Friday council update: chum salmon bycatch
The North Pacific Fishery Management Council has wrapped up its work for this meeting on the Bering Sea chum salmon bycatch agenda item. After issues raised during this initial review, further revisions were requested before the council will adopt anything like a preliminary preferred alternative.
The council also engaged in a discussion relative to the six Nome area tribes who requested an alternative of a 30,000 hard cap for chum bycatch. Duncan Fields of Kodiak said he considered adding the 30,000 cap as alternative for analysis, but decided against it based on his opinion that adding the option wouldn't move the process forward and added he expected it would create major "push back" from the pollock fleet. John Henderschedt of Seattle noted that analysis shows average foregone harvest of pollock of some 330,000 metric tons under the current option for a cap of 50,000 and that adding a 30,000 option would upset the balance between national standards requiring optimum yield and to minimize bycatch.
ADF&G Commissioner Cora Campbell reiterated her comments from Thursday morning that the tribes' concerns are addressed in the current alternatives, and Chairman Eric Olson said he agreed with that rationale.
What follows are some of the SSC comments that will be addressed in revisions to the analysis, and the motion introduced by Campbell and adopted by the council.
Among the comments from the SSC:
"The treatment of the predicted impacts of the alternatives provides only superficial treatment of any affected user group, except commercial pollock fisheries. While the ability to comprehensively quantify economic impacts may be data-limited, it does not exempt the analysis from assessing these effects to the fullest extent practicable."
"The SSC expresses concern that the (Regulatory Impact Review) contains minimal information about the likely impacts of the proposed actions on these communities of users. This is particularly problematic since, under both federal and state law, subsistence is the highest priority use."
"The SSC has concerns about the lack of impact analyses on the commercial chum salmon industry throughout the North American range of these stocks ... this analysis is important because public testimony highlighted the links between commercial and subsistence use of this resource, with commercial activities often subsidizing subsistence use."
"The SSC reiterates its longstanding concerns about lack of pollock industry cost data that are critical to estimating impacts on industry net performance. The RIR does acknowledge that estimates of potentially foregone gross revenues may have no meaningful relationship to the economic performance, viability, or profitability of these commercial fisheries. In addition, the retrospective analysis of pollock industry revenue at risk implicitly assumes that there would be no change in industry behavior in response to the proposed alternatives ... the RIR would benefit from a qualitative discussion of the likely ways in which behavior could change, and how that might affect these estimates."
"There is a disproportionate emphasis on the potential adverse impacts on Western Alaska Region, literally to the exclusion of other impacted regions. While there is ample reason to assess the relationship, if any, between chum PSC in the BSAI Pollock trawl fisheries and diminished runs of chum in the WAK region, it is not the sole dimension of this management action."
Here's the motion from Campbell, revisions from the AP motion (that passed 21-0) are noted with
strikethrough, and the additions in bold:
1. Make Component 1 Alternative 3 a separate alternative: Fleet PSC (prohibited species catch) management with non-participant triggered closure.
2. Create a new Alternative 4 which includes Components 1-6: Fleet PSC management with non-participant triggered closure AND trigger closure area and timing for RHS (Rolling Hot Spot) participants
Option: General objectives and goals for rolling hot spot program would be in regulation; specific parameters of the hot spot program would not be in regulation
3. Include analysis of specific modifications to the RHS program:
• Modification of RHS to operate at a vessel level, platform level for mothership co-op;
• Prioritize RHS closures to best protect Western Alaska origin chum and chinook salmon using best information available. Use identification tools, for example:
* Non-genetic identifiers like length and weight;
* Genetic identification of bycatch on an as close to real time analysis as possible;
* Use information being developed (ie. Dr. Guyon’s ongoing research to identify areas and times more likely to have higher proportions of Western Alaska chum salmon;
• Floor base rate;
• Speed up shoreside data flow by obtaining trip chum counts as soon as it becomes available.
• Increase chum salmon protection measures during June/July. For example:
* Weekly threshold amounts that would trigger additional protection measures when bycatch is abnormally high;
* Initiate “Western Alaska chum core closure areas.” These areas would trigger during abnormally high encounters of chums believed to be returning to Western Alaska river systems.
• Limit weekly base rate increases to 20% of the current base rate;
• Stop RHS closures in a region (east or west of 168 degrees West Longitude) as chinook salmon bycatch levels start to increase in the later part of the B season;
• Adjustments to the tier system — consider a range of incentives that would lead to different levels of bycatch reduction.
4. Make the following revisions to the Draft EA/RIR:
• The analysis should also provide information on the necessary provisions or objectives of the RHS that would need to be under regulations under new Alternatives 3 and 4.
Include worst case impact rates as if entire bycatch is from one stock (ie. Norton Sound, Kuskokwim, lower Yukon, etc.) in addition to impact rates calculated against an aggregated Western Alaska run size.
• Provide additional qualitative analysis on the use of AEQ (adult equivalent) and how the impacts to individual river systems may vary annually, depending upon when and where bycatch occurs. While the limitations of the genetic data only allow for large aggregate groupings by regions, the composition of the bycatch may not be evenly distributed among the river systems included in a single region, and therefore may have differential impacts within the region that may exceed the average impact rates by region provided in the AEQ analysis.
• Include information from Wolfe, et al about projections for future subsistence demand for chum salmon in the AYK (Arctic-Yukon-Kuskokwim) Region.
Under Alternative 4, provide spatial analysis of the combined effect of the triggered area closures and the closures implemented under the RHS to visually display the available fishing areas given the layering of potential chum salmon closures under Alternative 4.
The Council also recommends that staff incorporate SSC comments regarding the EA, in particular the comment that the analysts made use of variable (lambda) to express how the pollock fleet would respond to area closures in June and July by either waiting to fish until later in the season (lambda = 0) or seeking to fish for pollock outside the closed area (lambda ranging from greater than 0 to 1). The Council recommends that in addition to scenarios with a lambda of 0, scenarios with lambda of 1 be presented in the summary tables that compare outcomes of the alternatives to represent a range of possible reactions of the pollock fleet to the alternatives. The Council recommends that the analysts incorporate the SSC recommendations on the RIR as practicable.
The Council recommends that NMFS continue to prioritize and fund the analysis of the chinook and chum genetic composition data. The Council also recommends using the pre-2011 observer sampling protocol to obtain salmon length data.
Andrew Jensen can be reached at email@example.com.