The Council reviewed an analysis of alternatives to modify methods to calculate and apportion snow crab PSC limits in groundfish trawl fisheries operating in the C. opilio Bycatch Limitation Zone (COBLZ). The Council paused development of the analysis and requested staff provide a data report on C. opilio bycatch in the directed crab and groundfish fisheries that describes the spatial distribution of bycatch throughout the BSAI by gear and fishery.
The COBLZ was created in 1997 by Amendment 40 to the BSAI Groundfish FMP and limited snow crab PSC for groundfish trawl fisheries within the area. The analysis was requested by the Council in February 2016 after a series of discussion papers from 2010 through 2016. Those discussion papers initially considered crab bycatch issues for all 10 crab species addressed in the BSAI Crab FMP, and over the course of several years, narrowed the scope to consider only modifications to calculating snow crab PSC limits for groundfish trawl fisheries within the COBLZ. Those previous discussion papers addressed snow crab bycatch that occurs in fisheries other than the groundfish trawl fishery, inside and outside the COBLZ, and presented information that indicated that the Council could consider managing snow crab bycatch by weight rather than by numbers. However, the Council chose not to take any action on those issues and instead limited the action to trawl PSC limits within the COBLZ.
To date, the COBLZ has been closed only to the 2010 BSAI Trawl Limited Access (TLA) yellowfin sole fishery when approximately 1.38 million snow crab were encountered early in the year. The COBLZ closed to that fishery in February 2010.
In February 2016, the Council provided a purpose and need statement that stated that a review of snow crab PSC limits was necessary because no review had been conducted since limits were put into place in 1997. The Council also included two alternatives that modify the methods for calculating PSC limits for the Community Development Quota (CDQ), Amendment 80 (A80) and BSAI TLA fisheries. The action alternatives would modify the abundance estimate from which PSC calculations are made to the modeled estimate of total abundance rather than the estimate of predicted survey abundance, as in status quo management. Staff note the disconnect between the very broad purpose and need statement and the very specific alternatives for analysis.
The analysis compared actual snow crab PSC usage from 2008–2017 in the CDQ, A80, and BSAI TLA fisheries to new limits that would have been imposed under the action alternatives. Staff noted that past performance may not be a predictor of future performance, but because of the limited data available, an effort reprojection was not possible. The analysis concluded that although some of the new PSC limits could have resulted in PSC limits that were lower than PSC usage for some fisheries in some years, it would remain a rare occurrence for fisheries to exceed their snow crab PSC limits under any alternative, either status quo or either of the action alternatives because of the way that the A80 and BSAI TLA fisheries are currently managed by cooperatives. Analysis also concluded that in the rare event that one or more fisheries were excluded from the COBLZ, there is little likelihood that any catch would be foregone, although there are likely to be some costs to the fisheries for fisheries to avoid areas of higher than acceptable snow crab PSC rates, or for redeployment should the fisheries exceed the COBLZ limit and be excluded from the area. The analysis also concluded that no alternative was likely to result in significant impacts to the human environment.
Both the SSC and the AP recommended that the analysis should be expanded. The SSC recommended additional discussion of the size distribution of snow crab in the estimate of survey abundance or total abundance and in PSC usage, and the treatment of undersize crab included in the modeled biomass estimates vs. those that show up in survey estimates currently used to establish PSC limits. The SSC also requested an additional section in the RIR addressing differential distribution of risk of foregone catch or increased operational costs among fishing communities participating in or dependent upon the fishery. The AP recommended that the Council clarify the purpose and need statement, increase the range of alternatives to better reflect the purpose and need, and include descriptions of: trade-offs of using the predicted survey abundance vs. total abundance as the index of abundance for setting PSC limits; data on size and sex composition of bycatch and amount of bycatch in weight and numbers of crab; description of the impacts of the alternatives on the C. opilio directed fishery; description of impacts on communities and small entities; report total bycatch in directed and groundfish fisheries in number of crabs to be consistent with the way that bycatch is measured; include research on gear modification/mortality reduction that was included in the February 2016 discussion paper; include information on temporal movement of trawl fishery relative to marine mammal interactions; consider the chances of displacing trawl vessels into areas of higher PSC (red king crab, halibut, etc.) and to what extent it could increase that PSC; include examples of how all bycatch removals in all fisheries, beyond on-pelagic trawl, are impacting the crab biomass and the amount available in directed fishery.
After review and public testimony, the Council paused development of the analysis and requested a data report on C. opilio bycatch in the directed crab and groundfish fisheries that describes the spatial distribution of bycatch throughout the BSAI by gear and fishery. The Council requested that staff provide information on possible gaps in bycatch data, identify regulatory provisions that could hinder the ability to minimize bycatch to the extent practicable and provide a qualitative description of potential impacts of avoiding C. opilio bycatch on fishery participants.
The Council also encouraged the crab and groundfish industry to coordinate to find non-regulatory measures to minimize C. opilio bycatch. Staff contact is Steve MacLean.