NPFMC 280 Day 3 - October 10, 2026

Good morning, everyone. So we are beginning our day today with our AP report on C3. After the completion of our C3 AP report, we will be taking up public testimony on both the Bering Sea and Gulf preliminary specs at the same time. So if you wish to testify on C3, please sign up before the end of the AP report. Thank you.

And Ms. Mann, we're ready whenever you are. Good morning. Excuse me. Good morning, Madam Chair, council members. For the record, my name is Heather Mann.

I'm a co-vice chair on the advisory panel. I'll be providing 3 motions that we took under groundfish specifications, and we'll stop after each motion for questions.

Okay, uh, so first I'll start with the Bering Sea. Uh, the AP recommends the council adopt the proposed 2027 and 2028 BSAI ground specifications for OFLs, ABCs, and BRDs as recommended by the SSC. And set proposed tax with all proposed specifications consisting of rollovers of 2026 final specifications from 2026-2027 harvest specifications. The proposed tax for both Bering Sea and Aleutian Island Pacific cod have been adjusted to account for the statewater GHL fisheries.

The proposed tax for sablefish have also been reduced in the BSAI by 5% to accommodate the GHL fishery.

The AP recommends the council adopt the proposed 2027 and 2028 seasonal and spatial allowances for atka mackerel as shown in Table 3. The AP recommends the council adopt the proposed 2027 and 2028 flatfish ABC reserves annual and seasonal PSC limits and apportionments in the BSAI as provided in Tables 7, 8, 9, 10, and 11. The AP recommends the council adopt the proposed 2027 and 2028 halibut discard mortality rates for the BSAA as shown in Table 12. And finally, Tables 1, 3, and 7 through 12 can also be found in the meeting agenda under C3. And that motion passed unanimously.

I'd be happy to answer any questions. Yeah, are there any Any questions on the first AP motion?

Okay, seeing none, I think we can continue.

Is it in this PowerPoint?

Yeah. Okay, sorry about that. Uh, so this is for the Gulf of Alaska. It's our second motion. The AP recommends the council adopt the proposed '27 and '28 Gulf of Alaska groundfish specifications.

I think we have the wrong one up. One moment. Oh, there we go. Sorry. Start again.

The AP recommends the council adopt the proposed '27 and '28 Gulf of Alaska groundfish specifications for OFLs and ABCs as recommended by the SSC and set tax as shown in Table 1. Final specifications will be approved in December 2026. The tax for both GOA cod and pollock have been adjusted to account for the statewater GHL fisheries. The proposed GOA Pacific cod adjustments are shown in Table 2. The AP recommends that the council adopt the proposed 2027 and 2028 annual and seasonal Pacific halibut PSC limits and apportionments in the Gulf as provided in Tables 9, 10, and 11, and the proposed 2027 and 2028 halibut discard mortality rates in the Gulf of Alaska located in Table 12.

That motion also passed unanimously, and I'd be happy to answer any questions. Thank you very much. Are there any questions on the second motion?

I think we're ready to move on. Thank you.

And our final motion, the AP recommends the Sablefish Stock Assessment Team explore additional stock assessment models and methods not limited to 25.12_1 Reg_CONT, 26.1_1 Reg, and 26.2_FAA for the November Joint Groundfish Plan Team and December Council meetings. The AP recommends the Sablefish Stock Assessment Team explore the following models. First is model 26.1_1 Reg with carryover apportionment. 2, A 3-year phase-in of the 26.2 FAA model and how it would be apportioned through all regions. 3, Model 26.2_FAA with dome selectivity for the model and the survey for the Bering Sea.

And 4, a sensitivity run that uses the M value from 26.1_1reg in Model 26.2 underscore FAA. Finally, the AP supports reestablishment of comprehensive annual surveys for this valuable stock and the use of commercial size composition and CPUE data. And I'd be happy to answer as many questions as I did on the first two. Not sure I'm gonna let you off that easy on this one. Um, see if there are any questions.

Yes, Ms. Kimball. Thank you, Miss Mann, um, for presenting the motion. I, I guess I just, uh, wondered if the AP had— I, I think the intent language or the rationale in support of the motion is very clear. I appreciate that very much. And so the intent makes sense to me.

Did the AP have the benefit of any discussion from staff, or I, I don't assume NOAA staff or NOAA GC staff, to let you know the bounds of what the council can do in proposing new models that the SSC, or different models than the SSC recommended during this agenda item? Through the chair, Ms. Kimball, we did not have that. We did not have staff from NOAA in there. We did have a quick discussion about which of— so two of these models were recommended by the SSC. The other two were presented to the SSC from the industry.

While the SSC did not recommend those additional two, they acknowledged them, and that was the extent of that conversation, is my recollection.

Thank you. Last question through the chair on number 2 in the motion. I just wanted to understand that the request to have a 3-year phase-in, and that is see the results of the FAA model but, but phase in the apportionment among areas, since that would be significantly different from, from status quo, phase that in slowly over a 3-year period, or is there something more to that, please? Uh, through the chair, that's, that is my understanding, the phase-in, um, and that potentially because it's managed as one stock, if that apportionment needed to change based on, um, because it could be a very large reduction, and so, um, sort of stepwise taking that across the, the different areas is my recollection of that discussion.

Yes, and Mr. Ritchie. Thank you, Madam Chair. Uh, thank you for the report. I'm looking at, um, number 2 with the 3-year phase-in, and I'm wondering, um, I think in the SSC report we read that, you know, between a CIE review, um, plan team and the SSC, uh, there's a determination that it's the you know, that something might be— like a model might be using the best scientific information available, which makes it the model that the SSC adopts.

And I'm wondering if there was conversation at the AP about if that is the case, if we do— if the SSC does come to the determination that that model is the best scientific information where exactly that leaves us with a 3-year phase-in, given the constraints that we have process-wise.

Through the chair, Brian, I'm not sure I understand the last part of your question. Do you mean the regulations and what's allowed through the FMP in terms of apportionment, or—. No, but maybe I'll catch you offline and try to understand. I guess I'm just, um, I'm a bit confused by the motion, but I can catch you offline. Um, I, I will, if it's okay, Madam Chair, just add, um, Brian, that we did have a conversation around best available science, and I think it's— I think we added it to our rationale.

We wanted to be clear that we weren't sort of throwing stones at the science. We just thought that the, the magnitude of the potential drop was so significant and some of the questions we had of staff were around, you know, has a drop of this level ever occurred? Um, the part of the response— the response was no, we don't think so, we'd have to look. And that when we do phase-ins, it's usually going up, not going down. That was one of the responses.

And then the other response was a little bit of questioning of the amount of waiting of the CIE.

Suggestion that this was the best available science, and how did that weigh in into the process with the SSC? But to be fair, we were already meeting when the SSC was having this discussion, and we didn't have the notes yet, their report. So, um, that, that's just a little bit more context.

That is very helpful. Uh, thank you.

Okay, I'm not seeing any other questions. Thank you for the AP report. Have a good morning. Thanks. You too.

So that brings us to public testimony on C3. Uh, looks like we have 6 people signed up. Uh, we'll begin with Julie Kavanaugh, followed by Jim Armstrong, and I think Julie is joining us online.

Can you please unmute yourself, Julie?

Hello. Good morning. Yeah, good morning. Just, I apologize in advance, we have Starlink issues at our house, so if I go offline, I apologize. Chair and members of the council, my name is Julie Cavanaugh.

I live in Kodiak, Alaska, and my family has participated in state and federal fisheries since the early 1980s. We are asking the council to consider the broader impacts of the proposed increase in the Gulf of Alaska arrowtooth flounder TAC. We understand that the recommendation is based on the available stock biomass. However, arrowtooth flounder remains substantially underutilized with an exploitation rate of approximately 11%. Our primary concern is the effect on Pacific cod availability.

The plan team has recommended a reduction in the Gulf of Alaska Pacific cod TAC, and our boats participate in the pot cod sector. We are also concerned about potential impacts on Gulf of Alaska Tanner crab. Arrowtooth harvests require associated incidental catch allocations. Based on a preliminary calculation, A 15% increase in arrowtooth tach could increase associated Pacific cod IC allocation by approximately 1.5 million pounds in the Gulf of Alaska. This raises an important question: when the directed species is harvested at only 11% of its available level, what happens to the incidental IC allocation associated with the unharvested arrowtooth?

We understand that in-season management includes a rollover process that can make unused IC available elsewhere. Given current arrowtooth harvest levels, there appears to be little chance that the fishery would need additional Pacific cod IC allocation, and we ask and wonder if this allocation will increase also. We therefore also ask the council to clarify whether holdback amounts for cod and other IC or PSC species will increase to accommodate an arrowtooth increase, and if unused allocation would ultimately just become available to other tall fisheries. If that is the expected outcome, we oppose the proposed increase in arrowtooth flounder TAC. Arrowtooth is not constraining to the fisheries, to other fisheries, and the existing TAC is not being fully harvested.

Increasing it appears unnecessary while the associated IC allocation could affect other sectors that depend directly on Pacific cod. We are also concerned about increased harvest of arrowtooth in the Gulf of Alaska on the east side of Kodiak and its impacts impacts on the Gulf of Alaska Tanner crab biomass. Arrowtooth flounder are bottom-dwelling flatfish that spend most of their lives on the ocean floor. In the Gulf of Alaska, bottom trawl surveys used in stock assessment sample them on the seabed, and fishery catch data also comes from bottom fishing. NOAA describes adult and juvenile arrowtooth as living, quote, living on the ocean floor, and these fish are caught at or near the bottom.

We ask the council to consider these cross-sector impacts before approving the arrowtooth increase. Thank you.

Thank you very much for your testimony. We'll see if there are any questions.

Yes, Ms. Kimball. Thank you. Maybe— thank you, Ms. Kavanaugh, for your testimony. Maybe just clarifying question. You were referencing the Gulf of Alaska.

That was my first question. Yes, it was for the Gulf of Alaska. Correct. Thank you. And is your testimony to highlight for the council when we get to setting actual tax based on the updated assessments to be aware of that in December.

I just want to understand the concern, and especially related to the arrowtooth catch being a very, very small percentage of the TAC, which, which was making me think that TAC was almost irrelevant in this case because it's such a small percentage. But maybe you can clarify your concern a little bit more for me. Yeah, thank you. I felt like this was a good time to raise this concern, give it— giving the council time to consider that prior to December and get, get any questions answered in a timely manner instead of last minute. And although arrowtooth is a small percentage of the catch, it's got unused— 89% of it is underutilized.

And so it's even, even though maybe it's the plan team's job to look at biomass and increase amounts, it feels like that 15% will also go underutilized. And so we're concerned with how holdbacks for incidental catch in PSC works. Like, I listened to the presentation and they showed numbers of, of those. I don't know if it's called holdbacks, but that's what comes to my mind. It didn't really describe on the record if that was an increase over the previous year, or would— one question would be, would the increase not come with increased IC or PSC holdbacks for that?

And that would be, that would be like something that would settle some of our concerns.

Thank you.

Not seeing any other questions. Thank you for your testimony, Ms. Gavin.

For how reallocation happens, it's a— but we, we, I do believe that generally speaking, allocation, reallocation of unused incidental catch or other types of bycatch go to the, to same sector or similar sector type fisheries. And so we are concerned with the preemption of that cod to an underutilized species, and that is then unavailable to a fixed gear sector. And that could cross over to other species, but I kept my testimony related to the species that we personally were concerned about.

Thank you for that, Ms. Cavanaugh. Appreciate your testimony. I'm not seeing any other questions. All right, thank you. Thanks.

So Jim Armstrong is up next, followed by Linda Banken.

Good morning, Madam Chair, members of the council. Jim Armstrong for the Freezer Longliners. Um, congratulations, Mr. Bowers and Mr. C, on your appointments. We submitted written comments on C-3 as well, and testimony to the SSC, um, on harvest control rules. We're pleased to see our perspectives and those of the SSC And I think the Council, from previous conversations on this, that we all agree on many aspects of this issue.

For instance, I think we all recognize the enormous challenge associated with it, meaning that for most stocks, informative links between climate and productivity are not known and may never be known. We also seem to all support a retrospective look at how alternative, uh, HCRs would have performed through the Gulf heat wave. And I think we all recognize that there's, uh, quite a bit of flexibility under the current HCR and annual review process, which means, uh, uh, it will need to be explicitly demonstrated that a given HCR alternative represents an improvement over the status quo. Uh, as you refine your objectives for climate resiliency, we encourage you to keep the list manageable, focusing on practicality in terms of data demands and, and HCR complexity, ensure the objectives recognize the importance of stability for stakeholders, make sure retrospectives are priority deliverable for Gulf cod and maybe a contrasting stock like sablefish, and for each HCR you ask in the retrospective, that is, :What ABCs would have been set? When would they have diverged from the status quo?

What would have— what would that have meant for biomass and for harvesters and communities?

And also holding off on adopting an alternative HCR for any stock until it has been demonstrated to represent an improvement. For instance, we caution against assuming that Gulf cod HCR is going to be the same as for Bering Sea. Genetic differences associated with movement exist among cod stocks in the presence of physical barriers, and thermal refugia in the Gulf and Bering Sea are quite different. Moving on to sablefish, the recently adopted FAA— or the recently developed FAA model produces an ABC A third below current specifications.

Much of the change in ABCs reflects a change in model structure, not observed decline in the stock. So FLC prefers the status quo model. The SSC did not take up the phase-in approach, but they did raise concerns about the FAA model. Its performance in simulations may come from canceling biases. Trends in the Bering Sea and Aleutian Islands.

And in other words, the areas at the edge, at the edge of the stock that are taking the largest cuts may not reflect changes in the core areas of the stock. So we share the SSC's concerns. We also share the SSC's concerns about losing logbook data. For EBS cod, We support the determination of the models for specification setting. We also echo the SSC's concern about maintaining aging capacity at the Science Center.

The SSC encouraged work on seasonal movement. We welcome being a part of that work in order to get the work done during A season and other times outside of the summer survey. For the past several years, our boats have served as platforms for both satellite tagging and genetic sampling.

And lastly, on Greenland turbot, the SSC plan team and assessment authors all agree that Bering Sea slope surveys or stations promote— provide the primary data for this stock. If the redesigned survey begin sampling slope stations in 2031, as currently projected. A 15-year, uh, gap in core data for this stock will have occurred. Uh, it'll take a few more years after that to build up a new time series of slope data. In the meantime, the, the shelf and longline surveys, which sample the margins of the stock and therefore provide a, a less stable population index, uh, will be used for management.

The SSC found inconsistency between these surveys with the deepwater surveys implying high— higher historical biomass than on the shelf. Until the slope data collections resume, we ask the Council to urge the SSC to provide catch advice for turbot that will support fishery stability. FLC operated the only directed turbot fishery harvesting between 1,000 and 1,200 tons a year before 2021. As you may recall, we stepped away because whale depredation was getting out of hand. We're grateful to the council for the regulatory amendment that provided us with a tool, pot gear, for dealing with whale depredation.

Unfortunately, just as we were about to begin using that tool, um, continuous— continued uncertainty from the assessment that had lost its primary survey inputs and additional precautionary reductions from the risk table as a response to that reduced our allocation to zero. Perhaps this is an issue for December, but we really need a TAC that will let us reengage in the fishery using pot gear. It's possible that a model-estimated ABC will do that. But, uh, additional reductions from the risk table will shut us out until slope data from 2031 forward, uh, contribute to, um, uh, an improved assessment. Thank you for the opportunity to testify.

Thank you very much for your testimony, Mr. Armstrong. Are there any questions? Yes, Ms. Kimball. Thank you, and, um, thanks for your testimony. I don't know if this is a fair question, but given it's your fleet that's— and one other fleet that would be primarily interested in Greenland turbot, have you— and that we haven't had a slope survey for years, have you explored alternative ways, or with the agency, on how to provide data on a slope survey?

Is that just totally out of the bounds of cooperative research at this point? It just doesn't seem, uh, like it's coming back anytime soon, and I feel like an alternative needs to be explored that could be seriously implemented. Uh, thank you. Through the chair, uh, Miss Kimball, um, you know, um, this is an assessment that I think is really trying hard to, to get some information about the surveys that exist. But, um, and the, the fallback alternative to doing a Tier 3 is now Tier 5, which is actually ironically more dependent on the survey than, than Tier 3 is, um, in some regards.

And it may be that Tier 6 is actually more appropriate for this, which it just looks at a historic catch and sets it at something that, that is reasonable until there are surveys that will support an actual assessment. So that's another option. And, but I think this is the first time that idea has been on the public record. So like you said, you know, we need to talk to the other sector and to the Science Center and those involved in the assessment and see just really what the options are. But something like that that would just provide, you know, it's never been a big fishery, so the historic catch that's way back there would be kind of ridiculous, but something that's more reflective of, of recent catch history would probably— we could talk about how, what the risks and benefits are of that.

I'd be happy to engage in that conversation between now and maybe next year.

Thank you for your testimony.

Linda Benken is up next, followed by Lancey Wetman.

Good morning, Madam Chair. Linda Benken, hoping you can hear me okay. Yes, good morning. Thank you. I'm testifying for Alaska Longline Fishermen's Association and focused on sablefish specifications.

Start by saying we support the motions from the SSC and the AP and asking that the stock assessment authors explore alternative methods and models for consideration in December as the basis for the 2026 sablefish assessment and '27 specification process. My understanding is that all the models in the AP motion were identified by the SSC for another review, although one was only for sensitivity analysis, and I think they didn't reference the phase-in, but I will let the SSC clarify those details. It just sounds like there may be some confusion around that. Um, we, we asked for this method and model review in full knowledge that there are more sablefish in the water now than there has been any time since the 1970s, and that the biomass is increasing. In other words, there's no conservation issue, and it seems like there really is time to more fully evaluate these proposed changes.

We understand that most of the potential reductions in the sablefish ABC are caused by data gaps and the methods identified to fill those gaps. As the SSC said, improved data collection should be the highest priority for the stock, both logs and surveys. We really agree with that, and we hope we can work with the council to make sure those gaps are filled. We have a lot of concerns with where we are on the stock assessment, and I just wanted to speak to a couple of them. First, as we said in our written comments, this is the most valuable finfish fishery in Alaska on a per-pound basis.

It really deserves to be comprehensively surveyed every year, and not too long ago, we relied on that annual survey. We are working to help find resources to return the survey to annual, but in the meanwhile, we would ask that there be consideration given by NOAA to how to conduct meaningful surveys in each area on an annual basis, even if they can't include all survey sites. Missing the entire Gulf every other year really leaves some data gaps that we feel are not being accounted for in ways that adequately reflect the the health of the stock. Also, with 90% of the fleet now using pots and filling out the daily fishing log, there should be a lot of data available to NOAA from the fleet on CPUE. Also, size composition is available through the processing sector.

We are filling those out, those are being sent in. We even have vessels that are using electronic versions of those logbooks, Somehow we have to make sure that data is being used. Our other big concern, and I also included graphs in our written comments to illustrate this from the plan team presentation, but that the implications of the method changes that the stock assessment authors are now moving forward to you from this year's plan team meetings would indicate that the biomass in 2005 to 2015 was actually half of of what it was estimated to be during that time. That would be a huge overestimation and does not ground truth what those of us who were fishing then saw on the grounds. Fishing wasn't as good then as it is now, but it wasn't that bad.

And it's really hard for us to believe that the stock assessment estimate was that far off, given that in those days there were annual surveys, historic data being used, CPUE data available to the assessment team and the Gulf trawl survey data was being used. All of that data has been dropped out for different reasons. But I would note, as one SSC member said, just because dropping data improves model fit and performance, it doesn't necessarily mean it's right. So as others have said, a cut of this level when the biomass is increasing will have a huge impact on the fleet. We've for years asked that this ABC not be increased.

We were worried about overshooting a sustainable level and having that followed by a decline. That big increase did happen. It did destroy the value of this resource for a number of years. We're just climbing out of that hole with prices stabilizing and market strengthening and the fleet starting to recover. We would ask that the council do some more review before taking a cut at this time to make sure it's really warranted from a conservation perspective.

So again, to close, we support the motions from the SSC and AP and hope that the council will do the same.

Thank you for your testimony, Miss, Miss Bengen. I'll see if there are any questions.

Yes, Ms. Kimball. Thank you, Ms. Banken, for your testimony. I'm trying now to reconcile what the SSC actually recommended with the AP motion, and you mentioned both, and, and my understanding— so I'm seeing if it's consistent with yours— is, is the difference in what the AP recommended is an explicit look at the 3-year phase-in for the FAA model, but Please clarify if there is another gap between what the AP recommended and the SSC recommended. Thank you. Yeah, thank you for that question through the chair.

And I don't want to speak for the SSC, so I hope someone from the SSC is available to clarify. But what I understood is that they looked for a sensitivity analysis with the fleets as areas model questioning some of the methods that were used in that and wanting to understand how some of the assumptions around selectivity and maybe natural mortality were being incorporated. But I hope there's someone there from the SSC to speak to that. So anyway, that, that they were looking for a sensitivity run on that. They were looking for full diagnostics on two of the models.

And I— yeah, I don't believe they spoke to a phase-in, but more to see what ABCs might be brought forward that would then give the council some leeway to think about changes to the TAC and setting the TAC below ABC over a series of years.

Thank you.

Thank you for joining us this morning. Thank you. So, Lancey Wetman is next, followed by James Johnson.

Good afternoon, Madam Chair and members of the council. My name is Lancey Wetman, and I'm speaking today on behalf of Alaska Marine Community Coalition, or AMCC. AMCC is a fisherman-founded and fisherman-led organization working to advance sustainable fisheries, healthy marine ecosystems, and thriving fishing communities across Alaska. Thank you for the opportunity to comment on the council's agenda item C3, groundfish harvest specifications. Today, AMCC respectfully requests that the council first set groundfish harvest specifications and total allowable catch precautionarily using available ecosystem information, and secondly, continue developing alternative harvest control rules, or HCRs, that connect ecosystem and climate information to management action.

First, turning to my first point, AMCC encourages that the council set TAC precautionarily using available ecosystem information. Each year, the council SETs groundfish harvest specifications in the Gulf of Alaska and the Bering Sea and Aleutian Islands, review stock assessments, ESRs, SAFE reports, SSC recommendations, and ecosystem status reports, to name a few. These materials do include ecosystem-based fishery management information, or EBFM, but that information is often qualitative and contextual. And while models incorporate precaution, Ecosystem information does not necessarily trigger TAC adjustments even during rapid environmental change. So in the near term, AMCC asked the council to use the EBFM information available to it when setting annual TACs where ecosystem considerations and conditions and uncertainty warranted.

Ultimately, AMCC advocates, though, that EBF information must directly inform TAC setting adjustments and decisions. A stock can be healthy on its own while the broader ecosystem is struggling, and so harvest specifications must account for both. Turning to my second point, that's why AMCC encourages the council to continue developing alternative harvest control rules that account for climate and ecosystem conditions. AMCC recognizes that the alternative HCR discussion won't be coming up till next year, um, for council action. Nevertheless, AMCC believes that it is important to keep developing these alternative HCRs.

For instance, the North Pacific has experienced multiple marine heat waves over the past decade. These, these events have affected both ecosystems and fishing economies, including the Eastern Bering Sea snow crab and the Gulf of Alaska Pacific cod. Alternative HCRs could help account for this environmental variability. And when evaluating alternative HCRs, AMCC recommends using measurable criteria. These could include recovery after climate shocks, prey availability, food web relationships, bycatch, habitat impacts, and there could be many more.

The council should also establish clear decisions and rules linking those ecosystem indicators to management action. These rules should identify when conditions warrant changes to acceptable biological catch, TAC, spatial management, etc.

Because climate-resilient HDRs can help protect spawning biomass during climate shocks and long-term changes in stock productivity, AMCC asked the council to continue developing alternative climate and ecosystem-informed HDRs that are linked to management decisions. In conclusion, AMCC encourages the council to use available EVF information now in its annual harvest specifications and then continue developing alternative harvest control rules directly connecting ecosystems and climate information to management decisions. Thank you. Thank you very much for your testimony. We'll see if there are any questions.

Yes, Ms. Vanderhoeven.

Thank you, Madam Chair. Thank you, Ms. Wetman.

Um, we're, we're only doing preliminary specs now. Um, we won't do final specs until December, um, and at that point we'll have the stock assessments and the risk tables. Um, I think a lot of the ecosystem information you referenced is incorporated in those risk tables. Is there other information that's provided to us at tax setting that you feel is not already incorporated in the assessment model or the risk tables? Thank you.

Through the chair, um, AMCC, our biggest ask is that you, you already have a lot of information and ecosystem-based, um, information to make those adjustments, and you have adjusted, um, TAC in the past and made buffers. However, we're asking that down the line harvest controls more directly incorporate climate variability, which currently the harvest controllers don't. And so in the near term, we're just asking to use information that does come to you and is presented in those risk tables to make a precautionary tax setting. But in the, you know, future and next year, really start to think about incorporating alternative harvest control rules. And this is supported by the SEC, who also kind of indicated that it's— it could be time to incorporate those alternative HCRs into, um, you know, the current tier system, um, or just revising a tier system altogether.

Thank you for your testimony.

James Johnson is up next, followed by Glen Merrill.

I think Jim is joining us online. Good morning, Madam Chair, members of the Council. Got me? Good morning. Good morning.

My name is James Johnson. I'm the Executive Director for the Deep Sea Fishermen's Union of the Pacific. Thank you for the opportunity to comment on the sablefish stock assessment and the advisory panel's recommendation. I want to begin by expressing my support for AP Motion 3, which passed unanimously by a vote of 18 to 0. The motion asks for additional assessment model evaluations before the council considers final harvest specifications in December.

The preliminary assessment indicates an approximately 32% reduction in the Alaska-wide sablefish ABC, with potentially greater reductions in certain management areas, particularly the Aleutian Islands. For fishermen and fishing communities, a reduction of this magnitude is consequential. It affects vessel revenues, crew compensation, quota values, and the economic stability of the businesses that depend on this fishery. But the issues before the Council is not simply economic hardship associated with the reduction in catch. The fundamental question is whether the magnitude and regional distribution of the proposed reduction are supported by the best scientific information available.

The Advisory Panel has identified 4 specific areas requiring further examination. The single region model with carryover apportionment, a potential 3-year phase-in of the fleet-as-area model and its regional consequences, dome selectivity assumptions for the Bering Sea, and the sensitivity of the fleet-as-area model to alternative natural mortality assumptions. These are reasonable and important scientific questions. They are particularly important when a significant change in assessment methodology may affect both the Alaska white abalone and its distribution among management areas. I would also draw the council's attention to 50 CFR 603.10, the National Standard 1 guidelines.

These regulations expressly recognize that substantial changes in catch limits resulting from new scientific information can have a significant short-term consequence for future— or for fishing industries. The regulation provides a framework for developing phase-in ABC control rules over a period not exceeding 3 years, provided fishing is prevent— provided overfishing is prevented and the applicable fishery management plan authorizes their use. I'm not suggesting that the Council can simply disregard the SSC's scientific recommendations or adopt a higher ABC for economic reasons. I'm suggesting that the council should fully examine the scientific and regulatory alternatives before accepting a reduction of this magnitude. Accordingly, I urge the council to support the advisory panel's unanimous motion, direct the requested model evaluation for the November plant team review, and ask the SSC to clearly explain the scientific basis for its December recommendation.

I would also encourage the council to request clarification from NMFS and NOAA general counsel regarding the applicability of phase-in authority and any available procedural flexibility should important scientific questions remain unresolved. Finally, I support the AP's recommendation to restore comprehensive annual fish— sablefish— annual sablefish surveys and strengthen the use of commercial size composition and catch per unit effort information. We are not asking the council to compromise conservation. We are asking it to ensure that a decision with substantial biological and economic consequences rests on the most complete and defensible scientific record available. Thank you.

Thank you for your testimony.

Not seeing any questions. Thank you for joining us.

And Glenn Merrill will be our last testifier.

Thank you. Excuse me. Thank you, Madam Chair, members of the Council. My name is Glenn Merrill. Today I'm representing North Star Fishing Company.

We participate in the Bering Sea sablefish as well as the turbot fishery, and some of my comments will be specific to those fisheries. I'd like to begin by closely aligning myself with the testimony you just heard from the Freezer Longline Coalition. I think that they highlighted a range of different issues that are important for the Council to consider. And in particular, I wanted to highlight two things: harvest control rules, and also some of the questioning that came up from Ms. Kimball concerning participation in surveys to improve our understanding of Greenland turbot. On the first issue, on page 22 of the SSC minutes, there's a recognition by the SSC and continued support by the SSC to look at a retrospective analysis of the issues in the Gulf of Alaska Pacific cod fishery as a way to kind of perform a test case, if you will, of how an alternative control rule may operate.

I think that holds a lot of value for those of us in the industry having participated in the Plan Team meeting, SSC, and then here today trying to follow these issues. It's an extremely complicated process, and at its core, I think what many of us are struggling with is how will this alternative control rule process perform? Why is it better than our existing methodologies that we have in place? And I think you have a clear example with the Gulf of Alaska of a stock that had a, a clear and demonstrable response to climate change. If we had something different in place, what would have happened?

What would our management advice have been? And so I think focusing time and energy on that in particular could go a long way to building a bridge and a better understanding with those of us in the industry who are directly affected by these regulations that ultimately result from this type of scientific process to better understand and better appreciate where we're going. On the second issue concerning Greenland turbot, I think the industry has been always willing to participate in cooperative research, and I think in particular with Greenland turbot, we've had a couple of suggestions, one of which is in our existing survey, understanding we don't currently have a slope survey, getting deeper station coverage is important. It's not only important for Greenland turbot, but it's also important for a range of other species. One of the other species that a deep water station could also give us a better understanding of is the other rockfish complex.

As I think some of you are aware, that has been a constraining complex in the past for a range of different fisheries. So I think there is great value in improving our understanding. That's using our existing scientific methodology. In the past, we worked very closely with NOAA to try and establish a cooperative research program, the CIRCA project, to get a better understanding of how we could improve what we know about rockfish stocks and untrollable habitat. Unfortunately, there was not the ability of the resources for NOAA to be committed to that research to continue, and it's on pause now.

We would like to continue those types of efforts, whether it's rockfish, whether it's Greenland turbot. We're certainly open to that, but having that clear partnership and resources will be key. Thank you for your time. Thank you for your testimony. Are there any questions?

Yes, Ms. Kimball. Thank you, through the chair. Mr. Merrell, on your first point about the harvest control rule changes to incorporate climate information, is the type of analysis or retrospective that you are suggesting, is that something you're suggesting be done within the analysis of HCRs as a way to test what— like what you said, what, what would have happened in the past had that been— is that something you're actually asking for in the context of our analysis of those alternatives, potentially when we get to that in February?

Through the chair, Ms. Kimball, yes, I think, I think it'd be helpful for the council if work is ongoing between now and February. I think it would be very helpful for the council to signal this in particular is the thing that we would like to have come back with a better understanding understanding of how those alternative HCRs would perform, because I think it would be most illustrative to those of us in the industry about what we could expect if this were applied to other stocks in the future.

Thank you.

So that concludes our public testimony on C3. Uh, let's take a brief stand down, um, or I guess we're close enough to our mid-morning break. Let's, um, do that, come back at 10:05, um, and see what the wishes of the council are as far as action on C-3. Thank you.

Welcome back, everyone. Uh, before we, uh, consider action on C3, I think we may have a question for staff. Ms. Baker. Thank you, Madam Chair, and thank you. I really just wanted to follow up on some of the questions that came out of the AP report this morning and trying to reconcile that with some of the recommendations from the AP with, of course, our SSC report that we received yesterday.

And so my question is about sablefish stock assessment, AP motion number 3. And in reading the AP report, the AP recommends the sablefish stock assessment team explore the following models. There's a list of 4 models. I believe Ms. Mann said in her report, or in response to a question, that the SSC recommended all but one of the same models go forward that the AP did. And I'm just, as I read the SSC report, the only model the AP recommended that the SSC did not was number 2 in the AP report, a 3-year phase-in of the 26.2 FFAA model, and I just wanted to ask staff if that's correct and perhaps a little bit of background and reminder why potentially the SS— or, you know, if the SSC discussed that model at all, the recommendation under number 2 in the AP report and what challenges we may or may not have going forward with that.

Thank you. Through the Chair, Diana Stram, Council staff. The SSC did not talk about a phase-in. There is, as you heard in public testimony, there is a provision under the National Standard Guidelines to develop a phased-in control rule in situations where new scientific information causes short-term economic hardship on the fishery. The Council could develop an ABC control rule that would allow for a 3-year phase-in as long as you don't exceed the OFL in any year.

However, you would have to develop and implement that control rule, so you'd have to amend your FMP. Our current maximum ABC control rule does not allow for a 3-year phase-in, so it is a latitude that you could do. And if the council wished to pursue something like that in the future, you could amend your FMP and amend your ABC control rules to allow for that. But right now, you do not have that ability. When we talk about phasing in— and Ms. Mann alluded to this in her testimony as we had this discussion at the AP— the The SSC has often, um, stair-stepped an ABC, but only going up, not coming down.

Once your max ABC is set by your control, you cannot exceed it, so you cannot stair-step above it. If that answers your question, Ms. Baker.

Ms. Kimball. Thank you, and, and thanks to Ms. Baker for helping to to sort that out. So what I'm reading is that we have 3 recommendations from the AP on the sablefish stock assessment that will already be brought back. They're, they're consistent with SSC recommendations, and then one that is not possible based on the harvest control rule that we have today. Can I just confirm that's right?

Through the Chair, Ms. Kimball, yes, the, the other 3 ABC—. The other 3 AP recommendations are consistent with the SSC recommendations. One follow-up. Thank you.

And, and so I think that clarifies the action that could be possible at this meeting, but, but I, but I did want to ask for some clarification on, on our ability as a council to make recommendations if there were models that we were interested in, or at our meeting when the SOC has already made their recommendations. For model development and things to bring back in December. And I've—. The AP motion was really clear that they said this isn't really past practice, but this is important. And I, I very much agree this is important, but I don't know if Mr. Fortenberry could be prepared to say what our authority is to do that, given that the SSC is our peer review body for harvest specifications and has the sole authority over OFLs and ABCs.

Just for the future. That doesn't seem to be on the table anymore for this meeting, but for the future, I'd like to know if we're going to start to delve into this.

Uh, yeah, through the chair, Ms. Kimball, um, so I would think about this in a couple steps. First, the MSA obviously says that the council must develop annual catch limits that can't exceed the fishing level recommendations of the SSC. Those recommendations are are entirely the province of the SSC. So I would point the Council to National Standard 2 guidelines, which says that debate and evaluation of scientific information is the function of the SSC. It's solely the function of the SSC.

It—. The way the independent peer review process is set up, there's not a feedback loop whereby the Council can tell the SSC what scientific information it thinks it should evaluate. We want the SSC to independently evaluate what it thinks is the best scientific information available and then make its recommendations to the Council for those recommendations to be valid under National Standard 2.

Thank you, Mr. Fortenberry.

Any further questions before we move on? Yep, Ms. Baker.

Thank you, Madam Chair, and thank you, Mr. Fortenberry. But to follow up on that and pointing back to Dr. Stram's response to My question, the— if the Council was interested in the future, as Ms. Kimball said, in a phased-in model type approach for the situation that we're looking at here for sablefish, the, the appropriate process to work through that within all of the national standards in the Magnuson Act is to amend the FMP and develop a harvest control rule such that some sort of phased-in model approach would be allowed. That's— I'm sort of understanding that is the, is the conclusion to what you just shared with us. Is that close?

Through the chair, Ms. Baker. Yeah, I think that's close. Essentially, if the council wanted to have an ABC control rule that allowed for phased-in implementation, the development of that control rule would itself go through the peer review process. So we would evaluate the scientific validity of a phased-in control rule through the full council process. We would amend the FMP so that there would be an objective set of processes in place in the FMP that would allow for that sort of phased-in.

But it still wouldn't be the council recommending models or the way that the SSC should look or consider certain models. It would basically be saying the SSC would itself evaluate whether there is scientific merit in doing some sort of phased-in APC implementation. In response to large changes in stock status.

Okay, thank you, Mr. Portenberry. And thank you. Not seeing any other questions, so we'll see what the council— what the wishes are as far as action on C3. Ms. Kimball, I'm—. I am sending that Right now I'm—.

Okay, we'll just give it a moment to come on screen.

Did that go through? Oh, okay. Sorry for the delay. I wanted to hear the answer to the questions first.

This is on C-3 for the proposed Gulf of Alaska groundfish specifications. The motion reads, the Council adopts the proposed 2027 and 2028 Gulf of Alaska groundfish specifications for overfishing limits and ABCs as recommended by the SSC and the tax shown in Table 1. The tax for Gulf of Alaska Pacific cod and pollock have been adjusted to account for the state water guideline harvest level fisheries. Pacific cod adjustments are shown in Table 2. The proposed TAC for Gulf octopus has also been adjusted to account for the statewater GHL fishery included in Table 1.

The Council adopts the proposed 2027 and 2028 annual and seasonal Pacific halibut PSC limits and apportionments in the Gulf of Alaska as provided in Tables 9, 10, 11. The Council adopts the 2027 and 2028 halibut discard mortality rates for the Gulf of Alaska shown in Table 12. Final specifications will be approved in December of 2026 when stock assessments are completed and full information is available. Regarding spatial apportionment, the Council is interested in SSC advice in December 2026 as to whether there's flexibility in the survey-based spatial apportionments recommended by the SSC for Gulf shortrigger rockfish, Gulf rough-eye and black-spotted rockfish complex, Gulf thornyhead rockfish, and Gulf skates, big and longnose skates. Useful information from the SSC could include whether the previous year's BRDs or small changes from the current SSC recommended BRDs would be likely to result in biological impacts to the stock or stock complex.

And with a second, I'll speak to it briefly. Thank you for the second, Ms. Vanderhoeven. Ms. Kimball. Thank you for the second, Ms. Vanderhoeven. I—.

This really are just proposed and what we need to have as carryover and in place in order to get to our December meeting where we then review all of the updated information and survey information and assessments in order to do our final total allowable catch, all catch limits in December. So this is our standard process in order to have the proposed in place, but just want to be clear that those will be replaced by final numbers when we get to specifications in December. I did repeat for spatial apportionment, you know, we had discussions with the SSC. I did repeat the same species that we were interested in, whether there's going to be any level of flexibility. For spatial apportionment differences from the survey information once we get to final tax in December.

I did not change those rockfish species. I did not change skates. I recognize that SSC has already given us their information on skates, and we're just holding on to that until we get to our final specifications in December. I did want to mention also on the, the intent on, on BRDs or spatial apportionments of ABC, I just want to confirm that all of the discussion with the SSC and with staff, that they're asking us to relist those species each year that they're in— that we're interested in. I think that's an important role for the council, that we're not expecting new analysis in order to provide information to the SSC, but existing information, and that we should provide some rationale on record as to why we want to look at certain stocks.

And so my rationale from last year at this time is the same these are clearly stocks that have been limiting in terms of incidental catch, hard to survey, long-lived stocks, and we wanted to see if there was any ability to have a little bit of flexibility in the spatial apportionment of those, and we'll get that back in December. I think one other thing I— two other things I wanted to mention in my rationale is just we heard testimony on the Gulf arrowtooth flounder. Again, we got that full assessment at this meeting, but the actual total allowable catch we won't We won't specify until December, but I appreciate the note for the Council to be aware of things like implications for incidental catch allowances of cod, for instance, if tax increase. We will see what that assessment— we'll get that final assessment in December, like I said, and I think we can see the NIMS management report remind us of what the ICA is for cod in the Gulf of Alaska and provide any kind of suggestions to NCIS and management if we think there's a reason that they should be aware of a potential to hold that the same, increase it, or decrease it. But again, I think that's a December conversation.

I appreciate the conversation about sablefish. I don't, I don't think you need to belabor that. And, and while I don't think we have the latitude to recommend anything different from the SSC given our NOAA GC advice, I do just want to thank the public for, and the APE for providing a lot of detail and digging in to what might be possible in light of a potentially very big change and a change that's not based on any concern with biomass but only a concern based on lack of a survey, a longline survey. So that's my proposed Gulf groundfish specs. I'd be happy to answer any questions.

Thank you for the motion, Ms. Kimball, and I'll see if there are any questions.

No, see none. Any comments?

Mr. C. Thank you, Madam Chair. I, I will support this motion. I did also just want to acknowledge some of the comments from the public about the HCR harvest control rules and how those can be looked at, and also on the comments about looking at the Greenland turbot assessment and how that might, might be addressed, looked at, and in a way acknowledging the lack of the, of the slope survey and other assessment or other survey tools for that, um, for that stock. So, uh, that's as one council member, I appreciate those comments and are hopeful that those will be, will be noted.

So thanks. Thank you, Mr. C. Any other comments? Okay.

Thank you, Miss Kimball, for all of your work on this motion as usual, um, and for all of the, um, follow-up rationale and references to, um, the various issues we've heard in public testimony in regards to specs. Okay, with that, um, proposed specification, so we don't need a roll call vote. I'll ask if there's any objection.

Seeing none, that motion passes without objection. Any further actions? Yes, Miss Vanderhoeven. Thank you, Madam Chair. The motion that I've sent to staff— just wait for it to come up.

Motion reads, the council recommends the proposed 2027 and 2028 Bering Sea and Aleutian Islands groundfish harvest specifications for OFLs and ABCs as recommended by the SSC and sets the tax as shown in the attached BSAI Table 1 With all proposed specifications consisting of rollovers of 2026 final specifications from the 2026-2027 harvest specifications approved in December 2025. The tax for both Bering Sea and Aleutian Islands Pacific cod have been adjusted to account for the statewater GHL fishery. The Bering Sea sablefish tax has been adjusted to account for the statewater GHL fishery. The Council recommends the proposed Ahtna, Makah, Atka mackerel seasonal, spatial, and gear allowances; flatfish ABC reserves; 2027 and 2028 annual and seasonal PSC limits and apportionments in the Bering Sea Aleutian Islands as proposed in Tables 3, 7, 8, 9, 10, and 11 for halibut, red king crab, Tanner crab, opilio crab, and herring, and their gear type and target fishery apportionments. The 2027 and 2028 crab and herring PSC limits have been revised using current biomass estimates.

The council recommends the proposed 2027 and 2028 halibut discard mortality rates for the BSAI as shown in Table 12. Regarding spatial apportionment, the council is interested in SSC advice in December as to whether there's any flexibility in the spatial apportionments recommended by the SSC for bearing Sea Aleutian Island Sablefish and Blackspotted Rougheye. And with a second, I can speak to the motion.

Thank you for the second, Ms. Kimball. Thank you, Ms. Kimball. Thank you, Madam Chair. As Ms. Kimball noted, the groundfish stock assessments for this year have not been run or reviewed yet by our peer process, including the groundfish plan team NSSC or by our advisory panel and the public. That process will occur over the next several weeks leading up to our December Council meeting, and at that time we'll recommend the final OFL's ABCs and TACs for 2027 and 2028.

We need to put forward proposed specs at this meeting without the updated catch and survey data for the, for the current year in order to follow the harvest specifications process and for NMFS to publish in the Federal Register and solicit public comment on proposed harvest specifications. After our December meeting, when we make our final recommendations for 2027, the updated values for OFL's ABCs and tax will be updated in the Federal Register, usually around March. In this motion, OFL's ABCs and tax are consistent with what was approved last year for 2026. 2026 In order to meet the tax setting process to authorize the groundfish fisheries in the Bering Sea Aleutian Islands for 2027 and 2028. The Pacific cod TAC numbers account for the, for the statewater fisheries at the 2026 levels because the fishery is still open and will be until November 15th.

When we make final recommendations in December, we'll adjust the allocation to reflect any change based on actual harvest in 2026. To accommodate for the GHL fisheries as outlined in regulation. The Statewater Pacific Cod jig allocation has been accounted for as well, and the Bering Sea Sablefish TAC accounts for the Bering Sea and Aleutian Islands Statewater fishery. With the Bristol Bay Red King Crab fishery open, so is the Red King Crab Savings Subarea, or the Strip as we refer to it. To non-pelagic trawl gear.

Table 9 includes that PSC limit. The halibut discard mortalities rates in Table 12 have been updated to reflect the changes recommended by our advisory bodies. The council received the updated herring biomass value and the PSC table for herring has been updated. The council has not received the halibut estimates from the IPHC to set the Amendment 80 halibut PSC limits, under abundance-based management. These numbers are expected to be available at the December council meeting.

As noted in the staff presentation, the PSC limit for Chinook for the Eastern Bering Sea pollock fishery is not included in the tables because the council does not take action on these numbers during the groundfish specifications process, but I wanted to publicly recognize that we have received the Three River Index notice from ADF&G and the fleet will be operating under the lower limit of 45,000 fish. The Table 3 akamackrel allocations, I'm proposing a reduction of the Eastern Aleutian Island Bering Sea jig allocation setting it to 0 metric tons. We did this last year. The sector has not fished the allocation since 1995, leaving those fish stranded. I'd like to highlight this so that if the sector does have plans to prosecute the fishery in 2027, they can provide us with public comment for the December meeting for consideration of setting final specs for next year.

And finally, for sablefish apportionments for flexibility, my interest in flexibility there relates to the harvest patterns for both areas in recent years and looking to provide more opportunity to achieve optimum yield under the 2 million metric ton cap And as to the black-spotted ruffeye flexibility, I'm looking for any flexibility to address area overages in recent years as it might relate to potential accountability measures. And with that, I'd be happy to take any questions.

Thank you for the motion and rationale, Ms. Vanderhoeven. We'll see if there are any questions.

Any comments on the motion?

Seeing none, um, thank you very much for all of your work on this and your thorough rationale. So with that, I'll see if there's any objection to the motion.

And seeing none, that motion passes without objection. Thank you. Any further actions for C3?

Okay, seeing none, that brings us into our D1 agenda item. We are, uh, a little ahead of schedule still, and our AP report will not be done until after lunch. So, um, just a note to the public, we'll probably— if we do end our staff presentation before lunch, we'll be taking an early lunch.

Morning, Madam Chair, members of the council. For the record, Sarah Mearnan, council staff. This is D1, this is a staff presentation for the charter halibut permit use and angler effort data request, a discussion paper we worked on, and here to present the staff report with me is Adam. I'll let him introduce himself. Good morning, Madam Chair, members of the Council.

I'm Adam St. Saviour, statewide groundfish coordinator with ADFNG, and I will have a short bit at the end of this presentation.

Also in here, here in person, we have Doug Duncan with National Marine Fisheries Service who's available to answer questions, and we have Ben Jevons with ADFNG who's online. Who can help us out with questions. The discussion paper, of course, is posted to the e-agenda. There's also an appendix there that's for reference in two of the data requests that we'll talk through. We also have the report for the Charter Halibut Management Committee, and I can present that directly following the staff report, if that works.

They—. The Charter Halibut Management Committee also reviewed this discussion paper at a committee meeting prior to the council meeting and provided some recommendations. So we'll present the discussion paper, and then following that, I'll present the committee report.

There's a short history of action here for this discussion paper. The council tasked this paper last year in December. It's intended to provide useful context for annual management measure process and in considering the performance of the charter halibut limited access program and in considering possible impacts of the recreational quota entity. It's not intended to be a comprehensive review of the charter halibut limited access program. It doesn't direct specific action, although next steps may be considered after the review.

So here are the data requests. There were 7 data requests. Note that these are reorganized and renumbered from the council's motion. So the first 5 cover charter halibut permit renewal and retirement, ownership and lease transfers, trends in charter halibut permit use and angler effort, community quota permits, and consolidation under the holding caps.

Request number 6 was done by Adam. He'll present this part, and it looks at how much effort would need to reduce to achieve a specific set of less restrictive management measures, holding everything else constant. And we're going to work through these different data requests, so we will talk through more about what this— what these particular data requests mean as we get to each one. The 7th data request looks at how much less restrictive could management measures be if the RQE was holding up to the maximum amount that it could hold under the transfer limits, holding everything else constant.

So before we get into the, those 7 data requests, I have a little bit of background information. Since 2011, all charter halibut vessel operators are required to have valid charter halibut permits on board. These are issued as transferable, or there was a lower threshold to receive a non-transferable permit. The permits are endorsed for a certain number of anglers to be on board. There's Table 2 in the paper shows angler endorsements across areas, so that's— those endorsements are between 4 to 38 anglers per permit.

There are some special non-transferable permits. There's permits for Community Quota entities and U.S. Military Morale, Welfare, and Recreation Program. The program includes a holding cap of 5 CHPs Although there were some permits that were grandfathered in over that limit. So you can see in Table 1, there are 529 regular Area 2C permits, 65% of them are transferable. There's also the special permits, so that makes a total of 578 permits in Area 2C.

In Area 3A, there's 426 regular permits, 70% of them are transferable, so for a total of 488 permits in Area 3A.

You can see in that Table 2 that the 6-angler endorsements dominate both areas. Area 3A has substantially more permits endorsed for greater than 6 anglers, so that angler endorsement capacity is really a structural difference between the two areas.

I wanted to provide some summary background here before I move on. Marianne, you have a question? Sure. Yes, Mr. Bowers. Thank you, Madam Chair.

Miss Marinan, can charter halibut permits be held by corporations, or are they only held by individuals? Through the Chair, Mr. Bowers, yeah, they can be held by individuals or entities, yes. Thank you.

We have some background here on leasing of permits. The Council has had an extensive history around considering restrictions on the leasing of permits However, CHP leasing is still an authorized feature of the program. An operator must have an original valid permit on board a charter halibut. However, there's no transfer that occurs through NIMS for someone who's not the permit holder to use a permit. CHP leasing can include complex business agreements with a specific paperwork that's filled out, or it could be as simple as one person handing someone their permit for the day.

So there have been some previous concerns highlighted around leasing, including the creation of absentee ownership, risk of latent capacity coming online, and increasing effort. However, permits were issued to charter business owners. So as we talked about, that could be an individual, it could be an entity, it could be a partnership. So one of the concerns in establishing limitations is the unintended effect on businesses that might not lease permits but whose operational structure might be based on a non-permit holder using the permit. So for instance, an employee of a business that holds the permit.

I also have some background here on the Recreational Quota Entity. The RQE is a nonprofit entity that's authorized to purchase and hold commercial halibut quota share on behalf of charter halibut anglers in Regulatory Area 2C and 3A. This quota can augment the apportioned pounds of halibut for charter catch limit in that area and in that year, which can be used to relax the annual management measures. So the charter halibut stamp is the funding mechanism for this entity, which began accruing revenue in 2026. It's my understanding that the RQE has received its first transfer of Area 2C halibut quota share this year.

This included approximately 26,000 units of Class A Area 2C quota, which is equivalent to about 1,300 pounds in 2026. This slide also highlights transfer restrictions for the RQE. There are total or cumulative limits on how much can be transferred, which is a shared limit with guided angler fish provisions, which we'll talk about more later. There are annual limits on the type of— on how much quota share can move in one year, and there are limits on the type of quota share that can be purchased in each area.

Okay, so moving into the data requests. The first data request was to look at renewal, or another word for that is registration and retirement of permits. Since 2020, CHPs must be registered annually to be valid for use. So Table 3 here shows for each year for Area 2C, 31 to 48 of the 529 permits have not been registered each year. For Area 3A, 27 to 57 of the 426 permits have not been registered each year.

For both areas, you can see a greater proportion of non-transferable permits that have not been registered relative to the portion of transferable permits that have not been registered. Across both areas, 34 permits have never been registered.

There isn't an automatic process for retiring permits. If a permit isn't registered, it's just not valid until it is registered. But there have been times when NMFS has been notified, an effort is put in to establish that a permit should actually be retired. So this would be the case for a non-transferable permit if the holder passes away, or if an entity— the entity holding it dissolves, or additional partners or shareholders are added to that entity holding the permit. Then a non-transferable permit is intended to be retired.

So throughout the course of the program, so far 25 permits have been retired.

Request number 2 looks at ownership transfer and lease transfer of permits. So transferable CHPs may change ownership over time through a transfer application that's submitted to NIMP's Restricted Access Management Division, RAM. Uh, so a simple way to think about consolidation or expansion of permit holders is to look at the number of permit holders between initial issuee and the most recent year. Uh, that's what Table 5 does in the paper. So it shows a slight expansion in holdings in Area 2C and net consolidation in Area 3A.

Table 6 in the paper shows annual transfer activity from 2011 to 2026. You can see a spike in transfer activity in 2021 and 2022.

Leasing a permit is not a transfer that's done through NIMS, as we just talked through. There's currently no monitoring or reporting ability for this type of transfer. However, the permit registration application includes a question about whether financial compensation was received for allowing another person to use the permit, um, so leasing the permit. So this essentially provides self-reported lease rates since 2020. and you can see this in Table 7 in the paper. For Area 2C, um, an average of 17% of the permits, um, the owner reported receiving financial compensation for its use.

For non-transferable permits specifically, owners reported receiving financial compensation for an average of 19% of these permits.

In Table 7, you can also see the numbers for Area 3A. There's greater levels of self-reported leasing in Area 3A, an average of 19% versus Area 2C's 17%. In both areas, a greater proportion of the active non-transferable permits are leased compared to the proportion of transferable permits that are leased.

Request number 3 asks for trends on transferable and non-transferable permit use and angler effort. So this is the first data request where we've integrated ADFNG saltwater logbook data, merging it with charter halibut permit characteristics. We have some different definitions here than are often used in ADFNG reports and what, what's relied on for Data Request #6 and #7. So just to define some terms quickly, the data in this section shows CHP trips, which is a vessel-level trip in which halibut was caught and retained, and CHP angler days, which is an angler trip in which halibut was caught and retained. So for example, if you have 6 anglers that caught halibut on 1 vessel, you'll have 1 CHP trip and 6 CHP angler days.

Data is provided in the section from 2018 to 2025. The paper talks about how data quality has substantially improved in what we have for CHP activity, mostly attributed to the change to e-logbooks, also CHP registration. However, some errors were still evident when we were working with the data. So while some errors persist, the data is expected to be sufficient to demonstrate high-level trends that were requested within this discussion paper. And we expect data quality and accountability to improve with the implementation of the charter halibut stamp.

So there's a number of ways the use data is displayed in Section 3.3. For purposes of this presentation, I'm just going to cover a few of them. So in the paper, we have number of active permits, number of CHP trips, number of CHP angler days, average CHP trips and angler days per permit. We have these tables broken out by area and permit type. The activity also includes CQE and MWR permits.

The figures I have here on the screen correspond with Table 8 and 9. It shows number of active CHPs, number of CHP angler days for Area 2C, You can see a notable impact from COVID in 2020, but otherwise relatively consistent use of permits and angler days. Both of these metrics decline between 2024 and 2025.

These figures correspond with Table 8 and 9 for Area 3A. We have number of active CHPs and number of CHP angler days. So there's similar to Area 2C, there's consistency in permit use, but there may be a bit more variability in angler days. We can see a rebound here after COVID, which likely has to do with more relaxed management measures following the uncertainty of 2020. For Area 3A, there's also a decline in permit use and CHP angler days between 2024 and 2025.

More, you can also see from these data and figures that more CHP trips occur in Area 2C and more CHP angler days occur in Area 3A. The average number of trips in 2C is 42, number of angler days is 177, the average number of trips in 3A is 41, and the average number of angler days is 267. So definitely more permits on the higher end of angler days distribution in Area 3A compared to 2C, and that's likely connected with the higher angler endorsements that occur in 3A.

So moving on to data request number 4, so this request was use of CQE CHPs issued to non-active CQEs. CQEs are nonprofit entities that represent an eligible community in the Gulf of Alaska or Aleutian Islands. The program was initially started due to the migration of quota share outside of communities. It allows these entities the opportunity to buy commercial quota share. It also allows certain other opportunities that have been added into the program, including the ability for CQEs to apply for a special community charter halibut permit and receive a certain amount of these permits free of charge.

The CQE internally determines who uses their commercial quota share or charter halibut permit. There are some stipulations on use of these permits that the resident using them, or the individual using them, must either begin or end their trip in the community that's associated with the CQE. Currently, there are 20 CQEs that hold 104 community CHPs across both areas. The data request here was about non-active CQEs. Um, there might have been a number of ways to consider this, but based on the discussion that happened when the motion was made, my understanding was to focus on CQEs that no longer exist.

So I looked at the Alaska Department of Commerce Community and Economic Development searchable database. Um, you can look up business status there, and 4 of the 20 CQEs were listed as involuntarily dissolved.

CQE permits are not required to be re-registered each year, and the regulations are silent as to whether a CQE status invalidates a community CHP. Table 12 in the paper provides a summary of activity for active community permits.

Miss Marinan, uh, question? Mr. Pamplin. Thanks, Madam Chair. Appreciate the presentation thus far. Could you provide just a little bit more context on what a CQECHP is?

So a community is holding a charter halibut permit. Are their clients essentially members of the community, or are they charging other people that are visiting the community, and this is a way for that community to make revenue through the charter permit? I'm just—. Could you just add a little more detail, please? Thanks.

Through the chair, sure. So, the community CHP was an opportunity that was added into the CDE, the CQE program later on after it had been developed, and I think with a similar intent to the original objectives of the CQE program, it was intended to provide opportunity for residents and individuals fishing in that region. So it allows for an individual or entity that wants to operate a charter in that CQE community access to the permits. The CQE internally decides how they might distribute those permits. As I mentioned, there are stipulations in the regs for these permits where the trip needs to either begin or end in the CQE community.

So the business would likely need to be local or structured around that community in that way.

CQEs are required to submit annual reports, so some of them have detail about these operations that happen in their community or the, the operations that have come to rely on those permits, but it's similar to other opportunities within the CQE. It's intended to be community-based opportunity to access charter, the charter fisheries. So in, in many ways, they're just like the regular CHPs, but there are some special provisions connected to the CQE goals.

Okay, moving on to data request number 5. This request asks for a description of the extent to which businesses which are at the CHP holding cap, which is 5 permits, are using additional CHPs through lease transfer. Table 13 in the paper shows distribution of permits held in 2026. The majority of permit holders have 1 permit, as you can see in that figure. In Area 2C, 27 CHP holders are at or over the cap, and in Area 3A, 4 CHP holders are at the cap.

So we focused on these CHP holders. This is 34 to 35 entities, um, depending on which year you're looking at between 2018 and 2025. When the motion for the discussion paper was made, we tried to especially manage expectations around this data request, um, because as we've talked to, there's no easy way to discern trips with leased CHPs or to know the relationship between the CHP holder and the user unless they have the same name. So we took an approach by comparing the number of permits held by a CHP holder that's at the cap to the number of permits used by matching business names through the data set. So this is not necessarily a lease, and it's not being defined this way in the paper, but it's an— it is intended to demonstrate a sense of consolidation and to address the data request.

Um, Table 15 is the reference here for this data request. The business names of these 34 to 35 CHP holders were matched with business names in the ADF&G logbook activity when possible. So we could do this with 20 to 25 businesses, um, each year. It's possible that some of the businesses we couldn't match leased their permits or they were inactive. Most businesses that could be evaluated used their full number of permits or more, and in aggregate, as you can see in the table, these businesses consistently used over their number of CHPs.

You can see a big drop after 2019 in the data, and that's likely due to improved data quality, e-log books, and permit registrations, which could have a large impact on the number of reported CHPs used. And just providing extra thanks to Ben Jevons here for working through this tricky data request with me and adding extra effort for the name matching component of it.

Ms. Kimball. Thank you, and thanks for the presentation, Ms. Marinette. Can you just tell me, what is my— what am I learning from this? What am I What is my take-home on these businesses consistently use over their number of CHPs? Is that trying to give me a sense of the amount of leasing in each area, and that's, that's it?

Uh, through the chair, Ms. Kimball. Yeah, again, it doesn't necessarily indicate leasing. Likely there's some leasing that occurs, but I guess my take-home from looking at this table and the underlying data is that there is consolidation. Within the fleet among certain entities.

Yeah, it does happen, and especially I think looking back at the figure, there are a lot of entities that just have one permit and likely operate their business around that one permit, but there's also entities that have more consolidation. I think it also highlights really the diversity in operational types among the charter sector. And Ms. Marinan, I just want to clarify that this is, this is permissible leasing past your holding cap, like your holding cap doesn't embody leasing activity and ownership. Is that accurate? Yeah, uh, Madam Chair, so again, it could be leasing, it could be that they are employing a guide that then brings their own CHP, so it looks like more permits than they hold.

But there's no restrictions on leasing right now either. We don't have a monitoring enforcement mechanism, and there's no regulations that prohibit it. So, um, consolidation is possible, and this is demonstrating some amount of it that likely occurs.

Thank you for that clarification.

Okay, with that, I'm going to pass it over to Adam for data request number 6. Uh, thank you, Sarah. For the record, Adam St. Saviour, ADF&G. For request number 6, I was tasked with determining how much effort would need to be reduced to achieve a set of specific, less restrictive management measures. Holding constant the most recent allocations, average weight, and harvest per unit effort.

This is similar to the annual management measures analyses, but instead of projecting removals, I was projecting effort. The measures I projected effort for were a U45/O80 reverse slot limit with no additional harvest measures, one fish of any size with no additional harvest measures, and 2 fish of any size with no additional harvest measures. And those 3 are specific to Area 2C. For Area 3A, the 3 measures investigated were 1 fish of any size and a second fish of 28 inches or less, closed Wednesdays, and a 1-trip daily limit. 1 Fish of any size and a second fish of 32 inches or less with no additional harvest measures.

And 2 fish of any size with no additional harvest measures.

I'll run through each of these and I'm happy to take questions during or after. I ran these analyses in 20— sorry, January of 2026 before the 2026 allocations were announced, so the results are reflective of the information that was available at the time, specifically the 2025 allocations. I'll briefly explain how I calculated these methods for the other analyses are similar to this first one. For the under 45 over 80-inch request, this one calls for no closed days, so I had to add— or I had Tuesday savings available, it was calculated during the 2026 status quo forecast, and this is the estimated number of fish that would have been harvested had Tuesdays been open in Area 2C in 2025. I back-calculated effort from Tuesday savings and the observed harvest per unit effort in 2025 and added that to the total 2025 effort to simulate what effort would have been with no closed days.

This is the plus Tuesday effort column in the, in the table on this slide there.

And as a reminder, effort is defined as angler days where bottom fish stataries were recorded or halibut were harvested in charter logbooks.

The larger harvest forecast was then used to create a new reverse slot table, and then I iteratively, iteratively adjusted effort downward until harvest reached a level where U45-080 removals in the reverse slot table were less than or equal to the 2025 allocation of 0.72 million pounds. The results from this first analysis are shown in the table. A 36% reduction in effort is required for U45080 removals to reach a level that is less than or equal to 0.72 million pounds. The column labeled reduced 2025 effort is reflective of the 36% reduction from no close days.

Uh, the second analysis was for one fish of any size. And that's equivalent to under 50/over 50 in the reverse slot table. The same methodology was used to project the effort required to achieve U50/O50 based on the 2025 allocation as in the previous analysis. Uh, in this case, a 62% reduction in effort is required for U50/O50 removals to reach a level that's less than or equal to the 2025 allocation of 0.72 million pounds. Um, for the, the third request, available data were explored to determine the viability of a 2-fish of any size with no additional harvest measures analysis.

The difficulty with this one was there was no way to know what proportion of anglers would keep 2 versus 1 or no fish. The nearest available data were from 2010, the last time there was a 2-fish limit in Area 2C. Given how the stock and angler behavior has changed since then, it was deemed it would not provide a meaningful projection. Furthermore, the analysis, you know, the one-fish analysis indicated a 62% reduction would be needed to get to one fish of any size. So to get to two fish of any size, effort would obviously have to be reduced well more than that, and we didn't think a reduction of that magnitude was realistic, so we didn't pursue that one any further.

Moving on to Area 3A, I use the same methodology as in 2C to project effort required to achieve 1 fish of any size and a second fish of 28 inches to close Wednesdays and a 1-trip daily limit. Uh, this one would require an 18% reduction in effort relative to 2025. Plus no closed Tuesdays to achieve a 2025 allocation of 1.48 million pounds.

Here are the results from one fish of any size and a second fish of 32 inches with no additional harvest measures. This scenario includes open Wednesdays and no trip limits, so in addition to the methods I've described, Wednesday effort was also added back in. And since Wednesday effort was not available because Wednesday's been closed for a very long time, Tuesday effort was used as a proxy. And so Tuesday effort ended up getting added back in twice in this scenario. And to remove trip limits, the percent of a second-plus trip in— by sub-area in 2013 was used as this was the last year without trip limit in Area 3A.

This was applied as a project— or excuse me. This was applied to the projected harvest as a percent increase. For this scenario, a 42% reduction in effort is required for removals to reach a level that is less than or equal to the 2025 allocation of 1.48 million pounds.

Uh, for two fish of any size in Area 3A with no additional harvest measures, the same methodology was used as in the previous analysis to project effort with all days open and to expand harvest for no trip limits. Mean weight was also adjusted in this projection to reflect the mean weight of over 27-inch fish, consistent with a similar analysis in last year's management measures analyses. In this scenario, a 57% reduction in effort is needed for removals to reach a level that is less than or equal to the 2025 allocation of 1.48 million pounds This concludes my proportion of the presentation, and I'm happy to answer questions.

Thank you, and Ms. Kimball has a question. Thank you. What, what a difficult analysis this was and, and not intuitive to me at all. So I, I just wanted to ask, like, how do I use this? The effort is obviously in angler days, and so is, is the take-home for me that you know, unless, for instance, in your last table we had a 50% reduction in angler days, we're not going to come close to being able to have 2 fish of any size with no additional harvest measures.

Or am I trying to translate, like, the reduction in that would be needed in angler days to the number of permits to see how many permits would need to be removed from the fishery in order to meet this? Just, I know this was tasked to you, it wasn't, be, you know, your choice on how to do this, but how do I— what is this helping me understand? Yeah, Miss Kimball, through the chair, I'll do my best to answer that to the best of my knowledge. Um, I, I believe the intent was to get a sense of, um, how achievable these more desirable management measures would be, and I think in, in part it would be the to get an idea of the additional RQE and the, and, you know, they use GAF currently, but like how much more fish they would need to buy basically to get there.

And then, yeah, as far as the permitting part of it goes, I'm not sure about that. Maybe Sarah can add something.

Through the Chair, yeah, I would say that this doesn't necessarily translate into permit restrictions, it just stops at angler days, reduction in angler days, and it doesn't say how that would be achieved. So it's just rolling it back with this specific, specific set of preferred measures, how much, how many angler days would need to be taken off the books. When we do management measures each year, we look at essentially different tools for reducing angler effort, and some of that is the things that that were not rolled back here, so day of the week closures would reduce angler effort. So the how is not part of this, part of the analysis, it's just showing how many angler, or reduction in effort, which could translate into angler days, but like if you were going to think about how that would happen, generally you would add back in the tools that we use for management measures like day of the week closures or some of the other measures, you know, going back to one fish of any size or things like that. So that is how we generally think about reducing effort each year when we look at management measures.

This is not going that far, it's just looking at how much effort would need to be reduced to get that preferred set of measures.

Thanks to both of you. I really commend you on, on this analysis. It's not any comment on how good it is. I think it's fantastic. I just, it's not what I'm used to seeing at all.

So I make sure I'm understanding it. Thank you.

So, Madam Chair, moving on to data request number 7. Number 6 and number 7 are both kind of like scenario building. These are, um, are sort of different ways to look at things. This request essentially says if the RQE held the maximum amount it can, so for Area 2C, that's 10% of the 2C quota share pool, and for Area 3A, that's 12% of the quota share pool, holding constant the most recent projected trends in average weight and harvest per unit effort and angler effort, what is the least restrictive management measures that we could have gotten to in that year? These cumulative transfer limits also include what can be transferred as guided angler fish, so I just wanted to note that here, but I'll discuss that further after we get through the, the results of these scenarios.

So the first part of this task is actually pretty simple, it's just converting the 10% and the 12% into pounds for the previous years to understand what the RQE could have potentially held. So Table 21 shows this for Area 2C, what would have been translated into annual pounds. So the second column shows what the actual charter allocation was from 2014 to 2026. The next column shows the ratio of quota share units to IFQ that's produced by NMFS every year based off of what the commercial allocation ends up being. And then we use that ratio to translate the 10% holding limit into the maximum that the RQE could have held.

And then so column 2 plus column 4 are added together to get your adjusted allocation, which is the maximum amount that the allocation could have been in those years. So for the time series, you can see for Area 2C, the highest allocation was in 2017 at 915,000 pounds. And adjusted with the maximum holdings, the adjusted allocation could have been up to 1.34 million pounds. The lowest allocation in 2C was this year, 2026, at 650,000 pounds, and adjusted with maximum holdings, the adjusted allocation could have been up to 932,000 pounds.

So in this exercise, we look at those adjusted allocations and use the latest ADF&G analysis So it's attached as Appendix 1, was done in December 2025 projecting to 2026, and we use that analysis to say if you had this higher adjusted allocation, where could you have gotten to on these management measure tables? I wanted to add a few caveats here because we've done this exercise before. We did it during the RQE development. These scenarios aren't a prediction of the future, nor are they really a retrospective evaluation throughout a time series. We're using the projections of harvest and effort for 2026 specifically and then applying different hypothetical allocations to it.

So in the future, there's a lot of factors that we're holding constant here that are expected to change, that will likely change. So in 2026, the Area 2 seed measures were 1 fish daily bag limit. You can retain 1 fish either 34 inches or under or over 80 inches or over. Thursday closures, June 18th through September 10th, that's 12 Thursdays closed. Using the reverse slot table from the appendix, which is reproduced as Table 22 in the paper, with the adjusted allocation from 2026, you can see the yellow highlighted cell in that table with 932,000 pounds.

Area 2C may have had a management scenario of 1 fish daily bag limit with a U38O76 and no day-of-the-week closures.

In June, at the June council meeting, there was some discussion about doing this task for more than just 1 year's allocation, so we did look at that whole set from Table 21 of adjusted allocations that could have occurred in the past and looked at what it could have been under a year with a higher allocation. So again, 2017 was the year with the highest allocation. If that allocation was applied to the projections from 2026, the management measures could have been 1 fish daily bag limit with a U50O74 and no day of the week closures. None of the adjusted allocations using the 2026 projections would have gotten Area 2C to a 1 fish daily bag limit with no size restrictions, but each of the scenarios could have relaxed management measures to some degree.

So we did this exercise for Area 3A as well. In the time series, you can see the highest allocation for Area 3A was in 2015, at £1.89 million and adjusted with maximum holdings, the adjusted allocation could have been up to £3.55 million. The lowest Area 3A allocation was in 2025 at approximately £1.48 million and adjusted with maximum holdings, it could have been up to £2.89 million.

So we ran the scenarios of what the 2026 management measures could have been with the adjusted allocation for Area 3A. So in 2026, the measures for 3A were a 2-fish daily bag limit with a U27 for 1 fish. Wednesdays were closed all year and 13 Tuesdays were closed. There was a 1-trip-per-permit-and-per-vessel day limit. The The—.

Looking at the Appendix 1 and the analysis of management options for 2026, it didn't cover a wide enough range for potential measures under that adjusted allocation. The least restrictive measures that were looked at in that year, which is reproduced in Table 25 in the paper, would have been a 2-fish daily bag limit with youth 32 for 1 fish, Wednesdays closed, and a trip limit for permits and vessels. But no day of the week closures. So that could have been achieved under the 2026 adjusted allocation or any of the allocations within the time series. To think about this a bit further, we also considered the management measure analysis for 2025, which it's, it's not attached, but one of the table, Table 26 is reproduced from that analysis.

It, it shows projected removals with no day of the week closures and up to a 32-inch second fish. So using those 2025 values projected for harvest and effort, adjusted allocations from nearly all the years with the exception of 2025 and 2026 could have achieved at least that set of measures. And Table 27— oops, Table 27 here on the screen shows substantial remaining allocations in most years at that measure. So perhaps measures could have been relaxed further from that.

All these scenarios assume an RQE is holding quota share all the way up to the cumulative limit.

And one other point that I want to highlight under data request number 7 is that, again, the cumulative transfer limit is shared between RQE and the guided angler fish provisions. GAF is a temporary transfer of commercial halibut IFQ that's leased by a charter halibut permit holder. It enables charter anglers the opportunity to retain a halibut up to the limit for unguided anglers when the charter management measures in place are more restrictive. The pounds leased translate into a number of fish that can be caught based on a conversion factor, so it allows an angler to catch a halibut on a day that would otherwise be closed to charter fishing, or in 2C, it allows them to retain a fish of any size Each year NIMS produces a GAF report, which includes the conversion factor. This table 28 is reproduced from the GAF report.

It shows IFQ translated and transferred and harvested as GAF each year.

GAF transfers have increased dramatically in Area 2C, with some increase from 2024 to 2025 in Area 3A as well. In 2025, approximately 260 5,000 pounds of halibut transferred as GAF in Area 2C. So thinking about the combined cumulative limit, this leaves approximately 43,000 pounds short of the limit.

In practice, the RQE, if the RQE purchases quota up to that amount, RQE holdings will dictate the available remainder for the, for able to be transferred as GAF. So we're highlighting that this could be a point of tension in the future for operators that have come to rely on GAF. In particular, if the RQE is not able to relax management measures enough to provide the kinds of opportunities that GAF has been providing, this could be a point of consideration.

Ms. Marinan, just quickly, can you remind me how that occurs in, in real time? Is it a kind of a first-come, first-served on a first-served basis, the accessibility of GAF as it's, as that pool is kind of shrinking as the RQE grows, or how is that determined? Madam Chair, yeah, so REM hasn't had to deal with this yet, so I'm not sure exactly how it would play out, but because the RQE holdings are a long-term transfer, they would be known what the RQE is holding, and so the remainder of the cumulative limit would be available annual transfers, leases of GAF from IFQ, and I'm assuming that RAM would probably process those, yeah, on a first-come, first-served basis. So at the point when the application was received, but I'm not sure if Doug has any other input. Yeah, okay, okay, we're seeing a thumbs up.

Yep, okay, thank you for that clarification. Yes, Ms. Kimball. Thank you. I had a similar question, but I still don't quite understand. Is— does that mean that there— is there a deadline by which you need to— RQEs need to purchase quota so that folks know what's remaining for potential GAF leases the rest of that year?

I can't remember if we put a deadline on when they can purchase for the— for the coming year. Um, through the chair, Ms. Kimball, there is a deadline that what is evaluated for the following year and what could be translated into additional allocation of management measures? I believe it's October 1st. By October 1st of the previous year. So for instance, this year the RQE has purchased an amount of quota in Area 2C, and it did prior to October 1st of this year, so that amount will be considered for the charter allocation when management measures are set.

If it purchased quota now or in November, that would not be considered until the next year. So it also wouldn't restrict GAF until the following year. Thank you. And, um, can you remind me also that there— so there's a limit when you talk about under this analysis, the management measures under full RQE transfer, and I keep thinking of that as, as 10 years. Because there's a limit on how much they can buy each year.

But I guess I wasn't factoring in the fact that the quota share pool can change so dramatically over time that it doesn't necessarily mean more quota. It means you can increase your percentage of the pool, but it doesn't necessarily translate to more pounds over time.

Through the chair, Ms. Kibble, that's correct. So the 10% is of the quota share pool. So 10—. It's a specific number of units that they can purchase, but the amount of pounds will vary over time.

Um, so that is the end of our staff presentation. Um, for next steps, the discussion paper again doesn't direct specific action, although next steps may be considered. Um, you can consider an expanded discussion paper or analysis if a purpose and needs statement and set of alternatives are able to be identified. And I definitely like to thank all the individuals that contributed to helping me with this discussion paper, and we're happy to take any further questions.

Thank you both. Any additional questions on the discussion paper at this point? Yes, Mr. Ritchie. Thank you, Madam Chair, and thank you for the presentation and all the work on all of these data requests. It was pretty extensive, so it's much appreciated.

My question is on the last slide, something I didn't see there. Maybe you got to it earlier, but I'm just wondering if you could describe the GAF leasing. It's been my understanding that once the RQ is implemented, then there was a 10% limit on the— or cap on pool that's combined between RQE and GAF, so effectively a 10% cap on GAF. Is, is that correct, or was it after the first quota share purchase by the RQE? I'm just a little bit confused on the process there and wondering if you could describe it.

Through the Chair, Mr. Ritchie, so when the RQE was implemented, those associated regulations included the cumulative limit for GAF and RQE, they— that cumulative limit applies even if the RQE doesn't purchase anything. So GAF transfers, total GAF transfers would be restricted up to that 10%.

Annual IFQ leasing would be restricted to that 10% even if the RQE didn't purchase anything in Area 2C.

Thank you, that's helpful.

Madam Chair, if there's no other questions, I have the committee report after this as well. Great. I think we're ready to move on. Thanks.

Okay, rolling right into the committee report. So the Charter Halibut Management Committee met virtually on September 30th in the morning. The committee report is attached to the e-agenda. I'm primarily going to present 3 motions that came out of the committee. And I'm just going to read through them.

So the Charter Halibut Committee reviewed the permit use and angler effort discussion paper that we just reviewed. After review of this paper, the committee recommended the following two motions. So the first motion is for an expanded discussion paper. So the Charter Halibut Management Committee requests the council task MPFMC staff with an expanded discussion paper of charter halibut management to compare the following dynamics of recreational and commercial fisheries: examination of the relationship between allocation and quality of fishing opportunity, including the effects of harvest restrictions, size limits, daily bag limits, annual limits, closed days, and season lengths; how each fishery responds to increases and decreases in allocation and abundance; Differences in how participants respond to increasingly restrictive regulations, including changes in effort, participation, trip demand, and substitution to other fisheries or activities. Differences in the ability of each sector to adapt and reduce allocation, including consolidation, efficiency, changes in effort, changes in revenue, and changes in customer demand.

The role of access and opportunity in generating recreational economic activities, the potential for regulatory restrictions to reduce economic activity and other tangible and intangible benefits even when the recreational fishery remains open, the importance of regulatory predictability and stability to businesses and participants, whether management systems based primarily on pounds of mortality adequately account for the different ways commercial and recreational fisheries produce benefits benefits from halibut resource. Identify the objectives and assumptions supporting the differential treatment of halibut anglers and the establishment of different management approaches and harvest regulations in MPFMC-managed waters. Where possible, evaluate whether those objectives and assumptions remain applicable under current conditions and underscore MSA principles. Explore the benefits of parity in recreational harvest across Alaska waters.

Additionally, the Charter Halibut Management Committee requests the council task MPFMC staff to include the following in an expanded discussion paper: GAF performance, examine GAF use over time, current industry reliance on the program, and evaluate whether current GAF program limits provide qualified charter halibut permit holders sufficient opportunity to offer guided anglers additional harvest opportunities. Assess whether potential expansion of the GAF program would advance or undermine the RQE's ability to provide shared recreational opportunity. RQE capacity and impacts on the commercial halibut fishery. Evaluate what changes to the RQE program would be required to acquire sufficient quota to support a daily bag limit of 1 halibut of any size with no day closures in Area 2C. Identify the additional quota needed under current conditions and program changes required, including cumulative holding limits, annual acquisition caps, and eligible quota categories.

Using available information, identify management options responsive to these findings. Identify essential data gaps, additional analytical requirements, and proposed schedule for Council consideration. A focused GAF performance assessment may return separately if it cannot be completed sooner.

And that motion passed unanimously among the committee members, and I can read some rationale points from the, from the report as well for that motion. So the committee members recognize that the motion is robust. However, they didn't want to miss an opportunity to highlight concerns within the sector and focus on some of the charter fishery nuances that are important to downstream impacts.

The members explained that there's a distinct difference between how recreational fishery halibut fishery and commercial halibut fisheries are affected by and respond to low and high halibut abundance scenarios. Members stated that in low abundance scenarios, they have an inferior product to offer, thus they have both decreased supply as well as decreased demand that price will not offset. Members highlight the importance of stability and predictability in the charter fishery. Because of these differences, they felt that the management approach employed through the catch sharing plan may not be appropriate for the recreational fishery, especially during periods of low abundance.

The motion asks for a review of the GAF program, and the rationale raised concerns about RQE capacity With the discussion paper demonstrating a best-case scenario of a 38-inch fish, and this would be phasing out all of gaff, members stated that such an outcome may not provide an attractive opportunity for recreational anglers or support the businesses that serve them. And I'll pause for any questions on the first motion.

Thank you. And Mr. Bowers. Thank you, Madam Chair. Thank you, Ms. Marinan. So my question is on the final bullet talking about the expanded discussion paper, explore the benefits of parity and recreational harvests across Alaska waters.

I'm curious about the use of the word benefits there. I mean, that almost implies that we know quite a bit about what parity would do. I mean, could you expand on maybe why that, that particular word was used there, or just some background behind that bullet? Thank you.

Um, through the Chair, I don't recall having a conversation about that specific language, but I, I do think that maybe that bullet and also the bullet related to, um, the differential treatment of halibut anglers, I think there was some discussion about about the unguided recreational sector and some of the differences between management structures and how that could have downstream impacts to the guided sector.

I think, yeah, that bullet, the language does sort of direct you in a certain way. We didn't have discussions about the specific language, but we did talk about some of the broader impacts of other sectors that might be highlighted in this paper should it move forward.

Thank you.

Thank you. And Ms. Kimball. Thank you. On the same bullet, if the— if this was tasked, the staff would be looking at—. At what?

They'd be looking at the unguided sector, the rental boat sector, and the charter sector and looking at benefits of parity across those 3 recreational sectors? Would that be the staff approach? Um, through the chair, Ms. Kimball, yes, I would suspect so. I will note that we didn't walk through each bullet and talk about how staff might address each one. I think there would be some outstanding questions about what type of information would be pulled in to achieve that, the intention of that bullet.

But I, I think you're right that it would be important based off of the language about recreational harvest. We would probably be looking at guided and unguided there.

Thank you. And Mr. C.

Thank you. I, I was just curious. I appreciate that the committee noted that this is a rather robust motion. Um, was there any conversation about prioritization of any of these particular elements of this motion, if there was a need to pare this down a little bit? Um, through the chair, there was some conversation, and, um, I will note too that Mr. Ritchie, as chair of the committee, can also speak to this because we did have some discussion about paring it down.

I don't think there was anything specifically highlighted as of lower importance. There were some things highlighted as higher importance. I think, you know, the bullet about predictability and stability was highlighted as an important aspect of consideration, and some members spoke to— spoke to the specific importance of predictability and stability. And I think another thing that was highlighted when that topic came up was just the general dynamics and nuances of the differences between commercial and recreational fisheries at times of low abundance, so price differences, adaptability differences, resilience of the fishery, ability to diversify, those things that are— this motion is sort of I think it was characterized as kind of 3 components, as the first being some of the dynamics between commercial and recreational fisheries and how they respond to extremes, low and high abundance, the second part being looking at GAF performance, and the third part being looking at RQ performance. And I think some of those points were highlighted, but happy if Mr. Ricci wants to add anything more to that discussion.

From that discussion.

Thank you. Um, being forward, I'd rather not. Um, I, I think that there was the discussion around this is that there, there was a lot of, um, obviously there's a lot of items and elements in, in this motion. Um, some of them may be more important to stakeholders and others. Um, and some, uh, some of these, it seemed— and I think this was brought up during the committee meeting— some of these are probably not able to be addressed through a discussion paper or maybe even an analysis.

Um, so there's— I think that for, for a motion like this to, to come back, I think that there needs to be a lot more discussion and, and, uh communication with staff before we see something like this again, just given that it may be difficult to analyze things that are both tangible and intangible, or things that are benefits or not. And I think that putting, putting an analyst in a place to make a subjective judgment about those things is, is something that I think the, the committee could could consider better before making motions like this in the future.

Thank you. I think we're ready to move on to the next motion.

Okay, Motion 2 is shorter. Um, so Motion 2 is the Charter Halibut Management Committee requests the council stay the GAF phase-out provision in the RQE with a 10-year sunset. GAF would become uncoupled from the RQE and not influence RQE caps. The committee also requests the council increase the annual transfer cap for the RQE to 2% in Area 2C.

So just some description and rationale from the, from the report. The motion recommends that GAF total transfer limit would be uncoupled from the RQE total transfer limit Currently, the cumulative limits restrict the combination of long-term RQE transfers and short-term lease transfers of GAF to 10% in 2C and 12% in Area 3A, essentially phasing out GAF if the RQE purchases up to the limit. I wanted to highlight that there was some confusion about how the limits would be decoupled. In the, in the meeting, I interpret this, and the way I wrote it in the report, is that the motion would separate the limit such that 10% of the commercial IFQ of the commercial IFQ in Area 2C could be leased in a season, and 10% of the commercial quota share could be transferred to the RQE in total. And for 3A, it would be 12% of the commercial IFQ could be leased, and 12% of the 3A commercial quota share could be transferred to the RQE in total.

My understanding after further conversations is it was the motion maker's intent that the— that this motion would take the GAF out of the cumulative limit, so GAF would not have a total transfer limit and the 10% would just apply to the RQE. Um, so I wanted to note that kind of point of distinction. The motion would generate a sunset date for the separation of these limits such that in 10 years the limits would again be cumulative. In practice, this means that if at the time the RQE held up to the cumulative cap, there would be no GAF lease transfers approved in that year. The committee is recommending these changes to the cumulative limits for both Area 2C and 3A.

And so just some points of rationale in support of this motion. The committee supported consideration of separating the limits as a measure to provide stability for the charter halibut sector. The committee noted that GAF transfers in 2C is already approaching the 10% combined limit due to increasingly restrictive management measures in this area. Members shared that charter operators and anglers have come to rely on gaff during these times of low abundance, and they expressed concern that harvest measures analyzed in the discussion paper under full RQE holdings show that the holdings may not be sufficient to stabilize businesses or meet angler demand. So increasing the cap would provide near-term flexibility, and the sunset provision would require the issue to be reconsidered in the future.

Some members felt that GAF shouldn't be viewed as a permanent solution for the charter sector. They expressed concern that long-term reliance on the quota leased from a competing sector could create uncertainty for charter businesses since availability of GAF can change based on conditions. This is a— they noted concern about reliance on GAF that could discourage RQE transfers Some members expressed concern around sunsetting GAF provisions, as some charter operators have purchased commercial quota shares so they can lease GAF to themselves. However, they felt a sunset provision may be considered at this stage. And then the motion also speaks to increasing the annual transfer limit for the RQE.

The committee noted the council previously considered annual transfer limits ranging from 0.5 to 5% but selected 1% in 2C. The committee stated that the 1% is expected to constrain the RQE's ability to purchase quota even when sufficient funds are available. So I'll pause for any questions on Motion 2.

Looks like we have a few. Ms. Kimball. My question was on— because I didn't hear whether there was any rationale to the amendment. To include Area 3A. I mean, my understanding was the RQE was intended— it was like the better option.

It was the intent is you purchase quota, it goes into the recreational sector, and it benefits everybody in that sector by changing the management measures to something less restrictive, as opposed to GAF, which is an individual operator or business helping, just trying to benefit their own business for that year. And so when I went through your analysis and was trying to ask questions, it looked like, it looked like the RQE was going to work for Area 3A. So is there rationale for including Area 3A in the first part of the motion?

Um, through the chair, yes, there was an amendment to expand it to looking at 3A in addition to 2C. I think there was some conversation. I don't think we had a lot of conversation. Like you said, I think it is a bit of a different story in 3A. In that they haven't used— there hasn't been as much GAAP leasing in 3A, and also the RQE looks like it has a higher total transfer limit already, and it looks like a bit of a different situation.

I think the rationale for including 3A at this stage was to the ability to consider it, that it can take a while for amendments to happen if if, um, this moves forward, perhaps the Area 3A operators would want to have that as an option for consideration in the future, but we didn't have extensive discussion.

Thank you. And Mr. Pamplin?

Thanks, Madam Chair. Um, would you mind just explaining the status quo of the 10-year sunset, and then also what this— you touched on it towards the end of your remarks, and then you jumped additional rationale, and I just didn't quite pick up what you were laying down. Thanks. Through the chair, currently there is no sunset provision. There is— so there's a cumulative limit between how much long-term quota can be purchased through the RQE, and that, that 10% for Area 2C, that 10% is shared with how much GAF can be transferred.

So in a way, it— the RQE purchases could phase out what is available for GAF. So that exists, but there isn't currently a sunset provision that would remove any of that. It's— there's just a cumulative limit on both. Does that answer your question? It does partially, thank you.

And just to follow up then, so then what is the 10-year sunset that's proposed on the screen? Yeah, through the chair. So my understanding of what was proposed here, um, just based off of what was stated and what I understand about sunset provisions, um, with that 10-year sunset provision being put in, my understanding of the intention was that, um, the combined limits would change under an action that moves forward, and that after 10 years, whatever that change that was made, that would, um, the, um, so the cum— if it was a change to the cumulative limits, they would go back to status quo after 10 years. What was spoken to at the meeting also is that there would be an opportunity to review it before a sunset comes in and changes things. But the way that I read the motion, um, in 10 years, the limit again would be cumulative.

So if there was some kind of decoupling where GAF was either not part of the total limit or it had its own separate limit, after 10 years they would come back together as cumulative. So if the RQE had purchased up to 10% in Erie 2C at that time, in 10 years there would be no more GAF transfers approved. Um, that's my understanding of the 10-year sunset and how that would apply.

Are there any other questions? No. Um, Mr. C. Thanks, um, for— I appreciate the conversation on, on GAF and this uncoupling, uh, element. And I'm just curious, so under this motion then, if GAF is uncoupled, is there to be a consideration of whether there's a limit on the GAF transfers, or is or is— would it be assumed that uncoupling of GAF would result in no limit on the number of transfers on GAF?

Um, through the Chair, my understanding from the meeting and what the motion stated was that with the uncoupling of GAF, GAF would have its own 10% limit and RQE would have its own 10% limit. I think some other members understood it that way. It's my understanding after further conversations that the maker of the motion actually intended with the amendment that said total GAAP transfer— total GAAP capped 10%— in that amendment, the intention was to not have any total transfer restriction on GAAP. So I've kind of presented both of the nuances here in the minutes. My understanding in the meeting was that GAAP would be capped at 10% or QE would be capped at 10%.

It, um, but I'm highlighting that there may have been different interpretations when the motion was passed. Thank you.

Yes, Mr. Ritchie. Thank you. And thank you. I want just one last question. So yeah, it was my understanding during the minutes and— or during the, the meeting, and maybe yours as well, that, uh, without a cumulative limit of 10%, so there would be no cap on the overall amount of gaff, but there would still be the CHP limits of 400 guided anglerfish per permit.

Um, through the chair, yes. So, uh, my understanding of the motion that was made and based on the discussion is there, under status quo, there's also GAF transfer restrictions for how much IFQ can be leased from an individual and how much GAF can be transferred to a CHP holder. So there's individual limits on both sides, and this motion wouldn't change that. There was no discussion about changing those status quo regulations, so my understanding is those would continue to exist under what was put forward here.

Thank you, Miss Marin. And just one last question, just going back to the 10-year sunset. Was there—. And looking at that in the context of the second part of the motion, which is kind of, um, expediting the annual RQE transfers for 2C— where was that— the length of the sunset ever discussed in the context of an expedited RQE transfer allowance as well. So I mean, if we did a simple math, if, if 2% was transferred, we know that that didn't happen in the first year, but theoretically, if we see some opportunity to transfer up to 2% a year, that would be, it would be reasonable to maybe look at a 5-year sunset instead of a 10-year.

Is there something specific about the, or I guess, were those two things discussed in combination from your recollection? Recollection? Madam Chair, we didn't discuss that, no.

Thank you. Okay, there's one more motion here from the committee.

This motion from the Charter Committee came up under other business. So the Charter Halibut Management Committee recommends the council initiate a sector-neutral review of charter halibut mortality in Gulf of Alaska, including trawl PSE, fixed gear and directed commercial discard mortality, and charter release mortality. The review should evaluate whether current PSE ceilings, discard management measures, minimum size requirements, and charter release management measures remain appropriately calibrated to current stock conditions, actual mortality, and demonstrate fishery performance and should identify practicable opportunities to reduce avoidable, halibut mortality without unnecessarily constraining viable fisheries. The analysis should also consider the age and size composition of mortality, recognizing that the biological effects of halibut mortality may differ among sectors and is not necessarily equivalent on a pound-for-pound basis. Where relevant, measures fall principally within IPHC authority include the commercial minimum size— including the commercial minimum size limit, the Council should coordinate with or and request appropriate analysis from IPHC.

And some of the rationale points for this motion: the committee supported consideration of a review of Pacific halibut mortality across all sectors in the Gulf of Alaska. The review could evaluate opportunities to reduce avoidable halibut mortality while maintaining reasonable fishing opportunities across sectors.

Committee members noted it's important to assess whether existing mortality limits, as well as commercial and charter management measures, remain appropriate under current stock conditions, and they noted some of the scope may fall outside of its direct authority, so they support forwarding the concept to the council with IPHC consultation.

And I'll pause for any questions on Motion 3. Thank you, Ms. Marinan. Are there any questions? Yes, Mr. Pamplin. Uh, thanks, Madam Chair.

Thanks, Mr. Marinan. Um, in the first paragraph, in the list of different sectors to be reviewed, I'm not seeing just the recreational, and I'd imagine that's a different data set or, or maybe different comp— comparability in terms of the, the type and amount of data that would be available, but I still think it would be part of a comprehensive review and just was wondering why the committee didn't include recreational. Thanks. Through the chair, um, we didn't have an extensive discussion around this motion, but I do think it was the motion maker's intent to include all sources of halibut mortality. So I think that was intended to be part of it.

Okay, um.

So that was the 3 motions from the Charter Committee. I just wanted to highlight our next Charter Halibut Management Committee is October 21st, online. This is our annual meeting. We will have a review of final 2025 charter removals and preliminary 2026 charter harvest. This is a meeting where members request analysis of management measures to be evaluated for 2027. and I expect we'll also save some space on the agenda to discuss the RQE charter halibut stamps.

And I wanted to highlight that we are— one of our Area 2C members has stepped down, so we'll be soliciting nominations for an Area 2C charter committee member. And that's the meeting report, and I just want to turn over to Mr. Ritchie to see if he had anything else to add from the charter committee meeting.

Um, thank you, Miss Marin. Um, I don't— I just would point out that this was 3 motions in a 4-hour meeting. That's almost, uh, 1 motion an hour, and I think the next meeting is scheduled to be longer, so I'm hoping that we don't, um, we don't repeat that. Uh, that's all, but thank you for the report.

Yes, Miss Kimball. I have a question, and I, I don't mean this to sound mean, but does the Charter Committee review its terms of reference prior to meeting? Um, through the chair, uh, we have recently— staff and the chair have recently reviewed our terms of reference and I think updated it, but we don't read through our terms of reference at each meeting. I'm not familiar with that in other committees as well. It was just popped up when I saw the 3 motions that, um, might be better practice for all of our committees.

But thanks.

Thank you, Ms. Baker. Thank you, Madam Chair. Thank you, Ms. Kimball. I was weighing whether to kind of broach this topic either, and, and I guess same question, Ms. Marinan, related— similar question relating to the posted agenda. For these meetings.

I think, um, honestly, I wasn't aware there was an other business, uh, portion in the agenda for this particular committee. And so just following up on that, I, I'm not sure if that's common practice for our other committees, but, um, so for this particular— the next Charter Halibut Management Committee meeting, Madam Chair, my apologies, this is my question, um, is it limited to these items or is or is— are there going to be other opportunities for the committee to discuss other topics?

Through the chair, we often include other business as agenda item in our committee meetings. We have to put out the agenda quite a bit ahead of time now with the new Federal Register notices, so we try to solidify the main topics we're going to discuss, and usually we build the timeframe around those topics. Topic, so other business might not get as much time allocated to it. But because of when we have to submit the Federal Register notice for the meetings, I think that's for the committee meetings that I've been part of, that standard practice to have another business. It—.

For the charter committee meeting, we usually highlight other meetings that are happening or other topics of relevance. I don't know if Ms. Evans has any other content text. Through the Chair, um, Ms. Baker, yes, that is our standard practice for the reasons that Ms. Marinan identified. Um, I think it's, it's, uh, the point that she made is important, that we try to build the agenda to the extent that we can. We routinely share the major topics of the agenda at the council meeting before so that you are aware of what those committees are taking up, and that, that obviously falls in your purview for what you are tasking the committees to work on.

We have always taken the approach that they are committees that are providing expertise to you, so that we try not to constrain what the committees talk about, but we do try to focus their time on the issues that you think are relevant and important. And that's, as you said, how we structure the agenda and how we structure the proportion of time spent on different issues. Thank you.

Thank you. Any, any other questions? Thank you both for the presentation and the report. We appreciate it.

So let's break for lunch and come back at 1:10. Um, I think the AP report will be— if it's not posted already, it will be posted shortly. So please review that over lunch, and we'll come back and take up our AP report. Starts at 1:10, um, and then we will go right into public testimony after that. Thank you.

Welcome back, everyone. So we are beginning our afternoon with our AP report on D1. Um, I'd ask any members of the public, uh, wishing to testify on D1 to please sign up before the end of this report. Um, we, uh, I think it might be a little too early to tell whether or not we're going to start on D3 this afternoon. Um, we do have an executive session planned for 4.

We may start that a little bit early, um, and pick up D3 in the morning, but I will, um, we'll track public testimony before we take action. I'll I will make an announcement on that, but certainly I think it's probably safe to say we will begin staff tasking tomorrow for any members of the public wanting to track our staff tasking discussion. So, Ms. Mann.

Uh, good afternoon, Madam Chair, council members. For the record, my name is Heather Mann. I am one of the vice chairs members on the advisory panel, and I'll be providing one motion on D1. The motion reads: The advisory panel recommends that the Council initiate an analysis to explore the potential effects of eliminating or modifying the cap for guided angler fish, also known as GAF, described under 300— regulations 300.65.

In IPH Areas 2C and 3A, either permanently or for a set duration. Analysis should also include a section exploring the possibility of NIMPS changing the annual transfer cap of IFQ to the RQE described at 679.42 from 1% to 2%. That, uh, you can see that there was an amendment that failed, and then the main motion passed 14 to 4. and there's rationale included in support and in opposition to that main motion, and I'd be happy to try and answer any questions.

Thank you for the motion. Are there any questions on the AP report?

Yes, Mr. Ritchie. Thank you, Madam Chair. Thank you, uh, thank you for the report. Um, I'm just wondering if you could— you mentioned that there was an amendment that failed, and I wondered if you could walk us through what that amendment was.

Uh, through the chair, Mr. Ritchie, sure. The amendment was to strike the first part of the motion and only focus on increasing the annual transfer cap from 1 to 2%. And You know, basically the maker of the amendment felt that, um, there was, there was support for the second part of the motion from the commercial fleet, but not for the first part due to, um, sort of unlimited potential transfers that are basically, um, in their opinion, uh, reopening the catch sharing plan.

Okay, thank you.

Yes, Miss Kimball. Thank you, thank you, Miss Mann. On the first part of the motion, do I assume that the advisory panel is just following suit with the charter committee motion to include both Area 2C and 3A, um, or did you have a lot of discussion about including 3A when the, the data really looked very differently for those two areas? Through the chair, Ms. Kimball, that's correct. The data— we agreed that the data was very different, the needs were very different, the circumstances were different.

However, it was picking up on that part of the Charter Halibut Committee's discussion.

Thank you. Any further questions on the AP report?

Thank you, Miss Min.

So that'll take us to public testimony on D1. I'm going to refresh my screen here.

It looks like we have 11 people signed up to testify.

So we will begin with James Kearns, followed by Lauren Howard.

Okay, we will circle back to James. Lauren Howard followed by Norm Pillon.

Yeah, do you have me? Yes, good afternoon. You're a little faint. Okay, I will try to speak up if that helps. Yep, that's better.

Thank you. Okay, great.

Is it possible to see the clock on the Zoom so I can make sure I stay within my time, or? Yes, we'll put that on. Great. Okay, thanks.

Good afternoon, members of the council, and thank you for the opportunity to comment on this issue. The RQE was developed as a solution to the last reallocation issue that came up between the commercial and charter halibut sector. It was analyzed and put into law, and the overall cap on the reallocation was 10%. Met. This included the phase-out of GAF as RQE purchased IFQ.

2026 Was the first year the solution went into effect. They raised money and they purchased quota. Though the effects are not great or immediate, you could consider the program a success by those metrics. At this time, GAF can still be utilized as it is transitioned out and the RQE continues to grow in its allocation. Give the RQE time to do what it intended to do.

The idea of extending GAF, especially at an unlimited amount, is contrary to the design of the RQE. This is reopening up the reallocation discussion within the catch share plan, and as many of you know, that was not a very amicable discussion. What also needs to be brought front and center in this conversation is the historically low abundance of halibut and how that is affecting the charter sector as well as all other halibut users. Aside from very low abundance, there's a much larger underlying issue in charter and commercial halibut allocation through the growth of the unguided rental boat sector. I can't stress enough the frustration we as commercial fishermen feel that the Council is considering action to extend GAF when no action has been taken to measure or manage the increased unguided rental boat take of halibut.

In 2026, both charter and commercial halibut harvesters in 2C took a 10% reduction in allocation due to a very large increase in the recreational take of halibut. The business model that markets trips for unguided rental boats promises anglers a much larger bag limit, 2 fish of any size, and ironically, the growth in that sector is largely driven by lodge operators and other independent charter operators. It's almost like there's a hole in the bucket. They're taking allocation from themselves and then coming back to the council and asking for more. More.

I personally have been working on this issue, including sitting on a task force with legislators, but to date nothing has been done. So I highly encourage the council to find a way to work with the other agencies to both monitor and then manage the growth of the unguided sector before even considering other options for reallocation. If unguided had a set of checks and balances that kept it from growing unchecked, and continue to erode the allocation of both the commercial and the charter sector, I'd be very open to discussing an extension of GAAP transfer. But at this time, it makes no sense to consider other allocation options when there is a continued erosion of that allocation from another source that has little to no accountability or management at this time. Thank you for the opportunity to comment.

Thank you very much for your testimony. We'll see if there are any questions. Yes, Miss Kimball. Thank you for the testimony. I just wanted to clarify, when you're referencing the unguided sector, are you referencing the unguided recreational sector in total or just the rental boat business that we've been trying to get our hands around?

Yeah, thanks for the question, Miss Kimball. Um, so at this time, there is no mechanism to separate the two. Um, so it is the entire recreational sector, which is considered unguided, but there has been a lot of, you know, testimony, conversation, and I know it's mostly anecdotal evidence of the growth in that sector, including CEGO testifying to it, saying that they're representing those operators at this time and they're working with them. So I'm referencing both because they're lumped into the same allocation, but primarily focus on action that could be taken to monitor and manage the unguided rental boat sector. Thank you.

Any further questions? Yes, Mr. Ricci. Thank you, Madam Chair. Thank you, Ms. Howard, for your testimony.

You mentioned concerns on the part of commercial stakeholders that this, this would be a reallocation. Prior to RQE implementation, there was, from my point of view, a much more liberal GAF cap, it being 400 guided anglerfish per vessel. And I don't— the data doesn't support that we saw a large compensated reallocation into this sector. I think the most we've seen, if I remember right, is 9.1%. Um, so I'm wondering if you could help me understand what you think has changed now.

Well, I think the biggest thing that has changed is abundance. You know, everyone's taken really big decreases, um, because of the resource being in such low abundance. So I understand the distress of 2C. Um, you know, I live in this area. There are a lot of my friends and peers.

But what I think feels a little bit insincere is the lack of that being forward in the conversation, in that abundance is the driving factor for a lot of those decreases.

Thank you. That's, that's helpful.

Thank you. Not seeing any further questions. Thank you, Ms. Howard. Thank you.

Norm Pillon is up next, followed by Woody Sire.

Good afternoon, Madam Chair and members of the Council. I'm Norm Pillon. I'm president of Seafood Producers Cooperative here in Sitka. Thank you for the opportunity to comment. With over 360 members, their crews, our processing operation, our coastal communities, we greatly depend on stable access to a well-managed commercial halibut fishery.

SPC opposes transferring an additional halibut quota from the commercial fishery to the charter sector beyond what was identified and agreed to under the catch sharing plan and RQE. The existing catch sharing plan already divides the resource, adjusts allocations with abundance, and provides a market-based path for charter operators seeking additional access. That path is a one-way door providing opportunity for the charter fleet that is not available to the commercial fleet. Our primary concerns: commercial fishermen have invested in quota, vessels, gear, crew, and businesses based on an established allocation framework. Removing more pounds from the commercial pool reduces earning capacity and weakens confidence in the IFQ program.

Growth in one sector should not destabilize another sector. Our co-op is highly dependent on receiving pounds of halibut. If quota transfers to charter, that poundage is not available to our plant. It is also not available to our customers, the public who access this resource through commercial fishermen. Commercial halibut supports crew income, processing, vessel maintenance, fuel, freight, local businesses, and municipal revenues.

A quota transfer affects far more than the quota holders. It affects working fishermen, processors, service providers, families, and opportunities for the next generation in Southeast Alaska. Before providing additional charter access, the Council should fully account for guided, assisted, unguided, unguided, bareboat, and other recreational removals. Reallocating commercial pounds would not resolve gaps in monitoring and accountability, would simply shift the cost to the commercial fleet. We are particularly concerned about growth in the bareboat charter operations.

When a vessel is rented or packaged with fishing-related services but classified as unguided, the practical distinction may be unclear. This can place fishing activity outside the monitoring and accountability measures apply to guided charters. The Council should understand and control the size and growth of this fleet, the services being provided, its catches, reporting requirements, and enforcement challenges before considering any further transfer of commercial quota. SPC is also concerned about continuing the Guided Angler Fisher, GAF, program while allowing the recreational quota entity to become a lot— to acquire a larger share of commercial quota. GAF was intended to phase out as RQE 3B came in to ensure not more than cumulative 10% in 2C and 12 and 3A can transfer away from the commercial sector.

Any more than that is a permanent erosion of the commercial base. Reallocation does not create more halibut, it only changes who bears the reduction and conservation burden. When abundance is constrained, each sector must operate within accountable limits. Any change will be based on the available science and support long-term conservation of the resource.

In closing, SBC recognizes the charter's importance to Alaska visitor economy. Our concern is not the legitimacy of that sector, it is requiring commercial fishermen and communities to pay for its expansion. The CSP is conservation-based and respectful of investments made by all sectors. Reopening the allocation battle will rip that Band-Aid off a lot and a lot, awful lot of slow-healing wounds. Respectfully ask the Council to preserve the current allocation framework, address bareboat accountability gaps, and avoid imposing further losses on the commercial fishery and the communities it supports.

Thank you for your time. Thank you for your testimony, Mr. Pillon. Yes, we have a question. Mr. Ritchie. Thank you, Madam Chair.

Thank you, Mr. Pillon. Uh, it's good to hear you today. I understand you mentioned that you have 360 members in your seafood co-op and that they rely on access. GAAF is a, as you know, it's a leasing program between a willing leaser and a willing lessee. I'm just wondering if any of your co-op members currently lease IFQ through the GAAF program to guided recreational stakeholders.

Is that something that you have information on? I do believe that that happens with some of our folks that don't have enough quota to maybe justify taking their own vessel out.

I do know that, I believe that it does happen. I think it's pretty limited basis, but I believe it does happen, yes.

Okay, thank you.

Thank you for your testimony.

Woody Sear is next, followed by Nels Evans.

Oh, can you hear me all right? Yes, we can. Good afternoon. Hi there. Yeah, my name's Woody Sear.

I live in Sitka, Alaska. I'm a commercial fisherman. I've got about 8,000 pounds of halibut quota now. It was 10 not too long ago. And yeah, I'm also a co-op member.

Of SPC. So yeah, um, you know, it seems egregious that we're talking about extending GAF when we're supposed to be phasing it out after this catch share plan's been made. And we've got these bareboat rentals who basically are just a different arm of the charter industry who are taking quota out of me. I mean, I got cut again this last year in 2C and like they didn't get caught, they just took the fish from me. And the people who are operating these bareboat rentals are either directly related or the same people who are chartering.

So it's like just another way to take quota out of my pocket. I mean, it's ridiculous. So to ask to extend the gaff program as well as do the RQE when we've already said RQE is fine if we phase out gaff, like, that's, that's ridiculous. I'm sorry. I personally have gaffed as much fish as I can in one season to two of my charter friends.

I had a medical issue and I wasn't sure how much fish I would be able to catch, and I could make it easier to catch what I needed to catch by gaffing that fish out. Made short— made it so I didn't need as many trips if the fishing was scratchy or whatever. Anyways, that worked great for me. It worked good for my friends. We didn't use brokers.

It was very nice. I think that gaff has been, and I have other friends who gaff some of their fish as well for different reasons. I think that if we, if that had, if we had agreed to both gaff and RQE at the same time already, that's a different story. We hadn't done that. What we agreed to is gaff and transition to RQE, so like more reallocation stuff.

Like, it's— yeah, it's ridiculous. I'm sorry. Um, yeah, I think that's basically what I've got to say at this point. I'm happy to try and answer any questions.

Thank you, Mr. Seer. Appreciate your testimony. Um, I have a question for you. You did mention Yeah, you did mention your participation in GAF and how it did work out for you. I'm not sure if you followed the AP report or discussion, but there's some language in there about potentially a limited duration and more of a, maybe a soft landing for the transition of GAF and RQE.

Is that, I mean, I think you stated your position very carefully about the original intent, But, um, do you see any merit in a limited time period considering the, the increased growth and utilization of Gaff and in Tucson in particular? No, because we already agreed to a plan and you give an inch and you take a mile. That's all I've seen from them. That's it. No, thank you for that clarification.

Appreciate it.

I'm not seeing any other questions. Thank you. You're welcome. So, Nels Evans is up next, followed by Craig Evans.

Yeah, hi, Madam Chair, members of the council. Can you hear me?

Yes, we can hear you. Awesome. Oh, my name is Nels Evans. I'm Executive Director of Petersburg Vessel Owners Association, or PVOA. PVOA is a commercial fishing trade association based out of Petersburg, Alaska.

PVOA represents commercial fishermen that participate in a broad array of fisheries of almost all gear types in both state and federal fisheries of Alaska, with the largest contingent participating in the halibut and sablefish IFQ fisheries. Petersburg also has one of the highest 2C quota holdings by any community in, in the state, so any reallocation of halibut away from the IFQ sector will directly impact fishermen and the town of Petersburg negatively. Petersburg does not believe that the information provided in the discussion paper warrants any further action on requests #6 or #7. All commercial directed users, IFQ, and charter sectors of the halibut fishery are feeling the limitations of the current spawning stock biomass. To analyze issues in use and allocation without strongly addressing the weight of the current SSB does not truly get to the root of the issue in in our opinion.

The analysis also does not address the growth in the assisted unguided sector. Largely, this sector still only participates in Area 2C. We don't see as much of it in 3A, which operates as a direct competitor to the charter sector due to its relaxed harvest rules in comparison to the guided sector. It also provides a DIY nature of experience. PVOA is acutely aware of the current current, that there is currently no way for the assisted unguided harvest to be parsed out of general sportfish harvest and no way to provide additional management parameters.

We believe that this needs to be addressed before any further reallocation action is pursued. Both the IFQ and the charter sector saw a decrease in their total allowable catch due to a pretty significant increase in the unguided take last year. PVOA has concerns with Motion 2 from the Charter Halibut Committee and the direction it ultimately went in informing the motion that came out of the AP. The GAF program has been used as a means of a one-way allocation transfer from the IFQ fishery to the charter sector and is originally intended to phase out as the RQE is phased in due to the total 10% allocation in 2C 12% in 3A. For every pound of RQE purchased, a pound of GAF cannot be leased.

Pretty, pretty straightforward there. We're very concerned with the idea of decoupling the RQE and the GAF, particularly with no cap and an extension into perpetuity.

This would, in a best-case scenario, double— best-case scenario seen by the commercial sector would be a cap put in place, ultimately doubling the amount of IFQs that could move into the charter sector.

We see this again as just continuing the precedent of one-way reallocation of IFQ fish into the charter sector without any considerations of mechanisms to return IFQs back. We see that this just continues trends and encourages the continue to ask for IFQ fish to move out of our sectors into others.

While we do not support moving, moving forward, we understand that, that actions do move forward. If there is to be further discussion papers or analysis on the RQE and GAF programs, PVOA strongly encourages the incorporation of biomass trends of Pacific halibut and the competitive interplay between the assisted unguided sector and the charter sector in 2C and 3A separately to be incorporated into any further documents. The impacts on the IFQ sector through any increased reallocation of fish should be also— should also be incorporated into any further document on the issue. The additional potential halibut that would be included in any gap in RQED coupling would not come out of thin air, but would come from direct ownership of IFQ pounds, and those allocative impacts need to be fully understood. Sunset.

If the Council chooses to take action furthering for another discussion paper or analysis, we encourage a sunset provision to be the only option provided for any GAF extension explored. In closing, PVOA would like to reiterate that we believe the current state of the spawning stock biomass and growth of the assisted unguided chart— unguided sector, not allocation, are the drivers of the issues that are facing the sector. To continue trends in reallocation from the IFQ sector to the charter sector will do nothing but destabilize and degrade businesses in an attempt to prop up others. Thank you for your time and consideration on these issues. Thank you very much for your testimony, Mr. Evans.

Mr. Muller has a question. Yeah, thank you, Madam Chair. Thank you, Mr. Evans, for your testimony. In your comments, you reference a term I'm not familiar with, assisted unguided sector. Would that—.

My assumption is you're referring to the rental boats, is that correct? Yeah, that's correct. And in reference to what we see down on the docks, that we feel that there's more assistance than just a bareboat operation going on and trying to address it to more of what we see in practicality.

Thank you. Mr. Ritchie has a question. Thank you, Madam Chair. Thank you, Nils, for your testimony today. Um, you mentioned, uh, that you would, you would rather not have, and your membership would rather not consider, um, increases in the GAF pool that would be in effect in perpetuity, which implies that you would in favor of something that had a sunset if anything had to happen.

I'm wondering if you have given any thought to what that sunset period might be or what kind of range would be appropriate to look at? Yeah, through the chair, thanks for the question, Mr. Ritchie. I've given thought just to 10 years seems to be appropriate with RQE implementation, the original kind structure was for the RQE to be fully realized, actualized in a 10-year framework. So I think sticking with that, that same 10-year timeline would be most appropriate if it were to be analyzed.

Thank you.

Thank you very much for your testimony.

Okay, we'll go to Craig Evans next, followed by Jeff Farver.

Good afternoon, Madam Chair, council members. My name is Craig Evans. I'm a commercial halibut fisherman based out of Petersburg. I disagree with the decoupling of the GAF from the RQE program. Halibut is a fully utilized resource and the commercial sector is entirely dependent on our IFQ allocation.

Right now we're at historic lows in halibut biomass but we're also at a historic high of lodge growth through the unguided sport loophole. Please don't consider further allocation of the halibut resource away from established commercial fishing sector and the established processing sector, especially in this time of low abundance before any guardrails are put in place to control the unguided sport sector. After that. Thank you.

Thank you very much for your testimony. Not seeing any questions, appreciate your time.

So Jeff Barber is up next, followed by Forrest Braden.

Hi, good afternoon. 1, 2, 1, 2, Sound check. Yes, good afternoon. Great, thank you, Miss Chairwoman and council members. Good morning, Commissioners.

Thank you for this opportunity to testify. My name is Jeff Farber. I am a commercial fisherman residing year-round in Sitka. I'm here to testify on agenda item D1, and first I'd like to thank the staff for the analysis. It was very informative and again highlights how the allowance of extremely liberal leasing of CHPs exacerbates issues within the charter sector.

But rather than speak to individual components on this agenda item, I'll just say that if a potential action is truly benign to the commercial sector, then that's fine, but I can't support any actions that would further diminish our commercial halibut fishery. For context, there are several advantages that the guided sector has over the commercial sector to increase charter allocation and allocation. Those include: one, 1, under low halibut abundance like we are now, the guided sector's allocation is increased percentage-wise over the commercial allocation. 2, The guided sector can tap commercial allocation under the GAF program, whose management is solely paid by the commercial sector, while the inverse is not true. And 3, the RQE program allows charter sector to tap even more commercial allocation Well, again, we can't tap theirs unless it's our QE fish.

So this illustrates while these two broke— two of these programs are willing buyer, willing seller arrangements, all of them lack reciprocity for the commercial sector. That's a continued destabilization of the commercial sector. I will add that like myself, most of the IFQ holders are second-generation fishermen meaning they have bought and are buying all their quota. In Area 2C where I live, almost all that commercial quota, IFQ, is held by residents of our region. There are a couple things the charter sector can do to be proactive in cleaning their own house that would help considerably.

Those would include address its overcapitalization, address the fairly unrestricted CHP leasing, and address the continued expansion of unguided boat rentals. In closing, I'll add that as you well know, quotas are low for several species at both commercial guided and unguided target. I believe we should be looking at promoting measures that foster responsibility and prevent further instability to sectors and we— to our sector, and we need your help to do it. Thank you. Thank you very much for your testimony, Mr. Farver.

I'll see if there are any questions.

Yes, Miss Kimball. Thank you, Mr. Farber. I just had a quick question on, like, what are you seeing in terms of commercial halibut IQ holders in your area? Are they still buying quota at this time, or is there still folks looking for a market for small blocks? Like, what is the trend there on the commercial side?

Yep, thanks for the question. That, uh, a really interesting piece of this because the program is so big and so old. There's been, you know, a lot of regulatory changes and things that try to promote that exact kind of thing for, especially for new entrants in the 2C sector. But it's, it's pretty dynamic, Ms. Kimball. It, it really kind of changes with the price of the quota and the availability of quota, and I cannot honestly get my head wrapped around on after all the years of being on the AP myself and the IFQ committee of what really, really drives that.

But I will say that quotas are low right now. Prices are high at the dock, but just 2 years ago, prices or the quotas were almost the same at the same amount, but they were— we got about 40% less at the dock. So at that time, you know, the price seemed low, so So people weren't buying as much quota. So I'd love to give you a better answer, but I'd probably have to really dig into there. But I know it's desirable.

People want it. As far as buying it, if there's additional risk, including reallocations and things like that, it definitely disincentivizes new entrants from getting into the program. Thank you. Thank you.

Thank you for your testimony, Mr. Farver. So, Forrest Braden is up next, followed by Kim Landine.

Good afternoon, members of the council. Madam Chair, appreciate the opportunity to be up here in front of you. Had a chance to speak to most of you, but publicly we'd like to address a few things. Oh, um, Forrest Braden testifying for Recreational Quota. Entity, or RQE Alaska, that, um, is the nonprofit that directs that at this point.

Uh, I will save time at the end if I have it to, um, speak to, um, the discussion paper. Um, maybe I'll say briefly that, uh, to maybe to dispel some misinformation or misunderstanding, um, that I think, uh, most importantly what the report brings out, the analysis brings out, is there's really no drastic change in the charter harvest— not the charter harvest, the angler days and CHP trips. There's tables in there that shows you that. There's tables in there that shows you that leasing has constricted from 25% down to 12%. So I don't think leasing is an issue, like increased effort.

So I don't think we're looking at like increased effort in the charter industry through leasing provisions or gas GAF, or sorry, CHP juggling. I was surprised to see that actually, um, but that's, that's a good outcome— or not a good outcome, but a good piece of data, good metric to look at. So I want to save most of my time for talking about GAF and the request that the motions have made through the Charter Habitat Management Committee and the AP. I will say that, um, as director of the RQE, we know— we— what we don't know is what will be available on the market when the RQE actually in earnest starts buying fish when the revenue, stamp revenue comes around in 2027 and is released through the grant process through NIMPS. So that's an unknown.

What we do know is that 31% artificially caps what the revenue shows that we can purchase in a year. And we need, especially in 2C, that's specific to 2C, we don't have enough revenue in 3A stamps to purchase all they're able to move in a year. But 2C is probably the more critical of the two fleets right now in terms of harvest measures and regulations. And so I know that the impetus for asking for that is that it was still conservative in terms of what the council originally analyzed with RQE. They, they analyzed up to 5%.

2% Would still be conservative, but it would go a long way to maybe liberalize the ability of the RQE to move fish quickly into Area 2C to solve some of these harvest measure issues.

So moving on to why this is all coming before you, we hear a lot about low abundance and tightening belts and everybody's suffering. I think the reason why this is so urgent is because, and I don't know if this means anything to everybody here, but a 34-inch fish as a maximum size limit, one a day, is a completely unappealing regulation for a sport fishery, completely unappealing. The reason why GAF increases— GAF transfers have increased to almost the 10% cap, or at 90% of our 10% cumulative cap, is because businesses have had to rely on GAF just to keep customers interested in coming to Area 2C. People, we don't sell pounds, we sell opportunity. I know that's sort of a tagline, but it's really true.

You know, when I go fishing, I'm— I think the reason why you get so much money per pound of resource is because it's not just the pounds that you're selling. You're selling the experience of pulling on your own fish, harvesting your own fish. In the case of halibut catching, having the opportunity to catch that big halibut of a lifetime that people come to Alaska for. And when you're down to a 34-inch regulation, you actually don't get pounds, you don't get that experience. There's just nothing left.

A 34-inch fish doesn't even fight There's just nothing there to sell. And so I would liken that for those folks who are considering commercial, I would liken that to you're down to about zero pounds, you have no product to put on the market. So I think that's why we're here. That's why it's so urgent. I'd like to speak to the GAF program.

Mr. Ricci already spoke to it, but the original GAF transfer allowances were governed by constraints on block sizes and amount of pounds that could transfer and the number of fish that could be put on a CHP. The analysis in the RIR for the RQE shows that that amounted to roughly, and it changes by year, 49%. So this Council already passed the ability for 49% of commercial fish to move to the charter fishery through the GAF program. We aren't, we don't necessarily need that. You can do that.

I don't think we'd ever get there, But that was already sanctioned by this council. What we're asking is for a provision, and maybe temporary, and we, we support the sunset to be able to liberalize GAF to keep these businesses afloat, to offer an attractive fish to an angler to bring them up here until the RQE or other mechanisms can solve our problems. I think I'd say that just remind everybody that there is no twisting of arms with the GAF transfer. Program that's willing seller, willingly see if the commercial fleet transferred more than the commercial fleet thought was, you know, reasonable. That, that's their own peer group that's doing that.

It's— there's nobody forcing them to make that transfer. They're doing it because it fulfills needs in the commercial fishery. They're doing it because they can get more money doing that than paying 30 to 50% to the— be on a boat when they don't own those anymore and charter out, there's opportunities for those folks that, that have had to sell their boats or whatever to still make money off their IFQs. So I've got a million things that I could share with you. I'm happy to answer questions about any of these things.

I'm pretty intimately familiar with the RQE program and all of the things that surround it. So I'll stop there and thank you for your time.

Thank you for your testimony, Mr. Braden. I'll see if there are any questions. Yes, Mr. Bowers. Thank you, Madam Chair. Thank you for testimony, Mr. Braden.

So you said that a 34-inch fish is not a great angling opportunity for guests that come up and fish with folks in your sector.

How has your sector adapted to that? I mean, have you—. Have folks in the charter industry started targeting other species or tried to compensate for that limited opportunity that's available on halibut? Through the Chair, thank you for the question, Mr. Bowers. Absolutely.

King salmon, silver salmon, we've had restrictions in king salmon limits on non-residents, which affects to the charter industry, that's actually come down. We had like a 1 fish annual limit, which is 2 fish below any other annual limit that we had in kind of the beginning of our season. That was super hard for folks to endure, and a lot of people got put off by that. We're getting reductions that people can only keep— non-residents can only keep like 1 lingcod between 30 and 35 inches now in most southeast areas. There's restrictions down the like 2 or 3 on pelagic rockfish.

There's 1 a year on non-pelagics. There's almost nothing, you know, left to spread around or any area to go into. They're leaning on black cod a little bit, but it's just super restrictive down there. It's a beautiful place to visit and a wonderful place to fish, but there's not a lot to offer anymore. Thank you.

Thank you. So, Mr. Braden, I I have a question.

Really appreciate your perspective on this and some of the conversations we've had on the side.

I'm interested in learning a little bit more from your perspective how you think the Council should look at the potential for a sunset if we decide to move forward with considering decoupling GAF and RQE, and what type of benchmarks we might want to look at, at the outset of doing so to provide a level of comfort for those not, you know, not in support of this, that this isn't going to become a moving target at the end of the sunset. And, you know, whether or not that is, you know, simply, you know, from your perspective, some of the concerns that you've expressed about a specific management measure that is your target, and if that's achieved at the end of this sunset because of abundance or otherwise, that would be a measure of, you know, success or at least maturity of the sunset, or if there's something else that we should be looking at here to provide a level of comfort for those who, again, are concerned about potentially concerned about us moving down this pathway. Thank you for the question. I'll start by saying that it's impossible to do what we're asking in terms of the relaxing of the GAAP program without decoupling. You just have to.

It's part of the mechanics of making that work. Um, and, and just so this group knows, this council knows, um, we are actually, um, we're concerned about the, the GAAP GAF provision, and I think the original concept behind phasing it out is that the RQE would solve some of the problems, and I'll speak to like where we think we'd like to get, but the RQE would solve some of the problems and GAF would be no longer needed. And GAF presents an actual direct competitor to the RQE in terms of purchasing halibut quota, because if you as an IFQ holder can lease your quota, you're disincentivized to put it on the market so that the RQA can pick it up. So they kind of compete against each other. That's a concern.

I think that's one of the reasons that the sunset provision was thrown in. Part of it was also to appease any fears that, you know, this would be some type of permanent expansion.

Speaking to like where we'd like to go, so this, so this body knows, both fleets, 3A and 2C, took basically a cut cut in half from a 2-fish bag limit to a full cut in 2C to 1 fish in 2009 and '10. There still was a small second fish allowed in 3A, but since then, we've taken a cut from 1 fish of any size down to a 34-inch fish in 2C. It's— and I think the hope would be, I think that folks feel that a recreational angler fishing with a guide in 2C be very satisfied with being able to catch a fish without a size restriction. So if this council considered actually putting in regulation some size benchmark, it would probably be a fish of any size without day closures. I don't know that there's a lot of— you might be wasting resource by doubling that.

Some people may disagree, but I think for a halibut angler to be able to come up and catch a fish of any size in Southeast Alaska, probably probably fulfill their, their need.

Okay, thank you for that clarification.

Yes, Miss Kimball. Thank you. Um, thank you, Mr. Braden, for your testimony. I guess I have a kind of a broad question. I'm, I'm trying to understand how, how tinkering with GAF and maybe within a 5 or 10 year period solves the problem in 2C.

So that is my question. Is it even a Band-Aid that does what's needed in 2C in that time period, or are there just too many other factors, including additional growth in the rental boat sector, that mean this will not be as helpful as it seems? Just like your perspective, if you have that. Yeah, through the Chair, thank you for the question, Ms. Kimball.

So the reason why this is so urgent is because as we've mentioned, we're already up against the, the cap, the combined cap with the GAF use that's currently happening. Um, our concern is, uh, that if we don't have some flexibility in place, that over the course of the next few years— we don't know fully how long it'll take for the RQE to get its 10%, and we don't— we actually have analysis from this discussion paper that shows the best that it could do with, um, current effort and, you know, current HPWE and all that is the U38080. I don't think this council should be comfortable with the U38080 as the ultimate end of GAF, uh, the GAF program. Like, that's some win, especially if it phases out all, uh, possibility of, of GAF transfer. So I don't— I think the sunset could help revisit or force a revisiting.

Maybe there's another way to do that through the process. Us, but I think this council should understand that we're in immediate need right now, here and now. Yes, there is a bareboat— there's bareboat effort that has expanded, and I wouldn't say that that's charter people switching over. I haven't seen a lot of that. I've seen just real pure unguided businesses springing up, and I hear that that's continuing and even accelerating.

So yeah, that's a, that's a separate problem that this council probably needs, or the state needs to take a look at. But, um, I'm— we're here asking for immediate relief, and this is the only way that we can see to do it with the tools that you've given us. And the way we see forward is some flexibility in GAF by decoupling and raising the ceiling, or going to the original CSP GAF constraints, until we can get down the road and, and see how this program actually actually works. Thank you.

Yes, Miss Vanderhoeven. Thank you, Madam Chair. Thank you, Mr. Braden. Um, in this process, I get a little concerned when people talk about immediate and very rapid timelines. And so, um, can you, can you share what you mean by that in this process, realistically, what you'd be looking at that you think we'd be able to get something like this done if we went down that road?

Through the chair, thank you, Ms. Vanderhoeven, for the question. Yeah, the saying goes, yesterday would be great. Um, I— we understand that this council moves fairly slowly. Um, there may be analytical, um, problems in addressing analysis for like initial review. So we're not expecting anything, but I don't know if there's a way to fast-track it, that'd be fine.

But we're not expecting to see results probably for a year, um, or a year and a half, maybe two down the road. Hopefully there's staff available to process this in time on your schedule or your agendas to look at it, because I think it's just going to get worse before it gets better. Um, maybe we should have been having this discussion a couple of years ago, but it was hard to look at that without some of the analysis that we've gotten back in the discussion paper.

Thank you for your testimony. Thank you. So Kim Landine is next, and followed by Linda Banken.

Good morning, Madam Chair. I sent some Thanks to you, can we get those up? As we're pulling those up, I just want to put on the record, my name is Kim Lundeen, and I realize I may be a salmon swimming up the Columbia River right now, about to head into a dam or into the mouth of the Peniped. But it is our belief at SEGO that all facts need to be analyzed, including what you see before you. I've been telling my daughter as of late that we need to start being able to hold the tension of this and, meaning that this and that can be true.

And that's the conversation that's happening before you right now. I am going to attempt in the next 5 minutes to cover approximately 30 years of management, much of which has been unanalyzed in this portion to the committee at this, or to the committee at this point. So we heard, and we're here again, we're hearing here again that the self-guided growth must be addressed before this is a, before these actions are taken. Um, the AP voted that down 4 to 15, and while SEGO is putting in significant time and energy into helping understand this fleet more, going as far as opening up our own membership, as you heard here today, to include them in the conversation, we have a seat so that they can have a seat at the table. We do ask that all parties keep in mind that before this council and before this plan, these anglers are treated differently, and that's why this conversation is occurring.

What you're seeing here before you is the pain that's in this room. You're looking at an Area 2C halibut harvest share by sector. In Area 2C, commercial landings averaged about 9 million pounds a year from 1995 to 2004. Over the last 10 years, that's been about 3.6 pounds— or 3.6 million. Behind these numbers are the people that you're hearing about.

It's the processors that you're hearing about. As you can see on this, over the same time, the chart shows, the sport share in the 2C harvest went up 18% from, or went from 18% to 44% of overall harvest in 2C. Next slide, please.

What we found interesting is what you're looking at right now, is that this chart is the sport fishery in 2C split by guided and unguided proportionally. I want to point your attention to line 4. It's the implementation of the CHP program. Before 2011, guided anglers almost always took the larger part of the sport harvest. In 2011, unconsequentially, the relationship inverted, and it has not gone back.

It is not our belief that anglers suddenly developed a desire to captain their own boats in Alaska waters. The timing, in my mind, points to policy, policy pushing market demand into a fishery that the catch sharing had chose from the very beginning not to include. Next slide, please.

So this is a different angle of the same data that we presented in chart 1, but in pounds instead of the catch share. I'll point to the two lines along the bottom, which represent the guided and unguided sport harvest from 1995 to 2004. During—. With a large stock in the water, the sport fishery as a whole took about 2.2 million pounds over that time period. And over the last 10 years, as the stock came down, the harvest was about 2.1 million.

Sport harvest barely moved, but as the stock declined, the steady harvest became a bigger piece of the shrinking pie, as we see in these charts, or how— as we saw in chart 1.

The uncontrolled growth that we keep hearing about, it's not showing up on the charts. It's not there. But if you go back to the previous chart, we're just think back to the previous chart, we did see an inverse relationship happening between how this fishery was accessed and how these fish came out of the water. Um, slide—. Next slide, please.

So this slide shows 2C permit use and angler days. Unlike the commercial fishery, sport fishery value is opportunity times experience, not pound times accessible price. And what we like today under— or what we lack under today's management is forest, as the previous testifier mentioned. Is that we don't have a market right now. And so when you look at this chart, my first question becomes, how are we staying so stable?

About the same angular days, about the same CHP usage. So how are we getting there?

Next slide, please.

For many of them, the answer is GAF. This chart brings together the pieces of the GAF program since it began We do not have time to dig into all these numbers, though I wish we do, and I'm open to questions. But the bigger picture is, as charter rules tighten from under 44 inches in 2017 to under 34 inches this year, GAF leasing grew about 9-fold. Simply put, the plan that we have now does not work for the stock, nor the business models that we are managing, which makes the free market tools built into this more importantly, a.k.a. The GAF and the RQE program.

Next slide, please.

So this last chart puts IPHC's own numbers side by side, their estimate, their estimate of the stock back to 1923 on the left and their simulation going out to 2018 or 2080 on the right. It shows the stock's leveling off near today's level within the range it held for much of the last century and not returning to the early '90s or late '90s, early 2000s where this IPHC AFQ fishery was developed and these catch sharing plans put in place. And the catch sharing plan itself was developed in 2008, and when the spawning stock was roughly 1.5 times what it is today. Those are the pressure points. That's the pain that you're feeling in there.

We're managing a fishery and fishermen and communities and business models in a way that it doesn't make sense. So if you're looking at this right now, that, that line, vertical dotted line is when the IFQ fishery was rationalized. We have seen over time that the sport fishery is stable harvesters. How people choose to harvest that fish is being greatly influenced by the decision of federal management, but we are seeing that in the guided sector specifically, that there is still interest in the guided sector, but that it's requiring free market tools to keep people in that sector. They're willing to pay the gap staff.

They're willing to pay the RQE to pull some of the pounds that originally was, was rationalized in the IFQ fishery at these very high points where we didn't need the access to it, and we were sitting at the 2.2. But to maintain that 2.1 that we're seeing now requires these free market, free market skills. So with that, Madam Chair, I'll take questions if there are any. Thank you very much for your testimony. We'll see if there are any questions.

Thank you. Appreciate it.

So Linda Benken is up next, followed by Rebecca Skinner.

Thank you. Excuse me, Madam Chair. Linda Benken, testifying for Alaska Longline Fishermen's Association. Start by saying at risk of documenting my insanity and age, I'll let you know Alfa and I have both been engaged with this charter issue since 1993. That was the year Alfa first pointed out to the Council that the charter sector was growing, that their increasing harvest was deducted from the total before commercial catch limits were set, and then since IFQs were on the horizon, the erosion of the commercial quota was going to impose an ever-increasing economic burden on the commercial sector.

Since '93, there have been 6 final actions to limit guided sport harvest. GHLs, GHL adjustments, charter moratorium, CHIP, and eventually the catch sharing plan twice, which included the GAF. It was months of council time, years of staff and public time. At each step in the process, the allocation to the charter sector was increased, always above their current harvest at that time, with the understanding that the fleet would work to limit growth before reaching their new limit. That last part never happened.

The fleet has never addressed overcapacity in their sector, has not only not plugged the loophole of bareboat charter, but many are instead taking advantage of it and now are coming back to again access more from the commercial halibut fleet. While this may not technically necessitate reopening the CSP, that is semantics. It's reallocated reallocation. We're all struggling with low abundance. Sego points out that their sector is stable in terms of numbers of trips and boats.

I wish our sector was. The commercial sector is anything but stable. We're taking less trips, have less boats, and less processors in the fishery. Because the halibut spawning biomass is at historic low levels, because we've seen reallocation, and because the bareboat charter sector is expanding. From the analysis, you know, the RQE and the GAF allow the charter fleet to increase their allocation, one through purchase and one through lease.

GAF was designed to phase out as the RQE purchase quota to limit the reallocation of quota from commercial to charter. That limit is really important to the commercial sector, not just harvesters, as others have said, but processors, marine support sectors, and the consumers who clearly value their access to this resource through the commercial sector. As included in the AP motion, that reallocation could theoretically end up with 50% more of the 2C commercial quota being reallocated as GAF to the charter sector. Since the motion removed any limit on the GAF, that would wipe out our industry. Industry, along with the entry level to the IFQ program, including entry level for the CQ communities.

We're working hard to help.

To our members, the most egregious part of this ask is that many in the charter sector are contributing to the problem. We see the growth and how it's eating into both the commercial and the charter sector. It's increased from just under a million to closer to $1.4 million. And the fix instead should be addressing that internal switch and bareboat problem rather than taking more from the commercial side. If the talk is really of a free and fair market, then if we're going to take a look at this, let's also take a look at creating a two-way door, allowing the commercial fleet to access chips, and bring that quota back over to the commercial side, or to lease GAF pounds from the charter sector.

Please remember that the commercial halibut fleet is largely a small boat, owner-operated, community-based fleet. Leasing is not allowed except for leasing to the charter sector. GAF feeds that. Commercial fishermen can hold quota, lease it, and never go fishing. We want that to end and to get people to sell if they don't want to fish.

That's important for entry level to the commercial fishery and important to entry level for the CQE communities. Our ask is to drop this reallocation analysis until the charter fleet works with the legislature and the council to limit bareboat charter harvest. Low abundance is hard for everyone. At minimum, if you move this ahead analysis, retain the existing GAF and RQE limits, and analyze a 5-year GAF extension. Look at making the GAF and CHP a two-way street and take a hard look at the impact of these alternatives on individual and CQE entry levels to the commercial fishery.

To be clear, we oppose the AP motion. We can live with a 2% annual purchase by the RQE but we would prefer no other action beyond that proposed change. The council can return to this issue once the bareboat loophole is addressed. Thank you. Be happy to try and answer any questions.

Thank you for your testimony, Ms. Banken. See if there are any questions.

Okay, not seeing any. Thank you for joining us. Thank you. So Rebecca Skinner, um, is next, and then I'll circle back to James Kern.

Sorry, trying to figure out the technical of this. Okay. Good afternoon. My name is Rebecca Skinner. I'm the executive director of Alaska Whitefish Trawlers Association.

And with me is Patty O'Donnell, a longtime Kodiak trawler and president of AWTA. I am here— we are here today mainly to address Motion 3 that came out of the Charter Committee. It did show up in this agenda item, so this is where I'm going to share my slides and my thoughts on this issue.

So the, the first thing I wanted to address is we keep hearing that halibut is at historically low levels. And so this, the slide on the screen, the first slide in the attachment to my testimony, shows IPHC data back to 1926 and, and then forward through 2026. And what you can see is that the levels we're at now are are not drastically low. They're in fact a little bit higher than, than some points in history. What you do see is a huge peak in the female spawning stock abundance around the 1990s, and that orange line on the chart shows when halibut was rationalized with the IFQ program.

So what that did, in my opinion, is anchored people's expectations in around how much halibut they received in the IFQ program. So the IFQ gave you quota shares, but when people first got their halibut, they probably just looked at it as pounds of halibut that they received. So when abundance was high, that equated to a certain number of pounds. When abundance went back to more normal levels, that number of pounds obviously decreased.

So from a big picture perspective, in my opinion, looking at this IPHC data, we are not at historically low levels. We're about where, where you would expect to see the halibut abundance. Sego shared a slide a little bit ago that showed the IPHC forecast. I think it went to 2080, and on that slide it showed we expect about the same amount of halibut until 2080. So what this tells me is that where we are today is where we were for much of the history that's shown on the graph, and it's where we should expect to be going forward.

So I think that's a very different narrative or a very different starting place than we are at historically low abundance of halibut. Moving on to the next slide.

Um, because Motion 3 dealt with looking at mortality in the Gulf of Alaska and specifically mentioned, um, trawl— well, PSE, which includes trawl PSE— I wanted to make sure it was clear that according to IPHC data, which I'm considering the best science available for halibut, over, um, 65% of the halibut biomass is in the Gulf of Alaska. So if you have trawling in the Gulf of Alaska, there's just more halibut that we have to try to avoid or deal with. And that's a very different picture than it— than, for example, the Bering Sea, if you think about abundance-based management in the Bering Sea. The next slide shows more of the, the different story in the Gulf. In the Gulf, PSE is only 4% of all halibut mortality.

Most of the mortality comes from the directed commercial fishery for halibut, as well as the discard mortality. The gray slice is charter at 14%, unguided is also 14%, and then you'll see PSE is the, the green slice at 4%.

Sorry, I'm advancing my own slides the wrong way. Um, so the next slide shows two things. One, it shows there's a difference between NPS data and IPHC data. On the left, you'll see the NPS data, which indicates that IFQ discard mortality. So these are— this is, um, in the, in the halibut fishery, when they discard, when those fish die that are discarded, that's 4 times more than trawl PSC mortality, and that's according to NPS data.

On the right, you'll see IPHC data, which counts that number differently, but the PSE is, is pretty close to IFQ discard mortality, but both of those are dwarfed by the unguided mortality, which is the yellow.

Moving on to the next slide.

So this just documents that since 1985, because that was a, a year that came up in conversations I had about this issue, Comparing 1985 to 2025, there was 143% increase in recreational use and a 40% decrease in, in PSE. So I just point this out to show that there, there has been an increase in recreational, but I think that makes sense because in 1985, I, I doubt there was that much recreational.

The next slide, this just documents— this is Fish and Game data It just documents the increase in unguided, so this is private angler data in Southeast, and blue is non-resident. And I just share this to show when you hear the charter in Southeast is being pinched, it's because they are being pinched. So it doesn't get to whose fault that is, it's just showing there's been an increase. And then the last slide again shows the female spawning stock biomass, so over time, 100 years of data, The blue dotted line are commercial halibut removals, so you can see that kind of proportionally there were far higher commercial removers— removals back at a time when the spawning stock biomass was about the same. And then the green line at the bottom is PSC removals, and you can see that it has decreased, but that it was also at a higher level when the spawning stock biomass was approximately the same.

Same. So again, in the big picture of things, to me this does not indicate an emergency with PSE use in the Gulf of Alaska. And I'll end there. Thanks. Thank you very much for your testimony.

We'll see if there are any questions.

Yes, Miss Kimball. Thank you. Thanks for your testimony and putting that information together. I guess we've been focused mainly on GAF and RQE Holdings Is the purpose of you providing this around— is that around the Charter Committee's third motion? We really haven't discussed that, but is that the context for this, not something related to GAF?

It is. It mostly comes in reaction to motion number 3 because it did— it was presented during this agenda item. I didn't want to miss the opportunity to share these comments and then find out, you later kick myself that I didn't. But, but I think it— I also look at this as, you know, when you look at the first slide that showed when IFQ went into effect, it went into effect at a peak of abundance. And so management decisions or a management structure that made sense at that level, at that very unusually high level, may not make sense today.

And because is according to IPHC data that I've looked at, I expect that this, the halibut, the levels we have today to continue. It's important that, in my opinion, we not look at, we're in a trough of halibut and we're gonna come out of it in a couple of years. I don't think that's what the data says. I think we need to be planning for, this was close to historical levels, and these are the kind of levels we're gonna look at going forward. So it, it a little bit, it a little bit, um, relates to overall management of halibut.

Thanks.

Thank you. Thank you for your testimony.

So I'll circle back to James Kearns. Is he online? Okay, so that'll conclude our public testimony.

Um, on D1, like to take a stand down to consider all of the public testimony that we've heard and see if the council would like to take action. Um, let's come back at 2, um, let's try 2:35, and we will let you know if we need additional time. Thank you.

Welcome back, everyone. So, um, before we ended public testimony on D1, I think someone was having a technical difficulty and couldn't join us, and since resolved that. So we're gonna take one more public testifier before considering action on D1. So, James Kern. Yeah, thank you.

Can you hear me okay? Yes, welcome. Perfect.

Yeah, I'm sorry for the, uh, for the technical difficulties. Thank you so much for the opportunity to comment. My name is James Kearns. I live in Gustavus, Alaska, and I represent Halibut Forever. We advocate first and foremost for conservation of the halibut resource and would ask that all users recognize that in times of low abundance, if that's what we're having, we all have to tighten our belts, like one of the testifiers said.

So And that's what I think is abundance-based management. Secondly, we want to recognize that the halibut fishery has 4 distinctly different user groups. There's the undirected commercial, I guess we call it the trawler bycatch. There's the directed commercial, the recreational, and the subsistence. And we advocate for the fair and equitable access to all users, and we believe that that can be done with separate allocations for each group.

So we ask that the council consider revising the catch sharing plan with a separate allocation for the recreational group that includes both guided and unguided anglers. Uh, we don't support uncompensated reallocation of the directed commercial fish reallocation, but as I said, there should be equitable access for the recreational group. So we propose that a recreational allocation that is the average of the recreational removals, both guided and unguided, for the past 26 years in pounds, and listed as a percentage of the TAC be established. Also, that 1 halibut of any size per day be the daily bag limit for all recreational anglers, and that the recreational fishing be managed— the recreational fishery, sorry— be managed to stay within their allocation by implementing number one, an annual limit with an accounting process that gives valuable data regarding gender, size, and location of the fish that's caught. And also, it, it can be managed with season adjustments, day closures, and possibly even possession limits with a very strict definition of what possession limits are.

Additionally, additionally, that a provision be put in place that would require any recreational halibut kept that is over 60 inches in length be counted as 2 fish on the angler's annual limit. This revision would, number 1, simplify this council's work the work of managing this recreational removals, because this is a lot of work. You have been through many years of it, and it's always hard. Number 2, it would give transparency to all recreational halibut anglers. And number 3, it would remove the loophole in the current management system that allows rental unguided businesses to have an unaccountable and unfair greater access to the resource.

In addition, our group requests that you consider making a regulation that does not allow for leasing of non-transferable CHPs, and that prov— and, and that regulation that would provide for accountability in the leasing of transfer— transparent— transferable CHPs. Although CHP holders are not a commercial halibut fishery, they are actually licensed Coast Guard-approved entities that are authorized to carry recreational halibut fishermen for hire, but they're individuals and businesses, and, and they should have limitations. They are a limited entry entity, and that should have similar accountability and regulation as other limited entry entities. And I have 1 minute left to go, so, um, I'll just say, with— I have clients that love to fish for halibut and they love to eat what they catch, but they recognize that if they use the halibut money or the amount of money that they spent to to come and fish recreationally with me, they could buy way more fish, freshly frozen halibut, from a commercial vendor. And frankly, they do.

They buy it. And I have way less locals now who want to go use my charter services because they have a different limit if they go with me than if they go with their friends or if they buy a boat or rent a boat themselves. Equity means that all recreational anglers have the same regulations, and all recreational anglers need to adjust to the abundance of the resource along with all other user sectors. And finally, as a commercial fisherman, I am not allowed to fish recreationally from my boat. So why did we ever allow GAF?

Because it's not in line with the, with the prohibitions to fish recreationally from a commercial boat. So why would we be able to allow people to fish commercially from a recreational boat. Thank you for taking my testimony, and I appreciate you coming back to me. Thank you very much for joining us. See if there are any questions.

Yeah, not seeing any. Thanks again. Yep, thank you.

So, um, just before we consider action on D1, I think As far as our scheduling, um, we'll, we'll take action, then we'll break for the day. We do have an executive session planned, so we'll ask the, um, the public to, um, clear the room shortly after we consider action. We'll come back tomorrow morning and begin D3, and we will very likely begin, and if not end, staff tasking tomorrow afternoon. Um, but we'll have to assess how many public testifiers we get. So with that, I'll ask, um, if the council would like to take action on D1.

Yes, Mr. Ritchie.

Thank you, Madam Chair. I do have a motion prepared. I'll wait for it to get on screen.

I'll apologize in advance, I'm going to read the motion from my phone. I think if I try to change the window on my iPad right now, it might explode.

The council adopts the following purpose and need statement and alternatives for analysis. Purpose and need: since council final action on recreational quota entity program in 2016, International Pacific Halibut Commission IPHC allocations in Area 2C and other areas have declined. As conditions have led to more restrictive management measures, the use of guided angler fish has increased, with GAF transfers in Area 2C currently approaching 10%. Regulations limit the leasing of GAF in Area 2C such that the sum of IFQ halibut equivalent pounds transferred as IFQ to GAF and the pounds of recreational fishing quota, RFQ, issued to the RQE during a calendar year may not exceed 10% of the total quota share pool in Area 2C. Therefore, current regulations will phase out the opportunity to lease gaff as the RQE purchases quota.

Harvest measures under a fully funded RQE may not be sufficient to stabilize charter businesses or to meet angler demand. The council is concerned that these limits may constrain the guided recreational fleet in Area 2C Area 2C and limit the use of GAF, a regulatory tool that has high historic utilization. Based on charter businesses' increased reliance on GAF leasing, there may be a need to maintain GAF access with modifications to existing total transfer limits. The council is considering whether to allow the RQE to purchase more quota in a year than the annual transfer restrictions of 1% in Area 2C and 1.2% the 25% in Area 3A specified in regulation. This would reduce the time needed for the RQE to reach its total transfer limits and more immediately provide less restrictive management measures.

It is expected that RQE stamp purchases will provide enough funding to provide less restrictive measures if additional annual transfers are permitted. Alternatives 2 and 3 are not mutually exclusive. Alternative 1, status quo. Alternative 2, decouple the cumulative limit on the transfer of IFQ to GAF and the pounds of RFQ issued to the RQE in Area 2C. The limit on RFQ issued to the RQE would remain in place at 10% of the Area 2C quota share pool.

Element 1, limit the total annual IFQ transfer to GAF percent of the the Area 2C quota share pool. Option 1, 5%. Option 2, 10%. Element 2, sunset provision. The cumulative limit on the transfer of IFQ to GAF and pounds of RFQ would be reimplemented after Option 1, 5 years.

Option 2, 10 years. Alternative 3, revise the RQE transfer provisions such that the annual quota share transfer to the RQE would be Option 1, 2% in IPHC Area 2C, Option 2, 2.4% in IPHC Area 3A. Uh, with that, uh, with the second, I'll speak to rationale.

Thank you, Miss Vanderhoeven and Mr. Ritchie. Thank you, Madam Chair. Thank you, Miss Vanderhoeven, for the second.

Going into this meeting, I found myself torn between going to initial review versus motioning for an expanded discussion paper based on the concerns I heard in public testimony and in AP deliberations. IFQ market impacts, the potential for consolidation in the processing sector, increased entry costs, and challenges for CQEs— these are all things that I hope would be explored in analysis. I've also heard many concerns about how restrictive management measures in 2 are are in part due to aspects currently outside of this council's control, like increased unguided recreational effort and lower halibut biomass coast-wide, not just in 2C. That said, I don't think those concerns preclude analysis and seeking a greater understanding of how the council might address or not address the problem identified by guided recreational stakeholders.

When I sat down to look at how these concerns, along with those of people who rely on gaff leasing, I struggled to see how all of this would be captured in another discussion paper. It seems that those concerns could be much better explored through analysis and initial review. After consulting staff, I want to double down. I believe that many of the concerns we have heard can be much better addressed and explored through initial review than through an expanded discussion paper. Analysis does not presume any result, and I believe in this Council's ability to make an objective decision based on the information that review provides.

To explain some of the reasoning for what I included in this motion, I want to walk through it. Alternative 1 is status quo. It's a NEPA requirement that any reasonable range of alternatives include a no-action alternative. In this case, status quo would mean that language around gaff leasing would continue to be a part of a combined pool with the recreational fishing quota purchased and transferred to RQE in IPHC Area 2C. That pool would retain a 10% a 10% combined TAC and RQE purchase would gradually phase out GAF.

Alternative 2 describes the change to limitations for GAF leasing. It would decouple the limits so that the 10% transfer limit for the RQE in 2C would remain, but an additional cap for GAF would be created to the amount specified in Element 1. I think that we heard rationale for this in public testimony. Many charter businesses in 2C have grown reliant on access to GAF as annual management measures have become more restrictive over time. My intent is that analysis would include concerns I spoke to earlier.

I think we also heard that consideration should be made to look into the effects of increased recreational effort and lower overall halibut abundance. I included only 2C in my motion here because I don't believe that the discussion paper adequately supports analysis for revision of— to GAF leasing in 3A. The paper illustrates a different scenario under RQE, full RQE funding for 3A, and I think it's a much more positive outlook as far as angler opportunity.

Element 2, I included this because I think that there is support for it in public testimony. I want to be responsive to that request. I wasn't here through implementation of the RQE, so the best I can do is read about intents from back then and listen to the people who were there and use that information to make the best judgment about what I think is right to include in analysis. I felt that a sunset was a compromised position and analysis of it as an element might offer valuable information.

Um, Alternative 3, I want to be fully transparent. Originally I had another alternative here. I want to speak to it because I think the details are important and I I hope that some of what might have been there could make it into analysis. This alternative would have removed the current transfer caps on GAF and retained the individual CHP limits, which are already in regulation. Those limits are 400 GAF, that's guided angler fish, for each permit 6 anglers or less, and 600 GAF for permits greater than 6 anglers.

This is what the regulations were prior to RQE implementation in 2007. 2016. I think it's important to include this as an— in the analysis because it could show IFQ lease rates under what I consider to be a very liberal GAF cap. Under these regulations, there was a much higher overall GAF cap combined amongst the active permits than we currently see with the 10% cap between the RQE and GAF. Under those circumstances, do we see more, less, or relative lease rates for GAF?

I think that this information would be helpful, would be helpful for the conversation around the value of GAF and its potential to destabilize another equally valuable fishery along with an important processor sector in 2C. I removed this alternative in response to public testimony, but my intent is that the period where GAF leasing existed under these regulations should be analyzed. I would like to understand the impacts then on processor operations and on the IFQ market market. I understand that this was part of the original RQE analysis. I also want to recognize now though that it's important to call out that back then we were in a different situation for halibut.

The coast-wide abundance was, was very different, and there was different, uh, unguided recreational effort. Alternative 3, this alternative is included in response to the motion in the Charter Halibut Management Committee 2C and the council's advisory panel. Um, both the numbers that you see in option 1 and 2 are simply twice as high as the, uh, original number. It used to be— or it currently is 1% in 2C and 1.2% in 3A. Uh, with that, I want to thank testifiers and welcome any questions.

Thank you, Mr. Richie. We'll see if there are any questions on the motion.

Yes, Mr. Pamplin. Thanks, Madam Chair, and thanks, Mr. Ritchie, for the motion as well as your rationale. That really helped me understand kind of the motivation here. I do have a question for you on Alternative 2, Element 2, the sunset provision. And to me, it could be sunset provision, full stop.

Option 1, Option 2. Question 2, it's the sentence that, that you have there is what's a little bit confusing to me. So to put it in my own words, does this say the cumulative limit on the transfer of IFQ to GAF and pounds of RFQ would be restored to 10% after 5 years and 10 years? Thank you, Mr. Pamplin, for the question. Yes, that, that is my intent.

Got it, thank you.

Yes, Mr. Kerlin. Thanks, Madam Chair, and thanks, Mr. Ritchie, for the motion. I heard you in your discussing your rationale, you talked about your thoughts as to whether to ask for another discussion paper versus proceeding to recommend an analysis. But I don't think I heard you address sort of overall kind of the why now question. Question.

If in terms of consideration of like allowing the RQE program to play out for a while or opportunity for addressing the unguided sector, the expansion of the bareboat charter component, that sort of thing. So I wonder if you could address that in your thinking in proposing this.

Thank you, Mr. Kerlin, for the question.

Um, why now? I think that we, we heard a lot of evidence for, for why now through public testimony and also through AP discussion. Um, unguided anglers in, in 2C, uh, in 2026 were fishing at a U26.080 limit. The majority of the removal were fish that were underneath 32 inches, which is below the current currency of management at the IPHC, which their allocations are actually based on. I think that that— I don't want to say that that necessitates taking a hard look at these things, but I think that it gives good evidence that the Council should consider looking at alternative management measures to to help alleviate some of the pressures that are on that sector.

Myself being a charter fisherman, I do think that it would be difficult for me to market a 34-inch fish, so I understand the pressures that we heard in public testimony, and I want to be responsive.

Does that answer your question, or I can— if you could rephrase it if I need to provide more information. I think you covered it. Thank you. Thank you. Any further questions?

Yes, Ms. Baker.

Thank you, Madam Chair. Thank you, Mr. Ritchie, for the motion. I— my question is on your proposed Alternative 3, and I just, uh, appreciate— I thought you referenced sort of your, your rationale for including this was discussions from the Charter Halibut Management Committee and maybe public testimony. And I think I'm clear on what this proposed Alternative 3 would do. Can you please remind me of your rationale for including Area 3A in Option 2 and not just Area 2C?

Thank you for the question, Ms. Baker. I didn't speak to that in my rationale, but I'll, I'll speak to it now. I think that it would be, um, I'm hoping it wouldn't be a huge lift to include Area 3A in this. Um, in AP deliberations and in, um, public testimony both at the AP and at the council, I haven't heard opposition to 3A's inclusion. Um, and it was included in the AP motion, so I thought that it would be appropriate to include Here, through the chair, thank you, Mr.

Ritchie, for that. And so I, I just, I appreciated that. And I, so as you responded to that question, it does seem like the last paragraph of your proposed purpose and needs statement here, in, in terms of really the, your intent behind including Alternative 3, is to reduce the time needed for the RQE in either area to reach its total transfer limit. So you're, you're just proposing that we do that for both areas is how I'm reading that. Thank you, Ms. Baker.

That's right.

Any further questions?

I'm deciding if I have one. Sorry about that. Hold on a second.

Mr. Ritchie, if we look back at the AP motion, um, That was past 14 to 4, um, in the first paragraph. And I'm just trying to compare that with your alternative to element 1, um, as far as the different percentages that you have here. Um, if I'm— if I read the AP motion correctly, I would interpret that as, um, potentially a decoupling for either permanently or a set duration of time, but there's no specificity as far as, you know, changing the existing cap that was put into place, that cumulative cap. So I assume that was a 10% if that was decoupled. And so I just wanted to confirm that Element 1, Option 2 was consistent with probably that language if we're to interpret that that's implied, and Option 1 would be actually more restrictive.

Madam Chair, that's correct.

Okay, thank you.

Okay, any further questions?

Any comments on the motion? Oh, sorry, Ms. Kimball, an amendment.

Um, this is in the purpose and need, and I couldn't find a way to ask a question to let people know I was thinking about this. Um, but if we could go to the purpose and need on the motion.

Um, my amendment would be to the second paragraph, and it would be to strike the sentence that starts, the council is concerned, and in the last sentence, strike the words with modifications to existing total transfer limits and replace it with the words for a limit— for a limited period of time. And with the second, I'll speak to it. Maybe we'll make sure that's redlined first.

Sure, I'd be glad to repeat it. I apologize, I don't have it sent to you. It would be to strike the whole sentence that starts, the council is concerned.

There we go. And then to strike with mod— in the second sentence below that, strike the words with modifications to existing total transfer limit.

And replace after that with the words 'for a limited period of time.' I'll second the amendment.

Thank you for the second, Mr. Pamplin. I'm sorry, it's just part of that sentence, so there's not a— the last sentence would read, 'Based on a— on charter business.' I mean, Based on charter businesses' increased reliance on GAF leasing, there may be a need to maintain GAF access for a limited period of time. Yeah, that's my amendment. Okay, so we have a second from Mr. Pamplin. And Miss Kimball, would you like to speak to your amendment?

Just, just briefly, and I don't really want to nitpick purpose and needs, but I feel like the statements about the council's concern always is highlighted, and, and I I think what that statement says is, is exactly what we expect limits to do. They constrain sectors, and I didn't want to put forward that that actually is a problem. I think we're going to look in an analysis whether there should be modifications for a limited period of time, and that's the purpose of the whole analysis. But I, I just felt uncomfortable personally in stating that we thought it was a problem that limits existed to constrain the guided halibut sector. That's why we had these limits in the first placed.

So, important enough to me at least to put on the table, but welcome to hear other comments. Thank you, Ms. Kimball. We'll see if there are any questions on the amendment or any comments on the amendment.

Yes, Mr. Ritchie.

Thank you, Madam Chair, and thank you for the amendment. Um, my question is, is kind of process-oriented, I think. Um, just looking at this, and as we're crafting a purpose and need statement for this, I'm wondering if including for, for a limited period of time there, um, does that change alternative 2 element 2? Because that is, uh, the council would in the future have an option to take up element 2 or not. But if we have for a limited period of time is the intent and the purpose and need statement, I don't I don't quite understand why we would have element 2, and I don't want to preclude us from selecting that in the future.

I'm not comfortable with that as a council member, so I'm just asking, asking that. Thanks, Mr. Ritchie. I, I think I see your question. I, I think the inclusion of for a limited period of time, it points to a need for element 2 as opposed to the opportunity to not choose Element 2. So if the council's a lot less interested in a temporary situation here, then maybe they don't support this amendment.

But I think it points toward choosing something under Element 2.

Thank you for that clarification.

Any further questions or comments?

On the amendment? Yes, Mr. Ritchie.

I want to thank you, Nicole, for— Miss Kimball, for making the, the amendment. I think that I, I do agree with it, but I, I am, I am afraid of, um, presuming what we might find from, from an analysis, and I think that this This might do that. So while I appreciate it, I don't think I'll be voting for it. Thank you. Thank you, Mr. Ritchie.

Any other comments on the amendment?

Seeing none, we'll take a roll call vote on the amendment.

Through the chair, this is a roll call vote for the amendment to the D1 motion to make changes to the second paragraph of the purpose and need as displayed. On the screen at present.

And that starts with, uh, Mr. Bowers. Yes. Miss Kimball. Yes. Mr. Kurland.

Yes. Mr. McIntosh. Yes. Mr. Muller. Yes.

Mr. Pamplin. Yes. Mr. Ritchie. No. Mr. See.

Yes. Miss Vanderhoeven. Yes. Ms. Baker? Yes.

And Ms. Drobnyka? Yes. That amendment passes 10 to 1.

Thank you. Any further amendments?

Yes, Ms. Kimball. Thank you. I have a very small one based on Mr. Pamplin's question. Um, it's under Alternative 2, Element 2, and it's the addition of the 10% cumulative limit on the transfer of IFQ to GAF. It's just adding the words 10% to be clear.

Under element 2. Yeah, right after the— no, that's fine. That's not what I said, but that's totally same thing. Yeah, that looks great. Great, that's my amendment.

Um, I can speak to it.

Thank you. Is there a second? Second. Thank you, Mr. Pamplin and Ms. Kimball. Thank you.

Just, I think it's to be as clear as possible since it's— there's a lot of limits being both discussed and referenced that just to be really clear, what we're looking at is what's currently in regulation at 10% for Area 2C. Thank you. Thank you. Any questions on the moment?

Any comments on the amendment?

Mr. Ritchie. I want to thank Miss Kimball for, uh, making what's a really complicated system a little more digestible. So thank you.

Thank you, Mr. Ritchie.

I'll assume that's support. Okay. Great. And any other comments or objection to the amendment? Seeing none, that passes without objection.

Any further amendments?

Now we're at comments on the amended main motion.

Mr. Muller. Yeah, thank you, Madam Chair, and thank you, Mr. Rickey, for the motion. Um, I really appreciate, uh, the work you put into the motion here, and it's horribly unfortunate, um, where we are with halibut abundance in Area 2C and other areas across the state. Um, we've heard through public testimony that this is at least contributing to the—.

To what you're trying to fix here relative to this action in front of us. And I'm extremely sensitive to all user groups that are impacted by this low abundance in 2C, including the charter sector.

All that being said, Mr. Ricci, I, I again appreciate what you're, what you're attempting to do here, but I have concerns, um, with these changes at this point in time, primarily because we have entire sector, entire user group that is largely unregulated, and that's the unguided rental boat sector. And so for those reasons, Mr. Ritchie, I appreciate your efforts here, but I will not be able to support your main motion.

Thank you, Mr. Mohler. Any other comments on the motion?

Hey, Miss Kimball. I'm, I'm really— thank you, through the chair. I'm, I'm really torn on the, on the motion. Not that I don't see a problem, but I guess I align myself with Mr. Mohler and a lot of the sense that I feel like we're not tackling the right piece of the problem. Um, I, I, I, we have heard through public comment, both in written and oral comment, that there is an opportunity both through the legislature and some— it would take a lot of state work as well to try to identify the rental boat businesses and then manage them in the way that the council saw fit.

I really feel like that's where efforts should be focused. Um, so I'm very torn on putting this forward in light of our whole discussion on priorities I think I'll— I support the motion going forward for analysis. And I, I guess I just want to say it doesn't presuppose where I would come out on a, on a final action, because I think it's a little bit misplaced in terms of the level of, like, meaningful impact that this will have compared to some other factors. So that's where I am.

Thank you, Miss Kimball. Any other comments? Mr. C. Thanks. I, I also have had some concern, well, reservations about which way to go on this action, and I, I think I would align myself with Ms. Kimball's comments on, uh, the, uh, the interest in moving this forward, uh, not presupposing a solution or a position on this set and ahead of analysis.

But I, I think that seeing the analysis on, particularly on Alternative 2, will be really helpful to understand some of the impacts and, and whether those changes may be beneficial and to what degree they could help with addressing the, the concerns within the charter sector. Here. And so I do look forward to seeing the analysis on this. I, I do want to emphasize just the importance of, of all stakeholders trying to redouble efforts to address some of these broader issues that are impacting the, the sector and creating this problem we're trying to deal with here. So thanks.

Thank you, Mr. C. Any other comments? Ms. Vanderhoof. Thank you, Madam Chair. Um, I, I really appreciate the comments made by Mr. Muller and Miss Kimball and Mr. C. I, I also have been a little bit torn on this, um, and I think in, in listening to the discussion and reminding myself again of the prioritization discussion that we're going to be having under staff tasking and that I also don't think this really gets to the root of the problem with the unguided sector. I think I'm going to be inclined to vote no on the motion, but I really appreciate Mr. Ritchie and all the public comment.

It's, it's a problem that keeps coming forward, and I just don't think this is going to be— this isn't going to move the needle far enough to, to provide some stability there for the sectors that are impacted by this. So I, I think I'm probably going to vote no.

Thank you, Miss Vanderhoeven. Any other comments?

Hey, um, I too am struggling with this motion, uh, quite a bit. Um, I heard, but I am, I think, inclined to also support it for a closer look through our analytical process. Process. At this point, I am— we've heard a lot of really valid concerns from the commercial sector, including impacts on entry-level participants. I think getting a clear look at that in the next iteration is something I'm really— will be focused and interested in seeing.

I do also agree with others around the table that we've heard consistently about and have seen potentially some anecdotal, you know, evidence that we, we have some challenges in the unguided rental sector. Been following legislative activity that may give us a little bit more guidance with the definition moving forward and allow us to potentially work, tackle that issue a little bit closer. So I want to be very open to redirecting, you know, if we do move this forward for analysis, redirecting efforts, or at least supplementing efforts on really looking into the rental boat issue.

And I think really critical to my support here was the inclusion of a sunset provision and the amendments made to the purpose and need. So appreciate that, Ms. Kimball, and appreciate all of the work that you've done on this motion, Mr. Ricci.

So with that, I think we'll take a roll call vote. Okay, calling the roll on the amended main motion to initiate an analysis to evaluate changes to the cumulative GAF RQE limit and the RQE annual transfer provisions.

Yes. Mr. Kerland? Yes. Mr. McIntosh? Yes.

Mr. Mohler? No. Mr. Pamplin? Yes. Mr. Ritchie?

Yes. Mr. C? Yes. Miss Vanderhoeven? No.

Miss Baker? Yes. Mr. Bowers? Yes. Mr. Obnica?

Yes. That motion passes 9-2.

Okay, any further action on D1? Okay, seeing none, so we will break for the day. Um, it's a reminder we're going into executive session, so I'll give council members, um, about, um, let's— I'll give you 10 minutes, uh, to take a little break and come back, um, and give some time for members of the public to clear the room. We'll begin tomorrow morning at 8:30 with D3, and again, we expect to probably start and finish staff tasking early afternoon, or start at early afternoon, finish it by the end of the day, unless we get a lot of public engaged. Um, so, uh, we'll see everyone at 8:30 and council members back in the room in 10 minutes.

Thanks.