MSC Final Report and Determination for Alaska Pollock – Bering Sea-Aleutian Islands
MRAG Americas, Inc.
Don Bowen, Jake Rice, and Robert J. Trumble
December 2015
CLIENT DETAILS:
At-Sea Processors Association 4039 21st West, Suite 400 Seattle, WA 98199 USA
Document template tracking no.: MRAG-MSC-7a-v3
MSC reference standards: MSC Standards Version 1.1 MSC Certification Requirements Version 1.3 MSC Guidance for Certification Requirements Version 1.3
Contents Glossary ...... 1 1. Executive Summary ...... 2 2. Authorship and Peer Reviewers ...... 3 2.1 Assessment Team ...... 3 2.2 Peer Reviewers ...... 4 3. Description of the Fishery ...... 4 3. 1 Unit(s) of Certification and scope of certification sought ...... 4 3.2 Overview of the fishery ...... 5 3.3 Principle One: Target Species Background...... 6 3. 3.1 General Considerations ...... 6 3.3.2 Assessment Information ...... 8 3.3.3 Assessment Methods ...... 13 3.3.4 Assessment Results ...... 17 3.4 Principle Two: Ecosystem Background ...... 26 3.4.1 BSAI Ecosystems ...... 26 3.4.2 Oceanography and bottom sediments ...... 26 3.4.3 Climate ...... 27 3.4.4 Non-target Interactions ...... 28 3.4.5 Marine mammals ...... 29 3.4.6 Seabirds ...... 30 3.4.7 Retained ...... 32 3.4.8 Bycatch ...... 33 3.4.9 ETP species ...... 37 3.4.10 Habitat ...... 41 3.4.11 Food web ...... 43 3.4.12 Ecosystem Management ...... 45 3.5 Principle Three: Management System Background ...... 47 3.5.1 Area of operation of the fishery and under which jurisdiction it falls ...... 47 3.5.2 Recognized groups with interests in the fishery ...... 52 3.5.3 Consultations leading to the formulation of the management plan...... 53 3.5.4 Arrangements for on-going consultations with interest groups ...... 56 3.5.5 Non-fishery users or activities, which could affect the fishery, and arrangements for liaison and co-ordination...... 56 3.5.6 Details of the decision-making process or processes, including the recognized participants ...... 57 3.5.7 Objectives for the fishery ...... 61 3.5.8 Outline the fleet types or fishing categories participating in the fishery ...... 64 3.5.9 Individuals or groups granted rights of access to the fishery, and the nature of those rights ...... 64
BSAI Alaska Pollock – Final Report and Determination page i 3.5.10 Description of the measures agreed upon for the regulation of fishing in order to meet the objectives within a specified period ...... 64 3.5.11 Arrangements and responsibilities for monitoring, control and surveillance and enforcement ...... 65 3.5.12 Details of any planned education and training for interest groups ...... 67 3.5.13 Date of next review and audit of the management plan ...... 67 3.5.14 Description of fishery’s research plan ...... 67 4. Evaluation Procedure ...... 69 4.1 Harmonised Fishery Assessment ...... 69 4.2 Previous assessments ...... 69 4.3 Assessment Methodologies ...... 69 4.4 Evaluation Processes and Techniques ...... 69 4.4.1 Site Visits and Consultations ...... 69 4.4.2 Evaluation Techniques ...... 71 5 Traceability ...... 73 5.1 Eligibility Date ...... 73 5.2 Traceability within the Fishery ...... 73 5.3 Eligibility to Enter Further Chains of Custody ...... 74 5.4 Eligibility of Inseparable or Practically Inseparable (IPI) stock(s) to Enter Further Chains of Custody ...... 74 6 Evaluation Results ...... 75 6.1 Principle Level Scores ...... 75 6.2 Summary of Scores ...... 75 6.3 Summary of Conditions ...... 76 6.4 Determination, Formal Conclusion and Agreement ...... 76 References ...... 77 Appendices ...... 89 Appendix 1 Scoring and Rationales ...... 89 Principle 1 ...... 89 Principle 2 ...... 118 Principle 3 ...... 164 Appendix 1.1 Conditions ...... 185 Appendix 2. Peer Review Reports ...... 186 Peer Review No. 1 ...... 187 Peer Review No. 2 ...... 201 Appendix 3. Stakeholder submissions ...... 207 Appendix 3.1 Site Visit Comments ...... 207 WWF Comments ...... 207 Western Alaska Communities Comments ...... 209 Appendix 3.2 PCDR Comments ...... 210
BSAI Alaska Pollock – Final Report and Determination page ii Greenpeace and WWF ...... 211 MSC ...... 225 Appendix 4. Surveillance Frequency ...... 227 Appendix 5. Client Agreement ...... 228 Appendix 5.1 Objections Process ...... 229
BSAI Alaska Pollock – Final Report and Determination page iii Glossary
ABC Acceptable Biological Catch AFA American Fisheries Act AP Advisory Panel ADFG Alaska Department of Fish and Game BSAI Bering Sea and Aleutian Islands CDQ Community Development Quota CVOA Catcher Vessel Operational Area EAM Ecosystem Approach to Management EA/RIR Environmental Assessment/Regulatory Impact Review EEZ Exclusive Economic Zone EFH Essential Fish Habitat EIS Environmental Impact Statement ESA Endangered Species Act FEP Fishery Ecosystem Plan FMP Fishery Management Plan GHL Guideline Harvest Level GOA Gulf of Alaska HAPC Habitat Areas of Particular Concern IFQ Individual Fishing Quota IPHC International Pacific Halibut Commission IRFA Initial Regulatory Flexibility Analysis IRIU Improved Retention/Improved Utilization LLP License Limitation Program MSFCMA Magnuson-Stevens Fishery Conservation & Management Act MMPA Marine Mammal Protection Act MRA Maximum Retainable Allowance MSY Maximum Sustainable Yield mt Metric tons nm Nautical miles NMFS National Marine Fisheries Service NOAA National Oceanic & Atmospheric Administration NPFMC North Pacific Fishery Management Council OY Optimum Yield POP Pacific Ocean perch PSC Prohibited Species Catch SAFE Stock Assessment and Fishery Evaluation SSC Scientific and Statistical Committee SSL Steller Sea Lion TAC Total Allowable Catch
BSAI Alaska Pollock – Final Report and Determination page 1
1. Executive Summary
An assessment team of Don Bowen, Jake Rice, and Robert J. Trumble conducted the assessment of Alaska pollock ((Theragra chalcogramma and Gadus chalcogrammus)), using CR v1.3. The assessment team met with scientists, managers, and other stakeholders from 27-30 May 2014 in person. The Bering Sea-Aleutian Islands fisheries for Alaska pollock are exceptionally well managed and are characterized by state of the art stock assessments and harvest strategies. The stocks are in good condition. The management system implements high levels of control over the fisheries to minimize environmental impacts. The overarching legislation and regulation affecting Principle 1 and Principle 2 are highly developed, and applied specifically to the fisheries. On the basis of this re-assessment of the fisheries, the Assessment Team recommends that the Bering Sea-Aleutian Islands fisheries for Alaska flatfish maintain certification. The fisheries received no conditions.
The fisheries scored greater than 80 for all principles, and no performance indicators scores less than 80.
Final Principle Scores Principle Score Principle 1 – Target Species 97.5 Principle 2 – Ecosystem 93.0 Principle 3 – Management System 99.0
BSAI Alaska Pollock – Final Report and Determination page 2
2. Authorship and Peer Reviewers
2.1 Assessment Team
The assessment team consists of Dr. Don Bowen, Dr. Jake Rice, and Dr. Robert J. Trumble. Dr. Trumble serves as assessment team leader. Qualifications of the team are:
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 years. He has considerable experience as an MSC assessor having been involved with a number of groundfish fisheries certifications (e.g., pollock, Pacific cod) in the Bering Sea and Gulf of Alaska.
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.).
Dr. Robert J. Trumble joined MRAG Americas in 2000 as a senior research scientist and became Vice President in 2005. He has wide-ranging experience in marine fish science and management, fishery habitat protection, and oceanography. He has overseen all MRAG pre- assessments and full assessments. He has received MSC training on numerous occasions, including the Risk-based Framework, and has led an RBF on three occasions. Previously, he served as Senior Biologist of the International Pacific Halibut Commission in Seattle, Washington, in various research and management positions at the Washington Department of Fisheries, and with the US Naval Oceanographic Office. Dr. Trumble has extensive experience working with government agencies, commercial and recreational fisheries groups, Indian tribes, and national and international advisory groups. He received appointments to the Scientific and Statistical Committees of the South Atlantic Fishery Management Council and the Pacific Fishery Management Council, the Groundfish Management Team of the North Pacific Fishery Management Council, the affiliate faculty of Fisheries at the University of Washington, and the Advisory Committee of the Washington
BSAI Alaska Pollock – Final Report and Determination page 3 Sea Grant Program. Dr. Trumble received a Ph.D. in Fisheries from the College of Fisheries, University of Washington.
These individuals collectively have knowledge of the stock status and assessment, ecosystem impacts, and management systems applicable to this fishery.
2.2 Peer Reviewers
Tom Jagielo has a wide breadth of experience in marine fish science, habitat studies, and oceanography. He formed his own firm in 2008 to provide consulting services in quantitative fisheries science. Previously he served for 24 years with the Washington Department of Fish and Wildlife, and 6 years with the Fisheries Research Institute at the University of Washington in Seattle. He has specialized in groundfish stock assessment and survey design, adapting state of the art tools and methods to assess marine fish populations for sustainable fisheries management. He has produced groundfish stock assessments used by the Pacific Fishery Management Council, including analysis of lingcod, black rockfish, and yelloweye rockfish populations. Tom has experience working with government agencies, commercial and recreational fisheries groups, Native American tribes, community organizations, and both national and international advisory groups. He has received appointments to the Scientific and Statistical Committee of the Pacific Fishery Management Council, the Technical Subcommittee of the US-Canada Groundfish Committee, the Pacific Coast Ocean Observation System, and other workshop panels and review bodies. He has published in peer-reviewed journals and symposium proceedings, and has presented papers at national and international meetings. Tom received a B.S. degree in Biology from the Pennsylvania State University, and a M.S. degree in Fisheries from the University of Washington, where he also conducted post M.S. graduate studies in fisheries population dynamics and parameter estimation. In addition to serving as an MSC Surveillance Team Member/Auditor (P1, P2, and P3 expert) for various stocks in the US and Europe, he has experience in providing MSC Peer Reviews on the West Coast-US (Pacific hake, Limited Entry groundfish, sablefish, Pacific halibut), West Coast-Canada (dogfish shark, sablefish, Pacific halibut), Alaska (sablefish, Pacific halibut, pacific cod, flatfish), and Australia (blue grenadier).
Susan Hanna is professor emeritus of marine economics at Oregon State University. Her research and publications are in the area of marine economics and policy, with an emphasis on fishery management, ecosystem-based fishery management, property rights and institutional design. Dr. Hanna has served as a scientific advisor to the U.S. Commission on Ocean Policy, National Oceanic and Atmospheric Administration, National Marine Fisheries Service, Minerals Management Service, Northwest Power and Conservation Council and the Pacific Fishery Management Council. She served on the Ocean Studies Board of the National Research Council (NRC), National Academy of Sciences, and several NRC Committees, including the Committee to Review Individual Quotas in Fisheries and the Committee on Protection and Management of Pacific Northwest Anadromous Salmonids. She has conducted reviews for the Center for Independent Experts (CIE) and has participated in MSC reviews of West Coast Dungeness crab, Oregon pink shrimp, West Coast groundfish, Fogo Island shrimp, Alaska Pollock, Alaska flatfish, and Alaska Pacific cod fisheries.
3. Description of the Fishery
3. 1 Unit(s) of Certification and scope of certification sought
BSAI Alaska Pollock – Final Report and Determination page 4 The MRAG Americas assessment team determined that the fishery is within scope as required by the MSC. It is not conducted under a controversial unilateral exemption to an international agreement; is not subject to unresolvable controversy; has not failed or had a certificate withdrawn; and does not use out of scope fishing methods. The fishery involves neither enhanced stocks nor introduced species.
The unit of certification consists of: Species Alaska Pollock ((Theragra chalcogramma and Gadus chalcogrammus)
Geographical US federal EEZ and State waters of the Bering Sea-Aleutian Islands range of fishing operations Method of capture Pelagic trawl
Stock Pelagic trawl. The fleet comprises trawl catcher vessels that deliver pollock onshore for processing (50% of TAC) or to mothership processing vessels (10% of TAC), and catcher/processor vessels that both harvest and process (40% of TAC).
Management Alaska pollock are managed under the authority of the Magnuson- Stevens Fishery Conservation and Management Act (Magnuson- Stevens Act, MSA), with management recommendations from the North Pacific Fishery Management Council (NPFMC) and implementation through the National Marine Fisheries Service (NMFS).
Client group The client group, the At-Sea Processors Association, represents the entire fishery.
This unit of certification represents the range of US BSAI Alaska pollock, and includes all eligible fishermen of the US with authorization to fish for Alaska pollock.
3.2 Overview of the fishery
The Bering Sea-Aleutian Islands Stock Assessment and Fishery Evaluation (SAFE) report (NMFS 2014) and the Bering Sea-Aleutian Islands Fishery Management Plan (NPFMC 2014) provide basic background information for the Alaska pollock and other fisheries in the BSAI, and those documents provide the source of information for this overview. The BSAI Alaska pollock fisheries are conducted in the U.S. EEZ waters of the Bering Sea and Aleutian Islands under federal management. Historically, with implementation of the Fishery Conservation and Management Act in the U.S., annual quotas (or catch targets) had been used to limit the catch by foreign and domestic fisheries.
Native fisheries have taken place along the coastal areas of the BSAI for most of the history of human habitation in Alaska, and small-scale commercial fisheries have occurred in coastal waters since the 1860s. During the early 1960s, a Japanese longline fishery harvested EBS Pacific cod for the frozen fish market. Beginning in 1964, the Japanese trawl fishery for Alaska pollock (Theragra chalcogramma) expanded and cod became an important bycatch species and an occasional target species when high concentrations were detected during pollock operations.
Several foreign countries conducted large scale groundfish fisheries in the BSAI prior to 1991. Vessels from Japan, the USSR (Russia), Canada, Korea, Taiwan, and Poland all plied the waters of the North Pacific for groundfish. In the mid-1950s, vessels from Japan and
BSAI Alaska Pollock – Final Report and Determination page 5 Russia targeted yellowfin sole, and catches peaked at over 550,000 mt in 1961. In the 1960s, Japanese vessels, and to a lesser extent Russian vessels, developed a fishery for Pacific ocean perch, pollock, Greenland turbot, sablefish, and other groundfish. By the early 1970s, over 1.7 million mt of pollock was being caught by these two countries in the eastern Bering Sea annually. Korean vessels began to target pollock in 1968. Polish vessels fished briefly in the Bering Sea in 1973. Taiwanese vessels entered the fishery in 1977. By the time that the Fishery Conservation and Management Act went into effect in 1977, foreign catches of Pacific cod had consistently been in the 30,000-70,000 t range for a full decade. The transition period from foreign to fully domestic groundfish fisheries was stimulated by a quick increase in joint-venture operations. The American Fisheries Promotion Act required that allocations of fish quotas to foreign nations be based on the nation’s contributions to the development of the U.S. fishing industry. This provided incentive for development of joint- venture operations, with U.S. catcher vessels delivering their catches directly to foreign processing vessels. In 1981, a U.S. domestic trawl fishery and several joint venture fisheries began operations in the EBS. Joint-venture operations peaked in 1987, giving way to a rapidly developing domestic fleet. By 1991, the entire BSAI groundfish harvest (1,765,397 mt; $351 million ex-vessel value) was taken by 391 U.S. vessels. Groundfish harvest has been entirely domestic since that time.
Presently, the Pacific pollock stocks are exploited by pelagic trawls. In the EBS, Pacific pollock are caught throughout much of the continental shelf and upper slope.
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. The CDQ Program allocates a percentage of all Bering Sea and Aleutian Islands quotas for groundfish, prohibited species, halibut, and crab to eligible communities. The purpose of the CDQ Program is (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.
3.3 Principle One: Target Species Background
3. 3.1 General Considerations The BSAI Alaska pollock (hence “pollock”) stock complex subject to certification comprises a suite of stock components of varying but incomplete levels of differentiation, harvested primarily with midwater trawl gears in the Eastern Bering Sea (EBS) shelf waters and along the Aleutian Islands (AI) chain. These are the highest volume fisheries in US waters, with a landed valued above US$300 million in most recent years, and product value of a billion dollars. Studies of the life history, influence of environmental and trophodynamic conditions on the various aspects of stock productivity and distribution, and impacts of fisheries on distribution and biology have been conducted for decades. A major book (Bailey 2013) summarized information on life histories and fisheries on these stocks, and research continues to accumulate with the Web of Science reporting over 100 new primary publications between 2013 and 2015 with “Bering Sea” and “pollock” as search criteria. Bailey (2013), many of the new publications (cited below), and the NOAA SAFE Reports were used as main sources of background information on pollock biology and fisheries, augmented by past MSC Certification assessment reports and new literature accumulated since the last MSC certification assessment.
Pollock are broadly distributed throughout the North Pacific with the largest concentrations found in the Eastern Bering Sea. To the east the range extends to the continental US coast,
BSAI Alaska Pollock – Final Report and Determination page 6 with the southernmost stock wintering as far south as Baja California in some years. To the west pollock are found to the Sea of Japan. They are widely distributed in the water column with fishable concentrations often in 100-200 meters, but can be found down to the demersal waters across the Shelf, from depths of 100 to over 500 m. The highest fishable concentrations are often over depths of 400-500 m (e.g., Figure 1).
Figure 1 Distribution of winter and spring catches of pollock in BSAI in 2013. Height of bar represents magnitude of catches. After Ianelli et al. 2013, Figure 1.2c.
Stock structure is complex. In the U.S. portion of the Bering Sea three stocks of pollock are identified for management purposes, although the degree of separation from the Western Bering Sea stock to the west and the Gulf of Alaska stock to the east is incomplete. The three stocks in the MSC assessment area consists of pollock occurring on the Eastern Bering Sea shelf from Unimak Pass to the U.S.-Russia Convention line; the Aleutian Islands Region encompassing the Aleutian Islands shelf region from 170oW to the U.S.-Russia Convention line; and the Central Bering Sea-Bogoslof Island pollock. The latter stock component is not targeted by any US fisheries, and is not considered further in the P1 assessment.
These three management stocks undoubtedly have some degree of exchange, and the Bogoslof stock forms spawning aggregations that has some connection with the deep water region of the Aleutian Basin (Ianelli et al. 2014b). Exact stock delineation is a subject of active research, with different studies producing results generally supporting the stocks used in management, but differing in details. DNA studies support differentiation of western and eastern BS stocks as well as from stocks further west (Shubina et al. 2009, Yanagimoto et al. 2012) but lesser differentiation among the Bering Sea stocks. Whereas some studies report nearly complete functional separation of spawning concentrations even within the BSAI components (Bacheler et al. 2010, Stepanenko and Gritsey 2014) and other studies suggest the spawning relationships among these stock components may be variable with environmental conditions (Grant et al. 2010).
Pollock are the most abundant finfish in much of the EBS and Gulf of Alaska, but abundance declines along the Aleutian Islands, and at depths shallower than generally 200 m. Habitat preferences in the water column are strongly influenced by water temperature (NMFS 2005). A number of studies have documented seasonal and inter-annual variation in both general distribution and degree of patchiness of distribution, and a general preference for waters of 2-3 degrees C (Horne and Walline 2005, Bacheler et al. 2012, Benoit-Bird et al. 2013, Kotwicki and Lauth 2013, Hulson et al. 2013, Barbeaux et al. 2013b). Moreover, studies of
BSAI Alaska Pollock – Final Report and Determination page 7 the pattern of changing abundance in space and time have shown the changes are the result of complex interacting processes of at least density dependence (expansion into less preferred substrate types at high densities), prey distributions, and water temperatures (Loggerwell et al. 2010, Stabeno et al. 2012, Baker and Hollowed 2014). These patterns have significant implications for the spatial and temporal prosecution of the fisheries (Stepanenko and Gritsey 2014, Barbeaux et al. 2014, Ianelli et al. 2014).
Maturation of pollock extends over several years with an age of 50% maturity generally 4, but with some variation. Maturation is size dependent, so effects of environmental conditions, particularly water temperature and prey supply can affect age of maturation (Adams et al. 2007, Stahl and Kruse 2008, Ianelli et al. 2014). Natural mortality is higher prior to maturation, when it is estimated to become fairly constant at 0.3 (Ianelli et al. 2014a), and again is thought to be influenced by environmental conditions, including feeding and predation (including cannibalism), primarily for juveniles (Boldt et al. 2013, Siddon et al. 2013a,b, Stige et al. 2013). Correspondingly, maximum age is estimated to be around 15 years, somewhat younger than most other BSAI whitefish.
Studies of data from the recent two decades indicate that pollock spawn in two pulses spanning 4-6 weeks: first in late February, then again in mid-late April (Bacheler et al. 2010). Spawning is widespread and exact locations vary somewhat inter-annually, with multiple areas of egg concentrations in typical years - north of Unimak Island and the Alaska Peninsula being the most concentrated. With large inter-annual variation in year-class strengths from similar spawning stock biomass (SSB), causes of recruitment variation have been studied intensively. Although there is some effect of SSB on recruitment (Litzow et al. 2014, Ianelli et al. 2014a,b), the effect is small compared to the large effects of environmental conditions on both physics of 0-group production (e.g., transport processes and larval energetics; Smart et al. 2013, Stachura et al. 2014, Vestfals et al. 2014, Guy et al. 2014) and age 0-3 survivorship (Heintz et al. 2013, Siddon et al. 2013a, Litzow et al. 2014, Strasburger et al. 2014).
Pollock are generally planktivorous throughout life, although the size of favoured prey increases with age (Adams et al. 2007, Heintz and Vollenweider 2011, Urban 2012, Siddon et al. 2013a) and cannibalism increases in importance with larger adult pollock biomasses (Boldt et al. 2012). Spatial overlap of various age groups of pollock have been documented to affect both growth and survivorship, as have the large and small-scale spatial overlap of pollock and their prey, which has been studied extensively (Coyle et al. 2011, Smart et al. 2012, Hulson et al. 2013, Holsman and Aydin 2015 ). Pollock can be an important prey for many predators in the BSAI, and that effect is considered in P2.
Together the effects of environmental conditions on recruitment levels and feeding have made pollock a major test species for investigating potential climate change effects on pollock. Although the studies vary in the details of their predictions, all suggest pollock may do less well under scenarios of climate warming (Coyle et al. 2011, Mueter et al. 2011, Hollowed et al. 2012, Litzow et al. 2014, Heintz et al. 2013) or increased acidification (Hurst et al. 2012, 2013). These results are already being considered in the context of future management of pollock (Ianelli et al. 2011, Haynie and Pfieffer 2013, Staeno et al. 2013b, Stepanenko and Gritsay 2014), although impacts possibly requiring major changes to management are sufficiently far in the future to not require being addressed in the current certification assessment.
3.3.2 Assessment Information
The information on the pollock assessment methods and stock status is taken from Ianelli et al. 2014a, Barbeaux et al. 2014, and Ianelli et al. 2014b, with some reference to prior
BSAI Alaska Pollock – Final Report and Determination page 8 assessments. EBS pollock are assessed and managed as a Tier 1 stock, whereas the AI component is assessed and managed as a Tier 3 stock (Barbeaux et al. 2014).
The main sources of data used in the assessment are the annual multispecies trawl survey of the Bering sea continental shelf (AFSC), the triannual and then biannual hydroacoustic survey of the EBS, the biannual multispecies trawl survey along the Aleutian Islands and slope of the continental shelf, sampling by at-sea observers on the commercial fishery, where coverage has been 100% for over a decade, and landings and logbook data. The depth range covered by the surveys has changed in different stanzas from 1980 to the present, but generally has covered depths starting with 200m, and extending to between 1,000 and 1,200 meters. These minor differences in depth are taken into account with survey data used on assessments of the resource.
Fishery catch data are available from 1979-2014 (EBS) or 1977-2014 (AI) and fishery length- frequency data from the full period are used in the assessment. Commercial catch data by season are presented in Table 1(taken from Ianelli et al. 2014a, table 1.2) and summed for the year for AI in Table 2 (after Barbeaux et al. 2014 Table 1A.1).
Table 1 Commercial catches of BSAI pollock by fishing season, from Ianelli et al. 2014a Table 1.2
BSAI Alaska Pollock – Final Report and Determination page 9
Table 2 Catch of AI pollock by year, from Barbeaux et al. 2014a Table 1A.1
Accurate recording of discards began to be kept in 1991, and Table 3 presents estimates of retained and discarded Pollock for all stock components from 1991 to the present.
BSAI Alaska Pollock – Final Report and Determination page 10 Table 3 Discards disaggregated by stock component from 1991 – 2014. From Ianelli et al. 2014a, table 1.5
Biomass estimated from the AFSC shelf trawl surveys first increased from 1982 to 1990, decreased to approximately the 1982 biomass in 1998, increased again until 2004, with a peak in 2002 that is particularly uncertain but may be comparable to the earlier peak, decreased again until 2009 when a possible record low estimate was reached, and has increased again thereafter. Data from the survey area-expanded biomass estimates are plotted in Figure 2 (from Ianelli et al. 2014a).
BSAI Alaska Pollock – Final Report and Determination page 11
Figure 2 Bottom trawl survey biomass estimates for EBS Pollock from 1982-present
The biomass estimates for the AI survey show a very different pattern. Abundance apparently increased 4 to 5 fold from 1975 to 1985, plateauing or slighting decreasing until 1990, and dropping precipitously to fall below the 1975 value by the later 1990s. Since that time, estimates have increased slowly but fairly consistently, but with lower values in the two most recent surveys (Table 4, taken from Barbeaux et al. 2014a).
Table 4 Survey biomass estimates for AI by subarea and in total from 1980 to 2014. Table from Barbeaux et al. 2014a Table 1A.9
The acoustic survey show four waves of Pollock moving through the population; the first present at the beginning of the survey in the early 1990s, the second commencing in the second half of the 1990s, and the third commencing in in the mid-2000s, and a new one, the largest in the series, showing in the most recent survey (Figure 3, after Ianelli et al. 2014).
BSAI Alaska Pollock – Final Report and Determination page 12
Figure 3 Estimated numbers at age from the acoustic surveys in EBS from 1991 to the present, from Ianelli et al. 2014 Figure 1.17.
3.3.3 Assessment Methods
The assessments are conducted in state-of-the art, single-species, stock-assessment models. The BSAI assessment includes separate analyses for the EBS, AI, and BO stocks. The models take account of all sources of fishing mortality on the pollock stocks as pollock catches and pollock bycatches are observed (or based on estimates expanded from observed catches), and both retained catches and discards are included in the total catch amounts specified in the assessment models. The assessments include application of
BSAI Alaska Pollock – Final Report and Determination page 13 precautionary harvest control rules from which acceptable biological catches (ABCs) are determined. The ABCs depend on the state of the stocks and are designed to achieve management objectives reflected by stock target and limit reference points. The structure of the BSAI assessment model and the approach to estimation was developed by Fournier and Archibald (1982), Methot (1989, 1990), and Kimura (1989, 1990). Parameters are estimated using AD Model Builder, a C++ software language and automatic differentiation library. The software estimates a large number of parameters in a non-linear model efficiently using differentiation methods extended from the work of Greiwank and Corliss (1991). The optimizer in AD Model Builder is a quasi-Newton routine and is described by Press et al. (1992). The assessment takes into account uncertainty and evaluates stock status relative to reference points in a probabilistic way.
Ianelli and Fournier (1998) evaluate the statistical properties of some model estimates. AD Model builder software is now in the public domain (www.otterrsch.com/admodel.htm), and open-source support allows for the development of advanced analyses such as Markov- chain Monte Carlo analysis (to evaluate model sensitivity to parameter estimates and information about data variances) and fully integrated Bayesian posterior distributions (to better evaluate uncertainty and provide projections useful for the NPFMC and NMFS in recommending ABC). On this latter issue, Stokes (2000) reports: There are major advantages with using a Bayesian approach (the calculation of intuitively, interpretable probabilities, a natural feed-in to decision analyses, the use of prior information from a variety of sources etc.) as opposed to more traditional fishery assessment models. Computation time, however, is a problem, especially for full sensitivity testing. The approach adopted for the EBS pollock assessment uses a fast approximation to the Bayesian analysis, still using prior information, to investigate alternative model structures and sensitivity to data and assumptions. In the final analysis, however, having adopted a particular model, it is then important to run the full Bayesian integration, to check fully integrated versus approximate posteriors.
All of the assessments take into account the major features relevant to the biology of pollock. In the EBS assessment, modelled processes include the initial age structure of the stock, the stock-recruitment relationship, natural and fishing mortality (with fishing mortality separable by year and fish age), mean fishery selectivity, and annual and by-age deviations in fishery selectivities and resource survey catchabilities and selectivities. The analytical approach involves a combination of independently estimated parameters available from life history studies and for the core preferred model another 758 parameters estimated conditionally on data and assumptions from the model (Ianelli et al. 2014a).
The EBS assessment includes resource survey data from the summer bottom-trawl and Echo-Integration Trawl (EIT) surveys (presented above) as well as catch per unit effort data from the Japanese fisheries during 1965-1977. The bottom-trawl and EIT surveys together cover a large portion of pollock habitat on the EBS shelf (Figure 4).
BSAI Alaska Pollock – Final Report and Determination page 14
Figure 4 Survey catches of Pollock for 2014, showing the distribution of sets across the EBS. The same survey design has been used in surveys since the commencement of the series, with minor expansions to the north or off the shelf in a few years. Table from Ianelli et al. 2014a, Figure 1.12)
Comprehensive data on the age and size structure of all significant catches are available, both from the fisheries and from fishery-independent resource surveys. As the BSAI stock assessment is an age-structured model of a fish stock, the results depend on accurate estimates of the age composition of the commercial catch and the catches from resource surveys. Aging error for both the fishery and resource-survey age composition data is incorporated via the use of a transition matrix (Kimura and Chikuni 1989, Kimura and Lyons 1991). Recent work to correct for density-dependent effects in abundance estimates from bottom trawl surveys has been done by Kotwicki et al. (2014) by combining a subset of bottom trawl catch data with simultaneously collected acoustic data from EBS pollock. The model also makes use of estimates of natural mortality, fraction mature at age, and length and weight at age from various studies of Alaska pollock life history. Pollock life history information has been collected from resource surveys and the fisheries since the late 1970s. Stomachs and gonads are collected in the resource surveys and from the fisheries to determine fecundity, the fraction mature at age, and trophic interactions (Brodeur et al. 1996). Comprehensive knowledge of some life history characteristics exists for all significant management units, and the dependence of life history parameters on stock density and abundance, the environment, and the ecology of related species is becoming understood and taken into account in the assessments. For other life history characteristics, knowledge is such that changes in the productivity and abundance of the stocks through time and space can be estimated (e.g., see GOA spawner productivity analysis in Figure 1.30, Dorn et al. 2014). Some Alaska pollock characteristics, such as natural mortality for adult pollock, have converged to a common value for the EBS and GOA (i.e., M equals 0.3 for all ages in the age 3+ biomass). In the BSAI assessments the rate of natural mortality does not vary by sex. In these areas the natural mortality estimate indicates that about 26 percent of the age 3+ biomass is lost to ecosystem predators and detritivores each year (Wespestad and Terry 1984).
The AI assessment is implemented through the Assessment Model for Alaska (referred to as AMAK). AMAK is a variation of the “Stock Assessment Toolbox” model presented to the Plan Team in the 2002 Atka mackerel stock assessment (Lowe et al. 2002), with some small adjustments. AMAK models catch-at-age 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 age groups that are modeled, with alternative formulations including different age ranges. Weight at age and maturation at age
BSAI Alaska Pollock – Final Report and Determination page 15 are estimated outside the model from biological data on the stock component, and recruitment strength for projection scenarios are estimated by alternative stock-recruit models. Depending on model structure either 137 or 136 parameters were estimated, covering cohort size for past year-classes, fishing mortality, selectivities etc. (Barbeaux et al. 2014a).
For all pollock assessments, recent-year results have estimated natural mortality conditionally within the model, and estimates of M have been in the vicinity of 0.20. For the 2014 AI assessment, the preferred model estimated natural mortality at 0.19 using a prior distribution with a mean of 0.20 and a coefficient of variation of 0.20 (Barbeaux et al. 2014a). Alternative models for natural mortality are examined annually. The natural mortality rate used in the EBS assessment has remained unchanged since 1982, and according to Ianelli et al. (2014a, p.1.11), the value “appear[s] reasonable for pollock.” However, continuing work on pollock natural mortality estimates involves linking predation impacts on natural mortality using multispecies models (James Ianelli, personal communication, January 5, 2015). Other pollock characteristics, such as the fraction mature at age, exhibit distinct differences that are taken into account in the assessments. For example, fecundity and maturation are known to be age dependent and so, where appropriate, age dependent parameter estimates are employed in the assessments. There is also some evidence of inter-regional and inter- annual differences in somatic growth (e.g., Figure 5).
Figure 5 Variation on weight at age from assessment to assessment, illustrative of the magnitude of this effect. Taken from Ianelli et al. 2014a, Figure 1.20
BSAI Alaska Pollock – Final Report and Determination page 16 The assessment authors routinely incorporate sensitivity analysis to investigate the effects of life history characteristics on management advice. Most recently, routines have been added to the model to evaluate sample size assumptions and changes in the selectivity parameterizations, and the stock-status projection model has been updated to handle uncertainty in the estimate of BMSY.
3.3.4 Assessment Results
For EBS, the main assessment resuits, including estimates of reference points and current biomass are summarized in the Executive Summary of Ianelli et al. 2014a, and reproduced below in Table 5. The results of the 2013 assessment are also summarized in the table, to illustrate the minor changes in perception of stock status from assessment to assessment.
Table 5 Summary of EBS assessment results, taken from Ianelli et al. 2014a, summary.
A similar tabulation is presented in Barbeaux et al. 2014a, for the AI stock component, and it is reproduced below in Table 6.
BSAI Alaska Pollock – Final Report and Determination page 17 Table 6 Summary of AI assessment results, taken from Barbeaux et al. 2014a Executive Summary.
The time series of EBS spawning biomass was estimated to have experienced a brief decline of nearly 40% in the early 1990s followed by a rapid recovery to pre-decline levels by 1993, and a long period of general stability until 2004. Then a second rapid and large decline (approximately 60%) occurred until 2008. Since then there has been a consistent increase in SSB, until the pre-decline level was reached again in 2013 or 2014 (Figure 6).
BSAI Alaska Pollock – Final Report and Determination page 18
Figure 6 Time series of SSB estimates with uncertainties and time series from past assessments also presented. Taken from Ianelli et al. 2014, figure 1.37.
The strong dynamics in SSB reflect major variations in strength of recruiting cohorts first to the fishable and then the spawning biomass. There is strong autocorrelation of the year- class strengths (Figure 7a), for reasons thought to be linked to environmental factors, as explained above in section 3.3.1. Strong year-classes have been produced by relatively low SSBs, and many average to below year-classes have been produced by large SSBs (Figure 7b)
BSAI Alaska Pollock – Final Report and Determination page 19
Figure 7 a – time series of recruitment strengths estimated by the 2014 assessment, and b – plot of year-class strengths by SSB, from the same assessment, with the MSY and B40% reference points illustrated. (Taken from Ianelli et al. 2014a Figure 1.36)
BSAI Alaska Pollock – Final Report and Determination page 20
Although Figure 6 and Figure 7 indicate SSB following recruitment pulses rather than being driven primarily by fishing pressure, there is some relationship between trends in fishing pressure and SSB. After an initial high exploitation rate at the end of the 1970s, exploitation never reached a level when harvests alone would be depleting the biomass. However, it did increase at the end of the 1980s and again in the early 2000s. Exploitation of the SSB has fallen in the second half of the 2000s and remained at levels consistent with stable or growing SSB in the past (Figure 8).
Figure 8 Fishing mortality and SSB exploitation rate from 1978 to the present, table from Figure 1.32 of Ianelli et al. 2014a).
For the AI stock component, the SSB and total biomass show a very different pattern. As discussed in the section on abundance and exploitation trends, there was an unexploited large increase in biomass in the early 1980s, which remained stable for nearly a decade and then returned equally quickly to pre-increase levels (Figure 9).
Figure 9 Time series of total biomass (left panel) and SSB (right panel) for AI stock component. From Barbeaux et al. 2014a Figure 1A.9
BSAI Alaska Pollock – Final Report and Determination page 21 The pulse in biomass is a direct result of the recruitment of the exceptionally strong year- class of 1979, and the several modest year-classes in the early 1980s. However recruitment fell to low levels before the SSB declined markedly, and has never recovered even to the levels in the 1980s (Figure 10).
Figure 10 Year-class strengths form 1978 to the present for the AI stock component. Taken from Barbeaux et al. 2014a, Figure 1A.21.
Fishing mortality of the AI stock component was around 0.3, approximately the current target for stocks with similar life histories, at the start of the time series, and then declined over the 1980s, during the period the 1979 year-class was contributing to the fishable biomass. Once that year-class passed through the population, F increased abruptly to remain at or above 0.3 until the end of the 1990s. At that point regulatory restrictions on AI pollock harvests were introduced. Since then, F has been negligible, but recovery of fishable and spawning biomass is progressing only very slowly (Figure 11).
BSAI Alaska Pollock – Final Report and Determination page 22
Figure 11 Time series of fishing mortality from the 2014 assessment of AI pollock. Taken from Barbeaux et al. 2014a, Figure 1A.18.
In summary, both stock components have experienced periods of stronger and weaker recruitment since the 1970s, when the assessment reconstructions begin. Although in some years, intensity of fishing mortality may have also contributed to trends in population biomass. In more recent decades, the harvest strategies have kept fishing mortality at low to moderate and sustainable levels. The stock biomass does still vary, reflecting the recruitment signals. However, the phase plot for EBS pollock shows that the harvest strategy has kept the stock well within the target reference points for the past two decades or more (Error! Reference source not found.). For the AI stock, the phase plot shows that although there were significant dynamics of stock status relative to the reference points in the 1980s and 1990s, for the past decade or more, all observations are clustered above the biomass reference point and far below the fishing mortality reference point, but with little response of SSB to the very low Fs (Figure 13).
BSAI Alaska Pollock – Final Report and Determination page 23
Figure 12 Phase plot of ratio of current F to F against current SSB to SSB, for EBS pollock since 1978. From Ianelli et al. 2014a Figure 1.35.
BSAI Alaska Pollock – Final Report and Determination page 24
Figure 13 Phase plot of ratio of current F to F against current SSB to SSB, for AI pollock since 1978. From Barbeaux et al. 2014a Figure 1A.22.
BSAI Alaska Pollock – Final Report and Determination page 25 3.4 Principle Two: Ecosystem Background
3.4.1 BSAI Ecosystems
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) (NMFS 2005), and Appendix C, Ecosystem Considerations for 2013 (Zador [ed.] 2013). 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 following text is largely based on these sources.
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.
3.4.2 Oceanography and bottom sediments
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 (AI). 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 exists 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 exists 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 alters 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 EBS 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
BSAI Alaska Pollock – Final Report and Determination page 26 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.
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 EBS waters. The AI continental shelf is narrow compared with the EBS 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 AI 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 BS, 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.
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 AI 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 AI, nearshore surface salinities are higher as the higher salinity EBS surface water occasionally mixes southward through the AI. 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.
3.4.3 Climate
Atmospheric pressure systems propagate across the North Pacific from west to east. The magnitude and position of the Aleutian Low during winter and spring underlie the inter- annual variability of atmospheric forcing over the North Pacific Ocean and Bering Sea area. The magnitude and position of the Aleutian Low have a strong bearing on weather in the region and are correlated with other climate indices such as El Niño/Southern Oscillation. These winter and spring pressure patterns are somewhat independent and have different oceanographic consequences. The winter index is referred to as the North Pacific Index and lower index implies stronger winds and warmer temperatures over the Bering Sea. In spring, the index is a displacement in pressure northward or southward. A shift to positive values provides for higher pressure and increased number of days with clear skies and increased Bering Sea surface temperature due to solar heating.
A major climate shift in the Bering Sea occurred after 1977, when conditions changed from a predominantly cold Arctic climate to a warmer, subarctic maritime climate. The warm winters
BSAI Alaska Pollock – Final Report and Determination page 27 of the late 1970s and 1980s were followed by cooler winters in the 1990s. This cooling was likely a result of a shift in the Arctic Oscillation and hence a tendency for higher sea-level pressure over the Bering Sea. Since 1998, negative sea level pressure (SLP) anomalies have prevailed, which is indicative of greater Pacific influence and consistent with generally milder winters. The winters of 2003-2005 were anomalously warm and comparable in scale with major warm episodes in the late 1930s and late 1970s – early 1980s. The spring transition occurred earlier, and the number of days with ice cover after March 15 had a significant downward trend. In 2005, the ice cover index reached the record low value. The lack of ice cover over the southeastern shelf during recent winters resulted in significantly higher heat content in the water column. In 2006 and 2007, however, cooler temperatures resulted in more ice cover. In 2007, the presence of sea ice together with below normal ocean temperatures likely resulted in the first ice edge bloom since 1999. There was a pronounced warming in late spring to the extent that upper ocean temperatures were above normal by the middle of summer. This anomalous warming can be attributed to the relatively high sea level pressure for the region and fewer storms than normal and hence less wind mixing of cold water from depth, and presumably, reduced cloudiness and hence greater solar heating. Considering that a substantial cold pool was also present, the thermal stratification on the Bering Sea shelf was also relatively large. Although these regime shifts have had dramatic consequences for the Gulf of Alaska and the EBS, impacts on the Aleutian Islands weather west of 170° W have been insignificant (Rodionov et al 2005).
3.4.4 Non-target Interactions
Detailed information on the nature and amount of retained species and the bycatch of the fishery, including marine mammals and seabirds is collected by The North Pacific Groundfish and Halibut Observer Program (Observer Program) operated by the NMFS (for details see Section 3.5.11). Data are collected by well-trained, independent observers to enable the North Pacific Fishery Management Council and NMFS to comply with the Magnuson-Stevens Fishery Conservation and Management Act, the Marine Mammal Protection Act, the Endangered Species Act, and other applicable Federal laws and treaties. 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 2014a). The restructured observer program minimally affects coverage in the BSAI pollock fishery as all vessels carry observers. 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 show the National Marine Fisheries Service intends to assign at-sea and shoreside observers to operations fishing under the authority of the BSAI FMP (NMFS 2013).
Observer coverage of the pollock fishery in the BSAI in 2013 is summarized in Table 7 (NMFS 2014a, Tables 4-4, 4-5). Over 96% of the catch was taken by catcher/processors and catcher vessels using non-pelagic gear and essentially 100% observer coverage. Most of the remaining catch was taken by catcher processors using non-pelagic trawls, which also had essentially 100% observer coverage. About 0.4% of the catch was taken by vessels using longlines and again this catch was essentially all observed.
BSAI Alaska Pollock – Final Report and Determination page 28
Table 7 2013 Observer coverage in BSAI pollock fishery. (NMFS 2014a, Tables 4-4, 4-5)
Gear Type Observed (%) Proportion catch (%) Longline Catcher/Processor 99.2 0.4 Catcher vessel Non-pelagic Trawl Catcher/Processor 99.3 3.0 Catcher vessel 83.7 0.1 Pelagic trawl Catcher/Processor 99.9 48.8 Catcher vessel 98.3 47.2
For the BSAI groundfish fisheries as a whole, the annual discard rate for groundfish decreased from 14.7 % in 1994 (total discards, 286,200 mt) to 4% in 2008 (total discards, 60,700 mt) with the greatest reduction occurring in 1998 (http://access.afsc.noaa.gov/reem/ecoweb/ecochaptdataselect.cfm?ID=60).
3.4.5 Marine mammals Some 29 species of marine mammals, from the orders Pinnipedia (seals, sea lion, and walrus), Carnivora (sea otter and polar bear), and Cetacea (whales, dolphins, and porpoises) inhabit the BSAI. They occupy diverse habitats, including deep oceanic waters, the continental slope and shelf. The marine mammal fauna of the Bering Sea is particularly rich because it includes north temperate, subarctic, and arctic species. Several species of the North Pacific fauna (e.g., harbor seal, Steller sea lion, sea otter, beluga whales, and Dall's porpoise) are resident in the area throughout the year. Other species (e.g., gray, fin, blue, and humpback whales, northern fur seals) migrate into the Bering Sea during summer months to feed. Allen and Angliss (2013) present the most recent population assessments of marine mammal species in Alaskan waters.
Marine mammals inhabiting the BSAI feed on a wide array of species and at several different trophic levels. Most tooth whales, phocid seals, fur seals, and sea lions feed principally on fishes, with invertebrates making up a relatively small part of the diet, although squids can be important in some species. Bearded seals and walruses eat mostly epifaunal and infaunal invertebrates, and thus their diets differ greatly from other pinnipeds. Baleen whales feed largely on planktonic crustaceans and small fishes.
Commercial fisheries effects on the availability of prey to marine mammals have been addressed by examining the potential for food competition (i.e., effects of fishery removals) and indirect or cascading effects of the fisheries on the food web of the mammals. For marine mammals whose diets overlap to some extent with the target or bycatch species of the fisheries, fishery removals could potentially decrease the density of prey fields or cause changes in the distribution of prey such that the foraging success of the marine mammals is affected. If alternate prey is not available or is of poorer nutritional quality than the preferred species, or if the animal must spend more time and energy searching for prey, reproductive success and/or survival can be compromised. In the case of marine mammals that do not feed on fish or feed on different species than are taken in the fisheries, the removal of a large number of target fish from the ecosystem may alter the predator and prey dynamics and thus the abundance of another species that is eaten by marine mammals. The mechanisms and causal pathways for many potential food web effects are currently poorly understood, but some of these effects have been explored in ecosystem models (e.g., Aydin et al. 2007).
Marine mammals are rarely taken incidentally in the BSAI pollock fisheries (Table 8). Comparison of species-specific estimates with the Potential Biological Removals (PBR) for
BSAI Alaska Pollock – Final Report and Determination page 29 each species indicates that interaction with the pollock fishery is below national limits and is highly unlikely to cause serious harm. PBR is not available for Ribbon seal, ringed seals and Dall’s porpoise as current estimates of population size are not available. However, a rough estimate of population size is about 50,000, 200,000, and 20,000 for these three species, respectively (Allen and Angliss 2013). Thus, mortality rates of these species from the pollock fishery indicate the fisheries are highly unlikely to cause serious harm or hinder recovery to these species.
Table 8 Estimates of the rate on serious interactions with the pollock fishery in the BSAI compared to the most recent estimate of PBR for each species (from Allen and Angliss 2013).
Species period Individuals/yr PBR (numbers/yr) Steller sea lions 2007-2010 6.2 275 (western stock) Northern fur seal 2007-2010 1.9 11,130 Harbour seal 2007-2010 0.3 1,167 Walrus 2007-2009 2.4 2580 Ribbon seal 2007-2009 1.2 1 Ringed seal 2007-2009 0.75 1 Dall porpoise 2007-2010 0.3 1 Humpback 2007-2010 0.4 8 1PBR not available
3.4.6 Seabirds
Some 71 species of seabirds occur over waters off Alaska and could potentially be affected by direct and indirect interactions with the BSAI and GOA groundfish fisheries. Thirty eight of these species regularly breed in Alaska and 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 and non- breeding migrant birds probably account for an additional 30 million birds. Most of the migrant birds are present only during the summer months (May through September) although some non-breeding albatross have been sighted at all months of the year. The distributions of species that breed in Alaska are well known in summer but in some species winter distributions are poorly documented or completely unknown (http://www.fws.gov/alaska/mbsp/mbm/seabirds/species_list.htm).
The US Fish and Wildlife Service compiles data collected for seabirds at breeding colonies throughout Alaska to monitor the condition of the marine ecosystem and to evaluate the conservation status of species. Their most recent report (Dragoo et al. 2014) covers the period through 2013. Statewide, productivity was below average in 25% of species, average in 69% and above average in 6% of species in 2013. Pelagic cormorants had high productivity, whereas glaucous-winged gull, thick-billed murre, parakeet auklet and crested auklet success was low in 2013. Across Alaska, 12% of species showed declining trends, 69% were stable and 19% exhibited an increasing trend between 2004 and 2013. Between 2004 and 2013, northern fulmars declined in all regions where they were monitored.
The Alaska Fishery Science Center (AFSC) has increased its research emphasis on seabird-fishery interactions, and has incorporated seabirds into ecosystems models being developed for the Bering Sea and Gulf of Alaska (e.g., Aydin et al. 2007). The AFSC is engaged in a series of studies designed to gain a better understanding of seabird interactions with the Alaska Groundfish trawl fisheries and the factors that affect those interactions. A summary of seabird and fishery interactions research is at: www.afsc.noaa.gov/refm/reem/Seabirds/Default.php.
BSAI Alaska Pollock – Final Report and Determination page 30
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. The AFSC Fishery Monitoring and Analysis Division monitors seabird bycatch through the Groundfish Observer Program. Between 36,000 and 39,000 coverage days are completed each year in the Alaskan groundfish fisheries (longline, pot, pelagic trawl, and non-pelagic trawl). These collected data are provided for analysis of seabird bycatch. The AFSC produces annual estimates of total seabird bycatch from these fisheries (http://www.afsc.noaa.gov/Quarterly/ond2013/divrptsREFM2.htm). The 2007-12 seabird bycatch estimates seabirds taken in fisheries include short-tailed albatross, black-footed albatross, Laysan albatross, unidentified albatross, fulmars, gulls, shearwaters, unidentified tubenoses, alcids, other bird species, and unidentified seabirds (those not identified to one of the other ten groups)(Table 9). Estimates are produced from the NMFS Alaska Regional Office, Catch Accounting System.
The 2012 estimated numbers for the combined groundfish fisheries (Table 9) are 40% below the 5-year average of 8,295 for 2007-11. Albatross bycatch was lower in 2012 by 27% compared to the previous 5 years, with the greatest decrease in Laysan (Phoebastria immutabilis) and Black-footed (P. nigripes) Albatross (36% and 11% declines, respectively). Northern fulmar (Fulmaris glacialis) bycatch, down by 39% compared to the 5-year average and 52% from the year before, remained the highest proportion in the catch at 61%. Average annual mortality for fulmars since 2007 has been about 4,600. Nevertheless, when compared to estimates of total population size in Alaska of 1.4 million, this bycatch represents an annual 0.3% mortality due to groundfish fisheries.
Trawl fisheries for pollock and other species account for a small fraction of seabird bycatch, as demersal longline fisheries in Alaska are responsible for about 91% of seabird bycatch annually (http://alaskafisheries.noaa.gov/protectedresources/seabirds/guide.htm).
Table 9. Total estimated seabird bycatch in Alaskan federal groundfish fisheries, all gear types and Fishery Management Plan areas combined, 2007 through 2012. Source: AFSC
Species/ Year Species Group 2007 2008 2009 2010 2011 2012 Unidentified 16 0 0 0 0 0 Albatross Short-tailed 0 0 0 15 5 0 Albatross Laysan 17 420 114 267 189 128 Albatross Black-footed 176 290 52 44 206 136 Albatross Northern 4,581 3,426 7,921 2,357 6,214 3,016 Fulmar Shearwater 3,602 1,214 622 647 199 510 Storm Petrel 1 44 0 0 0 0 Gull 1,309 1,472 1,296 1,141 2,208 885
BSAI Alaska Pollock – Final Report and Determination page 31
Kittiwake 10 0 16 0 6 5 Murre 7 5 13 102 14 6 Puffin 0 0 0 5 0 0 Auklet 0 3 0 0 0 7 Other Alcid 0 0 105 0 0 0 Other Bird 0 0 136 0 0 0 Unidentified 509 40 166 18 259 284 Total 10,228 6,914 10,441 4,596 9,298 4,977
Pelagic trawl fisheries during the period 2007-2010 mainly interacted with Northern fulmars, with numbers ranging from 69 to 552; shearwaters and gulls were also taken in small numbers, typically less than 25 birds of each of these taxa each year (http://www.afsc.noaa.gov/refm/reem/Seabirds/Seabird%20bycatch%202007%20to%202010 _Alaskan%20Gndfish_PrelimReport.pdf). Northern fulmars in the pelagic trawl fisheries represented about 4-10% of the total estimated fulmar bycatch over the 2007-2010 period.
NOAA Fisheries website has information for fishermen on the current regulations and measures to reduce/avoid seabird bycatch (http://alaskafisheries.noaa.gov/protectedresources/seabirds/guide.htm). 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.
3.4.7 Retained
Retained species in the BS pollock fishery are given in Table 10. Thirteen species or species groups are retained, however, each of the species or species groups accounts for <0.05% of
BSAI Alaska Pollock – Final Report and Determination page 32 the Pollock catch and therefore are considered di minimis and not considered further. Thus there are no main retained species. The AI pollock catch has been small since 1999, typically < 2,000 t/yr and therefore retained catch is not reported in the AI assessment (Barbeaux et al. 2014). Although their catches are <0.05%, skates, sharks and sculpins are considered vulnerable species because of their low potential rate of increase. This coupled with the large catch of Pollock can result in sizable removals of these vulnerable taxa. The most recent assessments estimate the 2014 ABCs for these taxa at 35,383 t, 1,020 t, and 42,318 t, respectively. Relative to these ABCs, the Pollock fishery retained 4.2%, 7.4% and 0.45% of the recommended catch of skates, sharks, and sculpins, respectively.
Table 10 Species retained (t) in the BS pollock fishery during the past 5 years (Ianelli et al. 2014). Greyed species are <0.05% of the catch. Those in bold italics are nonetheless considered vulnerable.
Taxa 2010 2011 2012 2013 2014 Pacific cod 6987 9,998 10,047 8,944 5,193 Flathead sole 4309 4,846 3,957 3,142 2,537 Rock sole 2330 8,463 6,819 6,360 4,380 Yellowfin sole 1057 1,095 1,452 2,072 1,927 Arrowtooth 1502 1,599 735 958 756 POP 231 660 713 611 1,295 Atka mackerel 57 894 263 70 117 turbot 26 29 53 21 41 Alaska plaice 126 74 129 147 322 skates 1,886 2,342 2,017 1,756 811 squids 277 178 495 117 1,478 sharks 26 65 55 43 75 sculpin 258 315 286 221 189 Other 375 590 512 242 495
3.4.8 Bycatch
More than 15 taxa are taken as bycatch in the BS pollock fishery. The biomass of the bycatch is low relative to the pollock catch and all the bycatch taxa, excepting Scypho jellyfish, account for <0.05% of the directed catch (Table 11) and are considered di minimus and not considered further. The biomass of Scypho jellyfish taken in the bycatch is nonetheless <2% of the Pollock catch. Therefore, there are no main bycatch species.
Table 11 Bycatch of non-target species in the BS Pollock fishery (Ianelli et al. 2014). Greyed species are <0.05% of the catch.
Taxa 2010 2011 2012 2013 2014 Scypho jellies 2,661 8,893 3,878 6,117 13,886 Misc fish 173 325.8 163 151 50.1 Sea star 13.2 37.5 8.1 14.8 30.1 Eulachon 0.7 3.3 1.7 0.8 2.4 Eelpouts 2.1 1.3 1.3 1.8 8.1
BSAI Alaska Pollock – Final Report and Determination page 33 Taxa 2010 2011 2012 2013 2014 Osmerids 0.1 0.3 0.2 0.2 0.5 Sea pens 3.1 2.9 3.9 2.3 4 Sponge 4.9 3.9 0.5 6.6 2.5 Snails 1.4 1.4 1.5 1.1 1.7 Lanternfishes 0 0 0.1 0 0 Sea anemone 2.4 2 1.7 2.4 2 Brittle star 0.3 0.2 0.1 0.1 2.3 Urochordata 3.1 0.9 0.1 1.9 1.1 Invertebrates 1 0.7 2.2 0.2 0.6 Misc crabs 0.1 0.3 0.2 0.6 0.4 All other 2 1.8 0.6 0.8 1.7
Prohibited species identified in the BSAI FMP (NPFMC 2014) are Pacific halibut, Pacific herring, Pacific salmon, steelhead trout, king crab, and Tanner crab. They must be avoided while fishing groundfish and must be immediately returned to the sea with a minimum of injury when caught. All catch of pollock, Pacific cod, and shallow water flatfish must be retained when directed fishing for those species is open. At-sea discarding of any processed product from pollock, Pacific cod, or shallow water flatfish is also prohibited, unless required by other regulations.
The bycatch of crab species in the BSAI pollock fishery includes blue and red king crabs and Tanner crabs. Opilio Tanner crabs are most frequently taken (Table 12). Crab stocks are assessed by the NMFS to support management under the BSAI King and Tanner Crab FMP. Crab abundance is measured annually using the groundfish bottom-trawl survey. Total catch mortality of the Bering Sea Opilio stock in 2013/14 was 28,200 t, while the retained catch in the directed fishery was 24,480 t. This is below the 2013/14 OFL of 78,100 t. Snow crab bycatch occurs in the directed fishery and to a lesser extent in the groundfish trawl fisheries. Estimates of trawl bycatch in recent years are less than 1% of the total snow crab catch (The Plan Team for the King and Tanner Crab Fisheries of the Bering Sea and Aleutian Islands 2014). Estimates of stock status were above B35% in the assessment since 2010/11, and 96% of the value for B35% calculated in the 2014 assessment indicating that the stock is fluctuating about its reference point.
Table 12 Bycatch estimates of prohibited species caught in the BS directed pollock fishery, 2009 - 2014 based on then AKFIN (NMFS Regional Office) reports from observers. Herring and halibut units are in t, all others represent numbers of individuals caught. Data for 2014 are preliminary (Ianelli et al. 2014). Greyed species are <0.05% of the catch.
Taxa 2009 2010 2011 2012 2013 2014 Bairdi crab 6120 13589 10319 5413 12149 Blue king crab 20 29 20 0 34 Chinook salmon 12743 9831 25499 11344 13108 15020 Golden king crab 0 0 0 0 147 Pacific halibut 588 357 509 475 347 191 Herring 66 351 377 2352 958 Opilio crab 7428 9431 6332 6106 8549 Red king crab 1137 1009 577 344 316 Other salmon 46893 13797 193555 22390 125525 219092
BSAI Alaska Pollock – Final Report and Determination page 34 Pacific herring are considered a prohibited species in the groundfish fishery, including BSAI pollock, and must be immediately returned to the sea with a minimum of injury (NPFMC 2014). Historically, bycatch of herring was high in the Bering Sea pollock fishery. But, in the early 1990s the Council adopted a prohibited species catch (PSC) limit of 1 percent of the herring biomass. Herring stock trends are assessed by the State of Alaska Department of Fish and Game (ADFG) using an age-structured model. Once reached, the cap triggers closure of a predetermined “herring savings area” for the remainder of the season. This measure has succeeded in limiting herring bycatch in the pollock fishery (Table 13). Herring bycatch in other target groundfish fisheries is very low https://www.afsc.noaa.gov/REFM/Docs/2013/BSAIforage.pdf.
Table 13 Herring PSC and PSC Limit, BSAI, 2003-2013 (AFSC 2011)
Year Herring PSC Herring PSC Limit 2003 962 1,525 2004 1,208 1,876 2005 692 2,013 2006 485 1,770 2007 409 1,787 2008 216 1,726 2009 63 1,697 2010 356 1,973 2011 397 2,273 2012 2,376 2,094 2013 986 2,648
Pacific halibut in the BSAI is assessed annually using an age-structured, coast-wide model of the stock, including removals from all fisheries including the BSAI pollock; the bycatch of halibut varies between 50-275 tons annually. The NPFMC http://www.npfmc.org/bsai-halibut- bycatch/ is now considering the impacts of bycatch on the directed halibut fishery. The NPFMC states the issue as: “Declines in the exploitable biomass of halibut since the late 1990s, and decreases in the Pacific halibut catch limits set by the IPHC for the directed BSAI halibut fisheries, have raised concerns about the levels of halibut PSC mortality by the commercial groundfish trawl and hook-and-line sectors. Reductions in halibut PSC mortality have not been proportional to the reductions in directed halibut harvest limits over this time period, although Council recognizes industry efforts to reduce halibut PSC mortality. … The proposed action would reduce the halibut PSC limits in the BSAI, which are established for the BSAI trawl and fixed gear sectors in Federal regulation, and in some cases, in the BSAI Groundfish FMP. … Halibut savings that would occur from reducing halibut PSC mortality below current levels would accrue to the directed halibut fisheries in both the near term and long term.”
The assessment team reviewed the issue for BSAI halibut PSC reduction. The IPHC assesses/manages the resource as a single stock with varying levels of exploitation by area. The IPHC allocates catch by area relative to the exploitable biomass in the area. Currently, the stock as a whole is within biological limits http://www.iphc.int/publications/rara/2014/rara2014_11stockassessment.pdf: “The current level of spawning biomass is estimated to be 42% of the equilibrium condition in the absence of fishing, with a 10 out of 100 chance that the stock is below the 30% relative spawning biomass harvest policy threshold. All sources of estimated removals for 2014 correspond to a fishing intensity point estimate of F43%. Harvest levels of this magnitude are generally consistent with target rates for many similar stocks.”
BSAI Alaska Pollock – Final Report and Determination page 35
Halibut in the BSAI is a minor bycatch species for the Alaska pollock fishery, and within biological limits. The responsibility for balancing the effects of the bycatch and directed catch falls to the NPFMC. The IPHC will reduce directed catch as necessary to keep exploitation within bounds. Any benefits from bycatch reduction will accrue to the directed halibut fishery. Therefore, the team has concluded that the decision by the NPFMC on halibut PSC reduction is primarily allocation, with minimal conservation implications, and that the team will not factor this issue into scoring of bycatch performance indicators.
Reducing the bycatch of Chinook salmon in the pollock fishery has been an issue the NPFMC has been addressing for some time. Chinook salmon bycatch in 2014 was once again low at 15,020 (36% of the 2003-2014 mean value) and consistent with the magnitude of bycatch since the implementation of Amendment 91 in 2011, which placed a hard cap on the level of bycatch permitted. In addition to Amendment 91, the council introduced the C5 Bering Sea Salmon Bycatch Council motion in June 7, 2014. The Council recognizes that Chinook salmon are an extremely important resource to Alaskans. Multiple years of historically low Chinook salmon abundance have resulted in significant restrictions for subsistence users in western Alaska and failure to achieve conservation objectives. Throughout the course of development of salmon bycatch management, NMFS has consulted with Alaska natives and Western Alaska communities on responses to the salmon issues in the Bering Sea (e.g., Harrington and Gerke 2015; see also Section 3.5.1).
The current Chinook salmon bycatch reduction program under Amendment 91 was designed to minimize bycatch to the extent practicable in all years. In October 2014, the NPFMC requested a discussion paper to evaluate several aspects of salmon PSC management in the Bering Sea in order to provide information necessary to initiate modifications to the current management program. Information on two broad topics was requested: 1) evaluation of the regulatory changes needed to incorporate Bering Sea chum salmon bycatch management into the Chinook salmon Incentive Program Agreements (IPAs); and 2) an evaluation of possible measures to refine the current Chinook salmon bycatch management program either by regulatory measures or through incorporation of additional provisions in the IPAs. While Chinook salmon bycatch impact rates have been low under the program, there is evidence that improvements could be made to ensure the program is reducing Chinook salmon bycatch at low levels of salmon abundance. The NPFMC, at the April 2015 meeting, passed a package of Chinook and chum salmon bycatch reduction measures for implementation in 2016-2017 (NPFMC 2015). Specifically, the Council action incorporated chum salmon avoidance into Amendment 91 Incentive Plan Agreements, including more strict requirements for Incentive Plan Agreements, requires salmon excluder devices, establishes penalties for vessels that consistently have high bycatch relative to the fleet, adjusts seasonal allocations, and lowers the hard cap and performance standard by 25% in years of low Chinook abundance.
In October 2013, the NPFMC reviewed a discussion paper, which provided updated Adult Equivalent (AEQ) analysis of the bycatch estimates to aggregate Alaskan rivers of origin as well as an analysis of fishery and bycatch performance in the first three years of the bycatch management program. The main differences from the earlier work on Chinook salmon adult equivalent (AEQ) analysis were the additional, genetic data have been collected and used to determine stock of origin for a more representative sampling scheme (for this purpose), the in-river maturity information was updated by ADFG, and the genetic stock composition estimates were appropriately lagged to coincide with the annual AEQ values (previously the genetic stock composition information from the bycatch was assumed to be static). lanelli and Stram (2014) provide updated estimates of the bycatch impact on Chinook salmon runs to the coastal west Alaska region and found that the peak bycatch levels exceeded 7% of the total run return. Since 2011, the impact has been estimated to be below 2%. Also in 2013, the Arctic-Yukon-Kuskokwim Sustainable Salmon Initiative Chinook Salmon Expert
BSAI Alaska Pollock – Final Report and Determination page 36 Panel submitted a report summarizing available information and presenting seven hypotheses for the declines in salmon abundance (Schindler et al. 2013). Schindler et al. concluded that “Based on available data, the bycatch within the domestic walleye pollock fisheries seems unlikely to have been the primary cause for the recent dramatic declines of Chinook salmon in the AYK region, because estimates of bycatch from this source are not high relative to the estimated declines in the total returns to the drainages.” Thus, the AEQ analyses and the amount of bycatch relative to the declines in abundance provide evidence that the impacts of the Chinook salmon bycatch in the pollock fishery on returns to Alaskan rivers are expected to be small.
3.4.9 ETP species
The endangered, threatened, and protected (ETP) species inhabiting the BSAI and GOA are mainly under the responsibility of NMFS (Table 14). The US Fish and Wildlife Service (FWS) are responsible for sea otters and for threatened and endangered seabird species. Assessments of the effects of the Alaska groundfish fisheries on many ETP species are provided in the Alaska Groundfish Harvest Specifications Environmental Impact Statement (NOAA 2007).
Table 14 Endangered, threatened, and protected species in the BSAI and GOA based on listing of Endangered Species Act (ESA) and Marine Mammal Protection Act (MMPA).
ESA Endangered (E) Threatened (T) MMPA Depleted Beluga whale (E-Cook Inlet) Killer whale (Transient) Blue whale (E) Bowhead whale (E) Fin whale (E) Humpback whale (E) North Pacific right whale (E) Sei whale (E) Sperm whale (E) Steller sea lion (E-Western) Northern fur seal (Eastern Pacific)
Short-tailed albatross (E) Spectacled eider (T) Steller’s eider (T)
Northern sea otter (T-Southwest AK) Pacific leatherback turtle (E)
Chinook salmon (T-Lower Columbia River) Chinook salmon (T-Upper Willamette River) Chinook salmon (T-Upper Columbia River, Spring)
NMFS annually categorizes all U.S. commercial fisheries under the MMPA List of Fisheries according to the levels of marine mammal mortality and serious injury. Category III fisheries interact with marine mammal stocks with annual mortality and serious injury ≤ 1% of the marine mammal’s Potential Biological Removal (PBR) level and total fishery-related mortality < 10% of PBR. Any fishery in Category III is considered to have achieved the target levels of mortality and serious injury. Category II fisheries have a level of mortality and serious injury that > 1% but is < 50% of the stock’s PBR level, if total fishery related mortality is ≥ 10% of the PBR. Category I fisheries have frequent mortality and serious injury of marine mammal resulting in annual mortality ≥ 50% of PRB. There are no Alaska groundfish fisheries listed in
BSAI Alaska Pollock – Final Report and Determination page 37 Category I. The BSAI pollock pelagic-trawl fishery is Category II (http://www.nmfs.noaa.gov/pr/interactions/lof/final2014.htm).
Although most of the species in Table 14 do not interact with the pollock fishery to any significant degree, two pinniped species, three seabirds species, and several salmon stocks are addressed in more detail below as they may more frequently interact directly or indirectly with the BSAI pollock fishery.
Steller sea lion - The western U. S. stock of Steller sea lion (Eumetopias jubatus) is currently listed as “endangered” under the ESA, and designated as “depleted” under the MMPA as a result of a dramatic decline in numbers through the 1990s. Steller sea lions are widely distributed in the North Pacific, but are most abundant in the GOA and Aleutian Islands. Although not migratory, individuals disperse widely outside of the breeding season (late May-early July), thus potentially intermixing with animals from other areas. They are the largest member of the Otariid (eared seal) family and are highly size-dimorphic. There is an extended period of pup dependence. Weaning takes place gradually during the winter and spring prior to the following breeding season, but it is not uncommon to observe 1- or 2-year- old sea lions still suckling. Steller sea lions feed on wide variety of fishes and cephalopods. Steller sea lion diets vary geographically and seasonally. Some of the more important prey species in Alaska include walleye pollock (Theragra chalcogramma), Atka mackerel (Pleurogrammus monopterygius), Pacific herring (Clupea harengus), Capelin (Mallotus villosus), Pacific sand lance (Ammodytes hexapterus), Pacific cod (Gadus macrocephalus), and salmon (Oncorhynchus spp.).
Many factors could have contributed to the decline of the western Steller sea lion stock in the 1980s and 1990s. These include incidental take in fisheries, illegal and legal shooting, predation or certain diseases, as well as other factors that indirectly would lead to population declines by reducing productivity, such as competition with groundfish fisheries. These factors were evaluated against relevant empirical studies in the Final Revised Steller Sea Lion Recovery Plan (NMFS 2008) and have been most recently evaluated in the current Steller sea lion Biological Opinion (NMFS 2014b).
Estimates of the numbers Steller sea lion pups and non-pups (adults and juveniles) by the National Marine Mammal Laboratory were made mostly recently in June-July 2013. During the period 2000-2013, these surveys indicate that in the Eastern Aleutians both pups and non-pups have increased at average rates of 3.6% per year. Counts of pups and non-pups in the Central Aleutians have remained roughly stable (i.e., credible limits include zero rate of increase), but counts in the Western Aleutians have declined by 8.9% per year in pups and 7.2% per year in non-pups (Fritz et al. 2013). Overall, the numbers of sea lions have increased but significant declines are still evident in the western Aleutians.
The most recent BiOp concluded that the western Steller sea lion stock in Alaska appears to be increasing at a rate of 1.67% per year (95% credible interval: 1.01, 2.38) and in Russia this stock is also estimated to be increasing. There are regional differences in the population growth rate with apparent declines occurring from the central Aleutian Islands through eastern Kamchatka. Model forecasting shows a virtually nil probability of the western Steller sea lion stock reaching quasi-extinction in 100 years, although if the recent rate of decline continues, this conclusion would not be true for the western Aleutian Islands sub-population.
The Risk Analysis in section 5.4 of the BiOp (NMFS 2014b) evaluated whether the proposed groundfish fisheries are likely to result in local depletions of prey in times and areas that are important to sea lions, with an emphasis on adult females in winter and spring. There remains little evidence for the effect of the pollock fishery on Steller sea lion demography (reviewed by Bernard et al. 2011, three CIE reviews (available on the NMFS website), also see Conn et al. 2013), but the BiOp notes that there are extensive gaps in the available
BSAI Alaska Pollock – Final Report and Determination page 38 information which prevent understanding the causal relationships affecting Steller sea lions in the western and central Aleutian Islands. Therefore, although NMFS concluded a finding of no jeopardy with respect to the pollock fishery, they proposed a cautionary approach to fishing for prey species in Steller sea lion critical habitat, especially in winter when we have the least information about groundfish biomass.
A number of management actions were implemented between 1990 and 1998 to promote the recovery of the western U. S. stock of Steller sea lions, such as the establishment of critical habitat. Critical habitat included 3 nmi no-entry zones around rookeries, prohibition of groundfish trawling within 10-20 nmi of certain rookeries, and three special aquatic foraging areas in Alaska; the Shelikof Strait area, the Bogoslof area, and the Seguam Pass area. There were also measures that changed the spatial and temporal allocation of Aleutian Island Atka mackerel total allowable catch. Modifications finalized in 2002 involved a complex set of regulations that changed the temporal and spatial distribution of the pollock, Pacific cod and Atka mackerel fisheries throughout the range of the western stock in U.S waters, but also removed the blanket prohibition of fishing with trawl gear within 10 (or 20) nmi of rookeries in the western stock in U.S. waters.
Effective December 26, 2014, new measured for the Atka mackerel, Pacific cod, and pollock fisheries primarily in the Aleutian Islands disperse fishing effort temporally and spatially to provide protection from potential competition for important Steller sea lion prey species. The new measures apply a combination of closed areas, harvest limits, and seasons (http://alaskafisheries.noaa.gov/frules/79fr70286.pdf).
Northern fur seals - Fur seals are a size-dimorphic species, in which adult females and males weigh 30-50 kg and 185-275 kg, respectively. The Pribilof Island population of the Eastern Pacific stock of Northern fur seals was designated as "depleted" under the Marine Mammal Protection Act (MMPA) in 1988 because it had declined by more than 50% since the 1950s. The Eastern Pacific stock is currently estimated at about 600,000 animals from a historical high of 2.1 million in the late 1940s to early 1950s. A Conservation Plan has been developed (NMFS 2007).
Northern fur seals range from southern California north to the Bering Sea and west to the Okhotsk Sea and Honshu Island, Japan. During the summer breeding season, most of the worldwide population is found on the Pribilof Islands in the southern Bering Sea. Following the breeding season, both sexes migrate south and spend the next 7-8 months at sea. Adult females and pups from the Pribilof Islands migrate through the Aleutian Islands into the North Pacific Ocean, often to the Oregon and California offshore waters. Many pups may remain at sea for 22 months before returning to their rookery of birth. Adult males generally migrate only as far south as the Gulf of Alaska in the eastern North Pacific.
Fur seals diet composition varies seasonally and geographically. Sixty-three species of fishes and squids have been identified throughout their range. In the Bering Sea, fur seals primarily consume walleye pollock, squids, salmon, Pacific sandlance, northern smoothtongue and Pacific herring (Sinclair et al. 2008).
Pup production on the Pribilof Islands (St. Paul and St. George Islands combined) declined 43.8%, or at an annual rate of 4.3% between 1998 and 2010. Although pup production has declined greatly in recent decades, the 2012 estimate for St. Paul Island (97K) was 2.5% greater than the estimate in 2010. The 2012 pup production estimate for St. George Island (16K) was 9.9% less than the estimate in 2010. Overall pup production for the Pribilof Islands increased approximately 0.5% from 2010 to 2012, marking the first year since 1998 that estimated pup production did not decline. By contrast, the 2011 pup production estimate for Bogoslof Island (23K) was 30.3% greater than the estimate in 2007. Since the first pup
BSAI Alaska Pollock – Final Report and Determination page 39 was observed on Bogoslof Island in 1980 pup production has increased at an annual rate of 38.2% and at an annual rate of 11.7% since 1997 (http://www.afsc.noaa.gov/nmml/species/species_nfs.php).
Although Northern fur seals face a variety of threats, the factors affecting the survival of the Pribilof component survival are poorly understood, particularly while the animals range outside the Bering Sea. Entanglement in lost fishing gear and other plastics is a known source of fur seals mortality that may have contributed significantly to declining trends of the population on the Pribilof Islands during the late 1970s. Studies on the Pribilof Islands between 1995 and 2006, show that although sighting of entangled fur seals persist, the rates in females and pups are low (<<1%, Zavadil et al. 2007).
Recent studies, comparing the foraging behavior, diets and performance of the lactating fur seal on the Pribilof Islands and on Bogoslof Island indicate that Pribilof females are working much harder (longer and more distant feeding trips) and yet are producing lighter and leaner offspring than females at the increasing Bogoslof population (Springer et al. 2010 unpublished report to NPRB, NMFS unpublished). These findings suggest that food abundance or distribution may differ between these sites. As pollock are a component of this species diet (e.g., Sinclair et al. 2008), reduced prey availability as a result of the indirect effects of commercial groundfish fisheries has been proposed as a mechanism for the fur seal decline (e.g., Trites and Larkin 1989, NMFS 2007). Cornick (2013) reviewed the recent literature on diet and foraging behaviour of fur seals and concluded that “There is no current evidence that the commercial fishery is directly competing with fur seals for pollock.” Cornick went on to conclude that “it is unclear if competition for juvenile pollock exists between adult pollock, fur seals, and arrowtooth flounder or other predators, although some data are suggestive. Adult pollock are the largest consumers of juvenile pollock, and fur seals and arrowtooth flounder are both opportunistic predators that will switch prey as availability changes.” Thus, while there is some basis for considering that the pollock fishery might influence fur seals dynamics, there seems to be little evidence of a negative impact.
Seabirds - There are three species of seabirds listed as threatened or endangered in the BSAI (Table 7). The endangered Short-tailed albatross is a long-lived species with a low reproductive rate. 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 1200 birds and is increasing. 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. The recovery plan states that the major threat of over-exploitation that led to the species’ original endangered status no longer occurs and that the most notable existing threat to the species’ recovery is the possibility of an eruption of Torishima, their main breeding site (USFWS 2008). There have been no mortalities associated with the BSAI pollock fishery.
The breeding population of spectacled eiders (Somateria fischeri) on the Yukon-Kuskokwim (Y-K) Delta declined by over 96% between the 1970s and the 1990s. The causes of this steep decline remain unknown, but its magnitude prompted the U.S. Fish and Wildlife Service to list the species as threatened under the Endangered Species Act in 1993 (http://www.fws.gov/alaska/fisheries/endangered/species/spectacled_eider.htm). Spectacled eiders breed along the central coast of the Yukon-Kuskokwim Delta, the arctic coastal plain of Alaska, and the arctic coastal plain of Russia. An average of about 5,000-6,000 nest on the Y-K Delta today. Winter surveys in the Bering Sea, which include nonbreeding birds, indicate a minimum worldwide population of about 370,000. Lead poisoning, predation and illegal harvest are listed as the major threats by the recovery team. They over winter in an
BSAI Alaska Pollock – Final Report and Determination page 40 area south of St. Lawrence Island, but none were taken in BSAI pollock fishery during the period 2007 to 2012.
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). Population sizes are only imprecisely known. The Russian Pacific population likely contains between 50,000 to 100,000 individuals. 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 pollock fishery as none have been recorded by the AFSC seabird bycatch program.
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. New observer sampling protocols implemented in 2011 should provide reliable estimates of the stock of origin (from both CWT and genetic stock assignment) of the Chinook bycatch from the pollock fishery. In 2013, the NMFS AFSC Auke Bay Lab reported genetic stock identification results for a subset of Chinook salmon bycatch samples collected in the Bering Sea from the bycatch of the 2011 groundfish trawl fisheries, mostly pollock (Guthrie et al. 2013). The 2,473 Chinook salmon bycatch samples originated from stocks in Coastal Western Alaska (68%), North Alaska Peninsula (9%), British Columbia (8%), and U.S. west coast (6%). The remaining 9% comprised stocks from Northern Alaska Peninsula, Washington, Oregon, and Upper and Middle Yukon River, confirming the previous studies. Updated results indicate that 84% of the CWT 14 Chinook salmon bycatch in the BSAI originated from British Columbia and Alaska. Starting in 2011, sampling expansion factors can be calculated for CWT recoveries in the bycatch of the Bering Sea pollock fishery, thus allowing calculation of total estimated contributions for stocks of interest. However, few CWTs have been recovered in the BSAI trawl fishery in the last couple years (NMFS 2013).
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.
3.4.10 Habitat
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
BSAI Alaska Pollock – Final Report and Determination page 41 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 (see BSAI FMP, NPFMC 2014).
In 2005, NMFS published the Final Environmental Impact Statement (EIS) for Essential Fish Habitat (EFH) in Alaska which identified EFH for fisheries managed by the NPFMC, recommended an approach to identify Habitat Area of Particular Concern (HAPC), and to minimize to the extent practicably possible the adverse effects of fishing on EFH (NMFS 2005; http://alaskafisheries.noaa.gov/habitat/seis/efheis.htm). As a result all FMPs now include a description and identification of essential fish habitat, adverse impacts, and actions to conserve and enhance habitat. In 2010, NOAA Fisheries conducted a 5-yr review of EHF (http://alaskafisheries.noaa.gov/habitat/efh/review.htm). That 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, p.66). The second 5-yr review is scheduled for 2015.
Pelagic trawls used in the pollock fishery are fished with doors that do not contact the seafloor and because the pelagic trawl’s unprotected footrope effectively precludes the use of these nets on rough or hard substrates, they do not affect the more complex habitats that occur on those substrates (NMFS 2005). Pelagic trawls are estimated to contact the seafloor across some substrates for 44% of the duration of a tow (Final EFH EIS, Appendix B, Table B.2-4). Pelagic trawl footropes are made of steel chain or cable. Regardless of the actual percentage of time spent on the sea floor, it is clear that a moving footrope in contact with the seafloor impacts habitat, and is particularly damaging for animals anchored on or in the sediment (NFMS, Final EFH EIS, pg. 3-166). Damage from footropes was estimated at 20% reduction per gear contact and 30% reduction for both living and non-living structure, respectively. Recovery rates for infauna and epifauna were estimated at 3 to 4 months for sand, 6 to 12 months for sand/mud, and 6 to 18 months for mud habitats (NMFS 2005). Long-term Effects Impact analysis suggested Pollock non-pelagic trawling would result in a 4.6% and 7.2% reduction in habitat features for the most sensitive features in sand/mud and slope biostructure, respectively (NMFS 2005, Table B.2-10).
Habitat areas of particular concern (HAPC) 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 5 years, coinciding with the EFH 5-year review, or may be initiated at any time by the NPFMC. 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) and 2) Alaska Seamount Habitat Protection Area (Bowers Seamount, mobile bottom contact gear prohibited) and four areas designated as the Aleutian Islands Coral Habitat Protection Areas where no contact with the bottom is permitted. 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). NOAAs 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 that may need protection.
In 2006/2007, the Council requested information from the Alaska Fisheries Science Center on the Pribilof, Pervenets and Zhemchug canyons for consideration as HAPC designation. The Council 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. Recently, the NPFMC has received proposals to preserve the Pribilof and
BSAI Alaska Pollock – Final Report and Determination page 42 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 BS 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 motion acknowledged the need to determine whether and how the Council 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 MSA. Consistent with the Council’s adopted policy for incorporating the Ecosystem Approach to fisheries management and the authorities of the MSA, the Council intends to initiate action to investigate where and how to protect coral in these areas.
During the autumn of 2014, NOAA Fisheries scientists conducted a broad-area survey looking for deep-water corals on the outer continental shelf and slope of the Bering Sea (Press 2014). At 250 randomly selected locations, they used a dual lens camera to take bottom pictures along transects. The resulting images will help identify corals and estimate their abundance. The dual lens camera produced three-dimensional images that scientists can use to measure the dimensions of corals and gauge their importance as structural habitat for fish and crabs. The NPFMC will use this and other relevant information to determine the appropriate action necessary for protection of the habitats.
A recent review of fishery effects on two BS canyons being considered as HAPC indicated that approximately 3% of the total mid-water trawl pollock was caught in Pribilof Canyon over the time frame examined (2004-2012). This compares with 0.38% from Zemchug Canyon (http://www.npfmc.org/wp- content/PDFdocuments/conservation_issues/BSHC/BScanyonsDiscPaper513.pdf). Sigler et al. (2015) examined 5 large canyons (Bering, Pribilof, Zhemchug, Pervenets and Navarin) by compiling data from the eastern Bering Sea that included trawl survey data on fish and invertebrate distributions and observations of ocean conditions and benthic habitat. Based on a multivariate analysis they found that the 5 canyons are not faunally distinct features of the eastern Bering Sea slope. Following up on the multivariate analysis, NOAA conducted a 2014 camera drop research survey, in which 225,000 video images of the eastern Bering Sea seafloor were analyzed. This research found that the model of coral presence or absence (Sigler et al. 2015) was generally accurate in predicting coral presence or absence in the camera survey. The bottom trawl survey models were also accurate in predicting sponge and sea whip presence or absence, but to a lesser degree than for coral. Imagery showed that corals were found at 32 of 250 transects, most of which 19 were located in Pribilof Canyon and the slope area to the northwest. Overall, the densities of 20 corals were low. Direct evidence of fishing gear 30 occurred at 12.8% of transects. Individual demosponges (0.3%), Isididae corals (2.9%) and sea 31 whips (9.0%) were observed to be damaged. These findings, summarized in Rooper et al. (unpublished manuscript) provide evidence that the pollock fishery is highly unlikely to reduce habitat structure to the point of serious or irreversible harm.
3.4.11 Food web Aydin and Mueter (2007) developed an ecosystem model of the Bering Sea that describes species interactions among trophic levels, identifies key species, environmental forcing and fishing effects on biological relationships and species dynamics. A regional AI food web model is described in Ortiz (2007). Aydin et al. (2007) presented the first comprehensive comparison of mass balance models (modified Ecopath models) for the EBS, GOA and AI ecosystems to explore key food web relationships and potential fisheries interactions in each ecosystem. These three models use the large amount and high quality of data available for Alaskan fisheries and ecosystems by including biomass pools for juveniles and adults of all
BSAI Alaska Pollock – Final Report and Determination page 43 major groundfish species, for many forage species, birds, marine mammals, benthos and zooplankton. Alaskan fisheries catch data was used to define 14-16 fisheries in each model with a full suite of target and incidental species catches, both retained and discarded providing the capability to evaluate ecosystem effects of bycatch mortality on non-target as well as target species. The EBS model has the highest quantity and quality of information of the three models due to extensive long-term research of this ecosystem. Fishery catch data in this ecosystem are of the highest quality because most large scale fisheries have 100% observer coverage. Estimates of production and consumption for all groups are generally available. There is extensive information on the diet composition of main fish, marine mammal, and bird species. The Aleutian Islands is perhaps the most data poor of the three ecosystems modeled and required more adjustments of existing data and assumptions to balance the model than the other two areas. Despite the large amount of information used to construct these models, there are gaps or large uncertainties in input data, thus important assumptions still need to be made. To incorporate both the information and uncertainty in the input data (initial model state and parameters), a simplified Bayesian Synthesis approach was used (Aydin et al. 2003). Although these models represent our best current understanding of the structure and functioning of these ecosystems, some caution is still required in drawing conclusions.
Comparing these aggregated food webs, it is apparent that the EBS has a much larger benthic influence in its food web than either the GOA or the AI. The consumption of detritus represents the largest portion of consumption, due to the strong benthic energy flow pathway in this system. The groundfish groups “small flats” and yellowfin sole, along with crabs and pollock, are dominant in the EBS. Conversely, the AI has the strongest pelagic influence in its food web relative to the two other systems. Consumption of plankton is dominant due to the strong pelagic energy flow pathway. The most important groundfish in the AI occupying the pelagic pathway are Atka mackerel and Pacific Ocean perch. Although there are large biomasses of both fish and invertebrate eating predators in each ecosystem, overall consumption of fish and large invertebrates amounts to less than 5% of the total in each ecosystem.
There are key differences between ecosystems in energy flow supporting the predator species, including the groundfish, which are targets of commercial fisheries. This can be explored in the ecosystem models by examining the consumption of forage species at trophic level (TL) 2.5, as a reference level. In the EBS, consumption of TL 2.5 groups has the highest proportion of benthic forage species groups of any system. By contrast, the AI consumption of TL 2.5 groups is 87% pelagic forage. In the EBS, the most consumed forage fish is juvenile pollock (48% of consumption), while myctophids are most consumed (49%) in the AI. Sand lances are the second most consumed forage fish in both the EBS at ~14% of total consumption. In the AI, juvenile pollock are second most consumed (14%). Ecosystem models can also be used to assess the “footprint” of fisheries by examining the sources and fates of the production of each group (Aydin et al. 2007). These models enable the partitioning of mortality sources for each major species between fishing and predation mortality, and therefore can estimate the relative importance of fishing mortality and explore the relationship between fishing mortality and trophic level. These models can also be used to explore the consequences to the ecosystem of changes in the abundance of species, either through fishing or though environmental change. Aydin et al. (2007) illustrate such “what if” scenarios through a perturbation analysis of Pacific cod biomass.
While pollock and demersal fish were important in both the 1960s and the 1980s, the overwhelming dominance of pollock as a consumer within the food web is a feature of the post-1970s time period. Pollock were responsible for 16% of the total prey consumption in the 1960s compared to 66% of the consumption in the 1980s (Aydin and Mueter 2007). In addition to its numerical dominance, Walleye pollock has a central role in the Bering Sea food web, with a wide range of species feeding on this key forage species. EBS pollock,
BSAI Alaska Pollock – Final Report and Determination page 44 however, are also cannibalistic and an increase in adult biomass exerts strong top-down controls on pollock recruitment. While both small and large pollock are primarily planktivorous, most of the natural mortality of juvenile pollock is due to cannibalism. Pollock are both a major predator on pandalids and a major consumer of euphausiids and copepods. Therefore an increase in pandalids after a decrease in pollock may be the result of both lowered predation and increased prey supply. For other forage fish such as capelin, pollock do not cause a substantial portion of the mortality, so the primary mechanism is competitive release. In addition to large pollock, other fish predators of pollock include yellowfin sole, flathead sole, arrowtooth flounder, Pacific halibut, Pacific cod, turbot and Alaska skates.
Aydin et al (2007) found that their food web model suggests a relationship between the relative importance of fishing mortality and trophic level (TL). Thus, lower trophic level species such as pollock experience large predation mortality, to the extent that predation mortality exceeds fishing mortality, even though pollock are a commercially exploited species. When viewed within the food webs, the pollock trawl fishery is a relatively high trophic-level predator, which interacts mostly with adult pollock.
3.4.12 Ecosystem Management
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. The Council‘s Ecosystem Committee provides advice to the Council on ecosystem issues in the North Pacific in the light of national ecosystem discussions, and suggests new ways for the Council to engage in ecosystem-based management. The current status and objectives of the Council’s EBM are described at http://www.npfmc.org/wp- content/PDFdocuments/membership/EcosystemCommittee/EBFMstatus.pdf. The Council views Ecosystem-Based Fisheries Management (EBFM) as a process to continually improve the long-term sustainability of fisheries. Since 2004, the Council has adopted comprehensive ecosystem-based goals and objectives for groundfish FMPs based on science-based decision-making, and adherence to SSC advice. Elements of the EBFM plan include: Management measures: . Optimun yield cap on total groundfish yield; Arctic FMP reduces optimum yield to 0 (based on the results of an ecosystem assessment) . Individual TACs for all species or species groups (based on lowest common denominator species) . Groundfish control rule with automatic rebuilding . Ecosystem considerations included qualitatively in each stock assessment . No directed fishing for forage fish . Habitat, marine mammal/seabird, bycatch protections . Broad time/area closures, bottom trawl restrictions . Gear modifications (biodegradable panels, salmon/halibut excluder devices, seabird deterrents, elevated trawl sweeps) . Bycatch limits on non-FMP species (salmon, halibut, herring, crab, forage fish) Ecosystem reports and Fisheries Ecosystem Plans o Annual ecosystem considerations report prepared as part of annual harvest specifications, including assessments by ecosystem region o Aleutian Islands Fishery Ecosystem Plan adopted in 2007, which identifies key ecosystem interactions and includes a preliminary risk assessment
BSAI Alaska Pollock – Final Report and Determination page 45 o Scoping currently underway for a Bering Sea Fishery Ecosystem Plan
The Council has developed an Aleutian Islands Fishery Ecosystem Plan (AI FEP). The AI FEP is a strategic policy and planning document intended to be an educational tool and resource that can provide the Council with both an ‘early warning system,’ and an ecosystem context for fishery management decisions affecting the Aleutian Islands area. The plan can be found at http://www.npfmc.org/wp- content/PDFdocuments/conservation_issues/AIFEP/AIFEP12_07.pdf. The Council is considering the development of a Bering Sea Fishery Ecosystem Plan (BS FEP) to provide a synthesis of ecosystem information relevant to fisheries to help managers consider the ecosystem perspective in fishery decision making.
Recently, the Council also 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.
Since 1995, the Council has also included an analysis of the state of the ecosystem to help inform fisheries management and conservation issues in the BSAI. The most recent analysis is contained in Zador [ed] (2013).
BSAI Alaska Pollock – Final Report and Determination page 46 3.5 Principle Three: Management System Background
3.5.1 Area of operation of the fishery and under which jurisdiction it falls
The BSAI Alaska fishery is conducted in the U.S. EEZ waters (Figure 14) of the Bering Sea and Aleutian Islands under federal management. Historically, with implementation of the U.S. Magnuson-Stevens Fishery Conservation and Management Act (MSA), annual Alaska pollock quotas (or catch targets) had been used to limit the catch by foreign and domestic fisheries.
The principle legislative instrument for fisheries management in the U.S. is the MSA (MSA 2007). The MSA contains ten National Standards (NSs) which fishery managers must consider when preparing a Fishery Management Plan (FMP) or Amendment. 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.
The National Marine Fisheries Service (NMFS) implements the MSA and the National Standard Guidelines (NSG). The procedures on how NMFS follows the NSs are published in the US Federal Register at 50 CFR Part 600 subpart D. National Standard 1 has been interpreted as being consistent with international agreements and criteria for precautionary approaches. Proposed guidelines for implementing the legislation have been translated into scientific and technical guidance for developing limit and target control rules, with some
BSAI Alaska Pollock – Final Report and Determination page 47 suggestions for defaults (Restrepo et al 1998). The control rules specify management actions (fishing mortality rate), based upon current stock status (Restrepo and Powers 1999).
The NPFMC is one of eight regional councils established by the MSA in 1976 to manage fisheries in the 200-mile Exclusive Economic Zone (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 conducts public hearings so as 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 (16 U.S.C. 1852(h)). The NPFMC has developed a management policy and objectives to guide its development of management recommendations to the Secretary of Commerce. 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.
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). 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 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. 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).
The US Department of State (DOS) and NMFS conduct formal consultation with Alaska native entities to assure that they have opportunities to receive results of the scientific investigations by NMFS and other research institutions and to provide input into relevant management actions (e.g., http://www.npfmc.org/wp- content/PDFdocuments/rural_outreach/RCOCreport911.pdf; https://alaskafisheries.noaa.gov/tc/chinook_bycatch/beringsea-salmon0415.pdf). DOS and
BSAI Alaska Pollock – Final Report and Determination page 48 NMFS conducted formal consultation prior to the April 2015 NPFMC meeting. The NPFMC, at the April 2015 meeting, passed a package of Chinook and chum salmon bycatch reduction measures for implementation in 2016-2017 (NPFMC 2015). Specifically, the Council action incorporated chum salmon avoidance into Amendment 91 Incentive Plan Agreements, including more strict requirements for Incentive Plan Agreements, requires salmon excluder devices, establishes penalties for vessels that consistently have high bycatch relative to the fleet, adjusts seasonal allocations, and lowers the hard cap and performance standard by 25% in years of low Chinook abundance. Alaska native entities also have membership on the North Pacific Fishery Management Council, and have representatives on the NPFMC Advisory Panel, providing for direct input into management recommendations and decisions. Consultation with Native communities included convening an expert panel to review the hypotheses for declining Chinook runs on the Yukon River. The panel concluded that the weak runs of concern were due to anthropogenic fluxes of other salmon species that compete for food in the marine environment (http://www.aykssi.org/wp-content/uploads/AYK-SSI-Chinook-Salmon-Action-Plan- 83013.pdf). Western Alaska Native organizations participated as full partners on a steering committee overseeing the expert panel. This report provides clear evidence that federal and state fishery managers – even beyond those subject to evaluation in this assessment – continue to work closely with affected Western Alaska native stakeholders.
The importance of Alaska salmon for cultural and subsistence needs of Alaska natives and western Alaska communities, and the issue of potential impacts on salmon from bycatch by the trawl fisheries, was one factor leading to the NPFMC and NMFS initiating outreach to Alaska natives. The NPFMC established in 2009 a Rural Outreach Committee to improve outreach and communications with rural communities and Alaska Native entities and develop a method for systematic documentation of Alaska Native and community participation in the development of fishery management actions http://www.npfmc.org/committees/rural-outreach-committee/. The Committee has three primary tasks:
1. To advise the Council on how to provide opportunities for better understanding and participation from Alaska Native and rural communities; 2. To provide feedback on community impacts sections of specific analyses, if requested; and 3. To provide recommendations regarding which proposed Council actions need a specific outreach plan and prioritize multiple actions when necessary.
In February 2014, the Council adopted an Ecosystem Policy to guide all of the Council’s work, including long‐term planning initiatives, fishery management actions, and science planning to support ecosystem‐based fishery management. The implementation Strategy section of the Policy specifically acknowledges the importance of local and traditional knowledge http://www.npfmc.org/management-policies/: Implementation Strategy - The Council intends that fishery management explicitly take into account environmental variability and uncertainty, changes and trends in climate and oceanographic conditions, fluctuations in productivity for managed species and associated ecosystem components, such as habitats and non-managed species, and relationships between marine species. Implementation will be responsive to changes in the ecosystem, and our understanding of those dynamics, incorporate the best available science, including local and traditional knowledge, and engage scientists, managers, and the public (emphasis added).
The NPFMC’s rural outreach committee met with salmon stakeholders in western Alaska villages, to hear their ideas and concerns, and to incorporate them into the decision documents for minimizing and reducing BSAI salmon bycatch in the BSAI pollock fisheries
BSAI Alaska Pollock – Final Report and Determination page 49 prior to council action. This was done over a period of 2-3 years, and was a concerted effort by the NPFMC to understand and incorporate both local knowledge and TEK. This outreach plan included meetings in rural communities and statewide teleconferences to try to reach more stakeholders. The information from this consultation was used in the development of the public review document of the Bering Sea Salmon Bycatch Management Measures (NPFMC 2015), e.g., Chapter 3.4.7 subsistence Utilization of Alaska Chinook and Chum Salmon, and Appendix A-4 Subsistence Utilization of Alaska Chinook and Chum Salmon. References in these sections demonstrate a long list of sources that extended beyond NMFS and NPFMC staff. One of the main purposes of these actions was in response to Alaska Native and rural community feedback that in times of low Chinook abundance, any and all sources of removals, including bycatch in marine waters, needs to be evaluated and minimized.
TEK refers to the evolving knowledge acquired by indigenous and local peoples over hundreds or thousands of years through direct contact with the environment. This knowledge is specific to a location and includes the relationships between plants, animals, natural phenomena, landscapes and timing of events that are used for lifeways, including but not limited to hunting, fishing, trapping, agriculture, and forestry (USFWS 2011).
The team has concluded that TEK has had no opportunity to consider the types of information used in determining the impacts of the pollock fishery on western Alaska Chinook and chum stocks. For example, calculation of adult equivalents or the use of tagging and genetics to determine stock composition of the salmon bycatch in the pollock fishery require use sophisticated science and technology. Therefore, the team considered that the NPFMC has sought, received, used, and reported on TEK. The NPFMC used traditional science to a greater degree than it used TEK for the determination of the impacts of the pollock fishery on western Alaska Chinook and chum stocks. This resulted in a conclusion strongly supported by the best available science. However, the assessment team did consider that the management system did not explicitly explain how it used or did not use TEK.
In coastal waters off the United States, Alaska pollock catch is under the jurisdiction of the Bering Sea-Aleutian Islands Groundfish Fishery Management Plan (FMP) and the MSA. The geographical extent of the FMP management area is the U.S. EEZ of the Bering Sea- Aleutians Islands. The NPFMC BSAI management area is divided into Bering Sea and Aleutian Islands subareas.
BSAI Alaska Pollock – Final Report and Determination page 50
Figure 14 The US EEZ of the Bering Sea, Aleutian Islands, and Gulf of Alaska (NPFMC 2012)
Implementation comes under federal law CFR › Title 50 › Chapter VI › Part 660 › Subpart D › Section 660.131. Under this jurisdiction, the NPFMC recommends management and enforcement measures to NMFS, the agency charged with implementation.
The management system process includes proactive response from the decision-making agencies to legal actions brought against the management system. The Office of General Counsel (OGC), which represents NMFS, provides legal advice and counsel for the National Oceanic and Atmospheric Administration (NOAA) of the U.S. Department of Commerce. The OGC provides legal service and guidance for all matters that may arise in the conduct of NOAA's missions. Under the Administrative Procedures Act, NOAA (and other) agencies must maintain a full administrative record that supports agency actions (Schiffer 2012). Courts have determined what the administrative record must contain. The NOAA OGC has established a formal guideline for maintaining the agency administrative record. While this record serves to increase efficiency of the agency, it also increases the efficiency for any plaintiffs and for the court. This helps lead to a transparent and effective system for resolving legal disputes.
The Council Coordination Committee (Director-level representatives of the regional fishery management councils) periodically receives litigation updates from NOAA OGC (e.g., CCC 2012). A representative of NOAA OGC reviewed significant litigation, and the members of the CCC discussed with NOAA OGC the lessons learned and the actions to take to better comply with laws and regulations, and thereby reduce the opportunity for legal challenges (CCC 2012). At this 2012 Council Coordination Committee meeting, the NOAA OGC summarized legal issues regarding ACLs, which basically revolved around the need to use the best available science in determining such limits, and noted the need to show the justification for decision making and not to oversimplify the information. Between the scientific expertise of the Councils and their many committees and advisory bodies and the expertise of NMFS and the review of issues and FMPs, there is a tremendous amount of technical expertise to which the courts will defer if proper documentation supports how
BSAI Alaska Pollock – Final Report and Determination page 51 conclusions have been arrived. Thus, the agency administrative record becomes an important aspect of justifying decisions and avoiding lawsuits (Schiffer 2012).
The NOAA OGC has summarized recent litigation for MSA national standard 1 issues (Issenberg 2013) into a series of topics and the cases affecting each:
Stocks in Fishery: o Flaherty v. Bryson (D.D.C.) – Herring Am. 4 o Oceana v. Locke (D.D.C.) – New England Amendment 16 o Oceana v. Blank (D.D.C.) - Mid-Atlantic Omnibus OY o Western Seas Fishing Co. v. Locke (D. Mass.) – NE Atlantic Herring o Oceana v. Blank (N.D. Cal.) – CPS Amendment 13 Mixed Stock Fisheries o New Bedford/Lovgren v. Locke (1st Cir.) – NE Am 16 o Mass. v. Gutierrez (D. Mass.) – NE FW 42 Rebuilding Plans o NRDC v. Locke (N.D. Cal.) – Pacific groundfish specs Accountability Measures o Oceana v. Locke (D.D.C.) – NE Am 16 o NRDC v. NMFS (D.D.C.) – S. Atlantic Snapper-Grouper Reg Am 11 ABC Control Rule o Oceana v. Locke (D.D.C.) – NE Amendment 16 o Flaherty v. Locke (D.D.C.) – Herring Am. 4
NOAA gets sued for issues other than NS1, for example habitat or threatened and endangered species, and maintains an administrative record for each case.
3.5.2 Recognized groups with interests in the fishery
Alaska 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.
The pollock fishery operates under the American Fisheries Act (AFA), signed into law in October 1998 (http://www.npfmc.org/american-fisheries-act-afa-pollock-cooperatives/). 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. NMFS has numerous reports on the performance of the pollock vessels operating under AFA (http://alaskafisheries.noaa.gov/sustainablefisheries/afa/afa_sf.htm).
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
BSAI Alaska Pollock – Final Report and Determination page 52 needed to enter the fishery (NPFMC 2014). The CDQ Program allocates a percentage of all Bering Sea and Aleutian Islands quotas for groundfish, prohibited species, halibut, and crab to eligible communities. The purpose of the CDQ Program is to (i) provide eligible western Alaska villages with the opportunity to participate and invest in fisheries in the Bering Sea and Aleutian Islands Management Area; (ii) support economic development in western Alaska; (iii) alleviate poverty and provide economic and social benefits for residents of western Alaska; and (iv) achieve sustainable and diversified local economies in western Alaska. The current allocation is 10 % of the pollock TAC (e.g. https://alaskafisheries.noaa.gov/cdq/allocations/annualmatrix2014.pdf).
The Alaska pollock management process has many stakeholders: Alaska pollock license holders, processors, the states of Alaska, Washington, and Oregon, fishermen’s organizations, CDQ groups, and several environmental groups.
3.5.3 Consultations leading to the formulation of the management plan
To comply with its decision-making responsibility (see section 3.5.6) in an open and transparent manner, the NPFMC established a wide-ranging consultation process. The process used by the NPFMC to manage groundfish is described in a brochure explaining the overall Council process (NPFMC 2009) and the Council Operating Procedures (NPFMC 2012a). The Council 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 is 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).
Proposals for management measures may come from the public, state and federal agencies, advisory groups, or Council members. 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 Council makes a final decision at the next meeting the item is scheduled. After considering Council 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 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
BSAI Alaska Pollock – Final Report and Determination page 53 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; 2014). 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.
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 15).
BSAI Alaska Pollock – Final Report and Determination page 54
Figure 15 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 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 recommends alternatives to be evaluated) (NPFMC 2009).
BSAI Alaska Pollock – Final Report and Determination page 55 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 designated 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 Council 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 Council 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).
3.5.4 Arrangements for on-going consultations with interest groups
See Section 3.5.3 above and 3.5.6 below.
3.5.5 Non-fishery users or activities, which could affect the fishery, and arrangements for liaison and co-ordination
Should any entity want to dredge or fill in areas that could affect the fisheries, they would be subject to the Clean Water Act, Section 404, and the proponent would be required to prepare and Environmental Assessment (EA) or environmental impact statement (EIS) to be considered for a permit.
Other applicable law applies to non-users and users alike that is directly relevant to the management of marine fisheries includes (Buck 1995): • National Environmental Policy Act (NEPA): requires an EIS for actions with a federal nexus 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. Consultations, including a Biological Assessment are required. • 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 (PFMC 2011g). • 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
BSAI Alaska Pollock – Final Report and Determination page 56 • 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. • 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 U.S. Fish and Wildlife Service (USFWS) to develop memoranda of agreement to conserve migratory birds and to evaluate the effects of their actions on migratory birds in NEPA documents.
3.5.6 Details of the decision-making process or processes, including the recognized participants
Decision-making for North Pacific groundfish occurs primarily within the NPFMC process. However, NMFS, the states of Alaska, Washington and Oregon, and numerous industry, academic, and NGO stakeholders participate in the process. See Section 3.5.2 for details on the procedures for changing management rules, which is an important part of the decision- making process. The process used by the NPFMC for decision-making is described in the NPFMC 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 Bering Sea, Aleutian Islands, and Gulf of Alaska. The following section relies on NPFMC (2009) and NPFMC (2012a).
The North Pacific fisheries comprise numerous species managed under five fishery management plans (NPFMC 2009): Bering Sea/Aleutian Islands Groundfish FMP: This FMP includes all species of groundfish (pollock, cod, flatfish, sablefish, rockfish, etc.) and management measures for vessels using trawl, longline, pot, and jig gear. In-season management of these fisheries is conducted by NMFS in Juneau. Gulf of Alaska Groundfish FMP: The GOA Groundfish FMP also includes the major groundfish target species except for a few that are managed by the State of Alaska. Many management measures mirror the BSAI groundfish FMP.
BSAI Alaska Pollock – Final Report and Determination page 57 Bering Sea/Aleutian Islands King and Tanner Crab FMP: This FMP includes fisheries for king and Tanner crab (red, blue, and brown king crab, Tanner crab, and snow crab). In- season management of these fisheries is provided by ADFG in Kodiak. Alaska Scallop FMP: This FMP was developed to control fishing effort in the weathervane scallop fishery. Only 9 vessels are permitted under a license limitation program. In season management of the fishery is provided by ADFG in Kodiak. Alaska Salmon FMP: The Salmon FMP was developed to prohibit fishing for salmon in the EEZ except by a limited number of vessels using troll gear in Southeast Alaska. All other salmon fisheries are conducted in State waters and are managed by the State of Alaska (NPFMC 2012). The NPFMC has eleven voting members and four non-voting members. NPFMC members must balance competing interests while trying to make decisions for the overall benefit of the nation. NPFMC members are advised by the NPFMC advisory panels and committees, NPFMC staff, the public, states, academia, and NMFS. The states of Alaska, Washington, and Oregon are represented on the Council.
The eleven voting members include: The director of the Alaska Department of Fish and Game or a designee. The director of the Washington Department of Fish and Wildlife or a designee The director of the Oregon Department of Fish and Wildlife or a designee The Regional Administrator of the National Marine Fisheries Alaska Regional Office or a designee. 7 private citizens who are familiar with the fishing industry, marine conservation, or both. These citizens (5 members from Alaska and 2 from Washington) are appointed by the Secretary of Commerce from lists submitted by the Governors of Alaska and Washington.
There are also four non-voting members who assist the NPFMC in decision-making. They represent: The Pacific States Marine Fisheries Commission (data and research) The U.S. Fish and Wildlife Service (seabirds, ecosystems, otters and walrus) The U.S. Department of State (decisions that have international implications) The U.S. Coast Guard (enforcement and safety issues)
The NPFMC has established two formal advisory groups: a Scientific and Statistical Committee (SSC) and an Advisory Panel (AP). Subject to the availability of appropriations, stipends are available to members of committees formally designated as SSCs or APs who are not employed by the Federal Government or a state marine fisheries agency. For purposes of this section, a state marine fisheries agency includes any state or tribal agency that has conservation, management, or enforcement responsibility for any marine fishery resource.
The NPFMC also maintains Plan Teams for each fishery management plan, and appoints standing and ad hoc committees necessary to advise the Council on particular conservation and management issues. Stipends are not available to members of plan teams or other committees.
As required by the Act at Sec. 302(g)(1), the NPFMC 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 NPFMC development and amendment of any of its fishery management plans. The SSC is composed of experts in biology, statistics, economics, sociology, and other relevant disciplines from the federal, state, and private scientific communities and other appropriate sources. Members appointed by the NPFMC to the SSC shall be federal employees, state
BSAI Alaska Pollock – Final Report and Determination page 58 employees, academicians, 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).
The NPFMC has established an advisory panel (AP) under Sec. 302(g)(3), as required by the Act. The NPFMC appoints an Advisory Panel (AP) of recognized experts from the fishing industry and several related fields, and represents a variety of gear types, industry and related interests as well as a spread of geographic regions of Alaska and the Pacific Northwest having major interest in the fisheries off Alaska.
The NPFMC 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 NPFMC’s fishery management plans. The AP will consist of approximately 20 members. However, the NPFMC will not necessarily keep all seats filled. This arrangement should allow sufficient flexibility in funding so the Council can invite as necessary other individuals with particular expertise to work with the AP on an ad hoc basis. It is expected that as the issues and concerns of the Council change and evolve so, too, will the profile of the membership of the AP. AP members will serve for three-year terms beginning with the first meeting each calendar year. All members will be appointed by and serve at the pleasure of the NPFMC and may be reappointed to two subsequent consecutive terms. Appointments will be staggered to provide for the appointment of 1/3 of the membership of the AP each year.
The NPFMC 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, NPFMC, SSC or AP. Appointments to the team will be made by the NPFMC 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.
The NPFMC may appoint standing and ad hoc committees from among the voting and non- voting members and knowledgeable members of the public, as it deems necessary for the conduct of Council business. The NPFMC Chair may also appoint standing or ad hoc
BSAI Alaska Pollock – Final Report and Determination page 59 Committees that include industry representatives or other participants to address specific management issues or programs.
Under MSA, each council must reflect the expertise and interests of its constituent States, with membership that is knowledgeable about conservation, management, commercial or recreational harvest, of the fishery resources within the council area. The Secretary of Commerce is charged with ensuring each council has membership that fairly represents the commercial and recreational fisheries under that Council’s jurisdiction. Each year the Secretary submits a report on council membership to the Senate Committee on Commerce, Science, and Transportation that list the fisheries under the jurisdiction of each Council and their characteristics, assesses council membership in terms of the apportionment of the active participants in each council’s fisheries, and states a plan and schedule for actions to achieve a fair and balanced apportionment on each council (MSA 2007).
The NPFMC normally meets five times each year. Each meeting normally lasts from six to seven days and begins on Wednesday of the meeting week. The NPFMC's SSC and AP generally meet concurrently with the NPFMC, starting two days prior to the NPFMC. All meetings are open to the public, except for a short closed Council session in which the NPFMC deals with personnel, administrative, or litigation issues. Meeting locations rotate among member state cities. Advisory bodies also meet at various times between Council meetings.
Management measures developed by the NPFMC are recommended to the Secretary of Commerce through the National Marine Fisheries Service (NMFS). Management measures are implemented by NMFS Alaska Regional Office and enforced by the NOAA Office of Law Enforcement, the U.S. Coast Guard, and local enforcement agencies.
Alaska Board of Fisheries
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 (see Alaska Statute 16.05.221).
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. The description of the BOF relies on http://www.adfg.alaska.gov/index.cfm?adfg=fisheriesboard.main.
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;
BSAI Alaska Pollock – Final Report and Determination page 60 and establishing the methods and means for the taking of fish. The regulations the BOF has authority over are 5 AAC Chapters 1- 77.
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.
ADFG staff participates in the NPFMC Plan Team process soliciting peer reviews of stock assessments, and its meetings consider outside views regarding its analyses. As a participant in the Plan Team process, a panel of biologists, from various state and federal agencies and recognized as having considerable expertise in the field of groundfish population dynamics are consulted on an annual basis to review the most recent groundfish survey information from the NMFS. If new data points for biomass estimates suggest a higher or lower ABC, then the outside experts have equal input with assessment authors relative to adjusting these parameters.
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. When the Plan Team recommends these adjusted ABCs to the NPFMC, and the BOF makes regulatory adjustments based on the adjusted ABCs, the process again gets external review and discussion from commercial fishing groups, sport fishing groups, tourism representatives, etc. This process of external review is repeated in the BOF meeting schedule every 3 years.
For the State of Alaska as a whole, legal challenges to BOF and ADFG staff management decisions through the court system have often required managers to explain and justify their management actions.
3.5.7 Objectives for the fishery
The MSA contains ten national standards with which all fishery management plans (FMPs) must conform (MSA 2007). The national standards provide the primary guidance for the management of US fisheries; see section 3.5.1.
The NPFMC’s policy (from the BSAI Groundfish Fishery Management Plan NPFMC 2014) is to apply judicious and responsible fisheries management practices, based on sound scientific research and analysis, proactively rather than reactively, to ensure the sustainability of fishery resources and associated ecosystems for the benefit of future, as well as current generations. The productivity of the North Pacific ecosystem is acknowledged to be among the highest in the world. For the past 25 years, the NPFMC management approach has incorporated forward looking conservation measures that address differing levels of uncertainty. This management approach has in recent years been labeled 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 NPFMC intends to continue to take appropriate measures to insure the continued sustainability of the managed species. It will carry out this objective by considering reasonable, adaptive management measures, as described in the Magnuson-Stevens Act and in conformance with the National Standards, the Endangered Species Act (ESA), the National Environmental Policy Act, and other applicable law. This management approach takes into account the National Academy of Science’s recommendations on Sustainable Fisheries Policy.
BSAI Alaska Pollock – Final Report and Determination page 61
Adaptive management requires regular and periodic review. Objectives identified by the NPFMC (2014) are reviewed annually by the NPFMC. The NPFMC also reviews, modifies, eliminates, or considers new issues, as appropriate, to best carry out the goals and objectives of this management policy. To meet the goals of this overall management approach, the Council and NMFS uses the Alaska Groundfish Fisheries Programmatic Supplemental Environmental Impact Statement (PSEIS) (NMFS 2004) as a planning document. To help focus consideration of potential management measures, the Council and NMFS use the following objectives as guideposts, to be re-evaluated, as amendments to the FMP are considered over the life of the PSEIS (NPFMC 2014).
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. [Continue to use the existing optimum yield cap for the GOA 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.
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 programs 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.
BSAI Alaska Pollock – Final Report and Determination page 62 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.
Avoid Impacts to Seabirds and Marine Mammals: 22. Continue to cooperate with U.S. Fish and Wildlife Service (USFWS) to protect ESA-listed species, and if appropriate and practicable, other seabird species. 23. 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. 24. Encourage programs to review status of endangered or threatened marine mammal stocks and fishing interactions and develop fishery management measures as appropriate. 25. 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: 26. Review and evaluate efficacy of existing habitat protection measures for managed species. 27. 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. 28. Develop a Marine Protected Area policy in coordination with national and state policies. 29. Encourage development of a research program to identify regional baseline habitat information and mapping, subject to funding and staff availability. 30. 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: 31. Provide economic and community stability to harvesting and processing sectors through fair allocation of fishery resources. 32. 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. 33. Provide for adaptive management by periodically evaluating the effectiveness of rationalization programs and the allocation of access rights based on performance. 34. 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: 35. Continue to incorporate local and traditional knowledge in fishery management. 36. Consider ways to enhance collection of local and traditional knowledge from communities, and incorporate such knowledge in fishery management where appropriate. 37. Increase Alaska Native participation and consultation in fishery management.
Improve Data Quality, Monitoring and Enforcement: 38. Increase the utility of groundfish fishery observer data for the conservation and management of living marine resources. 39. Develop funding mechanisms that achieve equitable costs to the industry for implementation of the North Pacific Groundfish Observer Program.
BSAI Alaska Pollock – Final Report and Determination page 63 40. Improve community and regional economic impact costs and benefits through increased data reporting requirements. 41. Increase the quality of monitoring and enforcement data through improved technology. 42. 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. 43. Cooperate with research institutions such as the North Pacific Research Board in identifying research needs to address pressing fishery issues. 44. 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.
3.5.8 Outline the fleet types or fishing categories participating in the fishery
See Section 3.5.2.
3.5.9 Individuals or groups granted rights of access to the fishery, and the nature of those rights
See section 3.5.2.
3.5.10 Description of the measures agreed upon for the regulation of fishing in order to meet the objectives within a specified period
The U.S measures for regulating the BSAI fisheries are found in 50 CFR 600 and 679:
50 CFR 600: Magnuson-Stevens Act Provisions covering Fishery Management Councils, the National Standards, Confidentiality of Statistics, foreign fishing and other general issues
50 CFR 679: Fisheries of the Exclusive Economic Zone Off Alaska:
50 CFR 679 Figures
50 CFR 679 Tables
Fishery Management Boundaries: Alaska Department of Fish and Game Groundfish Statistical Areas, National Marine Fisheries Service Reporting Areas, and International Pacific Halibut Commission Regulatory Areas (charts)
Essential Fish Habitat Habitat Protection Areas
Groundfish Harvest Specifications
Seabird Bycatch Reduction 679.24 (e) and 679.42 (b)(2)
Steller Sea Lions Protection Measures, Critical Habitat and No-Entry Zones
BSAI Alaska Pollock – Final Report and Determination page 64 3.5.11 Arrangements and responsibilities for monitoring, control and surveillance and enforcement
Observers. 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 BSAI pollock.
The MSA and the MMPA authorize NMFS to place observers on Alaska groundfish vessels. The action is mandatory. The BSAI Groundfish FMP (NPFMC 2014) 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 2014). 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 FMP (NMFS 2013).
NMFS is responsible for funding and overall administration of the program including observer training, debriefing and data management. 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 2013b; 2014a). 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.
Compliance. 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. Outreach to the
BSAI Alaska Pollock – Final Report and Determination page 65 Alaska groundfish fleet was conducted throughout the process of program development and implementation (M. Killary, OLE, pers. comm. 2014). • 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).
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 (OLE 2014). 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.
The USCG serves as the primary agency for at-sea fisheries enforcement (USCG 2014a). 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 NPFMC 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.
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 2014). 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.
The NMFS Alaska Region OLE reports few major compliance issues. In a conversation with staff member of the OLE, he observed that as fishery abundance declines, infractions increase. Alaska has stocks in good condition, and this tends to lead to fewer compliance issues (M. Killary, OLE pers comm 2014). As an example, OLE reports to the Council at six month intervals on notices of violation or written warnings; OLE reported at the February 2014 Council Meeting that it issued eight from July 1, 2013, through December 31, 2013
BSAI Alaska Pollock – Final Report and Determination page 66 (OLE 2014). Of these, three were issued under the Northern Pacific Halibut Act, and five were issued under the MSA.
The USCG also reports a low proportion of infractions discovered during at-sea boarding; these infractions represent all BSAI fisheries, not just pollock. From 2009-2013, the number of boardings ranged from 477-716 (USCG 2014b) with a proportion of infractions ranging from 5-9%. The 27 infractions noted in 2013 (USCG 2014b) were: 9 – Fishing in a prohibited area 5 – Logbook violations 4 – Missing or no fisheries permit 3 – Failure to respond to LE Assets 3 – Boarding Ladder 1 – Failure to use Seabird Avoidance Gear 1 – Illegal subsistence halibut gear 1 – Illegal halibut processing
The high level of compliance is supported by the sanction schedules requested during prosecutions: for inadvertent and many first-time violations, prosecution requests small sanctions such as warning or summary settlements. This acts as a reminder of the need to comply, and OLE finds this approach very effective (M. Killary, OLE, pers. comm.). This approach is 70-80% effective in preventing repeat offenders. Repeat offenders are prosecuted through the criminal statutes, which have sanctions of fines, vessel forfeiture, and jail, and often remove the violators from the fishery.
3.5.12 Details of any planned education and training for interest groups
The NPFMC 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 NPFMC website identify several elements of NPFMC procedures that enable the distribution of information to stakeholders and the provision of public comment to management.
3.5.13 Date of next review and audit of the management plan
The annual management cycle and activities related to groundfish, including BSAI pollock, management contain extensive points of review detailed in the Council Operating Procedures (NPFMC 2012). These involve specific review actions taken by the SSC, GPT, and AP. Management measures are implemented annually with harvest specifications (ABCs and OYs) identified for each year. The BSAI Groundfish FMP has had over 80 amendments (99 amendment numbers in 2014, but not all were pursued or adopted), indicating a high level of review (Appendix 1 to BSAI Groundfish FMP, NPFMC 2014).
3.5.14 Description of fishery’s research plan
The NPFMC has identified priorities for research, over the next 1 to 5 years, as those activities that are the most important for the conservation and management of fisheries in the Gulf of Alaska, Aleutian Islands, eastern Bering Sea, and the Arctic. This listing of priorities has two purposes: 1) to meet the requirements of the revised MSA for the councils to identify research that is needed in the next 5 years, and 2) to provide guidance on research priorities to the research community and funding agencies. Research priorities are organized into four categories (critical, high, medium, and low), but within each category, are in no particular order of importance. The NPFMC currently has a list of 127 research topics, of which six are considered critical and 54 as high priority. The Pacific States Marine Fisheries
BSAI Alaska Pollock – Final Report and Determination page 67 Commission (PSMFC) has developed a searchable online listing of the research priorities (PSMFC 2014).
The SSC considers the research plan annually, and adjusts the topics and priorities as necessary. The plan teams also provide recommendations of research that would benefit stock assessments within the species report in the annual SAFE document.
BSAI Alaska Pollock – Final Report and Determination page 68
4. Evaluation Procedure
4.1 Harmonised Fishery Assessment
The BSAI Alaska Pollock fishery partially overlaps with the BSAI Alaska flatfish and Pacific Cod fisheries. The stocks are different but the same management applies for all three fisheries. The Alaska flatfish and Pacific Cod fisheries do not use pelagic trawl gear, so have minimal overlap for harmonization of P2. The assessment team has considered and reported on the overlap that resulted in harmonization of P3.
4.2 Previous assessments
The BSAI Alaska Pollock fishery is in its second re-assessment. At the time of the first re- assessment, the Conformity Assessment Body (CAB) Intertek Fishery Certification (IFC) determined during the third annual surveillance that all conditions were closed. The MRAG Americas surveillance team did not find any justification for reopening conditions or requiring new conditions. Therefore, the fishery enters the second re-assessment with no conditions.
4.3 Assessment Methodologies
This report used CR V1.e with no change to the default assessment tree, and used MSC Full Assessment Reporting Template V1.3.
4.4 Evaluation Processes and Techniques
4.4.1 Site Visits and Consultations
The surveillance team of Robert Trumble (Lead Assessor), Don Bowen, and Jake Rice met with the staff of: the Alaska Regional Office and Alaska Fisheries Science Center of the US National Marine Fisheries Service (NMFS), the North Pacific Fishery Management Council, the World Wildlife Fund (WWF), and the Yukon River Drainage Association, and the fishery client from 27-30 May 2014. The client close-out meeting was held 30 May. The team met in person in Seattle with those organizations and individuals that requested a meeting and by teleconference with others. MRAG posted a notice of the site visit on the MSC website and on the IntraFish website, and invited stakeholders to present information and to meet with the team. The table below summarizes the participation, location, and topics of the meetings.
The assessment team combined topics for the fourth surveillance with topics for the second fishery re-assessment. The assessment process included discussions with NMFS and North Pacific Council staff members on key issues of Principles 1, 2, and 3; changes in science and management; and likely future changes or changes underway. The clients had provided substantial documentation in advance of the site visit, and the NMFS and Council staffs provided additional material to document the information presented at the visits. Two other stakeholder meetings occurred during the site visit: WWF and a consortium of Yukon River Drainage Fisheries Association, Tanana Chiefs Conference, Kawerak, Inc., Association of Village Council Presidents, and Bering Sea Fishermen’s Association.
Date Location Name/Affiliation Topic 2014 27 May Seattle and Bob Trumble, Jake Rice, Changes to Enforcement framework
BSAI Alaska Pollock – Final Report and Determination page 69 Date Location Name/Affiliation Topic 2014 conference Don Bowen – MRAG Summary of compliance, enforcement call Assessment Team; David issues Gaudet – XFG BioConsulting; Amanda Stern-Pirlot – APA; James Browning – AFDF; Jason Anderson – AKSC; Mike Killary - OLE 27 May Seattle and Bob Trumble, Jake Rice, Changes to the fishery management conference Don Bowen – MRAG framework call Assessment Team; David Changes to mgmt. tools Gaudet – XFG Upcoming changes BioConsulting; Amanda Stern-Pirlot – APA; James Browning – AFDF; Jason Anderson – AKSC; Mary Furuness - AKRO 27 May Seattle Bob Trumble, Jake Rice, 2013 stock assessments – BSAI stocks Don Bowen – MRAG Assessment Team; David Gaudet – XFG BioConsulting; Amanda Stern-Pirlot – APA; James Browning – AFDF; Jason Anderson – AKSC; Sandra Lowe, Steve Barbeaux, Ingrid Spies, Tom Wildebuer, Carey McGilliard, Pat Livingston – AFSC; Dan Averill - MSC 28 May Seattle Bob Trumble, Jake Rice, 2013 stock assessments – GOA Don Bowen – MRAG Observer program – GOA focus Assessment Team; David Ecosystem considerations Gaudet – XFG Seabirds BioConsulting; Amanda Marine mammal interactions Stern-Pirlot – APA; James Browning – AFDF; Jason Anderson – AKSC; Sandra Lowe, Carey McGilliard, Martin Dorn, Teresa A’Mar, Farron Wallace, Stephanie Zador, Shannon Fitzgerald, Lowell Fritz – AFSC, Jennifer Cahalan – PSMFC/AFSC 29 May Seattle and Bob Trumble, Jake Rice, Management considerations conference Don Bowen – MRAG Revised observer program call Assessment Team; David Planning for GOA rationalization Gaudet – XFG Research Planning BioConsulting; Amanda Ecosystem issues – salmon, canyons, Stern-Pirlot – APA; James structure and function, seabirds Browning – AFDF; Jason Anderson – AKSC; David Witherell – NPFMC 29 May Seattle Bob Trumble, Jake Rice, Yukon Chinook and BSAI pollock Don Bowen – MRAG Assessment Team; Becca Robbins-Gisclair – Yukon River Drainage Fisheries
BSAI Alaska Pollock – Final Report and Determination page 70 Date Location Name/Affiliation Topic 2014 Association 29 May Seattle and Bob Trumble, Jake Rice, Western Alaska salmon and pollock conference Don Bowen – MRAG fishing call Assessment Team; Heather Pollock catch by Russia fisheries Brandon, Bruce Robson – Subsistence users affected by BSAI WWF pollock ETP interactions in BSAI pollock fishery Habitat considerations for BSAI pollock fishery 30 May Seattle and Bob Trumble, Jake Rice, Changes to the fishery conference Don Bowen – MRAG Nearshore and AK territorial fisheries call Assessment Team; David Halibut and salmon bycatch, mitigation Gaudet – XFG Marine mammals BioConsulting; John Gauvin – Groundfish Forum, James Browning – AFDF; Jason Anderson – AKSC; Amanda Stern-Pirlot – APA, Julie Bonnie – Alaska Groundfish Data Bank
4.4.2 Evaluation Techniques
MRAG published an announcement of the re-assessment of the fishery on IntraFish.com, and the MSC posted the announcement on its re-assessment downloads page. Together, these media presented the announcement to a wide audience representing industry, agencies, and stakeholders.
The assessment team and the clients set up meetings with science, management, and enforcement personnel, and the team set up a meeting with all other stakeholders who requested one.
Scoring followed a consensus process in which the assessment team discussed the information available for evaluating performance indicators to develop a broad opinion of performance of the fishery against each performance indicator. Review of sections 3.2, 3.3, 3.4 and 3.5 by all team members assured that the assessment team was aware of the issues for each performance indicator. Subsequently, the assessment team member responsible for each principle filled in the scoring table and provided a provisional score. The assessment team members reviewed the rationales and scores, and recommended modifications as necessary, including possible changes in scores. The team members agreed on the final scores. This process followed the MSC CR V1.3 section 27.10. The MSC has 31 ‘performance indicators’, seven in Principle 1, 15 in Principle 2, and nine in Principle 3. The performance indicators are grouped in each principle by ‘component.’ Principle 1 has two components, Principle 2 has five, and Principle 3 has two. Each performance indicator consists of one or more ‘scoring issues;’ a scoring issue is a specific topic for evaluation. ‘Scoring guideposts’ define the requirements for meeting each scoring issue at the 60 (conditional pass), 80 (full pass), and 100 (state of the art) levels.
Note that some scoring issues may not have a scoring guidepost at each of the 60, 80, and 100 levels. The scoring issues and scoring guideposts are cumulative; this means that a performance indicator is scored first at the SG60 levels. If not all of the SG scoring issues meet the SG60 requirements, the fishery fails and no further scoring occurs. If all of the SG60 scoring issues are met, the fishery meets the 60 level, and the scoring moves to SG80 scoring issues. If no scoring issues meet the requirements at the SG80 level, the fishery
BSAI Alaska Pollock – Final Report and Determination page 71 receives a score of 60. As the fishery meets increasing numbers of SG80 scoring issues, the score increases above 60 in proportion to the number of scoring issues met; performance indicator scoring occurs at 5-point intervals. If the fishery meets half the scoring issues at the 80 level, the performance indicator would score 70; if it meets a quarter, then it would score 65; and it would score 75 by meeting three-quarters of the scoring issues. If the fishery meets all of the SG80 scoring issues, the scoring moves to the SG100 level. Scoring at the SG100 level follows the same pattern as for SG80.
Principle scores result from averaging the scores within each component, and then from averaging the component scores within each Principle. If a Principle averages less than 80, the fishery fails.
Table 4.3 Scoring elements [Add or delete rows as needed] Component Scoring elements Main/not main Data-deficient or not Target EBS pollock - Not Target AI pollock - Not Retained Pacific cod Not Not Retained Flathead sole Not Not Retained Rock sole Not Not Retained Arrowtooth flounder Not Not Retained Alaska plaice Not Not Retained POP Not Not Retained Atka mackerel Not Not Retained Turbot Not Not Retained Sharks Main Not Retained Squids Main Not Retained Sculpins Main Not Bycatch Scypho jellies Not Not Bycatch Chinook salmon Main Not Bycatch Red king crab Not Not Bycatch Bairdi crab Not Not Bycatch Opilio crab Main Not Habitat Outer shelf-upper slope Main Not Habitat Canyons Main Not ETP Steller sea lions (western stock) Not ETP Northern fur seal Not ETP Northern fulmar Not ETP Shearwater Not ETP Gull Not Ecosystem Bering Sea Main Not Ecosystem Aleutian Islands Main Not
[Note: the outcomes of stakeholder engagement and their supporting rationale are to be documented in the Evaluation Results section (section 6), while the specific content of stakeholder written or verbal submissions or information generated in meetings or workshops are to be provided in Appendix 3 of this report.]
BSAI Alaska Pollock – Final Report and Determination page 72
5 Traceability
5.1 Eligibility Date
The fishery is currently certified. The target eligibility date is the date of recertification.
(REQUIRED FOR PCR ONLY)
1. The report shall include: a. The actual eligibility date. b. The rationale for any difference in this date from the target eligibility date
5.2 Traceability within the Fishery
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 report landings and/or production data for groundfish, IFQ/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 CoC, 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 on 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.
BSAI Alaska Pollock – Final Report and Determination page 73 Nearly 100% of the catch had observer coverage in 2013, 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 unit of certification or the opportunity for substitution of certified fish with non-certified fish is low. Risk of substitution in the fishery is very low given that vessels fish only in UoC where VMS and observer coverage is required. Risk of substitution at point of landing is controlled by the government required PTR, which can be reconciled against the eLandings report. Risk of mixing at point of landing is controlled by the government required product transfer report, which is required to be reconciled during CoC audits given that CoC starts at the offload from the fishing vessel (see Section 5.3). 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.
5.3 Eligibility to Enter Further Chains of Custody
Traceability of product to the point of offload and sale is excellent, and BSAI pollock may enter the MSC certified chain of custody. 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 amount of BSAI Alaska 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. Chain of custody for at-sea processors starts on board at delivery to the factory for vessels operating as catcher/processors or in mothership capacity. Through agreement with the Alaska pollock client between MSC clients for the Pacific cod and Alaska flatfish certifications, incidental catch of Alaska 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.
5.4 Eligibility of Inseparable or Practically Inseparable (IPI) stock(s) to Enter Further Chains of Custody
The BSAI Alaska 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.
BSAI Alaska Pollock – Final Report and Determination page 74
6 Evaluation Results
6.1 Principle Level Scores
Table 6.1: Final Principle Scores Final Principle Scores Principle Score Principle 1 – Target Species 97.5 Principle 2 – Ecosystem 93.0 Principle 3 – Management System 99.0
6.2 Summary of Scores BSAI Alaska Pollock Commented [BT1]: Replace
Prin- Wt Component Wt PI Performance Indicator (PI) Wt Weight Contribution to ciple (L1) (L2) No. (L3) in Score Principle Score Either Principl Or Either Or One 1 Outcome 0.5 1.1.1 Stock status 0.5 0.25 0.333 0.1667 95 23.75 1.1.2 Reference points 0.5 0.25 0.333 0.1667 95 23.75 1.1.3 Stock rebuilding 0.333 0.1667 Management 0.5 1.2.1 Harvest strategy 0.25 0.125 100 12.50 1.2. Harvest control rules & tools 0.25 0.125 100 12.50 21.2. Information & monitoring 0.25 0.125 100 12.50 31.2. Assessment of stock status 0.25 0.125 100 12.50 Two 1 Retained 0.2 42.1. Outcome 0.333 0.0667 85 5.67 species 12.1. Management 0.333 0.0667 90 6.00 22.1. Information 0.333 0.0667 90 6.00 Bycatch 0.2 32.2. Outcome 0.333 0.0667 95 6.33 species 12.2. Management 0.333 0.0667 90 6.00 22.2. Information 0.333 0.0667 95 6.33 ETP species 0.2 32.3. Outcome 0.333 0.0667 95 6.33 12.3. Management 0.333 0.0667 100 6.67 22.3. Information 0.333 0.0667 95 6.33 Habitats 0.2 32.4. Outcome 0.333 0.0667 100 6.67 12.4. Management 0.333 0.0667 95 6.33 22.4. Information 0.333 0.0667 90 6.00 Ecosystem 0.2 32.5. Outcome 0.333 0.0667 100 6.67 12.5. Management 0.333 0.0667 100 6.67 22.5. Information 0.333 0.0667 95 6.33 Three 1 Governance 0.5 33.1.1 Legal & customary framework 0.25 0.125 100 12.50 and policy 3.1.2 Consultation, roles & 0.25 0.125 100 12.50 3.1.3 responsibilitiesLong term objectives 0.25 0.125 100 12.50 3.1.4 Incentives for sustainable fishing 0.25 0.125 100 12.50 Fishery specific 0.5 3.2. Fishery specific objectives 0.2 0.1 90 9.00 management 13.2. Decision making processes 0.2 0.1 100 10.00 system 23.2. Compliance & enforcement 0.2 0.1 100 10.00 33.2.4 Research plan 0.2 0.1 100 10.00 3.2.5 Management performance 0.2 0.1 100 10.00 evaluation Overall weighted Principle-level scores Either Or Principle 1 - Target species Stock rebuilding PI not scored 97.5 Stock rebuilding PI scored Principle 2 - Ecosystem 94.3 Principle 3 - Management 99.0
BSAI Alaska Pollock – Final Report and Determination page 75 6.3 Summary of Conditions
No conditions assigned.
6.4 Determination, Formal Conclusion and Agreement
The fishery attained a score of 80 or more against each of the MSC Principles. The MRAG Americas Assessment Team, therefore, recommends that the Alaska Pollock Fishery – Bering Sea-Aleutian Islands be certified according to the Marine Stewardship Council Principles and Criteria for Sustainable Fisheries.
(REQUIRED FOR PCR)
1. 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.
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BSAI Alaska Pollock – Final Report and Determination page 88 Appendices
Appendix 1 Scoring and Rationales
Principle 1
Evaluation Table for PI 1.1.1
The stock is at a level which maintains high productivity and has a low PI 1.1.1 probability of recruitment overfishing Scoring Issue SG 60 SG 80 SG 100 ha It is likely that the It is highly likely that There is a high degree of stock is above the the stock is certainty that the
point where above the stock is above the recruitment would be point where point where impaired. recruitment recruitment would be would be impaired.
Guidepost impaired. Met? (Y/N) Y (Y/N) Y (Y/N) EBS Y; AI N
BSAI Alaska Pollock – Final Report and Determination page 89 The stock is at a level which maintains high productivity and has a low PI 1.1.1 probability of recruitment overfishing SG60 see SG80. The Bossy and Fmsy values for the EBS are considered biologically appropriate reference points for this stock, with Bossy reflecting a spawning biomass where productivity of the stock is high (see next sub-criterion). The B40% is considered a biologically appropriate proxy for BMSY, for some types of comparisons with other stocks that are Tier 3 rather than Tier 1. The assessment provides reliable estimates of MSY for this stock complex (Ianelli et al. 2014a), and as for many other groundfish stocks, the B35% benchmark is also considered a conservative approximate of Bmsy. Although there are concerns about the appropriate analytical methods for taking account of the uncertainties about productivity parameters in a variable environment (Holsman and Aydin 2015, Stepanenko and Gritsay 2014), stocks above these reference points are considered to have a status where there is high certainty that recruitment is not impaired by an insufficient spawning biomass. In the 2014 assessment, the biomass producing MSY was estimated to be 1.948 mmt, whereas the 2015 SSB was estimated to be 2.850 mmt with a CV of 14%. (Ianelli et al. 2014a, table 1.23); the bottom of the 95% confidence bounds exceeded the target reference point, and therefore well exceeded the limit reference point. Thus, based on the assessment results it is very unlikely that this stock component near or in the neighborhood of a biomass where recruitment would be impaired, reaching the SG100. For the much smaller Aleutian Island stock component assessed as a Tier 3 stock, there is much greater assessment uncertainty about stock status. The assessment (Barbeaux et al. 2014a) indicates that the stock underwent a more than fourfold increase in spawning biomass in the early to mid-1980s, was stable for several years, and then underwent a five-fold decline in the early 1990s. Neither the increase in SSB (due to a period of consistently strong recruitment) nor the decrease (due to a decline in year-class strengths that began in the early 1980s, when SSB was at record high levels) has been well explained biologically. These several-fold differences in year-class strength are poorly related to SSB, as the very large year-classes began to be produced when the SSB was typical of SSBs for the past 20 years, and year-class strengths had dropped more than 50% while the SSB was still at record high levels. Thus it is not straightforward to unambiguously define a SSB at which recruitment is (or is not) impaired. However, the SSB has been increasing gradually but fairly consistently since the mid-1990s, and is at a size comparable to the SSBs which produced the strong recruitments of the 1980s.
Therefore it is highly likely that the minor stock component is above a level at which recruitment would be impaired relative to productivity of the stock over the past three decades, reaching the SG80. However, its ability to produce year-classes comparable to those producing the increase in SSB in the early 1980s cannot be assessed under present environmental conditions.
Justification b The stock is at or There is a high degree of fluctuating certainty that the around its stock has been target fluctuating around its
reference target reference point. point, or has been above its target reference point, over
Guidepost recent years. Met? (Y/N) Y (Y/N) EBS Y; AI N
BSAI Alaska Pollock – Final Report and Determination page 90 The stock is at a level which maintains high productivity and has a low PI 1.1.1 probability of recruitment overfishing For the EBS component of the stock. The spawning biomass has been varying with a multi-year trend that has been more strongly influenced by variation in recruitment strength passing through the stock than by fishing mortality causing greater or lesser depletions of SSB (Ianelli et al. 2014a, Figure 1.37 [SSB trends] compared to Figure 1.32 [exploitation rate]). The SSB reached a nadir in 2008 and has been steadily increasing thereafter. The mean estimate of SSB is estimated to have increased above Bmsy in 2012, with entry of the very strong 2007 year-class into the SSB, and has continued to increase as that year-class continued to mature and other near-average year-classes thereafter have recruited. Given the confidence bounds in Figure 1.37, the midpoint of estimates for the spawning biomass in 2015 is 1.46 of the MSY target reference, and with a 14% CV the lower 95% confidence interval is also well above the target. The SSB has been above Bmsy since 2013, and continues to increase. For the Aleutian Island stock component there is less certainty that the spawning stock is at a level that can maintain high productivity. However with the very large increase and then decrease in SSB in the time series, it has been difficult to estimate a target reference point based on MSY-type considerations. Rather, spawning biomass seems to follow recruitment, rather than vice versa, and the current spawning biomass levels have been associated with both high and below average productivity. Thus there is high certainty that the Aleutian Island stock is at a level where it can maintain high productivity with environmental conditions are suitable, and although no known size of biomass is certain to maintain high productivity under particularly unfavorable environmental conditions. Importantly, aside from the brief period of exceptionally strong recruitments, the Aleutian Island SSB has been less than 100,000 t and in recent years
unfished or very lightly exploited (Barbeaux et al. 2014a, Figure 1A.16), whereas the EBS stock component has been above 2 million t for the 2010s. Hence the greater uncertainty about the productivity of the AI stock component does not negate the confidence that when the two stock components are viewed together there is high certainty that the SSB has
Justification been above the Bmsy level for several years. Holsman, K.K., and Aydin, K. 2015. Comparative methods for evaluating climate change impacts on the foraging ecology of Alaskan groundfish. Marine Ecology Progress: 521: 217-235 References Stepanenko, M.A. and Gritsay, E. V. 2014. Eastern Bering Sea pollock recruitment, abundance, distribution and approach to fishery management. Fisheries Science 80: 151-160 Stock Status relative to Reference Points
Type of reference Value of reference Current stock status relative point point to reference point Target For the EBS stock EBS Target = 1.946 According to the 2014 reference component the (Bmsy), with the Bering Sea assessment the point target SSB = Bmsy standard proxy of midpoint of estimates for the B40% = 2.014mmt spawning biomass in 2015 is For the AI (Ianelli et al. 2014a 1.46 of the MSY target Component the Exec. Summary) reference, and with a 14% target SSB + B40% CV the lower 95% confidence interval is also
BSAI Alaska Pollock – Final Report and Determination page 91 The stock is at a level which maintains high productivity and has a low PI 1.1.1 probability of recruitment overfishing AI Target B40% = well above the target. The 83.) kt; B35% = 72.7 corresponding value for kt (Barbeaux et al. 2016 is estimated to be 2014a; Exec. Summ.) 151% of the targets.
For the Aleutian Island stock component, mean estimated SSB = 70.012 kt in 2015, which is 84% of the B40% target, and 71.77 kt in 2016, which is 87% of the target Limit The Limit Reference For EBS the BOFL According to the 2014 reference Point for the Bering value is not given in assessment the 2015 point Sea stock the assessment, but spawning biomass for Bering component is not B20% = 1.03 mmt. Sea pollock would be 274% defined in the of the B25% value. The assessment report, For the AI stock 2016 Biomasses would be but for US stocks component the B20% 284% of B25% values for managed as Tier 1 value = 41.52 kt the stock. values of B25% are used in harvest For the Aleutian Island stock control rules to component corresponding guide the rate at spawning biomasses would which fishing be 169% of the B20% 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. For the Aleutian Island 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
BSAI Alaska Pollock – Final Report and Determination page 92 The stock is at a level which maintains high productivity and has a low PI 1.1.1 probability of recruitment overfishing by regulation and kept below 19,000 or the estimated ABC whichever is less. OVERALL PERFORMANCE INDICATOR SCORE: Note: Given the scale of the Eastern Bering Sea fishery compared to the Aleutian 95 Islands fishery; the assessment team weighted the EBS:AI as 4:1 in scoring.
CONDITION NUMBER NO CONDITION ISSUED
BSAI Alaska Pollock – Final Report and Determination page 93
Evaluation Table for PI 1.1.2
PI 1.1.2 Limit and target reference points are appropriate for the stock
Scoring Issue SG 60 SG 80 SG 100 a Generic limit and Reference points are target reference appropriate for the
points are based on stock and can be justifiable and estimated. reasonable practice appropriate for the
Guidepost species category. Met? (Y/N) Y (Y/N) Y The biological basis of both MSY spawner-per-recruit reference points is deeply rooted in simulation modeling and research (Clark 1993, 2002, Gabriel et al. 1989, Gabriel and Mace 1995, Morgan et al. 2009, Murawski et al. 2001) and accepted as appropriate for Bering Sea groundfish stocks
nearly two decades ago (NMFS 1996). These simulations included work to address stocks where runs of better and worse recruitment were expected. As a result of this work, there is high confidence that a limit reference point for spawning biomass of B20% and a corresponding F limit of F20% would be appropriate for this stock. Therefore, reference points are appropriate
Justification and can be estimated, meeting SG 60 and SG80. b The limit reference The limit reference point is point is set above the set above the level at which
level at which there is there is an appreciable risk an appreciable risk of of impairing reproductive impairing capacity following reproductive consideration of
Guidepost capacity. precautionary issues. Met? (Y/N) Y (Y/N) Y The biological basis of both MSY spawner-per-recruit reference points is deeply rooted in simulation modeling and research (Clark 1993, 2002, Gabriel et al. 1989, Gabriel and Mace 1995, Morgan et al. 2009, Murawski et al. 2001) and accepted as appropriate for Bering Sea groundfish stocks nearly two decades ago (NMFS 1996). These simulations included work to address stocks where runs of better and worse recruitment were expected. As a result of this work, there is high confidence that a limit reference point for spawning biomass of B20% and a corresponding F limit of F20% would be appropriate for this stock, and F25% would have a high likelihood of maintaining the spawning biomass at a level where for all but highly
unfavorable environmental conditions the likelihood of poor recruitment is kept low. Given that unfavorable environmental conditions can produce weak year-classes even for large spawning biomasses of pollock, the recruitment potential of stock is unlikely to be impaired for biomasses larger than B20% and very likely to be impaired for spawning biomasses larger
Justification than B25%. This meets the SG60, SG80, and SG100.
BSAI Alaska Pollock – Final Report and Determination page 94 PI 1.1.2 Limit and target reference points are appropriate for the stock c The target reference The target reference point is point is such that the such that the stock is stock is maintained maintained at a level at a level consistent consistent with BMSY or some with BMSY or some measure or surrogate with measure or surrogate similar intent or outcome, or with similar intent or a higher level, and takes into
outcome. account relevant precautionary issues such as the ecological role of the stock with a high degree of
Guidepost certainty. Met? (Y/N) Y (Y/N) EBS Y; AI N The same references used for the simulations that documented limit reference points are relevant to target reference points above. The suitability of Bmsy for a target has been clearly articulated in, for example Gabriel and Mace (1999) and NMFS (1996). Again, it appears that under highly unfavorable environmental conditions even very large spawning
biomasses do not ensure good years will be produced. Nonetheless, the Bmsy reference point is considered adequate to provide the stock full opportunity to take advantage of environmental conditions that are not unfavorable to achieve full recruitment for the stock. For the BS segment of the stock, this reaches the SG60, SG80, and SG100. Lower confidence for
Justification the AI segment reaches the SG60 and SG80, but not SG100. d For key low trophic
level stocks, the target reference point takes into account the ecological role of
Guidepost the stock. Met? (Y/N/Not relevant) NA Although Pollock of young ages (0 to perhaps age 2) are consumed by
many predators, the fishery exploits older ages where predation mortality is a very small part of natural mortality (Mueter et al. 2006, Bailey 2013, Bulatov 2014). Hence providing full production of recruits (Criterion 1.1.1) addresses the availability of young pollock to potential predators, and the fishery is not on a lower trophic level. The role of young pollock in the food
Justification web is addressed in P2. 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 Heintz, R. A.; Siddon, E,C.; Farley, E.V., Jr.; et al. 2013. Correlation References 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 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
BSAI Alaska Pollock – Final Report and Determination page 95 PI 1.1.2 Limit and target reference points are appropriate for the stock
Studies In Oceanography 65-70: SI: 31-45 Brooks, E.N., J.E. Powers, and E. Cortés 2010. Analytical reference points for age-structured models: application to data-poor fisheries ICES J. Mar. Sci., 67 (2010), pp. 165–175 Clark, W.G., 1993. The effect of recruitment variability on the choice of a target level of spawning biomass per recruit. In: Kruse, G, Marasco, R.J., Pautzke, C., Quinn, T.J. (Eds.), Proceedings of the International Symposium on Management Strategies for Exploited Fish Populations. Alaska Sea Grant College Program Report, 93-02, University of Alaska, pp. 233–246. Clark W.G. 2002. F35% revisited ten years later North Am. J. Fish. Manage., 22 (2002), pp. 251–257 Gabriel, W.L., M.P. Sissenwine, and W.J. Overholtz. 1989. Analysis of spawning stock biomass per recruit: an example for Georges Bank haddock. North Am. J. Fish. Manage., 9:. 383–391. Gabriel, W.L. and P.M. Mace 1999. A Review of Biological Reference Points in the Context of the Precautionary Approach Proceedings, 5th NMFS NSAW. 1999. NOAA Tech. Memo. NMFS-F/SPO-40. Pp 34-45. Morgan, M.J., H. Murua, G. Kraus, Y. Lambert, G. Marteinsdottir, C.T. Marshall, L. O’Brien, and J. Tomkiewicz 2009. The evaluation of reference points and stock productivity in the context of alternative indices of stock reproductive potential. Can. J. Fish. Aquat. Sci., 66: 404–414 Murawski, S.A., P.J. Rago, and E.A. Trippel 2001. Impacts of demographic variation in spawning characteristics on reference points for fishery management ICES J. Mar. Sci., 58 :002–1014 National Marine Fisheries Service (NMFS). 1996. Environmental Assessment/Regulatory Impact Review for Amendment 44 to the Fishery Management Plan for the Groundfish Fishery of the Bering Sea and Aleutian Islands Area and Amendment 44 to the Fishery Management Plan for the Groundfish Fishery of the Gulf of Alaska to Redefine Acceptable Biological Catch and Overfishing, Appendix B. Alaska Fisheries Science Center, National Marine Fisheries Service, 7600 Sand Point Way NE., Seattle, WA 98115-0070. Stabeno, P. J., Kachel, N.B., Moore, S.E., et al. 2012. Comparison of warm and cold years on the southeastern Bering Sea shelf and some implications for the ecosystem By: Deep-Sea Research Part II- Topical Studies In Oceanography e: 65-70 Special Issue: SI: 31- 45 Megrey, B.A. and Aydin, K.Y. 2009. A macrodescriptor perspective of ecological attributes for the Bering and Barents Seas. Deep-Sea Research Part Ii-Topical Studies In Oceanography 56: 2132-2140 Aydin, K. and Mueter, F. 2007. The Bering Sea - A dynamic food web perspective. Deep-Sea Research Part Ii-Topical Studies In Oceanography 54: 2501-2525.
OVERALL PERFORMANCE INDICATOR SCORE: 95 Note: Given the scale of the Eastern Bering Sea fishery compared to the Aleutian
BSAI Alaska Pollock – Final Report and Determination page 96 PI 1.1.2 Limit and target reference points are appropriate for the stock
Islands fishery; the assessment team weighted the EBS:AI as 4:1 in scoring.
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 97 Evaluation Table for PI 1.1.3
Where the stock is depleted, there is evidence of stock rebuilding within a PI 1.1.3 specified timeframe Scoring Issue SG 60 SG 80 SG 100 a Where stocks are Where stocks are depleted, depleted rebuilding strategies are demonstrated strategies, which to be rebuilding stocks
have a reasonable continuously and there is expectation of strong evidence that success, are in rebuilding will be complete place. within the specified
Guidepost timeframe. Met? (Y/N) (Y/N) NA NA
Justification b A rebuilding A rebuilding The shortest practicable timeframe is timeframe is rebuilding timeframe is specified for the specified for the specified which does not depleted stock that depleted stock that is exceed one generation time is the shorter of 30 the shorter of 20 for the depleted stock. years or 3 times its years or 2 times its generation time. For generation time. For
cases where 3 cases where 2 generations is less generations is less than 5 years, the than 5 years, the rebuilding timeframe rebuilding timeframe
Guidepost is up to 5 years. is up to 5 years. Met? (Y/N) (Y/N) (Y/N) Not Applicable
Justification c Monitoring is in There is evidence place to determine that they are whether the rebuilding stocks, or rebuilding strategies it is highly likely are effective in based on simulation rebuilding the stock modelling or previous
within a specified performance that timeframe. they will be able to rebuild the stock within a specified
Guidepost timeframe. Met? (Y/N) (Y/N)
BSAI Alaska Pollock – Final Report and Determination page 98 Where the stock is depleted, there is evidence of stock rebuilding within a PI 1.1.3 specified timeframe
Not Applicable.
Justification References OVERALL PERFORMANCE INDICATOR SCORE:
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 99
Evaluation Table for PI 1.2.1
PI 1.2.1 There is a robust and precautionary harvest strategy in place
Scoring Issue SG 60 SG 80 SG 100 a The harvest strategy The harvest strategy The harvest strategy is is expected to is responsive to the responsive to the state of the achieve stock state of the stock and stock and is designed to management the elements of the achieve stock management objectives reflected harvest strategy work objectives reflected in the in the target and limit together towards target and limit reference
reference points. achieving points. management objectives reflected in the target and limit
Guidepost reference points. Met? (Y/N) Y (Y/N) Y (Y/N) Y 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, a smaller Allowable Biological Catch (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). 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
Justification 100 is also considered to be met for this stock component.
BSAI Alaska Pollock – Final Report and Determination page 100 PI 1.2.1 There is a robust and precautionary harvest strategy in place b The harvest strategy The harvest strategy The performance of the is likely to work may not have been harvest strategy has been based on prior fully tested but fully evaluated and evidence
experience or evidence exists that it exists to show that it is plausible argument. is achieving its achieving its objectives objectives. including being clearly able to maintain stocks at target
Guidepost levels. Met? (Y/N) Y (Y/N) Y (Y/N) Y 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. 2015 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 ication challenged; under present conditions there is high confidence that the harvest strategy functions in a precautionary manner. This meets the SG
Justif 60, SG80 and SG100. c Monitoring is in
place that is expected to determine whether the harvest strategy
Guidepost is working. Met? (Y/N) Y
BSAI Alaska Pollock – Final Report and Determination page 101 PI 1.2.1 There is a robust and precautionary harvest strategy in place
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
Justification harvest control rules are working. Hence the SG 60 is fully met. d The harvest strategy is periodically reviewed and improved as necessary.
Guidepost Met? (Y/N) Y The general performance of the harvest is evaluated as part of the annual assessment process and the consultations that follow the assessment. The entire framework used by NOAA was reviewed in 2008 in preparation for reauthorization of the Magnuson-Stevens Fisheries Act (NMFS 2008), and with reauthorization necessary again, another round of review is underway. Part of that review is being done in an international setting (Deroba et al. 2015).
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
Justification as for Steller sea lions. e It is likely that shark It is highly likely that There is a high degree of finning is not taking shark finning is not certainty that shark finning is place. taking place. not taking place.
Guidepost Met? (Y/N/Not relevant) (Y/N/Not relevant) (Y/N/Not relevant)
BSAI Alaska Pollock – Final Report and Determination page 102 PI 1.2.1 There is a robust and precautionary harvest strategy in place
Not Applicable
Justification 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., Barbeaux, S., Honkalehto, T., and S. Kotwicki. 2014. “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.Deroba J., Butterworth D., Methot R., De Oliveira J. A., Fernandez C., Nielsen A., References 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
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.
Thompson G.G. 1999. Optimizing Harvest Control Rules in the Presence of Natural Variability and Parameter Uncertainty.
OVERALL PERFORMANCE INDICATOR SCORE: 100
BSAI Alaska Pollock – Final Report and Determination page 103 PI 1.2.1 There is a robust and precautionary harvest strategy in place
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 104
Evaluation Table for PI 1.2.2
PI 1.2.2 There are well defined and effective harvest control rules in place
Scoring Issue SG 60 SG 80 SG 100 a Generally Well defined harvest understood harvest control rules are in rules are in place place that are that are consistent consistent with the with the harvest harvest strategy and
strategy and which ensure that the act to reduce the exploitation rate is exploitation rate as reduced as limit limit reference points reference points are
Guidepost are approached. approached. Met? (Y/N) Y (Y/N) Y 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 tons, and in the last five years no pollock were harvested in directed fisheries, and less than 3,000 tons of pollock were harvested as bycatch in each year since 2010. 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
Justification exploitation rate reduction as necessary, meeting SG60 and SG80. b The selection of the The design of the harvest harvest control rules control rules takes into takes into account account a wide range of the main uncertainties.
Guidepost uncertainties. Met? (Y/N) Y (Y/N) Y
BSAI Alaska Pollock – Final Report and Determination page 105 PI 1.2.2 There are well defined and effective harvest control rules in place
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 tons, and in the last five years no pollock were harvested in directed fisheries, and less than 3,000 tons of pollock were harvested as bycatch in each year since 2010. 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). 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. 2014). 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 harvest control rule does take account of a wide
Justification range of uncertainties and meets the SG 100. c There is some Available evidence Evidence clearly shows that evidence that tools indicates that the the tools in use are effective used to implement tools in use are in achieving the exploitation
harvest control rules appropriate and levels required under the are appropriate and effective in achieving harvest control rules. effective in the exploitation levels controlling required under the
Guidepost exploitation. harvest control rules. Met? (Y/N) Y (Y/N) Y (Y/N) Y
BSAI Alaska Pollock – Final Report and Determination page 106 PI 1.2.2 There are well defined and effective harvest control rules in place
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 (Figure 6, Ianelli et al. 2014) 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.
Justification References NMFS 1998, Restrepo et al. 1998, Ianelli et al. 2014 OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 107 Evaluation Table for PI 1.2.3
PI 1.2.3 Relevant information is collected to support the harvest strategy
Scoring Issue SG 60 SG 80 SG 100 a Some relevant Sufficient relevant A comprehensive range of information related information related to information (on stock to stock structure, stock structure, stock structure, stock productivity, stock productivity productivity, fleet fleet composition, stock and fleet composition and abundance, fishery removals composition is other data is and other information such
available to support available to support as environmental the harvest strategy. the harvest strategy. information), including some that may not be directly related to the current harvest
Guidepost strategy, is available. Met? (Y/N) (Y/N) (Y/N) Y
BSAI Alaska Pollock – Final Report and Determination page 108 PI 1.2.3 Relevant information is collected to support the harvest strategy
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 and 2014. The Aleutian Islands 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 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
Justification Bering Sea and Aleutian Island pollock, meeting the SG 100 standard.
BSAI Alaska Pollock – Final Report and Determination page 109 PI 1.2.3 Relevant information is collected to support the harvest strategy b Stock abundance Stock abundance All information required by and fishery removals and fishery removals the harvest control rule is are monitored and at are regularly monitored with high least one indicator is monitored at a level frequency and a high degree available and of accuracy and of certainty, and there is a monitored with coverage consistent good understanding of sufficient frequency with the harvest inherent uncertainties in the to support the control rule, and one information [data] and the harvest control rule. or more indicators robustness of assessment
are available and and management to this monitored with uncertainty. sufficient frequency to support the
Guidepost harvest control rule. Met? (Y/N) (Y/N) (Y/N) Y 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. 2014). All major uncertainties are taken into account in the assessments which trigger the application of the harvest control strategy. Redesign of the Bering Sea observer program should increase the quantification of uncertainties in all catch records and in fleet behavior, which can improve
Justification what is already good performance of the system. c There is good information on all other fishery removals from the
Guidepost stock. Met? (Y/N) Y
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
Justification Alaska fisheries, meeting the SG 80 standard. Aydin and Meuter. 2007. Bacheler et al. 2012, Boldt et al. 2012 References Grant et al. 2010 Heintz and Vollenweider 2010 Holsman and Aydin 2015 Jones et al. 2014
BSAI Alaska Pollock – Final Report and Determination page 110 PI 1.2.3 Relevant information is collected to support the harvest strategy
Siddon et al. 2013a,b, Siddon et al. 2014 Shubina at al. 2009 Spencer and Dorn 2013 Urban 2012 Yanagimoto et al. 2012 OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 111
Evaluation Table for PI 1.2.4
PI 1.2.4 There is an adequate assessment of the stock status
Scoring Issue SG 60 SG 80 SG 100 a The assessment is The assessment is appropriate for the appropriate for the stock and for the stock and for the harvest control rule. harvest control rule and takes into
account the major features relevant to the biology of the species and the
Guidepost nature of the fishery. Met? (Y/N) Y (Y/N) Y
BSAI Alaska Pollock – Final Report and Determination page 112 PI 1.2.4 There is an adequate assessment of the stock status
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 ADMB modeling foundation (Fournier et al. 2012). The modeling 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. 2014). 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 modeled (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
Justification the fisheries, meeting the SG 100 standard.
BSAI Alaska Pollock – Final Report and Determination page 113 PI 1.2.4 There is an adequate assessment of the stock status
b The assessment estimates stock status relative to reference points.
Guidepost Met? (Y/N) Y 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 60 standard.
Justification
c The assessment The assessment The assessment takes into identifies major takes uncertainty into account uncertainty and is sources of account. evaluating stock status uncertainty. relative to reference points in
Guidepost a probabilistic way. Met? (Y/N) Y (Y/N) Y (Y/N) Y As described in the justifications for 1.2.4a as well as 1.1.2 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. For both stock components the assessments update all biomass and fishing mortality reference points and estimate stock status probabilistically relative
Justification to those reference points. Hence it meets the SG 100 standard. d The assessment has been
tested and shown to be robust. Alternative hypotheses and assessment approaches have been
Guidepost rigorously explored. Met? (Y/N) Y
BSAI Alaska Pollock – Final Report and Determination page 114 PI 1.2.4 There is an adequate assessment of the stock status
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 Bering Sea 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
Justification SG100. e The assessment of The assessment has been stock status is internally and externally peer subject to peer reviewed. review.
Guidepost Met? (Y/N) Y (Y/N) Y
BSAI Alaska Pollock – Final Report and Determination page 115 PI 1.2.4 There is an adequate assessment of the stock status
The assessments receive peer review at three levels. The first is internal, in that the 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 has 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 Bering Sea assessments for all the major stocks in 2011 (CIE 2012). That review, with over 100 recommendations potentially affecting the
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, and is a recent and wholly external review of the assessments. Together, this evidence shows internal and external peer review, meeting the SG80
Justification and SG100. 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 References 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. Gavaris, S. 1988. An adaptive framework for the estimation of population size. CAFSAC Res.Doc. 88/29: 12 p.
BSAI Alaska Pollock – Final Report and Determination page 116 PI 1.2.4 There is an adequate assessment of the stock status
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. Patterson, K. Cook, R., Darby, C., Gavaris, S., Kell, L., Lewy, P., Mesnil, B., Punt, A., Restrepo, V., Skagen, D. W., and G. Stefánsson. 2001. Estimating uncertainty in fish stock assessment and forecasting. Fish and Fisheries 2, 125–157. 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. OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 117 Principle 2
Evaluation Table for PI 2.1.1
The fishery does not pose a risk of serious or irreversible harm to the PI 2.1.1 retained species and does not hinder recovery of depleted retained species Scoring Issue SG 60 SG 80 SG 100 a Main retained species Main retained species There is a high degree of are likely to be within are highly likely to be certainty that retained species biologically based within biologically are within biologically based limits (if not, go to based limits (if not, go limits and fluctuating around scoring issue c below). to scoring issue c their target reference points.
Guidepost below). Met? (Y/N) Y (Y/N) Y (Y/N) Y – some elements N – most elements (see text)
BSAI Alaska Pollock – Final Report and Determination page 118 The fishery does not pose a risk of serious or irreversible harm to the PI 2.1.1 retained species and does not hinder recovery of depleted retained species Thirteen species or species groups are retained; however, each of the species or species groups accounts for <0.05% of the BSAI pollock catch and therefore are considered di minimis and not considered further (Table 10). The AI pollock catch has been small since 1999, typically < 2,000 t/yr and therefore retained catch is not reported in the AI assessment (Barbeaux et al. 2014). Although their catches are <0.05% in the BS pollock fishery, skates, sharks and sculpins are considered vulnerable species because of their low potential rate of increase and considered as main species. This coupled with the large catch of pollock can result in sizable removals of these vulnerable taxa. The most recent assessments estimate the 2014 ABCs for these taxa at 35,383 t, 1,020 t, and 42,318 t, respectively. Relative to these ABCs, the Pollock fishery retained 4.2%, 7.4% and 0.45% of the recommended catch of skates, sharks, and sculpins, respectively. Harvest recommendations for Alaska skate (Bathyraja parmifera), the most abundant skate species in the BSAI, are made using the results of an age structured model and Tier 3 methods. The remaining species (“other skates”) are managed under Tier 5 due to a lack of data. Some 14,400 t of the 14,600 catch in 2012 was taken in the longline fishery and the remainder in the trawl fishery. Estimated survey biomass of the skate complex in 2013 was about 400,000 t with a lower 95% confidence level greater than 300,000 t (Ormseth 2013, Fig. 1) indicating that the incidental catch in the Alaska pollock fishery represented a minimal mortality. The estimated aggregate ABC for the skate complex was 38,800 t and the OFL was 45,800t for 2013 (Ormseth 2013). The AI sculpin assessment is conducted with Tier 5 methods (Spies et al. 2013) using mean biomass estimates over the past four survey years for the six most abundant sculpins in the BSAI. An exploitation rate is then applied to the estimated current biomass to obtain the ABC and OFL. The sculpin complex mortality rate is a biomass-weighted average of the instantaneous natural mortality rates for these six species. The complex mortality rate may change as new survey data become available. The ABC for sculpins in the BSAI was 43,318 t in 2013 (Spies et al. 2013), and the retained bycatch in the Alaska pollock fishery fell far below this. While reference points are not calculated, the stability of biomass over the past four survey years and the low proportion of the biomass taken by the fisheries provide evidence that the sculpin biomass is highly likely to be within biological limits. Sharks have been considered a Tier 6 species because they are not targeted and biomass estimates are unreliable (Tribuzio et al. 2014). The current Tier 6 method adopted in 2010 for sharks uses the catch time series during 1997 - 2007 where OFL is equal to the maximum catch and ABC is 75% of OFL. The SSC, Plan Teams and CIE reviewers have all expressed concerns over the declining population trends in Pacific sleeper sharks. The CIE recommended using an average catch, as a more conservative management strategy than the maximum historical catch. Either approach is unlikely to constrain the fishery. Examining the catch history from 1997 to the present shows that catches are not likely to have exceeded the ABCs from either calculation, as catch estimates for the last 5 years have been < 20% of the ABC. The evidence that F falls substantially below the limit F supports a conclusion that the SG60 and SG80 levels are met. MSC certified species are considered to be within biological limits with a high degree of certainty. The MSC certified flatfish and certified Pacific cod make up the majority of the retained catch in the pollock fishery, but certified fish do not fall in the ‘Retained Species’ category. Each of these retained species is assessed annually to provide estimates of the allowable biological catch and overfishing level (e.g., NPFMC 2014). In all cases, the lower 95% confidence of estimated biomass falls above Bmsy level. These data indicate that there is a high degree of certainty that catches are within biologically based limits. Atka mackerel shows that the current biomass, on the order of
167,000mt, is substantially above the B40% level of 133,000 mt, and has a high degree of confidence that current biomass exceeds B20% the bottom 95% confidence limit of the estimate exceeds the B40% biomass (Lowe et al. 2014). The SG60 and SG80 levels are met. The SG100 level is met for one of seven minor retained species, meeting the SG80 overall: POP – 80; Atka mackerel – 100; Turbot – Justification 80; Skates – 80; Shark – 80; Sculpin – 80; Squid – 80.
BSAI Alaska Pollock – Final Report and Determination page 119 The fishery does not pose a risk of serious or irreversible harm to the PI 2.1.1 retained species and does not hinder recovery of depleted retained species
b Target reference points are defined for retained species.
Guidepost Met? (Y/N) Y – some elements N – some elements (see text) Target reference points are defined for most, but not all (e.g., skates, squids, sharks, and sculpins) retained species (NPFMC 2014). Pacific cod and several flatfish are currently certified, and therefore do not fall in the ‘Retained Species’ category. The other retained species account for <0.05% of the pollock catch. Of the species >0.5%, the fishery meets the SG100 for three of the seven species, and does not reach SG100 for five, rounded to SG90: POP – 100; Atka mackerel – 100;
Justification Turbot – 100; Skates – 80; Shark – 80; Sculpin – 80; Squid – 80. If main retained If main retained species are outside species are outside the limits there are the limits there is a measures in place partial strategy of that are expected to demonstrably ensure that the effective fishery does not management
hinder recovery and measures in place rebuilding of the such that the fishery depleted species. does not hinder recovery and
Guidepost rebuilding. Met? (Y/N) NA (Y/N) NA
Justification d If the status is poorly known there are measures or practices in place that are expected to result in the fishery not causing the
retained species to be outside biologically based limits or hindering
Guidepost recovery. Met? (Y/N) NA
Justification
BSAI Alaska Pollock – Final Report and Determination page 120 The fishery does not pose a risk of serious or irreversible harm to the PI 2.1.1 retained species and does not hinder recovery of depleted retained species Barbeaux, S., J. N. Ianelli, and W. Palsson. 2014. Chapter 1A: Assessment of the pollock stock in the Aleutian Islands. NPFMC Bering Sea and Aleutian Islands SAFE, Dec 2014. Lowe, S., J. Ianelli, and W. Palsson. 2014. Assessment of the Atka mackerel stock in the Bering Sea/Aleutian Islands. Bering Sea SAFE Document 2014. http://www.afsc.noaa.gov/REFM/Docs/2014/BSAIatka.pdf. NPFMC 2014. Stock Assessment and Fishery Evaluation Report for the Groundfish Resources of the Bering Sea/Aleutian Islands Region, References December 2014. Ormseth, O.A. 2013. Chapter Chapter 18. Assessment of the skate stock complex in the Bering Sea and Aleutian Islands. NPFMC Bering Sea and Aleutian Islands SAFE December 2013. Spies, I., Ormseth, O.A. and TenBrink, T.T. 2013. Chapter 19. Assessment of the sculpin complex in the Bering Sea and Aleutian Islands. NPFMC Bering Sea and Aleutian Islands SAFE November 2013 Tribuzio, C. A., K. Echave, C. Rodgveller, and P.-J. Hulson 2014. Assessment of the shark stock complex in the Bering Sea and Aleutian Islands. BSAI SAFE Document 2014. http://www.afsc.noaa.gov/REFM/Docs/2014/BSAIshark.pdf. OVERALL PERFORMANCE INDICATOR SCORE: 85
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 121
Evaluation Table for PI 2.1.2
There is a strategy in place for managing retained species that is designed to PI 2.1.2 ensure the fishery does not pose a risk of serious or irreversible harm to retained species Scoring Issue SG 60 SG 80 SG 100 a There are measures There is a partial There is a strategy in place in place, if strategy in place, if for managing retained necessary, that are necessary, that is species. expected to maintain expected to maintain the main retained the main retained species at levels species at levels which are highly which are highly likely to be within likely to be within
biologically based biologically based limits, or to ensure limits, or to ensure the fishery does not the fishery does not hinder their recovery hinder their recovery
Guidepost and rebuilding. and rebuilding. Met? (Y/N) Y (Y/N) Y (Y/N) Y – some elements N – some elements (see text) All of the retained species in the BSAI pollock fishery are assessed by NMFS and NPFMC (e.g., NPFMC 2014). Estimates of Overfishing Levels and Acceptable Biological Catch levels are reviewed regularly, mostly annually. These measures are expected to maintain retained species at levels which are highly likely to be within biologically based limits. FMPs have been developed for each species or groups that constitute both a partial strategy for managing retained species. The SG60 and SG80 are met. There is a strategy in place for most retained,
but not all retained species (e.g., skates, squids, sharks, and sculpins) (NPFMC 2014). All of the bycatch species account for <0.05% of the pollock catch and therefore, the fisheries meet the SG100 for three of the seven species, and do not reach SG100 for four, reaching SG90 overall: POP – 100; Atka mackerel – 100; Turbot – 100; Skates – 80; Shark – 80; Sculpin –
Justification 80; Squid – 80. b The measures are There is some Testing supports high considered likely to objective basis for confidence that the strategy work, based on confidence that the will work, based on plausible argument partial strategy will information directly about the
(e.g., general work, based on some fishery and/or species experience, theory information directly involved. or comparison with about the fishery similar and/or species
Guidepost fisheries/species). involved. Met? (Y/N) Y (Y/N) Y (Y/N) Y – some elements N – some elements (see text)
BSAI Alaska Pollock – Final Report and Determination page 122 There is a strategy in place for managing retained species that is designed to PI 2.1.2 ensure the fishery does not pose a risk of serious or irreversible harm to retained species Catch limits specified within SAFE reports are considered likely to work based on extensive experience with such limits in the BSAI and elsewhere. Annual estimates of the catch composition of retained species from the Observer Program demonstrate that there is an objective basis for confidence that the partial strategy will work. Observer coverage in the pollock fishery is effectively 100%. Regular assessment of stock status coupled with observer data from the fishery provides the basis for high confidence that the strategy will work. The SG60 and SG80 levels are met. There is a strategy in place for most
retained, but not all retained species (e.g., skates, squids, sharks, and sculpins) (NPFMC 2014). All of the bycatch species account for <0.05% of the pollock catch and therefore, the fisheries meet the SG100 for three of the species, and do not reach SG100 for four, reaching SG90 overall: POP – 100; Atka mackerel – 100; Turbot – 100; Skates – 80; Shark – 80; Sculpin
Justification – 80; Squid – 80. c There is some There is clear evidence that evidence that the the strategy is being partial strategy is implemented successfully. being implemented successfully.
Guidepost Met? (Y/N) Y (Y/N) N Application of annual catch limits and accountability measures required
under the MSA provides evidence of successful implementation of the strategy. The SG80 is met. The SG100 level is not met as biological limits for skate, sharks, squids, and sculpins retained catches are not available for all species and therefore it is not possible to have high confidence that the
Justification management strategy will work for all retained species. d There is some evidence that the strategy is achieving its overall objective.
Guidepost Met? (Y/N) Y
The biomass of retained species has fluctuated without trend and averaged about 18,000 t/yr since 1998. The retained biomass as a proportion of the pollock catch is about 0.2% providing some evidence that the strategy to minimize retained catch is working.
Justification
e It is likely that shark It is highly likely that There is a high degree of finning is not taking shark finning is not certainty that shark finning is place. taking place. not taking place.
Guidepost Met? (Y/N/Not relevant) Y (Y/N/Not relevant) Y (Y/N/Not relevant) Y
BSAI Alaska Pollock – Final Report and Determination page 123 There is a strategy in place for managing retained species that is designed to PI 2.1.2 ensure the fishery does not pose a risk of serious or irreversible harm to retained species The 2010 Shark Conservation Act requires that all sharks in the United
States be brought to shore with their fins naturally attached. Essentially 100% of the pollock fishery is observed. There are no reports of finning. The SG60, SG80 and SG100 levels are met.
Justification NPFMC 2014. Stock Assessment and Fishery Evaluation Report for the References Groundfish Resources of the Bering Sea/Aleutian Islands Region, December 2014. OVERALL PERFORMANCE INDICATOR SCORE: 90
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 124
Evaluation Table for PI 2.1.3
Information on the nature and extent of retained species is adequate to PI 2.1.3 determine the risk posed by the fishery and the effectiveness of the strategy to manage retained species Scoring Issue SG 60 SG 80 SG 100 a Qualitative Qualitative Accurate and verifiable information is information and information is available on available on the some quantitative the catch of all retained
amount of main information are species and the retained species available on the consequences for the status taken by the fishery. amount of main of affected populations. retained species
Guidepost taken by the fishery. Met? (Y/N) Y (Y/N) Y (Y/N) Y – some elements N – some elements (see text) Quantitative information on retained species in the BSAI pollock fishery from the Observer Program and updated stock assessments are available on an annual or regular basis (NMFS 2014a). Observer coverage is essentially 100% in this fishery (Table 7).
The SG60 and SG80 levels are met. Accurate and verifiable information on
the catch is available for most retained, but not all retained species (e.g., skates, squids, sharks, and sculpins) (NPFMC 2014). All of the retained species account for <0.05% of the pollock catch and therefore, the fisheries meet the SG100 for three of the seven species, and do not reach SG100 for four, reaching SG90 overall: POP – 100; Atka mackerel – 100; Turbot –
Justification 100; Skates – 80; Shark – 80; Sculpin – 80; Squid – 80. b Information is Information is Information is sufficient to adequate to sufficient to estimate quantitatively estimate
qualitatively assess outcome status with outcome status with a high outcome status with respect to biologically degree of certainty. respect to based limits. biologically based
Guidepost limits. Met? (Y/N/Not relevant) Y (Y/N/Not relevant) Y (Y/N) Y – some elements N – some elements (see text)
BSAI Alaska Pollock – Final Report and Determination page 125 Information on the nature and extent of retained species is adequate to PI 2.1.3 determine the risk posed by the fishery and the effectiveness of the strategy to manage retained species Regular stock assessments for each of the retained species or species groups provide quantitative estimates of the over-fishing level and the acceptable biological catch level. These assessments indicate that current level of retained species catches are within biologically based limits. Therefore, there is a quantitative basis to assess outcome status with respect to biologically based limits.
The SG60 and SG80 levels are met. Information on the catch is sufficient to
quantitatively estimate outcome for most retained, but not all retained species (e.g., skates, squids, sharks, and sculpins) (NPFMC 2014). All of the retained species account for <0.05% of the pollock catch and therefore, the fisheries meet the SG100 for three of the seven species, and do not reach SG100 for four, reaching SG90 overall: POP – 100; Atka mackerel –
Justification 100; Turbot – 100; Skates – 80; Shark – 80; Sculpin – 80; Squid – 80. c Information is Information is Information is adequate to adequate to support adequate to support support a strategy to
measures to a partial strategy to manage retained species, manage main manage main and evaluate with a high retained species. retained species. degree of certainty whether the strategy is achieving its
Guidepost objective. Met? (Y/N) Y (Y/N) Y (Y/N) Y – some elements N – some elements (see text) Information on the biomass and species composition of the catch from the Observer Program is adequate to support measures to manage main retained species. Combined with annual stock assessments and conservation measures listed in the FMP, these data support a partial strategy to manage main retained species. The SG60 and SG80 levels are met.
Information on the catch is adequate to support a strategy for most retained,
but not all retained species (e.g., skates, squids, sharks, and sculpins) (NPFMC 2014). All of the bycatch species account for <0.05% of the pollock catch and therefore, the fishery meets the SG100 for three of the seven species, and does not reach SG100 for four, reaching SG90 overall: POP – 100; Atka mackerel – 100; Turbot – 100; Skates – 80; Shark – 80; Sculpin –
Justification 80; Squid – 80. d Sufficient data Monitoring of retained continue to be species is conducted in collected to detect sufficient detail to assess any increase in risk ongoing mortalities to all level (e.g. due to retained species. changes in the outcome indicator
score or the
ost operation of the fishery or the effectiveness of the
Guidep strategy)
BSAI Alaska Pollock – Final Report and Determination page 126 Information on the nature and extent of retained species is adequate to PI 2.1.3 determine the risk posed by the fishery and the effectiveness of the strategy to manage retained species Met? (Y/N) Y (Y/N) Y – some elements N – some elements (see text) Annual catch records and Observer Program data combined with the regular assessment of biologically based limits for the catch of retained species provides sufficient data to detect an increase in risk to those populations. Thus the SG80 level is met. Monitoring of retained catch is conducted in sufficient detail for most
retained, but not all retained species (e.g., skates, squids, sharks, and sculpins) (NPFMC 2014). All of the bycatch species account for <0.05% of the pollock catch and therefore, the fishery meets the SG100 for three of the seven species, and does not reach SG100 for four, reaching SG90 overall: POP – 100; Atka mackerel – 100; Turbot – 100; Skates – 80; Shark – 80;
Justification Sculpin – 80; Squid – 80. NMFS 2014. North Pacific Groundfish and Halibut Observer Program 2013 Annual Report. National Oceanic and Atmospheric Administration, 709 West 9th Street. Juneau, Alaska 99802. References NPFMC 2014. Stock Assessment and Fishery Evaluation Report for the Groundfish Resources of the Bering Sea/Aleutian Islands Region, December 2014. Schindler et al. 2013 OVERALL PERFORMANCE INDICATOR SCORE: 90
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 127
Evaluation Table for PI 2.2.1
The fishery does not pose a risk of serious or irreversible harm to the bycatch PI 2.2.1 species or species groups and does not hinder recovery of depleted bycatch species or species groups Scoring Issue SG 60 SG 80 SG 100 a Main bycatch Main bycatch species There is a high degree of
species are likely to are highly likely to be certainty that bycatch be within biologically within biologically species are within based limits (if not, based limits (if not, biologically based limits. go to scoring issue b go to scoring issue b
Guidepost below). below). Met? (Y/N) Y (Y/N) Y (Y/N) Y – some elements N – some elements (see text)
BSAI Alaska Pollock – Final Report and Determination page 128 The fishery does not pose a risk of serious or irreversible harm to the bycatch PI 2.2.1 species or species groups and does not hinder recovery of depleted bycatch species or species groups More than 15 taxa are taken as bycatch in the BS pollock fishery. The biomass of the bycatch is low relative to the pollock catch and all the bycatch taxa, excepting Scypho jellyfish, account for <0.05% of the directed catch and are considered di minimus and not considered further. The biomass of Scypho jellyfish taken in the bycatch is nonetheless <2% of the pollock catch so is considered minor.
Prohibited species taken in the pollock fishery include Tanner and King crabs, halibut, herring and salmon (Table 12). Of the species caught, only Chinook salmon and Opilio crabs are taken at a level that warrants further discussion as the other taxa account for <0.05% of the catch. Chinook salmon are highly valued and this combined with continued low stock sizes in Alaskan rivers has led to action to reduce mortality. Chinook salmon bycatch in 2014 was once again low at 15,020 (36% of the 2003-2014 mean value) and consistent with the magnitude of bycatch since the implementation of Amendment 91 in 2011 which placed a hard cap on the level bycatch permitted. lanelli and Stram (2014) provide updated estimates of the bycatch impact on Chinook salmon runs to the coastal west Alaska region. Since 2011, the impact of the Chinook bycatch has been estimated to be below 2%. Thus the impact on returns to Alaskan rivers is expected to be small.
As in shown in Table 12, the bycatch level of chum salmon in the BSAI Pollock fishery varies considerably from year to year. Genetic analyses indicate that over half of chum samples in the Pollock fishery were from North and East Asian stocks, with about 20% from the Yukon and Western Alaska (Vulstek et al 2014). Abundance of hatchery chum salmon (all regions) exceeded that of wild chum salmon, largely in response to high hatchery production in Japan. During the 1990s, hatchery production of adult fish averaged 76 million chum. Wild chum salmon abundance averaged approximately 47 million fish per year, through 2000 (Mantua et al. 2009). Given the level of bycatch (<1%) relative to the estimated abundance of wild stocks, and the ~20% proportion of Yukon and Western Alaska stocks, there seems little chance that the bycatch poses serious threat to chum salmon stocks.
Crab stocks are assessed by the NMFS to support management under the BSAI King and Tanner Crab FMP. Crab abundance is measured annually using the groundfish bottom-trawl survey. Total catch mortality of the Bering Sea Opilio stock in 2013/14 was 28,200 t, while the retained catch in the directed fishery was 24,480 t. This is below the 2013/14 OFL of 78,100 t. Snow crab bycatch occurs in the directed fishery and to a lesser extent in the groundfish trawl fisheries. Estimates of trawl bycatch in recent years are less than 1% of the total snow crab catch (Crab PSC 2014). Estimates of stock status were above B35% in the assessment since 2010/11, and 96% of the value for B35% calculated in the 2014 assessment indicating that the stock is fluctuating about its reference point.
The SG60 and SG80 levels are met for all bycatch species. The SG100 level is met for prohibited species, but not for group taxa (i.e. jellies) in which species are not
Justification individually identified, resulting in a score of 95.
BSAI Alaska Pollock – Final Report and Determination page 129 The fishery does not pose a risk of serious or irreversible harm to the bycatch PI 2.2.1 species or species groups and does not hinder recovery of depleted bycatch species or species groups b If main bycatch If main bycatch species are outside species are outside biologically based biologically based limits there are limits there is a mitigation measures partial strategy of in place that are demonstrably expected to ensure effective mitigation
that the fishery does measures in place not hinder recovery such that the fishery and rebuilding. does not hinder recovery and
Guidepost rebuilding. Met? (Y/N) NA (Y/N) NA
Justification c If the status is poorly known there are measures or practices in place that are expected to result in the fishery not causing the
bycatch species to be outside biologically based limits or hindering
Guidepost recovery. Met? (Y/N) NA
Justification Ianelli, J.N. and D.L. Stram. 2014. Estimating impacts of the pollock fishery bycatch on western Alaska Chinook salmon. ICES Journal of Marine Science. doi:10.1093/icesjms/fsu173 Crab PSC in the Bering Sea/Aleutian Islands Fisheries. C6 BSAI Crab PSC Discussion Paper February 2014 References Mantua, N.J., N.G. Taylor, G.T. Ruggerone, K.W. Myers, D. Preikshot, X. Augerot, N.D. Davis, B. Dorner, R. Hilborn, R.M. Peterman, P. Rand, D. Schindler, J. Stanford, R.V. Walker, and C.J. Walters. 2009. The Salmon M,ALBEC Project: A North Pacific-scale Study to Support Salmon Conservation Planning. North Pacific Anadromous Fish Commission Bulletin No. 5: 333–354. NPFMC 2014. Stock Assessment and Fishery Evaluation Report for the
BSAI Alaska Pollock – Final Report and Determination page 130 The fishery does not pose a risk of serious or irreversible harm to the bycatch PI 2.2.1 species or species groups and does not hinder recovery of depleted bycatch species or species groups Groundfish Resources of the Bering Sea/Aleutian Islands Region, December 2014. Vulstek, S. C., C. M. Kondzela, C. T. Marvin, J. Whittle, and J. R.Guyon. 2014. Genetic stock composition analysis of chum salmon bycatch and excluder device samples from the 2012 Bering Sea walleye pollock trawl fishery. U.S. Dep. Commer., NOAA Tech. Memo. NMFS-AFSC-271, 35 p. OVERALL PERFORMANCE INDICATOR SCORE: 95
CONDITION NUMBER (if relevant):
Evaluation Table for PI 2.2.2
There is a strategy in place for managing bycatch that is designed to ensure PI 2.2.2 the fishery does not pose a risk of serious or irreversible harm to bycatch populations Scoring Issue SG 60 SG 80 SG 100 a There are measures There is a partial There is a strategy in place in place, if strategy in place, if for managing and minimizing necessary, that are necessary, that is bycatch. expected to maintain expected to maintain the main bycatch the main bycatch species at levels species at levels which are highly which are highly likely to be within likely to be within
biologically based biologically based limits, or to ensure limits, or to ensure the fishery does not the fishery does not hinder their recovery hinder their recovery
Guidepost and rebuilding. and rebuilding. Met? (Y/N) Y (Y/N) Y (Y/N) Y – some elements N – some elements (see text)
BSAI Alaska Pollock – Final Report and Determination page 131 There is a strategy in place for managing bycatch that is designed to ensure PI 2.2.2 the fishery does not pose a risk of serious or irreversible harm to bycatch populations The NPFMC has adopted a number of measures to minimize bycatch in BSAI groundfish fisheries, including pollock, (see NPFMC 2014). The Observer Program resulted in fundamental changes in the nature of the bycatch program by providing good estimates of total groundfish catch and non-groundfish bycatch by species that are counted against TACs. The Observer Program data makes it possible to enforce bycatch quotas for the non-groundfish species that by regulation have to be discarded at sea. Prohibited species catch (PSC) limits are in place to close target fisheries once limits have been reached. Such limits apply to Red king and Tanner crab species, Pacific halibut, Pacific herring, and Chinook salmon. Hard caps have been placed on the bycatch of Chinook salmon in the BS pollock fishery. Together, these measures constitute a strategy for managing and minimizing bycatch, which are highly likely to maintain main bycatch taxa within biologically based limits. The SG60, SG80, and SG100 are met for all species with the exception of non-Chinook salmons, dominated by chum leading to an overall score of 95. The Council action incorporated chum salmon avoidance into Amendment 91 Incentive Plan Agreements, due to go into effect for the 2016-2017 fishing year, including more strict requirements for Incentive Plan Agreements, requires salmon excluder devices, establishes penalties for vessels that consistently have high bycatch relative to the fleet, adjusts seasonal allocations, and lowers the
hard cap and performance standard by 25% in years of low Chinook abundance. Although measures have been taken to reduce the bycatch of chum salmon, they currently are in the implementation stage for minimizing bycatch (Haflinger and Gruver 2014). Therefore, the SG100 level is not met
Justification for this species. b The measures are There is some Testing supports high considered likely to objective basis for confidence that the strategy work, based on confidence that the will work, based on plausible argument partial strategy will information directly about the
(e.g. general work, based on some fishery and/or species experience, theory information directly involved. or comparison with about the fishery similar and/or species
Guidepost fisheries/species). involved. Met? (Y/N) Y (Y/N) Y (Y/N) N
BSAI Alaska Pollock – Final Report and Determination page 132 There is a strategy in place for managing bycatch that is designed to ensure PI 2.2.2 the fishery does not pose a risk of serious or irreversible harm to bycatch populations ABCs specified within regular assessments are considered likely to work based on extensive experience with such limits in the BSAI and elsewhere. Annual estimates of the composition of non-targeted and prohibited species bycatch from the Observer Program indicate that there is an objective basis for confidence that the partial strategy will work. Coverage in the pollock fishery is essentially 100%. The restructured Observer Program will further increase the proportion of the catch observed and therefore increase confidence in the strategy to avoid risk to bycatch species. Application of the bycatch reduction measures in BSAI pollock fishery supports high confidence that the strategy will work. The SG60 and SG80 are met for all species. Although the catches of Chinook salmon have decreased in the past three years since the
implementation of Amendment 91, more testing is needed to determine if the measures will be effective over a range of Chinook salmon stock sizes. Similarly, more time and direct evidence is needed to determine if measures to reduce the bycatch of Chum salmon will be effective. Some taxa are not identified to the species level making it difficult to determine if the strategy
Justification will work for all species. Therefore the SG100 level is not met. c There is some There is clear evidence that evidence that the the strategy is being partial strategy is implemented successfully. being implemented
Guidepost successfully. Met? (Y/N) Y (Y/N) Y Over the past decade or so the bycatch of crab species had declined considerably. Since Amendment 91, designed to reduce the bycatch of Chinook salmon, consistently reduced levels of bycatch in the past three
years provide some evidence that the new measures are working. Indirect estimates of savings (expected reduction, Haflinger and Gruver 2014) in chum bycatch resulting from measures adopted to reduce the bycatch of chum salmon provide evidence that the strategy is being implemented successfully.
Justification The SG80 and SG100 levels are met. d There is some evidence that the strategy is achieving its overall objective.
Guidepost Met? (Y/N) N There is some evidence from the reductions in bycatch for many of the
species that the strategy to reduce overall bycatch is achieving its objective. Efforts to reduce the bycatch of chum salmon are still at an early stage. Therefore, the SC100 level is not met.
Justification Haflinger and Gruver 2014. Report to the North Pacific Fishery Management Council on the 2013 Bering Sea Pollock References Intercooperative Salmon Avoidance Agreement. ITEM C7 - AFA Chum ICA Report APRIL 2014. Ianelli, J.N. and D.L. Stram. 2014. Estimating impacts of the pollock fishery
BSAI Alaska Pollock – Final Report and Determination page 133 There is a strategy in place for managing bycatch that is designed to ensure PI 2.2.2 the fishery does not pose a risk of serious or irreversible harm to bycatch populations bycatch on western Alaska Chinook salmon. ICES Journal of Marine Science. doi:10.1093/icesjms/fsu173 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. OVERALL PERFORMANCE INDICATOR SCORE: 90
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 134
Evaluation Table for PI 2.2.3
Information on the nature and the amount of bycatch is adequate to PI 2.2.3 determine the risk posed by the fishery and the effectiveness of the strategy to manage bycatch Scoring Issue SG 60 SG 80 SG 100 a Qualitative Qualitative Accurate and verifiable information is information and information is available on available on the some quantitative the catch of all bycatch
amount of main information are species and the bycatch species available on the consequences for the status taken by the fishery. amount of main of affected populations. bycatch species
Guidepost taken by the fishery. Met? (Y/N) Y (Y/N) Y (Y/N) Y – some elements N – some elements (see text) Regularly updated stock assessments (NPFMC 2014), fishery catch records, and quantitative information on bycatch in the pollock fishery from the Observer Program are available on a regular, mostly annual, basis (NMFS 2014a). Observer coverage is essentially 100%. Thus accurate and
verifiable information is available to assess the consequences of bycatch on the affected species. The SG60, SG80 levels are met. The SG100 level is met for most of the bycatch species, but is not met as some bycatch species (i.e., jellies) as they are not currently evaluated at the individual species level. Overall, this
Justification reaches a score of SG95. b Information is Information is Information is sufficient to
adequate to broadly sufficient to estimate quantitatively estimate understand outcome outcome status with outcome status with respect status with respect respect to biologically to biologically based limits to biologically based based limits. with a high degree of
Guidepost limits certainty. Met? (Y/N/Not relevant) Y (Y/N/Not relevant) Y (Y/N) Y – some elements N – some elements (see text) FMPs for each of the prohibited species and some of the non-target taxa provide quantitative estimates of the over-fishing level and an estimate of the acceptable biological catch level. For other non-target bycatch taxa, survey estimates of abundance are regularly available against which to
judge outcome status of the bycatch levels. Therefore, information is generally sufficient to assess outcome status with respect to biologically based limits. The SG60, SG80 levels are met for all species. The SG100 level is met for most of the bycatch species, but is not met others (i.e., jellies) as this group is not currently evaluated at the individual
Justification species level. Overall, this reaches a score of SG95.
BSAI Alaska Pollock – Final Report and Determination page 135 Information on the nature and the amount of bycatch is adequate to PI 2.2.3 determine the risk posed by the fishery and the effectiveness of the strategy to manage bycatch c Information is Information is Information is adequate to adequate to support adequate to support support a strategy to
measures to a partial strategy to manage retained species, manage bycatch. manage main and evaluate with a high bycatch species. degree of certainty whether the strategy is achieving its
Guidepost objective. Met? (Y/N) Y (Y/N) Y (Y/N) Y – some elements N – some elements (see text) Information on the biomass and species composition of the catch from the Observer Program is adequate to support measures to manage main bycatch species. Combined with survey estimates or indices of abundance, annual stock assessments, outputs from ecosystem models, and
conservation measures listed in the FMP, these data support a partial strategy to manage main bycatch species The SG60 and SG80 levels are met for all species. The SG100 level is met for most of the bycatch species, but is not met for others (i.e., jellies) as this group is not currently evaluated at the individual
Justification species level. Overall, this reaches a score of SG95. d Sufficient data Monitoring of bycatch data is continue to be conducted in sufficient detail collected to detect to assess ongoing any increase in risk mortalities to all bycatch to main bycatch species. species (e.g., due to changes in the outcome indicator
scores or the operation of the fishery or the effectively of the
Guidepost strategy). Met? (Y/N) Y (Y/N) Y – some elements N – some elements (see text) Annual Observer Program data combined with regular estimates or indices of abundance from fishery independent surveys, and assessment of
biologically based limits for bycatch species provides sufficient data to detect an increase in risk to those populations. Thus the SG80 level is met for all species. The SG100 level is met for most of the bycatch species, but is not met for others (i.e., jellies) as this group is not currently evaluated at the individual
Justification species level. Overall, this reaches a score of SG95. NPFMC 2014. Stock Assessment and Fishery Evaluation Report for the Groundfish Resources of the Bering Sea/Aleutian Islands Region, References December 2014.
NMFS 2014a. North Pacific Groundfish and Halibut Observer Program 2013 Annual Report. National Oceanic and Atmospheric Administration,
BSAI Alaska Pollock – Final Report and Determination page 136 Information on the nature and the amount of bycatch is adequate to PI 2.2.3 determine the risk posed by the fishery and the effectiveness of the strategy to manage bycatch 709 West 9th Street. Juneau, Alaska 99802.
OVERALL PERFORMANCE INDICATOR SCORE: 95
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 137
Evaluation Table for PI 2.3.1
The fishery meets national and international requirements for the protection of ETP species PI 2.3.1 The fishery does not pose a risk of serious or irreversible harm to ETP species and does not hinder recovery of ETP species Scoring Issue SG 60 SG 80 SG 100 a Known effects of the The effects of the There is a high degree of fishery are likely to fishery are known certainty that the effects of be within limits of and are highly likely the fishery are within limits of national and to be within limits of national and international
international national and requirements for protection requirements for international of ETP species. protection of ETP requirements for species. protection of ETP
Guidepost species. Met? (Y/N) Y (Y/N) Y (Y/N) Y Observer Program data provide annual estimates of interactions of ETP fish (salmon), seabirds and marine mammals with the pollock fishery in the BSAI. These data show that the known direct effects are small. Based on allowable takes specified in ETP species population assessments and recovery plans, there is a high degree of certainty that the effects of the fishery are within limits.
Short-tailed albatross, spectacled eider, and Steller’s eider have not been observed as bycatch in the pollock fishery.
The estimates of ETP salmon in the pollock fishery come from coded-wire tag recoveries from salmon bycatch. These data indicate that between 1984 and 2012 few wild Chinook from the lower Columbia or upper Willamette rivers were taken by the pollock fishery (Ford 2011). Most (97%) of the CWT recoveries are from hatchery salmon. 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.
The BSAI pollock pelagic-trawl fishery is a Category II (low impact) fishery with respect to direct effects on marine mammals (http://www.nmfs.noaa.gov/pr/interactions/lof/final2014.htm). Few Steller sea lion and northern fur seals are taken as bycatch in the pollock fishery, and thus the fishery contributes few animals annually against the PBR (see Table 8, Section 3.4.2).
The low amounts of ETP interactions relative to limits demonstrates that the effects of the fishery are known to be within limits of national and international requirements for protection of ETP species (Balsiger 2012, USFWS 2008, Allen and Angliss 2013).
Justification The SG60, SG80, and SG100 levels are met.
BSAI Alaska Pollock – Final Report and Determination page 138 The fishery meets national and international requirements for the protection of ETP species PI 2.3.1 The fishery does not pose a risk of serious or irreversible harm to ETP species and does not hinder recovery of ETP species
b Known direct effects Direct effects are There is a high degree of are unlikely to create highly unlikely to confidence that there are no unacceptable create unacceptable significant detrimental direct impacts to ETP impacts to ETP effects of the fishery on ETP
Guidepost species. species. species. Met? (Y/N) Y (Y/N) Y (Y/N) Y Observer Program data coupled with population assessments of allowable takes indicate that known direct effects of the pollock fishery are highly unlikely to create unacceptable impacts on ETP species (Short-tail
albatross, Zador et al. 2008; Steller sea lion and Northern fur seal, Allen and Angliss 2013; salmon, Balsiger 2012). These data and assessments provide a high degree of confidence that the fishery meets national requirements for protection (stipulated in recovery plans, Section 3.4.6) and that there are no significant detrimental effects due to the pollock fishery.
Justification The SG60, SG80, and SG 100 levels are met. c Indirect effects have There is a high degree of
been considered and confidence that there are no are thought to be significant detrimental unlikely to create indirect effects of the fishery unacceptable on ETP species.
Guidepost impacts. Met? (Y/N) Y (Y/N) N
BSAI Alaska Pollock – Final Report and Determination page 139 The fishery meets national and international requirements for the protection of ETP species PI 2.3.1 The fishery does not pose a risk of serious or irreversible harm to ETP species and does not hinder recovery of ETP species Indirect effects of the pollock fishery on short-tailed albatross has been considered (e.g., Zador and Fitzgerald 2008, Zador et al. 2008). As fishery effects were not identified as a current threat in the updated recovery plan (USFWS 2008).There is a high degree of confidence that the fishery does not cause unacceptable impacts, meeting the SG100 level.
Recent studies, comparing the foraging behavior, diets and performance of the lactating fur seal on the Pribilof Islands and on Bogoslof Island indicate that Pribilof females are working much harder (longer and more distant feeding trips) and yet are producing lighter and leaner offspring than females at the increasing Bogoslof population (Springer et al. 2010, unpublished report to NPRB, NMFS unpublished). These findings suggest that food abundance or distribution may differ between these sites. As pollock are a component of this species diet, reduced prey availability as a result of the indirect effects of commercial groundfish cannot be ruled out with a high degree of confidence.Therefore the SC100 level is not met for Northern fur seals.
Although pollock is likely an important food in the diet of the endangered western stock of Steller sea lions, despite multiple efforts to test for negative effects of the pollock fishery on Steller sea lions, few to none have been found (e.g., Bernard 2012). Thus, although there is opportunity for competition with the pollock fishery, indirect effects have been considered and based on current understanding, are thought unlikely to create unacceptable impacts (NMFS 2014) and therefore meeting the SG80 level.
No indirect fishery effects are considered to impact endangered salmon stocks (Balsiger 2012).
The SG100 level is met for Short-tailed Albatross. The SG100 level is not met for Steller sea lions and Northern fur seals as indirect effects are difficult to measure
Justification and thus some uncertainty remains regarding indirect effect on these ETP species. Allen, B. M., and R. P. Angliss. 2013. Alaska marine mammal stock assessments, 2012. U.S. Dep. Commer., NOAA Tech. Memo. NMFSAFSC-245, 282 p. Balsiger, J. W. 2012. 2011 Annual report for the Alaska Groundfish Chinook Salmon Incidental Catch and Endangered Species Act Consultation. NMFS April5, 2012. Ford M. J. (ed.). 2011. Status review update for Pacific salmon and steelhead listed under the Endangered Species Act: Pacific Northwest. U.S. Dept. Commer., NOAA Tech. Memo. NMFS-NWFSC-113, 281 p. National Marine Fisheries Service. 2007. Conservation plan for the Eastern Pacific stock of northern fur seal (Callorhinus ursinus). National Marine Fisheries Service, Juneau, Alaska. References NMFS. 2014. Endangered Species Act - Section 7 Consultation Biological Opinion: Authorization of Alaska groundfish fisheries under the proposed revised Steller sea lion measures. NOAA/NMFS, Juneau Alaska, April 2, 2014. Sinclair, E. H. and T. K. Zeppelin (2002). "Seasonal and spatial differences in diet in the western stock of Steller sea lions (Eumetopias jubatus)." Journal of Mammalogy 83(4): 973-990. Sinclair, E. H., L. S. Vlietstra, et al. (2008). "Patterns in prey use among fur seals and seabirds in the Pribilof Islands." Deep-Sea Research Part Ii-Topical Studies In Oceanography 55(16-17): 1897-1918. Schindler et al. 2013 Springer, A.M., R.R. Ream and S.J. Iverson. 2010. Seasonal Foraging Strategies and Consequences for Northern Fur Seals at Colonies with Opposite Population Trends. Year 2 (COFFS), NPRB Project 524 Final Report 79p.
BSAI Alaska Pollock – Final Report and Determination page 140 The fishery meets national and international requirements for the protection of ETP species PI 2.3.1 The fishery does not pose a risk of serious or irreversible harm to ETP species and does not hinder recovery of ETP species U.S. Fish and Wildlife Service. 2008. Short-tailed Albatross Recovery Plan. Anchorage, AK, 105 pp. Zador, S.G., Punt, A.E. & Parrish, J.K. (2008) Population impacts of endangered short-tailed albatross bycatch in the Alaskan trawl fishery. Biological Conservation, 141, 872-882. Zador, S. G., and S. M. Fitzgerald. 2008. Seabird attraction to trawler discards. AFSC Processed Rep. 2008-06, 26 p. Alaska Fish. Sci. Cent., NOAA, Natl. Mar. Fish. Serv., 7600 Sand Point Way NE, Seattle WA 98115. OVERALL PERFORMANCE INDICATOR SCORE: 95
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 141 Evaluation Table for PI 2.3.2
The fishery has in place precautionary management strategies designed to: Meet national and international requirements; Ensure the fishery does not pose a risk of serious harm to ETP PI 2.3.2 species; Ensure the fishery does not hinder recovery of ETP species; and Minimise mortality of ETP species.
Scoring Issue SG 60 SG 80 SG 100 a There are measures There is a strategy in There is a comprehensive in place that place for managing strategy in place for minimise mortality of the fishery’s impact managing the fishery’s ETP species, and on ETP species, impact on ETP species, are expected to be including measures including measures to highly likely to to minimise mortality, minimise mortality, which is achieve national and which is designed to designed to achieve above international be highly likely to national and international
requirements for the achieve national and requirements for the protection of ETP international protection of ETP species. species. requirements for the protection of ETP
Guidepost species. Met? (Y/N) Y (Y/N) Y (Y/N) N
BSAI Alaska Pollock – Final Report and Determination page 142 The fishery has in place precautionary management strategies designed to: Meet national and international requirements; Ensure the fishery does not pose a risk of serious harm to ETP PI 2.3.2 species; Ensure the fishery does not hinder recovery of ETP species; and Minimise mortality of ETP species.
There are no records of the gear used in the pollock fishery interacting with Short-tailed albatross, Spectacled eider or Steller’s eider. Nevertheless, there are measures and a comprehensive strategy in place to minimize mortality for this and other seabirds, as described on the NMFS Seabird Bycatch Reduction Program website (http://alaskafisheries.noaa.gov/protectedresources/seabirds.htm). The collection of seabird bycatch interactions by observers has provided reliable data to assess performance of the reduction program. Unlike the longline fisheries, there are no specific measures in place to limit seabird interactions with the pollock fishery presumably because only a small fraction of the seabird bycatch is associated with those fisheries. The pollock fishery accounts for <10% of the seabird bycatch from Alaskan groundfish fisheries (See Section 3.4.3).
The BSAI pollock fishery does not interact with Northern fur seals or Steller sea lions to a significant degree. These fisheries are classified by NMFS under the MMPA as a Category II fisheries of acceptable impact (i.e., estimates mortalities >1% and less than 50% of the PBR, see Section 3.4.10). A number of measures, recently updated (see Section 3.4.9), have been taken to further minimize mortality of Steller sea lions, including 3 nmi no-entry zones around rookeries, prohibition of groundfish trawling within 10-20 nmi of certain rookeries, and spatial and temporal allocation of Gulf of Alaska pollock, Pacific cod, and Aleutian Island Atka mackerel total allowable catch (Allen and Angliss 2013). These measures are components of a comprehensive strategy to manage fishery impacts. Although the direct effects of the Pollock fishery on Northern fur seals are limited and managed by provisions of the MMPA, ongoing research has identified no indirect fishery effects, so there has been no reason to develop comprehensive strategy to manage them in the NMFS Conservation plan (NMFS 2007). Chinook and other salmon are a prohibited species on the BSAI pollock fishery. Few ESA listed Chinook salmon are taken in the Pollock fishery. Overall, the number of Chinook in the pollock fishery has declined markedly since 2011 regulations were implemented. The numbers of Chinook in the BSAI pollock fishery recently has been well below the hard cap established to manage the bycatch, indicating that Amendment 91 is achieving its objective.
The above measures, along with restructuring the Observer Program to increase observer coverage, are elements of a comprehensive strategy for
managing the fishery impact on ETP species.
The SG60, SG80 and SG100 levels are met for all species, except Northern fur seal as a comprehensive strategy to manage fishery effects has not been developed. Nevertheless, there is a strategy to manage fishery effects
Justification within national limits, thus achieving the SG80 level.
BSAI Alaska Pollock – Final Report and Determination page 143 The fishery has in place precautionary management strategies designed to: Meet national and international requirements; Ensure the fishery does not pose a risk of serious harm to ETP PI 2.3.2 species; Ensure the fishery does not hinder recovery of ETP species; and Minimise mortality of ETP species. b The measures are There is an objective The strategy is mainly based considered likely to basis for confidence on information directly about work, based on that the strategy will the fishery and/or species plausible argument work, based on involved, and a quantitative
(e.g., general information directly analysis supports high experience, theory about the fishery confidence that the strategy or comparison with and/or the species will work. similar involved.
Guidepost fisheries/species). Met? (Y/N) Y (Y/N) Y (Y/N) Y The management measures and strategy to minimize mortalities are considered likely to work based on the careful design of the strategy. The strategy uses prior observer data, simulation models, and extensive
research on the ETP species to design the strategy specifically for the species. The quantitative information collected from the fishery by observers is subsequently used to assess that the fisheries are substantially below take limits set for ETP species, and therefore high confidence that the fisheries do not have adverse impacts on ETP species.
Justification The SG60, SG80 and SG100 levels are met. c There is evidence There is clear evidence that that the strategy is the strategy is being being implemented implemented successfully. successfully.
Guidepost Met? (Y/N) Y (Y/N) Y
There is clear evidence that the strategy to minimize mortalities of ETP species is being successfully implemented based on annual reports such as Marine Mammal Assessments, NMFS Seabird Bycatch Reduction Program and Ecosystem SAFE and analysis of observer data from the pollock fishery.
Justification The SG80 and SG100 levels are met. d There is evidence that the strategy is achieving its objective.
Guidepost Met? (Y/N) Y No short-tailed albatross, spectacled eider or Steller’s eider mortalities have been observed in the pollock fishery (Seabirds, Section 3.4.3). The
incidental takes of Steller sea lions and Northern fur seals in all groundfish fisheries, including pollock, are small relative to PBR (Table 8, Section 3.4.2; Allen and Angliss 2013). The incidental catch of ESA-listed Chinook salmon stocks is very low (Balsiger 2012). Thus, there is evidence that the strategy is achieving its objective.
Justification The SG100 level is met.
BSAI Alaska Pollock – Final Report and Determination page 144 The fishery has in place precautionary management strategies designed to: Meet national and international requirements; Ensure the fishery does not pose a risk of serious harm to ETP PI 2.3.2 species; Ensure the fishery does not hinder recovery of ETP species; and Minimise mortality of ETP species.
Allen, B. M., and R. P. Angliss. 2013. Alaska marine mammal stock assessments, 2012. U.S. Dep. Commer., NOAA Tech. Memo. NMFSAFSC-245, 282 p. References Balsiger, J. W. 2012. 2011 Annual report for the Alaska Groundfish Chinook Salmon Incidental Catch and Endangered Species Act Consultation. NMFS April5, 2012.
OVERALL PERFORMANCE INDICATOR SCORE: 95
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 145 Evaluation Table for PI 2.3.3
Relevant information is collected to support the management of fishery impacts on ETP species, including: Information for the development of the management strategy; PI 2.3.3 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 a Information is Sufficient information Information is sufficient to sufficient to is available to allow quantitatively estimate qualitatively estimate fishery related outcome status of ETP
the fishery related mortality and the species with a high degree mortality of ETP impact of fishing to of certainty. species. be quantitatively estimated for ETP
Guidepost species. Met? (Y/N) Y (Y/N) Y (Y/N) Y There is sufficient quantitative information being collected to estimate fishery-related mortality of ETP species. This information comes from, annual or periodic stock assessments of marine mammals, seabirds and salmons, take reduction team reports, and annual estimates of interactions derived from Observer Program data collected from the pollock fishery in the BSAI. Data on the mortalities of ETP seabirds is known to be within limits identified in recovery plans (see Section 3.4.3). Similarly, recorded mortalities of marine mammals are well below PBRs estimated in annual
population assessments and conservation or recovery plans (see Section 3.4.2). Therefore, combined with confidence limits on estimates of population abundance of ETP marine mammal species and direct counts of short-tailed albatross, information is sufficient to quantitatively estimate outcome status with a high degree of certainty.
Justification The SG60, SG80, and SG100 levels are met. b Information is Information is Accurate and verifiable adequate to broadly sufficient to information is available on
understand the determine whether the magnitude of all impacts, impact of the fishery the fishery may be a mortalities and injuries and on ETP species. threat to protection the consequences for the and recovery of the status of ETP species.
Guidepost ETP species. Met? (Y/N/Not relevant) Y (Y/N/Not relevant) Y (Y/N/Not relevant) N Information collected by the Observer Program on ETP species that interact
with the pollock fishery, coupled with population assessment of those ETP species, is adequate to broadly determine impacts and to assess the level of threat the fishery might pose. The information collected is accurate and verifiable with respect to direct impacts, thereby meeting SG60 and SG80; this cannot be stated with confidence for all impacts (i.e., including indirect),
Justification thereby not meeting SG100.
BSAI Alaska Pollock – Final Report and Determination page 146 Relevant information is collected to support the management of fishery impacts on ETP species, including: Information for the development of the management strategy; PI 2.3.3 Information to assess the effectiveness of the management strategy; and Information to determine the outcome status of ETP species. c Information is Information is Information is adequate to adequate to support sufficient to measure support a comprehensive measures to trends and support a strategy to manage impacts, manage the impacts full strategy to minimize mortality and injury
on ETP species. manage impacts on of ETP species, and ETP species. evaluate with a high degree of certainty whether a strategy is achieving its
Guidepost objectives. Met? (Y/N) Y (Y/N) Y (Y/N) Y
Regularly updated assessments of stock status, and annual information collected on ETP bycatch by the Observer Program, from the pollock fishery is adequate to support measures to manage impacts, to measure trends, and to support a full strategy. Observer coverage in the pollock fishery is essentially 100%.
Justification The SG60, SG80, and SG100 levels are met. NPFMC 2014. FISHERY MANAGEMENT PLAN for Groundfish of the Bering Sea References and Aleutian Islands Management Area. North Pacific Fishery Management Council, 605 W. 4th Avenue, Suite 306, Anchorage, Alaska 99501, APRIL 2014. OVERALL PERFORMANCE INDICATOR SCORE: 95
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 147
Evaluation Table for PI 2.4.1
The fishery does not cause serious or irreversible harm to habitat structure, PI 2.4.1 considered on a regional or bioregional basis, and function Scoring Issue SG 60 SG 80 SG 100 a The fishery is The fishery is highly There is evidence that the unlikely to reduce unlikely to reduce fishery is highly unlikely to
habitat structure and habitat structure and reduce habitat structure and function to a point function to a point function to a point where where there would where there would be there would be serious or be serious or serious or irreversible irreversible harm.
Guidepost irreversible harm. harm. Met? (Y/N/Partial) Y (Y/N/Partial) Y (Y/N/Partial) Partial
BSAI Alaska Pollock – Final Report and Determination page 148 The fishery does not cause serious or irreversible harm to habitat structure, PI 2.4.1 considered on a regional or bioregional basis, and function The following elements were scored: corals, sponges, and sea pens and sea whips combined based on Sigler et al. (2015) and Rooper et al. (2014). The team considered that damage to the habitat that leaves at least 80% of its structure and function with no impact, or recoverable to 80% within 5-20 years if fishing on the habitat were to cease entirely, would demonstrate that serious or irreversible harm has not occurred. Corals – the distribution of corals is well understood based on photographic data from and predictive habitat models of the BS with correct classification of presence/absence of 93%. Low densities of coral were consistent with the lack of hard substrates. Corals are rarely encountered in the NMFS bottom trawl survey and therefore trends in CPUE are not presented in the Ecosystem Considerations SAFE (Zador 2013). Photographs showed infrequent damage to Isididae corals; damage was not observed in other genera. The apparent impacts on coral fall substantially short of the 20% threshold for considering damage as serious or irreversible. Corals were most abundant in Pribilof Canyon and westward. Given these results and the fact that only a small fraction of the Pollock fishery occurs in the Pribilof canyons, and that the spatial footprint of the fishery relative to the size of the Bering Sea is very limited, data indicate that it is highly unlikely that the Pollock fishery would reduce corals to the point of serious harm, meeting the SG80. Although Sigler et al. (2015) and Rooper et al. (2014) present some evidence that the pollock fishery is highly unlikely to reduce corals to the point of serious or irreversible harm, confirming evidence will be needed to achieve the SG100 level. A score of 90 is given. Sponges – sponges are more widely distributed than corals in the BS with correct classification of presence/absence of 75%. Relative CPUE of sponges from NMFS bottom trawl surveys has increased from a low in 2008 to among the highest values observed in 2013 (Zador 013). Although interactions with sponges were widespread, only about 3% showed evidence of damage. The apparent impacts on sponges fall substantially short of the 20% threshold for considering damage as serious or irreversible. Given these finding, and that the spatial footprint of the fishery relative to the size of the Bering Sea is very limited, it is highly unlikely that the Pollock fishery would reduce sponges to the point of serious harm meeting the SG80. Although Sigler et al. (2015) and Rooper et al. (2014) present some evidence that the pollock fishery is highly unlikely to reduce corals to the point of serious or irreversible harm, confirming evidence will be needed to achieve the SG100 level. A score of 90 is given. Sea Whips – sea whips are widely distributed in the BS with correct classification of presence/absence of 90%. Relative CPUE of sea whips from NMFS bottom trawl surveys has increased since about 2003, showing large interannual variation but without trend (Zador (2013). Although interactions were widespread only 9% of individuals showed damage, and the spatial footprint of the fishery relative to the size of the Bering Sea is very limited. The apparent impacts on sea whips fall substantially short of the 20% threshold for considering damage as serious or irreversible. Data indicate that it is highly unlikely that the Pollock fishery would reduce corals to the point of serious harm meeting the SG80. Although Sigler et al. (2015) and Rooper et al. (2014) present some evidence that the pollock fishery is highly unlikely to reduce corals to the point of serious or irreversible harm, confirming evidence will be needed to achieve the SG100 level. A score of 90 is
Justification given. 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, References AK. NMFS 2010. Final EFH 5-year Review Summary Report, April 2010 Rooper, C., M. Sigler, P. Goddard, P. Malecha, R. Towler, K. Williams, and R. Wilborn. Validation of models of the distribution of structure-
BSAI Alaska Pollock – Final Report and Determination page 149 The fishery does not cause serious or irreversible harm to habitat structure, PI 2.4.1 considered on a regional or bioregional basis, and function forming invertebrates in 1 the eastern Bering Sea using an underwater stereo camera Unpublished manuscript. Sigler, M.F., C.N. Rooper, G.R. Hoff, R.P. Stone,R.A. McConnaughey, T.K. Wilderbuer. 2015. Faunal features of submarine canyons on the eastern Bering Sea slope. Marine Ecology Progress Series 526:21- 40. 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. OVERALL PERFORMANCE INDICATOR SCORE: 90
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 150
Evaluation Table for PI 2.4.2
There is a strategy in place that is designed to ensure the fishery does not PI 2.4.2 pose a risk of serious or irreversible harm to habitat types Scoring Issue SG 60 SG 80 SG 100 a There are measures There is a partial There is a strategy in place in place, if strategy in place, if for managing the impact of necessary, that are necessary, that is the fishery on habitat types.
expected to achieve expected to achieve the Habitat Outcome the Habitat Outcome 80 level of 80 level of performance. performance or
Guidepost above. Met? (Y/N) Y (Y/N) Y (Y/N) Y 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 has set out a procedure for the 2015 EFH review. 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, 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 habitat areas of particular concern (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 (see 2.4.1a), which demonstrates low risk of adverse impacts while research continues.
Justification The SG60, SG80 and SG100 levels are met. b The measures are There is some Testing supports high considered likely to objective basis for confidence that the strategy work, based on confidence that the will work, based on plausible argument partial strategy will information directly about the
(e.g. general work, based on fishery and/or habitats experience, theory information directly involved. or comparison with about the fishery similar and/or habitats
Guidepost fisheries/habitats). involved. Met? (Y/N) Y (Y/N) Y (Y/N) Y
BSAI Alaska Pollock – Final Report and Determination page 151 There is a strategy in place that is designed to ensure the fishery does not PI 2.4.2 pose a risk of serious or irreversible harm to habitat types Research and inference demonstrate that identifying sensitive areas and implementing measures to protect them, to the extent practicable, will succeed. 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 and the prohibition of bottom contact in
areas to reduce fishing impacts are widely practiced in other parts of the world and there is a long history of experience of such measures from pollock fisheries in the BSAI. VMS (Loefflad et al. 2014) data on fishing locations and Observer data on the nature of catches provide a basis for testing that the strategy will work.
Justification The SG60, SG80, and SG100 are met. c There is some There is clear evidence that evidence that the strategy is being
the partial implemented strategy is successfully. being implemented
Guidepost successfully. Met? (Y/N) Y (Y/N) Y
VMS (Loefflad et al. 2014) data on fishing locations and Observer Program data (Table 7) on the nature of catches provide a basis for testing that the strategy will work. These sources of information also provide evidence the Council’s strategy is being successfully implemented, that is, the fishery is respecting habitat protection measures.
Justification The SG80 and SG100 are met. d There is some evidence that the strategy is achieving its objective.
Guidepost Met? (Y/N) N Ecological monitoring of sensitive areas is not ongoing since the HAPCs
and other measures were put in place, so it is not clear that evidence exists of the strategy achieving its objective.
Justification Loefflad, M. R., F. R. Wallace, J. Mondragon, J. Watson, and G. A. Harrington. 2014. Strategic plan for electronic monitoring and electronic reporting in the North Pacific. U.S. Dep. Commer., NOAA References Tech. Memo. NMFS-AFSC-276, 52 p. 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. OVERALL PERFORMANCE INDICATOR SCORE: 95
BSAI Alaska Pollock – Final Report and Determination page 152 There is a strategy in place that is designed to ensure the fishery does not PI 2.4.2 pose a risk of serious or irreversible harm to habitat types
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 153
Evaluation Table for PI 2.4.3
Information is adequate to determine the risk posed to habitat types by the PI 2.4.3 fishery and the effectiveness of the strategy to manage impacts on habitat types Scoring Issue SG 60 SG 80 SG 100 a There is basic The nature, The distribution of habitat understanding of the distribution and types is known over their types and vulnerability of all range, with particular distribution of main main habitat types in attention to the occurrence
habitats in the area the fishery are known of vulnerable habitat types. of the fishery. at a level of detail relevant to the scale and intensity of the
Guidepost fishery. Met? (Y/N) Y (Y/N) Y (Y/N) Y – BS; N – AI McConnaughey and Smith (2000) and Smith and McConnaughey (1999) described available data on sediments for the Bering Sea shelf and the relationship of that data to the distribution of pollock. A comprehensive inventory of bottom habitat data in the BSAI is provided in McConnaughey et al. (2009). The types, distributions and vulnerability of the main habitats, consisting mainly of muds, sand, and gravel bottoms, in the BS are reasonably well known at the scale relevant to the fishery as described in the EFH report (NMFS 2005). 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 fishery (NMFS 2005). Recent multivariate analysis of trawl data and an extensive camera survey of 5 canyons in the eastern Bering Sea in 2014 (Sigler et al. 2015, Rooper et al. unpublished manuscript) show that the distribution of habitat types is known, with particular attention to vulnerable habitats such
as corals. The SG60 and SG80 levels are met for both the BS and AI. The SG100 level is met in the BS based on new analysis and field research. The SG100 level is not met for the AI as the distribution of vulnerable habitats is less well known. Given the small catches of pollock in the AI, a score of 95 is
Justification given. b Information is Sufficient data are The physical impacts of the adequate to broadly available to allow the gear on the habitat types understand the nature of the impacts have been quantified fully. nature of the main of the fishery on impacts of gear use habitat types to be on the main habitats, identified and there is including spatial reliable information
overlap of habitat on the spatial extent with fishing gear. of interaction, and the timing and location of use of the
Guidepost fishing gear. Met? (Y/N) Y (Y/N) Y (Y/N) N
BSAI Alaska Pollock – Final Report and Determination page 154 Information is adequate to determine the risk posed to habitat types by the PI 2.4.3 fishery and the effectiveness of the strategy to manage impacts on habitat types The EFH report (NMFS 2005) and 5-year review of EFH (NMFS 2010) provided information to broadly understand the nature of the main impacts of gear use on the main habitats in the BSAI pollock fishery. There are model estimates of long-term bottom habitat impacts of pelagic trawl gear used in the pollock trawl fishery that provide some data to allow the nature of impact and their spatial extent to be generally determined (EFH, NMFS 2005). However, current assumptions based on input from industry, is that pelagic gear contacts the seafloor approximately 44% of the time the gear is being towed. Recent multivariate analysis of trawl data and an extensive camera survey of 5 canyons in the eastern Bering Sea in 2014 (Sigler et al. 2015, Rooper et al. unpublished manuscript) show that the distribution of habitat types is known, with particular attention to vulnerable habitats such as corals. Thus the physical impacts of the area used in the pollock fishery have been reasonably well quantified. Therefore, the SG60 and SG80
levels are met.
As there has been only some quantification of impacts, the eastern Bering Sea fishery does not fully meet the SG100. In the AI physical impacts of trawl gear on habitat types have not been fully quantified, not meeting the
Justification SG100. c Sufficient data Changes in habitat continue to be distributions over time are collected to detect measured. any increase in risk to habitat (e.g. due to changes in the outcome indicator
scores or the operation of the fishery or the effectiveness of the
Guidepost measures). Met? (Y/N) Y (Y/N) N Sufficient data by means of VMS and the Observer Program continue to be collected from the pollock fishery 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
on Observer Program collects detailed information on the nature and composition of the bycatch from the fishery which could signal changes in habitat impacts. The SG80 level is met. The SG100 level is not met as changes in habitat
Justificati distributions over time have not been measured. McConnaughey, R.A. and K.R. Smith. 2000. Association between flatfish abundance and surficial sediments in the EBS. Canadian journal of fisheries and aquatic sciences. 57(12):2410-2419. References McConnaughey, R. A., J. V. Olson, and M. F. Sigler. 2009. Alaska Fisheries Science Center essential fish habitat data inventory. AFSC Processed Rep. 2009-01, 40 p. Alaska Fish. Sci. Cent., NOAA, Natl. Mar. Fish. Serv., 7600 Sand Point Way NE, Seattle WA 98115. Rooper, C., M. Sigler, P. Goddard, P. Malecha, R. Towler, K. Williams, and
BSAI Alaska Pollock – Final Report and Determination page 155 Information is adequate to determine the risk posed to habitat types by the PI 2.4.3 fishery and the effectiveness of the strategy to manage impacts on habitat types R. Wilborn. Validation of models of the distribution of structure- forming invertebrates in 1 the eastern Bering Sea using an underwater stereo camera. Unpublished manuscript. Sigler, M.F., C.N. Rooper, G.R. Hoff, R.P. Stone,R.A. McConnaughey, T.K. Wilderbuer. 2015. Faunal features of submarine canyons on the eastern Bering Sea slope. Marine Ecology Progress Series 526:21- 40. Smith, K.R. and R.A. McConnaughey. 1999. Surficial sediments of the EBS. Continental Shelf: EBSSED Database Documentation. OVERALL PERFORMANCE INDICATOR SCORE: 85
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 156
Evaluation Table for PI 2.5.1
The fishery does not cause serious or irreversible harm to the key elements PI 2.5.1 of ecosystem structure and function Scoring Issue SG 60 SG 80 SG 100 a The fishery is The fishery is highly There is evidence that the unlikely to disrupt unlikely to disrupt the fishery is highly unlikely to the key elements key elements disrupt the key elements underlying underlying underlying ecosystem
ecosystem structure ecosystem structure structure and function to a and function to a and function to a point where there would be a point where there point where there serious or irreversible harm. would be a serious would be a serious or
Guidepost or irreversible harm. irreversible harm. Met? (Y/N/Partial) Y (Y/N/Partial) Y (Y/N/Partial) Y Based on the nature and amounts of retained and bycatch species (see Sections 3.4.7 and 3.4.8), the limited interactions with ETP species (Section 3.4.5 and 3.4.6), and habitat and ecosystem analyses (e.g., Aydin et al. 2007), the fishery is highly unlikely to disrupt the key elements underlying
ecosystem structure and function to a point where there would be 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.
Justification The SG60, SG80, and SG100 levels are met. Aydin, K., S. Gaichas, I. Ortiz, D. Kinzey, and N. Friday. 2007. A References 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, 298 p. OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 157
Evaluation Table for PI 2.5.2
There are measures in place to ensure the fishery does not pose a risk of PI 2.5.2 serious or irreversible harm to ecosystem structure and function Scoring Issue SG 60 SG 80 SG 100 a There are measures There is a partial There is a strategy that
in place, if strategy in consists of a plan, in necessary. place, if place. necessary.
Guidepost Met? (Y/N) Y (Y/N) Y (Y/N) Y
There are measures in place, as specified in the BSAI FMP (NPFMC 2014), to ensure that the fishery does not pose a risk of serious and irreversible harm to the ecosystem. The stated objective of the FMP is to “ensure the sustainability of fishery resources and associated ecosystems for the benefit of future.” The NPFMC has adopted measures to accelerate ecosystem- based management principles that protect managed species from
overfishing, and increase habitat protection and bycatch constraints. The Ecosystem Considerations SAFE (Zador [ed.] 2013) tracks a number of ecosystem indicators of environmental change and fishing to ensure that the pollock fishery does not pose a risk of serious and irreversible ecosystem harm.
Justification The SG60, SG80 and SG100 levels are met. b The measures take The partial strategy The strategy, which consists into account takes into account of a plan, contains measures potential impacts of available information to address all main impacts the fishery on key and is expected to of the fishery on the elements of the restrain impacts of ecosystem, and at least ecosystem. the fishery on the some of these measures are ecosystem so as to in place. The plan and achieve the measures are based on well- Ecosystem Outcome understood functional 80 level of relationships between the performance. fishery and the Components and elements of the ecosystem.
This plan provides for development of a full
strategy that restrains impacts on the ecosystem to ensure the fishery does not cause serious or irreversible
Guidepost harm. Met? (Y/N) Y (Y/N) Y (Y/N) Y
BSAI Alaska Pollock – Final Report and Determination page 158 There are measures in place to ensure the fishery does not pose a risk of PI 2.5.2 serious or irreversible harm to ecosystem structure and function The management measures take into account key elements of the ecosystem, such as the corals, and other sensitive habitats, marine mammals (e.g., Steller sea lions), prohibitions on the catch of highly valued species such as halibut, herring, salmon and, King and Tanner crabs, measures to reduce bycatch, restrictions on the use of non-pelagic trawls, and restrictions on bottom contact in sensitive habitat. These measures represent strategy to restrain all main impacts of the fishery (NMFS 2007; BSAI FMP 2008). The FMP is based on well-understood functional
relationships, as evidenced by the extensive research to understanding the structure and functioning of both ecosystems (e.g., Adyin et al. 2007). The plan provides for development of a full strategy that restrains fishing impacts on the ecosystem as evidenced by the wide range of measures in place and others under consideration (e.g., protection of canyons in the BS).
Justification The SG60, SG80 and SG100 levels are met. c The measures are The partial strategy is The measures are considered likely to considered likely to considered likely to work work, based on work, based on based on prior experience, plausible argument plausible argument plausible argument or (e.g., general (e.g., general information directly from the
experience, theory experience, theory or fishery/ecosystems involved. or comparison with comparison with similar similar fisheries/ecosystems fisheries/ecosystems
Guidepost ). ). Met? (Y/N) Y (Y/N) Y (Y/N) Y
The measures are considered likely to work, based on plausible arguments and direct experience from the BSAI groundfish fisheries, and the strategy is considered likely to work based on the direct experience of ecosystem status over a period of many years (e.g., Ecosystem Consideration SAFE, Zador [ed.] 2013).
Justification The SG60, SG80 and SG100 levels are met. d There is some There is evidence that the evidence that the measures are being
measures comprising implemented the partial strategy successfully. are being implemented
Guidepost successfully. Met? (Y/N) Y (Y/N) Y Evidence that the measures comprising the partial strategy are being
implemented successfully comes from annual reports and analysis of data from the fishery collected by the Observer Program on the amount and composition of retained species, bycatch species, prohibited species and interactions with ETP species. Many of these measures are summarized in the Ecosystem Considerations SAFE (Zador [ed.] 2013).
Justification The SG80 and SG100 levels are met. Aydin, K., S. Gaichas, I. Ortiz, D. Kinzey, and N. Friday. 2007. A comparison of the Bering Sea, Gulf of Alaska, and Aleutian Islands References large marine ecosystems through food web modeling. U.S. Dep. Commer., NOAA Tech. Memo. NMFS-AFSC-178, 298 p.
BSAI Alaska Pollock – Final Report and Determination page 159 There are measures in place to ensure the fishery does not pose a risk of PI 2.5.2 serious or irreversible harm to ecosystem structure and function NMFS 2007. Alaska Groundfish Harvest Specifications, Final Environmental Impact Statement. United States Department of Commerce, National Oceanic and Atmospheric Administration, National Marine Fisheries Service, Alaska Region, January 2007. NPFMC 2014. FISHERY MANAGEMENT PLAN for Groundfish of the Bering Sea and Aleutian Islands Management Area, April 2014, 144 p. Zador, S. [ed.] 2013. Ecosystem Considerations 2103. November 18, 2013North Pacific Fishery Management Council. OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 160
Evaluation Table for PI 2.5.3
PI 2.5.3 There is adequate knowledge of the impacts of the fishery on the ecosystem
Scoring Issue SG 60 SG 80 SG 100 a Information is Information is adequate to identify adequate to broadly the key elements of understand the key the ecosystem (e.g., elements of the
trophic structure and ecosystem. function, community composition, productivity pattern
Guidepost and biodiversity). Met? (Y/N) Y (Y/N) Y In both the BS and AI, information is adequate to identify key elements of
the ecosystem, as demonstrated qualitative descriptions of both ecosystems (e.g., Ecosystem considerations, SAFE, Zador [ed.] 2013; EIS EFH NOAA 2005). Quantitative models of both ecosystems (e.g., Aydin et al. 2007) demonstrate that information is adequate to broadly understand the key elements of the BSAI ecosystems.
Justification Thus both SG60 and SG80 are met. b Main impacts of the Main impacts of the Main interactions between fishery on these key fishery on these key the fishery and these ecosystem elements ecosystem elements ecosystem elements can be
can be inferred from can be inferred from inferred from existing existing information, existing information information, and have been and have not been and some have been investigated. investigated in investigated in detail.
Guidepost detail. Met? (Y/N/Not relevant) Y (Y/N/Not relevant) Y (Y/N/Not relevant) N There have been few studies of the impacts of pelagic-trawls on bottom fauna. Some impacts are expected as the foot rope of the trawl contacts the bottom rather often (estimated about 44% of the time). Impacts are generally less in soft-bottom substrates such as the BS. Damage from footropes was estimated at 20 % reduction per gear contact and 30 % reduction for both living and non-living structure, respectively. Recovery rates for infauna and epifauna were estimated at 3 to 4 months for sand, 6 to 12 months for sand/mud, and 6 to 18 months for mud habitats (NMFS 2005). Long-term Effects Impact analysis suggested pollock non-pelagic trawling would result in a 4.6% and 7.2% reduction in habitat features for the most sensitive features in sand/mud and slope biostructure, respectively
(NMFS 2005, Table B.2-10). Impacts of the trawl fishery on marine mammals and seabirds can be inferred from existing information and some have been investigated in detail. The SG60 and SG80 levels are met. The SG100 level is not met as the long-term ecosystem effects of pelagic trawling for pollock have not been
Justification empirically determined in the BSAI.
BSAI Alaska Pollock – Final Report and Determination page 161 PI 2.5.3 There is adequate knowledge of the impacts of the fishery on the ecosystem c The main functions of The impacts of the fishery on the Components (i.e., target, Bycatch, Retained target, Bycatch, and ETP species are
Retained and ETP identified and the main species and functions of these Habitats) in the Components in the ecosystem are ecosystem are understood.
Guidepost known. Met? (Y/N) Y (Y/N) Y 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, bycatch, retained and ETP species and habitats have been identified and the main functions of these components are understood through extensive quantitative modeling of the ecosystem (e.g., Aydin et al. 2007).
Justification The SG80 and SG100 levels are met. d Sufficient information Sufficient information is is available on the available on the impacts of impacts of the fishery the fishery on the on these Components and elements
Components to allow to allow the main some of the main consequences for the consequences for the ecosystem to be inferred. ecosystem to be
Guidepost inferred. Met? (Y/N) Y (Y/N) Y Analyses conducted for the definition of EFH provide sufficient information of the impacts of the fishery on bottom fauna (NMFS 2005), whereas,
ecosystem modelling (e.g., Aydin et al. 2007), data on seabird and marine mammal takes from the Observer Program and marine mammal assessments (Allen and Angliss 2013) have provided sufficient information of the impacts of the fishery on other components. These analyses and models also allow the main consequences for the ecosystem to be inferred.
Justification The SG80 and SG100 levels are met. e Sufficient data Information is sufficient to continue to be support the development of collected to detect strategies to manage any increase in risk ecosystem impacts. level (e.g., due to changes in the outcome indicator
scores or the operation of the fishery or the effectiveness of the
Guidepost measures). Met? (Y/N) Y (Y/N) Y
BSAI Alaska Pollock – Final Report and Determination page 162 PI 2.5.3 There is adequate knowledge of the impacts of the fishery on the ecosystem
NMFS conducts a comprehensive program of surveys to monitor the abundance and key elements of the BSAI ecosystems. The Observer Program collects annual catch, retained species and bycatch statistics and biological samples from the pollock fishery. Together they collect 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 demonstrated by the Aleutian Islands Fishery Ecosystem Plan (NPFMC 2007), and the motion by the NPFMC to develop a similar plan for the BS (http://www.npfmc.org/bsfep/).
Justification The SG80 and SG100 levels are met. References NPFMC 2007. Aleutian Islands Fishery Ecosystem Plan, December 2007
OVERALL PERFORMANCE INDICATOR SCORE: 95
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 163
Principle 3 Evaluation Table for PI 3.1.1
The management system exists within an appropriate legal and/or customary framework which ensures that it: Is capable of delivering sustainable fisheries in accordance with MSC PI 3.1.1 Principles 1 and 2; and 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 a There is an effective There is an effective There is an effective national national legal national legal system legal system and binding system and a and organised and procedures governing framework for effective cooperation cooperation with other cooperation with with other parties, parties which delivers other parties, where where necessary, to management outcomes necessary, to deliver deliver management consistent with MSC
management outcomes consistent Principles 1 and 2. outcomes consistent with MSC Principles with MSC Principles 1 and 2. 1 and 2
Guidepost Met? (Y/N) Y (Y/N) Y (Y/N) Y Management of the Alaska pollock 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 MSA is the principal law governing the harvest of fishery resources within the federal portion of the U.S. 200-mile zone. Under the MSA, 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 NPFMC 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 Alaska pollock 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
Justification regulations to further reduce seabird interactions in the fishery.
BSAI Alaska Pollock – Final Report and Determination page 164 The management system exists within an appropriate legal and/or customary framework which ensures that it: Is capable of delivering sustainable fisheries in accordance with MSC PI 3.1.1 Principles 1 and 2; and 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. b The management The management The management system system incorporates system incorporates incorporates or subject by or is subject by law or is subject by law to law to a transparent to a mechanism for a transparent mechanism for the resolution the resolution of mechanism for the of legal disputes that is legal disputes resolution of legal appropriate to the context of arising within the disputes which is the fishery and has been system. considered to be tested and proven to be effective in dealing effective. with most issues and that is appropriate to the context of the
Guidepost fishery. Met? (Y/N) Y (Y/N) Y (Y/N) Y The NPFMC relies on a consensus approach among advisory bodies with room for minority reports should these groups fail to reach consensus (NPFMC 2009). The NPFMC 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 MSA. 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 NPFMC and NMFS through the federal court system.
There is no current litigation involving NPFMC decisions. However, several decisions of other regional fishery management councils have come under court challenges (e.g., CCC 2012; Issenberg 2013). These challenges often move to District Courts of Appeal for final decision. The NOAA Office of General Counsel (OGC) represents the councils and NMFS in court. NOAA OGC has established a formal guideline for maintaining the agency administrative record (Schiffer 2012.). While this record serves to increase efficiency of the agency, it also increases the efficiency for any plaintiffs and
for the court. This helps lead to a transparent and effective system for resolving legal disputes. These mechanisms have proven effective for providing resolution of challenging and controversial management issues, and setting effective precedent for future management measures, thereby meeting all the requirements of SG60, SG80, and SG100.
Justification
BSAI Alaska Pollock – Final Report and Determination page 165 The management system exists within an appropriate legal and/or customary framework which ensures that it: Is capable of delivering sustainable fisheries in accordance with MSC PI 3.1.1 Principles 1 and 2; and 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. d The management The management The management system system has a system has a has a mechanism to formally mechanism to mechanism to commit to the legal rights generally respect the observe the legal created explicitly or legal rights created rights created established by custom of explicitly or explicitly or people dependent on fishing established by established by for food and livelihood in a custom of people custom of people manner consistent with the dependent on fishing dependent on fishing objectives of MSC Principles
for food or livelihood for food or livelihood 1 and 2. in a manner in a manner consistent with the consistent with the objectives of MSC objectives of MSC
Guidepost Principles 1 and 2. Principles 1 and 2. Met? (Y/N) Y (Y/N) Y (Y/N) Y 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. 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
n 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
Justificatio measures under the MSA. 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 2014 [CDQ]). The CDQ Program allocates 10.7% of the TAC (except for pollock and sablefish) for each directed groundfish fishery pursuant to Section 305(i)(1)(B) of the Magnuson-Stevens Act. Therefore, the BSAI Alaska pollock fisheries meet the requirements of SG60, SG80, and SG100.
CCC. 2012. Council Coordination Committee. 2012 Minutes of the Meeting Issenberg, A. 2013. Fisheries Litigation Update. Presentation of NOAA References General Counsel to Council Coordinating Committee Meeting February 21, 2013. MSA. 2007. Public Law 94-265 as amended by the Magnuson-Stevens Fishery Conservation and Management Reauthorization Act (P.L.
BSAI Alaska Pollock – Final Report and Determination page 166 The management system exists within an appropriate legal and/or customary framework which ensures that it: Is capable of delivering sustainable fisheries in accordance with MSC PI 3.1.1 Principles 1 and 2; and 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.
109-479). An Act to provide for the conservation and management of the fisheries, and for other purposes. As amended through January 12, 2007 NOAA. 2013. NOAA Procedures for Government-to-Government Consultation with Federally Recognized Indian Tribes and Alaska Native Corporations. NOAA 13175 Policy. NPFMC. 2014. Community Development Quota Program. North Pacific Fishery Management Council, Anchorage AK. Schiffer, S. J. 2012. National Oceanic and Atmospheric Administration Guidelines for compiling an Agency Administrative Record. Memorandum from Lois J. Schiffer, General Counsel. OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 167
Evaluation Table for PI 3.1.2
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 a Organisations and Organisations and Organisations and individuals involved individuals involved individuals involved in the in the management in the management management process have process have been process have been been identified. Functions, identified. Functions, identified. Functions, roles and responsibilities are roles and roles and explicitly defined and well responsibilities are responsibilities are understood for all areas of
generally explicitly defined and responsibility and understood. well understood for interaction. key areas of responsibility and
Guidepost interaction. Met? (Y/N) Y (Y/N) Y (Y/N) Y The NPFMC process is the primary means for soliciting stakeholder information important to the Alaska pollock fisheries. Organizations/individuals involved in the management process are identified, including the NPFMC staff, advisory bodies such as the Advisory Panel, Groundfish Plan Team and the Scientific and Statistical Committee, and several ad-hoc committees (NPFMC 2009; 2012).
Functions, roles and responsibilities are explicitly defined and well understood for all areas of responsibility and interaction (NPFMC 2009; 2012). Management measures developed by the NPFMC are recommended to the Secretary of Commerce through the NMFS. 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 (ADFG 2014; OLE 2014; USCG
2014a,b). Additional details provided in Sections 3.5.2 and 3.5.3.
All participants have been well identified, and all functions, roles and responsibilities are explicitly defined and well understood, thereby meeting
Justification the SG60, SG80, and SG100.
BSAI Alaska Pollock – Final Report and Determination page 168 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 b The management The management The management system system includes system includes includes consultation consultation consultation processes that regularly processes that processes that seek and accept relevant obtain relevant regularly seek and information, including local information from the accept relevant knowledge. The main affected information, including management system
parties, including local knowledge. The demonstrates consideration local knowledge, to management system of the information and inform the demonstrates explains how it is used or not management consideration of the used.
Guidepost system. information obtained. Met? (Y/N) Y (Y/N) Y (Y/N) N
The NPFMC process is the primary means for soliciting stakeholder consultation relevant to the Alaska pollock fisheries (NPFMC 2009; 2012). The NPFMC develops a meeting agenda and prepares a briefing book on issues of concern to Fisheries Conservation Zone (FCZ) management. Stakeholders are encouraged to prepare written and oral testimony on these issues. Written testimony submitted before briefing book deadlines is incorporated into the briefing book. Stakeholders can also provide public comment during the council meeting. The draft and final decision documents provide the rationale for decisions made and explanations for alternatives not considered or selected. Further, the management system complies with E.O. 13175 requirements for consultation with Federally-recognized Indian Tribes and Alaska natives (NOAA 2013), including membership on the NPFMC and representatives on the NPFMC Advisory Panel.
The NPFMC’s rural outreach committee met with salmon stakeholders in western Alaska villages, to hear their ideas and concerns, and to incorporate them into the decision documents for minimizing and reducing BSAI salmon bycatch in the BSAI pollock fisheries prior to council action. This was done over a period of 2-3 years, and was a concerted effort by the NPFMC to understand and incorporate both local knowledge and TEK. TEK was incorporated into the Bering Sea Salmon Bycatch Management Measures review document (NPFMC 2015). The team considered that the NPFMC has sought, received, used, and reported on TEK, but used traditional science to a greater degree that TEK for determining the impacts of pollock fishing on western Alaska salmon. Therefore, the process seeks and
accepts information and demonstrates the use of information in decisions, thereby meeting SG60 and SG80,
However, the assessment team did consider that the management system did not explicitly explain how it used or did not use TEK, thereby not meeting SG100.
Justification Additional details provided in Sections 3.5.1, 3.5.2 and 3.5.3. c The consultation The consultation process process provides provides opportunity and
opportunity for all encouragement for all interested and interested and affected affected parties to be parties to be involved, and involved. facilitates their effective
Guidepost engagement. Met? (Y/N) Y (Y/N) Y
BSAI Alaska Pollock – Final Report and Determination page 169 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 The NPFMC process is the primary means for soliciting stakeholder consultation relevant to the Alaska pollock fisheries. The NPFMC develops a meeting agenda and prepares a briefing book on issues of concern to Fisheries Conservation Zone (FCZ) management, including trans-boundary issues. Stakeholders are encouraged to prepare written and oral testimony
on these issues. Written testimony submitted before briefing book deadlines is incorporated into the briefing book. Stakeholders can also provide public comment during the council meeting. The process provides opportunity and encouragement for all interested and affected parties to be involved, and facilitates their effective engagement, thereby meeting SG60, SG80, and
Justification SG100. Additional details provided in Sections 3.5.2 and 3.5.3. ADFG. 2014. Enforcement of Alaska’s Fish and Wildlife Laws. Alaska Department of Fish and Game OLE. 2014. NOAA Office of the General Counsel, Enforcement Section Enforcement Actions July 1, 2013, through December 31, 2013. Office of Law Enforcement-AK Region. 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%20con sultation%20handbook%20111213.pdf NPFMC. 2009. Navigating the North Pacific Council Process. North Pacific Fishery Management Council, Anchorage AK. NPFMC. 2012. Statement of organization, practices, and procedures of the References North Pacific Fishery Management Council (Draft). North Pacific Fishery Management Council, Anchorage AK NPFMC 2015. Bering Sea Salmon Bycatch Management Measures - Public review, March 2015. http://npfmc.legistar.com/gateway.aspx?M=F&ID=1eb8347c-1280- 444e-bd44-0560c64c6b39.pdf USCG. 2014a. Mission: Maritime Stewardship. US Coast Guard USCG. 2014b. 17th Coast Guard District 2013 Year in Review. USCG report to NPFMC. http://www.npfmc.org/committees/rural-outreach-committee/; http://www.npfmc.org/wp- content/PDFdocuments/rural_outreach/RCOCreport911.pdf; https://alaskafisheries.noaa.gov/tc/chinook_bycatch/beringsea- salmon0415.pdf) OVERALL PERFORMANCE INDICATOR SCORE: 95
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 170
Evaluation Table for PI 3.1.3
The management policy has clear long-term objectives to guide decision- PI 3.1.3 making that are consistent with MSC Principles and Criteria, and incorporates the precautionary approach Scoring Issue SG 60 SG 80 SG 100 a Long-term objectives Clear long-term Clear long-term objectives to guide decision- objectives that guide that guide decision-making, making, consistent decision-making, consistent with MSC with the MSC consistent with MSC Principles and Criteria and Principles and Principles and the precautionary approach,
Criteria and the Criteria and the are explicit within and precautionary precautionary required by management approach, are approach are explicit policy. implicit within within management
Guidepost management policy policy. Met? (Y/N/Partial) Y (Y/N/Partial) Y (Y/N/Partial) Y The MSA has established fisheries-management objectives in the form of the 10 National Standard Guidelines (NSG). The NSG are implemented by NMFS under 50 CFR Part 600 subpart D. The NSGs have been interpreted as being consistent with international agreements and criteria for precautionary approaches. Guidelines for implementing the legislation have been translated into scientific and technical guidance for developing limit
and target control reference points for assessing stock abundance reference points, with some suggestions for defaults. The control rules specify management actions (fishing mortality rate), based upon current stock status. (Restrepo and Powers 1999). The NSG provide explicit, precautionary objectives, and have been effectively implemented, thereby
Justification meeting the SG60, SG80, and SG100. 50 CFR Part 600 subpart D MSA. 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 References the fisheries, and for other purposes. As amended through January 12, 2007 Restrepo, V. R. and Powers, J. E.. 1999. Precautionary control rules in US fisheries management: specification and performance. ICES J. Mar. Sci. 56 (6): 846-852. OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 171
Evaluation Table for PI 3.1.4
The management system provides economic and social incentives for PI 3.1.4 sustainable fishing and does not operate with subsidies that contribute to unsustainable fishing Scoring Issue SG 60 SG 80 SG 100 a The management The management The management system system provides for system provides for provides for incentives that incentives that are incentives that are are consistent with achieving consistent with consistent with the outcomes expressed by achieving the achieving the MSC Principles 1 and 2, and outcomes expressed outcomes expressed explicitly considers by MSC Principles 1 by MSC Principles 1 incentives in a regular
and 2. and 2, and seeks to review of management ensure that perverse policy or procedures to incentives do not ensure they do not arise. contribute to unsustainable
Guidepost fishing practices. Met? (Y/N/Partial) Y (Y/N/Partial) Y (Y/N/Partial) Y The management system provides incentives to fishers to fish sustainably, and engender a sense of stewardship of the resources. The management system provides reduced information gaps and uncertainties for fishers with an extensive consultation; strategic or statutory management planning; clear descriptions of roles, rights and responsibilities of the various stakeholders; and an opportunity to participate in management, research and other relevant processes. Proactive incentives result from implementation of Amendment 80, which 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 [GRS was subsequently repealed and replaced with an industry program that currently leads to groundfish retention of approximately 94%]; (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. This provides for incentives that are consistent with achieving the outcomes expressed by MSC Principles 1 and 2, and seeks to ensure that perverse incentives do not arise, meeting the SG60 and SG80. Further, the NPFMC recognizes that encouraging the fishing industry to experiment with voluntary bycatch reduction measures will provide an incentive for the industry to make better use of its bycatch
and thereby catch more groundfish for a given amount of bycatch. As an example, the NPFMC developed incentive plan agreements to keep bycatch lower than the BSAI Chinook cap level. These agreements include explicit incentives and penalties for the pollock fleet to avoid Chinook salmon in all conditions. It is clear that the Council explicitly considers incentives in these
Justification decisions, thereby meeting SG100.
BSAI Alaska Pollock – Final Report and Determination page 172 The management system provides economic and social incentives for PI 3.1.4 sustainable fishing and does not operate with subsidies that contribute to unsustainable fishing NPFMC. 2014. Fishery Management Plan for Groundfish of the Bering Sea- Aleutian Islands. North Pacific Fishery Management Council, Anchorage AK. References NPFMC. 2014. Amendment 80 to the Bering Sea and Aleutian Islands (BSAI) Fishery Management Plan (FMP) http://www.npfmc.org/wp- content/PDFdocuments/bycatch/Bycatchflyer913.pdf OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 173
Evaluation Table for PI 3.2.1
The fishery has clear, specific objectives designed to achieve the outcomes PI 3.2.1 expressed by MSC’s Principles 1 and 2 Scoring Issue SG 60 SG 80 SG 100 Objectives, which Short and long-term Well defined and are broadly objectives, which are measurable short and long- consistent with consistent with term objectives, which are a achieving the achieving the demonstrably consistent with
outcomes expressed outcomes expressed achieving the outcomes by MSC’s Principles by MSC’s Principles expressed by MSC’s 1 and 2, are implicit 1 and 2, are explicit Principles 1 and 2, are within the fishery’s within the fishery’s explicit within the fishery’s
Guidepost management system management system. management system. Met? (Y/N/Partial) Y (Y/N/Partial) Y (Y/N/Partial) Partial 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 Webs; 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, thereby meeting the SG60 and SG80. While the 45 sub- objectives are well-defined and comprehensive, they are not measurable,
Justification so obtain a partial score of SG90. NPFMC. 2014. Fishery Management Plan for Groundfish of the Bering Sea- References Aleutian Islands. North Pacific Fishery Management Council, Anchorage AK. OVERALL PERFORMANCE INDICATOR SCORE: 90
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 174
Evaluation Table for PI 3.2.2
The fishery-specific management system includes effective decision-making processes that result in measures and strategies to achieve the objectives, PI 3.2.2 and has an appropriate approach to actual disputes in the fishery under assessment. Scoring Issue SG 60 SG 80 SG 100 a There are some There are decision-making established decision- processes in place making processes
that result in that result in measures and measures and strategies to achieve strategies to achieve the fishery-specific the fishery-specific
Guidepost objectives. objectives. Met? (Y/N) Y (Y/N) Y 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 NPFMC 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 Bering Sea, Aleutian Islands, and Gulf of Alaska. These decision-making procedures demonstrably result in conservation plans and management that meet MSC outcomes for P1 and P2, thereby meeting
Justification SG60 and SG80. b Decision-making Decision-making Decision-making processes processes respond processes respond to respond to all issues to serious issues serious and other identified in relevant identified in relevant important issues research, monitoring, research, identified in relevant evaluation and consultation, monitoring, research, monitoring, in a transparent, timely and evaluation and evaluation and adaptive manner and take consultation, in a consultation, in a account of the wider transparent, timely transparent, timely implications of decisions.
and adaptive and adaptive manner manner and take and take account of some account of the the wider implications wider implications of of decisions.
Guidepost decisions. Met? (Y/N) Y (Y/N) Y (Y/N) Y
BSAI Alaska Pollock – Final Report and Determination page 175 The fishery-specific management system includes effective decision-making processes that result in measures and strategies to achieve the objectives, PI 3.2.2 and has an appropriate approach to actual disputes in the fishery under assessment. The NPFMC has a comprehensive process for receiving information about the resources under its responsibility. The plan teams provide analyses on the status of stocks and the impacts of fishing; the SSC and AP provide technical and industry-based review of information relevant to the fishery; stakeholders have encouragement and opportunity to submit information to the council. The NPFMC deals with all of the information presented during the decision-making process. Not all issues identified or proposed for actions are accepted by the NPFMC, but the council explicitly deals with
them in a transparent manner. In many cases, the identified issues will undergo staff review to provide a summary to assist decision-making, and the issues could move into full analysis or drop out of consideration. But in all cases the decision is transparently made and based on considering the implications for the stock management. This meets the SG60, SG80, and
Justification SG100. c Decision-making
processes use the precautionary approach and are based on best
Guidepost available information. Met? (Y/N) Y
The decision-making processes use the precautionary approach (Restrepo and Powers (1999); United Nations (1995) and are based on best available information, as mandated in National Standard 2 of the MSA (2007).
Justification d Some information on Information on Formal reporting to all fishery performance fishery performance interested stakeholders and management and management provides comprehensive action is generally action is available on information on fishery available on request request, and performance and to stakeholders. explanations are management actions and provided for any describes how the actions or lack of management system action associated responded to findings and with findings and relevant recommendations relevant emerging from research,
recommendations monitoring, evaluation and emerging from review activity. research, monitoring, evaluation and
Guidepost review activity. Met? (Y/N) Y (Y/N) Y (Y/N) Y
BSAI Alaska Pollock – Final Report and Determination page 176 The fishery-specific management system includes effective decision-making processes that result in measures and strategies to achieve the objectives, PI 3.2.2 and has an appropriate approach to actual disputes in the fishery under assessment. Formal reporting of Council deliberations and actions occur at all stages of the process (NPFMC 2009; 2012). A detailed briefing book provides to all stakeholders all of the information available to the NPFMC members. Draft documents (e.g., stock assessments, plan amendments, environmental assessments, and environmental impact statements) are posted on NPFMC and state and federal agency websites to allow easy access; review periods
typically last at least one month. The NPFMC deliberates and votes in public. Final decisions, including comments from the public and specific responses from the decision-makers, are also posted for easy access. This provides comprehensive, formal reporting of the management system response to relevant findings and information, thereby meeting the SG60,
Justification SG80, and SG100. e Although the The management The management system or management system or fishery is fishery acts proactively to authority or fishery attempting to comply avoid legal disputes or may be subject to in a timely fashion rapidly implements judicial continuing court with judicial decisions decisions arising from legal challenges, it is not arising from any legal challenges. indicating a challenges. disrespect or defiance of the law by repeatedly
violating the same law or regulation necessary for the sustainability for the
Guidepost fishery. Met? (Y/N) Y (Y/N) Y (Y/N) Y
BSAI Alaska Pollock – Final Report and Determination page 177 The fishery-specific management system includes effective decision-making processes that result in measures and strategies to achieve the objectives, PI 3.2.2 and has an appropriate approach to actual disputes in the fishery under assessment. The Office of General Counsel (OGC), which represents NMFS, provides legal advice and counsel for the National Oceanic and Atmospheric Administration (NOAA) of the U.S. Department of Commerce. NOAA OGC has established a formal guideline for maintaining the agency administrative record (Schiffer 2012). While this record serves to increase efficiency of the agency, it also increases the efficiency for any plaintiffs and for the court. This helps lead to a transparent and effective system for resolving legal disputes. NOAA OGC summarized legal issues regarding ACLs, which basically revolved around the need to use the best available science in determining such limits, and noted the need to show the justification for decision making and not to oversimplify the information (CCC 2012). Between the scientific expertise of the Councils and their many committees and advisory bodies and the expertise of NMFS and the review of issues and FMPs, there is a tremendous amount of technical expertise to which the courts will defer if proper documentation supports how conclusions have been arrived. Thus, the agency administrative record becomes an important aspect of justifying decisions and avoiding lawsuits. Further, NOAA and
NMFS consult with plaintiffs and potential plaintiffs to settle disputes. The management system process includes proactive response from the decision-making agencies to legal actions brought against the management system, and strives to prepare decisions in substantive compliance with laws and regulations to minimize the likelihood of lawsuits, thereby reaching
Justification the SG60, SG80, and SG100. CCC. 2012. Council Coordination Committee. 2012 Minutes of the Meeting. MSA. 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. References NPFMC. 2009. Navigating the North Pacific Council Process. North Pacific Fishery Management Council, Anchorage AK. Restrepo, V. R. and Powers, J. E. 1999. Precautionary control rules in US fisheries management: specification and performance. Schiffer, S. J. 2012. National Oceanic and Atmospheric Administration Guidelines for compiling an Agency Administrative Record. Memorandum from Lois J. Schiffer, General Counsel. OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 178
Evaluation Table for PI 3.2.3
Monitoring, control and surveillance mechanisms ensure the fishery’s PI 3.2.3 management measures are enforced and complied with Scoring Issue SG 60 SG 80 SG 100 a Monitoring, control A monitoring, control A comprehensive and surveillance and surveillance monitoring, control and mechanisms exist, system has been surveillance system has are implemented in implemented in the been implemented in the the fishery under fishery under fishery under assessment assessment and assessment and has and has demonstrated a there is a demonstrated an consistent ability to enforce
reasonable ability to enforce relevant management expectation that they relevant measures, strategies and/or are effective. management rules. measures, strategies
Guidepost and/or rules. Met? (Y/N) Y (Y/N) Y (Y/N) Y Under the Federal North Pacific Groundfish Observer Program a comprehensive monitoring, control and surveillance system has been implemented. All Alaska pollock vessels are required to carry observers as requested, and most carry two observers at all times 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 2014), and the US Coast Guard (USCG 2014a). Ability to enforce relevant rules is demonstrated by extensive patrols showing very low violation rates (USCG 2014b; Killary, pers comm 2014). Therefore, comprehensive MCS has been
Justification implemented and shown effective, meeting the SG60, SG80, and SG 100. b Sanctions to deal Sanctions to deal Sanctions to deal with non-
with non-compliance with non-compliance compliance exist, are exist and there is exist, are consistently consistently applied and some evidence that applied and thought demonstrably provide
uidepost they are applied. to provide effective effective deterrence.
G deterrence. Met? (Y/N) Y (Y/N) Y (Y/N) Y 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 Office of General Counsel 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. Sanctions to deal with non-compliance of U.S. rules exist, are consistently applied and demonstrably provide effective
deterrence (NOAA GC 2014). Under MSA, violations are civil, not criminal. Penalties may range from severe monetary fines, boat seizure and/or imprisonment (NMFS 2011c). The low proportion of violations encountered during at-sea or shoreside patrols demonstrates effective deterrence (USCG 2014b; M. Killary, OLE, pers. comm. 2014). Together, these aspects
Justification of MCS meet the SG60, SG80, and SG100.
BSAI Alaska Pollock – Final Report and Determination page 179 Monitoring, control and surveillance mechanisms ensure the fishery’s PI 3.2.3 management measures are enforced and complied with c Fishers are Some evidence There is a high degree of generally thought to exists to demonstrate confidence that fishers comply with the fishers comply with comply with the management system the management management system under for the fishery under system under assessment, including, assessment, assessment, providing information of including, when including, when importance to the effective required, providing required, providing management of the fishery.
information of information of importance to the importance to the effective effective management of the management of the
Guidepost fishery. fishery. Met? (Y/N) Y (Y/N) Y (Y/N) Y
There is a high degree of confidence that fishers comply with the management system under assessment (Killary, M. Pers. comm. 2014), including, providing information of importance to the effective management of the fishery. This is also evident from compliance with the Federal North Pacific Groundfish Observer Program and participation of fishers in the
Justification NPFMC process. d There is no evidence of systematic non- compliance.
Guidepost Met? (Y/N) Y
There is no evidence of systematic non-compliance in North Pacific groundfish fisheries (USCG 2014b; Killary, pers comm 2014). Fisher proactive involvement in the management process is high and rule violation rates are extremely low.
Justification ADFG. 2014. Enforcement of Alaska’s Fish and Wildlife Laws. Alaska Department of Fish and Game. NOAA OGC. 2014a. Policy for the Assessment of Civil Administrative Penalties and Permit Sanctions. NOAA Office of the General Counsel – Enforcement and Litigation References OLE. 2014. NOAA Office of the General Counsel, Enforcement Section Enforcement Actions July 1, 2013, through December 31, 2013. Office of Law Enforcement-AK Region. USCG. 2014a. Mission: Maritime Stewardship. US Coast Guard. USCG. 2014b. 17th Coast Guard District 2013 Year in Review. USCG report to NPFMC. OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 180
Evaluation Table for PI 3.2.4
The fishery has a research plan that addresses the information needs of PI 3.2.4 management Scoring Issue SG 60 SG 80 SG 100 a Research is A research plan A comprehensive research undertaken, as provides the plan provides the required, to achieve management system management system with a the objectives with a strategic coherent and strategic consistent with approach to research approach to research across MSC’s Principles 1 and reliable and P1, P2 and P3, and reliable and 2. timely information and timely information
sufficient to achieve sufficient to achieve the the objectives objectives consistent with consistent with MSC’s Principles 1 and 2. MSC’s Principles 1
Guidepost and 2. Met? (Y/N) Y (Y/N) Y (Y/N) Y The Council Operating Manual (NPFMC 2012) states in item 1 that the council, to comply with MSA requirements, will: Develop, in conjunction with the SSC, multi-year research priorities for fisheries, fisheries interactions, habitats, and other areas of research that are necessary for management purposes, that shall establish priorities for 5-year periods; be updated as necessary; and be submitted to the Secretary and the regional science centers of the National Marine Fisheries Service (NMFS) for their consideration in developing research priorities and budgets for the region of the council. The NPFMC currently has a list of 127 research topics, of which six are considered critical and 54 as high priority (NPFMC 2014). The Pacific States Marine Fisheries Commission has developed a searchable
online listing of the NPFMC research priorities (PSMFC 2014). NMFS undertakes much of the research; the public listing of the research priorities also provide academic and private researchers with a rationale for research proposals that enhances the likelihood of achieving funding. Together, these actions provide a comprehensive research plan with timely and
Justification reliable information, thereby meeting SG60, SG80, and SG100. b Research results are Research results are Research plan and results available to disseminated to all are disseminated to all interested parties. interested parties in a interested parties in a timely timely fashion. fashion and are widely and publicly available.
Guidepost Met? (Y/N) Y (Y/N) Y (Y/N) Y
All research information funded by the US government is publicly available; Alaska-related material is most often on the NPFMC web site. Research plans and results are disseminated by the affected entities (NPFMC 2012; 2014; PSMFC 2014) to all interested parties in a timely fashion and are widely and publicly available, thereby meeting SG60, SG80, and SG100.
Justification NPFMC. 2012. Statement of organization, practices, and procedures of the References North Pacific Fishery Management Council (Draft). North Pacific Fishery Management Council, Anchorage AK. NPFMC. 2014. Research Priorities. North Pacific Fishery Management
BSAI Alaska Pollock – Final Report and Determination page 181 The fishery has a research plan that addresses the information needs of PI 3.2.4 management Council, Anchorage AK. PSMFC. 2014. North Pacific Fishery Management Council: Research Priorities. OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 182
Evaluation Table for PI 3.2.5
There is a system of monitoring and evaluating the performance of the fishery-specific management system against its objectives PI 3.2.5 There is effective and timely review of the fishery-specific management system Scoring Issue SG 60 SG 80 SG 100 a The fishery has in The fishery has in The fishery has in place
place mechanisms place mechanisms to mechanisms to evaluate all to evaluate some evaluate key parts of parts of the management parts of the the management system. management system
Guidepost system. Met? (Y/N) Y (Y/N) Y (Y/N) Y The NPFMC 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 1H (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 NPFMC. Congress reviews the MSA every five years and amends it as necessary. The evaluation of the management system meets the SG60,
Justification SG80, and SG100. b The fishery-specific The fishery-specific The fishery-specific
management system management system management system is is subject to is subject to regular subject to regular internal occasional internal internal and and external review. review. occasional external
Guidepost review. Met? (Y/N) Y (Y/N) Y (Y/N) Y The NPFMC 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 NPFMC Advisory Panel, SSC, public comment, and council member discussions. All NPFMC
recommendations are externally reviewed by NMFS, NOAA, and the Department of Commerce, and NOAA OGC reviews proposed actions to assure compliance with the MSA. Further external review occurs through occasional legal challenges, which refine understanding of requirements under laws and regulations. The regular internal and external review meets
Justification the SG60, SG80, and SG100. NPFMC. 2009 (second edition). Navigating the North Pacific Council Process. North Pacific Fishery Management Council, Anchorage AK. NPFMC. 2012. Statement of organization, practices, and procedures of the References North Pacific Fishery Management Council (Draft). North Pacific Fishery Management Council, Anchorage AK. NPFMC. 2014. Fishery Management Plan for Groundfish of the Bering Sea- Aleutian Islands. North Pacific Fishery Management Council, Anchorage AK.
BSAI Alaska Pollock – Final Report and Determination page 183 There is a system of monitoring and evaluating the performance of the fishery-specific management system against its objectives PI 3.2.5 There is effective and timely review of the fishery-specific management system
OVERALL PERFORMANCE INDICATOR SCORE: 100
CONDITION NUMBER (if relevant):
BSAI Alaska Pollock – Final Report and Determination page 184
Appendix 1.1 Conditions
No conditions raised for this fishery.
BSAI Alaska Pollock – Final Report and Determination page 185 Appendix 2. Peer Review Reports
Peer Review No. 1 Overall Opinion
Has the assessment team arrived at an Yes Conformity Assessment Body appropriate conclusion based on the evidence Response presented in the assessment report? Justification: The assessment team concurs with the comment
Do you think the condition(s) raised are NA Conformity Assessment Body appropriately written to achieve the SG80 Response outcome within the specified timeframe? Justification: The assessment team concurs with the comment
If included: Do you think the client action plan is sufficient NA Conformity Assessment Body to close the conditions raised? Response Justification: The assessment team concurs with the comment
General Comments on the Assessment Report (optional)
BSAI Alaska Pollock – Final Report and Determination page 187 Performance Indicator Review
Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to information and/or rationale raised improve specific scoring issues and any relevant documentation where possible. Please available been used to score this the fishery’s attach additional pages if necessary. used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)
1.1.1 Yes Yes NA See comments The assessment team concurs with the comment
1.1.2 Yes Yes NA See comments The team added a statement in the justification recognizing the greater uncertainty for the AI segment of the stock.
1.1.3 NA NA NA
1.2.1 Yes Yes NA See comments The assessment team concurs with the comment
BSAI Alaska Pollock – Final Report and Determination page 188 Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to information and/or rationale raised improve specific scoring issues and any relevant documentation where possible. Please available been used to score this the fishery’s attach additional pages if necessary. used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)
1.2.2 Yes No NA See comments It is a judgement call how many uncertainties need to be taken into account before one has a “wide range.” The team agrees some plausible uncertainties have not been explicitly considered in the many tests that have been done of the HCR; some of that testing would be called a MSE in most jurisdictions. The HCR has been tested against environmental variability – not every conceivable type of uncertainty, but definitely against the major environmental uncertainties. The HCR has not been tested again varying proportions of the stock sometimes being in the Russian zone but the HCR recognizes that some portion of the stock does occupy the Russian zone. Data show that the proportion in the Russian zone is not a major source of uncertainty. Overall, the team concludes that that the assessment and the HCR take into account a wide range, but not all, uncertainties, thereby reaching the SG100. The score remains unchanged.
1.2.3 Yes Yes NA See comments The assessment team concurs with the comment
BSAI Alaska Pollock – Final Report and Determination page 189 Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to information and/or rationale raised improve specific scoring issues and any relevant documentation where possible. Please available been used to score this the fishery’s attach additional pages if necessary. used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)
1.2.4 Yes Yes NA See comments The assessment team concurs with the comment
2.1.1 Yes Yes NA See comments The assessment team concurs with the comment
2.1.2 Yes Yes NA See comments The assessment team concurs with the comment
2.1.3 Yes Yes NA See comments The assessment team concurs with the comment
2.2.1 Yes Yes NA Since 2011, the impact of the Chinook The assessment team concurs with the bycatch has been estimated to be below 2%. comment The SG100 level is met for prohibited species, but not for group taxa (i.e. jellies) in which species are not individually identified.
2.2.2 Yes Yes NA Hard bycatch caps have been placed on the The assessment team concurs with the bycatch of Chinook salmon. Measures to comment reduce the bycatch of chum salmon are in early stages and thus scoring at the SG100 level is precluded.
BSAI Alaska Pollock – Final Report and Determination page 190 Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to information and/or rationale raised improve specific scoring issues and any relevant documentation where possible. Please available been used to score this the fishery’s attach additional pages if necessary. used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)
2.2.3 Yes Yes NA Observer Program improvements, including The assessment team concurs with the a random sampling design, has increased comment confidence in the strategy to avoid risk to bycatch species. Bycatch accounting for some species is aggregated into species complexes (e.g. jellies) and thus precludes assessments at the individual species level. Therefore, the SG100 level is not met.
2.3.1 Yes Yes NA The SG100 level is not met for SI c. Indirect The assessment team concurs with the effects are difficult to measure and thus comment uncertainty remains regarding indirect effect on some ETP species (i.e., Steller sea lions and Northern fur seals).
2.3.2 Yes Yes NA There is clear evidence that the strategy to The assessment team concurs with the minimize mortalities of ETP species is being comment effectively implemented based on analysis of Observer Program data.
2.3.3 Yes Yes NA Annual Observer Program information The assessment team concurs with the supports the management of fishery impacts comment on ETP species.
BSAI Alaska Pollock – Final Report and Determination page 191 Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to information and/or rationale raised improve specific scoring issues and any relevant documentation where possible. Please available been used to score this the fishery’s attach additional pages if necessary. used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)
2.4.1 Yes Yes NA The Team cites evidence from the EIS for The assessment team concurs with the EFH (NMFS 2005), A NOAA review of EFH comment (NOAA 2010), and a study by Sigler et al (2015) to support the scoring.
2.4.2 Yes Yes NA A strategy is in place to ensure the fishery The assessment team concurs with the does not pose a risk of serious or comment irreversible harm to habitat types, but evidence that the strategy is meeting its objectives is lacking. The Team scored this PI at 95.
2.4.3 Yes Yes NA Relative to the EBS, the distribution of The assessment team concurs with the vulnerable habitats in the AI is less well comment known. Physical impacts of gear on habitat types have not been fully quantified, and changes in habitat distributions over time have not been measured.
2.5.1 Yes Yes Yes Ecosystem analyses indicate that the fishery The assessment team concurs with the is highly unlikely to disrupt the key elements comment underlying ecosystem structure and function to a point where there would be a serious or irreversible harm.
BSAI Alaska Pollock – Final Report and Determination page 192 Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to information and/or rationale raised improve specific scoring issues and any relevant documentation where possible. Please available been used to score this the fishery’s attach additional pages if necessary. used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)
2.5.2 Yes Yes NA Management measures and implemention The assessment team concurs with the demonstrate an effective strategy to restrain comment all main direct and indirect impacts of the fishery on ecosystem structure and function.
2.5.3 Yes Yes NA Information from EFH and ecosystem The assessment team concurs with the modelling studies support the scoring. The comment SG60 and SG80 levels are met. The SG100 level is not met as the long-term ecosystem effects of pelagic trawling for pollock have not been empirically determined in the BSAI.
3.1.1 Yes Yes NA Relevant information was used and the The assessment team concurs with the rationale supports the scoring. comment
3.1.2 Yes Yes NA Relevant information was used and the The assessment team concurs with the rationale supports the scoring comment
3.1.3 Yes Yes NA The NSGs provide explicit, precautionary The assessment team concurs with the objectives, and have been effectively comment implemented.
3.1.4 Yes Yes NA The Team provided examples of incentives, The assessment team concurs with the and the review of incentives by the NPFMC. comment
BSAI Alaska Pollock – Final Report and Determination page 193 Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to information and/or rationale raised improve specific scoring issues and any relevant documentation where possible. Please available been used to score this the fishery’s attach additional pages if necessary. used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)
3.2.1 Yes Yes NA Sub-objectives are not measurable, The assessment team concurs with the precluding scoring at the SG100 level. comment
3.2.2 Yes Yes NA Relevant information was used and the The assessment team concurs with the rationale supports the scoring. comment
3.2.3 Yes Yes NA Relevant information was used and the The assessment team concurs with the rationale supports the scoring. comment
3.2.4 Yes Yes NA MSA requirements mandate preparation and The assessment team concurs with the review of a Research and Data Needs plan. comment
3.2.5 Yes Yes NA Relevant information was used and the The assessment team concurs with the rationale supports the scoring. comment
Any Other Comments
Comments Conformity Assessment Body Response
BSAI Alaska Pollock – Final Report and Determination page 194 BSAI Pollock Peer Reviewer 1Comments on Performance Indicator Review
Performance Indicator 1.1.1. The stock is at a level which maintains high productivity and has a low probability of recruitment overfishing.
Scoring Issue a: Stock Status.
Relevant information was used and the rationale supports scoring at the SG 100 level for Eastern Bering Sea (EBS) Pollock. Greater uncertainty in the Aleutian Islands (AI) (Tier 3) assessment precluded scoring at the SG 100 level.
The Assessment Team (Team) used information obtained from the December 2014 SAFE documents for the EBS (Ianelli et al. 2014) and AI (Barbeaux et al. 2014) regions.
The terms Likely (P >= 70%), Highly Likely (P >= 80%), and High Degree of Certainty (P >=95%) were interpreted by the Team in a manner consistent with CB2.2.1.1, CB2.2.1.2, and CB2.2.1.3, respectively.
In the EBS, reliable estimates of Bmsy are available for this stock, obviating the need for an MSY proxy reference point (e.g. B40%). The estimate of spawning stock biomass (SSB) and associated CV in 2015 (2.85 M mt; CV = 0.14) indicate that the lower 95% confidence limit of the SSB estimate (2.05 M mt) is above the target reference point (Bmsy = 1.95 M mt), and therefore well above the limit reference point (B20% = 1.03 M mt). The 2014 assessment indicated the probability that the current stock size is below 20% of B0 (based on estimation uncertainty alone) is <0.1% for 2014 and 2015 (Ianelli et al. 2014, Fig. 1.31). This is consistent with using the term “Highly Degree of Certainty (i.e. P >= 95%) with respect to fishing not impairing recruitment. This would merit scoring at the SG 100 level; however, the much smaller AI stock component has been assessed with greater uncertainty. For example, in the AI, several-fold differences in year-class strength are poorly related to estimates of SSB. The Team noted that, given the higher uncertainty in AI stock status, the overall (EBS and AI), could not be scored at the SG 100 level. I concur.
Scoring Issue b: Stock Status in Relation to Target Reference Point.
As in Scoring Issue (SI) a (above), relevant information was used and the rationale supports scoring at the SG 100 level for EBS pollock. Greater uncertainty in the Aleutian Islands (Tier 3) assessment precluded scoring at the SG 100 level.
As in SI a, the Team used information obtained from the December 2014 SAFE documents for the EBS (Ianelli et al. 2014) and AI (Barbeaux et al. 2014) regions.
As noted above under SI a, the most recent assessment indicates that stock status in the EBS has been above the target reference point in recent years, with a high degree of certainty. Stock status in the AI is more uncertain. The Team points out that the most recent assessment indicates that current spawning biomass levels have been associated with periods of both high and below average productivity; therefore the Team reasons that the Aleutian Island stock is at a level where it can maintain high productivity when environmental conditions are suitable. This reasoning supports scoring at the SG 80, but not the SG 100 level for AI pollock.
BSAI Alaska Pollock – Final Report and Determination page 195 Performance Indicator 1.1.2 Limit and target reference points are appropriate for the stock.
Scoring Issue a: Appropriateness of reference points
Relevant information was used and the rationale supports the scoring. The limit and target reference points are based on justifiable and reasonable practice. Actual estimates of Bmsy are produced as target reference points for EBS pollock, due to the richness of the historical data. The standard groundfish target reference point proxy (B40%) is used for AI Pollock. The standard groundfish limit reference point (B20%) is used for both stocks. They are appropriately defined and are estimated in the stock assessments for EBS (Ianelli et al. 2014) and AI (Barbeaux et al. 2014), supporting scoring at SG 80.
Scoring Issue b: Level of limit reference point.
Relevant information was used and the rationale supports the scoring.
The team concluded that scoring is justified at the SG 100 level, requiring that: “The limit reference point is set above the level at which there is an appreciable risk of impairing reproductive capacity following consideration of precautionary issues”. The Teams rationale is that the limit reference point was based on simulation studies that accounted for a variety of recruitment scenarios, including those that could be expected to occur under poor environmental conditions.
Scoring Issue c: Level of Target Reference Point
Relevant information was used, and the rationale supports the scoring.
The Team concluded that scoring is warranted at the SG 100 level for EBS, requiring that: “The target reference point is such that the stock is maintained at a level consistent with BMSY or some measure or surrogate with similar intent or outcome, or a higher level, and takes into account relevant precautionary issues such as the ecological role of the stock with a high degree of certainty.” The Team scored the AI stock at the SG 80 level (with no reason given); presumably due to the greater uncertainty of information available for this stock.
Performance Indicator 1.1.3. Where the stock is depleted, there is evidence of stock rebuilding within a specified timeframe.
NA. pollock is not overfished.
Performance Indicator 1.2.1. There is a robust and precautionary harvest strategy in place
Scoring Issue a: Harvest strategy design.
Relevant information was used and the rationale supports the scoring.
The Team notes that the harvest strategy for EBS has been examined in simulations that considered the main sources of uncertainty. Furthermore, the US management practice of setting of OFLs, and smaller ABCs (to account for uncertainties) results in a precautionary harvest strategy.
BSAI Alaska Pollock – Final Report and Determination page 196 Scoring Issue b: Harvest strategy evaluation.
Relevant information was used and the rationale supports the scoring.
The Team reasoned that the harvest strategy for BSAI Pollock was demonstrated to be successful in reducing exploitation during a period in the early-mid 2000s (when recruitments were low due to poor environmental conditions) such that the stock did not fall to a level where recruitment was likely to be impaired by low 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. The Team used this rationale to score at the SG 100 level.
Scoring Issue c: Harvest strategy monitoring.
Relevant information was used and the rationale supports the scoring.
Reliable monitoring is in place, including 1) full at-sea observer coverage, 2) dockside sampling, and 3) fishery independent surveys in both EBS and AI.
Scoring Issue d: Harvest strategy review.
Relevant information was used and the rationale supports the scoring.
The harvest strategy is reviewed or a regular basis internally by NMFS/NPFMC, and has also been reviewed by external peer-reviewers.
Performance Indicator 1.2.2. There are well defined and effective harvest control rules in place.
Scoring Issue a: Harvest control rules design and application.
Relevant information was used and the rationale supports the scoring.
Under the NPFMC system, well defined HCRs are in place for EBS and AI. The HCRs are designed to reduce fishing mortality as the spawning stock biomass declines from the target to the limit reference points.
Scoring Issue b: Harvest control rules account for uncertainty.
Relevant information was used but the rationale does not support the scoring.
The Team scored this issue at the SG 100 level. This would require that the design of the harvest control rules takes into account a wide range of uncertainties. The Team’s rationale does support that the harvest control rule takes into account the main uncertainties, and thus supports scoring at the SG 80 level. Evidence from a Management Strategy Evaluation (MSE), where an explicit and robust examination of uncertainties is conducted, would be an example of accounting for a “wide range” of uncertainties. Such an MSE could incorporate concerns regarding environmental variability, stock overlap with the Russian EEZ, etc.
BSAI Alaska Pollock – Final Report and Determination page 197 Scoring Issue c: Harvest control rules evaluation.
Relevant information was used and the rationale supports the scoring.
The Team scored this issue at the SG 100 level. This requires evidence clearly showing that the tools in use are effective in achieving the exploitation levels required under the harvest control rule. Empirical evidence has demonstrated that the HCR-required exploitation levels were applied effectively during the period of environmentally induced stock weakness in the 2000’s.
Performance Indicator 1.2.3. Relevant information is collected to support the harvest strategy.
Scoring Issue a. Range of information.
Relevant information was used and the rationale supports the scoring.
The Team scored this issue at the SG 100 level. This is appropriate considering the wide and comprehensive amount of information routinely collected on BSAI pollock.
Scoring Issue b. Monitoring.
Relevant information was used and the rationale supports the scoring.
The Team scored this issue at the SG 100 level. Multiple indicators are monitored routinely, with a high degree of certainty.
Scoring Issue c. Comprehensiveness of Information.
Relevant information was used and the rationale supports the scoring.
The Team scored this issue at the SG 80 level. There is high confidence that there is good information on BSAI pollock removals in other Alaska fisheries.
Performance Indicator 1.2.4. There is an adequate assessment of the stock status.
Scoring Issue a: Appropriateness of assessment to stock under consideration.
Relevant information was used and the rationale supports the scoring.
The Team scored this issue at the SG 100 level. As implemented for the EBS stock component, the 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. The modelling platform is a custom model similar to SS3, and is implemented in ADMB. Thus, the assessment is appropriate for the stock and HCR, and takes into account the major features relevant to the species and the nature of the fishery. The Aleutian Islands assessment is conducted with AMAK (cf the NMFS Stock Assessment Toolbox), also implemented in ADMB, and is judged to be appropriate given the available data.
BSAI Alaska Pollock – Final Report and Determination page 198
Scoring Issue b: Assessment approach
Relevant information was used and the rationale supports the scoring.
The assessments estimate stock status relative to reference points for both EBS and AI.
Scoring Issue c: Uncertainty in the assessment.
Relevant information was used and the rationale supports the scoring.
The Team scored this issue at the SG 100 level. For both EBS and AI, the assessments take into account uncertainty and they evaluate stock status relative to reference points in a probabilistic way.
Scoring Issue d: Evaluation of the assessment.
Relevant information was used and the rationale supports the scoring.
The assessment has been tested and shown to be robust. Simulations, sensitivity analyses, and alternate hypotheses have been explored as reported in annual SAFE documents.
Scoring Issue e: Peer Review of the assessment.
Relevant information was used and the rationale supports the scoring.
Annual NMFS/NPFMC reviews are conducted in a structured review process. Also, an external CIE review of the assessment was conducted in 2011.
Performance Indicator 2.1.1. The fishery does not pose a risk of serious or irreversible harm to the retained species and does not hinder recovery of depleted retained species.
Scoring Issues a and b:
Relevant information was used and the rationale supports the scoring. The overall score for the PI was 85.
For SI a, the Team reports that the SG60 and SG80 levels are met. The SG 100 level is met for one of seven minor retained species, meeting the SG80 overall: POP – 80; Atka mackerel – 100; Turbot – 80; Skates – 80; Shark – 80; Sculpin – 80; Squid – 80.
For SI b, the Team reports that target reference points are defined for most, but not all (e.g., skates, squids, sharks, and sculpins) retained species. Of the species >0.5%, the fishery meets the SG100 for three of the seven species, and does not reach SG100 for five, rounded to SG90: POP – 100; Atka mackerel – 100; Turbot – 100; Skates – 80; Shark – 80; Sculpin – 80; Squid – 80.
BSAI Alaska Pollock – Final Report and Determination page 199 Performance Indicator 2.1.2. The fishery does not pose a risk of serious or irreversible harm to the retained species and does not hinder recovery of depleted retained species.
Scoring Issues a, b, c, d, and e:
Relevant information was used and the rationale supports the scoring. The overall score for the PI was 90.
The Team noted that SG 100 is not met as some individual retained species are not assessed.
Performance Indicator 2.1.3. Information on the nature and extent of retained species is adequate to determine the risk posed by the fishery and the effectiveness of the strategy to manage retained species.
Scoring Issues a, b, c, and d:
Relevant information was used and the rationale supports the scoring. The Team assigned an overall score of 90 for this PI.
The Team reports that the SG 60 and SG 80 levels are met for each SI. Skates, sharks, sculpin, and squid did not merit scoring at the SG 100 level.
BSAI Alaska Pollock – Final Report and Determination page 200 Peer Review No. 2
Overall Opinion
Has the assessment team arrived at an Yes/No Conformity Assessment Body appropriate conclusion based on the evidence Response presented in the assessment report? Yes Justification: The assessment team concurs with the comment The assessment team has reviewed the appropriate documentation and developed a sound evidence-based conclusion for each scoring element.
Do you think the condition(s) raised are Yes/No Conformity Assessment Body appropriately written to achieve the SG80 Response outcome within the specified timeframe? NA Justification: The assessment team concurs with the comment
If included: Do you think the client action plan is sufficient Yes/No Conformity Assessment Body to close the conditions raised? Response NA Justification: The assessment team concurs with the comment
General Comments on the Assessment Report (optional)
The report is well written, soundly reasoned and fully documented using existing data and information. Descriptions and explanations are complete, with excellent illustrative use of tables and graphs.
Edits are noted in track changes on the report draft.
BSAI Alaska Pollock – Final Report and Determination page 201
Performance Indicator Review
Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to information and/or rationale raised improve specific scoring issues and any relevant documentation where possible. Please available been used to score this the fishery’s attach additional pages if necessary. used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)
1.1.1 Yes Yes NA The explanation is detailed and well- The assessment team concurs with the documented. The score weighting of EBS comment and AI is justified.
1.1.2 Yes Yes NA The explanations provided under sections The assessment team concurs with the a,b,c, and d are detailed and well- comment documented.
1.1.3 NA NA NA The stocks are not depleted. The assessment team concurs with the comment
1.2.1 Yes Yes NA The explanations provided under sections The assessment team concurs with the a,b,c,d are complete and well-documented. comment
1.2.2 Yes Yes NA The explanations provided under sections The assessment team concurs with the a,b,c,d are clear and well-documented. comment
1.2.3 Yes Yes NA Explanations in sections a,b,and c are The assessment team concurs with the complete and well documented. comment
1.2.4 Yes Yes NA Explanations in sections a,b,c,d and e are The assessment team concurs with the detailed and well documented. comment
BSAI Alaska Pollock – Final Report and Determination page 202 Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to information and/or rationale raised improve specific scoring issues and any relevant documentation where possible. Please available been used to score this the fishery’s attach additional pages if necessary. used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)
2.1.1 Yes Yes NA Explanations in sections a,b,c,d are complete The assessment team concurs with the and documented. Reasons for different comment scores by species are clear.
2.1.2 Yes Yes NA Explanations in sections a,b,c,d,e are The assessment team concurs with the complete and documented. Reasons for comment different scores by species are clear.
2.1.3 Yes Yes NA Explanations in sections a,b,c,d are complete The assessment team concurs with the and documented. Reasons for different comment scores by species are clear.
2.2.1 Yes Yes NA Explanations in sections a,b,c are complete The assessment team concurs with the and documented. Differences in bycatch comment information among species are well explained.
2.2.2 Yes Yes NA Explanations in sections a,b,c,d are complete The assessment team concurs with the and documented. Differences in bycatch comment information among species are well explained.
BSAI Alaska Pollock – Final Report and Determination page 203 Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to information and/or rationale raised improve specific scoring issues and any relevant documentation where possible. Please available been used to score this the fishery’s attach additional pages if necessary. used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)
2.2.3 Yes Yes NA Explanations in sections a,b,c,d are complete The assessment team concurs with the and documented. Differences in bycatch comment information among species are well explained.
2.3.1 Yes Yes NA Explanations in sections a,b,c are complete The assessment team concurs with the and well documented. comment
2.3.2 Yes Yes NA Explanations in sections a,b,c,d are complete The assessment team concurs with the and well documented. comment
2.3.3 Yes Yes NA Explanations in sections a,b,c are complete The assessment team concurs with the and well documented. comment
2.4.1 Yes Yes NA The explanation is detailed and well The assessment team concurs with the documented. comment
2.4.2 Yes Yes NA Explanations in sections a,b,c,d are complete The assessment team concurs with the and well documented. comment
2.4.3 Yes Yes NA Explanations in sections a,b,c are complete The assessment team concurs with the and well documented. Differences between comment BS and AI are well explained.
BSAI Alaska Pollock – Final Report and Determination page 204 Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to information and/or rationale raised improve specific scoring issues and any relevant documentation where possible. Please available been used to score this the fishery’s attach additional pages if necessary. used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)
2.5.1 Yes Yes NA The explanation is complete and well The assessment team concurs with the documented. comment
2.5.2 Yes Yes NA Explanations in sections a,b,c,d are complete The assessment team concurs with the and well documented. comment
2.5.3 Yes Yes NA Explanations in sections a,b,c,d,e are The assessment team concurs with the complete and well documented. comment
3.1.1 Yes Yes NA Explanations in sections a,b,c,d are complete The assessment team concurs with the and well documented. comment
3.1.2 Yes Yes NA Explanations in sections a,b,c are complete The assessment team concurs with the and well documented. comment
3.1.3 Yes Yes NA The explanation is complete and well The assessment team concurs with the documented. comment
3.1.4 Yes Yes NA The explanation is complete and well The assessment team concurs with the documented. comment
3.2.1 Yes Yes NA The explanation is complete and well The assessment team concurs with the documented. comment
BSAI Alaska Pollock – Final Report and Determination page 205 Performance Has all the Does the Will the Justification Conformity Assessment Body Response Indicator relevant information condition(s) Please support your answers by referring to information and/or rationale raised improve specific scoring issues and any relevant documentation where possible. Please available been used to score this the fishery’s attach additional pages if necessary. used to score Indicator support performance to this Indicator? the given score? the SG80 level? (Yes/No) (Yes/No) (Yes/No/NA)
3.2.2 Yes Yes NA Explanations in sections a,b,c,d,e are The assessment team concurs with the complete and well documented. comment
3.2.3 Yes Yes NA Explanations in sections a,b,c,d are complete The assessment team concurs with the and well documented. comment
3.2.4 Yes Yes NA Explanations in sections a,b are complete The assessment team concurs with the and well documented. comment
3.2.5 Yes Yes NA Explanations in sections a,b are complete The assessment team concurs with the and well documented. comment
Any Other Comments
Comments Conformity Assessment Body Response
BSAI Alaska Pollock – Final Report and Determination page 206 Appendix 3. Stakeholder submissions
Appendix 3.1 Site Visit Comments
WWF Comments [See attached PDF]
MRAG Response
The WWF submission provides extensive comments on a wide range of topics. Since the date of the submission, new information has become available. The Assessment Team has considered the WWF comments, and has applied the new information in our comprehensive evaluation of the fishery.
Stock assessment
The Stock assessment shows that the pollock abundance has increased from 2008 to the present, suggesting that any Russian harvest of BSAI pollock should not cause a conservation problem. The Assessment team has thoroughly reviewed the harvest strategy, information, and stock assessment, and has provided our conclusions in the text and in the scoring.
Bycatch
The amounts on non-pollock species caught and discarded represent a very small proportion of the total catch. The Assessment Team has provided extensive review of the salmon bycatch, and concluded that the fishery has no adverse impacts on salmon. Since the date of the WWF submission, enhanced management has occurred for salmon bycatch that further reduces any impacts.
ETP
The assessment team reviewed the decision to close out ETP condition during the fourth surveillance, and found no reason to question that decision.
Habitat
The Assessment Team acknowledges that pelagic trawls contact the bottom some portion of the time. Based on the NPFMC review of essential fish habitat, and more recently the NMFS evaluations of pollock trawl impacts in Bering Sea canyons, the Assessment Team concluded that the fishery has no serious adverse impacts, with sufficient management and information to support the conclusion.
Ecosystem
WWF acknowledges the passing status of the ecosystem performance indicators.
Governance and policy
WWF acknowledges the high level of management and governance of the NPFMC-NMFS system, but points out concerns for the implementation of EO13175 and the recognition of
BSAI Alaska Pollock – Final Report and Determination page 207 Native Alaskan rights. The Assessment Team has thoroughly reviewed NMFS and Council actions in conducting our evaluation and concluded that recognition exists at a high level.
Consultation
WWF points out concerns that Native Alaskans have not had an opportunity to present information. The Assessment Team has thoroughly reviewed NMFS and Council actions in conducting our evaluation, and concluded that consultation exists at a high level.
BSAI Alaska Pollock – Final Report and Determination page 208 Western Alaska Communities Comments
[See attached PDF]
MRAG Response The Western Alaska Communities submission provides extensive comments on salmon status and bycatch in the Bering Sea. Since the date of the submission, new information has become available. The Assessment Team has considered the Western Alaska Communities comments, and has applied the new information regarding science and management. The Assessment Team has provided extensive review of the salmon bycatch, and concluded that the fishery has no adverse impacts on salmon.
BSAI Alaska Pollock – Final Report and Determination page 209 Appendix 3.2 PCDR Comments
The assessment team received comments from Greenpeace, WWF, and MSC. The team prepared a single response to the Greenpeace and WWF comments, given the similarities of the comments.
BSAI Alaska Pollock – Final Report and Determination page 210
1661 Mission Street, San Francisco, CA 94103
Tel: 415-255-9221 • Fax: 415-255-9201
November 20, 2015
Robert J. Trumble, Ph.D. Vice President-Fisheries MRAG Americas, Inc. 10051 5th St. N, Suite 105 St. Petersburg FL 33702
RE: Greenpeace comments on Public Comment Draft Report for Alaska Pollock - Bering Sea, AI
Sent Via email to [email protected]
Dear Mr. Trumble,
Thank you for the opportunity to submit comments on the MSC Public Comment Draft Report for Alaska Pollock - Bering Sea, Aleutian Islands. We are concerned that draft scores on relevant habitat performance indicators do not accurately reflect the threat posed by the pollock fishery to vulnerable marine ecosystems in Alaska. Why, for instance, would the fishery’s scores on habitat performance indicators increase now that there is more data and analysis available confirming the presence of vulnerable living habitats in the area where the fishery is operating than there was in the previous assessment?
We present the following information to provide a rationale and evidence to support the opinion that more action is needed for the pollock industry to be considered sustainable and achieve the scores currently assigned. These comments focus primarily on the coral and sponge habitat in the Bering Sea, but also where similar habitat occurs in the Aleutian Islands, where the pollock fishery operates, these comments should be considered in your assessment of Performance Indicators 2.4.1, 2.4.2, and 2.4.3.
In line with international best practice, the Marine Stewardship Council (MSC) has recognized that vulnerable marine ecosystems, including corals and sponge fields, should be adequately protected from fishing impacts. This concept serves as the basis for new requirements for habitat protection issued by the MSC in October 2014. One of the primary goals of the MSA is to protect valuable marine habitat based on the best available scientific information. As currently fished pollock trawls are a threat to coral, sponge and sea whip habitat.
Habitat at risk
Deep-sea corals are fragile, slow-growing and long-lived species that provide invaluable ecosystem services.1 Coral and sponge communities provide essential habitat for numerous species, including many that are commercially-important and many other species that do not have
1 Stump, K., Pribilof and Zhemchug Canyon Habitat Conservation Areas: An Updated Review with Implications for Management, White Paper submitted to the Council (March 20, 2012) at 15 1 commercial value, but play integral roles in ecosystem function. Coral and sponge habitats are particularly important for juvenile fish, and provide places for fish and invertebrates to spawn and lay their eggs.2 Deep-sea corals and sponges are often long-lived, extremely slow to recover, and highly vulnerable to bottom tending fishing gear.3 Recovery times for deep-sea corals disturbed by fishing activities can be 50 to 100 years or longer, if they recover at all, making it virtually impossible to replace the lost value to the ecosystem.4
Over the past decade, our understanding of the distribution, ecology, and importance of deep-sea coral and sponge ecosystems has increased greatly as a result of field exploration and predictive habitat modeling efforts in numerous regions. While we still have much to learn about the intricacies of ecosystem functions in deep-sea canyons, and relationships between benthic and pelagic species, we should take a precautionary management approach that can ensure the integrity of these productive ecosystems upon which we all depend. We contend, for the pollock fishery to be widely considered sustainable they must ensure that they are not adversely impacting vulnerable marine ecosystems such as the coral and sponge habitat in the Bering Sea.
The Bering Sea Canyons and Green Belt
Surveys and analyses that the National Marine Fisheries Service (NMFS) and others have completed in the last year have strengthened the understanding that Pribilof and Zhemchug canyons, as well as slope areas adjacent to those canyons contain a substantial amount of the coral and sponge habitat that is located along the shelf-break (known as the Green Belt), and that the habitat is being threatened by fishing activity.
Pribilof and Zhemchug canyons, and slope areas adjacent to both, contain a diverse amount of deep-sea corals, sea whips, and sponges.5 The best scientific information demonstrates the canyons also serve as important spawning, nursery, and foraging habitat for many species.6 The Council has identified EFH in the canyons for a number of commercially-managed species, including king crab species, tanner crab species, and most species of groundfish, notably pollock, Pacific cod, and rockfish species.7 Coral is also identified as EFH for both yelloweye rockfish and golden king crab.8 The canyons contain several habitat areas of particular concern that support documented skate egg nurseries.9 Although the NPFMC has identified large amounts of EFH as well as habitat areas of particular concern both in the canyons and along the Green Belt, the Council has not yet set aside any areas located in the Green Belt for protection.
2 Id. at 5-6. 3 Id. at 15-20; see also Deep Sea Corals Amendment to the Atlantic Mackerel, Squid, and Butterfish Fishery Management Plan: Measures to Protect Deep Sea Corals from Impacts of Fishing Gear, prepared by the Mid- Atlantic Fishery Management Council in cooperation with NOAA Fisheries, revised as of May 27, 2015 (hereinafter Draft Deep Sea Corals Amendment), at Appendix C (provides a review of research studies demonstrating the vulnerability of corals to fishing gear impacts). 4 See NOAA Strategic Plan at 5. 5 Id. at 8; Miller, J. et al., Structure-Forming Corals and Sponges and Their Use as Fish Habitat in Bering Sea Submarine Canyons. PLoS ONE 7(3): e33885 (March 2012). 6 Stump 2012 at 7. 7 See Council, Fishery Management Plan for Groundfish of the Bering Sea and Aleutian Islands Management Area (August 2015) (hereinafter BSAI Groundfish FMP), at Appendix E; Council, Fishery Management Plan for Bering Sea/Aleutian Islands King and Tanner Crabs (October 2011) (hereinafter BSAI Crab FMP), at App. D.3; 135-137. 8 BSAI Groundfish FMP at 92; BSAI Crab FMP at 136-37. 9 Council, EA/RIR/IRFA for Areas of Skate Egg Concentrations (March 2012). 2
To protect valuable benthic habitat along the Bering Sea slope, sponges must also be considered as well as corals. Recent surveys, publications and reports evaluating deep-sea habitat along the Green Belt have included vulnerable sponge habitat as part of the analysis.10 Sponges and corals play similar roles in the Bering Sea ecosystem. They both are slow-growing, long-lived, structure-forming invertebrates that provide habitat and are highly vulnerable to fishing impacts. The value of sponge habitat is reflected in the primary goal of the National Oceanic and Atmospheric Administration (NOAA) Strategic Plan for Deep-Sea Coral and Sponge Ecosystems (released in 2010): to "improve the understanding, conservation, and management of deep-sea coral and sponge ecosystems."11
Zhemchug Canyon stands out in recent studies as an area containing rich sponge habitats. NMFS models show moderate to high probability of sponge habitat in Zhemchug Canyon.12 The NMFS models do not include coral and sponge records obtained from independent submersible expeditions in Zhemchug canyon13 which could have resulted in an underestimation of predicted coral and sponge habitat in the canyon and/or lower probabilities. In addition, 17 percent of Zhemchug canyon is considered too steep and bumpy for a trawl survey, so was not included in NMFS models.14 Miller et al. (2015) predicted moderate to high habitat suitability for gorgonian corals throughout Zhemchug canyon.15
Evidence Demonstrating the Need for Protections in and near Pribilof and Zhemchug Canyons
In the last year, new evidence has emerged that strengthens our understanding of the habitat in Pribilof and Zhemchug canyons, and indicates the need to protect coral and sponge habitat in both canyons and in slope areas adjacent to these canyons which contain known occurrences and/or predicted habitat. The NMFS and others completed surveys which confirm that Pribilof and Zhemchug canyons are hotspots for coral and sponge species. A study conducted by the NMFS found that Pribilof Canyon and the adjacent slope supports as much as 85 percent of predicted coral habitat on the entire Bering Sea slope.16 Another report from the NMFS, based on a 2014 survey, showed that coral densities were higher in Pribilof Canyon than any other areas along the Green Belt and densities of sponges were high in both canyons.17 Modeling analysis conducted by Miller et al. (2015) found that Pribilof Canyon contained over half of high-quality habitat for
10 See infra; see also Sigler, M.F., et al., Are Bering Sea canyons unique habitats within the eastern Bering Sea?, Draft White Paper submitted to the Council (June 2013); Sigler, et al., Faunal features of submarine canyons on the eastern Bering Sea slope, Marine Ecology Progress Series 526: 21-40 (2015); Draft NMFS response to Council on Agenda Item C-7 from June, 2013 meeting (Aug. 27, 2013). 11 National Oceanic and Atmospheric Administration, Coral Reef Conservation Program, NOAA Strategic Plan for Deep-Sea Coral and Sponge Ecosystems: Research, Management, and International Cooperation. Silver Spring, MD: NOAA Coral Reef Conservation Program. NOAA Technical Memorandum CRCP 11 (2010) (hereinafter NOAA Strategic Plan), at 6. 12 See, e.g., Rooper, C. et al., Validation of models of the distribution of structure-forming invertebrates in the eastern Bering Sea using an underwater stereo camera (October 2015). 13 See, e.g., Miller, R.J., C. Juska, & J. Hocevar, Submarine canyons as coral and sponge habitat on the eastern Bering Sea slope, Global Ecology and Conservation 4: 85-94 (2015). 14 Sigler, M.F., et al., Are Bering Sea canyons unique habitats within the eastern Bering Sea?, Draft White Paper submitted to the Council (June 2013), at 24. 15 Id. 16 Sigler, M. F., et al., Faunal features of submarine canyons on the eastern Bering Sea slope, Marine Ecology Progress Series, Vol. 526: 21-40 (April 22, 2015), at 35. 17 Rooper 2015 at 26. 3 gorgonian corals and nearly half of high quality habitat for sponges, even though the entire canyon only represented 1.7 percent of the study area.18
The recent studies also confirm that commercially-managed species have significant positive associations with the coral and sponge habitat located in the canyons. The 2014 survey conducted by the NMFS reported that coral and sponge in the canyons have significant positive associations with both rockfish species and king crabs.19 According to the analysis completed by Miller et al. (2015), Pribilof Canyon provides abundant high-quality habitat for Pacific ocean perch in the form of structure-forming gorgonian corals and sponges.20
Evidence of gear impacts
Evidence demonstrates that fishing in Pribilof and Zhemchug canyons is causing adverse effects for benthic habitats, including corals, sea whips, and sponges. Bottom trawling, pelagic trawling, and longlining have occurred in both Pribilof and Zhemchug canyons for decades and have likely considerably altered the landscape and ecosystem there already, a fact that should be considered when evaluating the seriousness or long-term effects of fishing. A GOA study on the effects of a single pass of a commercial trawl on benthic habitat showed damage to 14-67% of large sessile epifauna and significantly higher densities of organisms in unfished reference sites. 21 Heavy trawling has been shown to result in a patchier and less structured habitat with lower diversity of sedentary organisms.22 Bottom trawling also reduces the mean body size of seafloor invertebrates.23 In temperate systems such as the Bering Sea the broader ecosystem consequences associated with habitat degradation are still poorly understood, and cannot be inferred from simply looking at the effects of a trawling on habitat.24
Although both fixed gear and trawling can affect benthic species, trawling is likely the greatest threat to coral and sponge habitat in the canyons.25 Current trawling in the canyons includes both bottom trawls and pelagic trawls. The pollock fishery primarily utilizes pelagic trawl nets, and the National Marine Fisheries Service has estimated that at least 44 percent of pelagic trawling efforts make contact with the ocean floor.26 This 44% figure, though, is not derived from scientific studies but is based on anecdotal information provided by the pollock industry. Other anecdotal estimates of the pollock gear contact with the bottom have been as high as 85 percent.
18 Miller 2015 at 89. 19 Rooper 2015 at 47. 20 Miller 2015 at 90. 21 Meuter, F. (2004) “A review of the impacts of fishing gear on seafloor habitat and benthic communities as summariezed in the draft Alaska groundfish fisheries Programmatic Supplemental Environmental Impact Statement prepared for the Marine Conservation Alliance.” Groundfish Forum. Retrieved from http://groundfishforum.org/a-review-of-the-impacts-of-fishing-gear-on-sea-floor-habitat-and-benthic- communities-as-summarized-in-the-draft-alaska-groundfish-fisheries-programmatic-supplemental- environmental-impact-statement-pre, at 2. 22 McConnaughey, et al., An examination of chronic trawling effects on soft-bottom benthos of the eastern Bering Sea. ICES Journal of Marine Science 57: 1377-1388 (2000). 23 McConnaughey, et al., Effects of chronic bottom trawling on the size structure of soft-bottom benthic invertebrates, American Fisheries Society Symposium 41: 425-437 (2005). 24 Meuter 2004 at 4-8
25 Stump 2012 at 16-17. 26 National Marine Fisheries Service, Final Environmental Impact Statement for EFH Identification and Conservation in Alaska, Appendix B, Evaluation of Fishing Activities that may Adversely Affect EFH (April 2005) (hereinafter EFH EIS), at Table B.2-4. 4
According to the paper “Trawl Effects on the Bering Sea Habitat” available on the industry group Marine Conservation Association website at https://drive.google.com/drive/u/0/folders/0ByVEvk-6Dsi6UDNfZnV0OGlDS00: “Pelagic trawl gear used by the pollock fishery also impacts seafloor habitat. In use, this gear is not truly pelagic as there is contact of the gear with the seafloor. Estimates of the amount of time a pelagic trawl contacts the seafloor in practice were provided by fishing organizations and used by NMFS in the EFH fishing effects model (EFH EIS Appendix B, Pg. B-11). Pelagic trawls are estimated to contact the seafloor across some substrates for 44% of the duration of a tow (Final EFH EIS, Appendix B, Table B.2-4). Pelagic trawl footropes are made of steel chain or cable. Regardless of the actual percentage of time spent on the sea floor, it is clear that a moving footrope in contact with the seafloor impacts habitat, and is particularly damaging for animals anchored on or in the sediment (NFMS, Final EFH EIS, pg. 3-166). In addition, the codend of the net can also contact the seafloor. The central estimates of impact to benthic features when this gear hits bottom are 21% reduction for infaunal prey, 16.5% reduction of epifaunal prey, 20% reduction of living structure and 20% reduction of non-living structure.”
The MCA review further discusses the impact of trawling in the Bering Sea: “Habitat-wide effects are apparent in the results of the Long-Term Effects Index, which indicates that status quo management will result in long-term reductions of benthic habitat features in the Bering Sea (NFMS, Final EFH EIS, Appendix B). Most striking in the Bering Sea is a 3-19% reduction in soft substrate living structure in across all sand/mud habitat in the Bering Sea. Habitat-wide impacts that overlap with individual species distributions are also extensive. These include:
• a 35% reduction in Bering Sea sand/mud living structure estimated to provide 25-30% of red king crab habitat
• a 15-20% reduction of living structure in Bering Sea sand/mud estimated to provide 71- 68% of tanner crab habitat
• a 12-14% reduction in Bering Sea sand/mud living structure estimated to provide 56-65% of Greenland turbot habitat
• a 13-15% reduction of living structure in Bering Sea sand/mud estimated to provide 37- 41% of rock sole habitat
However dire these predictions may seem, these effects are calculated over huge areas of habitat, which lessens the overall percentages of reduction of habitat features. If effects are examined more closely on a spatial scale, localized impacts are apparent and disconcerting. The habitat impacts model predicts that some areas that are trawled will become completely devoid of living structure if the current level of trawling continues.”
Pollock trawls have greater overall impact on the living biostructure of the Bering Sea shelf than the bottom trawl fishery and a greater impact on the Bering Sea slope than all other bottom trawl fisheries combined.27
One scour of a pelagic net across seafloor can quickly destroy fragile coral and sponge habitat hundreds of years in the making. The seafloor area impacted by a pelagic trawl (estimated at 136 meters (446 feet) wide for vessels over 125 ft length) would essentially all be affected by the footrope of the trawl net which is generally a bare chain or cable, with some additional contact coming from weight clumps. While the pollock fleet has taken a relatively small percentage of their
27 See EFH EIS at B-22. 5 overall catch from Pribilof and Zhemchug canyons over the past decade that is no guarantee that they have not, and will not in the future, adversely impact vulnerable habitat. The testimony of pollock industry representatives to the NPFMC has been that while they may not fish much in the canyon areas now, they want to reserve the right to do so in the future.
Data verifies fishing impacts
Visual surveys conducted by Greenpeace provide photographic evidence of fishing damage to corals, sea whips, and sponges in both canyons.28 In a 2007 survey, Greenpeace noted evidence of fishing disturbance on 13 occasions, including trawl scars in the area, toppled corals, and fishing gear tangled around coral.29 In a later survey, conducted in 2012, Greenpeace reported 79 observations of fishing damage. The 2014 visual survey conducted by NMFS also reported fishing damage. It found either evidence of fishing gear or damage to benthic invertebrates in 37 percent of transects.30 Out of those observations, the survey reported damage to sea whips in 24 percent of transects, damage to coral in 1 percent of transects, and damage to sponges in 3 percent of transects. It reported evidence of fishing in 13 percent of transects, including evidence of fishing gear and trawl tracks.31 The study noted that it is often difficult to quantify damage to benthic organisms like corals and sponges because the species have amorphous body shapes, so damage may be underreported.32 Species like sea whips display damage more prominently and that may be the reason scientists most often reported damage to that species during the survey.33
Observer-reported bycatch indicates that benthic fauna, including corals and sponges, is regularly hauled up with trawl gear in Pribilof and Zhemchug canyons. 34 Many benthic organisms drop out of the large mesh panels in the pelagic nets before they are hauled up, so observer reports likely underestimate the amount of interaction between fishing nets, corals, and sponges.35 Additionally, there is plenty of evidence that the pollock fishery operates at depths where coral and sponge habitat occurs. For example this NOAA news release documents pollock fishing in Pribilof Canyon at depths considerably deeper than most coral records documented in the region: https://alaskafisheries.noaa.gov/newsreleases/2007/rockfish040507.htm
In 2010, NOAA published a strategic plan to focus research and management on protecting deep-sea coral and sponge ecosystems.36 The first two conservation and management objectives in that plan clearly identify sustainable fishing practices in the presence of valuable coral and sponge habitat:
1. Protect areas containing known deep-sea coral and sponge communities from impacts of bottom-tending fishing gear.
28 Miller 2012 at 2. 29 Id at 4. 30 Rooper 2015 at 47. 31 Id. at Table 8. 32 Id at 43. 33 Id. 34 Pribilof and Zhemchug canyons: fishing activity, protection measures and process for future action, Council staff discussion paper (May 2013), at Figures 12-20. 35 Bering Sea/Aleutian Islands Fishery Management Plan for Groundfish (2015), at Appendix F, F-7. 36 NOAA Strategic Plan 2010; see also NOAA Fisheries, Deep Sea Coral Research & Technology 2014 Report to Congress. 6
2. Protect areas that may support deep-sea coral and sponge communities where mobile bottom-tending fishing gear has not been used recently, as a precautionary measure.37 The plan states, “In general, it is expected that the implementation of Objectives 1 and 2 will involve, but not be limited to, area closures to specific bottom-tending fishing gears likely to damage, or result in bycatch of, deep-sea corals or sponges in order to protect these resources within such areas.”38
Fishing is Having Adverse Effects on EFH in the Canyons
Under the MSA implementing regulations, NMFS has defined an “adverse effect” to mean “any impact which reduces the quality and/or quantity” of EFH, which can include “direct or indirect physical, chemical, or biological alterations of the waters or substrate and loss of, or injury to, benthic organisms, prey species and their habitat, and other ecosystem components.”39 In these canyons, as discussed above, evidence indicates that fishing is causing physical alterations to the benthic habitat by damaging corals, sea whips, and sponges that reside there. As a result, fishing reduces both the quantity and quality of habitat in the canyons, thereby causing an adverse effect.
The Adverse Effects from Fishing in the Canyons is Not Temporary
Under the MSA implementing regulations, “Councils must act to prevent, mitigate, or minimize any adverse effects from fishing, to the extent practicable, if there is evidence that a fishing activity adversely affects EFH in a manner that is more than minimal and not temporary in nature.”40 The terms “minimal” and “temporary” are not defined in the relevant regulations. However, the preamble to the EFH final rule states:
Temporary impacts are those that are limited in duration and that allow the particular environment to recover without measureable impact. Minimal impacts are those that may result in relatively small changes in the affected environment and insignificant changes in ecological functions.41
The best scientific information available demonstrates that the adverse effects from fishing in the canyons and on other Bering Sea coral and sponge habitat is far more than temporary. In its 2005 environmental impact statement related to EFH, the Council, together with NMFS, evaluated whether fishing was causing adverse effects in any EFH.42 That environmental analysis determined that trawling on coral and sponge habitat has long-term effects that are more than temporary.43 Numerous studies have also demonstrated that damage to coral, sea whips, and sponges from
37 NOAA Strategic Plan 2010 at 6. 38 Id. at 30. 39 50 C.F.R. § 600.810(a). Adverse effects may result from actions occurring within the habitat or outside of the habitat and may include “site-specific or habitat-wide impacts, including individual, cumulative, or synergistic consequences of actions.” 40 50 C.F.R. § 600.815(a)(2)(ii). 41 67 Fed. Reg. 2343-07, 2354 (Jan. 17, 2002). 42 EFH EIS. 43 Id. at B-15 through B-25, Table B.2-5; Record of Decision, at 10-11; see also Bering Sea/Aleutian Islands Groundfish Fishery Management Plan (2015), Appendix F, at F-11; F-5, F-7, F-8, F-10. 7 fishing gear has lasting impacts on those species from which the species cannot easily recover.44 Thus, the current damage from fishing is causing adverse effects that are not temporary.
The Adverse Effects from Fishing in the Canyons is More Than Minimal
Damage from fishing to habitat in the canyons is also more than minimal. In the past, the Council and NMFS have evaluated whether adverse impacts on EFH are more than minimal by focusing on the effects on commercially-managed species rather than effects on the habitat directly. The 2005 environmental analysis concluded that impacts from fishing were not more than minimal. It noted that NMFS’s interpretation of the term “necessary” in terms of EFH limits it to only habitat that is necessary for a managed species to support a sustainable fishery and the managed species’ contribution to a healthy ecosystem.45 As a result, the analysis concluded that fishery effects must limit the welfare of a managed species in order to result in “adverse effects,” rather than causing impacts to habitat on a local scale,46 and focused on whether impacts were affecting the ability of any species to meet and sustain its maximum sustainable yield.47 At that time, NMFS and Council concluded that the best available information did not indicate that the current rate and intensity of fishing would limit the capacity of EFH to support healthy populations of managed species over the long-term.48
Focusing on the long-term yield of a managed stock to determine whether fishing is having an adverse effect is not consistent with the requirements of the MSA. The definition of EFH includes all habitat “necessary to fish for spawning, breeding, feeding and growth to maturity.”49 Under the plain language of the MSA, if fishing is causing adverse effects on habitat that supports important life functions of fish species, the Council and NMFS must act to minimize that effect to the extent practicable.50 Further, the EFH requirements of the MSA direct the Council and NMFS to not only protect EFH, but also find ways to encourage the conservation and enhancement of the habitat.51 The Council cannot wait until changes to the stock of a managed species occur before taking action to minimize adverse effects in the canyons. When finalizing regulations related to EFH, NMFS cautioned:
It is not appropriate to require definitive proof of a link between fishing impacts to EFH and reduced stock productivity before Councils can take action to minimize adverse fishing impacts to EFH to the extent practicable. Such a requirement would raise the threshold for action above that set by the Magnuson-Stevens Act. The final rule encourages Councils to use the best available science as well as other appropriate information sources when evaluating
44 Stump 2012 at 18-20; NOAA Strategic Plan at 5. 45 EFH EIS at B-26. 46 Id. 47 Id. at B-3; see also Bering Sea/Aleutian Islands Groundifsh Fishery Management Plan (2015), Appendix F, at F-12. 48 EFH EIS, Record of Decision, at 10-11; see also Bering Sea/Aleutian Islands Groundifsh Fishery Management Plan (2015), Appendix F, at F-26. In terms of rockfish, the evaluation did recognize that much was unknown about many species’ dependence on benthic habitat and how impacts to that habitat may affect certain species on smaller spatial scales. See, e.g., EFH EIS at B-95. 49 16 U.S.C. § 1802(10). 50 Id. §§ 1802(10); 1853(a)(7). 51 Id. 8
the impacts of fishing activities on EFH, and to consider different types of information according to its scientific rigor.52
Best available evidence demonstrates that fishing is having adverse effects on EFH in the canyons that are more than minimal. Visual surveys and observer reports described above have demonstrated that fishing is causing damage to corals and sponges in these areas and that corals and sponges are regularly being removed from these canyons as bycatch. It is likely that fishing damage is much more extensive than has been documented so far due to the difficulties of identifying damage to these benthic species. The best available evidence demonstrates that there is a significant association between managed species, including rockfish and crab species, and the coral and sponge habitat located in the canyons. All of the recent surveys confirm that these canyons contain some of the highest densities of coral and sponge habitat found in the entire Green Belt. Pribilof Canyon alone contains over half of the highest-quality coral habitat in the entire Green Belt and as much as 70 percent of high-quality habitat for some species of coral.53 As a result, the best available evidence demonstrates that fishing is causing potentially large and significant changes to coral and sponge habitat and ecological functions in Pribilof and Zhemchug canyons that are more than minimal.
In conclusion, we request that all the information and evidence in these comments be fully considered and addressed, especially where they contradict justifications provided for the current scores on all habitat performance indicators, in your draft assessment of the Alaska pollock fishery’s effect on habitat.
Thank you for you consideration of these comments.
Sincerely,
Jackie Dragon Greenpeace
52 67 Fed. Reg. 2343, 2354 (Jan. 17, 2002). 53 Miller 2015 at 90. 9
World Wildlife Fund Arctic Field Office 406 G. Street, Suite 303 Anchorage, AK 99501 USA
Tel: (907) 279-5504 Fax: (907) 279-5509
www.worldwildlife.org November 20, 2015
Robert J. Trumble, Ph.D. Vice President MRAG Americas, Inc. 10051 5th St. N, Suite 105 St. Petersburg FL 33702 USA
Dear Dr. Trumble,
WWF appreciates the opportunity to submit comments on the final Public Comment Draft Report for the Bering Sea -Aleutian Islands (BSAI) pollock fishery to MRAG Americas, Inc. WWF has participated as an active stakeholder in the MSC assessment process for the BSAI pollock fishery since the first assessment. We have presented detailed documentation on improvements that we believe are necessary for the fishery to fully meet the MSC requirements.
In the opinion of WWF, the current assessment did not appropriately or adequately address WWF’s stakeholder comments on the target stock (MSC Principle 1), bycatch, habitat, and ecosystem impacts (MSC Principle 2), and the fishery management system (MSC Principle 3) which we outlined in a 25+ page letter in 2014 and in a stakeholder meeting with your assessment team.
Below we reiterate and update our comments in order to provide input for the public record that some performance indicators for this fishery were not scored correctly.
Respectfully,
Ms. Heather Brandon Dr. Annika Mackensen Senior Fisheries Officer Fisheries Certification and Livelihoods Manager World Wildlife Fund, Arctic Field Office World Wildlife Fund, Smart Fishing Initiative
1.1.1 Stock status PI: The stock is at a level which maintains high productivity and has a low probability of recruitment overfishing.
The assessment team should have considered fishing pressure and uncertainties on the spawning stock biomass.
WWF believes that, while the stock status has returned to a relatively high level, significant concerns exist regarding recent declines in the stock level from historic highs. According to the 2013 stock assessment, spawning biomass for Eastern Bering Sea (EBS) pollock in 2008 was at the lowest level since 1980, but has increased by 71 percent since then.1 There was at least some evidence that the commercial fishery contributed to the recent low stock levels as indicated by increased fishing pressure on the spawning stock in recent years. In 2006 and 2007, the fishery removed more than 25 percent of the spawning age female pollock.2 This level of sustained fishing pressure on the spawning stock raises questions regarding sustainability. It is known that recruitment patterns for pollock are cyclical and rely on periodic years of high recruitment, however it is unclear whether the recent fluctuations in spawning biomass were also influenced by overharvesting or related to other external factors such as climate change. WWF believes that this inherent uncertainty warrants an additional level of precaution in setting the Total Allowable Catch (TAC).
The assessment team should have considered weaknesses and uncertainties in the current stock assessment methodology, especially the amount of EBS Pollock harvested in Russia. In our comments submitted during the first MSC reassessment of the Bering Sea - Aleutian Islands (BSAI) pollock fishery, WWF presented detailed information demonstrating that the current stock assessment methodology does not adequately explore sensitivities to assumptions, parameters and data, and key sensitivities related to a lack of information from the Russian pollock fishery in the northwestern Bering Sea. The Russian Bering Sea Pollock fishery entered the MSC assessment process in 2008 and was subsequently divided into two units of certification, the Western Bering Sea (WBS) and the Navarinsky Basin. The client data submission for the Western Bering Sea unit of certification was submitted by the Russian Pollock Catchers Association (PCA) in September 2010. The assessment has been withdrawn, but some documentation of the stock was made publically available on the MSC website.
As WWF documented in our previous assessment comments, peer reviewed science indicates a sustained migration pattern of EBS pollock into the Russian Exclusive Economic Zone (EEZ) consistent
1 Plan Team for the Groundfish Fisheries of the Bering Sea and Aleutian Islands. 2013. Introduction to the Stock Assessment and Fishery Evaluation (SAFE) Report for the Groundfish Resources of the Bering Sea/Aleutian Islands (BSAI) Regions, p. 17. North Pacific Fishery Management Council, 605 W 4th Avenue, Anchorage, Alaska. 2 Ianelli, J., et al. 2007. Stock Assessment and Fishery Evaluation (SAFE) Report for the Groundfish Resources of the Bering Sea/Aleutian Islands (BSAI) Regions, p.41-42, 55-56. North Pacific Fishery Management Council, 605 W 4th Avenue, Anchorage, Alaska.
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with warming patterns in the North Pacific.3 From 2005 to 2007, managers observed a redistribution of pollock from the EBS into the Navarin Basin region. In the Russian EEZ, the northern pollock stock located along the Navarin shelf from 171°E to the U.S.- Russia Convention line is likely comprised substantially of EBS pollock according to the best available science.4 Dr. Jim Ianelli, the NMFS scientist in charge of the BSAI pollock assessment, has stated that 10-20% of the EBS pollock stocks stray into Russian waters.5 This view is corroborated by Russian fisheries science indicating that approximately 20% of the WBS stock is comprised of EBS pollock.6 The client data submission for the Western Bering Sea unit of certification submitted by the PCA also states: “In Russian waters of the Bering Sea, Pollock provides a basis for a sustained large-scale fishery. This fishery’s target resource in the West Bering Sea Zone (east of 174°00 E) is Pollock of the East Bering Sea population, the greater portion of which migrates to this area from the sea’s eastern part during the summer-fall period. Pollock belonging to this population is exploited in U.S. waters as well and, during high abundance periods, by some other countries in the central part of the Bering Sea, beyond the boundaries of Russian and U.S. waters.”7 Furthermore, fisheries enforcement, management authorities, and fishermen have confirmed that this “spillover” is fished heavily by the Russian trawl fleet and Russian authorities have expressed their clear intent to increase fishing effort in this region.8
WBS pollock stocks have declined from their highest catch levels in the 1980s. The largest catch occurred in 1988, when Russian fishermen landed 1,327,000 mt. In the last decade pollock biomass decreased similarly to the US EBS stock and by 2009 it was at the lowest level registered in last 15 years. The average catch of WBS pollock was 368,000 mt between 2001-20049 and the harvest was 473,000 mt in 2005; about 30% of the 1988 maximum catch.10 The ratio of EBS pollock to WBS pollock that is harvested in the Russian EEZ is uncertain. The PCA client data submission cites Stepanenko (2001, a, b) stating that in a hydrological and planktonic situation close to average multi-year data, about 18-20% of pollock, mostly young-age individuals, migrates to the West Bering Sea Zone from the adjacent eastern
3 Mueter, Franz J., and Michael A. Litzow. 2008. Sea Ice Retreat Alters the Biogeography of the Bering Continental Shelf. Ecological Applications: Vol. 18, No. 2, pp. 309-320. 4 Supra note 1 at 49. 5 See http://www.latimes.com/news/nationworld/nation/la-na-pollock19-2008oct19,0,5226958.story?page=2 6 Balykin, P. A. 1996. Dynamics and abundance of western Bering Sea pollock. In Ecology of the Bering Sea. p. 177- 182. Alaska Sea Grant Report 96-01, Fairbanks, AK. 7 Russian Pollock Catchers Association Information Submission for MSC Certification Assessment of West Bering Sea – Principle 1. p. 6. Available at: http://www.msc.org/track-a-fishery/fisheries-in-the-program/in- assessment/pacific/russia_navarinsky_pollock. Accessed May 29, 2014. 8 See http://www.seafoodnews.com/newsemail.asp?key=634976 ('The warming of the climate will be to our advantage,' [Russian Federal Fisheries Agency head Andrei Krainy] said. 'Because of this, 35 percent of Alaska pollock will migrate from the U.S. part of the Bering Sea to colder waters, towards our coasts, So the U.S. plans to lower the catches, while we have sizably increased the fishing quota.') 9 Balykin, P.A.; Varkentin, A.I. 2006. Interpretation of ichthyoplankton survey data for the assessment of the spawning stock of Pollock, Published in: Fish species of the Far Eastern Seas: techniques of research. VNIRO Proceedings, 146. p. 159-165 10 Supra note 8 at 2.
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part of the sea.11 However little is known about the size and age class of pollock retained by the Russian fleet. More importantly, what is known about the Russian harvest that may be EBS pollock is not accounted for in the EBS stock assessment. With up to 20% of the EBS pollock stock being harvested in the Russian EEZ, we could be observing a dynamic similar to that documented in the late 1980s to early 1990s where the EBS pollock biomass declined correspondingly with overfishing in the Central Bering Sea and subsequent decrease in the Central Bering Sea biomass.12 Surveys by NMFS in the Russian EEZ may provide an indication of stability in the stock if a more substantial time series is achieved. However, the survey cannot fully distinguish the impacts of sustained and intensified harvest on the mixed WBS and EBS stock in Russian waters without additional harvest data on Russian fisheries prosecuted in the region. U.S. fisheries managers must fully understand and account for the harvest of the EBS stock in the Russian EEZ to truly ensure the sustainability of the pollock resource. Without an accurate assessment of the Russian portion of the EBS pollock stock, U.S. managers cannot confidently determine the true stock status of EBS pollock. Furthermore, there is at least anecdotal information that the Russian pollock fleet may be contributing substantial mortality to smaller size classes of pollock and, therefore, leading to recruitment overfishing of EBS pollock stocks.
The previous assessment team acknowledged that this issue was a legitimate concern in response to WWF comments, but dismissed it on the basis that no retrospective pattern was evident in the assessment of the EBS stock that indicated unaccounted for mortality. We questioned whether reliance on retrospective patterns represents a precautionary management strategy as required by the MSC certification process. Little effort was made on the part of the previous or current assessment team to acquire additional data on Russian pollock catches in the western Bering. WWF believes that this issue was not adequately addressed during the current reassessment to meet MSC requirements (see also comments under PI 1.2.2 and PI 3.1.1). Given that significant questions still remain regarding the contribution of Russian harvests in the northwestern Bering Sea, U.S. managers must achieve better access to data on harvests of the EBS pollock stock in Russian waters as well as any relationship between the EBS and WBS stocks.
Harvest strategy
1.2.1 Harvest strategy PI: There is a robust and precautionary harvest strategy in place.
The assessment team should have considered uncertainties and gaps in the existing harvest limits and reference points that leave the stock vulnerable to overfishing.
11 Ibid at 7 12 Ianelli, J.N., et al. 2006. “1. Assessment of Alaska Pollock Stock in the Eastern Bering Sea.” Appendix A: 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.
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While WWF feels comfortable that a relatively adequate harvest strategy is in place, several opportunities for improvement exist. Specifically, as noted above, there are potential areas where uncertainty or gaps in the existing harvest limits and reference points may be leaving the BSAI pollock stock vulnerable to overfishing.
Recent advances in predictive multi-species modeling should allow testing of existing harvest strategies for robustness against different assumptions regarding the role of natural environmental variability on pollock stocks. These tests should be conducted to ensure the effectiveness of the current harvest strategy. In conjunction with this improved modeling, more efforts must be made to obtain information on fisheries mortality in the Russian fisheries of the WBS. Until this information is incorporated into the harvest strategy, the fishery may be susceptible to overfishing.
1.2.2 Harvest Control Rules PI: There are well defined and effective harvest control rules in place.
The assessment team should have considered uncertainties to a greater degree.
At the SG 100 level for scoring issue (b), the design of the harvest control rules must take into account a wide range of uncertainties. WWF concurs with peer reviewer 1 that a score of 100 is not justified unless the harvest control rule explicitly incorporates a wider range of uncertainties in the stock assessment methodology due to environmental variability and in particular the amount of EBS Pollock harvested in Russia.
1.2.3 Information/monitoring PI: Relevant information is collected to support the harvest strategy.
The assessment team should have considered climate effects and how they are addressed, and uncertainties caused by Russian harvests on the EBS population and their effects on productivity and resilience.
While the pollock industry remains subject to some of the most thorough information and monitoring requirements, the criteria of “other data” identified by the MSC remains deficient. Climate effects on pollock have not been adequately addressed in previous assessments and the current process must incorporate a detailed review of recent results of the Bering Sea Integrated Ecosystem Research Program administered by the North Pacific Research Board. This should include the results of modeling conducted to determine climate effects as a predictor of fisheries distribution and ecosystem dynamics. Substantial information gaps also exist resulting in uncertainty regarding fisheries mortality from removals of EBS pollock in the Russian pollock fishery as described above. These additional sources of uncertainty could be having a profound effect on stock productivity and resiliency. Without further research into these other data, the EBS pollock fishery remains subject to potential overfishing.
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1.2.4 Assessment of stock status PI: There is an adequate assessment of the stock status.
The assessment team should have considered the effects of unknown mortality on the EBS stock from Russian harvesters and uncertainty resulting from climate change.
As has been pointed out previously, the EBS pollock fishery fails to adequately take into account fishing mortality on the EBS stock that occurs in Russian waters. Because this portion of fishing mortality could significantly impact the stock and could increase in intensity if the stocks continue a trend of northward range into Russian waters, it is imperative that it be fully understood. Furthermore, additional uncertainty must be considered with respect to climate change.
Bycatch
2.2.1 Outcome Status PI: The fishery does not pose a risk of serious or irreversible harm to the bycatch species or species groups and does not hinder recovery of depleted bycatch species or species groups.
The assessment team should have considered the high volume of bycatch.
While the pollock fishery claims a bycatch total of far less than 5 percent of their total catch, it is important to note that even 1 percent bycatch constitutes a very large volume of bycatch species considering the volume of target species. From the 32 year period from 1977-2013, the catch of EBS pollock in the US EEZ has averaged 1.17 million mt.13 This constitutes up to 17,550 metric tons of bycatch annually in the EBS alone. For the long-lived, low fecundity species such as skates and sharks, this could have a profound impact. In some years, the amount of salmon bycatch by the BSAI pollock fleet exceeded the directed salmon harvest in certain river systems. Thus, in a high volume fishery such as the BSAI pollock fishery the percentage of bycatch is an inappropriate measure of the directed fishery’s effects on bycatch species.
The assessment team should have considered the conservation impacts of salmon bycatch in the EBS pollock fishery on salmon fisheries in Alaska, British Columbia, and the Pacific Northwest.
In 2011, the National Marine Fisheries Service implemented a cap on Chinook salmon bycatch in the EBS pollock fishery, yet there is no bycatch cap on chum salmon. Despite the cap, Chinook salmon runs are in decline, even crisis, in many river systems in Alaska, including the Yukon, Kuskokwim and Kenai Rivers, and Cook Inlet/Upper Cook Inlet. Several Chinook and chum salmon runs in Alaska have been designated by the Alaska Department of Fish & Game (ADF&G) as stocks of concern. Impacts of BSAI bycaught salmon on Alaska salmon runs of concern are poorly understood. WWF believes that, despite lacking
13 Ianelli, J., et al. 2013. Stock Assessment and Fishery Evaluation (SAFE) Report for the Groundfish Resources of the Bering Sea/Aleutian Islands (BSAI) Regions, p.82. North Pacific Fishery Management Council, 605 W 4th Avenue, Anchorage, Alaska.
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official legal status under the ESA as threatened, endangered, or protected, the certifier should have considered Chinook and non-Chinook salmon stocks of concern in Western Alaska, British Columbia and the Pacific Northwest that are likely being impacted.
It would be prudent for the BSAI pollock fishery to be proactive in addressing these stock concerns by implementing a bycatch cap for chum salmon, lowering the bycatch cap for Chinook salmon, requiring the use of bycatch excluder devices, and other conservation and management measures, as well as continuing to improve and possibly institutionalize in regulation the voluntary Rolling Hot Spot system of closures and salmon excluder device usage. Continued improvement of the bycatch mitigation gear under an experimental fishing permit should be encouraged because it could reduce both Chinook and chum salmon bycatch of the mid-pelagic trawl fleet greatly, if successful.
Because Alaska salmon stocks are not considered ETP species by the MSC definition, the assessment team should have evaluated salmon as a main bycatch species.
2.2.2 Management Strategy PI: There is a strategy in place for managing bycatch that is designed to ensure the fishery does not pose a risk of serious or irreversible harm to bycatch populations.
The assessment team should have acknowledged the lack of a strategy for managing bycatch.
Currently, there is not a strategy in place for managing bycatch that is designed to ensure the fishery does not pose a risk of serious or irreversible harm to Chinook or chum salmon populations. Regulatory management measures for chum bycatch are under discussion because the voluntary rolling hot spot system has not reduced bycatch of chum and other salmon. The current management measures remain substantially insufficient to address bycatch of salmon species and does not constitute a partial or full strategy. Furthermore, the bycatch cap measures that have been implemented do not reduce bycatch enough because they institutionalize bycatch levels that occurred during the worst (highest) bycatch years and the bycatch cap is not responsive to Chinook abundance. There are few successful bycatch reduction measures in place for chum salmon, no bycatch caps, the bycatch mitigation gear (excluder device) is not effective for reducing chum bycatch, and there is no clear timeline for regulatory measures to be enacted to reduce chum bycatch which have been under discussion at the NPFMC for several years. It is for these reasons that we recommended a score for this PI of no more than 70 based on the scoring guideposts.
ETP Species
2.3.1 Outcome Status PI: The fishery meets national and international requirements for protection of ETP species. The fishery does not pose a risk of serious or irreversible harm to ETP species and does not hinder recovery of ETP species.
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The assessment team should have considered direct and indirect effects on Northern right whale, Steller sea lion and northern fur seal more critically and with the most up-to-date information.
Direct Effects
The PCDR correctly lists the ETP species subject to consideration under the ESA and MMPA. WWF agrees that although the BSAI Pollock fishery is listed as a Category II fishery under the MMPA, relatively few marine mammals are reported to be directly taken in the Bering Sea pollock fishery. Therefore the potential level of direct mortality is below the potential biological removal (PBR) calculated during the MMPA stock assessment process for all marine mammals which have a PBR determined. However we note that although the BSAI Pollock fishery is unlikely to adversely affect any of the ETP marine mammal species through direct mortality caused by the fishery, we stated in our initial stakeholder comments that designated critical habitat for North Pacific right whales includes areas where the BSAI pollock fishery operates in the Bering Sea.14 While no incidental catch of a North Pacific right whale has been recorded, a fin whale incidentally caught in the pollock fishery in 2006 demonstrates the potential for large whales to be incidentally caught in pollock fishery trawls.15 The PBR for North Pacific right whale stock is considered zero due to the extremely small size of the population.16 North Atlantic right whales have been shown to be vulnerable to ship strikes due to their slow swimming speed and it is also conceivable that a pollock trawl could incidentally catch a North Pacific right whale.17
Indirect Effects
At SG80 the MSC FCR requires that “indirect effects have been considered and are thought to be unlikely to create unacceptable impacts.” Due to the large spatial extent and high volume of removals by the BSAI pollock fishery from important foraging habitat for several ETP species, WWF does not believe that a score of 80 for the indirect effects scoring guidepost is justified. Of the nine marine mammal species in the BSAI that are documented to eat pollock (fin whales, humpback whales, minke whales, bearded seals, spotted seals, ribbon seals, northern fur seals, Steller sea lions and harbor seals) three species, Steller sea lions, northern fur seals and ribbon seals depend on pollock as a principal prey species18. The Alaska Groundfish Harvest Specifications EIS determined that competition for key prey species is not likely to constrain the foraging success of marine mammal species or cause population declines19 with
14 73 FR 19000, April 8, 2008 15 Draft EIS/RIR/IRFA, Bering Sea Chinook Salmon Bycatch, December 2008. p.242. National Marine Fisheries Service, 709 W 9th, Juneau, Alaska. (retrievable at http://www.fakr.noaa.gov/sustainablefisheries/bycatch/salmon/deis1208.pdf). 16 Angliss, R. P., and B. M. Allen. 2012. Alaska marine mammal stock assessments, 2012. U.S. Dep. Commer., NOAA Tech. Memo. NMFS AFSC-193, 258 p. 17 Waring GT, Josephson E, Fairfield-Walsh CP, Maze-Foley K, editors. 2009. U.S. Atlantic and Gulf of Mexico Marine Mammal Stock Assessments 2008. NOAA Tech Memo NMFS NE 210; 440 p. 18 NMFS 2007. Alaska Groundfish Harvest Specifications Environmental Impact Statement. January 2007. DOC, NOAA, National Marine Fisheries Service, P.O. Box 21668, Juneau, Alaska 99802. Available from http://www.fakr.noaa.gov/analyses/groundfish. 19 Id.
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the exception of northern fur seals and Steller sea lions, which potentially compete for principal prey with the groundfish fisheries.20 In the case of these two species, NMFS management analyses have consistently found that the BSAI groundfish fisheries, including the Bering Sea pollock fishery, may impact Steller sea lions and northern fur seals through competition with the fishery for prey21,22,23.
Steller Sea Lions
NMFS determined in the Recovery Plan for the endangered Steller sea lion that prey depletion by commercial fisheries in the Bering Sea poses a threat to the endangered western population of Steller sea lions. The recent analysis presented in the current NMFS Biological Opinion24 is summarized in the PCDR stating: “there are extensive gaps in the available information which prevent understanding the causal relationships affecting Steller sea lions in the western and central Aleutian Islands.“ WWF strongly agrees with the need stated by NMFS for a precautionary approach to any fishing that is allowed in Steller sea lion critical habitat. In the context of the recertification of the BSAI Pollock fishery such a precautionary approach must ensure that the fishery does not hinder the recovery of Steller sea lions as defined in the Steller sea lion recovery plan. The specific demographic criteria recovery established in the 2008 Steller Sea Lion Recovery Plan require: a) statistically significant increases in sea lion abundance for 30 years, 2) no statistically significant population declines in two adjacent sub-areas, and 3) no decline in abundance of more than 50 percent in any sub-region relative to the 2000 base year.25 The recent SSL Biological Opinion states that “significant population increases need to occur for another 17 years to achieve the first demographic de-listing criterion. Given current population trends (significant increases in only 3 of 6 sub-regions in Alaska), the second criterion is not being met and substantial increases in western Aleutian Islands population abundance need to occur to satisfy the third criterion”.26 Therefore WWF does not consider that the SSL WDPS can be considered to be recovering under existing management criteria and there is potential for the BSAI Pollock fishery to hinder this recovery.
The PCDR cites the reviews of the 2010 SSL Biological Opinion by the Alaska Department of Fish and Game (ADF&G) and the Washington Department of Fish and Wildlife (WDFW)27 and the Center for
20 Id. 21 Final Steller Sea Lion Protection Measures Supplemental Environmental Impact System. 2001. National Marine Fisheries Service. Alaska Region 22 NMFS. 2005. Final Environmental Impact Statement for Setting the Annual Subsistence Harvest of Northern Fur Seals on the Pribilof Islands. NMFS Alaska Region, Protected Resources Division, Juneau, AK. 23 NMFS. 2008. Recovery Plan for the Steller Sea Lion. DOC, NOAA, National Marine Fisheries Service, P.O. Box 21668, Juneau, Alaska 99802. 24 NMFS. 2014. Endangered Species Act Section 7 Biological Opinion: Authorization of the Alaska groundfish fisheries under the proposed revised Steller Sea Lion Protection Measures. National Marine Fisheries Service. Juneau, Alaska. 25 Supra note 29 26 Supra Note 31 27 Bernard, D.D.R., Jeffries, S.J., Knapp, D.G., and Trites, D.A.W. 2011. An independent , Scientific Review of the Biological Opinion ( 2010 ) of the Fisheries Management Plan for the Bering Sea / Aleutian Islands management areas, Anchorage, Alaska.
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Independent Experts (CIE) which found that the conclusions of the first NMFS Biological Opinion were not supported by the evidence and that numerous attempts to identify negative impacts of the pollock fishery on SSL have found no such effects. However the report by Conn et al.28 prepared by the National Marine Mammal Laboratory (NMML) in response to the CIE reviews shows that many of these studies have little to no statistical power to provide meaningful inferences regarding the prey limitation hypothesis depending on the type of analysis and selection of dependent and independent variables.29 WWF also notes that a study using the recommended multi-hypothesis testing approach called for in Condition 1a of the first reassessment of the Pollock fishery found strong support for models where SSL recruitment was written as a function of total prey availability or prey species composition.30
Northern Fur Seals
The PCDR uses out of date information from the 2012 pup production estimate to summarize the northern fur seal population status. The 2014 pup production estimate for St. Paul Island is 5.2% less than the 2012 estimate, however St. George pup production increased by 17% from the 2012 estimate. Due to the larger size of the St. Paul population, overall pup production for the Pribilof Islands decreased by approximately 2.1% from 2012 to 2014. Since 1998 pup production on the Pribilof has declined 45%, or at an annual rate of 3.7%.31 Given the continued decline of the Pribilof Island fur seal population WWF considers that there is potential for indirect effects of the BSAI Pollock fishery to hinder the recovery of this population.
The principle source cited in the PCDR regarding indirect effects of the Pollock fishery is a contract report submitted at the 3rd surveillance audit by the client fishery as required by condition 1a for northern fur seals.32 As cited in the PCDR, the report by Cornick (undated) concludes that there is no current evidence that the commercial fishery is directly competing with fur seals for pollock. However the findings of the report assessing nutritional stress are based primarily on a recent multi-year study of the consequences of fur seal foraging strategies at two colonies with opposing population trends, St. Paul Island in the Pribilof Islands and Bogoslof Island in the Southeastern Bering Sea by Springer et al.33 The results of the Springer et al. study provide several plausible mechanisms for indirect effects of the Pollock fishery on northern fur seals. First, although adult female fur seals from both islands were able to rear and wean healthy pups, St. Paul Island pups were significantly smaller. Lower weaning weights of
28 Conn, P., D. Johnson, L. Fritz, and B. Fadely. 2013. Use and misuse of fishery and survey data to detect prey removal effects on Steller sea lions (Eumetopias jubatus). Draft manuscript submitted to the Alaska Regional office of NOAA Fisheries. 49 pp. 29 Id 30 Wolf, N., and M. Mangel. 2008. Multiple hypothesis testing and the declining population paradigm in Steller sea lions. Ecological Applications 18:1932{1955. 31 National Marine Mammal Laboratory 2014. Available at: http://www.afsc.noaa.gov/nmml/PDF/2014-nfs-pup- counts-pribs.pdf. 32 Cornick, L.A. 2013. Factors Affecting Northern Fur Seal Recovery in the Pribilof Islands, Alaska: State of the Science and Assessment. Prepared for At-Sea Processors' Association. Juneau, Alaska. 33 Springer et al. 2010. Seasonal Foraging Strategies and Consequences for Northern Fur Seals at Colonies with Opposite Population Trends – Year 2 (COFFS). NPRB Project 524 Final Report. North Pacific Research Board. Anchorage, AK.
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northern fur seal pups have been correlated with decreased survival rates among northern fur seals, indicating that survival rates could be lower for St. Paul Island pups.34 Second, females from St. Paul Island made significantly longer foraging trips and were in poorer condition at the end of the breeding season based on total body fat, thus indicating possible reduced body condition (i.e. nutritional stress). Satellite telemetry studies have shown that foraging areas utilized by female fur seals from St. Paul Island overlap significantly with the spatial distribution of the pollock fishery during summer/fall and that these foraging areas have been consistent over studies dating back to the beginning of the recent decline.35,36,37 In contrast the Bogoslof Island area is closed to fishing in an area that largely encompasses the foraging range of females from the Bogoslof breeding site. While this does not establish a direct cause and effect relationship between the fishery and nutritional stress among St. Paul females, previous studies of Antarctic fur seals (e.g. Lunn et al. 199438) have shown that when foraging trips are long (indicating reduced local food resources), females return to the breeding beaches later, fewer females have pups, they give birth to lighter pups and weaning success is reduced in the subsequent year. Thus it is plausible that reduced prey abundance in proximity to St. Paul Island could be a factor in the Pribilof Island fur seal decline either through decreased pup survival rates or reduced birth rates among adult females due to nutritional stress. It is also important to note that while in the Bering Sea 40 – 80% of the diet of fur seals from the Pribilof Islands consists of pollock39 and that there is evidence of direct overlap between the size of fish taken by the commercial fishery and the size consumed by fur seals.40
In summary, based on the information presented above WWF does not find the scoring rationale presented in the PCDR for indirect effects of the BSAI Pollock fishery to be well supported. The results of the most comprehensive study of fur seal foraging dynamics in the Eastern Bering Sea to date present evidence that prey abundance in proximity to the Pribilof Islands region may impact northern fur seal foraging success and the condition of fur seal females at the end of the breeding season prior to the implantation of the following years pup. WWF urges the assessment team to consider revising the current scoring for scoring issue (c) under PI 2.3.1. to less than 80. WWF realizes that this will not result
34 Baker JD and Fowler CW (1992) Pup weight and survival of northern fur seals Callorhinus ursinus. Journal of Zoology 227(2): 231-238. 35 Robson, B.W., Goebel, M.E., Baker, J.D., Ream, R.R., Loughlin, T.R., Francis, R.C., Antonelis, G.A., and Costa, D.P. 2004. Separation of foraging habitat among breeding sites of a colonial marine predator, the northern fur seal (Callorhinus ursinus). Can. J. Zool. 82(1): 20–29. doi:10.1139/z03-208. 36 Call, K.A., Ream, R.R., Johnson, D., Sterling, J.T., and Towell, R.G. 2008. Foraging route tactics and site fidelity of adult female northern fur seal (Callorhinus ursinus) around the Pribilof Islands. Deep Sea Res. Part II Top. Stud. Oceanogr. 55: 1883–1896. doi:10.1016/j.dsr2.2008.04.022. 37 Kuhn, C. E., R. R. Ream, J. T. Sterling, J. R. Thomason, and R. G. Towell. 2014. Spatial segregation and the influence of habitat on the foraging behavior of northern fur seals (Callorhinus ursinus). Can. J. Zool. 92:861-873. 38 Lunn, N.J. I. L. Boyd and J. P. Croxall. 1994. Reproductive Performance of Female Antarctic Fur Seals: The Influence of Age, Breeding Experience, Environmental Variation and Individual Quality Journal of Animal Ecology Vol. 63, No. 4 (Oct., 1994), pp. 827-840. 39 Zeppelin, T. K., and R. R. Ream. 2006. Foraging habitats based on the diet of female northern fur seals (Callorhinus ursinus) on the Pribilof Islands, Alaska. J. Zool. 270:565-576. 40 Gudmundson, C. J., T. K. Zeppelin, and R. R. Ream. 2006. Application of two methods for determining diet of northern fur seals (Callorhinus ursinus). Fish. Bull. 104:445-455.
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in an overall score below 80 for PI 2.3.1 resulting in a condition, however we strongly urge that the CAB strengthen the recommendation for ongoing evaluation of indirect effects to include the development of an enhanced catch database for northern fur seal foraging areas similar to that proposed under PI 2.3.2 for Steller sea lions (see below).
2.3.2 Management Strategy
Based on the information presented above under the ETP Species Outcome PI, WWF questions whether the ETP Management Strategy PI for the pollock fishery has precautionary management strategies in place that will not hinder recovery of SSL and NFS. The SSL protection measures proposed under the revised SSL Biological Opinion41 will open additional areas of SSL Critical Habitat (CH) to pollock fishing in which the SSL sub-population units are not recovering at significant rates relative to the requirements of the SSL recovery plan.
For northern fur seals, a non-ESA listed species, there is no comparable suite of management measures in place to insure that the fishery does not hinder their recovery. The Pribilof Habitat Conservation Area encompasses a large area east of the Pribilof Islands however it protects only a small percentage of documented fur seal foraging habitat and offers no protection from the effects of the pollock trawl fishery because the no trawl zone is exclusively in the middle shelf domain where the fishery seldom operates. In addition to the lack of habitat protection for northern fur seal foraging habitat, NMFS has determined that the measures implemented to protect Steller sea lions may actually be having a detrimental effect on northern fur seals. The 2002 Ecosystem Considerations chapter of the Status of Stocks and Fishery Evaluation Report42 first evaluated the displacement of pollock fishing into fur seal foraging habitat by Steller sea lion protection measures. This analysis was updated in the 2001 Steller sea lion Supplemental Environmental Impact Statement43, which also resulted in a finding of a conditionally significant adverse impact of commercial fisheries removals on northern fur seals. These findings were repeated in the Final Environmental Impact Statement for Setting the Annual Subsistence Harvest of Northern Fur Seals on the Pribilof Islands44 and the NMFS, BSAI and GOA Harvest Specifications for 2006-2007: Environmental Assessment (EA) and Regulatory Flexibility Analysis (FRFA).45 Most recently, the Bering Sea Chinook Salmon Bycatch Management Draft EIS/RIR/IRFA found that the groundfish fisheries may have a conditional cumulative effect on prey availability if the fisheries
41 Supra note 38 at 153. Table 5-21. 42NMFS. 2002. Ecosystem Considerations Chapter, Status of Stocks and Fishery Evaluation Report. 43 Final Steller Sea Lion Protection Measures Supplemental Environmental Impact System. 2001. National Marine Fisheries Service. Alaska Region
44 Final Environmental Impact Statement for Setting the Annual Subsistence Harvest of Northern Fur Seals on the Pribilof Islands. 2005. National Marine Fisheries Service. Alaska Region
45 BSAI and GOA Harvest Specifications for 2006-2007: Environmental Assessment (EA) and Regulatory Flexibility Analysis (FRFA). 2006. National Marine Fisheries Service. Alaska Region
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were to become further concentrated spatially or temporally in fur seal habitat, especially during June through August46. In a new satellite telemetry analysis of NFS foraging habitat conducted to evaluate the consistency of documented NFS foraging areas in view of the continued population decline in the Pribilof Islands, Kuhn et al.47determined that Pollock fisheries continue to operate intensively in NFS foraging areas northwest of St. Paul during the fall season.
The Conservation Plan for the Eastern Pacific Stock of Northern fur seals documents that northern fur seals are in the midst of a long-term decline. Pribilof Island populations are at 30-40% of peak historical levels in the 1950s. The continuing decline since the late 1990s has occurred while pollock fishing has consolidated in northern areas that coincide with Pribilof fur seal foraging habitat, especially in areas that overlap with fur seal foraging habitat for female seals from southwest St. Paul Island.48 In contrast to the Pribilofs, the Bogoslof Island population that has continued to increase steadily over recent decades, but may be showing signs of reaching carrying capacity.49 The boundaries of the Bogoslof management area, closed to trawling for several decades, encompass the majority of the observed foraging range for adult females from the Bogoslof population. The observed population trends for northern fur seals underscore the need to better understand the relationship between the pollock fishery and apex predators in order to maintain a sustainable fishery within the Bering Sea ecosystem.
WWF believes that it is necessary to further develop the spatial management structure in the BSAI to evaluate and mitigate any adverse effects of fishing on Steller sea lions, northern fur seals and other predators. To reverse the fur seal decline decline and restore fur seals to their optimum sustainable population as mandated under the Marine Mammal Protection Act (MMPA), a coordinated effort should be undertaken to identify and implement appropriate spatial measures to reduce the potential for localized depletion of prey resources similar to what has been done for Steller sea lions. This should include a clear delineation of fur seal foraging habitat in the Bering Sea based on the current body of scientific information. Once identified and designated, fur seal foraging habitat will provide an important spatial basis for identification, coordination and evaluation of research and management measures that may impact fur seals and their foraging habitat. In the Conservation Plan, NMFS recognizes the need to establish a foundation for spatially-based management. Colony-specific foraging areas for northern fur seals have been identified from radio and satellite tracking studies50,51,52,53. These
46 Draft EIS/RIR/IRFA, Bering Sea Chinook Salmon Bycatch, December 2008. p.242. National Marine Fisheries Service, 709 W 9th, Juneau, Alaska. (retrievable at http://www.fakr.noaa.gov/sustainablefisheries/bycatch/salmon/deis1208.pdf). 47 Supra note 37. 48 Id. 49 Kuhn, C.E., Baker, J.D., Towell, R.G., and Ream, R.R. 2014. Evidence of localized resource depletion following a natural colonization event by a large marine predator. J. Anim. Ecol. doi:10.1111/1365-2656.12202. 50 Sterling, J.T., and R.R.Ream. 2004, At-sea behavior of juvenile male northern fur seals (Callorhinus ursinus) Can. J. Zool. 82:1621-1637 51 Supra note 35 52 Supra note 36 53 Supra note 37
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spatial patterns have been further substantiated and refined using fur seal diet data.54 This action will provide a coherent and consistent spatial structure from which to evaluate research and management measures that can be used to mitigate the impacts of fishing on northern fur seals and other apex predators in the Bering Sea ecosystem. Examples of such measures could include future modifications of Steller sea lion habitat protection measures; fisheries management measures to reduce bycatch of salmon or squid; potential changes in the spatial extent of the Pribilof Islands Habitat Conservation Area (PHCA); or spatial and seasonal apportionment of fishery catch rates under revisions to the Fishery Management Plan. If fur seals continue to decline to a level warranting protection under the Endangered Species Act (ESA), designation of foraging areas will provide an effective means to evaluate appropriate actions to protect critical habitat for northern fur seals.
In Summary, there is a management system in place for Steller sea lions as mandated under the ESA and as such there is a basis for confidence that the Steller sea lion protection measures may be working to reduce direct impacts on the species. However it remains to be determined whether these measures are sufficient to recover the Steller sea lions to levels mandated by the SSL Recovery Plan. Furthermore, the management agency has determined on multiple occasions that these measures are likely to have adverse impacts on another ETP species, the northern fur seal thereby potentially hindering its recovery or even causing the Pribilof Island population to decline. For these reasons that we recommend a score for this PI of no more than 80 based on the scoring guideposts that require that a partial strategy to be in place that ensures that the fishery does not hinder the recovery of ETP species. At an absolute minimum, WWF recommends that the Pollock fishery implement an enhanced catch database similar to that developed during the NMFS Effects Analysis55 to fully document catch levels in CH both in the Aleutian sub areas and other CH areas in the Bering Sea which may be subject to high fishing levels of effort (e.g. Dalnoi Point in the Pribilof Islands). The same system should be used to document catch levels in areas identified as primary foraging habitat for northern fur seal females.
Habitat
We disagree with the scorings of the Habitat PIs (2.4.1 / 2.4.2 / 2.4.3). In our opinion the scores assigned to these PIs were arbitrary insofar as the rationales do not sufficiently justify the high scores. Additionally, there was also a procedural irregularity due to the fact that the assessment team did not assign separate scores for the different scoring elements (27.10.7). We are also disappointed that our concerns regarding squid bycatch/impact on pelagic habitats were ignored and not discussed in the current PCDR. 2.4.1 Outcome Status
PI: The fishery does not cause serious or irreversible harm to habitat structure, considered on a regional or bioregional basis, and function.
54 Zeppelin, T.K., and R.R.Ream. 2006. Foraging habitats based on the diet of female northern fur seals (Callorhinus ursinus) on the Pribilof Islands, Alaska. 55 Id Appendix I
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The assessment team should have appropriately scored habitat impacts of the fishery.
Benthic habitats:
In our opinion a score of 100 in P.2.4.1 is highly unjustified. CB3.14.4 states that “The team should score the fishery at SG100 if evidence shows that the fishery has no impacts on habitats”. However, in the case of the Eastern Bering Sea and Aleutian Islands Pollock Fishery the opposite is true. There is overwhelming evidence that the fishery highly impacts benthic habitats in the region due to the fact that: a) the gear contacts frequently the bottom (44% 56 up to 85% 57 of the tow duration) b) it has been demonstrated that the gear reduces habitat complexity, alters seafloor communities and reduces habitat productivity significantly reduces living structures during ground contact 58 c) the fishing area the fleet overlaps with vulnerable marine ecosystems (VME) 59 d) large amounts of indicator species of vulnerable marine ecosystem are frequently caught by the Pollock fishery (especially sea pens (up to 4t / year) and sponges (up to 6 t /year))60. For a better understanding of this amount: The encounter threshold for sea pens that triggers the move on rule is 7kg per tow in the Northwest Atlantic 61. e) trawl tracks and damaged biota are clearly visible in VME hotspots during drop-camera1 or submersible 62 surveys. e) reproduction and recruitment rates for VME habitats are generally very slow (between years (sea pens63), decades (sponges64) and centuries (corals65 ) and therefore recovery rates of these habitats are well beyond the 6-18 month stated in the PCDR.
56 Final Essential Fish Habitat (EFH) EIS. April 2005. National Marine Fisheries Service, 709 W 9th, Juneau, Alaska. Appendix B, Table B.2-4 (retrievable at http://www.fakr.noaa.gov/habitat/seis/efheis.htm). 57 Loverich, G. 2001. NET-Systems. Trawl dynamics and its potential impact on habitat. Report submitted to the National Academy of Science, Evaluating the Effects of Bottom Trawling on Seafloor Habitats. Anchorage, Alaska. June 2001. 58 National Research Council. 2002. Effects of Trawling and Dredging on Seafloor Habitat. National Research Council, National Academy Press, Washington, D.C. 59 Rooper et al. 2015. Results of the 2014 Underwater Camera Survey of the Eastern Bering Sea Outer Shelf and Slope. Presentation at the NPFMC Meeting Anchorage 60 Ianelli, J. N., T. Honkalehto, S. Barbeaux, and S. Kotwick. 2014. Assessment of the walleye pollock stock in the Eastern Bering Sea. NPFMC Bering Sea and Aleutian Islands SAFE, Dec. 2014. 61 Auster P, Bergstad O, Brock R, Colaco A, Duran Munoz P, et al. (2013) Report of the ICES\ NAFO Joint Working Group on Deep-water Ecology (WGDEC), 11–15 March 2013, Floedevigen, Norway. Report of the ICES\ NAFO Joint Working Group on Deep-water Ecology (WGDEC), 11–15 March 2013, Floedevigen, Norway. 62 Miller, Robert J., Claudette Juska, and John Hocevar. "Submarine canyons as coral and sponge habitat on the eastern Bering Sea slope." Global Ecology and Conservation 4 (2015): 85-94. 63 Wilson, Matthew T., et al. "Axial rod growth and age estimation of the sea pen, Halipteris willemoesi Kölliker." Hydrobiologia 471.1-3 (2002): 133-142.
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f) there is scientific evidence that these VMEs have an important ecological function in the region 66 67 68. For example fewer fish were observed in the sparse sea whip groves than the dense sea whip groves69.
We also do not understand why the scoring increased from 85 in the 2010 re-assessment to 100 in the present PCDR. The only additional information in the rational is the drop camera study from Sigler / NOAA 70 and the remark that only ~3.4% of the Pollock catches occur in the canyons. Sigler stated that the 5 canyons are not faunally distinct features of the eastern Bering Sea slope. However, the study identified distinct VME hotspots (corals, sponges and sea pens/sea whips) on the slope, outer shelf and shelf break. Several of these hotspots are in areas where the fishery operates.
In our opinion some habitats (e.g. corals gardens, sea pen fields, sponges) might not even reach SG 80. At least not based on the given rational and without a more detailed spatial analysis of VMEs and fishing activity. The argument that Long-term Effects Impact analysis suggested Pollock non-pelagic trawling would result (only) in a 4.6% and 7.2% reduction in habitat features should not be stressed too much. These effects are calculated over large expanses of different habitats, which lessens the overall percentages of reduction of habitat features when viewed on the whole. Without a more detailed analysis including the specific (sub-) habitats the assessment team cannot state that it cannot be ruled out that fishing activity can lead to regional depletion of key habitat forming species and significant alteration of habitat cover/mosaic that may causes major change in the diversity of the associated species assemblages.
Although MSC Standard 1.3 does not include specific precautionary rules regarding VMEs like the new MSC2.0 standard or the UNGA resolutions 61/105 and 64/72, the current standard (V 1.3) asks the certifiers to score habitat types separately as different scoring elements (GCB3.14.1). VMEs with their distinct functions, structures and life cycles should be treated as stand-alone scoring elements (see conclusion of the MSC Independent Adjudicator in the Greenland cod objection71).
We therefore ask for additional justifications/scoring of vulnerable habitats that are likely affected by the fishery like VMEs on soft bottoms like (sea pen and sea whip fields, sponges and coral gardens).
64 Rooper, Christopher N., et al. "Modeling the impacts of bottom trawling and the subsequent recovery rates of sponges and corals in the Aleutian Islands, Alaska." Continental Shelf Research 31.17 (2011): 1827-1834. 65 Roark, E. Brendan, et al. "Radiocarbon-based ages and growth rates of bamboo corals from the Gulf of Alaska." Geophysical Research Letters 32.4 (2005). 66 Heifetz, Jonathan. "Coral in Alaska: distribution, abundance, and species associations." Hydrobiologia 471.1-3 (2002): 19-28. 67 Stone, R. P. "Coral habitat in the Aleutian Islands of Alaska: depth distribution, fine-scale species associations, and fisheries interactions." Coral reefs 25.2 (2006): 229-238. 68 Krieger, Kenneth J., and Bruce L. Wing. "Megafauna associations with deepwater corals (Primnoa spp.) in the Gulf of Alaska." Hydrobiologia 471.1-3 (2002): 83-90. 69 Stone, R., M. M. Masuda, and P. W. Malecha. 2005. Effects of bottom trawling on soft-sediment epibenthic communities in the Gulf of Alaska. In: P.W. Barnes and J.P. Thomas (editors), Benthic Habitats and the Effects of Fishing. Am. Fish. Soc. Symposium 41. pp. 461-475. 70 Sigler, M.F., C.N. Rooper, G.R. Hoff, R.P. Stone,R.A. McConnaughey, T.K. Wilderbuer. 2015. Faunal features of submarine canyons on the eastern Bering Sea slope. Marine Ecology Progress Series 526:21-40. 71 https://www.msc.org/track-a-fishery/fisheries-in-the-program/certified/north-east-atlantic/greenland-cod- haddock-and-saithe-trawl/assessment-downloads-1/20150505_PCR_COD412.pdf
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Given the very slow recoverability of VME habitats, their fragile nature, their important role in the ecosystem as bioengineers and the lack of scientific knowledge in many aspects (e.g. growth, recolonization rates, species composition etc.) we would like to see a more precautionary approach by the fishery that is in accord with the UNGA resolutions 61/105 and 64/72 and the FAO deepwater fishing guideline, especially that the fishery voluntarily avoids hotspots of known VMEs.
We also recommend that the Trawl Performance Standard must be altered to minimize or, if practicable, eliminate bottom contact of pelagic trawls in space and time. Until such time, a methodology or technology must be developed to record when, where, and how long pelagic trawls used in the Pollock fishery actually comes in contact with benthic habitat rather than a proxy that raises more questions than it answers.
Pelagic habitats
As stated above, we are disappointed that our concerns regarding pelagic habitats were ignored and not discussed in the present PCDR. Whether these concerns fit to PI 2.4 or PI 2.5., impacts of pelagic trawling on discrete biological features in the water column should not be discounted. In an open ocean ecosystem, consideration of the pelagic habitat of important trophic species is essential for ecosystem-based fisheries management.72 Pelagic habitat is widely utilized by commercial fish species and the Magnuson-Stevens Act has broadly defined Essential Fish Habitat to include "those waters and substrate necessary to fish for spawning, breeding, feeding, or growth to maturity." In addition, the presence of prey concentrated in pelagic habitat is in itself a characteristic of habitat suitability. Prey species are often concentrated by hydrographic features that define areas of pelagic habitat. These features can either be static (e.g. sub- marine canyons) or dynamic in nature (e.g. oceanic gyres and currents). In the Bering Sea, FMP-managed squid are an example of an important trophic species that aggregates in shelf-edge pelagic habitat and, by their presence, define such habitat for other species.
However, despite the importance of such pelagic habitat to trophic species such as squid, mesopelagic fish and juvenile pollock, most of the effort to assess and designate Essential Fish Habitat in the Pacific and NPFMCs has focused on defining critical benthic habitat. The NPFMC in 1997 prohibited directed fishing for a 73 range of important forage fish and krill; however this action did not address the habitat needs of these species. Squid, which are a fundamental forage species in the North Pacific, did not receive similar protection. In the Bering Sea, underlying bathymetric features and the proximity of key ecological areas such as the Pribilof Islands to the shelf break influences current and tidal flows to create complex pelagic habitat.74
Commercial fisheries, when operating in such pelagic habitat zones, may have increased bycatch of non- target prey and increased interaction with pelagic predators. For example, squid bycatch in the Bering Sea occurs primarily in the pelagic trawl pollock fishery, and is concentrated in Zhemchug, Pribilof and Bering 75 Canyons along the shelf break. Concentration of squid bycatch in space and time presents a risk due to the unique life cycle of squid and also raises possible concerns about the effects on the forage availability for
72 Agostini, V. 2005. Climate, ecology and productivity of Pacific sardine (Sardinops sagax) and hake (Merluccius productus). Ph.D. dissertation, School of Aquatic and Fishery Sciences, University of Washington, Seattle. 73 Witherell, D., Pautzke, C., and Fluharty, D. 2000. An ecosystem-based approach for Alaska groundfish fisheries.ICES Journal of Marine Science, 57: 771-777. 74 Stabeno, P.J., J.D. Schumacher, and S.A. Salo. 1999. Physical environment around the Pribilof Islands. In Loughlin, T.R. and K. Ohtani, eds, Dynamics of the Bering Sea, pg. 193-215 75 Gaichas, S. 2005. Bering Sea and Aleutian Islands Squids. In Bering Sea and Aleutian Islands Stock Assessment and Fisheries Evaluation Report. National Marine Fisheries Service, Alaska Fisheries Science Center
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Northern fur seals and Steller sea lions. Both of these predators have been shown to prey upon squid and other pelagic forage species in the Bering Sea and Aleutian Islands.76
Because the trawl performance standard as it currently exists makes it impossible to assess the true habitat impacts from bottom contact by pelagic trawls and little is known about the effects of pelagic trawling on pelagic habitat, it is impossible to say that the fishery is highly unlikely to reduce habitat structure and function to a point that the fishery does not cause serious harm. The measures in place through the trawl performance standard, at minimum, allow for only some confidence that serious or irreversible harm is unlikely, thus justifying a score of no more than 80 for this performance indicator.
2.4.2 Management Strategy
PI: There is a strategy in place that is designed to ensure the fishery does not pose a risk of serious or irreversible harm to habitat types.
The assessment team should have recognized that there are no protections for certain vulnerable habitat types.
We do not agree with a SG of 95. For certain VME habitats in the region (e.g. sponges, sea pens and sea whips) there are no strategies /specific protection measures in place. And we repeat our general criticism from our first input due to the fact that this input was not discussed in the PCDR. The National Research Council clearly pointed out some of the deficiencies of the management strategy.
“For practical purposes, nonpelagic trawl gear is defined as trawl gear that results in the vessel having 20 or more crabs (Chionocetes bairdi, C. opilio, and Paralithodes camstchaticus) larger than 1.5 inches carapace width on board at any time. Crabs were chosen as the standard because they live only on the seabed and they provide proof that the trawl has been in contact with the bottom.”… “However, these trawls may be frequently fished in contact with the seafloor, especially in shallow water (<50 fathoms)…. If these trawls never touch the bottom, the pelagic trawl definition could be set at zero crab tolerance. Because typical pelagic trawls have large mesh webbing in the lower section of the net and are affixed to chain footropes, bycatch enumerated by onboard observers might substantially underestimate the number of demersal fish and invertebrates that are affected because they fall through the large mesh panels instead of being captured by this gear.”77
Thus, the National Research Council acknowledges that trawl performance standard could be revised to reduce both the known and unquantified effects of pelagic trawls on benthic habitat.
Specific steps we believe the pollock fishery should take to come into better alignment with this performance indicator include:
76 Sinclair, E.H. and T.K. Zeppelin. 2002. Seasonal and spatial differences in diet in the western stock of Steller sea lions (Eumetopias jubatus). J. Mammal 83:973-990; Zeppelin, T.K. and R.R. Ream. 2006. Foraging habitats based on the diet of female northern fur seals (Callorhinus ursinus) on the Pribilof Islands, Alaska. Journal of Zoology. 77 National Research Council. 2002. Effects of Trawling and Dredging on Seafloor Habitat. National Research Council, National Academy Press, Washington, D.C.
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• Providing spatial protections for known important habitat areas including representative Bering Sea canyons, crab habitat, sponge and coral concentrations, and known skate nurseries; • Modifying pelagic trawl performance standards to ensure pelagic trawl gear does not impact the seafloor and, where appropriate, is independently verifiable; and • Conduct additional research and monitoring; including pelagic habitat identification, bycatch monitoring, increased benthic habitat mapping, and improved observer data collection and monitoring to assess benthic impacts.
Until such time as these management improvements are made by the pollock fishery, we do not believe there is a sufficient strategy to ensure that no serious or irreversible harm to habitat types is occurring. 2.4.3 Information/Monitoring
PI: Information is adequate to determine the risk posed to habitat types by the fishery and the effectiveness of the strategy to manage impacts on habitat types.
The assessment team should have considered the lack of information on vulnerable habitats.
We do not agree that sufficient data are available to justify a score of 90. There is not enough information to assess the vulnerability of many VME habitats due to missing information on species composition, recolonization rates, growth etc. There is not sufficient information to identify the nature of the impacts of the fishery. Better data on the proportion of time the footrope contacts the bottom is needed. 78 There is no analysis of the spatial extent of interaction and identified VME hotspots yet from a technical point of view this could be done now.
Bycatch of epibenthic invertebrates recorded by fishery observers on trawl vessels is a direct measure of habitat impacts by commercial fisheries. However, since not all epibenthic invertebrates that interact with a trawl are retained in the net and an unknown proportion remain crushed or broken on the seafloor, estimates of habitat impacts from bycatch records are unreliable. Additionally most observers do not have the training/background to identify VMEs or invertebrate species correctly79. All this is compounded by the lack of long term ecological monitoring and sufficient research on distinctions between trawled and untrawled habitat.
Thus, the current regulatory regime remains inadequate for assessing or addressing the risk to important habitats. With a more directed observer program, significant data gaps may be identified over time to enable the effective protection of valuable marine habitat. We recommend that in order to achieve the necessary habitat protection goals indicated above that the following steps must be taken by the pollock fleet:
• Long-term continuation of 100% observer coverage on all vessels to eliminate data bias
78 https://www.msc.org/track-a-fishery/fisheries-in-the-program/certified/pacific/bsai-pollock/Reassessment- downloads-1/14.12.2010_BSAI_Pollock_2010_Public_Certification_Report_v2.pdf 79 Stone, R., D. Stevenson, and S. Brooke. "Assessment of a Pilot Study to Collect Coral Bycatch Data from the Alaska Commercial Fishing Fleet." (2015).
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• Implementation of monitoring tools (e.g., winch sensors, video equipment) where appropriate or feasible to enhance catch monitoring and measurement • Adequate resources and methods for improving identification and enumeration of catches in all species categories, especially those species representing or comprising benthic habitat • Whole-haul observer sampling on selected vessels to test assumptions of random sampling methodology, or as needed to improve total catch measurement and ensure that confidence in the data is high
Until such time as these issues are addressed in the pollock fishery and based on the scoring guideposts of this principal indicator, we recommend a score no greater than 75.
Ecosystem
2.5.1 Outcome Status PI: The fishery does not cause serious or irreversible harm to the key elements of ecosystem structure and function.
The assessment team should have considered the indirect effects of the fishery on ETP species which are representative of ecosystem structure and function.
The information presented in the 2013 Ecosystem Considerations chapter80 directly addresses two of the examples in the FAM for reduced capacity to provide ecosystem services. The results show that neither the size composition of the ecological community or species diversity appear to be adversely impacted in the Bering Sea or Aleutian Islands, despite the fact that northern fur seal and Steller sea lion populations in the Bering Sea and Aleutian Islands are at all-time lows. The collection and accessibility of this ecosystem information also reflects favorably on the management system, yet there is still a wide gap between noting ecosystem effects and implementing ecosystem-based management measures.
The information presented above in the ETP species sections provides information regarding the declines and reduced status of two “keystone” predators, northern fur seals and Steller sea lions, that are largely dependent on pollock as a primary prey species. The results of management analyses for both species provide a plausible argument for an ecosystem level effect that constitutes possible evidence of serious or irreversible harm to the ability of the ecosystem to provide essential services due to the effects of a trophic cascade. This argument is based on both expert opinion and long-term observations from both the fishery and monitoring of predator populations that have declined to less than 50% of their estimated historical abundance. Several studies have characterized the decline of Steller sea lions in the Bering Sea as the result of a trophic cascade.81,82 However it is important to note that both of these species have also been subject to substantial direct mortality unrelated to trophic interactions with the fishery and although both species have failed to recover when the source of direct
80 NMFS. 2013. Ecosystem Considerations Chapter, Status of Stocks and Fishery Evaluation Report. 81 Merrick, R.L., 1997. Current and historical roles of apex predators in the Bering Sea ecosystem. Journal of Northwest Atlantic Fisheries Science 22, 343–355. 82 National Research Council. 1996. The Bering Sea Ecosystem. National Academies Press.
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mortality was no longer in effect, the declines do not necessarily fit into either of the trophic cascade scenarios described in the scoring guideposts.
In view of the depleted and endangered status of several important predators that are major consumers of pollock, the ecosystem outcome component should not score 100 or even 80.
2.5.2 Management Strategy PI: There are measures in place to ensure the fishery does not pose a risk of serious or irreversible harm to ecosystem structure and function.
The assessment team should have recognized the decline of keystone BSAI predators as indicators of serious harm to ecosystem structure and function.
The BSAI pollock fishery is managed using a single species management approach and as such does not explicitly take into account the needs of the larger ecosystem. The scientific review of the harvest strategy used in the BSAI groundfish fisheries commissioned by the NPFMC83 contains the following statement addressing the potential for ecosystem level effects of single species management approaches:
“A harvest management strategy, such as F40%, that by design reduces the biomass of the target stock biomass by a large fraction, will, all other things being equal, reduce the total consumption by higher trophic levels by a similar large fraction, and we would expect the predator populations to be reduced accordingly. This may or may not be deemed a desirable, or acceptable, outcome from the standpoint of policy. And, in fact, all other things often are not equal, especially in ecosystems, and there are a variety of mechanisms whereby the reduction in target stock biomass by a harvest strategy such
as F40% could cause a more than proportional reduction in the populations of predators dependent on those same stocks for prey, as is recognized in the ecosystem-effects world view.”
The depleted status of several keystone BSAI predator species is cause for concern that the single species management approach could have a negative outcome on the larger ecosystem. A possible alternative strategy that would explicitly take into account the needs of the ecosystem might entail building an additional margin of safety into the fishing mortality rate rules (such as shifting to F50% or F60% for example) or stipulating a more stringent threshold on the total allowed depression of equilibrium biomass (such as the limit adopted in the Commission for the Conservation of Antarctic Marine Living Resources Convention).
In spite of the overall single species management approach employed in the BSAI groundfish fisheries, NOAA Fisheries and the NPFMC have invested a significant effort in the development of indicators of the
83 Goodman, D., M. Mangel, G. Parkes, T. Quinn, V. Restrepo, T. Smith 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 Ave., Suite 306, Anchorage, AK 99501.
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status of marine ecosystems and impact of fishing and made considerable progress in this regard in recent years. Examples of these efforts include a number of partial strategies that have been implemented such as mass-balance food web modeling,84 and multi-species stock population-dynamics models. Each of the stock assessment reports contained in the annual SAFE documents includes a standard formatted ecosystem consideration section that may be used in the process of setting over- fishing levels and allowable biological catches, although explicitly how it is used is not clearly articulated.
Based on the effective implementation of partial ecosystem-based management approaches and progress toward incorporating ecosystem considerations into the setting of the TAC a score of 80, not 100, is appropriate for the Ecosystem Management PI.
2.5.3 Information/Monitoring PI: There is adequate knowledge of the impacts of the fishery on the ecosystem.
NMFS and the NPFMC have made considerable progress in recent years to insure that adequate knowledge exists to assess the impacts of the fishery on the ecosystem and the North Pacific fisheries. Since 1995 staff from the AFSC have prepared a separate Ecosystem Considerations chapter for the annual Stock Assessment and Fishery Evaluation (SAFE) reports. The Ecosystem Considerations are intended to provide the NPFMC with information about the effects of fishing from an ecosystem perspective and to summarize the effects of environmental changes on fish stocks85. In so doing the goal is to provide a historical perspective of status and trends of ecosystem components and ecosystem level indicators.86 As stated above, the SAFE report provides annual updates to specific ecosystem status indicators for use in assessing the status of specific ecosystem components. How or if the indicators are incorporated into the stock assessment or into management decisions is not made clear in the SAFE report. Trade-offs between harvesting fish and providing for food web components is not in a clear risk assessment format for use by decision makers. Compiling a list of indicators is far from actual implementation of measures.
In addition to fishing pressure, the BSAI ecosystem is subject to less predictable threats, including climate change, ocean acidification, pollution, and invasive species. Natural risks also exist, such as decadal warm/cold regime shifts which can greatly alter population abundances of BSAI species. Ecosystem-based fishery management would attempt to understand and buffer against these other threats by protecting the ecosystem functions of resilience, biodiversity and productivity. Protected areas and protection measures in the BSAI are only aimed at protecting productivity. The NPFMC has re- activated its ad hoc Ecosystem Committee, which is attempting to examine gaps in the NPFMC’s ecosystem-based management approach and practices in the Bering Sea, but this committee is just beginning its work and has yet to develop implementable strategies to understand of manage ecosystem impacts.
84 Aydin, K., S. Gaichas, I. Ortiz, D. Kinzey, and N. Friday. 2008. A comparison of the Bering Sea, Gulf of Alaska, and Aleutian Islands large marine ecosystems through food web modeling. NOAA NMFS Tech Memo. 233 p 85 NMFS. 2009. Ecosystem Considerations Chapter, Status of Stocks and Fishery Evaluation Report. 86 Id.
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Although there are no scoring guideposts provided for the Ecosystem Information Monitoring PI, the efforts to date to fall within the SG80 range based on the general FAM guidance, not 95.
Governance and policy
3.1.1 Legal and/or customary framework PI: The management system exists within an appropriate and effective legal and/or customary framework which ensures that it:
• Is capable of delivering sustainable fisheries in accordance with MSC Principles1 and 2; • 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.
The assessment team should have considered the failure of the management system to observe the legal rights of the Alaska Native community and the failure to meet international treaty obligations.
WWF acknowledges that the legal framework established for the pollock fishery is generally consistent with local, national, or international laws or standards that are aimed at achieving sustainable fisheries in accordance with Principles 1 and 2. However, there are improvements that could be made to the legal and customary framework established under the MSA.
The process established under the aforementioned authorities remains deficient with respect to observing legal rights owed to the Alaska Native community and, at least tentatively, the fishery as a whole is not exhibiting a respect for the law with regard to reductions in salmon bycatch.
The legal framework fails to adequately acknowledge the rights of Alaska Natives. In recent years, Alaska Native tribes have experienced increasing conflicts with established commercial fisheries in Alaska. This conflict, in part, has been exacerbated by a failure of NMFS and the NPFMC to engage in meaningful consultation and coordination with affected Alaska Native tribes87. Executive Order (EO) 13175 calls for a trust responsibility by the United States to protect tribal sovereignty and self-determination, tribal lands, assets, resources, and treaty and other federally recognized and reserved rights.88 To achieve meaningful consultation and coordination, NMFS must seek to establish and define this trust responsibility with the Alaska Native tribes. To date, NMFS has sought to achieve this trust responsibility through bulk mailing of form letters to haphazardly selected Alaska Native communities and representatives. However, trust is built through interface, interaction, genuine dialogue, and incorporation of Alaska Native views regarding actions that may affect Alaska Native tribes or the resources they depend on. Federal agencies’ trust responsibilities must reflect these elements to achieve a truly meaningful relationship with Alaska Native tribes.
87 Current tribal involvement in federal fisheries management in Alaska and possibilities for expanding tribal participation in the future. 2011. WWF Arctic Field Program, Roundtable whitepaper (attached). 88 Exec. Order No. 13,175, 65 Fed. Reg. 67,249 (Nov. 9, 2000).
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The direction in EO 13175 to engage in “meaningful” consultation with Alaska Native tribes suggests that policies that have tribal implications must defer to Alaska Native tribes to establish standards. The primary policy standard that must be met is the policy of what is “meaningful” as perceived by the respective Alaska Native tribe affected by any Federal action. The government-to-government relationship between the U.S. and the tribes mandates that the principal focus for consultation is with individual tribes.
Although NMFS has begun to establish official consultation and coordination procedures under EO 13175, there are currently no substantive provisions in place to address customary and traditional concerns of Alaska Natives consistent with the intent of the EO. The NPFMC had a Rural Outreach Committee to conduct outreach on salmon bycatch, which was a significant improvement, but this committee has not met since 2011 despite a clear need for outreach. Active and thoughtful outreach appears to have been a brief pulse of activity, rather than an ongoing dialogue or program.
This issue could also be further resolved by the establishment of an official Alaska Native seat on the NPFMC. The MSA was previously amended to establish an indigenous seat on the Pacific Fishery Management Council, but an equivalent measure was not undertaken for the NPFMC. Alaska Natives have organized to push for establishment of this seat, but have met opposition from industry and political leaders.
WWF has also become increasingly concerned about the issue of respect for laws as it relates to Chinook salmon bycatch. The U.S. Department of State has repeatedly emphasized that, under the 2002 Yukon River Agreement of the Pacific Salmon Treaty, the U.S. must meet its domestic obligation to improve escapement on the Yukon River, in part to support subsistence harvests for interior indigenous tribes in Canada. WWF believes that the NPFMC has not done enough to ensure the U.S. complies with the Pacific Salmon Treaty.
We recommended a cumulative score of 70, not 100 as the assessment team incorrectly assigned. A score of 70 is based on the judgment that the current management system only marginally observes the legal rights of people dependent on fishing for food or livelihood and that the pollock industry and the established management system collaborated to set a bycatch standard that they knew would likely be inconsistent with international treaty obligations.
3.1.2 Consultation roles and responsibilities PI: The management system has effective consultation processes that are open to interested and affected parties. The roles and responsibilities of organizations and individuals who are involved in the management process are clear and understood by all relevant parties.
The assessment team should have considered the failure of the management system to observe the legal rights of the Alaska Native community.
As detailed in 3.1.1, substantial improvements must be made to the management system to ensure proper recognition of the Alaska Native community and proper integration of traditional ecological knowledge (TEK). Thus, based on the scoring guideposts, this PI should have achieved a score no greater
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than 75 because it only marginally provides opportunity for all interested and affected parties to be involved and does not regularly seek and accept relevant TEK.
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Response to comments from WWF and Greenpeace
Introductory remarks
Many of the comments received on the Bering Sea / Aleutian Island Pollock certification assessment center on the degree to which uncertainties were considered in the scoring. In some cases it seemed that the concern from WWF and Greenpeace was that additional sources of uncertainty could have been discussed individually. In other cases the concern from WWF and Greenpeace seems to be that the scoring was overly optimistic, given the general extent of uncertainty. In addition to case-specific responses to the individual comments received, it seems efficient for the assessment team to explain the context for our scoring.
Two points were foundational in our conduct of this assessment. First, there is some uncertainty in every aspect of any marine resource assessment; uncertainty about the values of all relevant biological and oceanographic processes and parameters, uncertainties about cause-effect relationships, and uncertainties about future states of nature due to environmental variability. However many sources of uncertainty are treated explicitly in stock assessments, impact assessments, or these certification assessments; a creative biologist can always come up with some source of uncertainty that was not yet treated explicitly. Second, we assume that the 100 scoring guideposts were intended to be an attainable score for a scientifically sound assessment in a realistically data-rich condition.
Combining those two points, we concluded that a high score, even 100, could be given to a fishery without explicitly considering every imaginable source of uncertainty. Moreover, the sources of uncertainty that were addressed would not have to be added to every single parameter of every computation done in the assessment. In fact one of the key features of the Management Strategy Evaluation (MSE) frameworks used extensively now in advanced fisheries assessments is that they can provide realistic confidence intervals that capture the range of uncertainties affecting the historical time series in ways that are manageable to conduct and manageable to interpret. The performance tests of these methods, including scenario-based simulations and retrospective analyses, both in general for MSE methods and in particular for Pollock, attest to their effectiveness. Likewise the extension of these methods to ecosystem impacts has been comparably tested. If soundly conducted, these applications are considered to be robust in their estimates of the magnitude of uncertainties that need to be taken into account in management.
The exact language of the 100 Guidepost is not identical in performance indicators and scoring issues where uncertainty is a consideration. However, looking at some examples key phrasing appears each time that gives insight into what we interpret as the intent of the criteria and scoring guideposts: Examples include: 1.1.1 “There is a high degree of certainty that the stock has been fluctuating …”; 1.2.2b “The design of the harvest control rules takes into account a wide range of uncertainties”; 1.2.4a “…takes into account the major features relevant to the biology of the species and the nature of the fishery”; 2.1.1 “There is a high degree of certainty that retained species …”; 2.1.2 “Testing supports high confidence that the strategy will work …” – and repetitions of those phrases in the other corresponding parts of P2.) If 100 is taken to be an attainable score, when would we have “a high degree of certainty” or “high confidence” and what constitutes “a wide range of uncertainties” and “the major features”? Those are indeed judgement calls, and views may differ among perspectives. However, we are satisfied that there is a “high degree of certainty” from suitable results, if
BSAI Alaska Pollock – Final Report and Determination page 212 the most contemporary analytical methods were applied and interpreted correctly to data that were collected systematically and with methodological rigor. We are satisfied that a sufficiently wide range of sources of uncertainty were considered if the main biological parameters of the target or bycatch species were characterized, and known causes of variation in those parameters were included in some analytically appropriate way. Having examined the methods and data from our own expertise, and the reviews by the Center for Independent Experts and by the assessment Plan Teams, we can conclude that those conditions are often met. It was that context that guided our scoring throughout this assessment. If some of the stronger parts of these certification assessment cannot meet those standards, then we conclude that the 100 Guidepost is an unattainable score for any fishery, given the realities of the variable ocean.
Principle 1
WWF
The assessment team should have considered fishing pressure and uncertainties on the spawning stock biomass.
The assessment team feels that the current harvest strategy takes fully into account the major uncertainties, including variability of recruitment to the stock. The ways that this is achieved are explained in detail in the justification text for several of the P1 scoring criteria, since such variation and uncertainties are taken into account in the reference points, harvest strategy, and assessment methods. With regard to the specific concerns in the narrative accompanying the comment, the data in tables 1.1 and 1.27 of Ianelli et al. 2015 are particularly germane. The data in the tables do support the statement that the fishery in 2006 and 2007 did remove more than 25% of the spawning biomass. However, the harvests in those years were supported by the strong incoming year-classes, such that the resultant spawning biomass in the next year was above the biological reference points for the stock and each year was increasing. Had recruitment continued to be poor in the immediately following years (2007, 2008, 2009) SSB would indeed have declined more than it did. However, the improvement in recruitment was already established in the surveys, and application of the harvest strategy allowed both the catches in 2006 and 2007 and an increase in the next year’s spawning biomass. The assessment team feels the stock trajectory in the specified years validates the effectiveness with which the reference points and harvest strategy apply adequate precaution, and keep exploitation sustainable, fully taking the variability of recruitment into account.
With regard to fishing pressure specifically on the spawning biomass during spawning, the assessment team feels that a negative impact on spawning success by fishing during the spawning season has not been demonstrated for marine fish with life histories similar to Pollock. During the years of the roe fishery in the 1980s, both some of the strongest (1983, 1985) and some of the weakest (1987, 1988) year-classes ever recorded for this stock were produced. This indicates the variability of recruitment was the same with a directed roe fishery as it was after the roe fishery was closed. Hence there is no evidence that even directed fishing on spawners during the peak in their annual reproductive cycle decreased the likelihood that the stock could provide strong year-classes if environmental conditions were suitable, or increased the likelihood that poor year-classes would be produced.
We agree that the long term consequences of possible climate changes on the future productivity of all Bering Sea (and all oceanic) stocks, including Pollock, are incompletely known. If such changes occur in future they may indeed require adjustments to current harvest strategies. However the research in the Bering Sea on climate change is cutting edge globally, as demonstrated in IPCC Assessment Report 5, WG 2, where it was commonly featured in the adaptation work. We are satisfied that monitoring relevant to
BSAI Alaska Pollock – Final Report and Determination page 213 picking up such impacts of climate change is in place and supported by timely analyses of the data. Future reassessments will need to ensure the NMFS assessment remains vigilant to changing stock productivity. However over the coming five years there is no justification for changing right now a harvest strategy that has been exceptionally well tested for present conditions because of changes in the ecosystem that may happen some years in the future.
We see no cause for changing scoring or Justifications in the current certification assessment.
The assessment team should have considered weaknesses and uncertainties in the current stock assessment methodology, especially the amount of EBS Pollock harvested in Russia.
The scoring and justification for criterion 1.2.4 explains in detail the assessment methodology used for these stock assessments, and the range of uncertainties that they address explicitly. As highlight in the Introductory Remarks that we have prepared, no stock assessment method will ever be able to address every conceivable uncertainty that might affect a stock. However thorough an assessment team is, critics will always be able to find some additional factor that was not included explicitly. In our certification assessment we applied two key standards. First, was asking if the major known sources of uncertainty in the data sources, stock productivity, and computational methods were addressed adequately, and itemized many of these in the relevant justifications of performance indicators 1.2.3 and 1.2.4. We concluded the EBSA Pollock stock assessment is at the state of the art in their practices. Our second standard was whether the analytical results of the assessment were used in probabilistic ways (including in applying reference points and harvest control rules) to ensure the uncertainties that were well quantified were transferred into the advice (e.g., performance indicators 1.2.4c and 1.2.4d). Again we conclude this stock assessment is applying state-of-the-art practices and does consider weakness and uncertainties in the assessment methodologies. In these areas the certification assessment teams feels that no changes to the scoring or justifications are needed.
Specifically with regard to accounting for possible Russian catches of EBS pollock, we agree that this point was not featured in the justifications and scoring. However, it had been established in past certification assessments and audits that information on performance of Russian fisheries was being provided annually to NMFS, and there were exchanges of survey results and other biological information on a regular basis. This flow of information has not been altered by the changing diplomatic relations between the US and Russian Federation governments, and excellent scientist – to – scientist flows of information are maintained. All the information relevant to EBS Pollock that is acquired from Russia is being used in the annual assessments. We have been assured that when the survey results, particularly in the second half of the year, suggest that EBS Pollock distribution is nearing the international border, scientists in both countries pay particular attention to these exchanges of information. If there were large but unreported catches of EBS Pollock in Russian fisheries, then negative retrospective patterns would have to show up in the annual assessments: more fish had died during the year than could be accounted for by fishing and natural mortality. In recent years to the extent that there is any sequential discrepancies between annual assessments, they are positive retrospective patterns: more fish are surviving than expected. Hence unreported Russian catches are extremely unlikely to be contributing to greater than estimated uncertainties in the assessment. To better address this concern in the certification assessment, we proposed to add to in scoring issue 1.2.3a the following new paragraph after the current third paragraph of justification (the paragraph ending “population being ensonified”
“In some years the oceanographic conditions are such that EBS pollock may approach or even cross the international boundary with the Russian Federation. At such times they may
BSAI Alaska Pollock – Final Report and Determination page 214 be taken in Russian fisheries. These fisheries are monitored by Russian fisheries authority, and there are annual exchanges of information between the Russian and NMFS scientists. The information on any possible catches of EBS Pollock in Russian fisheries is included in the annual assessments, and the assessments have been tested for robustness to different assumptions about the reliability of these data. In addition, the EBS Pollock stock has only been noted to cover a large enough portion of the eastern Bering Sea in years when the stock was at high abundance. This further increases the robustness of the assessment methods and the harvest strategies, because the Russian catches would only be likely to be more than very small in years when the stock abundance was large.”
The assessment team should have considered uncertainties and gaps in the existing harvest limits and reference points that leave the stock vulnerable to overfishing.
The certification assessment team also feels “comfortable that a relatively adequate harvest strategy is in place” and notes that “several opportunities for improvement exist” – and will always exist. As explained in the preamble, we interpret the scoring criteria and guidance to compare fisheries to the best practices in the field, when “best practices” are sufficient to produce demonstrably sustainable outcomes. Total perfection in an ideal world is not necessary. The only “uncertainties and gaps” specified in the comments are with regard to multispecies modelling. In that field we agree there will remain for many years scope to improve multispecies model structure and the data input to them. However, the certification assessment team is satisfied that current multispecies models of the Bering Sea are among the most advanced and thoroughly tested of any such models that have been developed, as justified in several of the performance indicators under P2. Moreover, the stock assessment team is very well connected to the ecosystem modelling team and has incorporated many multispecies results into the stock assessment practices, as specified in performance indicators 1.2.1, 1.2.2 and 1.2.4. Importantly, we see no evidence that the current harvest strategy and reference points “leave the stock vulnerable to overharvesting”. Rather the evidence demonstrates that harvest strategy has preventing overfishing of the stock, even during periods of poor incoming recruitment due to adverse environmental conditions, as explained in the justification for the 1.2.2c score.
We see no cause for changing scoring or Justifications in the current certification assessment.
The assessment team should have considered uncertainties to a greater degree.
The certification assessment team has nothing to add to the points made in our Introductory Remarks. The question is not whether uncertainties exist, because they do and always will. The relevant question is whether they affect the robustness of the harvest strategy and control rules, such the stock is left vulnerable to overfishing. As argued in the justification to 1.2.2c, the evidence is just the opposite. There has been a challenge to the effectiveness of the harvest strategy and control rules, by the period of an atypically large cold pool that resulted in a series of atypically weak year-classes. The harvest strategy and control rules were found sufficient to prevent overfishing during these extreme environmental conditions.
We see no cause for changing scoring or Justifications in the current certification assessment.
The assessment team should have considered climate effects and how they are addressed, and uncertainties caused by Russian harvests on the EBS population and their effects on productivity and resilience.
These are repetitions of concerns already raised in the review. Environment influences on distribution and productivity are fully taken into account the treatment of recruitment and
BSAI Alaska Pollock – Final Report and Determination page 215 growth, and the rationales are presented in 1.2.3 justifications. The longer term possible impacts of climate change on stock productivity will have to be considered in future assessments, when the ways that the Bering Sea oceanographic and biotic conditions are affected by climate change are actually seen. However, the simulations used to test the harvest strategy do fully address the existing range of environmental conditions which the stock may encounter during the duration of the upcoming certification. Robustness of the harvest strategy to this range of environmental conditions is demonstrated by both model results and performance in the real world, as explained already in 1.2.2c. The impacts of possible Russian harvests in discussed in our response to the concern about performance indicator 1.1.1 and will not be repeated here.
We feel the paragraph added to address the issue of possible Russian catches adequately addresses this concern.
The assessment team should have considered the effects of unknown mortality on the EBS stock from Russian harvesters and uncertainty resulting from climate change.
These are exactly the same concerns as for 1.2.3 and our response is the same as well. We feel these sources of uncertain were addressed “adequately”. If the work done on the EBS Pollock harvest strategy and annual stock assessments does not meet the guideposts for 1.2.4, we conclude that the guidepost scores are presently unattainable for any real stock in an ocean where knowledge will always be incomplete and ocean climate will not remain permanently static.
Principle 2 Greenpeace and WWF
Bycatch 2.2.1 Outcome Status Despite the low bycatch rate in the BSAI Pollock fishery, WWW is concerned that given the large amount of Pollock taken in the fishery, even the observed low bycatch rate is sufficient to have a negative impact on long-lived, low-fecundity species such as skates and sharks. These species are managed under the NPFMC’s annual specification process that sets allowable harvest levels. ABCs for skate species are set using the NPFMC Tier 3 and 5 procedures, based on an age-structured model and mean biomass, respectively. Sharks are a Tier 6 complex with the OFL based on maximum historical catch between the years 1997 – 2007 (ABC is 75% of OFL). The sculpin assessment is conducted with Tier 5 methods, whereby the current estimated biomass is obtained from estimates over the past four survey years for the six most abundant species. Then an exploitation rate is applied to the estimated current biomass to obtain the ABC and OFL. Catches in the BSAI Pollock fishery relative to ABCs for these taxa indicate that the levels of skates, shark, and sculpin catches are highly unlikely to pose a serious risk.
Of the species taken as bycatch, the biomass of jellies dominate, but even here the catch is only 2% of the Pollock catch and thus is a minor species. Jellies are not considered to have a vulnerable life history as their biomass can change significantly from one year to the next, apparently influenced largely by variations in climate (Brodeur et al. 2008). Although absolute estimates of biomass are not available, relative biomass from surface and bottom trawls indicate that recent abundance of jellies is high compared to the previous 10 years (Zador 2014) and therefore catches in the Pollock fishery are highly unlikely to have serious impacts.
WWW also expressed concern about the bycatches of salmons in the EBS. The assessment did highlight the bycatches of Chinook and other salmon (primarily chum) as main species. As noted in the assessment report, lanelli and Stram (2014) provide updated estimates of the bycatch impact on Chinook salmon runs to the coastal west Alaska region and found that
BSAI Alaska Pollock – Final Report and Determination page 216 since 2011 the impact has been estimated to be below 2%. Also in 2013, the Arctic-Yukon- Kuskokwim Sustainable Salmon Initiative Chinook Salmon Expert Panel submitted a report summarizing available information and presenting seven hypotheses for the declines in salmon abundance (Schindler et al. 2013). Schindler et al. concluded that “Based on available data, the bycatch within the domestic walleye Pollock fisheries seems unlikely to have been the primary cause for the recent dramatic declines of Chinook salmon in the AYK region, because estimates of bycatch from this source are not high relative to the estimated declines in the total returns to the drainages.” Thus, the AEQ analyses and the amount of bycatch relative to the declines in abundance provide evidence that the impacts of the Chinook salmon bycatch in the Pollock fishery on returns to Alaskan rivers are expected to be small. Unfavourable ocean conditions are thought to underlie the continued low abundance of Chinook salmon stocks (references in Schindler et al 2013).
Although the bycatch of chum salmon were noted in Table 12 of the assessment report, the assessment team agrees that text supporting our scoring was lacking. We propose to add the following text “As in shown in Table 12, the bycatch level of chum salmon in the BSAI Pollock fishery varies considerably from year to year. Genetic analyses indicate that over half of chum samples in the Pollock fishery where from North and East Asian stocks, with about 20% from the Yukon and Western Alaska (Vulstek et al 2014). Abundance of hatchery chum salmon (all regions) exceeded that of wild chum salmon largely in response to high hatchery production in Japan. During the 1990s, hatchery production of adult fish averaged 76 million chum salmon. Wild chum salmon abundance averaged approximately 47 million fish per year, through 2000 (Mantua et al. 2009). Given the level of bycatch (<1%) relative to the estimated abundance of wild stocks, there seems little chance that the bycatch poses serious threat to chum salmon stocks.”
2.2.2 Management Strategy In their comments, WWW contend that there is no strategy for managing salmon bycatch in the BSAI Pollock fishery. However, the assessment team notes that management measures taken to reduce the bycatch of Chinook salmon have been effective as catches have been reduced and maintained well below the cap since 2009. A number of measures have been taken by the NPFMC and endorsed by the fishery that together constitute a strategy for reducing Chinook bycatch and other non-salmon species.
Also noted in the assessment report, the Council has been developing additional measures to reduce the bycatch of chum salmon in the BSAI Pollock fishery for several years (see Council documents on their website). As measures have yet to be implemented and tested, a strategy is not in place currently and therefore SG 100 is not met for chum salmon. Nevertheless, closures and rolling hotspots have been used to minimize chum salmon bycatch and to keep bycatch within biologically acceptable levels thus satisfying the SG 80.
ETP Species 2.3.1 Outcome Status Direct effects WWW expressed concern that the direct effects of the Pollock fishery on Northern right whales had not been adequately addresses in the assessment report, while at the same time acknowledging the direct effects were unlikely as no incidental catch of the Northern right whale has been observed in the Pollock fishery. We acknowledge that a direct interaction between Northern right whale and the Pollock fishery is conceivable given their spatial overlap. Nevertheless, evidence clearly indicates that there is a high degree of certainty that the fishery does not currently pose a threat to this species.
Indirect effects WWW raised concern about that indirect effects of the fishery were not adequately addressed in the cases if three species known to consume Pollock, namely Steller sea lions,
BSAI Alaska Pollock – Final Report and Determination page 217 northern fur seals, and ribbon seals. Although they were included in the WWW submission, the team notes that ribbon seals are not an ETP species. They cite the 2007 Alaska Groundfish Harvest Specifications EIS and several other older references as the basis for their conclusion. However, since then new measures have been taken (http://alaskafisheries.noaa.gov/sustainablefisheries/sslpm/eis/default.htm) that restricts groundfish fishing in the AI to ensure the groundfish fisheries are not likely to result in jeopardy of continued existence or adverse modification or destruction of designated critical habitat for the western DPS of Steller sea lions. The most recent Biological Opinion also concluded that the modified protection measures are not likely to jeopardize the continued existence of the western DPS of Steller sea lions or adversely modify designated critical habitat (http://alaskafisheries.noaa.gov/protectedresources/stellers/esa/biop/2014/final0414.pdf.) WWW also point to a 2013 unpublished paper by Conn et al. (2014, published version) as evidence that indirect effects of the Pollock fishery on Steller sea lion dynamics may not have been adequately considered. This paper uses simulation to explore possible relationships between Steller sea lions, a single hypothetical prey, and a fishery on that prey. The paper concludes that the statistical power to detect a negative effect of fishing on Steller sea lions, from the correlation studies that have been conducted to date, may often be low and therefore it may be premature to conclude, on the basis of finding no impact, that there is none. This is a useful contribution, but as the authors’ conclude, further study will be needed to determine the power of such tests under more realistic conditions, such as Steller sea lion prey dependence and frequency of abundance surveys. The assessment team agrees with WWW that some uncertainty remains, and hence the SG100 level is not met, but we conclude that indirect effects have been considered and evidence suggests that those effects, specifically competition for prey, are thought unlikely to create unacceptable impacts.
In regard to North fur seals, WWW notes that more recent pup production estimates are available since the draft assessment was completed. The assessment team has updated the report with the most recent estimates (available at https://www.afsc.noaa.gov/nmml/PDF/2014-nfs-pup-counts-pribs.pdf). The assessment team agrees with the WWW observation that there is an opportunity for competition with the Pollock fishery as foraging trips by females from St. Paul Island do overlap with the fishery and northern fur seal females do consume Pollock. We also agree that this overlap does not, in itself, establish a cause and effect relationship between removals from the Pollock fishery and female reproductive performance. The EIS on harvest specifications (NOAA 2007) stated that the probability of adverse impacts stemming from spatial or temporal concentration of fisheries in Northern fur seal foraging areas were lowered given that (1) 45 % of the catch from both fisheries occurs during the A season in winter when female and juvenile male fur seals are not commonly found in the areas fished, (2) the pollock fisheries do not target fish younger than 3 years of age, which is the size preferred by foraging fur seals, and (3) the Pribilof Islands Habitat Conservation Zone limits prey removals in waters surrounding the Pribilof Island rookeries. Although, there is no evidence that the removal of Pollock negatively impacts fur seal dynamics, this is an area of some uncertainty and there is room for differences in interpretation. However, the assessment team considers that indirect effects of the fishery have been consider and are not thought to create unacceptable impacts, supporting a score of 80 for this scoring issue.
2.3.2 Management Strategy WWW expressed concern that the management strategies in place are insufficient to protect Steller sea lions and Northern fur seals. While expressing concern, WWW also acknowledged that “there is a basis for confidence that the Steller sea lion protection measures may be working to reduce direct impacts on the species”. The assessment team agrees and would further argue that the suite of measures implemented by the Council constitute a comprehensive strategy for managing the fishery’s impact, thus meeting the
BSAI Alaska Pollock – Final Report and Determination page 218 SG100 level. Management measures stipulated by the MMPA are in place to limit the direct effects of the Pollock fishery on both Steller sea lions and Northern fur seals, and information from the fishery demonstrates that these measures are effective.
Although there is a strategy to minimize the direct effects, the EIS (NOAA 2007) concluded that conditionally significant adverse indirect effects could occur with changes in harvesting activity and/or concentration of harvesting activity in space and time, such as increased groundfish fishing in fur seal habitat during June through August. Studies during the summer breeding season at the Pribilof Islands have shown female trip duration is longer than at Bogoslof Island where the population is increasing and pup growth rates and weaning masses are less. These results do indicate that females are working harder but are rearing smaller pups (Springer et al. 2010). Although, there is no convincing evidence that adverse indirect effects of the Pollock fishery are taking place, at the same time it cannot be concluded that there is a high degree of confidence that there are no detrimental effects. Therefore, the assessment team agrees current management measures do not merit a score of 100, but the SG80 level is met. On the basis of our re-assessment, we score PI 2.3.2 at the SG95 level.
Habitat
2.4.1 Outcome Status Benthic habitats In their comments, WWW and Greenpeace expressed concern that the impact of the Pollock fishery on bottom habitats had not been fully evaluated in the assessment. Table 11 of the PCDR shows that epifauna, in the aggregate, varied from 20 to 55 mt from 2010 to 2014. Given that pelagic trawls are designed with large-size leading mesh to fish primarily above the bottom, and touch bottom where smooth enough, infauna are not retained in the net. As noted in the PCDR, epifauna and infauna together make up such a small amount of bycatch given the very wide distribution of the fishery across the Bering Sea that the assessment team considered them di minimis from the point of view of pelagic trawl impacts. WWW also pointed out that habitat elements should have been scored individually. The assessment team agrees and has now provided individual scoring for the following living structure-forming taxa, corals, sponges, and the combined group of sea pens and sea whips – see revised assessment report. On the overall assessment of outcome status, both WWW and Greenpeace pointed to the fact that the pelagic gear used in the Pollock fishery does make some contact with the bottom, that damage of sensitive fauna results from that contact, and that sensitive habitats overlap the area fished for BSAI Pollock. The assessment team agrees with these points, but notes that it is precisely these issues that the fishery effects modelling of EFH evaluated (NOAA 2005). In the EFH assessment, separate sensitivity and recovery rates were derived and applied to each organisms making up infaunal prey, epifaunal prey, living structure, and non-living structure habitats. A CIE review of the model found it to be a reasonable approach for assessing impacts (Drinkwater 2004) and a re-assessment of EFH found no basis for changing the assessments of impacts (NMFS 2010).
The assessment team’s current scoring of outcome status is heavily influenced by updated estimates on the intensity of fishing with pelagic trawls in the Bering Sea (http://alaskafisheries.noaa.gov/habitat/efh/review/efh_5yr_review_sumrpt.pdf) and the extensive field studies, statistical analyses and habitat modelling conducted by NMFS through 2014 and briefly summarized in the PCDR. During the period 2003-2007, although the same number of fishing blocks were fished, the intensity of fishing (total area swept in 100 km2 block units) significantly decreased. Furthermore, the estimated maximum area of seafloor potentially disturbed by all trawls (pelagic trawl not listed separately) was only about 10% of the area of the Bering Sea from the mid-1990s though 2010 (Zador 2013). The recent benthic habitat field research conducted by NMFS covers most of the area fished for
BSAI Alaska Pollock – Final Report and Determination page 219 Pollock in the BSAI, and used information from a variety of sources and platforms to characterize benthic habitats and to assess vulnerability of impact to corals, sponges and sea pens/whips from pelagic trawling. The authors of these studies examined the spatial overlap of fishing and vulnerable habitats by combining the probability of coral, sea whip and sponge presence, fishing effort distributions, and an index of susceptibility to damage by fishing. The probability of coral, sea whip, and sponge presence was based on the predictive maps produced by the GAM modeling. These predictions were validated using data from drop camera images (Rooper et al. 2014). For the susceptibility index, each coral and sponge taxon was scored for vulnerability to damage from fishing based on visual observations of damage rates from the central Aleutian Islands and the height and rigidity of the specimens. The small fraction of the habitat disturbed by trawling, coupled with the low catches of corals, sponges and sea whips, their widespread distribution, and modeling and widespread video imagery provide evidence that serious and irreversible harm does not occur. Nevertheless, the authors of these studies acknowledge the limitations of this research and the need for better information and further validation. The assessment team considers that a score of 85 is warranted for this PI.
Pelagic habitats
WWW raised concern about the concentration of squid bycatch in the Pollock fishery as a pelagic habitat issue. Squid bycatch is addressed earlier in the assessment report under 2.1.1. The team notes that despite the concern about the spatial concentration of the bycatch (considered a minor species as a percentage of catch), the level of bycatch is less than the ABC for this group and is therefore highly likely to be sustainable.
2.4.2 Management Strategy In their comments WWW is of the opinion that current management measures are insufficient to ensure that the fishery does not pose serious or irreversible harm to habitats. Greenpeace also expressed concern that sufficient protection has not given to the areas in and near the Pribilof and Zhemchug Canyons. As noted in the PCDR (Section3.4.11 and listed in the BSAI FMP) a number of management measures have been implemented to ensure that the pollock fishery does not pose a serious risk to benthic habitat. First and foremost is the restriction of gear used in the fishery to pelagic trawl. Long-term Effects Impact analysis on benthic habitat estimated that Pollock pelagic trawling would result in a 4.6% and 7.2% reduction in habitat features for the most sensitive features in sand/mud and slope biostructure, respectively (NOAA 2005, Table B.2-10). Other specific measures include: fishing with trawl vessels is not permitted year-round in the Crab and Halibut Protection Zone and the Pribilof Island Habitat Conservation Area; bottom contact gear is prohibited in the Aleutian Islands Coral and Alaska Seamount Habitat Protection Areas year- round; and marine mammal measures in Aleutians reduce impact on benthic habitats. VMS and NMFS-certified observers verify location of fishing and catch composition and quantities, including at-sea discards, and collect biological information on all marine resources. Nevertheless, the team agrees that although there is a strategy in place for managing risk to habitat, evidence is needed to determine if the objectives of the strategy are being met. Therefore a score of 95 is given for this PI.
2.4.3 Information Monitoring WWW notes that because information on the species composition is lacking or incomplete for many vulnerable marine ecosystems that the team’s score of 90 is not justified. In the team’s view, this characterization seems harsh given the highly successful and informative studies of benthic habitat undertaken by NMFS in recent years. These studies have mapped large areas of the Bering Sea, including most of the area fished for pollock, with special attention to corals and other vulnerable benthic species. Predictive habitat models have been validated with widespread video imagery. For the most part identification has been made at the lowest possible taxonomic level, but many species have been combined for the
BSAI Alaska Pollock – Final Report and Determination page 220 sake of statistical analysis. However, Sigler et al (2015) noted that one limitation of the current state of knowledge is that the low numbers of individual corals encountered and taxonomic uncertainty of other invertebrates required a pooling of species into 3 general groups. The ecological requirements of individual species within these groups may differ and manifest as differences in their spatial distributions, which modeling general groups will mask. Council has also called on AFSC to report in the Ecosystem SAFE chapter both changes in coral frequency, composition and distribution in the trawl survey and changes in trawl effort in areas of model predicted coral abundance. Therefore, a score of 85 is given for this PI.
Ecosystems 2.5.1 Outcome Status WWW contends that the assessment team should have considered the indirect effects of the Pollock fishery on ETP species in the context of the ecosystem. Perhaps this is another issue where there is a difference in interpretation of the MSC standard. The assessment team explicitly addressed the issue of possible indirect effects of the fishery on Steller sea lions and Northern fur seals under ETP species. Under ecosystems PI 2.5.1, the intent is to evaluate the impacts of the fishery at the level of the broader ecosystem, which the team believes we have done. An extensive database from the BSAI has been used to construct state-of-the-art ecosystem models that have been used as tools in the evaluation of the effects of the Pollock fishery in this broader context. In addition, the Ecosystem Considerations SAFE uses the most recent data to annually update a number of physical and biological indices of ecosystem performance, including those related to fisheries effects. Therefore, the team believes its scoring of this issue is justified.
2.5.2 Management Strategy WWW argues that the BSAI Pollock fishery is managed using a single-species management approach that does not recognize the needs of the ecosystem. Again, the team disagrees with this point of view. However, the team does agree with WWW that “NOAA Fisheries and the NPFMC have invested a significant effort in the development of indicators of the status of marine ecosystem and the impact of fishing and made considerable progress in recent years”. As noted in the PCDR, 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. The Council‘s Ecosystem Committee provides advice to the Council on ecosystem issues and new ways for the Council to engage in ecosystem-based management. Ecosystem considerations accompany each species’ stock assessment. A system of time-area closures and restrictions on gear, the designation of HAPCs, Steller sea lion measures, prohibited species limits, and other measures listed in section 3.4.11 of the PCDR provide ample evidence that there is strategy in place to ensure that the fishery does not pose a risk to the ecosystem. The comprehensive nature of the strategy meets the SG100 level.
2.5.3 Information Monitoring The assessment team agrees with many of the observations expressed by WWW in their public comment. The ongoing stream of relevant information from the fishery, the Observer Program, fish and invertebrate abundance surveys, ecological studies of marine mammals, fish, and invertebrate species, benthic habitats, and physical and biological oceanography, coupled with statistical analyses and ecosystem level modelling provide state-of-the-art monitoring of the ecosystem. Thus, the team feels justified in concluding that information is sufficient to support the development of strategies to manage ecosystem impacts and therefore a score of 95.
BSAI Alaska Pollock – Final Report and Determination page 221 Principle 3
PI 3.1.1 Legal and Customary Framework WWF claims that the management system fails to observe the legal rights of the Alaska Native community and fails to meet international treaty obligations. The assessment team concludes that the WWF comments greatly overstate any such problems in this regard.
WWF acknowledges that the legal framework established for the pollock fishery is generally consistent with local, national, or international laws or standards that are aimed at achieving sustainable fisheries in accordance with Principles 1 and 2. However, WWF alleges that the management system remains “deficient with respect to observing legal rights owed to the Alaska Native community and, at least tentatively, the fishery as a whole is not exhibiting a respect for the law with regard to reductions in salmon bycatch.” The assessment team maintains that the management system observes the legal rights of the Alaska Native Communities, and meets treaty obligations, as detailed below.
Observing legal rights and meeting treaty obligations
The State Department and NOAA Fisheries conducted a formal tribal consultation prior to the April 2015 Council meeting. The report, which the assessment team previously reviewed, is found at: https://alaskafisheries.noaa.gov/tc/chinook_bycatch/beringsea- salmon0415.pdf. The report documented a clear exchange of ideas from the native communities and the US government. The report further documented outreach meetings that have occurred in rural communities to listen to concerns and gather input. The implications on low Chinook runs formed the primary basis of discussion. This consultation followed previous consultation by the North Pacific Council Rural Outreach Committee formed to obtain and provide information from and to Native Alaskan communities http://www.npfmc.org/committees/rural-outreach-committee/.
Subsequently, in April 2015, the Council passed a package of Chinook and chum salmon bycatch reduction measures for implementation in 2016-2017 http://www.npfmc.org/salmon- bycatch-overview/bering-sea-chinook-salmon-bycatch/. Specifically, the Council action incorporates chum salmon avoidance into Amendment 91 Incentive Plan Agreements, includes more strict requirements for IPAs, requires salmon excluder devices, establishes penalties for vessels that consistently have high bycatch relative to the fleet, adjusts seasonal allocations, and lowers the hard cap and performance standard by 25% in years of low Chinook abundance. This is substantial evidence that the management authority meets the 100 SGs for the P3 PIs at issue.
WWF also advocates for a designated Alaska Native seat on the North Pacific Council. The inference is that the management authority is not open to the views of Native stakeholders, and that is not the case. In fact, over many years, a representative of Alaska Native communities has served on the Council. Currently, Simon Kineen of the Norton Sound Economic Development Council is a voting member. Mr. Kineen succeeded Eric Olson, who served several terms including serving as Council chairman. This demonstrates continuous representation on the Council for over a decade.
The NPFMC and NMFS further consult with the Native Alaskan communities through the Western Alaska Community Development Quota (CDQ) program created by the Council. A link to a NOAA report https://alaskafisheries.noaa.gov/cdq/cdqprogsummary.pdf shows that Western Alaska Native communities have been allocated 10.7% of the target and non-target catches of all BSAI groundfish even though such communities had no historical participation in these fisheries. The CDQ program also includes allocations of annual harvest levels of sablefish, halibut, and crab. The report also estimates that 80% of royalties derived by Western Alaska communities come from the Alaska pollock fishery.
BSAI Alaska Pollock – Final Report and Determination page 222
Salmon Bycatch Management
Alaska state salmon fishery managers and independent scientists agree that Chinook salmon bycatch is not material to the recovery of Western Alaska salmon populations. An expert panel concluded that the weak runs of concern were due to anthropogenic fluxes of other salmon species that compete for food in the marine environment (See: http://www.aykssi.org/wp-content/uploads/AYK-SSI-Chinook-Salmon-Action-Plan- 83013.pdf). The importance of this report is not only the finding that salmon bycatch under the current management regime is not a significant factor in Chinook population declines, but it provides clear evidence that federal and state fishery managers – even beyond those subject to evaluation in this assessment – continue to work closely with affected Western Alaska native stakeholders. Western Alaska Native organizations participated as full partners on a steering committee overseeing the expert panel. The findings of the AYK expert panel were not disputed by the steering group that included the Native stakeholders. A Chinook salmon adult equivalent (AEQ) analysis (Ianelli and Stram 2014) and NMFS conclusions (Balsiger 2012) further supporting the conclusion that pollock bycatch of salmon does not adversely impact Yukon salmon,
It follows that since Chinook bycatch in the Alaska pollock fishery is not material to the recovery of Western Alaska salmon stocks, then Alaska pollock federal fishery managers are not responsible for inadequate escapement of Yukon River Chinook into Canada in past years. It also follows that the pollock fishery management does not violate any requirements of the Pacific Salmon Treaty, as the pollock fishery does not adversely impact the size of the Yukon runs. It does not appear that the Pacific Salmon treaty has explicit requirements for the Yukon River. As stated on the Pacific Salmon Commission website http://www.psc.org/about_treaty.htm “In 1985, the Pacific Salmon Treaty included a commitment by Canada and the United States to carry on further negotiations concerning Yukon River salmon. The Parties exchanged notes concluding an agreement on Yukon River salmon in December 2002. There is a formal relationship between the Yukon Agreement and the Pacific Salmon Commission in that the Yukon River Agreement forms Chapter 8 of the Pacific Salmon Treaty. However, the Pacific Salmon Commission has no legal responsibility to administer the Yukon Agreement or to oversee the work of the Yukon Panel.” Rather, the Yukon Panel makes recommendations to authorities in Alaska and the Canadian government concerning the conservation and coordinated management of salmon originating in the Yukon River http://www.psc.org/pubs/27thAnnualReport.pdf. Even so, the NPFMC and NMFS have monitored the situation of Yukon and other salmon stocks and have taken action to prevent hindering the recovery of the salmon stocks by US fisheries in the BSAI.
In summary, the attention to Native communities’ interests forms an important part of the Council and NMFS policies and actions.
PI 3.1.2 Consultation, Roles, and Responsibilities
WWF claims that substantial improvements must be made to the management system to ensure proper recognition of the Alaska Native community and proper integration of traditional ecological knowledge (TEK), as the management system only marginally provides opportunity for all interested and affected parties to be involved and does not regularly seek and accept relevant TEK. The assessment team concludes that the NPFMC does seek and use TEK, as indicated in the public review documents for Bering Sea Salmon Bycatch Management Measures (NPFMC 2015).
In February 2014, the Council adopted an Ecosystem Policy to guide all of the Council’s work, including long‐term planning initiatives, fishery management actions, and science
BSAI Alaska Pollock – Final Report and Determination page 223 planning to support ecosystem‐based fishery management. The implementation Strategy section of the Policy specifically acknowledges the importance of local and traditional knowledge http://www.npfmc.org/management-policies/: Implementation Strategy - The Council intends that fishery management explicitly take into account environmental variability and uncertainty, changes and trends in climate and oceanographic conditions, fluctuations in productivity for managed species and associated ecosystem components, such as habitats and non-managed species, and relationships between marine species. Implementation will be responsive to changes in the ecosystem, and our understanding of those dynamics, incorporate the best available science, including local and traditional knowledge, and engage scientists, managers, and the public (emphasis added).
The NPFMC’s rural outreach committee (see section 3.5.1 of the assessment report) formulated a multi-year rural outreach plan, to meet with salmon stakeholders in western Alaska villages, to hear their ideas and concerns, and to incorporate them into the decision documents for minimizing and reducing BSAI salmon bycatch in the BSAI pollock fisheries prior to council action. This was done over a period of 2-3 years, and was a concerted effort by the NPFMC to understand and incorporate both local knowledge and TEK. This outreach plan included meetings in rural communities and statewide teleconferences to try to reach more stakeholders. The information from this consultation was used in the development of the public review document of the Bering Sea Salmon Bycatch Management Measures (NPFMC 2015), e.g., Chapter 3.4.7 subsistence Utilization of Alaska Chinook and Chum Salmon, and Appendix A-4 Subsistence Utilization of Alaska Chinook and Chum Salmon. References in these sections demonstrate a long list of sources that extended beyond NMFS and NPFMC staff. One of the main purposes of these actions was in response to Alaska Native and rural community feedback that in times of low Chinook abundance, any and all sources of removals, including bycatch in marine waters, needs to be evaluated and minimized.
TEK refers to the evolving knowledge acquired by indigenous and local peoples over hundreds or thousands of years through direct contact with the environment. This knowledge is specific to a location and includes the relationships between plants, animals, natural phenomena, landscapes and timing of events that are used for lifeways, including but not limited to hunting, fishing, trapping, agriculture, and forestry (USFWS 2011).
The team has considered that TEK has had no opportunity to consider the types of information used in determining the impacts of the pollock fishery on western Alaska Chinook and chum stocks. For example, calculation of adult equivalents or the use of tagging and genetics to determine stock composition of the salmon bycatch in the pollock fishery require use sophisticated science and technology. Therefore, the team considered that the NPFMC has sought, received, used, and reported on TEK. The NPFMC used traditional science to a greater degree than it used TEK for the determination of the impacts of the pollock fishery on western Alaska Chinook and chum stocks. This resulted in a conclusion strongly supported by the best available science. However, the assessment team did consider that the management system did not explicitly explain how it used or did not use TEK. This resulted in a score of 95 for this indicator.
BSAI Alaska Pollock – Final Report and Determination page 224 www.msc.org
Marine House 1 Snow Hill London EC1A 2DH United Kingdom Tel: +44 (0)20 7246 8900 Fax: +44 (0)20 7246 8901 Date: 20/11/2015 SUBJECT: MSC Review and Report on Compliance with the scheme requirements Dear Robert Trumble Please find below the results of our partial review of compliance with scheme requirements. CAB MRAG Americas, Inc (MRAG) Lead Auditor Robert Trumble Fishery Name Alaska pollock - Bering Sea and Aleutian Islands Document Reviewed Public Comment Draft Report Ref Type Page Requirement Reference Details PI 18408 Major 92, 103, 112 CR-27.10.6.2 v.1.3 The rationale shall make direct reference to every PI 1.1.2, scoring issue a: The rationale presented for 1.1.2, 1.2.2, scoring issue and whether or not it is fully met. scoring issue a is inadequate to directly address the 1.2.4 scoring guideposts. Simply referring to guidepost b does not allow clear justification for why the assessment meets the SG80 level for scoring issue a. A full rationale specific to scoring issue a is required to demonstrate that the scoring issues are fully met. PI 1.2.2, scoring issue a: As per the MAJOR finding for PI 1.1.2, scoring issue a requires information specific to the guideposts. Amend as per previous TO comment. PI 1.2.4, scoring issue b: As per previous TO comment for PI 1.2.2 and PI 1.1.2.
MSC – the best environmental choice In seafood Company Reg. 3322023 Limited by guarantee. Registered Office: 1 Snow Hill London EC1A 2DH Registered Charity No. 1066806 Page 1 of 4 www.msc.org 18409 Major 126, 145 CR-27.10.6 v.1.3 To contribute to the scoring of any PI, the team PI 2.2.1, In the GoA report halibut is considered main 2.2.1, 2.4.1 shall verify that each scoring issue is fully and as a 'highly valued' species, yet is not considered main unambiguously met. in this report. No rationale on the discrepency is provided.
PI 2.4.1, scoring issue a: The connect betweeen the evidence presented in percentage of damamged habitat and whether that can be considered serious or irreversible harm is not fully explained. Furthermore, the closing rationale for this PI states: "These findings, summarized in Rooper et al. (unpublished manuscript) provide evidence that the pollock fishery is unlikely to reduce habitat structure to the point of serious or irreversible harm." note that likelihood levels at SG80 and SG 100 are "highly unlikely" 18412 Minor 72 CR-27.12.1.5 v.1.3 27.12.1 The CAB shall determine if the systems of The report mentions on page 72 that catch is tracking and tracing in the fishery are sufficient to sometimes offloaded to foreign transhipment vessels make sure all fish and fish products identified and (trampers). It is not clear whether these transhipment sold as certified by the fishery originate from the points require CoC, nor where product flows from certified fishery. The CAB shall consider the these trampers. For example, is product landed at the following points and their associated risk for the eligible points of landing or elsewhere? integrity of certified products: 27.12.1.5 Any transhipment activities taking place.
MSC – the best environmental choice In seafood Company Reg. 3322023 Limited by guarantee. Registered Office: 1 Snow Hill London EC1A 2DH Registered Charity No. 1066806 Page 2 of 4 www.msc.org 18413 Guidance 73 CR-27.12.2.1 v.1.3 27.12.2 If the CAB determines the systems are On page 73 the report states that pollock caught as by- sufficient, fish and fish products from the fishery product in the Pacific cod and Alaska flatfish fisheries may enter into further certified chains of custody are eligible to be sold as certified through and be eligible to carry the MSC ecolabel. The CAB "agreement." The report should clarify how this shall determine: 27.12.2.1 The scope of the fishery agreement addresses risks to CoC, to ensure only certificate, including the parties and categories of product eligible to be sold as certified enters certified parties eligible to use the certificate and the point chains of custody. (s) at which chain of custody is needed. a. Chain of custody certification shall always be required following a change of ownership of the product to any party not covered by the fishery certificate. b. Chain of custody certification may be required at an earlier stage than change of ownership if the team determines that the systems within the fishery are not sufficient to make sure all fish and fish products identified as such by the fishery originate from the certified fishery. c. If the point where chain of custody certification is required is covered by the fishery certificate, the team shall determine the parties or category of parties covered by the fishery certificate that require chain of custody certification. 18417 Minor 72, 73 CR-27.12.1.6 v.1.3 27.12.1 The CAB shall determine if the systems of The report does not state the number and/ or location tracking and tracing in the fishery are sufficient to of points of landing. make sure all fish and fish products identified and sold as certified by the fishery originate from the certified fishery. The CAB shall consider the following points and their associated risk for the integrity of certified products: 27.12.1.6 The number and/or location of points of landing.
This report is provided for action by the CAB and ASI in order to improve consistency with the MSC scheme requirements; MSC does not review all work products submitted by Conformity Assessment Bodies and this review should not be considered a checking service. If any clarification is required, please contact Megan Atcheson on [email protected] for more information.
MSC – the best environmental choice In seafood Company Reg. 3322023 Limited by guarantee. Registered Office: 1 Snow Hill London EC1A 2DH Registered Charity No. 1066806 Page 3 of 4 www.msc.org Best regards, Fisheries Oversight Director Dan Hoggarth Marine Stewardship Council
cc: Accreditation Services International
MSC – the best environmental choice In seafood Company Reg. 3322023 Limited by guarantee. Registered Office: 1 Snow Hill London EC1A 2DH Registered Charity No. 1066806 Page 4 of 4 Assessment team response to MSC TO
MSC Reference 18408: In an effort to economize on text and reduce duplication, the assessment team referenced scoring adjacent scoring issues rather than specifically address the scoring issue for PIs 1.1.2, 1.2.2, and 1.2.4. The text in the referenced scoring issues contained relevant information. The text required to specifically address these scoring issues has been transferred into the appropriate box for the Final Report to explicitly comply with the MSC requirements.
MSC Reference 18409: PI 2.2.1: MSC notes that Pacific halibut was listed as Main in the GOA re-assessment report in PI 2.2.1, but not in the BSAI re-assessment report. The listing in the GOA report was an error: the introductory text (Section 3.4.8) clearly specifies Pacific halibut as a di minimis species because of the low amounts of bycatch mortality. The reference to Pacific halibut as Main in the GOA was removed.
PI 2.4.1: In response to Greenpeace and WWF comments, this section was rewritten to further describe the habitat elements, and the information available to draw conclusions on those elements. The team has provided a rationale to link damage and harm.
MSC Reference 18412: The transfers of product to foreign transhipment vessels and CoC requirements are now clarified in Sections 5.2 and 5.3.
MSC Reference 18413: The report now clarifies the agreement among the certified Alaska groundfish fisheries and addresses CoC risks from the agreement in Sections 5.3.
MSC Reference 18417: The report was rewritten to clarify number and points of landing.
BSAI Alaska Pollock – Final Report and Determination page 226 Appendix 4. Surveillance Frequency
BSAI Alaska Pollock – Final Report and Determination page 227
Appendix 5. Client Agreement (REQUIRED FOR PCR)
The report shall include confirmation from the CAB that the Client has accepted the PCR. This may be a statement from the CAB, or a signature or statement from the client. (Reference: CR: 27.19.2)
BSAI Alaska Pollock – Final Report and Determination page 228
Appendix 5.1 Objections Process (REQUIRED FOR THE PCR IN ASSESSMENTS WHERE AN OBJECTION WAS RAISED AND ACCEPTED BY AN INDEPENDENT ADJUDICATOR)
The report shall include all written decisions arising from an objection. (Reference: CR 27.19.1)
BSAI Alaska Pollock – Final Report and Determination page 229