Bering Sea Fishermen Press North Pacific Council on Halibut Bycatch

Alaska Journal of Commerce – By Elizabeth Earl – November 24, 2021 •

Keith Pearson, left, pushes a halibut as the Auction Block Company crew offloads the fish from a boat, Aug. 9, 2016. The fish are sorted by size, iced and boxed for moving. (Anne Raup/ADN archive)

After years of deliberations, the North Pacific Fishery Management Council is inching toward a decision on whether to tie halibut bycatch limits in the Bering Sea to abundance indices.

The action, known formally as Bering Sea-Aleutian Islands halibut abundance-based management, or ABM, is intended to reduce bycatch of halibut in the Bering Sea by the Amendment 80 trawl fleet when the fish stocks are lower. The Amendment 80 fleet is a group of catcher-processor vessels that are allocated a portion of groundfish harvest. Each year, the fleet is bound to a hard limit on how many halibut they can take as bycatch, known as the prohibited species catch, or PSC limit.

That limit is fixed, however, while halibut stocks and the allowable catch for the directed fleet vary. Over the last six years, the council has been considering whether to instead adjust the PSC limit to fluctuate with halibut abundance indexes based on two surveys, effectively pushing more of the halibut available for harvest to the directed fishery fleet. Depending on which of four alternatives the council chooses — from no action to varying changes —the effects could range from a 45% cut to a 15% increase, depending on abundance.

Chris Woodley, executive director of the Groundfish Forum, a trade association representing members of the Amendment 80 fleet, said the draft environmental impact statement provided to the council points out that a shift to ABM would overall be detrimental economically.

“There are a number of things the Groundfish Forum is concerned about — the primary one being that the draft EIS is very clear that there is going to be little to no benefits to the halibut stocks or to conservation in general and that the net (economic) benefit to the nation is expected to be negative,” he said. “That’s very up front and very clear.”

The issue has been controversial from the beginning, in part because of the cost to the trawl fleet. The National Marine Fisheries Service estimates that cost to the Amendment 80 fleet would be between $68 million and $138 million, depending on fishing variables and the alternative implemented. By contrast, the draft EIS estimates that the economic benefit to the directed halibut fleet would be between $1.1 million and $2.2 million. There are about 835 crew positions in the Amendment 80 fleet, compared to about 400 in the directed fishery for halibut in the region. Because the loss is so large and the number of people relatively small, the reduced revenue would pencil out to about a $30,000 loss per crew position in the Amendment 80 fleet under one alternative.

“There’s virtually zero upside to the directed fishery and a huge amount of downside to the Amendment 80 fishermen,” Woodley said.

Though the review concludes that the net benefit of implementing abundance-based management would be negative economically, both the social and economic impacts are considered. Diana Stram, a senior scientist with the NPFMC who worked on the document, said the statement about the net benefits is largely an economic one.

The council is bound to consider the 10 national standards under the Magnuson-Stevens Fishery Conservation and Management Act, which include standards like conservation, minimizing bycatch to the extent practical and minimizing costs. Stram said the council must balance its decision across those standards.

“Certain actions are going to be more related to one of the national standards than others,” she said. “What we do as analysts in the document is we try to provide some narrative to help the decision-makers understand how this plays into their actions, but the onus is on the council if one alternative is balancing one standard higher than another.”

None of the four alternatives have a significantly different impact on the spawning stock biomass for halibut in the Bering Sea, according to the draft EIS. That’s because the International Pacific Halibut Commission manages the halibut stocks as well and sets the catch limits based on its survey for sustainable harvest levels, Stram said. Whatever the council decides to do would only affect the amount of fish available for harvest, not the spawning stock.

Some fishermen in the Bering Sea region are pushing for the council to enact the motion both out of economic and sustainability concerns. The directed halibut fleet in the Bering Sea is one of the economic mainstays for coastal communities in Western Alaska. Halibut is also a critically important subsistence resource in many of the communities of the Aleutian Islands and Bering Sea, particularly as other stocks like crab decline.

St. Paul Island is one of those communities. The island, with a population of about 480 people, depends on subsistence foods and commercial fishing. Halibut is a staple there, and the community has a vested interest in the long-term sustainability of the stock, said Lauren Divine, the director of the ecosystem conservation office for the Aleut Community of St. Paul.

None of the alternatives are enough to do what the community feels is necessary, but they want to see something happen, she said.

A number of other halibut-dependent coastal communities have already stopped fishing for halibut, in part because of the decline connected with the static bycatch cap, Divine said. The community of St. Paul is home to a Community Development Quota group, the Central Bering Sea Fishermen’s Association, and people on the island do depend on fishing jobs, but it’s not just about the economics for community, Divine said.

“From an Indigenous community perspective, it’s not just about money,” she said. “It’s a way of life people don’t want to give up.”

Heather McCarty, a fisheries analyst who works with the Central Bering Sea Fishermen’s Association, said the group is advocating for Alternative 4, but feels for a number of reasons that the draft EIS doesn’t provide enough information for the council to make a decision. For one, she said Alternative 4 is the only option that meets the council’s purpose and needs statement for the project. For another, the draft EIS focuses on the perspectives of the CDQ groups, which may not always be the same as the perspectives of the communities.

The group supports the action because it would help spread out the burden of conservation to the trawl fleet, she said. Because the bycatch cap is static, in some years, the trawl fleet might be able to take nearly all the halibut available for harvest.

“The directed fishermen bear the entire burden of conservation,” she said.

Divine said the Aleut Community of St. Paul also finds Alternative 4 preferable.

“Alternative 4 isn’t enough, but it is a good start as we move into abundance-based management away from static caps,” Divine said. “But I think this is going to be an ongoing (issue).”

Stakeholders on both sides of the discussion agree that the EIS has some information holes in it that need to be addressed before the council uses it to take action, including on topics such as the effects of climate change on fish populations.

The council is expected to take action on BSAI halibut abundance-based management at its upcoming meeting beginning Dec. 8.

Both McCarty and Divine said the communities aren’t advocating for the trawlers to be completely closed, but for there to be a more equitable division.

National Standard 9 of the MSA requires the council to reduce bycatch to the extent practicable. The Amendment 80 fleet has taken multiple steps to reduce halibut bycatch as more attention has turned to the issue. Since 2007, the fleet’s bycatch is down by 49%, the vessels have reduced their bottom contact by an estimate 90%, and are communicating about areas with higher halibut bycatch to avoid fishing there. They are also using excluders, deck sorting, avoiding night fishing and using small tows, among other efforts. In the past few years, the fleet has encountered high numbers of halibut on the grounds, such as in 2019, when record-breaking warm waters affected fisheries all over Alaska.

Woodley said one of the fleet’s concerns is that the 2019 conditions will become a new normal, so the fleet wants more flexibility within bycatch regulations to adapt.

“We are committed to continued halibut bycatch reduction, but with halibut bycatch already so low and with all current tools fully utilized, future efforts will likely result in only small incremental improvements.”

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At Least Let’s Try to Solve the Halibut Problems – By Dennis Moran, President Fishermen’s Finest – October 7, 2021 •

“If your only tool is a hammer, every problem looks like a nail.”- Zen Master or maybe Mark Twain.

As we get close to the North Pacific Fishery Management Council’s final action cutting the Amendment 80 sector’s halibut – yet again – we should pause and reflect on what this will accomplish. There are problems with halibut management, to be sure. The Pribilof Island community-based fleet needs bigger halibut allocations in times of low abundance. There is too much waste in the groundfish fleets forced by crushingly outdated regulations. Let’s try to solve these halibut problems rather than just cutting Amendment 80 halibut and acting surprised in another 4 years when the Pribilof Island community-based fleet comes back to the Council pleading that they still need fish and that the last round of cuts failed to even make a dent in the problems. This has been the cycle about every 4-5 years since the halibut stock scientists realized they had allowed large overharvest of halibut in the Bering Sea: the Pribilof Island directed halibut fleet pleads to the Council that it doesn’t have enough fish; the Seattle and Arizona halibut fleet owners jump on the bandwagon and demand that the Council must make cuts to the Amendment 80 fleet or else the whole council system is corrupt if they don’t; the Council makes cuts and then the cycle starts again. Maybe it’s time to consider the possibility that a halibut cut to the Amendment 80 fleet is not the right tool. Maybe it’s time to consider solving the Bering Sea halibut problems with some other tools.

The challenges arise out of the fact that there are two competing user groups for halibut in the Bering Sea, 1) the directed fishery users, represented by the community-based Pribilof Island directed halibut fleet (“PI Fleet”) and 2) the Amendment 80 fleet (“A80” Fleet). The PI community fleet consists of approximately 15 ships, 75 crew, they fish with hooks, can legally harvest only halibut longer than 32 inches and are required by law to throw back shorter fish as “bycatch.” The PI Fleet crews depend on the fishery to provide earnings for their families on St. Paul Island. The A80 fleet consists of 19 ships, 2,285 crew, fish with nets, legally harvest species like yellowfin sole, cod, atka mackerel, rock sole, etc. and are required by law to throw back 100% of the halibut they catch, regardless of size. The 2,285 A80 crew also depend on the fishery to provide earnings for their families in Alaska, Washington and over the United States. Both fleets are allocated a fixed halibut quota measured in weight- pounds or metric tons. Both fleets are required to stop fishing when they reach their quotas. Where they differ is that the PI fleet tries to harvest its halibut quota but the A80 fleet tries NOT to harvest its halibut quota because that shuts down their fishing for all the other species too.

What are the specific problems? First, there is a problem with the Pribilof Island fleet fishing in Bering Sea areas 4CDE getting low harvest allocations during times of low abundance – they simply need more fish when the amount of large fish in the Bering Sea is low. Second, there is the problem of waste – it is a waste to require the A80 fleet to throw away dead halibut that could and should be used for food like all the other fish commercially harvested. Third, due to the byzantine halibut management structure, cutting the A80 halibut allocation gives the PI fleet barely any increase in their directed halibut quota and will severely damage the A80 fleet. But cutting is the only tool the North Pacific Council has ever used on this issue, so cut it will, and those cuts will not solve any of these three problems, not even one, and this time around the cuts will create new problems for the Alaska communities in the form of dramatically reduced landing tax revenue caused by the contraction in A80 harvest.

What would solve the problems?

1. Problem of a PI fleet that needs additional halibut during periods of low abundance. Create a path for A80 to transfer fish to the PI fleet with a private, enforceable contract. In years of low halibut abundance, where Area 4CDE halibut allocation is below 1,500,000 lbs., regulations already exist that permit the A80 fleet to lease directed halibut quota share from other, absentee Seattle or Arizona based owners for example, and distribute that fish to the PI fleet CDQ groups so that they can distribute it to the ships in their fleet. All that needs to be done is for the A80 owners and the PI CDQ group to negotiate a private contract. This will cost A80, but will reduce the harm to the A80 crew earnings far more than Council based halibut cuts. A80 companies stand ready to work out a deal with the PI fleet to build this structure.

2. Problem of halibut waste. The only place halibut is wasted like this is in the US North Pacific and Eastern Bering Sea and Gulf of Alaska. The only reason halibut is wasted like this is because the US halibut laws require it. Halibut is commercially harvested by trawl catcher processors, sensibly and sustainably all over the world including the Russian Bering Sea, Eastern Canada, Greenland, North Atlantic and Barents Sea. Laws requiring waste are wrong environmentally, morally, and commercially. They are relics of a fossilized 1923 US-Canada treaty and a less ecologically enlightened past. What might have made sense in 1923 doesn’t make sense in 2021. NOAA can amend the federal regulations by deleting the word “halibut” from 50 CFR 679.21 and let A80 manage halibut like it manages cod, with fixed quotas that permit retention and fishing stops when the quota is exhausted. Managing halibut like cod would 1) eliminate the waste, 2) potentially increase the food production by roughly 3.5 million halibut meals, 3) increase annual crew pay to the 2,285 A80 crew by $3.7m (roughly $1,638.00 per person) and 4) increase the annual landing tax paid to the State of Alaska and local communities by roughly $435,000. That’s a win, win, win, win solution.

3. Problem of cutting halibut allocation to A80. One of the great management success stories is how A80 has already reduced the fleetwide halibut bycatch rate by 49% since 2007, to a point where it constitutes less than 0.4% of the total catch. That bycatch ratio is lower than almost all the other gear types, including crab pot, cod and halibut longline. There is no room, now, for additional cuts without causing massive contraction in A80 harvest and landing tax revenue to Alaska communities, damage to the A80 companies, their crews and their families from which they are unlikely to recover. Data from North Pacific Council’s latest Economic study shows this next round of proposed cuts will have the following effects on crews and Alaska communities (est.):

a. A 20% cut to A80 increases annual halibut crew shares by $435.00/person in the 75 crewmember PI fleet ($32,625.00), but it decreases A80 crew shares by an average of $7,631.00/person in the 2,285 person A80 fleet ($17,430,140.00 total) and contracts Alaska State Landing Tax by roughly $627,773.00. Half of the landing tax goes to the local communities, which in this case is principally Dutch Harbor/Unalaska. So, increasing the PI crew share $435/person costs Dutch Harbor/Unalaska roughly $313,886.00 in lost landing tax revenue.

b. A 25% cut to A80 increases the annual halibut crew shares by $544.00 for 75 PI crew ($40,800) but decreases the A80 crew shares by an average of $10,354.00/person for 2,285 A80 crew ($23,660,559.00 total) and contracts Alaska State Landing Tax by roughly $851,780.00. The $544.00 PI crew share increase costs Dutch Harbor/Unalaska roughly $425,890.00 in lost landing tax revenue.

c. A 40% cut to A80 increases the halibut crew shares by $871/person for 75 PI crew ($65,325) but decreases A80 crew share by an average of $15,391.00 for 2,285 crew ($35,168,530.00 total) and contracts Alaska State Landing Tax by roughly $1,266,067.00. That’s a reduction of $633,033 in lost tax revenue to the local Alaska communities, almost all of which would come from the City of Unalaska. The $851/person crew share increase costs Dutch Harbor/Unalaska roughly $633,033.50 in lost landing tax revenue.

Zen Master warns us against a common foolishness. Look at the problems, then look into the tool belt and see if there are other tools besides the hammer that might actually solve the problems. Or maybe Zen Master is telling us something about human nature, that we just like pounding on things with hammers. We’ll see.

Opinion: Wrong Again, Oceana – By John Gauvin, Fisheries Science Project Director, Alaska Seafood Cooperative – September 9, 2021 •

In my role as Fishery Science Project Director for the Alaska Seafood Cooperative since 2008 I have worked with fishery managers, fishery scientists, and fishermen to find ways to reduce trawl bycatch and modify bottom trawl gear to reduce seafloor impacts. During my tenure, the Amendment 80 fleet has made significant progress on both of these fronts through longstanding participation in collaborative, peer-reviewed research, and steadfast commitment to deploying new fishing gear, new fishing methods, and new fishing technology borne out of this research.

Last week’s piece by Oceana is misleading and designed to mischaracterize the bycatch trade-offs of the fishery. Even more troubling for me, however, from my years of following the rigors of the scientific process used for evaluation of impacts of fisheries on the seafloor in Alaska, are the statements about effects of trawling on seafloor.

Contrary to Oceana’s statements, the effects of trawling and other fishing gears on the seafloor habitats in the federally managed fisheries in Alaska are a success story for fishery management. Effects of trawling is one of the best-studied and managed food production practices in the United States, maybe the world.

Under the Magnuson Stevens Act’s Essential Fish Habitat (EFH) requirements, comprehensive scientific reviews of the effects of fishing gears on fish habitat are mandated to be done every five years. These reviews incorporate the latest fishery data and scientific research. The last EFH review of the effects of fishing on the seafloor in federal waters off Alaska concluded that effects of fisheries individually and cumulatively: “…were determined to be minimal and not detrimental to fish populations or their habitats.” (See:, page 76.)

Further, Oceana specifically, and incorrectly, asserts that Arrowtooth Flounder in the Gulf Alaska has unsustainable habitat impacts. In fact, the stock assessment authors for Arrowtooth flounder – scientists who know this species and its habitat inside and out – concluded that the effects of trawling on the mud and sand seafloor where Arrowtooth fishing occurs are essentially so small they are “unmeasurable.” (See This information hardly comports with Oceana’s reckless assertion that the Arrowtooth flounder fishery and other trawl fisheries are damaging fish habitat and are destructive and unsustainable.

In fact, it’s not only the National Marine Fisheries Service that disagrees with Oceana on this subject.  The Marine Stewardship Council (MSC) and the Responsible Fisheries Management (RFM) are both independent, third-party certification programs that evaluate management of fisheries and specifically look at how fishing gear affects the seafloor. Both bodies score the management measures in place for the Arrowtooth flounder fishery in the Gulf of Alaska and Bering Sea Aleutian Islands as exemplary.

Last, Oceana throws in their general anti-trawl rhetoric, which suggests closing additional areas to bottom trawling in Alaska. Currently 517,000 square nautical miles off Alaska are closed to bottom trawling – yup, this is not a typo – 517,000 square nautical miles. This means that existing habitat closures in Alaska amount to three times the land area of the State of California!  Oceana asserts, with no evidence, that even more area needs to be closed, but many scientists have come to the exact opposite conclusion – making more areas off limits actually could force fisheries out of productive areas they fish year after year and have a deleterious rather than a positive effect.

Oceana’s attack is authored by a long-time participant in the North Pacific Fishery Management Council process, who well knows all the information I have just provided regarding the comprehensive scientific review process for habitat effects of fisheries. He has, within this scientific process, frequently challenged the science, the analyses, and models, and I have seen the habitat scientists bend over backward to incorporate data and model runs to examine his concerns. These additional analyses did not produce the conclusions Oceana wanted. Put simply, the science did not support the result Oceana sought.  Unsatisfied by the actual science, Oceana seems determined to resort to phony science to get their way. I for one am tired of reading their claims about trawling affecting the seafloor. If they’ve got a better case then I say bring if forward, but otherwise, Oceana, time to accept the science.

This op-ed is in response to a piece that ran on September 1.