NPFMC 279 Day 6 - June 9, 2026

Good morning, everyone. So we have, um, 2 agenda items as well as staff tasking to get through before the end of the day here. Um, so we will try to have our focused conversations throughout the day, making sure that we get all of the information we need to move forward with either direction to staff or action. Um, we will begin with our E1 agenda item, and we have Ms. Latonich here to introduce E1. Thank you.

Good morning, Madam Chair, members of the council. For the record, Katie Latonich, council staff, and I'll be giving an overview of E1, the Groundfish Management Policy Review Report. So the actions before the Council on this item are to review the Council's Groundfish Management Policy and actions in support of the policy, receive this portion of the Ecosystem Committee's report from our May meeting, and then determine whether the Council wishes to make any changes to the management policy or pursue any additional actions in support of the policy. And I will keep my presentation focused on highlights in the interest of time, and I'm happy to answer questions on any portion of the report.

Sorry. Okay, so for context, I know I've covered this before, I'll keep this brief, but as a reminder, these groundfish management policy reviews are a long-standing self-imposed requirement that's established through the two groundfish FMPs. So to clarify, this is not a Magnuson requirement. This is something voluntary that's built into the management policies within the two FMPs. This used to be an annual process.

The Council shifted this cycle to be a triennial process to better align with the kind of lifespan of Council actions, and this was most recently completed in 2022 for the years 2019 through 2021. So this current review period covers the years 2022 through 2025. And much like an allocation review or a LAP review or an EFH review, this is a process requirement. So the council considers the information and determines whether to make any changes, but there's no requirement to make changes. As a reminder, the management policy includes several components.

So there's a, a management approach statement, which is like a preamble, uh, 9 goals and 45 objectives. So it's quite comprehensive. Um, it's a lot to keep in mind. So this is provided as Appendix 1 in the review report, and I also have slides with the goals and objectives if those are helpful for reference. And the management policy was established in 2004 based on the analysis and the programmatic supplemental environmental impact statement.

So this policy has been in place for over 20 years.

So typically when the council undertakes these reviews, it's the same kind of basic set of tasks which involve reviewing and revisiting the groundfish management policy, reviewing the council's work in support of the management policy during the review period, considering whether any modifications to the policy are warranted, and then considering any additional activities in support of or to help implement the policy.

For this review cycle, the Council directed staff to take a more cumulative approach for several reasons. Again, it's been about 20 years since this management policy was first adopted, so it's appropriate to take kind of a longer-term look at the history of groundfish management and how things have changed. It's also a chance to consider the Council's work on climate resilience planning and incorporation of local and traditional knowledge, since those were areas of focus during the review period. And finally, it's a chance to consider FMP goals and objectives in the broader context of other Council policy guidance. So in the past 20 years since this FMP guidance was adopted, the Council has adopted other forms of standalone guidance like the Council's ecosystem policy, as well as goals and objectives that are built into other documents like the Bering Sea FEPP goals and objectives.

So the Council can kind of look at all of this guidance collectively.

This is also a chance to ask some bigger picture questions. The Groundfish Management Policy, at the time it was adopted, was very proactive, and it stated the Council's approach to taking a precautionary, forward-looking approach and incorporating ecosystem-based information and considerations. So it's a way for the Council to convey what's distinctive about its approach and its objectives for, or priorities for, groundfish management. So the Council can reflect through this review on whether the management policy continues to do all of these things that we want to do through FMP guidance. So does it provide timely and relevant guidance given how the groundfish fisheries currently operate, our understanding of the marine ecosystems, and in light of current Council practices and priorities?

And again, the Council can consider any updates or modifications to the policy, and some of the reasons why the Council might consider doing that are to help provide guidance to staff, provide transparency about how the Council considers information and tradeoffs in its management recommendations, and again, to better communicate the Council's values and priorities at a, a very high kind of strategic level.

Within the review document, which I'll walk through portions of in a minute, staff began with a statement that the Council's work, from our perspective during the review period, continues to generally align with and support the management policy as written, and we didn't identify any strong concerns or mismatches between the management policy current Council practices. So that's just our, our perspective from staff and from reviewing the Council's work during the review period. What we did do is identify some areas where portions of the management policy, um, may provide opportunity for further discussion because, for example, the interpretation or the wording or the implementation of a goal or objective may have evolved since it was first written 20 years ago.

So the decision points before the council are first to determine whether or not you want to make any changes to the management policy. Of course, one option is no action, and the council could determine that this is the, the path you'd like to take while also acknowledging that maybe the interpretation of goals and objectives has changed over time. So, for example, you could conclude that the policy is still timely and relevant, but that the guidance should be interpreted in today's context. Alternatively, the council could choose to modify any portion of the management policy, including the management approach statements and/or goals and/or objectives. And to clarify, any, any modifications regardless of scope would require an FNP amendment.

Additionally, the council could consider other actions in support of the management policy, whether or not you choose to take any action to modify the policy itself. And these are not mutually exclusive. So for example, the council could choose to develop new policy guidance. You might want to consider a work plan for implementing specific goals or objectives if you feel that's appropriate. Another possibility is providing guidance on future policy reviews.

So the requirement to conduct policy reviews is built into the FMPs, but it does not specify how they should be conducted. So for example, if the council feels there's a a better, more effective way to be tracking work relative to goals and objectives, you could provide guidance to staff on how best to do so. And the same is true for our in-meeting groundfish work plan updates. Those are usually provided under staff tasking and provide a two-meeting snapshot of work relative to goals and objectives. Other opportunities could include doing a similar policy review for, for other FMPs such as crab, and as well there may be other outreach and communication opportunities, and we'll talk about this more under the ecosystem committee's recommendation.

And of course, that— those are just examples of ideas, and of course the Council may have others.

So I do want to highlight just two sections of the document that achieve the task of reviewing the Council's work relative to goals and objectives. Again, I won't go through this in any detail, but happy to answer any questions. So first is Section 2, which is a summary table, and usually when the Council receives these groundfish management policy reviews, this is the format you're used to seeing. So it's a list of all the groundfish FMP goals and objectives with the council's work during the review period kind of mapped to those goals and objectives to show how they've been supported and advanced. Additionally, this time around we added another column to this table that includes highlights of actions relative to goals and objectives prior to the review period, so between 2004 and 2021.

So there's a ton of information packed into this. It's a good reference and resource, and it really helps capture all of the work the council has done relative to all of these goals and objectives, both during the recent review period and since the adoption of the policy. And that's really all I'll say about this table, but again, happy to answer any questions. There's also a narrative complement to this section, and this is Section 5 of the document. So for every goal and objective, there's a written component that includes key points, accomplishments, challenges, uh, context, especially for the wording of goals and objectives, and a summary of the council's work aligned with each objective.

So for example, um, rather than just including, um, the, the name of the council action, for example, MRA adjustments, we just include a paragraph about what that action was. And so that's a resource for the council and public to take a look back, and even if you're not familiar with all of the kind of details of groundfish management, have a better idea of what the council accomplished.

So I'm going to move on to Section 3 of the document, which are cross-cutting themes, and this is where staff identified some opportunities for the council if you desire to take a look. And consider whether any revisions or updates are warranted. And looking ahead to our Ecosystem Committee report, this was the focus of our discussion as well, so I'll spend most of my remaining time here. So one of the themes looking across the Groundfish Management Policy is that it is lengthy, it's comprehensive, and some of the language in there is derived pretty closely from the national standards and also restates the Council's requirement to comply with other federal laws like the Endangered Species Act. So one of the Council's considerations could be whether it wants FMP guidance to continue restating Council requirements.

There's no right or wrong answer to this, it's just a, a matter of preference, and this is kind of an area of contrast between the groundfish FMPs and other FMP policy guidance, which is more concise.

The bulk of Section 3 is focused on the durability of FMP guidance over time, and here's where we've tried to highlight where Maybe the interpretation or the wording of a goal or objective may have evolved relative to the language or the practices the Council follows today. Just to briefly run through those, those include things like references to intended management actions. So, for example, when the management policy was adopted, the Council did include examples of specific actions it intended to take, like the restructuring of the Observer Program. So the Council can consider whether those are still relevant or whether any objectives have been achieved. Another is the use of terms that have evolved or changed.

For example, Goal 3 refers to maintaining the food web, whereas today we might use the term ecosystem. There are also references to marine protected areas, where today the Council's term of choice might be area-based management measures. There are also several research-focused objectives, and these are a bit duplicative, and they're also complementary to the Council's research priorities. So the Council could consider whether it's whether it's helpful to continue having all of these different research-focused objectives or whether they can be consolidated. As well, there are examples of evolving priorities and tradeoffs.

Also, the alignment of goals and their associated objectives is something the Council could take a look at. For example, this, this refers to how goals are— objectives are nested within goals. So if you think of goals as kind of higher level, higher level aspirational statements, objectives are more about intended or kind of specific courses of action, so you can kind of look at whether the alignment of those makes sense. And finally, there are some opportunities for minor cleanup and revisions, and I won't go through those in detail, but they are described in the paper.

There's also a brief section on climate resilience, and the Groundfish Management Policy does not explicitly refer to climate change or climate resilience. It's really a matter of preference whether the Council thinks the Groundfish Management Policy should refer to climate change or whether it's kind of embedded within other goals or objectives. As part of this, you could reflect on the attributes that make a management policy climate resilient. And so, for example, you might consider whether there's value added by updating the policy to refer specifically to climate change, and whether there's a need to be more explicit or consistent regarding when and why and how to consider climate resilience and integrate climate information. For example, you could look at some of the goals and objectives within the existing management policy and see that there are on-ramps or opportunities embedded within those for integrating climate information.

So, for example, the harvest specifications process or EFH reviews. So even though it doesn't refer explicitly to climate change, it kind of does by reference, by, by pointing to these other processes that provide for the uptake of climate information and considerations.

Additionally, like I mentioned, the Council has a broader kind of array of policy guidance at this point. The Council can consider how the FMP policy guidance aligns with or complements those other forms of guidance in, in terms of making any revisions. And finally, the management approach, which I mentioned, is like a text preamble to the goals and objectives. I don't think in the past the Council has typically looked at this and made changes, but again, the Council could look at this this kind of preamble text and consider whether it still makes those aspirational statements and helps identify the distinctive attributes of the North Pacific process.

So that was a very abbreviated, quick version of this, but again, I'm happy to go back and answer any specific questions. And the decision points before the council again are to choose whether you want to make any modifications to the existing policy and whether you wish to consider any other actions. In support of the management policy. And so I'll pause there. I'm happy to take any questions.

Thank you very much for the presentation, Ms. LaTonnage. Are there any questions? Yes, Ms. Kimball. Thank you, Ms. LaTonnage, for your presentation. And I know you emphasize that these are— is a self-imposed review, you know, and to kind of review our kind of vision statements or policy goals.

I think one of the things, and I know we'll get to the Ecosystem Committee report, but one of the things that was bothering me once we went through this process was even if there are places where the management objectives are just repetitive of the national standards or repetitive of something that we have in another place in our vision or goals, or removing those at, at this time still looks to the public like we're making some statement about not doing that objective, even if we've just decided We don't need the national standards in here because they're the national standards. We have to comply with them all the time. So did you think about advice to the Council when you're suggesting revisions on how to deal with that situation, just how to communicate to the public if the Council did make changes based on those kinds of things, um, that it's not taking away from our normal requirements under the Magnuson Act or other laws?

Thank you, Ms. Kimball. Through the Chair, that is something we discussed at the Ecosystem Committee level, and it came up in the context of the fact that the groundfish management policy is really extensive compared to some of the other FMP goals and objectives. And maybe I'm getting ahead of myself, but kind of in keeping with your statement, the committee felt that if there's— if there may be duplicative references to the national standards embedded within the management policy, there's probably no good reason to take things out. There are still things the Council has to do. That said, I think it came up because we were thinking about if you were to redesign the groundfish management policy or think about how to achieve more consistency across FMPs, you might not necessarily repeat all of those things, but because they're already there and they emphasize things that the Council is required to do and they help the Council track its work relative to the national standards, there's, there's No compelling reason to take them out.

Sorry, I don't know if I'm answering your question, but I think part of communicating any changes to the public would be emphasizing how they better communicate the council's values and priorities and practices today. So really emphasizing kind of what is important about the council process that isn't already communicated through the things you're required to do.

Thank you for that. And, and do we know how other councils do this, and maybe you don't, it's not a very fair question, but do you know how other councils track their work against their potentially explicit stated goals and objectives, or is this just a process we've adopted here and it's really not replicated elsewhere? Thank you for the question. Through the Chair, I think that's pretty unique to the North Pacific process. I think across councils there are, you know, Most FMPs have goals and objectives.

A lot of them don't get frequently updated, and some councils have undertaken the work to, to revise their strategic guidance. The closest example I can think of is the Mid-Atlantic Council does have a strategic plan and a yearly implementation plan, but that's kind of cross-cutting across all the council's work and not specific to FMPs. So I think in terms of a yearly or a triennial review like we're talking about, this is pretty unique to our process.

Thank you. Any further questions?

Thank you for the presentation.

Okay.

It's okay if I go ahead.

Okay. Okay. So next up, I'll be giving a brief summary of the Ecosystem Committee's meeting. We held a— well, this was actually our second Ecosystem Committee meeting. We held a first meeting of the reconstituted Ecosystem Committee back in March.

That was mostly an informational and introductory meeting, so I won't talk about that. We did include a little summary under staff tasking, so I'm happy to answer any questions about that initial meeting. Once we get to staff tasking. So our May meeting focused on two agenda items, so I'm going to split my report between those. First, we talked about the Groundfish Management Policy Review, and then we talked about the Climate Resilience Work Plan and discussion paper on alternative HCRs.

So I'll come back up when Dr. Stram gives that portion of the E2 report.

So, um, I'll, I'll keep this pretty concise. I just want to point out that in the committee report, we did include a redline summary of the Groundfish Groundfish Management Policy, and this includes all of the committee's detailed discussions and recommendations on potential changes. So I won't go through all of those in detail, but those are available to you, and I'm happy to answer questions on them. The committee's main recommendation was the Council do consider modifying the existing Groundfish Management Policy, with the caveat that this is as resources allow, and recognizing that an FMP amendment would be necessary to make any changes.

The committee also recommended the council not finalize these changes at this point by initiating an FMP amendment to allow for additional ecosystem committee discussion on specific revisions and wording. And this is particularly driven by discussions of two goals: Goal 3, preserve food web, and Goal 8, increase Alaska Native consultation. So I think a way to characterize this in the, the and the committee chairs may, uh, want to add to this, but the Ecosystem Committee thought about what sorts of revisions kind of meet the threshold or rise to the level of, um, suggesting that modifications to the entire management policy are appropriate. So there are, for example, smaller housekeeping-type corrections, but it was really the discussion of these two goals that led to the committee's recommendation that they'd like more time to think about this and develop the appropriate wording. So I'll focus on these just briefly.

Oops. So regarding Goal 3, this is worded as "Preserve food web." The group felt that it would be appropriate to revise this to focus on marine ecosystems, and that this would potentially be the place to incorporate climate resilience. In our discussion, we, we discussed that climate resilience could be embedded across all goals and objectives. It's really relevant to all of the council's work. But it's probably the best fit here if you were to kind of choose one place to track this work.

The group did feel that it would be helpful to have some more time to discuss the exact wording of these revisions, but they did think that the wording could be a place to capture or kind of tie in the work of the Climate Resilience Work Plan that Dr. Stramwell presents on, and that this would be a place to tie in healthy fisheries and communities in addition to sustainability, and that this could draw on and complement the council's ecosystem policy. So I mention this because across the ecosystem policy and the FEP goals and objectives, there's a lot of wording about how the council thinks about maintaining ecosystems and supporting productive ecosystems, and some of that language can be referenced here.

The other goal that was a subject of a lot of discussion was Goal 8, increase Alaska Native consultation. In this case, the term consultation The meaning— well, at the time the council adopted the word consultation through the 2000— or supported by the analysis in the 2004 PSEIS, the council used the term consultation very broadly to include things like participation, engagement, outreach, information sharing, and things like that. Whereas consultation has a very specific meaning referring to government-to-government consultations between NOAA and federally recognized tribes. So there's a mismatch here between the formal definition of consultation and as we use it in the council process and the way it was used kind of less formally at the time. So the group felt that the term engagement or something similar would be more appropriate here.

Another revision that we, we are— the group largely agreed on was under objective 36. So this is referring to local and traditional knowledge. The group felt that it would be appropriate, not appropriate. Using the same word twice, that the phrase "where appropriate" should be removed from this objective because it suggests that there's kind of a subjective element to when local and traditional knowledge should be included. And the group felt that, especially with the adoption of the Local and Traditional Knowledge Protocol, that we've— the Council has guidance on the appropriate incorporation and procedures for integrating information.

There were some other considerations we discussed that again led to the, the Ecosystem Committee wanting more time to really give some deeper thought to the appropriate wording here. The group talked about the importance of not just supporting engagement, but thinking about the impact and effectiveness of that engagement and recognizing that it's a two-way process. We also discussed that although the goal is structured as focusing on Alaska Native participation, This tends to be where the council tracks other examples of outreach and communication work that pertains to other groups that are not necessarily tribes. So this may be an opportunity to reorganize those a bit. And finally, while the council doesn't engage in consultations, it would be important for the wording of this revised goal and objectives to reflect that it's all— it's still important for this information to be available to the council at an appropriate and effective point in the process.

So, in summary, there's a lot more to the Ecosystem Committee's report. Again, happy to speak to any of those other specific suggestions, but these were the two discussion points that really rose to the top and led to the committee's desire to spend more time looking at this issue. So, in summary, the committee recommended the Council consider modifying the existing management policy, recommended the Council not finalize these changes at this point. Providing the Ecosystem Committee with more time to think about the appropriate wording. And additionally, the Committee recommended the Council task the Ecosystem Committee with a role in developing and reviewing plain language materials related to the Council's climate resilience work.

This was a recommendation that spans the two discussion topics at our May meeting, so this kind of cut across our discussions of the groundfish management policy and the harvest control rule work. And the Committee felt that it would be really important to do a, a good job of communicating why climate resilience matters to the Magnuson Act into the Council process and making sure that the materials that the Council is distributing really help put this in plain, accessible language. And the committee felt that they could really serve an important role helping ground truth what plain language means and also helping distribute materials through their networks. So that's it, and I'm happy to answer any questions.

Thank you again for this presentation. I'll ask if there are any questions or any additional comments, particularly from the co-chairs on the committee.

Nope, not at this time. Yes, Ms. Kimball. Thank you. Through the chair, I thank you for the report. I think that was a great summary of the Ecosystem Committee work on this item.

I just wanted to I guess emphasize what Ms. LaTonic said about, if you look at, I think it's starting page 5 of the Ecosystem Committee report, it, it really does provide like a red line strikeout of the changes that they already agreed they thought were worthwhile. And then that's in addition to the recommendation that we spend some more time before going through those changes, working on those couple goals and objectives. But they did have some very specific recommendations already in their work from the May meeting, so I just wanted to point the council to that. Even though they recommended not initiating an FMP amendment at this time.

Thank you for that, Ms. Kimball. And Mr. Pamplin. Thanks, thanks, Madam Chair, and I agree with what Ms. Kimball summarized and appreciate Ms. Latanich, your summary of the proceedings. Um, the way I understand it as well is, you know, we kind of cut, uh, we crossed the threshold from the committee's recommendation on, on recommending pursuing an FMP amendment when time allows to incorporate these changes, especially on the couple areas that were identified. But it would still be a— take the time to look at the— you know, once we crack it open, take a look at all the goals and objectives.

So we identified some areas of emphasis, but I think that there is some other areas that the committee might want to explore further.

Thank you for that, Mr. Pamplin.

Yeah, not seeing any other hands up or questions at this point. Thank you for all of your work on this and your assistance in the committee process, as well as the leadership from Mr. Pamplin and Ms. Kimball.

Thank you.

So that'll bring us to our AP report. Good morning, Madam Chair, members of the council. For the record, my name is Chelsea Riddell, Co-Vice Chair of the Advisory Panel, and I'm here to give the AP report on the groundfish— on E1 groundfish management policy.

Goals and objectives.

The AP motion reads, the AP supports the Ecosystem Committee recommendations to modify the language of the groundfish management policy and to task the EC with further developing specific recommendations for council and AP review. The motion passed unanimously. And with that, I can take any questions.

Are there any questions on the AP report? Yes, Miss Kimball. Thank you. I just wondered, thanks for the report, Miss Riddell, if the AP discussed similarly to the Ecosystem Committee, like, the urgency or need to take this up, the priority that the Ecosystem Committee was pretty clear that they didn't see a dire need to do an FMP amendment, which was one of the reasons that they thought they could use some more time. Um, but was that discussion happening in the AP as well about the priority need to move on this?

Thank you for the question, Ms. Kimball, through the chair. Um, the AP didn't have extensive discussion, but just generally aligned themselves with, um, the, the environment ecosystem committee and thought that they were on the right track, um, with reviewing it. So there wasn't an extensive discussion though.

Any further questions on the AP report? Thank you, Ms. Riddell. So I forgot to announce that our public testimony sign-up would be closing on E1 after the AP report. So I'll give an extra 3 minutes here for anyone wishing to sign up on E1. Let's come back at 8:40.

We'll do a quick stand down and please sign up if you'd like to testify, and we will begin public testimony in about 3 minutes. Thank you.

Welcome back, everyone. So we're ready to begin our public testimony on E1.

As a reminder, individuals and companies will have 3 minutes to testify, organizations and associations 6 minutes. We have 5 people signed up to testify, starting with Therese Vicente, followed by Jim Simon.

Good morning, Madam Chair, members of the council. You're almost there.

Thank you for the opportunity to testify. By way of introduction, my name is Therese Vicente. I'm the Policy and Programs Director for the Kuskokwim River Intertribal Fish Commission, which is an intertribal nonprofit that seeks to support the needs of our federally recognized tribes in the Kuskokwim River watershed in fisheries management, research, and monitoring. As guided by our tribe's knowledge and values, as well as the best available Western science.

The Fish Commission asks the council to not give the groundfish management policy final approval at this meeting, but to task the Ecosystem Committee with updating the policy statement, goals, and objectives to be more reflective of the council's intents for ecosystem-based fisheries management and including local knowledge, traditional knowledge, and subsistence information in the suite of best available science.

Part of the Ecosystem Committee's work should be identifying how the different objectives interact and relate with one another. For instance, under Goal 3, whether that maintains its current name to preserve food web or is altered to focus on ecosystem and climate resilience, there should be objectives related to reducing bycatch and considering the condition of species caught as bycatch, objectives related to including indicators from LK and TK holders as part of the human-fish ecosystem, as well as limiting impacts to ocean habitat. These are all foundational parts of the ecosystem and of ecosystem-based fisheries management, so they shouldn't be siloed from one another into different goals. Or consider under Goal 8 to increase the council's inclusion of Alaska Native people and knowledge systems in its processes. Is this meant to be a checklist of tasks from the LKTKS protocol to complete outside of other council activities?

Or is it rather a set of living guidelines for the Council to bring to the forefront Alaska Native knowledge, values, and communities when deliberating, deliberating bycatch reduction measures and habitat preservation and protections and promoting sustainable fisheries and eco— and communities? The Council and agencies should work not just through the Ecosystem Committee to update Goal 8 and incorporate the essence of its objectives throughout,, but they should work directly with Alaska Native tribes and tribal organizations through consultation and engagement sessions. The council should also task the East Ecosystem Committee with considering new goals and objectives to add. Two that the Fish Commission mentioned in our written comment are related to providing transparent communications about fishery management data, decision-making processes, and priorities. As well as prioritizing participation in gravel-to-gravel recovery efforts for wild Alaska salmon.

The Ecosystem Committee is also an appropriate forum for envisioning new activities or products needed to support the goals and objectives in this policy, and it would be wise to task them to do so. Zooming out to the big picture, this policy statement and the suite of objectives should be guiding all of the work the council all of the work of the council, and the Kuskokwim Fish Commission urges the council to reflect on whether that is the case, particularly when it comes to prioritizing habitat protections, bycatch reductions, and providing sustainable opportunities for subsistence communities fishing on the same level as promoting the optimum yield of large-scale trawl fisheries. Are your values, priorities, and actions truly aligning with this policy statement, goals, and objectives? This warrants critical reflection. And one final comment related to Goal 6.

The Kuskokwim Fish Commission urges the council to keep in mind that static marine protected areas are still a valuable tool for protecting sensitive habitat for marine species, from coral gardens to marine mammal feeding areas. The Ecosystem Committee's discussion notes state that the idea to replace marine protected area language with area-based management does not exclude these static closure areas, but this does raise concern for the Fish Commission that the Council intends to move slowly— excuse me— to move solely toward trawl industry-developed and industry-led dynamic closure areas. We do not want to see more support for industry self-management because this leaves little room for transparency and public and regulatory oversight. Thank you for your time today.

Thank you very much for your testimony. Miss Gohn.

Thank you, Madam Chair, and thank you, Miss Vicente, for your testimony. Um, you spoke a bit to making sure we're looking at the trade-offs that are happening in our actions, and I know as a council we struggle with that across actions that we're taking. We often look at the fishery that we're directly regulating, but then looking at other impacts to other fisheries or subsistence users are more— it's more challenging for us to capture. Do you have suggestions on how to do that better and kind of capture those trade-offs?

Thank you, Ms. Goen, for the question. Through the chair, I think that's a really good question, and In the work that I helped the Kuskokwim Fish Commission do in the chum salmon bycatch action, it became apparent to me that the current structure and laws and policies guiding this council to really focus on data and information and analyses solely related to directed fisheries, it does leave out impacted fisheries, impacted fish species, which are not targeted by the fisheries that the Council directly manages. And I have a better understanding of, you know, why that is, the policies and the laws that this Council must adhere to, but I think it does leave some big gaps in the Council's ability to be able to fully embody, embrace enact ecosystem-based fishery management. Like, there cannot be true ecosystem-based fishery management in the North Pacific without considering salmon and salmon communities and their knowledge, without considering marine mammals and other— the many other species that the Council manages as bycatch. Or as other targeted fisheries, but then sees as bycatch in, you know, in different fisheries.

So I don't know that I have a concrete proposal right now, you know, for how to better do that. It probably takes a fundamental look at how some of these policies and the guidelines structure the Council's focus on the directed fishery. That could be something for the Ecosystem Committee to engage in more as it looks through this document and considers updates to this document to see how it could better incorporate this information, including about impacts to non-target species and communities that depend on those species. So I hope that helps a little bit, but I'm definitely happy to think more about that.

Yes, Ms. Kimball. Thank you. Thank you for your testimony. Um, a couple of things that you mentioned as, as including, um, I guess I wanted to pursue that a little bit about providing transparency and communication and support for other initiatives. And, and I think that's part of the hard part of this exercise is in the— these goals and objectives have been used to focus our management measures in an FMP but not capture everything the council doing or support for, you know, research or things like that.

I wonder, I guess my question is, is this a worthwhile exercise or is it just confusing to the public to list these things but not list everything we do in one place? Because I think some of the feedback we can get, it wouldn't fit in an FMP trying to guide a management measure. But it might fit in how the council does business or approaches the public or things like that. And I guess, is that— that's maybe not a fair question, um, Ms. Vincente, but if you could answer it, I just want to see if this is still worthwhile to the public because it's not something we have to do. And if it's just— if it causes more confusion than value, I would love to hear that.

Through the chair, thanks, Ms. Kimball. Just a clarification for me, when you say this exercise, is that updating the, the policy document, or is that considering transparent communications? Or I just want to make sure I'm understanding what you're asking. Yes, very fair. I just meant like, have— doing this, having management goals and objectives, um, that we line out in a separate document and review every 3 years, just even having that.

Thank you, that's helpful. Um, through the chair, I think it is. I, I think it's always important to, you know, look at what you have stated as your policy approach, your goals, and how you intend to enact those goals, and to review them regularly. The 3-year process makes sense to me. It gives some time for consideration of, you know, new management ideas, new management actions, new research and information, new people and communities engaging in this process and what their desires are for the North Pacific.

So I do think it's a worthwhile exercise to reflect on these and see if they're both— not to use the same word, but reflective of the council's, you know, values and current actions, but also guidelines for, for future actions. And I understand keeping them high level. Yeah, so that they can, um, you know, be broadly transferred to different actions. Um, but I also think there's value, as stated in my testimony, to making sure that they're interrelated and interconnected with one another. So this is really a holistic guiding document for the council and its actions.

And then to your point on transparent communications, I mean, I, I see your point that it's not maybe as often about the management, um, documents or management plans that need more transparent communication. It's often about the research. But I do think if you make it an objective or a goal to have more transparent communications, that can guide all of the council's products, um, because, you know, newer stakeholders, newer people following this process, it's it's quite confusing if you come in from the outside, whether that's about its research or about how the process works. And I think the Council and its staff have, um, done many things to try to make the process more transparent and approachable, but more could be done. And stating that as a very clear goal and objective, I think, could really help guide some of the Council's actions towards that.

So hopefully that's helpful.

Okay, thank you for your testimony. So Jim Simon is up next, followed by Sarah Webster.

Pardon me. Good morning, Madam Chair, members of the council. Uh, thank you for the opportunity to speak to you today about, uh, agenda item E1. I will also briefly make mention, um, of E2 because I have to head to the airport, but, um, I'm the policy director of of the Yukon River Intertribal Fish Commission, and we represent the tribes and First Nations of the Yukon River drainage in Alaska and Canada in fishery stewardship and advocacy. Our member tribes are experiencing yet another year of severely depression of kinshom salmon returns with subsistence fishery closures continuing to devastate food security, cultural practices and traditions, and community wellbeing throughout the watershed.

The ongoing collapse of these stocks suggests that the Council should treat Yukon River salmon not as simply as incidentally bycatch concerns, but as ecosystem indicators with direct management implications for directed ground fisheries in the Bering Sea. And, um, you know, with my extended engagement professionally as a member of the Department of Fish and Game, the AYK Regional Supervisor for 14 years, and then my service to the various intertribal organizations since my departure from the department almost 10 years ago, I think this is one of the most complicated systems to engage in. So I definitely support the continuation of the groundfish management policy. Because— and, and, but I also do support the efforts that, um, Councilmember, uh, Miss Kimball suggested, that integrating, uh, this policy within larger frameworks to, to help make it more accessible, this process more accessible. Um, just my phone has been blowing up since yesterday, and with thanks of people who have been in the room with PhDs, etc., who feel now that, like, yeah, they actually deserve to have a space here and a voice in this process.

So I'm— I appreciate that, and I hope all of you do too. Um, the, the Canadian First Nations on the Yukon River are connected to the North Bering Sea ecosystem, and, and I think the compartmentalization and the species-specific approaches of this council do tend to to sort of make it difficult to maintain this bigger perspective of ecosystem services and ecosystem-based management, which I believe is what you have been striving for. And, um, so I think it's important to, to consider larger perspectives in ecosystem-based management and I'm here in part because of the Gravel to Gravel initiative, one of 9 keystone initiatives in the United States that's looking at the northern Bering Sea and trying to restore salmon populations and ecosystems to ensure that tribes and First Nations can, can continue to practice their ways of life. And, you know, it's formalized through an agreement with many of the Department of Interior agencies, and I'm very disappointed that, um, the NOAA Fisheries chose not to be part of that process because our salmon spend— many of our stocks spend most of their life in your jurisdiction. And so the overall larger fragmentation and species-specific focus of this council is, is understandable because of the complexities involved, I'd like to see definitely the Ecosystem Committee spend some more time revising the Groundfish Management Policy.

I agree with the AP's motion there.

I, I've reviewed the red line and actually have made my own red line to that document because, you know, suggesting that the precautionary management approach is recent is sort of silly. That needs to be updated. It's over 30 years old and coming from the United Nations Food and Agriculture Organization. And I think, I think that topic in particular could use some expansion because, um, I, as I've testified before this council previously, um, when I teach my classes in the University of Alaska system. And the way I have been taught about how to look at precautionary management approach in face of uncertainty seems to be that, that we don't necessarily have the same perspective there.

So I think diving into that a little bit and to the literature to update that and modernize that aspect of the policy would be very valuable. And, um, I, I have learned a lot and I appreciate the engagement of staff and and council members with some of my colleagues here to understand that bycatch, even it's, you know, it got its own goal within the groundfish management policy, but that it's not really the proper place, I guess, to be considered in harvest control rules, and that is more in the TAC setting process. So I'd really encourage the council to to do a parallel process within tax setting, uh, as you, uh, hopefully will be embarking on with harvest control rules for, uh, setting ABCs, etc. And, um, I'd like to thank the Chair for her generosity, um, uh, in, in testimonies, just as I have thanked her before in, in, um, the graciousness that you've provided to one of our tribal elders, Benedict Jones, if you may remember. And unfortunately, we have now lost him.

And, uh, I really appreciate my relationships with a number of you, and, uh, thank you for your service.

Thank you very much for your testimony, Dr. Simon.

And we are very saddened to hear of the passing of Mr. Jones. Are there any questions? Yes, Ms. Kimball. Thank you. Thank you for your testimony.

And mine's really more technical. Do you think if the Ecosystem Committee took this up again, I mean, that would be an opportunity for you to provide comment? You mentioned already having some redline strikeouts of your own, um, just working through the Ecosystem Committee to consider those those kinds of changes first before coming to the council seem like a good approach to you? Yeah, thank you, uh, through the chair, thank you for the question, um, Miss Kimball. Um, I myself am, am fortunate because my supervisor, um, Craig Chifluk, is a member of the Ecosystem Committee, so I have already provided my red line to him for an upcoming Ecosystem Committee meeting.

But I do, and I I was thinking about it as I was walking in down the hill today. Um, you know, I don't know if— I'm trying to remember, there was some discussions about perhaps having a public workshop, you know, prior to an ecosystem committee. But then, I'm sorry, I couldn't remember if that was specifically on this topic, um, because half of my day I was dealing with a First Nation in Canada having concerns about what's happening here as well as within Alaskan waters. So I'm multitasking regularly, which is also why I can't spend all of my work time, you know, on, on council products. But I think it is worth some consideration as to whether or not there should be a public engagement opportunity, because not all have the opportunity to, to pass it on to their boss who's on the committee.

Thank you for your testimony.

Sarah Webster is up next, followed by Nick Jacek.

Good morning, Madam Chair and members of the council. For the record, my name is Sarah Webster, and I am the science projects director for the Alaska Seafood Cooperative. Representing the Amendment 80 non-pollutant trawl catcher processor fleet. It's been a long meeting, so I'll try to keep my comments pretty brief. Probably not that brief though, sorry.

Uh, we did submit a comment letter under this agenda item, so I'll be speaking to that comment letter. And I just want to note right off the bat that we do support the AP recommendation to task the Ecosystem Committee with further developing potential revisions to the Groundfish Management Policy for Council review. Our comments in our letter really focused on Goal 6 and Objective 26. Goal 6 is to reduce and avoid impacts to habitat, and we just suggest consideration of the phrase long-term adverse impacts to better align with EFH mandates and with the fishing effects model framework. Um, I think more importantly, we recommended strengthening the language around Objective 26 6, which calls for the council to review and evaluate the efficacy of existing habitat protection measures.

One of the themes that was identified in, uh, this report is the durability of FMP guidance. And while many of these policies have remained durable, some of the longstanding area-based management measures, I think, warrant some additional review. Um, the council has implemented numerous area closures and other spatial management measures to address a wide variety of conservation concerns. The measures were developed using the best available science, the management priorities, and the fishing practices at that time, but some of those management measures are now decades old, and since then the science has advanced, ecosystems have changed, many of the fisheries have been rationalized, fishing gear and operational practices have evolved, um, and management objectives have expanded. So I think importantly, the groundfish management policy should really help to ensure that area-based management measures are periodically evaluated to ensure that they remain purposeful, effective, and responsive to the changing conditions.

I think we saw some of this play out this meeting in Alternative 3 in the Gulf of Alaska Tanner crab analysis. It's a good example of, of how this can be really challenging., and there are numerous other examples throughout the North Pacific Fishery Management System. So just as the ecosystem continues its review of the groundfish management policy, I really would encourage consideration of Objective 26 and also Goal 6, and whether Objective 26 in particular, in particular, should more explicitly recognize the importance of periodically evaluating not only the efficacy of habitat protection measures, but also just their continued appropriateness relative to current conditions. If the council does choose to move forward with the eco— with additional ecosystem committee review, we really hope that that review remains sufficiently broad to allow continued discussion of these adaptive management considerations, and we will look forward to participating in that process. Um, thanks.

I guess that's all I have for today, but I'd be happy to take questions. Thank you for your testimony. Are there any questions? Seeing none, thank you.

Nick Jacek is up next, followed by Linda Banken.

Good morning, Madam Chair, members of the council. My name is Nick Jacek. I live in Kenai, Alaska. I'm a citizen of the Kenaitze Indian Tribe, but today I am here representing Ocean Conservancy as the fisheries policy manager. I just want to say, starting, that we support updating the Groundfish Management Policy.

This is in line with both the Ecosystem Committee and AP recommendations, and we would specifically like to discuss updates to the Groundfish Management Policy goals 3, 4, and 8 to allow groundfish FMPs to more directly address climate variability and reduce productivity in the North Pacific. Moving forward with updated language for these goals will provide on-ramps so that groundfish FMPs can account for the well-being of Alaska's tribal communities and ensure the emphasized concern of climate drivers and impacts in marine food web dynamics and bolster bycatch mitigation efforts of sensitive and declining PSE species. With this position, I would like to provide further explanation for these points. Goal 3 addresses food web dynamics in the marine systems, and I would like to see— I would like to urge for the Council to incorporate climate-informed trends influencing the shifting dynamics of marine food webs. The scope of this should be holistic, addressing impacts of fishing pressure and reduced productivity across trophic levels, and utilizing relevant ecosystem-wide indicators to identify the data gaps and trends on fish productivity and health and the marine ecosystem.

As well, listed under the issues and actions for objective 13 in goal 3 is the implementation of the LKTKS protocol. Although the development of this protocol is a good first step, there's still more work to be done. I would urge for the council to support updating the language that incorporates this protocol as a primary method for engaging the diverse knowledge systems of tribal governments and knowledge holders of those who wish to engage in the process to have the opportunity to adequately represent their knowledge and values throughout the process. Goal 4 aims to reduce bycatch waste and incidental catch, and as PSC bycatch continues to be a core concern of many of Alaska's cultures and communities, both in 2004 when the Groundfish Management Policy was established, even to present day, we urge for the count— for the language under this goal to be updated to more directly address how spatial and temporal bycatch trends can inform tax setting each year. There has been a lot of conversation at this meeting about accounting for ecosystem considerations and tax setting, and if we are truly striving to manage using ecosystem approaches, bycatch should be one of the important elements of the groundfish specifications and tax setting processes.

It is important to consider bycatch mitigation as a continual proactive ecosystem consideration rather than just a cap compliance exercise. And with Goal 8, Goal 8 aims to further increase tribal engagement and consultation in the harvest specifications process. It was identified by the authors of the Groundfish Management Policy Review that the interpretation of tribal consultation is ambiguous and reflective of, quote, increased tribal engagement in the management process. This is paramount that the language in this goal resolves the ambiguity around consultation and aligns with the government-to-government obligations of Executive Order 13175. To understand the weak points of tribal consultations process, NOAA and the council should aim to develop the updated language in tandem with tribal governments to ensure that engagement is meaningful and consistent throughout the entire harvest specifications process.

In closing, I would like to reiterate that it is necessary for the Groundfish Management Policy to be updated to reflect the ecosystems and communities in Alaska struggling to respond to rapidly changing environmental conditions. The language of this 22-year-old policy should reflect the context it is applied in. Therefore, we stress that policy revisions should address climate shifts and food web dynamics and bycatch trends and the needs to solidify tribal consultation in this process. Thank you. Thank you very much for your testimony.

See if there are any questions. Yes, Ms. Kimball. Thank you. I Um, thank you for your testimony. Some of the suggestions are quite specific, and I, I guess, are you looking for a shift from the really broad overarching goals, um, and that approach that the council or previous councils have taken to this management policy into way more of the nitty-gritty, into the specific objectives?

I it's a— from what you explained, it seemed a little bit different than keeping very broad overarching goals and then mapping back to what we've been doing so we know if we're just meeting those goals, and, and putting maybe a lot more emphasis on these than we would otherwise. So if you could just explain your reasoning for being very specific, that would be helpful. Uh, yes, thank you through the chair, Ms. Kimball. Um, so I mean, going through the Ground Fish Management Policy Review, there's a lot of considerations that were had and also being— viewing the conversation that was happening at the Ecosystem Committee and a lot of the things that were coming into my mind throughout that conversation and what I've been considering going through just the process of this meeting in general and reviewing the documents is a really core focus towards both climate resilience and also towards increased participation and transparency with the public and also increased tribal consultation and engagement throughout this process as well. And as I've considered those aspects, I mean, they're— I mean, given I only have about 6 minutes, I could have identified more and that probably would have, you know, gone more into specifics.

But these are things that I wanted to initially highlight to address so that, you know, The updates to this language is able to really further identify and reflect the political and environmental reality of how this— of the, of the system and marine system that this policy currently manages.

Yes, Miss Cohen.

Thank you, Madam Chair, and thank you for your testimony.

You brought up a concept I'm interested in trying to better understand. You were talking about spatial temporal bycatch and how to inform tax setting by that, and it reminds me of our last agenda item where we were talking— one of the testifiers mentioned like moving from a 2D approach to a 3D approach, and I'm just wondering if you can explain a little bit more what you're thinking there with spatial temporal bycatch. Yes, uh, thank you for the question, Ms. Gowan, and through the chair, um, So I've been thinking about this a lot too, and you know, before outlining the importance of addressing managing bycatch and reducing it to the furthest extent practicable, you know, I will say I'm still fairly new to this process. I have started coming to Council meetings for roughly about 2.5 years now, and in my new role as the Fisheries Policy Manager at Ocean Conservancy, I've been actively tracking and testifying for since just October of last year. And I would say that something that has really come up, even from the very first meeting that I was there, even into this meeting as well, that one of the primary concerns, one of the primary focuses of agencies, industries, communities, tribes, is the concern of bycatch and how it can be considered and further considered in this process.

And as we, you know, see evolving research being developed and understanding, you know, patterns and trends of bycatch within specific fisheries, that exploring opportunities for that to be incorporated into the harvest specifications process, for that to additionally account for potential impacts.

Thank you again for your testimony.

Linda Benken is our last testifier on E1, and I think she's joining us remotely. Yeah, good morning, Madam Chair. I hope you can hear me okay. Yes, good morning. Thank you.

Yeah, Linda Benken, testifying for Alaska Longline Fishermen's Association. Um, I am a member of the Ecosystem Committee as well, and really grateful for the opportunity to be part of that process. I think I can keep my comments short. I really agree with most of the recommendations you've heard from previous testifiers and also the recommendations from the AP and the Ecosystem Committee relative to updating the groundfish management policy but not initiating action at this time because a lot of people see a need to work on this a bit more, in particular to work on the goals and Goal 3 and 8. As you've heard from other people, there's interest in improving how this policy references the engagement and consultations and inclusion of local and traditional knowledge and also to really update our policy relative to thinking about the ecosystem and how it is responding now under a— in this time of climate change and how we might improve our management to respond to that.

A previous testifier spoke to also looking at our static or existing habitat closure areas I would just say that if we do that, we really should be doing that in the context and with full awareness of the stress the ecosystem is under right now and how that is impacting habitat, and that we aren't looking necessarily at whether those are appropriate, but really whether they're adequate and whether we need to do more to protect that habitat and to provide buffers to the shocks. We anticipate that our to our ecosystem and fishery as well that we are already seeing and that we anticipate to become only more frequent in the future. I did want to raise, and I, I think we all struggle a bit to know where this fits, but this conversation around a parallel process to the Max ABC harvest control rule work that would allow more discussion of the tax setting process way, or the SPECS, and in particular the TAC setting process within that, and how we can help that process be more inclusive of ecosystem considerations and of non-target species, of economic and social and community stability concerns, and an avenue for more of those values to be incorporated um, I don't know whether that fits better under the next agenda item or here, but I wanted to raise it at this time to allow people a little bit of time to think about that. Um, thank you. That's, that's all I have, but I'm happy to answer questions.

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

Okay, not seeing any. Thank you for joining us this morning. Thank you. Okay, so that concludes our public testimony on E-1. Let's take a brief stand down, um, about 5 minutes.

We'll see if the council would like to provide any additional direction to staff. So, um, let's come back at 9:25, please. Thanks.

Council members, please come back to order.

I'll ask if the council would like to take action on E1. Ms. Kimball. Thank you, Madam Chair. I do have a motion.

Okay, we'll wait for that to come up on screen.

The motion reads: Upon review, the council finds that the groundfish management policy review document is complete and the council's work during the 3-year review period continues to generally align with and support the current management policy. The council also supports amending the BSAI and Gulf of Alaska groundfish fishery management plans to modernize and update the language in the management approach goals and objectives. The Council tasked the Ecosystem Committee to further review the current management policy and make recommendations to the Council prior to the Council initiating an FMP amendment. And with a second, I will speak briefly to it. Second.

Thank you, Mr. Pamplin, for the second. Thank you, Mr. Pamplin. Um, just very briefly, that the Ecosystem Committee did a, a pretty thorough review. I think there were some very specific changes as Ms. Latonich and and I pointed out, already provided in the ecosystem report. But given the fact that they thought some further input on two specific goals were warranted, specifically Goal 3 and 8, that stood out— they stood out to me as well, and I think to my co-chair, Mr. Pamplin, as well— that they could use some updating to reflect our previous task force actions related to LKTK subsistence and climate resilience.

I didn't see the purpose of initiating an FMP amendment at this time to make changes. I'd rather afford the ecosystem Ecosystem Committee an additional meeting to come up with some specific changes for those goals. I hope we can retain the approach of keeping those fairly broad, but I think the Ecosystem Committee is really the right place to start to, to make further recommendations on those changes. I'd also point out again that the Ecosystem Committee was very aware and, and respectful of staff limitations, and because these amendments are, are certainly very prudent and helpful for providing direction. They're not action forcing, so the committee wanted to pursue this as an amendment process as time and staff time allowed.

I, I very clearly said that we found that the groundfish policy review document is complete, and the purpose of stating that is that's one of our actions when we receive this every 3 years is, is the doc— the analysis or the evaluation document complete, or are we asking the council staff to do further work on that document? Amendment. So that's a separate action from deciding whether we want to initiate an amendment on changing any of the language for goals and objectives. I'm saying I find that this document is complete and we're not asking staff to do a second version of this document. Um, I think the only other thing I'd say is I really hope we do get more feedback, um, from the public and the regulated public before making amendments to this FMP.

The motion, of course, doesn't schedule an additional, ecosystem committee meeting yet. I think that's more appropriate in staff tasking and discussions between the staff and the chair, of course. So that's the rationale for the motion. I think it's very similar to the AP motion, um, with a few additional wording changes. Thank you.

Thank you, Ms. Kimball. Are there any questions on the motion? Any comments? Mr. Pamplin. Thanks, Madam Chair, and thanks for the motion, Miss Kimball.

I really appreciate the work, uh, Miss Letanich, uh, completed in this triennial review. Um, the summary of actions in the 9 pages of Table 1 that the council has accomplished over the past couple decades, with the emphasis over the past 3 years, is just a great inventory of an impressive body of work. I recognize in forums like this, as we jump from agenda item to agenda item, meeting to meeting,, and we often revisit topics as they navigate our, our process gauntlet, that it's also important to pause and reflect on how much has been accomplished and whether or not we're addressing the goals and objectives we set for ourselves. This table, I agree with Ms. Kimball, the, the report is complete and it documents significant work and also just shows the leadership of this forum across both national and global fisheries. So as we're nearing the end of a long meeting and about to consider all the new work we might undertake in staff tasking, I just hope folks will review that report through that lens as well.

As for the groundfish policy goals and objectives, I'm eager to work with Ms. Kimball, Ms. Letanich, and the Ecosystem Committee to further refine the wording and bring back recommendations to this body. Thank you. Thank you, Mr. Pamplin. Any other comments?

Thank you both again for your work on the motion as well as your leadership on the Ecosystem Committee.

Is there any objection to the motion? Okay, seeing none, that motion passes without objection. Any further actions?

Anyone? Seeing none, that brings us to our E2 presentation.

Dr. Stram.

Good morning, Madam Chairman, members of the council, Diana Stram, council staff. We're on agenda item E2, a review of an update on the council's climate work plan, and then an update and a review of the discussion paper on alternative harvest control rules. With me online is Dr. Kirsten Holzman, my counterpart at the Alaska Fisheries Science Center. I'll be providing the presentation, but she is also available for questions or additional information as we walk through this. I would note that in the interest of time, I have, um, curtailed much of the background information out of this whole presentation.

It's all appended as extra slides. We are happy to answer any questions, but in the interest of the council's timeline today, we've compressed our presentation significantly.

There's 2 items then under this agenda item. Again, a, a brief review of how we have put together a tracking tool for the council's work plan focused around the 4 initial elements, and then the detailed discussion paper that you have in front of you. That's one element of the council's climate work plan regarding development of alternative harvest control rules.

Under the climate work plan, then that's the first document that you have, um, under E2, um, just going through the development of the work plan stemming from the council's actions in December of 2024.

4. I'll show a brief overview of the 4 elements and then the spreadsheet tracking tool that we've put together and our coordination with the Changing Ecosystems and Fisheries Initiative at NOAA Fisheries as well.

So just to remind you, in terms of your December 2024 council motion and the 4 elements, initial elements of the council's work plan, we've renumbered them A through D in order to better track them in our tracking tool, but those are the, the 4 elements that you identified in your motion. Just in brief, that includes incorporating climate forecast-linked management advice, incorporating climate-driven interactions and cascading impacts through the use of ecosystem indicators and models, considering and incorporating dynamic management tools to increase in-season adaptation capacity, and then what we'll talk a little bit more about today with regards to climate-informed biomass targets and climate robust or forecast-informed harvest control rules.

We have put together, together with AFSC and regional office staff, a tracking tool. So what you have in your, in your document is a 2-page summary of the 2025-2026 initial tracking that we've been doing on each of these elements. I'm just going to walk through the format of it. Looking, um, and if the council has any feedback in terms of the format of it or the periodicity for review. It's our intention to update this twice a year and provide it to you under staff tasking.

Again, this is focused on 2025-2026, and I would just note the way that we've organized this. We, we have, um, let me just move to the table. I'm just going to walk through each of these. Then is listed under a key element, and then we've listed another column for what the council product is that the council will review this agenda when this when this product will come to the council and in what form. We have a brief summary of product details, but if you go to Section 3 of your document, there's— each is annotated by the numbering system and includes more information and links as, as possible to more information on that product detail.

We've also categorized them under new, existing, and modified. And here I just say that the— we have existing operational, which are ongoing projects, a modification to existing— that means it's something that's ongoing but has new changes or updates being made currently— new and development indicates a project where work's begun but it's not yet available for review, completed projects, and then potential projects. So we, because we decided to do this through what we know you will, will be coming forward by the end of 2026, you won't see anything in the spreadsheet right now that's listed as potential. We have filled out a much broader spreadsheet that includes all those potential projects, but if they're not coming online before the end of 2026, they will not show up in the spreadsheet that's being made publicly available under this agenda item. I would note that that does include, as you heard in your SSC report, that Go A Climb does not appear in this version of the spreadsheet.

That is, it is in the, the broader spreadsheet, but their timeline, it was not producing something by the end of 2026, and that's why it's not included included in here. Um, and just to note for you, then the way that you can read this is when you look at the element and how it's numbered, for instance, Element A1, Climate Science Brief, one-pager, SEFI, and then you can go to the Section 3 and find more information on it, as well as a link to the pilot version of this. So this is something that's listed as modification to existing. That's because you did have a two-page climate brief in 2024. During your specification cycle.

That was not possible in 2025 due to the government shutdown, but we are anticipating that you will see an updated version of that during specifications in 2026.

And one other thing before I move off of this, again, this is just a brief orientation to you of this. Um, if you're looking at the numbering system that you see and things are non-sequential, that's just indicating that because this is a broader spreadsheet than the ones that we've called forward here, that just means that that's one of the potential projects that is not yet— the details are not yet being shared publicly, but that that is in the, in the docket. So, for instance, on this page, A2, 3 are not shown in here, and because those are items that are in the potential, and so we've filtered this for things that are available either through 2025 or by the end of 2026.

And just to remind you that we're working with the Alaska Fishery Science Center and the regional office to provide these This was our attempt to comprehensively show the council all of the things that are ongoing, either council-initiated, AFSC regional office. We did a, a pretty good job of casting a broad net to try to compile all of this, but we can't promise that we're— we'll do a better— we'll continue to expand who we're speaking with to make sure that as we look at the council's elements and the items that fit under that, that we're continuing to update this in the broadest way possible to better represent to the council all of the ongoing things that are, that are going that fall under the elements of your work plan.

And I would just also note that council and regional office staff are also included in the SEFI team, as well as on the Alaska Climate Team for coordinating and communicating climate activities. Madam Chair, that's all I have on the work plan. Can pause if there's any— Thank you. And Ms. Kimball. Thank you, and thank you, Dr. Stram, for providing this.

And, um, I feel like this is really similar to what the council has been looking for to try to track all of the climate-related actions. I was going to ask about the decision to limit it to items that have already been initiated. It says in here that items planned but not yet started or potential items aren't included. So would the— all of the council's direction on specific items related to climate be included, or are you just leaving out the ones that maybe the Science Center is going to continue to work on but are not yet in the queue? I just wanted to find a way to track what the council's already initiated at the very least.

Thank you for the question. Through the chair, yes, Ms. Kimball, we are including all the council's actions, or we're trying to. The reason for not including— this was our first attempt to do this, and so we decided to freeze the timing for the end of 2026. When it's an Alaska Fishery Science Center activity, and unless we have received approval to indicate that that will be coming forward at a certain time, we haven't included it. And that's why it was included in potential, because we weren't sure in terms of staffing and funding, and there was a desire to not include things that, that seemed uncertain given budget and things.

But if there's an actual— if there's a council-initiated thing or regulatory amendment or anything like that from the regional office, we can certainly include that. We just— we were trying to— we were struggling with how long to go out in terms of the timing of, um, of when you could look at those, those tools. We're also experimenting with how we could make this available and searchable on the council's website so that you could look at a certain project, and then we can embed more information on on different links and, and ways to get more information on it. And we're hoping that, again, pending the ability to report out on things that we're not in control of, that it would be something that you could search for a longer timeline and at least look for— for instance, if we know that the council has something on the docket in 2027, you could possibly search for 2027. You won't get the things at the Science Center that they are— that are uncertain, but the ones that we are able to report out on, we could Thank you.

I think that's really helpful, especially for the things that the council's already tasked. We do something like this for the observer monitoring programs, and even if it hasn't— doesn't have staff associated with it yet, it really just simply says, you know, work has not been initiated. But it does help us keep track of all the things we've already done. One, so we're not repetitive to staff, and two, for a public ability to follow something that's really hard to get your hands around. So I appreciate the work on this.

I think it's really great, and, and maybe hopefully something that we could attach, you know, in every meeting agenda at staff tasking. Not that it needs review, but it's just there as a reference. So thank you for your work. Thank you. We'll be sure to include that as we're moving forward.

And again, we appreciate any feedback, um, even outside of the meeting on how we're trying to put this together and how it could be most helpful.

Okay, with that, Madam Chair, I'm going to move on to the discussion paper on the harvest control rules and the treatment of risk and uncertainty in our harvest specifications process.

This is the outline in general of the paper. Anything that's in italics I have removed from the presentation because it is largely a description of our current status quo process. And in the interest of time, again, I've appended those slides. All the information is in the paper, but I'm not going over that. The intention of one of the goals of the paper was to come to a common understanding and make it very clear to the public how, how harvest specifications are set and how OFL and ABC and TAC are determined in our process, and to lay that out explicitly in terms of stock assessments, ABC setting, and TAC setting., as well as how risk and uncertainty is considered, because as we move towards consideration of alternative harvest controls, it gets increasingly complex.

And so I'm— I apologize that I'm skipping over a lot of that, but in the interest of time, again, I'm happy to answer questions, but I'm going to focus on the things that are new to the council process with a very brief overview of harvest control rules. In terms of considerations for the council at this meeting, there's, there's 3 different aspects. Projects. One is defining the objectives, and we'll get to this in a, in a little bit, um, in terms of the council defining a suite of objectives for, um, the, the harvest control rule team to work on refining harvest control rules as well as developing performance metrics that would align with those council-stated objectives. And that's the sort of thing that would help the council, um, in the future inform a purpose and need statement for this analysis.

The second is a discussion, and we have this with the SSC, with staff suggestions in terms of scalability of this analysis in order for us to continue to bring forward pieces of this so you can refine alternatives. We had some staff suggestions in terms of a subset of Tier 3 stocks for groundfish to move forward with. And then next, we're looking for some feedback on engagement and communication strategy. One thing that we've, we've come to realize is the importance of understanding, communicating our current process. It is complex, and it is not— until now, we have not had one comprehensive place to describe start to finish how that happens.

And so that was another goal and objective of doing this paper was to have a resource for folks to read on how exactly does OFL ABC intact get set in our process for both groundfish and for crab. And then, so given that, it seems that there is a need for a targeted engagement communication strategy for this effort so that when we move forward off of our current process, that, that needs better explanation to the public and the stakeholders, as well as when and why and for which stocks we would move to alternative harvest control rules. There's also, in terms of engagement communication, a need for stakeholder involvement in refining performance metrics. I'll get to that at the very end, but once we have defined Council objectives for harvest control rules that might be in conflict with each other, we then look at refining— at developing performance metrics so that you could evaluate how well different harvest control address specific council objectives using these metrics, and for that we need input from stakeholders to ensure that we're— what performance metrics we are developing are actually aligning with the way that people view how meeting that objective looks like.

Just briefly, in terms of considerations of risk and uncertainty, the council considers treatment of risk and uncertainty in the harvest specifications for groundfish and for crab. Crab, that falls into both the overfishing limit and the acceptable biological catch that comes out of the SSC, as well as treatment of risk and uncertainty in setting your total allowable catch. For groundfish, that's solely under the jurisdiction of the council. For crab stocks, that's a Category 2 measure under our crab FMP and set by the state of Alaska. And just to remind you, in terms of the definitions of risk and uncertainty, uncertainty refers to a lack of information, a relative lack of information, or confidence in the reliability of that information.

Whereas risk is looking at something like the likelihood of an adverse event and the severity of the consequences. So given a certain characterization of uncertainty, what are you going to do about it? How concerned are you? Are you going to be risk-averse or, or less risk-averse in addressing that? That's important as it relates to the ABC control rule, because the ABC control rule by its nature is both a science and a policy decision in terms of the treatment of both risk and uncertainty.

This is Section 2 of your paper. Again, I'm only going over a subset of it, so I'm going to skip over much of the information in it and just go straight to the harvest controls that we use. This is a slightly modified schematic of the one that is in your paper. This is the Tier 3 harvest control rule that we use for groundfish stocks. I just want to orient you to it because when we go through the alternative harvest control rules, you will have this as the backdrop of it.

So just to show you on a very coarse basis, it is a measure of spawning stock biomass compared with a fishing mortality rate. So it's a calculation of a fishing mortality rate. It's more complicated than that in the, in the calculation itself, but if you're just thinking about it as the spawning stock biomass and a fishing mortality rate that's applied to it, for our purposes we have a sloping control rule for both OFL and ABC. The kink in that control rule then, what it does is it provides automatic rebuilding of the stock when you are below a threshold. The threshold that we define in our groundfish FMP is 40% of unfished biomass, so B40, and that's what you see is that straight line where the OFL and the ABC both decline below that level.

Our actual definition of our target, or our BMSY, is B35, and that is the line that you see. The green represents biomass that is above B35. The shading in this graph, which is slightly different later on, this is meant to show you just stock status, not necessarily overfishing but anything to the right that's in green is above the target. So it's the biomass divided by the BMSY targets, that's why it's 1, and anything to the right of that is shaded green. Anything below that, um, between, um, 0.5 and 1 is, um, shaded in yellow, and below 0.5, that's our definition of minimum stock size threshold.

So anything below that dotted line there is considered overfished. We have one other precautionary measure that's built into our harvest controls, and that's the parameter on the x-axis, so that there's an alpha parameter that's set so that, that the line does not go through zero. It is offset so that it's a little bit more conservative and you have a steeper slope there. We also— for— there's an arrow pointing to the B20. If you recall, for Steller sea lion stocks, pollock, pecod, and atka mackerel, there is a directed fishery closure at 20% of unfished biomass, so the B20.

In comparison, one other thing I just want to note is there obviously is an ABC and an OFL control for groundfish with the buffer in between that's meant to reflect the uncertainty in the estimate of the OFL. This is the same similar design for the OFL control for our crab stocks. Notably, there is also an alpha parameter that is even higher than we have for groundfish, and then there's a beta parameter where there's also a directed fishery closure for crab stocks at 25% of the BMSY estimate. The— under our crab FMP, we have an OFL control rule. However, our maximum ABC control rule is set approximately equal to the OFL, and as we'll touch on, and you heard in your crab reports earlier this week, as a result of that, the ABCs for crab stocks have never been set using the control role.

They have always been set using a percentage buffer below it on a, on a sliding scale basis.

Dr. Stram, we have a question. Ms. Kimball. Thank you, Dr. Stram. If you could maybe go back to the groundfish one, just because there's a buffer there. So I just wanted to I've been learning more about this through your paper, things we should already know, but this is the HCR rules, the harvest control rules, only they are a calculation for a specific stock to set the OFL, the overfishing level, and the ABC, given the risk and uncertainty that we need to provide for in the Magnuson Act, so that we're protecting spawning stock biomass of the specific stock we're managing from becoming low enough to be in an overfished level.

Is that the general— I think the paper goes into TAC, um, as well, but the HCR itself does not determine TAC. We just know TAC needs to be set and cannot exceed ABC. Through the Chair, thank you for the question, Ms. Kimball. Yes, and I didn't— again, I'm sorry, but a lot of the slides that I took out have to do with the tier system, the way that the harvest controls are specified are specific by tier and they're specific by stock status. So all of those determinations go into that, but yes, the, the entire tier system for groundfish sets up your OFL and your ABC based on the information that's available by stock as well as the stock status in relation to these parameters, and then a maximum ABC control for OFL, for ABC is calculated from that.

That has nothing to do with the TAC level, that is solely the definition of the ABC is to accommodate the scientific uncertainty and the point estimate of the OFL. So looking at how uncertain you are to ensure it is also to prevent overfishing, that is why it is defined that way, is exceeding your ABC is a concern for overfishing because of the uncertainty in your estimate of the OFL. It's not considered overfishing, not until you exceed an OFL, but it's to accommodate that uncertainty. The rules for the, for tax setting are entirely different. They cannot, your TAC cannot exceed your ABC.

It can be set equal to it, and again, that gets into management uncertainty. But then we also have OI rules, OI ranges in both of our FMPs. And so the OI range for the Bering Sea is 1.4 to 2 million metric tons, and then you have a lower one in the Gulf of Alaska. The sum of your tax has to fall within that range. Change, though, and your individual species-specific TAC cannot exceed the ABC that's been recommended by the SSC.

Excuse me, another question, Mr. Pemblin. Thanks, Madam Chair. Dr. Stram, just, just one other element of this, just for my own clarification. Um, if a fishery exceeds OFL one year, we don't necessarily say it's overfishing yet. It's usually like a number of times a fishery has overfished as a rate, like 3 out of 5 years or something like that.

It depends on the stock and the FMP. Is that correct?

Through the Chair, Mr. Pamplin, and I might look to Ms. Watson as well. When, when an OFL is reached, we have measures to close the fishery. We have measures to close the fishery to prevent reaching the OFL. However, when the OFL is reached, all fishery, directed fishery for that stock and others that might catch it as bycatch, are closed by in-season management. We would then report the next year that overfishing did occur.

But I'm not— we don't— we have certain rules for ABC that are different from that. So our— I mean, maybe that's what you're referring to. So when we have an ACL, an annual catch limit, that under our FMPs we defined as the ABC, so the annual catch limit cannot— should not be exceeded more than once in 4 years. And if it is exceeded more than once in 4— in a 4-year period, we are supposed to go back and reevaluate our annual, our accountability measures that would prevent exceeding the ACL. So for instance, you will see an analysis in October at your meeting of in-season management measures to prevent exceeding the OFL— the ACL, because that has been exceeded in the, for the black-spotted ruffeye stock in the Bering Sea.

So the council initiated an action to look at increased in-season management authority The, the in-season management authority to close fisheries to prevent reaching an OFL already exists. What doesn't exist is the same authority for an ABC. Thanks for that clarification.

Okay, going on then, again, this section goes over a description of risk and uncertainty, where uncertainty is considered in a stock assessment, where risk and uncertainty are considered in the ABC setting,, where risk and uncertainty are considered in the tax setting and what the reason to look towards alternative harvest control rules at this point. Again, I'm only showing a subset of this section, so I'm only going to touch on a little bit of this. Getting at the idea of, of risk and uncertainty, again, this is a schematic that is developed and that we developed that mimics the National Standard 1 schematic from NOAA Fisheries, and this is directly from the National Standard 1 guidelines. Science in terms of setting an ABC. So the ABC is intended to, again, reflect the uncertainty in the point estimate of the OFL.

The ABC is recommended to the council from the SSC, and that ABC— I cannot exceed that ABC. The ABC control rule, however, which sets the maximum ABC, is a blend of science and management. There's a feedback there, and this is where the council's risk policy on the treatment of uncertainty uncertainty comes into play because the ABC and the OFL control rule are policy decisions by the Council based on this balance of risk and uncertainty. The last time that you took up an amendment analysis to, to put into place harvest— maximum ABC controls for groundfish was under Amendments 56-56, where you looked at alternative harvest control rule formulations and alternative tier systems, and then the Council in conjunction with recommendations from your science, scientific and statistical committee on the validity of that analysis, as you would do with any other amendment analysis, selected a preferred alternative and move forward with that. And we amended our FMP, and those are the maximum ABC control rules that we currently use.

What we're looking at now is modifying them potentially for some tiers and some stocks, so that goes through the exact same amendment analysis and the policy consideration by the council that you would do for any amendment analysis. So there is a council role in setting the ABC control rule. Once that maximum ABC control rule has been implemented in the FMP, it is a mathematical aspect of the assessment that produces that max ABC in the assessment. And then the, the SSC, as they do now with the advice of their Assessment authors, plan teams can decide whether to use the maximum ABC or recommend a level below that. And as I'll get into really briefly, using risk tables recently, the— in recent years, the ABC has been recommended for many stocks over multiple years below that max ABC for a variety of reasons.

Once the ABC is received by the Council and recommended by the SSC to the council, you cannot exceed it. So where your policy comes— where your council direction and council policy comes in is in setting that maximum ABC control rule amongst a range of ones that you might consider. The other aspect to the council role is in setting TAC. That is entirely based on management uncertainty, which is basically the uncertainty of your management program to constrain the catch to the ACL. Again, an RFMP ABC equals ACL.

Ms. Kimball has a question. Thank you, Madam Chair. Thank you, Dr. Stram. On the, on the statement about the HDR choice is a policy decision by the council based on balance of risk and uncertainty. It's still the risk and uncertainty in our OFL and ABC determinations.

The risk around whether we got it right and saying that was the correct OFL for that particular species? Is that the uncertainty you're talking about? Through the chair, thank you, Ms. Kimball. Yes, it, it is still— your ABC is still characterizing the scientific uncertainty in your OFL. However, as you'll see, you can look at different formulations of that ABC control rule that may meet different objectives you may have for long-term sustainability, for addressing climate shocks.

The whole reason why we're looking at this— largely over the history of management in the North Pacific, the ABC controllers we have in place have been very successful, but we have found in recent years, primarily due to environment changing, environmental conditions, they're not always working. And that's why we're looking at tweaking them. But you're still looking at addressing that uncertainty. The reason that ABCs have been set below maximum ABC in recent for different stocks is because there's additional uncertainty in what the ABC control rule is calculating out as a maximum. And so there's a concern that either there's an issue with the assessment itself and model configuration, there's environmental conditions or recruitment conditions that aren't well represented by that ABC, and therefore there is a perception that there's additional uncertainty that's not being considered, and therefore the ABC is being set below that maximum, but again, based on uncertainty.

Ms. Kimball. Thank you. And so, so that means the choice is like, is there environmental information to— that would warrant changing the slope of the line in order to create a new harvest control rule that would put some of the uncertainty out of the risk table in a qualitative way and into the harvest control rule? In a quantitative way. I'm just trying to follow because I don't want to just come across as there's more uncertainty in the ecosystem, there's more dynamic variables there than we had before, there's climate shocks, and so we're just going to create more buffers.

What we're trying to do is transfer some of that buffer into a quantitative way in the harvest control rule, but correct me if I'm wrong. Through the chair, thank you, Ms. Kimball. No, that's exactly correct, and when we get to the examples, you'll see what we're trying to do right now is look at tweaks to the harvest control controls that better address that uncertainty because we have for a number of years found that for a number of stocks what we're, what we're applying is not sufficient for the situations that we're finding ourselves in. It's not, it's not matching the situation, the environmental conditions that we're in are not well represented by that ABC control rule currently, and that's why additional uncertainty is being considered. It doesn't mean that a new harvest control would remove any of that that, it means there may still be a use for risk tables, but ideally we would be better addressing that environmental component of the risk tables for marine heat waves, climate shocks, different long-term productivity issues, and therefore it would be less common to see reductions from Max ABC because more of that uncertainty is contained in the quantitative estimate of the ABC from the control rule.

Thank you. And that's still around transferring that uncertainty into the quantitative assessment, but still around protecting the spawning biomass for the stock that we're managing? That's the purpose? Through the chair, yes. And again, when you look at defining objectives for looking towards different harvest controls, you may have a suite of objectives.

They will always be to prevent overfishing. That is the primary primary, that is the primary purpose. That doesn't change. That is our objective now, and, and we're achieving it, preventing overfishing. But there might be other objectives that you're looking for that are not currently contained in our harvest controls, such as some of this environmental variability or fluctuations.

Thank you. And Ms. Baker. Thank you, Madam Chair. Thank you, Dr. Stram. And I think my question probably falls into the background information that you, you removed from this particular presentation, but I, I just really appreciate this slide.

I recognize our focus is on thinking about alternative harvest control rules, but this slide really clarifies for me the different types of uncertainty that we're dealing with in this process. And my, so my question is about the, the really the council's tax setting, and you very clearly said in your presentation, it's here on the slide, that, um, tax setting is focused on, uh, incorporating any management uncertainty, which, you know, usually would be a reduction of ABC to set the tax. Can you give some examples of that management uncertainty that we have used recently, or just to distinguish it from the scientific uncertainty that we're trying to capture in the harvest control rule? Thank you. Through the Chair, thank you for the question, Ms. Baker.

Yes, and I, I would say the, the good thing about this schematic is we're talking about everything above that line in the middle. That is where the harvest control for the ABC is. It is not in, in TAC setting. It's, um, there are stocks for which you set ABC equal to TAC. A lot of them are rationalized fisheries, fisheries for which you are fairly certain that you can manage to that TAC without exceeding that ABC.

There's many examples, particularly in the Bering Sea, where you set TAC below ABC, but that is based on the optimum yield range and the need to set below ABC because of the upper end of the range with the 2 million metric ton cap. There are other examples I think we can summarize, and there's, there's some information in the paper on on, on tax setting and examples of setting below the— setting TAC below the ABC that might have to do with just management constraints in the Gulf of Alaska with respect to reaching bycatch limits or market constraints. A lot of times that's market-related as well, if that helps.

Thank you.

Okay, backing up slightly, and I'm not going to go into a lot of detail on this, but as a backdrop, and there's more information in your paper on Section 3.1 on this. There are assessment changes, so this is outside of setting the ABC— I'm sorry, this is outside of the risk aspect and the policy aspect of setting the ABC. There are assessment changes that can annually change the ABC that are outside of this. These are strictly related to assessment modifications, and in general they fall into 3 broad levels: model structure modifications, and these are things that are reviewed by the plan teams and the SSC annually. Those model structure modifications, that's what we go through in the September-October timeframe of your plan team SSC meetings where the SSC reviews proposed models for an individual stock assessment and recommends which suite of models or which single model should go forward for the final assessment.

So that's something that can happen within an assessment year, and that can have— those model changes can have a dramatic effect on the ABC, that's the maximum ABC, as a result of that. There are also Biological reference point changes or the addition of new or revised data. That can be new data, revised time series, selectivity changes. That does not reflect a change in the model structure, but it still can impact the biological reference points. Those are not always reviewed by the plan teams in the SSC in the assessment cycle.

Sometimes there's new data that's input after the October meeting that, that makes— reflects in a change in the ABC for your final assessment. And then tier level changes are always reviewed reviewed at least within the, the assessment cycle by the SSC and plan team— September, October, November, December— before they're adopted. The most recent one was dropping EBS Pollock from Tier 1 to Tier 3. You'll also see a proposal this fall to drop Bering Sea Aleutian Islands Yellowfin Sole from Tier 1 to Tier 3. Those also have an effect on the ABC.

So that— it's important because there's a lot of moving pieces that these things are not going to necessarily change. That's not a reflection of environmental variability. That is a reflection of modified assessments and using the best available information and assessment moving forward.

Moving into then how ABCs are adjusted below maximum, there's more information in your document. You're familiar with the risk tables, the levels of concern, and the 4 categories that are included. So this is just a summary of the groundfish stocks where the ABC has been set below maximum from 2018 through 2024, and it gives you the percent reduction and then the risk table scores that are greater than 1. There is no formulaic representation of a risk table score to a buffer, but it tells you based on that where, which stocks have had this. And the point of this really is to show you that in recent years there have been a number of reductions below Max ABC by use of the risk tables.

They've also, there's been reductions below Max ABC uncertainty prior to the development of risk tables. Risk tables were developed in order to better characterize that relative uncertainty. The risk table speaks to the uncertainty in the— that is not captured by the assessment in those categories, and then what you do with that uncertainty is reflected in the, in the relative percentage buffer that's applied.

Briefly then, for crab, again, we don't have the ABC max ABC would be set at approximately equal to the OFL. So buffers alone have been used for crab stocks, and that just gives you a short history by crab stock. This table's in your— Table 4 in your document— of the variability for some stocks and how that buffer has, has changed over various years based on the estimated uncertainty that's not reflected in the OFL for those crab stocks.

Uh, briefly then, this is just a summary again of the, the 3 different things: assessment changes, below-max ABC changes, um, TAC changes, and the timeline for that. So talking about the assessment changes that we discussed, it's— they're very stock-specific dynamics. There's a scientific peer review that provides quality control on those assessment changes. It can seem less transparent to the public. All of these changes are always explained at plan team meetings when the assessment author provider provides the information in the assessment.

Usually they change over an extended time, but they, they can change within an assessment cycle. This does not have any direct Council action. The maximum ABC that is applied in the assessment is what's fixed, so that's what we're looking at possible changes to.

In terms of ABC changes from max ABC, this is more in the realm of what we're talking about here. Again, that's setting your ABC below the maximum permissible from the control rule. It can be done within an assessment cycle, um, usually drawing on information in the assessment or with the use of risk table scoring and justifications. Um, it is qualitative. The scoring and resulting reductions can be inconsistent across assessments.

There's no counsel involvement in how that ABC is set below maximum permissible. You also cannot recommend an ABC that is above the maximum permissible. Without considering an alternative HCR, and we will show you one alternative HCR that does allow that to fluctuate. And then again, TAC adjustments that can be done by the council within a single meeting without additional analysis, but different drawbacks there with respect to it can lack analytical basis and doesn't create lasting structural change.

Moving on to reasons for considering— oh, I'm sorry. A question, Ms. Kimball. Thank you. I hope this doesn't come across as too nitpicky, Dr. Strang, but would it be even more accurate under the approach to say ABC reductions from max ABC and TAC reductions from ABC? Like, there's only one direction that can go, and I think in, in thinking about how to be more communicative and transparent to the public, maybe we should consider our wording on that one.

Thanks. Thank you.

Okay, this is part of the— what's included in your Table 10. And again, this is what we've been struggling with for a number of years, which is the origin of this action, is that there's multiple stocks for which the application of the maximum ABC control rule has been problematic for a variety of reasons. We summarize some of these reasons for stocks. It can be recruitment variability, particularly when we're addressing um, irregularly large recruitment events. We've got prolonged recruitment failure for some stocks, increased natural mortality or elevated or event-driven, such as with cod stocks, environmental sensitivity of year-class strength, and then long-lived slow recovery, declining productivity stocks despite having large biomass.

Um, POP is a good example of that. Many of these have resulted in increased reliance on risk table ABC reductions to account for environmental changes. That's one category in the risk table. A lot of times the reduction has been pinned very much to the environmental changes that are outside of the assessment. And so again, just highlighting that's the council policy to— if you want to look at council policy in these, in the treatment of this kind of environmental uncertainty, it would lead you towards looking at modified harvest control controls.

I'm going to step through a couple of graphs. I would note the, the presentation that's posted to your agenda is updated from what was posted last night because for these figures, these figures are slightly updated from the version that was posted previously. Going back, this is again the schematic of your current harvest control rule for Tier 3 with the, the kink in the control rule at B40 and automatic building revision, automatic rebuilding provision as a result of that. Moving to one of the alternative harvest control rules, this is HCR 7. This is an analytical approach looking at trying to take into some of the considerations explicitly qualitatively from the risk table and turning it into a quantitative estimate.

So looking at species for which productivity is known to vary with environmental conditions. So this example then shows you a negative correlation. So again, And just to orient you, the, the dotted lines are our current OFL and ABC. That hard blue line then is what the ABC control rule under a situation where a stock has a negative correlation to the current environmental conditions or the expected environmental conditions. And the result of that is a lower, more shallow ABC control rule and also a shift in the and the kink in the control roll further to the right for better protection for the stock.

Similarly, this— oh, I'm sorry. Thank you, Dr. Strahm. Mr. Pamplin.

Thanks, Madam Chair.

So in this particular scenario, if, for instance, there was like a heat wave alternative, you would— would it be that you'd still have your base HCR, but then when conditions reach a certain threshold, a different HCR is then triggered that depresses that line? Is that correct, or would you always have the alternative control rule be in effect? Through the Chair, Mr. Ramplin, thank you for the question. We had this conversation with the SSC We were discussing the idea of trigger thresholds to move to a different HCR. The feedback that we received from the SSC and, and that we've heard is that we might be better poised to look at more robust alternative harvest control rules rather than a trigger, looking at a robust harvest control rule.

And this is where we might be leaning towards more stock-specific because different stocks are going to respond differently to environmental conditions. And so if we have a robust control rule for a stock, just hypothetically for a cod stock, that we think would, would be more robust in the long term to fluctuating conditions, we would move to that harvest control rule, not switch back and forth. There was a lot of concern that's been expressed about what would trigger it, how arbitrary that might be, how well known those conditions would be, and so the whole point of it would be to to make sure that we run sufficient simulations to have confidence that that is a better control rule for a given stock under environmental conditions.

Thank you, Ms. Vanderhoeven. And then Ms. Kimball. Thank you, Madam Chair. Thank you, Dr. Stram. Um, it sounds like then the approach going forward, there's a lot data input you have because we don't know necessarily how stocks are likely to respond to some of the changes.

And so I guess I'm just trying to think through, do we anticipate having enough of the right information to be able to do that better than what we've been doing with the qualitative buffers?

Thank you. Through the Chair, Ms. Vanderhoeven, and I also, I apologize, I also want to pause to give my colleague a chance chance to respond as well, but we did have some of that discussion with the SSC. I think our current focus on 3 stocks— pollock, cod, and sablefish— are reflective of the ones for which we have better known environmental correlations, and so that's why we're trying to focus on the ones for which we do have that, that sort of information or that sort of environmental correlation or different information. But I did want to pause to see if Dr. Holzman wanted to add anything there as Yeah, through the chair, thanks, Diana, and hopefully you can hear me okay. Yet the, the goal of some of the ongoing simulation work that's taking place, and which will provide some update on in the fall, is looking specifically at these, these species that we do have some linkages and then testing those for this robustness.

So we'll be going through a variety of different parameters for this harvest control rule and then looking at that robustness against those future projections under— in a simulation setting.

Thank you. And Ms. Kimball. I just wonder, thank you through the chair, if you could try one more time to help me understand if, if, like, for, for Pequot in particular, like, in the Gulf, if we show a negative correlation with heat waves and, but when that turns around, I guess I still don't understand, are we still we're still stuck with the assumption that expected environmental conditions are poor. And so what— how are we dealing with the dynamic nature of the expected environmental conditions, not just the dynamic nature of the stock's reaction?

Thank you. Through the Chair, Ms. Kimball, I'm going to pause and see if Dr. Holzman wants to, to address that. Again, I would say that we were looking trigger mechanisms to move back and forth. And so I think that the point of a long-term robust control is to accommodate both positive and negative environmental conditions for that stock, but for one that has a higher correlation with negative events occurring. But again, there's another example here for positive events occurring and moving, having that, that fluctuate.

But Kirsten, did you want if you want to chime in more on that. Yeah, through the Chair, thank you. I think the question is a good one. The question is, do we need, or what performs better, a static/robust harvest control rule that's an alternative to the current one, or one that is dynamically linked to, for example, forecasts of marine heatwave conditions? And we're going to be looking at both of those.

Scenarios and simulating both, and so we'll have a better ability in the fall to articulate the trade-offs that are involved in those, especially around things like in ecosystem performance metrics and fishery performance metrics. So I hope that helps. At this point, the rationale behind the harvest control rule might be the same, trying to accommodate something like a marine heatwave shock, It's just whether or not there is a dynamic annually or every couple of years updated trigger, or if there is a static formulation of that alternative harvest control rule that's implemented. I hope that helps. Yes, thank you.

So again, same, same harvest control rule here, but looking at an example where there's a positive correlation with productivity. From expected environmental conditions. And again, here I would show you that this is where the, the kink then is shifted to the left. And this is again where we're looking at— previously we, we had sort of characterized this as only the ABC control, but I think we would be looking at both OFL and ABC because in this instance, if that shift resulted in setting a higher OFL and a higher ABC, and that might be for some stock where the, the correlation with the productivity under the expected conditions is higher and would warrant you wanting to be able to go both above the, the current harvest control rule as well as in the alternative situation below it.

Next, we're looking at harvest control rule that again buffers against environmental shocks, but looking at it from the standpoint of increased biomass reserves at high stock sizes. So what you see is the exact same harvest control rule we have currently when you're below B40, but when you're above B40, this shows an offset so that you catch— you cap catch at about B60. So again, the kink to the right, normally that would— under our current control rules, it's static. This would cap the catch at a catch level corresponding to B60. This is similar to— again, when we brought this forward a while ago, it's similar to what the realized fishing mortality rate is for Bering Sea pollock, and that's because of it bumping up against that 2 million metric ton cap.

And so you've effectively capped catch for Pollock at a level each year, and this would be what that looks like if you were doing that by design rather than as a result of the, um, the tax setting reaching the upper level of the million— 2 million metric ton cap. This is the same harvest control rule, but rather than having an offset, you start to cap catch at the level exactly right at the B40 level. And again, these are all for— these would be for stocks that would be more beneficial at higher stock sizes to have more of a biomass reserve. So it's not that you're, you're just capping the catch, you're not decreasing the catch level. And once you get past that, keeping in mind you're still multiplying by your relative spawning biomass.

And then HCR5 then is looking at buffering again for environmental shocks at high stock sizes. So again, same control below,, but a decrease above B40, and that might be for something with, again, environmental variability. Cod could be a good example of this as well.

So preliminary results so far of looking at simulations for these harvest control rules, that they might provide increased age class diversity, higher productivity states, and the fish biomass increase in larger fish and increased ecosystem and fishery productivity. The analysis that will come forward would be looking at the council's stated objectives and then the performance metrics that we would derive from those objectives to show the degree to which each alternative harvest control rule addresses the council's objectives. And so these are just preliminary results, but we would basically be looking at metrics to that effect, um, and others depending on the council's objectives for this action.

Um, pages 28 and 29 of your document provide some general overarching goals. That's something— these are the kind of things that you might fold into a purpose and need statement for this analysis, and then objectives that we would be looking at. These are just what we've heard in some of our, our planning meetings and our team discussions, but looking at some draft objectives for, say, sustainable biomass for groundfish and crab stocks, preventing overfishing. These are not necessarily different from your current ones. It's just looking at why we— what additional objectives we might be looking for.

So again, increased buffering against environmental shocks, potentially socioeconomic sustainability, transparency in the ABC setting process. That's getting at the relative— getting— removing some of the variability in the ABC setting process by virtue of using a control rule versus using risk tables that can change on a— the result of the risk tables changing annually. And then once those objectives are defined, this is— a lot of this information is contained in Appendix Appendix 3 of your documents. I'm not really going forward, going through it. I just wanted to describe what performance metrics mean, um, and that we would be defining performance metrics that would be aligned to those objectives.

So once we have an objective, for instance, looking at these, um, an objective for sustainable biomass and stability of yield, we would then look at what does a metric look like for that. Are we talking about the change in mean age or size What does stability mean in terms of an objective? This is part of where we need stakeholder input on this because we will come up with some draft metrics based on Council objectives, but then we need to run them through the interested stakeholders, potentially by, by fishery or by whichever stocks, to see is that— what does that— what metric would give you an idea of meeting that objective? And then the analysis will show to what degree different harvest control rules address different management objectives, and then you'll look at, you'll be able to view, they won't meet all of them equivalently, they'll meet some more than others depending on what you are, you as a policymaker, are looking at in the policy that you want from that management control rule.

Thank you, and Ms. Kimball. Thank you, Dr. Stroum. One of the We got this a long time ago, but one of the points in the SSC report was, was a request to simplify and shorten the number of metrics to make them more usable and transparent. And is that something that the team is going to consider how to do that, make these much more concise, or is that something the council needs to weigh in on at this meeting? Is that like a default assumption that you would take some of those SSC considerations into account?

Account. Thank you. Through the chair, Ms. Kimball, um, we have talked about the SSC's suggestions. I think at this point our process going forward would be to have— and this is not in, in conflict with the SSC's recommendations— we would have detailed objectives. There might be quite a lot of them, but in communication of how each HCR is meeting those objectives, we would synthesize it down to a, to a few that better represent the overall.

And I, I think the SSC did did note that they would anticipate there would be an appendix with multiple numerous objectives, and that's— that would be our starting point, would be the, the full suite of objectives. And then we would do our— we would synthesize those into some top ones to, to better address in communication.

Thank you. And Ms. Baker. Thank you, Madam Chair. And I wonder, Dr. Strand, My question is actually, I think, on the previous slide because I just want to make sure that I'm tracking through terminology for those of us maybe less enmeshed in the details of this. When, when you started the presentation, you said that for the ABC harvest control rules that we have under the current system, that actually includes includes science and policy considerations, because I think you said the council's risk policy is incorporated in that ABC harvest control rule.

Is it accurate to say that this list of objectives here is the current council risk policy, or is that something that— am I tracking that, or is there— because I don't think we have a harvest specifications risk policy as a separate document anywhere. It—. Should I understand that, that this is essentially what we have in our current system? Through the chair, thank you, Ms. Baker. Um, thanks for the question.

I, again, I would say these are the objectives that we just put forward. We're looking for council concurrence on, on objectives, and, and I think it's fair to say that how you define your objectives for this action would be defining the considerations that you want to look at in how a harvest controller, the harvest control rule is not going to contain, say, socioeconomic considerations. It's just that if that is an objective in conjunction with other objectives in looking at how well a harvest controller performs into the future, you would be measuring that, those results against the different objectives you have. It may be that preventing overfishing is, is the thing that you are the most concerned about, and so whichever harvest control rule does the best job of that, you're less concerned with some of these other objectives, or you might have different ranking in, in your mind in terms of selecting a policy. The policy that you select in the harvest control rule is the one that will best address your competing objectives for that action.

Thank you. And Ms. Kim Thank you. Thank you for allowing all the questions when we're wrapping our hands around this. But the thing I heard you say there is that you're not— you don't incorporate if one of your objectives is in the social realm, like you have here, societal realm, you don't incorporate that in a harvest control rule. You set an objective like that, and then you have to run all your simulations to see which one, which harvest control rule actually met that objective best.

So that's the point of having the objectives. You run these simulations and see under these scenarios, did we meet that one or did we only meet maintaining our biomass above a certain threshold so we don't exceed OFL? Through the chair, Ms. Kimball, yes, that's correct. That's the point of the objectives is to frame the analysis for, for us to be able to bring back to you the results of these harvest control. The harvest control rule is still just addressing the biological aspect of applying a fishing mortality rate.

The changing slope, the changing formulations of those are to tweak for better alignment with changes in productivity, environmental conditions, the desire for higher biomass, higher, more biomass reserves, but it is still a biological harvest control rule of a fishing mortality rate applied to spawning biomass, whether or not Not different formulations of that for an individual stock happen to meet some of these, your considerations and your objectives better or worse is what we would bring back in an analysis. It's also why we're trying to both get an idea of those objectives from the Council so that we can then begin to draft these performance metrics so that we can better understand how, what does achieving that objective look like as a metric. That doesn't change the harvest control rule, it just gives us a metric to come out of the analysis that helps us look at how well that achieves it. There are— I would point you to some of the information in the analysis and some of the— are in the discussion paper and some of the extra slides that show you some radar plots from the sablefish MSE that give you an idea of what that looks like in terms of how you would be mentally conceiving of meeting those objectives by a different harvest control rule.

Thank you. And Mr. Pamplin. Thanks, Madam Chair. Thank you, Chair. Dr. Strahm, I appreciate your patience as I just kind of go back to an earlier question that I had and also one that Ms. Kimball asked.

And that is, as you're looking for feedback from the council into this process, the idea of having an alternative harvest control rule that goes into effect when there's an environmental trigger versus developing what you described as the static, robust, the executive HCR that would be in, in effect from this point forward. Is that guidance that you would like for the council to engage in? Or to me, I just would like to know that if that conversation is still on the table, then I'm, then I'm satisfied. But otherwise, I don't know if we need to put our thumb on the scale on that one. Thanks.

Thank you. Through the chair, Mr. Pamplin, I think that's very much still on the table, and I think that then our next round, once we receive our feedback and our guidance coming out of this meeting, then we'll be meeting in trying to, to look at addressing what does that look like and how does, for an example, how does harvest control rule 7, where there's a, it could go up or down, what's going to trigger that and will that vary interannually, will that just be fixed for a stock? I think that's all very much on the table. Just to pause to make sure, Dr. Holzman, I'm not saying anything that you're not agreeing with.

Through the chair, thanks, Dana. No, That's correct. Thank you. And Ms. Gone. Thank you, Madam Chair, and thank you, Dr. Stram.

This is— it's really interesting work, and I know in crab we use a harvest control rule similar to number 7 for Tanner crab with a female dimmer depending on how the female population is doing. So I'm curious if you can explain very briefly on how this work would be applied in crab in particular? Thank you. Through the chair, Ms. Goehn. We've struggled with that.

We've struggled with it because we don't have an ABC control rule. So the control rule that you're speaking of is the harvest strategy by the state of Alaska. That's to set TAC. We are only looking at setting ABC, and for crab, we don't have— we would have to make some assumption of how ABC is being set because there is no quantitative control rule, it would be incorrect to just assume that TAC is— that, sorry, ABC is set at the maximum permissible for crab because it's not. So we have, we have somewhat struggled with that.

Our recommendation coming into this meeting that the SSC concurred on is to consider crab, to continue to consider crab in this section, but to consider it on a different timeframe as we try to work on on how best to characterize what our current system is so that we can compare it against a different harvest control rule. I think where we're leaning now is to try to work with some of the crab authors to see if some of the simulations for groundfish are applicable to crab to help us start to design how we might look at a similar analysis for crab while we continue to figure figure out how we address what status quo actually is for crab as it relates to an ABC, not a, not a, the TAC consideration from the state.

Thanks for that explanation, that's helpful. And then a second question kind of goes to a much higher level question that I'm grappling with, you know, under the new seafood competitiveness executive order, we are looking at how to maximize fishery trees in this region. And then here we're looking at potentially more buffers and conservation to balance out concern over environment, shifting environmental and climate impacts. So just kind of, um, can you speak briefly to that tension here that we're working through? Thank you, through the chair.

Thank you, Ms. Gowan. I, I think a good example of that is the HCR-7, where you are looking at above and below what's our current max ABC. And so looking at whether or not it, just to go back briefly, looking at whether or not there's situations that make sense to fish above where you can right now. And I think that's really one of the things that's interesting about it is it would directly get at that executive order in terms of there might be situations. This isn't being less precautionary, it just means that there's a, there are situations where being able to fish more at the current time might be preferable to only fishing less moving forward.

Sorry, just briefly, I only have one more slide after this. This is just our plan in terms of analytical plan going forward. I think that you've also heard from from the, the SSC as to a narrowing of the, the stocks, and there are considerations. But right now, in the fall, this is our internal working plan, but we have the sablefish MSE that is ongoing, and we've been trying to, to pull these two pieces together so that we're looking at this at the same time. The results of that MSE, which is a separate analysis, are going to be presented to the groundfish plan teams in the fall.

We're also hoping to update the plan teams on the current simulations of those harvest control rules, the alternative ones, for pollock and Pacific cod, potentially for some flatfish stocks for which that's available. And then long-term, in terms of 2027-28, looking at the, the go-a-climb and, and a-climb scenarios that are, are currently being formulated, I would say that pending council direction at this meeting, we would be looking towards this fall providing those alternative simulations and looking at developing performance metrics that would go along with council-defined objectives.

Which gets me to the last slide in terms of decision points for the council. Again, um, looking at identifying the overarching goal and associated objectives for this analysis to move towards drafting a purpose and need perhaps at a subsequent meeting. Again, keeping in mind those, those objectives can be competing. The point of the analysis is to show you, using the performance metrics, how different harvest control rules address those objectives. The scalability of the analysis I spoke about at the beginning of this, we are looking at— staff suggested and the SSC concurred— looking at a smaller group of stocks to start so that we can come back to you, not with just the formulation of the harvest control rule, but how it performs for some of these stocks and what that looks like in terms of helping to refine alternatives for analysis.

So cod and pollock in the Bering Sea and Gulf of Alaska, and Alaska sablefish. And right now, the way we're looking at this is we're, we're continuing to look at whether or not harvest controls should be applied to stock groupings. Right now, the harvest control rule is by tier level. We're focusing on Tier 3 stocks, which there's a table in your document that shows you the categorization of Bering Sea and Gulf brownfish stocks, almost the bulk of all of your stocks are in Tier 3, and that's where we're struggling with one single control rule, not— maybe they shouldn't be by tier and maybe they should be by stock or stock grouping. And then going on to the engagement communication, it is a really complex— just description of status quo is complex.

And so we were highlighting that we think that this might benefit from a targeted communication strategy That could be a number of things, not limited to potentially additional primary materials and presentations on status quo considerations of risk and uncertainty, including infographics. I would say that as we go forward from, from status quo, things will get increasingly more complex. And so our ability to simplify that, to explain it, to continue to, to try to be as transparent and, and clear as possible in communication about complex analyses and, and harvest control rules. And then again, separately from engagement communication strategy, we are looking to figure out how best to include the public in the development of performance metrics and social indicators for this analysis. And I believe that's all I have, Madam Chair, but I'm happy to answer more questions.

Thank you very much for the presentation, Dr. Strum. I'll see if there are any final questions for Are you? Yes, Ms. Kimball. Thank you, through the chair, and just to save time because I know we haven't received the AP report yet, but it does refer to a hybrid harvest control rule for sablefish, and I wondered if you could point me to what that is referring to.

Thank you, um, for the question, through the chair, um, Ms. Kimball. They did a simulation. These are all included. Apologies, I just get to the section here. There's an appendix to your document that includes consideration.

So part of the sablefish MSE that is ongoing, and again, those results will be presented to the plan teams. That has not been something that has yet come into our council process. It's been work they've done with stakeholders. They looked at 5 different harvest control rules, in general looking at the current harvest control rule, and they looked at some stability constraints to the harvest control rule so that the catch couldn't increase above a certain level, level, and then they looked at capping the catch, and then they looked at what they called a hybrid approach that combined the ramping down of fishing mortality when the stock size is below a reference point, which is what we have right now. So basically, our current harvest control rule that fishing mortality decreases when you're below B40, but then including with that a harvest cap and a stability constraint that says that you can, you go slow as biomass increases.

So like a fast down as biomass decreases, you ramp down quicker, which we do right now. And then, but as biomass increases, you are slow to move up. So that's what they were balancing, basically our current harvest control rule with these dampening mechanisms to cap the catch at a certain level so that it can't go above it. Some of it is included in the way that we've been formulating some of these control rules, but most of ours, we're looking at it over B40 in terms of capping catch so that what you see in the control rows, it looks like a decline, but it's because you're not allowing catch to go up any further. So they, theirs is more extreme at, I think, a 20,000-ton cap on overall harvest.

I would say one difference in the sablefish MSE currently, and I hope I'm not misspeaking, but they, the way that they formulated it is their max ABC that's included. So it's, it's a harvest control rule for maximum ABC, but they also consider that the max ABC is set equal to the ABC is set equal to the TAC. So they are, they are looking at harvest control rule on, on TAC because by virtue of defining it equal to the ABC.

Thank you. Any, any other questions? Madam Chair, I failed to note we do have an ecosystem committee report as well. Great, thank you. Thank you.

Um, I think before we take that report, we'll take a short mid-morning break. We'll come back at 11 o'clock, take our ecosystem report associated with this agenda item, and then we'll take the balance of the AP report, and then we'll begin public testimony after that. So I'll see you back here at 11. Thank you.

Welcome back, everyone. So we'll be taking our Ecosystem Committee report on E2, then we'll move into the balance of the AP report and would ask any members of the public wishing to testify, please sign up before the end of that AP report. So, Ms. Latonich. Thank you. Good morning again, Madam Chair, members of the Council.

Katie Latonich, Council staff. I'll be giving the balance of Ecosystem Committee report. Again, this is from our meeting on May 8th. We had a 1-day in-person meeting at the council offices, and this is the second agenda item we talked about in addition to the groundfish management policy review.

So first, much like today's presentation, the Ecosystem Committee received an update on the climate resilience work plan and tracking tool. This is primarily informational, and the Ecosystem Committee did not have any specific feedback at that time.

As far as our discussion of the alternative harvest control rules discussion paper, our discussion focused on two kind of different aspects of that paper, and the first was developing objectives for modified harvest control rules. The group supported the objectives that are provided in the discussion paper and also wanted to recognize that the Council is building through this work on an already strong foundation with the existing current harvest specifications process. The group was also interested to know when the public would be able to provide input on objectives and also performance metrics for particular stocks, recognizing some objectives may be more important or more appropriate for certain species and stocks. And in particular, we talked a lot about sablefish and, for example, age structure being an objective for long-lived stocks.

We also talked a lot about effective communication and public engagement related to this topic. Topic. As we've already discussed today, this is really complex, and it's a lot for the public and the council, you know, everybody in the council process to digest. The committee felt that further simplification is needed to both communicate how the current harvest specifications process currently works, and also the reasons for considering an approach that can better incorporate ecosystem effects. And specifically, the group recommended making information about the current harvest specs process and the incorporation and treatment of uncertainty and Harvest Risk more publicly accessible through the Council website.

Uh, the group was really complimentary of the work that Dr. Strahm and her colleagues put into the discussion paper and felt that this really helps capture how the current harvest specifications process works. And as such, it's a really good resource to translate to the Council's website and other materials to help the public better understand how this works. The group also requested use of the Council's Inflation Reduction Act funding to support additional public-facing outreach products that we could further develop through discussion with the Ecosystem Committee and could include things such as short 1- to 2-page flyers. I mentioned this in my previous E1 report as well. The Ecosystem Committee thought that they would be well positioned to have a role in reviewing and refining these products and making sure that we truly are translating them to plain language materials.

Oh, I guess that was it.

Sorry, I felt like I stopped abruptly there. So, yes, in closing, the Ecosystem Committee's recommendation was that they continue to have a role in public outreach on this topic and felt like they could serve as a review body to help ensure that we're reaching the public and helping distribute matters— distribute materials in a manner that reaches the public effectively. Thanks. That's it.

Thank you for the report. Are there any questions?

Or comments from our co-chairs.

Okay, thank you.

So that'll take us to the balance of the AP report.

Just quickly remind any members of the public wishing to testify on E2, please do sign up before the end of this report.

Thank you, Madam Chair, members of the council. For the record, my name is Chelsea Riddell, co-vice chair of the advisory panel, here to give the balance of the AP report. First, we have 2 motions on E2 and then 1 staff tasking motion.

Okay, sorry, just making sure I went to the right slide. Um, the Advisory Panel's first motion on harvest control rule reads, the AP recommends the consideration of the following language in a draft purpose and need and alternative initiatives to help identify objectives of this action and move the work forward. Purpose and need: the North Pacific ecosystem is experiencing rapid change and increased instability. The AP is interested in increasing ecosystem, industry, and community resilience under continued environmental variability and is exploring management strategies that contribute to that goal. Modifications to existing harvest control rules, or HCRs, for some or all tier levels as well as some or all stocks may provide additional protection and increased resilience for the long-term sustainability of fish and crab stocks.

AP supports exploration of appropriate modifications to HCRs followed by testing and simulation through management strategy evaluation frameworks.

In exploring alternative HCRs, the objectives are to maintain precautionary harvest buffers in the Bering Sea and Gulf of Alaska, prevent overfishing, transition from the use of risk tables under the status quo system to an explicit analytical approach for species whose productivity is known to vary with environmental conditions, increase buffering against environmental stock, increase socioeconomic stability, identify and achieve community-level objectives, maybe fishery-specific, increase transparency in the ABC tax setting process, increase use of LKTK.

Alternatives. Council staff have identified 4 HCRs in Table 9 on page 26 of the document, which outline the current focus HCRs and the consideration of combining them or creating hybrid versions of HCRs. This list is not exhaustive, and the AP recommends that the Council direct staff to identify the HCRs that should be moved forward for analysis. It is the AP's intent that Council's exploration and adoption of modified HCRs will start with the 3 candidate species identified in the HCR analysis: Bering Sea Aleutian Islands Gulf of Alaska Pacific cod, pollock, and sablefish, then proceed on a species-by-species or species-aggregate-based basis as appropriate and ready for council action. Relative to sablefish, the AP recommends further development of the hybrid harvest control rule, which seems to meet both ecological and economic resilience objectives.

The main motion passed 16 to 0, and with that, I can take any questions. Thank you. Yes, Ms. Kimball. Thank you, Ms. Riddell, for your AP report. I mean, I commend the AP Thank you for what looks like a really thorough motion on a really difficult topic.

My question's on the objectives and, and really whether, really whether the AP received a lot of public comment or testimony on the objectives, especially given the AP's recommendation to, to narrow this first scope to Pacific cod, pollock, and sablefish. And in particular, I'm wondering if you got public comment from fishermen in those particular fisheries on the objectives.

Thank you, through the Chair, Ms. Kimball, for the question. The AP did receive some testimony, and there was some testimony regarding sablefish, but there wasn't significant testimony from fishermen as a whole for all three species.

Thank you. And Mr. Ritchie. Thank you, Madam Chair. Thank you, Mr. Dell, for the report. Um, I'm wondering if you— if there was any conversation, um, around the analysis looking at trigger mechanisms for when alternatives could be used, and if there was a conversation around that, if you could briefly characterize it for us.

Thank you, Mr. Ritchie, for the question through the chair.

To my recollection, there wasn't a specific detailed discussion. Um, the maker of the motion did indicate that this was based on the recommendations from staff. These objectives were taken out of the analysis, so, um, it was really trying to make consistency with what had already been recommended to the AP.

Okay, thank you for the, for the report on E2.

Thank you. Now I'll begin the AP report for E2 Climate Resiliency Work Plan and our second motion. The AP recommends that the council task the Ecosystem Committee to support the development and review of plain language materials related to the council's climate resilience work plan. Work, including the harvest control work. The main motion passed 14 to 0.

Thank you. Are there any questions?

Okay, thank you.

All right, and finally, um, I will read the advisory panel's report for our one staff tasking motion, enactment of small sablefish release rule change.

The motion reads, the advisory panel recommends that the Council request assistance from NMFS headquarters in Washington, D.C. to ensure that the small sablefish release amendment is enacted in time for implementation during the 2027 fishing season. The main motion passed 15 to 0.

Thank you, Ms. Riddell. Are there any questions on this motion?

Yes, Ms. Cohen. Thank you, Madam Chair, and thank you for the motion. I'm curious if, uh, was the AP envisioning a letter from the council to the agency, or do you have some more specifics around that?

Thank you through the chair. Um, yes, Ms. Cohen, I believe that was the intent. While letter not specified, um, but really asking the council to request in the method that they deem appropriate.

Yes, Ms. Goehn. Thank you. And I'm looking at the rationale for this motion that's posted online, and it— you speak to some EFPs and whether a tool like that might be able to be used in the interim. I'm wondering if you can explain a bit more about that.

Thank you. Through the chair, that rationale is also consistent with with what the AP had also discussed in the past. So since there was concerns from stakeholders about the negative implications or challenges with delayed rule implementation, that the exempted fishing permit process does exist to help test and work out challenges or to allow fishing activity to occur I mean, the AP did discuss that typically that begins much earlier than final action, but that if some of the challenges with implementation are going to be long-term, that that process could be explored to give relief to the fleets.

Thank you, Ms. Riddell. Was the— in the AP discussion, was there any recognition or consideration of some of the resource constraints that we've been talking about over the last year or so, and kind of how this, how this fits in with other, you know, pending rules to be implemented. Thank you, Ms. Jabnicka. Yes.

There was discussion about that, but the, the stakeholders affected by the action felt that this had already taken several years for the action to get to final action and that the challenges or consequences for delaying implementation until 2028 just put further burden on the fleet. So recognizing that there are capacity challenges, they We're continuing to request that this be a priority.

Okay, thank you, Ms. Riddell.

So that'll take us to public testimony on E2. Pull up the sign-up sheet here.

Looks like we have 8 people signed up, and I would like to, um, take I'm going to take Dr. Jim Simon first since he needs to depart, and then Jacqueline Muehlbauer.

Madam Chair, members of the council, thank you for taking me out of order. I'm giving my travel requirements, and for the record, my name is Jim Simon. I'm the policy director of the Yukon River Intertribal Fish Commission, and I've learned a lot from the staff presentations just now. Panel and, and particularly, um, Madam, uh, or Miss Kimball's questions, because I, I got very confused at the advisory panel in discussions of trying to set, uh, ABC above the max. And then, um, staff also mentioned that, and, and it's very confusing to me.

And then Member Kimball saying, well, there's only one way to go from ABC Max down. And so I'm very interested to continue to track this process to see how that pans out, because it seems very concerning to me, just given my salmon management experience, because we I don't know that in the marine environment we have a clear understanding of how various stocks and species are going to respond to the environmental changes that were occurring. I'm aware of just from the University of Alaska Fairbanks climate change scenario team, the SNAP team, you know, that we keep learning through climate change scenarios and simulations that we keep not quite getting it right and that things are happening quicker than most of the models are predicting. And I just think that that suggests that there's a lot of uncertainty. And so the— I understand the executive order, um, you know, is playing a role here, but I think we really need to not forget what the precautionary management principle possible is.

And again, as I've said before, it's like stepping back because we don't really know exactly what's going to happen. So I think it's going to be very important for the science to come and, and actual discussions of the data that are feeding into these processes. Um, and with that, I'm, I'm really done, and I really appreciate the conversation of the council and Makes me feel better that some of the council members seem to also be struggling to understand some of these things, you know, and to that one, you know, that you can't exceed the OFL, right? I mean, that was good to get clarified on the record. And, uh, so thank you very much for your time.

Thank you very much for your testimony, Dr. Simon. I'll see if Any questions?

Thank you.

Jacqueline Muehlbauer is next, followed by Jim Armstrong.

Good morning. My name is Jacqueline Muehlbauer. I am a policy analyst based in Fairbanks, Alaska. Alaska, and this is my personal testimony. It does not reflect the views of anyone else, including my employer or any other organization.

Um, I echo Dr. Simon's, uh, comments that staff here are— make beautiful presentations that are very informative for someone who is very new to this process, and the questions you all ask are also usually mirror what I'm wondering too. So with that, I'd like to support the AP motion, which passed 12 to 3. The AP got the sequencing right. Finish the science before drawing policy conclusions. We don't yet have empirically grounded UFM estimates for the red king crab, and we don't have peer-reviewed contact outputs integrated in the model.

Advancing policy before that foundation exists undermines the science-based framework a benchmark we've heard over and over and over again this past week. I ask the council to adopt this motion, hold to the February 2027 timeline with SSC-reviewed outputs, and treat the UFM tasking and public transparency commitments as binding deliverables, not aspirational ones. Climate-linked HCRs depends on reliable observational inputs, but as I've testified before, the B9 ISSIP report documents a 235% year-over-year increase in inshore, inshore chum bycatch, a 25-point EM coverage shortfall in fixed BSAI strata, and a 33-day medium review lag. That's a signal arriving through a compromised sensor. An HCR calibrated to that signal adapts management to a biased measurement of reality, not to actual conditions.

Interior communities feel actual conditions first. In the river before the covariates catch up. I ask this council to incorporate observation data quality metrics into the HCR performance framework alongside biological outcomes, recognize TEK as an independent real-time observational system under the LKTKS protocol, and include observational data failure as an explicit meta-rule trigger. Not only biological failure. Interior communities have managed these resources since time immemorial.

I'm asking the Council to listen to the full range of sensors available, including traditional knowledge. Thank you.

Thank you very much for your testimony. See if there are any questions. Thank you for joining us.

Jim Armstrong is up next, followed by Therese Vicente.

Good morning, Madam Chair, members of the council. Jim Armstrong with the Freezer Longliners. Um, we also submitted written comments on this agenda item, um, but so I'll focus here on a few additional points that I think help round out our perspective. First, FLC agrees that climate and other environmental conditions affect cod populations. Our concern is ensuring the clarity and practicality guide our conversation of how we factor that into our harvest specifications process.

HCR 7 is the only one that explicitly factors in environmental information under it. Um, harvest rates would be responsive to anticipated changes in stock productivity from a combination of population model inputs and environmental covariates. But how accurately can we forecast climate conditions in a time scale relevant to harvest specifications? On that question, we share the same doubts that were expressed by the ecosystem What we really need in order to bring clarity to this conversation is an example of how things would have been different for Gulf cod if HCR-7, for example, had been in place. What ABCs would have been set?

When would those ABCs have, have diverged from the status quo? How much biomass would have been preserved? How would the stock trajectory have changed? Changed? How, how would fishery impacts have been different?

Now let's ask the same questions about sablefish. Those two species provide bookends for how differently temperature anomalies can affect fish populations. Whatever we do, these species are telling us that a one-size-fits-all approach would be unwise. I know that several SSC members recognize the need for greater clarity and communication of this issue to stakeholders,— nothing would achieve that more effectively than running through a specific example. We aren't burying our heads in the sand about the importance of changing ocean temperatures.

We just question whether it's appropriate to chart a timeline for alternative HCRs, uh, before we have demonstrated that any of the candidate HCRs would in fact have achieved climate resiliency. We also suggest the council, uh, evaluate the addition additional data collections that would be needed to better understand the appropriateness of the candidate HCRs. Moving to a higher level of model complexity introduces new sources of uncertainty. What investments need to be made to scale data collections to the increase in complexity? And how does that value— how does the value of those investments compare to the reductions in uncertainty that would come from basic research on cod life history.

Another issue, uh, is competing temporal scales. Under our current process, harvest limits are adjusted annually based on the most recent data collections. The additive effects of multi-decadal decreases in carrying capacity or recruitment are going to either be undetectable or be swamped by other near-term population effects, adding unnecessary complexity to an already complex process. Process. If we were trying to predict what average biomass would be in 50 years, long-term trends would be directly applicable.

When we're talking about next year, not so much. Um, reflecting on what changes we could consider, uh, to our harvest specifications process does create some opportunities. I was glad to hear the discussion in the SSC touch on the P* approach. Approach. FLC is not alone among stakeholders in seeing the emergence of risk tables as a source of unpredictable subjectivity.

Risk tables and the MAX ABC concept seem to have caused us to forget all about OFL as the threshold for risk. There's a scientific— there is a significant buffer between OFL and ABC for Tier 3 stocks that accounts for all sources of scientific uncertainty uncertainty. That buffer corresponds to 30,000 tons for Bering Sea cod. Thinking of something that has not been explicitly factored into an assessment does not add uncertainty. It just adds more definition to what our uncertainty is comprised of.

We encourage the Council to consider comparing our current process to different approaches, like P*STAR, that do not include the subjectivity inherent in non-scientific exercises like expert opinion. The Council's conscientious— this Council's conscientious approach to fishery management issues is why FLC and others hold you in such high regard. While we applaud the aspirational nature of the ongoing conversation on climate resiliency, we suggest that as you continue that conversation, you hold tightly to two important considerations. One, remember to fully consider consider the resiliency existing processes already provide, and two, accept that there's a limit to what we'll actually be able to do. Thank you for the opportunity to comment.

Thank you very much for your testimony. Yes, Miss Kimball has a question. Thank you, and thank you for your testimony, Mr. Armstrong. I—. Just to get down to it, do you still see utility in this exercise?

I, I really see it as an experiment to see whether whether this could work or would be better than status quo for the objectives that we set out for ourselves, but we won't know that until we run through those simulations and do that evaluation. But are your— is your level of kind of caveat or caution on this really to be interpreted as we already incorporate climate resiliency in the risk tables, so don't go forward, or we should go forward cautiously? Thank you for the question through the Chair. I, I think that, you know, an attempt to run actual examples, like, and it has to be done in a way so that as that exercise is being described, you're taking the information that was available, say, in 2015, you know, the crash was in 2018, but you've got HCR 7 in there and somehow or another it's allowing you to do something different than what you would have done. If there's some value to that, that alternative harvest control rule, then that exercise is going to reveal it, or it is going to reveal that actually we can't even pull it off.

And that's I'm kind of leaning toward that as an expected outcome, and it's a question of maybe resources and priorities for the Council as to whether we need to go through that exercise or we can, you know, if there's value in doing that.

I just— I'm— I think we would have probably seen something by now It just seems like, you know, that was like the thing after it happened. Like, how could we have prevented this, right? And I'm not sure. I feel like we're closer to having something now than we were then. And it's just, that's just unfortunately the world we live in.

I think sometimes you have to just, there's some things we can't predict. Predict, and there's an important relationship between cod and water temperature, but we have to— and so I think the question was asked during the staff presentation, you know, or the differentiation between can we predict what the effect of the thing will be on— of something will be on the cod population. Yeah, we can predict that, but can we predict that climate— you know, anticipate that it's going to show up. And I haven't seen anything so far that has convinced me we can. So yeah, that's all.

Thank you. Yep. Thank you for your testimony.

Therese Vicente is up next, followed by Nick Jacek.

Good morning again, Madam Chair and members of the Council. For the record, again, my name is Therese Vicente. I am the Policy and Programs Director with the Kuskokwim River Intertribal Fish Commission.

The Kuskokwim Fish Commission first supports the Ecosystem Committee member comments from their May 8th meeting. That there needs to be a working definition of climate resilience to guide the council's work. The committee's minutes reflect that the Climate Change Task Force did develop this and reported it in their December 2024 final report. Um, but this definition remains buried in that report. Um, it should be shared more broadly, for instance, by clearly pasting it onto the council's webpage dedicated to climate readiness activities under the section on the CCTF.

And it's also worth considering identifying guiding principles from this definition to inform the council's work for climate resilience. The Fish Commission supports this as a task for the Ecosystem Committee, perhaps as part of their work in evaluating the groundfish management policy goals and objectives. We also note that guiding principles for informing work toward climate resilience must include holding subsistence fishery community needs and knowledge on par with the needs of directed fishery communities and findings of Western scientific data and models. The North Pacific will never be resilient amidst climate change if Alaska Native well-being, values, and knowledge systems are not included in your work. Onto the harvest control rules.

The Fish Commission supports advancing work on HCRs largely as outlined by the Advisory Panel, and in addition to the objectives supported by the AP, we support adding objectives that explicitly aim to protect Alaskan subsistence communities' food sources and ways of life, to protect habitat including on the seafloor, and preserve food web dynamics that relate to the analyzed fishery stock but also include non-target species.

Species. We have concern about proposed HCRs that could allow a future ABC to be set above the current max ABC. This may be biologically unsound in an ecosystem that seems to be disintegrating around us and in a system that desperately needs to move from single stock approaches to ecosystem-based management. Management and scientific uncertainty amidst unpredictable effects of climate change should lead to more precaution. And therefore more buffers rather than increased liberalization of the calculations to set ABC.

This can make sure that food webs and the ecosystem remain intact alongside fishery removals. There needs to be more clarification on how these dynamic HCRs would work to be precautionary during this changing climate. As we understand it, HCRs will be assessed according to performance metrics identified from the objectives that you set. The Fish Commission recommends that there be a public workshop to get feedback from tribes, scientists, analysts, and the fishing industry on specific performance metrics for the control rules. If the council advances development of a harvest control rule for pollock, these performance metrics should include considering the condition and abundance of PSC species such as salmon, as well as reducing the frequency of their bycatch.

And finally, the council should consider developing a parallel pathway for modifying the tax setting process. The Fish Commission has tried to engage in tax setting by contributing traditional knowledge and salmon information to the Eastern Bering Sea Ecosystem Status Report and by sharing insights on impacts to salmon and salmon communities of setting outsized tax for the pollock fishery. Industry. And in this engagement, we found that the current tax setting process does not work to include traditional knowledge, ecosystem considerations, or socioeconomic and well-being information from subsistence communities dependent on salmon and other PSC species. Rather, it's primarily driven by economic information from, for, and by the trawl industry.

If the tax setting process is the best way to integrate ecological and socioeconomic data, values, and knowledge of non-target fish species and non-directed fishing communities, including about salmon and from Salmon People, then there needs to be a refreshed and transparent way for this to be done. The council should envision this through the public workshop around performance metrics for the harvest control rules and/or by tasking it to the Ecosystem Committee. To conclude and echo our written The goal of the development of alternative harvest control rules must be to promote and practice ecosystem stewardship, not to maximize profit for high-yield fisheries. Protecting the health, biodiversity, and stability of the interconnected ocean-to-rivers North Pacific ecosystem must be at the forefront of advancing this action. Thank you.

Thank you for your testimony. Yeah, not seeing any questions. Thank you. Nick Jacek is up next, followed by Linda Banken.

Good morning, Madam Chair, members of the council. Um, for the record again, my name is Nick Jacek, and I'm here representing Ocean Conservancy as the Fisheries Policy Manager for the Arctic and Northern Waters Program. I'd like to start off my testimony by saying that we support the AP motion on HCRs in continuing work on modified harvest control rules. Incorporating climate resilience— resilient HCRs has been a stated goal of the council for years. It is an important element of the climate work plan and is needed more than ever as climate variability continues to increase in the North Pacific.

As this process gets moved forward, the current and potentially expanded range of HCR alternatives should focus on building in additional buffers to address uncertainty and provide stability for fisheries and fishing-dependent communities. The objectives of the HCRs should help guide what performance metrics should be developed. The performance metrics are important for evaluating how revised HCRs perform relative to their objectives. This is what we see— this is where we see an opportunity for public engagement and collaboration and enhancing climate resilience in groundfish and crab specifications. We have 3 additional comments related to this object— to the objectives and performance metrics for the HCRs.

First, I would like to say, while we understand the objectives may differ with species-specific HCRs, it is paramount that the HCR alternatives are guided with objectives rooted in climate resilience. These established objectives should lay the foundation as a forward-thinking framework for addressing climate-related challenges by using climate-related data for informing stock biomass trends, the connections of species in the greater marine ecosystem, and the impact on Alaska's fishing-dependent communities and cultures. These HCRs should be operating towards long-term sustainability and climate-resilient fisheries, and therefore the performance metrics should be oriented to reduce the risk of stock stock collapses under the combined pressures of climate change and commercial fishing, instead of being an avenue for maximizing harvest opportunity. Currently, HCR7, with its time-varying responses from environmental covariates and population models, is a useful example for adjusting harvest rates based on the range of recovery in varying conditions. It's modeled to use climate-informed data to estimate recovery rates to stock biomass as a result of climate shock.

Fish stocks. While OC is not yet ready to explicitly advocate for a specific alternative, we would urge that any modified HCR be examined with the harvest mortality parameters that do not increase pressure on the fish stocks. And then secondly, as the work on the HCR alternatives moves forward, I want to highlight the importance of developing and defining the community-level objectives. I also urge the council to strive to increase transparency for the public on the specific role of performance metrics for evaluating HCRs against their objectives and how HCRs drive ABC and ultimately tax setting. I also want to emphasize the important role of diverse knowledge systems in this process for defining community-level objectives.

The LKTKS protocol is an existing tool that directs stock assessment authors to engage with tribal governments, governments and knowledge holders to identify relevant climate indicators. Thirdly, I would like to say, while we understand that HCR measures address ABC determinations directly, we strongly urge the Council and Ecosystem Committee to develop a parallel pathway for increasing climate resilience and ecosystem considerations in the tax setting process. This does not need to slow down the HCR work. Instead, the processes established through the ACCLIMB and the, uh, in the HCR development over the last few years can serve as an ideal guide for identifying new ecosystem-based frameworks that can more transparently guide tax setting each year. Revised HCRs, coupled, coupled with the exploration of new ways of expanding ecosystem and community considerations in the tax setting, will strengthen the groundfish specifications process and improve its responsiveness to changing ecological and socioeconomic conditions.

Wrapping up, I would like to say that the ACLIMB team's modeling framework is a strong foundation and deserve support and responsible direction for moving this work forward. So we support the HCR alternatives analysis moving forward, provided that alternative HCRs are grounded in a process of buffers and uncertainty, consider, consider predicted declines in ecosystem productivity, and prioritize the long-term sustainability and of our ecosystems and well-being of the communities and cultures that rely on them. The development of the climate-informed HCRs and associated objectives and performance metrics should be viewed from the lens of an iterative and adaptive management. As such, we would urge the Council to consider a workshop later this year to work with the public to develop performance metrics reflective of community and ecosystem needs.

Thank you for your testimony.

Linda Banken is up next, followed by Patty O'Donnell. Thank you, Madam Chair. Linda Benken, testifying for Alaska Longline Fishermen's Association. Start by saying that we support the council's efforts to incorporate climate change into fisheries management and your underlying goal of building climate resilience across the North Pacific marine ecosystem, fishing industry, and fishery-dependent communities. I want to recognize the leadership in this work of Dr. Strand, Litanich, and Holtzman, also of our ecosystem committee chairs, Ms. Kimball, Mr. Pamp, discipline.

I know there are many others involved, and I really appreciate their efforts to move this work forward and to help the rest of us understand and engage. Because the changes we are witnessing are so rapid, Alpha expects that navigating the next 10 to 20 years will require a willingness to question, test, and change many existing aspects of fisheries management. We recognize that management will need to shift to provide greater buffers against uncertainty and unstability higher level of protection for overall ecosystem health, and a new focus on providing pathways for industry and fishing communities to survive by maximizing value over volume. As part of moving management towards these objectives, Alpha strongly supports the council's ongoing work to incorporate other ways of knowing and new objectives into the harvest specification process and into the, into the re-evaluation of harvest control rules. Alaska Native people have survived and thrived for over 10,000 years in this place.

Clearly, they have much to teach us. Fishermen and coastal residents are also now on the front lines of climate change in real time and have much to contribute to the management process. While some of these considerations may be better incorporated at the TAC level rather than in this work, we expect some can be incorporated as performance metrics to evaluate alternative HCRs. I would note the SSC recommendation on this agenda item, or one of their recommendations is, and to quote it, the SSC encourages further exploration of the possibility of adding social indicators to harvest control rule evaluation and consideration of methods to communicate these metrics in a way way that supports decision-making. As you know, Alpha has a particular interest in sablefish management, which is one of the species advancing through this process.

Alpha also strongly supports the ongoing work to reevaluate HCRs for sablefish. Our experience with the slow train wreck of sablefish management over the past 6 years has made us firm believers in the need for change. We're excited by the MSC work led by Drs. Cunningham and Goethl and appreciate the active inclusion of fishermen in this, in this work. I would call your attention to Appendix A of this agenda item, which reviews the poor outcomes of recent sablefish management with age truncation and a massive drop in economic value, and to the more promising performance of an alternative harvest control rule, namely the hybrid HCR that has been tested with the MSE model.

That's on pages 58 and 59. We ask that the Council build on this work to guide an analysis of alternative sablefish HCR. Additional analysis, including expansion of economic data available to the MSE model, will allow the, the Council to identify an alternative harvest control rule that improves sablefish management even as climate change tests all existing assumptions. Along with initiating analysis to amend the sablefish HCR, ALFA supports the council exploring alternative HCR for other groundfish and crab as appropriate, with Gulf, Bering Sea, sablefish, pecan, and pollock ready to advance at this point. We support the work of the council on this agenda— sorry, of AP on this agenda item and believe they did a good job of developing a purpose and need objectives that guide the work moving forward, which was mostly taken from pages 28 and 29 in this report, and alternatives for further analysis.

Again, as I stated in previous testimony, we would like to see a parallel process or pathway to increase climate resilience and ecosystem considerations as part of the tax setting process, we also support a workshop around performance metrics to better incorporate objectives of the public, industry, tribes, and communities into this work. And some were eager to see this work to identify and implement alternative harvest control rules move forward. We're particularly excited about the sablefish work, but recognize it's— it makes sense for it to move forward with peacod and pollock, given that these three species are advancing because of known environmental correlations. Um, we want a process that incorporates new objectives for management into the process, builds climate resilience, and meets industry and community needs to maximize value over volume and achieve a measure of stability in a less stable environment. Thanks so much for the opportunity to testify.

Thank you for your testimony. Testimony. I'll see if there are any questions. Yes, Ms. Kimball. Thank you for your testimony, Ms. Banken, and it's a pretty broad question, but how do we focus this work less on whether the ABC would go up or down for a particular stock and more on are we better off in protecting spawning biomass while optimizing yield?

That's our requirement under Magnuson act under these rapidly changing environmental conditions by using a different HCR to produce OFL and ABC than we do currently? Like, how do we move from focusing on the potential outcome to focusing on whether we are better off in addressing risk and uncertainty by moving to a modified HCR that has different inputs?

To the chair, thank you. You can always say no, you don't need to answer. No, I think that is a great question. I mean, I guess I, you know, I have really been focused on taking lessons learned from sablefish and thinking of ways to identify objectives that are responsive to changes in the environment, but also really do meet the needs of the industry, of the stock over the long term, and much less focused on, you know, whether we end up with raising those max ABCs over time. And I think maybe part of it is to remind the public that we will learn a lot from an analysis that allows us to think broadly about this issue.

And while I don't expect that I— Alpha would support increases in ABC, that it's important to take a look at what that might do in the future as part of this exercise to inform our decision-making moving forward and to really recognize that this is an experiment and how we improve our management, how we make it more responsive to the changes we are seeing, um, and that we need to break down some of our existing ways of doing things and really try to be flexible in our thinking in that evaluation, um, while still recognizing that, you know, the likely outcome is a need to be more conservative in the face of an ecosystem under stress, um, and where it's just likely to be less predictable moving forward. I hope that's, that's helpful. Um, I'm certainly willing to give it more thought, but that's my best I can give you at this point. Thank you.

Thank you for your testimony.

So next up is Patty O'Donnell, and then Sarah Webster and Glenn Merrill will be our last testifiers.

Fires. Thank you, Madam Chair, members of the council. For the record, Paddy O'Donnell, trawl fisherman out of Kodiak. So I'm going to speak today about the, the, uh, what was brought up at the SSC with Gulf of Alaska survey changes and, and in relation to the harvest control rules. And, uh, I had a slide there that hopefully can get put up.

There was two additional considerations that were not included in the SSC report on slide 50 in the PPT presented to the SSC. Excuse me, I'm getting the crud here like everybody else, I guess.

And, and two of them were species moving in and out of regions and species and stocks moving out of historic, historical survey areas. There's a slide I hope you have it and you can see in blue the surveyed areas by the Oscar Days in this last winter and then in grey what they did not survey and that's of a concern based on the report that they give us that they've seen a 25% reduction in pollock in the shellfish. We're concerned about the reduction of 17% in stations in the bottom trawl survey in 2025. We're not seeing a reduction on the grounds with POP especially, and it's been a bumper year. My boat's on a—.

Got a—. On his last trip here for his next trip, so it's been going pretty good, better than many, many years. And in regards to Pollack and the Oscar Days in here, the Pollack, they were done with the survey completed and Pollack showed up further up the Shelagh Cove and We haven't seen that since the '90s, early 2000s. They changed the survey structure a couple of years back, 2, 3, 4, 5 years ago, to capture pre-spawning pollack earlier in the season. So they moved the survey earlier, which in turn resulted in the conditions going back to normal here, where they were done, they were done with the survey when the pollack moved in into the Shelagh Cove and further up the Shelagh koff.

We're seeing changes also with POP where they're, uh, they moved out of an area that we typically fish POP in, and, and now they're, uh, we're fishing pollock there in the season where we've never fished pollock before. So there's changes in distribution and, and all species happening that I'm concerned with reductions and changes. And, and the new survey, uh, changes that, that's been adopted and the lack thereof of surveys, and especially the, the stations. We, uh, we do the Pollack winter survey during spawn. We do the bottom trawl survey post-spawn for cod, piope, and Pollack.

And I don't know how that factors into everything, but I just want to say, as a fisherman and what we're seeing on the ground, say I wanted to flag all of this to you guys. Thanks.

Thank you, Miss Rodon. And I'll see if there are any questions. Yes, Miss Kimball. Thank you. I thank you, Mr. O'Donnell.

I appreciate the flag that the— I just want to make sure I understand on the gray lines, that would be expected to be surveyed in the next Gulf survey. So is that your understanding, or did you get different information from the SSE presentation? That's for the chair, Miss Kimball. This is the Oscar Dason Wontour Acoustic Survey. Survey, and we had a very cold winter, a lot of wind, northwest wind and heavy freezing spray, and they were anchored on the mainland for I think about 7 days before they couldn't survey, and thus they ran out of time to survey all the grey areas.

We do this survey annually, so it's probably about half of the area didn't get surveyed. Or vid based on that particular chart. So, and what I'm concerned about is what the fleet is seeing and then the fact that the Pollack was a couple of weeks late coming in and we did have a huge biomass move in after they got done with the survey and that wasn't captured. And we were notified because they give a presentation at the end of March to the Kodiak fleet as to the conditions of the survey and what they're seeing out there. There, and, uh, they indicated that there was a 25% reduction in Pollock, and again, we're not seeing that on the ground.

Thank you for that explanation.

Okay, thank you for your testimony. Sarah Webster and Glen Merrill.

Good morning, just barely again, Madam Chair and members of the council. Once again, my name is Sarah Webster, and I am the Science Projects Director for the Alaska Seafood Cooperative. I am here with Glenn Merrill, who is our co-op president. I am actually going to keep this testimony really short because I do have to get to the airport, but I did just want to briefly comment on the climate-informed harvest control rules. Um, I really appreciate all the work that has gone into this on the part of the staff, including their efforts to distill it down to digestible components so that the public can understand.

That said, it still is pretty unclear how this fits into the precautionary approach that already exists in the North Pacific. Environmental covariates can already be incorporated into stock assessments, and uncertainty is incorporated in— into the risk table. Variables, including environmental uncertainty. In addition, we have an extra layer of precaution already built in with the 200 metric, metric ton cap in the Bering Sea. Considering the unknown future in terms of climate variables, which could fluctuate in multiple directions, as well as the variable responses from different stocks to different covariates, I think it's just really unclear how this might play out in the management process.

So I guess what we're hoping for is that if this moves forward, there are some more tangible samples that demonstrate the very wide range of possibilities that could occur. And it's really just unclear to us at this point if there's value in that process considering the already robust and precautionary process that exists. Um, I did also just want to touch very briefly on the sablefish MSE process to date, which we understood was to be a research MSE that was outside of the scope of the council process. And while we have attended several meetings, it seems that the work today really has focused on a single stakeholder group, and our input, input and perspectives have not largely been included up to this point. We do just want to flag that concern and request that if the MSE moves forward for sablefish and it's brought into this process, that a more diverse group of stakeholders be better included in the development of relevant performance metrics and associated covariates.

And I'm going to turn it over to Mr. Merrill, but I will walk away if he talks for too long.

Can we all do the same?

Please. Everyone's going home. Here we begin. Uh, thank you, Madam Chair. Uh, thank you, Sarah, for that wonderful introduction.

Um, why don't I just, uh, touch base very briefly on a couple of things. First, as somebody who's not a scientist,— but has participated in this process of tax setting. Ultimately, over the years, I think there's layers of precaution at your OFL, at your ABC, and then we have a very complicated process for tax setting as well. Understanding, even on a species-by-species basis, how uncertainty is incorporated by each of the individual stock authors is complicated. Layer on top of that changes in harvest control rules, that gets even trickier.

I guess thinking about Gulf Pacific Cod, there is always a challenge when you have an adaptive harvest control rule whether or not you got it right or whether or not your existing system provides you the flexibility that you need. And I wanted to provide one example from the West Coast. So we participate in fisheries on the West Coast as well. Rockfish. Rockfish is something that has been a real challenge on the West Coast in terms of management.

Several years ago, there was effort to try and have a much more precautionary harvest control rule for a number of those rockfish species. They are choke species for a large number of commercial recreational fisheries. And what ended up happening is that at the same time that you had more precautionary harvest control rules, you had a significant reduction in the amount of survey coverage and survey opportunity for a number of these species. So you created a more precautionary approach approach, you removed some of the information that you needed to inform that approach, and what you ended up with is very precautionary management that we have actually found has not worked particularly well for a number of these stocks, and additional information has indicated that that response was perhaps not appropriate. Most recently, the Pacific Council had to take emergency action to have a 10% increase in the amount of Canary rockfish that was allowable for harvest.

That's how tight the little boxes are on the West Coast. We've got lots of tight little boxes here in Alaska as well. That type of dynamic, I think, is only exacerbated and made less, less clear under a harvest control rule. I think the other thing that I'd just like to briefly close on is the ability of having a harvest control rule that tries to incorporate some sort of economic factor into it is extremely difficult. Markets change very rapidly.

Geopolitical considerations affect markets. Our ability to have some sort of harvest control rule that incorporates those very, very rapid changes that we don't know about and can change on a daily basis are the types of things that I think are very difficult to incorporate in some sort of structured method for setting a, a TAC or an OFL. So with that, I'll close. Thank you for your time.

Thank you very much for your testimony. Let's see. Yes, Miss Kimball. Thank you. I'm just based— thank you for your testimony, both of you.

But based on your last comment, Mr. Merrill, like, I don't think there's any intention to include market impacts or changes or those socioeconomic factors in the actual harvest control rule. Those are— were explained to us as biological parameters only to develop a calculation for OFL and ABC. But are you saying that that is still too dynamic of a system to include as an objective by which to measure our progress because those change too much? Or not progress, but performance? That's what I wanted to understand.

Yeah, thank you for the question, Ms. Kimball. Yes, I mean, I think it's very difficult for us as an operator selling into various markets. Is our economic performance in a year or a couple of years indicative of something that should be folded into our overall approach to a harvest control rule. And I guess I would argue that there are very different situations that can affect different stakeholders in the fishery differently. That makes it really hard to incorporate some sort of overarching factor into a harvest control rule consideration.

Thank you. Any other questions? Thank you both for your testimony.

So I will I will, in the consideration of time here, ask if the council wishes to take action on this item and try to get through our discussion before lunch, and then we'll pick up after lunch at staff tasking.

Do you need a minute? Yes, let's stand down for 2 minutes. Minutes here. So please stay in the room, everyone.

Okay, thank you everyone. So, um, we have completed our staff presentations and public testimony on E2. What are the wishes of the council? Yes, Miss Kimball. Thank you, Madam Chair, and for the moment, um, to get things together, I do have a motion on E2.

The motion reads: The council's climate resiliency work plan is focused on: 1, expanding the council's processes, collaborations, and partnerships to facilitate inclusion of multiple knowledge systems in climate planning; and 2, considering management tools and options that can include existing and emerging climate information. Evaluation of harvest control rules, or HCRs, is one component of the plan. The Council supports continued evaluation of whether modifying specific groundfish and crab harvest control rules to better incorporate changing ecosystem conditions is feasible and could improve conservation and/or management performance compared to status quo. The purpose of a harvest control rule formula is to calculate the fish or crab stock's overfishing limit, an acceptable biological catch limit based on biological parameters, parameters, given risk and uncertainty as required by the Magnuson-Stevens Act. The Council's intent is to determine if a modified HCR for some species could perform better to protect spawning biomass while optimizing yield during climate shocks and longer-term changes that impact stock productivity under rapidly changing marine environmental conditions than the current HCRs in the Bering Sea Aleutian Islands and Gulf of Alaska groundfish and Bering Sea Aleutian Island crab fishery management plans.

Further work should explicitly recognize that: 1, the emphasis of objectives in the harvest control rule will likely differ by stock; 2, environmental, environmental variables' influence on population dynamics will not be sufficiently understood for all stocks to proceed with modified HCR development; and 3, moving to an alternative HCR may not mean other methods to account for risk, such as qualitative risk tables, are unnecessary as long as risk is not being double-counted. The Council approves the following next steps: include the SSC recommendations as possible, support the objectives provided by staff for purposes of the synthesis and initial review of performance metrics used to determine how alternative HCRs perform compared to status quo. The Council will refine objectives based upon preliminary stock-specific results as alternatives are being developed. Evaluations for pollock and Pacific cod, Bering Sea, Aleutian Islands and Gulf, and Alaska stable sablefish relative to sablefish recommend further development of the hybrid harvest control rule. Engagement and communication strategy per the Ecosystem Committee recommendations develop plain language materials related to the Council's climate resilience work, including the current system to set overfishing and catch limits and the new harvest control rule work.

Outline the scalability of this work under varying budget scenarios, which includes survey data streams that are in flux due to budgets, and finalize the results from the sablefish management strategies evaluation, including single area and spatial breakouts and preliminary findings from the Bering Sea Harvest Control Rule evaluations of pollock and Pacific cod and present to the groundfish plan team in fall of 2026. With a second, I'll speak to it. Thank you for the second, Ms. Vanderhoeven. Just need to move.

Um, it is hard to be brief. This is such a complicated issue that could have such— it's such great experimental work and could have significant influence on our process. I really appreciate the paper and the council staff and Science Center work to move us forward in this component of our climate resiliency plan. It's helpful to remind ourselves we had the Climate Change Task Force. That was a year or more work, and that compiled a whole climate readiness synthesis as a starting point for us.

We just approved that in November of 2024. So it's still very recent. And that plan was basically determining how climate ready the current management system, system is overall and to assist us in looking at different ways to improve that. So harvest control rules are just one part of that very large peer-reviewed process and calculation to set OFLs and ABCs, and I think we all take it very seriously since it's our fundamental task under the Magnuson-Stevens Act. I think the SSC, I read those minutes carefully, were very clear that we've had a lot of success avoiding overfishing and protecting spawning biomass for the stocks we manage under the current system.

And so we don't want to change or threaten the success that we've had. But the fact that we're experiencing extremes in ecosystem conditions is the impetus for this kind of evaluation.

I value the SSC's comments on the overall process already being climate resilient. I wanted to echo those thoughts. It's resilient to an extent because it incorporates both risk and uncertainty today, which means our catch limits are very much buffered. But this move to look at whether harvest control rules themselves can be more climate resilient and how they respond to ecosystem conditions or climate shocks is one of the key things that the Task Force recommended reviewing. And so I'm putting this forward as continuing that work.

But I think the discussion has to include whether we have the data to support such changes that came up and from all different aspects of our public comment, and as noted in our early public comment, whether we understand the relationships clearly enough between these environmental data and the species we manage well enough to make a change. And our whole idea here is, would these modified harvest control rules perform better than status quo? I appreciate everyone on the same learning curve as the rest of us, um, about harvest control rules and what they do and don't do. I won't repeat that, but I appreciate the public's patience with some of these complex issues. I also wanted to note that the, the OFLs and ABCs are important because they are the biological upper limits of catch that don't risk the long-term sustainability of the stock that we're required to manage, and it's very clearly defined for us in the MSA, and we have to stick by that definition.

I really appreciate the AP's work on this. I think they did a great job giving a starting point for what a purpose and need does. I didn't pick that up because I didn't feel like we were in a place to advance specific alternatives at this, at this juncture. And while I feel like we can hold the AP's purpose and need kind of in check for when we get to that place, I didn't want to set the precedent of doing a purpose and need and not also doing alternatives. I—.

That doesn't seem like that's what the council normally does, and I, I didn't want to start that. Um, I also didn't modify yet the objectives, and I, I also would look, um, point people to the AP motion where they had some modification to objectives. I'm just moving forward the staff's very general objectives in the hopes that when we get this back, we have more public engagement. I appreciated the public engagement we had, but I think there's a note that we need more, um, especially with the narrowing down of this, this evaluation to pollock, cod, and sablefish. I just think that will help notify the public of where the Council's headed for these first evaluations and maybe generate more public input onto what those objectives can look like.

And I think we can all hold fast to the public comment we got at this meeting and continue to look back at that as reference for input we've already received on the objectives. I think that's very helpful. Helpful. I might have lost my place here. I appreciate the Ecosystem Committee recommendations.

I think if you didn't get to listen to the Ecosystem Committee when Dr. Stram and Dr. Holzman provided their presentation, and then Dr. Stram said, and we will be providing plain language materials after the committee just reviewed this very intense paper, complicated paper. I think, like, if you could have seen the faces, it just, it shows that we're not great at providing plain language materials. I think the Ecosystem Committee is really a good review space for something that would be more accessible to the public and resonate with the public more so than just a staff-generated and put it on the website. So I, I think if the Ecosystem Committee is willing and the Council's willing to task them with that, I would fully support that because I think it's a good group to do that. To do that.

Finally, I just want to be really clear that, that we are facing budget uncertainty, and that feeds into every single thing we're doing at this council. I would expect when we get this back, we not only get this kind of a little bit of an idea about how budget scenarios and, and survey budget scenarios would affect the ability to continue this work or to see it perform well in the future, but also just whether we continue to move down this path, if we don't feel like we're getting a bunch more value out of modified HCRs compared to status quo, which is already pretty appropriately buffered to deal with all sorts of scenarios, then the council at that time could say, you know, with our limited staff time and resources, we're not going to pursue this at this time. But I sure wasn't ready to go there. I just feel like we should go there a little bit cautiously, and I hope that the council can see that reflected in this motion.

Motion. Thank you very much for the motion and rationale, Ms. Kimball. Are there any questions on the motion? Yes, Ms. Gohan. Thank you, Madam Chair, and thank you, Ms. Kimball, for the motion.

Um, and I think you got to it in your rationale, noting that we heard some feedback on things to consider and objectives during public testimony, but there was also a request for a work workshop. I wonder if you can speak to how you envision public input might be folded into this process.

Thank you for that question, Ms. Gowan. I forgot to mention that, um, I just don't know where we are in terms of the budgets to hold a workshop. I think that was a good idea, but I wasn't going to put it on the table not being on the Finance Committee or having that conversation yet with the chair. I do think our normal public process, if we can do a better job of outlining for people what we're looking for in input. You know, I don't think we need a bunch of complex input on the HCR rules.

I think we want people to comment on the objectives. And so even just having this conversation and trying to notify the public on what we're looking for in input, I think is helpful. We have an open public process to do that. We also have that opportunity if this would— gets picked up again by the Ecosystem Committee through that, through that idea. But I, I think that's still on the table.

It's early in the process, but I just didn't feel comfortable going forward with a workshop in the event that we just can't fund that. Thanks.

Thank you. Any other questions?

Okay, any comments on the motion?

Any amendments?

Yeah. Oh, any comments on the motion? Mr. Pamplin. Thanks, Madam Chair. Uh, thanks for the motion, Miss Kimball.

Um, just want to begin by thanking Dr. Stram, uh, for her accessibility, uh, and work meeting with me to walk through this material earlier this spring, her work and presentations at the Ecosystem Committee, and her presentation today. Certainly a lot to this, and I learn a lot each time I hear you present. The white paper that was developed regarding how we incorporate risk and uncertainty in HarvestBECs is a fantastic resource, something I wish I had available to me when I first joined the council process, and glad it's out there because I was trying to string together different artifacts and it's hard to compile it on your own. This is still a very much a, a technical white paper, and thus translating this information into more consumable available public-facing products, and having materials posted on the council's website will be an important resource. I agree with Ms. Kimball about the ecosystem committee's willingness to essentially serve as a focus group to, to review these materials with— is welcomed.

I'm excited about some of the advancements on alternative harvest control rules, um, and, uh, I, I would want to acknowledge I'm a bit concerned if we're getting a little bit too far ahead of our headlights if alternative harvest control rules are based on continued or new scientific surveys, and being cognizant of signals we've been hearing from NIMPS over the past year about budget implications affecting core science and work that may be occurring relative to risk-value tables that may prioritize their work in light of available budget. Also appreciate— appreciate the clarification during today's presentation about whether alternative harvest control rules would be new robust static rules that would replace our current ones, or whether we may have a base HCR and a new alternative HCR would be triggered if certain environmental parameters were met. I'm glad that, uh, item is still on the table by the scientists pursuing this work. Just want to close by acknowledging that we're embarking on this as a way to to improve a functional fisheries framework. We're not doing this because the current system is somehow broken or needs repair.

The last time a groundfish stock was overfished was in the 1990s, and ABCs are rarely exceeded. I appreciate that this initiative is intended to further improve this solid framework that is already in place. Thanks.

Thank you, Mr. Pamplin. Any other comments? Comments? The motion? Yes, Miss Kimball.

I have another comment on my own motion. Um, I just—. I—. One thing I forgot to say that I think was really important from several stakeholders is that introducing new complexity potentially reduces transparency. And so I, I wanted to make sure that, that I just— I, as one council member, is very cognizant of that.

We don't want to make some things better and make other things worse. And so I think we'll keep that in mind as we move forward as well, at I will. Thank you.

Thank you. Um, very good point. Um, so, uh, I appreciate all of the work that you put into this, Miss Kimball, um, and agree with all of, um, Mr. Pamplin's statements of support. Um, and to your last point, I think that It is the, the work to really incorporate more accessible public-facing material, translating all of these nuances and complexities, and, and really how our current system works now is going to be really, really beneficial to our process. So greatly looking forward to that.

So I will ask if there's any objection to the motion.

Seeing none, that motion passes without objection. Any further actions on E2?

Okay, that'll bring us to our lunch hour, or I'm not going to give quite an hour today. Um, we will come back at 1:15 and begin our overview of staff tasking, and then we'll go into public testimony. So we'll see you back here at 1:15. Thank you.

Welcome back, everyone. So we are nearing the home stretch here and ready to begin our staff tasking agenda item. So, um, we have a, um, typically a presentation by Ms. Evans. So following that presentation, we will be beginning public testimony on staff tasking. So please, um, follow, um, follow that accordingly and sign up if you wish to testify on staff tasking before the end of this report.

Thank you. Ms. Evans.

Good afternoon, members of council.

Okay, I'm going to— I'm not— I don't have a presentation to show you, so I'm really highlighting information that's already in the action memo, and I'm probably not going to hit on every point. So if you do have questions on things that I don't cover, let me know. But I wanted to just highlight a couple of things important important items for you. One is to note that this is the meeting at which you generally call for nominations if you want for your advisory panel and your SSC. So you put out that call for nominations after this meeting.

For your decision on appointments, isn't made until December 2026, but we schedule that so that there's an opportunity, lots of opportunity for people to get the word out and apply. One other note on, on committee section of the report, just want to highlight that last year, I believe it was, you had asked that we go and ensure that we have terms of reference across all of our committees, which I believe most of the committees now have met and have approved terms of references. And I've noticed that there's some discrepancies between some because we kind of did it in a piecemeal way. And so one of our tasks over the summer as staff is we'll just go through those terms of reference and make sure that each of them include all of the components that the Council wants to see in terms of reference. So we'll be bringing that back to you in October, that review back to you in October.

Highlighting, just recently posted on the agenda for under this F item is a summary from the Executive Finance Committee. Finance Committee that met on Wednesday of last week. The main message that I want to highlight for you here is that we as a council did receive our FY26 funding, and we also received a little bit of a bump in funding to support— just a one-time bump to support the executive order implementation of the executive order. And that has, at the recommendation of the Finance Committee, allows us to go ahead and book our October 2026 and our October 2027 meetings to occur in person. So if you might recall from before, we had, um, for budget uncertainty, left a little bit of flexibility there.

Um, but understanding that that is a top priority of the Council, uh, we'll go ahead and schedule those to occur in person. So all 4 of our meetings this year and next year, uh, would be scheduled in person. We're also— we'll be putting out an announcement placement to backfill one of— for one of our fishery analysts. We continue to be fiscally conservative, and you've heard that referenced already around the table today, but that's how we're trying to adapt to that funding specific to support the executive order.

The action memo includes information about upcoming meetings, including CIE reviews, so the dates for that, those are included. They'll also be included in our newsletter, but I did want to highlight for your interest that the Council has worked with the Board of Fish to schedule a joint protocol committee on October 16th, which will be the Friday after the end of our October Council meeting. Just a reminder that that is not an action taking form. The committee doesn't take action, but it is an opportunity to provide some information back and forth between the board and the Council, and we will be putting an agenda out for that after this meeting. I'll be talking with the, with the Board of Fish executive director to develop that agenda.

So you should see that probably in the next month or so.

Um, moving on to the tasking and scheduling section of the memo, um, a couple things I wanted to highlight. Um, I think that actually, um, uh, if we could— Miss Hillary, thank you for pulling up the 3-meeting outlook. Um, so this is small on the screen, um, so please please pull it up. It is posted on the agenda so that you can read information, but just information with respect to the next 3 meetings, um, highlighting that we are moving beginning in 2027 into our new timing cycle. Uh, so we will be having meetings in late February and March and in May, um, and then October and December for our, our 4-meeting schedule.

Um, one of the things that we'll bring back for you is, uh, in October is some information about what that means for some of our annual products. You heard a little bit at this meeting about the observer report, but just recognizing cost recovery, there's a number of other things that are on that annual cycle, and we want to make sure that that's clear and transparent how that will work over the next year as we adapt to that new cycle.

Also important to note, in December 2026, and you'll see that reflected in the dates on the three meeting outlook, the SSC will need to have a 4-day meeting to be able to get through all their groundfish stock assessment information because they are still catching up from the year of the shutdown and the, the additional stock assessments that they're reviewing as a result of that. And so that will have cascading impacts for the Advisory Panel and the Council. We anticipate both of those to start at least a day later than normal, so just be aware to look at the dates carefully. So the Council in December will be starting on Friday instead of on Thursday.

Okay, so with that, I can walk through some of the highlights on the 3-meeting outlook. Just to— this revised jury meeting version, we'll also post another version with our newsletter that will probably look similar to this. But because we do have a longer time between now and the October meeting. We usually put out the October agenda around August 1st, you know, a couple of months before the meeting, and we'll try to update the 3-meeting outlook at that time too, after we've had more chance to have conversations within our staff and also working with Mr. Kerlin's staff as well. But looking at the October agenda, I wanted to highlight that we have tried to include some of the items that you took action on at this meeting.

Um, in your B2 motion, um, the EO 14267— I don't— 276, that doesn't look right. Um, we, uh, that's where we— you'll get updates back on some of the information you requested, um, on the discussion paper on observer provider and cameras in transit. During that report, those are consultations from the agency back to the Council. We also— I mentioned groundfish specifications.

The— because we are— there's an action attachment posted to F agenda, part of the agenda that lays out very clearly which stock assessments will be reviewed when in October and December, and the SSC is taking final action on some their final action, final recommendations for some stocks in October, which is different than our normal process. So I just want to make sure that everybody's aware of that if you're following those particular stock reviews. However, the Council will take— will not consider your setting specifications until you have all of the information in December. So those will be SSC-only items, but they will not come back in front of the SSC in December. So just wanted to make sure that that was really clear, and that list is in the, in the document if you have questions questions.

We have staff who can help you respond to that.

Other things to highlight in October, you'll see that there's a few different tentative items, or tentative is listed under quite a few different items. Um, we are— need to have some conversations internally about our capacity and how that relates with Mr. Kerlin's staff to be able to produce some of these different products for you. We did try to schedule the other two items that came out of the Bureau reports on discussion papers on PSC disposition and AFA catch accounting changes. One of those is for October and the other one is for December. Again, tentative as we figure out staffing and make sure we have the right expertise available to be able to bring those back to you in the form as requested.

And for— that's— those are the So those are the main things to highlight for the October meeting. Looking at December, that meeting is primarily focused on specifications.

And then going ahead to the February meeting, we have scheduled for you, in addition to cooking salmon, which you take up every February, you have initial review on the herring PSC limit adjustment analysis, and we are, we are tentatively we're scheduling the Gulf Tanner Crab Protection Measures initial review for February as well. As you discussed during that agenda item, we will bring you back a report in October after we've had a chance to review the workload associated with producing that second initial review, and we'll let you know in October if we think that that timing isn't feasible. But that's our first guess at that. We also have the EFH 5-year review progress updates to the SSC that you talked about under the D1 agenda items, scheduled for February as well.

Finally, under the items not yet scheduled section, there are a couple of different items in that section that we anticipate will likely be able to move to the agenda either in October or December. One of those is LEED Level 2 endorsement criteria and also the Norton Soundray Kingcraft participation paper. And we need to have a few more conversations about exactly where— when to schedule those. Those, but you should see some of those changes at our midsummer update to the 3-meeting outlook, if those are— if you're tracking the timeframe on those. And we did signal in the items not yet scheduled that the discussion paper on pelagic trawl gear performance standard would tentatively be for the May meeting.

We're trying to purposely schedule that so that it falls after the SSC review so that we can incorporate the information that will be presented as part of that discussion into the discussion paper, because it's directly relevant to the things that you chose.

So the only other item that I wanted to highlight for you before you move on to public testimony and your, um, your, your discussion of this is circling back to the idea of prioritization, which we talked about in B reports, um, and I talked about as well in the ED report, um, that is our intention to work closely with Mr. Kerland over the summer to talk about where we can make efforts to help structure your conversation with respect to giving prioritization and an effective use of, of your council time. Um, and we'll, we'll plan to have those conversations and hopefully bring back some suggestions to you in October. Some examples of the things that I know that we intend to look at We definitely have a lot of items we're struggling with SSC agenda time and being able to make sure that there's sufficient time on the right timing for all of the items that you want your SSC review on. So we're going to think about how to— whether there's opportunities to be more effective with our SSC time, or at least be more transparent about how we make those decisions.

Maybe talk with, uh, with Mr. Curlin's staff as well to see if there's a way to help structure, um, some— the way in which we present the relative projects, either that are— that you have completed, that are looking at— that NEMSIS is looking to implement, or even the ones in which we require NEMS expertise to be able to move some of your priorities along. How can we present that information to you so you can have a structured conversation in October about providing that prioritization feedback to the agency. So that would be our intent, is to come back with perhaps a way of looking at the various, the various different skill categories or constraints, or just better understanding some of the different tradeoffs that, that affect priorities in how the agency uses its capacity and its skill skill set and how that intersects with your needs and your interests.

That's all I was planning to cover, Madam Chair, but I certainly am able to answer questions. Thank you very much for the overview, Ms. Evans. I'll see if there— yes, Mr. Carlin has a question. Thanks, Madam Chair. Not a question, but I might just amplify a point that Ms. Evans made about the agency's interest in any input from the Council on things that are— maybe the council is done with, but they're in the implementation stages and how we are prioritizing those things given our available staff capacity.

So, you know, again, Ms. Evans touched on it. I think typically the council focuses on what's squarely in the council's arena, but that would be just sort of a different facet where I would certainly welcome input from the council.

Thank you, Mr. Curlin. Um, are you— you're talking about those items that have— we've taken final action on but are pending rulemaking right now? Correct. Okay, thank you. Um, any other questions for Ms. Evans?

Hey, I just did. Oh, Miss Cohen.

Thank you, Madam Chair, and I'm, I'm not sure this is the appropriate place to let me know, but my question is on the action memo under this agenda item, um, and it's on the council schedule looking out into 2027 and 2028, and particularly noting that these October meetings have this coming year and the next couple years are later than they tend to be, which challenges the season start date for the crab fishery. And just looking to where we can, if there's any way. I know we're already locked in for this year, but in the out years, '27 and '28, if there's any opportunity to move those a little bit earlier so that there's more breathing room before the October 15th start date of the crab season.

Through the chair, Ms. Gowan, I do appreciate that, that statement. It's something that we talked about, I believe, at the last council meeting as well. And we have had conversations with Alaska Department of Fish and Game. I think that for the next couple of years when we do have these kind of difficult timeframes, that an interim solution is that they can begin to make their decisions once the SSC takes action on these. It doesn't preclude that— obviously it would require the— if the Council were to make a different decision than the SSC, we would need to be able to react to the Council's decision.

But given given that in the, the council generally adopts the SSC's recommended ABC and OFLs, it seems like a workable solution when we have these time constraints so that it won't hold up the beginning of the crab fisheries. That's the conversation we've had to date.

Thanks for that. And then I guess I would just encourage that the SSC take up that agenda item at the start of their meeting. I know October 5th seems to be a really critical time have that information for all the things that have to happen after that to get it done, but by the start of the season. So that'd be helpful if they could prioritize that first. Through the chair, Miss Gohan, we'll— we will, um, definitely have the SSC take the CRAB specs first.

Thank you. Any other questions for Miss Evans? I'll just, um, express my appreciation for your, your last statements, Miss Evans, about trying to bring bringing back some criteria or considerations for the council as we undertake our prioritization process. And so we're able to— because we will be, you know, really looking at the trade-offs of scheduling, you know, some items in front of others, and will, I think, allow us to have a more structured and meaningful conversation when we're ready to do so, likely in, I'm guessing, October. So thank you so much.

Thank you so much. Okay, anything else? Okay, so we are ready to begin public testimony on staff tasking. Um, let me refresh this here.

It looks like we have, um, quite a few testifiers. Um, I'm counting correctly, 25. Um, so as a reminder to the public, Individuals and companies will have a 3-minute time limit and organizations and associations 6 minutes.

I think if it is going to be, it may be quite tight getting through all of these before the end of the day, and we have limitations because we've only noticed this meeting through Tuesday. So we will, we will need to complete testimony and have time for action. So I just want to make everyone aware of that. I think getting, getting through, making sure we have some productive back and forth and clarification from testifiers and focused conversations will be kind of our main objective this afternoon. So appreciate everyone's cooperation there, both in the messages they share and the questions what we, we ask of testifiers.

So thank you. So we will begin with Philip Powell, followed by Kelsey Trojan.

Sorry about that. That was my fault.

Madam Chairwoman and members of the Council, thank you for the opportunity to speak. My name is Philip Powell. I serve as General Counsel for Global Seas. I'm here to request that the Council initiate staff tasking to evaluate the framework for issuance of an additional AFA shoreside processor permit under existing law. The authority for that evaluation is already clearly established under 50 CFR 679.4, Roman numeral 5.

The Council may recommend issuance of an additional inshore processor permit where BSAI Pollock TAC exceeds the threshold, or in the event of a loss of an existing processor. The regulation further provides that the Council may identify the defined permit structure, and establish procedures consistent with the Magnuson-Stevens Act. Similarly, Section 210 subsection F2 of the American Fisheries Act authorizes the Secretary, upon Council recommendation, to approve measures allowing deliveries to shoreside processors not currently eligible under the existing structure. That language reflects express congressional recognition that additional shoreside processing capacity may be appropriate under certain conditions. In recent— in addition, recent executive orders, including Executive Order 13921 and Executive Order 14276, directs agencies and councils to prioritize actions that increase domestic seafood production, improve market access, strengthen supply chains, and enhance U.S. seafood competitiveness.

Evaluating the pathway for additional shoreside processing capacity fits squarely within those Despite that authority and policy direction, the pathway has never been fully or meaningfully developed in practice. There is little clarity around process, evidentiary standards, sequencing, or implementation. That lack of clarity creates structural constraint. On one hand, there is an increasing recognition that capacity constraints and market consolidation exist within the inshore processing sector. And that the current structure may limit flexibility, competition, and market responsiveness in ways that warrant further examination.

On the other hand, there's no clear and predictable pathway for new entry or expansion under that current framework that leads to practical circularity. Without a defined permitting pathway, it's difficult to advance serious discussions around financing, infrastructural investment, or processor participation. At the same time, without those elements, it's difficult to demonstrate the kind of business viability that would support a permitting decision. Our request is intended to address that threshold issue. A discussion paper would allow the Council, NIMPS, and industry participants and affected communities to better understand the tools available under existing law, the constraints, and the practical considerations that would inform any future decision.

We recognize that the Council and agency resources are limited and that there are differing views within the industry. For that reason, we're approaching this in a measured way. The goal here is to develop industry— develop clarity and a shared understanding of the framework before any substantive policy decisions are made. At a minimum, we believe there is value in putting this issue before the Council, beginning that process, and allowing future discussions to proceed on a more informed and transparent basis. Thank you for your time and your consideration.

With that, I'd be happy to take any questions. Thank you for your testimony, Mr. Powell. I'll see if there are any questions.

Yes, Ms. Baker.

Thank you, Madam Chair. Thank you, Mr. Powell, for your testimony, and appreciate you, you bringing this request to our attention. And you're right, I think this particular regulatory The temporary provision, while very clearly laid out, has never really been used. And so your request to evaluate the pathway is, is grounded in that lack of clarity around how that process would work. But you also referenced creating the status quo creates a structural constraint for additional shoreside processing capacity.

So can you help me understand in terms of the Council questioning, quite frankly, the sense of urgency around this. Is it creating a structural capacity in the sense that there's sort of potential shoreside processing capacity ready to go and this is what's holding it back? Or I feel like maybe you were describing a slightly different scenario. Not a business person, so I'm not as, as familiar with— is this AFA shoreside processing permit regulatory certainty, I'll call it, that we'd like to explore, kind of something that you're thinking is needed to explore financing and per other permitting options to make additional shoreside processing capacity viable? Certainly, and I'm talking about regulatory practical circularity, and it's a fair question.

I think it goes to sequencing. From a business and capital allocation standpoint, legal and regulatory clarity is a threshold issue. Before you can responsibly evaluate or commit to significant infrastructural investment, financing, siting, or operations, you need to understand whether there's a viable and predictable permitting pathway. We do have meaningful operating experience through our East Coast operations, Norpel, and we are involved in processing plants and cold storage facilities. While not as remote as Alaska, we're familiar with the scope, capital requirements, operational considerations, allocations and things associated with these types of assets.

The challenge here is not a lack of understanding about the business, it's a lack of clarity around how existing statutory or regulatory frameworks would be implemented and a regulatory framework would be able to be used. And that uncertainty makes it difficult to responsibly advance detailed business planning or capital allocation discussions. That's, that's precisely the purpose of my ask here today, and to your points, the regulatory uncertainty in the pathway. It allows the council and NIMS to clarify the framework so that industry participants can then evaluate viability in a more informed, disciplined, and responsible way as it pertains to business decisions.

Thank you, Mr. Powell. I completely understand that, and you might not be able to answer this question. I I just, I understand that it is challenging to really invest a lot of time and resources until you have regulatory clarity, but just on a very cursory level, have you been able to kind of assess the viability, like on, you know, land access and in remote communities and other, you know, just basic permitting that might be required from an environmental—. We have a general idea about the commitment and seriousness that would to take. And given kind of the scope and seriousness of it, that's why we think that legal permitting is probably a threshold issue such that without better understanding a clear pathway, further development into those sections would be financially irresponsible from a business perspective.

I, I appreciate that. You know, we are also undertaking some or witnessing some very significant resource constraints on our end. So And this is, it seems like a very substantive or could be a very substantive regulatory analytical process for us. And I appreciate that you recognize that too. So thank you for answering that.

And if I could tack on one more point, I think, you know, as we talk about Dutch Harbor, there's, I think, 3 owners that own the 5 processing plants. We're also bumping up against threshold processing limits. Many of these plants are also aging. I think there's only one or two things that could happen in a way that would make it business-wise infeasible to operate or difficult, and then we'd be at this table having a different conversation about threshold limits and different issues like that. So I think it's important to start the process early to understand the best way to move forward and develop infrastructure and path forward for the industry and for the fisheries at large, because these infrastructures are interdependent.

Thank you. Thank you for your testimony. Appreciate it. Kelsey Trojan is up next, followed by Bonnie Millard.

Kelsey's not online.

Okay, circle back to Kelsey. Um, Bonnie Millard.

Is Bonnie online? Okay, Bonnie, can you unmute yourself, please?

Yeah, me now?

Yes, yes. Okay, so I'm— I'm hope I'm testifying. I'm just testifying, uh, in regards to the, um, unguided sector. Is it—. Is this the right meeting?

Yes, I believe so. Well, we'll see. Okay, well, stop me if it isn't— maybe I'm confused, but, uh, okay, let's say, uh, unmute. Okay, okay, hold on here. I'm caught a little off guard.

Um, hold on a sec. Okay, so I would like to thank you for taking my testimony. I would like to begin by stating that Alaska's halibut resource is currently at an all-time low, approximately a 40-year low, and is approaching an endangered state as a result of irresponsible management decisions. For more than 40 years, I have commercial fished for halibut in 2C, primarily in Cross Sound, Icy Strait, Lynn Canal, and adjacent corridor. I currently participate in the commercial longline fishery to— and operate under the most highly monitored regulatory frameworks in the state.

My vessel is equipped with cameras that operate 24 hours a day through the duration of each fishing trip, documenting all activity. In addition, NOAA enforcement is present at the conclusion of each trip to verify compliance, ensuring that there are no violations and critically that my landings do not exceed my allocated poundage. My logbook entries must match both camera footage and offload weights. This data is accurate, verifiable, and enforceable. Given this level of accountability, it is reasonable to ask why the halibut resource is nevertheless at a 40-year low.

Over time, as the commercial quota has been reduced, I have purchased additional quota in order to remain viable.

We cannot continue to allow 100% resource extraction without accurate and enforceable system of accountability. The rapid expansion of unguided fishing effort is alarming.

The increasing harvest by anglers is actively decimating the very corridor in which I have fished for decades. I'm strongly strongly opposed to reallocating harvest away from the commercial sector.

Um, bear with me here one second. Okay.

As IFQ holders, we make substantial investments that contribute directly to Alaska's economy, unlike some unguided participants who in certain cases may not pay pay local taxes. IFQ holders purchase quota, maintain vessels, employ workers, and support local businesses. We spend, as well as myself, have spent hundreds of thousands of dollars on vessel maintenance upgrades and operating costs in order to remain competitive and adapt to an ever-changing fishery. These investments are common among the IFQ holders throughout the fleet. If unguided participants wish to harvest a larger share of the resource, they should be subject to the same market-based system and investments that IFQ holders have made through the purchase of IFQs.

Thank you very much for your testimony, Ms. Ms. Millard, thank you. Thank you. Let me, let me see if there are any questions for you.

I'm not seeing any. Thank you again for joining us. Thank you very much.

Lindsay Anthony is up next, followed by David Creighton. Hello, can everybody hear me okay? Yes, we can. Good afternoon. Awesome.

Good afternoon. Thank you guys so much for your time today. I'm reading I am reading this statement on behalf of my fiancé, Jonathan Davis, who is on the water today. Johnny has served as a charter captain for more than 20 years. My family has called Southeast Alaska home for over 30 years and continues to rely on these resources as part of a subsistence lifestyle.

These waters are not just where we work, they are part of our family's Dait way of life. After 20 years in the industry, Johnny can tell the difference between the normal ups and downs of fishing and a broader decline in guest satisfaction. Action. The disappointment this year is real, and it's affecting whether anglers choose to return. One of the most common things Johnny hears from his guests this year is that they do not want to keep the extremely small fish.

More than once, an angler has looked at a fish and said, 'That's so small, I don't even want a picture with it.' Others have told him, 'It's so sad to kill such a little fish.' The reality is that a life is being sacrificed for a very small amount of meat, and many guests simply do not feel good about that outcome. This year, captains and anglers routinely spend a full day on the water and leave disappointed because they are unable to keep even a single fish. One trip, for example, more than 18 halibut were brought to the surface only to be released because of these regulations. That day, no fish were kept— they were too big by mere inches. It leaves anglers questioning the thousands of dollars to travel to Alaska and experience one of the world's unique and premier sport fishing industries.

For some, this was a once-in-a-lifetime opportunity. This regulation is also increasing operating cost. To find fish that meet retention requirements, captains spend more time searching and covering additional water. That means more fuel burned, higher operating costs, and more financial strain on family-run businesses like ours. The disappointment does not end when the trip is over.

Guests who are leaving dissatisfied are not rebooking this year, and they're vocalizing it's because of the regulations. When they feel disappointed, it affects gratuities as well. For captains and crew members who rely on these tips as part of the income, that impact is already significant by thousands of dollars. I've shared Johnny's experience on the water, but mine comes from the home front. I worry about the long-term impacts these regulations may have on the community that we call home.

Less anglers means less money spent in local businesses and fewer opportunities for working families. Families. For example, gift shops, working for the airlines, cleaning Airbnbs, restaurants— the list goes on. As a mother, I think about the children my daughter calls friends and the difficult decisions their families may be forced to make as the economic consequences of these regulations continue to ripple through our community, the ones that my family is making ourselves. For years, our family in this industry have adapted to the regulation changes because we trusted that they were being made in the best interest of the resource and the people who depend on it.

Today we are here because we have reached our breaking point. The disappointment we see from our guests is affecting rebookings, which is increasing cost, reducing income for the captains and crews, and impacting family livelihoods. Thank you very much for your guys' time.

Thank you very much for your testimony, Miss Anthony. Um, I, I've— I guess I have a question for you. I'm not sure if You know, if you can't answer it, that's totally fine. I've been really curious about how to measure that guest impact on regulations, you know, as they change and can change very, very slightly. And wondering if you could provide any more context for how your bookings are being affected.

Or any other context for the impact that you're seeing by more restrictive management measures? So I think unfortunately Johnny would be able to better speak to this firsthand. I'm just the one at the home front, but I feel like our guests over the last 20 years have gone with the web and flow of the restrictions continuing to decrease decrease and the 34-inch fish, just because of the quality of meat. Um, the frustrations that I expressed in my testimony are hitting its breaking point. It's, it's too small.

Um, I don't know if that answered your question or not. Yes, that's helpful. Thank you. So, um, you know, for example, last year with, you know, a lot of people were, oh, the king salmon restrictions, the king salmon restrictions, you know, what does that do, what does that do? And this is the first year that we're really seeing the vocalization from the guests as they're checking out that are saying, I'm not coming back here next year because it's not worth it for me.

Okay, thank you for that. We appreciate your testimony.

So next up is David Creighton, followed by Scott Van Valen.

David, can you please unmute yourself? Oh, he's not on.

Okay, will he be missing?

Okay, we'll circle back to him just in case. Um, Scott Van Valen. Hey, you can hear me okay? Yes, good afternoon. Hey, good afternoon, council members.

My name is Scott Van Valen, and I'm a second-generation owner of El Capitan Lodge, a multi-day sport fishing lodge located on Prince of Wales Island. Our operation has been serving anglers for 38 years and currently operates 7 charter vessels throughout the fishing season. For nearly 4 decades, we have built our business around providing visitors from across the United States with the world-class fishing experience, maintaining an exceptional 85 to 90% repeat customer rate while generating significant economic activity throughout Southeast Alyssa, I'm testifying here today to express my serious concerns regarding the catch sharing plan and the damaging impacts it's having on our business, our guests, and the broader Southeast Alaska economy. A management framework that restricts charter anglers to 1 halibut per day, 34 inches or smaller, combined with mandatory no-retention days, cannot reasonably be considered a fair or effective catch sharing plan. The current system is no longer— or sorry, the current system no longer reflects the original intent of providing meaningful harvest opportunity for guided sport fishing sector.

For the first time in our 38-year history, El Capitan is experiencing significant trip cancellations directly related to halibut size restrictions and weekly measures. During the 2026 season alone, we have lost approximately $231,000 in bookings, with customers specifically citing halibut regulations as the reason for canceling their trips. These are not projected losses, they are real losses that are already affecting our business and local economy today. Our historic repeat customer rate is a testament to the quality and value of Southeast Alaska fishing experience. Today, however, many longtime anglers no longer view Southeast Alaska as a destination that provides sufficient value to justify the expense of coming here.

The guided sport fishing industry contributes approximately $271 million annually to the coastal economies of Southeast Alaska and serves as a vital economic engine for many communities throughout the region. The council must recognize that the current allocation framework is failing to provide meaningful access for charter anglers and is causing measurable economic harm throughout the region. The existing management system has evolved into one where the guided sport fishing sector bears a disproportionate share of conservation measures while receiving increasingly limited harvest opportunity. The result is a system that is neither equitable nor sustainable. I respectfully urge the Council to provide a comprehensive review of the catch sharing plan plan and to consider immediate management adjustments that restore meaningful and equitable harvest opportunity for the guided sportfishing sector.

The current framework is producing unintended economic consequences that are harming businesses, communities, and Alaska's reputation as a premier sportfishing destination. Maintaining status quo will continue to erode customer demand, reduce economic activity, and threaten businesses that have spent decades investing in Alaska's tourism and fishing industries. Thank you for your consideration and your continued service to Alaska's fisheries and coastal communities. Thank you very much for your testimony, Mr. Van Vaelen. I'll see if there are any questions.

Seeing none, thank you for joining us.

So Paul Clampett is up up next, followed by Lloyd Krompka.

Thank you, Chair Dubrovnik. I'm sorry, Dravnicka. That's Dravnicka. Thank you, and, and council members. Uh, my name is Paul Clampett.

I'm president of the Sablefish and Albatross Association, and I also appear day on behalf of the Fishing Vessel Owners Association. I own and operate the fishing vessel Augustine, a fixed gear IFQ sablefish vessel. My testimony today is concerning the delay of the implementation of allowing the release of small sablefish. The council approved the release of small sablefish in 2025. The science is done, the review is done.

We are asking that it be implemented in time for the 2027 season. Since 2014, continuing record year classes have been good for the stock. Quotas are up and prices are finally rising, but there's still lots of fish under 22 inches with significantly lower market value than the mature fish we target. These fish are better off in the water. Dr. Ian Kanucki's yield per recruit analysis makes it— makes this case definitively.

When discard mortality is low, and NMFS' own research puts it around 12%, Releasing these small fish returns greater long-term value than retaining them. They survive, grow, and recruit into the spawning biomass. Keeping them is not conservation, it is waste. What I ask this council to consider is that the freezer longline fleet, large catcher processors fish the same waters, target the same sablefish under the same plan. They already have the right to discard sablefish of any size today, right now.

No new rules needed. Needed. Our smaller vessels do not have that right. We are asking for the same treatment for the same fish in the same fishery. We know the National Fishery Service has cited stock assessment model updates as a reason this rule cannot move until 2028.

With respect, those are two separate things. The rulemaking is completed— Council is, is a completed Council action. The model update is an integral agency matter. One should not wait for the other. The Council has already made the conservation determination supported by the National Fishery Service's own peer-reviewed science.

The National Fishery Service obligation is to implement that determination, and updating the population model is subsequent bookkeeping, not a legal prerequisite that justifies years of delay. We are asking for 2027, a completed rule ready to transmit. The rulemaking is done, the science is done, we respectfully ask the Council to encourage the National Marine Fisheries Service to treat these as the separate tracts they are and move this rule forward. I'm requesting that the Council formally seek assistance from the National Marine Fisheries Service headquarters in Washington, D.C. to advance implementation of the approved small sablefish release rule through the regulatory process in time for the 2027 fishing season. And thank you for continued leadership on this issue and the opportunity to testify today.

Thank you very much, Mr. Clampett. Yes, Miss Gohn.

Thank you, Madam Chair, and thank you, Mr. Clampett, for the testimony. We heard about this under B reports as well, and you probably saw the AP motion on this issue. And I'm not sure if my question is more for you or Mr. Kurland, but you mentioned the need for the stock assessment to be adjusted as part of the holdup, but my understanding was it's also requiring some changes in the IT systems at the agency. I guess I'm just looking for some clarity on what the holdup is.

Through the Chair, uh, thank you for the question. I, I'm not, I'm sorry, I'm not familiar with that, with that term IT. I don't, I don't know what that, that is. I, I, we got an email from the National Fishery Service that stated that it had— unless I misunderstood— that it had to do— the delay had to do with the fact that they had to adjust for catch accounting and population dynamics. And through discussions with people in Washington, D.C., I actually talked to Laura Grimm there And, and she told us that the two were not related, that they may be related, but they're not, it's not required.

You can go through the rulemaking without a make, and you could do the adjustments later. I mean, you could put a, you could, you could use a, choose a mortality rate and use it as a placeholder and then say 80% or even 50% and, and, and then continue with the rulemaking and then you could adjust that later. That's what we were told.

Thank you. Um, I, I think we did hear a little bit about the complexities in the implementation during B reports, but, um, can, uh, have a probably, uh, reminder of that, um, when we complete, uh, public testimony, probably on the side would be great. Um, Mr. Klampa, I, I appreciate that, um, you've brought this to our attention and understand how much of a priority it is for you Um, I'm really, uh, interested, just circling back to the introduction to staff tasking and, um, Ms. Evans highlighting how she's going to bring back some, you know, considerations for us as we prioritize things in within our queue, as well as when we're communicating with the agency when these types of issues are, uh, present themselves when we know that there are limited resources limited capacity, but, and there are a number of things in the queue. So if, and that the agency is welcoming some direction from the council, but I'm interested as far as the structure of the conversation that we have, what are, wondering if you could really highlight a little bit more your concerns related to the holdup right now. Are they, I understand that it's been longstanding and a priority, but things that you want us to consider as far as why this should go ahead of the queue of other things that we direct or we provide guidance to the agency on, you know, barring that we may not have control if they're really, you know, technical components that are just going to require more time.

So is it, you know, are they compliance issues? Are they something else? So I just, I want to better understand what, you know, what your primary concern is so that we can consider that in our messaging? Well, thank you for the question. Well, my major— my main concern is the fact that there's a lot of these small fish.

They're easy to fall over the side. And the next thing you know, one of our members is getting a ticket. And members have gotten tickets for this. And here we have a— and so that's my major concern. My major concern is that people inadvertently break the law and is held accountable.

I mean, there's been some pretty draconian, uh, uh, tickets given out already, and there's been, um, um, some of the enforcement that's, that's going on right now has become very nitpicky, in my opinion. The other part of it is, is just the fact that we started working on this 5 years ago, and now we're or, you know, we're talking about a 7-year process to— for, in our opinion, a simple rule change. I mean, how does that give people, you know, um, faith in this system when it takes that long to get something changed? I mean, we started when we tried to get, uh, the pot fishery, uh, allowed to use pots. I believe that from start to finish it took us 10 years.

I mean, this is— I, I— and so, I mean, we've already done all the work here, and, and, and I, I don't know exactly, you know, I, I can't tell you what process goes on behind the, you know, at the National Fishery Service to, to finish this process, finish the implementation of this. But I really appreciate your answer. I hate to cut you off, we don't have some other— but I, I think that you really gave me what I needed. So it's really primarily a compliance issue. So thank you so much.

Yeah, I know you got to catch planes. Thank you very much. Thank you.

So Lloyd Comcoff is next, followed by Madeline Lee.

Hey, good morning or good afternoon. Can you hear me? Yes, good afternoon. Thank you. All right, Madam Chair and Council, thank you for taking your time to review my proposal today.

My name is Lloyd Konkop. I'm a tribal member of the Native Village of Chenega. I am also the president of the Chenega IRA Council, and I hold a Shark Card under the tribal rules, not, um, rule. So what I was asking today is a change or an addition to NR 300-65H, limitations on subsistence fishing.

Subsistence, under the rules or application, it says you got 6 questions to answer why, why, how should the new regulations read, why should the regulation be changed, what impact, how it'll affect subsystems users, and what the effect is on other sports, recreation, and commercial. Currently, currently under the rule, what I'm trying to change is the addition, and you guys have a copy of the letter that we submitted. So I'm gonna not read it word for word.

I, I believe you guys got a copy, and, uh, what I'm trying to add under the new section of the current regulations, 50 CFR 300-65h, is an exception to the rule. While a shark card holder is actively harvesting subsistence halibut in an approved area, They may utilize immediate family—mother, father, grandfather, grandmother, husband, wife, son, daughter, stepson, stepdaughter, grandson, granddaughter—to do any fishing as long as a current shark card holder is on board the vessel.

The way it reads currently is under the CFR R5300.65H. It says fishing means the taking, harvesting, and/or catching of fish, or any activity that can reasonably be expected to result in the taking, harvesting, or catching the fish, including specifically the deployment of any amount of component part of setline gear anywhere in the marine time area. So things like baiting hooks, deploying subsistence gear, retrieving gear, gaffing halibut are all activities that can reasonably be expected and result of taking or catching fish. I'm trying to change that or add to it utilizing, for my purposes, my wife. She qualifies in the state, or in Nome, for subsistence for tribal.

But tribal members cannot go from one area to another area, only rural can. And there will be no impact to this change. We will not increase the amount of fish that we are taking. The fish quota will still remain the same, but it will enhance the safety factor of the user, and it will not affect any change to any other users. All it is is a— the right to utilize family members in a subsistence arena where subsistence is a family event.

Okay, thank you so much for your testimony. I, I thank you for, uh, taking the time. Do you have any questions? Let me see if there are any questions for you.

Yes, Miss Kimball. Thank you for your testimony. I'm just trying to understand the situation. I appreciate you starting to talk about an example. Is it— is the concern concern that, or is the ask that there still would be an eligible Shark Card holder on the vessel but they wouldn't be, have otherwise been eligible in that area, or am I missing something?

Correct. She, my, my, we'll use my wife as an example. I qualify for Area E, her Area E, I guess is 3A. My wife is from Nome. She qualifies up there under tribal enrollment, not rule.

We live in Valdez, so we can't apply for rule. Uh, we go out fishing. She can't help me drive the boat, set the gear, pull the gear, and it's a very unsafe event to try to set my gear by myself and drive the boat and stop when the hooks get tangled up or anything like it, or even if I get hooked myself and try to get in there and stop the boat. By allowing immediate family members, all we're doing is increasing the safety factor. We're not increasing the limit catch or anything.

If I take my son with me who has a shark card, that increases the amount of fish we catch, because I can catch my limit and he can catch his limit, and we're not looking to do that. You know, we're family, and he has his card because he needs it to go out with me. But based on the rules, we should be able to double our intake, and I don't want to do that. I want to be able to be safe and have my wife run the boat while I'm setting Thank you. That explains it.

Thank you.

Thank you very much for your testimony. Okay, thank you very much.

Madeline Lee is next, followed by Jerry Dahl.

Dear members of the North Pacific Fisheries Management Council, My name is Madeline Lee, and I serve as a tribal fish biologist with the Chugash Regional Resources Commission, where I work closely with tribal communities throughout the Chugash region of Alaska on fisheries conservation, subsistence harvest monitoring, monitoring, and food security issues. I am writing in support of the comments submitted by Lloyd Comcoff regarding modifications to the subsistence halibut registration certificate. Certificate, shark regulations under 50 CFR 300.65. Specifically, I support considerations of an exemption that would allow immediate family members who do not hold a shark card to assist with subsistence halibut fishing activities while accompanied by a valid shark holder. Throughout coastal Alaska, subsistence fishing is fundamentally a family-centered activity that serves serves purposes far beyond food harvest alone.

These activities provide opportunity for the transfer of traditional ecological knowledge, fishing skills, safety practices, cultural values, and stewardship ethics between generations. Restricting participation by immediate family members can create barriers to those important cultural and educational practices. From a fisheries and safety perspective, allowing immediate family members to assist in the deployment, tending and retrieval of gear while a shark holder is present aboard the vessel would improve safety, particularly for elders, individuals with physical limitations, and single permit holders operating in challenging marine environments. Handling halibut gear can be physically demanding and in some circumstances hazardous when conducted by a single individual. Importantly, the proposed change would not increase the harvest limits or expand the number of fish authorized for subsistence harvest, rather would allow family members to assist in the harvest process under the direct supervision of a qualified shark holder.

As such, the biological impact on halibut stocks would be expected to be negligible while providing meaningful social, cultural, and safety benefits for subsistence users. Many tribal communities place significant value on intergenerational participation in subsistence activities. The current restrictions can unintentionally limit opportunities for youth to learn harvesting practices from parents, grandparents, and other family members. Supporting family participation helps ensure the continuation of traditional knowledge and cultural practices. For these reasons, I respectfully support Mr. Comcoff's recommendation and encourage the council to evaluate regulatory changes that would allow immediate family members to assist shark holders during subsistence halibut harvest activities while maintaining existence— existing harvest limits and conservation objectives.

Thank you for your consideration of this important issue and for your continued efforts to support sustainable fisheries and subsistence opportunities for Alaska communities. Thank you very much for your testimony, Ms. Lee. I'll see if there are any questions.

Yes, Mr. Ritchie. Thank you, Madam Chair. Uh, thank you, Miss Lee, for your testimony. Um, I guess we heard from Mr. Comcoff, but I'm wondering if this is a common request that, that you're getting in your position. Are you hearing this from, from more people, or is this, um, something a little more specific?

Uh, yes, I think that we are hearing this from more tribal members, and it is, um, it's kind of once one has voiced the concern, we were learning that it is more of a sustained issue that we need to address. Pretty rapidly. Thank you. Thank you, Ms. Lee, for bringing this to our attention.

So, Mr.— or Jerry Dahl is up next, followed by Shaelee Dahlmore. Can you hear me? Yes, good afternoon. Good afternoon. Thank you, Madam Chair and the council, and thank you for this opportunity.

I'm a third-generation Alaskan. I'm 59 years old, started halibut fishing when I was 12. I'll let you do the math on how many years on deck that was. And before that, I was just in the way. I just really cautious this, you know, a catch share plan, changing this catch share plan at this time.

You would be just doing it for the folks that want. And, you know, I want more too. I've started out with, uh, had to purchase 99% of mine, started out with 12,000 pounds and ended up now with 3,500. I've changed my business model to meet my lifestyle. That is my, that's what I have to do to survive.

I don't ask for somebody else's. I don't go to my neighbor and take some of his land because I need more to store some of my gear on that I've had to diversify it into 5 fisheries now.

Just really, really be cautious. Cautious. There's a management plan in place. The RQE, RQE has not yet proven itself or even given it the due process. So please, please don't throw the baby out with the bathwater.

And also, there is another avenue for these charter folks. If you want halibut IFQs, buy them. Take your clients, get a commercial license for 3 to 7 days, or I think it's a 7-day license, you can, you got, you're under a, you're a D-class vessel, you can go jig up as many as you want and sell them to your clients and they can go home with as many halibut as they want that you have purchased. Similar to me, I have purchased.

I don't know what else to add to, but if you have any questions, I'll take them now. Thank you very much for your testimony, Mr. Ms. Shaley Dahl. See if there are any questions.

Seeing none, thank you for your time.

Shaley Dahl Moore is next, followed by Joe Short. Yes, good afternoon. Can you hear me? Yes, good afternoon. Hi, good morning, or good afternoon, Madam Chair and members of the council.

Thank you for the opportunity to speak today. My name is Shaley Dahl Moore. I hold halibut IFQs in area Toosweet. I'm a fourth-generation Peterford fisherman. I'm asking you not to task staff with reevaluating the catch share plan.

I understand that the charter fleet is feeling economic pressure right now. That pressure is being felt on the commercial side as well. When the stock is down or quota is cut, all of us feel it, but we do have a stock biomass issue, and this is one that I think all of us— charter, commercial, subsistence, etc., need to work on, work through together. The plan already has mechanisms built in for low abundance, including increases to the charter allocation and the RQE. Like my dad just said, I purchased my quota 13 years ago at age 16 as a long-term investment in the halibut fishery and in my future.

Reopening this plan right now when it hasn't had the chance to to work, creates uncertainty for young fishermen like myself who are trying to build a future as lifelong Southeast Alaska residents, not only for ourselves but for our future generations as well. Thank you very much for your time, for your work, and the opportunity to speak today. I ask that you do not task staff with reevaluating the catch share plan. Thank you. Thank you very much for your testimony.

Tsi'aa. Absolutely.

Joe Short is up next, followed by William Connor.

Yeah, good afternoon. Can you hear me? Yes, good afternoon.

Good afternoon, Council, Madam Chairman. I'm testifying against SECO's request for more halibut pounds. My name is Joe Short. I'm a third-generation fisherman. I qualify I qualified for quota share with a small boat, so through the years I bought half of the quota I now own.

The last few years I've watched the charter and sports sector grow unbelievably. It seems that it's, you know, it's out of control for the amount of resource available. We have a catch share plan in place, and we've built business plans around these catch share plans.

We all know that the halibut stocks fluctuate up and down, and we all suffer in these times of low abundance. I have two kids that have financed and bought quota for— and for the last two years, they've not made their payments from their halibut income, and they don't expect to for a few more years until the stocks rebound. The charter sector already has 18.5% of the 2C stock and have provisions built built into the catch share plan to allow for an increase in allocation in times of low abundance. They also have the GAF and soon the RQE coming into play, which allows the charter sector in 2C to buy 10% more of the 2C IFQ at a ratio of 1% a year. And at today's level, that would be an additional 280,000 pounds The commercial sector has none of these tools to help our business in times of low abundance.

The commercial sector, we also hire our crew, a majority, at least from where I am in Southeast Alaska here, from rural towns and villages. And we do the majority of our boat maintenance in Alaska. We provide year-round work for processors and their workers., and the majority of this money earned stays in Alaska. From my experience, there's a high majority of the lodges are owned out-of-state people who bring in out-of-state guides. They're here for 3 or 4 months and gone along with the money they earned.

So please, let's follow the catch share plan. Let's give the REQ a chance to work. Work and, uh, not disrupt our business plans. Thank you, Council.

Thank you very much for your testimony. See if there are any questions.

Not seeing any. Thank you for joining us. Thank you. William Connor is up next, followed by Bernie Burkholder.

Okay. Hello, Council, do you hear me? Yes, we can. Welcome. Okay, thanks for taking my testimony.

I'd first like to start out with, I do oppose SEGO's request to be reallocated IFQ from the commercial sector. I have fished for halibut starting in 1975. I have seen the halibut quota increase and decrease over the 51 years.

I have made and still make my living on this fishery, supporting my family and an additional 4 families during this time. When IFQ was imposed on the open access halibut fishery, I invested over $350,000 to purchase more quota, halibut quota, to fish. Then at some point along the way, there was a reallocation of quota to the charter industry, and I lost 18% of my investment overnight. And as the halibut biomass has decreased, so has my harvestable pounds decreased. Just as a charter industry harvest has decreased, and because of poor regulations on the unguided halibut register last year, I've been hit with another additional 9% decrease.

And yet I still need to make a living and will make do with what quota I have left. I do not agree with the mandami redistribution that has taken place to date, so I am against any redistribution of halibut quota to any industry, and I request the council to this request forever. In addition, since IFQ was adopted, my contribution to Alaska's economy from my halibut business, I can calculate at around $4.5 million through crew shares, through a local Alaska business, grocery, mechanics, fuel, shipyard, hotels, bait sales, etc. The calculations I come up with is 35 years, and if I average out what my quota has been, it's been as high as 100,000, it's down to 20,000 now. If I use a 30,000-pound figure, that's 900,000 times $5 a pound gives a $4.5 million contribution to Alaska's economy.

The problem that exists is while the commercial halibut fisherman fleet has been capped since 1995, the charter industry has continued to expand at, at exploding rate. I believe if we go back to 1995 and cap the charter participation at that date, the need for more resource would be met by the reduction in that fleet. Thank you for your time.

Thank you. Any questions? Thanks for your testimony. I'll see if there are any questions. Questions for you.

You're welcome. Okay, seeing none, thank you.

Okay, Bernie Burkholder is next, followed by Alan Ottniss.

Hello, my name is Bernie Burkholder and, uh, I own I own, or part owner, family-owned business, 4 vessels. 2 Of them fish almost exclusively in Alaska. And I began working on, I guess, pot catching sablefish in 1990, I think it was. And we have, we're here today at, at, you know, the 2026 trying to implement, you know, the rules to release small sablefish. And I understand things go that way.

I'm part of the process, so I understand, I guess, the process. But I'm here today to just ask, you know, for any help we can get in reprioritizing prioritizing getting the release of small sablefish done. It's just, it's gone on, I think, for too long. I'm not here to blame anybody. I'm not here to point fingers at anybody.

I'm just here to say, look, this is a prioritization that if we can take care of, we should do it. I think I could give you a lot of statistics, a lot of dates.. But I think you've heard a lot of that already, and I'll just end there. And if you have any questions, I'd be glad to try to answer them. Thank you.

Thank you very much for your testimony. Earlier this meeting, someone was asking about their transcript and whether or not it was accurately being portrayed, and you said that you started fishing in 1919, so I started laughing. Um, you're— yeah, you're aging very well.

My apologies, I started fishing in, uh, 1985, I guess it was. I don't know where that came from.

Okay, Alan Ottness is next, followed by Matthew Short. Thank you, Mr. Burkholder.

We'll circle back to Alan. Matthew Matthew Short is up next, followed by Nels Evans.

You got me here. Good afternoon.

Hey, good afternoon. My name is Matthew Short. I'm calling in opposition of a CGO's request. I'm a fourth-generation commercial fisherman born and raised in Petersburg. I grew up in the halibut industry and I've spent roughly half a million dollars on purchasing halibut IFQs in TOC since I was 19 years old.

In that time, I've seen my quota consistently being cut over and over and I understand I understand that being for low halibut abundance to help conserve the stocks. I'm all for that. What I'm not okay with is taking cuts due to other sectors overfishing their allowance. Last year, the unguided charter boats doubled their allowance, and for that, we commercial guys took a 9% cut, even though IPHC kept the TAC in see status quo for the year. The commercial sector is highly regulated between observers and all the regulations we have, and yet we're losing poundage to a highly unregulated sector.

Adjusting existing regulations rather than addressing the unrestricted growth of another harvester group seems irresponsible to me. Thank you for Thank you for your time. Thank you for your testimony.

Yes, Mr. Mueller has a question.

Good afternoon, Mr. Shorten. Thank you for your testimony. So we've heard two— excuse me— at least two testifiers reference the unguided sport here. One referred to the removals as alarming, and And you, um, in your testimony, you, you mentioned doubling the removals.

Can you give me a sense of, um, what these removals are?

Oh, I, I don't know what the, the exact numbers are. Um, that's just what I've been told. And, uh, but they, they are highly unrated. Regulated. You know, us as commercial guys, every, every last pound is counted for, accounted for.

They can go out and catch and have nobody check them and just, it's highly unregulated.

Thank you for joining us.

Thank you. So Nels Evans is up next, followed by Michael Lake.

Yeah, hello, Council. Can you hear me?

Yes, we can. Welcome. All right, thank you, through the Chair. I'm Nels Evans, Executive Director, Petersburg Vessel Owners Association. Petersburg Vessel Owners Association is a commercial fish and trade association based out of Petersburg, PVOA represents commercial fishermen that participate in a broad array of fisheries with all gear types in both state and federal fisheries of Alaska.

One of the largest contingencies of our membership are halibut and sablefish IFQ harvesters. Our membership is acutely aware of the challenges that are being faced by the halibut and sablefish industries, and I would like to express some of those concerns. Concerns today. So first off, I would just like to highlight our support for the ask by Fishing Vessel Owners Association in prioritizing and continuing to elevate the adoption of small sablefish release. We originally thought that we would have that regulation in place for the current 2026 season.

It now It looks like we won't have that in place until 2028. If there's any way that we can get that by 2027, the fleet would be largely appreciative of that. I just wanted to echo our support there. Second, we would like to address the ask put before the council by SEGO. We are opposed as an association to the reallocation of 2 CIFQs to the charter sector.

Charter sector. Petersburg would be acutely impacted by this as the largest 2C quota shareholding community in the state of Alaska. So, we would feel those impacts larger and broader than, than any other community. Currently under the CSP, the charter sector already gets an increase in their 2C allocation up to that 18.5% when we are in a low abundance regime, which we currently are in.

They also have the ability to use GAF pounds, which there has been a large adoption of since introduction. And then the RQE has finally become implemented and they are able to buy into the, the first year of the program currently, buying 1%, potentially 1% of the 2 CIFQs per year for 10 years leading up to total ownership in the RQE of 10% additional of the 2C quota. There are currently more routes and avenues available to the charter sector to provide them with more fishable pounds at any biomass level, but particularly at low biomass levels. There's nothing that works the opposite way for the IFQ fleet. I just want that to be emphasized.

Uh, we believe that this is a wholly irresponsible ask to open up the real— any reallocation issues between the fixed gear and charter sectors when the elephant of the unrestricted growth of the unguided charter sector is still in the room. That sector saw almost 50% increase last year from roughly £700,000 to £1.45 million. So to answer a question asked to the previous testifier, it was in the ballpark of a 700,000-pound increase. That increase in harvest by the unguided sector in one year led to a 9% cut in the directed harvesters' tack, both IFQ and charter. So IFQ fishers saw their quota decrease, the charter sector went down a Harvest Tier 2 in the CSP tiers.

We encourage the Council take no action on CEGO's request at this meeting and want to continue to highlight the negative impacts the halibut, the halibut fishery in 2C is seeing due to the unrestricted growth in the unguided sector in the region. We believe that this should be the priority in management for halibut management in the, in the region before moving into anything anything else. Finally, we want to highlight an issue that we have recently become aware of in regards to interest from a new vessel wanting to use the Golden Fleece's permit to harvest flatfish in the Gulf of Alaska. That permit does not have any halibut sideboards and has differential monitoring requirements than other non-pelagic trawl catcher processors. We are concerned on the potential halibut PSC increases that could occur from the renewed usage of this permit without additional sideboards for Halibut.

Uh, we have very recently become aware of this and don't have much more information, but wanted to flag it before the council while we are raising other halibut-related issues. Uh, and finally, I just want to thank the council for the opportunity to speak here. I appreciate the work that you guys are doing. Happy to answer questions. Thank you very much for your testimony, Mr. Mr. Evans, Ms. Baker has a question for you.

Thank you, Madam Chair. Thank you, Mr. Evans, for your testimony. And I would like to take you back to your first topic, if you don't mind, the small sablefish release rule. And, and I'm wondering— my question isn't so much substantive, it's more a process question. I thought I heard you say that several members of your fleet had anticipated implementation of that in 2026.

Did I hear that correctly? Because the council took action on that in April 2025, and even under the best of circumstances, um, we don't usually get rules implemented that quickly. So maybe can you correct me? I'm, I'm just trying to get the sequence that you laid out for us. Yeah, no, that, that's correct, uh, through the chair.

That's correct, Miss Baker. That was, that was our hope and dream that it would be implemented in time for this season or partway through, and then learned later on in the spring, closer to the season start date, that the likelihood is a 2028 season implementation now. So, it was a hope by the fleet that we would have it by then.

Thank you, Mr. Evans.

Okay. Ms. Van der Hoeven has a question.

Question. Thank you, Madam Chair. Thank you, Mr. Evans. Um, my question is on your last topic, um, the regarding the Golden Fleece replacement vessel, and I just wasn't 100% clear what your concern was. There are some measures in place from when that program was implemented and those, those would apply, and it's a vessel that hasn't fished in this fishery, so I'm just not real clear what the concern is for a vessel that hasn't participated in the fishery yet.

Yeah, through the Chair, thank you for the, the question, Ms. Vanderhoeven. Our concern is exactly that, it hasn't participated in the fishery, and so we're worried about potential halibut PSE mitigation measures, sideboards that may not have been in place and haven't been caught in this time. So we just wanted to raise that, raise that there is renewed interest and wanted to make sure that proper protections for halibut are in place considering we're at a time of low stock abundance, just out of general concern and wanting to flag it.

Thank you, Mr. Evans. Thank you. Michael Lake is up next, followed by Chad. See, members of the council, for the record, my name is Michael Lake. I'm the owner of Alaskan Observers, and I'm here to comment, uh, on the council's EO recommendations, uh, And I'll be very brief.

First of all, I want to thank the Council for your support with regard to the B2 management report Council motion on June 5th. Some further modification, more, or some more work on the modifications of the statement of projected observer assignments that must be submitted by the observer provider. It's greatly appreciated that we can have a dialogue. Earlier I heard Ms. Evans say that there could be a potential of bringing a paper in October or December. And it was a little unclear, couldn't find it anywhere, but if I could ask the question and maybe get an answer when I'm done here about the modifying the endorsement criteria to allow hauls in the at-seek Hake sampled, is that the paper?

And then I can get that here in just a moment. Again, this has been a lot of work, and, you know, I've been following this meeting, looking at the workloads, working at all the committees, and it's— boy, no wonder you guys are, you know, tired when you go home after these weeks. And thank you so much for all you do. I'd also like to thank Nicole, Miss Kidman— sorry— to, you know, for writing the promotion. I'd like to thank Chad for all of his hard work lobbying in the hallway there.

And then finally, I'd like to thank Mr. Tsukada for his service. Alaskan Observers and CBRF has had a long-standing relationship, and Mr. Tsukada, I'd like to thank you for your service. And you know, one of the things as I was looking at the workloads and such, I realized that, man, you guys are busy. But we're all busy except for one person, and I'm gonna make fun of him on just a hair, but this is his last meeting. He's been my hunting and fishing partner since 1992, and he has now become the greatest living fisherman, or greatest traveling fisherman in the world, and that's Chris Oliver.

And thank you, Chris, for serving for the second time with with regard to the council. With that, I will just ask one further question. Why isn't the modified— the minimum sample haul requirements to obtain LL2 certification on trawl vessels to 60 sampled hauls rather than 100— not included? We've been after these two modifications for 15 years, and we built a record with regard to those. So again, I appreciate everything, but I just don't want to get too far kicked down the road too far.

Thank you very much, and I'll be glad to answer any questions.

Thank you very much for your testimony, Mr. Lake. Perfect. Thank you. Thank you.

So Chad C is up next, followed by Wes Jones and Glenn Chad Merrill. All right, Council Chair, members of the Council, thanks for the opportunity to speak today. My name is Chad. See, I'm the Executive Director of the Fraser Longline Coalition. I'm following up on comments I made under B reports to ask that Council schedule the initial review on the LL2 endorsement criteria initiated by Council last October.

We appreciated the action by Council to initiate this initial review as a follow-up to its June and October 2025 motions identifying recommended actions consistent with EO 14276. This action reflected specific regulatory measures identified by observer providers to address longstanding challenges with Lead Level II availability and to reduce the regulatory burden on providers and their fishing vessel customers. These challenges are no less pressing for our fleet today than last October. We appreciate the very challenging resource and time constraints that Council and the agency faces with scheduling actions and are encouraged to hear this afternoon that this analysis is under consideration for scheduling at an upcoming meeting. Our observer providers are facing threats to their operations that go beyond the level 2 availability and to sustain their businesses.

This action was initiated— since this action was initiated, continued deployment challenges and higher costs associated with meeting full coverage observer needs of fleets is only making them more difficult for our providers to operate, particularly without overburdening their— our fleet and their— and other customers with additional expenses. Looking ahead, losing additional observer providers could threaten the viability of the agency's full coverage observer program, not just for our fleet but for all full coverage participants. We believe it's important that Council take up action as soon as possible to help find solutions to this problem. Our expectation is these actions will not require a significant amount of analysis on the part of the agency or Council staff. The proposed measures are narrowly targeted changes geared, as reflected in the, uh, in the Council's purpose and needs statement, toward modifying existing criteria for observers to secure their lead Level 2 endorsement, with the intent to increase the pool of lead Level 2 qualified observers and mitigate potential impacts of Lead Level 2 shortages on vessel operators.

The action also proposes to grant Observer Program the authority to waive Lead Level 2 requirements for observer deployments on full coverage vessels when no Lead Level 2 observers are reasonably available. It's important these measures are analyzed to ensure that they do not diminish the quality of Lead Level 2 observers nor take away from the ability to achieve the monitoring objectives on full coverage fleets. Our fleet shares an interest in maintaining first-rate observers who provide accurate data for use by the agency and our vessels. With that said, this would appear to be a pretty straightforward analysis. With the new FMA director now in place, we are hopeful this also affords some additional capacity to take up this work soon.

As a note, FLC has a separate item in the batterer's box as well addressing the use of flow scales in the fishery. I've had some questions about timing and interest in moving this action forward as well. Our thought is that this issue may best be taken up as part of our EM project that our fleet is undertaking. With that said, we'd suggest keeping it in the batter's box until we have a chance to talk more about its fit with that project. Also, on the question about pending regulatory measures awaiting implementation, I'd put a plug in for ensuring the Council's action to adjust groundfish MRAs is recognized as a top priority.

This action will provide meaningful improvements to groundfish harvesting but also address confusion on MRA rules that has contributed to erroneous and contentious enforcement actions. That all. Take any questions. Thank you, Mr. C, for your testimony.

Yes, Mr. Pamplin. Thanks, Madam Chair. Mr. C, appreciate you recognizing, uh, the, the various issues that are on our docket. So I just want to make sure, really understand, as we're thinking about for staff tasking, so the Sablefish flow scale issue, you're saying it can remain in the batter's box, not be assigned a date at this point because it's likely going to roll forward into the, the freezer longliner EM project? Is that, is that right?

Thanks, Nate, through the chair. That's what we believe can be done with that, with that issue at this time. We just ask that it stay in the batter's box for now, uh, until we can confirm that that is a great fit for that.

Thank you very much for your testimony, Mr. C. Thanks. So Wes Jones and Glenn Merrill, followed by Kathy Hansen.

Good afternoon, Madam Chair. Can you hear me? Yes. Good afternoon. Okay.

Good afternoon. I'm Wes Jones, NSCDC's quota manager, and thank you for the opportunity to provide comment. I'll provide some comments and then Mr. Merrill will follow me there in person. Under the CDQ program, the Pacific cod allocation apportionment is not further allocated by season, providing groups the flexibility to use it across gear types. Peacod is an important species for both directed and indirect harvest for the sector.

While there is no seasonal allocation, there is— there are seasonal limits for by gear type, making allocation schemes challenging challenging and inevitably leading to unutilized quota. In several cases, there are more restrictive for the CDQ sector than non-CDQ sector. The CDQ sector has been considering the potential benefit of removing the seasonal apportionment restrictions to the PUCOT allocation. The elimination of seasonal apportions could— would clarify the current regulation outlined in Amendment providing the sector with greater flexibility and potentially improving utilization. You know, the most important issue is, is that regular regulatory clarity for this situation.

So, and before I turn it over to Mr. Merrill, I'd like to thank Mr. Sakata for his time on the council and his work there. Thank you. Thank you very much, Mr. Jones. Mr. Merrill, thanks for the Vancouver, uh, portion of the testimony.

I just wanted to highlight, as an operator, we participate in the multi-species CDQ program. We harvest for 3 CDQ partners. The overlap of inconsistent regulations with the CDQ seasons and then our seasons that we have for our operations are certainly very complicated. Add to that the complications of additional groups, and I think what is perhaps an inconsistency inconsistency with the regulation of harvest provisions, which require more restrictive limitations on CDQ participants than non-CDQ participants in LAPS that are applicable to some of the fisheries we participate in, raises some concerns that we'd like to address. I think our hope is that the Council recognizes that this is an important issue of regulatory clarity.

Our preference would be to try and see if we could address this through the EO efforts that the Council has ongoing. If not, then I think we're looking at some other regulatory amendment package. I think it can be limited in scope. I think it can be very focused on this specific issue, and I think by removing these seasonal apportionments or gear limitations that exist for CDQ groups and aligning them with how the allocation is actually made to the CDU program, which is not by seasonal apportionment, that would provide great clarity for us as operators and ensure that able to fully harvest for our CDQ. Uh, that— so thank you for your time.

Happy to take any questions.

Thank you both. Uh, Mr. Sakata?

Yes, thank you. Thank you very much for the testimony. Um, of course, CDQ has always been near and dear to my heart, and I think it's generally known that CDQ quota cannot be more restrictive than the other quotas is, um, can you explain briefly why the 2012 regulations of the harvest rulemaking didn't resolve this? Was it some action, oversight?

Through the Chair, Mr. Cicada, and I'd also like to join Wes in thanking you for your service here on the Council. I think it's a little bit complicated, but short story is when the current non-CDQ specific cod regulations were put into place. It was roughly the exact same time that there were the regulation of harvest provisions that we were still struggling with in terms of how those would be implemented through the Magnuson-Stevens Act amendments. And so when Amendment 85 went into place, I don't think the specific issue of looking at CDQ gear was really addressed by the agency at that time. And since that time, I think there have been changes in how CDQ fisheries have operated that have just highlighted the fact that there is this disconnect between what was undertaken in '90— in under Amendment 85 and then the existing regulations for CDQ.

Thank you. Thank you, Ms. Kimball. Thank you, Mr. Merrill. Isn't some of this issue mitigated by the fact that CDQ has more flexibility flexibility in where you use your quota? You can move it, it can be on longline gear for cod, it can be on trawl gear for cod, and you can move it around.

And then my second question that I'll just embed in there is like, have you considered, just because it's bringing back memories of cod seasonal allocations and our stellar sea lion restrictions, would we be reinitiating Section 7 consultation if we took this up? Thank you. Through the Chair, Ms. Kimball, so on the first point, you're right, because CDQ is not allocated by a specific gear type, it can be used anywhere. Part of the reason that it becomes then very complicated for operations is that you don't know necessarily as a harvesting partner exactly how much you may have available because there are other needs for other harvesting partners. So that makes it really difficult for us to be able to comply, um, with some of those seasonal apportionments.

The seasonal apportionments that exist for some gear types are highly restrictive as compared to non-CDQ. That also is a challenge when you're trying to integrate CDQ and non-CDQ operations. In terms of Steller sea lions, I think it's important to note that in the proposed rule that implemented Amendment 85, they actually looked specifically at what do we anticipate the total, uh, ACs and catch would be, uh, for all the non-CDQ sectors, assuming that 100% of the under 60-foot harvest would be in the A season. We know that that is not in fact the case. That is not seasonally apportioned now under our existing Amendment 85 seasonal apportionments, and assuming a 60/40 split for CDQ.

Using those assumptions, the agency indicated that 67% of the harvest would occur in the A season. So even if you provide relief from the existing seasonal apportionments applicable to the CDQ program, highly likely it would be less than 70%, which is a provision that was put in place to honor, honor or mirror the requirements that were established in the 2001 biological opinion. Currently, using NMFS available data for the last 10 years, 50% of the CDQ catch has actually been harvested in the A season, and then this last year it was only 47%. So again, because CDQ has to be used throughout the season, I think the likelihood of it in any way creating challenges with our existing regulatory structure resulting in some sort of consultation that wasn't already analyzed or considered when we first authorized the Amendment 85 program seems unlikely.

This is a clarify. I don't think that was really good, but I don't think that answered just my question. I think you're saying you, you would win the argument that it wouldn't have additional effects, but would it? My question was, would it require initiating a Section 7 consultation? So I'm just clarifying my original question.

Through the chair, Ms. Kimball, so my understanding of the process is that the agency, as they undertake the analysis of this action, would consider whether or not it would require consultation. And typically, and we will look at whether or not the action was within the scope of what was previously analyzed and authorized, and provided that it is, which I guess is my argument, then the test stops there. Or you can continue and look at the issue and say if you believe that the action is not likely to jeopardize or adversely modify the typical JAM test that I think we've had in the past, that if that's the case, you undertake an informal consultation under Section 7 of the ESA. So it's an issue that we would address later in the process, but I think it's unlikely we would even have to reach that point.

Thank you, Mr. Merrill. You've heard, um, I think me ask similar questions to other testifiers. I, I think as we, um, you know, we're dealing with resource constraints, the realities of that, needing to do better at prioritizing, um, and do better not putting more things on the list, um, until there's a level of ripeness, wondering if you could just speak to the risks, any, you know, risks that we should be aware of, the urgency of this. I think you spoke a little bit to the complexity. I think that's going to be part of our calculus too.

So just want to verify that. Also, you think that this could be limited scope. We're not talking about, you know, analyzing a range of specific percentages, but just, you know, perhaps maximizing flexibility and removing. So just if you could highlight or touch on a couple of those points as we think about, you know, how to potentially address this concern. It would be helpful.

Sure. Through the Chair—to the Chair. Thanks for the question. You know, I think it's complexity, but it's also a compliance risk. And as you've heard several times during this meeting, I think there have been many concerns expressed about compliance and enforcement.

And so our concern would be that one could interpret these regulations in ways that would be very difficult for us to comply with. How do you know that you have met a seasonal gear limitation when the quota that you receive is not limited by gear? How might that be interpreted in the future? We as operators don't have regulatory clarity. That's a risk.

I think the other issue is that the regulations themselves, when they're put in place, are particularly problematic for a couple of the sectors, including the sector we participated in, the trawl sector. There's 3 separate seasonal allocations, one for trawl, one for trawl CPs, one for trawl CVs, all apparently equally applicable at the same time. How do you comply with that? How might that be interpreted? That's a concern for us.

Thank you. Well, I won't tell you that was very good, but I will thank you for your response. Keep talking until everyone left, and you're still here. Thank you. Thank you.

Yeah, uh, appreciate your time. And, uh, Mr. Jones as well. Thank you. Okay, Kathy Hansen is up next, followed by Linda Thank you. Can you hear me?

Yes, good afternoon.

Madam Chair and council members, thank you very much for this opportunity to testify. My name is Kathy Hansen. I'm the executive director for Southeast Alaska Fishermen's Alliance. We're a smaller vessel, multi-gear, a lot of salmon-halibut combination boats, over 300 vessels, about 85% Alaskan residents. And we ask that you do not grant SEGO's request to reevaluate the catch share plan.

I was one of the two commercial representatives on the Halibut Charter Stakeholder Committee that helped to develop the catch share plan, and it was meant to stop reallocation of quota share, particularly from the commercial sector has purchased their quota, and at this point in time, a significant portion of the quota has changed hands and been purchased.

The elephant in the room, as has been stated already, is the explosive growth in the unguided sector, which is affecting both the charter sector and the commercial sector at the same time that we're facing low halibut levels.

I'm going to keep my comments short. I don't need to go in the details. I don't believe PVOA has hit on a bunch of them, and I'm sure Linda will hit on a lot after me. The other thing I would just mention really briefly is I support trying to get the release of small sablefish action through the process and implemented. And thank you for the opportunity to testify.

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

I'm not seeing any. Thank you again.

So Linda Benken is up next, followed by Forrest Braden. Thank you, Madam Chair. For the record, Linda Benken with Alaska Longline Fishermen's Association. I'll also try to be brief. You've heard a lot of good testimony on the topics already that I intend to cover, but I did just want to put us on the record along with others in the, in our industry in support of moving the small sablefish release as quickly as possible.

I thought you asked a really good question, Madam Chair, of a previous testifier on how the council might advise the agency on prioritizing these actions that seem to be stuck in the pipeline. And I would think that certainly at the top of that list would be issues that have to do with conservation or resource waste. And that's really the element here that I hear from fishermen all the time and experience myself on the water is just this unwillingness to kill these little fish that we know are not mature yet, that haven't contributed to the mass. They also don't have value, but it's that, you know, waste of that resource. Um, and that, that should be one of the— in a, in a weighing of what gets priority, it seems like that should be something that comes near the top, as long as just along with this time element that it has been.

I think we're starting to push, um, 8 years now and we're still a year or two out according to the agency. And I, you know, I realize that the agency has been limited. They've lost a lot of staff. And I, in thinking about how to address this and what the solution might be, I just hope that when the Council does provide comment back or take action, continue to communicate with the administration, with headquarters about the EO and the need to make our fisheries competitive and modernize our fisheries, that really we can only do that if we have the capacity in the region to do the science we need and to have the council be well-funded, as well as to have the regulatory power to move these issues through and get them in place in a reasonable timeframe.

Moving on to halibut, you've also heard a lot on this. Yes, halibut stocks are at low levels. We're all worried about them, and it's not been easy for anybody, particularly people who have bought all the quota that they currently hold. This— the assisted unguided bareboat charter sector and that rapid growth that others have spoken to has had a big effect. It's had much more of an effect on the commercial fleet than on on the charter fleet, and we are working with the legislature to try and secure a definition that we can then come back to the council with, try and get the IPHC, the council, legislature to work with us to actually come up with a way to manage and constrain the, the growth in that fleet to everybody's benefit.

But that said, it is frustrating to hear go come back and ask for more halibut and to ask to take it away from the commercial sector. Each time that we have addressed the catch sharing plan, we have given more of an allocation to the charter fleet with the understanding that they would find a way to manage expectations and control growth while they grew to that new limit, and instead it's never enough. I know I know the amount is down, but it's down for all of us. That's what a resource does, natural resource does, and it's really important for them to take responsibility, educate clients on expectations, and find a way to work together to rebuild this resource. Finally, on this issue of the Golden Fleece, along with NELS, it's just recently come to my attention that we may have a vessel without sideboards around, it's halibut bycatch, and that that could really create some resource issues and some allocative issues for others in the halibut fishery and in the trawl fisheries that take halibut as bycatch, and just ask that that be flagged for council attention, um, as soon as possible.

Thanks. I will— and end there.

Thank you very much for your testimony. I'm not seeing any questions. Thanks. Thank you. Thank you for all your work.

Thank you. So Forrest Braden is up next, followed by Rebecca Skinner.

Madam Chair, members of the council, thank you so much for hanging in there and listening to everybody's comments and thoughts. I'm Forrest Braden, testifying for SEGO today, and we represent sport fishing providers in Southeast Alaska, and that actually includes unguided folks, even though we started out as a guided organization. And And one thing that we might keep in mind, we also by proxy represent all the anglers across the United States that access halibut through the charter fleet, the unguided fleet, or friends and family that live here in Alaska, or in Alaska. And so when you make decisions, you're not just affecting sectors necessarily, you're affecting U.S. citizens that have interest and access rights to Alaska resources. Okay, I'm not going to refer to that just yet, and I don't know where to start.

It could take 36 minutes just addressing some of the misconceptions that I've heard just in testimony today. But I will, um, I will say this to folks who think that SEGO is asking to take fish from a particular sector. When we ask for a look at the catch sharing plan, the catch sharing plan is very capable of addressing all users of the halibut resource that, and some are not currently included in the catch sharing plan. So you might maybe connect the dots that that could include a look at a comprehensive overview of who uses it and what those allocated relationships should be. I'd also say that it's kind of hard to hear rhetoric about people taking fish from other sectors.

The council's basic duty, I think, or mandate, is to decide the burden on particular sectors and make decisions, allocated decisions, about how those scant resources should be used among sectors. And I think that that also looks at how we weigh the burden on the charter fleet. And that's what you'll be hearing from me today, is what does it mean. And, um, Chair Drodnika asked the question, what does it mean for people these days that these regulations are burdensome. So I'd like to read quickly.

I can't even see how many minutes I have left. I should have glasses on. Is that 3 or 4? It's okay. So let me read this from the council's February 8th, 2022 motion for the catch sharing plan review.

It says the council is concerned about the impacts of the charter management measures and the Halibut Catch Sharing demand on the charter sector, particularly at times of lower abundance. The measures imposed on the halibut charter fleet have reduced demand for charter trips and the socioeconomic well-being of some charter operators and coastal communities. The CSP did not anticipate the current and continued low halibut abundance levels for these foreseeable— sorry, for the foreseeable future and recent changes in catch limits across management areas. These changes have increased uncertainty related to annual allocations for the charter sector, contrary to the goals of the Halibut Catch Sharing Plan. And I would just say that I think it is the council's responsibility periodically to say, as we move forward in this program, which components of it are relatively new, that we do assess the ability of the programs we've developed to minimize harm or allow equilibrium or return to reasonable access..

And I'm going to jump to the idea of how the 2C sector, particularly I'm speaking guided right now, is affected by the current harvest measures. And going to, to slide 1 here, and hopefully everybody can see it on their laptop. It's a little unclear for me. People have asked, will ask us specifically, how are being— okay, thank you. Uh, how are you being affected by this, or how are we, how are we supposed to see the impacts?

And I think this is a really, really clear illustration of the impacts to the charter fleet. If you look, uh, the first column after the Title 2 and 3, uh, talks about, um, shows the IFQ pounds transferred in 2025. That's 264,674 pounds. Can I advance this? Nope, okay.

So just relative, so that you get an idea, a feel for what that is, this is the current allocation with the SIR, 650,000 pounds, with a comparison of the GAF pounds used last year. And so this is one of the outlets that we have that everybody's leaning heavily on, and it shows you that it's not half, but it's 40% of, it's not 40% of the allocation, allocation, but compared to 40% of the allocation, people are leaning on GAF to prop up their business models. Can I get the next slide, please? This is a screenshot that I took this morning from Alaska, um, quota and permits in Petersburg, and you'll notice that, uh, 2C GAF tags, um, are valued at $400. So it costs $400 to get a GAF tag, uh, to have available for customers on the boat, and that is borne by operators, and that can be passed on to customers, which increases the price of a ticket.

And you can see 3A on the bottom of that. I'm going to have to condense my comments here, and I'll take questions. I'll just say that our analysis of— current analysis of the RQE is that it really doesn't actually provide relief. We're, we are concerned about even putting a pound of halibut in 2C RQE pool right now, because immediately what'll happen, if you look at the blue RQE full pool number, 281,000 pounds plus, we are almost at that usage. If you're familiar with RQE program and how it works, it phases out, or the GAF program phases out as RQE pounds come in., and as soon as we put a pound in there, we will not be able to exceed that cap.

I called today and we're already— my time's expired. I'll finish and just say there's only 28,000 pounds a year that can transfer in a U-34. We would still have a U-34 next year if we had a full RQE transfer of 1% because it'll only pull back maybe 4 or 5 closed days of the week, and we're still, you know, essentially right back where started. Thank you very much for your testimony, Mr. Braden. I'll see if there are any questions.

Yes, Mr. Ritchie. Thank you, Madam Chair. Thank you, Mr. Braden, for your testimony. Um, I talk to you often, but I still have a lot of questions sitting here. Um, the first one's about, um, I think where you started your testimony with, um, you referenced the catch share plan and, um, maybe that there could be some creativity there in regard to rental boat boats, and I just— or other, other sectors, I think, is maybe what you said.

I can't quite remember. But, um, if you could just expand on that briefly. Sure. Um, through the chair, Mr. Ritchie, so there's— there, there are compensated and uncompensated, um, remedies to— if there's any— if the council perceives that there's any additional impact to, for instance, the charter sector. Um, but, uh, we also know that, um, growing sectors or other recreational sectors can have impacts across sectors, and so I think there's been a lot of talk by a lot of different folks that are in the know about how do we comprehensively look at halibut usage.

Unguided fishing is not a bad use of the resource. Recreational fishing adds value, a lot of value for the state per pound of resource, so we are not bad-talking necessarily the unguided sector, but we do have to ask ourselves in the future, what do what we want Alaska to look like, what kind of protections and sideboards do other sectors need to protect the programs that they have to operate under.

Thank you. Mr. Muller.

Thank you, Madam Chair. Thank you, Mr. Redden, for your testimony here. We heard previous folks testify that not only the commercial but your sector as as well, part of the woes we're having right now is low abundance, but specifically low abundance and unguided activity, the growth of the unguided sports sector. And recognizing that you introduced yourself as a— your organization is representing both guided and unguided, I fully understand if you can't answer my question. But my question is, is how do you respond to the folks that are making that comment, that that's the reason we're even having this discussion right now is because of the low abundance of halibut and unrestricted growth in a certain sector of the industry.

Yes, through the Chair, Mr. Muller, and I hope I can answer that question for you. Yeah, I think that there's general agreement that when the resources at level that everybody that's using the resource should take a, you know, they should be taking a good look at. I don't think the unguided sector wants unfettered growth in their own industry. This recreational fishery is really sensitive to comparisons to market, I would say market advantage. That's one thing that the unguided sector is really lost— or sorry, the guided sector's really lost in 2C is marketing advantage.

If you look at regulations in the unguided sector, in 3A, in Canada, even in Washington, like, we're low man on the totem pole. And that's meaningful. It's not like a commercial fishery where the product is more of a commodity, and whether it comes from, you know, Area 3A or wherever, it's generally the same product, and scarcity actually drives the price up. But for the recreational fishery, the price and product value lowers in these situations. But I would— we would encourage the council, and this is part of our letter, which you can refer to, is that the council does need to consider this.

Um, it would probably be less responsible not to, not to continue to take a look into everybody that's using the resource.

Thank you. And Ms. Baker. Thank you, Madam Chair. Thank you, Mr. Brain, for your testimony.

And I guess I'm just going to ask you to repeat sort of your ask of the council today. I, I get the general request, uh, maybe to take a look at the catch sharing plan for the reasons you just discussed with Mr. Moller, who, who is managed by it. My question is, was there a separate ask maybe be with the information at the end, or you may be asking, uh, for, uh, the charter sector specifically. Are you asking us to look at the pool concept where the GAF phases out and maybe look at that specifically? I just— can you clarify what your ask is today, if any, related to that?

I can, through the chair, Mr. Speaker. I ran out of time. I did— we do have an ask, and it's specific to the council adopted a motion in December, I believe, of last year to look at charter halibut permit trends, to do some analysis on where, what effort needs to look like to reach certain mileposts in terms of harvest measures. In the last bullet, we would hope to see, we thought maybe that this was would be available under the existing motion, but it sounds like maybe not. But we'd like to see a hindcast of RQE quota, like historically.

And we did, we did share with some of the council members, we shared some work that we had done that really looked at what would, what would a full RQE pool look like superimposed over historical regulations allocations? What would have done for us, and that's— that was looking at 2026 effort, which is the most current idea we have of where the fleet operates at. But we feel like that would be really useful material to be able to, instead of just sort of projecting forward in a future we don't know about, to look at historically how it would have helped us.

I don't know if that's clear as mud or what.

Thank you, Mr. Braden. Just really quick follow-up. I, I, maybe I'm not 100% clear. Can you describe the difference of what you just described as the ask, the hindcast of RQE quota, how that would be different than what we looked at in the RQE analysis? Is it just an update of those numbers, or— I mean, we kind of had to look at that in terms of what RQE implementation would look like.

So what's different about your request than what we looked at in analysis? Yeah, time has lapsed. We're in a different situation. We now know what current stock abundance is. We also know what current effort is, and to be able to take a fresh look historically how that would have helped, how the fleet would have benefited from the combination of the two rather than just moving forward to see, you know, it just has a more real feel to it to say, yeah, this is where we would have been and this is how it would have helped or not helped.

Thank you, Mr. Braden. You described your challenges of the sector during times of low abundance. We also heard from the commercial fishing sector previous to your testimony, and I'm not challenging any of those, those concerns at all. I just, I just wanted to really, just looking at some of this data, looking at the GAF utilization, looking at how expensive it is, and still, and it seems like customers are still interested in, in GAF opportunities. I just, I want to just align, I guess, really better understand kind of that, those signals which appear to be still a lot of interest.

And, you know, I'm from Southeast too, so I'm seeing, you know, I see a lot of activity, a lot of really, you know, meaningful, I think, activity into the charter arena with concerns that you have about customer experience and implications either now or in the future. And it's similar to a question that I asked an earlier testifier, and I know you highlighted that in your testimony, but didn't, I don't think, had enough time to fully expand upon that. So if you could, you could explain to me a little bit better the customer experience and impacts that you think are going to translate into the viability of your operation a little bit more, that would be helpful. Thank you. Thank you for the question, Madam Chair.

I think the best way to answer this question is to illustrate what I went through last year. We finally found that we couldn't retain people on like a 37-hour 7-inch halibut. And we start— we did something that I think a lot of folks are gravitating towards, and we included a gaff permit for each angler on the boat. Not multiple, like every day, but a gaff permit. And what we've found is that when people come to Alaska to experience sport fishing, it— we do it.

I've heard a lot about diversity, and, and that has always been a part of model, like we do see the sites, we do see whales, we do take in Alaska, and that's probably value added right there. So we can't really diversify that way. The people really do focus on the product. And when you come up and your opportunity, if you've got an opportunity to catch one fish of any size, you might only catch a 40-incher or a 35-incher. But when you buy that ticket, I don't want to say it's like the lottery because there's a lot better odds, but you are buying the potential to be able to harvest.

And when they come and they're held at like a 34-inch fish or under, you've taken essentially all the value out of a lot of what people have come to Alaska to experience. And so it's, it's not like we're just going down in poundage. We're going down in huge amounts of opportunity, which brings a lot of value to the state and to local communities. You can't compare a commercial fishery with the the economics of sport fishing. We keep trying to do that and trying to do that, and they're just not comparable.

If we lose customer— if we lose a 10-year customer base, 75 to 80% of all these businesses have returning clientele, and you lose that momentum, it could really put you under. You've got to maintain that for the amount of assets that you have to have to prosecute this fishery.

Thank you for that. Okay, thank you for your testimony.

So next up is Rebecca Skinner followed by Craig Evans.

Uh, good afternoon. Rebecca Skinner testifying for Alaska Whitefish There are 3 things I wanted to talk about. One, the Joint Protocol Committee. Two, the 3-meeting outlook. And then 3 would be the Golden Fleece issue, very briefly.

As far as the Joint Protocol Committee, there was an Alaska Board of Fish meeting earlier this year where they were considering some trawl-related and trawl gear-related issues, and the Alaska Board Board of Fish took no action with the understanding that they would be meeting with the council and the Joint Protocol Committee. So I just wanted to express my hope that as part of that committee meeting, and obviously the— I think the chair of that is going to be, um, Tom Carpenter, I think. So obviously in consultation with him, but I'm hoping that part of what will happen is inclusion or presentation of information so that everybody in that meeting is starting from the, a similar page because the Board of Fish members probably don't follow the council as closely as people who are on the council. And so I just want to make sure that there's a common starting point for understanding of where the council is as far as the gear definitions, performance standard, bottom contact monitoring, basically a lot of what got discussed at this meeting so that the joint protocol discussion with Board of Fish members can be productive. So I'm a big fan of starting from a common place, and I really think that that group would benefit from getting a set of information so everybody's starting in a similar place.

Um, 3 meeting outlook. I just wanted to express my appreciation that at least on the draft, the Gulf Tanner issue is, um, February, and, and I hope no earlier than February. In my comment letter on that agenda item, I did ask when the next iteration of the paper comes out if we can get it as far in advance as possible, so at least 30 days, but 45 would be better. So I appreciate that it wasn't, um, you try to squish it into the December meeting. I had almost no opportunity to to actually read the paper, 256 pages, absorb it, kind of summarize it, and be able to talk about that with the members of AWTA.

And that is an important part of the, you know, the value add that I can bring to the members so they don't have to read the 256 pages. But when I don't have enough time to do that, it's— I think that we all lose a lot in the process because then my members don't really understand what's in the paper. They're not able to contribute input that might be really valuable. Valuable. And, um, so I'm, I'm just hopeful that whenever that ends up getting scheduled, the farthest in advance the paper can be released, that would be helpful.

And then just briefly on the Golden Fleece issue, so I'll add to the, the hearsay because I think you're hearing from people who have heard stuff, but my understanding with the Golden Fleece situation is that the new The vessel is basically stepping into the shoes of the Golden Fleece. So the Golden Fleece fished in the Gulf before, and they, they did operate under halibut bycatch limits. And my understanding is the new boat will operate under those exact same limits. Those limits are the same as the, the CV. So the boats that I represent, they're sharing that pool of halibut PSC, and we, we We are not panicking.

Yes, this is a change, and yes, it's something that we're going to keep an eye on, but there are limits in place, and those are divided up throughout the year. So it's not— there is no way that the entry of this boat could come in and in one fell swoop take all of the halibut PSC.

And I think that's all I have. Thank you. Thank you very much for the feedback. Feedback. I'll see if any questions.

Yes, Ms. Baker. Thank you, Madam Chair, and thank you, Ms. Skinner, for your testimony on, on those specific items. I, I would— I will take, um, you up maybe on asking about— I think that has been confusing a little bit for me, uh, for the vessel replacement issue for the CP and in the Gulf. I think the discussion we've had thus far is that the Golden Fleece did— was exempt from a sideboard limit. But can you— so can you explain how the PSC limit you're referring to is different than what we've been talking about in terms of the sideboard limit?

Probably not. So I'm talking about things of which I have a kind of a tangential understanding. My understanding is that when we talk about the sideboard limits, that applies to Amendment 80 vessels, and that the Golden Fleece was not either not an Amendment 80 vessel or was not an Amendment 80 vessel per se.

So, but what I can say is that it— the Golden Fleece operated under the same pool of halibut PSE that is structured the same way as the CV vessels. So there are, that's divided up into like 5 tranches throughout the year, so it's spread out in time and there's, you know, little bits. And if you exceed a PSC limit, if you exceed PSC limit 1, then the fishery, my understanding is the fishery closes. And then, but then there's another pool that's available a little bit later, so it's kind of these 5 seasonal apportionments. And I think that's probably as much detail that I can provide.

Hopefully I didn't misstate, but— and unfortunately I don't know really anything about the Amendment 80 sideboards because I don't work with Amendment 80, but I can say with certainty that there are absolutely halibut PSC limits that will apply to this vessel.

Yes, Ms. Kimball. I don't— thank you, Madam Chair. Thank you, Ms. Skinner. I, I guess I'm, I am still confused on why there wouldn't be concern with sharing, given that the Golden Fleece hasn't been operating in the Gulf for several years. Suddenly there will be a new vessel involved with no halibut PSC sideboards and sharing the PSC limits with the CV sector, in which we know when CPs have come in in the past, particularly the Golden Fleece, they've taken up to half of the PSC limit.

So I guess I'm, I'm really curious why there would be no concern from vessels that whether or not it's apportioned by season, you may be closed in a season.

Yeah, thank you. I wouldn't say there was no concern. I said we're not panicking.

But I guess from my perspective, the Golden Fleece did operate in the Gulf, so we know, we have a sense of what that looks like. And my understanding is it's gonna be the same captain running the new boat. So from my perspective, the reason I guess I would say concerned in the sense that we will keep an eye on it, there's only about half a year left So I guess from, I think it's fair to see, not to panic, see how the rest of this year goes and be in good communication. But I think, I mean, really the reason I'm not more concerned is that it literally is stepping into the shoes of a boat that had operated. Maybe it hasn't operated in the last couple of years, but we know what that looks like.

And, you know, obviously the PSE constraints are a real thing, especially with, with flatfish. We would love to grow flatfish markets, but that's just something that we continually are dealing with, and we're gonna keep communicating about and trying to maximize the, the amount of harvest that we can while sticking with the limits that we have. But I, I have committed to, to be in close communication with the, um, the, the operators of the, the boat that's coming on to keep an eye on, on what's happening. Thanks.

Thank you. And Miss Vanderhoeven. Thank you, Madam Chair. Thank you, Miss Skinner. I, I'm reading your comments to basically mean you're going to let them prove themselves to be a good neighbor, and if they're not, you'll come back and let us know and ask us to deal with it then.

Is that how I should take your comments?

Yeah, I, I think that's fair, although I, I really didn't mean the part about, oh, I'm going to come back and, and tattle on them later. I, um, but yes, I, I am okay with them operating, and like I said, the fact that we, we have history to— we know what that has looked like like in the fairly recent past. And, um, but yes, we will be keeping an eye on it, and we will bring it back if it needs to come back. Thank you.

Okay, thank you for your testimony. Craig Evans is our last testifier on the list, then I'm going to circle back to Alan Otnes.

Good afternoon, Madam share. My name is Craig Evans, and I'm going to comment on the request made by SEGO and their ask to reevaluate the halibut catch share plan. I'm a commercial halibut fisherman. I hold IFQ in Area 2C. I've been fishing halibut commercially since 1977, and I've purchased all of the IFQ that I own.

It is— I believe it is inappropriate for the charter industry, which is a much more recent user of the halibut resource, to attempt to get halibut reallocated to themselves just because they want it. Through the council process, we established the current catch share plan years ago that all parties involved in have made business decisions based upon.

The halibut resource is finite, and it is also variable, as we all know. We take the good with the bad. There are no guarantees in natural systems, and the charter industry is no more entitled to guaranteed income than the commercial sector is. The SEGO argument that recreationists are entitled to their access to the recreation, I don't believe can stand up against the fact that people, United States citizens, fishermen also should have the ability to buy fish at the supermarket and restaurants. Commercial sector provides food, not entertainment.

The biggest issue that the council should be addressing, as you've heard several times today, isn't the catch share plan or RQE, it's the unrestrained taking of halibut by the sports sector, especially the unguided sports sector, most of which is owned and coming from the lodges.

The IFQ program was adopted to address overcapitalization of the commercial sector.

Later, the catch share plan was adopted to address overcapitalization of the guided sports sector. Now it seems that the guided sports sector would like the Council to endorse current and further future overcapitalization in their sector. My ask is that the Council does not take up the request made by CEGO. Thank you.

Thank you for your testimony.

I'm not seeing any questions. Thank you.

So, Alan Ottis— Alan's not online Okay. Oh, Kelsey Trojan.

Okay, Kelsey, can you unmute yourself? Hello? Hello? Can you hear me?

Yes. Hello? Hi, thank you, really appreciate your time. Um, I just want to give my testimony. Um, I've been involved with charter operations for the last, um, 20 years.

Sorry if I sound loud, I'm actually driving a boat in at the moment. Um, I missed the earlier time because I was out fishing. Um, I, I heard a comment earlier, and you know, it kind of just speaks to the charter industry, is we have people that come up here and pay, um, $4,000 to catch essentially 6 fish in, in the afternoons. And so when people come up here to catch these fish, they're paying, you know— I'm sorry, my phone's going— is acting up. Give me one moment.

Can you hear me again? Yes, we can. I'm sorry for that.

Basically, we have people that pay $4,000 to $5,000 to come up in June and essentially catch 6 fish, and we have daily closures on halibut. You know, now they're paying $4,000 to catch 5 fish. Fish. And when we have that and have the, the gaff program in place, we're not able to sell those trips at 34 inches unless the gaff program's in place. So when, when I hear comments like, you know, we are busy, the reason we're busy is because we basically gave a $400 discount selling these gaff fish to clients.

And if it wasn't for that opportunity, like Forrest was referencing we wouldn't be able to sell these trips in June, let alone May. And so like for us, if it wasn't for that GAF program and that propping up our industry, it's just, we wouldn't operate. And I know personal friends, colleagues, number of people that are advocating for buying commercial quota to rent it in the GAF program. And that is the entire purpose of buying that 1,500 pounds and even buying the 1,500 pounds pounds in different classes. And so that just seems like it wasn't the original intent from the commercial industry to simply go about buying commercial quotas to then lease back to charter fishermen.

And so when it comes to the appropriate use of the resource, it seems like people in the commercial sector are now pursuing selling back to charter fishermen. And it's really frustrating because if it wasn't for that quota and the opportunity to than go and catch that fish. And just like, people love it, and that experience of just coming out there and the opportunity and the excitement of missing a bite. Like today we had a big halibut bite, we didn't get it, but just going out there and trying to do that is what made the whole experience so useful. And so I just really want to emphasize that, you know, we are different from a commercial entity and that we need the opportunity to go and pursue catching fish.

Um, I mean, I'm a local here, I grew up in Craig, Alaska. I've never kept a halibut under 34 inches. The quality of meat's just not a good quality fish. And to, to ask the guests to pay $4,000, $5,000, $6,000 per person for 3 days of fishing to catch a fish with low quality meat is just something that is really frustrating for me as an operator.

Thank you very much for your testimony, Mr. Trodden. See if there are any questions. Yes, Mr. Ritchie has a question. Thank you, Madam Chair.

Thank you for your testimony. Um, you referenced that people are buying up IFQ, um, or charter businesses are buying IFQ. I've seen the same thing in my region. I guess I'm just wondering I mean, if— have you partaken in that? I know that you need to have a certain number of commercial fishing days to qualify to buy that quota, but not everyone does.

So just wondering if you've bought quota yourself. I personally have not myself, but we do have a guide at our lodge that has done that and leased back, and we've had old owners do that and lease back.

Thank you. Thank you. Are there any more questions?

Seeing none, thank you for joining us. Thank you for your time.

Okay, so that concludes our public testimony on staff tasking. I'd like to stand down for 22 minutes or so. We'll see if we need more time after that. Come back at 4:10 and see if the council would like to take any action or have any follow-up discussion on any of the items that we heard and stop tasking. Thank you.

Council members, please come back to order.

Thank you, everyone. So we are getting very close. Thank you for everyone's work and patience. Um, so we've completed public testimony on staff tasking. Um, just want to provide council opportunity to offer any motions or have any follow-up conversations on any items that we heard during staff tasking.

So I'll look around and see if we have any Mr. Ritchie, thank you, Madam Chair. Um, I guess I have a question, or I'm looking for some clarification about something we heard in, uh, public testimony about a council motion from December, and that information was supposed to come back in the— in October, uh, to the Charter Management Committee. And I was wondering if, um, Miss Marinan would, would answer. Thank you, Miss Marinan.

Thank you.

Hi, um, thank you. Uh, we heard in testimony that there might be, uh, utility in having, um, I think it was characterized as a hindcast, but, uh, a look at a fully funded RQE, what that would have done in different years And I— my interpretation of the motion from December, uh, regarding the, the permit usage, um, was that that was kind of encompassed in, um, in element 7 of that request, of that data request. And I'm wondering if you had the— if you had the same interpretation, if that's something you were intending to work on already, or is that something that we would have to change?

Uh, Madam Mr. Ritchie, for the record, my name is Sarah Merritt, council staff. Um, and yes, uh, under the council's motion on charter halibut permits from December 2025, there's point 7, um, referencing what was highlighted in public testimony, what you're suggesting. Um, uh, it would be my intention in working on this to look at a series of years. Um, so this request under point 7 under point 7 of that motion that's already been made would do a similar exercise to, as Ms. Baker highlighted in questioning, something that we did in the original RQE analysis of looking at different catch limits with the most recent projection of angler effort and average weight and looking at what an RQE could achieve with the maximum amount of transferred quota. Um, and so it'd be my intention under that point to look at a number of years, at catch limits from a number of years, to, to bring back under that discussion paper.

So no, you wouldn't need to change the motion for us to bring that back. Okay, thank you for that clarification. Thank you, Miss Marinan. Yep, Miss Kimball. Thank you, Miss Marinan.

And then I'm just trying to pull up a bunch things. But, and that paper is planned to come back to the council in October and go through the Charter Halibut Committee, or how does that work? Um, through the chair, Ms. Kimball. So, uh, it is scheduled on the agenda right now for October to come back to the council. Um, uh, we typically have a Charter Halibut Management Committee in October after the October council meeting.

So unless something additional is scheduled, we don't have a Charter Helbit Committee planned prior to the Council receiving that discussion paper. Thank you. That— I forgot about that timing. That makes sense. But we will be getting it at a time at which stakeholders will be ready to look at those issues.

Okay, thank you.

Thank you. Anything else from Council members?

Mr.

Thank you. I do have a motion. I sent it to staff. I'll wait a moment for the motion to get on screen.

The Council initiates an analysis for regulatory in Bering Sea Aleutian Islands groundfish FMP amendment to require any Amendment 80 replacement vessel operating in the Gulf of Alaska Gulf of Alaska to be subject to Amendment 80 halibut prohibited species catch sideboard limits and to ensure Amendment 80 vessels are subject to the same monitoring requirements when they are operating in the Gulf of Alaska. The Council approves the following purpose and need statement and alternatives for this action. Purpose and need statement: Given declines in coast-wide halibut stock biomass— or coast-wide halibut stock status and recent changes to reduce halibut PSC limits for the Amendment 80 sector in the Bering Sea and Islands. The council is evaluating a conservation measure to eliminate the exemption to Amendment 80 halibut PSC sideboard limits in the Gulf of Alaska. Under current regulations, one Amendment 80 catcher-processor vessel, the Golden Fleece, is eligible to fish flatfish in the Gulf of Alaska and not be subject to the Amendment 80 halibut PSC sideboard limits in the Gulf of Alaska due to the vessel's historical participation.

Well, this vessel If a vessel has not been fishing in the Gulf of Alaska since 2022, it is eligible to be replaced by a different vessel. Current regulations allow the replacement vessel to be exempt from the Gulf of Alaska halibut PSC sideboard limits as long as the replacement vessel is the same length or shorter than the original license allows, 124 feet in length overall. Additionally, Amendment 80 vessels are subject to different monitoring requirements when operating in the Gulf of Alaska. Gulf of Alaska, which means that current monitoring requirements do not provide the sufficient PSC accounting that is required to monitor compliance with the sideboard. As a result, the council is also evaluating whether regulation changes are needed to improve catch monitoring in the Gulf of Alaska and to ensure consistent requirements for Amendment 80 vessels operating in Bering Sea, Aleutian Islands, and the Gulf of Alaska.

Alternatives. Alternatives 2 and 3 are not mutually exclusive. Alternative 1, no action. Alternative 2, remove the exemption from the Gulf of Alaska halibut PSC sideboard limits for an Amendment 80 vessel that replaces the Golden Fleece. Alternative 3, apply Amendment 80 monitoring requirements in the Bering Sea Aleutian Islands at 679.93 to Amendment 80 trawl catcher processors operating in the Gulf of Alaska.

With a second, I'll speak to Rationale. Thank you for the second, Ms. Baker. Thank you, Ms. Baker. The permit the Golden Fleece operated in the Gulf of Alaska with is unique. It was granted exemptions in 2007 under conditions that have significantly changed.

One of these exemptions is the exemption to halibut PSC sideboards. The state of the halibut stock has changed dramatically since 2007. This council has heard about that through public testimony, and information on this is readily available to the International Pacific Halibut Commission. Given the observed low abundance of Pacific halibut in the Gulf of Alaska, I believe it is important that any non-pelagic trawl catcher processors operating in the Gulf operate under a sideboard. The National Marine Fisheries Service report is clear the replacement vessel is a Bering Sea Aleutian Islands Amendment 80 vessel, and that, that replacement is allowed under current regulations without two things: one, a halibut PSC sideboard limit, and and 2, the same monitoring requirements required for catcher processors when operating in the Bering Sea.

Without monitoring regulations consistent with other non-pelagic trawl catcher processors, the difference is that this vessel would not be required to have 2 observers and could operate with only 1. This difference could lead to greater uncertainty in unsampled hauls, and I don't think that's, that's sufficient if a vessel is held to a PSC sideboard, and I don't think think that's adequate to the higher monitoring standards we have today. Making the monitoring regulations consistent with the Bering Sea Aleutian Islands would also apply other important regulations like required sampling stations, bin monitoring, and flow of fish. These are all requirements which ensure total catch accounting has the precision required in regulation for all other non-pelagic trawl catcher processors. Without this monitoring consistency, the vessel fishing this permit presents potential uncertainty in halibut PSC and monitoring.

I would like to add that the vessel which is replacing the Golden Fleece is a Bering Sea Aleutian Island Amendment 80 vessel, and because of this participation in that area, it has been compliant with all of these requirements. This is just requiring they retain those same requirements in the Gulf of Alaska. I offer this motion to initiate analysis, and I hope that the information we get back would provide us with enough to determine the appropriateness of exemptions it has previously been granted.

I think that the alternatives in this motion and their potential outcomes are discrete enough that moving forward to analysis is warranted. I do not see added value in a discussion paper here. Further, I think there's a resource concern amongst directed halibut users that increased PSC may stress already stressed business models and communities across the Gulf. Um, with that, I'll welcome any questions.

Questions? Thank you very much for the motion and the rationale, Mr. Ritchie. I'll see if there are any questions.

No questions. Um, any amendments?

Any comments on the motion? Ms. Van Der Oven. Thank you, Madam Chair. Thank you, Mr. Ritchie, for your motion. Um, I'll just go ahead and say up front that I'm not going to support your motion.

We heard from the catcher vessel fleet that would be sharing the PSC limit at this meeting, and they were comfortable with giving that a go to see how that goes. The boat will have 100% observer coverage, and I feel pretty good about that for the Gulf fishery, and I think this is premature future and speculative, and I want to see a problem before launching into a reg package for one vessel with our limited resources that we have. Um, and I think if this was a problem in the future, once that boat actually starts fishing in the Gulf, then I could be supportive. But under the circumstances at this time, I can't support the motion.

Thank you, Miss Vanderhoeven. Any other comments? Mr. Pamplin. Thanks, Madam Chair, and thanks, Mr. Ritchie, for, for your work on this motion.

I'd align myself with the concerns raised by Miss Vanderhoeven and, and don't plan to support the motion. I really don't think this was on a radar here until the NIMSB report, which was just the transparency that a vessel transfer permit had really been approved. The vessel has been fishing a few years ago. It sounds like it's the same operator, and we heard from the sector that's going to be sharing the limit that they understood what was potentially going to happen and something just to monitor. So finally, this is an awful lot of work is what it seems like for a single vessel.

The council recently declined action on pot cod lap due to workload. We're struggling to advance small sablefish regulations because of workload, and we're going to take on a regulatory review for a single vessel. So for those reasons, I think I'll oppose the motion. Thank you. Thank you, Mr. Pamplin.

Any other comments? Ms. Baker. Thank you, Madam Chair. Thank you, Mr. Ritchie, for the Motion, I will support it. I appreciate the resource conservation concerns.

As I see it, uh, the original vessel for which the sideboard exemption and, and different monitoring requirements were provided in current regulations is differently situated than the replacement vessel, and I am a little concerned particularly about the difference in, in monitoring requirements, just given when those, the current monitoring requirements in the Gulf were established for the Golden Fleece versus how we have improved since that time. And I think this is the right time to evaluate that. So thank you, Madam Chair.

Thank you very much, Ms. Baker. Any other comments? Yes, Mr. Muller.

Nia theidum. Thank you, Madam Chair, and thank you, Mr. Ritchie, for the motion. For similar reasons that Ms. Baker noted here, I think, yes, I was originally concerned with, with, you know, implementing a package or starting a package as such for a single vessel, but I think it's prudent for this council to take into account the resources, particularly halibut resource in the off, um, the substantial decline that we've had even since 2022. And I think this is a prudent, uh, package to push forward. And so for those reasons, Madam Chair, I'll be supporting the motion.

Thank you very much, Mr. Muller. Any other comments? Yes, Miss Gwon.

Thank you, Madam Chair, and thank you for the motion, Mr. Ritchie. And I actually don't know which way I'm going to land yet, so hopefully I'm further down on the voting scale, but I, um, just want to acknowledge the workload— staff workload concerns we continue to hear. And so I'm— I am concerned about doing a package for one vessel, although on the flip side, I also am very concerned about the halibut resource overall and how low that stock is at. And, you know, would like to have a better understanding of the monitoring concerns here. So we'll see where I land here shortly.

Thank you, Ms. Gunn. Any other comments?

Um, thank you for the motion, Mr. Ricci. I'm also— I'm very torn as far as the, um, extensive resource conversations we've been having, um, and really strive to be consistent across the board. There are some unique circumstances though that I think we're going to have to to assess, and that's what prioritization is all about. I think that larger conversation we're hoping to have in October— I know this is a little early for that. It's— this is a situation that came up that was, I, I don't think, on our radar, but I do think warrants a really close look at this time.

Um, and I, I think it's, uh, this very legitimate participation from this vessel, but I, I think my initial read that this exemption is rather dated for the times that we're living in and dated for the condition of the halibut resource. So I do think that we should look at an analysis to ensure consistency with regulations for essentially the same sector operating in the same fishery. So I appreciate the work that you put into this, and we'll look forward to what we, what we find in an analysis. And we'll, you know, have to work closely with staff to ensure this is appropriately positioned in, in the queue of our other extensive list of priorities. So thank you.

Okay, any further comments?

Okay, all right, now have to do a roll call on this. Ms. Evans calling the roll on the motion for an analysis to require that any Amendment 80 replacement vessel in the Gulf be subject to Amendment 80 halibut PSE sideboard limits and monitoring. Ms. Kimball? Yes. Mr. Kurland?

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

Mr. Ritchie? Yes. Mr. McIntosh? No. Mr. Sukata?

Yes. Miss Vanderhoeven? No. Miss Baker? Yes.

Miss Gohan?

Yes. That motion passed. Oh, excuse me, Miss Dravnicka, do I get a vote? You do. Okay.

Yes, thank you. Uh, that motion still passes, uh, 8 to 11— 8 to 3. Okay, thank you. Um, anything else for discussion or motion? Ms. Baker.

Thank you, Madam Chair. I do not have a motion. I really just wanted to speak to or acknowledge the testimony that we received relative to proposed management changes regulatory changes to halibut subsistence management. And I, again, I do not have a motion. I just appreciated the testimony and the specific suggestion.

What I would like to propose is, is I will look— it's been a while since I looked at those regulations, and I'd like to— there's some nuances to the proposal that I think I'm not quite getting, and so I just wanted to signal to the council that, um, I intend to look at that and, and would perhaps do a little checking and, and maybe at a future meeting, uh, come back with something. Thank you, Miss Baker.

Any other items? Miss Kimball? I don't have a motion either, but I did want to speak to actually what was proposed, um, by Miss Evans and the chair about prioritization of actions and I guess we could use this part of the meeting to try to prioritize individual things, but I heard we're going to try to take a more holistic view of that come October. And I guess we were given a little bit of an idea of what kind of products might come forward, both on the analytical side and on the rulemaking side of what's in the queue. So we have a bigger picture look.

I think that's going to be really helpful. We heard specific asks from stakeholders to prioritize it just prioritized certain things in the rulemaking process, and I'm anxious to look at the whole package in October. Thank you. Thank you, Ms. Kimball. Um, yeah, and, and I, I appreciate you, um, circling back on that.

I, I would like to express appreciation to, um, what we heard in, in public testimony, and we heard very specifically about, um, sablefish. Um, I, I think we can address this in October as part of that larger conversation. I also really appreciated, you know, some of the considerations that the public thought we should take into account during that conversation, including, you know, the relative conservation issue or priority that in a particular action may hold, wastage compliance issues. Issues and cross-referencing that, of course, with the resources that we have available and expertise on our staff, both at the council and agency level, to address specific issues. So those are just— that's not a relative priority there.

It's just a couple of themes, and I think we're going to be expanding on those themes, and hopefully we'll get some additional expertise from Ms. Evans that in October as part of that discussion. So, Mr. Sugata. Yes, sir, thank you very much. Um, I just wanted to bring up the CDQ Pacific cod seasonal gear apportionment issue that we heard from several testifiers.

Uh, you know, the fact that CDQ quota cannot be more restrictive than other quotas is a very fundamental and important part, I believe, of the CDQ program. I know that maybe this time around it might have been a little premature given the— I don't want to use the word premature, but given the level of effort and priorities, I just want to make sure, as this is my last council meeting, that that is picked up in October. I think the issue is basically a no-brainer in the sense that once again MSA does not allow for this. I know it wasn't done maliciously or anything like that. It was just an oversight given the different programs that came afterwards.

But I do believe that it is critical, and I'm hoping that as early as the October meeting that this issue can be brought up and at least analysis begun on it, because it is, once again, a fundamental part of CDQ quota and the value that it brings to the Alaska communities. And then finally, I just wanted to thank everybody here. I spent a lot of time on the other side of the table, and these 3 years have been great. I want to just thank all the staff and all the council members and the public for this experience. So thank you very much.

Thank you, Mr. Sakata. I do— I agree, I'm interested in learning more about about that issue and really trying to, trying to figure out the analytical lift and as well as the urgency involved with and the risk associated with some of the concerns that stakeholders brought up regarding the CDQ PCOD seasonal apportionment. So thank you for circling back on that.

Anything further from council members? Yes, Mr. Muller. Yeah, thank you, Madam Chair. And just, just, um, so I'm clear, um, so in October we should expect a, um, a more comprehensive list of what we, um, what we have on the plate as a council now. And in addition to that, we will have an opportunity to, to bring forth, um, you know, some of what we heard in staff tasking today, uh, from the public, if it's council members' desire to do that.

But so that's, that's my understanding, is, is, is we'll have an opportunity to prioritize as, as a council, take a look at, um, you know, the, the resources, not only, uh, council resources but the agency resources as well, and actually have a, a more thorough discussion and in terms of, of how and what this council prioritizes in October. Am I correct? Yes, that's our thinking. Thank you, Mr. Muller.

Anything further? Okay, so we are, as Ms. Evans, um, brought up in her her introduction presentation to us, we will be issuing a call for nominations for both the SSC and the AP for 2027. The SSC is currently at 18 members, and recognizing they have some upcoming changes in expertise, the Council is interested in appointing up to 2 additional persons to the SSC. Following their recommendation, the call for nominations, uh, should be prioritizing expertise in stock assessment, statistical design, and modern statistical modeling methods. The council will also consider nominations for expert social scientists with a background in anthropology, sociology, human geography, or a related field, or an expert with expertise in climate, ecosystem, and integrated thinking.

For the advisory panel, the council is interested to hold the membership at 19 persons for 2027, and so the call for nomination should follow the standard procedure of announcing which AP members have terms expiring this year and which are eligible for and/or interested in reappointment. Note that for a few nominations for reappointment to the AP tribal representative seat, our policy does, does require a letter, letter of nomination by a tribe or tribal consortium. Consortium. In both cases, the call for nomination should highlight the council's ongoing interest in having balanced representation on both the SSC and AP, which we consider when we make appointments in December.

Thank you.

So just one last thing on my list is to express gratitude and appreciation for Mr. Tsukada. This is his last meeting. I've greatly appreciated the insights that you've brought to this process, your expertise in operations, and that critical experience to help inform our understanding in the operational components of our centuries, and your care and passion for Western Alaska communities always came through very clearly, and we will miss you and hope to see you in the audience or making specific requests or commands. So we do have a plaque for for you and would like to come on over.

It's in recognition and appreciation of the 3 years of service on the council and for your overall dedication to the conservation and management of—.

Yeah, no long speeches, but just simply to say what an honor it's been. I know we sit around, there's not, you know, sometimes the room's packed, sometimes it's not, but I think it's just important to recognize that at least I consider this to be like the Super Bowl or World Series of, you know, fishery management and both the competitive side but also the importance of it, and I wish everybody Everybody, uh, good luck. I see some new faces. Uh, this process will go on. I hope it stays science-based, but, uh, really, it has been an honor.

So, uh, thank you very much. Thank you, Mr. Sakata.

Mr. Muller.

Thank you, Madam Chair. Thank you, Rudy. We so appreciate you. You forgot the marathon part.

No, it's been a pleasure to work with you, and I just want to, I want to voice my appreciation. And, you know, quite frankly, this is, if not the gold standard, to integrity in fisheries management. You certainly helped this, this body continue to keep that. And so, so appreciative of you and wish you the best, and enjoy your trip to Japan. Thank you.

Thank you, and yeah, best of luck in retirement, and we'll, yeah, we'll look forward to following you on social media, those of us who are on social media, and all of your exciting kayak fishing trips. So, nope, thank you. Hoping to do a lot more flex line sampling versus some of this regulatory stuff in the future. So Thank you.

So with that, unless I'm missing anything, I think we're shockingly going to adjourn before the end of business hours today. So, um, thank you everyone for your assistance in that. Um, we'll adjourn this meeting and see you in October. And I just want to thank staff as always for all of your work, excellent presentations, um, your support to the public and council members throughout this meeting. So thank you.

Take care and see you in October. Meeting adjourned.