NPFMC October AP Meeting, Day 2, 10.08.2026

Good morning. AP is back on record at 8 o'clock. We are going to continue on with the staff presentation on C-3 groundfish harvest specifications. Sarah? Good morning, Mr. Chairman, members of the AP.

I am Sarah Cleaver, Council staff. With me is Diana Stram. We're the groundfish plan team coordinators and we are presenting on the Gulf of Alaska, Bering Sea, Aleutian Islands, and joint plan team reports from our recent meeting. We'll also be kind of blending in some updates from our side on council staff as part of these presentations. And note that the SSC took up these agenda items over the past couple of days.

So we'll try to answer any questions on updates from them as we can. On the screen here, we have a list and just pictures of our plan team, the chairs and co-chairs of the plan teams. And I'm not sure if we have any of them on here this morning, but just wanted to say thank you to them for helping us get through our plan team meetings and prepare for the APN council meetings.

This is just a list of our, uh, plan team members, and we wanted to note that, um, Steve Whitney and Sophia Wasserman had their last meetings with us, so we wanted to not only thank all the team members but Steve and Sophia for their contributions to the teams, uh, over over the past many years.

Our future meetings, we have an upcoming plan team meeting where we'll be doing the final recommendations for OFLs and ABCs in November. We also have the dates for our November meeting next year, but we are still waiting to determine our dates for the September meeting next year. That meeting will be virtual, and we should have those dates for you by the December meeting of this year. So stay tuned for those. And the— both the November meetings will be in person.

This year is a little different, though I think I say that every year. Last year we had impacts, or we're still seeing impacts from the government shutdown, so we have a lot of assessments to review this year, and we've changed the scheduling of these due mainly to SSC and plan team review timing. So at this meeting, the APN council, you all, go through proposed harvest specifications, which are usually just some summary updates and a rollover of the specifications so that it notifies the public of expected council action later on in December. Our assessment plans for this year make that a little bit more confusing. So in September and at this meeting, we had our proposed models for certain stocks reviewed on— those stocks are on the left side.

That is our typical process where we bring forward proposed models. And in addition to that, the plan team and SSC reviewed SAFE chapters and provided their final recommendations for the next 2 years on the stocks that are on the right side of the screen. Again, that's simply due to review timing. So the AP and council, you will not be providing any final TAC recommendations at this meeting.

We will bring all of the information on those stocks forward to you with all of the other final stocks at your December meeting. So these are— this was mainly or specifically for Plant Team and SSC review.

Going through our joint plan team presentation summary, Diana and I typically don't walk through all the proposed models at the AP Council for this meeting since you'll be receiving all the final updates in December, but we just wanted to note what, what the topics at our plan team meeting were and note that we have the the plan team report that highlights all of the discussion and recommendations on these agenda items on your e-agenda for you, and we'll highlight some of the specific updates from this in this presentation, but very high level.

At the plan team meeting, Pat Mallica provided an update on the long line survey logistics and methods and reviewed the, the standard data collections That includes the catch lengths and otoliths, as well as some, some tagging of sablefish, short-spined thornyhead, and greenlit turbot this year. And as a reminder, the longline survey changed starting in 2025 from sampling the Gulf of Alaska every year and the Bering Sea or Aleutian Islands every other year. So now it samples the Gulf of Alaska in odd years and the Bering Sea and Aleutian Islands in even years. So this year, 2026, was a Bering Sea-Aleutian Islands year. And they collected a lot of information, and the temperature data for subsurface temperatures was near average in both the Bering Sea and the Aleutian Islands.

And we have some kind of the raw survey data here for Pacific cod. It was down in the AI, up Bering Sea, Greenland turbot was down in both areas, shortraker was up in both areas, and ruffeye blackspotted was up in the AI and down in the Bering Sea.

A summary of kind of some of the significant proposed changes to the sablefish assessment. As a reminder, we didn't have an assessment in 2025.

But also in 2025, we had that survey change and that created a problem for the stock assessment in that in any given year, we only have about half of the usual survey area that's actually sampled by the survey. And so the authors are recommending a new modeling approach to try to deal with some of the survey challenging of not sampling all of these areas in the same year. The sablefish assessment also underwent a CIE review, and I think you, you heard about the extent of this, yeah, of what can occur within a CIE review yesterday during your ADP presentation. The sablefish assessment went through one of those reviews in June, and trying to deal with that survey change was a large part of that review.

There was a lot of substantial documentation provided at the plan team meeting on that review. So if you're interested, I encourage looking on the plan team e-agenda for the results of all of that, and the high-level results of that were also presented to the SSC.

The most recent long line survey for sablefish, uh, the results were mixed. So the Aleutian Islands Index increased by 26% compared to the last time that it was sampled in 2022, and that's near historic highs, while the Bering Sea Index declined 14% compared to the last time that, uh, that was sampled, which was 2023.

The authors' recommended model, which again, the kind of final recommended models are provided in November and at the, at the plan team and SSC meetings. At this time, they provide a suite of models that they want to see the results of upcoming in November, but the authors' recommended model at this time had a 32% decline in the Alaska-wide ABC from the 2026 harvest specifications. So that's, that's not saying that that is the 2027 ABC because we don't have that, that information yet, but trying to, to provide some information on the relative magnitude of changes that we would see from the authors' recommended model.

Yeah, through the chair, thanks for the presentation so far. I know that sablefish took up a significant part of this conversation in the SSC. We don't get SSC minutes, but I just wanted to touch on— we saw the averaging across the AI and Bering Sea is positive in the survey results, yet the recommended management model is a 32% decline. I was wondering if you could unpack that a little bit more, provide context from SSC discussion. Through the Chair, thanks, Mr. Evans, for the question.

So I'll caveat this by saying that SSC will do a heck of a job better than this at the SSC report tomorrow, but overall there were so many model structure changes in both because of the, the survey change as well as, um, uh, some of the changes that we would have seen to the model in 2025 had we had the assessment, um, that a lot of these, these structural changes ended up in a, um, a decline that is not necessarily indicative of a change kind of in the population, but all of these, all these model changes together have really compounded.

And the author's proposed apportionment method is a little bit different, or I guess the recommended apportionment method is different from the author's recommended model, and it actually somewhat, somewhat re— not redistributes, somewhat mitigates the changes in the decline that we would see in the Gulf. But overall, because of the significant decline in the ABC, those changes across all areas in apportionment are actually, they're all negative.

The SSC had some comments about whether or not the author's recommended model is the right approach, and they chose to try to bring forward an additional— an additional model that we obviously don't have the results of yet. But they had some concerns about the author's recommended model and— I can't remember the rest of what I was gonna say there. Do you have anything else?

You know, we looked at this pretty hard and a group of us were at the SSC to speak about it, but, and this is no way meant to be a dig or controversial, but why so many model changes? You know, and they really affect the population. I mean, you just, plug them in and the population just jumps all over the place. And from what we're not seeing logbooks used anymore, we're experiencing almost the highest CPUEs, well we are experiencing the highest CPUEs that we've ever seen. The fish are healthy, they're very fat and not sores on them, it's a great biomass.

And it just seems like these models are, you know, with little changes in mortality and stuff, they just jump, you know, tens of thousands of pounds. And it's tough, you know, if you're in the industry, you're trying to plan, and it, I guess I'm just saying, why so many model changes?

Through the chair, Mr. Burkhalter, I think it's important to remember that they did just go through a CIE review, so it's a combination of not having the assessment last year, working on assessment modifications, changing some data weighting, removing some data that both the authors and the CIE recommended. They did do a stepwise breakdown at the planning meeting as well as with the SSC as to what all of these changes were. But I think the important thing to remember is that there will be possibly as many as 4 different models that would be reviewed in November. So no recommendations have been made yet on which model will go forward. We're just trying to give an indication that there were a number of changes, but the important part to remember is it's a combination of all of these changes that's resulting in some of the trends.

And that's not updated for current I believe that the models that we looked at in September are not updated for the current survey, so you may see different trends when you come to the November meeting, regardless of which model that is brought forward. Thank you. Lauren and then Jill. Thanks, Mary, for the question. And just, just a slight follow-up to Anna on that, you know, you said that's not the model that is being approved at this point, and I understand that, but in the documentation, how much weight does the CIE review?

Because everything there says like, this is the preferred model, this is what we want to use, this is the best available science. So what weight do they put on that? Thank you. Through the chair, Ms. Howard, I cannot speak for the SSC, but they had a number of comments, um, in particular about the strong weighting that the CIE gave to its specific model. So no decisions were made.

They acknowledged that they— I really don't want to speak for them, but they did take a little bit of umbrage at the presupposition that the CIE was deciding which model would go forward. So that is one of the reasons why they suggested another model configuration. And the authors were already bringing forward 3. The SSC suggested a 4th. Whether or not they can whether we will fully explore all of those given the workload involved in that is yet to be seen.

But I would certainly not say that the SSC was leaning forward with just because the CIE recommended it.

Jim?

Thank you, Mr. Chair. Thank you for your presentation. I recall maybe 5 or 6 years ago, we approached things from an apportionment point of view, and I think I'm just curious with the model, or how much does apportionment now impact this, what seems like a big whipsaw in the ABC? I mean, if we weren't apportioning things like, if we were back the way we were 6 years ago, is there any, I don't know, do you understand my question?

I'm just curious, you know, what apportionment might do to the modeling and to what extent it plays a factor in all this. Thank you. Through the chair, Mr. Johnson, I don't think that the apportionment would have a— the apportionment wouldn't have any result on the potential decline in ABC that we're seeing, and the author provided information at the plan team meeting and at the SSC meeting that they didn't have any biological concerns if there were to be changes, some small changes in apportionments, just because of the, the nature of sablefish being an Alaska-wide stock.

So the apportionment methods don't really offset what could be these potential decreases in ABC as the, the output of the BRDs or apportionments across the board all drop in this case if the author-recommended model were to move forward. And that's without all of the information that we have from from the 2025 survey in the Gulf. We haven't added those— that information into the model yet. So apportionment could kind of mitigate some of those declines in certain areas, but it wouldn't change kind of the overall trend that we would see in whatever model is recommended. But there are some some options for apportionment that could be guided by the council to try to offset any of these impacts across regions.

I have a question. I appreciate you entertaining so many on sablefish.

I'm wondering if there's any conversation at the plant team or SSC regarding how to communicate some of this— these decisions and changes to stakeholders. Just recalling, it's not a completely analogous situation, but when the cod crashed in the Gulf in 2018, I think the authors did a really great job at being very proactive on trying to communicate what was going on with the model and to really break down the science so that fishermen could understand. Sablefish really impacts almost every sector, and it's a really important fishery for all of us, particularly the Alaska-based fleet. And so I think it's really critical that we understand these big changes. And so just wanted to see if there was any discussion about how to do that or whether we should be asking for that separately.

Mr. Chairman, I think that's a really good point. And I know the folks at Auke Bay Lab have been having a lot of conversations with stakeholders when they're approached, and they've been trying to send out information as they are requested. So they're trying to get ahead of it a little bit, but I think any feedback that the AP can provide in terms of how to better communicate, particularly when we have these, these plan team meetings and SSC meetings where the intended audience is really scientific experts, but we are trying to make sure we can communicate all of these results to a public audience with a better understanding of what's going on. We would appreciate any feedback on how we can do that, and we can certainly kind of be the conduits to those at the Science Center to try to figure out how to best communicate this to everybody. Thank you.

Heather. Thanks, Mr. Chairman. Thank you for the presentation so far. A lot of folks in the industry have talked about sort of a phase-in, and because there is no conservation concern here, is that something that the plan team and SSC talk about, or is that more what you were saying the Council could mitigate impacts so that you don't just, you know, walk off a cliff because there is no conservation concern, or people keep saying there isn't a conservation concern. So wondering where that fits in.

Through the Chair, Ms. Mann. So the— any changes, if there were to be kind of this stair-step of apportionment or phase-in towards the results of a new model. That should be driven by the council and stakeholders. We've had a lot of conversations about apportionment for other stocks, and when— once we kind of hear confirmation from the author's plan team and SSC that there may not be a conservation concern with some small changes to apportionment, We typically try to have that be guided by the council rather than the scientific review bodies since it's more of a socioeconomic impact that would be driving changes to the apportionment rather than kind of a biological need for those changes. So that's certainly something that could be driven by the needs of the council and stakeholders.

Just to follow up a little bit, it, um, if you're talking about a phase-in of the overall ABC, we've only ever done that when the ABC jumps up, not when it jumps down. There isn't really a mechanism because once the ABC is set, it is the max ABC, and there is no mechanism for, for stair-stepping above the max ABC. So again, with the caveat that we haven't decided the ABC yet, that won't happen. Until after November and then December. But just to set expectations that that isn't the kind of stair-stepping that we do.

We only do it on the way up and not on the way down.

Jim, did I see your hand? Yes, sir. Thank you, Mr. Chair. I appreciate you bringing the matter forward about how to communicate this to the stakeholders, since my question is kind of framed that way.

The groundfish team meets in November, second or third week, is— and I assume you both ladies are on that committee— I just want to ask, you know, in terms of making these interests of ours known, like we had discussed just a few minutes ago, is there an— how would you advise, I say me, to do that at the groundfish plan team? I mean, I think we— they do take testimony, but I want to signal strongly that, you know, industry is very concerned about this and the process, you know, this goes forward into December. So I feel like we need to try to make sure we understand this. So I just ask that of you. Thank you.

Thank you. Through the Chair, we can certainly communicate that to the plan teams and the authors in advance of the meeting that this was something that came up and we can note it at the beginning of the plan team meeting. But just to make sure that everyone is aware that We are, from the council side, also working towards increased communication and overall communications and education. So we can certainly try to communicate that to the teams and the authors in advance.

Nels? Yeah, thanks for fielding all these questions. Going back onto that stair-step question that Heather asked. Just historically, do you guys off the top of your head know what the largest decrease in sablefish ABC has been in recent— I don't know, within the last 10-20 years? Has it been within the range of the 18 to 32% that's proposed in either Model 26.1 or 26.2, just for— just trying to build context around these cuts?

Through the chair, Mr. Evans, off the top of my head, in the time that I've been around, I don't recall one being quite that dramatic a drop. But again, we'd have to go back and look. But I don't recall. We've obviously, as I'm sure you're aware, been facing the opposite issue of the large recruitment pulse driving up the ABC and then trying to look at how to, how to downweight things so that we're not having such a dramatic jump until we are a lot more certain But we could certainly go back and check on that.

Thank you, guys.

I guess I think maybe I mentioned this in these— in this discussion in Q&A, but the— we don't have all of the information yet from the 2025 longline survey age comps, and those are from the Gulf of Alaska. And so this is information that we, we didn't have at the plan team meeting, but these— there are indications from that information since we don't have any, any Gulf survey information from 2026 that the 2020 to 2022 cohort strength, that those are positive indications. So just an update in terms of setting any expectations forward that there, there will be changes to the information that we see in November. And that is one piece of data that had not been included before that we wanted to make sure was provided to everyone. So there is some positive indication, at least in that information.

This is just the plan team recommendation since we are providing the joint plan team report here. The teams appreciated the significant effort that all these model changes take and the documentation that was provided by the sablefish assessment team, and the team did recommend bringing forward different models in November. The SSC, as Dr. Stram mentioned, has recommended an additional one, additional one come forward as well. The plan team recommended avoiding further reductions in long line survey coverage, and we heard a lot of concerns about age data collection. The team felt it was really important to maintain current levels at a minimum, particularly given the decreases that we've seen in being able to age otoliths in the Age and Growth Program due to staffing and capacity constraints.

The—. As I mentioned before, the author-proposed updated apportionment methods Given that change in the survey design, this could result in large changes, but as we've talked about, the apportionment decisions specifically are made in November and December when the final ABCs are provided by the authors, plan team, and SSC. So while we are trying to get ahead and let the AP and council know where input or guidance might be helpful in terms of apportionment. The actual recommendations for those numbers coming out of the flip plan team are in November.

Sorry, Susie, it's hard to—. Thanks. On that comment specifically, and I'm thinking overall since there's, uh, there were some birds that went into the table that are posted to the agenda. Um, so would those just be considered proposed birds that we're setting today for, for Bering Sea? Through the chair, Ms. Zagorski, yes.

So all of the— you'll recognize that there are two different tables, which is different. Well, normally we have many tables, but we have an additional table this year as well So, what we did was try to have our proposed specifications table, which is just the rollovers from the final rule, which was published in March, and that's kind of our typical proposed recommendations until we can do the final recommendations in December. And then we have another table, which is really just the— which is the final OFLs, ABCs, birds on select stocks from the plan team meeting since they did review final assessments at this meeting. And that table for select stocks is back pocket information to be used in the council's tax setting process in December. So we have the proposed specifications, which are all rollovers, and then we have plan team and SSC recommendations for certain stocks that will end up being part of your final specifications in December.

So it kind of looks like we have two numbers for certain stocks, but it's more of a process issue. So you're correct that those are just the proposed specifications for staplefish. Okay, thanks, that helps.

Yeah, clarification that the final tables for select stocks, those we specifically didn't include those on your agenda so that you don't get confused that you're not setting any final tax at this meeting. Those are just on the SSC agenda.

As we usually do in September at the plan team meetings, we get a report from the Halibut DMR Working Group, and they provided, um, updated Halibut DMRs for the next 2 years. This is usually part of your proposed rule package, and these will not be changed, um, in December. And so the teams adopted these DMRs based on the working group's recommendations, and the only change in terms of methods for how the DMRs are calculated was there was a removal or the Gulf nonpelagic trawl rockfish program group was removed and it is now being part of the nonpelagic trawl CV group and that was just because of the low number of halibut assessments that were within that, within that category.

Thank you, Mr. Chairman. Can you tell me what, like, what criteria is used to make the change in what's recommended? So there's some changes between '26-'27, '27-'28 for some of the lines.

Through the chair, Miss Mann. So the— when the halibut DMR working group meets, they look at any of the updated samples that they have from their observer, I think they're called injury— are they injury assessments?

Viability assessments, thank you. And so based on those samples, they update the information as best they can, but there haven't been any changes to the actual methods between this year and last year.

And the specifics of that, we have a full report from the working group on the— on the plan team's agenda. But we were provided some pretty high-level information at the, at the planning meeting.

Okay, Mr. Chair, members of the AP, we're moving on now to the Bering Sea Aleutian Islands Groundfish Plan Team report, as well as a list of the actions for the AP under this agenda item. I just want to acknowledge the co-chairs of the Bering Sea Plan Team, Steve Barbeau, Kalei Shotwell, and the vice chair, Cindy Trebusio, who helped put together this whole report and provided all of their expertise at the SSC over the last 2 days. I do also want to acknowledge back at the staff tables Andrew Olson of the National Marine Fisheries Service In-Season Management. He's been working behind the scenes for the last couple years on Bering Sea specifications and he will be more of a lead on those moving forward and attending the Bering Sea Plan Team as well.

So just a quick overview of what you're doing today under proposed specifications. I'll give a brief overview of the Bering Sea Plan Team report. Again, just some of the survey updates and what things you will be seeing coming out of the November Plan Team meeting and December action in front of the SSCAP and Council. And then the action that you have today is adopting the proposed specifications. I'll walk through this at the end.

I just have a few slides on the tables. But again, understanding that you're setting proposed specifications for 2027-2028, those are just to inform the proposed rule. Those do not— those proposed specifications are used in the proposed rule. Final specifications will be based on the final harvest, the assessments that you'll see in December. As well as incorporating the ones that were reviewed and finalized by the SSC at this meeting.

And those are the information that the OFL and ABCs you receive in December will be what you use to set the final TACs, and those are the TACs that will go forward. So keeping in mind, the proposed specifications are intended to inform the proposed rule. We use updated information to the extent possible. We do not use updated OFLs and ABCs. We roll over the ones from 2026 to inform the proposed rule.

When we go through the tables, I'll note which parts of them have been updated. You do do tables on atcomackerel seasonal and spatial tackle allocations, the flatfish flexibility, and then your PSC and fishery apportionments. I will note that both crab and herring have been updated and you do not have your halibut IPHC survey estimate yet, so the halibut for the Amendment 80 trawl is based on last year's indication. And then you do have it— this Chinook Three River Index letter is posted to the e-agenda. We always have it for ADF&G at this meeting.

That is set in regulation, but they indicate that the, the combined Three River Index is below the 250,000 threshold, so the Pollock fishery will operate under the lower PSC cap in 2027.

This just gives, again, a high-level presentation summary of what we heard at the Bering Sea Aleutian Islands Plan Team. I'm not going to go over all of these. There's information in your minutes. We did go through most of them with the SSC, again, with a focus on the proposed models and as well as the harvest projections that were finalized and Bogoloslav Polak that was finalized at this meeting.

Oops. Okay, I will walk through a little bit of survey updates we did here. Dwayne Stevenson presented the results of the EBS bottom trawl survey. The 2026 EBS shelf survey completed all of the 350 standard stations. The Northern Bering Sea survey was not conducted in 2026, and that was really to allow for fieldwork associated with bottom trawl survey modernization.

We did get an update on timing for that, for the— but the EBS and the NBS will both be scheduled in 2027. Just some quick notes, the surface and bottom temperatures were the coldest since 2013. The cold pool was the largest since 2012. Biomass for most species in the Bering Sea trawl survey are stable or increasing. The polychaete volatil increased this year by 50%.

Alaska skates have a multi-year decline. And updated effort calculations associated with net mesuration sensors, recalculation changed the 2024-2025 biomass indices by about 3 to 4%.

And so they are— it's important to get the completed updated time series, not just the most recent year. We did have a discussion at the plan team about the progress and timeline for the survey modernization. The initial fieldwork started in 2026. The optimistic target for that survey is 2031, but that schedule is uncertain. We did have a— some discussion given the lack of a slope survey since 2016, discuss incorporating more deepwater toes into the redesign.

They're currently talking about an intent to go down to 400 meters.

Suzanne McDermott presented the results of the Aleutian Island Bottom Trawl Survey. They completed 373 of their 447 attempted tows, collected over 89,510 lengths and 6,060 otoliths. There was new hardware and software used for effort data collection. Surface temperatures were cooler than the average, but the bottom temperature increased to near average levels with distinct warming and localized hypoxia observed in the western Aleutians. General biomass trends with the— was the flatfish below the mean, rockfish above the mean, gadets are mixed, sablefish was above, and skates at low biomass levels.

Teams discussed a number of issues, the presence and absence of trends, and the potential to examine patterns in the future. They are now the new dissolved oxygen information that's available and whether hypoxic conditions might impact species distribution. There is a suggestion for comparison in the future with other dissolved oxygen data. There were some species IDs with the skates that might affect comparison with the long-term mean, mostly because Alaska skate and leopard skates were not distinct species prior to 2010, so comparison across that is more difficult. And it's possible to provide the current biomass comparison with the last survey and the long-term mean in the future.

There are some size shifts in rough-eye blackspotted rough-eye beginning after 2012, but that's not coinciding with any change in survey methods. And the teams really wanted to express their appreciation. They, they really rapidly processed and improved their presentation methods for the Aleutian Island Bottom Trawl Survey. Heather. Thanks, Mr. Chairman.

Thanks, Diana. Just want to confirm, I think what you said earlier, like this is saying sablefish is up. This isn't incorporated yet into decision— what we're going to be— have for decision-making in December.

Oh, I'm sorry. The new model is incorporating the AI survey data, but not the catch data yet.

I think you might have hit volume unmute on your— one of the computers.

Testing. Echo, follow-up. I think it might have been Heather. Heather. So if Sablefish is up and that's been incorporated, why is there such a decrease in the models that are being used?

I don't know, because I thought it was a decrease in the AI. Through the chair, um, sorry, I just want to make sure before I speak.

Wasn't it? Yeah, there was a— there was an increase in the AI, up 26% from 2022, um, but As we kind of mentioned earlier with Mr. Burkholder's question, some of the— so the Gulf of Alaska information is not— we don't have a survey from this year. And the Bering Sea— the Bering Sea dropped actually 14%, but again, a lot of the changes that we're seeing in the sablefish assessment are structural model changes.

And trying to figure out how to deal with the, the changes in the survey not having data on an entire region every year. So there's an increase in the AI, a drop in the Bering Sea, and then a whole lot of, um, changes that have resulted in this, uh, in this potential decrease in the, in the new model.

Then the last survey that I have an update on for the Bering Sea is the Summer Acoustic Survey and the AVO Index. The acoustic trawl survey is conducted biannually, and the AVO is derived from the acoustic data during the EBS bottom trawl survey annually. The 2026 preliminary estimate is 3.6 million tons and 13 billion pollock. It may change when bottom trawl information is included from near the seafloor. They observed more juvenile pollock than recent surveys.

Age 2 composition is the largest since the 2012 year class. And the ABO and ATS spatial patterns were similar in 2026. Again, the, the team expressed their appreciation for the substantial effort by the MACE and the GAP programs to conduct the survey and produce these rapid survey results for this meeting. We had some questions for the group regarding the temporal and spatial overlap. Similar seasonal period, but they don't sample the exact same location simultaneously.

And we suggested comparing the ABO and the acoustic trawl survey with numbers instead of biomass. And that's all I have on the summer acoustic survey.

Moving on to one more item that we discussed at the Bering Sea. We've been trying to have some general discussions at the end of the meeting. You'll hear this throughout, and the SSC will touch on this as well. Some of the cross-cutting issues, there is an aging growth capacity, program capacity issue with maintaining team expertise. It is affecting the ability to age otoliths.

That's well known within the center, and so they're working on addressing that. We had some suggestions to improve the communication of when CIE reviews are available. We're working with the Science Center on that to try to see what we can bring forward to the council schedule. There are— people generally expressed that they would like to know more rapidly in advance of CIE reviews so they can plan to participate in them. Similarly, earlier communication on major assessments and new methodology to the team.

Given the discussion of new methodology, which you'll hear a lot more about at your meeting in December, we supported and actually initiated a centralized information resource webpage in which we could provide additional information and resources on new methodologies being conducted in assessments. So we have a draft of that. It's not quite ready to go live, but the intention is that when we put the e-agenda up for the November plan team meeting will also include a link to this centralized webpage. It will have very technical information, but team members had requested that in advance of reading an assessment, especially when they only have about 5 days to go through it, when there's a new methodology, um, that it would be nice to be able to read up in advance to know what the methodology is that's being used in the assessment. And so we are using this centralized webpage as a way to provide all that information.

We'll also work separately with the crab plan team to also provide resources on the methodologies being used in crab assessments. So look forward to seeing that being available, we hope, in advance, about a week in advance of the— at least in advance of the November plan team meeting. But we're just starting to populate that with some of the, the methodologies that are being used, both for survey averaging for some of these new assessments.

Suzy. Thanks. Question about the aging growth program capacity. I recall there was some pretty good discussion about this multiple times at plan team. And I—.

First question is, is that an appropriations issue of funding not going to the program, or is that just internal AFS organization staffing or kind of a combination of both?

Through the chair, Ms. Zagorski, I can't speak for the agency. My understanding from our conversations is it's sort of a combination of both. A lot of positions were lost in the, in the most recent years. They— I do believe from the presentation that AFSC will be giving to the council on their AFSC update today that they are noting that they have some positions that they're trying to fill there. Thanks.

And I recall that this was— this is a pretty large concern, especially when it comes to stock assessments. Is there any type of prioritization that can be done in order to get— I think there were 9 stocks and years that still needed to be aged from 2025. Is there any additional insight on if there is prioritization, what does that mean? Are other things being dropped in the prioritization at AFSC to then accommodate agent growth?

Through the chair, Ms. Zgorski, I do believe so. We've had some sort of casual conversations about which stocks receive more priority, and in general, the more high-value, high-volume stocks. But there are other stocks such as Greenland turbot where that lack of age data is really hurting the assessment. And so while that one, I think, I believe that they're prioritizing a year of age data to process for that stock, but other stocks, I can't speak for Bering Sea skates, but I know that that might get deprioritized some in comparison to some of these others. So they are doing that.

I have not seen anything publicly produced on prioritization, but stock assessment authors generally talk about like, hey, I need, I need my age data processed, and so they're working on that as well as, I believe, a backlog for COD, but I'm not positive. Okay, thanks. And I'm trying to lead up to asking about, you know, we're seeing this happen, all of us here on the APA are stakeholders or involved in some way or another, and is there any opportunity for the AP or the council to even just write a letter of concern to the agency about things like this at the AFSC that are important to getting these stock assessments as informed as possible so that we can have informed ABCs, OFLs, tags, etc.?

Through the chair, Ms. Zgorski, yes, I think that is a good opportunity to express from the AP, from the council, to the agency that this really is a priority and it's been noted by the plan teams, by the authors, by the SSC that it's very important and it does affect, in addition to other data streams falling out or being less frequent, it really does affect the stock assessments.

Okay, moving on for just a snapshot of what you're going to see in November, again, as Sarah indicated we are, we are backfilling a backlog of assessments that were not done last year. So we have a pretty full slate of assessments to review in November that you'll see in December. As Sarah already mentioned, the harvest projections were already reviewed and completed, and that was really to get that off of the workload of the plan teams and the SSC for the November-December timeline. So what will be Reviewing at the, um, November plan team, we have 5 operational full assessments. So that means assessments for which, um, a suite of model, um, proposals were put forward to the SSC at this meeting.

So you'll see, um, different models being, uh, looked at for those stocks, um, and then a, a recommended model brought forward in the assessment by the author and then by the plan teams in the SSC. Operational updates, then, we have 7 of those. So those are stock assessments for which there is the single model that was used in the last full assessment that is updated with the available data and brought forward. So you won't be choosing— the SSC will not be choosing between model runs for them, but looking at those stocks and the resulting updated OFL and ABC that results from that assessment. And then moving down to the catch reports, ESPs.

Catch reports then are just a simple catch over ABC, just as an update snapshot in these off years. We have that for 3 of our stocks. We will also have an updated— so ecosystem socioeconomic profile, we'll have an updated ESP for Bering Sea cod, a draft Bering Sea pollock ESP, we believe. We also think that we will have a draft Greenland turbot ESP to bring forward to help with choosing specifications for that stock and looking at risk tables. And then there will be an ecosystem report for Bering Sea Aleutian Islands goa forage fish.

So that's what you'll be seeing in December. You will also, as Sarah indicated, get the results of the harvest projection updates and those recommendations coming from that.

Okay, moving into actions again for the AP then. I'm just going to walk through the tables that you have, keeping in mind that these are proposed specifications, so they are largely dependent on the 2026 specification, but I will note some updates as available for some, mostly for some of your PSC tables.

Again, these are posted to your agenda. These are the 2027-2028 proposed recommended from the plan team and the SSC when they produce their tables based on the 2026 OFL ABC, and then as you will move forward with your 2026 tax. The only change here, again, as Sarah mentioned, the biologically informed recommended distributions, that is just a new column. It is— it's not different from what you have done before as yet. It is just that those used to be stocks for which we had a sub-area ABC.

The ones that are grayed out, we don't have— we don't use BRDs for those. It's just set at for example, pollock Bering Sea-wide, separate stock for AI, separate stock for Boguslof.

Then Table 3, that's in— you have another suite of tables in your agenda for all of these collected tables. Table 3 then is your 2027-2028 seasonal and spatial allowances for Bering Sea Act mackerel, TAC. And I'm just going to note here that Beginning last year, we noted that while the, the jig TAC can be set up to 2% of the Bering Sea Eastern Aleutian Islands TAC, it hasn't been fished since 1994. So beginning in the 2026-2027 final specs, we have set that to zero. So you may wish to do the same in your proposed specifications to inform the final specifications should you be going forward with a zero TAC for the jug fishery.

Again, has not been fished since 1994.

Your flatfish flexibility tables, again, based on the 2026 ABCs and tax where you set your ABC surplus and the ABC reserve.

Table 8 then are some of your PSC catch allowances and apportionments. Here I would note, as normal, we— because we have the final crab assessments at this meeting, The crab biomass estimates used to set the PSCs that are contingent on thresholds or a calculation as it relates to the cobbles, the snow crab, those have been updated for the updated crab assessments. Again, halibut is based on last year's because we won't have the IPHC letter for that until the December meeting. But the herring letter from ADFNG that normally we don't receive until December has been posted to your e-Agenda, and so those herring biomass estimates and the total PSC have been updated for that herring estimate. And similarly, the red king crab and the herring fishery apportionments, again, these are using the updated herring number and the updated red king crab numbers, and then for the herring apportionments to fisheries using the, the relative proportions from last year.

At final specifications, you can modify these apportionments, but these are just based on using an updated number and the relative apportionments from last year for the proposed specifications.

Susie? Thanks. So just to clarify then, obviously this is all proposed at the moment, but Table 9 is essentially kind of—. That's going to stay the same likely in December. Especially for herring, potentially for herring.

But Table 10 has a much more—. A higher likelihood to potentially change if sectors come together. And I think I'm looking at the right table. I think you mean Table 9. So the overall number will be the same, but yes, when—.

The apportionments can change in the sector more likely if industry comes together and makes any changes to that. Yes, if you have recommended changes going into final specifications. This is again based on the relative proportion from last year across the fishery categories, but that is an action that you can take in December to modify the, the relative proportion by fishery category. We're just giving you the updated numbers so you have that information in order to have those discussions between now and then. Right, okay, thanks.

And then moving forward, Again, just your non-trial Halibut PSC in Table 11. And then Table 12, this is just your updated Halibut DMRs. You already saw in the joint presentation where the changes were from the previous Halibut DMRs. And then this is your Table 12 for your updated Halibut DMRs based on those recommendations. And with that, I'm happy to take more questions.

And again, just contact information. For the, the plan team chairs, vice chair, and the coordinator, myself. And we're happy to take questions.

Thank you. Any questions?

Okay, then we would move on to the Gulf of Alaska.

Again, just thanks to the plan team leadership, Jim Ianelli and Chris Lunsford. You will be receiving a lot of the information on the stocks that the SSC and plan team reviewed for the final stocks at the September meeting. You'll be receiving presentations from them. On those stocks as part of the December plan team report. So hopefully they'll be here with us in person to provide those.

I wish I could just say ditto to what Stram presented on your actions for proposed harvest specifications. They are a little bit different in the Gulf, but you just received the joint Bering Sea plan team reports, and I'll provide a very high level of the Gulf of Alaska plan team report, and then For your action under proposed harvest specifications for the Gulf, I will walk through Table 1 at the end of the presentation, and you'll be providing those rollover recommendations for tax, the same as what was published in March, and accounting for the state waters fisheries in the Gulf. That's Pacific cod, which we have in another fisheries for pollock and octopus. The octopus, I believe, was a new change that we began last year, so we'll provide information on that. And then the PSC limits for the limit apportionments for halibut, you'll be providing recommendations on those for proposed specifications and the halibut DMRs, which won't be changing between now and in December.

Sarah, just to interrupt for a second, in case people aren't following along with the PowerPoint, there's maybe 5 or 6 slides left. So if anybody in the public wants to testify, please make an effort to sign up. We do have the— not the normal kiosk, but there's an iPad in the back if anybody doesn't have a phone or computer that they can sign up on. Thanks.

These are the topics that were presented at the Gulf of Alaska Groundfish Plan Team. Again, we will have our stock assessment authors, our co-chairs here to present some information on the stocks that were final at this meeting, so I won't be going through those and I won't go through the, the proposed models. We typically don't go through those all at the, at the September meeting. But I'll highlight the, the Shelikov acoustic survey and a couple of other things in the next few slides.

This is just overall all of the SAFE documents that you'll see for Gulf of Alaska groundfish throughout the year here. Again, some of these won't be won't be reviewed again by the SSC or the plan team in November, but we have a bunch of operational full assessments that will be coming forward, a few different operational updates, one of which, Gulf of Alaska skates, was already, already reviewed by the plan team and SSC. All of the harvest projections were reviewed by the plan team and SSC at these meetings, and then we have a few catch reports and the Gulf of Alaska ESR will have that in full, and you'll be receiving a full presentation on that at your December meeting.

We did not have a Gulf of Alaska bottom trawl survey this year, and typically at these presentations we just provide any of the updated survey information that we have, so these are the results from the winter pollock pre-spawning acoustic trawl survey, and there were several areas that were surveyed in February. The biomass trends relative to previous years varied based on the, the subarea that was surveyed, and there were some issues with severe weather and vessel icing, so that curtailed the, the March survey of the Shelikof, Sherekhof, and Marmot areas. So there were actually 11 transsects in the southern Shelikof Strait that weren't surveyed this year, and the team, the assessment team, will be working with the survey team to try to revisit some of those missing transects, that missing Shelikof data, and trying to figure out methods for those to estimate biomass in those unsurveyed areas in November. So you'll be receiving an update on, on the methods they use for that in the pollock assessment in November and December when the model fits are available.

The, uh, there weren't any female pollock longer than 40 centimeters found in spawning or spent condition, and that indicated that the survey timing remained appropriate. So we try to provide you just an update on that every year.

I don't have any other survey information from the Gulf, but I wanted to highlight that we'll be bringing forward all information to the APN Council in December on spatial apportionments in response to this council motion in December. And again, we did discuss Gulf of Alaska skates at the plan team and SSC meetings and whether or not there's flexibility— flexibility flexibility in the survey-based spatial apportionments for those stocks at this meeting, and we'll, we'll provide the assessments for shortraker, ruffian blackspotted rockfish, and thornyhead rockfish, as well as any information that comes from the resulting plan team discussion in November regarding whether or not small changes from the whatever the SSC or the plan team recommends for BRDs whether any small changes from those would be likely to result in biological impacts to the stock or stock complex. And this was in response to the council asking for these conversations to occur at the plant team and SSC to determine whether or not the council, when it does its tax setting, whether it could have small deviations for some of these choke species when it sets the regional tax.

The plant team, uh, and the SSC yesterday recommended the rollover of the 2026 harvest specifications for 2027-28 proposed specifications. On the screen is a revised table from the SSC meeting. We found one more typo in the ruffeye black-spotted rollover numbers, so those are revised on here. And I'm not sure if the plan team recommendations attachment has been updated. They're not yet on the e-agenda, so I wanted to highlight that those are correct here in case you need that information.

The AP will again need to recommend tax that account for State Waters Pollock, Peacod, and Octopus. I have not included in the presentation all of those tables because they will be updated in December, but those are included on your e-agenda in a separate attachment. And any feedback on how to communicate, I don't want to throw up so many tables that might end up being updated in December since we're trying to really improve our communications on this. So any feedback on how we can prevent confusion on the proposed specifications process in the future is absolutely welcome.

We've included the, the PSC catch limit apportionments for halibut in tables 9 through 11 that are on your e-agenda and the halibut discard mortality rates in Table 12 on your eAgenda attachment as well. So I'm happy to take any questions on proposed specifications at this time for the Gulf.

Thanks, Sarah. I appreciate all the work you guys have been putting into communication. Any questions on the Gulf?

I don't see any, so we'll look to see who signed up for public comment.

Just one person, Linda. We'll give staff a minute to—.

Good morning, Chair, members of the AP. Linda Benken testifying for Alaska Longline Fishermen's Association on the sablefish spec process. Just start by stating that our ask is for— to support what the SSC did. Namely to develop alternative methods and models for consideration in December as the basis for the 2026 assessment and 2027 specifications. We ask this in full knowledge that there's more sablefish in the water now than there has been since the 1970s.

We don't feel like there is a real urgency to make what is really a slew of changes.

None of us want to see an increase in the quota. I think you've heard us for a number of years say that going up and going back down is the way to best destabilize this fleet. We want to be conservative, but taking a drop of this magnitude without ground-truthing some of the changes feels like a mistake to us. I would just note that, that most of the uncertainty that's introduced here that's driving these changes comes from a lack of data, not having an annual survey anymore, and because the stock assessment authors are not getting commercial catch data. It's, it's sort of a mystery to us why they aren't getting CPE data when 90% of the fleet is now fishing with pots, filling out the daily fishing log.

We even have boats that are electronically doing that on a grant that we've worked on and submitting that information to NOAA. So I'm still trying to track down why all that data has disappeared from their assessment, or for at least as an opportunity to ground truth, um, what they're seeing in their now truncated survey. So as we said in our comments, this is one of the most valuable finfish fishery on a per-pound basis in Alaska. It seems like it should be assessed every year. We would ask that the AP recommend to the council, highlight the importance of annual and comprehensive surveys, and ask that resources be dedicated to make sure we're doing that in this fishery as well as others.

There are also changes that the, that the stock assessment survey team can make to that survey so that they aren't missing whole ecosystems when they conduct the survey. With working with the resources they have, but staying within an operating model that gives them a more representative sample. I've watched the IPHC go through that process, and it's something I really hope the sablefish team will think about. I did want to mention that the implications, and I included a graph in our written comments, that right now, if this current assessment is correct, then it means that between 2005 and 2015, they were actually overestimating the abundance or biomass of sablefish by a factor of 2, so that there was 50% the fish in the water then as we thought there were. That raises a lot of questions with us.

Fishing was not as good then as it is now, but it was still good. And then they had comprehensive surveys. They had more commercial catch data. They were using the Gulf trawl survey, all pieces of data that they have dropped from the survey now. So it— that's part of why it just doesn't match up for us.

So just to wrap, I think there's a lot of people on this AP who sat there in the SSC and heard that conversation there, but we would ask that you recommend new, other alternative methods and models be brought forward in December so the SSE can give its best advice along with the CIE on what model should be used as the basis for your decision. I'm happy to list those models that were included in the SSE recommendation if that's helpful. But then also to ask that you include a recommendation for comprehensive surveys of the stocks and other stocks that the Council is managing.

And I'm happy to stop there and answer, try to answer any questions. Thanks, Linda. I see a question from Susie. Through the Chair, thanks, Linda. To your request about recommending that the Council do comprehensive surveys of all the stocks we're managing, I guess I'm— I think everybody's asking of this, it seems like, and with limited resources and surveys, I'm curious how much you expect that the council can do or how much weight we have— the council has to, to address that.

Just, I understand the recommend— the ask of that recommendation, but I guess I'm also trying to understand and manage expectations in this at the same time. Yeah, thank you for that question through the chair. So the sablefish stock assessment, or the sablefish stock, has been assessed annually for a long time. This is a new development to not have an annual stock assessment. We'll certainly add our voices, already have, in reaching out to our delegation to let them know what this is costing the industry potentially to have this much uncertainty result in this 32% drop.

And, you know, the $50 million that could cost the industry if that's what happens here. And I'm hoping others do the same, both with the Alaska delegation and the Washington delegation. I know the council can't lobby Congress, but they can certainly state how important surveys are in their messaging to NOAA about budgeting. But I would also just, I guess, add to that, the IPHC was recently faced with similar Limitations for funding the survey. Both surveys are funded by the fish that are sold from, from those surveys.

And when we saw the big drop in halibut abundance, there wasn't enough money to pay for a comprehensive survey. So the IPHC redesigned the survey to representative sample in every area and then use a space-time averaging of survey sites adjacent to missing survey sites as the best way to fill in those data gaps, as opposed to what the sablefish team has now decided to do of missing the entire ecosystem of the Gulf and extrapolating from Bering Sea and Aleutian Island data, which just to us feels like, you know, when, when sablefish can move around so much as they, particularly as they mature, that it's really giving us poor data as the basis for the stock assessment.

Thanks for that. And certainly understand the frustrations with not having surveys happening when you know you have a stock that's all over the place and changing. But kind of going back to something you said at the beginning of your testimony about not having fishery data included, have you considered considered or worked with folks about how to get that integrated better, whether it be through cooperative research or— like, I think you mentioned there's some, some projects that are going on, but is there any progress on that or understanding the obstacles? And are you guys working towards that rather than just relying on the stock assessment teams or the Science Center to to do that.

Yeah, thank you through the chair for that question. I, I have spent a lot of time yesterday trying to figure out why they're not getting that data. So years ago, PBOA and Alpha started a voluntary logbook program, decades ago, to make sure there was fleet data, catch per unit effort data from the under 60 feet. We still have boats that are filling that out. We've transitioned some of them through a NFWIP-funded cooperative research project to electronic logbooks.

So that doesn't even require key punching by anybody. When some of the collection of that data became more difficult, we worked with the IPHC for, again, decades. They were getting funding from the Catch Recovery Program and the IFQ program so that when they were down on halibut boats, and they are still doing this even though that funding's not there anymore. They are recording data on halibut sets as well as sablefish sets. So it's all being gathered.

But as boats have transitioned to pots, they are required to fill out the daily fishing log. And we now have some of those boats who are also doing electronic version, again on a cooperative research grant. And all of that is going to NOAA. So I'm trying to figure out why when we're doing our part, It's not being used. And in the past, the, the commercial catch data was not used in the survey, but it was used as a ground truth on the survey, and it was used in the apportionment.

And if we had that from the Gulf right now, I think it would really inform a lot of this filling in for uncertainty. So yes, we will continue to do our part. We will continue to push to try and find out why that connection has been broken. And also to think about other ways. I mean, we are also— all of our fish tickets, as probably is the case in your fisheries, but have size composition information because you're paid based on size.

And what does it take to make sure NMFS is getting that data and can at least look at catch composition, size composition, and the commercial catch? Even if they don't have a survey. But I think the better move is to redesign the survey, and we will be pushing for that.

Thanks, Linda.

Let's take a mid-morning break and we'll come back at 9:40. See if there's any motions.

Check, check.

Thanks everyone for your patience. Um, We're just pulling together some tables, so we're going to come back on record and see if there's any motions on C3. Susie?

Thanks. Um, all right, the APA recommends the council adopt the proposed 2027 and 2028 BSAI groundfish specifications for OFLs, ABCs, and birds as recommended by the SSC and set proposed proposed tax with all proposed specifications consisting of rollovers of 2026 final specifications from the 2026-2027 harvest specifications. The proposed tax for both Bering Sea and Aleutian Islands Pacific cod have been adjusted to account for statewater GHL fisheries. The proposed tax for sablefish have also been reduced in the BSAI by 5% to accommodate for the GHL fishery. The AP recommends the council adopt the proposed 2027-2028 seasonal and spatial allowances for Atka mackerel as shown in Table 3.

The AP recommends the council adopt the proposed 2027 and 2028 flatfish ABC reserves annual and seasonal PSC limits and apportionments in the BSAI as provided in Table 7, 8, 9, 10, and 11. The AP recommends the council adopt the proposed 2027 and 2028 halibut card mortality rates, DMRs, for the BSAI as shown in Table 12. Tables 1, 3, and 7 through 12 are below and can also be found in the meeting agenda under C3. And with a second, I'll speak to it. Second.

Thank you. Every October meeting, the council needs to start the proposed rulemaking for BSAI groundfish harvest specifications for the upcoming 2 years. These proposed '27 and '28 specifications reflect the recommendations by the BSAI groundfish plan team and serve as a placeholder for setting the final specifications in December. Once the plan team has finalized all of their stock assessments and safe reports, the SSC will set the final OFLs and ABCs for 2027 at the upcoming December meeting. I want to thank all the staff, plan team members, and survey crew for their hard work.

We're especially appreciative for the quick turnarounds from survey to plan team meetings and the efforts to mitigate final assessment slowdowns that may result from any future potential lapse in appropriations. We have received the herring biomass letter as well from ADF&G a bit earlier than we normally receive it. At this time, the PSE tables are proposed, and if any sector apportionment changes are requested, those can be addressed in December during final specs. Finally, we heard about multiple areas of reduced capacity in the age and growth program as well as in surveys. These reductions are concerning, especially since both are important data streams for stock assessments.

And I'd like to highlight this for the AP and the council, so if there, if there are any opportunities to bring this up or highlight it for the administration's priorities, it would be appreciated by all sectors in the BSAI to do so. And with that, I'll try to answer any questions. Questions?

Questions?

Amendments?

Comments?

Objections? Okay, motion passes unanimously. Are there other motions?

Chelsea? Oops, I'll just wait for it to get switched over.

Alright, the motion reads, the AP recommends the council adopt the proposed 2027 and 2028 Gulf of Alaska groundfish specifications for OFLs and ABCs as recommended by the SSC and set tax shown, or BRDs, in Table 1. Final specifications will be approved in December. The tax for both GOA cod and pollock abajun adjusted to account for the state water shell fisheries The proposed Gulf of Alaska Pacific cod adjustments are shown in Table 2. The AP recommends the council adopt the proposed 2025 and—. Oops, 2020—.

Sorry, 2027 and 2028 annual and seasonal Pacific halibut PSC limits and apportionments in the Gulf of Alaska as provided in Tables 9, 10, and 11, and the proposed 2027 and 2028 halibut discard mortality rates DMRs for the Gulf of Alaska in Table 12. And with a second, I'll state my rationale. Second. Thanks, Heather. First, I'll just note, it looks like I sent the wrong version of this and didn't finish updating the years.

So all of the years are supposed to be 2027 and 2028. And then, tax should be replaced with BRDs since that's the language that we're using now. So my apologies for that. At this meeting, the council will recommend for proposed rulemaking the Gulf of Alaska groundfish harvest specs for the upcoming 2-year period, which will notify the public of expected council action to set final harvest specs in December of this year. Final harvest specs in December will be based on stock assessment reports in the Groundfish Safe Reports for the Gulf of Alaska that will be released in November.

November of this year. I just wanted to note appreciation for the work of SE— survey teams, assessment authors, and plan team for all their hard work during the annual specification process, particularly after having to adjust to the disruption in the process that we had last year. And would just reiterate what Susie had mentioned in the Bearing SE Specs about capacity, especially for aging growth, that I think that's also applicable for the Gulf of Alaska. And that's all. I'd be happy to take any questions.

Questions? Through the chair, thank you, Chelsea. Can you all hear me okay? Yes, thanks. Okay, I just had a quick question.

It's not in regards to your motion, but in the third sentence where it says final specification will be approved in December. We can assume that it's going to be December 2026, but is it okay to put that little friendly insert in there?

Sure. Because you're referencing '27 and '28, so I just, I don't want members of the public to get confused about that. Thank you. Yes, thank you. I'd accept that as a friendly.

Thanks.

Any other questions, amendments, comments? Heather? Thanks, Mr. Chairman, and I should have commented with Susie as well. Just want to thank Chelsea and Susie for shepherding this. Um, it seems like it's super easy, but it's actually really complicated.

So I appreciate, um, the work that you did to get us here.

Any objection to this motion?

That motion passes unanimously. Any other motions on this? Nels?

I'll wait for it to get on screen.

Motion reads, the AP recommends the sablefish stock assessment team explore additional stock assessment models and methods not limited to 25.12_1reg_cont, which is current status quo, 26.1_1reg, and 26.2_faa for the November joint groundfish plan team and December council meetings. AP recommends the sablefish stock assessment team explore the following models: Model 26.1_1reg with carryover apportionment, A 3- and 5-year phase-in of the 26.2 FAA model and how it would be apportioned through all regions: AI, BS, West Goa, Central Goa, West Yak, and Southeast Outside. Model 26.2_FA with dome selectivity for the model in the survey for the Bering Sea. And a sensitivity run that uses the M value for 26.1_1reg in model 26.2_FA. 2_FAA.

Finally, the AP supports reestablishment of comprehensive annual surveys for this valuable stock and the use of commercial size composition and CPUE data. With a second, I can speak more. Second.

The coast-wide sablefish population has grown significantly since the start of the episodic recruitment events we've been seeing beginning back in 2014. The ABC for this stock has, has followed. The, there currently is no biological concern for the stock and there's evidence pointing towards continued strong recruitment classes in survey. Starting in 2025, NMFS implemented a new survey methodology for their sablefish longline survey, moving from the previous model of surveying the GOA annually and the Bering Sea or Aleutian Islands biannually. The new model surveys the GOA and the BSAI on opposing years, transitioning from a survey footprint that surveyed 75% of the stations annually to a new model that surveys 50% of the survey footprint annually.

Due to the recency of the survey shift, we've only received one survey per region, so one year in the GOA, one year in the BSAI. The shift in survey methodology and a CIE review has led to, led to the proposal of new models from the Sablefish Stock Assessment Team, Models 26.1_1reg and 26.2_FAA.

With 26.2_FAA being pushed as the preferred model. Model 26.1 would equate to an 18% coast-wide reduction in sablefish ABC, and 26.2 would lead to a 32% coast-wide reduction in the ABC. Both of these new models introduce a drastically different shift in the 2027 ABC, yet both represent an F40 harvest rate. In the sablefish document and presentation from the September Joint GPT, it was acknowledged that these new models and their associated reductions were not based on stock health, but instead solely due to a shift in modeling. It was also noted that the proposed FAA model will likely underestimate recent recruitment due to the current reductions in survey footprint.

These new proposed models lead— led to a large outcry by— from stakeholders. There were 15 comments to the SSC and 9 presenters from all across different sectors in the industry, so this is not a sector-specific ask. And the two of the proposed model frameworks come from sector— from the industry ask. The other two come from SSC recommendations. I wanted to have all of them represented here.

The first model option would reintegrate carryover data from the non-surveyed region into the modeling framework. So this would take that GOA data that's not fully inputted. With the BSAI and input it. This would lead to a significantly reduced reduction in the, in the GOA. A second model option would look at a way to phase in the proposed 26.2 FAA model over several years rather than taking the 32% coast-wide reduction in a single year.

The third option would be able to look more specifically at the sablefish population trends in the Bering Sea, as you don't see sablefish that stay in the Bering Sea, they generally start exiting the area starting at age 6. So using the same— using the same— oh, using the same model population trends in the Bering Sea that's used for the rest of the coast may need to be revisited, relooked at. The fourth model option would allow for an understanding of the treatment of how how M shifts the, the difference between 26.1 and 26.2, as right now they use two separate mortality values. By using the same mortality value, they'll be able to better analyze the other differences within the models and the impacts that they would have. I recognize that an ask for new model parameters outside of SSC recommendations is not common practice in this process, but due to the unprecedented cuts that are proposed through this— through these new models to the 2027 ABC and no biological concern for the stock, I believe that this is warranted.

With that, I'll take any questions. Thanks, Niles. Questions? Heather?

Thanks, Mr. Chairman. Thanks, Niles, for the motion. I have two questions. Your last point Are you— so we heard in public comment not only support for comprehensive annual surveys for this stock, but also all stocks that are important. So are you, with the way you've worded it, are you sort of prioritizing this over others?

Not prioritizing, just within the framework of this has kind of jumped out there is collective among all— or not all, but significant amount of user groups. Sablefish touches on a lot of different gear groups and sectors. There has been quite a lot of unification around concern on these new models. So I wouldn't say long-term prioritization, but I think that revisiting these models in this very moment would be responsive to folks. Thanks.

And then my second question is around the list of 4, I appreciate in your rationale you talked about how 2 came from the industry and 2 came from the SSC, but did the SSC also recommend the ones that came from industry or not? They acknowledged industry's concerns, but number 3 and number 4 were the specific recommendations that came out of the SSC. Okay. Thanks.

Any other questions?

Any amendments?

Any comments? Lauren? Yeah, thank you, Nils, for putting this together. I appreciate the work you did on this to translate the SSC speak. We all sat through the meeting and listened to everything they had to say, and I think the testimony and the comments were well heard and well understood in terms of the potential data that could be re-imputed into model considerations to maybe make some shifts on a change in survey structure, but not as stark of a change based on the lack of biological concern.

So this is very responsive to the conversation that we heard in the SSC as well as stakeholder comments. I appreciate it. Thank you. Other comments?

Chelsea. Thanks. Through the chair, thanks, Nels, for the motion and all of the work that you put into this. And thank you to everyone that has testified and been conversing about this. Um, you spoke really well to how this affects multiple user groups, and so I just wanted to note, um, you know, from the shoreside processor perspective, uh, while we want to use the best available science It's really important that, you know, we are connecting the real-world impacts with potential model changes, specifically when there's not a conservation concern.

If this cut had been in effect for 2026, you know, and 30% in the Gulf, that starts making processors have to make decisions about which plants are open, especially for the smaller regional plants that, you know, primarily do IFQ. So especially in light of, you know, everything else that would be going on in fisheries, and so I think that's just really important. This does impact everyone, and I'm hoping that we can have a successful outcome in November, December to really find somewhere to meet in the, in the middle on this. So thank you. Other comments?

I'm gonna just add a couple things for The rationale— I appreciate the motion, Nels, and will support it. I think I want to note that harvesters and processors have really worked hard to develop markets for black cotton and greatly improve the value. So this, this, this has an impact on, on the development of those markets. That said though, I— my support for this is not, you know, a signal that we should be second-guessing modeling and the experts, but I think it's more about the importance of surveys and data and what we lose when those, you know, fall short, and also about the importance of communication and support this because there's specific reference to the need for that. When models abruptly change and have very dramatic impacts on both forward-looking biomass and then looking backwards, it does have an effect of undermining people's support for and belief in the institution of how we get managed.

And so I think there's a really strong burden to be able to explain that and communicate that to all stakeholders. And that that it's really a critical component that I, from my experiences as a New Englander, sets this region apart in terms of how the stakeholders interact with the agency and the managers and the scientists. So I support this certainly, but just want to add those comments. Thanks, Nels. So with that, is there any opposition to Nels' motion?

Not seeing any. That passes unanimously. Let's take a— let's come back at 10:20 and we will start with D3 and then we will take— if we don't get to public testimony before lunch, we will take a testifier out of order due to some scheduling impact. So thanks.

Okay, we'll come back on record with D3, and I'll turn it over to you, Sarah. Good morning, Mr. Chair, members of the AP, Sarah Marenin, council staff. This is D3, IFQ and CQE adjustments. This is the staff presentation on an expanded discussion paper.

Presenting with me is Liz, and I'll let you— I'll let her introduce herself. Hi, I'm Dr.

Thank you, Sarah. My first time. I'm Dr. Henderson. You can call me Liz though, and I will be presenting on items related to PNOs and a clarification.

Yes, also we have Doug Duncan in the room here available to help out with questions. I think we'll have Alicia Miller and Josh Keeton with National Marine Fisheries Service on online to help with questions should we need their assistance as well.

So here is a brief history of action for this discussion paper. In December 2024, the AP and the Council received the IFQ program review, a comprehensive look at the, the whole IFQ program. After that review, the Council tasked a discussion paper that covered a number of topics related to changes in the IFQ and CQE program and looking at possible changes to beneficiary requirements. The council received that discussion paper in October 2025, and from there requested an expanded discussion paper related to the 4 of the proposals that were in that original discussion paper and then adding 5 additional items. So at this meeting, we're looking at that expanded discussion paper.

There's 9 items in total, um, from the council's October 2025 motion. Those items have been reorganized and renumbered for purposes of this paper, um, but in general, they're grouped in terms of transfer eligibility certificate requirements, community quota entity operations, and unloading landing issues. So here are the proposed items. The first 3 were all from the last discussion paper. I'm going to briefly remind you what they are in this presentation.

I think I just have one slide for each, but these are related to transfer eligibility certificate for the IFQ program. So it's—. The first proposal would allow tendering time in any federal or state commercial fishery off of Alaska to count towards 150-day TEC requirement to receive IFQ. The second proposed item looks at replacing NMFS's interim policy to establish a minimum age to be eligible to receive halibut or sablefish IFQ or quota share by transfer. And the third item is considering waiving the TCU requirements for individuals fishing annual IFQ derived from CQE held quota.

Those are the first 3 proposed items. The next items are related to CQEs specifically, so looking at improving CQE in-season management of IFQ, looking at increasing or removing the CQE-specific sablefish vessel caps in the Aleutian Islands, looking at increasing or removing the individual quota share use caps for CQEs, and And the 7th item is not a proposed action, but it's a clarification on whether CQEs in the Aleutian Islands can hold federal processing permits. So we'll talk about that as well.

The last 2 proposed items are new to this discussion paper. They look at waiving the prior notice of landings and unrestricted— and restricted unload hours for small IFQ deliveries. Number 9 would expand the designated unload areas for tenders receiving IFQ or CQE halibut or sablefish. So we're going to walk through each of these proposed items and we'll talk more about what the proposal is as we go through each.

I have a Venn diagram here to help you conceptualize some of these proposals. We can come back to this at the end too, but just in terms of Some of these proposals apply exclusively to the Gulf or the Aleutian Islands CQEs. Some would apply to all halibut and sablefish quota shareholders. We make this distinction as we walk through each proposal, but this is just a, a way to visualize it, who the proposal may apply to based currently on the language for the proposed items.

So I have 2 slides of background here and then we're going to walk through each of the 9 proposed items. So just so we're on the same page, the IFQ, halibut and sablefish IFQ program was implemented in 1995 for fixed-gear halibut and sablefish commercial fisheries off Alaska. Quota share was issued for a species in a regulatory area. Each year these quota share units are translated into fishable IFQ pounds based off of the total allowable catch for that species. In order to buy or lease IFQ, a person must be issued a Transfer Eligibility Certificate, a TEC.

This is done by meeting eligibility requirements, so 150 or more days of experience working as part of a harvesting crew in any U.S. commercial fishery and submitting an application attesting to this eligibility. Harvesting, as described here, is work directly related to catching and retaining a fish.

This requirement supports the IFQ program's goals of maintaining owner-operated fisheries. Owner-on-board requirements for IFQ holders are part of the program with some limited exceptions.

There's a background section, Section 2.2 in the paper, describing the Community Quota Entity CQE program. This was implemented in 2004 in response to concerns about outmigration of commercial quota out of small Gulf of Alaska coastal communities. It allows certain small coastal communities in the Gulf of Alaska and the Aleutian Islands to form nonprofit groups and participate in the IFQ program by purchasing halibut and sablefish quota. In the final motion establishing the CQE program, the council established 3 performance standards that, although they're not required in regulations, were intended as goals for the CQE program. So those are maximize benefits from use of community IFQ for crew members that are community residents, to ensure that benefits are equitably distributed throughout communities, and ensure that the quota share IFQ allocated to eligible community would not be held and unfished.

This Table 1 demonstrates that of the 46 eligible communities, 9 have both formed CQEs and purchased halibut and/or sablefish quota. You can also see in Figure 1 in the paper that aligns with this table that 7 of these 9 groups have acquired quota share between 2025 and '26 after relative stable holdings. So that was an item to note. A few of the CQEs are newly formed.

Okay, so moving into the proposed items. Again, the first 3 are carryovers from the last discussion paper, so I'm going to try to go through them quickly. Feel free to stop me with questions if you have them. The proposed item 1 is counting tendering time as part of sea days.

The proposal is to, again, allow tendering to count as part of the TCEC days. This was discussed as part of the IFQ program review. It also came up because at the time tendering was being considered for— in the CREB rationalization program as a demonstration of active participation. I already kind of reviewed some of the regulations around TEC requirements.

You need to meet the 150 days of sea days as harvesting crew in a U.S. fishery. Tendering because it's transporting unprocessed fish or shellfish from a fishing vessel to a processor, so it doesn't currently qualify for an IFQ program TC as sea days. Tendering participation occurs off of Alaska, which you can see some statistics in the paper in Table 3. It also can occur elsewhere in the US, on the West Coast and other places.

So the inclusion of tendering crew experience would expand the pool of people eligible to buy quota share. It could provide more opportunities for younger people to gain experience in the fishing industry and then buy, buy in with quota share.

Oh, I do have two slides on this one actually, but this is just— Table 5 shows some of the differences for the current and proposed regulatory changes in the crab rationalization and IFQ program in terms of what qualifies for a TC C. So I condensed a bunch of regulations into this table for you. There's kind of two differences in scope to look at here. They're in whether tendering qualifies and is the harvesting and processing that qualifies off Alaska or off the U.S. as a whole. And so there's some differences that already exist in the crab program scope. If the council moves forward with this proposal, it may wish to consider aligning the scope scope of tendering eligibility with the scope of harvesting eligibility within the IFQ program.

So harvesting eligibility is for any U.S. commercial fishery rather than what's currently written in the proposed item, which is tendering off of Alaska. So this might generate some internal consistency and hopefully reduce confusion if this moves forward.

Okay, Proposal 2. Proposed Item 2 is the minimum age for purchasing quota share.

NIMS Restricted Access Management, RAM Division, has received TCs from very young fishermen in the past. In 2022, NIMS Alaska Region established an interim policy to set a minimum age for issuance of IFQs. QTC at 18 years old. During the program review, there was some discussion about whether to establish a minimum age in regulations. So far, public testimony has highlighted some disparate views on if setting a minimum age is necessary, and if necessary, what that age might be.

There's some background in the document that's consistent with the last discussion paper. It shares that NIMS prefers consistency and clear regulations to promote compliance and ease of understanding and to improve enforceability. Section 3.2 includes a list of responsibilities for quota share and IFQ holders. So, for instance, complying with recordkeeping and reporting, paying cost recovery fees. So, in the event of a violation, a miner could potentially be exposed to the liability for civil for civil penalties and permit sanctions.

So something to consider when you're thinking about a minimum age. Age requirements vary between state and federal labor laws. There's some description of that in Table 6. NIMS recommends initiating analysis to establish a minimum age and regulations to be eligible to receive IFQ or quota share by transfer based on these applicable laws.

Proposed Item 3 is looking at the TCE requirements for CQE residents.

Testimony during the program review highlighted an interest in providing opportunity for CQE residents with less harvesting experience. The proposal would waive TCE requirements, so the harvesting CQE days, specifically for individuals harvesting IFQ from CQE-held quota share.

Under current regulations, eligible residents lease IFQ from the CQEs. Currently, they must have a TCE as the IFQ permit would be issued in their name. Leasing is an official transfer that goes through NIMS RAM Division. Residents of ADAC are an exception to this as regulations are written, no TCE requirements are required to lease IFQ from an ADAC CQE if they're being leased to a resident. One driver across the board for proposed actions related to CQEs is related to low prosecution rates and the ability of that quota to be harvested.

So there's some information there on Table 2. I'm going to reference that again coming up soon, but highlighting that an underlying objective of of these proposals is to increase the likelihood that a CQE's IFQ can be fished and that they have a pool of residents to be able to look to to fish their quota. So this action may expand the pool of community residents that are eligible to receive IFQ from a CQE, providing additional opportunities for residents in line with the program goals. And we note that there would be joint considerations for this proposal and others. For instance, Proposed Item 1 and Proposed Item 4.

Okay, moving on to Proposed Item 4. This is looking at CQE in-season quota management.

One topic of concern highlighted during the review and also has been brought up in subsequent testimony was about challenges that have occurred for internal management of a CQE. CQE's quota share. It was highlighted that the inability for CQE group managers to view the IFQ landings associated with their group or conduct efficient return transfers of the IFQ in the event that it wasn't fished by a resident may be factors leading to low prosecution rates and challenges, just general challenges within internal management. So the motion had us look at the ability of CQEs to assign and manage quota in-season for example, explore processes similar to the CDQ permitting for halibut or hired master permits.

The previous discussion paper highlighted some of the context for how the current process works. CQEs can lease or transfer IFQ to residents annually. If the lessee is unable to harvest the IFQ, there's no specific process or criteria to return IFQ to the CQE. The direct transfer between CQE residents is considered a sublease and it's not allowed. But the IFQ system isn't designed to track or process transactions for the purpose of returning IFQ to the quota shareholder after a temporary transfer has occurred.

So, NIMS evaluates the request for a return of transferred IFQ on a case-by-case basis. In the document, there's a list of criteria that RAM has considered before it approves a return transfer. And it requires manual backend return process requiring case-specific programming. So it's, it's not an efficient system. It may happen on a case-by-case basis, and it can take a long time.

NIMS is in the process of redesigning the IFQ. Permit application is part part of a larger project to design an integrated fisheries application, IFA, that's adaptive and supports all the needs of system stakeholders. The application will utilize new technology, improve data quality, and streamline permitting process as well as simplifying program modifications necessary to implement regulatory changes.

Pause for a question, Lauren. Thank you, Sarah, for the presentation. Could you go into a little bit more detail on the IFA, just in terms of like where they're at with that, if there's a timeline, if it's still just a concept, or if it's actively been being worked on?

Um, through the chair, Lauren, I can speak to that a bit, and then if Alicia's online, I think she's been involved in that, she could probably speak to it more. I guess I would say that it's, it's not just a concept at this point. They're actively working towards it. I think NMFS has had challenge— has not had a lot of programming staff, and so that's been a big struggle. I think RAM in particular has been understaffed, and they play a really important role in a lot of fisheries, and, and so their input and work is necessary for that as well, for that program.

So I think that is in some places where the bottleneck is, is in terms of programming staff and ability. We didn't get a specific deadline when we talked with RAM or NIMP staff during this project about when that rollout would happen.

It's still expected to take some time. But if Alicia's on— okay, Alicia, do you have anything to add? Thank you, Sarah. Through the chair, can you hear me okay? Yep, I think you came in a little bit louder there at the end, so go ahead.

Okay, awesome. Through the chair, my name is Alicia Miller, Nashmane Fisheries Service. It's nice to see the AP. And I can just weigh in a little bit. I'm actually working very closely with our RAM and Information Services Division to scope out the business requirements for the IFA system to implement IFQ.

So we're definitely actively working on this process and defining what the business processes are that need to be programmed, how they would work, and process improvements that we would want to see. So once we are done with our internal planning and development work, there will be a number of things that I will bring back to the council and the AP for input on, because one of the major improvements that we're looking at is designing the user interface for the public as well as our internal permit processing. And so we're anticipating a number of process improvements for tracking quota share and the resulting IFQ. And some potential improvements in, transparency of some of the, the overage/underrage calculations, and then what happens when there are leases. So these are all things that are on our radar, but we are, in the process of planning and, scoping those, and, um, we would bring those back, um, before implementation.

Like Sarah said, um, we do have capacity limitations. And the programming work does take quite a bit of time, and it's quite a complicated program, but we've got some experience with the internal processes we've already implemented in IFA. We have a number of things that we're currently processing in the system, so we've learned from those, and IFQ would be the, the biggest and most complicated program that we're putting into the new system.

But we anticipate that we should be able to report back on progress in the coming months or years. So I'm hesitant to try and scope out what the timeline might be, but that is information we would bring back at some point in the future.

Thanks, Alicia. I think that got it. Okay, thank you for that, Alicia. So, providing a little bit of context on the existing regulations for IFQ hired masters. So this is another way besides leasing that someone other than the quota shareholder may harvest halibut and sablefish IFQ.

The IFQ holder completes an application that lists the individual or individuals that will be harvesting their IFQ, if application is approved by NMFS, that individual will receive a hired master permit that they must carry aboard with them. The IFQ hired master privileges are only granted under specific circumstances. So for Class A quota shareholders or for catcher vessel quota shareholders, only initial issuees outside of Area 2C and Southeast outside with 20% ownership in a vessel and for quota share acquired before February 12, 2010. This is intended to permit business structures that existed prior to the IFQ program, but the council has amended provisions to limit further use of hired skippers a number of times. The IFQ report to the fleet, the most recent one, which is linked in the paper, shows decreasing trends in IFQ harvest by hired skippers, but I recall 2 program reviews ago when we looked at it, there was increasing use by hired skippers.

So it's sort of a new trend that we have decreasing catcher vessel quota share being harvested by hired skippers. So these practices, leasing and using a hired skipper, may look similar in practice. Sometimes it's done through a specific contract, but it doesn't require require IFQ to transfer through NIMS. So from a regulatory standpoint, it is quite different.

Quota shareholders remain liable for any fishing violations and fees associated with that IFQ.

Lauren? Thanks, Sarah. I slightly struggled with the understanding of why it's so different in regulatory because the CQE is a temporary transfer. Like, it's not treated as a permanent transfer. It's seasonal.

It doesn't, it doesn't perpetuate beyond the season in which it was transferred. So that, that's just something for, like, from a regulatory perspective and looking at it, why they, why they treat it more like a permanent transfer in regulation when it's not in fact permanent, if that makes sense. Through the chair, Lauren, I Just from a regulatory standpoint, leasing and hired skipper use is different. It's a different process. You know, one requires RAM effort and one doesn't.

I think what you're referring to is in concept, why is it not more similar to the way a shares or hired skipper works? Because it is intended to be temporary, but I guess my point here just is that the practice of leasing and the practice of hired skipper use in terms of the management work that happens in the background is different. Does that help?

Okay. Okay. As requested in this motion, we provided some background on the CDQ program and some similarities and differences with the CQE program. The CDQ— in the CDQ program, there's a portion of the BSAI tax and PSC limits that are apportioned to 6 regional nonprofit corporations that manages them on their, their own quota directly. CDQ managers must submit hired master applications for all individuals who are eligible to hire.

For CDQ halibut, it's the same application as the hired Hired Masters application except for CDQ, there's no demonstration of vessel ownership required from CDQ managers. So it's similar to the Hired Masters, similar to the Hired Masters. It's not an official transfer of quota like leasing is. The CDQ managers directly self-manage in-season distribution of the quota harvest across vessels and The broader CDQ management is liable to ensure that they don't exceed the group's quota.

Okay. So, my understanding of the impetus of this proposed item is there's an interest in generating more accessible and efficient internal management systems that may allow for more quota to be harvested. Um, so I just wanted to highlight Table 2 here to demonstrate there has been low prosecution rates of CQE quota, especially in recent years. Over 750,000 pounds of CQE sablefish and halibut combined went unfished in 2025. These low prosecution rates can be problematic because they may be out of alignment with the CQE program's goals, which is to ensure that the quota is allocated to eligible community entity and would be held and not unfished.

And I think like other quota shareholders, CQEs may need to secure funding for quota share purchases. They might need to take out loans. So if there's no value generated from that quota, it can make it difficult to service the debt. So an easier internal management system may encourage greater prosecution rates.

In the paper, we lay out two approaches for looking at improving internal CQE management. The primary distinction between the two options we lay out is around liability and direct control of the IFQ. So one possible pathway is to look at the hired master privileges as sort of a template for IFQ derived from CQEs.

There would be substantial regulatory changes to switch from this leasing style and structure that currently exists to a hired skipper style.

There's a number of regs, and our current system is built that way, but we do have a model. It could be similar to the process used for IFQ hired masters, CDQ hired masters. The CQE would complete an application to list the hired skippers to fish their IFQ. The IFQ in this case could remain in the name of the CQE. So that means they would still have access to the accounts.

They would see how much was fished. Also, liability would still remain with the CQE. It would mean there would, there would not be a transfer eligibility certificate or transfer process through RAM.

There's also kind of a distinct policy consideration with this pathway, and that's that the council has continued to recommend amendments to reduce the use of hired skippers to allow original business structures to exist, but for catcher vessel quota, the use of hired skippers has phased out over time towards the goal of an owner-operated fleet. So that's linked with some of the IFQ report stats, which show a decreasing trend in IFQ fished by hired skippers. On the other hand, having a more efficient system that allows for higher prosecution rates may be in line with the CQE's goals to encourage the IFQ to be fished.

Lauren? Thanks, Sarah. The no TEC or transfer process through RAM for hired master, I was told recently, maybe you could confirm this, that that also applies to the age restriction because age restriction is tied to the TEC.

Through the chair, Lauren, I have been thinking about that question. I don't know the answer to it. I could follow up on it, but I, I mean, NIMS has an interim— it's not set in regulations, but has an interim minimum age restriction for quota or IFQ transfer. And so my initial understanding is that that would be tied to the TEC. So I think that if the council pursues this path of looking at using a hired master option for CQEs, there's a number of follow-up questions we will need to go into, and I think that would be one of them.

So the second possible pathway here is to keep the leasing structure, but to provide some specific direction within the IFA, the Integrated Fisheries Application. So have the AP and the council direct what functions they would like to see. So the council could articulate specific things like increasing management efficiency, possibly providing self-managed return transfers by the CQE group manager. This still might require regulatory changes to dictate this scope, but the underlying structure would still be leasing and it would still require a transfer through the eFISH system. So that's a different sort of pathway that you could pursue.

Okay, if there— there's no other questions on Proposed Item 4, that's kind of a more complicated one, I can move on to Number 5.

Okay, so proposed item 5 looks at the CQE-specific vessel use cap for sablefish in the Aleutian Islands.

So we had testimony in October of last year that proposed to increase or remove the 50,000-pound vessel use cap that's specific for CQE drive sablefish and to look at at it for IFQ in the Aleutian Islands. It was stated that this cap is a barrier to full harvest of the CQE sablefish IFQ as current holdings would require 13 unique vessels to fully harvest this CQE group's full sablefish quota share. So there's some background on the regulations here. CQE regulations limit a vessel to harvesting no more than 50,000 pounds of sablefish derived from a CQE's quota within a fishing year. This 50,000-pound limit applies to all CQEs.

There's also a similar limit of 50,000-pound, vessel-level 50,000-pound limit for halibut IFQ as well. The original objective around these limits were to ensure broad distribution of CQE benefits among vessel owners.

There's also general vessel use caps that also apply. You can see those in Table 8, but they're usually much higher. So the CQE-specific cap is the one that would theoretically constrain a vessel first. Also of relevance here, there's a 50,000-pound limit on the amount of IFQ that an individual may receive from a CQE. That's not part of this proposal, so that limit would remain.

Lauren?

On that last point, how does that play here? So you would have to have multiple people on board in order to go over that 50,000-pound vessel cap because they're still constrained, because isn't it 50,000 pounds per individual, or has that been also waived for ADAC currently? Yeah, through the chair, Lauren. So that, that is in place. So I think I touch on this in the preliminary assessment.

You may be able to consolidate, if this proposal passes as described, you could consolidate the number of vessels harvesting, but you would still need a certain number, potentially up to 13 individuals. So they could be walk-on individuals on those vessels, but you still need, there's still a 50,000-pound limit for transfers to an individual. And just to clarify, that's not something that has been waived for ADAC? Currently. Future?

No. There is a fair amount of background on the ADAC CQE. So this is the ADAC Community Development Corporation is the CQE for ADAC. Table 9 shows ACDC's Sablefish holdings. You can see there's a difference there in 2025 and 2026.

2026. So this table also confirms what was stated in testimony. With this cap and holdings in 2025, it would take 13 vessels to harvest their quota, which is now 14 vessels with the quota— amount of quota that's held in 2026. So they've been successful in acquiring quota. They have had challenges in full prosecution of this quota.

Landings data is confidential, Um, but they've had 0 to 3 active vessels harvesting each year. These vessels have not been near the 50,000-pound cap in recent years. However, as highlighted in testimony, the proposed action could potentially provide new partnership opportunities if a vessel is able to capitalize on the economies of scale associated with the greater harvest of quota.

Page 25 of the analysis describes that even if the vessel caps were removed, there's likely a number of other factors that could continue to challenge the prosecution of this quota. For instance, only 1.7% of the AI TAC in 2025 was harvested. A lot of quota went unfished. Also, there's still a cap on the amount of IFQ that an individual can hold, which is what we just spoke to, so you could consolidate it onto potentially 2 vessels, but you'd still need a number of individuals to harvest it. Also, there's a temporary exemption for ACDC to be able to lease to non-residents, but that exemption expires in 2028.

So after that point, depending on what the TAC is, you could need 14 ADAC residents or a number of ADAC resident IFQ holders on board to fully harvest that TAC or that quota.

Lauren? Thanks, Sarah. I think one thing that I've been struggling to understand is— and I understand that so the performance standards that were developed by the council, I mean, those aren't necessarily regulatory. Those are kind of like guiding lights for how the program should operate. And it explicitly states, like, ensure that quotas or IFQ allocated to an eligible eligible CQE would not be held and unfished.

And when you— I look at ADAC, like, they've continued to acquire more and more quota that has continually gone unfished. So in a program review or anywhere, is that looked at and is that questioned? And in terms of like the intent, because it starts to look more like a speculative investment rather than an actual intent to use the program. I don't know how else I don't know how to phrase this, but I'm just trying to understand the interplay of, like, the performance standards and the goals of the program and the regulations and where that all comes together.

Through the Chair, Lauren, I'm not sure if that's something that would have been looked at in the IFQ program review. I mean, I think, like you're saying, they're kind of guiding principles, so it is something that comes up, for instance, when we're doing a discussion paper like this, through an analysis, it would be something that would be highlighted. I'm not sure if it's come up in the past.

Sarah? Yeah? I just had a question. We didn't receive any comment from the CQE there in the region. I didn't see them in your person's consulted list in the document.

Did you have any communication with representatives from ACDC or—. Mr. Chair, no, I didn't. I listened to the testimony from the last meeting in October, which helped to inform the sections that describe proposed action, but I did not reach out to them. Thanks.

So to follow up on this proposed item here, this is proposed item 5, not 4.

The proposal highlights a policy trade-off between the original objectives, as we've just been talking about, of ensuring broad distribution of benefits and ensuring that quota share has the opportunity to be fished. This type of policy trade-off has been considered before especially with recent changing dynamics within the fisheries. So I have a couple of examples here. One in particular, Area 4 vessel caps recently were considered and increased the— the council increased the halibut vessel cap for Area 4 and specified that halibut IFQ held by Area 4b CQE, so the Adax CQE, does not accrue towards the Area 4 vessel cap.

Proposed— this proposed action is specific to the ADAC CQE and specific to sablefish. If the council does choose to move this forward and identify, it may be helpful to identify a specific rationale around this scope. So why specific to ADAC and specific to sablefish in particular?

Okay, moving on to proposed item 6, CQE quota share use caps.

In October 2025, the council received public comment proposing to eliminate the individual CQE purchase limitations. Um, testimony described that community long-term planning and funding opportunities may be impacted by these limits. Um, and the motion Says the use caps established for all CQEs would remain in place at 21% of the total halibut and sablefish IFQ in each regulatory area, but the total halibut and sablefish quota a Gulf of Alaska CQE group is eligible to hold would increase.

So as stated in the proposal, there are limits on how much a CQE community can hold hold. That limit matches the quota share use caps for all persons holding quota share unless they were grandfathered in at a higher amount. Table 10 demonstrates the individual quota share use cap— use caps, which applies to a person as well as each community represented by a CQE. Table 11 demonstrates how many communities could theoretically purchase up to their individual cap based on the cumulative cap for each species and area. So this table demonstrates that the CQE cumulative cap is most likely to be constraining for Area 3B halibut or Central Gulf or Western Yakutat sablefish quota share, just based on the amounts.

Um, for the preliminary assessment of this proposed item, there's no Gulf of Alaska CQE that currently is close to the individual group caps. However, as highlighted in testimony, the limits may affect long-term planning funding opportunities and could be a constraint in the future. The caps were intended to balance CQE opportunity with possible impacts to other CQE new entrants and quota share markets. The proposed action may have no impact if no groups end up purchasing up to the cap, or it may allow one or more groups to transfer over the cap. Further analysis could consider broader quota share market impacts.

We highlight recent restrictions on medical lease transfers that may have resulted in more quota share on the market and the recent implementation of the charter halibut stamp as funding for the RQE that may generate more competition in the quota share market. So that's something that could be looked at in a future analysis if this moves forward.

Okay, for proposed item— or for item number 7, I'm going to turn it over to Liz.

Thanks, Sarah. As a reminder, NIMS wasn't able to attend the October 2025 meeting. Had we been able to, we would have gladly provided a clarification on item number 7, a clarification on whether current regulations allow CQEs in the GOA to also hold federal processing permits.

CQEs in the Gulf of Alaska and AI are able to apply for and hold FPPs, and this is specified in regulations at 50 CFR 6.79.4. I've also provided a link to our website, which should be clickable in the file that's on the Council E Agenda to take you to our website where you can see the FPP applications.

Item number 8— items 8 and 9 will both touch on the PNO topic.

This was a request to consider waiving the prior notice of landing requirement and restricted unloading hours for small IFQ deliveries.

In the Council's proposal, the specific wording was potential to waive prior notice of landing requirement and restricted unload hours for small IFQ CQE deliveries, considering specifically a 2,000-pound threshold. In testimony, It was stated that there was difficulty complying with PNOl submission time requirements, particularly for smaller vessels with lower operational efficiencies, and also in remote areas that don't have cell coverage to call OLE, which is the method of submitting a PNOl, is to call the OLE's call center, and that these OLE's operational hours which I will also get to in the following slides, preclude faster turnaround time to get back to fishing grounds and continue harvesting.

So the primary use to— for PNOs is to provide OLE with advance notice to perform inspections which are in compliance with statutory requirements. PNOs are also used by IPHC representatives to collect biological samples in accordance with their protocols.

The prior notice of landing requirement is in regulations at 679.5, and the PNOL requires— requirements state that it must be submitted 3 hours prior to landings of IFQ halibut, CDQ halibut, or IFQ sablefish by calling OLE during their operational hours, which are 6:00 a.m. to midnight Alaska time.

Something that we discovered after publishing the discussion paper on the eAgenda was an additional set of regulations under eLandings registered buyer landing reports.

And this specifies the unloading hours which are allowed for deliveries of IFQ halibut, CDQ halibut, or IFQ sablefish, that they may commence only between 6 AM to 6 PM unless given permission to land at a different time is granted by OLE in advance. So reading these two regulations together and noting that OLE reviews these PNOl requests on a case-by-case basis. So at the time that a PNO is submitted, vessels could ask OLE for permission to unload later than 6 PM, and that would be sort of a conversation with enforcement.

Lauren? Yep, thanks, Liz. And if you don't know the answer, that's totally fine. It's just something that I thought about. Do other fisheries outside of IFQ have these same requirements for the PnOL and for unloading hours that are restricted, other federal fishery landings for catcher vessels?

I cannot speak to other fisheries. The PnOLs are specific to IFQ halibut, CDQ halibut, and IFQ sablefish. We do have Alex Perry in the room and also Josh Keaton online if they have anything to add to that.

See no hands.

The trawl EM deliveries do have a prior notice of landing in the regulations. There's not a time, but they do have that notification requirement.

It is when they leave the ground, so there's not a time specified. It's as soon as they leave the ground.

So there are two existing waivers for PNOs, which can be found at 679.5, and they are both for landings of less than or equal to 500 pounds of IFQ halibut landed concurrent to either fishing by either salmon troll or lingcod dinglebar, and both of these waivers were adopted to facilitate compliance with regulations which require IFQ holders with remaining quota to retain halibut landed concurrent to other fisheries, and these waivers are also specific to state-managed fisheries.

Which would not otherwise require OLE notification. The 500-pound threshold was selected specific to— specifically as an amount that was sufficiently large to cover typical incidental landings in both of these fisheries and not so large as to jeopardize effective monitoring, which is a goal of the IFQ program. Program. And I've included links to both of the Federal Register final rules for those, which includes these details. And importantly, both waivers do not eliminate the requirement to submit a registered buyer landings report.

Sometimes this is referred to elsewhere as an IFQ/CDQ landings report, and I've included a link to our website where you can It can take you to eLandings, or you can also submit manual reports, but typically they're submitted through eLandings.

Laura? Let's just clarify, that's just the eLandings fish ticket for IFQ? Is that what you're referencing? Through the chair, yes, that is my understanding. Thank you.

PNOLs are used for monitoring enforcement. The council recognized that the issuance of quota could create incentive to underreport halibut landings, and so at the time of implementation of the IFQ program, they recommended requirements including the PNOLs to increase the monitoring enforceability of the program while also balancing costs to fishery user groups. Pnols, to recap, are in particular used for OLE officers to notify them of landings and also for IPHC port samplers. And also I've included a reference to the IPHC sampling manual which specifies protocols for how they sample small landings, which are defined as 2,000 pounds in larger ports and 1,000 pounds in all other ports. So a waiver of 2,000 pounds or lower numbers would affect this small landing sampling protocol.

Lauren. Thanks for including that. So is that— if I'm reading this correctly, they don't sample landings of that size? Is that what this is saying? Oh, I'm sorry.

Through the chair, yes. They do sample those landings, and that is a clickable link to their sampling manual. If you go to page 15, it includes kind of a specific table of days that these ports are sampled, and my understanding is that the IPHC republishes that table each year, so it could change. Um, yeah.

Um, so per the council's motion, uh, we considered this 2,000-pound threshold, and I'm just going to take a minute to explain what we're looking at here, uh, because it'll also, um, for the next few slides, this is going to apply. But tables 12 and 13 in the paper, I have broken them apart on these following slides into considering halibut first, and then we'll get to sablefish. And so what we did was, for the most recent 5 years available, 2021 through 2025, we pulled PnOL tickets that were predominantly halibut catch and then also sablefish catch, but we're looking at halibut right now. And on the top slide, on the top panel, which is part of Table 12 that I've taken over to this presentation, we tallied the number of PnOL tickets that were for trips that were less than or equal to 2,000 pounds of halibut and then took the proportion of trips each year that were represented by that number. And so the proportion is in the yellow column on the right, and it's for each year.

And across the 5 years considered, the proportion of P&OL tickets which delivered 2,000 pounds or less of halibut ranged from 46 to 50%, which means that essentially if we had been applying this 2,000-pound P&OL waiver from 2021 through 2025, 46 to 50% of trips would have been waived of that requirement. And in the bottom, we looked at from those same trips, we're looking at the amount of halibut landed, and we measure halibut by weight. So we're looking at the proportion of halibut weight each year that would have also been waived under the PnOL waiver for 2,000 pounds, and that number ranges from 6.8% to 11% by year. Lauren? Yep, thanks.

Um, I was wondering if you could touch a little bit on— and I don't know, this is— this might be confidential because of the smaller ports, um, but a large reasoning behind the PNO in the 3 hours was to reach remote ports and give enforcement enough time to arrive in remote locations that don't have enforcement staff like always there. Um, could you speak to that a little bit just to clarify that intention of the PNOOL? And then was any of this looked at from a perspective of which of these occurred, actually occurred in remote ports versus which occurred in ports that have regular enforcement that are within minutes from the dock on a regular basis? Through the chair, your point about remote versus major ports is taken, and it's something we've thought that could be useful if there is a recommendation for further analysis, but we we did not consider it for this paper. With regards to the intention of PNOs, that is my understanding, that the notice is intended to give them ample time to respond to whatever locations they agree on for these landings.

Alex Perry may have more to add.

Through the Chair, members of the EAP, Loren, Alex Perry, Office of Law Enforcement. You covered it well, Liz. I don't really have much to add with respect to the reasoning behind why that 3-hour limitation is put in place. It is absolutely to give our officers plenty of time to respond and be able to go and watch an offload and audit the process.

I did a quick dive through the regs based on your former question. You put me on the spot there, and I did not find any other fishery that actually has a landing offload hour restriction. And I can continue to dig for that, but I didn't find any other fishery.

Thanks, Alex.

And so, if you've been squinting at the numbers in this slide or in the paper, you may notice that these numbers have increased over time.

Too many computers going on. So, the numbers have increased over time and that's about what we would expect given that halibut tax and CPUEs also declined in recent years.

Just worth noting. Now I'll step through the same thing with our sablefish preliminary assessment.

So again, this is looking at 2021 through 2025. Sablefish deliveries that were tied to PnOL tickets and looking at the proportion of those trips that were less than or equal to 2,000 pounds in the top panel, which is coming from Table 12. And you'll notice that these numbers range from 4 to 7% of trips each year would, would have been waived had there been this PNO waiver for 2,000 pounds. And in the bottom panel, this is looking at the amount of sablefish by volume. And the amount of sablefish by volume that would have been exempt under the PNO waiver for 2,000 pounds ranged from 0.2 to 0.5%.

And just a note that it's kind of the opposite trend, that it— the proportion of trips and the amount of sablefish that would have been waived declined over time, inverse of what we saw with Halibut.

So in this preliminary assessment, the discussion paper explored the 2,000-pound threshold, which I stepped through in the previous slides. There seems to be a potential benefit to smaller vessels, which would have smaller deliveries, which would have less potential to offset operating costs, and also Got ahead of myself. The council could potentially recommend analyses of other thresholds that were closer— are closer to current exemptions, which are both for 500 pounds of only halibut. There's no current PnOL waiver for sablefish.

And the council may also wish to consider these lower thresholds as a pathway to reduce the intersection of impact with the IPHC's sampling of small landings. But regardless, I think that further recommendations for action on this would, would require consultation with the IPHC. The council could also ask the enforcement committee to weigh in on other potential paths to to meet the enforcement and monitoring goals of the PNO waiver. For example, using VMS could potentially reduce the reporting burden in these remote areas, as was brought up in October 2025 testimony. The Council may also wish to ask the Enforcement Committee to weigh in on any further discussion or analysis on this topic.

For potential impacts to compliance oversight.

And, uh, sorry, would it be possible to look at kind of like from a cost analysis perspective in terms of like small, small, um, landings, the amount of data collected, you know, the cost of that versus like looking at larger landings and what data you're getting from that? Is that something that's even possible from an analysis perspective?

Are you referring to the cost— through the chair, excuse me— are you referring to the cost of— cost to the vessel operators or—. No, agency, kind of administrative costs on the agency side of like, you know, you know, especially with OLE billing, you know, the 15-minute increments and all those kind of things, like what that looks like for going down for a 1,000-pound offload to watch it happen versus a 5,000-pound offload and what that could look like. I don't know if that's something that we look at even. It's just a question for what could be considered. Yeah, I think Sarah might be better to answer that.

Through the chair, Lauren, I think that's something we could possibly probably explore in a next iteration. I'm not sure how specific we'd be able to get, but I think as Liz is going to highlight, if this moves forward, we would certainly need additional consultation with OLE and IPHC, so maybe some of that characterization could come out.

This is probably more for you, Alex. You know, right now with the unloading hours, as is the 6:00 AM to 6:00 PM, like you can't start after 6:00 PM generally, but your call center is open till midnight. What are the working hours generally of OLE? Like how often are they looking at these offloads? Like in between what hours is that generally happening for them?

Through the Chair, thank you for the question, Lauren.

I—. These regs were written a long time ago, and so I don't I, for this discussion paper, I didn't look into the purpose of why those unloading hours were specified the way they were, but if I had to guess at it, it would be in order to, you know, have officers be available and present and not have to work, you know, auditing an offload through the middle of the night with, you know, no notice or less than 3 hours' worth of Notice. So there's kind of two aspects to this from a cost basis perspective. One would be increasing the number of hours and almost certainly personnel who would be through the data clerk contract for that call center. If we were to be looking at expanding the call center operation.

And so that's from, I believe, 6:00 a.m. to midnight. And then we would also need to look into the added costs for having officers available to audit landings that occurred afterwards. And as was stated, there is a process wherein folks can ask for and be granted waivers from those offload hours. Typically, when— and when we don't receive a lot of those, I would say maybe, you know, a dozen or less than 20 in a given year. Typically, we'll look at whether it's, you know, a safety issue or something like that that is causing the necessity to offload outside of those hours.

And as Liz said, we do look at it on a case-by-case basis.

Thanks, Mr. Chairman. Thanks, Alex. When you talk about expanding duties and call hours and things like that, does that become a cost-recoverable activity?

Through the chair, Ms. Mann, thank you for the question.

Yes, a short answer. In a longer answer, as we've had this iterative process going back and forth with cost recovery. You know, NIMS is taking a look at cost recovery now.

And the AP and council should expect to hear back once we figure out more about that process.

Chance? Thank you, through the chair. Apologies if I missed this.

Are 100% of those offloads that are reported witnessed by OLE, or do you guys reserve the discretion to witness at will?

Through the chair, Mr. Miller, thank you for the question. Uh, certainly not 100%. It is as officers are available and able. They will prioritize, you know, based on whether or not a vessel has been previously audited. And, you know, if a vessel has been previously audited for an offload in a season then they would prioritize a vessel that has not to go and perform an audit of that offload.

Bernie.

Through the chair, you know, I'm kind of looking at this from a smaller fishing vessel perspective, like ADAC. They They really don't even have a processing facility at this time. But to get a processing facility and get people to come in and deliver, you know, it's, it's tough if you're on a clock, especially for a small boat. If they've got to get there by a certain time, probably 50, probably 75% of the time they're going to be later rather than on time. It's just the way it goes.

So I'm, I'm all for, I mean, I know we've got a work with OLE and address your concerns. But I'm very supportive and hope that we could move through this and reduce the complexity and the cost for some of these smaller harbors like ADAC and help them to the degree we could. What are you— Are you opposed to that, I guess?

Through the Chair, Mr. Burkholder, thank you very much for the question.

From a general standpoint, OLE will enforce the regulations as they are designed by Council through the Council process and as they are implemented by NIMS.

If it is the council's desire to change the designated offload areas, OLE will enforce it as it is written in the regulations. So OLE doesn't have a particular desire. It would kind of come down to council's desire to determine whether or not and to what extent this monitoring does need to take in order to achieve the council's objectives of, you know, preventing fraud and so forth. So, as was mentioned in the discussion paper, you all and council may wish to request that we hold an enforcement committee meeting and potentially hash out some of those more detailed concepts.

Thank you. That helps me. It helped me a lot. I appreciate your comments there.

Thanks. Bernie, do you mind grabbing your mic there? We are going to take Duncan Fields to testify. He has an engagement, and so I am sorry, staff, I know this is a little choppy for you, but I want to make sure we allow him to testify before he has to leave, and given the importance of this issue to the folks he represents. So we'll just do a brief transition and I'll give staff a minute here.

Sorry to transition, get the timer up.

If you just give us a second, Duncan, we'll get the timer on board.

Okay, we're good to go. Thank you. Thanks, staff. Mr. Chair, members of the AP, thank you for my schedule, no matter how you try to plan things, it seems it always ends up as a conflict today.

So I appreciate the accommodation.

I'm going to just have some preliminary remarks, if I may, Mr. Chair. The CQE program was conceptualized in 1997. I wrote the white paper on it individually. It took 5 years of attending every APU meeting, every halibut committee meeting, every staff tasking to move it from an idea to be considered by the council, another 2.5 to 3 years to move it through the council process.

It was passed by the council in 2004, if I'm remembering right, and implemented regulatorily in 2006. The first CQE was purchased in 2008 by Kate Barnabas. I said all that to say this. You are a large part of the brain trust of this industry sitting around this table. Many of you are young and you have the capability of thinking outside the box.

The CQE program was thinking outside the box. We had an IFQ program that had been implemented in 1995. We had quota share rapidly leaving rural communities. The problem was how do we address that issue within an existing IFQ program. Program and the conceptual framework for the CQ program was born.

We as an industry have many, many problems. How to better manage Gulf of Alaska fisheries? Think outside the box. Don't grab the old rationalization program or the co-op program. Look for something hybrid.

Someone around this table can conceptualize how to better manage Gulf of Alaska fisheries. We also as an industry industry are proactive on many— or reactive on many, many issues. My own area that I've advocated for is better bycatch utilization. This is a time for the AP members and the industry to begin to develop a new type of approach to bycatch utilization, to be proactive for our industry and not reactive. And Mr.

Chair, that's what the CQA— CQE program was. It was something to be proactive within an existing management framework. Having said that, I wanted to say that the analysis is an excellent analysis. I was frustrated that we went out for a revised discussion paper when it occurred a year ago, but it was the right thing to do, and I think the discussion paper highlights most of the issues of relevance for the AEP's decision-making today. I would say one thing about the paper.

Most of the tables and the information relative to the amount of CQE that's been fished or not fished is with regard to ADAC's ownership of halibut and sablefish quota. Those tables should be revised and ADAC should be treated as an outlier within the CQE program because that's what it is, Mr. Chair. I can speak I should have said that I've managed the CQE's Cape Barnabas Inc. for Old Harbour and Yuzinki Community Holding for Yuzinki since the inception of the program. We have fished all of our quota consistently over the 14 or 15 years that we've had quota share.

We represent about 85% now of the Area 3A quota. And so the statistics relative to the amount of quotas being fished by the CQEs are substantially skewed by the inclusion of the ADAC data. Having said that, Mr. Chair, I think that the AP should move an omnibus motion forward and you should identify as a primary discussion alternative the inclusion or the identification of the qualified CQE as similar to A-share quota holders with the opportunity to identify and use hired masters. That solves many of the in-season transfer issues.

It solves concern about the certificate of eligibility. It also, I think, may solve some of the issues with regard to age that have come up, Mr. Chair. And I see that as an integration into an existing existing regulatory structure that provides for the needs of the CQE without creating an entire new programming dimension to the NIMS accounting program. I don't see that there's any reason to continue to have the CQE in-season transfer go through NIMS.

I think the CQEs are glad to assume liability should their designated skippers have fishery violations, there's a number of levers, economic levers the CQE can pull to ensure that those skippers minimize fishing violations or don't receive CQE quota in the future because of those violations. So to me, the identification by the AP of the A-share model and inclusion of CQEs within that model is the approach we to take. Relative to the concern about reducing hired skippers, it's a conceptual divide. The hired skipper reduction is focused on individuals that were grandfathered in that held the initial IFQ. But the program always envisioned that you would have A-share owners that would continue to have hired masters.

The CQE are much more similarly situated to A-share corporate ownership interests than they are to the individual fishermen. And that's the divide with regard to the policy. Should we be moving towards eliminating hired skippers, or should we recognize that the CQEs are similar to the A shares, which were envisioned to have hired skippers in perpetuity, Mr. Chair? With regard to the second issue— and I'm not sure where my time is now— but, um, it's really important to recognize that the frequency of being able to address CQE and IFQ amendments comes around every decade or so.

It's been about 15 years since you have the 10-year programmatic review, then development of concerns from that review, now two white papers from that review. So looking forward, We need to carefully analyze and expand the quota share purchase limits for the CQE. Remember, the underlying goals for the CQE program were to mitigate harm for rural communities because of the IFQ program and to provide an international standard 8 for the sustained participation of those communities in the program. We haven't done particularly well in that regard. But with the current individual caps on community ownership, we can't even begin to get there.

At 48,500 and some pounds for area in 3A and 3B, that sustains 2 fishermen in the community in terms of focusing on IFQ harvesting and, um, maintaining their vessel and hiring local crewmen. We're suggesting that we expand that cap to consider up to 3% of the available quota share in Area 3A, 3B, 2C combined, which is, for analysis purposes, 6 times the current quota. Remember—. Am I done? Okay, thank you for your courtesy.

Let me finish with this statement. Remember, The current quota cap is only one individual cap, and the AP has to ask, is it equitable or is it a good policy to constrain a CQE that represents an entire community to one individual cap? And, Mr. Chair, thank you for your time. Thanks, Duncan.

We'll go Lauren, then Heather. Thank you, Duncan, for your testimony. Um, I wanted to ask something about your last point, maybe give you some more time to speak to that, and also reference your comment letter, and also your long history in this program. So initially, in the inception of the CQE program, was it more just to provide access, sustain access, or was the intent to provide a season's worth of access to a fisherman operating a business? And I also ask that from the lens of where we're at with halibut abundance and the realities of fishermen only prosecuting one fishery these days, whereas maybe in the past that was more realistic.

But as we've seen quota levels drop, you see more diversification occurring. So you speak to the need to have enough quotas to sustain a person's entire business model for the CQE, and I just wish— would like you to speak to that a little bit further to understand if that was the original intent.

Thank you, Lauren. I'll try to be concise. You have a convergence of another of regulatory changes in the rural communities over the last 30 years. We've also, in addition to the migration of IFQs, seen the migration of limited entry salmon permits. Whereas in 1990, a rural resident from Old Harbor, for example, would probably fish salmon, herring, halibut, and if there was a Tanner crab season, Tanner crab.

In the last year, all but one of those has essentially gone away, which is halibut. So that's where reality has interfaced with programmatic goals in the community. Back in 2008, 2004 when this was implemented, perhaps it was realistic to think that a CQE quota shareholder would also have other fishing opportunities in the community. In 2026, that's much less possible than it was 20 years ago, if that answers your question.

Uh, thanks, Mr. Chairman. Thank you, um, Duncan, for your testimony on the first issue, you talked about a lot of the benefits that you saw and you listed those out. Can you think of any drawbacks to that? Because you're the expert on that. Well, that's always a good question.

From a policy standpoint, we have to ask, is there an importance or is there a reason to have Nationally Fisheries and RAM Division continue to to monitor those in-season transfers. From our perspective as the CQE, I'm not aware of that reason, but institutionally I'd be interested to hear from RAM relative to concerns they might have. I do know that currently their transfer system doesn't allow for CQE transfers. It has to be done manually by hand. It takes 2 or 3 times longer for CQE transfers to occur because of that.

I know as they're establishing a new data— a new program for transfers, that including the CQE program will make the development of and implementation of that problem more complicated. But having said that, I don't see a downside, but it's always an important question to ask. And while I have you, Heather, on a prior issue in June, I testified for this body on Tanner crab, and I used an erroneous statistic. And you called me on it after, and I thank you, and I apologize.

Thanks. And thank you for that response, Duncan. It really helps. And it leads me to ask about, in those communities, is there currently active processing, or how are you handling landings? And how does that interplay with some of the requests here for use of tenders and waiving of the prior notice of landing?

Um, multi— several questions in that question. Um, processing in both Old Harbor and Uzinkea at this point aspirational. The tribal entity in Old Harbor has acquired a processing plant and hopes to process both halibut and salmon on a niche market or artisanal basis. Part of their long-term community plan is to accommodate a few cruise ships per year in Dold Harbor, and they would like to have their own halibut and salmon available for purchase at that time. The— again, back to exploration plans, Yusinki has a similar long-term community plan that would include a facility dockside for both the ferry and cruise ships.

And they would like to have their own salmon and halibut from the community processed in Nusinkee as well. But currently the answer to that question is no. Relative to the notice requirements and the landing requirements, the hub, of course, in Area 3A where I am is Kodiak. And the rural residents in the communities haven't run into the same problems that you've experienced in Southeast Alaska. Complete support for accommodating issues in Southeast Alaska to support those CQE communities, but currently those issues haven't surfaced in the communities that I work with in Area 3A.

Nels?

Yeah, thank you, Duncan. You definitely— you know this very well through through and through the CQE program. I'd just like to mirror similar concerns that I had yesterday during the RQE and GAF conversation that I really think that a lot of this stems from the abundance of halibut and pulling from one pool to support or supplant another pool at a time of low abundance. I mean, we all know we're at, you know, we're at a 50-year low in the biomass. I do struggle with reallocation within any sectors right now because ultimately everyone is feeling the pain.

I just wanted— like, what considerations do you have about that? I know you answered a similar question to Lauren, but I just want to see if you have more of an expanded thought there. Sure. Let me rephrase your question, if I might. Your concern is that if the CQEs purchase up to 21% of the halibut in the Gulf, there's going to be a lot less halibut but for commercial fishermen.

I think initially we have to recognize that this was a program to mitigate harm and that initially that was a benchmark of quota that had historically been held by small rural communities. I've been through the allocation battles which were frequently politically driven and always difficult. I think we've moved more to a model within the council discussion of the economic exchange of quota or the ability for quota to move where it has the highest value. That's discouraging to me in some instances when I'm wearing my fisherman's hat because I would like to preserve the historical traditional Alaska small boat commercial fishery in all of Alaska. But the reality is, is it is a public resource and that resource needs to be able to flow to the industry that can provide the most economic value for that resource, even though I have this emotional historical tie to the commercial fishery.

So with regard to the CQE, as you're well aware, we have had a really difficult time finding money to expand and purchase quota share. We hope to continue that an endeavor, and that's why we're asking for opportunities for higher caps. I don't see that we're going to have an immediate or a significant— I'll say meaningful impact on the quota share market in the foreseeable future because of our funding limitations. But I share your overall, I would say, anxiety about changes in our industry. And losing some of our small boat commercial fishermen from our communities.

Yeah, thank you for that. And then just following up, both in your testimony written and oral here, you're clumping Gulf-wide, so 2C, 3A, 3B together. When you look at quota ownership within 2C, most of that quota is still held within the communities. Most of Southeast is rural, so I'm just wondering why you chose to lump everything together. As you mentioned, the issues within 2C are different than the issues in 3A, 3B.

So I just want to see if you have more expanded—. So, Nels, if that was your impression, I need to write more clear. It was my intention, and if you'll read my letter again, that 2C be viewed as separate and that the advocates for the CQE communities in 2C be consulted by the AP, and I think you'll have testimony to that effect in terms of moving anything forward. 2C is very different than 3A. The needs of the 2C CQE communities are different, and it's not my intent that as a motion comes out of the AP that you treat 3A and 3B identical to area 2C.

Chance?

Through the chair, thank you, sir. During your testimony, you mentioned this, and I just wanted to give you an opportunity to speak more to it. Can you talk more about why ADAC should be considered an outlier?

Well, ADAC, of course, was not initially included in the CQE program, but it lost its processor, and it had an allocation of POLIC, an allocation of COD, both of which were now limited because there was no processor in ADAC. And so in that context, the folks in ADAC came to the council and said, "The CQE model is out there. Could ADAC be included as part of that model?" They were included. They still face— and they were unique in that they had funding resources to invest in the quota. But of course, you're well aware For many years, the sablefish value, the sablefish was way down.

It wasn't economically meaningful to prosecute the sablefish fishery that far west. The logistic issues with regard to halibut out in ADAC inhibited them fishing that quota.

But the reason they're unique is because of their distance and their lack of a local processor. And currently only a very small economic core to that community. But I have optimism, and consequently, I think ADAC should be treated different, at least for a period of time. They shouldn't have vessel limits, they shouldn't have individual limits, and they should have an extension on the resident in ADAC limitation. In other words, currently that's waived, and I would include that waiver for another 10 years.

But eventually ADAC's gonna have a core economy. I think that probably will be provided by the military, but I don't have a crystal ball. When ADAC does, you're going to have a significant economic tool to maintain local fishermen in that community. Look at the amount of sablefish they have. Look at the amount— I mean, I'm jealous.

Frankly, I'm jealous. But they're under circumstances now that inhibit realization and the actualization of what the CQE program could be for that community. And that's the reason I'm suggesting we treat them differently, recognizing their current circumstances but trusting that the future will be different.

Bernie? Thank you very much for the history you bring and the knowledge And, you know, I'm struggling here. I mean, there are a lot— there's a lot of questions. Most of these CQE communities, whether it's Old Harbor, Usinki, ADAC, have vastly different needs for a viable business model. And the council process, as you well know, is not quick enough, I believe, or nimble enough to keep up with that because the changes are just there.

So how do we affect those changes and help the communities is my question because there's vast differences in what, you know, a CQE body may need in Southeast, they may need Yuzinki, they may be in ADAC, and I'm interested in what you think might be a viable tool.

I'm pausing not because I don't have lots to say on the topic, but because it's hard to refine that to a specific concise response, and Bernie will be meeting for dinner Friday night and we can really talk about these issues in detail. But generally, while we can point to problems in rural communities, inefficiencies from rural communities, social difficulties in rural communities, we can't give up on the fact that these communities have been tied to the marine resources in the Gulf of Alaska for a very very, very long time. And consequently, I continue to advocate and I continue to come to the council to provide opportunity for the continued participation of rural residents, small community residents, village residents, tribal residents in the fisheries in proximity to those communities. That's my goal, Bernie. It's sometimes very difficult and discouraging to see that we're not making much progress towards the goal.

But I can't give you a silver bullet in terms of how to get from where we are now to where we should be. Do a follow-up, please. I thank you very much. I don't think there is a silver bullet. But I'm like you, I'm trying to figure out how to help.

And, you know, sitting here today on the AP and being part of the council process, it's just not maybe flexible enough to stay in there and help on a year-to-year basis. I mean, processing is critical, getting small boats to the dock on time to maybe meet an enforcement officer. It's just a a lot of little problems. So we'll discuss it more over time, but I'm struggling to help. I want to help, and it's difficult.

So the one thing that would help me as a CQE manager immediately is raising the individual community purchase cap. That allows me to go out to a number of entities that are sort of impact investors and say, if you invest $5 million in old Harbor, we have enough quota for 8 fishermen to fish IFQ and survive in that community a long time. Now, getting those 8 fishermen is another challenge, but I always say, when you have the money, we can address the other challenge. And so that's something you can do immediately, is to raise the limit on the individual CQE community purchase. Okay.

Thanks. If you have time, I just— I have more of a background question. Bernie, do you mind? Sorry, just hearing a little reverb.

Thinking about the— sorry, the Item 4, which is the hired master, which you spoke to, and the policy considerations, also reflecting on your comments about thinking outside the box and about how CQEs were sort of tailored to be a solution to the impact, the negative impacts.

Can you talk about CQE governance and how it might— how they might be accountable to the community and unique— how each CQE is governed that may be unique to the characteristics of that community? Because I'm not really familiar with how they are, and it would be helpful to understand sort of what controls would be in place to govern that hired master change. So thank you for that question. And in my written comments, the first paragraph, the CQEs that I work with and manage and those that I advise, and I think I wrote the bylaws for a number of other CQE communities, some of which are not active, is that the governance is a 7-member board, 2 of which are from the tribal government 2 of which are from the municipal government and 2 of which are from the Angsa Corporation associated with that community. Those 6 members choose a 7th member.

Some of the Southeast CQEs are organized a little bit differently, but all of the CQEs I'm familiar with have a broad-based management structure within the community.

I may get in a little bit of trouble because we have some formal documents in terms of how the decision-making works within the CQE community, but I'm going to be real with the AP. In the early year or two when we got ready to allocate quota in Uzinki and Old Harbor, I had criteria listed in a point system and merit system in history and you know me, I'm going to get all the details, look it all out. And so we scored everybody in the CQE that applied for the CQEs and we sat down And the chairman said, "Well, thank you, Duncan, but who really needs to fish this quota?" And the discussion and the allocation of the quota within the sea communities that I represent to date has been an informal discussion about need and equity in the community. And there is always consensus in the end relative to who gets quotas. There's no votes.

There's a— not objective criteria. It's a community discussion about community need. Perhaps when we enjoy the luxury of 200,000 or 300,000 pounds of kóda in the community, we'll need to become more formal. But that's how it really works. You have tribe, corporation, municipal government, and they sit down and figure out who has the greater need in the community.

Thanks, Duncan. Appreciate that. I don't see any further questions. Thanks. Thank you.

Appreciate it. Let's finish the staff presentation and then we will break for lunch and finish the rest of the public testimony after lunch.

Thank you. So as we were getting into before Mr. Field's testimony, I think it's apparent by now that both PNOL proposed items in the discussion paper that the Council requested discussion of there's, there's some considerable overlap. Um, and so this is the last slide I have on proposed item number 8, which is relevant to the P&OL waiver, um, and unloading hours. But, um, I have a feeling that we will also be circling back to aspects of this in the next item. Um, and so, uh, to recap what the council's motion stated in October 2025, um, potential to waive the prior notice of landing requirement and restricted load hours for small IFQ/CQE deliveries, specifically the 2,000-pound threshold, which we went through our preliminary assessment of that.

Regarding specifically this part about restricted unload hours for small deliveries, any expansion— and I believe Alex Perry also touched on this, our OLE representative— any expansion of the unloading hours, which again were 6:00 a.m. to 6:00 p.m. or operational hours, 6:00 a.m. to 12:00 a.m., which again, the operational hours are the time period to call in and submit your PNO, which is the 3-hour notification of landings. Any expansion of either of those hours may incur proportional increases to the IFQ program's implementation costs and subsequently the cost recovery fees of the IFQ program.

Further costs related to expansion of OLE's hours would likely be the same regardless of the size of deliveries. Um, with regards to staff time, it was brought up prior to Mr. Field's testimony that there could be potential variability regarding travel time for OLE to remote areas versus more centrally located areas for their Officers, and if the council would like further exploration of that, we can, we can do that.

Oops, a little delay there. Item number 9 was requesting a discussion of expanding, potentially expanding, the designated unload areas for tenders receiving IFQ.

And the proposal language stated expansion of designated unload areas for tenders receiving IFQ or CQE halibut or sablefish. And testimony during the October 2025 meeting stated difficulty finding accessible processing and marketing options in remote communities of specifically, I think, Southeast Alaska. Proposers also suggested that the issue could be alleviated by expanding eligible unloading areas to tenders located outside of ports, potentially reducing, again, operational costs of transit to ports— fuel, travel time, planning for fishing operations in terms of turning around back to fishing, fishing grounds— and that this may be particularly relevant to the newly formed CQE, the Southeast Village Fisheries Collective. Proposers also noted that this access to tender service closer to fishing grounds is not exclusively relevant to CQE-driven IFQ.

Current regulations for PnOLs state requirements to, to include information regarding a port of landing and port code. Table— from Table 14A, which is the table of port codes specific to Alaska.

Apologies, the image that I had on this slide isn't showing up, but it's actually just a screenshot of the very top of Table 14A, which includes ports of landing and port codes. And also the P&OL information requirements require an exact landing location within the port. Port, for example, a dock name, harbor name, facility, or simply geographical coordinates. And Table 14A does include an option for, quote, "other Alaska ports," which I think ties back to this facet that these PNOs are reviewed by OLE on a case-by-case basis. And so that would sort of be a conversation with with OLE of what other Alaska ports would be acceptable.

Chance. Chance. Through the chair, thank you. And this might be a silly question, but is there an understanding of how many of these landing ports don't have an active OLE presence sort of all the time? Obviously, staffing is a massive issue, has been a concern, right?

With these P&OL considerations, the concept of having exclusions for places where there aren't OLEs stationed seems like a reasonable thing to think about, but how many of these landing ports don't have a consistent OLE presence? I'm going to hand that question over to my colleague, Lix Perry.

Thank you, Mr. Chair. Thank you, Mr. Miller. Alex Perry, OLE. So in the paper, we did list the ports that we have staffed.

And so that's Anchorage, Dutch Harbor, Homer, Juneau, Ketchikan, Kodiak, Petersburg, Seward, and Sitka. For this analysis, we didn't look at— and it was discussed earlier, brought up as a potential option— the kind of the number and amount of landings within each port. I don't have the exact number of ports that are in Alaska, but I believe I recall somewhere in the realm of 90 or more. So in reality, you know, I think that it would come down to kind of an analysis of the proportion of offloads, the proportion of catch, where it's landed. And any kind of consideration, you know, might need to take that into consideration for whether or not we can be responsive.

Um, we, we can respond to areas that have high activity through pulse operations, or if we know that there's going to be a lot of IFQ activity, we might travel to a port that we, we don't staff and monitor offloads for a period of time.

Forgive me also if this is a naive question, but are VSOs capable of auditing an offload? Like a village safety officer or somebody that might be acting as OLE in an otherwise, like a smaller port. Thank you, Mr. Chair. Thank you, Mr. Miller, for the question.

So we do have a joint enforcement agreement through Alaska Wildlife Troopers. And they are deputized, and so, yes, they are capable of performing audits of offloads representing the agency.

Interesting. Thanks. Thanks, Alex. Looks like we've lost our presentation.

She's bringing it back up. Oh, sorry. For Alex or— No, it's for Liz. Well, I don't know. I'm assuming this is for Liz.

The other ports, I started digging into this, and there was some language in the discussion paper that actually, like, limited what that could actually mean. Because at first it was like, oh, there's a way to use an other ports designation, but it doesn't sound like that's really a workaround. Could you speak to that?

Through the chair, this might be another one for Alex to step in on, but I I believe that it's sort of a case-by-case evaluation. It's sort of— this other Alaska isn't— it's not like a wildcard for any port. It's intended to balance enforcement and flexibility for operators. Does that help? Okay.

So the screenshot's showing now.

So existing regulations, as I stated, includes the location requirements for PNOs, and then also again these registered buyer permits now are under 6 79.4 of the Federal Register require that any person receiving IFQ CDQ halibut or sablefish from the person who harvests it— sorry, I misspoke— registered buyer permits are required of anyone receiving landings from the permit holder or hired master. And any person who harvests IFQ CQE sablefish could also have their own registered buyer permit to— getting all turned around here— but essentially a registered buyer permit is required of any person who harvests IFQ halibut sablefish or IFQ sablefish and transfers such fish in a dockside sale out outside of an IFQ regulatory area or outside the state of Alaska, and any vessel operator who submits a departure report. And also tying this back to the registered buyer landing reports, which I discussed under item 8, which I believe is under 679.5, There is also a requirement under landing reports for a location which would also be a port from Table 14. So there's essentially two parts of regulations that require a port of landing and port code from Table 14 that pertain to landings of IFQ CDQ halibut or IFQ sablefish. And so to expand unloading areas, the council would likely need to consider changes to both of those sets of regulations.

Collectively, the PNOL and the registered buyer landing report regulations mean that tenders with registered buyer permits must still be within ports to receive IFQ halibut, IFQ CDQ halibut, or IFQ sablefish. And so our preliminary assessment, we also looked at active tendering for IFQ landings in recent years, and the 2026 Report to the Fleet, which that is a link in the presentation, shows that the number of tenders with registered buyer permits increased from 2 to 4 in 2025. There were none listed for 2021. But furthermore, that none of those tenders with registered buyer permits were actively receiving IFQ/CDQ deliveries within the 5-year period 2021 to 2025.

The council motion language again specified expansion of the designated unloading areas for tenders receiving IFQ or CQE halibut or sablefish. If the council wishes to move forward on this proposal, it may consider whether this motion is intended to allow IFQ/CQE deliveries outside of ports, expand the list of ports in Table 14A, establish potentially specific criteria, for example, radius around port, radii around ports, or add other general language to clarify other types of locations allowable. And as part of any potential recommendations moving forward, considerations might include what requisite regulatory changes and analyses of impacts for alternatives might be beneficial. I mentioned several portions of the CFR that relate to landings of IFQ, CDQ halibut and sablefish. Also potentially weighing the objectives of Item 9 with the IFQ program.

So ability to unload closer to fishing grounds could increase operational efficiency for vessel operators, but how would that balance with the monitoring and enforcement, enforcement goals of the IFQ program? And additionally, further considerations might include specifics regarding the relative scope and potential benefits of alternatives.

Considering Items 8 and 9 together, I've sort of given shorthand summaries of them at the top of the slide, that Item 8 was for PNOOL exemptions and/or expansion of unloading hours, and Item 9 is for the expansion of unloading areas. If the council moves forward with both of these items, the analyses would need to consider cumulative impacts of changes. For example, if waiving the PNOL for small deliveries per item 8 of the discussion paper, would registered buyer landing reports still be required, as is the case under the two current PNOL waivers for 500 pounds of halibut landed concurrent to state fisheries. And further, if they would still require the registered buyer landing reports, would the regulations for those reports be revised to address Item 9 expansion of unloading areas for small deliveries? And I've included a link to that portion of the CFR for location codes in the registered buyer landing reports.

Other considerations for proposed items 8 and 9 of the discussion paper. Should the council recommend further analysis of items 8 and/or 9, it may also wish to consider consultation with the IPHC regarding the intersection with their sampling program, as have the two previous waivers for PNOs. And also consultation with OLE regarding, uh, potential changes to unloading hours or areas, um, and subsequently what potential changes to program costs could be incurred. Um, further, uh, restating that the council may also wish to ask the enforcement committee to review these elements and provide recommendations, um, if they are included in another discussion paper or an initial review draft analysis. And I will hand it back to Sarah for wrapping it up.

Next steps. Hopefully lunch and some fresh air. But after that, we can consider whether to move forward one or more of these proposals and if so, how you'd like to move them forward. We've had omnibus IFQ actions in the past, so these could be packaged together. There's trade-offs in thinking about, you know, 8 different proposed actions, how you might package them.

If you do, they— can they fit under the same purpose and need statement? Which proposed changes are the biggest lift? And whichever those are likely to drive the timeline for for the action. Packaging them together can lead to efficiencies.

Affected parties can come and testify at once. There can be shared background context, but it can also lead to a larger, slower package sometime, more for us to present when we come to you. So if this moves forward, the council might also consider its reliance on the expertise of its committees. As was mentioned, the Enforcement Committee, there's an IFQ Committee. Committee, so they could provide additional input if requested if this moves forward as analysis.

And with that, we are happy to answer any further questions before lunch. Thank you. Any final questions for staff?

Okay. We will be here after lunch, too.

Let's come back at 1:30. We will take public testimony with the remaining testifiers, and then we'll see if there's any motions.

Program participants. For the record, I am speaking in support of several proposed elements in the IFQ/CQE package under agenda item D3. First, on behalf of AC/DC, we do want to thank the AP and the Council for your recent action to liberalize the area 4B halibut regulations as they apply to CQE by removing the vessel use cap and some of the residency requirements.

We've been able to get fishermen fishing that resource again. Sorry, my computer decided to take a break.

This year, it doesn't show up in your data, but for the first time in many years, we had interest interested in getting the halibut out of the water out there. And so far, we've removed just under 100,000 pounds of halibut. Unfortunately, we still have to send it to Unalaska—no offense to Unalaska—but at least we're generating revenue and getting that fish out of the water again. I'd like to speak about 3 issues. The first is the ability of CQEs to assign and manage quota in season.

Uh, this is critical to us, and the reason is fairly easy to understand. Our season out there is only about 2 months, and what we find is harvesters come out there when they finished in harvesting in other areas. They do us last, and they want to get out of there by the end of September because of weather. If you look at the Gulf, they have 9 or 10 months to do what we need to do in 2 months. So whenever we need to move quota around, it's a laborious, time-consuming process for us, and it has resulted several times in stranded fish when the paperwork simply doesn't get done in time.

I used to be a business manager for a CDQ group. We'd like to see something similar where we can manage the, uh, quota ourselves in season. File the report with the agency at the end of the season. If we did something bad, slap our hands, but let us manage things like an adult and in a way that actually allows us to operate out there efficiently. The second item I wanted to talk about is the 50,000-pound sablefish vessel use cap.

Uh, your recent action to remove that from Pacific halibut immediately brought interest in, uh, people participating in that fishery again, and we're asking you to do that for sablefish as well. I recently negotiated an agreement with a harvester to harvest our sablefish out there. He already has quite a bit himself. We were incremental fish, very profitable for him, but because of that 50,000-pound cap, he simply couldn't make it pencil. We need vessels to be able to access more of that fish and make it economic for them to operate in our area.

Our area is just simply too remote and too expensive for them otherwise. And we've seen that it works with halibut. Let's do it again.

Uh, in conclusion, I just want to say we support removing the 50,000-pound sablefish cap to be consistent with halibut. We would like the ability to manage our own quota in season, and other than that, we'll leave you alone. Thank you very much.

Thanks, Steve. Question from Lauren. Steve, thanks for coming to speak to us today. Something came up in the conversation at the APE around the interplay between the vessel cap and the individual cap. So you're just asking for the vessel cap, but the individual cap is at the same limit, and would still exist, or how would that interplay?

Yeah, through the chair, Ms. Howard, the individual cap is not an issue for us out there. We are, as Mr. Fields pointed out, somewhat different than the rest of the CQEs. That's not our issue. Our issue is the vessel use cap out there. The individual cap is already a thing of the past for us.

It's the vessel use cap that's the problem.

Thank you. Thanks, Steve. Oh, sorry, Bernie. Steve, again, through the chair. Thank you.

I think that every place is different, and you have obviously got some challenges there that— and I think the use Cap is, or vessel cap is one of them, but the other one is how are you going to get processing? I mean, to really start, you know, with a fishery and get some guys out there that are going to be there day after day, not just a one-trip type deal, you're going to have to have processing. And I know that that's difficult. But what are some of the things that, besides this vessel cap, that you're going to need long-term to turn— to make this viable? Yes, Bernie, thank you for the question through the chair.

I'll try to keep this as brief as possible. So we had a viable processor up until certain other stakeholders sued to overturn Amendment 113. Which guaranteed ADAC 5,000 metric tons of Pacific cod as the foundation of the processing activity out there.

The processor then failed with less than a year. The council heard a lot about it at the time. Since that time, myself and a couple other board members and one consultant, we've been actively pursuing a new processor. I will say The current plant is no longer usable. The owner has not maintained it.

The roofs and the roof and the walls are starting to come down on top of all that processing equipment, which they also haven't salvaged. So we're looking at having to put up new capacity, which is not always a bad thing because new technology might reduce the, the amount of labor you need out there. We've been engaged now with with, let's say, more than one processor in discussions and pro forma analysis and resource projections and market analysis now for about 2 years, myself and one other person.

The good news has been the recent increases in the price of Pacific cod globally. There's significant interest because we're leaving A lot of cod in the water, 10 million pounds or more a year right now are being stranded because of the lack of a processor. So the interest is there. The economics are getting better. Recently, we applied for tidelands to build a new dock to support the fleet.

You're pretty familiar, Bernie. Pier 5 and Pier 3 are beyond their useful life, built by the Navy. World War II and it shows. So we're doing everything we can and the lift in COD prices is really helpful and we do have processors engaged. But when you get down to doing pro forma work and you see things like this where you— we have just under a million pounds, ACDC, we have just under a million pounds of black cod IFQ.

It's staying in the water right now. We can't get it out of the water. So we need relief like this so that we can get the fish, because then the fish can go in the plant and then the economics start working again. But we're starting over again, just starting over. Thank you.

Bernie kind of asked half of my question, and I appreciate that. It really helps to understand what's going on in ADAC. And I guess on the same note, that's kind of like the processing side, but what's the long-term vision for the CQE? There's been a lot of changes and asks, and recognizing it's a very different program, though it's still coupled under the same, you know, program. In a lot of ways, it'd be nice if they had a separate program.

But long-term, I mean, is it still a vision to grow a fleet, or is it more just a vision to continue to attract vessels to come to fish the quota? Thank you, Ms. Howard. Through the chair, no, we prior to the collapse of Golden Harvest, we were starting to get a pretty decent resident fleet and that's still our goal. And it's ACDC, we have programs where we'll help them acquire quota. We'll, you know, we'll do all sorts of things like the CDQ program does.

This isn't unique. We've created as many incentives as we can, but if fish doesn't get to the dock and there isn't a plant to receive it, none of the incentives work. So we're— like I said, we're starting at ground zero. What do we do to get the fish to the dock? And which dock is it, by the way?

But thank you for the question.

Okay, thanks, Steve. Thank you. Linda Bacon.

Thank you. Mr. Chairman, members of the EAP, Linda Benkem, actually testing for— testifying for Alaska Sustainable Fisheries Trust. I'm on the board of the trust. The mission of the trust is to strengthen fishing communities and marine resources through research, education, and economic opportunity.

We are— our trust has worked with Sea Alaska and Tlingit Haida Central Council and Spruce Root to set up a regional community quota entity in Southeast Alaska, so called the Southeast Village Fisheries Collective. And that collective, with both grant money and with some debt, have purchased quota for 3 communities. We have 2 communities that have fished that quota this summer and a third one that'll come online next year when they're, when they're ready. Um, but along the way, we have encountered a surprising number of obstacles to helping people in small rural communities get back into the fishing game. I think Duncan spoke to how much of this access to fisheries has left rural communities, particularly our Indigenous communities, and that even though the CQE program has been in place since 2003, very few communities have been able to make it work.

A lot of that is the administrative challenges, some of it is the sort of bureaucracy of it, and then also the high cost of quota. So, our response after all these years was to gather the right partners and build out a CQE at the regional level so we can help with the umbrella organization to manage a lot of those capacity challenges challenges and also do the fundraising more broadly. But running into these obstacles, some are unique to the CQE, some are common with small operators in rural areas fishing IFQ. We really appreciate the work staff has done so far to bring forward this discussion paper and identify what these challenges are, and we ask you to keep this work moving forward, it will make a really tremendous difference for helping people in these communities get back into these halibut fisheries. And really, some of these communities are losing communities because of having lost access to fisheries.

So important to their economics, important to their culture, and important to maintaining communities in these rural places. Just to speak to some of the elements that are particularly important to us, changing the management of quota for the CQE to be similar to the hired master or A-shares will make a tremendous difference. As others have said, right now the process of moving quota from one resident to another can be very time-consuming. And at late in the year, if we have someone who can't fish, boat breaks down, or a health issue, those weather windows are really important for them to be able to take care of their fishing in small boats. So we don't want to miss any time.

So being able to move it quickly to another resident of a CQE community through the— similar to what we do right now with A-Shares and the hired master provision would make a big difference there. It also takes care of two other issues, we think, that are in front of you right now. One is the requirement for a TEC, which has been really challenging for people in these communities to have the history to acquire. And the other, we think, is the age limit. So we did have someone in Yakutat who was 16 that wanted to fish the CQE we'd acquired for that community.

And that person was not granted a TEC and couldn't fish it this year because they were underage with NIMP's new 18-year limit. We think that needs to be looked at both for the CQE and IFQ. I know my boys both bought quota before they were 18 and used it to pay for college. So would like you to look at that broadly for both of them. IFQ and CQE fisheries.

On the ownership limit, right now NMFS's interpretation is that the CQE ownership limit is the same for a regional CQE as for individual CQEs. And our goal for Southeast is to provide opportunity as broadly to the 32 communities across Southeast that want to join and where we can help fundraise to be limited to the cap for a single CQE really limits our ability to help those communities. So we'd ask that you keep that one moving forward as a high priority. Um, and then finally, with the issue around prior notice of landing and the areas where people can land in, in these communities in Southeast, a lot of them, most of them, don't have processing capacity anymore. The people in these communities want to fish on small boats.

They're not looking to fish up onto larger boats. They want to fish it themselves, but it's not easy for them to get from the community they're fishing in to a processor in a small, often open skiff. So they want the ability to be able to offload their catch onto a tender that might be passing near the community. To do that, we have to expand the opportunity for them to offload onto tenders in places that are not currently designated as unload sites. Because our tenders now are all carrying Starlink, they can tie right into the NIMPS system to report an IFQ landing.

It would red flag immediately if anything was not right about that landing. So we don't see that as creating any kind of a problem for enforcement.

Also, with the prior notice of landing, I think staff spoke to this really well. People in these small boats in these rural areas are often operating outside of self-service. It's really difficult to call in and report with 3-hour notice, but often they're offloading and trying to get right, right back to fishing. So being able to turn that around quickly is really important to their ability to take care of good— take advantage of good weather windows. I see I'm out of time.

Sorry, I'll wrap up there, but happy to answer questions. Thanks, Linda. Question from Heather.

Thanks, Mr. Chairman. Thanks, Linda, for the testimony.

It seems like— if this is an unfair question, just tell me, but I'm trying to understand if the 3 testimonies we've heard are really all on the same page with maybe some different priorities depending on who provided the testimony, but in general, are most folks supportive of what's being proposed in the package? Is that a fair question? Thank you. Through the Chair, I think that's a fair question. I think everybody has supported this package, amendment package moving forward.

I think for all of us, the hired master provision is important, and looking at the caps on CQO ownership are really high priority. And then different people have spoken to different priorities beyond that. But everybody— I haven't heard anybody who opposes these changes. Thank you. Bernie?

Through the chair, Linda, quick question. What do you think is a fair age to start people out within Alaska communities with IFQ? Yeah, through the chair, Bernie. So right now in Alaska, someone— a young person can hold a set net permit at age 11. So we've asked that you look at 11, 14, 18.

And I would just add to that that, I mean, you all have experienced places where you have a minor who's going in for a— whether it's a medical procedure or some other opportunity, and the guardian or the parent needs to sign that line right below their signature as that guardian or parent. And our suggestion would be that if the concern from from enforcement is, who do I hold accountable if there's an IFQ violation, that we then just have for anybody under 18 an extra signature line that a guardian or parent signs to say, I'll take responsibility if there's a problem here, I'll make sure their IFQ fees are paid, I'm, you know, I'm taking that on for them. Thanks for the question. Thank you.

Thanks, Linda. That concludes public testimony. I'm sorry, McToyack, did you have a question for Linda? We can call her back up. It's okay.

Um, yes, I did.

Go ahead. Um, through the chair, thank you, Linda, for your testimony. Um, kind of piggybacking on what Bernie had asked, and it maybe it goes into other legal areas, but when it comes to the age, especially a, a person under 18 who decides to emancipate themselves from their legal situation, but they are, you know, in this position where they are their own signers. Do you think that with these changes, maybe the suggested changes, that that's also an area to consider?

Not profiling any cultural background, but there's a high precedence of Tribal members that are in the foster care system where they may become their own individual before the age of 18 and interested in the fishery sector.

Through the chair, that's a great issue to raise and not one I had thought about, but I would say we are supportive of lowering the age limits. I mean, there, there haven't been age limits in the past on acquiring a TEC and buying IFQ, or in this case also participating in CQE. We don't know that any signature by a guardian or parent— I mean, we're not saying that's needed, we're just saying if it's the only way we can get there and have enforcement and NOAA okay with this change, then we would support that. But that we can also think about ways to address the issue that you're raising.

Thanks for coming back up, Linda. Let's come back at 2 o'clock so we can make sure we've considered public testimony and are ready to go.

Okay. My vice chair has reminded me that it is 2 o'clock, so we will come back on record. She is a real stickler for time. So we will see I'll see if there's any motions after hearing public testimony and staff reports. Yes, thank you.

And it is posted. I'll give a second for it to come up. Bear with me, it's slightly long, rationale slightly long, but I'm hoping to comprehensively explain.

Okay.

The AP recommends the Council adopt a purpose and need and the following suite of alternatives for initial review. The purpose and need could include these recommendations: commercial fisheries have long served as the cultural, social, and economic foundation for coastal Alaska communities, providing jobs and income, food security, and multigenerational knowledge and culture transfer. While the CQE program was designed to create greater access for GOA communities over the past two decades, the high cost of halibut IFQ and administrative The administrative burden of starting and managing a CQE has limited its success. The CQE program intended to maintain commercial fishing opportunities in rural coastal Alaskan communities, to revive economic opportunity and rebuild infrastructure essential to the harvesting, processing, and marketing of seafood, the local employment and economy, and the generations of connections to the sea and the long-term viability of the community itself. And these actions intend to help enhance Access to the halibut and sablefish resource by residents of fishery-dependent communities.

Alternative 1: No action. Alternative 2: Modify the following provisions of the IFQ and CQE programs. Element 1: Allow time tendering in any U.S. federal or state commercial fishery to count towards the 150-day eligibility requirement to receive IFQ or quota share by transfer. Element 2: Replace the existing A, amend the existing NIMS interim policy with a regulation to establish a minimum age to be eligible to receive IFQ or quota share by transfer. The options are 11, 14, and 16 for analysis.

Element 3, allow a CQE to assign and manage quota in-season through the use of the Hired Master System. A, waive minimum eligibility requirements for eligible fishermen fishing CQE quotas. Similar to the regulations for hired master, and B, allow quota share or IFQ transfers to persons under 18 years of age.

Element 4, increase the amount of quota an individual GOA CQE can hold. No change to the overall cap for the entire program, 21% of the total halibut quota share and 21% of the total sablefish quota share in each IFQ regulatory area in which CQEs eligible to hold quota share. Area 2C, and this is per community, 1%, which is status quo, 1.5%, and 2%.

And Area 2C, 3A, and 3B combined, also per community, 0.5% status quo, 1%, and 2%. Recommended changes to the CQE regulations to to allow a regional CQE to hold up to the community-level cap for each individual community it represents.

Element 5, waive the prior notice of landing requirement and restricted unload hours for small IFQ deliveries. Analysis should include consideration of Element 6 and the ability of tenders to receive IFQ delivery at an amount sufficient to service a remote CQE community without a current operational processor. The options for analysis are 1,000 pounds, 1,500 pounds, and 2,000 pounds.

Element 6, expand IFQ unloading areas by adding all GOES CQE communities listed in Table 21 to Part 679 in 50 CFR. B, provisions to tie Elements 5 and 6 together. And C, allowing IFQ to be received by a tender vessel for delivery to a buying station or registered buyer in a port. And none of these elements are mutually exclusive and may be selected in combination.

That's all. Yeah. Second. Sorry. Catch my breath.

Okay.

Over the last 4 years, I have been developing and now managing a regional CQE in Southeast Alaska. I have become extremely familiar with the program, the regulations, as well as the time spent talking with other operational CQEs and agency staff, both in our planning and implementation of the regional CQE. These proposed changes largely address concern from the CQE communities, as well as IFQ holders, and this is also demonstrated in public comments. I will do my best to succinctly provide rationale for each element, but I encourage everyone to ask clarifying questions if there are any at the end. So speaking to Element 1, which is allowing timed tendering, this model— this is modeled after changes made to the crab rationalization program and will allow more opportunities for deckhands to accrue days towards their TEC requirements.

Tendering is an entry-level position into commercial fishing industry, and many crew go on to also work on harvesting vessels. Work on a tender is similar to harvesting vessels in deck skills as well as exposure to commercial fishing. So this would help broaden access to a CTC without eroding the initial premise to make IFQ available to crew members from fishing vessels.

Element 2 analyzed the following options to replace the existing interim policy with a regulation to establish establish a minimum age. As Linda noted, we did have an applicant to the CQE who was 16, who was very disappointed when he was told he couldn't get a TEC by RAM, especially because his sisters had received them, one at 14 and one at 16. They all grew up fishing together in Yakutat. Across Alaska, especially in rural coastal communities, fishing families raise their kids on their commercial fishing boats, and they start crewing with their parents, and some even go on to own quota at early ages.

Limited entry permits right now allow for the age of 11, which is why I chose that as a lower limit. 11 Is for set net permits, and then 16 is the regular age limit for most CVC permits. So those are the two bounds. 14 Was in between. It's a normal working age you see for a lot of children.

They would still be required to have the 150 days of experience and note that in TEC application, but it would allow them to receive a TEC at an age below 18.

Element 3, analyze options for CQE to assign a managed quota. We heard a lot from public testimony as well as in comments about the administrative burdens of managing the CQE. I could speak to that extensively from my personal experience in doing all the paperwork for it this year, and also at the same time running a quota bank that we have with the organization I work for that is able to use the Hired Master system. In the Hired Master system, you can select who fishes the quota. Once they're entered in the system, you can watch the landings.

You can track it. You can see what's happening in real time. With the CQE quota, you transfer it and it leaves your eFish. It goes to the other person's eFish and you have no idea their status of fishing. So for a program that was meant to have a high level of administration, it seemed like it was a very large oversight to not allow the person administering the CQE to see the— where the quota's at, what's going on, how things are progressing throughout the season.

So this one's a big ask from all parties. It's something we heard about prior to developing the regional CQE, and then again something I experienced in real time this year. So we appreciate the ideas brought forward to look at it like a hired master system and believe that all the bones are in place to potentially create that. We'd rather not wait for the IFA system to be developed, given that it seems like it's quite a ways out in terms of development, especially given the capacity— the staff capacity at RAM at this time. But as they're developing the IFA system, we would be able to build this into it through the opportunity that Alicia noted with public comment and public input.

Also, this could greatly decrease the administrative burden on both RAM and just the agency in general for the amount of transfers that they would have to process in season. Once a person who is eligible to fish the quota is in the system, then the administrator would be able to just designate them year after year. And often in these small communities, you're going to have similarly The similar people are almost the same people fishing year over year.

Element 4, options to increase the amount of quota a CQE can hold.

Regardless of any increases, all CQE total pounds would be held to the caps that are in place at the 21%. There's never been an ask for that to change. What I'm asking here in this is to look at status quo, and then for 2C, it would be 1.5% and 2%. And just to put some numbers on that, this year status quo would have been 28,100 pounds.

Next, or 1.5% would be 42,000 and 2% would be 56,000. So the way it's currently looked at for CQE caps, they have Area 2C alone And then they do the Area 2C, 3A, and 3B combined. That's why I broke it out here. That's how it currently exists in regulation. So same looking at 2C, 3A, 3B combined.

Status quo is the first option, and then 1% and 2%.

Also, we highly recommend clarifications and changes to the current regulations to allow the regional CQE to hold the same amount of quota for each individual CQE that it represents. The system was intended to be like that, but after going back and forth with agency, other council members, council staff for quite a long time prior to developing the CQE, it was determined that the regional model is still held to that single community limit. So that will be really restraining. Especially as we continue to grow the amount of communities that we're representing in Southeast. So looking to clarify the regional regulations on that to make sure that it's for each individual community.

The quota, when you purchase it for the CQE, regardless of the regional holding, is designated to the community.

Element 5, analyze the following options to waive the prior notice of landing requirement and restrict unload hours for small CQE and IFQ deliveries.

There was some concern around the 2,000-pound limit and what that could look like, so I wanted to try to open that up to further options. As we heard, there's a lot of small boat fishermen who target small amounts, small amounts of IFQ on shoulder seasons in short weather windows. They're often very restricted in their ability to go out in unfavorable weather. So the PNOL can often be a barrier for them to get into town at, at a reasonable hour, unload, and leave again, especially when it requires a 3-hour notice. So there's concern that this analysis noted the deliveries make up 46 to 50% of the total deliveries, but it's important to note that it's only 6.8 to 11% of the total halibut IFQ.

We would encourage further analysis to include a cost analysis of monitoring this level of catch. There was a potential that a disproportionate amount of money is being spent for a modest return in data. And this also doesn't mean necessarily that 46 to 50% of these landings would go unmonitored. The majority of them are being done in ports that have enforcement offices located within minutes of the dock. So there could still be a mechanism for notifying enforcement of a landing in progress that would give opportunity for the enforcement to show up.

The PNOL was originally intended to allow enforcement the opportunity to access remote ports or unmanned ports. So we would also encourage further analysis to demonstrate how many of these landings are occurring in these remote ports versus the ports with enforcement offices.

And it's also important to note that Element 5 and 6 really should be analyzed together and how they work in conjunction because, as I'll go into with Element 6, without being able to waive a PNO, Element 6 wouldn't necessarily work. Okay, last section. Element 6, consider the expansion of the designated unloading areas for tenders receiving IFQ or CQE halibut.

The list of designated unloading areas at this time doesn't even include all of the GOAS-CQE communities. So at minimum, we'd like to see the opportunity for GOAS-CQE communities to be on that list in the event that you could have a tender come to that community, tie up at the dock, and be able to take fish. It's important, again, like I said, to look at elements 5 and 6 together.

And just to go back to some of these CQE communities, a lot of them are historic fishing ports. A lot of them used to have processors. They had a lot of fisheries. A lot of that declined, you know, with IFQ, with catch shares, with limited entry. And the premise of a lot of these programs, especially CQE, is to try to bring that back and rebuild that.

There's a lot of interest, just like in ADAC, in rebuilding processing capacity, whether it's a microprocessor processor or a small processor. But in the meantime, if we can get people fishing and utilize tenders that are often running directly past these communities on a regular basis all throughout the summer, this would be a really critical way for these communities to be able to fish this quota.

The restriction for a registered buyer permit on board the tender is also concerning because it's quite a complicated permitting process. I don't know how much control this body could have over it, but it's worth considering what goes into having that and if there were ways to try to waive that for the tender or to be able to extend the tender's use of a registered buyer's permit that's held by the processor that they are operating within.

I think I will leave it at that and open it up for questions. Um, definitely would encourage anything clarifying questions. Thank you. Thanks, Lauren. That's a big lift.

I appreciate you making the motion. We'll see if there's any questions first.

Chelsea.

Thanks to the chair. Thanks, Lauren, for the motion. This is a big undertaking, so I appreciate you doing this. I was just wondering if this, um, includes specific includes sort of an overview or all elements that we heard in public testimony specific to like ADAC and then Uzinky, and if not, if you could just expand on your rationale why. Thank you for the question.

Um, I touched on everything in this proposal except for the issues regarding ADAC. At this time, I didn't personally feel comfortable continuing to work through that. I very much acknowledge and would like to kind of open that conversation up more broadly about the differences between the ADAC CQE model and the GOA CQE. And I think that's the most important part of that conversation is that ADAC has very, you know, geographically is very different than what you have in Southeast. We have community or even in Old Harbor, Harbour, Uziniki, you know, Kodiak, you have access to adjacent communities that you can work with to make up for the limitations that your own community is facing.

And we're doing that in Southeast to the best of our ability. Like on Prince of Wales, for example, we have a community that doesn't have a processor, doesn't have a lot of anything really, um, has a dock luckily, but you know, they're able to at least access Ketchikan or Craig or other areas. So I first want to recognize the uniqueness of ADAC, but, um, there's a lot of other complications that arise with ADAC regardless of the vessel cap, like including the sunset on their requirement for residents to fish that's going to come up here in 2028. So we keep turning the dial and not a lot has been able to provide the relief that they're looking for. And I'm not saying that that couldn't happen, I just at this time I feel that this action was necessarily going to continue to help that, especially in light of that sunsetting provision for a residency requirement.

Other questions?

Sure, Chelsea. Thanks. Through the chair, just one more follow-up question. I just— just to be clear though, You didn't want to put it in motion, but you're not necessarily saying should the council want to do something. Obviously they always have control to do what they want, but we're not really directing that it shouldn't be handled.

We— you just weren't sure how to handle it in this. Yeah, absolutely. I'm, I'm, I'm not completely against it. I just didn't feel comfortable like completely speaking to it. And I do appreciate that Steve came because there wasn't a public comment initially on this.

So that did help very much with the understanding. Understanding and with a lot of like the rationale between the differences, um, between the two communities. I just personally didn't feel comfortable putting that in at this time, and I understand that there is, um, probably action to be taken on the council.

Any amendments on Lauren's motion?

Okay, move on to comments.

Bernie? I'm going to support this, Loren, but I, but I, I mean, I'm concerned that things move, and is the council process really the place where we're going to be able to come back as things change and And I mean, I know ADAC's come back several times, but I see that, you know, in Uzenki, I see it in Old Harbor, I see it even in Southeast. Things are going to change. And can we, can we do that every 3 to 5 years through the council process and take up the time, the staff time, everything that's needed to do that.

Thanks, Barney. I'm going to have you turn off your mic.

Nelson. Yeah, thanks. Through the chair, thank you, Lauren, for the effort that it took to make sense of this action, try and tackle each of these individually that you have.

I just want to say that I appreciate the not touching of the total Q's cap. I mean, I've made that pretty clear, like, my concerns around this being a low abundance issue that's driving a lot of our halibut issues at this time, and that the cap stayed directed towards community holdership. I appreciate the work here and will support the motion.

Other comments? Heather?

Thanks, Mr. Chairman. Thanks, Lauren, for a really comprehensive motion. My question to the last testifier around whether this was broadly supported seemed to be, I think, the issue around ADAC can be spoken to over at the council and incorporated. So I just want to thank you for putting all the work into it, and I'll support it.

Yeah, no, thank you for the support on this. And like I said, from a personal experience this last year of of our first year in operation and managing the CQE, it was pretty incredible to get 15 people out fishing that hadn't had that much opportunity. You know, 5 of them, it was their first time getting a TEC. A couple of them were 19 and— you know, 2 guys were 19 and 20. You know, they were deckhands on a boat for a long time, so for them to have their own quota in their own hands was a big deal.

So to see this program work and recognize some of the barriers in in real time that we had, you know, heard of prior to the establishment, and then now having the opportunity to try to work through it. I don't think a lot of these are big substantial changes, like leaving in place the overall cap, for example, and modifying below that and things in there that can actually turn the dial a lot and really make a lot of opportunity for this program to be successful. So I'm hopeful that we're able to move this forward in some capacity. As a package, and I look forward to working on this. Thanks.

I'll offer some comments in support. First, congratulations on your work in Southeast. I think it's— when I started in the process, the CQEs down there were not organized and as well-funded and successful as the ones in Kodiak. And so I know a lot of hard work has gone into that, and it's nice It's nice to see some success build and have these programs be more utilized, and I think what we're doing here is taking that, you know, step further by making it easier for them to access this program. I think it's really critical that we maintain access for watershed residents and that the value from the fisheries continues.

Continues to be seen and recognized by everyone in Alaska. And as the entire industry has shrunk and consolidated due to largely outside forces, you know, if anyone's ever looked at the salmon canneries in Alaska map from the '50s, not one of those companies is still around. You know, you can go to Murder Cove and see some of the pilings and stuff, but it's dramatically changed our role, I think, in the state, and I think we took it for granted for a long time, our value. So I think this is one very small way to, to do that, but it's really important. And even in communities like Sandpoint, when people retire, it's hard to find people that will take those boats out, and you can't have a processor unless you have people that want to fish.

So I think this is a good partial step there. And appreciate it. So with that, see if there's any objection.

Okay. That motion passes. Are there any other motions on here?

Okay. Let's come back at 2:40 and we'll take staff tasking. See if anybody wishes to testify. It's a very brief, um, staff presentation, if, if really anything, and then we'll move right into public testimony. So please do so during the break, and then we'll see if there's any motions, and we should finish today.

All right, we will be starting our staff presentation on staff tasking, and I would just like to remind members of the public that the staff presentation for staff tasking is going to be very short, so if you would like to testify, please take a minute to sign up. So thank you.

Thank you, Madam Chair, members of the AP, Anna Henry Council staff here to present. I'm just going to walk through the action memo, uh, that's posted for staff tasking. I don't have a presentation because it's pretty brief here. Um, so the first thing up is that we have posted on our e-agenda a call for nominations for 2027 AAP members. Um, that nomination portal will be open through October 31st.

And then the council will discuss appointments at the December meeting.

We also have a list here of future advisory groups. The first one on here is probably of note to folks. The council's Joint Protocol Committee will meet on October 16th. So that's the Friday after the council meeting ends. It'll be here in Anchorage at the Marriott Hotel.

So the Joint Protocol Committee is convening at the at the request of the Board of Fisheries in order to provide for information exchange and education about the impacts of bottom contact from trawl fisheries, the Council's current management requirements, and measures under consideration. This information is intended to inform any future consideration of proposals that may come before the Board of Fisheries, but the Joint Protocol Committee does not generate proposals. They do not take any action on proposals. Proposals that have been under consideration by the Board of Fisheries or the Council. And we do have an e-agenda site for the Joint Protocol Committee, and meeting materials will be available and posted to that.

And just to note that we will be broadcasting the meeting online, but participation and public testimony will only be in person.

So some of the other upcoming advisory group meetings The Charter Halibut Management Committee will be meeting October 21st. The Bering Sea Aleutian Islands Crab Plan Team will be meeting November 5th, although as you'll see just below that table, the crab and scallop plan team are merging, so we're gonna have to get used to calling them something new, likely the crab and scallop plan team.

But we will provide updates on that membership and other logistical details about that merger. We also have the Joint and Bering Sea and GOA Groundfish Planning meetings and then another charter halibut management committee meeting that hasn't yet been scheduled for December.

As of 2025, all committees have terms of reference that have been adopted. And staff have recently— are working on completing a comprehensive review of those terms of reference.

So as any items that are noticed to revisit for consistency or specificity amongst those TORs, as those are identified by staff, any potential updates to those terms of reference will be reviewed by individual committees. Followed by Council review and final approval. And I believe the Council will be reviewing some updated terms of reference for the Executive Finance Committee during their executive session at this meeting.

The Ecosystem Committee met earlier this week, but just for your awareness, the Council— and you all won't receive the committee report from that meeting until the December meeting in conjunction with the Groundfish Management Priorities agenda item.

So that moves us to tasking and scheduling. And so the upcoming council meetings, the next 3 council meetings are all scheduled to be in person. The December meeting, which actually will start November 30th, that will be here at the Egan Center in Anchorage. Our February/March meeting that starts February 22nd and March 2nd. That will be in Anchorage, but it will be at the Marriott Hotel.

And then our May 2027 meeting, that's May 17th to the 25th, that will be at the Renaissance Hotel in Seattle.

And just to note that the December meeting, the schedule will be a little bit weird because the SSC will be meeting for 4 days, so the council will not start until Friday. So we will have the API start again on Wednesday, like you did at this meeting.

And then just an update on Cook-Inlet Salmon scheduling. Due to the delayed timing of our February meeting, we have added an agenda item for the council only in December to do a proposed specifications process for Cook-Inlet Salmon. So that'll kind of follow the similar process that we use for groundfish harvest specifications. Specifications. The council will recommend those proposed salmon specifications in December and then do the full review of the SAFE, and the SSC will do their review and everything at the February meeting.

And then we do have a brief update on progress of the GOA Tanner crab initial review. The short story is that everything is on schedule for that to be coming back in February as planned.

And then just for everyone's notice, for our February 2027 schedule, how we have it on the 3-meeting outlook right now, that it's overscheduled for the SSC. So we'll have to adjust that based on the council's prioritization discussion so that All the items that we have listed in February are— it's too much for the SSC in February, so those will be shifting, and we should be able to finalize that after the council has their prioritization discussion, which I went over a little bit during the administrative issues. So the council just is hearing a lot of information about that during their B reports now, and then they'll revisit visit that at staff tasking. And that's the end of my presentation. Thanks, Anna.

Question? Chelsea. Thanks through the chair. Thanks, Anna, for the report. I was just wondering if shellfish plant team would be a good solution so we don't have to say crab and scallop plant team.

I don't know. Or could we do a public naming contest? We could get Boaty McBoatface. Yeah, exactly.

The name is still TBD, but the crab plan team did recommend crab and scallop planting. So we'll probably finalize that after the council speaks to it at this meeting.

But thanks for the input. Any other questions for Anna before we move into public testimony? If anybody is still waiting to sign up, please do so in the next few seconds.

Okay. It looks like we have 4 people signed up. We'll take Michelle Fournier remotely first and then James Kearns, also remote.

We can circle back to Michelle. Is James on?

If not, we'll go to Linda, who I see in the room. I'm here. OK, great, James. We can. Thank you.

OK, good. Thank you so much. Thanks for offering this opportunity. My name is James Kearns from Gustavus, charter boat captain, commercial fisherman. Anyway, most of you have heard of me before, but I missed being able to comment during the charter halibut.

Section there, so I wanted to just give you some ideas on some things you might want to pass on or be thinking about. I think we have some things to be able to fix this whole charter halibut thing that won't impact our commercial fisheries either. But, you know, we have three halibut fisheries: commercial, recreational, subsistence. And I'm suggesting that you think about revising the CSB. Let's not throw it out, let's just revise it so that all three of those entities have an allocation, and so that would mean that there'd be an allocation for recreational only, which would include all recreational halibut anglers, whether they're guided or unguided.

And then to make it work, you'd have to have a bag limit of a halibut of any size for all those recreational anglers, but only one, a bag limit of one fish, any size. And then we need to make sure that it's an abundance-based management. To include first and foremost with an annual limit, a recreational annual limit with a reporting process that gives a real picture of recreational halibut removals and gives us a lot of halibut data as well. And then other things that would manage us within the allocation would be season changes, which we've done, and recreational day closures, which we've done. And then As for the, the charter fleet, uh, non-transferable CHPs, there's just no reason for us to allow leasing of non-transferable charter permits.

I don't know exactly what the process for leasing a commercial quota is all about. I haven't looked into that enough to know, but I'm pretty sure you have to have somebody on board that that is the owner, or at least they have to be in the same business, in that business. But there's just no reason that we should release it, that we should lease the non-transferable permits. And if someone has one, and I have one, and if you're not using it, and you— if you or your business aren't using it, then it should be gone. There should be no use, no use of that non-transferable.

It should go out of the system. Um, the second thing on CHPs, non-registered CHPs, they shouldn't be allowed to be transferred, um, or, oh, what did I say? Oh, they should not be allowed if someone is not going to use it. If they don't use it for a certain number of times, then maybe it's time we put it back into the, into the pool for a reassignment. And, and then finally, GAF, guided angler fish.

If you have a 1 halibut of any size per person daily bag limit in an allocation that's for recreational anglers only, there's no need for that. And these changes, as you can probably see, these changes would remove the unguided loophole that we've talked about so much. And granted All of this is kind of a heavy lift, as Andy Mesro said, but it, it would really solve a lot of these issues and make it so much easier. And, um, for Alaska residents who have their own boats, yeah, there would be people— I saw all the comments last year— there would, there would be people who would say, hey, we got to have our 2 halibut a day. But at the same time, it would recognize those Alaska residents who can't afford their own boat and would like to charter.

And that would give them an equal opportunity. So, you know, everybody has to pitch in. Anyway, that's my proposal. I'd sure like you to think about it, and if you have any questions, I'd love to answer them. I will be talking to the council as well.

But anyway, thank you so much for letting me comment.

Thanks, Mr. Kearns. We appreciate you calling in. I will see if there's any questions for you.

I don't see any, but we appreciate you again calling in. Thanks. Thank you. Linda Banken and then Sarah Webster, and we can circle back to see if Michelle is online.

Thank you, Mr. Chairman. I will try to be brief. Linda Banken with Alaska Longline Fishermen's Association. We submitted a Request under staff tasking written testimony asking for the council to consider abundance-based management of halibut bycatch in the Gulf, or at least reviewing the appropriateness of existing caps. I wanted to speak just briefly to that.

As I think you all know, halibut— the halibut spawning biomass is at historic low levels right now. We are hopeful that there will be be a strong year class at some point. We want to make sure that we don't compromise that year class with high bycatch, um, as it's starting to grow its way into the commercial fisheries. So to protect the rebuilding potential of the stock, taking a look at the appropriateness of the existing cap makes good conservation sense. We focused our request on the trawl sector because historically the trawl sector has accounted for the majority of that bycatch.

And because having been through the EBM process in the Bering Sea, it took at least 6 years and we focused it in on just Amendment 81 fishery in those areas. So to avoid doing a lot of analysis, that may not end up being used, that's where we chose to focus. I see from some of the other comments and from the action of the Charter Committee urge to look more comprehensively at bycatch and the impacts of bycatch across all sectors. Certainly don't object to that if you feel like you have the staff time and capacity to take that broad a look at this bycatch issue. So just asking that the council— AP recommend for the council to take this up.

The bycatch caps were set in 2014. The stock was in a really different place then than it is now. And it really is important for all of us that we, we protect that rebuilding potential of the stock for the future. So that's all I have. Thanks.

Thanks, Linda. Any questions for Linda?

Thanks, Linda.

Okay.

Through the chair, Linda, thank you as always. Do you know why, with your tenured knowledge of this process, why it changed from floating PSC limit to a static one.

Through the chair, I don't know that it was ever a floating cap. I might be forgetting something that you've looked at that it was at some point, but yeah, just that they, you know, those caps were set, they were lowered a bit at one point, but Not a big change, and it's been a long time since we've gone back to it. So since 2014, the sort of focus shifted at that point to the Bering Sea, Aleutian Islands. But actually, when we started that process of looking at doing abundance-based management for halibut bycatch, we're looking at doing it Gulf, Bering Sea, you know, sort of across the whole area. And we just kept narrowing it down to where it felt like we could get our hands around it.

I guess, to move it forward. So the Gulf dropped off with the idea we'd come back to it at some point, and we just think it's appropriate since that's how the council manages all fisheries, is based on abundance. Thanks.

Thanks, Linda.

Sarah Webster.

Good afternoon, chairs and members of the AP. For the record, my name is Sarah Webster. I am the science advisor for the Alaska Seafood Cooperative. We represent the Amendment 80 fleet. I want to speak briefly to the Charter Halibut Management Committee motion.

To take a comprehensive look at halibut mortality in the Gulf, and also to the comments from the previous testifier about looking at Gulf ABM. Um, and, and in particular, as we think about staff tasking moving forward, I just wanted to provide a bit of context regarding our halibut limits and how they fit into the broader context of halibut mortality in the Gulf. We are subject to strict halibut limits that have the potential to shut our fisheries down. And as a result, we work really hard to avoid halibut and to minimize mortality in order to ensure that we can continue to operate. For those of you who are not familiar with trawl halibut limits, the Amendment 80 sector is allowed to take a portion of the total trawl halibut limit.

This is further apportioned between shallow and deep water targets, and then it is apportioned among 5 different seasons. Any halibut bycatch is accounted for in season, and if we hit the limit in any target season combination, it shuts the fishery down. This is not a limit that we're trying to utilize. This is one that we are actively trying to avoid. I also want to draw your attention to the pie chart that I attached to this testimony just to provide some context.

This chart is of halibut mortality by user group in 2022. 2025. And in 2025, trawl PSC was about 2.5% of the total mortality in the Gulf of Alaska, and catcher-processors were about half that. At the same time, the recreational sector, including both charter and unguided components of the sector, represented about 27% of mortality. And I would note that with respect to the unguided sector in particular, while that sector accounted for 13% of the halibut mortality last last year, there is no sector limit that constrains the catch, and there is no in-season tracking of that data, nor is there in-season tracking of the charter— of the charter sector.

The commercial fishery mortality represents about 66% of total halibut mortality in 2025, which includes a substantial amount of halibut discards. I do want to note here as well that the commercial discard data That I've included here are the data that are used and reported by NMFS in season management. The IPHC uses a really different estimation method for their commercial, commercial discard accounting purposes. My understanding is that that is really because the inconsistency between those datasets is really because of the lack of observer coverage for a substantial portion of the commercial fleet. And then subsistence fisheries research and fixed gear PSC represented other, other minor sources of mortality in 2025.

I also just want to speak briefly to the comments that you heard from the last testifier about the state of the halibut stock. It is true that it is at a low point relative to when the IFQ fishery was implemented in the late 1990s. It is is not at a point right now that is inconsistent with levels that we, that we estimate in our stock assessments from 50 or 100 years ago. And that the, the halibut spawning biomass decreased substantially in the late 1990s and into the 2000s, and, and since 2010 it actually has been fairly stable. And so the limits that were set in 2010 were actually at a pretty similar place relative to the long-term history of halibut from what we were seeing then.

So the Charter Halibut Management Committee suggested taking a comprehensive and sector-neutral look at halibut mortality in the Gulf. Considering the current constraints both in staff— in staffing and in resources that we're facing in this region, I do think it's important to understand the scope and scale the scale of halibut removals and whether a more targeted approach, if we do look at anything, might be a better way to go. Thanks. I'm happy to take questions. Thanks, Sarah.

Question from Lauren. Thanks for your testimony, Sarah, and thanks for this graph. I was looking for some clarity to understand if you could break down commercial and what is included in that, and then commercial— how commercial discard is different than commercial. I'm just trying to understand what I'm looking at in a little more detail.

Sure, thank you for the question, Miss Howard. The commercial includes all IFQ landings that were reported from the IPHC, so that's from 2C, 3A, 3B. The commercial discards are the total commercial discards that NOAA estimated And I will note that when I put this together, I did correct between net weight and round weight, which is a pretty confusing thing that people often have a challenge with when they're looking at halibut data.

Chance had his hand up first, I think, and then we'll go to Nels. Or you did not? It's a false alarm. Okay. Nels.

Sorry. Yeah, I was going to wait for after, but this spurred one of the questions that I had. From your answer that you gave to Lauren, I mean, that commercial and charter, those are both directed use. Unguided could also be seen as directed use because we don't parse out that, that assisted unguided from sport recreational whatsoever. So then your commercial discard subsistence is also a directed harvest take.

It's apportioned for by IPHC. Than that. So your commercial discard, your fixed gear PSE, and your trawl PSE, those would be more representative to compare with one another. And then your directed— I'm just— would you— I'm trying to understand kind of how we're comparing directed mortality and non-directed mortality, I guess, is my question. Kind of why you feel it appropriate to compare them all in one pie chart versus like two next to each other with with associated numbers.

Uh, sorry for the rambling, I'm trying to make sense of it in my mind, seeing if you can help. Yeah, through the chair, and thank you, Mr. Evans, for the question. I mean, I think there are many different ways that you can skin a cat, correct? And so you could like look at it that way as well. Typically, when we're thinking about mortality of any species, we're looking at mortality across all fishery users from all sources, regardless of whether they're directed or not directed.

And so that's what I have included here. And I think when you're, when you're thinking about places that you can change limits or change use, you need to consider that across all sources, not just specifically non-directed or potential discard sources. I did not include as well in here The Charter and unguided— the Charter and unguided, um, sources here do also have some discard mortality that are included in those numbers. In the past, the IPHC has at times split those numbers out. In the 2025 data, they did not split those numbers out, so I did not put that together here.

I do think it's available if you dig into the U.S. report to the IPHC, though.

Thank you for that, and thanks for taking that kind of jumbled question there. Just going to something separate that you talked about, comparing time series spawning stock biomass. The reason why there is so much concern, so much mention around 1970, but spawning stock biomass was somewhere— it was back in the '70s we saw the lowest spawning stock biomass kind of within the most recent 50-year time series, we have now returned to a spawning stock biomass regime that is similar to that. We have been on this declining trend for a while. And so back in 2014, when the past PSC— the current PSC action was put in place, we had a spawning stock biomass of roughly 220 million pounds.

Right now we're at about 166 million pounds. This is off the IPHC their new dashboard tool. It's pretty easy to access from the IPHC landing page. So that shows a 25% reduction in the spawning stock biomass over the— from 2014 to now. So you said that we haven't— we are relatively similar.

Like, is a 25% reduction a similar state or not? Through the chair, Mr. Evans, I, I think that I am not aware of that dashboard. That's good to know about. But, but I do remember within the curve of the IPHC spawning stock biomass, at about 2010 we actually hit an even lower point, and that is the point when we were starting to talk about changes to the PSC limits in the Gulf.

And so it went up a little bit until I think about 2016 from 2010, and then went down again. And so when we were having these conversations conversations the last time, I do think that maybe we were at a slightly higher point, but it probably was not as much as that 25% you're referencing, or 20%, whatever, whatever it is. Yeah.

Lauren, could you speak a little bit into like past use of the PSC? Because I think there's a general understanding that there's a lot of the fishery that's not being prosecuted from markets, which has driven a lot of the decline in PSC. So there's potential if those markets revive that there could be, you know, an increase back to some historic levels that were higher. Could you speak to that at all and what that looks like currently and projections of those markets returning or that fishery being stronger?

Through the chair, Ms. Howard, I don't think that I'm an appropriate person to speak to that because the Amendment 80 sector use has actually been fairly consistent over, over the last 10 years at least. I haven't looked further back, all the way back to 2008 when it was implemented, but I do think that our sector, because our limits are so low and we, we don't have the same issues that the shoreside sector has with, with markets and that kind of thing, we have pretty consistently used the same amount of PSC. So I'm probably not a good person to speak to that otherwise. Sorry.

Thanks, Sarah. Thank you. We have Michelle online.

Take her to close out public comment.

Hello, yes, I'm here. Can you hear me all right? Yes, Michelle, thanks. You have 6 minutes for public testimony. Just, I haven't seen your name before in case you're not familiar with our process.

Thank you. And is it possible for me to share my screen, or for you to pull the document up that I uploaded? Yes, we'll get that pulled up for you. Thanks. Great.

Thank you very much.

All right. Well, first of all, I'd like to thank you all very much for your attention and the ability to testify tonight. I'll also Add that I'm here on behalf of the Kayasik Walrus Commission and in collaboration with the Togiak Traditional Council, and also in collaboration with Togiak School, the Village of Togiak, and the Bristol Bay Native Association. So I think I can see that figure here, which is just fine. But I'm here as an acoustician, so I'm here as a listener, and I wanted to talk to you today about a research program that we have ongoing in Bristol Bay and in Togiak Bay in particular, and what we are hearing both from from the ocean itself and also from the communities that I serve.

So I am a researcher from the University of New Hampshire and have been doing work listening to marine mammal species and subsistence species in Alaska for the past almost 20 years. And in 2018, I attended an ISEAL committee meeting where a Yup'ik elder from the village of Togiak told a quite extraordinary story about children hunting moose. And this was surprising to me at first, as it was a committee meeting dedicated to the subsistence species of ice seals. At the end of that 30-minute narrative, he expressed that the reason that those, those students were hunting moose was because there were no seals. And we began a dedicated acoustics research project in Togiak to see whether or not that particular subsistence species had left the area or whether or not they were there and underneath changing environmental conditions, changing soundscape conditions, the sound of the underwater environment, whether or not the presence of that species had been decoupled from traditional ecological knowledge.

We were looking for bearded seals, but what we found has surprised us, and what the community has indicated is that listening is an extremely important science. And so I want you to know that we have been listening, and some of the things that we're hearing have been have been boats. So you can see in this map that's in the, um, in the document that I uploaded today that there is an area around Togiak Bay. We have all these little dots on the map. In 2024, we began putting hydrophones underwater to listen continuously for subsistence species.

By the end of 2024, when we began analyzing these data, we realized that yes, bearded seals were present, but they had in fact been decoupled from their traditional behaviors. It was particularly difficult to hear this important species because in the summertime months, there was an abundance of noise that coincided with an increase in fishing activity in the bay. In addition to that, what we found is that walrus, which are an important subsistence species, and also extremely culturally important to the village of Togiak and to the Yup'ik people in the Bristol Bay area, Walrus, which we know not quite as much about as we should, were detected year-round. And walrus use vocalizations in order to communicate with mates, in order to communicate with conspecifics. The habitat that they're using relies— is a shallow water habitat, and sound gets bunched up in it.

And so the underwater soundscape, what these walrus are hearing, is critically important to their survival. Now this is true for all marine mammal species in the area, but it is particularly true for walrus who produce low-frequency sounds that are masked by vessel noise. So if it's possible to scroll down in that document, there is a picture down at the bottom of it. Go a little bit further down, right there, that's a spectrogram. So a spectrogram is a picture of sound.

The brighter something is, the louder it is. This is an image that shows us what the soundscape, the underwater sound arena, sounds like from early May until late August. And you can see those very bright, bright turquoise periods in what we consider the low-frequency realm, and that is all associated with vessel noise that we believe to be associated with the processing, the processing and capture of fish and fisheries in this area. Now, we presented this work to the community along with the graph on top where you can see those dark blue bars indicate periods when we detected walrus. There's actually a year-round detection of walrus in Togiak.

We also found several other important pinnipede species, harbor seals, spotted seals, and bearded seals, all again critically important subsistence species. But what we found is that in summer months, these detections died off. And they didn't die off because of an absence of species. They died off because of our inability to hear them, because the area got too noisy to detect the acoustic signals that were biological in nature. When we presented this work to the Togiak Traditional Council, the Togiak School, and the Kayasek Walrus Commission, folks were concerned.

They were concerned with vessel noise having a negative impact on these species' ability to communicate. They were concerned about animal displacement in the area. They were concerned about habitat loss and changes in the area associated with fishing activities, and they asked if we would expand the study for a minimum of one more year. So we are currently listening in this area. We deployed hydrophones next to a walrus haulout on Hagemeister Island, um, in August of this year, and we plan to deploy, um, several other hydrophones in the spring, um, near Round Island.

So we currently have three instruments deployed with what we hope to be another two that are underway. And the community wanted to be very vocal, and as their ambassador, I'm also going to be vocal about the the fact that listening matters, and the sounds that are associated with fishing and the fisheries in this bay are a major point of contention and concern for the well-being of the ecology, the well-being of subsistence species, and thus the well-being of the communities that rely on this area for their livelihood and for their cultural preservation. So we will continue to quantify these trends. When are walrus present? When are other pinniped species present?

And what types of underwater noise are we hearing? And we'll quantify that to the best of our ability and present it back to the communities so that they can make decisions about what sort of relationship they want to have with the users of their bay.

Again, this work is ongoing, and I am happy to take any questions about it. Thanks, Michelle. That was perfectly timed. See if there's any questions for you. Thank you.

Eva?

Hi, thank you for your testimony. I appreciate it. I've heard about this issue a couple times now from different people in Tokiak, and they came and testified about the walrus. And so I was wondering, uh, when you guys are looking at this data, are you also at the time, um, you're seeing a decline in the number of walrus, and they mentioned that it also seemed like the walrus were maybe not feeding enough, that they had changed their patterns for feeding, and that they might have possibly a food scarcity issue. Is that— do I have that correct as like part of what led up to this study too?

Those are certainly observations that have been reported to me from the community and from members of the Qia'asik Walrus Commission, that those are areas we need to understand better. What we can tell from the acoustics, and again, this was sort of an incidental study that began in part because of the concerns of the community and also because of the prevalence of walrus in our dataset. So what we're seeing is that the seasonal patterns, the temporal patterns of walrus use in Togiak Bay are different than expected. It was previously supposed that they were only using this area partially. Now it seems like they do have a year-round presence there.

Hold on one second. Whether or not their patterns of foraging have changed, I can't tell yet. There are certainly sounds that are specifically attributed to different behavior states. Reproduction is the easiest one for us to track. Um, but once we can assign certain sounds to different behavior states, we can begin to answer that question.

But what we have done now is increase both the spatial and temporal coverage, because up until now, um, the primary research done on walrus in this area was done on Round Island, and it was seasonal. Um, we've been able to actually listen for walrus year-round and start to track changes in where they're going. What this also means is that we can get an understanding as to how walrus are overlapping spatially and temporally with fishing with fishing activity and what some of the impacts might be to them. So foraging specifically, I've certainly heard reported. We haven't been able to investigate that yet.

Thank you for that. That's really helpful. And I had one follow-up question. Is there like a decibel level that is harmful to the walrus, and is that known, or And is there any signs of hearing damage, or would their behavior just move them away from that noise so that there's a less risk of hearing damage?

Yeah, that's a great question. Yes, there is a decibel level that has been published by Southall et al. I believe it's 2020, which is believed to cause either a temporary threshold shift or permanent threshold shift in the hearing of walrus. We only just started recording in Togiak Bay. To my knowledge, no one has ever placed recorders in this area before, so we're only beginning to quantify what that is.

But the hopes are within the next few years, as we continue this work, that we're going to be able to quantify exactly what the reduction in, in hearing or listening space is, what the reduction in communication space is, and then we do have the information necessary to assess whether or not whether there are permanent threshold shifts or temporary threshold shifts occurring in this species. Certainly being near large vessels that are traveling for long periods of time, it's not just a matter of the decibel level, not just how loud, it's also how long. So when we measure the impact of anthropogenic noise on protected species, we use a metric called sound exposure level, which is an integration of the amount of cumulative sound pressure or energy that an animal experiences over a unit time. So if you took a tiny snippet of a boat passing over an animal, you might say, oh, not that loud. But if you integrate it over, and what it's in this case, and you can see in this figure, is days, weeks, or months, there's a very different amount of cumulative exposure that these animals are subjected to.

So these are things that we, we hope to continue looking at in the future, again driven by the concerns of these Communities. Thank you. Other questions? Monica?

Thanks, Mr. Chair. Um, thanks very much for your testimony. Um, this is super interesting research. I had a question about at the bottom of the second page of your attachment, it gives a sort of an acoustic profile of this level of sounds that you're hearing and between May of 2025 and then August of 2025 and, and correct me if I'm wrong, but it looks like sort of as you see the brighter yellow, um, lines that, that go up, those are indicating vessel noise and I'm trying to get a sense of how what kind of vessels those noises are coming from, or if you're able to tell that from the information and from the equipment that you have deployed.

The text of the document seems to indicate that it's vessel noise associated with commercial fishing, but I'm wondering how— if there's a way that you can tell that, or, and if there's additional analysis that you've done to figure out that that's what that— those lines are actually indicating, or if there's other kinds of vessels in the area that might be contributing or creating that noise. And thanks for helping me understand that. Of course, and that's also an excellent question. So there's a two-part answer to that. One, we can get information on the size of the vessel by the frequency of the sounds that it's making.

So similar to animals, little animals make high-frequency sound and big animals make low-frequency sound. The same is also true for boats. So for a skiff that somebody local, the Togiak, might take when they're going out hunting would sound a little bit like a whine, whereas a large processing ship or a large fishing vessel has an acoustic signature. But what we've also done is actually coupled this with AIS tracks. So that analysis is very preliminary, I want to be clear about that, but we've been able to go through and look at the AIS tracks at periods of our highest noise and see what vessels are within a certain diameter from our hydrophones.

And so in that sort of initial qualitative analysis, we were able to determine the vessels that were present during some of our highest noise periods are associated with commercial fishing. But having a general knowledge of the patterns of what's happening in this area, again, I'm new to that. We're still figuring these patterns out. So some ships will hold acoustic signatures, and certainly what we can get from the acoustics alone is size class. So you're correct in that those brighter parts indicate periods that are louder.

Um, we can also hear storms, or if there was a singing whale, for example, that would make it brighter as well. But the acoustic parameters are very different for biological sounds than they are for vessel sounds. So by doing things like measuring the harmonics, measuring the frequency, and then coupling that with, um, available public data on vessel use and seasonal openings, and then what the villagers are telling us about watching ships coming in, that was how we made the determination that these were largely associated with commercial fishing. But that is a preliminary finding. But we do have the data available to continue making sure that we're being really robust in those noise assignment categories.

We certainly don't wanna point fingers anyplace where there's no blame to be had. But that was the combination of effects which led us to think that these were associated with commercial fishing.

Second question. Thanks. Thank you. That was super helpful. I'd certainly like to have further conversation on this and would appreciate you, as it gets ready to share, sharing your sort of your information looking sort of the AIS track lines.

My understanding of the area is that there's also large vessels that transit through— tankers, tug and barge— and that the area specific to where the hydrophones are is an area that's, I think, mostly, if not all, closed to federal commercial fishing. So this is a super interesting topic to me, and Um, I really appreciate you providing this public testimony. And I'll make it a question, Mr. Chair. Uh, hopefully you'll have the opportunity to come back.

Uh, we'd love to hear from you again. Would that be possible?

Absolutely, absolutely. Um, I think one of the things that is particularly tricky about low-frequency noise is that it can travel for many, many, many miles. So it's correct that many of the areas where we have our hydrophones are closed. The Round Island Whaler Sanctuary, for example, we have a hydrophone right outside of the sanctuary, and we can certainly hear vessels even when there are no vessels within several miles. Low-frequency sound, in fact, if you play it at the right loudness and at the right depth, the ocean is in fact transparent to it.

It can travel for up to 10,000 miles under the right circumstances. We don't yet understand how sound travels through Togiak Bay. I would love to find some funding to pursue that. I think that would be a really meaningful way to help create a collaboration between communities and industry and minimizing the acoustic footprint on this area. And certainly this project is in its early phases.

We've been looking at other topics here, and when, when these issues came up, we agreed that we were going to continue to pursue them. I would welcome the chance to share the process, to share the data as it unfolds, and come back and talk again. Thanks, Michelle. We have a question from Laktoya.

Through the chair, thank you, Michelle, for your testimony and providing these images for us and explaining all the beautiful colors. The question that I have is, have you interacted with the Eskimo Walrus Commission your focus area is specific to the Togiak/Bristol Bay area, but then if you dabble into the Eskimo Walrus Commission, there's walrus that are around the Norton Sound/Bering Strait area and then north, further north. And then if you have communicated with them? Have you looked to more ways of seeking the indigenous knowledge in the walrus feeding areas that might be impacted by these fishing— or not fishing vessels, but these different vessels that are going around, I guess you can say?

Thank you for your question. We have not yet engaged with the Eskimo Walrus Commission, um, because the walrus that we're studying fall outside of their, of their general field of concern. But what we're seeing is similar trends and shifts in anthropogenic noise in the Arctic as well. So we do have hydrophones listening outside of Utqiagvik, which of course is which is an area where walrus are found as well. We're conducting similar analyses there, but on different species, working with bearded seals.

The idea of listening in areas like Norton Sound and elsewhere is very appealing, but we haven't yet pursued it. So I think that this is the first step in what will hopefully become a broader project. But I will also say that the reason that we are going down this line of inquiry is is driven by traditional ecological knowledge. As a scientist, while I certainly have an interest in walrus because they're an amazing and fascinating and interesting species, we ended up going down this, down this path because the community in Togiak and elsewhere in Bristol Bay have asked us to. So as we continue to collaborate with other villages, and I think I will reach out to the Eskimo Walrus Commission and see if their community have a need or an interest in us expanding this work, I think that that would be a really valuable next step as we try and ensure that this species thrives and that the villages and communities that rely on these species thrive under what is a rapidly changing northern ecosystem.

Through the chair, one more question. Sure. Go ahead, Maktoon. Thank you. And let me lower my hand.

Thank you, Michelle, for that answer.

So because you had mentioned, you know, the part of the reliance, yes, it's very interesting from a Western scientific perspective, but, you know, incorporating Indigenous knowledge, you know, especially from an elder and their life experience or generational story that has been shared, but And again, realizing that this is focused, you know, in the Bristol Bay area, just thinking about the potential impacts because you do have walrus, you know, near the St. Lawrence Island area and that St. Lawrence Island Yup'ik, which is totally different than mainland Yup'ik, and then also the Inupiaq communities that also rely on walrus as a food source, especially with the lack of access to commercial food systems, you know, like the regular Target, Walmart, Carr's, whatever grocery stores.

If you are going to continue this work, I think it would be, you know, as Annika had mentioned, it would be very interesting to have— though I may not be on the advisory panel anymore, but just to have future interactions at this body and potential impacts from a variety of vessels to the Indigenous way of life. Thank you. Yeah, thank you for that comment, and I agree wholeheartedly. We've been very fortunate that the work we're doing in Togiak has been guided by the elders in the village. Sam Gusik in particular has been really instrumental in helping us to complete this work, and the placement of our hydrophones has been dictated by by elders in the— on the Kayasa Flowers Commission and also in Togiak.

And I think that the success of this project is based on the fact that it is strongly grounded in traditional ecological knowledge. And I will take this as an important cue to reach out to other villages for whom this kind of work could be really meaningful, to see whether or not listening and learning from those communities could take this and, and make it more broadly relevant for the communities for whom this resource is so important.

Susie, do you still have a question? Oh, okay. Thank you, Michelle. Appreciate you calling in. Thank you.

That concludes public testimony. Let's take a brief stand down so we can make sure we consider all the testimony. We'll come back at 3:40, and we'll see if there's Any motions on staff tasking? Thanks.

Okay. Oh, it's not 3:40, it's 3:39. Been lied to by my vice chair. Oh, you are right. It is a demerit point.

Uh-oh, permanent record. Well, I apologize. I have a much more flexible approach to timing, but we will start at 3:39. We will come back. We have had presentations and public testimony.

Does anybody have any motions before we adjourn? Chance?

Yeah. All right, the advisory panel 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 apportionments, 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. The analysis should also consider the age and size composition of mortality. The council should coordinate with or request appropriate analysis from the IPHC.

Second, I'll speak to it. Second.

The intent of this motion is not to single out any one sector. Halibut mortality occurs in several fisheries and under very different management systems. What I'm asking is that we look at these sources together and ask whether existing tools are still calibrated to the resource at this time of low abundance. Pacific halibut is currently near the 50-year low in biomass, and current PSC regulations may not be responsive to the state of low halibut abundance. The abundance that we are currently experiencing.

The halibut stock has seen a decline in recruitment since 2000, and only 3 years out of the last 20 with a recorded recruitment that were above the historic average. The conservation value of reducing halibut mortality is not necessarily measured pound for pound across sectors. As Stewart, Hicks, and Capri in 2021 explained, the much younger fish observed in non-directed fishery discards represent forgone yield due to somatic growth. This is concerning as the associated mortality of juvenile halibut PSC is higher than the natural mortality associated with other juvenile halibut. This further erodes the recruitment strength as those small halibut have less chance to grow and contribute to the SSB.

Stuart Hicks Capri, 2021. Being able to have further analysis on the relation between pounds of fish and numbers of fish in PSC across all sectors can provide a more holistic view on PSC impacts. Recognizing that current— that recent PSC mortality, which has been far below the cap and may be market-driven, I respect the need for operational flexibility, but cap and use are different questions and the biological consequences of mortality can differ by fishery. Types of mortality also differ significantly between fisheries. Recent use doesn't necessarily show what an appropriate long-term cap is.

The analysis should recognize that fisheries are different. The point is to understand the whole mortality picture and improve conservation where it's practical. The motion is broader than PSC. The question is total available halibut mortality. Different sources have different management mechanisms, but they all contribute mortality to the same stock.

Because directed harvest allocations are tied to current halibut abundance, it's reasonable to examine whether there are practical ways to reduce how available halibut— or how available killable mortality across the board while maintaining viable fisheries, particularly at current levels of low abundance. Where relevant measures fall principally within IPHC authority, including the commercial minimum size limit, the Council should coordinate with or request appropriate analysis from the IPHC. On timing, the December data will help this— will help, and this motion will give focus for that data and aid in regulatory action. Beginning the framework Now lets us use those data when they arrive.

Thank you. Thanks, Chance. Questions? Heather.

Thanks, Mr. Chairman. Thanks, Chance, for the motion. In your rationale, you said types of mortality differ between fisheries, and I'm wondering what that means because dead is dead to me. So can you kind of expand on that or provide a little more context on what you meant?

Thanks. Thank you, through the chair. I guess I mean that they're managed differently.

The different types of mortality are managed differently, and so they're not quite the same. A dead fish is a dead fish, you're correct, but some of those managements are required to release. For example, in fixed gear, you have to release a fish under 32 inches. Inches, you know, there's, there's different reasons for those fish to be dying. In the charter fishery, we have to release a fish if it's over 27 inches in Area 3A.

A portion of those fish die. Whether that's a good idea or a bad idea may matter. And when we look at some of those mortalities, they're high, and maybe there's something that we can do to avoid that, or maybe, maybe we shouldn't be managing the way we currently are, but we don't really know without analysis.

Thanks. Other questions for Chance?

Any amendments to the motion? Heather?

Sorry, I do have a A motion that should be over with staff.

Got it? Okay. This is a substitute motion, and I will start reading it. The advisory panel recommends that the council task staff staff with developing a discussion paper evaluating the feasibility, costs, benefits, and implementation considerations associated with achieving 100% at-sea monitoring through human observers, electronic monitoring, or a combination of both across all federally managed fisheries in the Gulf of Alaska.

The discussion paper should, one, evaluate existing monitoring requirements and coverage levels across GOA federally managed fisheries, identifying differences in monitoring coverage, catch and discard accounting, and individual vessel accountability for fisheries that have been allocated quota. To examine the feasibility of achieving 100% monitoring across fisheries and gear types, including the effectiveness of existing existing and emerging electronic monitoring technologies, operational considerations, and vessel safety. 3, Evaluate alternative funding mechanisms ranging from full industry responsibility for monitoring costs to expanded or modified cost-sharing approaches utilizing the existing— utilizing the existing Observer-Declare-and-Deploy system and partial coverage funding structure. And 4, assess the implications of differing monitoring coverage levels for the reliability of catch and bycatch estimates, individual vessel accountability, and the Council's ability to evaluate the effectiveness of conservation and bycatch reduction measures in GOA fisheries. The purpose of this discussion paper is to provide the Council with the information necessary to evaluate a more consistent, transparent, effective, and equitable monitoring framework across all GOA fisheries, especially fisheries that have been allocated quota, before moving forward with a sector-neutral examination of halibut mortality.

And with a second, I could speak to it.

Thank you, Monica. Mm-hmm. So the Council has received extensive public testimony in recent years calling for greater accountability, improved bycatch reporting, and additional measures to reduce incidental catch in federally managed fisheries. These concerns are legitimate and they deserve careful consideration. However, if increased accountability is the objective, the Council should first examine monitoring requirements comprehensively across all fisheries and gear types in the Gulf.

Accountability should be a fundamental expectation of every federally managed fishery regardless of gear type. Currently, substantial disparities exist in monitoring requirements among federally managed fisheries. Established component of federal fisheries management, they do not provide the same level of direct vessel-specific accountability as comprehensive monitoring. These differences are particularly relevant given the significant variation in discard rates among fisheries documented in recent council reports. At the February 2026 council meeting, staff presented updated bycatch information demonstrating that in 2025, Gulf of Alaska longline fisheries fishing fisheries discarded 41% of their total catch by weight compared with just 3.4% for Gulf trawl fisheries.

The Gulf halibut longline fishery had a 49.2% discard rate, meaning nearly half of its total catch by weight was discarded. Gulf Pacific cod longline fisheries had a 36.4% discard rate compared with 10.3% for Pacific cod trawl fisheries. Gulf pollock trawl fisheries had a discard rate of just 1.4%. These are not isolated differences. Council staff's historical data demonstrate that GOA halibut longline discard rates increased from 36.6% in 2016 to 49.2% in 2025.

During that same period, Gulf Pollack trawl discard rates remained between 0.9% and 3.2%. Now these figures do not establish that differences in monitoring coverage cause differences in discard rates, nor do they account for the distinct operational characteristics of individual fisheries, kind of like what Chance was just talking about. They do, however, highlight why a comprehensive comprehensive examination of monitoring requirements and the reliability of catch and discard accounting within rationalized fisheries is important. It's difficult to argue for greater accountability in federally managed fisheries without first examining whether accountability standards are being applied consistently— excuse me— across fisheries. This issue is especially relevant to ongoing discussions about halibut discard mortality in the Gulf of Alaska.

Before considering additional measures that could substantially affect particular fishing sectors, the council should have a clear understanding of how halibut bycatch, discards, and mortality are monitored and estimated across all fisheries that interact with the resource. Reliable catch accounting and independent monitoring are essential to evaluating conservation measures, measuring their effectiveness, and ensuring confidence in management decisions. The council should also recognize that several fishing sectors have already made substantial investments in comprehensive monitoring. CVs participating in the Bering Sea pollock and Pacific cod trawl cooperative fisheries operate under 100% monitoring requirements and bear significant costs. These programs demonstrate that comprehensive monitoring is achievable, although the appropriate monitoring tools, funding mechanisms, and operational requirements may differ among fisheries.

And I'm just about done. At the same time, expanded monitoring requirements must be evaluated in the context of the management tools available to individual fisheries. Rationalized fisheries often have quota management systems and operational flexibility that allow participants to better manage their catch and bycatch. Non-rationalized fisheries, including portions of the Gulf of Alaska fleet, do not necessarily have access to these same tools.

Importantly, this motion does not propose an immediate, immediate requirement for 100% monitoring across all fisheries. It simply requests that that the council examine the feasibility, the cost, the benefits, and potential consequences of moving toward a more consistent framework. It's a first step. I want to emphasize this is not a criticism at all of the observer program. Staff clearly devote substantial time and effort to building an effective, robust program.

I do find it difficult to understand why the rationalized IFQ fishery is not subject to 100% monitoring in order to hold up personal accountability catch accounting. If the goal is greater accountability and better understanding of halibut or any species discard mortality, the council should begin with a comprehensive evaluation of accountability across the entire fleet. This discussion paper focuses on GOA rationalized fisheries as well as non- rationalized fisheries as a first step. And this data can help inform a discussion around all— a discussion around reasonable, measured, and necessary first steps toward that objective. And I'd be happy to answer any questions.

Lauren. This is more of a question for you, Shannon, and for staff on process. This feels like a completely separate motion. And not a substitute. And I would just question a process or point of order here on this.

Yeah, I was working with Anna on that, and this is my fault. I should have got this earlier, but it sort of dawned on me while we were looking at them.

It does seem fairly analogous to the motion that Lauren made, or initially made in terms of it being— this seems like a different motion and action than what Chance did, from my perspective. Mr. Chairman, I guess respectfully I disagree with that, only because Chance's motion is focused on Gulf of Alaska. This motion is focused on Gulf of Alaska, and the information that's necessary to feed into your request doesn't currently— it's not currently all there. This kind of action would help inform what you would like to see done. Yeah, I think I'm going to make the decision.

I see Chance's motion as being— I understand that what you're trying to here is create a prerequisite to do what Chance is trying to do. But this— that it doesn't— I don't see them as being mutually exclusive, which is how I think of substitute motions. And so for that reason, I think it's separate. And I apologize because you did show this to me beforehand and I didn't catch that, so that's my fault. And you had to read a a lot and put a lot of work into it.

So I— that really is my fault. But I don't see them as being mutually exclusive. So you will still have the opportunity to bring this up after Chance's motion, but I'm going to treat it as a separate motion. So we will remove the amendment. And again, I apologize to everybody because wasted some time.

So we will go back to see if there are any amendments That's Chance's motion.

Any comments?

Lauren and then Nelson. Thanks, Chance. I will be supporting this, and in some ways I say hesitantly because as the directed fishery, we do show the highest mortality, both in directed fishing and in discards. But I do think that it's an opportunity to examine that and to look at potential measures that could help us to also decrease that on our own end. And I think it's an opportunity for us in a conversation that's worth having.

So though I think that, you know, personally from the sector that I participate in and work with, you know, this could come back and look pretty terrible, honestly. But at the same time, it just creates opportunity and it creates open dialogue. And I think that that's the point of this process, is to continue to have open, honest conversations with the best available data that we have to make informed decisions. So thank you for putting this forward. I will be supporting.

Nels? Yeah, thank you for the motion here, Chance. I appreciate you raising this at the Charter Halibut Committee and then your more refined version here at the council table. It's created a lot of, a lot of great conversation just surrounding halibut PSE in general. I want to mirror a lot of what Lauren had to say.

I mean, the numbers are there, they show what they show. It's been a huge point of consternation around this table why directed users have the discard that they do. I believe that this will show more of a holistic image as to why.

I think that unless we see a major recruitment event, all indicators show that we are going to be within this spawning stock biomass regime for the time being. I think that this is responsive to not only what we're seeing right now, but also what we're likely going to be seeing going forward within the halibut biomass. And I would just like to highlight what you said in, in part of your rationale. It really resonates that as directed users, our access to this fishery fluctuates as the biomass goes up and down. It's nice to understand the impacts of all the different inputs into halibut mortality on our directed harvest.

Heather? Thanks, Mr. Chairman. I don't think this will be a surprise. I'm not going to be supporting this motion. I do think we've heard in public comment from folks in the directed fishery, the IFQ fishery, that more observer coverage is actually needed in that sector.

And I think that by looking at this approach of— you said sector-neutral, but you also were pretty clear that under low abundance, you want to see something potentially change. And to me, that's a, that's a motion for abundance-based management without having a full picture of the removals. And in fact, with 100% observer coverage, or examining what that would look like for the other fisheries in the sector, it actually might show that their, their bycatch and discards is less. It could show it's a lot more, but right now you're doing it on an apples to oranges approach because a lot of fisheries are 100% observed and these ones aren't, and they are having a significant impact on the stock under low abundance conditions. And so for those reasons, I looked up the number of vessels that are in the fishery, and as of the last the directed IFQ fishery.

As of the last review in 2023, it had just under 700 vessels for halibut, and I think 250 for sablefish. That's a lot of vessels with 15% observer coverage that's not being achieved. And so I just can't, can't support this moving forward, but I appreciate your effort. Other comments?

Jim? Well, maybe mine is one of order. I heard you say that these aren't mutually— whatever the word is— exclusive and that Heather's motion can come forward because it's not a substitute. Am I understanding that right? Okay.

Thank you.

Thanks, Mr. Chair. Thanks, Chance, for the motion. Um, I'm not going to support it.

I appreciate what you're trying to do, and I appreciate what the charter committee was trying to get at with a sector-neutral evaluation of goa halibut mortality. However, I'm looking at the potential scope of this document and thinking about how large it is, and I'm thinking about what we already know and whether there's more sort of a surgical or approach to this or some low-hanging fruit or something that this body or the council can do to fix either uncapped and increasing sources of halibut mortality in the Gulf, um, or pretty severe discard mortality wastage issues, whether they be in a directed fishery or not. I think those are the most appropriate places to be putting effort and time into, and I don't think we need a sector-neutral discussion paper in order to tell us that. I think it's pretty clear from what we heard in public testimony and looking at the pie chart. I also think that Putting in a review of a PSE limit for trawl in the Gulf of Alaska when the use is so tiny right now, you're not really saving any fish.

You're not decreasing mortality. You're decreasing a cap. So to me, What you're doing essentially is you're saying, and what this is, this is what I think their public comment from the Charter Association says, is you're basically saying there's capacity for an anomalous high bycatch event, which is a low probability. So what you're going to do is you're going to look at a very low probability event and then try to manage that in a process that has very limited resources. To me, I don't see the value in that at this time.

And so I think at this point, I, I can't support it. I think we could look at sources of halibut mortality that are currently happening in the Gulf of Alaska, do better with some of those sources, and redirect our limited efforts in those— to those areas, and this motion doesn't get there for me. So thank you for putting it forward, but I can't support it. Chelsea.

Thanks to the chair. Thanks, Chance, for the motion. I really appreciate you bringing this forward and the, um, you know, your intentions to look at this holistically and sector— and sector neutral. I really do I do appreciate that, and I understand your goals in that, and that we're at a time of low abundance. But I have a couple sort of fundamental challenges with supporting the motion, just because one, it doesn't do anything to look at the unguided sector, and I realize that's because we don't have a legal definition of that sector, and we don't have, you know, a way to manage that.

But for me, I find it hard to spend council and agency capacity on looking at something when we still aren't addressing that major issue. It just doesn't get at the— what I see as the biggest elephant in the room. And then secondly, I just wanted to address some discussion from earlier around the table about changes in halibut PSE use in the shoreside sector. The shoreside flatfish market did essentially collapse in 2021 and 2022, so catcher vessel PSE was pretty low. But that— those markets have been continuing to rebuild, and it's a lot of work to rebuild those markets.

And catcher vessels need processors to rebuild those markets, and they need us in order to prosecute fisheries. And it's not really like a secret that the processing sector has been been struggling with high costs and consolidation for years now. And without processors in our communities, vessels don't have anywhere to deliver their catch. We hear about this all of the time, you know, just ask Adak, King Cove, St. Paul, and then other communities that are now just seasonal processing communities and don't have year-round. And Kodiak has the largest resident processing workforce, and we can't have that workforce unless we have the ability to prosecute fisheries and have enough volume moving through the plant 12 months, um, throughout the year.

And so having opportunities for shoulder season fisheries, which require halibut PSC allotments, is just important for that and keeping our community whole. Um, and so the other subpart of this is this motion doesn't include doesn't include anything for management tools. And so the fleet that this would impact has asked for management tools and has been promised by this council that when they get caps, including the ones currently in place, including the salmon caps, that they would be given management tools. And so just as a processor, it's hard to support something that potentially chips away at the diversity of fishery. Fisheries that we need to operate.

And we need halibut and sablefish, we need all of the fisheries, but it just doesn't get sort of the big issues for me and the mechanisms that we need in place so that we can, and you know, management tools also come with 100% monitoring, which solves a lot of issues and improves monitoring. You know, if you move the Gulf trawl sector to the full coverage fishery and they're pairing their own, then there's going to be enough money in the partial coverage budget for improvements on IFQ observer coverage rates. So there's a lot of things, you know, that are just missing pieces, and we need those sort of those bigger things to, to be worked on. So thanks. Jim.

Mr. Chair, can I ask a question about the motion, or am I too late for that? No, no, you can ask a question. Chelsea made a good point about seems like the absence of of any requests something be looked at with respect to the charter or bareboat charter industry. Can you comment on that?

Is that missing? Am I— are we wrong about that, or why isn't it in your motion?

Through the Chair, that is simply negligence and omission. I would absolutely include it. I think the concept is to include everybody that's accessing the resource. I'm not sure— recreational is allotted by, you know, they're allotted an apportionment of the resource in each stat area, and I don't see why that wouldn't be included there as well. I'm not sure how they would do it because they have no logbooks and there's no, you know, there's port sampling, I guess.

Maybe in the state's survey, you there's information there as to how many fish they might have released, or, you know. But I think that— I guess I think that that's my answer. I would happily add the word recreational in there as a friendly amendment to the motion, if allowed.

Other comments?

Jeff? I guess I'll Just comment. I appreciate all your perspectives and I value them greatly. I'm naive and new to this place.

I saw an opportunity in the charter halibut management meeting. There's been stakeholders there that have been concerned about PSE levels for a long time and finally just said something about it, and we made an opportunity to make a motion here. And it's kind of awkward because it's not really the body of people that should be making a motion like this, but they're stakeholders and they're allowed to do that during committee.

You know, in just response to some of— if I were to be critical about some of the things that are on the table, I'm not sure. As we know, we know a lot about mortality. We know there's a bunch of dead fish going in the water. Heather's motion that unfortunately didn't go— hopefully we'll see it again, you know. But the it talked a lot about those percentages.

It seems like we know we're killing a lot of fish, and I don't understand how monitoring, increasing monitoring, is going to change that amount of fish death. It seems like it's just going to confirm it. Maybe it confirms it in a way that's greater, maybe like Heather said, it confirms it in a way that's not, but it would just establish something that I feel like we kind of already know. And we saw staff present on the cost of EM and observers, and it seems very expensive to the point where we're not totally even sure why it's as expensive as it is in some cases. Anecdotally, we might have talked about that off away from the table, but the— I guess the short version is I really appreciate everybody's concern consideration here and tolerance and patience with me in putting this forward.

And we'll see— I guess we'll see what happens. But thank you. Thanks, Chance. I guess I'll offer my comments then to close. I do appreciate that this is responsive to the Charter Committee and just you putting it forward and trying to take a sector-neutral review.

My hesitations with it are that Really, I mean, I think this information already is here and we're not— we're not— it's not asking for anything other than really a data poll. But it's also— there's really only one place it can go, which is PSE reduction. And I support PSE reductions in the Gulf because I think there's a lot of room for improvement in how the fisheries are operating. Operate it, but it's— I think that it's missing an opportunity, like a testifier said on the last issue, to think outside the box and be creative.

And the shoreside fleet has been significantly under the cap for many years, and there's different reasons for that, but it just strikes me that they've been asking for this bycatch management program for a long time, and there's an opportunity for the charter sector and others to work with them to try to improve some of the, um, the management measures that they need. I also support 100% monitoring for every single vessel in the Gulf. I think that that's critical, and that's missing here too. Um, and, you know, I— we had a lot of conversations on the charter issues about, um, the efficacy of taking action when there's all these other leaks in the system. And so I am struggling with that, but I also appreciate that there's room for improvement across all fisheries in the Gulf.

And I think the concept of introducing some caps without some of the other tools is where I hesitate. But I do appreciate where you're coming from here. So with that, let's do a vote.

All those in support? Sure, yeah, sorry. Sorry, I kind of wanted to hang on to this, but I also think there's a key sentence in here that sticks out for me, and I have no skin in the game about halibut, but many of the tribal communities I represent sure enough do.

And what you're asking for is determine if it remains appropriately calibrated to current stock conditions. And for me, it's like, that's not just about PSC reduction, it's about reduction overall in all the takers, is what I would have read and interpreted from this. And why it matters to me and why I wanted to Speak Up is it's kind of related to the Chinook Salmon Three River Index where, yeah, you're not hitting the cap, you're still operating under the cap or whatever, but the cap doesn't match the current situation.

That's, that's how—. So what I'm saying is like the situation with halibut is changing as to what's available, and maybe this review can shed some light on that. And those are just my two cents as somebody who doesn't really know that much about halibut fishing, but I do see some similarities. Thanks, Eva. We will go to a vote.

Let's do a count of how many people are here first.

Sorry, Mike Toye, I missed you. Oh, you're good.

Please raise your hand.

All those opposed? Okay, that motion fails 5 to 12.

Heather. Thank you, Mr. Chairman. I have a motion. It's already with Staff. Okay.

The advisory panel recommends that the council task staff with developing a discussion paper evaluating the feasibility, costs, benefits, and implementation considerations associated with achieving 100% at-sea monitoring through human observers, EM, or a combination of both across all federally managed fisheries in the Gulf of Alaska. The discussion paper should: 1, evaluate existing monitoring requirements and coverage levels across GOA federally managed fisheries, identifying differences in monitoring coverage, catch, and discard accounting in individual vessel accountability for fisheries that have been allocated quota. To examine the feasibility of achieving 100% monitoring across fisheries and gear types, including the effectiveness of existing and emerging electronic monitoring technologies, operational considerations, and vessel safety. 3, Evaluate alternative funding mechanisms ranging from full industry responsibility possibility for monitoring costs to expand or modify cost-sharing approaches utilizing the existing, uh, odd system and partial coverage funding structure. 4, Assess the implications of differing monitoring coverage levels for the reliability of catch and bycatch estimates, individual vessel accountability, and the council's ability to evaluate the effectiveness of conservation and bycatch reduction measures in Gulf fisheries.

The purpose of this discussion paper is to provide the council with the information necessary to evaluate a more consistent, transparent, effective, and equitable monitoring framework across all Gulf fisheries, especially fisheries that have been allocated quota, before moving forward with a sector neutral examination of halibut mortality. And with a second, I can very briefly speak to it. Thanks, Chance. I would, by reference, incorporate all the rationale I read before. If somebody wants a copy of that, I'm happy to share it, but I'm not adding anything additional to it.

Any questions for Heather? Laura.

Thanks, Heather. Um, appropriately, we just received a lot of information at this meeting regarding the observer program, so it is top of mind and easier to think about this from a realistic perspective. And I feel like from everything we heard in the ADP, we cannot get to current management goals or objective goals of monitoring as it, as is. So we know that's not feasible, um, and so I'm just curious where that information went into this because we've seen the numbers, like they've been in front of us many times, and we've seen what we can do with the current cost recovery program. So I'm just trying to understand, um, the realistic aspect of this.

Yeah, I appreciate that. I think the realistic aspect is captured quite a bit in number 3, evaluate alternative funding mechanisms. I'm not suggesting that we move forward with the program that exists now in terms of ODS, which is partial coverage anyway. This would be exploring an overhaul, and there's many fisheries— in fact, most rationalized fisheries in the country country, people have 100% observer coverage and the industry pays for it. So I'm suggesting we look at all different types of funding.

And we've heard a lot from the public over the last several years from the fixed-gear sector about cost-effectiveness and needing improvements in the program. And so maybe instead of, you know, trying to keep plugging up these leaks, we actually need a complete overhaul of the program, and this would be a way to start exploring that.

Thanks. And I've personally been working on a bunch of projects trying to get more monitoring into that fleet through NFWIF grants with varying success. But the, the other thing, and it was a question I asked that I got some clarification on later that wasn't shared with the group, but there was I had expressed concern around the levels of monitoring and the management goals and objectives. And I was told that there actually was little concern about that decreased level, like the 10% rather than the 15% or the 30%, because of using the— what's the name of it? We're using the— the proximity allocation model.

Thank you. That a lot of these fisheries and these vessels are occurring, they're fishing in the same area. So that model actually allows a really good, like, spatio-temporal picture of the fishery. So again, just kind of curious with that response having, you know, received from the agency saying actually those low numbers are okay because we are still getting a really good picture of the fishery because of how concentrated it is. So how about that consideration?

Through the chair, Lauren, thanks for the question. If that's true, then we could have the same thing with trawl fisheries that are all operating in the same area. But more so, we do know from scientific studies that there is an observer effect. And so I believe that vessels are acting differently when they have a human observer on. And I think that the bycatch in some of these fisheries, it could be much, much higher, the discard, particularly in the IFQ fishery, than is being reported.

So I don't know how to reconcile that, the observer effect with the proximity model. That's new, the proximity model. But with 700 vessels at that low observer monitoring level, I have a hard time believing that 1 or 2 vessels all operating in the same area are representative of the whole fleet.

Other questions?

Sure. Thank you. Yeah, I have to remember that. Okay, last question. And as I'm just continuing to chew on this a little bit, like, so based on your answer and some of the rationale and what we're seeing, like, in some ways this is looking at, like, an overhaul of the whole observer program, the potential of that, like, acknowledging that it's not possible to do this under the current program, which we know very clearly.

We were told that, you know, in this meeting through the ADP. So in some ways this is looking at a full overhaul but the purpose of this, that the statement, kind of the last section of this, this last, um, the purpose of this discussion paper, um, isn't necessarily explicitly stating that. It's saying that we— this is actually related to looking at halibut mortality. So there's some— feels like some conflicting goals of this. I just wanted some clarity on that.

Well, I appreciate that. Uh, it was around halibut because it was substitute motion for Chance. And what he's asking for in that motion that failed was understanding all the sources of mortality of halibut in the Gulf of Alaska. And so I can tell you that some of the trawl vessels operating right now from my fleet are not thrilled about me putting a motion out there that suggests we look at 100% coverage for them when they don't have the tools that they need to to be able to minimize bycatch, even though we've asked for them repeatedly. We've been on the cusp of that from more than once, and then an administration change comes in and that goes away.

But what it's really about for me is the double standard. Every single trawl fishery is constantly under attack for not being accountable, when the reality is most of us are 100% accountable. 100% Accountable in some places. I think the freezer longliners are the only other fleet potentially that are as accountable. And I think it's time that we take a look at the directed IFQ fishery, regardless of if it's just halibut.

If I look at the document that was shown in 20, you know, for 2025, the discards of skates is huge in your fishery. And so, or in the directed fishery. So in the Gulf, we need to understand all of this. So, you know, it really is not just about halibut. It's about leveling the playing field because right now it is inconsistently applied to fisheries and it's a fairness issue.

So that's, that's what this is about.

Other questions?

Move on to amendments.

Comments? Lauren? Don't all speak up at once.

Yeah, I guess I am struggling with this because it's coming from two different sides. A lot of this I feel like should have been brought up in in the first issue we took up at this meeting. If there were these concerns that coverage isn't sufficient, you think that that would have maybe been outlined from the committee reports, both FMAC and PCFMAC, as well as outlined in the ADP, and they would have expressed serious concerns that there isn't enough monitoring in our fisheries. I agree that the levels are low, which is why I asked those questions on whether or not there were management objectives and we needed to be meeting certain, certain thresholds. Like I said, I've personally been working on a project trying to incorporate AI into, um, review of fixed gear footage because we need to speed that up.

We need to make that more effective so that we can have more people being covered. So as someone from that sector with concern, I took it upon myself to initiate that project. Um, and we're still working through it. We have a couple months left. Um, and we're gonna hopefully continue to work on the POT side as well.

So we are doing our part to try to get higher levels of coverage, but to me this, this feels a bit out of place considering we took up this issue at this meeting specific to the observer program, and nowhere in there was a concern expressed around the level of coverage. There was a lot in there saying we're doing the best we can with the current funding. We're going to look for more funding mechanisms. We're going to look for more efficiencies. So this is a very large ask because if it is indeed looking at a complete overhaul of the observer program, that's pretty significant.

Not saying it couldn't be done, but you're usually the first person to bring up priorities, staff time, the lift that is required, and this seems like a very large lift in terms of taking action of this sort. So I'm struggling with the placement of this other than it be being reactive to a controversial motion that was put forward before. So thank you for bringing this up. I think it's a worthwhile discussion to continue having on ways that we can create more monitoring. Also, I have two vessels that I worked with, with Archipelago, to get like a micro camera on, like, for the state fishery.

So, like, they're developing more prototypes, they're developing more technology that can be used on smaller vessels that can be more efficient. Again, I'm working in this space actively. There's a lot that's being done. So there is potential to talk about this, but, like, this seems like either an observer issue or obviously another action here in staff tasking to open up the entire observer program to revamp it completely.

I just have a couple of quick responses to that. I did bring up concern about the coverage level. We also have heard it in public comment. So under that agenda item, I did bring that up. I think the other part toward the end of your comments there that is accurate is the committee was not expressing concern.

They were saying we're doing the best we can with the funds that we have. And MTC vessels on the West Coast pioneered electronic monitoring. So I have also been in that space for 15 years. And so, like, I get that. But, you know, without being more controversial than I need to be, we're also in the process of doing all kinds of things with pelagic gear.

But you guys wouldn't stop and wait for that to happen. You had to push through on a motion to do something more. Right? So again, it's the double standard. We are held to a much higher standard than anybody else.

And this is just looking at not implementing anything. And it doesn't say overhaul the program. It's only focused on the Gulf. But are there ways that things can be better and everybody can be more accountable? So those are quick responses to that.

Okay, let's see if there's other comments. Monica. Thanks, Mr. Chair. Thanks, Heather, for the motion.

I'll support it. I work in a fleet that has 200% observer coverage. That means 2 observers on every vessel at any time, every haul is sampled. So I recognize the cost of having observers, um, in the full coverage fleet, 200% monitored. I— what I like about this motion, um, even though one— what we heard from the Observer ADP is that we're doing an excellent job in the North Pacific, what I like about this job— about this motion is that what it's doing is it's trying to examine the feasibility of achieving 100% monitoring.

And I think for me, that should be the goal, and I think we can always do better. Even though we're doing well, we can always do better. And so for me, fundamentally trying to reach for that is what this motion does, to see if it's possible. And so for that reason, I'll support it. Thank you.

Other comments? Susie. Through the chair, thanks, uh, thanks for this motion, Heather. I'm going to support your motion. As someone that manages to 100% observed fisheries in the Bering Sea.

It's hard to hear about issues regarding data availability as well as lack of proper management tools without hearing the suggestion of full observer coverage until now. While it may seem feasible to have— while it may not seem feasible to have full coverage across the Gulf tomorrow, I think this really starts that serious inquiry to really understand how we as a region can work towards towards it and officially understand the hurdles and the art of the possibility. And so I think this is a really great starting point. We may uncover other areas in which this could—. Other maybe management tools or other species besides halibut PSE that could— that this could help with.

But I'm going to support it, and I also want to just echo some of what Annika said as well. Chelsea. Thanks to the chair. Thanks, Heather, for the motion.

I feel very torn on this motion for a couple reasons, just because I've said repeatedly at this table that I can't support motions, um, if the tools aren't included. And I get that this is just an evaluation and a discussion paper, but I also just use that as rationale for not supporting Chance's motion. But I also agree with Annika's statements that we should be shooting for 100% observer coverage for everyone. Like, that should just be the goal, and evaluating how we get there is really important. And then as someone who sits on the monitoring committees, I really do believe that our ADP, you know, I wasn't here when the partial coverage program and everything was redesigned in 2013.

But I know a lot of work has gone into it since then. And, you know, I wasn't a part of the decision-making process of the partial coverage fee system, but that fee system is why we don't have 100%— is one of the reasons why we don't have 100% observer coverage in the Gulf. So I'm just really torn. I'm not sure where I'm going to land, but I really do— I support the intention of this motion. Wholeheartedly because I do think we should be striving for 100% monitoring because then we know the numbers we have are the numbers that we have.

Chance? Um, Chair, thank you for your motion. I'm not sure how— I know you'd quoted that there were 700-something fixed-year boats and 200-something you know, sablefish boats. I don't know how many charter boats there are, and I don't know how many recreational boats there are, but I don't know for sure how we would ever get electronic monitoring on all of them. And if we're going to bring up the concept of why recreational isn't involved in a mortality conversation, then I'm assuming that charter and recreational boats are included in this one because you're your motion requires all cross fisheries and gear types.

And so I do appreciate the, the thought. I would align my, my, um, my comments with Chelsea. I, I understand and appreciate the goal here, but for that reason specifically, I, I can't endorse it. But I do see what you're trying to do, and I do think that coverage in And monitoring in the Gulf is a good idea. Thank you.

Other comments?

Rick. Through the chair, thank you, Heather, for the motion. I just wanted to point out that I'm especially excited to see information from this. I'm going to support it. And I really like point 2 with the emerging electronic monitoring technologies.

I think there's already work in place. And Lauren mentioned some too that's going on with, uh, you know, emerging technology, AI, smaller cameras. And I think that in the future, maybe not too long from now, with the way the pace of technology is going these days, that we may see something in the near future that could be applied in places where we didn't think it could be before. So thanks. Paul, through the chair, thanks Heather for your motion.

Um, I'm not quite sure if I'm going to be supporting quite yet. We, the council, went through a long and rigorous process to restructure the Observer Program barely 10 years ago, and during those discussions there was consideration of greater coverage levels in all fisheries. And I think this is, this is, there is, I believe, I would agree with you that that there are some shortcomings in some of the data that's coming in from various fisheries, and ideally we would address all of those. And I think increased monitoring and smaller fixed-gear vessels would go a long way towards that. But I think the reality is that we're, you know, through the PCFMAQ and through the FMMAQ and through the ADP and the reviews that we do here annual report that we review every year, I think that there's a great bit of effort to try and maximize the observer coverage levels that are based on the available funding.

And I, you know, without, you know, some sort of major increase in funding, I don't see significant changes to that. So, but thank you for the motion. I think this is a really important issue to consider. Nelson. Yeah, through the chair, thank you for the motion here, Heather.

I'm not surprised— or I'm surprised that I haven't seen this earlier because this is something that you really champion is 100% monitoring for everything. I do struggle. I'm not going to support this. I do struggle with the fact that this is asking for increased 100% observer coverage for a fleet that as of right now we're not even able to deploy the— to the coverage level that is, you know, asked for, that is projected for. I think that asking for 100 before we're able to hit 15 is— it is a huge lift.

Longline fleets, we often see, we'll send in our data for EM and we won't receive a— if there is an infraction, you might get a notice 2 years later. There's missing gaps throughout the whole system. I see this as too big of a lift, not just in funding, not just in available technology hardware that can be implemented, getting to remote communities where the fixed gear fleet operates out of. I mean, if you don't have EM, you call, you call for a trip, you're going to have that 3-day window for them to get that observer out. You could miss your weather window.

Now you have an observer arriving, you may not have a weather window. Your vessel can safely go for another 2 weeks. So there's a lot of, you know, just outside of this, just comprehensive issues with even attaining the observer coverage that we have for the partial coverage fixed gear fleet at, at the moment. I think that shooting for this large of a jump, this large of an ask right now without fixing kind of all those other layered, uh, just departmental agency level things first is, I think it's kind of jumping the prerequisite steps that are necessary before we, we can attain that. So for that reason, I'm not going to be able to support this today.

Through the chair, thanks. And I would actually, I would agree with you if I was asking for 100% observer coverage on your fleet right now. This is asking for a paper that looks at that, and I would think all of those issues that you've all talked about, whether it's charter boats carrying cameras or what you— all the things you just mentioned, that would be borne out in this discussion. And I think it would actually could be helpful to you. So I'm really kind of surprised at the resistance because everybody's always talking about improving accountability, but then when it comes to maybe taking a look at your fishery, it needs to be done offline.

I think this is just a paper exploring it. It's not, it's not asking for an overhaul of the program. It's asking what would it take to get there. And maybe all the things that you just said would say it's completely unfeasible. I don't know, but I think you're misrep— you're misunderstanding maybe what I'm asking for here.

It's just an evaluation.

Other comments?

I'll make a final comment. I, as I noted, I do support 100% observer coverage on all the vessels. I am even charter boat. I think that we should be striving towards that. I do think that there are issues.

There's a pretty large divergence when you look at the IPHC number for wastage and then when you look at the NIMS accounting for discard mortality. There's a lot of—. I think it was like close to 12 million pounds of discards. And so I think that there's a need across all the fisheries, and certainly in the trawl fisheries where there's, you know, potential for high bycatch events. But for many of the same reasons that I expressed on the last one, I'm not going to support this because I think it's not comprehensive enough and I don't think it's really working with the other sectors.

I guess I'll just take advantage of the fact that I've already pissed you off and just dig a hole a little bit deeper. So with that, I will take a vote. So all those in support of the motion, please raise your hand.

All those opposed?

That motion fails 6 to 11. Okay, any other—. Yes, yes, go Cindy. I move to approve the June 2026 AP meeting minutes. Second.

Thanks. Adjourn, please. Yes, thank you. We'll see everybody in December.