Seafood Watch Seafood Report

Walleye Pollock Theragra chalcogramma

(Image © Scandinavian Fishing Yearbook / www.scandfish.com)

Alaska

Final Report Original Report Dated August 15, 2005 Updated November 23, 2009

Robin Pelc, Ph.D. Fisheries Research Analyst Monterey Bay Aquarium

Jesse Marsh Fisheries Research Manager (former) Monterey Bay Aquarium

Stephanie Danner Fisheries Research Manager Monterey Bay Aquarium

Timothy Theisen Consulting Researcher Seafood Watch® Alaska Pollock Report November 23, 2009

About Seafood Watch® and the Seafood Reports

Monterey Bay Aquarium’s Seafood Watch® program evaluates the ecological sustainability of wild-caught and farmed seafood commonly found in the United States marketplace. Seafood Watch® defines sustainable seafood as originating from sources, whether wild-caught or farmed, which can maintain or increase production in the long-term without jeopardizing the structure or function of affected ecosystems. Seafood Watch® makes its science-based recommendations available to the public in the form of regional pocket guides that can be downloaded from www.seafoodwatch.org. The program’s goals are to raise awareness of important ocean conservation issues and empower seafood consumers and businesses to make choices for healthy oceans.

Each sustainability recommendation on the regional pocket guides is supported by a Seafood Report. Each report synthesizes and analyzes the most current ecological, fisheries and ecosystem science on a species, then evaluates this information against the program’s conservation ethic to arrive at a recommendation of “Best Choices”, “Good Alternatives” or “Avoid”. The detailed evaluation methodology and description of the process for developing recommendations are available at www.seafoodwatch.org. In producing the Seafood Reports, Seafood Watch® seeks out research published in academic, peer-reviewed journals whenever possible. Other sources of information include government technical publications, fishery management plans and supporting documents, and other scientific reviews of ecological sustainability. Seafood Watch® Research Analysts also communicate regularly with ecologists, fisheries and aquaculture scientists, and members of industry and conservation organizations when evaluating fisheries and aquaculture practices. Capture fisheries and aquaculture practices are highly dynamic; as the scientific information on each species changes, Seafood Watch®’s sustainability recommendations and the underlying Seafood Reports will be updated to reflect these changes.

Parties interested in capture fisheries, aquaculture practices and the sustainability of ocean ecosystems are welcome to use Seafood Reports in any way they find useful. For more information about Seafood Watch® and Seafood Reports, please contact the Seafood Watch® program at Monterey Bay Aquarium by calling 1-877-229-9990.

Disclaimer Seafood Watch® strives to have all Seafood Reports reviewed for accuracy and completeness by external scientists with expertise in ecology, fisheries science and aquaculture. Scientific review, however, does not constitute an endorsement of the Seafood Watch® program or its recommendations on the part of the reviewing scientists. Seafood Watch® is solely responsible for the conclusions reached in this report.

Seafood Watch® and Seafood Reports are made possible through a grant from the David and Lucile Packard Foundation.

1 Seafood Watch® Alaska Pollock Report November 23, 2009

Table of Contents

I. Executive Summary……………………………………………………………………3

II. Introduction……………………………………………………………………………6

III. Analysis of Seafood Watch® Sustainability Criteria for Wild-caught Species Criterion 1: Inherent Vulnerability to Fishing Pressure……………………………10 Criterion 2: Status of Wild Stocks…………………………………………………12 Criterion 3: Nature and Extent of Bycatch…………………………………………24 Criterion 4: Effect of Fishing Practices on Habitats and Ecosystems…………...... 42 Criterion 5: Effectiveness of the Management Regime……………………………55

IV. Overall Evaluation and Seafood Recommendation…………………………………...68

V. References……………………………………………………………………………..71

VI. Appendices…………………………………………………………………………….88

2 Seafood Watch® Alaska Pollock Report November 23, 2009

I. Executive Summary

Walleye pollock (Theragra chalcogramma) is one of the largest single-species fisheries in the world. Pollock is used predominantly in the production of frozen fillets, fish sticks, and a broad range of fish “paste” (surimi) products. In the U.S., common surimi products include imitation crab, shrimp, and scallops; in Japan, a greater variety of surimi products is available. The majority of pollock landed in the U.S. is caught in the Bering Sea, with a smaller amount caught in the Gulf of Alaska (on average, 6% of U.S. landings from 1996–2006). Although the pollock fishery in the Bering Sea began as an international fishery, it is completely domestic within the Exclusive Economic Zone (EEZ) of the U.S. at the present time.

Pollock is a groundfish and a member of the cod family. It occurs in dense aggregations throughout the year and is predominantly targeted using mid-water trawls. Pollock is considered inherently resilient to fishing pressure due to life history characteristics such as an early age at first maturity. In the Bering Sea, pollock is the most abundant groundfish; however, current biomass levels are below the biomass at which maximum sustainable yield is produced. The Gulf of Alaska stock is also below the biomass at which maximum sustainable yield is produced. However, neither stock is overfished or experiencing overfishing. Therefore, Seafood Watch® deems the Gulf of Alaska and Bering Sea pollock stocks to be a “moderate” conservation concern.

The mid-water trawls used to target pollock result in low bycatch relative to the targeted landings, although bycatch includes a species of concern. Bycatch of Chinook salmon includes a large proportion of Yukon River Chinook, which are listed as a “stock of yield concern.” Due to precipitous declines in catch and its status as a stock of yield concern, Seafood Watch® considers Yukon River Chinook salmon to be a species of special concern. The impact of the pollock fishery on the abundance of Yukon River Chinook stocks is unclear. Bycatch of Chinook salmon increased each year between 2004 and 2007 during a time when stocks and commercial catch were in serious decline, reaching new lows in 2008 and 2009. In addition, several management actions have been taken to reduce Chinook bycatch in the pollock fishery and others are pending. Given this information, bycatch in the pollock fishery is currently considered a “moderate” conservation concern since bycatch regularly includes species of special concern. It is not clear, however, that this bycatch has a large impact on Chinook populations, and Chinook bycatch is not increasing.

There is conflicting evidence regarding the role of the pollock fishery in the decline of the endangered Steller sea lion (Eumetopias jubatus) and the northern fur seal (Callorhinus ursinus). Recent population trends for Steller sea lions are up, although fecundity remains low and the population remains endangered. Populations of northern fur seals that are heavily dependent on shelf resources such as pollock are declining. To protect the ecosystem, the North Pacific Fishery Management Council has instituted a two million metric ton cap to the total harvest of all groundfish species in the Bering Sea and Aleutian Islands. In addition, the pollock fishery will be closed if biomass falls below 20% of un-fished biomass as a protection for pollock predators. Changes to the trawl gear used in this fishery have been required to protect certain hard bottom habitats. This gear is referred to as “pelagic trawl” gear, which is misleading since the trawls used in the Bering Sea pollock fishery are estimated to be fished on the bottom approximately 44% of the time. Quantitative analysis suggests that pollock trawls have a greater overall impact on the living biostructure of the Bering Sea shelf than any other bottom trawl fishery and a 3 Seafood Watch® Alaska Pollock Report November 23, 2009

greater impact on the Bering Sea slope than all other bottom trawl fisheries combined. Therefore, pollock trawls are considered to cause substantial damage to seafloor habitats, similar to bottom trawls, and are used over moderately resilient habitats across a large spatial scale. As such, the habitat and ecosystem effects of the pollock fishery are considered “severe” according to Seafood Watch® criteria.

Pollock in the Bering Sea/Aleutian Islands and Gulf of Alaska are managed by the National Marine Fisheries Service under the guidance of the North Pacific Fishery Management Council. Management measures include permit requirements, limited entry, time and area closures, quotas, gear restrictions, bycatch reduction measures, reporting requirements, and observer monitoring. The effectiveness of measures to reduce bycatch and habitat impacts remains in debate, but management has generally followed scientific recommendations and responded to declines in stock productivity by lowering the total allowable catch (TAC). In addition, management has taken proactive, precautionary measures to protect the ecosystem, including prohibiting the expansion of commercial fishing in the Arctic Ocean and developing a Fishery Ecosystem Plan for the Aleutian Islands, which provides an ecosystem context for fisheries management. As such, pollock management is considered highly effective according to Seafood Watch® criteria.

Overall, the moderate status of stocks, moderate bycatch concerns, and severe habitat impacts result in a recommendation of Good Alternative for pollock from the Bering Sea/Aleutian Islands and Gulf of Alaska.

The pollock fishery could mitigate many of the concerns detailed in this report to achieve a “Best Choice” ranking. Because the most severe conservation concern is the habitat damage caused by mid-water trawls that frequently contact the seafloor, one of the most important changes the fishery could make is to prohibit mid-water trawls from contacting the bottom and enforcing this regulation with a stronger performance standard. The pollock fishery should also take serious measures to reduce bycatch of Chinook salmon. The success of the Chinook bycatch reduction plan scheduled for implementation in 2011 will largely depend on the efficacy of Incentive Plan Agreements (IPAs) designed by industry. Seafood Watch will be evaluating the effectiveness of these measures in addressing the bycatch concern. Finally, in setting the level of TAC, managers should consider both the uncertainty inherent in the stock assessments and the importance of pollock as a prey species. Harvest rules should be more precautionary to compensate for potential errors in estimates of stock size and recruitment, and models used to determine harvest rates should incorporate predation by Steller sea lions, fur seals and other important predators. Seafood Watch® will continue to monitor changes in the pollock fishery. If the fishery takes actions that lead to improvements in stock status, sustained low bycatch of salmon and other species of special concern, and reduced habitat impacts, the overall recommendation for Alaska pollock may be changed from Good Alternative to Best Choice.

Since 2005, the Alaska pollock fishery has been certified as “sustainable” to the Marine Stewardship Council (MSC) standard. The MSC is an independent non-profit organization that has developed an environmental standard for sustainable and well-managed fisheries. It uses a product label to reward environmentally responsible fishery management and practices (http://www.msc.org/).

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Table of Sustainability Ranks

Conservation Concern Sustainability Criteria Low Moderate High Critical Inherent Vulnerability √ Status of Stocks √ Nature of Bycatch √ Habitat & Ecosystem Effects √ Management Effectiveness √

About the Overall Seafood Recommendation: • A seafood product is ranked Best Choice if three or more criteria are of Low Conservation Concern (green) and the remaining criteria are not of High (red) or Critical Conservation Concern (black) in the table above. • A seafood product is ranked Good Alternative if the five criteria “average” to yellow (Moderate Conservation Concern) OR if the “Status of Stocks” and “Management Effectiveness” criteria are both of Moderate Conservation Concern. • A seafood product is ranked Avoid if two or more criteria are of High Conservation Concern (red) OR if one or more criteria are of Critical Conservation Concern (black).

Overall Seafood Recommendation:

Best Choice Good Alternative Avoid

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II. Introduction

Walleye pollock (Theragra chalcogramma)1 is a semi-demersal member of the cod family that occurs in dense aggregations throughout the year (Smith 1981; Saunders et al. 1988). Pollock are distributed throughout the north Pacific Ocean and bordering seas from approximately 35ºN to approximately 68ºN; however, the range of known spawning locations is latitudinally more limited. Depending on its life history stage, walleye pollock may inhabit continental shelves and slopes, deep ocean basins (occasionally to 1200 m, commonly to less than 300 m) and estuaries (Smith 1981; Saunders et al. 1988; Bailey et al. 1999) (Figure 1).

Pollock is the most abundant groundfish species in the eastern Bering Sea and the second most abundant groundfish species in the Gulf of Alaska (NPFMC 2002a). Pollock supports the largest single-species fishery in the North Pacific (Barbeaux and Dorn 2003) representing about 36% of the groundfish biomass and 65% of the groundfish landings in the eastern Bering Sea (NPFMC 2008c), and 13% of the groundfish biomass and 28% of the groundfish landings in the Gulf of Alaska (NPFMC 2008d). Pollock is a key species in the Bering Sea ecosystem, playing an important role as both predator and prey. Pollock fry consume small zooplankton such as copepods and krill (Brodeur et al. 2000), while adult pollock are cannibalistic. As prey, juvenile pollock play an important role in the diet of many organisms including older pollock, Pacific cod (Gadus macrocephalus), Pacific halibut (Hippoglossus stenolepis), a number of seabirds, and marine mammals such as Steller sea lions (Eumetopias jubatus) and northern fur seals (Callorhinus ursinus) (Frost and Lowry 1981; Smith 1981; Lowry et al. 1989; Lowry et al. 1996; Merrick and Calkins 1996). Large year-classes of pollock may be subject to increased predation (Livingston 1993).

Figure 1. Geographic distribution (cross hatches) and known spawning locations (•) of walleye pollock (Figure from Bailey et al. 1999)

In the Bering Sea, there has been a large-scale directed fishery for pollock since 1964, following the Japanese development of a quality surimi paste made from pollock (Wespestad 1993). Foreign fishing in the central Bering Sea (also known as the “Donut Hole” region) increased rapidly throughout the 1980s and consisted mostly of fishing vessels from Japan, the Soviet

1 Throughout this report, walleye pollock will be referred to simply as pollock. 6 Seafood Watch® Alaska Pollock Report November 23, 2009

Union, Korea and Poland (Fritz et al. 1995). Since 1988, only U.S. boats have fished for pollock within the U.S. Exclusive Economic Zone (EEZ) (Ianelli et al. 2003). Since 1993, there has been a moratorium on fishing in the international zone of the Bering Sea after pollock catch peaked in 1989 and began declining (Ianelli et al. 2003). By 1991, catch in the “Donut Hole” region was 80% less than the catch in 1989 (Wespestad 1993). It is likely that pollock caught in the “Donut Hole” region originated from surrounding areas (Wespestad 1993) and therefore had the potential to affect the U.S. fishery in the EEZ. Within EEZ waters, the pollock fishery has transitioned from a foreign fishery (mothership supported by pair trawlers, freezer trawlers, and surimi trawlers) to a joint venture fishery and subsequently to a completely domestic fishery involving at-sea motherships supported by catcher vessels, freezer and surimi trawlers, and catcher vessels delivering to shoreside plants (Megrey 1988). Similarly, the commercial fishery for pollock in the Gulf of Alaska began as a foreign fishery (Megrey 1988), but transitioned to a domestic fishery by 1988 (Dorn et al. 2003). In the Gulf of Alaska, however, the total allowable catch (TAC) for pollock is allocated solely to catcher vessels delivering pollock inshore. These catcher vessels operate in the Gulf of Alaska and are smaller than the factory trawlers and catcher vessels operating in the Bering Sea. In the eastern Bering Sea and Gulf of Alaska, spawning aggregations are targeted to obtain roe (Dorn et al. 2003). Pollock roe stripping, the practice of retaining the roe and discarding female pollock, is prohibited in both the Bering Sea/Aleutian Islands (BSAI) and Gulf of Alaska. This practice has been prohibited since 1991 via Amendment 14 to the fishery management plan (56 FR 492).

In the U.S., pollock landings increased dramatically in the late 1980s; since 1989 landings have averaged 1.3 million metric tons (mt) annually (Figures 2 and 3) (NMFS 2007a). The value of pollock peaked at approximately US$380 million in 1992, fell to $160.5 million in 2000, and reached its second highest value of $330 million in 2006 (NMFS 2007a).

Figure 2. Pollock catch in the eastern Bering Sea, Aleutian Islands, Bogoslof Island, and “Donut Hole” region, 1964–2008 (2008 data are projected values) (Figure 1.1 from Ianelli et al. 2008a). 7 Seafood Watch® Alaska Pollock Report November 23, 2009

1.8 400 Landings (mt) Value (US $) 1.6 350

1.4 300

1.2 250 1 200 0.8

150 (Millions) $ US 0.6 Metric Tons (Millions) Tons Metric 100 0.4

0.2 50

0 0 1965 1970 1975 1980 1985 1990 1995 2000 2005 Year

Figure 3. U.S. commercial landings of pollock, 1965–2006 (NMFS 2007a). Note that landings prior to 1985 were by foreign and joint-venture vessels, which appear in Figure 2 above.

Pelagic, or mid-water, trawl gear is used to catch pollock in the Bering Sea and Gulf of Alaska (NPFMC 2009a, 2009b). Since 1999, mid-water trawls have been the only gear permitted to commercially catch pollock. Mid-water trawls targeting pollock are highly efficient and can catch as much as 400 mt in one tow (Fritz et al. 1995).

Pollock in the Bering Sea and Gulf of Alaska is managed by the National Marine Fisheries Service (NMFS) under advisement from the North Pacific Fishery Management Council’s (NPFMC) Fishery Management Plan (FMP) for the Bering Sea/Aleutian Islands Groundfish and the FMP for Groundfish of the Gulf of Alaska, respectively. Management measures administered by NMFS include permit requirements, limited entry, time and area closures, quotas, gear restrictions, bycatch reduction measures, reporting requirements and observer monitoring.

Pollock from the Bering Sea/Aleutian Islands and Gulf of Alaska is certified by the Marine Stewardship Council (MSC). The MSC label signifies “…environmentally responsible fishery management and practices” (MSC 2004). While certification for pollock from both the Gulf of Alaska and Bering Sea/Aleutian Islands began in 2001, certification for Gulf of Alaska pollock faced considerable scrutiny by several conservation groups. A lengthy objections process centering around low stock size and catch in critical habitat for Steller sea lions resulted in a report published by the objections panel, followed by an action plan submitted to the certification body. Gulf of Alaska pollock was certified by the MSC on April 27, 2005.2

2 See http://www.msc.org/html/content_492.htm for documents related to the MSC certification of Gulf of Alaska pollock.

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Scope of the analysis and the ensuing recommendation:

This report encompasses pollock caught in the Bering Sea/Aleutian Island and Gulf of Alaska commercial fisheries based in the U.S., although it focuses on Bering Sea pollock, which represents approximately 95% of total U.S. pollock landings from 1999–2006 (Dorn et al. 2007; Ianelli et al. 2007). This report does not analyze the international fishery for pollock.

Availability of Science

Due to the commercial importance and magnitude of the pollock fishery, there are sufficient data concerning the life history of the species as well as fishery-independent and dependent data. There is, however, some concern associated with the catch of pollock in the Russian EEZ and possible effects on U.S. stocks. Uncertainties associated with the ecosystem effects of the pollock fishery remain.

Market Availability

Common and market names: Walleye pollock is also known as Alaska pollock (Froese and Pauly 2004).

Seasonal availability: Fishing for pollock in the Bering Sea is divided into two seasons—the “A season” targets the winter spawning aggregation of pollock starting on January 20 and continuing four to six weeks, while the “B season” generally opens on June 1 and lasts through October (Ianelli et al. 2003). Pollock is available frozen year-round.

Product forms: Pollock is sold as fillets, frozen fish products such as fish sticks, and surimi, which is a minced product used to make a number of products including imitation crab, scallops and shrimp (Herrfurth 1987). For additional information on the Seafood Watch® recommendation for surimi, see the Appendix. Pollock roe is also available on the U.S. market, although it is more common in Asian countries (Herrfurth 1987).

Import and export sources and statistics: The majority of pollock available in the U.S. market is caught by U.S. fishing vessels operating in the Bering Sea and Gulf of Alaska. In 2008, total U.S. landings of pollock were 1.03 million mt (NMFS 2009a). Total imports of all species of pollock were 73,467 mt in 2008 (NMFS 2009b). Imports specified as products of Alaska pollock (“fillet frozen”, “fillet block frozen”, “frozen” and “roe frozen”) totaled 60,005 mt in 2008 (NMFS 2009b). Total imports of Alaska pollock in 2008 were about 6% of U.S. landings by weight3. Of this 6%, nearly 99% of imported pollock was from China; other countries that exported smaller amounts of Alaska pollock to the U.S. in 2008 included Canada, Japan, Russia and South Korea, which each accounted for less than 1% of U.S. imported pollock in 2008 (NMFS 2009b). In 2008, the U.S. exported 88,175 mt of frozen Alaska pollock products (excluding roe), and 19,825 mt of frozen Alaska pollock roe

3 However, note that processed products are approximately 20% of the round fish weight (D.L. Alverson, pers. comm.). If the U.S. landings of 1.0 million mt of pollock were processed it would result in a total weight of 200,000 mt of processed pollock products. 9 Seafood Watch® Alaska Pollock Report November 23, 2009

(NMFS 2009b). Only the U.S. component of the pollock fishery is encompassed in this report, as the majority of pollock in the U.S. market is landed in the U.S.

III. Analysis of Seafood Watch® Sustainability Criteria for Wild-caught Species

Criterion 1: Inherent Vulnerability to Fishing Pressure

Pollock has a moderate species range and is found in the eastern and western Pacific Ocean, the Bering Sea, the Gulf of Alaska, the Sea of Okhotsk and the Sea of Japan (Table 1) (Smith 1981). In the Bering Sea, 50% of Age-4 female pollock are mature (40–45 cm in length) (NPFMC 2002a). Prior to the 1970s, recruitment of pollock in the Gulf of Alaska was controlled by environmental effects on larvae; however, it is speculated that a climatic change may have shifted recruitment to biological control of juveniles (Bailey 2000). Recruitment variability is also affected by the cannibalism of juvenile pollock, which depends on the spatial distribution of adults and juveniles (Wespestad et al. 2000). Pollock cannibalism has been shown to be the largest source of biomass removal for Age-0 pollock (Dwyer et al. 1987; Livingston 1993). Environmental variables also have an effect on the abundance of pollock. For instance, the abundance of euphausiids and copepods (major prey for pollock that are influenced by oceanic conditions) affects pollock recruitment and abundance (Aydin et al. 2007).

The maximum recorded age for pollock is 31 years, while estimates of average lifespan range from 9–12 years (NPFMC 2002a). Juvenile growth rates vary with geographic location; in the western Gulf of Alaska, growth rates were higher in the northern areas (near Kodiak Island), ranging from 0.58 to 1.04 mm/day (Brown and Bailey 1992).

There are three pollock stocks in the Bering Sea—the eastern Bering Sea stock, the Aleutian Islands stock and the Bogoslof Islands stock—and there is some exchange between these three stocks (Ianelli et al. 2004). The Bogoslof Island stock forms a distinct spawning aggregation associated with the Aleutian Basin (Ianelli et al. 2004). Catches from the Bogoslof Island stock have declined dramatically since the late 1980s, from a catch of 377,436 mt in 1987 to a catch of 22 mt in 2002 (AFSC 2003). The Gulf of Alaska stock is separate from the Bering Sea/Aleutian Islands stock (Bailey et al. 1997). Pollock spawning occurs in specific grounds at certain times of the year (Bailey 2000), making pollock spawning aggregations vulnerable to fishing pressure, although the protection of sufficient spawning stock is taken into account for management and only 40% of the annual quota may be taken during peak spawning season. In captivity, pollock have been shown to pair-spawn (Sakurai 1988). In the southeastern Bering Sea and Aleutian Islands, peak pollock spawning occurs in mid-March, while it occurs from late February to early March in the Aleutian Basin, and late March in the Gulf of Alaska (Kim 1988; Brown and Bailey 1992; NPFMC 2002a). In the Gulf of Alaska, there is a spawning migration into Shelikof Strait during winter and early spring (Kim 1988). The discovery of the Shelikof Strait spawning aggregation resulted in the onset of the roe fishery in the early 1980s (Dorn et al. 2004). Similar to the Bogoslof Island stock, estimates of the Shelikof Strait population have declined from approximately 2.8 million mt in 1981 to approximately 290,000 mt in 2004 (Dorn et al. 2004). The National Marine Fisheries Service (NMFS) bottom trawl survey, however, shows a much smaller decline over the same time period.

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Pollock is highly fecund, with fecundity estimates ranging from 155,000–2,000,000 eggs being produced over a several-week spawning period each year (Hinckley 1987; Teshima et al. 1988; Chaffee et al. 2004a). Spawning pollock congregate spatially in the water column and have been frequently caught at depths of 100–250 m (Hinckley 1987). Hinckley (1987) found that fecundity increased almost linearly with length, with a steeper increase seen in fish greater than 60 centimeters (cm) in length.

Table 1. Life history characteristics of pollock.

Intrinsic Rate of Age at Growth Max Max Species Special Fecundity Sources Increase Maturity Rate Age Size Range Behaviors (r) Hughes and Hirschhorn 1979; Smith Pacific 1981; Ocean, Hinckley 50% of vBgf4: 91 cm Bering Sea, 1987; age-4 155,000 – L = 31 total Gulf of Spawning Teshima et Unknown female ∞ 2.0 million 52.2 cm, yrs length Alaska, Sea aggregations al. 1988; pollock are eggs k = 0.32 (TL) of Okhotsk, NPFMC mature Sea of 2002a; Japan Chaffee et al. 2004a; Froese and Pauly 2004

Synthesis Pollock has a moderate distribution in the North Pacific, and with an early age at first maturity (< 5 years), exhibits basic life history characteristics that make it inherently resilient to fishing pressure. However, spawning aggregations of pollock are targeted by the commercial fishery (aggregating to spawn is the only special behavior that may increase the ease of capture for pollock), although there are some management measures designed to protect spawning aggregations from over-exploitation. High recruitment variability, particularly in the Gulf of Alaska, also plays a role in the resiliency of pollock to fishing pressure. In general, early age at maturity, relatively short life span, and high fecundity make pollock inherently resilient to fishing pressure.

Inherent Vulnerability Rank:

Resilient Moderately Vulnerable Highly Vulnerable

4 vBgf = a commonly used growth function in fisheries science to determine length as a function of age. L∞ is asymptotic length, and k is body growth coefficient. Note that maximum size may be larger than L∞ due to individual variation around L∞. 11 Seafood Watch® Alaska Pollock Report November 23, 2009

Criterion 2: Status of Wild Stocks

The North Pacific Fishery Management Council (NPFMC) divides the U.S. pollock population into two major stocks: the U.S. Bering Sea stock and the Gulf of Alaska stock (Dorn et al. 2008; Ianelli et al. 2008a). The NPFMC further divides the U.S. Bering Sea stock into an Eastern Bering Sea shelf stock, an Aleutian Islands region stock and a Central Bering Sea-Bogoslof Island stock (Ianelli et al. 2008b). The Gulf of Alaska stock is divided into eastern and western stocks (Dorn et al. 2008). Evidence from larval drift, allozyme frequency, mitochondrial DNA (mtDNA) and microsatellite DNA studies suggest that the Bering Sea stock and the Gulf of Alaska stocks are probably also biological stocks (Dorn et al. 2008 and references therein). The Aleutian Islands region accounted for just 0.1% of the Bering Sea fishery in 2007–2008 and is expected to make up no more than 0.3% of the Bering Sea catch in 2009 (Ianelli et al. 2007; Barbeaux et al. 2008). The Central Bering Sea-Bogoslof Island pollock fishery has been closed since 1992. Therefore, while this report briefly discusses those stocks, this report and the resulting Seafood Watch® recommendation focus on the Eastern Bering Sea shelf and Gulf of Alaska stocks. Additional stocks not included in this report include several stocks in British Columbia (Shaw and McFarlane 1986), two stocks in Puget Sound (Pallson et al. 1997) and at least five stocks distributed along the western shores of the Bering Sea and Sea of Okhotsk (Tsuji 1989). Evidence suggests there is some mixing between the U.S. Bering Sea management stocks and pollock from the western Bering Sea stocks (Bailey et al. 1999; O’Reilly et al. 2004; Canino et al. 2005).

The U.S. pollock fishery quotas are established under the guidance of the NPFMC under a scheme which classifies stocks according to “Tiers”. Tiers are generally based on the level and quality of available information as well as the estimated biomass of a stock. The tier classification (set by the NPFMC’s Science and Statistical Committee) determines how to set the Overfishing Level (OFL) and the Allowable Biological Catch (ABC). The ABC must be set below the OFL, and the Total Allowable Catch (TAC) is set below or equal to the ABC while incorporating social and economic considerations (see Criterion 5: Effectiveness of the Management Regime) (NPFMC 2009a). The TAC is sometimes reduced below ABC such that total catch for all groundfish-complex species in the BSAI does not exceed two million metric tons, the cap set as an ecosystem protection measure in Amendment 1 to the BSAI FMP (NPFMC 2009a). In addition, the ABC will be set to zero if female spawning stock biomass (SSB) is below 20% of the estimated unfished biomass (B20%) (Chaffee et al. 2004a and 2004b).

Eastern Bering Sea Shelf Stock (EBS) Stock assessments for EBS pollock include both fishery-dependent and fishery-independent data, and provide estimates of spawning stock biomass and fishing mortality relative to the biomass and mortality rates at maximum sustainable yield (MSY). Various management strategies are suggested depending on the quality of available data (Ianelli et al. 2008a; NPFMC 2009a). An OFL is set at a level corresponding to FMSY, or the fishing mortality rate associated with producing MSY (Chaffee et al. 2004a). The minimum stock size threshold (MSST) is set at ½BMSY (biomass at MSY), and ABC levels are required to be below the OFL (Chaffee et al. 2004a). The most recent stock assessment for EBS pollock was conducted in 2008 (Ianelli et al. 2008a). Preliminary data from the NMFS 2009 bottom trawl and acoustic surveys were presented in September 2009 (NMFS 2009e), showing less biomass than previously projected. These data include new survey indices, but the assessment data that include new estimates of biomass

12 Seafood Watch® Alaska Pollock Report November 23, 2009

relative to reference points have not yet been released. The final 2009 stock assessment will be released in November 2009.

The 2008 stock assessment for pollock in the EBS calculated SSB at 1,443,000 t, approximately 75% of the estimated BMSY of 1,919,000 t (Ianelli et al. 2008a). The SSB/BMSY is projected to remain below 1.0 until 2010. The status determination criteria indicate that the stock is above the MSST and is not expected to approach an overfished condition. Since catches remain below the OFL, overfishing is not occurring. The FMP provides harvest control rules that vary according to the amount of available data and the current B/BMSY (NPFMC 2009a). Under application of the appropriate harvest control rule for EBS pollock based on the projected 2009 biomass estimates, the recommended ABC for 2009 was set at 815,000 t and the recommended OFL was set at 977,000 t. Under expected acceptable catch levels, SSB is projected to reach about 75% of BMSY by 2009 and is predicted to increase above BMSY in subsequent years (Figure 4) (Ianelli et al. 2008a).

The 2008 stock assessment estimates a 15% probability that SSB is below 20% of B0 (i.e., the probability that the SSB estimate is low and the B0 estimate is simultaneously high is 15% for 2008 and less than 10% for 2009) (Ianelli et al. 2008a). If SSB falls below 20% of B0, the fishery will close.

Overall, fishery-independent data indicate that pollock biomass in the EBS has been variable in the long-term and declining in the short-term, with a general decline through the 1990s followed by an increase beginning in 1998 and another decline since 2003 (Figure 5). The large variance associated with the 2003 estimate is due to a large survey tow; even without these data, biomass was still estimated at approximately 6.5 million mt (Ianelli et al. 2003). Estimates of the spawning biomass and the biomass of Age-3 and older pollock increased from 1991 through the mid-to-late 1990s, remained stable for a while, declined after 2004, and are currently estimated to have increased in 2009 (Figure 6) with a predicted further increase in 2010. However, the 2009 estimate and 2010 projections are based on highly uncertain estimates of a strong 2006 year class. Preliminary survey data collected in 2009 suggests that biomass is not increasing as was projected, and the projections cited here may be overly optimistic (NMFS 2009e).

Recruitment was below average from 2001–2005, and preliminary data from echo-integration trawl (EIT) surveys conducted in 2008 suggest above average recruitment from the 2006 year class followed by a below-average recruitment year for the 2007 year class (Figure 7) (Ianelli et al. 2008a). The anticipated increase in SSB/BMSY in 2010 is based largely on these new estimates of recruitment, but there is a high degree of uncertainty in these estimates (Ianelli et al. 2007; Ianelli et al. 2008a).

Estimated fishing mortality relative to FMSY (F/FMSY) has been estimated to be below 1.0 since 1981. Current estimates suggest an F/FMSY of about 0.64 for 2008 under the recommended harvest rule (Figure 8) (Ianelli et al. 2008a). Based on the 2008 stock assessment, which contains a public review period and review by the NPFMC’s Plan Team and Scientific and Statistical Committee (SSC), overfishing is not occurring (Ianelli et al. 2008a; NPFMC 2008).

Length-frequency data of pollock from 1987–2008, age composition estimates from 1979–2007, and sex composition estimates from 1991–2007 indicate that the size, age and sex distributions of pollock in the EBS are not skewed, and while periodic changes in the age and size structure 13 Seafood Watch® Alaska Pollock Report November 23, 2009

are common due to inter-annual recruitment variability, there has been no directional change in age, size or sex distribution over time (Ianelli et al. 2008a).

Although there is some uncertainty in the stock assessment’s estimates of female spawning biomass, fishing mortality and particularly recent recruitment, these estimates are based on long time-series of both fishery-independent and fishery-dependent data (Ianelli et al. 2008a). EBS pollock have been determined by the NPFMC’s SSC to qualify for ABC and OFL determinations under the FMP Amendment 56 ‘Tier 1’ classification (Ianelli et al. 2008a). This tier, as defined by the groundfish FMP (NPFMC 2009a), requires reliable point estimates of B and BMSY and a reliable estimate of the probability density function of FMSY. The uncertainty propagated through the FMSY estimates provides for a formally risk-averse buffer between the point estimate for the projected catch at FMSY (set as the OFL) and the maximum permissible ABC.

Figure 4. Estimated EBS pollock female spawning biomass trends, 1990–2011, with different 2009–2011 harvest levels. Horizontal solid line represents the Bmsy, estimate (Figure from Ianelli et al. 2008a).

14 Seafood Watch® Alaska Pollock Report November 23, 2009

Figure 5. Bottom-trawl survey biomass estimates with approximate 95% confidence bounds for eastern Bering Sea pollock, 1982 – 2008; horizontal line = mean (Figure from Ianelli et al. 2008a).

14,000 Age 3+ Biomass 12,000 Spawning biomass

10,000

8,000

6,000

Biomass (1000 mt) 4,000

2,000

0 1964 1966 1968 1970 1972 1974 1976 1978 1980 1982 1984 1986 1988 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008

Figure 6. Model estimated spawning biomass and Age-3+ biomass of eastern Bering Sea pollock, 1964–2009 (Data from Ianelli et al. 2008a).

15 Seafood Watch® Alaska Pollock Report November 23, 2009

Figure 7. Year-class strengths by year (as Age-1 recruits). Solid line represents the mean Age-1 recruitment for all years since 1964 (1963-2007 year classes). Figure from Ianelli et al. 2008a.

Figure 8. Estimated spawning biomass relative to annually estimated FMSY values and fishing mortality rates for EBS pollock, 1977–2008. (Figure from Ianelli et al. 2008a).

Aleutian Islands Region Stock (AI) There is uncertainty about how the Aleutian Islands pollock stock is best defined. For many years prior to 1995, much of the catch had been taken very close to the eastern edge of the 16 Seafood Watch® Alaska Pollock Report November 23, 2009

region, and it seems likely that this was a westward expansion of the Eastern Bering Sea stock (Ianelli et al. 1997). In some years prior to 1989, significant portions of the catch had been from deep-water regions to the west and appeared to be more accurately categorized as “basin” pollock. A wide variety of alternative stock-structure scenarios has been investigated in recent stock assessments (Barbeaux et al. 2008).

The AI directed pollock fishery was closed in 1999 due to concerns over the recovery of Steller sea lion populations for which walleye pollock is a major food source (Barbeaux et al. 2004). For the five years prior to the 1999 closure of the fishery, the AI catch represented between 2% and 5% of the U.S. Bering Sea catch (Ianelli et al. 2004). A limited fishery was opened in 2005 in order to provide opportunities to Aleutian Islands communities. However, areas around Steller sea lion rookeries and haulouts remained closed, effectively limiting fishing for shore- based fishers to two small areas near Adak Island. By 2007, barely 2,000 t of pollock had been landed, and as of October 2008, an additional 392 t had been taken. Another 802 t had been taken as incidental catch in other groundfish fisheries. Combined, this represents less than 0.1% of the total U.S. Bering Sea catch for the same period (Ianelli et al. 2007; Barbeaux et al. 2008).

As a result of substantial changes made to the assessment methodology, estimated biomass for previous as well as current and future years has increased. This results in a greater decline in stock abundance in the 1990s compared to what was previously reported, as well as an increase in B0 for current and future years. With these updated values, the recommended 2009 ABC is 26,873 t, and by Congressional mandate the TAC is limited to be less than 19,000 t. The actual catch for 2009 is estimated to be only 2,000 t, which would represent less than 0.3% of the U.S. Bering Sea pollock catch (Barbeaux et al 2008).

There is a high degree of uncertainty in the AI pollock stock assessment, not only due to the uncertainty in the spatial extent of the stock, but also because of high variability in pollock abundance estimates from AI bottom trawl surveys, the lack of AI bottom trawl surveys since 2006 due to NOAA budget constraints and the lack of winter fishery data since the fishery closure in 1999 (Barbeaux 2004). Although there is uncertainty in the stock assessment, it is believed to be the best possible evaluation of the health of the stock given the available data (Francis 2008). The trend in AI pollock abundance provided by the assessment logically follows what would be expected from a stock with the biological attributes of AI pollock and a history of exploitation like that observed in the Aleutian Islands. The highest exploitation rates occurred during the 1990s followed by closure since 1999. Starting in 2005, a small, spatially limited fishery was allowed, but catches have remained less than 2,000 t per year (mostly allowance for bycatch in other fisheries). All current models show both SSB and total biomass declining through the 1990s due to a period of below average recruitment followed by steep increases from 1999 through 2004 and more modest increases from 2005–2008. Both short- and long-term abundance trends are up, current total biomass is greater than BMSY, current fishing mortality is less than FMSY, and estimates for 2008 indicate that actual catch will equal only approximately 6% of the total allowable catch (TAC). Thus, the AI pollock stock is not overfished and overfishing is not occurring.

Central Bering Sea-Bogoslof Island Stock (BOG) A directed pollock fishery existed in the central Bering Sea/Bogoslof Island region (BOG) from around 1977–1991. The BOG stock generally includes pollock from U.S. waters around Bogoslof Island, as well as pollock presumed to regularly visit a nearby deep basin area located 17 Seafood Watch® Alaska Pollock Report November 23, 2009

in international waters and known regionally as the “Donut Hole”. Catch statistics for BOG pollock have historically included BOG-caught pollock as well as a portion (usually 60%) of the international “Donut Hole” catch. In 1992, the Convention on the Conservation and Management of the Pollock Resources in the Central Bering Sea concluded that Bogoslof Island pollock spawning stocks were linked to the abundance of pollock in international waters. As part of agreements contained in that convention, the BOG region was closed to directed pollock fishing. During 1992, the last year of fishing, 316,038 t of pollock were caught in the BOG region and 609,438 t in the “Donut Hole” for a total BOG catch of 492,708 t (BOG + 60% “Donut Hole”). Although there is currently no directed pollock fishery in BOG, stock assessments are conducted and records of pollock incidental catch from other groundfish fisheries are recorded. Between 1992 and 2001, annual incidental pollock catch averaged around 300 t, which reached 1,042 t in 2002 and then dropped to less than 10 t per year between 2003 and 2007. In 2008, the incidental pollock catch increased to 8.17 t (Ianelli et al. 2006, 2008b).

The most recent assessments in 2006 and 2008 indicate that the BOG stock has a relatively stable abundance trend and that under one formulation the SSB is about 77% of B100% (Ianelli et al. 2006). Depending on the Tier classification by the NPFMC SSC, quite different estimates of ABC result and range from 7,967 t to 65,700 t (Ianelli et al. 2008b). The 2008 stock assessment authors recommended adopting the lower value given stock structure uncertainty. The 2009 ABC recommendation for the BOG stock was 7,767 t. This is much larger than the 8.2 t of pollock taken incidentally in 2008; an updated survey planned for 2009 may provide the data necessary to make better estimates of ABC in future stock assessments (Ianelli et al. 2008b).

Gulf of Alaska (GOA) The Gulf of Alaska (GOA) pollock stock falls under Tier 3 of the NPFMC harvest guidelines (Dorn et al. 2008). Tier 3 management is applied when reliable estimates of B, B40% , F35% , and F40% , but not BMSY or FMSY, are available (NPFMC 2009b). The value of FX% is the fishing mortality rate that would reduce the spawning potential ratio (SPR) to X% of the SPR with no fishing, and BX% is the equilibrium biomass expected at that fishing mortality rate with average recruitment. Under Tier 3 management, because estimates of BMSY and FMSY are lacking, B40% and F40% are used as reference points to determine the appropriate management scheme for the fishery; B35% is used as a proxy for BMSY and F35% is a proxy for FMSY and a reference point to determine whether overfishing is occurring. Based on these reference points, an OFL is determined at or below the level of catch corresponding to F35%, and a maximum ABC is set at a level lower than the OFL. The TAC cannot exceed the ABC (NPFMC 2009b).

Stock assessments in the GOA are based on both fisheries-independent and fisheries-dependent data, including annual acoustic surveys, an annual Alaska Department of Fish and Game survey, and biennial bottom trawl surveys, as well as data from the North Pacific Observer Program. As such, the availability of information is great and the level of uncertainty for the GOA stock status is relatively low.

The 2008 stock assessment for pollock in the GOA projects a 2009 spawning biomass at 132,805t; 22.4% of unfished spawning biomass and 64% of the B35% reference point (208,000 t) used as a proxy for BMSY. These values have led to a recommendation that the ABC in the GOA (west of 140ºW) be reduced to 43,270 t in 2009, a 19% decrease compared with the 2008 ABC (Dorn et al. 2008).

18 Seafood Watch® Alaska Pollock Report November 23, 2009

Long-term trends in SSB in the GOA are down, while short-term trends are fluctuating. Spawning stocks have declined since the mid-1980s and have been below the B35% reference point since 1998 (Figure 9). Estimated SSB in 2008 was one of the lowest in the last thirty years, although biomass was lower in the 1960s before fishing began. The projected SSB for 2009 is close to the 2008 value with modest increases predicted in later years. This anticipated increase is contingent upon strong incoming year classes, which some survey results support; however, there is also a high degree of uncertainty in this estimate (Dorn et al. 2008). The biomass of GOA pollock is highly variable due both to short generation times and highly variable recruitment, and large year classes do not persist in the population for a long time period. Indeed, the pattern of pollock biomass in the Gulf of Alaska has been characterized by sharp short-term increases due to strong recruitment followed by periods of gradual decline (Dorn et al. 2003).

19 Seafood Watch® Alaska Pollock Report November 23, 2009

Figure 9. Estimated time series of Gulf of Alaska pollock spawning biomass (million t, top) and Age-2 recruitment (billions of fish, bottom) from 1961–2008. Vertical bars represent two standard deviations. The B35% and B40% lines represent the current estimate of these benchmarks (Figure from Dorn et al. 2008).

The 2008 stock assessment includes an estimate of the probability that the stock is below 20% of B0 in 2009; this probability is estimated at 12%. The probability that the projected spawning 20 Seafood Watch® Alaska Pollock Report November 23, 2009

biomass in future years is below 20% of B0 is less than 1%, assuming catch rates follow the scientific recommendations given in the 2008 stock assessment (Figure 10) (Dorn et al. 2008).

Figure 10. Uncertainty in spawning biomass for 2009–2013, assuming catch rates are applied as recommended by the 2008 stock assessment authors (Figure from Dorn et al. 2008).

Model results suggest that while F relative to FMSY has fluctuated, it has remained under 100% since 1961. However, when spawning biomass is below MSY, as it has been in the GOA for the last decade, overfishing can occur at fishing mortality rates lower than FMSY. According to the most recent stock assessment, F/FMSY has frequently approached the overfishing level in recent years but has not exceeded it. The fishing mortality rate in 2008 was approximately 50% of the FMSY proxy (Figure 11) (Dorn et al. 2008).

21 Seafood Watch® Alaska Pollock Report November 23, 2009

Figure 11. Gulf of Alaska pollock spawning fishing mortality relative to FMSY (1961–2008). The ratio of fishing mortality to FMSY is calculated using the estimated selectivity pattern in that year. Because these estimates change as new data become available, this figure can only be used to generally evaluate management performance relative to fishing mortality reference levels (Figure from Dorn et al. 2008).

The most recent size composition data show a slight decline in mean age/size in the fishery compared to previous years; however, this is presumed to be the effect of a strong year class rather than due to overfishing, and there is no indication that the age or size distributions are skewed due to overfishing (Dorn et al. 2008).

Despite the downward trends in spawning stock biomass, the overall conclusion of the 2008 stock assessment for pollock in the GOA is that it is not currently overfished and that overfishing is not occurring. The recommended ABC for 2009 is set at 43,270 t, and the recommended OFL is set at 58,590 t. For 2010, the recommended ABC and OFL are projected to be 67,700 t and 90,920 t, respectively. Under the recommended harvest policy, pollock SSB is expected to increase above the SBMSY proxy by 2012 (Figure 12) (Dorn et al. 2008).

22 Seafood Watch® Alaska Pollock Report November 23, 2009

Figure 12. Projected spawning biomass for 2009–2013 under alternative management strategies (Figure from Dorn et al. 2008).

Table 2. 2008 stock status of pollock in the Eastern Bering Sea and Gulf of Alaska. Degree of Classification Occurrence of Abundance Age/size/sex uncertainty Stock B/B F/F Sources status MSY overfishing MSY trends/CPUE distribution in stock status Bakkala Variable long- 1988; term biomass Ianelli et Eastern Not Overfishing not trend and al. 2004, Bering 0.75 0.64 Not skewed Low overfished occurring decreasing 2007, Sea short-term 2008; biomass trend NMFS 2004a Shima et Declining al. 2001; long-term Dorn et Gulf of Not Overfishing not biomass trend al. 2004, 0.64 0.5 Not skewed Low Alaska overfished occurring and variable 2007, short-term 2008; biomass trend NMFS 2004a

Synthesis The Eastern Bering Sea pollock stock is not overfished and overfishing is not occurring, although spawning biomass dropped below BMSY in 2007 for the first time since 1981. Pollock biomass in the EBS has continued to decline in recent years but projections, which are uncertain, indicate that the stock will be above BMSY by 2010. There is no indication of skewed age, size or

23 Seafood Watch® Alaska Pollock Report November 23, 2009 sex distributions in the region. The Gulf of Alaska pollock stock is also not overfished and overfishing is not occurring, although current biomass levels are also below BMSY. In the GOA, current stocks include a high proportion of smaller individuals, but this is believed to be the result of recruitment of a strong year-class. The probability that B< B20% in 2009 is calculated at 10% for the EBS stock and 12% for the GOA stock. Because stocks are below BMSY but are not overfished and overfishing is not occurring, the stock status of pollock in the Bering Sea and the Gulf of Alaska is considered “Moderate” according to Seafood Watch® criteria.

Status of Wild Stocks Rank:

Bering Sea/Aleutian Islands; Gulf of Alaska:

Healthy Moderate Poor Critical

Criterion 3: Nature and Extent of Bycatch

Seafood Watch® defines sustainable wild-caught seafood as marine life captured using fishing techniques that successfully minimize the catch of unwanted and/or unmarketable species (i.e., bycatch). Bycatch is defined as species that are caught but subsequently discarded (injured or dead) for any reason. Bycatch does not include incidental catch (non-targeted catch) if it is utilized, accounted for and managed in some way.

Pollock is caught with mid-water trawls in the Bering Sea and Gulf of Alaska (NPFMC 2009a, 2009b). Mid-water trawls, also known as pelagic trawls, are large mesh or rope nets that are fished in the water column rather than along the ocean bottom (Pereyra 1995). According to an expert panel of scientists, managers and industry officials, mid-water trawls generally have a “low impact” on the bycatch of seabirds, sea turtles, marine mammals and sharks, and a “medium impact” on the bycatch of finfish (Chuenpagdee et al. 2003). Mid-water trawls are thought to have low bycatch rates for fish such as halibut and crabs because of the large mesh size and wing rope spacing that allows them to escape (Pereyra 1995). Global estimates of bycatch in mid-water trawls indicate that the weighted average discard rate for these fisheries worldwide is 3.4% (Kelleher 2004).

In 2007, bycatch in the Bering Sea/Aleutian Islands (BSAI) pollock fishery comprised 2.0% of total landings. This bycatch is composed of pollock (including both sub-legal and larger discarded pollock) (1.2%), non-commercially caught species (0.43%), discarded groundfish (0.28%), and prohibited species (e.g., steelhead, Pacific halibut, Pacific herring, Alaskan tanner crab, Alaskan snow crab, Alaskan king crab and Pacific salmon) (0.08%) (ADF&G 2006a, 2006b, 2008a; Ianelli et al. 2007, Hiatt et al. 2008). Although discard rates in the BSAI pollock fishery are low, there may be unaccounted effects on fish and invertebrates that fall through the large mesh trawl nets and are not brought on board (NRC 2002). For example, juvenile pollock that pass through the trawls and are not caught have been shown to exhibit behavior changes that increase their predation risk, which may be a source of unaccounted bycatch (Ryer 2002). Small fish may be damaged while passing through the mesh of the nets, but these effects are difficult to predict because mesh sizes in the fishery are unknown.

24 Seafood Watch® Alaska Pollock Report November 23, 2009

Approximately 1.1% and 1.2% of BSAI pollock were discarded relative to total BSAI pollock landings in 2006 and 2007, respectively (Figure 13) (Ianelli et al. 2008a). From 1992–1997, discard rates for the BSAI pollock fishery were below 10%; since 2000, they have been below 2% (Figure 13) (Ianelli et al. 2007).

14

12

10 s 8

6 % Discard 4

2

0 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 Year

Figure 13. Percent of discarded pollock relative to total pollock catch in the BSAI pollock fishery from 1991–2007 (Ianelli et al. 2008a).

In the Gulf of Alaska, there is also low bycatch level (relative to the targeted species) associated with the pollock fishery (Dorn et al. 2008). In 2007, bycatch in the Gulf of Alaska pollock fishery comprised 8.9% of total landings. Discarded pollock (2.86%), discarded non-target groundfish (1.78%), non-commercial species (2.00%) and prohibited species (2.27%) comprised this bycatch (Dorn et al. 2008, Hiatt et al. 2008). Discarded pollock accounts for between 1% and 3% of total pollock landings in the GOA since 1999 (Dorn et al. 2008)(Figure 14).

25 Seafood Watch® Alaska Pollock Report November 23, 2009

Figure 14. Percent of discarded pollock relative to total pollock catch in the GOA pollock fishery from 1998–2007 (Dorn et al. 2008).

Non-commercially caught species Ianelli et al. (2008a) estimated that 5,775 mt of discarded bycatch of non-commercially caught species were associated with the directed BSAI pollock fishery in 2007; roughly 0.43% of the total landings. These discards were primarily composed of jellyfish (44%), skates (23%) and squid (21%). The remaining discards consisted predominantly of finfish (Figure 15) (Ianelli et al. 2008a).

In the BSAI, mid-water pollock trawls caught an average of about 4.5 tons/year of sponges and about 0.88 tons/year of sea pens and whips from 1997–2002 (Table 8) (Ianelli et al. 2008a). While small relative to pollock catches, this amount of bycatch may have serious impacts on these sensitive, slow growing and habitat-forming organisms. In addition, observer estimates of bycatch of benthic organisms may substantially under-estimate true bycatch rates because damaged organisms may fall through the large mesh openings near the bottom of the net and never be brought on-board (NRC 2002). Since this form of bycatch indicates significant bottom contact to seafloor habitats, the impacts are discussed and considered under Criterion 4: Habitat and Ecosystem Impacts.

26 Seafood Watch® Alaska Pollock Report November 23, 2009

0%

9% 3% 4%

41% Jellyfish

23% Squid Skates

Sculpins

Sharks

20% Other fish Other species

Figure 15. Estimated composition of non-commercially caught species bycatch in the 2007 directed BSAI pollock fishery. Note: The “other species” category includes sea stars, octopus, snails and benthic invertebrates (Data from Ianelli et al. 2008a).

In the Gulf of Alaska, a total of 1,011 mt of non-commercial species, or roughly 2.0% of the total pollock landings, were incidentally caught and discarded in the directed pollock fishery in 2007 (Dorn et al. 2008). This bycatch consisted mainly of squid, sharks and eulachon (Figure 16) (Dorn et al. 2008).

27 Seafood Watch® Alaska Pollock Report November 23, 2009

Figure 16. Estimated composition of non-commercially caught species bycatch in the 2007 directed Gulf of Alaska pollock fishery. (Data from Dorn et al. 2008).

Groundfish Species targeted by groundfish fisheries are also caught as bycatch in the BSAI pollock fishery. In 2007, the BSAI pollock fishery was responsible for catching 13,019 mt of groundfish (retained or discarded) representing 0.96% of the BSAI pollock fishery’s total landings (Ianelli et al. 2008a). However, only 3,800 mt of this groundfish catch (0.28% of the pollock fishery’s total landings), excluding pollock, was discarded (Hiatt et al. 2008). Both discarded and retained groundfish catch in the pollock fishery are accounted for and incorporated into the TACs for these groundfish species (Table 3). Because they are retained, managed and accounted for, retained groundfish caught in the pollock fishery are not considered bycatch according to Seafood Watch® criteria.

Management of incidental groundfish catch in the BSAI was first addressed when the North Pacific Fishery Management Council (NPFMC) adopted Amendment 49 to the BSAI FMP, establishing the Improved Retention/Improved Utilization (IR/IU) standards for BSAI fisheries, which created retention and utilization standards for pollock and Pacific cod. While the IR/IU standards were primarily responsible for the 1998 drop in pollock discards (Figure 13), the IR/IU standards did little to address bycatch of other groundfish, which has remained relatively stable since 1997, except for bycatch of Pacific cod, which steadily increased from 1999–2006 and declined slightly in 2007 (Figure 17) (Ianelli et al. 2008a). Currently, all managed groundfish species caught incidentally in the BSAI pollock fishery (retained and discarded) are counted against their respective fisheries’ established TACs (Witherell et al. 2000). In addition, according to the 2007 NMFS Report to Congress on the Status of U.S. Fisheries, none of the groundfish species occurring in the BSAI pollock fishery (Figure 17) are overfished (NMFS 2007d).

28 Seafood Watch® Alaska Pollock Report November 23, 2009

Table 3. Incidental catch (discarded and retained) of major groundfish species in the 20067 BSAI pollock fishery (mt) (Data from Ianelli et al. 2008a, Hiatt et al. 2008).

Species Discards Retained Total Pacific cod 100 5,181 5281 Arrowtooth flounder 600 1,694 2294 Flathead sole 1000 2,743 3743 Rock sole 100 310 410 Yellowfin sole 0 21 21 Atka mackerel 100 6 106 Turbot 0 105 105

9,000 Pacific cod 8,000 Arrowtooth flounder 7,000 Flathead sole 6,000 Rock sole

5,000 Yellowfin sole Atka mackerel 4,000 Greenland turbot 3,000 Rex sole

Incidental catch (mt) catch Incidental 2,000 Alaska plaice 1,000 Pacific ocean perch All other 0 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 Year

Figure 17. Estimates of groundfish species (mt) caught in the directed BSAI pollock fishery, 1997–2006 (Ianelli et al. 2008a).

As in the BSAI, much of the non-target groundfish incidentally caught in the GOA pollock fishery is retained, and this catch is counted against the respective species’ TAC. In total, non- target groundfish catch in the GOA pollock fishery in 2007 was about 3,471 metric tons (6.85% of total pollock landings) (Dorn et al. 2008). About 900 metric tons of non-target groundfish catch, or 1.78% of pollock landings, were discarded in 2007, excluding discarded pollock (Hiatt et al. 2008). Bycatch of most non-target groundfish species in the GOA pollock fishery peaked in 2006 and declined in 2007 (Figure 18) (Dorn et al. 2008).

29 Seafood Watch® Alaska Pollock Report November 23, 2009

Figure 18. Estimates of groundfish species (mt) caught in the directed BSAI pollock fishery, 2003–2006 (Dorn et al. 2008)

Prohibited species Prohibited species are defined in the BSAI and GOA groundfish FMPs as species that must be avoided. When caught, these species must be released with minimal injury or donated to charitable programs (e.g., food banks). In the Alaska pollock fishery, prohibited species include steelhead trout (Oncorhynchus mykiss), Pacific halibut (Hippoglossus stenolepis), Pacific herring (Clupea pallasii), Alaskan king crab (Paralithodes spp.), Alaskan tanner crab (Chionoecetes bairdi), Alaskan snow crab (Chionoecetes opilio) and all Pacific salmon (Oncorhynchus spp.). The BSAI and GOA groundfish fisheries have adopted measures to regulate the take of prohibited species (NMFS 2007c). The BSAI pollock fishery is subject to prohibited species catch (PSC) limits whose exceedance may result in area closures, although these do not close the entire pollock fishery. Limits on PSC for the BSAI pollock fishery are established annually for bycatch of herring, salmon, and king, tanner and snow crabs, but not for halibut or steelhead trout. Currently, no PSC limits have been established in the GOA, but they are under consideration for Tanner crab and salmon species.

The PSC limit for Pacific herring in BSAI groundfish trawl fisheries is set at 1% of herring stock biomass. Two BSAI crab stocks (Pribilof Islands blue king crab and Bering Sea snow crab) are presently under rebuilding plans. Directed fisheries for Pribilof Islands red and blue king crab are closed due to stock concerns, and the Pribilof Islands blue king crab habitat is protected in the Pribilof Islands Habitat Conservation Zone, which is closed to all trawling. The BSAI groundfish fisheries are subject to PSC limits for Bristol Bay red king crab, EBS Tanner crab and EBS snow crab. The effect of pollock fisheries on steelhead trout populations is thought to be negligible (only one fish has been observed), hence no PSC limits exist. Limits on PSC for Pacific halibut caught in trawl fisheries in the BSAI are established annually. Limits on PSC for salmon are discussed in the “Salmon” section below.

Data for PSC in the BSAI pollock fishery were only provided as fish counts, not by weight (mt), with the exception of Pacific herring and Pacific halibut. However, based on the 2007 numbers of prohibited species taken in the BSAI pollock fishery and the average weights of those prohibited species, we were able to calculate the percentage of PSC relative to BSAI pollock landings. For Chinook and chum salmon, the average weights were based on the 2007 average 30 Seafood Watch® Alaska Pollock Report November 23, 2009 weights of incidentally caught salmon in the U.S. groundfish fisheries (Berger 2008). Average weight per species was multiplied by the number of animals caught. This number was then converted to mt and divided by total BSAI pollock landings.5 In 2007, PSC relative to BSAI pollock landings was 0.08% (Table 4) (AFSC 1999, ADF&G 2006a, 2006b, 2008a; Ianelli et al. 2008a; Berger 2008).

Table 4. Prohibited species bycatch relative to pollock landings in the BSAI, 2007 (AFSC 1999, ADF&G 2006a, 2006b, 2008a; Ianelli et al. 2008a).

A B C D E F % Bycatch relative Bycatch (mt) (D to pollock landings Average divided by Bycatch (E divided by Bycatch weight per 2204.6, the (lbs) 1,354,000 mt, the (numbers species number of lbs 2007 pollock Species caught) (lbs ) (B * C) in a metric ton) landings) Red king crab 8 6.3 50 0.02 0.000002 Tanner crab 946 2.5 2,365 1.07 0.000079 Snow crab 2,936 1.2 3,523 1.60 0.000118 Chinook salmon 121,452 6.22 755,431 342.66 0.03 Chum salmon 87,177 4.98 434,141 196.92 0.01 Pacific herring NA NA NA 345 0.03 Pacific halibut NA NA NA 262 0.019 Total 1,149 0.08 Note: numbers may not add to total due to rounding

In the GOA, bycatch of prohibited species in 2007 relative to pollock landings was about 0.44% (Table 5) (AFSC 1999, ADF&G 2006a, 2006b, 2008a; Dorn et al. 2008; Berger 2008).

Table 5. Prohibited species bycatch relative to pollock landings in the GOA, 2007 (AFSC 1999, ADF&G 2006a, 2006b, 2008a; Dorn et al. 2008). A B C D E F

% Bycatch relative to Average Bycatch (mt) (D pollock landings (E Bycatch weight per divided by 2204.6, divided by 50,668 mt, (numbers species Bycatch (lbs) the number of lbs the 2007 pollock Species caught) (lbs ) (B x C) in a metric ton) landings) Red king crab 0 6.3 0 0.00 0.00 Tanner crab 19,393 2.5 48,483 21.99 0.04 Chinook salmon 34,414 6.6 227,132 103.03 0.20 Non-chinook salmon 904 6.82 6,165 2.80 0.01 Pacific herring NA NA NA 16.55 0.03 Pacific halibut NA NA NA 78.98 0.16 Total 223 0.44 Note: numbers may not add to total due to rounding

5 No weight calculations were made for Pacific herring and Pacific halibut because their catches were already provided in metric tons. 31 Seafood Watch® Alaska Pollock Report November 23, 2009

Bycatch of halibut in the GOA pollock fishery has increased steadily in recent years, from 9.9 tons in 2003 to 79 tons in 2007 (Dorn et al. 2008). In the BSAI, halibut bycatch increased from a 10-year average of 108 tons/year during 1997–2006 to 262 tons in 2007 and 267 tons in 2008 (Ianelli et al. 2008a). While halibut bycatch still makes up a small proportion of the pollock catch, the increasing trend in halibut bycatch may be a concern.

Salmon Incidental catch of Chinook (Oncorhynchus tshawytscha) and chum salmon (Oncorhynchus keta) in the BSAI pollock fishery increased substantially in the mid-2000s (Figure 19) (72 FR 57; YRDFA 2008). While chum salmon bycatch peaked in 2005 and has since declined, Chinook salmon bycatch in the fishery increased from 2002–2007, with 121,452 fish taken in 2007 (Figure 19) (Ianelli et al. 2007, 2008; YRDFA 2008). However, the estimate of Chinook salmon bycatch for 2008 was down substantially to 19,928 fish, with bycatch under 20,000 projected for 2009 as well (Figure 19). The causes of these fluctuations in salmon bycatch are unclear, but the increase in salmon bycatch rates from 2002–2007 may reflect changing oceanographic conditions that increased co-occurrence of salmon and pollock (Stram and Ianelli 2008; Stram and Evans 2009). Because bycatch rates are influenced by the spatial distribution of pollock fishing effort, salmon abundance and spatial overlap of salmon and pollock (which varies with oceanographic conditions), it is difficult to assess the effects of bycatch reduction management policies or to predict future trends in bycatch interaction rates. The management response to the increased bycatch from 2002–2007 is discussed briefly below (see “Management of salmon bycatch” in this section) and is covered in more detail under Criterion 5: Effectiveness of Management Regime.

140,000

120,000

100,000

80,000

60,000

40,000

Number of Chinook salmon Chinook of Number 20,000

0

1 8 7 93 00 02 09 995 004 199 1992 19 1994 1 1996 1997 199 1999 20 2001 20 2003 2 2005 2006 200 2008 20 Year

32 Seafood Watch® Alaska Pollock Report November 23, 2009

800,000

700,000

600,000

500,000

400,000

300,000

200,000 Number ofchum salmon 100,000

0 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Year

Figure 19. Bycatch of Chinook (top) and chum salmon (bottom) in the Bering Sea pollock fishery. Data from 2009 are projected as of August 24, 2009. (Data from YRDFA 2008; NMFS 2009c).

Recovery of coded-wire tag (CWT) marked fish suggests that Chinook from two Endangered Species Act (ESA)-listed stocks from the Pacific Northwest—Upper Willamette River (UWR) and Lower Columbia River (LCR) stocks—are incidentally caught on occasion in the pollock fishery. BSAI groundfish fisheries are required to operate under an Incidental Take Statement (ITS) under the ESA due to take of these listed stocks. According to a NMFS supplemental biological opinion issued in 2007 to determine the effects of the groundfish fisheries on listed salmon stocks, the groundfish fishery is not likely to jeopardize these salmon stocks (NMFS 2007g). The analysis was based mainly on data prior to the record maximum bycatch of 129,978 Chinook salmon in the BSAI groundfish fisheries in 2007, which exceeded the ITS. No new biological opinion has been issued, but no CWT ESA-listed salmon have been found in samples of bycatch from 2007. Based on recent CWT recoveries in bycatch from the pollock fishery, it is estimated that about 12.5 UWR Chinook and 3.5 LCR Chinook are caught per 100,000 incidentally caught Chinook salmon in the groundfish fishery (NPFMC 2008a). While this amount of bycatch is considered too low to substantially contribute to the listed stocks’ extinction risk, there is considerable uncertainty in this estimate. Bycatch of the listed stocks is based on CWT recovery data, which reflects only CWT marked groups of each stock; there are usually other groups within a stock that are not marked and therefore not accounted for in the bycatch rate estimates (NPFMC 2008a). In addition, estimates of the stock composition of incidentally caught salmon vary widely, and recent genetic analysis suggests that Pacific Northwest-origin Chinook salmon may make up a far higher proportion of salmon bycatch in the pollock fishery than previously estimated (Seeb et al. 2008; Templin et al. 2008; NPFMC 2008a). However, mortality of ESA-listed salmon due to the pollock fishery was probably very low in 2008 and 2009 due to the overall drop in salmon bycatch. While ESA-listed salmon are a species of special concern and bycatch of these stocks is a potential conservation concern, it is presently not clear how frequently salmon from these stocks are caught in the pollock fishery.

Under the Yukon River Salmon Agreement, a treaty between the United States and Canada, the United States is required to allow sufficient Yukon River salmon to cross the border between the 33 Seafood Watch® Alaska Pollock Report November 23, 2009

U.S. and Canada to provide for agreed-upon escapement goals and harvest shares. Both parties have agreed to “maintain efforts to increase the in-river run of Yukon River origin salmon by reducing marine catches and by-catches of Yukon River salmon” (Yukon River Panel 2002). In both 2007 and 2008, Canadian escapement goals were not met (ADF&G 2008b), although the escapement goal was met in 2009.

Returns of Chinook salmon to the Yukon River have declined in recent years (NPFMC 2008a). Myers et al. (2003) analyzed scale patterns from bycatch samples collected by observers in the pollock fishery from 1997–1999 and found that western Alaskan Chinook stocks comprised about 56% of the Chinook bycatch in the pollock fishery, with about 40% of the western Alaskan component of the bycatch estimated to be Yukon River stock. Therefore, Yukon River Chinook are estimated to make up about 22% of salmon bycatch in the BSAI pollock fishery (NPFMC 2008a). Stocks of Yukon River Chinook salmon have been classified as a “stock of yield concern”6 by the Alaska Board of Fisheries (BOF) since 2000 (a status that affords protections through regulatory actions such as in-river fishery closures) with a 5-year average harvest level between 2004 and 2008 at about 34% of previous levels (Evenson et al. in press). While annual rates of subsistence catch remained stable during that time period (Figure 20), annual catch rates from in-river commercial fishermen dropped precipitously (Figure 21). In 2008, subsistence fishermen experienced mandatory reductions in allowed Chinook salmon fishing times, and the in-river commercial fishery was closed to ensure a sufficient supply of fish returning upriver to spawn (USFWS 2009). In 2009, further restrictions were implemented including a complete closure of the subsistence fishery during the first pulse of Chinook salmon (thought to contain the highest proportion of Canadian-origin fish), a U.S. Fish and Wildlife Service (USFWS) limit on subsistence fishing applying to all federal public waters for federally qualified users, and an Alaska BOF emergency regulation prohibiting the commercial sale of Chinook salmon caught incidentally in other fisheries. Though these measures appear to have been effective in 2009 at meeting most escapement goals, Chinook abundance remains low and this stock remains classified as a “stock of yield concern.” According to Seafood Watch®, a species or stock that is threatened, endangered or protected due to concerns about its abundance is considered a “species of special concern.” Due to the declines in stocks, recent fishery closures and the protection of Yukon River Chinook as a “stock of yield concern,” Yukon River Chinook salmon are considered a species of special concern according to Seafood Watch®.

6 A stock of yield concern is defined as “a concern arising from a chronic inability, despite the use of specific management measures, to maintain expected yields, or harvestable surpluses, above a stock’s escapement needs” (5 AAC 39.222(f)(42)). A chronic inability is defined as “the continuing or anticipated inability to meet expected yields over a 4 to 5 year period” (5 AAC 39.222).

34 Seafood Watch® Alaska Pollock Report November 23, 2009

Figure 20. Annual subsistence Chinook salmon catch from the Alaskan portion of the Yukon River, 1961–2007 (Figure 10.41 from NPFMC 2008a).

Figure 21. Annual in-river commercial Chinook salmon catch from the Alaskan portion of the Yukon River, 1961–2007 (Figure 10.45 from NPFMC 2008a).

A number of factors have contributed to the recent Yukon River Chinook salmon stock decline. It is uncertain to what degree bycatch in the pollock fishery has contributed to the decline in salmon populations, but the pollock fishery provides an additional source of mortality to Yukon River Chinook salmon, a stock of yield concern that is currently experiencing declines, and has been subject to required reductions and closures of the in-river fisheries. In response to public concerns expressed in-season, Alaska Department of Fish and Game Commissioner Denby Lloyd stated:

While it is true that a portion of Yukon-origin Chinook salmon are taken as bycatch in the Bering Sea pollock trawl fishery, this alone is insufficient to explain the magnitude of decline in run sizes observed in recent years. Exact numbers of Yukon-origin Chinook salmon in the bycatch are not known, though according to the best scientific information available, generally they appear to be 35 Seafood Watch® Alaska Pollock Report November 23, 2009

a small percentage of the total Yukon River run. Chinook salmon runs throughout the state have been waning in recent years and many have been well below average in 2009. This suggests a more complex explanation of the low returns to the Yukon River in recent years, such as ocean conditions and other environmental factors. Nonetheless, bycatch of Yukon River Chinook salmon in the pollock fishery has the potential to affect in-river fishery management decisions, particularly in low abundance years.

Ruggerone (2009) estimated the effects of the pollock fishery on salmon runs and harvests by calculating the proportion of terminal catches and terminal runs captured by the pollock fishery. These calculations were based on adult equivalent mortality (AEQ) estimates from the Bering Sea Chinook Salmon Bycatch Management Draft Environmental Impact Statement (DEIS) (NPFMC 2008a) as well as estimates of run size based on either radio telemetry mark-recapture studies or Pilot Station sonar counts. Adult equivalent mortality is defined as an estimate of “the number of fish that would have returned to the natal river had they not been captured in the pollock fishery” (Ruggerone 2009). This estimate is lower than the actual bycatch mortality because it incorporates salmon that would have died of natural mortality rather than returning to spawn. Because the salmon are at sea for multiple years, calculations of AEQ mortality incorporate the proportion of salmon incidentally caught in both the previous and the current year that would have returned to spawn in the current year. Therefore, AEQ mortality was relatively high in 2008 despite low bycatch in 2008 due to the high bycatch in 2007. The stock- specific AEQ mortality was calculated using the estimated stock composition of bycatch reported in the DEIS (NPFMC 2008a).

The percent of salmon in-runs captured by the pollock fishery varied by region and year, and was highest for Alaska-origin Yukon River Chinook salmon, peaking in 2007. In that year, bycatch of Alaska-origin Yukon River Chinook salmon in the pollock fishery was 10.7% of the terminal run size according to the radio telemetry mark-recapture study, or 17% of the total terminal run size according to Pilot Station sonar counts (Ruggerone 2009) (Table 6). In most other years, AEQ was generally less than 10% of terminal run size for Alaska-origin Yukon River Chinook. While this amount of bycatch may appear low, an additional 10% mortality on a declining stock may contribute to declines or impair recovery. Furthermore, little is known about the extent of other sources of mortality or the effects of this mortality on population dynamics. Additionally, bycatch mortality was high relative to direct take in the commercial and subsistence in-river fisheries; AEQ mortality in the pollock fishery was equal to total take in the Alaska Yukon in- river fisheries in 2007 and exceeded total targeted take in the Alaska Yukon River in 2008 (Ruggerone 2009)(Table 6). Estimates of AEQ for Canadian-origin Yukon River Chinook were less than 1% of terminal run size for all years. However, these estimates involve large uncertainties around the stock composition of bycatch in the pollock fishery.

36 Seafood Watch® Alaska Pollock Report November 23, 2009

Table 6a. AEQ mortality of Yukon River Chinook salmon by region, 1994-2008. Total run size estimated from radio telemetry mark-recapture study. (Table from Ruggerone 2009).

37 Seafood Watch® Alaska Pollock Report November 23, 2009

Table 6b. AEQ mortality of Yukon River Chinook salmon by region, 1994–2008. Total run size estimated from Pilot Station sonar counts. (Table from Ruggerone 2009).

Data and analyses cited here generally focus on the impact of the BSAI pollock fishery, which provides the vast majority of the pollock catch, on Chinook salmon. There is not as much data available on the impact of bycatch in the GOA pollock fishery, and the stock of origin for incidentally caught salmon in the GOA fishery remains unknown (NPFMC 2008b). However, although overall bycatch numbers are lower because the fishery is smaller, bycatch of Chinook has also been increasing in the GOA pollock fishery. In 2007, estimated Chinook bycatch in the GOA pollock trawl fishery was 34,357 fish, more than double the average from the previous four years (Figure 22) (NPFMC 2008b). This rate of bycatch is actually higher in proportion to pollock catch in the GOA than the Chinook bycatch to pollock catch ratio in the EBS (Table 7). This level of bycatch, particularly in combination with bycatch in the EBS

38 Seafood Watch® Alaska Pollock Report November 23, 2009

fishery (which is likely to include a similar stock composition) may impact incidentally caught Chinook salmon stocks.

40,000

30,000

20,000

10,000 Bycatch (# of fish) 0 2003 2004 2005 2006 2007 Year

Figure 22. Bycatch of Chinook salmon in the GOA pollock fishery, 2003–2007 (Data from NPFMC 2008b).

Table 7. Ratio of Chinook bycatch to pollock catch in the GOA and EBS pollock fisheries by weight in 2007. Number of Chinook is converted to weight using the 2007 average weight of incidentally caught Chinook in the U.S. groundfish fisheries in the GOA (6.61 lbs) (Data from Berger 2008).

Fishery Chinook Chinook Chinook Pollock catch Chinook bycatch (#) bycatch bycatch weight (mt) bycatch: weight (lbs) weight (mt) (= catch lbs/2204.622) proportion (2204.622 = by weight no. of lbs/mt) GOA (2007) 34,357 227,233 103.071 52,120 0.001978 EBS (2007) 121,452 803,267 364.356 1,394,000 0.000261

Management of salmon bycatch Since 1995, salmon bycatch in groundfish fisheries has been managed by establishing PSC limits and area closures in the BSAI (72 FR 57); however, the PSC limits have been exceeded in recent years (NMFS 2008). The BSAI pollock fishery is subject to mandated year-round accounting of all Chinook and chum salmon caught as bycatch. The Chinook salmon PSC limit is 29,000 fish per year. If the PSC limit is exceeded, the Chinook Salmon Savings Area (SSA) within the pollock fishery will close (72 FR 57). The timing of the closure depends on when the limit is exceeded: if 29,000 Chinook are caught before April 15, the Chinook SSA is closed immediately until April 15 and again from September 1 until December 31. If the limit is reached between April 15 and September 1, the SSA closes on September 1 through the end of the year. If the limit is reached after September 1, the area is closed immediately through the end of the year.

The Chum salmon PSC limit has been set at 42,000 fish per year. There is a chum SSA area that is closed to the pollock fishery every year from August 1–31, regardless of bycatch levels. In addition, if the chum (or “other” salmon) PSC limit is exceeded in the Catcher Vessel Operational Area (CVOA) between August 15 and October 14, the chum SSA will close again for the remainder of the period September 1 through October 14.

From 2003–2005, the Chinook SSA was closed to trawling from September through December due to exceedance of the PSC limit of Chinook bycatch (72 FR 57). Incidental catch of chum

39 Seafood Watch® Alaska Pollock Report November 23, 2009

salmon exceeding PSC limits triggered chum SSA closures from 2002–2005 (72 FR 57). Unfortunately, according to the NPFMC, “bycatch may have been exacerbated by the current regulatory closure regulations, as much higher salmon bycatch rates were reportedly encountered outside of the closure areas” (NPFMC 2007c).

In 2004, the NPFMC began to consider revising the existing Chinook salmon bycatch management measures for the EBS because the pollock fishing fleet reported increases in Chinook salmon bycatch following closure of the Chinook SSA. One revision, implemented in 2006, exempts pollock fishers from observing the Chinook SSA closure if they participate in a voluntary rolling hotspot system (VRHS). The intention was to minimize salmon bycatch by moving fishing operations away from areas during times of high salmon bycatch. This was an interim measure in lieu of developing alternative salmon bycatch regulatory measures. However, while reports indicate that the VRHS may have reduced Chinook salmon bycatch rates compared to what they might have been (Haflinger et al. 2007), the overall rate of Chinook salmon bycatch from 2004–2007 was high relative to historical levels and well above the PSC limit, suggesting that further management actions are needed.

In 2007, the VRHS program was formalized as Amendment 84 to the Groundfish FMP. In response to the increase in salmon bycatch and an ensuing controversy, changes to the VRHS program were implemented, including changes in the sizes of the allowed closures and in the bycatch rates triggering closure. The bycatch of Chinook salmon in 2008 (and, according to preliminary data, in 2009) was far lower than previous years, which may reflect success of the new VRHS measures, but may also reflect changes in environmental conditions or salmon abundance in pollock fishing areas. The fishing industry has also been testing experimental salmon-exclusion devices that, if successful, could allow salmon to escape from trawls without reducing pollock catch.

In addition, the NPFMC has elected to institute a new management program. In April 2009, the NPFMC voted to recommend a hard cap of 47,591 Chinook salmon annually with an allowance for vessels participating in an approved Incentive Plan Agreement (IPA)7 to catch up to 60,000 Chinook salmon a year for up to two years out of seven. Both the 47,591 and the 60,000 hard caps are higher than historical 10-year averages of bycatch, estimated at 43,328 fish from 1997– 2006 and 32,482 from 1992–2001. If finalized, this plan will take effect in 2011. More details about the proposed bycatch management plan are provided under the “Criterion 5: Effectiveness of the Management Regime” section of this document. However, because the plan will not go into effect until 2011, and it has yet to be seen how it will affect Chinook salmon bycatch levels or what the status of the Yukon River Chinook runs will be at that time, the effectiveness of these proposed management measures cannot be evaluated in this report. The effectiveness of the existing management strategy for limiting Chinook salmon bycatch is currently uncertain. However, after implementation of the hard cap on Chinook bycatch, the effectiveness of the new regulations should be evaluated.

The impact of the pollock fishery on Chinook salmon populations is uncertain since bycatch in the pollock fishery is one of many sources of mortality for these declining stocks. Additionally,

7 An Incentive Plan Agreement (IPA) is a NMFS-approved plan that provides explicit incentive(s) for each participant to avoid Chinook salmon bycatch in all years. For example, levying a fee each year for participants with above average bycatch while providing a financial reward to participants with below average bycatch. Specific IPAs are not yet determined but will be designed by industry. 40 Seafood Watch® Alaska Pollock Report November 23, 2009

estimates of the numbers of Alaskan Yukon River-origin salmon caught in the pollock fishery remain unclear due to uncertainties in the stock composition of bycatch. While bycatch interactions increased through 2007, trends in bycatch rates have been down over the past two years. Currently, bycatch of Yukon River Chinook in the pollock fishery is considered a “moderate” conservation concern according to Seafood Watch® criteria. In the future, bycatch may be considered a “low” conservation concern if rates of Chinook bycatch remain low, management efforts are deemed effective at limiting salmon bycatch even in years of high distributional overlap between salmon and pollock, and/or the health of Chinook stocks improves such that they are no longer considered a species of special concern.

Synthesis Relative to targeted landings, the pollock fishery has low overall bycatch rates in both the BSAI (1.87%) and the GOA (8.9%). Management measures have prohibited discarding pollock and groundfish species to provide vessels with an incentive to reduce waste and catches of unwanted groundfish. Additionally, all managed groundfish species caught in the Alaska pollock fishery have been accounted for in their respective FMPs. Bycatch of Chinook salmon, a species for which there is no FMP, increased to record high levels in 2007 but declined considerably in 2008 and 2009. The most recent data suggest that the pollock fishery is not likely to jeopardize endangered salmon stocks from the Pacific Northwest or their critical habitat. However, bycatch rate estimates for endangered salmon stocks are highly uncertain. In addition, returns of Alaska Yukon river Chinook salmon have been low in recent years, and subsistence and in-river commercial users in the Yukon River are experiencing reduced fishing times or fishing closures to ensure an adequate supply of salmon return to upriver spawning locations, thus causing the Alaska Department of Fish and Game to deem them a “stock of yield concern.” The effect of bycatch mortality on terminal run size varies by year and region, but at its peak, bycatch in the pollock fishery accounted for mortality of an estimated 10% or more of the total run returning to the Alaska Yukon River in 2007. In addition, the estimated bycatch mortality of Chinook salmon in the pollock fishery was equal to total take in the Alaska Yukon in-river fisheries in 2007 and exceeded total take in the Alaska Yukon River in 2008. Due to their declining populations and status as a stock of yield concern, Yukon River Chinook are considered a species of special concern by Seafood Watch®. The impact of the pollock fishery on Chinook salmon populations is uncertain, as bycatch in the pollock fishery is one of many sources of mortality for these declining stocks. Due to the regular bycatch of Alaskan Yukon River-origin Chinook salmon, a species of special concern, and the recent decrease in this bycatch, the overall bycatch rank for the pollock fishery is deemed a “moderate” conservation concern according to Seafood Watch® criteria. Seafood Watch® will continue to monitor salmon bycatch and will make any necessary recommendation changes as new information becomes available.

Nature of Bycatch Rank:

BSAI: Low Moderate High Critical

GOA: Low Moderate High Critical

41 Seafood Watch® Alaska Pollock Report November 23, 2009

Criterion 4: Effect of Fishing Practices on Habitats and Ecosystems

Habitat effects Pollock are caught exclusively using a gear type referred to by fishery managers as “mid-water trawls” (or “pelagic trawls”) in the BSAI and GOA (NPFMC 2009a, 2009b), implying minimal contact with the seafloor. These trawls are different than bottom trawls in that they do not have footrope protections and their doors do not contact the seafloor when used correctly. However, NMFS (2005b) estimates that the “mid-water trawls” used in the Bering Sea pollock fishery contact the seafloor 44% of the time. This proportion of time on the bottom was calculated using 1998–2002 data from onboard observers (see Criterion 5: Effectiveness of Management Regime) and fishing organizations (e.g., vessel skippers) (NMFS 2005b). Reported effort was converted into swept area and then multiplied by vessel speed, trawl width and the proportion of effort on the seafloor8 (NMFS 2005b). The NRC (2002) report, Effects of trawling and dredging on seafloor habitat, states that mid-water trawls “may be frequently fished in contact with the seafloor, especially in shallow water.”

Chuenpagdee et al. (2003) and the Seafood Watch Criteria respectively describe mid-water trawls as having a “very low” and “minimal” impact on the physical and biological components of the seafloor. These descriptions are not applicable to the Alaska pollock fishery as they rely on the premise that mid-water trawls are not regularly fished on the seafloor. Therefore, it would be incorrect to assess Alaska pollock trawls as “mid-water” trawls, and it is unfortunate that fishery managers use such a misleading term for this fishing gear.

Pollock aggregate in the mid-water column at depths of approximately 64–450 m (NMFS 2005b). The EBS seafloor is composed of gravel, sand and mud particles, with particle fineness correlating to depth (Figure 23) (NMFS 2005b). In the southeast EBS, sand and gravel comprise the majority of the seafloor at 50–100 m, while muddy sand and sandy mud are the predominant seafloor components from depths of 100–200 m to the continental slope (NMFS 2005b). The northeastern Bering Sea is not as extensively sampled as the southeastern Bering Sea, but Sharma (1979) reports concentrations of silt in shallow nearshore waters as well as in deep water (e.g., the continental slope) (Figure 23). Additionally, the EBS has exposed areas of relic gravel, possibly left behind by glacial deposits (NMFS 2005b).

8 The estimate for the “proportion of effort on the bottom” takes into account the duration that any part of the trawl was in contact with the seafloor and the width of trawl contact during different periods (e.g., day/night, seasons A & B). 42 Seafood Watch® Alaska Pollock Report November 23, 2009

Figure 23. Spatial distribution of seafloor substrate in the BSAI (Figure from NMFS 2005b).

While most trawling for pollock occurs in moderately resilient soft-sediment habitats, the Bering Sea slope, Aleutian Islands and Gulf of Alaska contain sensitive deepwater coral habitats. In the Bering Sea, the upper slope and shelf break are not protected from fishing, while bottom trawling is banned in the deeper areas of the slope. Bottom-contact gear is banned in a few small protected areas of Primnoa (red tree coral) habitat in the Gulf of Alaska, although many corals are found outside of these protected areas (NOAA Coral Reef Conservation Program 2008). However, because the trawls used in the pollock fishery are considered mid-water gear, they are not banned in protected areas of deepwater corals despite evidence that they may be fished on the bottom (NMFS 2005b). The diverse coral habitats in this region that are open to pollock trawling include several unique taxa, and damage from fishing has been observed in areas of deepwater coral habitat (Stone and Shotwell 2007; Stone and Hocevar 2008). Bycatch of structure-forming epifauna, including sea pens and sponges, in the pollock fishery suggest that these trawls are grazing the seafloor in biogenic habitats. In the BSAI, mid-water pollock trawls caught an average of about 4.5 tons/year of sponges and about 0.88 tons/year of sea pens and whips from 1997–2002 (Table 8) (Ianelli et al. 2008a). While small relative to pollock catches, this amount of bycatch may have serious impacts on these sensitive, slow growing and habitat- forming organisms. In addition, observer estimates of bycatch of benthic organisms may substantially under-estimate true bycatch rates because damaged organisms may fall through the large mesh openings near the bottom of the net and never be brought on-board (NRC 2002).

Table 8. Bycatch of sponges and sea pens/whips in the BSAI directed pollock fishery, 1997–2002 (Data from Ianelli et al. 2008a). 1997 1998 1999 2000 2001 2002 Average, 1997-2002 Sponge 0.8 21 2.4 0.2 2.1 0.3 4.46 bycatch (mt) Sea pen/whip 0.1 .2 .5 .9 1.5 2.1 0.8833 bycatch (mt)

43 Seafood Watch® Alaska Pollock Report November 23, 2009

“Mid-water” trawls likely have a “smoothing effect” on sedimentary substrates (NMFS 2005b). Unlike bottom trawls, mid-water trawl doors do not come into contact with the seafloor when used properly and therefore lack the door effects associated with bottom trawls (NMFS 2005b); however, their footropes may have a greater impact on non-living structures because their smaller surfaces are more concentrated and therefore exert greater pressure on the seafloor (NMFS 2005b). The effect of mid-water trawls on non-sedentary benthic organisms is likely minimal because these organisms would be immediately returned to the seafloor through the large mesh sizes characteristic of mid-water trawls (NMFS 2005b). Sessile structure-forming invertebrates are vulnerable to mid-water trawling since these animals can be dislodged by trawl footropes combing the sediment (NMFS 2005b). Based on the combined results of Ball et al. (2000) and Sparks-McConkey et al. (2001), NMFS (2005b) estimates that mid-water pollock trawls generate a median 20% reduction per gear contact of the living and non-living seafloor structures. The average estimated recovery time for physical habitat is three months for sand, nine months for silt, and one year for mud. The estimated annual recovery rate for soft-bottom structure-forming invertebrates is 20% (NMFS 2005b).

Fishing gear used in Alaska fisheries was evaluated in the Final Environmental Impact Statement for Essential Fish Habitat Identification and Conservation in Alaska (EFH EIS) to determine the ecological impact on the seafloor habitat. This analysis included calculation of a long-term effect index (LEI), the estimated eventual reduction in habitat if current fishing intensity and distribution are continued until fishery impacts and habitat recovery rates reach equilibrium, for a variety of gear types. The LEI for living structures attributed to commercial fishing in the EBS was calculated at 10.9% for both the continental shelf and the continental slope (NMFS 2005b). The pollock mid-water trawl fishery was the largest single component of both LEIs (Table 9) (NMFS 2005b). In addition, this analysis found that in the Bering Sea slope soft substrate, pollock mid-water trawls actually had a greater overall impact on the seafloor habitat than the total impact of bottom trawls in the region (Table 9), which accounts for the majority of the LEI as noted in Appendix B of the Alaska EFH EIS:

While the pollock pelagic trawl fishery was the largest single component (4.6 percent) of the total effects on living structure in the EBS sand/mud habitat, the combined effects of the bottom trawl fisheries made up all of the remaining 6.3 percent (total LEI of 10.9 percent). This was not true for living structure on the EBS slope, where nearly all (7.2 percent out of 10.9 percent) of the LEI was due to the pollock pelagic trawl fishery.

While aggregate impacts to the entire Eastern Bering Sea are useful for comparison, the localized effects of pollock trawling in areas where the pollock fishery actually occurs are much more substantial. For instance, substantial areas of the Bering Sea shelf have effect scores greater than 50% (Figure 24), while a large portion of the EBS is not fished.

44 Seafood Watch® Alaska Pollock Report November 23, 2009

Figure 24. Distribution of Long-term Effect Indices (LEIs) of fishing effects on living structures in the Bering Sea, aggregated across all fishing gears assessed in the Alaska EFH EIS (Figure B-2.3a from NMFS 2005b).

Table 9. Long-term Effect Indices (LEI) Indicating the Effects of Fishing on Habitat Features by Fishery for the Features with the Highest LEIs in Each Region (Table from NMFS 2005b).

45 Seafood Watch® Alaska Pollock Report November 23, 2009

The LEI for living structures attributed to commercial fishing in the soft sediment habitats of the Gulf of Alaska and Aleutian Islands was about 3–4%. The proportion of this impact due to pollock mid-water trawling is not available. Mid-water trawling was not found to contribute strongly to overall impacts on the living structures of the GOA slope because the GOA contains more hard-bottom habitat, mid-water trawls were assumed not to contact the seafloor when used on hard substrate, and because the relative effort is much lower in the GOA. However, on soft bottoms in both the GOA and EBS, mid-water trawls are estimated to contact the bottom 44% of the time (NMFS 2005b).

The conclusion of the EFH EIS states that the impacts of fishing on EFH for managed species in Alaska are “not more than minimal and temporary” (NMFS 2005b). The EIS conclusion was based on the professional judgment of NMFS analysts whether the identified impacts would affect populations of managed commercial fish, not on unmanaged species or broader ecosystems (NMFS 2005b). However, the NMFS conclusion was disputed by the Center for Independent Experts (CIE) in a report stating that “[t]he use of the stock abundance relative to Minimum Stock Size Threshold to assess the possible influence of habitat degradation on fish stocks was not considered to be appropriate for several reasons, including that habitat effects are only one of many factors that influence the stock abundance, the criterion provides no spatial information, and the expected lag between habitat destruction and detection of its effect on the stock productivity is expected to be long, such that the habitat may be destroyed before mitigation could be implemented” (Drinkwater 2004). The CIE report stressed the need for a precautionary approach given that effects of habitat impacts on stocks may not be detectable until irrevocable damage has occurred. In addition, the use of stock abundance as an indicator of the effect of habitat destruction on sustainability of fish stocks was deemed inappropriate because stock abundance responds to many variables and is not highly sensitive to changes in habitat quality, and the criterion did not account for the effects of localized habitat damage or destruction. Finally, the CIE recommended precautionary measures including experimental closures to fishing until the effects of fishing on habitat could be evaluated appropriately (Drinkwater 2004). The NMFS analysts did not change their “minimal and temporary” conclusion in response to the CIE report. As a result of these concerns, managers implemented

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closures to bottom trawling and eventually froze the footprint of bottom trawling in the Bering Sea, but none of these measures were applied to “mid-water” pollock trawling. Despite the CIE recommendation, there have so far been no experimental closures to better evaluate the effects of the pollock trawling.

It is important to note that the goal of the EFH EIS was to determine the effects of habitat damage on the sustainability of managed fished stocks, whereas Seafood Watch® criteria focus more broadly on the ecosystem effects of fishing, including impacts to the seafloor habitat and all biota, whether or not they are commercially important. The criteria evaluate the destructive nature of the fishing gear, the resilience of the affected habitat, and the spatial extent of the fishery. Therefore, despite the conclusion of “minimal and temporary” impacts in the EFH EIS, the analysis provides information that suggests that the impacts of mid-water trawls on the seafloor habitat are “Severe”. According to Seafood Watch® criteria, the habitat impact of mobile trawl gear dragged on the seafloor is generally considered “Severe” unless the habitat area affected is very limited in scope or highly resilient to damage.

Bottom trawling is generally considered to have “Severe” habitat impacts based on numerous studies finding alterations to habitat complexity, species diversity and abundance, and community composition due to bottom trawling (NRC 2002). The soft substrate, moderate to deep water habitat commonly trawled by the pollock fishery is considered moderately resilient. A number of studies have found habitat damage caused by trawling in the soft-sediment habitat of the Bering Sea and Gulf of Alaska. Trawling in the region reduces biomass of benthic organisms, diversity of sessile organisms and habitat structure (McConnaughey et al. 2000), as well as mean size of benthic invertebrates (McConnaughey et al. 2005). Commercial trawling on the Bering Sea shelf has also been linked to reduced density, richness and biomass of macrofauna and reduced abundance of animals such as tube-dwelling amphipods that provide structure in soft sediments (Brown et al. 2005). Similarly, trawled areas in soft-sediment habitats of the GOA were found to have significantly different epifaunal abundance and diversity compared to untrawled areas, with reduced abundance of sea whip groves in trawled areas and fewer fish where the seawhips were reduced (Stone et al. 2005). While these studies focused on the effects of bottom trawling in the region, the results of the LEI analysis from the EFH EIS suggest effects of the pollock mid-water trawls are of a similar magnitude to the effects of bottom trawling detailed here. In particular, the predictions that pollock mid-water trawls were dragged on the seafloor about 44% of the time, had a predicted cumulative LEI on Bering Sea soft substrate slope biostructure that was greater than the combined LEI of bottom trawls in the region and had an estimated LEI on Bering Sea sand/mud biostructure greater than any single bottom trawl fishery’s impact, together suggest that the damage from pollock mid-water trawls is on the same order as damage from bottom trawling and should be ranked accordingly. Given the severe impacts from trawling on the bottom and the large proportion of time that the mid-water trawls used in the pollock fishery are estimated to be in contact with the bottom, Seafood Watch deems the impacts of pollock trawling on the soft-bottom habitat of both the EBS and the GOA to be ”Severe.”

Management has attempted to discourage the use of mid-water trawls on the BSAI seafloor by banning devices that protect trawl footropes and by prohibiting vessels from having more than 20 crabs on board at any given time as this could be an indication of “bottom” trawling (NMFS 2005b). While banning trawl footrope protection devices in the BSAI may be effective in preventing mid-water trawlers from intentionally making contact with the Aleutian Islands 47 Seafood Watch® Alaska Pollock Report November 23, 2009 seafloor (due to the potential of gear damage from hard substrates), as noted above, evidence suggests that mid-water trawls are frequently dragged along the seafloor in soft-sediment habitats (NMFS 2005b) and that more stringent standards may be needed to minimize bottom contact. The effectiveness of management measures in protecting habitat from the damaging effects of trawling is discussed more fully under Criterion 5: Effectiveness of the Management Regime.

Ecosystem effects Steller sea lions The EBS and GOA groundfish fisheries remove large quantities of pollock from the marine ecosystem and the Alaska pollock fishery is the largest fishery by volume in North America. One consequence of this massive removal of biomass is the reduction of prey available to Steller sea lions and other predators. Because of the importance of pollock and other groundfish to the ecosystem, management limits the total catch of all groundfish-complex species in the BSAI to two million metric tons and closes the pollock fishery if pollock stocks decline below 20% of the estimated unfished biomass (NPFMC 2009a).

Steller sea lions are protected under the Marine Mammal Protection Act (MMPA) and the Endangered Species Act (ESA). As a federally protected species, the Steller sea lion is considered a species of “special concern” according to Seafood Watch criteria. In Alaska, the western population of Steller sea lions is listed as endangered under the ESA, while the eastern population is listed as threatened. The western population occurs from west of Prince William Sound to Russia and Japan, while the eastern population occurs from Southeast Alaska south to California (Sease and Gudmundson 2002).

Since the 1960s, the western population of Steller sea lions has declined by more than 80% (Sease and Loughlin 1999). The Steller sea lion population in western Alaska continued to decline throughout the 1980s and 1990s, with a more rapid decline seen in the 1980s (Figure 25). Between 2000 and 2004, the western Steller sea lion population in Alaska rose 12% and remained stable from 2004–2008 (Fritz et al. 2008). Despite this recent increase, there is considerable variation in western Steller sea lion population trends across its range (Fritz et al 2008), which may inhibit the population’s ability to recover throughout its historical range (Winship and Trites 2006). Steller sea lion pup numbers rose by 4% between 2001 and 2005 (Holmes et al. 2007), which is a somewhat encouraging signal; however, it is a smaller increase than for non-pups, and the ratio of pups to non-pups has been steadily declining since the 1990s, a trend that may indicate a problem with adult female reproductivity (Holmes and York 2003; Holmes et al. 2007). Although the increases in non-pup Steller sea lions observed from 2000 to 2004 were the first observed region-wide in over 20 years, it is premature to conclude that such increases signify an end to the long-term population decline (Fritz et al. 2008).

Despite these assessments, a recent population viability analysis suggests that, overall, there is a low risk of Steller sea lions going extinct in the next 100 years. However, some subpopulations could go extinct if the population trends observed in the 1990s were to repeat (Winship and Trites 2006).

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Figure 25. Phases and possible factors of the Steller sea lion decline (Figure from NMFS 2001).

Large declines in juvenile survival and smaller declines in adult survival and birth rates appeared to lead to the steep declines in the Steller sea lion population that occurred in the 1980s. In contrast, in the 1990s and 2000s, juvenile and adult survival rates increased, but continuing low fecundity is believed to be inhibiting the sea lion’s recovery (Fritz and Hinckley 2005, Atkinson et al. 2008; NMFS 2008).

Causes of the Steller sea lion decline Both bottom-up and top-down pressures have been suggested as causes of the decline of the western stock of Steller sea lions (NRC 2003). Bottom-up hypotheses include nutritional limitation via a lack of prey or decreased prey quality, non-lethal disease and climate change (NRC 2003). Top-down hypotheses include predation by killer whales, incidental takes of Steller sea lions in fishing gear, direct harvest of Steller sea lions, shootings and pollution or disease resulting in increased mortality (NRC 2003). The existing data on the Steller sea lion decline provide no conclusive evidence supporting any one hypothesis, and the decline is likely a result of several of these factors working in concert (NRC 2003).

Fritz and Hinckley (2005) note that while direct, top-down sources of mortality such as hunting and incidental take in fisheries likely contributed to the 30-year decline of Steller sea lion populations (see “Top-down hypotheses” below), they are not sufficient to explain the Steller sea lion decline—carrying capacity must have declined as well (suggesting the influence of bottom- up forces such as nutritional stress).

Bottom-up hypotheses One bottom-up hypothesis suggests that declines in the Steller sea lion population are related to a diet shift from small, high fat content forage fish to species with lower fat content, such as pollock (the “junk food hypothesis”) (Trites and Donnelly 2003). Prior to the mid-1970s, common Steller sea lion prey included sand lance, cephalopods, herring, greenlings, rockfishes and smelts (Fiscus and Baines 1966; Pitcher 1981). Despite the prevalence of capelin in Steller sea lion diets prior to the 1980s, it is no longer a primary prey species (Sinclair and Zeppelin

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2002), possibly due to the high natural variability of capelin or the regime shift that occurred during the 1970s (NRC 1996). The mean fat content for pollock and capelin are similar (Iverson et al. 2002), but reduced densities of pollock may have resulted in decreased foraging efficiency (Shima et al. 2001). Although percent fat content varies both seasonally and with age groups, mean fat content for pollock ranges from 1.5–5.1%, while mean fat content for herring ranges from 3.5–14.2% across age groups (Iverson et al. 2002). In addition, recent studies have concluded that there is a correlation between diet diversity and population change (Merrick et al. 1997). However, Fritz and Hinckley (2005) and Atkinson et al. (2008) state that the junk food hypothesis has been refuted by numerous studies, and that the diet diversity hypothesis is not well supported.

Evidence supporting nutritional stress due to competition with fisheries as a cause of the Steller sea lion decline is mixed. Studies have shown that pollock and Atka mackerel are the two most common prey for Steller sea lions (Merrick et al. 1997; Sinclair and Zeppelin 2002), and groundfish fishing has been estimated to have reduced available Steller sea lion prey by up to 40% (NMFS 2001).

Pollock biomass was large relative to the Steller sea lion decline observed during the 1990s (NRC 2003). However, threats to the Steller sea lion most likely arise from more severe localized depletion rather than overall regional depletion of prey (NMFS 2001). For example, reduced pollock biomass in the “Donut Hole” region of the central Bering Sea due to heavy fishing pressure occurred at the same time that reduced Steller sea lion numbers were observed at nearby rookeries (Calkins and Goodwin 1988; Lowry et al. 1989). However, pollock in the eastern Bering Sea and Gulf of Alaska were increasing during this time period.

The nutritional stress hypothesis is supported by data showing that body growth of female Steller sea lions was reduced after the population decline that began in the 1970s (Calkins et al. 1998). In addition to Steller sea lion population decline, markers of sea lion health such as condition, growth and reproductive performance also declined during the same time period (NRC 2003). However, more recent data are equivocal in their support of the nutritional stress hypothesis as a cause of Steller sea lion declines in the 1980s and 1990s. Nutritional stress may result in a suite of changes to vital rates including reduced survival rates for all age classes and reduced fecundity, as well as increased numbers of emaciated animals (Atkinson et al. 2008). While reduced fecundity is considered a major cause of the Steller sea lion decline and subsequent failure to recover, and nutritional stress is likely a potential contributing factor to this reduced fecundity, there has been no evidence of increasing numbers of emaciated adults and juveniles, and adult survival showed no decline in the 1990s. The observed reduction in fecundity alone cannot account for the steep declines in Steller sea lion populations (Atkinson et al. 2008), although it could be inhibiting recovery (Holmes et al. 2007; NMFS 2008).

Ecosystem models indicate that changes in prey abundance alone cannot explain the full magnitude of the Steller sea lion decline (NRC 2003). It is likely that the causes for the Steller sea lion decline have changed over time (DeMaster et al. 2001) and are different from those impeding recovery (NMFS 2008).

Top-down hypotheses Increased killer whale predation, incidental take in fisheries, subsistence hunting, and increased pollution and disease have been proposed as possible top-down factors contributing to the 50 Seafood Watch® Alaska Pollock Report November 23, 2009

decline of Steller sea lions. Matkin et al. (2002) estimated that Steller sea lions comprise 5–20% of killer whale diets. While estimates of how many Steller sea lions are consumed by killer whales vary, some studies have concluded that the rate of removal by killer whales was insufficient to cause the decline, but may be limiting the recovery of the Steller sea lion population (Matkin et al. 2002). However, other studies have concluded that killer whale predation on Steller sea lions is greater than previously believed, and that this predation is the predominant factor in the decline of Steller sea lions (Springer et al. 2003).

In 1972, commercial hunting for Steller sea lions was prohibited with the enactment of the MMPA; from 1963–1972 more than 45,000 Steller sea lion pups were taken commercially (Merrick et al. 1987). From 1993–1995, the subsistence fishery for Steller sea lions took 412 animals each year (Angliss and Lodge 2002), and by 2001 this number had declined to 198 animals for the entire year (Wolfe et al. 2002). Incidental take in fisheries is another source of mortality for Steller sea lions. From 1966–1988, incidental take estimates in the foreign and joint venture fisheries were as high as 20,000 animals (Perez and Loughlin 1991). Over the last 25 years, the number of Steller sea lions killed incidentally in all groundfish fishing gear (not specifically the pollock fishery) has decreased dramatically. From 1968–1973 Steller sea lion mortality averaged over 1,600 animals per year; from 1974–1985, this number declined to 600 mortalities per year, and in the early 1990s Steller sea lion mortalities were less than 20 animals per year (Fritz et al. 1995). Estimates of incidental takes in the BSAI groundfish trawl fishery dropped to an average of 7.8 animals per year from 1996–2000 (Angliss and Lodge 2002). This drop is due both to the demise of the foreign and joint venture fisheries and to the management measures designed to reduce fishery and marine mammal interactions.

Atkinson et al. (2008) found that incidental take in fisheries, commercial hunting and shooting of sea lions likely contributed to the Steller sea lion decline, but are no longer threats impeding the population’s recovery. Overall, mortality rates for Steller sea lions due to hunting and incidental take were high during the 1970s and 1980s when low survival rates led to steep declines in the population, but currently survival rates are high and mortality due to hunting and incidental take of Steller sea lions is low, supporting the hypothesis that the causes of the decline in the populations differ from the factors currently impeding their recovery.

Factors impeding the Steller sea lion recovery One bottom-up hypothesis for the lack of recovery of the western Steller sea lion population is reduced reproductive success, caused by nutritional limitation due to competition with groundfish fisheries, particularly those targeting pollock, Atka mackerel and Pacific cod. There are a number of variables affecting the level of competition between the pollock fishery and Steller sea lions. There is overlap between the size of pollock targeted and the depth fished (NMFS 2001). The nutritional demands of Steller sea lions (females, in particular) are higher in the winter months, suggesting that prey availability in the winter months may be more important than in other months (NMFS 2001). In addition to these direct effects, pollock fishing boats and gear may affect Steller sea lions by disrupting their normal foraging patterns and by reducing their foraging efficiency by disrupting prey schools (NMFS 2001). Shima et al. (2001) conclude that decreases in the mean density of adult pollock, combined with changes in the distribution of pollock, resulted in decreased foraging efficiency for Steller sea lions. The availability of prey is more important than the absolute amount of prey present in terms of the survival and reproductive success of Steller sea lions (NMFS 2004b).

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The National Research Council (2003) found that “…top-down sources of mortality appear to pose the greatest threat to the current population” while nutritional stress hypotheses are “…unlikely to represent the primary threat to recovery,” but that “…there is insufficient evidence to fully exclude fisheries as a contributing factor to the continuing decline.” However, changes in the vital rates of Steller sea lions are not consistent with the finding that top-down sources pose the greatest threat to Steller sea lion populations. Top-down sources of mortality should be reflected in low survival rates. While juvenile survival rates were low in the early 1980s, likely contributing to the steep declines at that time (York 1994, Holmes and York 2003, Holmes et al. 2007), survival rates increased in the 1990s and 2000s while fecundity continued to decrease (Holmes and York 2003, Fay and Punt 2006, Holmes et al. 2007). These changes in vital rates suggest that bottom-up effects leading to reduced fecundity may be currently impeding the Steller sea lion’s recovery. More recent sources concur that nutritional stress caused by competition from fisheries cannot be ruled out as a significant contributing factor to the failure of SSL populations to recover (Atkinson et al. 2008), and that the threat to Steller sea lions from competition with fisheries remains “potentially high” (NMFS 2007c). While nutritional stress appears likely to be contributing to the inability of Steller sea lion populations to recover, it is not possible based on available evidence to distinguish between competition with fisheries and environmental change as a driver of nutritional stress (Atkinson et al. 2008). NMFS (2008) concluded in the Steller sea lion recovery plan that the three most likely threats to recovery (ranked ‘potentially high’ in the plan) are environmental change, killer whale predation and the competitive effects of fishing.

In 2000, trawling in Steller sea lion critical habitat was prohibited by a court order for a four month period (65 FR 49766, August 15, 2000) as a result of litigation by numerous conservation groups. Critical habitat for Steller sea lions includes 20 nautical miles (nm) around all major rookeries and haulouts, and three offshore foraging areas (50 CFR 226.202). To protect the critical habitat of Steller sea lions, NMFS has implemented a number of management measures designed to reduce interactions between fishing operations and Steller sea lions in these areas. The effectiveness of these measures remains uncertain (see Criterion 5: Effectiveness of the Management Regime).

Northern fur seals There are also concerns over potential effects of removing pollock from the ecosystem on northern fur seals (Callorhinus ursinus). The majority of northern fur seal breeding (74%) occurs in the Pribilof Islands (NMFS 2004b). There are two stocks of northern fur seals, one in the BSAI and GOA (the eastern Pacific stock), and one in California (NMFS 2004b). The population trend of northern fur seals in the BSAI and GOA has been affected by a number of factors that have changed over time. The harvest of female and juvenile northern fur seals was directly related to population trends prior to the 1970s (NMFS 2004b). The northern fur seal population increased during periods of no commercial harvest, or when harvest was limited to a land-based male harvest (NMFS 2004b). However, the onset of the harvest of females and juveniles from the mid-1950s until the late 1960s resulted in a population decline (York and Hartley 1981; NMFS 2004b). Surprisingly, despite the removal of harvest pressure on females in the late 1960s, the population has continued to decline (Towell et al. 2006).

Pup surveys suggest that the population has been declining at a rate of more than 5% since 1998 due to unknown causes (NMFS 2004b). Subsistence hunting by Alaska natives occurs for juvenile males, with an average annual take of 1,340 seals each year (NMFS 2004b). The take of 52 Seafood Watch® Alaska Pollock Report November 23, 2009 only juvenile males is expected to have a much lower impact on the population than taking females or adult males (Angliss and Allen 2009). The incidental take of northern fur seals in the U.S. groundfish fisheries is negligible, although the incidental take of northern fur seals in the foreign and joint venture fisheries averaged 22 animals per year from 1978 to 1988 (Perez and Loughlin 1991). The number of territorial males with females in the Pribilof Islands declined by 9.4% from 1999 to 2000, and by 6.3% from 2000 to 2001 (Robson 2002); declines in the abundance of adult males have continued in St. George (Angliss and Allen 2009). Estimated pup production declined by 6.1% per year from 1998–2006 on St. Paul Island (Figure 26), and by 3.4% per year from 1998–2006 on St. George Island (Figure 27) (Angliss and Allen 2009). Northern fur seals are considered to be a “depleted” stock under the Marine Mammal Protection Act (MMPA) due to the large historical decline. The eastern Pacific population is estimated at 665,550 individuals (Angliss and Allen 2009), down from a historical high of an estimated 2.1 million in the 1940s–1950s (Briggs and Fowler 1984).

Groundfish fisheries interact with the northern fur seal population through direct competition for target and bycatch species, as well as through overlap between northern fur seal foraging areas and groundfish fishing areas (NMFS 2004b). Both historical and recent studies have found that pollock is the dominant prey in fur seal diets on the Bering Sea shelf (the foraging habitat of most fur seals that breed in the Pribilof Islands), but not in the Gulf of Alaska (Scheffer 1950, Kajimura 1984, Perez and Bigg 1986, Sinclair et al. 1994, Sinclair et al. 1996, Robson 2001, Ream et al. 2005, Zeppelin and Ream 2006).

Sterling (2009) explored the connections between pollock abundance, fur seal diving and foraging behavior, and pup health. The depths of female fur seal foraging dives corresponded to the strength of year classes, with more shallow dives when there was a strong year class of Age-0 or Age-1 pollock (which live higher in the water column), and deeper dives when the strong year classes matured and the abundance of pollock recruits was low (Sinclair et al. 1994; Sterling 2009). In addition, in years when Age-1 to Age-5 pollock were highly abundant, female fur seals’ foraging trips were shorter and pups were heavier. Overall, fur seal diving trips were shorter and pups were heavier in years when pollock was dominant compared to years when forage fish (e.g., herring or capelin) were dominant (Sterling 2009).

The importance of pollock in the diet of fur seals in the Eastern Bering Sea and the relationship between pollock abundance and fur seal pup weight (which correlates to pup survival) suggest that declining pollock abundance in recent years may be contributing to the fur seals’ decline. Antonelis et al. (1997) found that the importance of pollock in the fur seal diet corresponded to regional bathymetry. Juvenile pollock were the most dominant prey for fur seals at St. Paul Island, which is the most distant of all sampled sites from the continental shelf-edge; squid were the most common prey at Medny Island (of the Commander Islands of Russia), which is adjacent to the continental shelf-edge, and both squid and pollock were important prey items for fur seals at St. George Island, which has an intermediate oceanographic environment. While pup production on St. Paul Island continues to decline steeply (Figure 26)(Angliss and Allen 2009), pup production has declined more gradually and recently seems to have stabilized at St. George Island (Figure 27)(Angliss and Allen 2009). The population at the Commander Islands has been stable or increasing since the mid-1950s (Burkanov et al. 2007). Similarly, fur seal populations on Bogoslof Island in the eastern Aleutians have been increasing while pup production has been declining on the Pribilof Islands (Towell et al. 2006). While fur seals breeding on St. George and Bogoslof Island can forage in pelagic off-shelf habitats where squid and other pelagic prey 53 Seafood Watch® Alaska Pollock Report November 23, 2009 are abundant, fur seals breeding on St. Paul require abundant on-shelf resources in order to forage successfully while returning frequently to feed their pups due to St. Paul’s distance from the continental shelf edge. Continuing declines of fur seal populations on St. Paul Island, while populations are decreasing more slowly on St. George and increasing on Bogoslof, may reflect a decline in available prey on the shelf relative to off-shelf conditions. Juvenile pollock are the dominant prey in the shelf habitat, and it is likely that the population declines and poor recruitment of pollock are contributing to fur seal decline on St. Paul Island and that competition from the pollock fishery may exacerbate the fur seals’ nutritional stress.

Management measures implemented to reduce fishing effort in Steller sea lion critical habitat may have resulted in a redistribution of effort in areas important to northern fur seals (NMFS 2004b), thereby emphasizing the increased need for an ecosystem-based management approach.

Figure 26. Decline in pup production on St. Paul Island (Figure from Angliss and Allen 2009).

Figure 27. Decline in pup production on St. George Island (Figure from Angliss and Allen 2009).

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Synthesis The mid-water trawls used to harvest pollock are estimated to be fished along the seafloor in the EBS and GOA approximately 44% of the time. In the EBS, where pollock fishing mainly takes place in moderately resilient habitats such as deep sandy and muddy areas, estimates of the long- term effects of fishing on the habitat suggest that the pollock fishery contributes the largest component of fishery-attributed habitat impacts of any single fishery in the region. The impact of the pollock fishery’s mid-water trawls exceeds the combined impact of all bottom trawling on the slope habitat. Because mid-water trawls are estimated to frequently contact the bottom in both the GOA and EBS, mid-water trawls rank as a mobile, bottom-tending gear. There is conflicting evidence regarding the degree of impact the pollock fishery exerts on the ecosystem. Considering the importance of pollock as a prey species, the removal of a large biomass of these fish each year may be the fishery’s main impact on the ecosystem. The fishery is likely one of several contributors to the decline of Steller sea lions and northern fur seals. Both top-down (e.g., increased predation by killer whales) and bottom-up (e.g., nutritional stress) processes have been determined to play a role in the decline of Steller sea lions. Recent research suggests that there are likely several contributing factors to the Steller sea lion population decline. Causes of the 30-year decline in Steller sea lion populations may differ from factors currently impeding their recovery, but nutritional stress due to competition from fisheries is likely to be a contributing factor. Competition with the pollock fishery may also impact populations of northern fur seals, which have been declining recently, particularly in areas where foraging fur seals are dependent on on-shelf habitats where pollock are the dominant prey. There is conflicting evidence regarding the role of the pollock fishery in the decline of the endangered Steller sea lion and northern fur seal, and therefore these ecosystem impacts are considered a moderate conservation concern. Overall, the effect of pollock fishing practices on habitat and the ecosystem is a “Severe” conservation concern according to Seafood Watch® due to the mobile, bottom-tending gear being fished on a large scale in moderately resilient habitats combined with conflicting evidence of ecosystem impacts.

Effect of Fishing Practices Rank:

Benign Moderate Severe Critical

Criterion 5: Effectiveness of the Management Regime

Management of Alaska pollock: Background In U.S. waters, pollock is managed by NMFS under the guidance of the North Pacific Fishery Management Council (NPFMC). There are two different FMPs for pollock, the Fishery Management Plan for Groundfish of the Gulf of Alaska and the Fishery Management Plan for the Bering Sea/Aleutian Islands Groundfish. Both of these FMPs were first implemented in 1978 and have been amended numerous times (NPFMC 2002). Management measures include permit requirements, limited entry, time and area closures, quotas, gear restrictions, bycatch reduction measures, reporting requirements and observer monitoring (Table 10).

Table 10. Commercial management measures for the pollock fishery.

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Management Total Size Observer Jurisdictions Allowable Gear Restrictions Area Closures Sources Limit Coverage & Agencies Catch 2008 None – 100% Numerous area TAC: all required on closures have NPFMC 2002a; NMFS; North 1 million pollock boats > 125 been Dorn et al. 2003, Pacific mt in the caught Fishery is ft; 30% for implemented to 2007; Ianelli et al. Fishery Bering is restricted to use of boats > 60 reduce the habitat 2003; NPFMC Management Sea; landed mid-water trawls ft.; not and ecosystem 2004a; NPFMC Council 53,590 mt to required on effects of the 2004b in the Gulf reduce boats < 60 ft. fishery of Alaska discards

In the Alaska groundfish fishery, three harvest levels have been set: the overfishing level (OFL), the acceptable biological catch (ABC), and the total allowable catch (TAC). The TAC is the annual quota for the fishery, the ABC is based on a single-species biological perspective, and the OFL defines the amount of harvest that would result in overfishing (Witherell et al. 2000). The ABC is always set lower than the OFL; the TAC is set below or equal to the ABC while taking social and economic factors into account. In determining quota levels, the NPFMC accepts advice from its Scientific and Statistical Committee (SSC) when setting the ABC, and from an Advisory Panel when setting the TAC. Stocks are classified into management “Tiers” depending on the quality of information available and the status of a particular stock. The OFL and ABC are determined according to criteria that vary by tier (Table 11) (NPFMC 2009a, 2009b).

Fishing for pollock in the Bering Sea is divided into two seasons—the “A season” targets the winter spawning aggregation of pollock starting on January 20 and generally lasting four to six weeks, while the “B season” generally opens on June 1 and lasts throughout October (Ianelli et al. 2003). The TAC for pollock in the Gulf of Alaska is divided both seasonally and regionally (NPFMC 2002a).

Table 11. Criteria for determining the Overfishing Level (OFL) and Allowable Biological Catch (ABC) for BSAI and GOA groundfish. The default value of a is set at 0.05, although the Scientific and Statistical Committee may choose to set it at a different value for a specific stock. The fishing mortality rate that would reduce the spawning potential ratio (SPR) to 40% of the unfished SPR is represented by F40%. The long-term average biomass expected under average recruitment while F=F40% is represented by B40%. In the pollock fishery, there is an additional requirement to close fishing if B < B20%. Source: NPFMC 2009a,b. Tier and Criteria FOFL FABC Tier 1: reliable point estimates for B and BMSY, reliable pdf for FMSY

1a: B/BMSY > 1 mA, the arithmetic mean of the <= mH, the harmonic mean of pdf of FMSY the pdf 1b: a < B/BMSY <= 1 mA × (B/BMSY - a)/(1 - a) < = mH × (B/BMSY - a)/(1 - a) 1c: B/BMSY <= a 0 0 Tier 2: reliable point estimates for B, BMSY, FMSY, F35% and F40% 2a: B/BMSY > 1 FMSY < =FMSY × (F40% /F35%)

2b: a < B/BMSY < = 1 FMSY × (B/BMSY - a)/(1 – a) < = FMSY × (F40% /F35%)× (B/BMSY - a)/(1 - a) 2c: B/BMSY <= a 0 0 56 Seafood Watch® Alaska Pollock Report November 23, 2009

Tier 3: reliable point estimates for B, B40%, F35% , and F40% 3a: B/B40% > 1 F35% <=F40% 3b: a < B/B40% <= 1 F35% × (B/B40% - a)/(1 – a) <= F40% × (B/B40% - a)/(1 - a) 3c: B/B40% <= a 0 0 Tier 4: reliable point estimates F35% <=F40% for B, F35% , and F40% Tier 5: reliable point estimates M <= 0.75 x M for B and natural mortality rate M Tier 6: reliable catch history Average catch from 1978– 0.75 × OFL from 1978–1995 1995, unless an alternative value is established by the SSC on the basis of the best available scientific information

In addition to the harvest rules described above, the pollock fishery is subject to additional management measures. The optimum yield for the groundfish-complex fishery in the BSAI is considered to be 85% of historical MSY, which is estimated at 1.4–2 million metric tons. The upper end of this range, two million metric tons, is set as the total annual cap for the BSAI groundfish complex. If recommended TACs would exceed two million metric tons in any year, the total TAC across all groundfish fisheries, including pollock, must be reduced so that the total is no more than two million metric tons (NPFMC 2009a). Also, under the American Fisheries Act of 1997, the offshore pollock fishery has been rationalized with fishing rights allocated to sectors under the Pollock Conservation Cooperative. This rationalization helps address the overcapitalization and “race to fish” that results from open-access fishing, and has reduced the number of vessels fishing for pollock in the area (Wilen and Richardson 2008). Pelagic trawling effort in the BSAI, dominated by pollock, has declined since the mid-1990s and remained stable since then. Pelagic trawling effort in the GOA and AI declined in the 2000s, due in part to measures designed to protect Steller sea lions (Figure 28) (Boldt 2008).

Figure 28. Gulf of Alaska, Aleutian Islands, and Bering Sea pelagic trawl effort (observed pelagic trawl tows), 1990–2007 (Figure from Boldt 2008). 57 Seafood Watch® Alaska Pollock Report November 23, 2009

Under the Community Development Quota (CDQ) program, a portion of pollock and other groundfish quotas are allocated to various Alaska village communities to provide investment opportunities and economic benefits (NMFS 2009d).

Stock status, scientific monitoring, and scientific advice In the Alaska pollock fishery, stock assessments are up-to-date and considered complete and robust. Scientists produce annual stock assessments using fishery-dependent and fishery- independent data, and collect data related to the status of the stock as well as short-term and long-term abundance trends. In the Gulf of Alaska and Aleutian Islands, for instance, the Alaska Fisheries Science Center has conducted trawl surveys since 1984. Trawl surveys are currently conducted every two years (Dorn et al. 2003). In the EBS, bottom trawl surveys are conducted annually to estimate the biomass of near-bottom pollock, and biennial echo-integration trawl surveys (EIT) are conducted to estimate the biomass of off-bottom pollock (Ianelli et al. 2008a). These surveys also provide estimates of the age and size structure of the population.

Managers do not have a track record of exceeding scientifically recommended catch limits. The NPFMC has consistently set the TAC at or below the ABC limit recommended by its scientific advisors in the Gulf of Alaska and Bering Sea, and catches have generally been below the TACs (Ianelli et al. 2003). In the Gulf of Alaska, catches were higher than the TAC in seven of the years between 1990 and 2003 (for these seven years, catch exceeded the TAC by an average of 7.8%) (Dorn et al. 2004)(Figure 29). In the Bering Sea, catches were higher than the TAC in three of the years between 1994 and 2003 (for these three years, catch exceeded the TAC by an average of less than 1%) (Ianelli et al. 2004; NMFS 1994-2003)(Figure 29).

Two controversial issues regarding the pollock fishery—the level of Chinook salmon bycatch (see Criterion 3: Nature and Extent of Bycatch) and the effects of pollock fishing on the endangered western population of Steller sea lions (see Criterion 4: Effect of Fishing Practices on Habitats and Ecosystems)—have motivated comprehensive data collection and analysis programs. In both cases, it has not been clearly demonstrated that the resulting management strategies have been successful in mitigating the possible negative effects of pollock fishing on these species. The effectiveness of the implemented management strategies is discussed in detail below.

58 Seafood Watch® Alaska Pollock Report November 23, 2009

1,600,000 140,000

1,400,000 120,000

1,200,000 100,000 1,000,000 80,000 800,000 60,000 600,000 EBS Catch 40,000 400,000 EBS Catch and TAC (mt) TAC and EBS Catch EBS TAC (mt) TAC and Catch GOA GOA Catch 200,000 20,000 GOA TAC 0 0 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008

Figure 29. Pollock TAC in the Bering Sea and Gulf of Alaska, 1989–2008 (Data from Dorn et al. 2008; Ianelli et al. 2008a).

Bycatch Management has reduced discards of pollock and Pacific cod since 1998 by requiring that vessels retain and utilize all pollock and Pacific cod catch, known as the Improved Retention/Improved Utilization (IR/IU) program. Although the IR/IU program results in fewer discards, the conservation community remains concerned that the utilization of juvenile pollock as fishmeal and baitfish does little to create an incentive to protect juvenile pollock from being caught (e.g., AMCC 2001).

Regarding Chinook salmon, in December 2008 the NPFMC released the Bering Sea Chinook Salmon Bycatch Management Draft Environmental Impact Statement/Regulatory Impact Review/Initial Regulatory Flexibility Analysis (EIS) report describing three alternative management strategies for reducing Chinook salmon bycatch (status quo, hard-cap, triggered closure), along with the projected impacts (NPFMC 2008a). A preferred preliminary alternative (PPA) was also included that represented the Council's preliminary decision, agreed to in June 2008, to propose a hard-cap management strategy that involved placing either a 47,591 or 68,392 annual cap on the number of Chinook salmon that could be caught as bycatch.

After considerable debate and public comment, in April 2009 the NPFMC voted on an Alaska Department of Fish and Game motion to recommend a strategy that provides two options to the pollock fishers in the EBS (NPFMC 2009d). Pollock fishers are subject to a hard cap of 47,591 fish annually unless their sector participates in an approved Incentive Plan Agreement (IPA). If an IPA is approved for a given sector, vessels that choose not to participate in the IPA are subject to their allocated portion of a lower (“opt-out”) cap of 28,496. Sectors operating under an IPA may exceed their proportion of 47,591 fish up to twice in seven years with no penalty as long as they remain under their total allocation of 60,000 fish. If the 47,591 cap is exceeded more than

59 Seafood Watch® Alaska Pollock Report November 23, 2009

twice in seven years, the hard cap for that sector is permanently reduced to that sector’s portion of the annual 47,591. While the NPFMC believes that the financial incentives to reduce bycatch under an IPA will ultimately lower salmon bycatch in both high and low salmon encounter years and result in lower overall bycatch than a simple hard cap of 47,591 fish (NPFMC 2009d), this management scheme allows bycatch of up to 60,000 fish annually in some years, despite the fact that this exceeds typical historical bycatch rates (Figure 19). The NPFMC recommendation must be approved by the Department of Commerce before becoming final. If approved, the plan will take effect beginning with the 2011 fishing season (NPFMC 2009d).

The Alaska Federation of Natives (AFN), which represents many of the subsistence Chinook salmon fishers, recommended a lower cap of only 30,000 Chinook salmon, which was considered in the original hard-cap analyses but was not part of the PPA (AFN 2008). The AFN also asked for immediate implementation of the plan rather than waiting until the start of the 2011 fishing season. In addition, the regulatory board that oversees Chinook salmon management in Alaska, the Alaska Board of Fisheries, requested a hard cap of just 32,482 fish (Jensen 2009), but the Department of Fish and Game responded that they believed the Council’s IPA plan and cap of 47,591 fish (with a bycatch of up to 60,000 fish permitted for up to two years out of seven) would be effective in reducing Chinook bycatch (Lloyd 2009). The U.S. State Department’s representative on the NPFMC, Nicole Ricci, testified that the cap ultimately chosen by the Council was not low enough to meet U.S. obligations to Canada under the Pacific Salmon Treaty (Hopkins 2009). Among alternatives considered for the hard cap, the EIS included the 10-year average level of Chinook bycatch from 1997–2006 (43,328 fish) and from 1992–2001 (32,482); both the 47,591 and 60,000 hard caps that were ultimately selected are higher than these historical averages (NPFMC 2008a).

Although the bycatch reduction program has not yet gone into effect, one example of a proposed IPA designed by the catcher-processor industry is a financial incentive plan (FIP) that provides payments or levies fees proportional to a particular vessel’s “undercatch” or “overcatch” of Chinook salmon relative to a performance standard (Madsen and Paine 2009). The catcher- processor sector also suggested tradable bycatch allocations on the individual vessel level (Madsen and Paine 2009). Economic analysis suggests that both tradable bycatch allocations and a reward/penalty system similar to the proposed FIP would create strong incentives for individual vessels to lower their bycatch by inducing a high marginal value to avoiding Chinook salmon. This approach should theoretically result in lower overall bycatch than a simple hard cap of 47,591 fish (Kochin et al. 2008). However, the success of the IPAs will clearly depend on the specific proposal, and NMFS will neither evaluate IPAs for their potential success nor hold any sector to the proposals described above. The IPAs will be chosen by industry, and NMFS will approve IPAs that describe incentives for individual vessels to reduce bycatch in both high and low salmon encounter years (NPFMC 2009d).

The hard cap/IPA plan addresses only bycatch of Chinook salmon; bycatch of chum salmon will be treated separately. Currently, management is considering programs to constrain bycatch of chum salmon, and it is likely that any management program to reduce chum bycatch will go into effect in 2012 at the earliest.

While management has taken steps to reduce Chinook bycatch in the pollock fishery, the effectiveness of current measures is still being debated, resulting in a ranking of “moderate” conservation concern for the bycatch factor of management effectiveness. Seafood Watch® does 60 Seafood Watch® Alaska Pollock Report November 23, 2009

not evaluate the success of proposed management measures until they are in place and will re- evaluate the effectiveness of bycatch reduction measures after the hard cap/IPA plan goes into effect in 2011. If new management measures prove effective in maintaining low levels of Chinook and chum bycatch in future years, this factor could change to a “low” conservation concern.

Fishing practices The pollock fishery has adopted several precautionary management measures to protect the ecosystem. Total take of groundfish species in the BSAI is limited to two million metric tons, and pollock fishing will be closed if biomass declines below 20% of the unfished biomass (NPFMC 2009a). In the Aleutian Islands, the North Pacific Fisheries Management Council has adopted a Fishery Ecosystem Plan to provide an ecosystem context for fisheries decisions, incorporating interactions among fisheries, abiotic and biological components of the environment, and socio-economic considerations (NPFMC 2007d). In a decision demonstrating adherence to the precautionary principle, the NPFMC recently voted to prohibit the expansion of commercial fishing in Arctic waters within the U.S. Exclusive Economic Zone (EEZ) (NPFMC 2009c).

Managers have attempted to address the deleterious habitat effects of trawling by permitting fishermen to target pollock only with mid-water trawls and by banning the use of bottom trawls in the pollock fishery (since 1999). In order to mitigate the habitat effects of mid-water trawls, devices protecting trawl footropes have been banned and vessels are prohibited from having more than 20 crabs on board, as this could be an indication of “bottom” trawling (NMFS 2005b). While these measures have succeeded in preventing the intentional contact of mid-water trawls with fragile seafloor habitats such as hard substrates (e.g., the Aleutian Islands), it has done little to impede the use of mid-water trawls on the soft-substrate habitats of the EBS (NMFS 2005b). Despite these measures, the pollock fishery is estimated to have the greatest impact on living habitat structure on the Bering Sea shelf and slope of any single fishery in the region (NMFS 2005a). The performance standard of no more than 20 crabs on board may be insufficient for preventing seafloor damage, as pelagic trawls may disturb the bottom and damage benthic organisms without violating this standard. As noted by the National Research Council, “[b]ecause 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” (NRC 2002).

Management has also implemented several measures to address the interaction of the pollock fishery with Steller sea lions (NPFMC 2002). In 1999, the NPFMC found that the pollock fishery jeopardized the continued survival of Steller sea lion populations. The Biological Opinion issued in 2000 proposed management measures to be implemented in the 2001 fishing season to alleviate jeopardy to the Steller sea lion populations (Bowen et al. 2001). As a result of this process, the pollock quota is now allocated both spatially and seasonally to prevent large removals of Steller sea lion prey from localized areas (Witherell et al. 2000). Management measures include establishing pollock fishery exclusion zones around sea lion rookeries and haulout sites, reducing the proportion of the TAC that may be taken in sea lion critical habitat, and dividing the TAC into seasons to spread the impact of the pollock fishery over time (Ianelli et al. 2008a). However, to determine the impacts of pollock fishing on Steller sea lions, both the National Research Council (NRC 2003) and the Steller Sea Lion Recovery plan (NMFS 2007c) 61 Seafood Watch® Alaska Pollock Report November 23, 2009 recommended a large-scale field experiment comparing Steller sea lion populations in control areas with areas where fishing mortality is experimentally reduced. Implementation of these proposed experiments was listed as a condition of MSC certification, but these field experiments have not been carried out, although the condition has been closed (Rice et al. 2009).

The effectiveness of management measures to protect Steller sea lions is still under evaluation (Ianelli et al. 2004). The amount of pollock caught in Steller sea lion critical habitat increased overall in the Bering Sea since 2000 (Figure 30) while exhibiting a net decrease in the Gulf of Alaska (Figure 31) (NMFS 2007c). In the Gulf of Alaska, catch in critical habitat declined from nearly 100,000 mt in 1999 to just over 60,000 mt in 2004 (Figure 31) (NMFS 2007c). In the Bering Sea, however, the critical habitat catch increased from about 1 million mt in 1999 to over 1.25 million mt in 2004 (Figure 30) (NMFS 2007c). Hennen (2006) found that correlations between Steller sea lion populations and commercial fishery activity weakened after 1991 and concluded that management measures implemented in certain rookeries have minimized the effects of commercial fisheries in those areas. The Aleutian Island directed pollock fishery was closed by the NPFMC in 1999 due to concerns over the recovery of Steller sea lion populations (Barbeaux et al. 2004). The fishery was reopened in 2005, but areas around Steller sea lion rookeries and haulouts remain closed, effectively limiting fishing to two small areas near Adak Island. Overall, the slight increase in Steller sea lion pups since 2000 and smaller increase in non-pups since 2001 are encouraging and may reflect modest success of the management program. However, the effectiveness of management regarding Steller sea lion populations is still in debate since concerns remain that the role of pollock as prey is not adequately understood or addressed in the setting of TACs, Steller sea lion recovery goals (as stated in NMFS 2001) have not yet been met, and the recommended large-scale field experiments to determine the impact of pollock fishing have not been carried out (Rice et al. 2009). In addition, there are no management efforts aimed at reducing the effect of the pollock fishery on declining fur seal populations, and management efforts designed to protect Steller sea lions by redistributing fishing effort may have inadvertently increased pressure on fur seal populations (NMFS 2004b).

Figure 30. Pollock catch from Steller sea lion critical habitat in the BSAI, 1991–2004 (Figure from NMFS 2007c).

62 Seafood Watch® Alaska Pollock Report November 23, 2009

Figure 31. Pollock catch from Steller sea lion critical habitat in the GOA, 1991–2004 (Figure from NMFS 2007c).

The effectiveness of management measures to protect seafloor habitat is debated due to evidence suggesting that mid-water trawls are frequently fished on the bottom with effects of a similar magnitude to bottom trawling in the Bering Sea soft-bottom habitat. Similarly, the effectiveness of management measures to protect marine mammals is debated since Steller sea lion recovery goals have not yet been met, the role of the pollock fishery in preventing Steller sea lion populations from recovering is still uncertain, and there are no measures to protect declining northern fur seal populations.

Enforcement In the Bering Sea and Gulf of Alaska, there is 100% observer coverage for fishing boats greater than 125 ft and 30% observer coverage for fishing boats greater than 60 ft (Chaffee et al. 2004a). Due to this high level of observer coverage, enforcement in the pollock fishery is considered highly effective.

Management track record Pollock stock productivity in the Bering Sea has historically been stable, but began declining in 2003. In the GOA, stocks have been declining for over two decades, and current abundance is a small fraction of previous levels. Currently, B/BMSY for pollock in both fisheries is between 0.5 and 1.0. If the female spawning biomass falls below B20%, or 20% of the unfished biomass, the ABC is set at zero as a precautionary measure to protect sufficient pollock biomass to support Steller sea lion populations (Chaffee et al. 2004a and 2004b). Management has recently responded to low biomass estimates by setting lower TACs in both regions. In the Bering Sea, although the ABC was adjusted downward as the stock declined, TACs were stable for several years at levels substantially below the ABC in order to comply with the overall two million mt cap for BSAI groundfish (Ianelli et al. 2008a). In response to low stock abundance, managers reduced the TAC in 2007 and again in 2008 in the Bering Sea (Figure 29). In the GOA, biomass has been decreasing since the mid-1980s and has been below the BMSY proxy since 1998. The TAC has varied from year to year but was lowered in 2006, 2007 and 2008 (Figure 29).

In the Bering Sea, fishing at levels similar to current harvest rates has been sustained for over thirty years with stocks fluctuating but remaining above B20%. However, it remains to be seen whether current TACs are sufficiently precautionary to allow the stocks to rebuild to BMSY. 63 Seafood Watch® Alaska Pollock Report November 23, 2009

Spawning stock abundance and Age-3+ biomass are currently at the lowest levels since 1980 (Figure 6), a time when recruitment was relatively high with several strong year-classes poised to enter the fishery (Figure 7). In the 2007 BSAI stock assessment, Ianelli et al. (2007) noted that five consecutive years of below-average recruitment (2001-2005) due to unfavorable oceanographic conditions constituted a “unique event for this stock.” The present combination of harvest pressure, low stock size and a series of below-average incoming year classes appears to be unprecedented for BSAI pollock. Projections that the stocks will recover within the next few years under current harvest rules depend on estimates of a strong year-class in 2006. While the strength of the 2006 year class is estimated to be above average, “a high degree of uncertainty in the magnitude of the 2006 year class remains, and the estimated confidence bounds nearly encompass the mean value,” contributing to uncertainty in stock predictions. Similarly, in the GOA biomass is at the lowest levels since the early 1970s, a time of exceptionally high recruitment. Recruitment rates have been low in recent years (Figure 9), creating a combination of low stock size and poor recruitment that appears to be unique in the history of GOA stock exploitation. While stock assessments using 2009 survey data are not yet available, preliminary 2009 bottom trawl and acoustic survey indices from the Bering Sea suggests that biomass remains at low levels (NMFS 2009e). While conservation groups have voiced concerns that overfishing is responsible for the declines in biomass, according to Doug DeMaster, Director of NOAA's Alaska Fisheries Science Center, “[t]he decreased biomass appears to be a cyclical fluctuation and is not a result of overfishing, which has caused problems in other fisheries worldwide” (NMFS 2009e).

However, there are concerns that harvest rules used to set ABC in the pollock fishery are not sufficiently precautionary and ecosystem-based, considering both uncertainty and the importance of Alaska pollock as food for a variety of predators (Marz and Stump 2002). A condition of MSC certification was to re-evaluate harvest rules from an explicitly ecosystem-based perspective and incorporate scientifically determined limit reference points to ensure that adequate biomass remains for predators. However, the fishery has not scientifically evaluated whether the B20 limit reference point or the overall harvest rule leaves sufficient biomass for predators. Despite this, the certifier closed the condition in 2009, citing continued scientific uncertainty regarding how limit reference points should be set in an ecosystem context (Rice et al. 2009). While the models used to set ABC are designed to be precautionary, it is unclear how conservative these catch limits are given the high uncertainty in the productivity of stocks. The GOA stocks are managed under Tier 3 using F35% as a proxy for FMSY. In an analysis of the harvest rules used in the BSAI and GOA groundfish fisheries, Goodman (2002) reported:

The adequacy (and safety) of F35% as a surrogate for FMSY depends on the inherent productivity of the stock. For most of the BSAI/GOA target stocks this surrogate appears to be adequate, though the case of the GOA pollock stock, which has declined from its 1985 stock size under this management system, warrants a closer look.

Field (2002) raised similar concerns that pollock may not be as inherently resilient as the harvest rules assume:

There could reason to suspect F40% might not be sustainable for some more “typical” groundfish as well. The observation by Mace and Sissenwine (1993) that many small gadids have high replacement %SPR values could suggest that 64 Seafood Watch® Alaska Pollock Report November 23, 2009

pollock are more vulnerable to overfishing under aggressive harvest strategies than currently believed, in part because life histories may be closer to those of forage species than that of larger piscivores such as Pacific (or Atlantic) cod. Certainly the central role that juvenile and adult pollock play in food webs throughout the Bering Sea and Gulf of Alaska might support such a conclusion. The observation by Hutchings (2000,2001) that many stocks (including a disproportionate number of gadids) have not shown strong signs of recovery following high levels of depletion further indicates that some stocks may not be as robust as the theoretical populations for which these reference points were developed. Consequently, management for those stocks with significant downward trajectories may require greater conservatism than is inferred from straightforward application of the current harvest policy.”

The analyses cited above focus on BSAI and GOA groundfish harvest rules based on F35% and F40%, such as the harvest rules used in Tier 3, because most groundfish including GOA pollock are managed as Tier 3 stocks. When both Tier 1 and Tier 3 harvest rules are applied to calculate ABCs for BSAI pollock, which has recently been managed under Tier 1, the ABC under Tier 3 are more conservative than the ABC under Tier 1 (Ianelli et al. 2007, Ianelli et al. 2008a). This suggests that if Tier 3 harvest rules are not inherently precautionary for pollock, Tier 1 harvest rules may not be sufficiently precautionary either.

Pollock stocks fluctuate in response to environmental conditions, and the response of pollock to varying climate conditions is complex. For example, while warm conditions are generally believed to favor high recruitment success for pollock, recent evidence suggests that in very warm years, when the water column is highly stratified, pollock recruits may suffer higher over- winter mortality due to low energy storage, leading to poor recruitment success (Ianelli et al. 2008a). This inherent variability of stocks and sensitivity to environmental conditions exacerbates concerns about uncertainty in stock projections, particularly as global climate change may have a dramatic but as yet poorly understood influence on pollock populations. While climatic fluctuations and resulting variability in stocks is not under fisheries managers’ control, a “new approach that incorporates climatic as well as fishing effects” would benefit management of this and other stocks that are sensitive to environmental conditions (Benson and Trites 2002). Currently, low stock abundance in both BSAI and GOA are attributed to environmental conditions, but it is important to recognize that “fishing may hasten the decline of stocks that are already declining due to natural reasons,” as when fishing on spawning aggregations in the Shelikof Strait (GOA) combined with poor recruitment led to a 67% decline in GOA pollock biomass between 1981 and 1993 despite the fact that harvest rates remained stable and at what was considered sustainable levels (NMFS 2000).

Concerns about uncertainty and variability are compounded by the reliance of harvest rules on reference points relative to unfished biomass estimates, since unfished biomass estimates are not only uncertain, but also change over time and may be influenced by fishing. Stock assessments make use of two different estimates of “unfished biomass”: B0, which is based on recruitment estimated from a stock-recruitment model, and B100, based on empirical estimates of recruitment since 1978. Stock assessments estimate the probability that a stock is below 20% of B0, but other reference points (e.g., B35% and B40%) are based on B100 calculated from a time series of recruitment data. Currently, estimates of B100 are higher than estimates of B0. However, B100 also may represent a “sliding baseline,” because if recruitment declines over time, B100 can also 65 Seafood Watch® Alaska Pollock Report November 23, 2009

decline (Field 2002; Marz and Stump 2002). According to NMFS (2000), “[i]f recruitment is a function of stock size, or if it exhibits a declining trend over time, then the stock may not be sufficiently protected under the existing management scheme” because target reference points may decline as stocks decline. Finally, uncertainty about the quantity of pollock removed in Russian waters provides additional rationale for a risk-averse harvest strategy (Ianelli et al. 2007). To the credit of pollock managers, they have recognized the need for precautionary management given uncertainty and declining stocks, and at times have set the ABC below the maximum ABC determined from Tier 1 harvest control rules in order to promote stock stability (Ianelli et al. 2007). However, the amount of adjustment needed to set a more appropriate ABC is difficult to quantify in the absence of more conservative control rules.

In spite of these concerns, independent reviews of the harvest strategy used in the pollock fishery determined that “[b]y the standards of most of the world’s large commercial fisheries, this management system is conservative” (Goodman 2002) and that “the current application of the F40% target harvest rate in the North Pacific satisfies the criteria for implementation of the precautionary approach based on the interpretation of the technical guidelines form implementing National Standard 1” (Field 2002).

Evaluating the appropriateness of the harvest rules in an ecosystem context is more complex. To protect Steller sea lions, the pollock fishery must close if biomass drops below 20% of unfished biomass, which adds a measure of safety for pollock predators as well as for the stability of pollock stocks. However, this global control rule does not address the ecosystem impact of a 60% reduction in pollock biomass (i.e., fishing at F40% with no reduction in mortality rates until biomass reaches B40%) (NMFS 2000). While NMFS (2000) cites a lack of empirical evidence that a 40–60% reduction in spawning stock biomass endangers ESA-listed predators, a truly precautionary strategy would shift the burden of proof to demonstrating that harvest rates are sustainable in an ecosystem context. According to Field (2002), “there is no clear consensus on what would actually constitute precautionary harvest policies or rates from a multispecies or ecosystem perspective,” but “there seems to be no empirical evidence that F40% is precautionary from the perspective of interspecific interactions.”

Because the fishery has not scientifically assessed harvest control rules from an ecosystem perspective (previously a condition of MSC certification), it is unclear whether these harvest rules are sufficiently ecosystem-based (Rice et al. 2009). Field (2002) concludes that from a single species perspective, and according to national guidelines for precautionary fisheries management, the harvest control rules used in the pollock fishery are precautionary, but greater precaution in the national guidelines themselves may be warranted to account for uncertainty and ecological impacts:

F40% has consistently been judged as inadequate by stock assessment authors, the SSC and the Council as a precautionary harvest rate. These measures that have been buil[t] into ABC decisions are consistent with greater precaution, and fisheries management by the North Pacific Council can and should be considered precautionary from a single species perspective as delineated by the National Standard guidelines and technical guidance. However, there may be a lack of precaution associated with the guidelines (and subsequent implementation) themselves, as evidenced by the wide range of opportunities for error, the increasingly observed low productivity of many stocks, the potential consequences 66 Seafood Watch® Alaska Pollock Report November 23, 2009

of impacts such as evolutionary and demographic shifts, the potential for past and current depletion of localized stock structure, and obviously the trophic and habitat related impacts.

Overall, pollock stocks have been variable and are currently low and declining. However, the pollock fishery has a history of adhering to scientific recommendations produced under harvest control rules that are considered conservative by standards used in most commercial fisheries. Biomass has remained above the limit reference points set to protect Steller sea lions and other predators, and managers have recently reduced TACs in response to declining populations. Due to declines in stock abundance and the importance of pollock as a forage species, managers are encouraged to take a leadership role in developing truly precautionary, ecosystem-based management policies that can sustain stocks and address the concerns described above.

Synthesis Both fishery-independent and dependent data are regularly collected and utilized in conducting Alaska pollock stock assessments, resulting in one of the most data-rich fisheries in the world. Managers have routinely set quotas at more conservative levels than recommended by scientific advisors. The stock productivity of pollock has historically been maintained in the Bering Sea, although there have been recent declines, while stocks in the Gulf of Alaska are in long-term decline. Managers responded to declines in abundance and below-target biomass levels by lowering the TAC in 2008 and 2009 in both regions. Whether the lower TACs are sufficient to allow stocks to rebuild remains to be seen and depends heavily on estimates of a strong year- class in 2006. Harvest rules are considered conservative from a single-species, standard fisheries management perspective. However, the TACs may not sufficiently incorporate a precautionary, ecosystem-based approach to account for the importance of pollock as a prey species as well as for the inherent uncertainty in stock projections. Management measures have been implemented to address potential habitat effects, ecosystem effects, and bycatch associated with the pollock fishery. The effectiveness of measures implemented to reduce habitat and ecosystem impacts of the pollock fishery are in debate. Measures implemented to reduce habitat impacts have likely had some positive effects, though some estimates indicate that the pollock fishery remains the most damaging fishery on Bering Sea soft-sediment seafloor habitats. The effectiveness of measures related to Steller sea lions is still under evaluation and little has been done to address potential impacts on fur seals. High bycatch of Chinook salmon in recent years combined with precipitous declines in Yukon River Chinook salmon returns raises concerns over the existing bycatch management strategy. Beginning in 2005, the NPFMC and NMFS responded to the need to revise salmon bycatch regulations—by allowing fishermen to participate in a voluntary rolling hot spot program to avoid areas with the highest bycatch rates—while also exploring other management options to reduce bycatch. Although bycatch levels were low in 2008 and 2009, the effectiveness of existing bycatch management measures remains uncertain. The NPFMC decided on a hard cap and an incentive program to reduce Chinook salmon bycatch in 2009. The new salmon bycatch regulations will not be implemented until 2011 and will be evaluated once they are in effect. While there is some debate about the effectiveness of management actions addressing pollock stock abundance, bycatch, and habitat and ecosystem effects, managers have taken progressive action on most of the conservation issues in this fishery. The effectiveness of management in reducing bycatch and mitigating habitat impacts are in debate and therefore ranked moderate (yellow). The track record for maintaining stock productivity is ranked moderate because, while stocks have varied and are currently declining, management has responded appropriately. Stock assessments, scientific monitoring, adherence to 67 Seafood Watch® Alaska Pollock Report November 23, 2009

scientific catch recommendations and enforcement are considered highly effective (green). Overall, management in this fishery is considered “Highly Effective” because the majority of management factors are green and the remaining factors are not red.

Effectiveness of Management Rank:

Highly Effective Moderately Effective Ineffective Critical

IV. Overall Evaluation and Seafood Recommendation

Pollock is considered inherently resilient to fishing pressure due to life history characteristics such as an early age at first maturity. Pollock stocks in the Bering Sea and Gulf of Alaska are not overfished, and overfishing is not occurring. However, in both regions pollock biomass is below BMSY, and stock status is considered a “moderate” conservation concern. The mid-water trawls used to catch pollock have low bycatch rates, but they impact the seafloor habitat due to frequent bottom contact. There is debate surrounding the role of the pollock fishery in the decline of Chinook salmon caught as bycatch as well as declines in Steller sea lions and northern fur seals due to competition for prey. These concerns result in a “moderate” bycatch conservation concern and a “high” conservation concern for habitat and ecosystem effects. The North Pacific Fishery Management Council has promoted numerous measures to maintain the productivity of the pollock stock and minimize any adverse effects of the fishery, but the effectiveness of these measures is debated. Management of the pollock fishery is considered highly effective. The preceding suite of criteria results in a recommendation of “Good Alternative” for pollock from the Bering Sea and Gulf of Alaska.

Improvements in stock status, bycatch and habitat impacts in the future could result in a change in recommendation. Despite relatively strong management, stock status and bycatch remain moderate conservation concerns, and habitat damage remains a severe conservation concern. These issues present an opportunity for the pollock fishery to set a standard for strong ecosystem-based management. While some stock fluctuations will occur regardless of harvest strategy, with more conservative harvest rates stocks are predicted to return to levels above BMSY more quickly. If this improvement in stock status occurs, Seafood Watch® will re-evaluate the fishery and the stock status ranking may change to a low conservation concern. However, if the stock declines below B20%, stock status will be considered overfished according to Seafood Watch criteria, which could result in a high conservation concern. In addition, if the fishery implements effective Incentive Plan Agreements (IPAs) or other measures that are demonstrated to constrain salmon bycatch to low levels and/or Yukon River salmon runs recover, the bycatch ranking for Alaska pollock may change to a low conservation concern. Finally, while the habitat and ecosystem effects of the pollock fishery’s mid-water trawls are currently ranked “severe” due to the large amount of time spent on the bottom, managers may improve this score by prohibiting mid-water trawls from contacting the bottom and enforcing this regulation with a stronger performance standard. Implementing experimental closures to evaluate management strategies for Steller sea lions (as per prior MSC conditions) and to evaluate effects on habitat (as

68 Seafood Watch® Alaska Pollock Report November 23, 2009 per the Center for Independent Experts recommendations) could provide additional information relevant to the Habitat/Ecosystem Criterion ranking.

Seafood Watch® will continue to monitor changes in the pollock fishery. If the fishery takes actions that lead to improved stock status, sustained low bycatch of salmon and other species of special concern, and reduced habitat and ecosystem impacts, the overall recommendation for Alaska pollock may be changed from Good Alternative to Best Choice.

69 Seafood Watch® Alaska Pollock Report November 23, 2009

Table of Sustainability Ranks

Conservation Concern Sustainability Criteria Low Moderate High Critical Inherent Vulnerability √ Status of Stocks √ Nature of Bycatch √ Habitat & Ecosystem Effects √ Management Effectiveness √

Overall Seafood Recommendation:

Best Choice Good Alternative Avoid

Acknowledgments

Seafood Watch® thanks Chris Oliver of the North Pacific Fishery Management Council, Dani Evenson of the Alaska Department of Fish and Game, John Hocevar of Greenpeace, Jon Warrenchuk of Oceana and five anonymous reviewers from government agencies who graciously reviewed this report for scientific accuracy.

Scientific review does not constitute an endorsement of the Seafood Watch® program, or its seafood recommendations, on the part of the reviewing scientists. Seafood Watch® is solely responsible for the conclusions reached in this report

70 Seafood Watch® Alaska Pollock Report November 23, 2009

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VI. Appendices

Appendix I. Wild-capture Fisheries Evaluation

Capture Fisheries Evaluation

Species: Walleye Pollock Region: Alaska

Analysts: Jesse MarshMarsh, & Date: MayOctober 11, 12,2009 2009 Tim ThiesenTheisen, & Robin Pelc

Seafood Watch™ defines sustainable seafood as originating from sources, whether fished9 or farmed, that can maintain or increase production in the long-term without jeopardizing the structure or function of affected ecosystems.

The following guiding principles illustrate the qualities that capture fisheries must possess to be considered sustainable by the Seafood Watch program. Species from sustainable capture fisheries: • have a low vulnerability to fishing pressure, and hence a low probability of being overfished, because of their inherent life history characteristics; • have stock structure and abundance sufficient to maintain or enhance long-term fishery productivity; • are captured using techniques that minimize the catch of unwanted and/or unmarketable species; • are captured in ways that maintain natural functional relationships among species in the ecosystem, conserves the diversity and productivity of the surrounding ecosystem, and do not result in irreversible ecosystem state changes; and • have a management regime that implements and enforces all local, national and international laws and utilizes a precautionary approach to ensure the long-term productivity of the resource and integrity of the ecosystem.

Seafood Watch has developed a set of five sustainability criteria, corresponding to these guiding principles, to evaluate capture fisheries for the purpose of developing a seafood recommendation for consumers and businesses. These criteria are: 1. Inherent vulnerability to fishing pressure 2. Status of wild stocks 3. Nature and extent of discarded bycatch 4. Effect of fishing practices on habitats and ecosystems 5. Effectiveness of the management regime

Each criterion includes: • Primary factors to evaluate and rank • Secondary factors to evaluate and rank • Evaluation guidelines10 to synthesize these factors • A resulting rank for that criterion

9 “Fish” is used throughout this document to refer to finfish, shellfish and other wild-caught invertebrates. 10 Evaluation Guidelines throughout this document reflect common combinations of primary and secondary factors that result in a given level of conservation concern. Not all possible combinations are shown – other combinations should be matched as closely as possible to the existing guidelines. 88 Seafood Watch® Alaska Pollock Report November 23, 2009

Once a rank has been assigned to each criterion, an overall seafood recommendation for the species in question is developed based on additional evaluation guidelines. The ranks for each criterion, and the resulting overall seafood recommendation, are summarized in a table. Criterion ranks and the overall seafood recommendation are color-coded to correspond to the categories of the Seafood Watch pocket guide:

Best Choices/Green: Consumers are strongly encouraged to purchase seafood in this category. The wild- caught species is sustainable as defined by Seafood Watch.

Good Alternatives/Yellow: Consumers are encouraged to purchase seafood in this category, as they are better choices than seafood in the Avoid category. However there are some concerns with how this species is fished and thus it does not demonstrate all of the qualities of a sustainable fishery as defined by Seafood Watch.

Avoid/Red: Consumers are encouraged to avoid seafood in this category, at least for now. Species in this category do not demonstrate enough qualities to be defined as sustainable by Seafood Watch.

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CRITERION 1: INHERENT VULNERABILITY TO FISHING PRESSURE Guiding Principle: Sustainable wild-caught species have a low vulnerability to fishing pressure, and hence a low probability of being overfished, because of their inherent life history characteristics.

Primary Factors11 to evaluate Intrinsic rate of increase (‘r’) ¾ High (> 0.16) ¾ Medium (0.05 - 0.16) ¾ Low (< 0.05) ¾ Unavailable/Unknown

Age at 1st maturity ¾ Low (< 5 years) ¾ Medium (5 - 10 years) ¾ High (> 10 years) ¾ Unavailable/Unknown

Von Bertalanffy growth coefficient (‘k’) ¾ High (> 0.16) ¾ Medium (0.05 - 0.15) ¾ Low (< 0.05) ¾ Unavailable/Unknown

Maximum age ¾ Low (< 11 years) ¾ Medium (11 - 30 years) ¾ High (> 30 years) ¾ Unavailable/Unknown

11 These primary factors and evaluation guidelines follow the recommendations of Musick et al. (2000). Marine, estuarine, and diadromous fish stocks at risk of extinction in North America (exclusive of Pacific salmonids). Fisheries 25:6-30. 90 Seafood Watch® Alaska Pollock Report November 23, 2009

Reproductive potential (fecundity) ¾ High (> 100 inds./year) ¾ Moderate (10 – 100 inds./year) ¾ Low (< 10 inds./year) ¾ Unavailable/Unknown

Secondary Factors to evaluate

Species range ¾ Broad (e.g. species exists in multiple ocean basins, has multiple intermixing stocks or is highly migratory) ¾ Limited (e.g. species exists in one ocean basin) ¾ Narrow (e.g. endemism or numerous evolutionary significant units or restricted to one coastline)

Special Behaviors or Requirements: Existence of special behaviors that increase ease or population consequences of capture (e.g. migratory bottlenecks, spawning aggregations, site fidelity, unusual attraction to gear, sequential hermaphrodites, segregation by sex, etc., OR specific and limited habitat requirements within the species’ range).

¾ No known behaviors or requirements OR behaviors that decrease vulnerability (e.g. widely dispersed during spawning) ¾ Some (i.e. 1 - 2) behaviors or requirements ¾ Many (i.e. > 2) behaviors or requirements

Quality of Habitat: Degradation from non-fishery impacts ¾ Habitat is robust ¾ Habitat has been moderately altered by non-fishery impacts ¾ Habitat has been substantially compromised from non-fishery impacts and thus has reduced capacity to support this species (e.g. from dams, pollution, or coastal development)

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Evaluation Guidelines

1) Primary Factors a) If ‘r’ is known, use it as the basis for the rank of the Primary Factors. b) If ‘r’ is unknown, then the rank from the remaining Primary Factors (in order of importance, as listed) is the basis for the rank.

2) Secondary Factors a) If a majority (2 out of 3) of the Secondary Factors rank as Red, reclassify the species into the next lower rank (i.e. Green becomes Yellow, Yellow becomes Red). No other combination of Secondary Factors can modify the rank from the Primary Factors. b) No combination of primary and secondary factors can result in a Critical Conservation Concern for this criterion.

Conservation Concern: Inherent Vulnerability

¾ Low (Inherently Resilient) ¾ Moderate (Moderately Vulnerable) ¾ High (Highly Vulnerable)

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CRITERION 2: STATUS OF WILD STOCKS

Guiding Principle: Sustainable wild-caught species have stock structure and abundance sufficient to maintain or enhance long-term fishery productivity.

Primary Factors to evaluate

Management classification status ¾ Underutilized OR close to virgin biomass ¾ Fully fished OR recovering from overfished OR unknown ¾ Recruitment or growth overfished, overexploited, depleted or “threatened”

Current population abundance relative to BMSY ¾ At or above BMSY (> 100%)

¾ Moderately Below BMSY (50 – 100%) OR unknown EBS = 0.75; GOA = 0.64

¾ Substantially below BMSY (< 50%)

Occurrence of overfishing (current level of fishing mortality relative to overfishing threshold)

¾ Overfishing not occurring (Fcurr/Fmsy < 1.0) EBS = 0.64; GOA = 0.5 ¾ Overfishing is likely/probable OR fishing effort is increasing with poor understanding of stock status OR Unknown

¾ Overfishing occurring (Fcurr/Fmsy > 1.0)

Overall degree of uncertainty in status of stock ¾ Low (i.e. current stock assessment and other fishery-independent data are robust OR reliable long-term fishery-dependent data available) BSAI, GOA ¾ Medium (i.e. only limited, fishery-dependent data on stock status are available) ¾ High (i.e. little or no current fishery-dependent or independent information on stock status OR models/estimates broadly disputed or otherwise out-of-date)

Long-term trend (relative to species’ generation time) in population abundance as measured by either fishery-independent (stock assessment) or fishery-dependent (standardized CPUE) measures ¾ Trend is up ¾ BSAI: Trend is flat or variable (among areas, over time or among methods) OR Unknown

¾ GOA: Trend is down

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Short-term trend in population abundance as measured by either fishery-independent (stock assessment) or fishery-dependent (standardized CPUE) measures ¾ Trend is up ¾ GOA: Trend is flat or variable (among areas, over time or among methods) OR Unknown

¾ BSAI: Trend is down

Current age, size or sex distribution of the stock relative to natural condition ¾ BSAI, GOA: Distribution(s) is(are) functionally normal ¾ Distribution(s) unknown ¾ Distribution(s) is(are) skewed

Evaluation Guidelines

A “Healthy” Stock: 1) Is underutilized (near virgin biomass) 2) Has a biomass at or above BMSY AND overfishing is not occurring AND distribution parameters are functionally normal AND stock uncertainty is not high

A “Moderate” Stock: 1) Has a biomass at 50-100% of BMSY AND overfishing is not occurring 2) Is recovering from overfishing AND short-term trend in abundance is up AND overfishing not occurring AND stock uncertainty is low 3) Has an Unknown status because the majority of primary factors are unknown.

A “Poor” Stock: 1) Is fully fished AND trend in abundance is down AND distribution parameters are skewed 2) Is overfished, overexploited or depleted AND trends in abundance and CPUE are up. 3) Overfishing is occurring AND stock is not currently overfished.

A stock is considered a Critical Conservation Concern and the species is ranked “Avoid”, regardless of other criteria, if it is: 1) Overfished, overexploited or depleted AND trend in abundance is flat or down 2) Overfished AND overfishing is occurring 3) Listed as a “threatened species” or similar proxy by national or international bodies

Conservation Concern: Status of Stocks

¾ Low (Stock Healthy) ¾ Moderate (Stock Moderate or Unknown) ¾ High (Stock Poor) ¾ Stock Critical

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CRITERION 3: NATURE AND EXTENT OF DISCARDED BYCATCH12

Guiding Principle: A sustainable wild-caught species is captured using techniques that minimize the catch of unwanted and/or unmarketable species.

Primary Factors to evaluate

Quantity of bycatch, including any species of “special concern” (i.e. those identified as “endangered”, “threatened” or “protected” under state, federal or international law)

¾ Quantity of bycatch is low (< 10% of targeted landings on a per number basis) AND does not regularly include species of special concern ¾ Quantity of bycatch is moderate (10 – 100% of targeted landings on a per number basis) AND does not regularly include species of special concern OR Unknown ¾ Quantity of bycatch is high (> 100% of targeted landings on a per number basis) OR bycatch regularly includes threatened, endangered or protected species Alaska Yukon River Chinook stocks

Population consequences of bycatch ¾ Low: Evidence indicates quantity of bycatch has little or no impact on population levels ¾ Moderate: Conflicting evidence of population consequences of bycatch OR Unknown ¾ Severe: Evidence indicates quantity of bycatch is a contributing factor in driving one or more bycatch species toward extinction OR is a contributing factor in limiting the recovery of a species of “special concern”

Trend in bycatch interaction rates (adjusting for changes in abundance of bycatch species) as a result of management measures (including fishing seasons, protected areas and gear innovations): ¾ Trend in bycatch interaction rates is down ¾ Trend in bycatch interaction rates is flat OR Unknown Increased each year from 2004-7, but decreased in 2008-9 – overall trend uncertain ¾ Trend in bycatch interaction rates is up ¾ Not applicable because quantity of bycatch is low

12 Bycatch is defined as species that are caught but subsequently discarded because they are of undesirable size, sex or species composition. Unobserved fishing mortality associated with fishing gear (e.g. animals passing through nets, breaking free of hooks or lines, ghost fishing, illegal harvest and under or misreporting) is also considered bycatch. Bycatch does not include incidental catch (non-targeted catch) if it is utilized, is accounted for, and is managed in some way. 95 Seafood Watch® Alaska Pollock Report November 23, 2009

Secondary Factor to evaluate

Evidence that the ecosystem has been or likely will be substantially altered (relative to natural variability) in response to the continued discard of the bycatch species ¾ Studies show no evidence of ecosystem impacts ¾ Conflicting evidence of ecosystem impacts OR Unknown ¾ Studies show evidence of substantial ecosystem impacts

Evaluation Guidelines

Bycatch is “Minimal” if: 1) Quantity of bycatch is <10% of targeted landings AND bycatch has little or no impact on population levels.

Bycatch is “Moderate” if: 1) Quantity of bycatch is 10 - 100% of targeted landings 2) Bycatch regularly includes species of “special concern” AND bycatch has little or no impact on the bycatch population levels AND the trend in bycatch interaction rates is not up.

Bycatch is “Severe” if: 1) Quantity of bycatch is > 100% of targeted landings 2) Bycatch regularly includes species of “special concern” AND evidence indicates bycatch rate is a contributing factor toward extinction or limiting recovery AND trend in bycatch is down.

Bycatch is considered a Critical Conservation Concern and the species is ranked “Avoid”, regardless of other criteria, if: 1) Bycatch regularly includes species of special concern AND evidence indicates bycatch rate is a factor contributing to extinction or limiting recovery AND trend in bycatch interaction rates is not down. 2) Quantity of bycatch is high AND studies show evidence of substantial ecosystem impacts.

Conservation Concern: Nature and Extent of Discarded Bycatch ¾ Low (Bycatch Minimal) ¾ Moderate (Bycatch Moderate) ¾ High (Bycatch Severe) ¾ Bycatch Critical

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CRITERION 4: EFFECT OF FISHING PRACTICES ON HABITATS AND ECOSYSTEMS

Guiding Principle: Capture of a sustainable wild-caught species maintains natural functional relationships among species in the ecosystem, conserves the diversity and productivity of the surrounding ecosystem, and does not result in irreversible ecosystem state changes.

Primary Habitat Factors to evaluate

Known (or inferred from other studies) effect of fishing gear on physical and biogenic habitats ¾ Minimal damage (i.e. pelagic longline, mid-water gillnet, mid-water trawl, purse seine, hook and line, or spear/harpoon) ¾ Moderate damage (i.e. bottom gillnet, bottom longline or some pots/ traps) ¾ Great damage (i.e. bottom trawl or dredge) Based on information that “mid-water” trawls contact the bottom 44% of the time and are a major contributor to fisheries-related habitat damage in the EBS.

For specific fishery being evaluated, resilience of physical and biogenic habitats to disturbance by fishing method ¾ High (e.g. shallow water, sandy habitats) ¾ Moderate (e.g. shallow or deep water mud bottoms, or deep water sandy habitats) ¾ Low (e.g. shallow or deep water corals, shallow or deep water rocky bottoms) ¾ Not applicable because gear damage is minimal

If gear impacts are moderate or great, spatial scale of the impact ¾ Small scale (e.g. small, artisanal fishery or sensitive habitats are strongly protected) ¾ Moderate scale (e.g. modern fishery but of limited geographic scope) ¾ Large scale (e.g. industrialized fishery over large geographic areas) ¾ Not applicable because gear damage is minimal

Primary Ecosystem Factors to evaluate

Evidence that the removal of the targeted species or the removal/deployment of baitfish has or will likely substantially disrupt the food web ¾ The fishery and its ecosystem have been thoroughly studied, and studies show no evidence of substantial ecosystem impacts ¾ Conflicting evidence of ecosystem impacts OR Unknown ¾ Ecosystem impacts of targeted species removal demonstrated

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Evidence that the fishing method has caused or is likely to cause substantial ecosystem state changes, including alternate stable states ¾ The fishery and its ecosystem have been thoroughly studied, and studies show no evidence of substantial ecosystem impacts ¾ Conflicting evidence of ecosystem impacts OR Unknown ¾ Ecosystem impacts from fishing method demonstrated

Evaluation Guidelines

The effect of fishing practices is “Benign” if: 1) Damage from gear is minimal AND resilience to disturbance is high AND neither Ecosystem Factor is red.

The effect of fishing practices is “Moderate” if: 1) Gear effects are moderate AND resilience to disturbance is moderate or high AND neither Ecosystem Factor is red. 2) Gear results in great damage AND resilience to disturbance is high OR impacts are small scale AND neither Ecosystem Factor is red. 3) Damage from gear is minimal and one Ecosystem factor is red.

The effect of fishing practices is “Severe” if: 1) Gear results in great damage AND the resilience of physical and biogenic habitats to disturbance is moderate or low. 2) Both Ecosystem Factors are red.

Habitat effects are considered a Critical Conservation Concern and a species receives a recommendation of “Avoid”, regardless of other criteria if: ¾ Four or more of the Habitat and Ecosystem factors rank red.

Conservation Concern: Effect of Fishing Practices on Habitats and Ecosystems

¾ Low (Fishing Effects Benign) ¾ Moderate (Fishing Effects Moderate) ¾ High (Fishing Effects Severe) ¾ Critical Fishing Effects

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CRITERION 5: EFFECTIVENESS OF THE MANAGEMENT REGIME

Guiding Principle: The management regime of a sustainable wild-caught species implements and enforces all local, national and international laws and utilizes a precautionary approach to ensure the long- term productivity of the resource and integrity of the ecosystem.

Primary Factors to evaluate

Stock Status: Management process utilizes an independent scientific stock assessment that seeks knowledge related to the status of the stock ¾ Stock assessment complete and robust ¾ Stock assessment is planned or underway but is incomplete OR stock assessment complete but out-of-date or otherwise uncertain ¾ No stock assessment available now and none is planned in the near future

Scientific Monitoring: Management process involves regular collection and analysis of data with respect to the short and long-term abundance of the stock ¾ Regular collection and assessment of both fishery-dependent and independent data ¾ Regular collection of fishery-dependent data only ¾ No regular collection or analysis of data

Scientific Advice: Management has a well-known track record of consistently setting or exceeding catch quotas beyond those recommended by its scientific advisors and other external scientists: ¾ No ¾ Yes ¾ Not enough information available to evaluate OR not applicable because little or no scientific information is collected

Bycatch: Management implements an effective bycatch reduction plan ¾ Bycatch plan in place and reaching its conservation goals (deemed effective) ¾ Bycatch plan in place but effectiveness is not yet demonstrated or is under debate Salmon bycatch plan in place may not be effective (based on increases in bycatch) in 2004-7. Interim measures (changes to VRHS plan) may have helped reduce bycatch in 2008-9. A hard cap plan has been proposed but is not scheduled to be implemented until 2011. ¾ No bycatch plan implemented or bycatch plan implemented but not meeting its conservation goals (deemed ineffective) ¾ Not applicable because bycatch is “low”

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Fishing practices: Management addresses the effect of the fishing method(s) on habitats and ecosystems ¾ Mitigative measures in place and deemed effective ¾ Mitigative measures in place but effectiveness is not yet demonstrated or is under debate Mitigative measures for effects on SSL are under debate - SSL populations are now increasing slightly, but recovery goals have not yet been met. Management continues to allow “mid-water trawls” to contact the seafloor and is not concerned about the resulting impacts. However, managers have precautionarily prohibited commercial fishing from expanding into the Arctic Ocean until an ecosystem-based management plan is in place. ¾ No mitigative measures in place or measures in place but deemed ineffective ¾ Not applicable because fishing method is moderate or benign

Enforcement: Management and appropriate government bodies enforce fishery regulations ¾ Regulations regularly enforced by independent bodies, including logbook reports, observer coverage, dockside monitoring and similar measures ¾ Regulations enforced by fishing industry or by voluntary/honor system ¾ Regulations not regularly and consistently enforced

Management Track Record: Conservation measures enacted by management have resulted in the long-term maintenance of stock abundance and ecosystem integrity ¾ Management has maintained stock productivity over time OR has fully recovered the stock from an overfished condition ¾ Stock productivity has varied and management has responded quickly OR stock has not varied but management has not been in place long enough to evaluate its effectiveness OR Unknown ¾ Measures have not maintained stock productivity OR were implemented only after significant declines and stock has not yet fully recovered

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Evaluation Guidelines

Management is deemed to be “Highly Effective” if the majority of management factors are green AND the remaining factors are not red.

Management is deemed to be “Moderately Effective” if: 1) Management factors “average” to yellow 2) Management factors include one or two red factors

Management is deemed to be “Ineffective” if three individual management factors are red, including especially those for Stock Status and Bycatch.

Management is considered a Critical Conservation Concern and a species receives a recommendation of “Avoid”, regardless of other criteria if: 1) There is no management in place 2) The majority of the management factors rank red.

Conservation Concern: Effectiveness of Management ¾ Low (Management Highly Effective) ¾ Moderate (Management Moderately Effective) ¾ High (Management Ineffective) ¾ Critical (Management Critically Ineffective)

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Overall Seafood Recommendation

Overall Guiding Principle: Sustainable wild-caught seafood originates from sources that can maintain or increase production in the long-term without jeopardizing the structure or function of affected ecosystems.

Evaluation Guidelines

A species receives a recommendation of “Best Choice” if: 1) It has three or more green criteria and the remaining criteria are not red.

A species receives a recommendation of “Good Alternative” if: 1) Criteria “average” to yellow 2) There are four green criteria and one red criteria 3) Stock Status and Management criteria are both ranked yellow and remaining criteria are not red.

A species receives a recommendation of “Avoid” if: 1) It has a total of two or more red criteria 2) It has one or more Critical Conservation Concerns.

Summary of Criteria Ranks

Conservation Concern

Sustainability Criteria Low Moderate High Critical

Inherently Vulnerability

Status of Wild Stocks

Nature and Extent of Discarded Bycatch

Habitat and Ecosystem Effects

Effectiveness of Management

Overall Seafood Recommendation

Best Choice

Good Alternative

Avoid

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Appendix II

Approximately half of global surimi production is made from Alaska pollock. However, a number of other species are also used to make surimi, including sardine, mackerel, barracuda, striped mullet, threadfin bream, Atka mackerel, hoki, blue whiting, Pacific whiting and cod (FAO 2005a; 2005b).

Estimates of the percentages of these species used in global surimi production vary. Some estimates put global surimi production at 600,000 mt, with 50% made from Alaska pollock, 25% from threadfin bream, and 5% from each of the following: Pacific whiting, southern blue whiting, bigeye snapper, and lizard fish (J. Park pers. comm.). Other estimates put global surimi production at 532,000 mt, with 35% made from Alaska pollock, 26% from threadfin bream, and less than 10% of each of the following: Japanese pollock, lizard fish, Pacific whiting, southern blue whiting and hoki, ribbon fish, bigeye snapper, goat fish, croaker, and northern blue whiting (C. DuPuis pers. comm.).

These species are fished worldwide in a number of fisheries, the sustainability of which is unknown. Due to the unknown factors associated with most surimi production, Seafood Watch® recommends that consumers choose surimi products made from Alaska pollock, which is a Good Alternative and has been certified by the Marine Stewardship Council.

Appendix III

In 2004 F/FMSY and B/BMSY were respectively calculated at 0.5 and 1.3 for Bering Sea pollock stocks (Ianelli et al. 2007) and 0.59 and 1.05 for stocks in the Gulf of Alaska (Dorn et al. 2007). Thus neither region was considered overfished or undergoing overfishing. Stock status of Bering sea stocks was considered a “low” conservation concern, while that of stocks in the Gulf of Alaska were considered “moderate” because the population was found to be skewed towards smaller individuals.

In 2009, both regions were reassessed. B/BMSY was found to be 0.75 and 0.64 for Bering Sea pollock and Gulf of Alaska pollock respectively. F/FMSY has risen to 0.64 for Bering Sea stocks, and fallen to 0.5 for pollock stocks in the Gulf of Alaska. Because of the drop in B/BMSY observed in Bering Sea pollock stocks, stock status has been changed from a “low” to “moderate” conservation concern.

Appendix IV

Criterion 3 data from 2002 pertaining to groundfish catch, percentage of pollock discarded, and discarded bycatch in the BSAI were updated/replaced with data from 2007 (percentage of pollock discarded). Data regarding the percentage of discarded pollock and groundfish catch remain stable with the exception of Pacific cod catch, which continues to increase. Discarded bycatch data from 2007 differs with that of 2002. Additionally, sections on prohibited species catch and salmon catch were added to criterion 3. In light of high bycatch of Chinook salmon in 2005-2007, Criterion 3 is now a “moderate” conservation concern.

Criterion 4 has been augmented with data cataloging the nature of mid-water trawl effort and 103 Seafood Watch® Alaska Pollock Report November 23, 2009 seafloor impacts in the Alaskan pollock fishery. These data suggest that mid-water pollock trawls are regularly fished on the seafloor, and that the fishery is the largest single component of fishery impacts on the living seafloor structure of the Bering Sea. Due to these data as well as uncertainty about the effects of the pollock fishery on populations of endangered Steller sea lions and fur seals, Criterion 4 is now ranked a “high” conservation concern.

Criterion 5 has been revised to take into account management’s response to recent stock declines and the drop in B/BMSY to less than 1.0 in both regions, recent increases in bycatch of Chinook salmon, and the debate over the effectiveness of management regarding bycatch as well as habitat and ecosystem effects. Management continues to be considered “highly effective”.

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