all following the closed area requirements. SG60 and SG80 are met. More information is needed to determine whether or not there is clear quantitative evidence (SG100).

References

BSAI FMP, GOA FMP, NPFMC 2014, http://www.npfmc.org/habitat-protections/, Loefflad et al. 2014

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80 Information sufficient to score PI but additional Information gap indicator information could increase score

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

94 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Information is adequate to determine the risk posed to the habitat by the UoA and the PI 2.4.3 effectiveness of the strategy to manage impacts on the habitat

Scoring Issue SG 60 SG 80 SG 100 Information quality The types and distribution of The nature, distribution and The distribution of all habitats the main habitats are broadly vulnerability of the main is known over their range, understood. habitats in the UoA area are with particular attention to the known at a level of detail occurrence of vulnerable OR relevant to the scale and habitats. intensity of the UoA. If CSA is used to score PI a Guide 2.4.1 for the UoA: OR post Qualitative information is adequate to estimate the If CSA is used to score PI types and distribution of the 2.4.1 for the UoA: main habitats. Some quantitative information is available and is adequate to estimate the types and distribution of the main habitats. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs A comprehensive inventory of bottom habitat data in the BSAI and GOA has been done. The types, distributions, and vulnerability of the main habitats in the BSAI and GOA are known at the scale relevant to the UoAs as described in the EFH report. Habitats in the AI are less well understood, but there is a basic understanding of the main types and general distributions and their vulnerabilities, again at a scale relevant to the UoAs. Therefore, SG60 and SG80 are met. SG100 is not met since the distribution of all habitats is not known over their range.

Information adequacy for assessment of impacts Information is adequate to Information is adequate to The physical impacts of the broadly understand the allow for identification of the gear on all habitats have nature of the main impacts of main impacts of the UoA on been quantified fully. gear use on the main the main habitats, and there habitats, including spatial is reliable information on the overlap of habitat with fishing spatial extent of interaction gear. and on the timing and location of use of the fishing Guide OR gear. b post If CSA is used to score PI OR 2.4.1 for the UoA: Qualitative information is If CSA is used to score PI adequate to estimate the 2.4.1 for the UoA: consequence and spatial Some quantitative information attributes of the main is available and is adequate habitats. to estimate the consequence and spatial attributes of the main habitats. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

95 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

All UoAs The EFH report and 5-year review of EFH provided information that is adequate to allow for identification of the main impacts of gear use of the UoAs on the main habitats in the BSAI and GOA. Model estimates of long-term bottom habitat impacts of trawl gear used in the UoAs provide sufficient data to allow the nature of impact and their spatial extent to be generally determined. Therefore, SG60 and SG80 are met. SG100 is not met since the physical impacts on all habitats have not been quantified fully.

Monitoring Adequate information Changes in all habitat c Guide continues to be collected to distributions over time are post detect any increase in risk to measured. the main habitats. Met? All UoAs – Yes All UoAs – No

Rationale

All UoAs Adequate information by means of VMS and the observer program continue to be collected from the UoAs to detect any change in the distribution of the fishery and, therefore, in risk to the habitat. VMS provides high-resolution information on the spatial extent of the fishery, whereas the observer program collects detailed information on the nature and composition of the bycatch from the UoAs which could signal changes in habitat impacts. SG80 and SG100 are met.

References

Observer data

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80 Information sufficient to score PI but Information gap indicator additional information could increase score

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

96 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

The UoA does not cause serious or irreversible harm to the key elements of ecosystem PI 2.5.1 structure and function

Scoring Issue SG 60 SG 80 SG 100 Ecosystem status The UoA is unlikely to The UoA is highly unlikely to There is evidence that the disrupt the key elements disrupt the key elements UoA is highly unlikely to Guide underlying ecosystem underlying ecosystem disrupt the key elements a structure and function to a structure and function to a underlying ecosystem post point where there would be a point where there would be a structure and function to a serious or irreversible harm. serious or irreversible harm. point where there would be a serious or irreversible harm. Met? All UoAs – Yes All UoAs – Yes All UoAs – Yes

Rationale

All UoAs Based on the nature and amounts of primary and secondary species, the limited interactions with ETP species, and ecosystem analyses, the UoAs are highly unlikely to disrupt the key elements underlying ecosystem structure and function to a point where there would be a serious or irreversible harm. Pollock is a key component of the BS and AI ecosystems. The long-term sustainable record of managing the fishery above the target reference point provides some evidence that the fishery is unlikely to disrupt key elements of the ecosystem. The SG60, SG80, and SG100 levels are met.

References

Aydin et al. 2007, Gaichas and Francis 2008, Gaichas et al. 2011, Gaichas et al. 2012

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80 Information sufficient to score PI but Information gap indicator additional information could increase score

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

97 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

There are measures in place to ensure the UoA does not pose a risk of serious or PI 2.5.2 irreversible harm to ecosystem structure and function

Scoring Issue SG 60 SG 80 SG 100 Management strategy in place There are measures in place, There is a partial strategy in There is a strategy that if necessary which take into place, if necessary, which consists of a plan, in place account the potential takes into account available which contains measures to a Guide impacts of the UoA on key information and is expected address all main impacts of elements of the ecosystem. to restrain impacts of the the UoA on the ecosystem, post UoA on the ecosystem so as and at least some of these to achieve the Ecosystem measures are in place. Outcome 80 level of performance. Met? All UoAs – Yes All UoAs – Yes All UoAs – Yes

Rationale

All UoAs The NPFMC has been committed to the development and implementation of ecosystem-based management (EBM) for some time. The principles and goals of EBM are described in the BSAI FMP and the GOA FMP. The NPFMC Ecosystem Committee provides advice to the NPFMC on ecosystem issues in the North Pacific in the light of national ecosystem discussions and suggests new ways for the NPFMC to engage in EBM. The current status and objectives of the NPFMC EBM are described online. The NPFMC has developed an Aleutian Islands Fishery Ecosystem Plan. The Plan is a strategic policy and planning document intended to be an educational tool and resource that can provide the NPFMC with both an “early warning system” and an ecosystem context for fishery management decisions affecting the Aleutian Islands area. The NPFMC has initiated the development of a Bering Sea Fishery Ecosystem Plan to provide a synthesis of ecosystem information relevant to fisheries and help managers consider the ecosystem perspective in fishery decision making. In 2006, the NPFMC signed a Memorandum of Understanding with 10 federal agencies and four state agencies to create the Alaska Marine Ecosystem Forum (AMEF). The AMEF seeks to improve coordination and cooperative understanding between the agencies on issues of shared responsibilities related to the marine ecosystems off Alaska’s coast. (There is no known plan for a GOA Fishery Ecosystem Plan.) Given all of this, it can be said that there is strategy in place that consists of plans for both BSAI and GOA that address the main UoA impacts on the ecosystem. SG60, SG80, and SG100 are met.

Management strategy evaluation The measures are There is some objective Testing supports high considered likely to work, basis for confidence that confidence that the partial Guide based on plausible argument the measures/ partial strategy strategy/ strategy will work, b (e.g., general experience, will work, based on some based on information directly post theory or comparison with information directly about the about the UoA and/or similar UoAs/ ecosystems). UoA and/or the ecosystem ecosystem involved. involved. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs There is also some objective basis for confidence that the strategy is working and being implemented successfully since annual or periodic stock assessment reports and analysis of data from the UoAs are collected by the observer program on the amount and composition of primary and secondary species and interactions with ETP species. SG60 and SG80 are met. More and current information is needed to determine whether or not there is testing to support high confidence (SG100).

98 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Management strategy implementation There is some evidence that There is clear evidence that the measures/partial strategy the partial strategy/strategy is c Guide is being implemented being implemented post successfully. successfully and is achieving its objective as set out in scoring issue (a). Met? All UoAs – Yes All UoAs – No

Rationale

All UoAs VMS and observer data provide at least some quantitative evidence that the partial strategy is being implemented successfully. SG80 is met. More and current information is needed to determine whether or not there is clear quantitative evidence (SG100).

References https://www.npfmc.org/wp-content/PDFdocuments/fmp/BSAI/BSAIfmp.pdf, https://www.npfmc.org/wp- content/PDFdocuments/fmp/GOA/GOAfmp.pdf, https://www.npfmc.org/wp- content/PDFdocuments/membership/EcosystemCommittee/EBFMstatus.pdf, http://www.npfmc.org/wp- content/PDFdocuments/conservation_issues/AIFEP/AIFEP12_07.pdf, https://www.npfmc.org/bsfep/, https://www.npfmc.org/alaska-marine-ecosystem-forum/

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80 Information sufficient to score PI but Information gap indicator additional information could increase score

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

99 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

PI 2.5.3 There is adequate knowledge of the impacts of the UoA on the ecosystem Scoring Issue SG 60 SG 80 SG 100 Information quality

Guide Information is adequate to Information is adequate to a identify the key elements of broadly understand the key post the ecosystem. elements of the ecosystem.

Met? All UoAs – Yes All UoAs – Yes

Rationale

All UoAs Information in BSAI and GOA is adequate to identify key elements of the ecosystem, as demonstrated qualitative and quantitative descriptions of the status of the ecosystems. Quantitative models of the ecosystems demonstrate that information is adequate to broadly understand the key elements of the ecosystems. Therefore, SG60 and SG80 are met.

Investigation of UoA impacts Main impacts of the UoA on Main impacts of the UoA on Main interactions between the these key ecosystem these key ecosystem UoA and these ecosystem b Guide elements can be inferred from elements can be inferred from elements can be inferred from post existing information, but have existing information, and existing information, and not been investigated in some have been have been investigated in detail. investigated in detail. detail. Met? All UoAs – Yes All UoAs – Yes All UoAs – No

Rationale

All UoAs There have been a number of studies of the impacts of trawls on bottom fauna, although fewer in Alaska. Impacts are generally less in soft-bottom substrates, such as the Bering Sea, and are expected to be less given that trawls used in Alaska have large bobbins to reduce contact of the foot rope with the bottom. Nevertheless, the often hard and complex sea bottom in the GOA provides more opportunity for bottom impacts. Long-term effects index for non- pelagic trawl gear impacts on fish habitat features were estimated as small, at 0.1% in hard-bottom habitats of the GOA, at 0.2% in soft-bottom shelf habitats of the Bering Sea, at 0.4% in slope habitats of the Bering Sea, and at 4.2% for the hard-bottom habitats of the Aleutian Islands. Impacts of the trawl fishery on marine mammals and seabirds can be inferred from existing information and some have been investigated in detail. Long-term effects index for non- pelagic trawl gear impacts on fish habitat features were estimated as small. Impacts of the trawl fishery on marine mammals and seabirds can be inferred from existing information and some have been investigated in detail. Therefore, SG60 and SG80 are met. SG100 is not met since all main interaction have not been investigated in detail.

Understanding of component functions The main functions of the The impacts of the UoA on P1 components (i.e., P1 target target species, primary, Guide species, primary, secondary secondary and ETP species c and ETP species and and Habitats are identified post Habitats) in the ecosystem and the main functions of are known. these components in the ecosystem are understood. Met? All UoAs – Yes All UoAs – No

Rationale

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All UoAs The main functions of and impacts on the components of the ecosystem are known through extensive biological sampling associated with regular surveys conducted by NMFS through its Resource Assessment and Conservation Engineering Division, Marine Mammal Laboratory, Resource Ecology and Fisheries Management Division, and the Observer Program. The main impacts of the fisheries on target, primary, secondary and ETP species have been identified and the main functions of these components are understood through extensive quantitative modelling of the ecosystem. Therefore, SG80 is met. More and current information is needed to evaluate if SG100 is met since all main functions need to be understood at this level.

Information relevance Adequate information is Adequate information is available on the impacts of available on the impacts of d Guide the UoA on these the UoA on the components post components to allow some of and elements to allow the the main consequences for main consequences for the the ecosystem to be inferred. ecosystem to be inferred. Met? All UoAs – Yes All UoAs – Yes

Rationale

All UoAs Analyses conducted for the EFH EIS provide sufficient information of the impacts of the fishery on bottom fauna, whereas, ecosystem modelling and data on seabird and marine mammal takes from the observer program have provided sufficient information of the impacts of the fishery on other components of the ecosystem. These analyses and models also allow the main consequences for the ecosystem to be inferred. Therefore, SG80 is met. These analyses and models also allow the main consequences for the ecosystem to be inferred. SG100 is met.

Monitoring Adequate data continue to be Information is adequate to e Guide collected to detect any support the development of post increase in risk level. strategies to manage ecosystem impacts. Met? All UoAs – Yes All UoAs – Yes

Rationale

All UoAs NMFS conducts a comprehensive program of surveys to monitor the abundance and key elements of the BSAI and GOA ecosystems. The observer program collects targeted catch and bycatch statistics, which is sufficient data to detect any increase in the level of risk to elements of the ecosystem and this information is sufficient to support the development of strategies to manage ecosystem impacts of the fishery, as specified in the GOA FMP, Aleutian Islands FEP, and the motion by the NPFMC to develop a similar plan for the Bering Sea. SG80 and SG100 are met.

References

Allen and Angliss 2015, Aydin et al. 2007, Dragoo et al. 2014, Gaichas et al. 2012, NMFS 2010, NOAA 2005, Zador 2013

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80 Information sufficient to score PI but additional Information gap indicator information could increase score

Overall Performance Indicator scores added from Client and Peer Review Draft Report

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Overall Performance Indicator score

Condition number (if relevant)

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7.4 Principle 3 Background The following text was taken from the MRAG Americas 2016 BSAI and GOA Alaska Pacific Pollock Public Certification Report (MRAG 2016, 2016a). The Bering Sea and Aleutian Islands (BSAI) and Gulf of Alaska (GOA) Pacific Pollock fisheries are conducted in the U.S. EEZ waters (Figure 15) of the Bering Sea and Aleutian Islands and the Gulf of Alaska. The principle legislative instrument for fisheries management in the U.S. is the Magnuson-Stevens Fishery Conservation and Management Act or the Magnuson-Stevens Reauthorization Act (MSRA) and is implemented by the National Marine Fisheries Service (NMFS). The North Pacific Fishery Management Council (NMFMC) is one of eight regional councils established by the MSRA to manage fisheries in the 200-mile EEZ. The NPFMC primarily manages groundfish in the Gulf of Alaska, Bering Sea, and Aleutian Islands, targeting cod, pollock, flatfish, mackerel, sablefish, and rockfish species harvested by trawl, longline, jig, and pot gear (NPFMC 2009). The NPFMC also makes allocation decisions for halibut, in concert with the International Pacific Halibut Commission that biologically manages the resource for U.S.-Canada waters. Other large Alaska fisheries for salmon, crab, and scallops are managed jointly with the State of Alaska. The NPFMC also works very closely with the Alaska Department of Fish and Game (ADFG) and the Alaska Board of Fisheries (BOF) to coordinate management programs in federal and state waters (0-3 nm from shore). Many fishery resources are harvested in waters under both state and federal jurisdiction. As such, the NPFMC and state work together to address habitat concerns, catch limits, allocation issues, and other management details through coordination meetings and delegation of management oversight to one agency or the other. For most federal groundfish fisheries, ADFG issues emergency orders for state waters that duplicate NMFS management actions, with exception of gear or other restrictions that might vary (ADFG 2019). These emergency orders establish parallel fishing seasons that allow vessels to fish for groundfish (primarily Pacific cod, Atka mackerel, and walleye pollock) in state waters with the same seasons as the federal fisheries.

Federal fisheries for Alaska Pacific pollock are under the jurisdiction of the Bering Sea-Aleutian Islands Groundfish Fishery Management Plan (FMP), the Gulf of Alaska FMP and the MSRA. The NPFMC BSAI management area is divided into Bering Sea and Aleutian Islands subareas. Parallel fisheries for pollock take place in state waters around Kodiak Island, in the Chignik Area, and along the South Alaska Peninsula (ADFG 2019). An open access state-waters fishery takes place in Prince William Sound (PWS); where the guideline harvest level (GHL) for this fishery is deducted from the combined federal Western, Central, and West Yakutat Gulf of Alaska Regulatory Area (W/C/WYAK) acceptable biological catch (ABC) (ADFG 2019). In the 5-year period ending 2002, pollock harvests averaged almost 2.9 billion pounds (1.3 million tons (mt)) in the federal fishery and have varied from a high of almost 118 million pounds (53,000 mt) in the state fishery in 1998 to about 2.5 million pounds (1,200 mt) in 2002. The federal fishery had an average of 196 permitted vessels and the catch yielded an average ex-vessel value of almost $267 million. Counterpart values for the state fishery were six permits and almost $215 thousand (ADFG 2019). The jurisdictional category according to FCR SA4.1.1 is single jurisdiction.

Figure 15 The US EEZ of the Bering Sea, Aleutian Islands, and Gulf of Alaska (NPFMC 2012).

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Recognized groups with interests in the fishery The pollock fishery operates under the American Fisheries Act (AFA), signed into law in October 1998 (NPFMC 2019e). The AFA tightened U.S. ownership standards for U.S. fishing vessels under the Anti-reflagging Act and provided the BSAI pollock fleet the opportunity to conduct their fishery in a more rational manner while protecting non- AFA participants in the other fisheries. The AFA eliminated the race for pollock through the establishment of cooperatives with specific provisions for their allocations, structure, and participation by catcher vessels and processing plants, as well as annual reporting requirements and excessive share limits. In response to a directive in the AFA, the Council added measures to protect other fisheries from adverse effects arising from the exclusive pollock allocation. Cooperative fishing began under the AFA program in 1999. The AFA affected the pollock industry through capacity reduction, efficiency increase, regulatory bycatch reduction, a higher portion of utilized fish, and higher valued products (NPFMC 2019e, MRAG 2016, 2016a).

Alaska Pacific pollock is harvested by commercial demersal trawl gear. The fleet consists of catcher vessels delivering to shore, catcher vessels delivering to motherships that process the catch, or at-sea catcher/processor vessels. The Western Alaska Community Development Quota (CDQ) Program was created by the Council in 1992 to provide western Alaska communities an opportunity to participate in the BSAI fisheries that had been foreclosed to them because of the high capital investment needed to enter the fishery (NPFMC 2019c). The CDQ Program allocates a percentage of all BSAI quotas for groundfish, prohibited species, halibut, and crab to eligible communities. The purpose of the CDQ Program is to (i) to provide eligible western Alaska villages with the opportunity to participate and invest in fisheries in the Bering Sea and Aleutian Islands Management Area; (ii) to support economic development in western Alaska; (iii) to alleviate poverty and provide economic and social benefits for residents of western Alaska; and (iv) to achieve sustainable and diversified local economies in western Alaska.

In 2004, through two consolidated appropriations acts, Congress required federal agencies to consult with Alaska Native corporations on the same basis that E.O. 13175 required consultation with Federally recognized Indian Tribes (NOAA 2013, MRAG 2015). The relationship between Federally recognized Indian Tribes and the federal government is one of sovereign to sovereign and has been described at length by the federal judiciary and referred to in federal law promoting Tribal self-determination and self-governance. Many presidential memoranda have recognized and this unique legal and political relationship between governments. Through government-to-government consultation and informal staff-to-staff collaboration, the United States acknowledges Federally recognized tribal governments as separate sovereign governmental entities, under the protection of the United States whose unique political historical and religious characteristics are reflected in their governmental priorities, concerns, and needs. Consultation recognizes and distinguishes the views and policies of American Indian and Alaska Native tribal governments from those of the general public and considers those views in the context of the responsibilities of Federally recognized Tribes to their people and tribal members. Through government-to-government consultation and informal staff-to-staff collaboration, the United States acknowledges Federally recognized tribal governments as separate sovereign governmental entities, under the protection of the United States whose unique political historical and religious characteristics are reflected in their governmental priorities, concerns, and needs. Consultation recognizes and distinguishes the views and policies of American Indian and Alaska Native tribal governments from those of the general public and considers those views in the context of the responsibilities of Federally recognized Tribes to their people and tribal members. Regional fishery management council meetings are a critical part of the fishery management planning process and are the first and earliest point of development of fishery management policy. It is most beneficial to tribes, councils, and NOAA if there is early and active participation in these fora, and NOAA strongly encourages councils to discuss and work with Tribes to address their concerns while developing fishery conservation and management measures under the MSA. Thus, while it is NOAA’s – and not the councils’ – responsibility to consult with Federally-recognized Tribes under Executive Order 13175, the councils’ early engagement with potentially affected Indian tribes will facilitate and enhance NOAA’s rulemaking process (NOAA 2013, MRAG 2015).

The Council implemented Amendment 80 in 2008, which allocated BSAI yellowfin sole, flathead sole, Atka mackerel, and Aleutian Islands Pacific Ocean perch to the “head and gut” trawl catcher processor sector and allows qualified vessels to form cooperatives. The program establishes GOA groundfish sideboard limits for pollock, Pacific cod, Pacific Ocean perch, northern rockfish, and pelagic shelf rockfish, as well as GOA halibut (NPFMC 2019f). GOA sideboard restrictions are based on historic participation during 1998-2004.This action meets the broad goals of: (1) improving retention and utilization of fishery resources by the non-AFA trawl catcher/processor fleet by extending the groundfish retention standard (GRS) to non-AFA trawl catcher/processor vessels of all lengths; (2) allocating fishery resources among BSAI trawl harvesters in consideration of historic and present harvest patterns and future harvest needs; (3) authorizing the allocation of groundfish species to harvesting cooperatives and establishing a limited access privilege program (LAPP) for the non-AFA trawl catcher/processors to reduce potential GRS compliance costs, encourage fishing practices with lower discard rates, and improve the opportunity for increasing the value of harvested species; and (4) limiting the ability of non-AFA trawl catcher/processors to expand their harvesting capacity into other fisheries not managed under a LAPP. In addition, Amendment 80 modified the management of halibut and crab prohibited species catch (PSC) limits (NPFMC 2019f). Northern and dusky rockfish are caught as part of the

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Amendment 80 fisheries that target Atka mackerel and POP. There is also a small allocation of these four species to the BSAI Trawl Limited Access sector, outside of Amendment 80.

The BSAI and GOA groundfish management process has many stakeholders: Alaska federal groundfish license holders, processors, the states of Alaska, Washington, and Oregon, fishermen’s organizations, CDQ groups and several environmental groups.

Details of consultations leading to the formulation of the management plan

In 1996, the United States Congress reauthorized the MSA, or MSRA, to include a new emphasis on the precautionary approach in U.S. fishery management policy. The MSRA contains ten national standards (NS) with which all fishery management plans (FMPs) must conform and which guide fishery management (NPFMC 2018). These NSs are:

1. Conservation and management measures shall prevent overfishing while achieving, on a continuing basis, the optimum yield from each fishery for the U.S. fishing industry; 2. Conservation and management measures shall be based upon the best scientific information available; 3. To the extent practicable, an individual stock of fish shall be managed as a unit throughout its range, and interrelated stocks of fish shall be managed as a unit or in close coordination; 4. Conservation and management measures shall not discriminate between residents of different states. If it becomes necessary to allocate or assign fishing privileges among various U.S. fishermen, such allocation shall be (A) fair and equitable to all such fishermen; (B) reasonable calculated to promote conservation; and (C) carried out in such manner that no particular individual, corporation, or other entity acquires an excessive share of privileges; 5. Conservation and management measures shall, where practicable, consider efficiency in the utilization of fishery resources; except that no such measure shall have economic allocation as its sole purpose; 6. Conservation and management measures shall take into account and allow for variations among, and contingencies in, fisheries, fishery resources, and catches; 7. Conservation and management measures shall, where practicable, minimize costs and avoid unnecessary duplication; 8. Conservation and management measures shall, consistent with the conservation requirements of the Act (including the prevention of overfishing and rebuilding of overfished stocks), take into account the importance of fishery resources to fishing communities in order to (A) provide for the sustained participation of such communities, and (B) to the extent practicable, minimize adverse economic impacts on such communities; 9. Conservation and management measures shall, to the extent practicable, (A) minimize bycatch and (B) to the extent bycatch cannot be avoided, minimize the mortality of such bycatch; and, 10. Conservation and management measures shall, to the extent practicable, promote the safety of human life at sea.

Under the MSRA, the North Pacific Fishery Management Council (Council) is authorized to prepare and submit to the Secretary of Commerce for approval, disapproval or partial approval, an FMP and any necessary amendments, for each fishery under its authority that requires conservation and management. The Council conducts public hearings to allow all interested persons an opportunity to be heard in the development of FMPs and amendments, and reviews and revises, as appropriate, the assessments and specifications with respect to the optimum yield from each fishery (NPFMC 2018).

The groundfish fisheries, including the Alaska Pacific pollock fisheries, in the BSAI and GOA are managed by two different, but complimentary, FMPs: BSAI FMP and GOA FMP. Program policies and measures are developed by the NPFMC through the preparation and maintenance of FMPs for groundfish, crabs, and scallop fisheries in the Bering Sea and Gulf of Alaska, as well as for all future fisheries in the Arctic Ocean. The FMPs are frequently amended by the Council to respond to new scientific information, changes in the environment, changes in policy, and operational changes in the fisheries. The plan amendments, together with regulatory amendments, are developed though the Council’s open and transparent regulatory process and implemented by the NMFS Alaska Regional Office (NMFS 2016).

BSAI FMP The BSAI Groundfish FMP was adopted by the Council in 1980 and implemented in 1982. The FMP has been amended several times to meet the changing fishery management needs. The BSAI FMP management area is the U.S. EEZ of the Bering Sea and that portion of the North Pacific Ocean adjacent to the Aleutian Islands which is between 170E W. longitude and the U.S.-Russian Convention Line of 1867 (NPFMC 2018). The BSAI FMP covers fisheries for all stocks of finfish and marine invertebrates except salmonoids, shrimps, scallops, snails, king crab, Tanner crab, Dungeness crab, corals, surf clams, horsehair crab, lyre crab, Pacific halibut, and Pacific herring

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(NPFMC 2018). One of the major objectives of the Council in the early 1980s was to phase out foreign fishing vessel participation in the BSAI EEZ (NPFMC 2018). The first ten amendments implemented in the BSAI Groundfish FMP specifically dealt with foreign fishing fleet participation in the fishery. After the foreign fleet was adequately addressed, the Council focused on managing and regulating the domestic fleet to allow for sustainable and profitable fisheries by limiting entry and addressing allocation issues, bycatch, and habitat conservation needs (NPFMC 2018). In recent years, the Council has adopted amendments to streamline catch share programs and address other science and management changes. The NPFMC has prepared summaries of each amendment to the FMPs that provide an overview of the purpose and need, analysis, regulation, and results of each action, and are meant as a resource for anyone interested in understanding the development of a federal fishery management program in the North Pacific. A full list of these actions can be found at the following link: BSAI Amendment Action Summaries.

GOA FMP The GOA FMP was implemented on December 1, 1978 and has been amended over sixty times. The GOA FMP governs groundfish fisheries of the GOA. The FMP management area is the U.S. EEZ of the North Pacific Ocean, exclusive of the Bering Sea, between the eastern Aleutian Islands at 170 E W. longitude and Dixon Entrance at 132 E 40’ W. longitude. The FMP covers fisheries for all stocks of finfish except salmon, steelhead, Pacific halibut, Pacific herring and tuna (NPFMC 2018a). The focus of the FMP has changed from the regulation of foreign fisheries to the management of fully domestic groundfish fisheries (NPFMC 2018a). The revised version has been updated to remove obsolete references to foreign fishery management measures, as well as outdated catch data and other scientific information. A summary of amendments, like that prepared for BSAI, is still in preparation.

The ADFG Management Plan for PWS pollock The management plan (5 AAC 28.263) specifies that no more than 60% of the GHL may be taken from any one section in order to reduce potential impacts on the endangered population of Steller sea lions by geographically apportioning the catch. The management plan also restricts bycatch to no more than 5% of the total round weight of pollock harvested, and the ADFG further manages bycatch by apportioning the percentage among the following species groups: rockfish (0.5%), salmon (0.04%), shark (0.96%), squid (3.0%), and other species (0.5%). The directed fishery for pollock in PWS has typically experienced low bycatch rates relative to many other groundfish fisheries. Currently, the GHL is determined as 2.5% of the combined W/C/WYAK ABC based on the GHL historical percent average from 2001 to 2010. ADFG has reserved a percentage of the calculated GHL for a test fishery. Revenues from these test fisheries are used to fund PWS commercial fishery management, including groundfish stock assessment and in-season pollock catch sampling (ADFG 2019).

Arrangements for on-going consultations with interest groups

The Council established a wide-ranging consultation process. The process used by the Council to manage groundfish is described in a brochure explaining the overall Council process (NPFMC 2009) and the Council Operating Procedures (NPFMC 2012). The NPFMC participates in international negotiations concerning any fishery matters under the cognizance of the Council. The Council also consults during preliminary discussions leading to U.S. positions on international fishery matters, including the allocation of fishery resources to other nations within its area of authority.

Each regular meeting and each emergency meeting are open to the public. Interested persons may present oral or written statements regarding the matters on the agenda at meetings, within reasonable limits established by the Chair. Current Council policy on oral testimony limits individuals to three minutes, and organizations to six minutes, per agenda item. All written information submitted to a Council by an interested person shall include a statement of the source and date of such information. Any oral or written statement shall include a brief description of the background and interests of the person in the subject of the oral or written statement (NPFMC 2009).

The Council may hold public hearings in order to provide the opportunity for all interested individuals to be heard with respect to the development of fishery management plans or amendments, and with respect to the administration and implementation of other relevant features of the Act. Notice of each hearing must be received by NMFS for publication in the Federal Register at least 23 calendar days prior to the proposed hearing. The Council will also issue notices to announce the time, location, and agenda for each hearing in a manner sufficient to assure all interested parties are aware of the opportunity to make their views known. If it is determined a hearing is appropriate, the Council Chair will designate at least one voting member of the Council to officiate. An accurate record of the participants and their views will be made available to the Council at the appropriate Council meeting and maintained as part of the Council’s administrative record (NPFMC 2009).

The procedure for changing Federal fishing regulations follows a standardized process, set forth by a combination of laws, regulations, operational guidelines, policies, as well as adjustments and adaptations developed by the Council to increase efficiency, provide public participation, and produce quality outcomes (NPFMC 2009; 2012). All documents 106 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019 are posted on the website in advance of the meeting, and public comment is taken by the Council and advisory bodies before any decisions are made. In addition, the NPFMC website has newsletters, articles, publications, meeting agendas and calendars of upcoming events and highlights current issues.

Details of other non-MSC fishery users or activities and arrangements for liaison

In both the GOA and BSAI there is a small incidental catch of pollock with hook and line and pot gear. Sport fishing is open to anyone in virtually all of Alaska, while commercial, subsistence, and personal use fishing are limited to certain areas, certain types of gear, or just to Alaska residents. There is a recreational fishery in the state of Alaska that targets groundfish, however pollock is usually less targeted or incidentally caught (ADFG 2019).

Details of the decision-making process

The MSRA is the primary domestic legislation governing management of marine fisheries in the United States. The Act was first enacted in 1976 and has been amended many times over the years. It was most recently reauthorized in 2006. Two major recent sets of amendments to the law were the: • The Sustainable Fisheries Act (1996) addresses many topics, among which includes Title V, Implementation of Western and Central Pacific Fisheries Commission (http://www.nmfs.noaa.gov/sfa/sustainable_fishereries_act.pdf). • Magnuson–Stevens Fishery Conservation and Management Reauthorization Act of 2006, which has numerous purposes (http://www.nmfs.noaa.gov/msa2005/index.html): a. Acting to conserve fishery resources b. Supporting enforcement of international fishing agreements c. Promoting fishing in line with conservation principles d. Providing for the implementation of FMPs which achieve optimal yield e. Developing underutilized fisheries f. Protecting essential fish habitats g. Additionally, the law calls for reducing bycatch and establishing fishery information monitoring systems.

The Council and National Marine Fisheries Service (NMFS) manage U.S. Federal fisheries off Alaska (3-200 nautical miles). Management is coordinated, and in some cases, jointly managed, with the State of Alaska. NOAA/NMFS is also responsible for carrying out the U.S. policies to manage and conserve marine protected resources. Other applicable law that is directly relevant to the management of marine fisheries includes (NPFMC 2019):

• National Environmental Policy Act (NEPA): requires environmental impact assessments of federal actions and compliance with other laws and executive orders. • Endangered Species Act (ESA): prohibits actions that are expected to jeopardize the continued existence of any endangered or threatened species under NMFS’ jurisdiction or result in harmful effects on critical habitat. • Marine Mammal Protection Act (MMPA): requires protection of marine mammals. NMFS is responsible for whales, dolphins, porpoise, seals, sea lions and fur seals. The U.S. Fish and Wildlife Service (USFWS) is responsible for walrus, sea otters, and the West Indian manatee. • Migratory Bird Treaty Act (MBTA): a shared agreement between the United States, Canada, Japan, Mexico, and Russia to protect migratory birds, prohibiting their taking, killing, or possession. The directed take of seabirds is prohibited. • Coastal Zone Management Act (CZMA): requires all federal activities that directly affect the coastal zone be consistent with approved state coastal zone management programs to the maximum extent practicable • Administrative Procedures Act (APA): provides for public participation in the rulemaking process • Paperwork Reduction Act (PRA): regulates the collection of information from the public • Regulatory Flexibility Act (RFA): requires assessment of the regulatory impact on small entities through a regulatory flexibility analysis. The analysis is combined with the regulatory impact review (RIR) and NEPA analyses. • EO 12866 (Regulatory Planning and Review): establishes guidelines for promulgating new regulations and reviewing existing regulations and requires agencies to assess the costs and benefits of all regulatory action alternatives. • EO 12898 (Environmental Justice): requires federal agencies to identify and address “disproportionately high adverse human health or environmental effects of their programs, policies, and activities on minority and low- income populations in the United States” as part of an environmental impact analysis associated with an action.

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• EO 13175 (Consultation and Coordination with Indian Tribal Governments): requires regular and meaningful consultation and collaboration with tribal officials in the development of federal policies that have tribal implications and the avoidance of unfunded mandates imposed on tribes. • EO 13132 (Federalism): requires federal agencies to consider the implications of policies that may limit the scope of or pre-empt states’ legal authority. Such actions require a consultation process with the states and may not create unfunded mandates for the states. • EO 13186 (Responsibilities of Federal Agencies to Protect Migratory Birds): supplements the MBTA by requiring Federal agencies to work with the USFWS to develop memoranda of agreement to conserve migratory birds and to evaluate the effects of their actions on migratory birds in NEPA documents.

The Council makes recommendations to NMFS, and NMFS approves, implements and enforces them. The Council consists of 11 voting members, including: 7 appointed members, 4 agency representatives (6 from AK, 3 from WA, 1 from OR, and 1 from NMFS). There are also 4 non-voting members that include representatives from the US Fish and Wildlife Service, US Coast Guard, Pacific States MFC, and the US State Department. The Council meet 5 times per year, and each meeting is ~8 days. All meetings are open to the public. Proposals for management measures may come from the public, state and federal agencies, advisory groups, or Council members. There is also a Science and Statistical Committee (SSC) and Advisory Panel (AP) that provide input to Council at each meeting. Public testimony is taken on each agenda item, at the SSC, AP and Council (NPFMC 2012a). The Council also maintains Plan Teams for each fishery management plan and appoints standing and ad hoc committees necessary to advise the Council on conservation and management issues.

The Science and Statistical Committee (SSC) As required by the Act at Sec. 302(g)(1), the Council shall establish, maintain, and appoint the members of a SSC to assist it in the development, collection, and peer review of such statistical, biological, economic, social, and other scientific information as is relevant to the Council’s development and amendment of any of its fishery management plans (MRAG 2015). The SSC is composed of scientists in economics, biology, social science and statistics. Members appointed by the Council to the SSC shall be federal employees, state employees, academics, or independent experts and shall have strong scientific or technical credentials and experience. Independent experts on the SSC cannot be employed by an interest group or advocacy group. The SSC will provide the peer review process for scientific information used to advise the Council about the conservation and management of the fishery. The review process, which may include existing committees or panels, is deemed to satisfy the requirements of the guidelines issued pursuant to section 15 of the Treasury and General Government Appropriations Act for Fiscal Year 2001 (Public Law 106– 554—Appendix C; 114 Stat. 2763A–153). SSC members serve one-year terms with no term limits. Members may be reappointed or replaced by the Council annually at their December Council meeting (NPFMC 2019b, MRAG 2015).

The Advisory Panel (AP) The AP is represented by members of the fishing industry, catching and processing and subsistence and commercial fishermen, observers, consumers, environmental/conservation, and sport fishermen. The Council relies on the AP for comprehensive advice on how various fishery management alternatives will affect the industry and local economies, on potential conflicts between user groups of a given fishery resource or area, and on the extent to which the United States will utilize resources managed by the Council’s fishery management plans (MRAG 2015). The AP consists of 22 members, usually serving three-year terms. These members may be reappointed or replaced by the Council annually at their December Council meeting (NPFMC 2019b).

Groundfish Plan Teams The Council appoints plan teams for each of the major fishery management plans (FMPs). Members of each team are selected from those agencies and organizations having a role in the research and/or management of fisheries. At a minimum, teams shall be composed of one member from agencies having responsibility for management of the fishery resources under the jurisdiction of the Council. Nominations of these individuals are at the discretion of the agencies. Other individuals may be nominated by members of the Plan Team, Council, SSC or AP. Appointments to the team will be made by the Council with recommendations from the SSC.

The Plan Teams review stock assessment information and assist in the preparation of the annual Stock Assessment and Fishery Evaluation (SAFE) documents including formulation of recommendations on annual Acceptable Biological Catch (ABC) levels for groundfish, crab, and scallop species under jurisdiction of the Council. The Teams may also prepare and/or review plans, amendments and supporting analytical documents for the Council, SSC and AP; aggregate and evaluate public/industry proposals and comments; summarize and evaluate data related to the biological, economic and social conditions of the fishery; conduct and evaluate analyses pertaining to management of the fisheries; evaluate the effectiveness of management measures in achieving the plan's objectives; and recommend when and how management measures need to be changed.

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For those proposals the Council chooses to pursue it directs the National Marine Fisheries Service (NMFS) and/or Council staff to prepare an analysis considering a range of alternatives. The Council reviews the analysis and selects a range of alternatives within which a preliminary preferred alternative may be identified. The analysis is then made available for public review, and the NPFMC makes a final decision at the next meeting the item is scheduled. After considering NPFMC recommendations and public comments, NMFS publishes the adopted regulations. For non- routine and annual management decisions, NMFS publishes a Federal Register notice and provides a public comment period before finalizing the recommendations (NPFMC 2009).The procedure for changing Federal fishing regulations follows a standardized process, set forth by a combination of laws, regulations, operational guidelines, policies, as well as adjustments and adaptations developed by the NPFMC to increase efficiency, provide public participation, and produce quality outcomes (NPFMC 2009; 2012). All documents are posted on the website in advance of the meeting, and public comment is taken by the Council and advisory bodies before any decisions are made.

The following NPFMC Council process was taken from NPFMC 2009, MRAG 2016, 2016a:

Proposal for Change. Concerns and proposals for change are brought to the Council’s attention by the public through the industry advisory panel or other committee, or directly to the Council via written or verbal public comment during the ‘Staff Tasking’ agenda item at each Council meeting (Figure 16).

Figure 16 Process for regulatory change, NPFMC (Source: NPFMC 2009).

Discussion Paper. A discussion paper is frequently prepared by staff as a first step to flesh out the scope of the problem identified and discuss issues that may be of concern in the development of alternatives. For very complex issues, several discussion papers may be necessary to explore the full scope of an issue before reasonable alternatives can be developed. For relatively simple changes, where the problem and alternatives are self-evident, a

109 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019 discussion paper may not be necessary, and the issue can go straight to analysis, even without developing an official problem statement and range of alternatives. The AP (and other committees if appropriate) provides recommendations to the Council at this stage regarding if the issue should proceed further in the process, if an expanded discussion paper is needed, or if the issue is ready for analysis (and recommend alternatives to be evaluated) (NPFMC 2009).

Initial Review of Analysis. Normally, the Council adopts a problem statement (or thoroughly describes the problem) and identifies alternatives to be considered, and then staff prepares a draft analysis that integrates analytical requirements of applicable laws and executive orders. The analysis is released for review about 2 weeks (or more) before the meeting. The analysis is reviewed by the Scientific and Statistical Committee (SSC) for scientific merit, and by the AP to make recommendations regarding any missing information and the suite of alternatives and options evaluated. If the SSC has deemed the analysis inadequate and not ready for public review, or if the Council determines that additional alternatives or other substantial changes to the analysis are required, another initial review may be scheduled before the issue is scheduled for final action. If the analysis is to be released, the Council may designate a preliminary preferred alternative to focus comments on their indicated course of action (NPFMC 2009).

Final Review of Analysis. After initial review, staff revises the analysis based on SSC, AP, and Council comments, and the analysis is posted on the Council website about 3 to 4 weeks before the meeting. The AP makes a recommendation to the NPFMC regarding a preferred alternative. The Council makes a final decision by roll call vote on the motion (NPFMC 2009).

Proposed Rule. The NMFS region prepares draft regulations based on NPFMC action, and once cleared by the region and OMB, a proposed rule is published in the Federal Register. The public is provided time to comment on the proposed rule (NPFMC 2009).

Final Rule. NMFS region staff summarizes comments and may make adjustments to the rule based on these comments. The response to comments, the revised final rule, and final approval decision is published in the Federal Register (NPFMC 2009).

Alaska Board of Fisheries (BOF) The BOF as jurisdiction over state waters fisheries (within 3 nm of the Alaska coastline). The BOF consists of seven members serving three-year terms. Members are appointed by the governor and confirmed by the legislature. Members are appointed on the basis of interest in public affairs, good judgment, knowledge, and ability in the field of action of the board, with a view to providing diversity of interest and points of view in the membership.

The BOF’s main role is to conserve and develop the fishery resources of the state. This involves setting seasons, bag limits, methods and means for the state’s subsistence, commercial, sport, guided sport, and personal use fisheries, and it also involves setting policy and direction for the management of the state’s fishery resources. The board is charged with making allocative decisions, and the department is responsible for management based on those decisions (ADFG 2019a).

The BOF meets four to six times per year in communities around the state to consider proposed changes to fisheries regulations around the state. The board uses the biological and socioeconomic information provided by the Alaska Department of Fish and Game, public comment received from people inside and outside of the state, and guidance from the Alaska Department of Public Safety and Alaska Department of Law when creating regulations that are sound and enforceable. The BOF is established under Alaska Statute 16.05.221 for the purposes of the conservation and development of the fisheries resources of the state. The BOF has the authority to adopt regulations described in AS 16.05.251 including: establishing open and closed seasons and areas for taking fish; setting quotas, bag limits, harvest levels and limitations for taking fish; and establishing the methods and means for the taking of fish. The BOF conducts regular reviews of groundfish fisheries within state waters of Alaska, in which external parties (i.e., consultants contracted by various user groups, experts that department staff has asked for input, etc.) have full opportunity for critical comment. The Board’s review of FMPs, amendments and other regulatory changes include input from ADFG staff, Regional Fish & Game advisory committees, non-ADFG scientists, industry, environmental non-governmental organizations, stakeholders and the general public. Legislative committees have conducted oversight and legislative hearings regarding the BOF’s actions in a region’s fisheries. The BOF and ADFG frequently turn to outside sources for technical advice, particularly regarding scientific matters and monitoring issues. If there are socio-economic or other ecosystem concerns expressed, the BOF can adjust time or area openings commensurate with the adjusted ABC. This process of external review is repeated in the BOF meeting schedule every 3 years (ADFG 2019a).

Objectives for the fishery

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The Council have several goals and objectives in both the BSAI FMP and the GOA FMP that have been established in order “to apply judicious and responsible fisheries management practices, based on sound scientific research and analysis, proactively rather than re-actively, to ensure the sustainability of fishery resources and associated ecosystems for the benefit of future, as well as current generations” (NPFMC 2019). The following objectives were taken directly from the BSAI and GOA FMPs (NPFMC 2018, 2018a): Prevent Overfishing: 1. Adopt conservative harvest levels for multi-species and single species fisheries and specify optimum yield. 2. Continue to use the 2 million mt optimum yield cap for the BSAI groundfish fisheries. 3. Provide for adaptive management by continuing to specify optimum yield as a range. 4. Provide for periodic reviews of the adequacy of F40 and adopt improvements, as appropriate. 5. Continue to improve the management of species through species categories. 1. Promote Sustainable Fisheries and Communities: 6. Promote conservation while providing for optimum yield in terms of the greatest overall benefit to the nation with particular reference to food production, and sustainable opportunities for recreational, subsistence, and commercial fishing participants and fishing communities. 7. Promote management measures that, while meeting conservation objectives, are also designed to avoid significant disruption of existing social and economic structures. 8. Promote fair and equitable allocation of identified available resources in a manner such that no particular sector, group or entity acquires an excessive share of the privileges. 9. Promote increased safety at sea. Preserve Food Web: 10. Develop indices of ecosystem health as targets for management. 11. Improve the procedure to adjust acceptable biological catch levels as necessary to account for uncertainty and ecosystem factors. 12. Continue to protect the integrity of the food web through limits on harvest of forage species. 13. Incorporate ecosystem-based considerations into fishery management decisions, as appropriate. Manage Incidental Catch and Reduce Bycatch and Waste: 14. Continue and improve current incidental catch and bycatch management program. 15. Develop incentive programs for bycatch reduction including the development of mechanisms to facilitate the formation of bycatch pools, vessel bycatch allowances, or other bycatch incentive systems. 16. Encourage research programs to evaluate current population estimates for non-target species with a view to setting appropriate bycatch limits, as information becomes available. 17. Continue program to reduce discards by developing management measures that encourage the use of gear and fishing techniques that reduce bycatch which includes economic discards. 18. Continue to manage incidental catch and bycatch through seasonal distribution of total allowable catch and geographical gear restrictions. 19. Continue to account for bycatch mortality in total allowable catch accounting and improve the accuracy of mortality assessments for target, prohibited species catch, and non-commercial species. 20. Control the bycatch of prohibited species through prohibited species catch limits or other appropriate measures. 21. Reduce waste to biologically and socially acceptable levels. 22. Continue to improve the retention of groundfish where practicable, through establishment of minimum groundfish retention standards. Avoid Impacts to Seabirds and Marine Mammals: 23. Continue to cooperate with U.S. Fish and Wildlife Service (USFWS) to protect ESA-listed species, and if appropriate and practicable, other seabird species. 24. Maintain or adjust current protection measures as appropriate to avoid jeopardy of extinction or adverse modification to critical habitat for ESA-listed Steller sea lions. 25. Encourage programs to review status of endangered or threatened marine mammal stocks and fishing interactions and develop fishery management measures as appropriate. 26. Continue to cooperate with NMFS and USFWS to protect ESA-listed marine mammal species, and if appropriate and practicable, other marine mammal species. Reduce and Avoid Impacts to Habitat: 27. Review and evaluate efficacy of existing habitat protection measures for managed species. 28. Identify and designate essential fish habitat and habitat areas of particular concern pursuant to Magnuson- Stevens Act rules, and mitigate fishery impacts as necessary and practicable to continue the sustainability of managed species. 29. Develop a Marine Protected Area policy in coordination with national and state policies. 30. Encourage development of a research program to identify regional baseline habitat information and mapping, subject to funding and staff availability.

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31. Develop goals, objectives and criteria to evaluate the efficacy and suitable design of marine protected areas and no-take marine reserves as tools to maintain abundance, diversity, and productivity. Implement marine protected areas if and where appropriate. Promote Equitable and Efficient Use of Fishery Resources: 32. Provide economic and community stability to harvesting and processing sectors through fair allocation of fishery resources. 33. Maintain the license limitation program, modified as necessary, and further decrease excess fishing capacity and overcapitalization by eliminating latent licenses and extending programs such as community or rights- based management to some or all groundfish fisheries. 34. Provide for adaptive management by periodically evaluating the effectiveness of rationalization programs and the allocation of access rights based on performance. 35. Develop management measures that, when practicable, consider the efficient use of fishery resources taking into account the interest of harvesters, processors, and communities. Increase Alaska Native Consultation: 36. Continue to incorporate local and traditional knowledge in fishery management. 37. Consider ways to enhance collection of local and traditional knowledge from communities and incorporate such knowledge in fishery management where appropriate. 38. Increase Alaska Native participation and consultation in fishery management. Improve Data Quality, Monitoring and Enforcement: 39. Increase the utility of groundfish fishery observer data for the conservation and management of living marine resources. 40. Develop funding mechanisms that achieve equitable costs to the industry for implementation of the North Pacific Groundfish Observer Program. 41. Improve community and regional economic impact costs and benefits through increased data reporting requirements. 42. Increase the quality of monitoring and enforcement data through improved technology. 43. Encourage a coordinated, long-term ecosystem monitoring program to collect baseline information and compile existing information from a variety of ongoing research initiatives, subject to funding and staff availability. 44. Cooperate with research institutions such as the North Pacific Research Board in identifying research needs to address pressing fishery issues. Promote enhanced enforceability. 45. Continue to cooperate and coordinate management and enforcement programs with the Alaska Board of Fish, Alaska Department of Fish and Game, and Alaska Fish and Wildlife Protection, the U.S. Coast Guard, NMFS Enforcement, International Pacific Halibut Commission, Federal agencies, and other organizations to meet conservation requirements; promote economically healthy and sustainable fisheries and fishing communities; and maximize efficiencies in management and enforcement programs through continued consultation, coordination, and cooperation.

Fleet types or fishing categories participating in the fishery Alaska Pacific pollock is harvested by commercial pelagic trawl gear. The fleet consists of catcher vessels delivering to shore, catcher vessels delivering to motherships that process the catch, or at-sea catcher/processor vessels.

Rights of Access to the BSAI and GOA AK Groundfish fishery A Federal groundfish license is required for catcher vessels (including catcher/processors) participating in all BSAI and GOA groundfish fisheries, other than fixed gear sablefish. Exemptions for vessels fishing in State of Alaska waters (0-3 miles offshore) and vessels less than or equal to 26 LOA in the GOA and 32 LOA in BSAI (NPFMC 2018; 2018a). Catch Is monitored through record keeping, reporting requirements and observer monitoring (NOAA 2019).

Description of the measures agreed upon for the regulation of fishing in order to meet the objectives within a specified period

Measures have been taken to try to reduce potential negative impacts of the pollock fishery on endangered Steller sea lions. These measures include fishery exclusion zones around sea lion rookeries and haulouts and changes in seasonal apportionments to reduce catch near critical habitat and temporally disperse the fishery (ADFG 2019). Former fishing grounds in the Aleutian Islands were closed to pollock fishing in 2000. Limitations have been placed on the number of vessels participating in the Bering Sea Aleutian Islands pollock fisheries. The U.S measures for regulating the BSAI and GOA fisheries are found in 50 CFR 600 and 50 CFR 679.

Other applicable regulations for the BSAI and GOA groundfish fisheries are listed below with links to the most recent available data: 112 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

• Essential Fish Habitat EFH 5 year review approach • BSAI Harvest Specifications • GOA Harvest Specifications • Stellar Sea Lions Protection Measures

Arrangements and responsibilities for monitoring, control and surveillance and enforcement The mission of the Federal North Pacific Groundfish Observer Program is to collect data on fishing effort, total catch by species, and biological data; characterize marine mammal and sea bird interactions during the fisheries for Pacific pollock. The MSA and the MMPA authorize NMFS to place observers on Alaska groundfish vessels. The action is mandatory. The BSAI and GOA Groundfish FMPs (NPFMC 2018, 2018a) requires that U.S. fishing vessels that catch groundfish in the EEZ, or receive groundfish caught in the EEZ, and shoreside processors that receive groundfish caught in the EEZ, are required to accommodate NMFS-certified observers as specified in regulations, in order to verify catch composition and quantity, including at-sea discards, and collect biological information on marine resources. In 2013, the Council and the NMFS restructured the Observer Program to place all vessels and processors in the groundfish and halibut fisheries off Alaska into one of two categories: (1) the full coverage category, where vessels and processors obtain observers by contracting directly with observer providers, and (2) the partial coverage category, where NMFS has the flexibility to deploy observers when and where they are needed based on an annual deployment plan. The purpose of restructuring the Observer Program was to: (1) reduce the potential for bias in observer data, (2) authorize the collection of observer data in fishing sectors that were previously not required to carry observers, (3) allow fishery managers to provide observer coverage to respond to the management needs and circumstances of individual fisheries, and (4) assess a broad-based fee to more equitably distribute the costs of observer coverage (NMFS 2013). Data collected from the observer Program are stored and processed within the NMFS’s Catch Accounting System, which produces annual reports available in SAFE reports of species or species complexes and online. The 2014 Annual Deployment Plan documents how the National Marine Fisheries Service intends to assign at-sea and shoreside observers to operations fishing under the authority of the BSAI and GOA FMPs (NPFMC 2018, 2018a).

NMFS is responsible for funding and overall administration of the program including observer training, debriefing and data management. In the full observer coverage category, the fishing industry is responsible for making arrangements with contracting companies that meet the North Pacific Observer Program NMFS-certification requirements for placement of NMFS-trained observers aboard their vessels and paying contractors for direct observer costs. The observer contractors are responsible for observer recruiting, deployment, logistics, and insurance/benefits (NMFS 2014). Observer coverage responsibilities are shared among the fishing industry and independent observer contractors (who are certified by NMFS). The contractors hire and deploy observers. The NMFS also provides other observer support services (sampling gear and training documents) and is responsible for maintaining information systems for scientific and operational data, and administrative support. In the partial coverage category NMFS contracts directly with the observer providers, and charges fees to the industry for running the observer program based on ex-vessel value.

At-sea and shore-side enforcement is carried out by the Alaska Wildlife Troopers, NMFS Office of Law Enforcement (OLE), and the US Coast Guard (USCG). State and federal fisheries enforcement officers make use of USCG vessels and aircraft to assist in surveillance and enforcement. At-sea and shore-side enforcement activities include: • Monitoring of commercial fishing activities to ensure compliance with fishery laws and regulations; • Actions to close commercial fisheries once catch limits have been reached; • Educating participants in the fishery on the laws and regulations; NMFS Management, NMFS OLE, and the USCG all conduct extensive outreach and education programs that seek not only to explain the regulations, but also to help the fishing industry understand the rationale for those regulations. • Penalizing violators. OLE agents and officers can assess civil penalties directly to the violator in the form of a summary settlement or can refer the case to NOAA's OGC for Enforcement and Litigation who can impose a sanction on the vessels permit or further refer the case to the U.S. Attorney’s Office for criminal proceedings. Penalties may range from severe monetary fines, boat seizure and/or imprisonment (NMFS 2011, MRAG 2015).

NOAA’s OLE protects marine wildlife and habitat by enforcing domestic laws and international treaty requirements designed to ensure these global resources are available for future generations (NOAA 2019a). OLE special agents and enforcement officers ensure compliance with the nation’s marine resource laws and take enforcement action when these laws are violated. All OLE work supports the core mission mandates of NOAA Fisheries—maximizing productivity of sustainable fisheries and fishing communities and protection, recovery, and conservation of protected species. OLE in Alaska focuses on outreach to help prevent or minimize infractions.

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The USCG serves as the primary agency for at- sea fisheries enforcement (USCG 2019). The USCG, in coordination with other federal and state agencies, enforces marine resource management and protection regimes to preserve healthy stocks of fish and other living marine resources. The USCG objectives are to prevent encroachment of the U.S. EEZ, ensure compliance with domestic fisheries regulations, and ensure compliance with international agreements. The USCG makes an annual report to the Council on resources applied to fishery enforcement in the previous year, including numbers of boardings. It also details numbers of violations by year, lives lost at sea, safety issues, and any changes in regulations. The Coast Guard conducts a wide range of activities for education and prevention; law enforcement; emergency response and containment; and disaster recovery. These activities lead to projecting federal law enforcement presence over the entire U.S. Exclusive Economic Zone, covering nearly 3.4 million square miles of ocean; ensure compliance with fisheries and marine protected species regulations on domestic vessels; and preventing over-fishing, reducing mortality of protected species, and protecting marine habitats by enforcing domestic fishing laws and regulations. The Seventeenth Coast Guard District is responsible for the largest amount of coastline and one of the largest areas of responsibility within the Coast Guard. It is also home to one of the most productive fisheries in the world. The D17 Response division is responsible for search and rescue, maritime law enforcement, and incident/pollution response within the Seventeenth District's area of responsibility (USCG 2019).

The primary responsibility for enforcing fish and wildlife-related statutes and regulations in Alaska lies with the Alaska Department of Public Safety, through its Division of Alaska Wildlife Troopers (ADFG 2019b). The division also enforces other types of regulations passed by the Board of Game and the Board of Fisheries. This includes those designed to protect Alaska’s native species from harmful invasive species, prevent importation of exotic pets, and prevent illegal export of animal parts from Alaska. Biologists and other staff of the ADFG sometimes participate in enforcement activities and assist the Wildlife Troopers as needed; however, law enforcement is not a primary function of ADFG (ADFG 2019b).

Details of any planned education and training for interest groups

The Council provides a range of opportunities for stakeholder education and input into management required by federal statute and implemented through its standard operating procedures (NPFMC 2012). Descriptions of stakeholder consultation procedures available on the Council website identify several elements of Council procedures that enable the distribution of information to stakeholders and the provision of public comment to management.

The Northern Bering Sea Research Area (NBSRA) was implemented in 2008 and prohibited bottom trawling in the northern part of the Bering Sea. The objective of the Council was to develop a research plan that would provide better data to allow for increased understanding of the potential impacts of trawling on the benthic and epibenthic fauna of the northern Bering Sea before any commercial trawling was authorized (NPFMC 2019e). The Council requested that the Alaska Fisheries Science Center (AFSC) develop a research plan and a discussion paper that compiles existing information on the NBSRA and review relevant data on the northern Bering sea ecosystem (NPFMC 2019e).

The Council has signed a Memorandum of Understanding (MOU) with 4 State agencies and 10 Federal agencies to create the Alaska Marine Ecosystem Forum (AMEF). The AMEF seeks to improve coordination and understanding between the agencies on issues of shared responsibilities related to the marine ecosystems off Alaska’s coast. The purpose of the forum is to: promote information and dialogue exchange; improve agency coordination by sharing data and priorities; allow agencies to understand the ecosystem impact of other activities; and provide opportunities for joint work and problem solving (NPFMC 2019). The Council also developed an Aleutian Islands fishery Ecosystem Plan (AIFEP) and a Bering Sea Fishery Ecosystem Plan (BS FEP). These plans are intended to be an educational tool and resource that can provide the Council with an ecosystem context for fishery management and policy decisions (NPFMC 2019).

Dispute Resolution Legal disputes are handled under the Administrative Procedures Act, which governs the process by which federal agencies (e.g. NOAA/NMFS) develop and issue regulations. Opportunities are provided for the public to comment on notices of proposed rulemaking (http://www.nmfs.noaa.gov/pr/pdfs/laws/apa.pdf). NOAA has an extensive Dispute Resolution Process, defined by the Administrative Dispute Resolution Act of 1996, Pub. L. No. 104-320. The Council resolves disputes by majority vote as required in section 302 of the MSRA (MRSA 2007). All stakeholders have an opportunity for input prior to the decision by the Secretary of Commerce. Any disputes remaining following adoption of regulations/rules may be resolved through the federal court system. The MSRA requires discussions and decisions to take place in public sessions using publicly available information, which ensures transparency in the process (IFC, 2014). In addition, the Council has an Alternative Dispute Resolution (ADR) process that consists of several approaches used to resolve conflict other than litigation if possible. The ADR process uses mediation, consultation and facilitated problem solving to resolve disputes in a confidential manner (NOAA 2019).

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Date of the next review and audit of the management plan The annual management cycle and activities related to groundfish, including BSAI and GOA Alaska Pacific pollock fisheries management, contain extensive points of review detailed in the Council Operating Procedures (NPFMC 2012). These involve specific review of actions taken by the SSC, and Advisory Panel. Management measures are implemented annually with harvest specifications (ABCs and OYs) identified for each year. These actions are specified in detail in the Council Operating Procedures (NPFMC 2012). Final harvest specifications are implemented by mid-February each year to replace those already in effect for that year and based on new information contained in the latest groundfish SAFE reports (NPFMC 2019). The next NPFMC Council meeting is scheduled for June 2019.

7.4.1 Principle 3 Performance Indicator scores and rationales

The management system exists within an appropriate legal and/or customary framework which ensures that it: - Is capable of delivering sustainability in the UoA(s); PI 3.1.1 - Observes the legal rights created explicitly or established by custom of people dependent on fishing for food or livelihood; and - Incorporates an appropriate dispute resolution framework

Scoring Issue SG 60 SG 80 SG 100 Compatibility of laws or standards with effective management There is an effective national There is an effective national There is an effective national legal system and a legal system and organised legal system and binding framework for cooperation and effective cooperation procedures governing Guide with other parties, where with other parties, where cooperation with other a necessary, to deliver necessary, to deliver parties which delivers post management outcomes management outcomes management outcomes consistent with MSC consistent with MSC consistent with MSC Principles 1 and 2 Principles 1 and 2. Principles 1 and 2.

Met? Yes Yes Yes

Rationale

Management of the BSAI and GOA fisheries is carried out under the authority of the federal Magnuson-Stevens Fishery Conservation and Management Act (MSA), first passed in 1976 and most recently reauthorized in 2006. The MSRA is the principal law governing the harvest of fishery resources within the federal portion of the U.S. 200-mile zone. Under the MSRA, the North Pacific Fishery Management Council (NPFMC) recommends management actions to the National Marine Fisheries Service (NMFS) for approval. In addition to the MSA, the Council adheres to a suite of “other applicable laws:” the National Environmental Policy Act (NEPA), the Endangered Species Act (ESA), the Marine Mammal Protection Act (MMPA), the Migratory Bird Treaty Act (MBTA); the Administrative Procedure Act (APA), Paperwork Reduction Act (PRA): Regulatory Flexibility Act (RFA): Coastal Zone Management Act (CZMA): and other relevant U.S. laws, Executive Orders and regulations. In addition, Alaska natives have rights that are taken into account in the management of the fishery, coordinated by NMFS.

Internationally, the BSAI and GOA AK Pacific cod fisheries are conducted in a manner consistent with provisions of the U.N. FAO Code of Conduct. The fishery is also governed by the U.S. High Seas Fishing Compliance Act of 1995. This federal legislation implements the U.N. Agreement to Promote Compliance with International Conservation and Management Measures by Fishing Vessels on the High Seas. The management of the fishery complies with the Migratory Bird Act Treaty, and the NMFS have instituted a number of regulations to further reduce seabird interactions in the fishery.

The Council relies on a consensus approach among advisory bodies with room for minority reports should these groups fail to reach consensus (NPFMC 2009). The Council resolves disputes (after weighing staff reports, advisory body reports, NMFS legal counsel advice, and public testimony) by majority vote held in public session as required in Section 302 of the MSRA. All stakeholders have an opportunity for input prior to the decision by the Secretary of Commerce. Legal action may also be used by those individuals or groups dissatisfied with the decisions made by the

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Council and NMFS through the federal court system. The fishery has met the SG100 level for this scoring issue for all UoAs.

Resolution of disputes The management system The management system The management system incorporates or is subject by incorporates or is subject by incorporates or is subject by law to a mechanism for the law to a transparent law to a transparent for the resolution for the resolution Guide resolution of legal disputes mechanism mechanism b arising within the system. of legal disputes which is of legal disputes that is post considered to be effective appropriate to the context of in dealing with most issues the fishery and has been and that is appropriate to the tested and proven to be context of the UoA. effective. Met? Yes Yes Yes

Rationale

Legal disputes are handled under the Administrative Procedures Act, which governs the process by which federal agencies (e.g. NOAA/NMFS) develop and issue regulations. Opportunities are provided for the public to comment on notices of proposed rulemaking (http://www.nmfs.noaa.gov/pr/pdfs/laws/apa.pdf). NOAA has an extensive Dispute Resolution Process, defined by the Administrative Dispute Resolution Act of 1996, Pub. L. No. 104-320. The Council resolves disputes by majority vote as required in section 302 of the MSRA. All stakeholders have an opportunity for input prior to the decision by the Secretary of Commerce. Any disputes remaining following adoption of regulations/rules may be resolved through the federal court system. The MSRA requires discussions and decisions to take place in public sessions using publicly available information, which ensures transparency in the process and is appropriate to the context of the fishery. In addition, the Council has an Alternative Dispute Resolution (ADR) process that consists of several approaches used to resolve conflict other than litigation if possible. The ADR process uses mediation, consultation and facilitated problem solving to resolve disputes in a confidential manner (NOAA 2019).

The management system incorporates, and is subject by law, a transparent mechanism for the resolution of legal disputes that is appropriate to the context of the fishery and has been tested and proven to be effective. The SG 100 level is met for this scoring issue for all UoAs.

Respect for rights The management system has The management system has The management system has a mechanism to generally a mechanism to observe the a mechanism to formally respect the legal rights legal rights created explicitly commit to the legal rights created explicitly or or established by custom of created explicitly or c Guide established by custom of people dependent on fishing established by custom of post people dependent on fishing for food or livelihood in a people dependent on fishing for food or livelihood in a manner consistent with the for food and livelihood in a manner consistent with the objectives of MSC Principles manner consistent with the objectives of MSC Principles 1 and 2. objectives of MSC Principles 1 and 2. 1 and 2. Met? Yes Yes Yes

Rationale

The MSRA states that “Conservation and management measures shall, consistent with the conservation requirements of this Act (including the prevention of overfishing and rebuilding of overfished stocks) take into account the importance of fishery resources to fishing communities by utilizing economic and social data to provide for the sustained participation of such communities and to the extent practicable, minimize adverse economic impacts on such communities. The US management system has a mechanism to formally commit to the legal rights created explicitly for First Nations and Treaty Tribes. Federal agencies are required to consult with Alaska Native corporations on the same basis as Federally recognized Indian Tribes under E.O. 13175 (NOAA 2013). The relationship between Federally recognized Indian Tribes and the federal government is one of sovereign to sovereign and has been described at length by the federal judiciary and referred to in federal law promoting tribal self-determination and self- governance. The fishery has met the SG100 level for this scoring issue for all UoAs.

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References

NOAA 2019; NOAA 2013; MSRA, 2007; UNCLOS, 1982, NPFMC 2009

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80

Information gap indicator Information sufficient to score PI

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

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The management system has effective consultation processes that are open to interested and affected parties PI 3.1.2 The roles and responsibilities of organisations and individuals who are involved in the management process are clear and understood by all relevant parties

Scoring Issue SG 60 SG 80 SG 100 Roles and responsibilities Organisations and individuals Organisations and individuals Organisations and individuals involved in the management involved in the management involved in the management process have been identified. process have been identified. process have been identified. a Guide Functions, roles and Functions, roles and Functions, roles and post responsibilities are generally responsibilities are explicitly responsibilities are explicitly understood. defined and well defined and well understood for key areas of understood for all areas of responsibility and interaction. responsibility and interaction. Met? Yes Yes Yes

Rationale

The MSRA and amendments to the MSRA, in addition to other relevant Acts, mandate that the functions, roles and responsibilities are well understood and explicitly defined for key areas of responsibility and interaction. Under the MSRA, the Council recommends management actions to the NMFS for approval. Ultimate decision authority is placed with the Secretary of Commerce. Such measures are implemented by NMFS Alaska Regional office and enforced by the NOAA Office of Law Enforcement, the U.S. Coast Guard 17th District, and State of Alaska State Troopers. These management authorities are clearly defined in law and are functional. The fishery has met the SG100 level for this scoring issue for all UoAs.

Consultation processes The management system The management system The management system includes consultation includes consultation includes consultation processes that obtain processes that regularly processes that regularly relevant information from seek and accept relevant seek and accept relevant b Guide the main affected parties, information, including local information, including local post including local knowledge, to knowledge. The management knowledge. The management inform the management system demonstrates system demonstrates system. consideration of the consideration of the information obtained. information and explains how it is used or not used. Met? Yes Yes Yes

Rationale

NOAA/NMFS has several processes that regularly seek and accept relevant information, including local knowledge. NOAA Fisheries partners with federal agencies and federally recognized tribes to advise and collaborate on activities that might impact endangered and threatened species, marine mammals, and important marine habitats. NMFS has also developed a Public Consultation Tracking System (PCTS), which is an information management system covering NMFS (NOAA Fisheries) consultations under the ESA and under the Magnuson-Stevens Fishery Conservation and Management Act sections 305(b)(2) & 305(b)(4) EFH. Information is publicly available that explains how information and management decisions are made, consultations with the various agencies and inter-agency sectors, council representation, etc. The Council meets five times a year according to a pre-announced schedule. Notice of meetings is made through the Federal Register. Meeting agendas are widely distributed before each meeting and accessible on the NPFMC website. Most Council meetings take eight days, with individual advisory body meetings occurring during the course of the week. All meetings are open to the public, except for a short-closed Council session in which the Council deals with in which the Council deals with personnel, administrative, or litigation issues.

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Participation The consultation process The consultation process provides opportunity for all provides opportunity and Guide interested and affected encouragement for all c parties to be involved. interested and affected post parties to be involved, and facilitates their effective engagement. Met? Yes Yes

Rationale

All meetings are open to the public and meeting information is available on the NPFMC website. Dates and locations of Council meetings are publicized in advance. Several upcoming webinars are posted on the NPFMC website, where interested parties can participate and receive information pertaining to Groundfish subcommittees, catch estimation methodology, electronic monitoring and from various other adhoc committees and subcommittees. The NPFMC website also provides a manual called “Navigating the Council Process” explaining the fishery management process in nontechnical language.

There are several other procedures that promote the engagement of stakeholders, including consultation among agencies, universities and stakeholders on needed research and scientific information, public review and comment of data and analysis, public attendance and comment periods at advisory body meetings, representation on advisory bodies and the Council, Council newsletter, blogpost, twitter feed, public review periods for regulations and FMP amendments, agency responses to review comments, and opportunity for legal challenges to Council actions.

The consultation process provides opportunity and encouragement for all interested and affected parties to be involved, and facilitates their effective engagement; and therefore, meets the SG 100 level for this scoring issue for all UoAs.

References

MSRA 2007, NPFMC 2019; . Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80

Information gap indicator Information sufficient to score PI

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

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The management policy has clear long-term objectives to guide decision-making that PI 3.1.3 are consistent with MSC Fisheries Standard, and incorporates the precautionary approach

Scoring Issue SG 60 SG 80 SG 100 Objectives Long-term objectives to guide Clear long-term objectives Clear long-term objectives decision-making, consistent that guide decision-making, that guide decision-making, Guide with the MSC Fisheries consistent with MSC consistent with MSC a Standard and the Fisheries Standard and the Fisheries Standard and the post precautionary approach, are precautionary approach are precautionary approach, are implicit within management explicit within management explicit within and required policy. policy. by management policy. Met? Yes Yes Yes

Rationale

The MSRA, National Standards and other legislation include explicit, well-defined short- and long-term objectives for sustainable fishing and conservation. NMFS incorporated precautionary concepts to ensure compliance with the Sustainable Fisheries Act 1996, which includes 10 National Standards for conservation and management of fisheries in the U.S. The Council have several goals and objectives in the BSAI and GOA FMPs that have been established in order to promote a stable planning environment for the seafood industry, including marine recreation events, while also maintaining the health of the resource and the environment (NPFMC 2018; 2018a). The fishery has met the SG100 level for this scoring issue for all UoAs.

References

NPFMC 2018; 2018a; UNCLOS, 1982; MSRA, 2007

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80

Information gap indicator Information sufficient to score PI

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

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The fishery-specific management system has clear, specific objectives designed to PI 3.2.1 achieve the outcomes expressed by MSC’s Principles 1 and 2

Scoring Issue SG 60 SG 80 SG 100 Objectives Objectives, which are Short and long-term Well defined and measurable broadly consistent with objectives, which are short and long-term achieving the outcomes consistent with achieving the objectives, which are Guide expressed by MSC’s outcomes expressed by demonstrably consistent with a Principles 1 and 2, are MSC’s Principles 1 and 2, are achieving the outcomes post implicit within the fishery- explicit within the fishery- expressed by MSC’s Principles specific management system. specific management system. 1 and 2, are explicit within the fishery-specific management system. Met? Yes Yes Yes

Rationale

In addition to the National Standard Guidelines that provide objectives for federally managed fisheries, the Council has established nine specific objectives, each with several sub-objectives, for BSAI and Gulf of Alaska groundfish fisheries in Alaska: • Prevent Overfishing; • Promote Sustainable Fisheries and Communities; • Preserve Food Web; • Manage Incidental Catch and Reduce Bycatch and Waste; • Avoid Impacts to Seabirds and Marine Mammals; • Reduce and Avoid Impacts to Habitat; • Promote Equitable and Efficient Use of Fishery Resources; • Increase Alaska Native Consultation; • Improve Data Quality, Monitoring and Enforcement.

The 45 sub-objectives substantially and explicitly support the outcomes of MSC P1 and P2.

Guiding principles for the BOF state managed fisheries can be found managed fisheries can be found here (5 AAC 28.263), and includes provisions such as “conservation of the groundfish resource to ensure sustained yield, which requires that the allowable catch in any fishery be based upon the biological abundance of the stock”. Details on the state P. cod fisheries can be found on the ADFG website, and include reports covering a wide range of issues pertaining to Pacific cod. The fishery has met the SG100 level for this scoring issue for all UoAs.

References

NPFMC 2018; 2018a; 2019, BOF State-managed fisheries, http://www.touchngo.com/lglcntr/akstats/aac/title05/chapter028/section089.htm

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80

Information gap indicator Information sufficient to score PI

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

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Condition number (if relevant)

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The fishery-specific management system includes effective decision-making processes PI 3.2.2 that result in measures and strategies to achieve the objectives, and has an appropriate approach to actual disputes in the fishery

Scoring Issue SG 60 SG 80 SG 100 Decision-making processes There are some decision- There are established Guide making processes in place decision-making processes a that result in measures and that result in measures and post strategies to achieve the strategies to achieve the fishery-specific objectives. fishery-specific objectives. Met? Yes Yes

Rationale

Decision-making for North Pacific groundfish occurs primarily within the North Pacific Fishery Management Council process. However, National Marine Fisheries Service (NMFS), the states of Alaska, Washington and Oregon, and numerous industry, academic, and NGO stakeholders participate in the process. The process used by the Council for decision-making is described in the guide for navigating the Council process (NPFMC 2009) and the Council Operating Procedures (NPFMC 2012a). The NPFMC is the regional council responsible for managing North Pacific Ocean fisheries in the Federal EEZ off the coast of Alaska (NPFMC 2009). The Council's geographic area of authority includes the Exclusive Economic Zone (EEZ) of the Arctic Ocean and Pacific Ocean seaward of Alaska, including the BSAI and GOA. Federal fisheries for Alaska Pacific pollock are under the jurisdiction of the BSAI Groundfish Fishery Management Plan (FMP), the GOA FMP and the MSRA. Parallel fisheries for pollock take place in state waters around Kodiak Island, in the Chignik Area, and along the South Alaska Peninsula (ADFG 2019). An open access state-waters fishery takes place in Prince William Sound (PWS); and the state management plan (5 AAC 28.263) has measures to reduce potential impacts on Steller sea lions, reduce bycatch and allocate the GHL (ADFG 2019).

The pollock fishery operates under the American Fisheries Act (AFA), signed into law in October 1998 (NPFMC 2019e). The AFA tightened U.S. ownership standards for U.S. fishing vessels under the Anti-reflagging Act and provided the BSAI pollock fleet the opportunity to conduct their fishery in a more rational manner while protecting non- AFA participants in the other fisheries. The AFA eliminated the race for pollock through the establishment of cooperatives with specific provisions for their allocations, structure, and participation by catcher vessels and processing plants, as well as annual reporting requirements and excessive share limits. In response to a directive in the AFA, the Council added measures to protect other fisheries from adverse effects arising from the exclusive pollock allocation. Cooperative fishing began under the AFA program in 1999. The AFA affected the pollock industry through capacity reduction, efficiency increase, regulatory bycatch reduction, a higher portion of utilized fish, and higher valued products (NPFMC 2019e, MRAG 2016, 2016a). The fishery meets the SG80 level for this scoring issue for all UoAs.

Responsiveness of decision-making processes Decision-making processes Decision-making processes Decision-making processes respond to serious issues respond to serious and respond to all issues identified in relevant other important issues identified in relevant research, monitoring, identified in relevant research, monitoring, b Guide evaluation and consultation, research, monitoring, evaluation and consultation, post in a transparent, timely and evaluation and consultation, in a transparent, timely and adaptive manner and take in a transparent, timely and adaptive manner and take some account of the wider adaptive manner and take account of the wider implications of decisions. account of the wider implications of decisions. implications of decisions. Met? Yes Yes No

Rationale

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Within the Council, decision-making processes are designed by law and practice to be responsive to issues raised from a number of sources. Processes are transparent, timely and adaptive to wider circumstances. The Council and its groundfish advisory bodies meet five times a year. Between meetings, committees composed of stakeholders, scientists and managers hold public meeting to consider specific problems and to evaluate management programs, developing recommendations for Council action. The BSAI and GOA FMPs state: The Council will maintain a continuing review of the fisheries managed under this FMP through the following methods: l. Maintain close liaison with the management agencies involved, usually the Alaska Department of Fish and Game and NMFS, to monitor the development of the fisheries and the activity in the fisheries. 2. Promote research to increase their knowledge of the fishery and the resource, either through Council funding or by recommending research projects to other agencies. 3. Conduct public hearings at appropriate times and in appropriate locations to hear testimony on the effectiveness of the management plans and requests for changes. 4. Consider all information gained from the above activities and develop, if necessary, amendments to the FMP. The Council will also hold public hearings on proposed amendments prior to forwarding them to the Secretary for possible adoption.

The Council also works very closely with the Alaska Department of Fish and Game (ADFG) and the Alaska Board of Fisheries (BOF) to coordinate management programs in federal and state waters (0-3 nm from shore).

While decision-making processes respond to important issues identified in relevant research, monitoring, evaluation and consultation, in a transparent, timely and adaptive manner, it cannot be said with a high degree of certainty that the decision-making processes respond to all issues identified. More information is needed. The scoring level 80 is met for this scoring issue, but the SG100 level is not met for all UoAs.

Use of precautionary approach Decision-making processes c Guide use the precautionary post approach and are based on best available information.

Met? Yes

Rationale

The Council management approach has incorporated forward looking conservation measures that address differing levels of uncertainty. This management approach has been labelled the precautionary approach. Recognizing that potential changes in productivity may be caused by fluctuations in natural oceanographic conditions, fisheries, and other, non-fishing activities, the Council intends to continue to take appropriate measures to insure the continued sustainability of the managed species (NPFMC 2018, 2018a). The scoring level 80 is met for this scoring issue for all UoAs.

Accountability and transparency of management system and decision-making process Some information on the Information on the fishery’s Formal reporting to all fishery’s performance and performance and interested stakeholders management action is management action is provides comprehensive generally available on available on request, and information on the fishery’s request to stakeholders. explanations are provided for performance and and Guide any actions or lack of action management actions d associated with findings and describes how the post relevant recommendations management system emerging from research, responded to findings and monitoring, evaluation and relevant recommendations review activity. emerging from research, monitoring, evaluation and review activity. Met? Yes Yes Yes

Rationale

At the federal level, the Council is required to create a record of decisions. Actions taken by the Council are recommendations to the Secretary of Commerce who holed the ultimate decision authority but, in most instances, 124 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019 delegates this authority to the NMFS or NOAA Fisheries level. A formal rulemaking process is conducted under which federal regulations are issued as proposed rules subject to public comment. Responses to stakeholder comments are included in the final rule.

Stakeholders also receive comprehensive reporting on management actions through live-blogs of Council meetings, meeting minutes and the Council newsletter.

The BOF meets four to six times per year in communities around the state to consider proposed changes to fisheries regulations around the state. The board uses the biological and socioeconomic information provided by the Alaska Department of Fish and Game, public comment received from people inside and outside of the state, and guidance from the Alaska Department of Public Safety and Alaska Department of Law when creating regulations that are sound and enforceable. The BOF conducts regular reviews of groundfish fisheries within state waters of Alaska, in which external parties (i.e., consultants contracted by various user groups, experts that department staff has asked for input, etc.) have full opportunity for critical comment. The Board’s review of FMPs, amendments and other regulatory changes include input from ADFG staff, Regional Fish & Game advisory committees, non-ADFG scientists, industry, environmental non-governmental organizations, stakeholders and the general public. The scoring level 100 is met for this scoring issue for all UoAs.

Approach to disputes Although the management The management system or The management system or authority or fishery may be fishery is attempting to fishery acts proactively to subject to continuing court comply in a timely fashion avoid legal disputes or rapidly Guide challenges, it is not indicating with judicial decisions arising implements judicial decisions e a disrespect or defiance of from any legal challenges. arising from legal challenges. post the law by repeatedly violating the same law or regulation necessary for the sustainability for the fishery. Met? Yes Yes Yes

Rationale

Legal disputes are handled under the Administrative Procedures Act, which governs the process by which federal agencies (e.g. NOAA/NMFS) develop and issue regulations. Opportunities are provided for the public to comment on notices of proposed rulemaking (http://www.nmfs.noaa.gov/pr/pdfs/laws/apa.pdf). NOAA has an extensive Dispute Resolution Process, defined by the Administrative Dispute Resolution Act of 1996, Pub. L. No. 104-320. The Council resolves disputes by majority vote as required in section 302 of the MSRA. All stakeholders have an opportunity for input prior to the decision by the Secretary of Commerce. Any disputes remaining following adoption of regulations/rules may be resolved through the federal court system. The MSRA requires discussions and decisions to take place in public sessions using publicly available information, which ensures transparency in the process. In addition, the Council has an Alternative Dispute Resolution (ADR) process that consists of several approaches used to resolve conflict other than litigation if possible. The ADR process uses mediation, consultation and facilitated problem solving to resolve disputes in a confidential manner (NOAA 2019.).

The Council conducts its ongoing decision processes in a manner designed to avoid legal disputes. It places a heavy emphasis on the use of advisory committees and stakeholder input as new regulations or programs are developed so that differences are resolved in the design stage. In addition, the wide dissemination of information to promote transparency ensures that the probability of stakeholders being caught off-guard is minimal. A score of 100 is awarded for this scoring issue for all UoAs.

References

NPFMC 2019e, MRAG 2016, 2016a; NPFMC 2009; NPFMC 2012a; NPFMC 2018; 2018a, NOAA 2019, ADFG 2019

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80

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Information gap indicator Information sufficient to score PI

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

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Monitoring, control and surveillance mechanisms ensure the management measures in PI 3.2.3 the fishery are enforced and complied with

Scoring Issue SG 60 SG 80 SG 100 MCS implementation Monitoring, control and A monitoring, control and A comprehensive surveillance mechanisms surveillance system has monitoring, control and exist, and are implemented in been implemented in the surveillance system has been Guide the fishery and there is a fishery and has demonstrated implemented in the fishery a reasonable expectation that an ability to enforce relevant and has demonstrated a post they are effective. management measures, consistent ability to enforce strategies and/or rules. relevant management measures, strategies and/or rules. Met? Yes Yes Yes

Rationale Under the Federal North Pacific Groundfish Observer Program a comprehensive monitoring, control and surveillance system has been implemented. All the UoAs’ vessels are required to carry observers as requested, to collect data on fishing effort, total catch by species, and biological data; characterize marine mammal and sea bird interactions. Vessels carry VMS to monitor location. At-sea and shore-side enforcement is carried out by the Alaska State Troopers, NMFS Office of Law Enforcement (OLE.) and the US Coast Guard (NOAA 2019a; USCG 2019). Monitoring, control and surveillance actions include: • Fishing permit requirements • Fishing permit and fishing vessel registers • Vessel and gear marking requirements • Fishing gear and method restrictions • Reporting requirements for catch, effort, and catch disposition • Vessel inspections • Record keeping requirements • Auditing of licensed fish buyers • Control of transshipment • Monitored unloads of fish • Information management and intelligence analysis • Analysis of catch and effort reporting and comparison with landing and trade data to confirm accuracy • Boarding and inspection by fishery officers at sea • Aerial and surface surveillance

The SG100 level is met for this scoring issue for all UoAs.

Sanctions Sanctions to deal with non- Sanctions to deal with non- Sanctions to deal with non- compliance exist, Guide compliance exist and there is are compliance exist, are b some evidence that they are consistently applied and consistently applied and post applied. thought to provide effective demonstrably provide deterrence. effective deterrence. Met? Yes Yes No

Rationale

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Penalties for fisheries related fisheries related violations include fines; forfeiture of fish, vessels, other property and quota; and imprisonment. With respect to permit sanctions, where applicable, the statutes that NOAA enforces generally provide broad authority to suspend or revoke permits. The SG 80 Level is met for all UoAs for this scoring issue, but more information is needed to reach the SG100 level.

Compliance Fishers are generally Some evidence exists to There is a high degree of thought to comply with the demonstrate fishers comply confidence that fishers management system for the with the management system comply with the management c Guide fishery under assessment, under assessment, including, system under assessment, post including, when required, when required, providing including, providing providing information of information of importance to information of importance to importance to the effective the effective management of the effective management of management of the fishery. the fishery. the fishery. Met? Yes Yes No

Rationale

Immigration and Customs Enforcement, U.S. Fish and Wildlife Service, monitor compliance and investigate potential violations of the statutes and regulations enforced by NOAA. The Cooperative Enforcement Agreements and Joint Enforcement Agreements also in place authorize state and U.S. territorial marine conservation law enforcement officers to enforce federal laws and regulations. These agreements also include a formal operations plan that transfers funds to perform enforcement services that are in support of Federal Regulations (NOAA, 2019a.).

More evidence needs to be provided to verify if the fishery is in compliance with the management system. The SG80 level is met for this scoring issue for all UoAs, but the SG100 level has not been met.

Systematic non-compliance d Guide There is no evidence of post systematic non-compliance.

Met? Yes

Rationale

To the team’s knowledge, no evidence of systematic non-compliance exists in these fisheries. The SG80 level is met for all UoAs for this scoring issue.

References

NOAA 2019; USCG 2014

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80 Information sufficient to score PI, but more Information gap indicator information is needed to score at the SG100 level.

Overall Performance Indicator scores added from Client and Peer Review Draft Report Overall Performance Indicator score

Condition number (if relevant)

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There is a system of monitoring and evaluating the performance of the fishery-specific PI 3.2.4 management system against its objectives There is effective and timely review of the fishery-specific management system

Scoring Issue SG 60 SG 80 SG 100 Evaluation coverage There are mechanisms in There are mechanisms in There are mechanisms in a Guide place to evaluate some parts place to evaluate key parts of place to evaluate all parts of post of the fishery-specific the fishery-specific the fishery-specific management system. management system. management system. Met? Yes Yes Yes

Rationale

The Council meets five times a year and has mechanisms in place to evaluate all parts of the management system. The annual management process is detailed in Council Operating Procedure (NPFMC 2009; 2012). Under the annual cycle, eligible management measures are put into place and adjusted through routine in-season evaluation and actions. The comprehensive amendments to the fishery management plan, averaging about two per year since the implementation of the council system, demonstrate the wide range of management topics evaluated by the Council. Congress reviews the MSA every five years and amends it as necessary. The SG100 level is met for all UoAs for this scoring issue.

Internal and/or external review The fishery-specific The fishery-specific The fishery-specific Guide management system is management system is management system is b subject to occasional subject to regular internal subject to regular internal post internal review. and occasional external and external review. review. Met? Yes Yes No

Rationale

The Council management system undergoes extensive internal review as part of the annual harvest specification process (see scoring issue a). All aspects are available for review through the Council Advisory Panel, SSC, public comment, and council member discussions. All Council recommendations are externally reviewed by NMFS, NOAA, and the Department of Commerce, and NOAA. OGC reviews proposed actions to assure compliance with the MSRA. The Center for Independent Experts periodically reviews the Alaska management and stock assessments. More information is needed to understand if management is subject to regular internal and external review. The SG80 level is met for all UoAs for this scoring issue, but more information is needed to see if the SG100 level is met.

References

NPFMC 2009; 2012

Draft scoring range and information gap indicator added at Announcement Comment Draft Report

Draft scoring range ≥80 Information sufficient to score PI, but more Information gap indicator information is needed to score at the SG 100 level

Overall Performance Indicator scores added from Client and Peer Review Draft Report 129 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Overall Performance Indicator score

Condition number (if relevant)

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8 References

Principle 1 References:

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The role of larval retention and transport features in mortality and potential gene flow of walleye pollock. J. Fish. Biol. 51(Suppl. A):135-154. Bailey, K.M., T.J. Quinn II, P. Bentzen, and W.S. Grant. 1999. Population structure and dynamics of walleye pollock, Theragra chalcogramma. Advances in Mar. Biol. 37: 179-255. Bailey, K.M., Quinn, T.J., Bentzen, P., et al. 2000. Population structure and dynamics of walleye pollock, Theragra chalcogramma. Pp 179-255. In Southward, A.J., Tyler, P.A., and Young, C.M. (eds) Advances in Marine Biology Book Series. Volume: 37 Springer. Barbeaux, S., J. Ianelli, S. Gaichas, and M. Wilkins. 2018. Aleutian Islands walleye pollock SAFE. In: Stock assessment and fishery evaluation report for the groundfish resources of the Bering Sea/Aleutian Islands regions. North Pac. Fish. Mgmt. Council, P.O. Box 103136, Anchorage, AK 99510., Section 1A Brodziak, J., J. Ianelli, K. Lorenzen, and R.D. Methot Jr. (eds). 2011. Estimating natural mortality in stock assessment applications. U.S. Dep. Commer., NOAA Tech. Memo. NMFS-F/SPO-119, 38 p. Cadrin S., et al. 2015. Simulation testing the robustness of stock assessment models to error: some results from the ICES strategic initiative on stock assessment methods. ICES Journal of Marine Science 72:19-30. Ciannelli, L. Bailey, K. M.; Chan, K.-S.; et al. 2007. Phenological and geographical patterns of walleye pollock (Theragra chalcogramma) spawning in the western Gulf of Alaska. Canadian Journal of Fisheries and Aquatic Sciences. 64: 713-722. CIE 2012. Center for Independent Experts (CIE) Review of the November 2010 Biological Opinion on the Bering Sea and Aleutian Islands and Gulf of Alaska Groundfish Fisheries. Available at https://alaskafisheries.noaa.gov/protectedresources/stellers/esa/biop/final/cie/review.htm Deroba J., Butterworth D., Methot R., De Oliveira J. A., Fernandez C., Nielsen A., Cadrin S., et al. 2015. Simulation testing the robustness of stock assessment models to error: some results from the ICES strategic initiative on stock assessment methods. ICES Journal of Marine Science 72:19-30. De Robertis, A., Hjellvik, V., Williamson, N. J., and Wilson, C. D. 2008. Silent ships do not always encounter more fish: comparison of acoustic backscatter recorded by a noise-reduced and a conventional research vessel. – ICES Journal of Marine Science, 65: 623–635. Dorn, M., Aydin, K., Fissel, B., Palsson W., Spalinger, K., Stienssen, S., Williams K, and Zador, S., 2018.Assessment of the walleye pollock stock in the Gulf of Alaska. In Stock Assessment and Fishery Evaluation Report for Groundfish Resources of the Gulf of Alaska. Prepared by the Gulf of Alaska Groundfish Plan Team, North Pacific Fishery Management Council, P.O. Box 103136, Anchorage, AK 99510. North Pacific Fisheries Management Council, Anchorage, AK. https://www.afsc.noaa.gov/REFM/Docs/2018/GOA/GOApollock.pdf Dougherty, A. B., Bailey, K. M., and Mier, K. L. 2007. Interannual differences in growth and hatch date distributions of age-0-year walleye pollock Theragra chalcogramma (Pallas) sampled from the Shumagin Islands region of the Gulf of Alaska, 1985-2001. Journal of Fish Biology. .71: 763-780. Dougherty, A.; Bailey, K.; Vance, T.; et al. 2012. Underlying causes of habitat-associated differences in size of age-0 walleye pollock (Theragra chalcogramma) in the Gulf of Alaska. Marine Biology 159: 1733-1744. Durant, J. M. Hidalgo, M., Rouyer, T. et al. 2013. Population growth across heterogeneous environments: effects of harvesting and age structure. Marine Ecology Progress Series 480: 277286 Fissel, B., Dalton, M., Felthoven, R., Garber-Yonts, B., Haynie, A., Himes-Cornell, A., Kasperski, S., Lee, J., Lew, D., and Seung, C. 2014. “Stock Assessment and Fishery Evaluation Report for the Groundfish Fisheries of the Gulf of Alaska and Bering Sea/Aleutian Islands Area: Economic Status of the Groundfish Fisheries Off Alaska, 2013”. Economic and Social Sciences Research Program, REFM, AFSC, NMFS, NOAA 7600 Sand Point Way N.E., Seattle, Washington. FitzGerald, J.L., Thorrold, S.R., Bailey, K.M., et al. 2004. Elemental signatures in otoliths of larval walleye pollock (Theragra chalcogramma) from the northeast Pacific Ocean. Fishery Bulletin 102: 604-616.

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Fournier, D. A., H. J. Skaug, J. Ancheta, J. Ianelli, A. Magnusson, M. N. Maunder, A. Nielsen, and J. Sibert. 2012. AD Model Builder: using automatic differentiation for statistical inference of highly parameterized complex nonlinear models. Optimization Methods and Software 27:233-249. Gaichas, S.K.; Aydin, K. Y.; and Francis, R. C. 2010. Using food web model results to inform stock assessment estimates of mortality and production for ecosystem-based fisheries management. Canadian Journal of Fisheries and Aquatic Science. 67: 1490-1506. Goodman, D. Mangel, M., Parkes, G., Quinn, T., Restrepo, V., Smith, T. and K. Stokes. 2002. “Scientific Review of the Harvest Strategy Currently Used in the BSAI and GOA Groundfish Fishery Management Plans.” North Pacific Fishery Management Council, 605 West 4th Avenue, Suite 306, Anchorage, Alaska. Grant, W. S., Spies, I., and Canino, M.F. 2010. Shifting-balance stock structure in North Pacific walleye pollock (Gadus chalcogrammus). ICES Journal of Marine Science. 67: 1687-1696. Heintz, R. A.; Siddon, E, C.; Farley, E.V., Jr.; et al. 2013. Correlation between recruitment and fall condition of age-0 pollock (Theragra chalcogramma) from the eastern Bering Sea under varying climate conditions. Deep-Sea Research Part Ii-Topical Studies in Oceanography 94: 150-156 Hollowed, A.B.; Ianelli, J.N. and Livingston, P.A. 2000. Including predation mortality in stock assessments: a case study for Gulf of Alaska walleye Pollock. ICES Journal of Marine Science 57: 279-293 Holsman, K. K. and Aydin, K. 2015. Comparative methods for evaluating climate change impacts on the foraging ecology of Alaskan groundfish. Marine Ecology Progress Series 521: 217-235 Hulson, P.-J, F.; Quinn, T. J., II; Hanselman, D. H.; et al. 2013, Spatial modeling of Bering Sea walleye pollock with integrated age-structured assessment models in a changing environment, Canadian Journal Of Fisheries And Aquatic Sciences 70: 1402-1416 Ianelli, J.N., S. Kotwicki, T. Honkalehto, A. McCarthy, S. Stienessen, K. Holsman, E. Siddon, and B. Fissel. 2018. “1. Assessment of the Walleye Pollock stock in the Eastern Bering Sea.” Stock Assessment and Fishery Evaluation Report for the Groundfish Resources of the Bering Sea/Aleutian Islands Region. North Pacific Fishery Management Council, 605 West 4th Avenue, Suite 306, Anchorage, Alaska. Kotwicki, S.; and Lauth, R. R. 2013. Detecting temporal trends and environmentally driven changes in the spatial distribution of bottom fishes and crabs on the eastern Bering Sea shelf. Deep-Sea Research Part Ii-Topical Studies In Oceanography 94: 231-243 Litzow, M.A.; Mueter, F.J.; and Hobday, A J. 2014. Reassessing regime shifts in the North Pacific: incremental climate change and commercial fishing are necessary for explaining decadal-scale biological variability. Global Change Biology 20: 38-50 Methot, R. D. 2005. Technical description of the Stock Synthesis II Assessment Program. Unpubl. manuscr. National Marine Fisheries Service, Northwest Fisheries Science Center, 2725 Montlake Blvd. East, Seattle, WA 98112- 2097. 54 p. Methot, R. D. 2009. Stock assessment: operational models in support of fisheries management. In The Future of Fishery Science in North America, pp. 137–165. Ed. by R. J. Beamish, and B. J. Rothschild. Fish and Fisheries Series, 31. 736 pp. Methot, R. D., and C. R. Wetzel. 2013. Stock Synthesis: a biological and statistical framework for fish stock assessment and fishery management. Fisheries Research 142:86-99. National Marine Fisheries Service (NMFS). 2005. Final environmental impact statement for essential fish habitat identification and conservation in Alaska. National Marine Fisheries Service, Alaska Region. P.O. Box 21668, Juneau, AK 99802-1668. NMFS 2009. Magnuson-Stevens Act Provisions; Annual Catch Limits; National Standard Guidelines. Final Rule. Federal Register 74:3178-3213. NMFS. 1999. “Environmental Assessment for the Amendment 56 to the Fishery Management Plan for the Groundfish Fishery of the Bering Sea and Aleutian Islands Area and Amendment 56 to the Fishery Management Plan for Groundfish of the Gulf of Alaska.” NMFS Alaska Region Office, P.O. Box 21668, Juneau, Alaska. NMFS (National Marine Fisheries Service). 2015. North Pacific Groundfish and Halibut Observer Program 2014 Annual Report. National Oceanic and Atmospheric Administration, 709 West 9th Street. Juneau, Alaska 99802. National Research Council (NRC). 1998. Improving Fish Stock Assessments. National Academy Press, Washington, D.C. 177 pp. Patterson K. R., and G. P. Kirkwood. 1995. Comparative performance of Adapt and Laurec-Shepherd methods for estimating fish population parameters and in stock management. ICES Journal of Marine Science, 52 (2): 183-196. Pfeiffer, L. and Haynie, A.C. 2012. The effect of decreasing seasonal sea-ice cover on the winter Bering Sea pollock fishery. ICES Journal Of Marine Science 69: 1148-1159 Restrepo, V. R., Patterson, K. R., Darby, C. D., Gavaris, S., Kell, L. T., Lewy, P., Mesnil, B., Punt, A. E., Cook, R. M., O’Brien, C. M., Skagen, D. W., and G. Stefánsson. 2000. Do different methods provide accurate probability statements in the short term? ICES CM 2000/V: 08:19pp. Schirripa, M. J., Goodyear, C. P., and Methot, R. M. 2009. Testing different methods of incorporating climate data into the assessment of US West Coast sablefish. ICES J. Mar. Sci., 66: 1605–1613.

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Shepherd, J. G. 1999. Extended survivors’ analysis: An improved method for the analysis of catch-at-age data and abundance indices ICES Journal of Marine Science, 56: 584–591. Siddon, E. C., Kristiansen, T., Mueter, F., J.; et al. 2013. Spatial Match-Mismatch between Juvenile Fish and Prey Provides a Mechanism for Recruitment Variability across Contrasting Climate Conditions in the Eastern Bering Sea. PLOS ONE 8: Article Number: e84526 Stabeno, P. J.; Kachel, N. B.; Moore, S.E.; et al. 2013, Comparison of warm and cold years on the southeastern Bering Sea shelf and some implications for the ecosystem. Deep-Sea Research Part Ii-Topical Studies in Oceanography 65-70: SI: 31-45 Thompson G.G. 1999. Optimizing Harvest Control Rules in the Presence of Natural Variability and Parameter Uncertainty. Williams, K.; Punt, A. E.; Wilson, C. D.; et al. 2011. Length-selective retention of walleye pollock, Theragra chalcogramma, by midwater trawls ICES Journal Of Marine Science 68: 119-129 Yanagimoto, T., Kitamura, T., and Kobayashi, T. 2012. Genetic stock structure of walleye pollock (Theragra chalcogramma) inferred by PCR-RFLP analysis of the mitochondrial DNA and SNP analysis of nuclear DNA. Marine Genomics 7: 17-25

Principle 2 References:

ACAP. 2010. Species Assessments: Laysan Albatross Phoebastria immutabilis. Hobart, Australia. Amano, M., A. Hayano, and N. Miyazaki. 2002. Geographic variation in the skull of the ringed seal, Pusa hispida. J. Mammal. 83:370-380. Arata, J.A., P.R. Sievert, and M.B. Naughton. 2009. Status Assessment of Laysan and Black-Footed Albatrosses, North Pacific Ocean, 1923-2005. U.S. Geological Survey Scientific Investigation Report 2009-5131. 80 pp. Aydin K, Mueter F (2007) The Bering Sea - A dynamic food web perspective. Deep-Sea Research Part Ii-Topical Studies in Oceanography 54:2501-2525 Aydin K, Gaichas S, Ortiz I, Kinzey D, Friday N (2007) A comparison of the Bering Sea, Gulf of Alaska, and Aleutian Islands large marine ecosystems through food web modeling. U.S. Dep. Commer., NOAA Tech. Memo. NMFS-AFSC-178, 298p BirdLife International. 2019a. Species factsheet: Rissa tridactyla. Available at: http://www.birdlife.org. BirdLife International. 2019b. Species factsheet: Rissa brevirostris. Available at: http://www.birdlife.org. Boveng, P. L., J. L. Bengtson, T. W. Buckley, M. F. Cameron, S. P. Dahle, B. P. Kelly, B. A. Megrey, J. E. Overland, and N. J. Williamson. 2009. Status review of the spotted seal (Phoca largha). U.S. Dep. Commer., NOAA Tech. Memo. NMFS-AFSC-200, 153 p. Byrd, G.V.; Williams, J.C.; Arthukhin, Y.B.; Vyatkin, P.S. 1997. Trends in the populations of Red-legged Kittiwake Rissa brevirostris, a Bering Sea endemic. Bird Conservation International 7: 167-180. Carretta, J.V., E.M. Oleson, J. Baker, D.W. Weller, A.R. Lang, K.A. Forney, M.M. Muto, B. Hanson, A.J. Orr, H. Huber, M.S. Lowry, J. Barlow, J.E. Moore, D. Lynch, L. Carswell, and R.L. Brownell Jr. 2016. U.S. Pacific Marine Mammal Stock Assessments: 2015. U.S. Department of Commerce. NOAA Technical Memorandum NMFS- SWFSC-561. Collie JS, Hall SJ, Kaiser MJ, Poiner IR (2000) A quantitative analysis of fishing impacts on shelf-sea benthos. Journal of Animal Ecology 69:785-798. Conn, P. B., J. M. Ver Hoef, B. T. McClintock, E. E. Moreland, J. M. London, M. F. Cameron, S. P. Dahle, and P. L. Boveng. 2014. Estimating multispecies abundance using automated detection systems: ice-associated seals in the Bering Sea. Methods Ecol. Evol. 5:1280-1293. Dahlheim, M., A. York, R. Towell, J. Waite, and J. Breiwick. 2000. Harbor porpoise (Phocoena phocoena) abundance in Alaska: Bristol Bay to Southeast Alaska, 1991-1993. Mar. Mammal Sci. 16:28-45. Dahlheim, M., P. A. White, and J. Waite. 2009. Cetaceans of Southeast Alaska: distribution and seasonal occurrence. J. Biogeogr. 36(3):410-426. Denlinger, L.M. 2006. Alaska Seabird Information Series. Unpubl. Rept., U.S. Fish and Wildlife Service, Migratory Bird Management, Nongame Program, Anchorage, AK. Descamps, S.; Anker-Nilssen, T.; Barrett, R.T.; Irons, D.B.; Merkel, F.; Robertson, G.J.; Yoccoz, N.G.; Mallory, M.L.; Montevecchi, W.A.; Boertmann, D.; Artukhin, Y.; Christensen-Dalsgaard, S.; Erikstad, K.-E.; Gilchrist, H.G.; Labansen, A.L.; Lorentsen, S.-H.; Mosbech, A.; Olsen, B.; Petersen, A.; Rail, J.-F.; Renner, H.M.; Strøm, H.; Systad, G.H.; Wilhem, S.I.; Zelenskaya, L. 2017. Circumpolar dynamics of a marine top-predator track ocean warming rates. Global Change Biology 23(9): 3770–3780. 133 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

Eich, A.M., J. Roberts, and S.M. Fitzgerald. 2018. Seabird Bycatch Estimates for Alaska Groundfish Fisheries: 2016 through 2017. U.S. Dep. Commer., NOAA Tech. Memo. NMFS-F/AKR-18, 32 p. Fritz LW, Sweeney K, Johnson D (2013) Aerial and Ship-Based Surveys of Steller sea lions (Eumetopias jubatus) Conducted in Alaska June-July 2008 through 2012 and an Update on the Status and Trend of the Western Stock in Alaska. NOAA Tech. Memo. NMFS-AFSC-251:91 Gaichas SK, Odell G, et al. (2012) "Beyond the defaults: functional response parameter space and ecosystem-level fishing thresholds in dynamic food web model simulations." Canadian Journal of Fisheries and Aquatic Sciences 69(12):2077-2094 Gaichas SK, Aydin KY, et al. (2011) "What drives dynamics in the Gulf of Alaska? Integrating hypotheses of species, fishing, and climate relationships using ecosystem modeling." Canadian Journal of Fisheries and Aquatic Sciences 68(9):1553-1578. Gaichas SK, Francis RC (2008) "Network models for ecosystem-based fishery analysis: a review of concepts and application to the Gulf of Alaska marine food web." Canadian Journal of Fisheries and Aquatic Sciences 65(9):1965-1982 Gelatt, T., R. Ream, and D. Johnson. 2015. Callorhinus ursinus. The IUCN Red List of Threatened Species 2015. Available at: http://www.iucnredlist.org/details/3590/0. Gould, P., P. Ostrom, W. Walker, and K. Pilichowski. 1998. Laysan and black-footed albatrosses: trophic relationships and driftnet fisheries associations of non-breeding birds. In G. Robertson and R. Gales (Eds.), Albatrosses: Biology and Conservation. Surrey Beatty & Sons: Chipping Norton. Goyert, H.F.; Garton, E.O.; Drummond, B.A.; Renner, H.M. 2017. Density dependence and changes in the carrying capacity of Alaskan seabird populations. Biological Conservation 209: 178-187. Gurevich, V. S. 1980. Worldwide distribution and migration patterns of the white whale (beluga), Delphinapterus leucas. Rep. Int. Whal. Comm. 30:465-480. Heptner, L. V. G., K. K. Chapskii, V. A. Arsen’ev, and V. T. Sokolov. 1976. Bearded seal. Erignathus barbatus (Erxleben, 1777), p. 166-217. In L. V. G. Heptner, N. P. Naumov, and J. Mead (eds.), Mammals of the Soviet Union. Volume II, Part 3--Pinnipeds and Toothed Whales, Pinnipedia and Odontoceti. Vysshaya Shkola Publishers, Moscow, Russia. (Translated from Russian by P. M. Rao, 1996, Science Publishers, Inc., Lebanon, NH.) Hiddink JG, Jennings S, Kaiser MJ (2006) Indicators of the ecological impact of bottom-trawl disturbance on seabed communities. Ecosystems 9:1190-1199. Hill JM, Marzialetti S, Pearce B (2011) Recovery of seabed resources following marine aggregate extraction. Marine ALSF Science Monograph Series No. 2. MEPF 10/P148. Newell, R.C. and Measures, J. (eds.), 44p. Hobbs, R. C., and J. M. Waite. 2010. Abundance of harbor porpoise (Phocoena phocoena) in three Alaskan regions, corrected for observer errors due to perception bias and species misidentification, and corrected for animals submerged from view. Fish. Bull., U.S. 108(3):251-267. Hutchings JA (2000) Collapse and recovery of marine fishes. Nature 406:882-885. Hyvärinen, H., and M. Nieminen. 1990. Differentiation of the ringed seal in the Baltic Sea, Lake Ladoga and Lake Saimaa. Finnish Game Res. 47:21-27. Kaiser MJ, Clarke KR, Hinz H, Austen MCV, Somerfield PJ, Karakassis I (2006) Global analysis of response and recovery of benthic biota to fishing. Marine Ecology Progress Series 311:1-14. Lang, A.R., Weller, D.W., LeDuc, R., Burdin, A.M., Pease, V.L., Litovka, D., Burkanov, V. and Brownell, R.L., Jr. 2011.Genetic analysis of stock structure and movements of gray whales in the eastern and western North Pacific. Paper SC/63/BRG10 presented to the IWC Scientific Committee. Le Boeuf, B.J., Crocker, D.E., Costa, D.P., Blackwell, S.B., Webb, P.M., & Houser, D.S. 2000. Foraging ecology of northern elephant seals. Ecological monographs, 70(3), 353-382. LeDuc, R.G., Weller, D.W., Hyde, J., Burdin, A.M., Rosel, P.E., Brownell, R.L., Würsig, B. and Dizon, A.E. 2002. Genetic differences between western and eastern gray whales (Eschrichtius robustus). Journal of Cetacean Research and Management 4:1-5. Lewison, R.L. and L.B. Crowder. 2003. Estimating fishery bycatch and effects on a vulnerable seabird population. Ecological Applications 13: 743-753.

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Lowry, M.S., R. Condit, B.Hatfield, S.G. Allen, R. Berger, P.A. Morris, B.J. Le Boeuf, and J. Reiter. 2014. Abundance, Distribution, and Population Growth of the Northern Elephant Seal (Mirounga angustirostris) in the United States from 1991 to 2010. Aquatic Mammals 40(1):20-31. Manning, T. H. 1974. Variation in the skull of the bearded seal, Erignathus barbatus (Erxleben). Biological Papers of the University of Alaska 16:1-21. McCann, T.S. 1985. Size, status and demography of southern elephant seal (Mirounga leonina) populations. In J. K. Ling and M. M. Bryden (eds.), Studies of Sea Mammals in South Latitudes. South Australian Museum. 132 pp. Moreland, E., M. Cameron, and P. Boveng. 2013. Bering Okhotsk Seal Surveys (BOSS), joint U.S.-Russian aerial surveys for ice-associated seals, 2012-13. Alaska Fisheries Science Center Quarterly Report (July-August- September 2013):1-6. MSC. 2014. MSC Fisheries Certification Requirements. Version 2.0, October 2014. London, UK. MSC (in prep) Scientific Basis for Revising the MSC Fisheries Standard, London, UK. Müller-Wille, L. L. 1969. Biometrical comparison of four populations of Phoca hispida Schreb. in the Baltic and White Seas and Lakes Ladoga and Saimaa. Commentationes Biologicae Societas Scientiarum Fennica 31:1-12. Muto, M.M., V. T. Helker, R. P. Angliss, B. A. Allen, P. L. Boveng, J. M. Breiwick, M. F. Cameron, P. J. Clapham, S. P. Dahle, M. E. Dahlheim, B. S. Fadely, M. C. Ferguson, L. W. Fritz, R. C. Hobbs, Y. V. Ivashchenko, A. S. Kennedy, J. M. London, S. A. Mizroch, R. R. Ream, E. L. Richmond, K. E. W. Shelden, R. G. Towell, P. R. Wade, J. M. Waite, and A. N. Zerbini. 2018. Alaska marine mammal stock assessments, 2017. U.S. Dep. Commer., NOAA Tech. Memo. NMFS-AFSC-378, 382 p. National Marine Fisheries Service (NMFS). 2016. Guidelines for preparing stock assessment reports pursuant to the 1994 amendments to the Marine Mammal Protection Act. 23 p. Available at: https://www.fisheries.noaa.gov/national/marine-mammal-protection/guidelines-assessing-marine-mammal-stocks. NMFS. 2008. Recovery Plan for the Steller Sea Lion (Eumetopias jubatus). Revision. National Marine Fisheries Service, Silver Spring, MD. 325 pages. NMFS (2010) Final EFH 5-year Review Summary Report, April 2010. NOAA (2004) Programmatic Supplemental Environmental Impact Statement for the Alaska Groundfish Fisheries Implemented Under the Authority of the Fishery Management Plans for the Groundfish Fishery of the Gulf of Alaska and the Groundfish of the Bering Sea and Aleutian Islands Area. Alaska Regional Office, National Marine Fisheries Service, 709 West 9th Street, Suite 453, P.O. Box 21668, Juneau, Alaska 99802-1668 NOAA (2005) Final Environmental Impact Statement for Essential Fish Habitat Identification and Conservation in Alaska. U.S. Dept. Commerce, NOAA, NMFS, Alaska Region, P.O. Box 21668, Juneau, AK NOAA Fisheries. 2019. Shark Conservation Act: Overview of the Shark Conservation Act of 2010. Available at: https://www.fisheries.noaa.gov/national/laws-and-policies/shark-conservation-act. NPFMC (2014) Fishery Management Plan for Groundfish of the Bering Sea and Aleutian Islands Management Area. North Pacific Fishery Management Council, 605 W. 4th Avenue, Suite 306, Anchorage, Alaska 99501, April 2014 Ognev, S. I. 1935. Mammals of the U.S.S.R. and Adjacent Countries. Vol. 3. Carnivora (Fissipedia and Pinnipedia). Gosudarst. Izdat. Biol. Med. Lit., Moscow. (Translated from Russian by Israel Program for Scientific Translations, 1962. 741 p.) Rice, D. W. 1998. Marine Mammals of the World: Systematics and Distribution. Society for Marine Mammalogy, Lawrence, KS. 231 p. Rone, B. K., A. N. Zerbini, A. B. Douglas, D. W. Weller, and P. J. Clapham. 2017. Abundance and distribution of cetaceans in the Gulf of Alaska. Mar. Biol. 164:23. Rooper C, Sigler M, Goddard P, Malecha P, Towler R, Williams K, Wilborn R (2015) Validation of models of the distribution of structure-forming invertebrates in the eastern Bering Sea using an underwater stereo camera. Prepared for NPFMC. Scheffer, V. B. 1958. Seals, Sea Lions and Walruses: A Review of the Pinnipedia. Stanford University Press, Palo Alto, CA. 179 p. Shaughnessy, P. D., and F. H. Fay. 1977. A review of the and nomenclature of North Pacific harbour seals. J. Zool. (Lond.) 182:385-419.

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USFWS. 2018. Seabirds. Available at: https://www.fws.gov/alaska/pages/migratory-birds/seabirds. USFWS. 2017. Section 7 Consultation. Available at: https://www.fws.gov/midwest/endangered/section7/section7.html. Wade, P. R., and R. Angliss. 1997. Guidelines for assessing marine mammal stocks: report of the GAMMS Workshop April 3-5, 1996, Seattle, Washington. U.S. Dep. Commer., NOAA Tech. Memo. NMFS-OPR-12, 93 p. Weller, D.W., S. Bettridge, R.L. Brownell Jr., J.L. Laake, J.E. Moore, P.E. Rosel, B.L. Taylor, and P.R. Wade. 2013. Report of the National Marine Fisheries Service Gray Whale Stock Identification Workshop. U.S. Dep. Commer., NOAA Tech. Memo. NOAA-TM-NMFS-SWFSC-507. Zador S, ed. (2013) Ecosystem considerations for 2013. Stock Assessment and Fishery Evaluation Report for the Groundfish Resources or the Bering Sea/Aleutian Islands Regions. North Pacific Fishery Management Council, Anchorage, AK, pp. 235

Principle 3 References: Alaska Department of Fish and Game (ADFG) 2019. Bering Sea/Aleutian Islands Area Subsistence Fishing. https://www.adfg.alaska.gov/index.cfm?adfg=ByAreaSubsistenceBeringAleutians.fishingInfo ADFG (2019) Alaska Department of Fish and Game Commercial Groundfish Fisheries. Juneau, Alaska. https://www.adfg.alaska.gov/index.cfm?adfg=CommercialByFisheryGroundfish.main ADFG (2019a). Alaska Department of Fish and Game - Alaska Board of Fisheries. Juneau, Alaska.http://www.adfg.alaska.gov/index.cfm?adfg=fisheriesboard.main ADFG (2019b.) Alaska Department of Fish and Game. Enforcement. Juneau, Alaska. https://www.adfg.alaska.gov/index.cfm?adfg=enforcement.main Magnuson-Stevens Act (2007). Public Law 94-265 as amended by the Magnuson-Stevens Fishery Conservation and Management Reauthorization Act (P.L. 109-479). An Act to provide for the conservation and management of the fisheries, and for other purposes. As amended through January 12, 2007 MRAG (2016). BSAI Alaska Pollock Fishery Public Certification Report. MRAG Americas, Inc. January 2016. MRAG (2016a). GOA Alaska Pollock Fishery Public Certification Report. MRAG Americas, Inc. January 2016. NMFS 2013. 2014 Annual Deployment Plan for Observers in the Groundfish and Halibut Fisheries off Alaska. National Oceanic and Atmospheric Administration, 709 West 9th Street. Juneau, Alaska 99802. NMFS. 2011. NOAA Policy for Assessment of Penalties and Permit Sanctions – March 16, 2011 [Online]. Available at: http://www.noaanews.noaa.gov/stories2011/pdfs/Penalty%20Policy%20--%20FINAL.pdf. NOAA. 2013. NOAA Procedures for Government-to-Government Consultation with Federally Recognized Indian Tribes and Alaska Native Corporations. NOAA 13175 Policy. http://www.legislative.noaa.gov/policybriefs/NOAA%20Tribal%20consultation%20handbook%20111213.pdf NPFMC (2019). Bering Sea/Aleutian Islands and Gulf of Alaska Groundfish. North Pacific Fishery Management Council. Anchorage AK. https://www.npfmc.org/bering-seaaleutian-islands-groundfish/ NPFMC (2019a). Scientific and Statistical Committee. North Pacific Fishery Management Council, Anchorage AK. https://www.npfmc.org/scientific-and-statistical-committee/ NPFMC (2019b) Advisory Panel. North Pacific Fishery Management Council, Anchorage AK. https://www.npfmc.org/ap/ NPFMC (2019c) Community Development Quota Program. North Pacific Fishery Management Council, Anchorage AK. https://www.npfmc.org/community-development-program/ NPFMC (2019e) American Fisheries Act (AFA) Pollock Cooperative. North Pacific Fishery Management Council, Anchorage. https://www.npfmc.org/american-fisheries-act-afa-pollock-cooperatives/ NPFMC (2019f) Amendment 80 Program. North Pacific Fishery Management Council, Anchorage. https://www.npfmc.org/amendment-80-cooperatives/ NPFMC (2018). Fishery Management Plan for Groundfish of the Bering Sea and Aleutian Islands Management Area. North Pacific Fishery Management Council, Anchorage AK. October 2018. NPFMC (2018a). Fishery Management Plan for Groundfish of the Gulf of Alaska. North Pacific Fishery Management Council, Anchorage AK. October 2018. NPFMC (2012) Statement of organization, practices, and procedures of the North Pacific Fishery Management Council (Draft). North Pacific Fishery Management Council, Anchorage AK. http://www.alaskafisheries.noaa.gov/npfmc/. NPFMC (2012a) Introduction to the Council process. North Pacific Fishery Management Council, Anchorage AK. https://www.npfmc.org/wp content/PDFdocuments/meetings/IntrotoProcess.pdf NPFMC (2009). Navigating the North Pacific Council Process. North Pacific Fishery Management Council, Anchorage AK. http://www.npfmc.org/wp-content/PDFdocuments/help/Navigating_NPFMC.pdf United Nations. 1982. United Nations Convention on the Law of the Sea (UNCLOS). http://www.un.org/Depts/los/convention_agreements/texts/unclos/unclos_e.pdf USCG (2019) Mission: Maritime Stewardship. US Coast Guard. https://www.pacificarea.uscg.mil/Our- Organization/District-17/ 136 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

9 Appendices 9.1 Assessment information 9.1.1 Previous assessments The BSAI and GoA pollock fisheries have been MSC certified since April 2005 when the first certificate was issued. There was a first re-assessment that concluded in 2010 and a second re-assessment that concluded in 2016. This is the third re-assessment. Previously, the BSAI and GoA fisheries were listed as separate fisheries and reported in separate reports on the MSC website. This report is the first to combine the regions into one report. The reassessment that concluded in 2016 had no conditions. The initial assessment reports are available on the MSC website, and there is a separate report for each stock. As this was nearly ten years ago, and the assessment trees used are very different to the one in use now, it is not appropriate to go through each one and report on conditions that may have existed and been closed in the initial certification term.

9.1.2 Small-scale fisheries

To help identify small-scale fisheries in the MSC program, the CAB should complete the table below for each Unit of Assessment (UoA). For situations where it is difficult to determine exact percentages, the CAB may use approximations e.g. to the nearest 10%.

Table X – Small-scale fisheries

Percentage of vessels with length Percentage of fishing activity completed Unit of Assessment (UoA) <15m within 12 nautical miles of shore

BSAI Pollock 0% ??

GOA Pollock 0% ??

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9.2 Evaluation processes and techniques 9.2.1 Site visits

The report shall include:

- An itinerary of site visit activities with dates. - A description of site visit activities, including any locations that were inspected. - Names of individuals contacted.

Reference(s): FCP v2.1 Section 7.16

9.2.2 Stakeholder participation

The report shall include:

- Details of people interviewed: local residents, representatives of stakeholder organisations including contacts with any regional MSC representatives. - A description of stakeholder engagement strategy and opportunities available.

Reference(s): FCP v2.1 Section 7.16

9.2.3 Evaluation techniques

The report shall include:

- Justification for how public announcements were developed. - Methodology used, including sample-based means of acquiring a working knowledge of the management operation and sea base. - Details of the scoring process e.g. group consensus process. - The decision rule for reaching the final recommendation e.g. aggregate principle-level scores above 80.

If the RBF was used for this assessment, the report shall include:

- The justification for using the RBF, which can be copied from previous RBF announcements, and stakeholder comments on its use. - The RBF stakeholder consultation strategy to ensure effective participation from a range of stakeholders including any participatory tools used. - A summary of the information obtained from the stakeholder meetings including the range of opinions. - The full list of activities and components that have been discussed or evaluated in the assessment, regardless of the final risk-based outcome.

The stakeholder input should be reported in the stakeholder input appendix and incorporated in the rationales directly in the scoring tables.

Reference(s): FCP v2.1 Section 7.16, FCP v2.1 Annex PF Section PF2.1

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9.3 Peer Review reports To be drafted at Public Comment Draft Report The report shall include unattributed reports of the Peer Reviewers in full using the relevant templates. The report shall include explicit responses of the team that include:

- Identification of specifically what (if any) changes to scoring, rationales, or conditions have been made; and, - A substantiated justification for not making changes where peer reviewers suggest changes, but the team disagrees.

Reference(s): FCP v2.1 Section 7.14

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9.4 Stakeholder input To be drafted at Client and Peer Review Draft Report To be completed at Public Certification Report The CAB shall use the stakeholder input template to include all written stakeholder input during the stakeholder input opportunities and provide a summary of verbal stakeholder input received during the site visit. Using the stakeholder input template, the team shall respond to all written stakeholder input identifying what changes to scoring, rationales and conditions have been made in response, where the changes have been made, and assigning a ‘CAB response code’. The team may respond to the verbal summary.

Reference(s): FCP v2.1 Section 7.15

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9.5 Conditions – delete if not applicable To be drafted from Client and Peer Review Draft Report The report shall document all conditions in separate tables. The CAB shall include rationale for exceptional circumstances in the summary of conditions in the Client and Peer Review Draft Report and all subsequent reports.

For reassessments, the CAB shall note:

- If and how any of the new conditions relate to previous conditions raised in the previous assessment or surveillance audits. - If and why any conditions that were raised and then closed in the previous assessment are being raised again in the reassessment. - If any conditions are carried over from a previous assessment, including an explanation of: - Which conditions are still open and being carried over. - Why those conditions are still open and being carried over. - Progress made in the previous assessment against these conditions. - Why recertification is being recommended despite outstanding conditions from the previous assessment. - If any previous conditions were closed after the 4th Surveillance Audit and reassessment site visit (i.e. in Year 5), including the rationale for re-scoring and closing out of the condition.

Reference(s): FCP v2.1 Section 7.18

Table X – Condition 1

Performance Indicator

Score State score for Performance Indicator

Cross reference to page number containing scoring template table or copy justification text Justification here. If condition relates to a previous condition or one raised and closed in the previous assessment include information required here

Condition State condition

Milestones State milestones and resulting scores where applicable

Consultation on Include details of any verification required to meet requirements in FCP v2.1 7.19.8 condition

9.6 Client Action Plan To be added from Public Comment Draft Report The report shall include the Client Action Plan from the fishery client to address conditions.

Reference(s): FCP v2.1 Section 7.19

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9.7 Surveillance To be drafted from Client and Peer Review Draft Report The report shall include the program for surveillance, timing of surveillance audits and a supporting rationale.

Reference(s): FCP v2.1 Section 7.28

Table X– Fishery surveillance program

Surveillance level Year 1 Year 2 Year 3 Year 4

e.g. On-site e.g. On-site e.g. On-site e.g. On-site surveillance audit & e.g. Level 5 surveillance audit surveillance audit surveillance audit re-certification site visit

Table X – Timing of surveillance audit

Proposed date of surveillance Year Anniversary date of certificate Rationale audit e.g. Scientific advice to be released in June 2018, proposal to postpone e.g. 1 e.g. May 2018 e.g. July 2018 audit to include findings of scientific advice

Table X – Surveillance level rationale

Year Surveillance activity Number of auditors Rationale

e.g. From client action plan it can be deduced that information needed to verify progress towards conditions 1.2.1, 2.2.3 and 3.2.3 can be provided remotely in year 3. Considering that milestones indicate that most e.g. 1 auditor on-site with e.g.3 e.g. On-site audit conditions will be closed out in year 3, remote support from 1 auditor the CAB proposes to have an on-site audit with 1 auditor on-site with remote support – this is to ensure that all information is collected and because the information can be provided remotely.

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9.8 Harmonised fishery assessments To be drafted at Announcement Comment Draft Report stage To be completed at Public Certification Report stage

Table 23 – Overlapping fisheries

Fishery name Certification status and date Performance Indicators to harmonise

PIs 2.1.x, 2.2.x, 2.3.x, 2.4.x, 2.5.x, BSAI Pacific Cod Certified, June 18, 2015 3.1.x, 3.2.x PIs 2.1.x, 2.2.x, 2.3.x, 2.4.x, 2.5.x, BSAI Flatfish Certified, October 29, 2015 3.1.x, 3.2.x PIs 2.1.x, 2.2.x, 2.3.x, 2.4.x, 2.5.x, GOA Pacific Cod Certified, June 18, 2015 3.1.x, 3.2.x PIs 2.1.x, 2.2.x, 2.3.x, 2.4.x, 2.5.x, GOA Flatfish Certified, October 29, 2015 3.1.x, 3.2.x BSAI and GOA Atka Mackerel, PIs 2.1.x, 2.2.x, 2.3.x, 2.4.x, 2.5.x, Pacific Ocean perch, northern In assessment 3.1.x, 3.2.x rockfish, and dusky rockfish

Supporting information

- Describe any background or supporting information relevant to the harmonisation activities, processes and outcomes. These fisheries share a common assessment process, and assessment teams have members in common. There is also a certificate sharing agreement in place.

Was either FCP v2.1 Annex PB1.3.3.4 or PB1.3.4.5 applied when harmonising? No

Date of harmonisation meeting DD / MM / YY

If applicable, describe the meeting outcome

- e.g. Agreement found among teams or lowest score adopted.

Table X – Scoring differences

Performance Fishery name Fishery name Fishery name Fishery name Indicators (PIs)

PI Score Score Score Score

PI Score Score Score Score

PI Score Score Score Score

Table X – Rationale for scoring differences

If applicable, explain and justify any difference in scoring and rationale for the relevant Performance Indicators (FCP v2.1 Annex PB1.3.6)

143 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

If exceptional circumstances apply, outline the situation and whether there is agreement between or among teams on this determination

144 MRAG Americas – US1913 BSAI & GOA Pollock ACDR MRAG-MSC-F28-v2.01 March 2019

9.9 Objection Procedure – delete if not applicable To be added at Public Certification Report stage The report shall include all written decisions arising from a ‘Notice of Objection’, if received and accepted by the Independent Adjudicator.

Reference(s): FCP v2.1 Annex PD

145 MRAG Americas – US1913 BSAI & GOA Pollock ACDR