NPFMC AP: October AP Meeting, Day 1, 10.07.2026

And then, ACFN has updated their allocation review dashboard's website with a few new allocation reviews.

Also under B1, we've posted a discussion paper that provides a framework for a council discussion on prioritization.

The council had requested that staff develop this framework to help the council organize a constructive conversation about prioritization.

So this paper provides an overview of kind of required versus discretionary actions that the council and other factors that the council should consider when prioritizing their actions.

The thing— the main things that the council may wish to consider when they— in this discussion, kind of, we're requesting is to structure this discussion around potentially highlighting 3 or 4 priorities among the council's discretionary actions that they want to prioritize. Also potentially looking at the review of the items not yet started list in the 3-Meeting Outlook to see whether any items should be removed.

Also looking for some feedback from them to affirm or provide input on National Marine Fisheries Service implementation priorities. And then some potential process changes considering looking at the council's approach to staff tasking at future meetings. And whether to constrain that discussion to designated meetings once or twice a year rather than taking them up at every meeting. And then another option is to commit to an annual strategic planning process discussion in October to develop the priorities for the upcoming year. So this is not a specific agenda item for the AP, but if you want to provide recommendations to the council related to these issues, you can.

Related to that kind of council prioritization discussion, we have some additional information in B1 as background information for prioritization. We have posted an updated version of the council work plan related to the Executive Order 14276 on the eAgenda.

We also have some information on information provided by NOAA on their regional priority guidance.

Um, and then there's other information in the B2 NIMS management report related to priorities to help just provide some background for this discussion, because one of those NIMS regional priorities was a potential review of Steller sea lion closure boundaries. So they've posted some information under B2 on the Steller sea lion protection measures. The proposed and final rules in 2014.

Another issue on the NMFS regional prioritization was the eliminate 2% IFQ deduction for bled sablefish. So NMFS has some implementation considerations in their B2 report to provide background on that. And then they've also included the kind of normal Sustainable Fisheries Division priorities that they include but with some additional information on their rulemaking priorities for 2027. So all that information is provided to help provide that framework for the council prioritization discussion, and that information is coming to them in the B reports, and then they will have that discussion and, and take action on it under staff tasking in E. So other items that NMFS wanted to highlight from their management report. There is a new recreational fishing executive order, 14430, Restoring American Saltwater Angling and Recreation.

The stated purpose is to ensure America's recreational fishing remains strong. They've also included their normal rulemaking updates with a bit more information about the status of certain projects that may be of interest. They are planning to propose a number of additional regulatory changes in their MRA rulemaking package. So those are listed in the B report under the heading Regulations Governing When a Vessel Must Retain or Discard Catch. They also provided an FFP permit renewal reminder.

The 3-year cycle resets in 2027. So if a vessel intends to fish in 2027, they must renew the FFP prior to that. NMFS has also received an application for an EFP from Seashare and Glacier Fish, and the council will receive a presentation on that.

They also have an announcement that they will be selecting a new IPHC Commissioner to replace Richard Yamada. They currently have nominations under review, but they have the intent to select one by December 1st.

They also provide some background information on the AFA inshore processor permit authorization framework, as well as a summary of comments on the council's cooperative reports. They've also included the tribal engagement summary in the B reports. Sometimes that's a separate posted item, but it's in the B report, the B2 report at this meeting. They also have some marine mammal updates and then staffing updates, including reassignments, new hires, and departures. And one particular reassignment is since mid-August, Dr. Jamal Moss, the Deputy Regional Administrator, has been performing the duties of the Alaska Fisheries Science Center Director.

And so I am done with my presentation, and if folks don't have questions, I'll invite Jamal up here to introduce himself to you all.

Thanks, Anna. Thanks.

Welcome, Dr. Moss. Good morning and thank you. It's great to be here. I just wanted to take a moment to introduce myself, mostly just to put a face with the name. I only see, I think, one person that I know here, and I'm just really excited to work with all of you and get to know you.

So please grab me in the hallway and chat with me.

Anything you all need from the science directorate, just feel free to reach out and ask me, and glad to help there. And was just going to give you a quick background. So I moved to Alaska in 2003 right out of grad school and started working for the Ak Bay Lab Division of Alaska Fisheries Science Center and was there for about 20 years, mostly as a fisheries research biologist. And then towards the end of my time there, I was the deputy lab director. And then I moved over to the policy side, management side, working with John Kurland as his deputy.

Was really excited to expand my horizons and try to meld the science and the management piece. And so I spent a lot of time there getting caught up on all things management and policy, but that's definitely a passion of mine. So really excited to work with this body and reach out to, you know, industry, communities, and stakeholders and understand your needs. So just wanted to share that that's a passion of mine and really looking forward to our time together. Thank you.

Thank you, Dr. Moss. Really appreciate you coming by to say hi.

Do we need a minute to transition into crab specs? Are we good to go?

We'll start with C2, Bering Sea crab specs.

Good morning, Mr. Chair, members of the AP. For the record, my name is Anita Kroska, Council staff. Today I am introducing agenda item C2, BSAI crab stocks. Harvest specifications.

Today you will be hearing a presentation on the final safe assessments and harvest specifications for a couple of stocks. Those are Eastern Bering Sea snow crab, Bristol Bay red king crab, Tanner crab, St. Matthew Island blue king crab, and rollover specifications for Western Aleutian Islands red king crab. You will also hear some trawl survey results closer to the beginning of the presentation and some overfishing results at the end of the presentation and the balance of the CPT report. This will be presented today, today by Katie Paloff from Alaska Department of Fish and Game. And with that, I'll hand it over to Katie.

Good morning, members of the AP. Katie Paloff, as Anita said. I'm the—. I keep saying I'm the co-chair, but I'm the only chair. So I am the chair of the Care Plan Team, and I'm here today to present you the report from our meeting that we had in September, and we were able to hold this meeting in person in Seattle, Washington.

There we go. Sorry about that. Oh, this is a slide that goes over the timing of management for all of our crab stocks. We're in the kind of middle blue box here that has our large three stocks: snow crab, Eastern Bering Sea snow crab, Tanner crab, and Bristol Bay red king crab that we assess on an annual basis in this timeline. In addition, we have some crab stocks that we do on now bi- bi- or quadrandial— quadrandial basis.

And one of those is St. Matthew blue king crab, and that is an additional stock that you'll see today that's up for specification setting that we do every 2 years. It kind of coincides— that stock is under a rebuilding plan and has been since 2020, and there needs to be updates on rebuilding in every 2 years, so the timing there coincides. We, um, we do have a 1-day virtual meeting in November where we'll do Norton Sound red king crab final specs. The timing of that is just due to the timing of the data that goes into that model not being available for us for this meeting.

All right. So this is kind of a, a brief overview of our September agenda. And so as we've kind of done the last few meetings or so, all the items here that are in black font we'll cover in some way in our oral presentation— in our— in my oral presentation today. Those in blue I won't cover. They are in our written minute report.

There are things that we covered at the meeting. I can take questions like kind of at the end of the presentation if there's any questions on anything I didn't present. I can take questions on that. So as Anita already said, there's specifications for 4 stocks here in addition to some rollover specification for Western Aleutian Island red king crab, and then I'll give you a brief overview of the trawl survey results and then just overfishing updates for the stocks that we don't assess. At this meeting.

So, come on.

Okay, well, sometimes it doesn't like me. Before I get into the survey results, I have the slide up here just to remind myself of a couple things that, that you could— so that you can be aware of them for the crab plan team. First is that we still have crab plan team vacancies. Specifically, we do not have have a co-chair position, and that's something that's ongoing. As you guys all remember, Mike Litzau retired, and they're working on backfilling his position at the Kodiak Lab.

And the hope is that when that is done, that we would have a co-chair. We also have an ADF&G management vacancy. Ethan Nichols, who works for— worked for us in the Dutch Harbor staff office, he took a different position. So right now we don't have anybody in that, that specific seat, but we do plan on filling that hopefully soon when that position is backfilled. And then in general, we've made it clear that we just would love more quantitative expertise on the, on the CPT.

And then I have to get used to not calling it the CPT anymore because we did approve merging it with the scallop plan team. So that was approved, and the new proposed name is crab and scallop plan team. Yeah, we did not come up with anything more creative, unfortunately. But, all right, so I'm going to jump into the survey results.

So the Eastern Bering Sea survey was executed this summer, 349 stations. That's the typical stations that were done. This figure here, all these figures are put together, I will say, by Emily Reisner, who's— who gave this presentation to us at PLAN team and was able to give it to the SSC. So she kind of curated the slides, and then we reduced them somewhat to what you guys will see, so to kind of high level. But if there's any questions on things I don't have still included in this presentation, we can take those.

The total harvestable biomass of crab did go up, as you can kind of see there, since that low point after the snow crab collapse. I think the big takeaway here is we saw a large increase in Tanner crab. And proportionally, we saw an increase in Bristol Bay red king crab. And then of course, we still have some hybrid components of the, the Tanner snow crab that are high this year, and that— but we did see a decrease in snow crab.

We'll get into that a little bit more. So these slides here are typical ones that the survey group has put together, and they show different components of each of the crab stocks and kind of their their trends over time from this survey. This is just raw survey data. And then their change from last year. So you'll see in general Bristol Bay red king crab was increasing in most size and sex classes.

Specifically, we did see an increase in legal males. There's also quite a large increase in juvenile or immature males and females. That, however, was due to one large toe during the survey. So there's some— there's a decent amount of variability associated with that increase in juveniles.

But if it proves to move through the population, it could potentially be a recruitment of a small— at least a small recruitment event for Bristol Bay red king crab, which would be a good sign.

Moving on to Tanner crab. This slide here shows Tanner crab. As you may recall, the state manages Tanner crab east and west of 166. So these slides here will have those designated separately. The assessment is an assessment that does the whole, whole Bering Sea, but we do manage them separately and kind of have different trends here.

So you can see the large— this is mature females on the top here, and then industry preferred males. There's a size delineation there if you aren't familiar with that. You see quite a bit large increase in both the east and west area, specifically for industry preferred males. And we did see quite a few females last year west, and we still, we're still seeing those. Not quite as large numbers but still seeing them.

So very large increase of Tanner crab, not as much in the immature and small, but that makes sense. Some of those have grown and are now are the bigger ones. So, but still good signs for that recruitment event that probably started a few years ago in Tanner crab moving through the population, which is what we want to see.

This, this figure just shows an idea of where the industry preferred males, Tanner crab wise, were caught in the survey compared to the last few years. I did leave this in here because there has been some— I realize the figures on the screen are kind of washed out, so hopefully if you have them on your computer you can see a little bit better. But especially the Eastern Tanner crab, there was kind of a hotspot right there down by the Aleutians, and then that has been— was a topic of conversation during CPT as far as some of the eastern Tanner crab population kind of relying on that, that hotspot. But the hotspots are typical for crab stocks in the survey and kind of something that we always kind of look at these maps and, and have some idea of the spatial distribution of the, the survey catch in order to inform our understanding of the, you know, one number that we get out of the survey data.

So for snow crab, mature females are continuing to increase. A lot, a lot of— oh, sorry. A lot of mature females out there for snow crab. However, there was a large— there was a decline in both industry preferred males, small males, and immature females. The legal male size did increased slightly, is about the same as last year, but not kind of slow, slow recovery here for snow crab.

Not necessarily unexpected because these crabs take quite a few years to get from, you know, the small sizes that we're just seeing in the survey to legal and industry preferred size.

I left this slide in here just to kind of remind folks, one of the things that's been on, on top of our mind with snow crab is that the number of males— so snow crab Red crab and tanner crab, just to remind everyone, have what we call a terminal molt. So when they molt to maturity, they actually stop growing. And basically the last few years, what we've seen is that the number of crab that are molting to maturity at an industry preferred size, or those larger sizes, is less and less. This year it was only about— in the past few years, it's only been about 3 to 4% that are actually getting to those larger sizes. And so the CPT has kind of reviewed a lot of the literature that's come out of Canada and some other places and is concerned that not having large males in the population, not having as many large males in the population, maybe can— there might be a feedback loop where crab are maturing at smaller sizes to be— because they can be maybe reproductively competitive, and that we need large males to get large males is kind of the overlying research that's been done in in Canada.

And so this is something that we've been tracking because we are concerned with, you know, the population. We still might have mature males, but whether we have those that are of harvestable size to sustain the fisheries is another question. Yeah, go for it. Thanks. You may touch on this on the next slide, but just in terms of how the hybrids interact with, with this issue, it'd be helpful then to note if there's any conversation at the CPT or SSC around whether that was the large abundance of females and the lack of over-4-inch males was driving some of the increase in hybridization.

Thanks. Through the chair, Shannon. Yes, that's a, that's a great question. Right now we think that this increase in hybrids that we're seeing that are industry preferred size, kind of larger 4-inch size, is the theory there that we kind of went over at our May meeting was that it's likely due to the fact that when the snow crab did collapse, the hybrids that were there that were small crab were able to survive because they didn't have any competition from snow crab because of the snow crab collapse. However, there's a lot about the hybridization and the mating dynamics that we just don't understand, and there is some concern that right now there's— I think our— I have a slide further down, but I think for every snow crab female there's 85 females to every one snow crab male that's of large size.

And so reproductively, I imagine— and there was no evidence in the survey that those females didn't— they all had full clutches and appeared to be mating. So most likely, we— I mean, we don't know yet, we don't have a way to look at that, but most likely some of those females are probably mating with Tanner crab, and there's probably there may be more hybridization in our future. I don't think it's something that's probably going to go away. We don't really understand if hybrids are as fit as the, the snow crab and tanner crab stocks. Tanner crab seem to be doing really well, so that doesn't seem to be problematic.

Snow crab, we kind of expected this slow increase. They wouldn't recover really quickly because of the collapse, so we don't necessarily have evidence to support that the hybrids are negatively impacting the snow crab stock, but it's, it's without really understanding the mating dynamics and overall fitness of a hybrid, it would be hard to know, you know, who's being successful in mating right now and what that the future of kind of all three of the stocks looks like. So there's a lot of questions there, and the CPT did really highlight that there's a lot of research that we need to understand, some of which can be done and, um, in a lab-type environment by bringing some hybrids back. And that's begun already from this year's survey. The NOAA, uh, lab, the NIMS lab in Kodiak, brought— was able to bring some hybrid crab back, and they're already starting some of that.

And then there's some other projects that are, I know, are being proposed as far as like through NPRB funding and research like that, that it might be coming up in the next year. So I think there's a lot of questions that we need to understand. Also just understanding how how much of a— a lot of the genetics related to these crab too, and having a better idea of hybridization. Thanks. And, um, Paul, um, one more question though.

And do you know, um, I wasn't able to listen to the full CPT and the SSC. Was there any effort to try to prioritize some of that research and work, um, rather than— because it does seem a bit overwhelming in terms of all the things that all the areas of uncertainty, and I'm just wondering if there was a collective effort to try to rationalize how we approach that, or if it's more ad hoc and, you know, opportunistic. Through the Chair, I'm trying to recall our conversations. We did list, like, a lot, you know, a number of areas that we felt like research was— research should be prioritized at CPT. I don't think that we prioritized that further.

I mean, there's quite a few areas in there. I think that there's a few folks— we had a really extensive conversation about hybrids last May at our meeting, and in that one, in that meeting, we really looked at everything that we do have in hand, like, well, here's the survey data, here's our fishery data, what can we learn from what we have in hand, and then what do we need to understand more? And so from that conversation, I feel like we did prioritize some of this understanding mating dynamics, survivability, like things that maybe we can do in a lab environment, or we can do a little bit more easily than actually being— you know, it is, as you know, it's expensive and time-consuming to be out on the water doing a lot of these and hard to sometimes make those observations. So what can we do in a potentially in a shorter term in a lab environment would, would probably be some of our priorities that we did kind of talk about. But I think it mostly was in that May, May CPT conversation.

I don't think we brought it up again at the this in the September. Thank you. Paul?

Through the chair, thanks for, for your presentation thus far and for your, your diligent management of the CPT. Um, I, I was just kind of curious, sort of back to that, to that same sort of line of discussion. Um, there's a larger amount of snow crabs that are sort of maturing at that terminal molt than a little bit smaller sizes. Kind of over time, how—. Was there discussions, or are you familiar with research that's going on to try and figure out whether there's nutritional deficits or some sort of environmental push that's just— because we don't have a good idea of snow crab aging, so do we have an idea of whether or not the environmental conditions are pushing those smaller sizes and not necessarily just reproductive fitness or whatever.

Thanks. Through the chair, that's a great question, Paul. So we do have some ideas of kind of snow crab energetic condition that have been developed that are currently done on an annual basis and included in the ESP for that stock, the ecosystem and socioeconomic profile. And that's showing that there's no concern over snow crab condition, like their kind of their health and overall ability to find food. And that was a, that was a kind of something that was developed after the collapse.

And when they went back and looked at samples, they saw that, you know, during the collapse they were seeing that they were potentially deficient in energetics. So we were not seeing any idea, any evidence that they, you know, have a hard time with food availability or energetic availability. I think the underlying kind of hypothesis right now is just that, you know, the— when you're making decisions as a snow crab, I guess, I don't know if they really make decisions, but to grow more and not mature or to mature, you know, with the kind of theory is that with the lack of a lot of other large males within the population, why would you get bigger when you can mature and be reproductively successful at a smaller size? So it's more of an, like, kind of reproductive successful— success strategy in the sense that, you know, as a population they want to continue and reproduce, right? And so if you can do that at a smaller size, putting energy into growing is not necessarily beneficial.

So that's the underlying theory right now. It's a little bit harder to do that type of research. It's almost like a lot of the research that they did in Canada was they had they basically chose to leave a— try to leave a larger proportion of their large males in the water. And that was kind of their research, is they like particularly didn't harvest as many of the large males to see if they could increase. And, and over time in their snow crab stock, they did.

So that's kind of— we haven't had that same experiment in our, in our stocks, so hard to know.

Okay, I do have more hybrid slides, so don't worry if you still have questions. I haven't even gotten to them yet, actually. All right, there we go. So the hybrid crab— and for, I think everyone here knows, but in case you don't— so hybrid crab are hybridizations that occur between snow and tanner crab, both kind of C.D. Species.

They are believed to be reproductively successful, although we don't have a lot of Good data on the, you know, reproductive or health of the, you know, next generation of hybrids if they were to reproduce and then and grow hybrid young, but they appear to be maturing and having full egg clutches. So you'll see here that this last year was the first year we saw this spike in all the size and sex classes for hybrids. That is still high, although it's all— all of them are down some from that Well, except for the industry preferred size. The rest are down some from last year, but still pretty high compared to the time series for all these size sex classes. So still something that's concerning, as we've already kind of discussed.

Here you'll see, this is those crab that are larger than 101 millimeters. So this is the industry preferred size for snow crab, and you'll see on the right here that the of the crab that are of that size, the majority of them are Tanner crabs. A Tanner crab is the blue and the green here, but then the yellow is snow crab and the red is hybrid. So this year compared to last year, there's actually more large hybrid crab, well, 1% more than there are snow crab. So that is something that is concerning and also something that was a large topic of our conversation, both at CPT and SSC.

And yeah, so something that we're kind of watching. The other thing here is if you look at where these hybrid crab were found in the survey, you'll see this is a map from the survey, kind of the same hotspots of the survey stations. You look on the left is the 4-inch male hybrids, on the right is the 4-inch male snow crab, and then in the middle is the industry preferred size for Tanner crab, which is a little bit larger. And you can see that where the hybrids are found, there's, there's some overlap with some snow crab, but then a lot of overlap with, with the Tanner crab there.

So, so where did we land with hybrids? We primarily discussed them some in our survey conversation and then some in the conversation of snow crab, which is probably what might happen here today too. It happened at the SSC just because of the way they're classified in our legal terms, which I can get into in a minute. The CPT did encourage that any additional data that we can collect on the survey— right now they're— they collected weights for hybrids to have a better weight-length curve for hybrids. Currently, we do not have much information on hybrid maturity and what size they're maturing at, so we encourage that collection during the survey if possible.

So just to kind of refresh everyone's memory where we landed in May, we had quite a lengthy hybrid topic at our May meeting, and we recommend that right at this time we weren't recommending putting them in either the snow crab or Tanner crab assessment models just due to the— just not understanding the dynamics of hybrids and those stocks. Those two models are pretty insensitive to hybrids with only having one year where we saw this spike. Spike. Instead, the CPT recommended continue tracking them in this, in the survey, like we saw here, and then, you know, potentially having further conversations if needed. And then specifically in our minutes from this meeting, and these are actually found in the snow crab section because we didn't have a dedicated hybrid section, and this is what, like, you were referring to, Shannon, as far as research.

We had a lot of different topics that we said should be high priority, but, you know, life history distribution, movement, genetics. I mean, that kind of is everything, but we really do need to understand them in order to move forward. We also recognize, and this is a struggle right now, so in our legal definitions, Tanner crab are defined as crab that have two red eyes and an M-shaped mouth. And so all other crab that are landed legally have to be, have to be one of the kind of C.D. Species, and if they don't have two red eyes and an M-shaped mouth, they're not Tanner crab.

Therefore, kind of everything— most of the hybrids get lumped into the snow crab as far as a legal definition and IFQ when it comes to rationalized— the rationalized fisheries. So we— the CPT did recommend that it'd be useful, and we talked some with SSC about this, to really understand, you know, if we have more information on hybrids and understand more if there are separate You know, can we separate them from snow crab? Should we manage them with snow crab? If—. Are there other like policy and regulatory pathways that we need to fully understand and kind of flesh out in order to move forward?

I think at this time we really do need more information before we move forward, but we didn't want to get to a point where we had the science and then we had to wait for policy to catch up. So we wanted to make folks aware that we should be thinking about these things kind of at the same time so that when we have science that potentially we can move forward. We have a next step. So we made a point of that, and we did present and talk to the SSC about that. So with that, that's my last slide for the survey.

But I— yeah, so I can take some questions. Thanks. Sorry, this will be my last question on hybrids, but it's a— I mean, as you know, it's a really huge opportunity for, for a lot of stakeholders in the crab fishery. But also a lot of uncertainty. And I do appreciate the recommendation, and hopefully the SSC looks at that as well.

I'm just wondering if there's any discussion about the value of getting some additional fishery-dependent data, because it seems like there's an opportunity to be able to, you know, be trying to understand a little bit more about these hybrids during the season. I mean, even Aside from all the biological questions, there's some market questions about infill. Do they fill in early like tanners or later like snow crab? Where are they? And those types of things.

Was there any conversation about that in the CPT? Through the chair, there wasn't that specific conversation about that at CPT. We did have some conversation about where they are during the fishery versus the survey because I think I have a slide under snow crab, but the— this last year the state did have a— we added £100 million to the snow crab tag with the idea that we would encourage the targeting of hybrids. We had kind of put an idea of like, here's where the high hybrid density for the survey was, like encouraging folks to look there. And then anecdotally, what we heard and what we saw in the data that we do have from the fishery was that the hybrids weren't really there in high numbers during the time of the fisheries, either for, for Tanner or snow.

So, and then it seemed like quite a few of the hybrids that we did catch were actually caught during the Tanner crab fisheries, not during the snow crab fishery. And that's some— somehow sometimes due to— if you look at that overlap slide, depending on where folks in the snow crab fishery went to fish, if they went further north, there were less hybrids there. So we do have some of that anecdotal information from our fishery data. We didn't really discuss that much about like what other information or what further we could utilize fishery-dependent data necessarily.

Thanks, Mr. Chairman. Thanks, Katie. Can you help me with in the second bullet what the word CHELA means? Oh yes, sorry about that. The—.

So the way that we determine kind of Ctenocetes crab maturity is their larger claw on the one— on their one side is a— it's called a chela. So we take a measurement of that large claw, and the proportional measurement between that large claw and their body size gives us an idea of if they're mature. So when they mature, they develop a really large claw on the one side, and well, on both, but one side is usually larger than the other. And that's the data that we're collecting to determine maturity for male crab. So for females, we can look and say, oh, they have a lot of eggs, they're mature.

For males, we're looking at, did they develop that really large claw that they use for mating? That's what that's called, a chela. It's a chela height. So sorry about that, it's a technical term. I should have defined that.

Craig. Thank you. Through the chair, thanks for the presentation. Following up on your last bullet point there on this slide, does the CPT intend to pursue that research, or do they need specific direction from the Council to continue along that path? Through the chair, great question.

So the CPT itself doesn't do research. We prioritize, you know, what we think we need to do research on. I will say that Right now, I know that there are folks that, you know, there are some hybrid crab in hand in the Kodiak Lab that they're starting some work on. I know of at least one study that is being submitted to NPRB with a number of different folks, I think mostly NIMS, looking at some genetic— developing some genetic panels. So I think there is ongoing research right now at NIMS for some of this.

Or people that are in the process of that. I think it would be, you know, great and to make sure that it's, you know, hey, this is a research priority, like understanding hybrids are a research priority for us, and we've made that clear. But I think elevating that doesn't hurt to elevate it to the council level too. I mean, that's why we've included it in our presentation, is to make sure that everyone knows that this is something that we do want to to elevate. There will be, as you, as you know, there were some disaster declarations for snow crab.

A lot of those, the research funding has already been allocated, but there is one that's going to be upcoming. I don't remember for which season. I think it might be '23-'24. And when that comes up, there potentially could be some research money there. It's designated for snow crab, but right now the way hybridization is is happening, it's affecting snow crab, and it's directly related.

So potentially could be some research monies there for folks that have other questions to utilize. And I think that would help both our understanding of the snow crab population and our understanding of the hybrid population, because I think that's the big question for a lot of us with hybrids is, is this evolutionarily beneficial to snow crab to have this hybridization? Does— is it helping them, you know, weather these ups and downs in their population. And then there's some folks that are, you know, saying, is it, is it harmful for snow crab to have all these hybrids? And that's not a, that's not an easy question to answer right now.

We don't have enough information to say, you know, is it good or bad? And I think that those are larger questions that would be great if we could have better answers on, or at least understand more about the dynamics between all the stocks so that we could try to answer them in a more educated way.

All right, I'll keep going.

All right, so the way of the rest of this conversation goes is I'll go through the stocks that we have for final specifications. I'll start with Bristol Bay red king crab, Tanner crab, snow crab, and then St. Matt's. So I, I'll kind of— I just have a few slides for each of these stocks. I'll go through and then I'll pause after each stock in case there's any questions.

Questions. So Bristol Bay red king crab and Tanner crab, you'll see, or if you looked at the, the CPT report too, you'll see that we do have an ESP for those two stocks, and it's just a report card. I left the slides in here to kind of highlight some of the take-homes from that. In general, I'm sure I'm telling you guys things you already know since a lot of you are familiar with the recent ecosystem conditions, but there was Bristol Bay was a lot colder this year. The summer temperature was the 4th coldest in the 47-year series— survey series— time series.

A lot of the females had delayed their molt-mate cycle, which is something that we do see when Bristol Bay is colder. The area occupied by males and females was above average in the summer. In general, Some of the ecosystem concerns that we've had for Bristol Bay were less this year because of those colder temperatures. So that was a good sign in that sense of potentially good conditions for Bristol Bay red king crab within, within Bristol Bay. As far as socioeconomic considerations for the stock, the total effort for the fishery increased relative to the past season but is really below the post-rationalized average, which is expected expected.

This is a stock, as you, as you may recall, there was two seasons where we had closures for Bristol Bay. Um, I'm not even going to try to remember, '21, '22, I believe. And so after that, that was around similar to when snow crab collapsed. There was quite a consolidation, so less folks participating because of the strain on just crab fisheries and stocks in general in that industry. The Fishery CPE was very similar to the previous year, and the ABSC, Alaska Bering Sea Crabbers, does a skipper survey, and we utilize that information both in our ESPs and then just for contextual information in our conversations with CPT.

And most of the skippers felt that there was consistent with having a higher fit— there was higher fishery CPE, an increase in perceived abundance, and 81% of the captains reported seeing 10% increase in legal mails, which is what we saw in the survey, that there was more legal mails out there. Yeah. Heather. Thanks, Mr. Chairman. Katie, do you know how many skippers participated in the survey?

Where's Corey when I need him? Corey went on the record during public comment in the SSC and did say I'm not going to get the exact number. I want to say there's— there is about 35 or so skippers in the fishery, and I want to say the number of people that participated were in the high 20s. So it was a pretty good percentage of the folks that participated. They tend to have pretty— Corey does a pretty good job of eliciting— Corey Lesher from Alaska Marine Sea Crabbers— for that participation.

And I want to say for all of them— oh, look at Anita has notes for me. 29, 29 Of the 35 vessels responded. There you go. Thanks. And my second question is, do any of those vessels have observer coverage?

They would, but I don't know the proportion of that. What proportion of those have observer coverage? But they would, yeah.

Okay.

I can get back to you on that. Bristol Bay red king crab is one of our Tier 3 annual stock assessments. It's in our, our GMAX modeling framework that we've used, and it's been that way since 2018. Both an increase in males and females. The mature female biomass and abundance is higher than recent years and meets— the state of Alaska has a threshold for females in their harvest strategy, and we met that this year.

I think the big takeaway from the survey data here is that If you look at the kind of size, size is on the y-axis there in those graphs and year on the— I mean, size is on the x-axis, sorry, and year is on the y-axis. If you look here at the most recent year, you'll see this kind of bump at about 100 millimeters, and that's that increase of recruitment that we potentially are seeing. Like I said, it was due to a kind of a hotspot tow, but could be some potential recruitment moving into the population. But in general, we haven't seen good recruitment, and that's what's kind of driving the then the kind of slow increase but not a large increase in Bristol Bay red king crab.

So there's, there's hopeful hope that next year's survey will also show this crab and we can see some recruitment moving through. The model that the CPT author and associate endorsed is a slight improvement to the previous model, and it also does— you'll see on the right is mature male biomass trend. It is trending up slowly for over the last few years. So with that slow trend in mature biomass, you see an increase in OFL there that we're recommending compared to last year. And as, as apparent here with the total catch value, total catch is less than the OFL, therefore overfishing is not occurring for the stock and did not occur last year.

The buffer considerations for this stock are 20%. They've been that way for 5 plus years. There's some ecosystem considerations for the stock. They are less this year, but just reminding everyone that even though the ecosystem conditions are this year, those crab that are existing in Bristol Bay growing, molting, they've, you know, had the ecosystem pressures for the last few years too. So just one year doesn't necessarily mean that we're going to see awesome recruitment.

In every year, it means that we need, you know, a couple years of better conditions. And then just overall, there's, there's some other concerns we have for, for this stock. And so we're not recommending changes to that buffer consideration for the ABC, and that leaves a resulting OFL of 7.13 kilotons and ABC of 5.7. So that— and that I did add in these slides, all the slides here with specifications, I did put that the SSE agreed with our recommendation here. So I think that's all I had for Bristow Bay unless you guys have any questions.

Thanks, Mr. Chairman. Thanks, Katie. When I was waiting in line for coffee this morning, I saw the paper and it said that ADFG had already published the specifications. Are you going to talk at all about that and how it relates to this, or we just ignore that? I'm not.

So typically we don't discuss the— what we approve here on the federal side is the OFAL and ABC, and then the state determines TAC based on our harvest strategy, which is slightly different than the way the specifications are done. And then we release those. Usually we wait to release those until these have been— the past few years we've waited to release those until those have gone— these have gone through the council. But this year, due to the timing of the fishery, it starts October 15th. We had conversations about releasing them after the SSC had endorsed and approved, since typically the council doesn't go against the SSC recommendations.

So those did come out yesterday, and there is— I think at the same time that we're meeting, there's going to be an industry presentation where the ADFNG staff will explain those TAC values and how we establish them to the industry. It starts at 9:00 today, actually.

So, all right, keep moving. All right, Tanner crab. I think the takeaway for Tanner crab is they're doing really well, which is great. We saw that from NIMS trawl survey results for the entire East St. Lawrence Sea. On the top there, the, the purple is male Male crab, the blue is female crab, and then the yellow— that's really hard to see— is industry preferred males.

We saw an increase in Tanner crab males specifically to higher levels than we've seen since 2000. We're seeing this year class— the figures on the bottom kind of show us this year class moving through the population, which is a good sign. Overfishing is not occurring for this stock, and the health of the stock is much higher than our minimum stock size threshold, so the stock is not overfished. The assessment author has been working on transitioning the stock to GMAX, so we saw kind of the bespoke or current model and a GMAX version. We didn't— weren't quite ready to adopt the GMAX version, so we kept the similar model that we've had the past few years.

But good signs for Tanner crab overall. Good that this recruitment event is moving through. However, we're still looking to see, you know, we're not there weren't a lot of smaller crab in the survey, so kind of fishing on this recruitment event could potentially see some cyclical changes after this recruitment event moves through the population. So the model that we chose here is highlighted in this box. It's similar to the one we've used the last few years.

Both the SSC and CPT agreed with the author on that and agreed with a 20% buffer for this stock also, which is similar to what we've had the past few years. In general, there's some considerations there, one of which is similar conversations we've had for snow crab, just kind of unsure is what the best metric for reproductive potential for the stock is. Continuing concern over, you know, our current harvest control rules potentially estimating high, high removal allowances compared to potentially what the stock can handle. And then there was a like we've mentioned, there was this— we are seeing these— this recruitment pulse move through the population, which is a positive point there. So yeah, with Tanner crab, good news and continued work by the author on transition to Gmax.

Any questions there?

All right, I'll keep going. You can always— we can always swing back if there's questions. All right, snow crab.

Snow crab is a stock that we do have an ESP for. So here's kind of some highlight of those. The ESP indicators— I didn't mention this during Bristol Bay, sorry— are kind of separated out into predictive and contextual. For Bristol Bay, none of them were predictive. Predictive just means that there is a statistical relationship between the stock and, and these different ecosystem considerations.

And this refers to, I think, Paul's question earlier talking about like kind of the health of the snow crab. One of the things they're monitoring is energetic condition. And that remains elevated in 2026, suggesting high survival due to the fact that they have enough energy, so enough food and things to move, to grow. Juvenile snow crab, there was definitely the increased cold pool and kind of cold conditions were beneficial to snow crab. The spring sea ice extent increased substantially in 2026.

And is above the time series mean. So high CAIS coverage promotes, you know, more primary production, potentially could be better conditions for snow crab. Sorry, there is some concern right now that there's a pretty strong female skewed operational sex ratio. It looks there, it's like, as I mentioned, 85 mature females for every 1 crab that's 95 millimeters or larger. 95 Millimeters, that size there was chosen because some of the research coming out of Canada shows that's a little bit better indicator of functional maturity.

So even if crab are mature below that, they may not be as reproductively successful. But we didn't see any indication of what could be happen— what could happen in reproductive failure for crab stocks is you have females that mature, females that aren't, that don't produce full clutches of eggs. So the idea there is if they're not able to interact with or find males, that they don't produce the eggs to mate because they, they don't think they're going to be successful in mating. We're not seeing that. We're seeing a lot of these females that have full, full or pretty full clutches.

Could be a lot of assumptions there about hybridization, who knows, but, but that's not an indication yet that there's any sort of reproductive failure. And then there's a couple other things that we do track here as far as bitter crab disease and Pacific— it looks like Pacific cod predation have remained below average in recent years. The center of abundance for snow crab males was near average. And then we've already mentioned that just kind of this— the size at maturity is really— has been trending down the past few years, and that is concerning for us with snow crab. And then there is some socioeconomic or fishery-informed information here.

This is also another one that we do have a skipper survey for. But in general, during fishery, the sea ice did affect the fishing behavior a little bit for this stock. Fishery CPE and total effort is still below average since the post-rationalized time series, which is to be expected. About 50% of skippers reported a greater than 10% increase in perceived abundance of industry preferred males, and about 47% of those noted slightly more than to a lot more hybrid crab than the previous season, which would be expected, I would think, if they were seeing those through the fishery. Yep, go ahead.

This question might be better for Science Center staff or NOAA Fisheries, but do you know why the information on processors isn't included in the socioeconomic component given their role in the fishery? That is a great question, and I'm not sure of the answer. I can get back to you on that though.

I know there was some delay in some of the— there's some delay in some of the socioeconomic information as to when we can get it. And so because of that, some of it doesn't get included in kind of our highlights because we don't have the current year's information. But that is something that we're kind of working through a little bit more.

Yeah. And so this— I kind of already briefly mentioned this, but just to sum up the snow crab fishery from this last year, 80— there's a couple I know these are hard to read, but there's bigger figures here if you wanna jump back to our catch presentation during the CPT presentation. But what ADF&G's, in their tax setting process, had a 9.3 million pound tax for snow crab. And the idea there was that was a snow crab specific tax plus a 1 million pound hybrid component. This hybrid opportunity, we encourage targeting in areas of high hybrid abundance.

From the survey. And so that's the top right figure there that has the kind of light green boxes. And then in the second figure, that's the red box is like where we saw a lot of hybrids in the survey. That observer hybrid encounters in that middle box is where the, the data that we do have from observers was encountering more hybrids. And you can see that wasn't in that box.

So that was anecdotally what we heard from, from the fleet too, was that those that did go look for hybrids in the box that they weren't in there during the time of the fishery. There was an estimated hybrid catch that was higher than the previous season, about 678,000, so about a little over half of that million, but most of it didn't come from that box, and a lot of it did come from snow crab that were— or hybrid crab that were being harvested during the, the Tanner crab fishery, not necessarily directed snow crab. So with this, in the context of this, currently the way that the tax setting process is done, ADF&G can take into account hybrid components. Specifically, the fact— the reason, you know, is like with the fact that most of the hybrids are being classified as a snow crab due to the regulation, the legal definition of Tanner crab, we can take that into account in our tax setting Conversations, as long as we set TAC that's below the, the ABC, we have the ability to, to do what we did last year in the future if that's necessary or needed or found to be appropriate for hybrid management. I think there still are a lot of conversations that need to be had about hybrids, and that was some of our conversation that we had with the SSC as to best steps forward.

There was a lot of conversations about what groups of folks we need to get together to have those conversations, what the best next steps were. And so I think those are things that we're kind of ongoing working on right now.

Heather, go for it. Thanks, Mr. Chairman. Katie, um, does the average crew member— are they able to identify, um, hybrids? Through the chair, that's a great question, and I don't know that per se, um, Maybe we'll have some public testimony where we can ask folks a little bit more on that. I will say that it's not straightforward, and especially my impression from a lot of folks when they're sorting on DEC is a lot of times they're sorting by size and then kind of secondarily looking to see, you know, whether there's hybridization or not within that.

It seems like chatting with the conversation we had at our industry symposium, which we have at the end of our CPT week that BSFRF and ABS put on, was that most the time that the processors are accepting the hybrids alongside the snow crab. They don't necessarily have to be separated out, but that it's, it's sometimes hard to tell what, what are hybrids and what are snow, especially on the back deck of a boat.

Okay, so to add to more complications, we currently, for our snow crab assessment, it has been a stock that we've assessed in a Tier 3 modeling framework. However, we have right now, currently right now, and as of last year, don't have a stable assessment assessment model. We're having issues with that model converging. So what, what we ended up using for management last year and what we're recommending this year is this kind of fallback smoothing of the survey data to get an idea of appropriate specifications. So that's what we recommended here.

To the right just shows the survey trends for different components of the male stock. So the blue is morphometrically mature males. So morphometrically mature, as I was Heather about the kilohigh measurement, that means those crab, we're measuring them and we're saying that they're mature based on the measurements of, of their large claw to their body. And then the other two designations there are just size cut lines of, you know, 95 millimeters is what the current Canadian research deems mature, and then our preferred males are the, the industry preferred size. So there's just the 3 different trends over the survey.

We're using, as we've been like recommended by, by the SSC, morphometrically mature males as the currency or the, what we're basing our management on. And we did this smoothing of that and come up with an OFL and ABC based on that. There was some conversation at CPT on appropriate buffers on this OFL. Last year, that was a 40% buffer. The CPT had put forward an increase of that to 50%.

Just earlier this week, the SSC reduced that back to the 40% that we've used previous year. And that's, I think, the next slide here that I have kind of goes into that a little bit. Some of the CPT's reasons for having that Higher buffer were related to just really under the fact that these males are molting at smaller sizes than industry preferred size, and they're, you know, they're not growing into that larger size. This kind of skewed operational sex ratio was concerning for us and the what, you know, potential future of the snow crab population. And then in general, the number of large crab out there is still pretty low compared to the entire time series.

And the CPT really put some— put stock in that Canadian research that's showing that having large crab in your population will help to create more large crab. And so we just have concerns over overharvesting of large crab within the stock. And then, of course, as we've already mentioned, hybrid considerations are complicated by the current status of the snow crab stock. So, you know, we did have some conversations about hybrids I think some of the concern from the CPT was, you know, allowing right now because of the regulations, allowing, you know, potentially having hybrid catch added to snow crab catch, which could potentially just result in more snow crab removals. So that was concerning for us, and that is kind of part of the decision-making process that ADFNG had last year too, is how much could you add to the tack of snow crab and not be detrimental to the snow crab population.

Because I think we all want the snow crab population to continue to recover and not be detrimental to that. So the resulting, the resulting decision by the SSC was to keep the 40% buffer. They agreed with a lot of our concerns but didn't feel that they were elevated from, from last year. And so I think that's all I had for snow. If you guys have any questions.

Great. So the last stock that we have final specifications and a full SEIFOR is St. Matthew Island blue king crab. As I already said, this, this is an assessment that is in, that is in our GMAX modeling framework. However, it is a Tier 4 stock, just meaning that we do not have as much specific life history information, so it's a little bit more of a simplified assessment. Assessment.

The directed fishery has been closed since 2016-2017. We have quite a bit of new data that either in May or September went into this model because it is an every other year assessment. We have new fishery data for 2 years and survey data for 2 years. ADFNG does do a pot survey in this area every 3 years, and we did have a new data point for that in 2025. So, so that's helpful.

The author explored a base model and then a model that uses what we call a model-based index from the Eastern Bering Sea trawl survey. And the reason for that is a few years ago, the, the trawl survey dropped the corner stations. They were doing higher-density corner stations around St. Maps and the Pribbs. Those were dropped just due to efficiency and time. And, and so now what we have is an index from the survey that accounts for those stations not being part of it by using a model to estimate— interpolate the survey information instead of just the current design base, which would be like an— if you're familiar— an area swept.

So what you see there on the right, the black dots and lines are the raw survey, the design-based survey information, and then the lines that are fit to that are the design-based. And you can see, especially for recent times, pretty close correlation. If anything, a little bit less variability. And that for St. Matt's, we definitely have a lot of hotspot where the survey will catch them or they won't. And the design-based puts a pretty high amount of variability on that data point.

But the model-based index can kind of reduce that and say, oh yeah, we didn't expect to see crab there. And even though we saw crab there, you know, that doesn't happen every year kind of thing. So this is seen as an improvement for the stock and a better way to monitor it. So the SSE and CPT did endorse that model that includes those model, the model-based index. However, it did— St. Matt's is slowly trending up.

This is the first year for the status for '25-'26. The stock is above 0.5 and 0.5 5 is our overfished threshold. So the stock is technically not overfished. It's not rebuilt because it needs to reach the MSY or 1, that ratio needs to be 1 to be overbuilt, but it is not overfished this, this for this past season. So, you know, slowly, slowly increasing there.

Did see some signs of potential, a little bit of recruitment coming into the stock and then the survey data. So overall, no large changes here for St. Matt's. We're recommending these specifications for the next 2 years. The SSC did endorse that model. We currently have a 25% ABC buffer on this stock, a little higher than our other stocks due to the fact that it is in a rebuilding plan and also just the Tier 4 stock here uses a lot of borrowed life history information from other king crab stocks because we don't have it specific for St. Matt's.

So, just more uncertainty in, in how well those approximate the actual life history. Processes for St. Matt's. So we've always had a slightly higher buffer than, than some of our other Tier 3 stocks. Heather. Thanks, Mr. Chairman.

Katie, that last bullet point about ecosystem concerns, um, is this about the potential El Niño impacts or because it was colder this year than it has been? Through the chair, Heather. Yes. So that's less to this year and just over time. The condition— blue king crab are really more of a cold water king crab species.

And just in general, the trend— I mean, it was colder this year, but the trend of more warming temperatures has kind of, we think, contributed to the lack of recruitment that we're seeing there. So even though it was cooler this year, there's still, you know, like I said, one cold year is not going to drastically change those recruitment trends, especially for king crab stock I mean, these— before we're seeing these crab in the survey, they've already been in the environment for 7, 8 years. So, you know, they've already had a lot of the, the potential warming that we've seen over the last number of years. Cooler temperatures could potentially be good for future, you know, recruitment, but the— for this stock specifically, we're just concerned with just in general warming that has occurred.

Yeah. Alright, and then this is my last slide, but I can take more questions if there are any. We have one stock, Western Aleutian Island red king crab. It's one of our Tier 5 stocks, which means we don't have a lot of information.

We are rolling over the specifications for this, so those are the specifications there that have been in place the last 2 years. We're just encouraging those to be rolled over for another year, and we had to do that officially. The total catch mortality for this stock was actually zero this year. There's no directed fishery because the stock's pretty low, low size, and there was no bycatch mortality. So no overfishing did not occur.

So the other stocks here that we do not do assessments for in this cycle, both the Privolof Island golden king crab stocks and then Pribilof Island golden king crab and Aleutian Island golden king crab. We just assess overfishing status at this meeting because the crab year goes from July 1st to June 30th. So this is the time where we can say, you know, what was the total catch, total catch mortality for this last crab season and compared to the OFL. Overfishing did not occur at any of these stocks, so there's no concern of that, but we are required to report on that. And so with that, that was our last slide.

And just like to thank all of our CPT members, CREB assessment authors, everyone that came and participated in our meeting. And we had some great conversations with folks on hybrids and different things. So we appreciate that. And it's like collaborative effort for a lot of these questions that we have. We need everyone's, you know, voice at the table.

So we appreciate that. So I can take any other questions that you guys might have.

Chance? Hey, sorry, I, uh, and thank you so much for the presentation. I learned a lot. Um, I was, uh, wondering whether or not I should ask this question on, uh, in the hallway or right here, so I'm just going to shoot for it. Is, um, regarding snow crabs, I guess specifically, is there a benefit or has there ever been any kind of like a reverse slot management method to keep larger crab in the water?

Through the chair, that's a great question. Not—. No, I guess the basic answer to that is no. I don't know if that's something that's even— that's been considered necessarily by the fleet or by us at ADFNG, but right now that hasn't been done. Yeah.

Thank you so much. Appreciate it.

I'm a little rusty. I should have made an announcement for public testimony, so we will give people a minute if anybody wants to sign up. I don't see anybody right now, and I don't see Corey in the room, who I believe is at the ADFMG meeting, so Making sure there's nobody online.

Okay, I don't see any. Um, does anybody have a motion? Landry. Thank you, thank you, Mr. Chair.

Uh, I believe the motion should be up on the screen shortly, but I can go ahead and start. C2 BSAI crab harvest specifications. The AP recommends the council adopt the 2026 Crab Safe Report as well as the 2026-27 OFL and ABC as recommended by the SSC for Bristol Bay red king crab, EBS tanner crab, EBS snow crab, and the 2026-2027 and 2027-28 OFL and ABC as recommended by the SSC for St. Matthew Island blue king crab. And lastly, the rollover of the OFL and ABC for Western Aleutian Islands red king crab for the year 2026-2027. With that, I can— or my rationale is— oh, sorry, I'm rusty too.

Yeah, we have a second. Go ahead. Thank you. I want to thank the CPT and SSC for their diligence and work to prepare these recommendations. I would also like to show appreciation to the CPT and SSC for the recognition of the continued high abundance of hybrids in this year's survey and the challenges they continue to create.

And lastly, I'd like to stress the importance that these continued high abundances of hybrid crab create in both assessment and research challenges but more importantly, the opportunities for increased harvest opportunity and economic value back to the industry.

And with that, just the continued discussion of next best steps with hybrid crab. With that, I'll take any questions. Thanks, Landry. Questions?

Any amendments?

Any comments?

Okay. Is there any opposition to this motion?

Not seeing any. That motion passes. I don't believe there's any other motions on this. All right.

We will move into D1. Um, do we need a minute to switch gears?

Good morning, Chair, members of the AP. This is Sarah Marinan, Council staff. Presenting D1 staff report with me is Adam St. Saviour, and also available for questions for this agenda item is Doug Duncan with NIMP. Who's here in the room, and Ben Jevons with ADF&G, who's available online. We're going to provide a staff presentation of the charter halibut permit use and angler effort discussion paper.

This discussion paper is attached to the e-agenda. Hopefully you've had a chance to review. There's also an appendix attached there that is a reference for two of the data requests in the paper. Earlier this week, we posted the report from the Charter Halibut Management Committee That's available under this agenda item. They reviewed this discussion paper last Wednesday, and so there are some recommendations provided there.

So I'll— we'll present the staff report on the discussion paper, and following that, I'll provide the committee report as well.

There's a short history of action here. The charter committee proposed this discussion paper, many of the components of it, and the AP added one component of it, the CQE data request. The council tasked this in October of last year.

The committee tasked it in October, and the council took it up in December along with additional data requests from the AP. AP. This paper is intended to provide useful context for annual management measure— the annual management measure process, also 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, and it doesn't direct specific action, although next steps may be considered after the review. So as we go through the presentation, you might be thinking about next steps.

There's 7 data requests that were outlined in the motion, so here they are over the next couple of slides. Note that we reorganized and renumbered these from the council's motion. So the first 5 cover charter halibut permit renewal and retirement, ownership and lease transfer, trends in permit use, angler effort, community quota entity permits, and consolidation under the permit holding caps.

The 6th data request was done by Adam. He'll present this part, and it looks at how much effort would need to reduce to achieve a set of specific and less restrictive management measures, holding everything else constant. And we will explain these data requests more as we work through each one of them.

Request number 7 is another kind of scenario-building exercise, and it looks at how much less restrictive management measures could be if the RQE was holding the maximum amount under the transfer limits, holding everything else constant.

So I have just a couple of background slides, and then we're going to walk through each of these data requests.

Lauren? Sorry, I just want to clarify before— looking at 6 and 7— okay, I think I answered it. So holding constant the most recent FCUI would be just holding the current abundance index forward. So that's for both 6 and 7, that was the considering. Consideration.

That's why they looked at it only under that current level. Yeah, through the chair, Lauren, and we're going to describe these in a lot more detail when we get to them, but I think the intention of the motion was looking at a specific point in time. So really, I think for both of those data requests, we're looking at the charter allocation in a particular year, so the FCY, but also what that translated in terms of the specific charter allocation in a year.

Okay, so some background here to get us started. Since 2011, all charter halibut vessel operators are required to have a charter halibut permit on board. These were issued as either transferable, or there was a lower threshold to receive a non-transferable permit. They're endorsed for a certain number of anglers to be on board. And you can see angler endorsements in Table 2 in the paper.

They also— there includes some types of special non-transferable permits for community quota entities and U.S. Military Morale, Welfare, and Recreation Program. There is a holding cap of 5 permits, although some entities and individuals were grandfathered in above that cap limit. So you can see in Table 1 that there are 529 regular Area 2C permits. 65% Of them are transferable, and then there's some of those special permits, so for a total of 578 permits in Area 2C. In Area 3A, there's 426 regular permits.

70% Of them are transferable, so there's a total of 488 permits in Area 3A when you include the CQE and MWR permits as well.

You can see in, in Table 2, which isn't on the slide, the 6-angler endorsement really dominates in both areas. That means a vessel can take out 6 anglers harvesting halibut. Area 3A has substantially more permits that are endorsed for greater than 6 anglers. So angler endorsement capacity is really a structural difference between the two areas.

Heather. Thanks, Mr. Chairman. Sarah, are there— can a CQE hold more than one quota or permit, or are there 48 and 56 community organizations that hold the permits?

Through the chair, Heather, yes, they can hold more than one. There's a certain number that they can hold. I think in Area 3A it's 7.

It should say in the paper— 6? And 4 in 2C. Yeah, so there's a maximum number that each CQE can hold. We'll go into this a little bit more in, I think, Data Request Number 4 that talks specifically about CQEs, but There's a maximum number that CQEs in each area can hold. They're issued from NIMS free of charge, and each CQE that has formed and requested permits has requested up to the maximum number.

So we will walk through how many CQEs there are that hold permits under that.

Okay, I wanted to provide some summary background as well on the leasing of permits. The council has an extensive, extensive history around considering restrictions on the leasing of permits. However, leasing is still an authorized feature of the program. An operator must have an original valid permit on board a charter halibut trip. However, there's no transfer that occurs through NIMS for someone who's not the permit holder to to use the permit.

Charter halibut permit leasing can include complex business agreements. There could be a civil contract with the agreement, a rate identified, or it could be as simple as one person handing someone their permit for the day. Previous concerns were highlighted around leasing, including the creation of absentee ownership, the risk of latent capacity coming online, and leasing effort. However, permits were issued to business owners. So one of the concerns around restricting of leasing is unintended effects of businesses that might not lease permits, but their operational structure might be based on a non-permit holder using the permit.

So, for example, a charter captain employed in a business that— and the business holds the permit— that person using the permit may not be a true lease, but It would be someone other than the permit holder using the permit. Lauren. Thanks, Sarah. These are considered federal permits, correct? Through the chair, yes.

Are there any other federal fishery permits that are just this loose, like in terms of just a piece of paper that I can hand you and say, go ahead and fish this? Is there any other system that's comparable or similar? That is that simple.

Through the chair, might have to think about that question a bit more. There are other permits that don't have owner-on-board requirements, so like LPs, I don't think there are requirements for a specific person to use. No, what I mean, even just the transfer mechanism, like the, the sheer ability to like hand someone the permit physically and say, okay, you're good to go, like no oversight from the agency or tracking in any of the permit transfer.

I know it's a broad question. I was just trying to wrap my head around it to see if there was anything that was similar or comparable because it's a bit baffling how loose the system is compared to our experience with most fishery permits.

Hmm, through the chair, Lauren, I might have to think about that. I have some examples in my head, but I don't know if they're perfect analogies. So I don't know if I can answer that right now. It's okay. I know it's a bit out there.

I've just been trying to rack my head too. So we can talk about it later as well.

Chance? Hey, through the chair, thank you, Sarah. I have a question, I guess, about your last bullet point here. Obviously, businesses or sole proprietorships with multiple CHPs are hiring people to run their boats to do this. That's not a lease, that's an employee of the business.

How is that— I guess because this is drawn out through leasing, was that considered leasing, or are you just clarifying that in this part of the—.

Through the chair, Chance, I'm clarifying that we don't have a federal definition of leasing for charter halibut permits. There are a lot of different charter business structures, and I think we've had a number of discussion papers and analyses that have looked at restrictions on leasing when the moratorium was put in place. There's a motion that's linked in the discussion paper. The council had originally prohibited leasing, but based on the language that was in the motion, it was not something that could be implemented. Um, so that piece was kicked back to the council to consider it again.

So it has been considered a number of times, but because the permits were issued to business owners rather than the guide themselves, it created kind of a more complicated system of trying to identify the relationship between the business owner and who's using the permit. And I think this is where we've come around in circles on— in other discussion papers is If you wanted to go down this road, you need to have a clear definition of what is a lease and what is the relationship between the permit— the person using the permit and the permit holder. Kind of have 3 entities. You have the business owner, you have the guide, and you have the permit holder. And they might all be the same person, and then it's clear it's owner-operated, it's not a lease situation.

But there's a lot of variations to that. That you need to identify whether that relationship is a lease or not, and then you would need an effective monitoring enforcement situation to show that relationship. So it's not so simple, I think, because of the way permits were issued.

Thank you very much for that. I guess, and that makes sense. So, you know, if I— because surely you don't have to be a charter boat captain in order to run a charter boat business. You can I could have a series of boats and a series of people and a series of CHPs and have that. But because you are saying, just to clarify for myself, because there isn't a clear definition of lease, that is not clearly defined as a normal operational structure.

Or I guess I didn't say that correctly. I apologize. I think I might have answered my own question in my rambling. Sorry. Thank you.

Through the Chair, we do have some more information. On leasing throughout the paper. We have— there's a number of data requests related to it, so we'll talk about this topic more. I just wanted to provide some background on the fact that we don't have a specific definition of leasing. There's some relationships that are clearly leasing and others that are— that are not.

And there's a few ways that we kind of look at this in the paper.

Sarah, I'm sorry, I have a question that maybe this is what Chance was getting at or that is in the paper and I missed, but is there any way to track how many CHIP holders have only ever leased and don't operate a business at all?

Mr. Chair? We don't, we don't have the monitoring to show that because we don't have— because the transfers don't go through National Marine Fisheries Service or ADF&G, so we don't have a clear way to show the relationship between the permit holder and the permit user. One thing that we're going to show in the paper is there's an annual registration process now and one of the questions on that is, Did you receive financial compensation for use of your permit? So that's sort of self-reported leasing.

That was the intention of it, to get at an understanding of how much leasing happens through that self-reported question. So that gives us some sense of it, but because temporary transfers don't go through NIMS, we, we can't specifically answer that question that you're asking.

Okay, a little background on the RQE, the Recreational Quota Entity. This is a nonprofit entity that's authorized to purchase and hold commercial halibut quota share on behalf of charter halibut anglers in regulatory areas 2C and 3A. Quota share held may augment the apportioned pounds of halibut for the charter catch limit for that area in that year, which could then be used to relax the annual management measures. The charter halibut STAMP is the funding mechanism for this entity, and it— that began collecting revenue in 2026. It's my understanding that the RQE received its first transfer of Area 2C Halibut Quota Share in 2026.

This included about 26,000 units of Class C Area 2C Quota Share, which is equivalent to about 1,300 pounds in 2026. I also wanted to highlight the transfer restrictions for the RQE, which are shown on the slide here. They are different for each area. There's total or cumulative limits. There's annual limits.

And limits on the type of quota share that can be purchased in each area.

Okay. So now we're going to walk through each of the data requests. For the first request—. Sure. I'm sorry.

Lauren and then— oh, Monica. Go ahead. Thanks, Mr. Chair. Thanks very much for the presentation.

I was hoping you could give me a little context for why the percentages for the annual limits were chosen for the different areas.

Through the Chair, Annika. So in the development of the RQE, there were a lot of different limits that were considered. I think the CQEs were kind of considered as a model. And there's— the CQE groups also have different types of limits in how much they can purchase.

The annual limits were considered as measures to— in a reaction to thinking about market impacts and how much an entity might buy in a given year. So at the time when the program was being considered, Wasn't sure what the funding mechanism would be or how this entity— whether this entity would have access to funding. And if it did, and if it had significant funding, and it could purchase the 10% or 12% in one year, there were concerns that that might create market disruptions for the quota share market. So the consideration was to slow the— transfers of quota to this entity so it didn't have such a large and immediate impact, understanding that at the time it wasn't— it wasn't clear whether there was going to be a funding mechanism or what that would look like. But I think just as a reaction to the possibility that a significant amount of quota could move from the commercial sector to the charter sector in one year, a range of annual limits were considered.

Lauren? This is just on the theme of like historical context for the recreational quota entity. So how I understand it is that it was a response to a request for reallocation. It was the catch share plan was being questioned and they wanted to— the charter industry wanted to find more access to allocation. So it was kind of like an opening up of the catch share plan and determining a mechanism for reallocating quota, and this was the compensated reallocation model that was developed.

So is it, is it fair to talk about the history of this as like an allocation, a reallocation, like the recreational quota entity was in response to a request for reallocation into the charter sector?

Um, through the chair, Lauren, it is my understanding that The intention was to design a compensated reallocation opportunity.

Yeah. Okay.

Any more questions? Okay. Moving into the data requests. So for the first request, we're looking at renewal and retirement of permits. Renewal, another word for renewal would be registration.

Since 2020, charter outlet permits must be registered annually to be valid for use. And Table 3 in the paper shows for Area 2C, between 31 to 48 of the 529 permits have not been registered each year. For Area 3A, between 27 and 57 of the 426 permits have not been registered each year. Registered each year. For both areas, the proportion of non-transferable permits that have not been registered is higher than the proportion of transferable permits that have not been registered.

In both— across both areas, 34 permits have never been registered.

Chance? Just thank you very much through the chair. I'm curious if there's any if there's any data or understanding as to why those things aren't registered. Is there sort of a— do we know if those people are dead? Do we know, you know, is there any way to know how much of that latent capacity is real or ever, you know, could ever be realized, in other words?

Through the Chair, Chance, I don't know the background on those 34 permits. I suppose at some point there could be an audit maybe looking into those permits if they continue to not be registered. This kind of leads me into my next slide, which is about the retirement of permits. And there isn't a systematic process to retire permits. It's not automatic.

If the permit isn't registered, it's just not valid until it is registered. Sometimes NMFS has been notified that a permit is no longer valid and then effort is put in to establish that that's true. If it's a non-transferable permit, someone's passed away or the business has dissolved and that's confirmed, then they would retire. But this system right now isn't for them to proactively retire permits.

So yeah, a permit would be retired if a non-transferable permit for a non-transferable permit, if the holder passes away, the entity dissolves, or an additional partner or shareholder is added to the entity holding the permit, then it's intended to be retired. But as you can imagine, if someone passes away, it's maybe not the first notification of the family to tell NIMS that that permit's no longer valid. So I would suspect that among those 34, there are some permits that may be intended to be retired, and perhaps at some point they will, but they're not valid for use at this time. So over the course of the program, 25 permits have been retired. You can see that in Table 4.

Lauren? Thanks. It wasn't clear when you spoke about these 34 CHPs that have not been registered, have they been used during that time frame that they weren't registered, or is it confirmed that they are not registered and also not being used?

Through the Chair, Lauren, I didn't look at that specifically. They would not be legal to be used, but I didn't look at the activity for those permits specifically.

Does anyone look at that in the agency? Through the Chair, so there is, A process that OLE goes through for enforcement of CHP. I can't speak to all the steps of that. They get data, specific data run through ADF&G and ACFIN. They have a specific data request where they have certain audits that they do each year on CHP use.

I can't speak to those specific permits. Heather and then Jane. Thanks, Mr. Chairman. Similar to Lauren's questions, I was wondering, is it possible that people are fishing just without a permit, and how would that be enforced?

Through the chair, Heather. Yeah, that would be out of compliance with regulations. If they're boarded by an enforcement agent, which could be state troopers or OLE and they didn't have a charter halibut permit and they were charter halibut fishing, that would be a violation. Do we have any idea how often that occurs, if at all? Through the chair, I don't have statistics on that with me.

Chance? Thank you, Sarah. I'm wondering, it's my understanding, and you let me know if this is true or not, when you use a CHP has to be— the renewal process happens through eFISH, right, which is a sort of barrier of entry to renew that permit. And then in order for it to show up on your logbook for you to actually use it, it's not possible for that to appear as a valid CHP unless that has happened. Is that accurate?

Through the chair, Chance, I think I got your question. So the, um, with e-logbooks, you have to enter a CHP number, and now in the process, if it has to be an accurate number, it has to be a valid number in order to be entered in the logbook, and the logbook won't accept a number that's the wrong number of digits or an invalid number. So it's fair to say that it's not possible for somebody to use an unregistered CHP in their logbook because that value would never populate?

Through the chair, I'm not sure about that. I know Ben Jevons is online and he might be able to answer the logbook question specifically. And also with some of our enforcement questions, we do have Alex Perry here too who would be able to answer those better than me. So maybe if Ben is online, would you be able to respond to the question about valid permits in the logbook? Yeah, so through the chair, so the way the e-logbook works now, we do configure permits from the publicly available RAM file on existing permits.

So any permit that exists that doesn't relate to registration will be configured to the, the business, or the business can select the permits that are in existence, so to speak, to populate into their e-logbook. Prior to going to the RQE program, the charter operator was able to enter, manually type in the number And Sarah spoke to this earlier, that it was limited by the number of characters, so only 4 characters, and those were limited between the 4000 and 5000 series. So it captured a restricted kind of swath of numbers that, that they could enter. And then on the back end, we would clean those data by, you know, comparing it to that table that I was just speaking to. So the current system is far tighter.

I would say this is the first year where we can— where really there's a serious barrier to kind of the questions that have been being asked. However, previously you could enter in a number, didn't necessarily mean it was your permit, didn't necessarily mean it was a registered permit. And then previously on paper, that was kind of open to entering whatever people could write, whatever they wanted in there. We do not compare to registration. We have investigated it in the past, but given the resources the department has at our disposal, we can't communicate with every single individual using a permit that may or may not be registered.

So it's a lot better. CHP data are a lot better now. But speaking to the specific question of could somebody use an unregistered permit? Yes. Could somebody use a permit that doesn't exist currently?

No, because we pre-populate only the ones that are available.

Thanks, Ben. And Mr. Chair, if you don't mind, maybe Alex can answer some of the questions related to the enforcement questions.

Good morning, members of the EAP. Alex Perry, Office of Law Enforcement. So, The questions were pretty similar. I'll go with answering the question that Heather asked first, and that way, Loren, you can follow up if there's any further follow-up information. For this discussion paper, we did not do a dive into the statistics or looking at the number of CHP violations or, you know, encounters of fishing activity without a valid permit on board.

In the past, we have done some analyses looking at like the IFQ fisheries. And so anecdotally, I'll say that, you know, from my recollection going back on those analyses, it's not a very common occurrence that we will have a boarding officer board a vessel and find that a CHP is invalid or there is none, but it does occur.

Any follow-up from either of you?

Thanks, Alex. Appreciate your availability.

Okay, so, Mr. Chair, moving on.

We're on to data request number 2.

So this 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 NIMS, Restricted Access Management, RAM Division. A simple way to think about consolidation or expansion of permit holders is to just look at the number of permit holders between initial issuee and the most recent year. So that's what Table 5 does here. This shows a slight expansion of ownership in Area 2C and net consolidation of ownership in Area 3A.

Table 6 in the paper shows transfer activity from 2011 to 2026 annually, and you can see a, a spike in activity of transfer activity between 2021 and 2022.

As we have talked about a bit now, leasing a permit is not a transfer that's done through NIMS, so 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 CHP, and I included the— an excerpt of the exact language from the application in the analysis so you can see what it says. It's intended to look at self-reported leasing, not compensation for getting taken out on a trip, but for using the permit specifically. So this provides essentially self-reported lease rates since 2020, and we can see this in Table 7. For Area 2C, an average of 17% of the permits the owner reported receiving financial compensation for their use.

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

You can also see these numbers for Area 3A in Table 7. 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 average of the active non-transferable permits are leased compared to the proportion of transferable permits that are leased.

Any questions before I move on to number 3?

Okay, data request number 3 asks for trends on transferable and non-transferable permit use and angler effort. So this is the first data request that required the use of integration of ADF&G saltwater logbook data was merged with data on CHP characteristics. We have some definitions for you here. These are a little bit different than what's typically used in ADF&G NG analyses and what is used in request number 6 and 7, but we show statistics on CHP trips. This is vessel-level trips in which halibut was caught and retained and CHP angler days, angler trips in which halibut was caught and retained.

So this means that if 6 anglers caught halibut on one vessel, that's one CHP trip and 6 CHP angler days. As Ben highlighted already a bit, the data is provided from 2018 to 2025 here. Data quality has really substantially improved with some of the new elements of the program with e-logbooks, use of e-logbooks, and also the charter halibut permit registration. However, some errors were still evident when we were going through the data. While some errors persist, the data is expected to be significantly sufficient to demonstrate the high-level trends that the Council is asking for in this discussion paper.

And there's some information in the paper that describes how data quality and accountability will likely improve with the charter halibut stamp implementation.

Thanks, Mr. Chairman. Sarah, one thing I'm a little confused about is how the unguided sector fits into any of this. Like, does it— like, when you put these— this information out, are you also— is there a caveat that says, but we really have no idea how many unguided operations are, etc., etc., or are you just kind of pretending it doesn't exist, or—. Through the Chair, Heather, so this discussion paper is focused on charter halibut permit and angler use in the charter sector.

The unguided sector is not part of the catch sharing plan. It's not part of the scope of this discussion paper. We do— ADF&G does get data on that sector through the statewide sport fish harvest survey, but it's not part of the scope of what we're doing here, so we didn't present information on it.

In order to fish in the unguided sector, you don't need a charter halibut permit. This is specific just to the charter sector.

So if you're in the unguided, they're not charters. Through the chair, no. The way charter is defined as we're using here is the guided sport recreational sector.

But in reality, they're charters, right? I think the unguided component is not within the scope of what we're dealing with. So unless there's a question that's sort of related to what we're trying to do. Let's move on.

Yeah. Nels. Nels. Yeah, through the chair, I guess the way to kind of tie what Heather was asking, this follow-up was created just within this analysis, was there much consideration on— I know that we were looking at this year's FCEY, projecting that forward for everything in this presentation. We've been seeing growth in the unguided take, which then pulls away from directed harvesters allocation.

Was there any consideration when you were projecting this forward in your analysis? Through the chair, Nels, no, that wasn't taken into account for specifically for data requests 6 and 7 is where that would come into play. And we didn't look at that because the analysis directed us to hold all these factors constant. So we're looking at a particular year for both data requests 6 and 7, we're looking at a particular year, a particular charter allocation, unguided recreational allocation in that year, holding it constant. So in reality, thinking about the future, there are a lot of factors that could vary, including harvest from the unguided sector that could affect what those two data requests would say, but for purposes of this analysis, we were told to hold those factors constant.

Okay, so number 3, data request 3, we're looking at trends in use.

So there's a number of ways we displayed the data in section 3.3. In particular, we have number of active charter halibut permits and number of charter halibut permit trips, angler days, average CHP trips and angler days per permit, and we have these tables broken out by area and permit type. The activity in these tables also includes CQE and MWR permits, and I have the— this information displayed in figures here. This corresponds with Table 8 and 9 in the paper. So The figures shown on the screen highlight active, the number of active CHPs and number of CHP angler days for Area 2C.

You can see here there's a notable COVID impact in 2020, but otherwise relatively consistent use of permits and angler days, and both of these metrics have a decline between 2024 and 2025.

These figures correspond with Table 8 and 9 for Area 3A, number of active charter halibut permits and number of CHP angler days. Similar consistency in CHP use, but maybe a bit more variability in angler days here for 3A. You can see there's a rebound after COVID, which might have to do with the 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. Yep.

Lauren. Thanks. I'm trying to— I think that I know what this is, but between '24 and '25 in 2C, there was a decrease in angler days. Is that because they had a closed day of the week? Week as part of their measures for charter helmet measures?

Would that be the, like, a reason for accounting for those, that decrease? Through the chair, Lauren, are you talking about 2C or 3A? 2C. I mean, 3A has had pretty regular day-of-the-week closures, I think, but 2C had to consider it last year, and I can't remember if it was something that occurred last year or not.

Um, through the chair, so Area 2C has had day-of-the-week closures for the last few years. Um, and you're talking about '24 and '25 specifically. Um, in, in 2024, Area 2C had 8 Fridays closed. And in 2025, they had 18 Tuesdays closed. Day of the week closures can definitely contribute to the amount of effort that's seen.

But it may not be the reason for the decline between 2024 and '25. Okay, I was just trying to see if that was— it was part of it potentially. But thank you for those numbers. That's helpful.

Chants, were there, uh, charter trip limitations in 2C in 2025 for a one trip per day per use, uh, CHP, or was that in, uh, I believe that was, I believe that was 2025 and then they changed that for 2026. Is that accurate?

Uh, through the chair, Chants, Adam St. Saviour for the record, ADF&G. I believe there was, um, let's see, we— '25, there was— I believe there was no trip limit in 2025. I'm going to double-check right now and I'll let you know when I'm, when I'm up here and I'll follow up with that.

Okay, thank you, Mr. Chair. We'll check on that. So moving through some of our use statistics, we, under data request number 3, we showed the distribution of trips and angler days for 2025 binned into different groups. Note that CHP trips figure on the left was corrected in errata.

The zero trip bin had an error. So on the left is charter halibut permit trips binned in 25-trip groupings, and on the right is charter halibut permit angler days distributed in groups of 100. So the average trips in Area 2C is 42, the average number of angler days is 177. You can see the distribution in this figure.

Figure 4 presents these bar charts for Area 3A. The average number of trips in 3A is 41, the average angler days is 200 and 67. So definitely more permits on the higher end of the angler day distribution in Area 3A compared to 2C. Sarah, I'm going to see if there's any questions and then we'll take our mid-morning break.

Okay, I don't see any. Let's come back at 10:20 and we'll continue on with slide 19.

All right, we're going to make our way back to our seats and continue on. Sarah.

Thank you, Chair, members of the AP, Sarah Muirnan, Council staff. We are on Data request, uh-oh, data request number 4 here, 4 of 7.

So this request was use of CQE CHPs issued to non-active CQEs.

CQEs, Community Quota Entities, 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 and lease to residents within the communities to be fished. Certain other opportunities were added into the program, including the ability for CQEs to apply for a special community CHP and receive a certain amount of permits free of charge. The CQEs internally determines who uses their commercial quota share or charter halibut permits.

There are some stipulations on the use of CQE CHPs. The permits are required— the trip that the permit's being used on is required to either start or end in the community associated with the CQE. Currently, there are 20 CQEs that hold 104 community CHPs across both areas. The data request asked about non-active CQEs. There might be a number of ways to consider this, but based off of the discussion that happened last December, 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 for each of these entities, and 4 of the 20 entities were listed as involuntarily dissolved.

CQE permits are not required to be re-registered each year like regular CHPs, and the regulations are silent as to whether a CQE status invalidates a community CHP. Table 12 in the discussion paper and on the screen provides a summary of activity for active community permits. And we have a question. Lauren? Yeah, thank you so much for providing this information.

I've done a lot of work on CQEs in the last couple of years and had extensive conversations with RAM about this because in doing research around active CQEs and then looking at charter helmet permits, I noticed this discrepancy and I was like, oh, this is crazy. These are inactive CQEs, but 2026 is showing they're still being issued permits. And in conversations with RAM, they were aware of the issue, um, but they needed direction to fix it, basically. So I guess I'm looking for maybe a recommendation on, like, would it be worth it to put language in a motion to help direct, um, that issue to be fixed? Or, um, I guess if possible, to provide advice on ways to move forward through this, because that was what was told to me by the agency, was kind of like, we have to have direction in order to make these changes?

Because according to the regs, you do have to be an active entity to hold the permits or to hold the quota. So I guess I'm just looking maybe for some advice or some insight as to how that could potentially be addressed, if that's possible from you, or we could speak offline on. Yeah, through the chair, Lauren. So CQE CHPs aren't reissued because they— there isn't a registration process. So if a CQE entity formed at one point and requested those permits, they still exist, but the regulations aren't clear on what happens at that point.

So I think there is a possibility that you could recommend some language to provide some direction at that point because they're not not part of the annual registration process. They don't reissue the permits, they just exist. So the discussion paper highlights that if it's the intent for community CHPs to be invalid when they're held by a CQE that fails to maintain its nonprofit entity status or meet annual reporting requirements or some other threshold, the council could recommend that NEMS amend its regulations to clarify what the status of those permits are at the time. We looked kind of closely at the regs to see what the direction is, and it really doesn't address this point. So because they're not annually renewed and there's no specific direction in regs as to what happens, I think that could be an opportunity to clarify in regulations.

No, that's helpful. Um, could you clarify the registration process that began with the other CHPs, was that like a regulatory change or was that just a process change? Through the chair, Lauren, yes, there was a regulatory package that went through to require permits to be registered annually. Okay, but I guess on that same note, the current— that current regular registration doesn't necessarily mean that a permit is invalidated because we kind of confirmed that there isn't a way to invalidate the permit regardless of registration according to what we heard. So, okay.

I guess, yeah, maybe after public comment we can take a moment to think about some language or I can get some direction. Thank you. Do you want to speak? I think, Mr. Chair, Doug Duncan with NMFS is here to clarify that point.

Hello. Through the Chair, my name is Doug Duncan, staff with National Marine Fisheries Service. Just a minor point of clarification to Ms. Howard's this statement about annual registration of CHPs, or just to avoid any potential confusion. A CHP subject to an annual registration requirement that is not registered is not valid for use in that year or until it is registered again.

So—.

No, that's helpful. So, it technically is not valid, but what we heard Was that there is not a current mechanism for invalidating it in the logbook, or there's not checks and balances that are actually checking that? Uh, through the chair, Ms. Howard. I—. No, I think as, as they described, yeah, like no real-time method for that.

Okay, Mr. Chair, moving on to data request number 5.

So this asks for a description of the extent to which businesses which are at the CHP holding caps, that's 5, are also using additional permits through lease transfer. Um, Table 13 in the paper shows the distribution of permits held in 2026. and you can see a visual of that on the screen. The majority of permit holders have one 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, based on the language of the motion, we focused on these CHP holders, looking at a time series that's 34 to 35 entities between 2018 and 2025.

When the motion for this discussion paper was made, we especially tried to manage expectations around this data request. Again, talking about our ability to monitor lease activity. There's no easy way to discern trips where— with lease CHPs or the relationship between the CHP holder and the user unless it's the same name. So we took an approach by comparing the number of permits held by a single user CHP holder that's at the cap to the number of permits they used, matching with their business names. So this is not necessarily a lease, and it's not being defined that way, but it is intended to demonstrate some sense of consolidation of permit use and to address the request the council had.

So Table 15 is the reference here. The business names of these 34 to 35 permit holders were matched with business names in ADF&G logbook activity when possible. So we could do this with 20 to 25 businesses each year. It's possible with some of the businesses we weren't able to match, it's possible that they leased their permits to another business or it's possible that they were inactive in that year. Most businesses that could be evaluated used their full number of permits or more.

And looking in aggregate in Table 15, these businesses consistently used over the number of permits they held. You can see the trend there, the numbers drop off quite a bit after 2019, and we attribute this especially to improved data quality through e-logbooks and registrations, which really could have a large impact on the number of reported CHPs used. And I wanted to give a big thanks to Ben Jevons here. For his work on this tricky data request and the name matching that it entailed.

Okay, moving on to request number 6, and this is for Adam. I'll turn the mic over to him.

Thanks, Sarah. Good morning, Mr. Chair, members of the AP. I'm Adam St. Saviour, statewide groundfish coordinator with 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.

The measures I projected effort for, uh, in Area 2C were for an under 45, over 80 reverse slot limit with no additional harvest measures, 1 fish of any size with no additional harvest measures, and 2 fish of any size with no additional measures. In Area 3A, the analyses were for 1 fish any size and a second fish of 28 inches or less, closed Wednesdays, and a 1-trip daily limit. And then 1 fish of any size, second fish of 32 inches or less, with no additional measures and 2 fish of any size with no additional harvest measures.

Thanks. So I'll run through each of these. I'm happy to take questions during or after. I ran these analyses in January 2026 before the 2026 allocations were announced. Balanced, so the results are reflective of the information available at the time.

And this is a kind of a twist on what I normally do for the harvest management measures, where typically I'm projecting what harvest will be. In this case, it's projecting what effort will be. And so I'll briefly explain how I calculated these methods. For the other analyses are similar. So this first request of U45080 reverse slot calls for no closed days.

I had a Tuesday savings calculated in the 2026 status quo forecast, which estimated the number of fish that would have been harvested had Tuesdays been open in 2025. I back calculated effort from the Tuesday savings and the observed harvest per unit effort in 2025, and then I 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 table you see on the slide there. And as a reminder, effort is defined as angler days where bottom fish was recorded or halibut were retained.

This increased effort was used to project a larger harvest forecast, and that larger harvest forecast was used to create a new reverse slot table. I then iteratively adjusted effort downward until harvest reached a level where U45/O80 removals in the reverse slot table were less than or equal to the 2025 allocation of 0.17 million pounds. The results are shown in the table here. A 36% reduction in effort is required for U45/O80 removals to, to reach that level. And the column reduced, or label reduced 2025 effort, is reflective of the 36% reduction from no closed days.

Second analysis was for one fish of any size with no additional harvest measures, and that's equivalent to under 50, over 50 in the reverse slot table. In my typical management measures analyses. The same methodology was used to project effort required to achieve U50O50 based on the 2025 allocation. In this case, a 62% reduction effort was required for U50O50 removals to reach a level that was equal to or less than the 2025 allocation of 0.72 million pounds.

And then for the third one, two fish of any size, available data were explored to determine the viability of that analysis. The difficulty with this one was there was no way to determine what proportion of anglers would keep 2 versus 1 versus 0 fish. The nearest available data in 2C was from 2010, last time they had a 2-fish limit. And given that how the stock and angler change— angler behavior has changed since then, it was determined that it wouldn't provide a, like, a meaningful projection. And furthermore, the analysis above indicated a 62% reduction would be needed to get to 1 fish any size.

So to get to 2 fish any size, effort would obviously have to be reduced well more than that, and we did not think a reduction of that magnitude was realistic, so that analysis was not pursued further.

Moving on to Area 3A, I use the same methodology— oh, thank you, sir— as in 2C to project effort required to achieve 1 fish of any size and a second fish of 28 inches, closed Wednesdays, and a 1-trip daily limit. This one would require an 18% reduction in effort relative to 2025 effort plus no closed Tuesdays.

As was the case in 2025.

For the second 3A analysis, a U40— oh no, that's not it— one fish of any size and a second fish of 32 inches with no additional harvest measures. This scenario included 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 they've had Wednesdays closed for a long time, Tuesday effort was used as a proxy for Wednesday effort. So Tuesday effort was added to total effort twice in this case. In terms of trip limits, the percent of second-plus trips by sub-area in 2013 was used as this was the last year without a trip limit, and then it was applied to the projected harvest as a percent increase.

For this scenario, a 42% reduction in effort was required— sorry, a 42% reduction effort was required for removals to reach a level that was less than or equal to the 2025 allocation of 1.48 million pounds in Area 3A.

And this is my last slide. So the third projection I did for Area 3A was for 2 fish of any size with no additional harvest measures. And 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. In this case, I had to adjust the mean weight to reflect the mean weight of over 27-inch fish, which is similar to what I did in a management measures analysis that they requested last year. In this scenario, a 57% 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.

And that's all I have. I'll take questions. Authority. Lori. Slightly might be off, and if you're not the right person, that's fine.

I just had made a note in the analysis in reading it. I was curious why the release mortality in 3A is less than that in 2C, like they had different numbers. I don't know if you're the person that could speak to that. Yes, I could speak to that, Lauren, through the chair. There's a few reasons.

It's—. They're slightly different rates based on like hook type and things like that, but the larger impact is that more larger fish are released in Area 2C compared to 3A because of the management measures they have in place there. And so it's like a higher, higher poundage that you would, you would expect to die from release mortality there.

Chance?

Sorry, thank you, Adam, through the chair. Is, uh, were the, were the new release mortality calculations for like single hook and line factored into that consideration? Aren't they— I seem to remember Ian last year talking about new data coming through that would have lowered those mortality rates substantially for, for the purposes of recreational charter based on the fact that the gear wasn't sitting at the bottom of the ocean for long periods of time, the fish are coming directly up, being immediately released, that sort of thing. Did that I guess probably not because the— this is data based on 2025 and that was released in— I think I've answered my own question. I'm sorry.

I could address that, I think, briefly anyways. So I believe what you're talking about, Chance, through the chair, is a study that the IPHC undertook. I'm not sure when, a couple years ago. Claude Dijkstra is the author. And, um, still awaiting publication on that one.

And like, the— my understanding is yes, the mortality rates will be lower based on those findings. I haven't actually seen specifically what they are. The rates we currently use are rates that Scott Meyer developed and presented to the SCC in 2007 based on other species and you know, hook type used, some other factors, and there was some kind of additional buffer built in there due to the uncertainty around it at the time. And so I think this study is promising in terms of like it's actually dealing with halibut in Alaska and more reflective of the type of releases that we use in the sport fishery here, but that's not available To date, as far as I know. I do have a— he's going to let me know when it is published, so.

Okay. Request number 7 is another scenario building exercise. It essentially says if the RQE, the recreational quota entity, held the maximum amount that 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. And holding constant the most recent projected trends in average weight, harvest per unit effort, angler effort, and allocations, what are the least restrictive management measures that we would have gotten to in that year?

So the first part of this data request is simple. It's just converting the 10% and the 12% into pounds for previous years to understand what the RQE could have potentially held if it held all the way up to the cap. Table 21 shows what this would have translated into in terms of annual pounds for Area 2C.

It also shows the maximum possible adjusted allocation. So That you can see the allocations in the second column from 2014 to 2026. The ratio is what's produced by RAM each year after the commercial allocation is set. It converts quota share units into pounds, and then that— then we apply the 10% to that for Area 2C that gets the maximum RQE holdings, and then the allocation and the holdings are added together for the last column to show the adjusted allocation. So in this time series, you can see the highest allocation for Area 2C charter sector 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 Area 2C allocation was this year in 2026 at 650,000 pounds, pounds, and adjusted with maximum holdings, the adjusted allocations could have been up to approximately 932,000 pounds.

In this—. Sarah? Oh, yeah. Nelson? Yeah, through the chair.

Thanks, Sarah. On that previous slide, yeah, so in 2026 with that 932,000 roughly pounds £1,000 would be equal roughly to the highest charter allocation in the, the time series of 2017. Do you guys have, for that 915, drawing those comparisons there, do you guys have the CHP measures that were used in 2017, just so that we would— we could compare to now versus what that would have looked like?

Through the chair, Nels, in 2017, Area 2C had a 1 fish bag limit with a reverse slot limit, so they could have retained 1 fish less than or equal to 44 inches or over 80 inches.

And in 2026, I think this is on the next slide, this past year the management measures for 2C were 1 fish daily bag limit with a reverse slot limit of U34 or 080 and 12 Thursdays closed, June 18th through September 10th. Answer your question? So, in this exercise, we looked at adjusted allocations and then used the latest ADF&G analysis. So, that's what Adam produced last year in 2025 looking at 2026. It's attached as Appendix 1.

And we looked at that to say, if you had this higher adjusted allocation, where could you have gotten to on— in the tables that that were produced. And I just wanted to say a few caveats here because we've done this exercise before. Um, we looked at it during the development of the RQE. These scenarios are not a prediction for the future, nor are they really a retrospective evaluation throughout the time series. We're using the projections of harvest and effort for 2026 specifically and then applying different hypothetical allocations to it.

So for instance, we talked about the unguided sector harvest, if unguided sector harvest changes in the future, that is a factor that could affect what we're looking at in terms of results here. This is holding everything constant and just applying a different allocation to the management measures that we're looking at for 2026.

Sarah? Lauren? Yeah. Based on what you just said about what actually occurred in 2017, You said U44 and I can't remember the other part. The O, was it 80?

Yeah. Oh, maybe this is— okay, I was just looking at this thinking about the U38 and O76 and projected for 2026 if they had held constant.

So I guess, yeah, if you could explain if that wasn't considered because I know we've heard an ask previously from the charter industry like a 45-inch minimum size was something that they'd be like happier with. It's not ideal, but so just curious why the U38 instead of something similar to what happened in 2017, like the U44 that you said actually occurred under similar harvest.

Does that make sense?

Through the chair, Lauren, I might have to ask you to clarify your question a bit. So in 2017, based off of what the allocation was in that year, which I guess—. Nell's question, yes, like what you referenced. Yeah, I can see at that time. But we didn't look at the 2017 ADF&G management measure analysis.

This table can be a little confusing because we're not actually projecting what measures would have been in in 2017 with that allocation in mind? No, no, I hear what you're saying. I think what I'm saying is, I guess, why did it land on a U-38 if it sounds like a U-34 was potential under those numbers? Because it occurred in 2017. So how did you determine the U-38 if, you know, in 2017 when it was actually $915,000, which is less than what this is projected, they were able to keep a larger fish on the U end.

Through the chair, Lauren, I think I understand your question now. So yeah, similar, we're looking at from what actually occurred for an allocation in 2017 versus what the hypothetical allocation from the adjusted allocation in 2026, um, the measures were very different. It depends on what is projected for harvest and effort. So these factors are changing constantly. So when Adam does the analysis, even looking at the same set of measures projected one year out, you might end up with a different projection of removals because these factors are changing.

So based off of the analysis that was done in 2017, that is what was able to be achieved, a U44080, because of the projections of angler harvest and effort. Effort. But if demand was different at that time, if other factors were different, you can end up with a different set of management measures. Does that answer your question? Yeah, I guess, I guess it's just the effort is the variable that's, that adjusts that.

Yeah, thank you. Yeah.

So we already talked about what the measures actually were in 2026. If you applied this adjusted allocation, so approximately 931,000 pounds for Area 2C in 2026, based on the management measure analysis that was done for that year, looking at those tables, the Area 2C, the least restrictive measures were 1 fish daily bag limit with a U38076. With no day-of-the-week closures. So this is the yellow cell highlighted in Table 22, which is reproduced from Appendix 1 from the Management Measure Analysis.

In June 2026, at the last council meeting, there was doing some discussion— there was some discussion about doing this task looking at more than one year's allocation, which is why we went back in time and showed what other allocations were. So we look at the adjusted allocation throughout the time series and applied those adjustments to the 2026 projected harvest and effort. So Table 23 shows hypothetical measures for Area 2C in 2026 under a range of historical allocations. So again, the highest allocation was in 2017. If the allocation— if that 2017 allocation was applied, to the projections of harvest and effort in 2026.

The least restrictive measures were 1 fish daily bag limit, a U80— sorry, a U50, O74, no day-of-the-week closures. None of the adjusted allocations in the time series would have gotten Area 2C to a 1 fish daily bag limit with no size restriction based on 2026 projections. But each could have relaxed management measures to some degree based off of what occurred in 2026.

So we can do a similar exercise for Area 3A as well. Um, this is the charter allocation for Area 3A from 2014 to 2026, and then you can see what the maximum RQE holdings would have been under a 12% 12% cap and then adjusted allocations by adding the charter allocation to the maximum holdings. In the time series, we can see the highest allocation for 3A was 20— 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 2025 at approximately £1.48 million, and adjusted with maximum holdings, the adjusted allocation could have been up to £2.189 million. In 2026, the adjusted allocation was £2.185 million, as you can see in the table.

So we ran these scenarios of what 2026 measures could have been with adjusted allocations for Area 3A. In 2026, the measures were a 2-fish daily bag limit with 1 fish equal to or under 27 inches, Wednesdays closed all year, Tuesdays closed, 13 Tuesdays closed, and 1 trip per permit per vessel per day limit. When I looked at the analysis from last year, it doesn't actually cover a wide enough range for potential measures under the adjusted allocation, The least restrictive measures that we looked at were in Table 25, reproduced from that analysis in Appendix 1, and that looks at 2 fish daily bag limit with a U32 for 1 fish, Wednesdays closed, 1 trip per permit per vessel per day, and no other day of the week closures. That's the least restrictive measures measures that we looked at in 2026. Um, and you could have gotten to that set of measures under any of the adjusted allocations.

Um, I looked a little further by considering management— the management measure analysis from 2025. Um, that Table 26 is reproduced from that analysis, and it does project removals with no day-of-the-week closure and a 32-inch second fish. So using those 2025 values projected for harvest and effort, the adjusted allocations for nearly all of the years with the exception of 2025 and 2026 could have achieved at least that set of measures. So that's 2 fish daily bag limit with a U32 for 1 fish and a 1 trip per permit per vessel per day, but no day of the week closures.

Table 27, which is on the screen, shows that there's substantial remaining allocation in most years, with most years allocation at these measures.

And all of these scenarios that I'm presenting assumes that RQE is holding quota share all, all the way up to the cumulative limit.

One other point under request number 7 is that the cumulative transfer limit here is shared between the RQE and guided angler fish provision. Guide angler fish, 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 are in place that are more restrictive. So the pounds that are leased translate into a number of fish that can be caught based on a conversion factor that's produced each year. It allows anglers to catch a halibut on a day that would otherwise be closed to charter fishing, or in Area 2C, it allows them to retain a fish of any size.

So each year NIMS produces a GAF report, which includes this conversion factor. This table on the screen, Table 28, is from the most recent GAF report. It shows IFQ transfer and harvest— IFQ that's transferred and harvested as GAF each year. From 2014 to 2025. You can see in this table that GAF transfers have increased dramatically in Area 2C, with some increase in 2024 to 2025 in Area 3A as well.

In 2025, approximately 265,000 pounds of halibut transferred as GAF in 2C, and this leaves— under the shared limit, this leaves approximately 43,000 pounds short of the limit.

In practice, the RQE holdings will dictate what's available for GAF because the RQE holdings are a long-term transfer and GAFs happen annually. So whatever the RQE holds, the remainder will be available for GAF transfers. And I'm highlighting here that this could be a point of tension in the future for operators that have come to rely on GAFs GAF, in particular if the RQE is not able to relax management measures to a point that provides the kind of opportunities that GAF has been providing. So, in the scenarios that we ran under Request #7, this assumes RQE full holding, so it, it assumes that there would be no remaining transfer limit available for GAF.

Anika. Thanks, Mr. Chair. Um, okay, so my question is about the funding mechanisms for these two separate sort of purchases. So RQE is done through a stamp, right?

And then that affects the management measures for the entire area, correct? And then GAF is a one-time transfer, and that goes to a specific angler and who funds that? So who, who buys GAF? Is it the client? Is it the charter operator?

Is it a mix? Can you give me some background on that? Sure. Through the chair, I think the answer may be different for different operations.

Your description is correct for RQE. For GAF, I think it's used differently among operators, so people in public testimony might describe how they use it, but some charter operations might fund that themselves to provide additional opportunities for their anglers. Some may make the transfer more clear to the anglers to see if they want to fund it themselves, but I think across operations they probably do it differently, but it, it is more direct, that a specific angler operation would pay for that rather than the sector as a whole, which is how the stamp functions.

Thanks, thanks for bearing with me. I'm—. This is not my level of expertise, but you would consider both of those transfers to go in sort of the compensated reallocation pile, correct? Through the Chair, I think you could consider them both to be a type of compensated reallocation.

Chance? Thank you, Sarah. Is there any analysis outside of the NOAA GAF analysis that shows how much self-transfer is happening, or could you talk a bit about self-transfer in Area 2A or 2C and 3A? If that's a thing. In other words, how many of these GAF are being transferred by an operator that owns the quota themselves?

Through the chair, Chance, I feel like I have seen that statistic before. I don't know off the top of my head if it's been produced in the GAF report or if we've had it in other analyses.

But I can look into that.

Through the chair, Doug Duncan with National Marine Fisheries Service. There is some information in the guided anglerfish annual reports on self-gaffing. Approximately 3% of the GAF permits transferred in 2025 were self-transfers.

And then there's some other kind of summary information provided there, but I can't think of another larger-scale council analysis that looked at trends of that over time off the top of my head.

Um, questions probably, um, more for you, Sarah, on history. So the— I know there's question around like the, the phase-out of GAF as the RQE comes in, and is there any history you can provide on that, um, provision of this action and maybe like where that was decided and how that was decided.

Through the chair, the cumulative transfer limit that essentially phases out GAF if the RQE holds up to the limit was put in place when the RQE was implemented. My recollection of some of those discussions were we looked at a lot of different total transfer limits for the RQE, and at At one point, there were concerns highlighted from the commercial sector that these are two different types of movement of quota from commercial sector to the charter sector, and so there was an interest in looking at them cumulatively.

So as one single reallocated compensation package, that was the concept that was brought forward.

Through the Chair, I mean, the package was mostly focused on developing the RQE, but there was a lot of consideration for GAF as it existed and what it might look like in the future at the same time.

Chance. Through the Chair, thank you, Sarah. Do you—. Are you aware prior to the RQE what the annual transfer limit was per CHP? For a 6-passenger or above 6-passenger vessel, was it?

There was— there was—.

It's—. I think it's my— I think it was 400 GAF annual for a 6-pack and 600 GAF annual for a 6-plus per CHP. And was that— was that limit put in place as the RQE was formed mostly because of a market concern, or do you know why? I guess it's a follow-up on her question. I'm just trying to learn more about that.

Through the Chair, Chance, there are a number of other restrictions around GAF transfers, like the one you cited. There's restrictions on how much can come from an individual quota shareholder. Those were put in place with the GAF program, not with RQE. So when the catch sharing plan was implemented, and each one has a different rationale behind them, and I don't have all the regs in my brain and the specific reason, but we could definitely pull that for you. But those, those provisions had already been in place when the RQE was implemented.

Um, that is my last slide, Mr. Chair. Um, this is my last slide.

Um, this discussion paper—. Sarah, you're going to do the committee report as well? Yes. Okay, so I'll just interrupt then here, um, and remind people, uh, members the public to sign up for public testimony. I think you have about 5 slides left.

So thanks. Yeah, yeah, Mr. Chair, clarify, this is my last slide for the staff report. I have some more slides too. But so this discussion paper, as I mentioned, doesn't direct a specific action, although next steps may be considered.

In terms of next steps, you can think about expanded discussion paper or an analysis of a purpose and need statement and a set of alternatives. Alternatives are able to be identified. And I'd just like to give a big thank you to all the contributors and people who have supported this discussion paper. Happy to answer any further questions.

I don't see anything, sir.

Okay, Mr. Chair, should I just roll right into the committee report then? Please. Thank you.

Okay, attached here.

So we had a Charter Halibut Management Committee meeting on September 30th in the morning. It was a virtual meeting. The report should be posted. The committee made 3 motions, so I'm primarily going to highlight those motions here in this committee report.

So the first motion is for an expanded discussion paper, and I'm just going to read the motion. 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 effect impacts of harvest restrictions, size limits, daily bag limits, annual limits, closed days, and season length. 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 for other fisheries or activities. Differences in the ability of each sector to adapt to reduced allocation, including consolidation, efficiency, changes in effort, changes in revenue, changes in consumer demand, the role of access and opportunity in generating recreational economic activity, the potential for regulatory restrictions to reduce economic activity and other tangible and intangible benefits 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 from the 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 _MSA principles. Explore the benefits of parity and recreational harvest across Alaska waters.

Additionally, the Charter Halibut 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 GAF program limits— the current GAF program limits provide qualified charter halibut permit holders sufficient opportunity to offer guided anglers additional harvest opportunity. 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 commercial halibut fishery. Evaluate whether 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 the 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 a proposed schedule for council consideration. A focused GAF performance assessment may be returned separately if it cannot be concluded— completed sooner.

So that is the first motion that was made, and I can read out a few points of their rationale, which are more There's more written in the actual report. So committee members recognize that this motion is robust. However, they didn't want to miss an opportunity to highlight concerns within the sector and focus some of the charter fishery nuances that are important to downstream management impacts. Members explain that there's a distinct difference between how recreational halibut fisheries and commercial halibut fisheries are affected by and respond to low and high abundance scenarios. Members also highlighted the importance of stability and predictability in the charter halibut fishery.

Because of these differences, they felt the management approach employed through the catchering plan may not be appropriate for recreational fishery, especially during periods of low abundance.

The motion asks for a review of GAF performance. The rationale also 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 gaff use. Members stated that such an outcome may not provide an attractive opportunity for recreational anglers or support the businesses that serve them. And I can stop there and see if there's any questions on Motion 1. Lauren?

Thanks, Sarah. Um, and I understand that the paper did not have any Um, in terms of the direction for writing, it didn't have anything in there regarding abundance. I mean, to me it felt like, like the elephant in the room when reading that entire paper because no consideration was taken for the abundance of the stock and the low levels we've been facing throughout the time series especially that was used. So I guess from what you just talked about, is that the extent, or like the more of a purpose of Motion 1, is like to actually consider effects of low abundance on the resource, or could you explain any conversation in the charter halibut committee related to, you know, the main issue with the halibut resource right now, which is low abundance?

Through the chair, Lauren, my recollection of the conversation and some of the points that were raised in support of this motion is, in particular, some references to water impacts that are experienced in the recreational fisheries when abundance is low and how that may look different than commercial fisheries. So I think that first part of the motion with the discussion paper, it's intended to highlight, um, some of the differences between the types of fisheries and their operations and how they may respond to or be affected by kind of the extremes of low and high halibut abundance. Does that answer your question? Yeah, and I guess unfortunately I was not able to listen. I had conflicting meetings, and I wish I would have been able to attend.

And I guess it's just a general sentiment of like any discussion that occurred around issues with abundance. I mean, like, to me, when I look at the halibut stock and I look at the time series that's talked about here, I mean, there's a stark decrease. There's a 30% decrease. Decrease in abundance during that, you know, main time series that's been analyzed that directly correlates to what we see in terms of the access of the charter fleet. So I just— at what point, or in any point, was there consideration of that in the discussion?

Through the chair, Lauren, we didn't talk about the time series of abundance or statistics on halibut abundance specifically. I think the main discussion was about response to abundance, and that is what's being asked for in the discussion paper, is information and understanding of the impacts of different levels of abundance.

Heather. Thanks, Mr. Chairman. Sarah, was there any discussion in this motion or the next two about the fact that the RQ RQE program is so new that it really hasn't had enough time to see how it performs?

Through the Chair, Heather, I don't think that point was raised.

I think the discussion is mostly focused on what the RQE might do in the future and what constraints it might bump up against in the near future with, for instance, the annual transfer limit and the combined cumulative limit with the GAF limit. But that specific point you highlighted wasn't, wasn't raised.

Okay, um, Motion 2.

This is a, um, shorter motion. So, uh, Motion 2 reads: 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 2. 2C, and that motion passed unanimously.

The motion recommends that the GAF transfer limit would be uncoupled from the RQE total transfer limit. Currently, the cumulative limit restricts the combination of long-term RQE transfers and short-term lease transfers from GAF to 10% in Area 2C and 12% in Area 3A, essentially phasing out GAF if the RQE purchases up capped to the limit.

So there was some confusion in how these limits would be decoupled. I wrote the minutes, and my interpretation at the time of the meeting is that the, the motion was intending to separate the limits such that the RQE would be capped in Area 2C, would be capped at 10% of commercial quota share transfer, and GAF would be capped capped at 10% of commercial quota share leased, and that in Area 3A, 12% of the commercial IFQ could be leased in a season and 12% of the Area 3A commercial quota share could be transferred to the RQE in total.

I have since spoken with members, and I think the intent of the maker of the motion was that by decoupling the cumulative limits, the GAF would just be removed from that total cap so that the cap would apply to RQE, but there would not be a total transfer cap on GAF. So that was the intent of the maker of the motion. I just wanted to highlight that there may be different ways to look at this language, and there was some confusion maybe on my part in terms of what was described at the meeting, and that's how the minutes were written. But there may be some different interpretations. 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 at the time the RQE held up to the cumulative limit, there would be no GAF lease transfers approved in that year.

That 10-year sunset could be reviewed prior to the time of consideration.

The committee is recommending these changes to the cumulative limits for both Area 2C and 3A.

Nels?

Yeah, thank you through the chair. Thanks for the in-depth run through these motions. I also had conflicting meetings and wasn't able to be here. I was getting kind of play-by-play as it was going.

So my understanding has always been that the GAF GAF is a stopgap method until the RQE is fully funded. Looking at the structure, particularly that last sentence here with that decoupling and the potential 2% purchase in 2C as opposed to 1%, 2C could achieve their RQE in 5 years and then still have an additional 5 years of GAF under this motion structure with them being decoupled. Am I understanding that correctly? So that stopgap measure would actually exist for an additional 5 years, or am I miss— misunderstanding the way that's written?

Um, through the chair, Nels, that is an interesting point that I don't think we discussed.

I guess we didn't— we did not discuss that in the committee. Just thinking about the math you've done there, I think it would also depend on when this would be implemented. So in the interim, the RQE could continue, and Area 2C could continue to buy quota at 1% each year. So for instance, if it took 2 or 3 years for something like this to be implemented, they might already hold a portion of the total cap. But I think the sentiment you're explaining would be true that if the Annual transfer cap is increased, they could achieve their total limit earlier, so there would be a period there as you're describing.

Nelson, then Lauren. Yeah, just to follow up. So this is what—. This would be a pretty big diversion from the original intent of how GAF and RQE were originally structured if that were to go in place. It's all hypothetical because We haven't brought any motions forward here, but just with that decoupling and then the potential shifting of timelines that could happen between GAF and RQE.

Through the chair, Nels, I would say this definitely does make a regulatory change for what exists now in terms of how the cumulative limits apply.

Mr. Chair, I also wanted to highlight a little bit more of the rationale. I kind of described this motion, read the motion and described it, but there are a few more points from the committee that I wanted to highlight in terms of their rationale for putting it forward. So the committee considered separation of the transfer limits as an immediate measure to provide stability to the charter halibut sector. The committee noted GAF transfers in Area 2C are already approaching the combined 10% limit due to increasingly restrictive management measures in this area, and many— and members shared that many operators and anglers have come to rely on GAF during these times of low abundance.

Increasing the cap would provide near-term flexibility, and the sunset provision would require the issue to be reconsidered considered in the future. Some committee members felt that GAF should not be viewed as a permanent solution for the charter sector. These members highlighted that reliance on GAF could discourage transfer to the RQE by creating an incentive for IFQ holders to retain quota for leasing to the charter sectors. They expressed concern long-term reliance on leasing quota from a competing sector creates uncertainty for businesses. Some members expressed concern around sunsetting GAF as some operators have purchased commercial quota and so they might lease GAF to themself, but they felt a sunset provision may be considered at this stage.

The motion also requests the council consider increasing the annual transfer limit from 1% to 2%, Area 2C. The committee noted that the council previously considered a range from 0.5% to 5% but selected 1%.

The committee stated that the 1% cap is expected to constrain the RQE's ability to purchase quota even when sufficient funds are available.

So any other questions on Motion 2? Lauren? And I don't want to be too repetitive, but I was having a similar train of thought as Nell's, just thinking about like the looking at the potential for there to be you know, almost a doubling of the initial agreed-upon change to the CAD share plan for the reallocation model. Because when I read this, I mean, and it's more like a— I'm— if I'm understanding this correctly, that, you know, the phase-out of GAF was part of that. The agreed-upon reallocation was 10% total between both programs.

So this is asking for, in effect, a doubling, you know, 100% increase in that, you know, with a sunset, so to speak. But it seems like a very large diversion from the original action that the RQE intended to deal with. So it's kind of like I'm reading this as a bigger action than kind of how it's written. Like, in terms of the analysis, the changes, the regulations that would have to be changed. Like, it's relatively complex.

Am I correct in assuming that and thinking that? Through the chair, Lauren, well, we haven't done an analysis for it yet. But I would say if this passed, the first component of it would look at many of the things we looked at during the RQE when considering where the appropriate level of transfer restrictions are. So I am certain there would be a lot of public testimony on both sides as to what would be an appropriate level there. There would be— there would definitely be some things that would need to be looked at within an analysis.

Thanks, Mr. Chairman. Sarah, so I I guess my question is, going from 1% to 2%, where does that percent come from? Does it— is there an impact to commercial from that or no?

Um, through the chair, Heather, so that is just a restriction on how much could transfer annually. Um, I think like Annika asked earlier, what are the kind of implications of, uh, a fast transfer to the RQE versus by putting the annual limits, it required the transfers to be slower. You know, when the RQE was developed and looking at those annual limits, I think one other thing we looked at was how much quota moves around normally annually, how many transfers take place. And I can't remember what the numbers were, but I think part of the consideration was how big of a player is the RQE going to be relative to other transfers that happen within the commercial sector. So, I mean, I think there were some points expressed at that time, both in support of maybe it would be better for a larger lump sum to transfer all at once, first requiring it to be a slow transfer based on annual limits.

So there's— I think there's trade-offs there that were represented in that original analysis. But ultimately they settled on 1%. I think part of that too was a parity between the total cap, which is 10%, so, you know, it would take 10 years for that to— for them to be able to achieve the total cap. But yeah, a range was considered at the time.

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

I can read off some of the rationale points for this Motion 3. The committee supported consideration of a review of Pacific halibut mortality across sectors in the Gulf of Alaska. The review could evaluate opportunities to review— 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 then the committee noted that some of the scope may fall outside of its direct authority, the council's direct authority, but supported moving the concept to the council and IPHC with IPHC consultation.

See if there's any questions on that.

Monica? Thank you. Thanks, Mr. Chair. Um, I was hoping you could characterize some of the conversation at the committee on this motion regarding the things that they specifically call in as more— call out as mortality sources in the first paragraph.

And there's some other mortality sources that we've heard a lot about in this process, like the unguided sport fishing, and that was not specifically listed in the first paragraph, and I'm wondering if the committee had any conversation about that or if the intent of this motion was to have it be sort of holistic for all sources of mortality. Thanks.

Through the chair, Annika, we didn't discuss that specifically during the committee.

We didn't go into that detail.

Chance? If allowed, I can speak to that.

The concept was a sector-neutral approach, so yes, I think the intention would be to analyze all types of mortality for halibut.

Chance, you're on the committee, I'm assuming? Yep. Thanks. Just want to make that clear.

So, Sarah, may I ask a question? Yeah. Did they have any— was there specific data they were looking at to drive this request, like in-season management reports, or was it more just conceptually recognizing this issue across sectors? I'm just wondering if there was specific numbers referenced or anything like that. Mr.

Chair, we also didn't talk about that at the committee meeting. Chances on the committee and was also the maker of the motion. So I don't know if you want him to go into more detail on his thoughts there, but we didn't specifically talk about it at the meeting. I, uh, if that's the case, then I think we could probably wait, um, if there's a motion. We don't need to have a conversation at the table.

I can follow up. Thanks.

So, Mr. Chair, that's all 3 motions from the Charter Committee. Our next Charter Halibut Management Committee is October 21st. It'll be an online meeting. This is an annual meeting that we have.

We're going to review final 2025 charter harvest estimates and preliminary 2026 data requests. The committee members will request analysis of management measures for analysis for 2027. And I think we're also going to have some time on the agenda to discuss the RQE charter halibut stamps. I also wanted to highlight that we had one member from Area 2C step down, so we're going to be soliciting nominations for a 2C committee member. Thanks, Sarah.

Before I see if there's any final questions, we'll just remind the public to sign up. We'll take public testimony after this and then break before our motion for lunch. Lauren?

Um, in terms of the committee, the charter halibut committee in general, was there any discussion at all about, um, unguided vessels in that sector? Um, through the chair, Lauren, we didn't talk about it that much within the main agenda because we were focused on the discussion paper. Um, I think that was maybe brought up a bit under Motion 1. I think there's some of the bullet points within that motion that are intended to talk about, that are intended to focus on, I think, differential treatment of recreational anglers might have been one of them. So I think there was some discussion within the motion making about, um, about that, that unguided rental boats could fit into that topic, but, um, That is where I would see the nexus.

All right. I don't see any further questions. Thanks, Sarah.

I see two people signed up for public testimony, so we'll take Forrest Braden and Kim Layden, and then Linda Banken.

Mr. Chair, members of the AP, my name is Kim Lundeen. I'm here with my co-director, CEO, or co-director of SEGO, Forrest Braden. We want to first start by thanking staff for the effort in this paper. It was significant on multiple different agencies' parts.

So with that, I'll be speaking to Motion 1 and Motion 3, and Forrest will be speaking to Motion 2. It is our understanding and our belief that halibut is a one fish shared by commercial fishermen, by charter clients, by unguided anglers, by subsistence users, and the communities that depend on all of us to be successful. The stock is low and everyone is feeling it. You can feel it here in this room. And the question isn't who's hurting most, it's whether the way we manage a low stock still matches the goals we set when it was more— when it was more plentiful.

For nearly 20 years, sport anglers on the same water have fished under different rules depending on how they access the fishery. Here in our community, Communities in this room and in the dock, people are starting to ask how we got here. My question and Cigo's question is, what does this teach us? And the paper is the first real look at that side of the charter fleet and how this has impacted it. It shows a relatively stable user group with charter effort following the annual measures like day closures, like was highlighted here earlier.

We share the goals that the council has set over time. The Halibut Act asks that allocations be, quote, fair and equitable to all such fishermen, unquote. The catch sharing plan set out to, quote, balance the differing needs of the charter and commercial halibut fisheries over a wide range of halibut abundance, unquote, and to, quote, the needs of all who depend on the halibut resource for food, sport, and livelihood. The RQE was created for less restrictive annual measures for charter anglers at times of low abundance. In 2022, the council recognized the strain, particularly at times of low abundance and chose the RQE as its path.

The paper now shows us what it can achieve. We do recognize that that is a projection, projection. That is what we use to manage. I mean, that is the best available data, so we need to figure out how to wrap that in. Our question is whether that outcome meets the goals of fair and equitable and how we'd know that we've even reached it.

We don't yet have a shared answer, and we'd like to create a space to decide what that is. Motion 1 takes on the hard question. What is fair and equitable looks like at low abundance, how to value recreation in a fishery managed in pounds, how each sector and market adapts to change, and how all halibut mortality compares. We also know very little about unguided activity, has been highlighted at the table here today, outside of growing harvest and anecdotal testimonies. And it is our belief that these anglers bring real value, and better information in partnership with that fleet would help us better to all be better stewards of the same water.

Motion 3 takes on mortality discard, a sector-neutral review of mortality in the Gulf, asking today— asking whether today's limits fits the stock and where avoidable mortality can be cut without unnecessarily constraining viable fisheries. It would be our intent that it is included in all sport fisheries, all user groups. To be clear, it is our intent in asking for this analysis that it will serve all users. All of our communities, help us as decision makers to have the answers that we currently do not have. We have spent hundreds of hours looking for these answers in the documents and in the history.

They are not there. We have not done the work. Um, we respectfully ask the AP to recommend that the council task Motion 1 and 3.

Yeah, thanks, Kim, for that. Um, I just want to direct your attention quickly, if you have this analysis open, to Page 17, Table 10, maybe to summarize SEGO's takeaways from the work, the great work, and this is— this really produced a lot of material for us to consider. I think what we see there, whether you see it or not, and maybe we can help you have insights into it, is that we largely for the last decade, we see a stable charter fishery. We also see a charter fishery that can absorb a lot more demand if it's there. There's a lot of latent capacity.

In the fleet and CHP use. But overall, in terms of angular days and CHP use, it's pretty steady. It's a— we see a little bit of decrease in GAF— sorry, in lease transfer of permits. That's where I'm going with it. And that was— we were looking for a silver bullet.

You know, are we increasing effort because we have lease transfers and we're monopolizing more available usage than original issue? We're using, but we're not seeing that. We're seeing a steady, a steady not growth in the charter industry. So we have to start looking at other reasons for this restriction and harvest measures, and they are very onerous. And really, other than allocation, our sensitivity to allocation gains— well, that's it.

We're very sensitive. If we drop NTCY into CTCY, if we drop you know, from a 5.7 to a 5.5 TCY, the results of that can drop us, like, down multiple inches on our reverse lot table. We're just super sensitive to minor tweaks. And the question, I think, for this council and you as the advisory panel is, you know, are there any small tweaks that we can make to the existing programs that will allow us to alleviate some of that pressure while we try to look for longer-term solutions? And so, CGO supports Motion 2, which is the tweak in transfer, annual transfer caps for the RQE, and also relaxing of the GAF provision.

And just to clarify some things that we've heard on record already, for the CSP, the original GAF transfer caps were individual to poundage for CHP IFQ holders and CHP owners. And the analysis shows, if you go back and look at it, there could be up to like 4 million pounds transferred in just a single area in Southeast Alaska and another 4 million in, in 3A in Southcentral. So we're asking for a relax for these caps, not because we're after like some revision of the CSP. We're actually asking for a relaxation of the GAF program to do what was intended to do and be a stopgap, because we're up against the wall. You can't go to a 34-inch regulation right now and pull that out from underneath if the RQ were suddenly to produce a full 300,000 pounds of fish and leave people that use 38080 and no gaff use because their business models would crumble in 3 minutes.

Goes quick. Thank you. Thanks, Forrest. See if there's any questions. Heather, then Lauren.

Thanks, Mr. Chairman. Thanks, guys, for your testimony. There's a lot of discussion around constraints with workload and there's going to be a priority exercise. Does CGO have a priority of the— with the three motions, um, which one is your top priority?

I, I think you're seeing it right here at the table. We don't come— we recognize what has been happening with the staffing capacity. We recognize the limitations that they're under. And it's hard to answer those questions because we are up against the ceiling. We're, as of next year, potentially going to be running into May, June, July when our, our operations that need GAF to keep these people coming no longer have that opportunity.

I think the battle comes between that as an immediate need, but there's also this understanding, and we're seeing it here, like, what is fair and equitable? There hasn't been that analysis done. It hard to quantify the social components of what a sport fishery is.

I know as decision makers we often are required to take really hard decisions and put aside what needs to be answered for what must be answered.

That would be the response, is that tomorrow, or at least next year, we hit that GAF cap, that GAF limit. But until we can answer the question of what this what this looks like as a state, what this looks like as a nation, it's going to be really hard to manage this fishery to fair and equitable. It's going to be very hard to capture the economic data, the social components of it, unless we put in the work. I guess my offer on the table from SEGO would be we want to partner in that. We are willing to partner in that.

App development at this point in the stage we're looking into. I got some really good recommendations from an AP member last last meeting about app development specifically in the self-guided fleet. We've started collecting that data. We will continue collecting that data and working with that fleet to try to bring that to the table. But there are some answers here in all three motions that I don't know if we can truly look past.

Thank you, Mr. Chairman. Thank you for that response. So no priority really between the three. There is an urgency And maybe if I'm reading too much into it, just tell me that if there weren't these sort of priority workload constraints, you may have even had more motions. Is that— well, because you said this is the compromise.

I appreciate that. Through the chair, yeah, actually, wouldn't we all want more information from you guys and more work being done by the federal government? I think we all have those requests, and— but I think we also have to be sensitive to workload. So amending that motion, I think next year the gas ceiling is going to be very tough. There's going to be real consequences immediately.

I think we are 20 years past defining what is fair and equitable. So at what point do we decide to prioritize that? And we have a stock that we have not faced at any level, like we're We're low, we're all feeling it. What's the goal of the state? What's the goal of the nation?

What's the goal of this halibut fishery? Like, I, as a leader in this, in this industry, like, I can't answer that. When my clients and my, and my people come to us and they say, what is fair and equitable? What has the council said? And I have to put them back to pounds, and pounds equals a U34080 with day closures in the exact same waters where anglers are now moving from their model to another model that's 2 fish a day of any size, or they can go to BC at U45080 unless it's September 1st, or how about stay in Washington and Oregon or come up here to South Central?

What is fair? What is equitable?

Thanks. Forrest, you said something that I'm trying to get some clarity around, and it's slightly based on— or it's based on something you said in public comment, but also something that was written in, in your letter. So what you say in public comment just now was that you're not after a revision of the CSP, but the letter explicitly states that the underlying problem is the CSP itself, and then it references the decrease in allocation from 2017 to 2026, which is directly correlated to the decrease in abundance that we've experienced in all halibut fish directories and, you know, directed or discards or commercial, however you look at it. So I'm trying to understand how to put those two statements together and where you really stand. Through the chair, thank you for the question, Lauren.

So we want to be real clear that these asks, the action items that were— the action items that we're looking for don't, in our view, open up the catch sharing plan. The catch sharing plan needs to be looked at in terms of how a sport fishery operates in comparison to a commercial fishery and the differences in how they respond to low abundance, which is what you continually bring up, and where there's equity. And just to speak to that, I own IFQs. I did really well this year, and I gaffed part of them for a lot of money, and then I went out and fished them for a lot of money, and it was really good. So low abundance didn't affect me the same way this year as it would in the sport fishery.

So, and, and those are nuances how we respond, and that's important for the council to have in their back pocket when they're making decisions. So, but these, these adjustments to the tools that you've already provided for us are what we're trying to work in, why we look at the longer-term solution. And so yes, we see We still want to take a look at the catch sharing plan. Can it be expanded to be a Gulf catch sharing plan that involves everybody? We've got one up in 4CD&E, we have one in 2A.

Why don't we have a catch sharing plan in the Gulf that handles the users and how they interact? So I hope that clarifies that we can still speak to both at the same time.

Yeah, it just still sounds conflicting because from what we heard from staff, you know, Motion 2 ultimately is an amendment to the catch share plan. It would be a change from, you know, the reallocation that was agreed upon for the RQE. It would be a shift. So I guess I'm still trying to understand how it's not. Through the chair, thanks for the question, follow-up question, Lauren.

So actually, we just clarified for ourselves what the original CSP GAF provision looks what it looked like, and we're happy to accept that version of it. So we're not changing it. The RQE changed it from the CSP, and so we're addressing RQE and the changes that it made, and we're asking for a relaxation of the annual transfer cap to 2%, which I think some literature supported and other user groups supported. And we're asking for the time being to go back to the original intent of the GAF program, just take it right back to what it was before the RQE we manipulated it for now because we need that stopgap. We need— we're up against— in 2C anyway, we're up against a cap that's going to harm people while we try to figure out this longer-term fix.

Sure. Through the chair. Through the chair, is that okay if I add to that? Lauren, appreciate the question. That's a holistic thinking that we need to be looking at at this table, and the fact that you bring that up in my mind tells me you're doing a dang good job representing the people that you're here to represent.

There was an intent of a sunset behind that, recognizing that it is— while fair market has its play in the world that we do, this management body also has to make sure all those triggers work together. It is our intent, in our understanding at this point, that without that, that additional availability of GAF while the RQA builds— we addressed it earlier— you've 38 U-380 with no GAF, there is— we can compete with no one. That's including with the beautiful scenery of Southeast Alaska, for the amazing lodge services that we offer, the great food that we provide, the kayaking that's starting to come into this. Like, there is so much to offer here in Southeast Alaska. But when you compare that, when you add to that opportunity a U-380 with no other opportunity and you're required to pay the price tag on that experience, or I can jump to my neighboring lodge that's doing self-guide, or I could stay in BC.

I can go to Washington, I can do to Oregon. There is a need, a brief need in our mind, to allow fair market to put those fish where they are most valuable as we are doing the work addressing the other question, as we're doing the longer-term work of trying to figure out what this looks like holistically. Chance?

Thank you, thank you both.

Forrest, as an RQE board member, can you talk a bit about the complications of GAF with RQE and how troubling this must be for you to sort of ask for an extension?

Yeah, through the chair, that's an important question and thank you for it. So some folks would extend the GAF program indefinitely. And see it just as, you know, fair market transfer of fish with both interested parties. Where the RQE itself runs into conflict, and why I think that the GAF cumulative limit came into existence, is because the RQE is concerned with competing against GAF for the purchase of quota share. And we've seen a trend, if you talk to the brokers, they say that the hottest block sizes, 1,500 pounds or thereabouts, just under, because those can be purchased and are being purchased for more money than bigger blocks, which is a reversal of history, because people can buy the block and gaff the entire thing, and there's no actual fishing that takes place.

And I kind of ran a little scenario because I thought about doing it myself, which is really hypocritical, but I can make like 20% on return on my investment. So I have cash sitting in the bank and there's a 1,250-pound block, I go purchase it, I'm getting 20% return annually on that investment. And I don't think that that's what the council meant for this to be, and RQE sees that as a threat because I'm not going to sell it to you if I can have that kind of a deal for me. And so that's why we see the conflict there.

Um, thank you very much for your answer through the chair. Do you— obviously, you've done the math on how the fully realized RQE with the CHP Live paper that is in front of us that shows it's not doing a whole lot for Area 2C, and that's the major concern. Do you know or have in mind, I guess, percentage of like a bottom-level percentage of continuance for GAF that would be amenable or appropriate to carry into the future for— that would get you guys to a reasonable you know, 45-inch, you know, status quo that you had for a decade or so?

Through the chair, I'll leave the harvest measure part out and we won't discuss, you know, what people may be able to quote-unquote survive on. But as far as relaxing, like if we had a total cap, one thing that I realized when the motion was made, because I made it, is that to hold— to have a 10% cap on even though they're decoupled, to have a 10% cap on GAF actually puts us right back in the same boat where we're already bumping up against that. So for the time being, we need that to be relaxed. Maybe it could be 20% or something like that. It's a free market transfer, so we're not bending anybody's arm to force them to lease to us.

You know, it's got to be advantageous to them, um, but we— and it seems to be advantageous to both sectors right now, but we, we would need to, you know, another 5% 10% may do it, but 10% would give us ample room, I think, for the time being.

Nels?

Yeah, through the chair, thank you for both being up here. You've got quite a lot of insight, know-how on all the issues here. Uh, one of the things that I keep coming up against and you guys keep raising is how do you compete up and down the Gulf along the West Coast? How are you guys able to maintain your competition, especially with your neighbors that are in the unguided sector? Like, what— from the commercial side, outside looking in, you know, there's— it seems kind of like a black box.

I—. You guys mentioned that you are more engaged, you're trying to get into that, that space of how to better react to the unguided. So I'm just wondering, how are you guys able to diversify in ways? How are you able to compete? Or what sort of It's kind of a black box.

I'm just curious more what your thoughts are since you're here. I do. This is one of my favorite topics to talk about, Nils, um, through the chair. We want to be very clear. So on the record, CEO has chosen to currently— we started Southeast Alaska Guides Organization originally in these halibut conversations back in the early 2000s.

Recently, our board, in recognizing the dynamic shift that's happening into SEEA decided to take under our wings, for lack of better terms, the self-guided fleet. It is our staunch belief as an organization that people shouldn't be managed without them being at the table. This idea that if you're not at the table, you're the one being eaten needs to be taken out of any policy. And so it was our intent to bring them to the table and to do the work necessary, recognizing that there are staff limitations. So I'm going to—.

And we did that not because— not only that we want them at the table, but that we see them as valuable. There is, there's a lot of money and a lot of social access, whether it's in Tusiit from national or national people coming into Alaska, whether it's Fairbanks and Anchorage coming down to Homer. There is, there's massive need for that self-guide, and it has become at this point, after 20 years, a fairly stable and I would even argue historical participant in this fishery at this point. So with that on the record, I guess I was most excited to talk about diversification. We—.

Let me just figure or lay out what it means to run a sport fishery. Let's talk lodge specifically. So before my season even starts, typically years in advance, I'm sitting at a show sometime in December, January, February, and I am marketing with material that I had developed typically in my time off, my season off, to try to gain anglers to come to my lodge. Competing oftentimes with hundreds if not thousands of other opportunists across, across the nation, even globally. So not only am I doing the job of ASMI, I am doing the job of ATIA, and that's before those clients even commit to coming to my lodge.

Once they commit to coming to my lodge, then I'm doing booking, then I'm doing follow-up. Typically, I have to have some sort of social presence or some sort of website design because I'm a small lodge, I have to do that in-house. So that's taking time, that's taking resource, that's diversification. Once I have that presence and I have them book, then I have to send follow-ups. I can't tell you how many people ask about what gear should I take, how many underlayers should I have on this boat.

So I'm answering all of those questions, spending all the time on the phone. We haven't even touched the boat yet. The boat's still in the shed. When it's time for the boat to come out of the shed, then I'm doing work on that boat. I'm Rocky's Marine, I'm any of the other marine services prepping these vessels.

By the time I even hit the boat, I have been working months, typically 8-hour days. Like, our season is not on the water. So if we talk about diversification, where am I— what time am I diversifying with? I'm doing ATIA's job, I'm doing ASMI's job, I'm doing Rocky Marine's job, I'm doing the restaurant's job. I'm typically doing— there's a lot of in-house processing, so Silver Bay Seafood Seafoods, for example.

I'm doing their job. I'm packaging it up. I am a travel coordinator. This is not a short-term— if I'm going to run and own this lodge, my diversification, even to be successful in the program of being able to put anglers on the water, is already so diverse. Now, with that being said, can we diversify what's happening on the water?

Absolutely. Are we seeing that? Are we seeing people start to focus on the landscape, starting to really educate their anglers on the fishery, starting to spend time with whales. Yes, all of that. We live in Southeast Alaska, for like, of course you're doing those things.

The pods of orcas are following the exact same salmon that we're, we're following. Those whales are following the exact same food chain we're following. We are giving them all of those experiences. So do we add kayaks to the trip? Yes.

Are we looking at direct-to-market? We can't sell our fish. Our direct-to-market is how do we get anglers to come to our lodge? So that's— that is a very short and not even comprehensive example of what it means to be a sport fishery. And I would say that diversification is built into the business model.

Yeah, follow-up. I appreciate that. I've got two commercial vessels. I spend 9 months on the water. I know the amount of work that it takes to participate in fisheries.

I was— I guess I didn't focus it enough. I meant more like species diversity. Diversification. I harvest 5 species a year because that's what it takes to support my business. I'm just wondering, like, there are other species opportunities in the summertime for charter operators.

Have you guys expanded into that, or is there still just full reliance on, on halibut? That is a great question, Nils. As you're aware, with Southeast, we are growing in not only lodge-based capacity and desire for people to come here, but that's primarily largely being driven by our tourism industry in total. Because of the lack of CHP availability, what we're starting to see— and I want to be careful quoting this because it's not necessarily anecdotal at this point— but rockfish charters popping up, king salmon fishing happening off the cruise docks in Sitka, even our lodge operations. It is very common that you have— that is marketed, and you can jump on any of these websites halibut, salmon, rockfish, lingcod.

The diversification is there. On average, from the numbers we're getting back with that diversification, our anglers are leaving with somewhere between 1 and 2 boxes of fish for $5,000. You can do the math on what that adds up to per pound, whether it's halibut or rockfish, lingcod. And I would say even under today's regulations, that's fairly high. But there is, in the fisheries, definite diversification for us.

Any thought on additional diversification? Maybe just some examples. When I first started, we non-residents were at 2 lingcod a day, no size limit. Now they're in our area, they're at— you can only catch them between 30 and 35 inches and 1 annually. Rockfish are down to 3.

The pelagic rockfish, you can only keep 1 annually. There's just nowhere to go. Honestly, the short answer, there's nowhere to go. We've We've already been catching those for years, and then we started focusing on them, and the pressure, the change in pressure going to a different species is just, you know, we're just ballooning out somewhere else. We need something to sell, and we're just all species, we're restricted, so we really can't go anywhere and diversify anymore.

I have one question. You guys have been up here for almost 30 minutes, so thank you very much. I didn't hear a lot about what's in your letter, which is initiate the sector-neutral review of halibut mortality and your support. And my question was really just, we get most of that information in December. It's not in the same place.

There's the charter halibut measures that have the recreational component, charter recreational mortality, and then there's the in-season reporting from NMFS that has all the mortality in the different fisheries, including IFQ and trawl and so forth. Is there a reason the request isn't being made now? Because it seems perhaps that it's just not ripe and maybe it would be a better request in December, but I wanted to maybe better understand your support for it now and see if there's something additional that you thought this review could bring that wasn't going to come back in December. Through the chair to the chair, thank you for the question.

I hope the intent of holistic management is coming across, and I think that's just part of that. And we measure pounds and what's being taken differently. I think we need to holistically look at all of the different triggers that have been set up over the last— was it 50 years of the fishery? The last 30-ish years more precisely, and then even the last 20 years of support has come into it. So the intent behind support is, okay, let's look at it all, let's put it all on the table, let's figure out— let's bring us all to the table and figure this out.

And that's one of, I think, an important component of it is how is bycatch being used, how is mortality being used, where is it coming from, what is the impact.

Just to clarify my question, I mean Is there a reason to do that now versus in December when we get that information and then perhaps can make a more focused discussion paper request that, you know, that doesn't require staff to compile that information between then and now? And I mean, if we did— if the Council did initiate something today, I don't think it would come back in December, so it would almost be duplicative work that would come back later. So I'm just trying to understand why it is to do it now. Thanks. If I'm hearing correctly from the chair, there seems to be a timing desire to switch it maybe towards the December meeting to speak to intent.

It was holistic management. Let's give you everything on the table. If you choose to take it up, great. If you're recommending to us that we move it to December, that's something we can consider maybe off record and then bring it back to you. But that's the intent, was holistic.

I'm not weighing in on what I think is right. I'm just trying to understand. Thanks. Thanks. I appreciate that.

Thank you for your stamina. Appreciate it. We'll take Linda Banken and then break for lunch.

Thank you, I guess, for standing between you and lunch.

Linda Banken with Alaska Longline Fishermen's Association. I also wanted to thank the staff for their work. Um, substantial and is ever really well done. Um, so at the risk of documenting my insanity and age, I would remind you I've been engaged on this issue since 1993. That's when ALFA first brought forward to the council that the growth in the charter sector was being deducted off the top before the commercial allocation was set.

And with IFQs then on the horizon, people were going to be borrowing money, buying quota, and watching that quota get reallocated. Since that time, I think there have been 6 final actions, may have been more, with GHLs, changing GASLs, raising GHLs, moratoriums, the CHIP program, the catch year plan, of course, revising the catch year plan, and the RQE. And at each step of this process, there has been continued reallocation to the charter sector from the commercial fleet. And always, that allocation included more quota than what the fleet was catching at that time to allow for some continued growth, give a little bit of a ceiling while the charter sector figured out how to manage their harvest, how to market differently, how to think about limiting their sector, recognizing that this is a natural resource. All natural resources have limits, and times of low abundance are going to be tough for everybody.

That limiting has not happened. We have continued to see growth. I know you hear SEGO saying it's a stable sector, but we are seeing an increased number of trips. We're seeing this diversification to the unguided assisted unguided sector. I think Ms. Mann called that out correctly right up front.

SEGO now has a number of members, um, diversifying into the assisted unguided or recreational sector where those trips are offered. There isn't the same bag limit on those trips. We're seeing really significant growth on the order of 40% in the couple years, pushing 60%, um, depending on what estimates of where they were before, where they are now, are correct. That's really driven by this increase in bareboat harvest, or assisted unguided harvest. A lot of that coming from the people who are sitting up in front of you saying, we have a problem and our solution is to take it from the commercial sector.

So my response to you on that would be, until they deal with that issue, it's largely an internal problem. Not solely internal, but they have an issue they need to deal with in their own sector, that it should not take up more council time. It should not take up more staff time to do the analysis of all their things that they are asking for. I guess I want to point out that if you did the analysis on this fair market value within weeks, at least within a year, that analysis is no longer correct because the prices that the commercial fleet is paying are always going to fluctuate. The cost of charters, the expenses that we're all experiencing is always going to change.

And if you're trying to base it on fair and equitable, Then why do we only have a one-way street on GAF or RQE? I mean, if they want to allow the commercial fleet to start to buy from the charter sector or lease, either one, we were fully supportive of that. They didn't support that. They stopped that from happening. If we want to let the market dictate how the public best values this resource, that would be the way to do it.

Not to go through all this extensive analysis, not to open up the RQE and move more fish over to the charter sector, but to let both of them be in a place where we can lease theirs, they can lease ours, or we can purchase for them, or they can purchase from us. So I, I don't think that's really what they're asking for, um, but I would just raise that in response to some of the rationale that you're seeing from their comments and from some of those— from their written comments and from what you just heard. I just wanted to also point out that the commercial fleet has an owner-on-board requirement. We don't allow leasing. We have in 2C particularly a very high resident ownership of halibut quota.

Been increasing ever since the IFQ program was put in place. On the charter side, you have 98% non-residents as their clients. You have free leasing. You have absentee ownership. So if we are going to think about impacts outside of markets and think about communities, there's also a big difference between the sectors there.

Um, I guess just to— I know, um, to wrap up here, I just say we don't support dedicating time to Motion 1. We don't support Motion 2. I think those are the two that fall under this agenda item, so I'll limit my comments to that, but just ask that you take no further action at this time on those requested changes. Thanks. Thanks, Linda.

Any questions?

Chance. Chance. Nels? Chance.

Oh, Chance. Yeah, thanks for the— through the chair, thanks for the testimony, Linda. Getting back to your fair and equitable piece there, I just want to make sure I understand that you are saying In your characterizing this as being fair and equitable, if there was an opening of that two-way allocative transfer, I wanted to make sure that that's what you were trying to get at. I know that in the past when we've heard testimony on similar issues in past meetings, other stakeholders brought that up. I just wanted to make sure I was capturing you correctly there.

Understanding. Yeah, thank you. Through the Chair, Nils, thanks for that question. I mean, the Council has a a lot of national standards to balance when it takes an action and determines fair and equitable thinking about sustained participation by fishery-dependent communities. Optima— I mean, you know them all.

So certainly you don't base all your decisions simply on price. Um, and I would say that, you know, if we— if you want to respond to what's being asked for of let's let the market be more responsive to where the demand is between commercial and charter. Yeah, let's make it a two-way street. And I would add to that that the fact that we had $10 a pound halibut this year on the commercial side does reflect a really strong demand from consumers for their access to this resource through the commercial fleet. I mean, yeah, people value halibut and there's a lot of people who can't afford to come stay at lodges in Alaska and spend that kind of money to go home with a couple boxes of fish that access this resource from the commercial fleet.

And I would just ask that you keep that in mind as you think about fair and equitable values of this resource and, and who is benefiting. Chance.

Thank you, Ms. Megan. I really appreciate your, your knowledge and understanding and your tenure with this. I certainly learn a lot from every letter that you write and every time you testify. So just to start with that, I, I, um, I've noticed, and maybe you have as well, that increases in regulation in general, but for 2C specifically, seem to drive an almost linear increase in the unguided sector allocation. In other words, the tighter they squeeze the charter guys, the, the, the more effort goes to recreational.

Um, do you think that without some kind of action like that demonstrated in Motion 2, we'll see a rise an unguided effort as there's an increase in regulatory effort for the 2C charter fishery. So thank you through the chair. So just to be clear, I don't see action motion 2 doing anything to address the rise in unguided sport. Doesn't address unguided sport. But, you know, I think we're seeing that rise for, for years.

The recreational catch has in Tucson has bumped right around a million, a little below, a little above, because it's people go out to catch a fish to eat or for their family. And we just weren't seeing an increase in that. When we started to see the increase was when we started to see charter operators and new entrants offering these bareboat charters. So outfitting, in some cases, those boats are also outfitted with computer that shows them where to go. They're following someone out to the grounds.

You see a little mosquito fleet following a lead. I mean, it's pretty guided. They're just not under the definition of guided. And so the harvest rate is much higher than it would be for someone who lives in the community and goes out a couple times a year. They're out there, you know, June, July, August, right?

So their catch rates are higher. And that's what— where we're seeing that reeling increase in that recreational sector is in that bareboat charter unguided, assisted unguided effort.

Yeah, I agree completely. I have issues myself with how that's working. I don't think it should be allowed. I think it absolutely needs to be handled, and I think that across sectors, I think everybody kind of agrees with that. I guess to drive more at my question is the And while 2C or Motion 2 doesn't necessarily talk about unguided ultimate dimension at all, I guess my point is if we don't take action to ameliorate the decline of access to the resource in 2C and their measures as a result continue to go down, will we see in your estimation a rise and a continued rise, like will that pinch them further and create more of a problem?

Is it going to dig that hole even bigger, I guess? I guess I'm seeing it that way. You know a lot more about this than I do, frankly. But I'm wondering what your opinion on that might be. Yeah, thanks, Sue, the chair.

I maybe I missed your question before, but I don't think I have too different an answer. Like, yes, the low abundance is hard on all of us. And people are looking for other opportunities. So until we close that, what is now a loophole, that if you don't want to be under restrictive management measures, you diversify your business into the assisted and guided model bareboat charter. We're not, we're not going to solve the problem.

But I think taking more from the commercial might solve your problem, but certainly doesn't solve the problem of of the commercial fishermen who have invested a lot in holding halibut quota and being participants in that fishery.

Heather. Thanks, Mr. Chairman. Thanks, Linda, for the testimony. I just want to clarify your recommendation. So you said no action on 1 or 2, and you didn't feel that Motion 3 belonged under this agenda item.

Can you just provide a brief context about that? I think it's because you think understaffed task— that people think understaffed tasking, maybe starting an abundance-based management approach. Is that—. Yeah, through the chair, I think the charter committee doesn't meet all that often, and maybe they thought this was the appropriate time. To bring that issue up and take action on what is Motion 3, but it's not specific to the action before you right now, and that to my mind that's better discussed under staff tasking.

Thanks, Linda. All right, we'll break for lunch. We'll come back at 1:30, and we'll see if there's any motions to make.

Okay, it's 1:30. We're back on record. We've had public testimony and staff presentations on D1.

Any motions?

Chance.

All right. D1, Charter Halibut Permit Data Request Discussion Committee Report Motion. The Advisory Panel recommends that the Council initiate an analysis to explore explore the potential effects of eliminating or modifying the cap for guided angler fish described under 300.65 in IPHC Areas 2C and 3A, either permanently or for a set duration. Analysis should also include a section exploring the possibility of, of NIMS to change the annual transfer cap of IFQ to the RQE described at 679.42F8I from 1% to 2%. And with a second, I will provide some rationale.

Second.

The purpose of this motion is to evaluate the interaction before increased RQE holdings begin to displace the existing and tenured management tool. GAF and the RQE serve different purposes. The RQE provides a sector-wide benefit through permanent acquisition of quota share with the interest in providing regulatory stability. GAF provides annual flexibility to CHP holders and operators who own or lease quota share. My intent is not— is that this analysis could explore if there is an amendment that could be made such that GAF would not be constrained as the RQE acquired quota and how.

For example, a 5% or 10% increase to the GAF for a 5- or 10-year period period of time while the RQE acquires quota would provide for, at minimum, a status quo opportunity or opportunities similar to regulations seen in 2018 or before for 2C. Overall, RQE caps would still apply. This fishery is currently expressed as being on the floor of commercial viability, and decreases in 2C management measures result in almost linear increases in the unguided rental sector. An action here is likely to drive more operations to bypass management measures by providing unguided rental. They simply won't be able to compete.

This motion does not pre-select a separate gap percentage or a higher aggregate transfer ceiling. It asks the council to analyze whether meaningful gap access can be maintained while preserving appropriate safeguards for the commercial sector and fully accounting for commercial, charter, and quota market effects, and for how long. It is my intent that this analysis should evaluate alternatives for maintaining a meaningful, separately defined gap transfer allowance while preserving appropriate limits and safeguards on the overall amount of commercial halibut quota made available to the charter sector. It should consider recent demonstrated GAF use, impacts on commercial quota share availability and value, impacts on entry-level commercial participants, and the effects of CHP holders that rely on GAF, including CHP holders who own commercial quota share IFQ and self-transfer GAF. The intent of the second element of my motion recommends that the council evaluate increasing the annual RQE quota share acquisition cap from 1 to 2 2% in Area 2C without changing the existing 10% cumulative limit on RQE quota share holdings.

This will allow for a faster acquisition of quota share.

Thank you. Questions? Heather. Thanks, Mr. Chairman. Thanks, Chance, for the motion.

It's all right.

This motion is really pared down from what was in the report from the Charter Committee. Could you put a little context to why, why that is? For example, I think in the, in the report from the Charter Committee, it did have like the 10-year stay of getting rid of GAF and things like that. So can you help me understand how it went from that to what you're proposing now? Through the chair, thank you, Heather.

It's in response to public testimony. The time element was in response to Nell's commentary earlier, his questions. I thought he had some good points. And while the paper talks about 2Cs fully realized RQE being unable to return them to a fish of any size ever, it also illustrates that a fully realized RQE at the time of current abundance gives them 4 inches larger on their current management measures, which is still a very challenging place to be. And as that unguided sector grows, I think there needs to be something that is done.

I think they're in trouble. But I wanted to simplify the motion and make it consider some of the comments that we heard here. Thank you. Loren?

Thanks, Chance, for the motion. Um, did you consider, um, putting anything in here regarding actions on, um, you know, looking at the unguided fleet or at Abundance and the effects that that has had on this allocation and, and/or any safeguards that could be around that? Because I think that the only thing being explored here for creating more allocation is is through GAF. And so just, just curious if there was any consideration of those two things that are very greatly affecting the allocation.

Through the Chair, thank you, Lauren. No, unguided concern was not part of the CHP LEP paper, and so I didn't bring that into the consideration. I think that's an elephant in the room and that everybody here and and sort of sector-wide is interested in managing that concern. It's my understanding that there's some legislative effort happening, and if it doesn't happen by the December meeting, I think we'll see some motions regarding that then. But I was advised to give that time before responding to it.

Through the Chair, thanks for the motion, Chance. One of the things that I keep coming back to through analysis, presentation, testimony is that one of the large hangups with RQE implementation or attainment of the annual percentage purchase in 2C is partly because of business models by 2C charter buying IFQs and then gaffing it within the sector, not wanting to give that up to create available pounds for the RQE. I mean, there's other market considerations, but that was touched upon in multiple, multiple times today by different, different folks at the table. So I'm just wondering how eliminating or modifying the cap for GAF, which seems to be part of the crux of the issue with RQE implementation, how expanding or extending that would help the ultimate implementation of the RQE, if that's intended goal. Thank you, Nels.

Through the Chair, yes, that's one of the reasons I asked during public testimony Forrest to comment on his concerns with GAF impacting the ability for the RQE to fund itself. It's additionally why I asked Mrs. Merriman during staff presentation about the number of self-transfers. I feel personally that we should have a conversation about protecting self-transferred GAF for people that invested in and purchased GAF for this— or quota share for this purpose to essentially use it as GAF as owner-operators. I think they should be able to continue to do that. And 3A, that effort is between, I think, 11 and 67% of all GAF transfers between the start of the program and now from the GAF report in 2025.

But I think that sort of protecting that moving forward as an alleyway is something I would be interested in. But I, yeah, I think that there's an issue with availability, but they also need it to survive. It's a crux, and it's just the hand they were dealt. And, you know, without doing something about it, I think it's going to get worse.

Other questions?

Any amendments to Chance's motion? Lauren?

She's gonna send it to Serena.

The AP recommends no further reallocation or changes to the catch share plan until there is a mechanism to monitor and address the effects of the unguided rental boat industry on halibut removals. The AP also encourages the council to create a definition for unguided sport fishing service provider and work with the appropriate agencies in the state of Alaska to further efforts in this area. The AP recommends the council increase the annual transfer cap for the RQE to 2% in Area 2C.

Second.

Okay, probably fix that 'and' and make that one sentence. Sorry.

So Motion 2 that came out of the Charter Halibut Committee was the basis of the motion that Chance brought forward, and I do appreciate the way he pared it down and, and tried to simplify this into something that was examining specifically GAF and the ability for GAF to function. But GAF was part of the RQE package that was designed as a compensated reallocation mechanism to address issues within the catch share plan. The RQE just finished its first year in activity. We've only just begun to see it. They raised money, they bought some quota, so in theory that is a success in which they were able to execute the program.

The relief is not immediate, it's a small amount of quota they brought, but also we should give it time to function before we make any further changes to the catch share plan. The major underlying problem with this issue is abundance of the resource. And also the diversification of charter operators into the assisted unguided model. As we heard, they can sell clients the ability to harvest 2 fish of any size, but they have to drive the boat themselves. So this is driving a significant increase in the harvest by this sector.

In 2025, the unguided sector was over their annual allocation by 35%. That harvest is deducted from the total allowable catch before allocations for the commercial and charter sector are set. So in 2C, the impact has become significant. And in 2026, the allocation for charter and commercial was deducted by 10%, not because of conservation or abundance concerns, but because of the increased harvest in this sector.

The unguided fleet is a large part of what is eroding the allocation for both charter and commercial.

But the charter sector is responding by saying, "We need more allocation." Ironically, they're the ones really driving this erosion of the allocation, as a lot of these lodges are expanding their business model to include this.

We've all taken a cut over the last few years. In Seago's comments, they specifically looked at 2017. 2026. And if you look at their numbers, it was a 30% cut. Ironically, my family bought some quota in 2017.

We've taken a 34% cut from 2017 to 2026. And all of that was due to conservation except for in 2026 because of the increase in the unguided harvest. So when I look at this and I look at the opportunity for creating a further mechanism for reallocation, I don't think it's going to change the needle if that allocation is going to continue to be eroded by a sector that is currently not well monitored, growing, and continuing to increase in their harvest. So in the end, we're all trying to run a business and create stability, and abundance issues impact all users. So we need to continue to work together to create a mechanism to track and manage the growing unguided charter sector prior to opening up any other reallocation conversations.

And I did include the second part about the RQE transfer to 2%. I do agree that that is a reasonable ask, and if they're able to raise the funds and find the quota, there's no reason that they should be hindered from trying to reach that allocation as they were allotted. Happy to take questions.

Questions?

Jim? Oh, thank you, Mr. Chair. Thank you, Loren, for your motion. And this is not a trick question.

I don't know the answer to this, but is the increase of the annual transfer cap to 2%, is that a feature of the catch share plan? Is that something that the catch share plan stipulates to be at 1%? I don't understand. Sarah is shaking her head, but no, I think that was just part of what they agreed upon in the RQE in terms of having it be like a metered transfer over time. And if you want to speak to that, Sarah, that's consistent with the plan.

Yeah, uh, through the chair, this is Sarah Marin, Council staff. Um, no, the— in the, um, implementation of the RQE, you're talking about the annual transfer restriction, the 2%? In the implementation of the RQE, um, For Area 2C, there's an annual transfer restriction of 1%. That's what it is right now. So this motion looks at changing that from 1% to 2%.

So they could transfer— they could purchase 2% of the 2C quota share pool in a year instead of 1%, which is the current restriction. Okay, a follow-up. I think I understand that. My question is, in the The very first sentence, first line, it says no changes to the CAT share plan. So is it in fact a change to the CAT share plan if we increase the annual transfer to 2%?

Through the chair, Jim, I think the intention here is that it's a change to the RQE regulations. I think that comes across in the motion.

I have a question for you, Sarah, while you're up there. Is the change— I'm not an expert on this, so this is probably a dumb question, but I'm trying to understand it. It sounded like there was a disagreement of perhaps whether or not some of the changes envisioned in the first part of Chance's motion were changes to the catch share program or to the IFQ regulations.

Is that, um, and I don't want to put you on the spot of making a subjective, uh, statement, so I'm just trying to understand if, um, Chance's motion is opening or making changes to the catch share plan or not.

Um, Mr. Chair, so I guess the way that I see it is The RQE was authorized as a nonprofit entity to participate in the commercial— in transfers of commercial halibut IFQ to supplement the allocation for charter anglers. So it is sort of an aspect— it engages with the catch sharing plan. It doesn't change the underlying structure of the catch sharing plan, which set up the allocation and has specific thresholds at which, under different levels of abundance, a different split happens between the two sectors. That was set during the catch sharing plan, the underlying allocations, and, and also the annual management process that happens each year where we come in December and talk through annual management measures.

That's a part of the catch sharing plan. So none of what I think is in chances motion would change that structure. It's looking at a change to an aspect of the overall transfer limits for the RQE and GAF. So, I mean, it might be a matter of semantics, but it sort of— it engages with the catch sharing plan, but it looks like the intent is to change a component of how the RQE and GAF functions. Does that help?

Yeah. So your answer was in in regards to both the RQE language and the changes to the GAF cap that he was exploring. Is that correct? Yes. Okay.

Thanks. Thank you. I— sorry, I'm just wondering if this qualifies as a substitute motion because I'm not trying to change, as Sarah just described, the catch sharing plan. It's a market tool. GAF is a market tool.

So I'm— I kind of want to— I guess push back a little bit about that. I don't— I think I'd push back that changing GAFF is not changing— is not reallocation. Yeah, that's what I was trying to understand. I think if we can just take a 5-minute stand down and we can work through this, but I was just trying to understand that from staff, so thanks.

Okay, we are back on record and we're going to, uh, we're going to withdraw the substitute motion and change it to an amendment.

Okay.

So let me know when you're back on the D1 and I can just let you know what it is.

Okay, so it would just be to strike the first paragraph and leave the anout— the second action regarding the 2% change.

Okay, we'll look for a second.

Okay, um, thank you for your patience in walking through this, and I understand, um, the confusion on that. So ultimately, they ask us to take no further action at this time, um, on examining options for reallocation, um, stating the same reasons that I gave before, primarily stating that there's other underlying issues that are greatly affecting the allocation in the sector that hopefully will be and need to be dealt with in a more timely manner before we look at other reallocation opportunities.

Thank you. Questions?

Chelsea.

Thank you. Through the chair, Thanks, Lauren, for the amendment. Um, my question is, even if this is an intent to not look at the catch sharing plan and just to look at changes to the RQE regs, I'm wondering if you could speak to your rationale, or maybe I'm just confused since this isn't my, like, language either. But to me, fundamentally, it seems like allowing the cap to expand, even though it's a compensated transfer, that's still quota leaving. I have— it's still a compensated reallocation.

So I was just wondering if you could elaborate on, so, your rationale of why you support that but not, um, the uncompensated, how you balance that. And I think the The main thing is that if there was a mechanism right now to create a cap or an allocation or a way to control the growth in the unguided sector, I think I would be more amenable to looking at the extension of GAF because it is a compensated model. My concern is that what— what the reason for looking into this is because they want to increase the allocation, but the allocation is going to continue to be eroded by the growing unguided sector. So it's not going to necessarily help. Like, if, if that sector continues to grow at the rate that it has been, then this analysis, you know, for continuing to create more allocation, it doesn't seem like it's going to necessarily have the effects they're looking for because we have a continued erosion of the allocation from somewhere else.

So part of it is just energy being spent to fix a an underlying, like, issue creating this before you look at other alternatives to solving it. It's like, we know one source of the problem right now, and there have been some efforts to fix it, but it hasn't gotten enough momentum and hasn't actually occurred. And so until that can happen, and then we know what that's going to look like, I hesitate to look at further reallocation schemes or extensions of them. Okay, thanks. I understand that.

I guess I'm still just confused is how is the part that remaining increasing it from 1 to 2%, how is that different to you? How does—. How is that— why are you okay with that change? But because to me, and maybe it's just not— I'm not understanding it, but it's still moving commercial quota to recreational even though people are buying it. So I guess, how is that okay is more my question.

Yeah, sorry. Okay, and this is very complicated. So the agreed-upon amount of compensated reallocation was 10%. So the idea was, is as the RQE purchased quota and that was brought into the RQE, that amount would then be removed from GAF. And so there would be like the access point.

So GAF was meant to phase out as the RQE came in. So that 10% was always the total amount of the compensated reallocation model. So examining extension of GAF is increasing that number from the agreed-upon number that the program was supposed to implement. And that goes back to me saying that this is year 1 of the program. You know, they're just getting started.

So I, I have no problem with them increasing from 1% to to 2% because that's all within the 10% cap that was placed on the entire program. So what the initial motion is looking at is expanding that outside of the 10% to continue to include GAF into that. I hope that helps. Okay. Other questions on the amendment?

Rick. Um, through the chair, thank you, Lauren, for the substitute and for that explanation. I think it Clarified something. I just want to make sure that I'm understanding. So the 10%, so going from 1 to 2, that's what changes it from like a 10-year plan to a 5-year plan.

Thank you.

Any other questions?

Any amendments to the amendment?

Okay, comments? Chance?

I guess I won't be supporting the amended motion. I don't understand why analysis about the viability of GAF continuance has anything to do with the recreational and guided sector. It's not analyzed in the discussion paper. Protecting self-transparency is transfer for commercial fishing owner-operators who hold quotas should also be important moving forward. And I think that that's something that would come out of analysis.

And I think we need to do something for, for 2C area fishermen specifically. Increasing the ability to change annual transfer limits is helpful. In that same 10-year program, it allows them, if market, if market permits to purchase more quota to transfer into their RQE. If it doesn't, then it doesn't. But so, I mean, I think that's wonderful that that remained, but I think that it's important to try to do something about this, and I think that an action on this that results in increased management measures for 2C halibut fishermen will increase the recreational unguided effort in that area and make the problem even worse.

Other comments? Heather? Thanks, Mr. Chairman. Thanks, Loren, for the amendment. I actually am going to align myself with the comments that Chance just made.

I do think that just taking a look is a good idea. I am— I think we're all concerned about the unguided or assisted unguided sector for sure, but I don't see a quick resolution to that. And I was really compelled by some of the public comment, particularly from Sego, about where people are going to be next year. And so the other thing I really appreciated about the original motion was you really did pare it down and were responsive to concerns from commercial, um, I thought. So I'm not going to support the amendment.

Lauren?

I think for me, just to kind of clarify some of the things that Chance spoke to is that, you know, this paper was looking at charter halibut permits and use and opportunities for, you know, what could and would work to make this sector whole, but nothing was included around the causes of what is it— what they're facing. So for me, it was hard to read that paper and not have a single line speak to the abundance of the resource and the declines in the resource and where that's played into these decreased opportunities for fishing. And I think that's a huge part of that conversation. And so, and I understand the paper addressed, you know, the specific outlined asks, and it did, and there was no ask to include abundance in there, but it seems like it's a very large part of that conversation. Allocation that is missing.

So for me, this skips a huge portion of what is eroding that allocation and the decreased opportunity, especially in Area 2C. And it's playing a really large role in that. And so to go directly to solutions without acknowledging the abundance issues or further erosions doesn't seem like a realistic move forward. It doesn't seem like— and maybe realistic's not the word I'm looking for, but I think that that's where I'm coming from ultimately, is that to read a paper and have nothing mentioned about like the largest underlying factor being the abundance issue and then have it not acknowledged in, you know, comments from the industry that's representing that paper was difficult. For it to turn immediately to an allocation issue was difficult to read.

Halibut's important to everybody.