NPFMC 279 Day 5 - June 8, 2026

I don't know if that was necessary this morning. Everyone is very attentive. So we are beginning our— continuing our D1 agenda item. We have 1 remaining, 2 remaining reports. Um, we'll start with, and then we'll go into public testimony.

Um, so please, uh, follow, um, the pace of these reports and sign up before the end of the AP report if you'd like to testify on D1. Um, we'll start with Susie Zagorski and Austin Esterbrooks. Thanks.

Good morning, Madam Chair and members of the council. For the record, I am Susie Zagorski, the inshore IP representative as well as the AFACV Inter-Co-op Manager.

James Mize is the Mothership IPA representative. He will not be able to be here to present, so I will be representing or presenting the Mothership data on his behalf. And with me, I have Austin Estabrooks.

Yeah, uh, for the record, Austin Estabrooks, uh, representing the CP, uh, Incident Plan Agreement.

So before we get in, we are here presenting the industry's report on the 2026 A season dynamic closure measures. And just kind of before we really dive into this presentation, this dynamic closure measure is not technically written into the IPAs. This was a request by the Council, but because the link to salmon avoidance and per the Council's request, the us IPA managers are here to report back on it. Also, this dynamic closure measure in a season was like a proof of concept, and while we will be presenting to you the preliminary catch and bycatch data from the NMFS catch accounting database, this is by no means a full-on analysis. It's simply a report back on fishing activity in relation to the dynamic closure measure as requested.

So just to remind folks of what the Council's request was for this report back in the December 2025 motion, So we will be presenting to you the weeks or week numbers of which the dynamic closure area was open versus closed and the overall fishing activity inside that dynamic closure area, as well as Bristol Bay red king crab bycatch inside and outside the RKCSA, salmon bycatch rates inside and outside in relation to the trigger, a description of our avoidance efforts outside our bycatch avoidance efforts inside and outside the RKCSA, as well as our vessel activities in the area and in relation to the closure.

So we'll start off with the catcher vessel fleets. This is just a reminder of the dynamic closure area that both the inshore and the mothership CB fleets were using this A season. It— the orange filled shaded shaded polygon there in the RKCSA that's 64% of the RKCSA and does not dip down into the subsavings area. And then the rules, a reminder of the rules that we had for the CV fleets, again, both the mothership and the inshore sectors, there was an open start and then our triggers for whether this closure area would open based off of salmon bycatch avoidance were if there was a rolling hotspot closure outside of the RKCSA and/or if cleaner Chinook rates were inside the RKCSA, so cleaner fishing inside the RKCSA while there was actual fishing in there. We also— this is also just kind of show the notification and monitoring that we had in place.

So to orient you to this table, we will have the similar table for the motherships sector as well. But just real quick to orient you to the table, the weeks in that first column are Friday to Friday weeks, so it matches our salmon avoidance and monitoring weekly basis. The blue weeks are when the sea ice had extended beyond the RKS ESA, and Chinook rates listed in the 5th and 6th columns are data that had become known after that week's fishing was complete. So that's why you'll see in those 2 weeks green highlighted cells that are offset, and those were based on rate-based openings. And the data for inside the RKCSA, as we're presenting it, is based on whole stat areas.

So the data for quote-unquote inside the RKCSA also includes the subsavings area. So for the inshore sectors, 2026-A season, it consisted of about 14 weeks of fishing, and the dynamic closure area was triggered open for 7 weeks and closed for 7 weeks. And those are indicated in the table to the left with open or closed. So there was a— the first week and a half was an open start, so this is to collect data to make sure that we were understanding the, the catch and fishing efforts in the Bering Sea. And then we had 3 openings overall for rolling hotspot closures outside of the RKCSA and 2 openings for cleaner lower rates inside.

All of this being said, no catcher vessels had fished inside the closure area even if it was open.

The inshore sector had a total of 25 red king crab bycatch inside the RKCSA and subsavings area and 7 outside the RKCSA. Majority of this was from the same week, and while the fleet was actively— or while the fleet was actively avoiding Chinook and herring outside the RKCSA, but as soon as any bycatch was known, it was immediately communicated widely across the fleet for additional avoidance. And you can see that from the data, whereas the following week, of where there were 20 inside and 5 outside. The following week there was zero after that.

So just to continue on with the inshore report, the fleet had only fished in the RKCSA for about 5 weeks. This was the month of February and the first couple days into March. And this was similar— this was similarly the timing reliance in previous years. 10% Of the inshore A-season harvest was from those 5 weeks of fishing inside the RKCSA, and those 5 weeks were mainly in the southwest quadrant of the RKCSA, and fishing activity was due to Chinook and herring avoidance in that area. And the data indicates this, but if needed, I can expand on the fishing activity on a week-to-week basis.

And additionally, Myself, James, and Sea State had all been using AIS and VMS tracks as well as catch accounting data to monitor the catcher vessels and their catch. This isn't— this is similar to the regular monitoring for salmon bycatch avoidance measures that we currently use, and both sectors' IPA reports were used as the medium for reporting to vessel operators whether or not the dynamic closure area was open or closed for that week.

All right, so for the Mothership Report, the fishing activity for the motherships were— mothership CVs were similar. However, they had 13 weeks of A season, so slightly shorter. 7 Of those 13 weeks in A season, the closure was open, but again, no fishing activity by catcher vessels in the Dynamic Closure Area while it was open. Their openings consisted of a 1.5-week open start. There were 4 weeks due to rolling hotspot closures outside and 1 week due to lower Chinook rates inside.

The mothership catcher vessels had zero red king crab bycatch inside or outside the RKCSA, and 3— they only had 3 weeks of fishing activity inside the RKCSA, and this was again for salmon and herring avoidance and overlapped with some of those same weeks that the inshore sector was fishing inside the RKCSA. And 7% of the mothership's a-season harvest was from the RKCSA. And this is, for the mothership sector, it can be a little bit more variable year to year due to greater ability to move around the Bering Sea for avoidance efforts. But those, their reliance on the RKCSA was again similar to the inshore sectors since all of our vessels are generally fishing together at some point. And I'll pass it on to Austin for the CP slides.

Excuse me, before you move on, we have a question. Ms. Gimbel. Thank you, thank you, Ms. Sikorski, for the presentation. I just wanted to clarify, were the trigger to open the closed area based on a Chinook rate or Chinook closure, did that closure have to occur anywhere, or did it have to be adjacent to the Red King Crab Savings Area? Just wanted to know what the thinking was there.

Through the Chair, Ms. Kimball, on this first year, the rules were if there was an RK— if there was a rolling hotspot closure outside of the RKCSA, for the fact that, for the reasonings that in A season, oftentimes if there's Chinook encountered outside of the RKCSA at certain times of the year, that becomes an area of reliance where cleaner fishing can be found. So the rule is fairly simple for this first year of effort, and it was if there was one outside. So you can see from the table for the inshore sector, there were the— there were two weeks later in March and early April where there the technically the dynamic closure area was open because there were rolling hotspot closures outside, but the fleet was not fishing inside or near the RKCSA at that time. Also, there was ice extent past the RKCSA. However, based off of our, I guess, long-term and short-term kind of fishing activity is normally the inshore sector is not fishing up in that area during those later weeks in the season, so there wasn't expected to be effort— avoidance effort up there.

Hope that helps.

So the, the CP fleet, uh, dynamic closure was, uh, slightly modified from what the catcher vessels used. Ours, uh, bisects the Red King Crab Savings Area minus the subarea from the southeast to northwest corner. And I'll skip here because that image was distorted slightly. So just as a reminder of the other spatial constraints that we operate under, just for example, to the east of the King Crab Savings Area is Area 512, and that area remains closed year-round to all trawling. And then Area 516, which is the western, sorry, the eastern half of the King Crab Savings Area, in addition to the areas north and south of the box, closed March 15th also to all trawling.

And then the SCA is the Steller Sea Lion Conservation Area, which limits pollock catch during the A season. And so again, just as a reminder, our open and close salmon bycatch trigger basically used a goal-level Chinook bycatch rate for the entire A season. So essentially how we calculated that was we took our performance standard, multiplied it by 0.8, and then divided our pollock catch from that remaining salmon number. And so that gives us sort of baseline goal level. And so we said if we are, um, achieving that goal, then the dynamic spatial closure will remain closed.

If we aren't achieving that goal, then it will open for fishing. And in consultation with Sea State, we did modify, um, the rate-based trigger from a 1-week, uh, calculated bycatch rate to a 2-week bycatch rate. And that just has effect of smoothing the data and therefore maintaining more consistency week to week in terms of whether or not the dynamic closure would be open or closed.

So looking at the weeks in which the dynamic closure was open versus closed, ours closed on January 31st following that initial data collection period to start the season relative to Chinook salmon bycatch rates, and then it remained closed every week of the season through April 1st when the CP fleet concluded their operations. But just highlighting the fact that much of the King Crab Savings Area itself was unfishable starting in early to mid-March due to sea ice.

This is an example of how our, the dynamic closures were noticed to the fleet within our weekly IPA reports from Sea State. So clearly identifying the lat-long coordinates and the timing of that closure for the fleet.

We were asked how many Bristol Bay red king crab did we catch both inside and outside. Our fleet fortunately caught zero red king crab both inside or outside the red king crab savings area this A season.

And just as a reminder, our CP dynamic closure didn't have an inside versus outside rate-based determination whether or not it was open or closed, but regardless, I did do— did pull the data and just confirmed that inside the red king crab savings area, our salmon bycatch, Chinook salmon bycatch rates were less than half than outside. So just reconfirming that that area, as has historically been the case, remains relatively clean fishing grounds with respect to Chinook salmon.

So again, our dynamic closure remained closed the entire A-season. And this was obviously because our fleet remained under their target Chinook bycatch rate the entire season. But I just wanted to highlight with this figure that all of the Chinook bycatch avoidance areas, which are, you know, denoted here in the, the red shaded boxes, were well outside of the king crab savings area. So just highlighting the fact that, again, the area remains critical for having lower bycatch rates.

We were also asked how, how we monitor fishing activity relative to the closures, so I'm just giving you a look at all of the hauls that occurred by our fleet within the king crab savings area this A season. Obviously, all of the fishing effort occurred in very southwest corner of the king crab savings area, and there was relatively low fishing effort within the savings area relative to some of the past few years. And a lot of this was simply due to the pollock distribution shifted to the west in this A season. They were concentrated more heavily around the 50-fathom curve, which If you don't know the bathymetry, it is— it lies west of the box. There was also herring in this A season, which isn't atypical.

We've seen that quite a lot in the last couple of years. And so obviously vessels don't want to take the risk of running into herring. They're difficult to discern from the pollock. On the echo sounders.

So just in summary, obviously this year was a first, first proof of concept, and, and we've appreciated the efforts of the crab industry to help us better identify where crab are, especially during the winter season. It's our sort of perspective that winter survey is, is the best available data for us to understand and be able to avoid crab during the time that we're out there in February. But absent that, we do appreciate, you know, Shawn Hardison's efforts to integrate tagging data into some movement models. And yeah, every year is different, so while This proof of concept work this year, every year is very different, and we ran into extensive sea ice this year, which sort of changed the fishing dynamics pretty significantly. And just in conclusion, the area obviously still remains, according to our experience this year, important for Chinook bycatch avoidance.

And that's all I have. So, thank you very much.

Are there any questions on the presentation? Yes, Ms. Gordon.

Thank you, Madam Chair, and thank you for the presentation. I just really want to commend the Bering Sea pollock industry for your work here to avoid red king crab in this area and the collaborative efforts between the crab industry and with scientists. It seems to have at least been doable, I should say. I'm curious if you see that if we did this again next year, is there a way to kind of check in based on what we heard under the crab research report where crab may move in cold versus warm years? Is there a way to check in and maybe change the shape of the dynamic closure annually?

Sure, yeah, through the chair, um, obviously Susie and I did meet with Sean and we said that, um, you know, and I mean, we don't have a great temperature data in season in terms of what, um, what the bottom temperatures are during the A season. However, you know, our skippers can get reasonable sense of what the temperature is like. Some of them run with temperature sensors on the gear, and so obviously I don't know how that we would formally integrate that into a dynamic closure per se, but it could be used as just additional information for skippers to use while they're on the grounds and making fishing decisions.

Through the chair, Ms. Gowan, to add to that, I think, you know, we, for the inshore sector, we have relied heavily on dynamic and season management, and this was not too dissimilar from that in the fact that it is based on dynamic aspects, and it has kind of the dynamic opening and closing. And so I think as new and emerging information becomes available, it certainly would be It would be considered for continued use of this, and I don't think that we would, we would shy away from continuing work with, um, and communications with, uh, BSFRF and others and integrating data.

Thanks for that. And I really, again, just want to echo appreciating the effort that's been made here. Thank you.

Thank you. And Ms. Kimball. I just wanted to make sure I understood, Mr. Estabrooks. Like, there— if you had had, um, a trigger such that the— like the CV fleet and the mothership did for Chinook, you're not— you're thinking that would not have actually changed what happened, or you think it would have been different where people fished and bycatch?

Um, so through the chair, I guess, is the question that, um, had we required that there be differential rates of Chinook inside versus outside, whether that would have changed whether or not the area would have been open or closed? Is that— yeah. Um, yes, I, I think our understanding is just that the rates are almost always going to be lower within the savings area than outside. And so, um, that just wasn't something that we, um, thought needed additional consideration. But—.

Thank you. Any other questions?

Appreciate the report. Thank you so much.

Okay, so that brings us to our AP report. And reminder to the public, if you'd like to testify on D1, please sign up before the end of the D1 report. Thanks.

Good morning, Madam Chair, members of the council. I'll just wait for it to get on the screen.

All right, good morning everyone. My name is Chelsea Riddell and I am Co-Vice Chair of the Advisory Panel here to give the report on D1 pelagic trawl gear research updates.

The motion reads, the AP received multiple updates regarding the Gear Innovation Initiative work, experimental fishing permit efforts, and the Bering Sea Fisheries Research Foundation crab habitat and species distribution research. AP supports these ongoing efforts to address data gaps which have been prioritized by the council. The AP reaffirms the FE model and the EFH process as the best scientific information available and the best method to understand the effects of all gear on habitat.

The AP recommends the council: 1, endorse the continued work and completion of the GII work, relevant ongoing EFPs, and BSFRF crab habitat and species distribution research. 2, Support and continue modifications and updates to the FE model, including information on crab habitat.

Distribution and outputs from the GII work. 3, Support the industry's consideration of the continued use of the dynamic closure measure in the red king crab savings area as a near-term tool. 4, Summarize in a publicly accessible format any previous gear innovation successes and current status of commercially available sensor technology, ideally to be updated when new information becomes available. 5, Encourage and support collaboration between industry participants, scientists, and managers throughout ongoing gear research, fishing effects model refinement, and any future evaluation of scientifically informed management measures. 6, Task the plan teams, Joint Crab Plan Team and Groundfish Plan Team, to consider all sources of habitat disturbance and crab mortality in the Red King Crab Savings Area and evaluate the magnitude of UFM on crab in the Red King Crab Savings Area.

The main motion passed 12 to 3.

And with that, I can take any questions. Thank you for the AP report. Are there any questions? Yes, Miss Vanderhoeven. Thank you, Madam Chair.

Thank you, Miss Riddell. Um, I apologize if it's in the rationale and I just didn't see it. Um, my question is on number 4, to summarize in a publicly accessible format. Um, did the AP discuss what that looked like?

Thank you, Miss Vanderhoeven, for the question. Through the chair, yes, the AP did discuss that. So there is a web page on the council website summarizing that, and so it was for it to continue to be updated since public understanding and perception is a big part of this. So making sure that we're communicating, because even though items can be found on the e-agenda for various meetings, that can be hard for public to go back and look at.

Thank you, Ms. Riddell. So, so it was really just that it would be in one place and you wouldn't have to dig through the e-agenda? Okay, thank you.

Yes, Ms. Baker.

Thank you, Madam Chair. Thank you, Ms. Riddell. I have a couple of questions. I'll start with, um, of the AP recommendations, I'm looking at number 6, and in the recommendation to task the, the plan teams, uh, to basically consider all sources of habitat disturbance crab mortality and evaluate the magnitude of unobserved fishing mortality on crab in the Red King crab savings area. And I'm wondering if the AP discussed the Unobserved Fishing Mortality Working Group report?

Because at a very simple level, I thought the conclusion was that more research needed to be done to actually evaluate the magnitude of unobserved fishing mortality, but I'm just wondering what the AP discussion was relative to that. Thank you. Yes, thank you, Ms. Baker. Through the Chair, yes, that was discussed, but It was given the amount of new research that continues to happen, um, that it may be appropriate now to start incorporating it since it seemed like there had been additional work, was my understanding in their rationale, um, and since it had been some time since the, uh, Working Group had met.

Thank you for that. My other question is related to, uh, it seems like the supporters of this motion, uh, felt it was not appropriate at this time to consider modifications to the performance standard given the ongoing efforts, uh, for the gear innovation update and some of the other work that's occurring. And so my question is Is— was there discussion about what the appropriate time might be? And I'm thinking particularly, my understanding was that preliminary results from the Gear Innovation Initiative would be available through the Fishing Effects Model early next year, and so I think, um, the count— a year ago, the council essentially stated its intent in 2026 to begin considering options. And so did the AP talk about when the supporters of this motion talk about— does that mean we need to wait for the EFH review to be completed before we might consider those options?

Or was there any discussion of the availability of the preliminaries, expected availability in early 2027?

Thank you, Ms. Baker, for the chair— for the question through the chair. Yes, the AP did discuss that extensively, and so while research is always ongoing, and Dr. Harris did communicate that the fishing effects model is always being updated, given the magnitude of the gear innovation project and the level of detail that it will be able to add to the FE model, that we should wait until we have the preliminary results in February 2027, um, since Dr. Harris had communicated that those should be able to be added. So although the council recommended, um, it in 2026, the project is taking longer, and so it's more appropriate to have that science-based empirical evidence to wait, um, until considering a performance standard.

Okay, I'm not seeing any of the questions. Thank you very much for the report.

So, we will be closing, um, the public testimony sign-up. Um, let's take— like to take a couple minutes here to transition. We'll come back at, uh, 8:50 and begin public testimony on D1. Thank you.

The gentle one. So we're ready to begin our public testimony on D1. We have 34 people. Signed up. As a reminder to the public, individuals and companies will have a 3-minute time limit and organizations and associations 6 minutes.

You'll see a timer on your screen. If you run out of time, I'll offer you a friendly reminder and ask you to provide a concluding statement.

Let's see here. Just, we, we appreciate the information that— before we begin, like to just express appreciation for all of the information that was presented by our partners yesterday and today, which improves our understanding of industry efforts that are ongoing and is in response to Council concerns about better understanding how plagic gear is used and impacts, especially to crab. So as we go into public testimony, I want to reiterate that the Council very much welcomes and values all perspectives on this issue to inform our recommendations moving forward. So we'll begin with Jeff Steele, followed by Casey Dockterman.

Audio good? Yes, good morning. Morning, Council members. My name is Jeff Steele. For the record, I am second-generation fisherman.

I've been involved for the last 50 years in the crab fisheries and the multiple other fisheries in the Gulf and the Bering Sea. I lived in home port of the boats in Kodiak for over 40 years. I have submitted a lengthy written comment attachment on Agenda D1 that is in the notebooks. My issues with the pollock fleet being defined as pelagic trawlers, commonly known as midwater trawlers. NIMS observer data shows that pollock vessels are in contact with the seabed floor a large percentage of the time while they are fishing.

Their nets utilize devices that are not in compliance with pelagic trawl gear. They also fish in a no-trawl zone identified as the RKCSA. I have fished vast areas of Alaska offshore waters that have never encountered such a dynamic area for crab. The deep 60-fathom hole at Potmoller in 512 is one of a kind. Which spills over in the KCSA.

This is at the apex of the Bristol Bay/Bering Sea ecosystems, 56°30' North, 161°50' West. As my chart attachments historically show, a large area was left by the Magnuson-Stevens Act in the eastern Bering Sea as protection for crab zones. This was later dismantled to encourage the Americanization of the groundfish industry by NIBS and the Council in 1981. The groundfish fleets have persisted in reducing the size of what we have left today and to legalize modification of pelagic trawl gear. The increase in trawling and the reduction in size of pot sanctuaries and habitat areas of particular concern for the crab has seriously contributed to the steady decline in crab stocks.

This high-value king crab stock is in near-to-collapse state. It is a mystery to me why they're allowed to continue their fishing activity in the RKCSA, not even knowing what the unobserved mortality rate is. It is also noteworthy to mention here that at this meeting, NMFS has submitted under Agenda B2 the final version of Amendment 57, revisions to the BSA crab FMP dated January 2026. Page 35, this notes under legal gear, trawls and tangle nets are specifically prohibited. Because of high mortality they inflict on non-legal crab.

Specifications of legal gear is important to attainment of biological conservation and economic and social objectives of this FMP. Further down that page, 3.3.6.2, description of habitat areas of particular concern, the RKCSA meets all 4 of those conditions. This area matters along with the state's reputation because the RKCSA SA became one of the best known examples of ecosystem-based fishery management nationwide in Alaska. It reflects a long-running struggle to balance commercial fishing, habitat conservation, also Indigenous and coastal communities' needs. Pawlik is MSC certified as midwater trawl in the Bering Sea.

I think the Pawlik fleet should not be allowed to fish in the RKCSA which is noted as no trawl zone until they can prove their gear is off the bottom 100% of the time. That's it. Thanks.

Thank you very much for your testimony, Mr. Steele. Are there any questions?

Seeing none, thank you for joining us. Welcome. So Casey Dr. Mann is up next, followed by Corey Lesher.

Good morning, Madam Chair and respected members of the council. My name is Casey Dockterman, president of North Point Fisheries and general manager of Bel Air Fisheries. I'm a second-generation Alaska crab harvester with 44 years in the industry and 48 years tied to the Kodiak community. Low crab stocks have devastated my family's livelihood for decades. It started with the 1983 collapse of the Kodiak king crab fishery, once the king crab capital of the world, peaking at 95 million pounds in 1965, now closed for 43 years.

Our Tanner crab fishery, which once reached 11 million pounds in 1976, has suffered low abundance for most of the last 3 decades. Similar tragedies have hit the Bering Sea. Bristol Bay red king crab dropped from a peak of nearly 130 million pounds in 1980 to just 2.6 million pounds tacked this '25-'26 season, a 98% reduction. Bering Sea opilio snow crab fell from 328 million pounds in 1991 to only 9.3 million pounds this year. A 95% reduction.

These collapses have forced many families, including mine, to sell vessels and equipment to avoid bankruptcy. While changing ocean conditions play a major role, the Council has acknowledged significant contact by pelagic trawl gear in the pollock fishery. Though called pelagic, this gear frequently contacts the bottom, especially in sensitive areas like the Red King Crab Savings Area, which is closed to bottom trawling to protect crab and crab habitat.

I respectfully urge the council to hold the Pollock Sector to the high standards its name implies. Implement enforceable performance standards and monitoring to prevent seafloor contact in the RKCSA. If that is not feasible, the council should reclassify this gear as mobile bottom contact gear and managing it accordingly, which may require closing the RKCSA to all trawl with bottom contact. I must recognize and appreciate current efforts by the pollock industry to reduce crab bycatch and mortality in this region. However, the Alaska crab fisheries have been struggling for decades.

As someone who represented all Alaska seafood internationally as the International Program Director at the Alaska Seafood Marketing Institute, I urge this council to act with balance. Protect crab stocks and habitat, while supporting all sectors and help return our crab fisheries to their former strength. Thank you for your time and consideration.

Thank you very much for your testimony, Mr. Dockterman.

Are there any questions?

Mr. Dockterman, if I understood your testimony correctly, you're from Kodiak. Correct. And it seemed like your testimony was really focused on the red king crab savings area.

And I understand the operations and the benthic structure is very different in the Bering Sea and Gulf of Alaska. And I just want to make sure that I understood your— the rationale for your reason of focusing on the savings area in the Bering Sea. Is it based on some of those difference? Differences in the, in the benthic structure and understanding of how pelagic trawling might operate or touch the bottom in the Bering Sea relative to the Gulf, or are other aspects maybe that you'd like to elaborate on? You know, the dynamics of each region is definitely different.

I think that the Bering Sea and Bristol Bay region are definitely unique in its bottom structure compared to a place like Kodiak.

I guess the reason why I focus on that region is it's the last place standing. I mean, in the '80s when I grew up, king crab was king of Kodiak in that region. And we learned a lot of hard lessons from that. And when the fisheries reopened, that area never reopened, which forced many of us harvesters to focus our efforts out west and become fishermen, Bering Sea fishermen. And seems to be the last place standing now.

And so that's where our focused efforts are. Okay, thank you. I hope I answered your question. You did. Thank you for that clarification.

Appreciate your testimony. Oh, Miss Kimball, thank you for your testimony. I just had a question. I don't know if you were here for— to hear the report on the voluntary measures to close part of— so that seems to be supported by the information from the foundation and the surveys to show where the crab actually are. Like, are we protecting the areas where the crab actually are?

I just wanted to see if you're supportive of those voluntary measures, as long as they are kind of tracking the survey data to ensure that we're staying out of the portion of the box that includes the most crab. Oh, by all means, I'm very supportive of any efforts made. I think that the industry in all sectors have made great strides, and, uh, I think it's really important that, uh, we don't base our decision based on emotion or past history, that we need to base our decisions on science and it needs to be equitable for all sectors.

Thank you for your testimony. Thank you.

Corey Lesher is up next, followed by Ben Entkapp and Lauren Hines.

Good morning, Madam Chair and members of the council. For the record, I'm Corey Lesher with Alaska Bering Sea Crabbers. ABSC is a trade association representing the majority of independent crab harvesters who commercially fish for king, snow, and Tanner crab with pot gear in the Bering Sea and Aleutian Islands crab rationalization program. I appreciate the opportunity to testify before you this morning, and I'll also be speaking to our comment letter submitted under this agenda item. Mm-hmm.

First and foremost, I'd just like to thank the presenters who shared their valuable research updates with the Council on relevant work to this issue. I know this was not an exhaustive list of the ongoing research, but I'm pleased that the Council invited updates from these groups. I'm very encouraged to see the variety of robust work being carried out that continues to inform our understanding of complex issues, which are crab movement, fishing impacts on crab gear, gear modifications, and the efficacy of cooperative dynamic crab avoidance measures. On that note, I'd like to offer my sincere appreciation for the gear modification research that Trident has been working on for a number of years now, as well as the efforts from the pollock industry this A season with her crab avoidance measures and the way they stepped forward in response to council direction to cooperate with crab industry and scientists springing into action despite not knowing if or how their gear was impacting crab. Full stop.

If the council, Pollock Industry, and members of the public take anything away from my comments today, I want it to be recognition for all these ongoing efforts to use the tools within the industry to minimize impacts to crab, despite again the uncertainty around what these impacts might even look like. This was a great example of industry and scientists working together to use the best scientific data available to inform industry-led dynamic management areas that balance both salmon and crab avoidance. Moving forward, I think continuing these efforts is perhaps one of the strongest tools that we have available to minimize pelagic trawl gear impact on crab when they're in their vulnerable life stage during A-season fishing. And I encourage the continuation of these cooperative efforts and ask the Council to endorse and support this as an appropriate tool that's continued to be utilized. So at this juncture, what are the next steps?

We want to minimize impacts to crab and the benthic ecosystem. We don't know what those impacts are, but we understand there's periodic seafloor contact by pollock fishing gear. I urge the council to consider a constructive approach for the midterm. Keep this momentum going forward. Exploration and development of an appropriate performance standard.

I use the word appropriate because I think bottom contact sensors or other monitoring technologies would be the best tool in this case. I understand that the current configurations of these technologies aren't yet sufficient to be deployed in a commercial capacity, but suggest a discussion paper that explores different pathways to innovate and incorporate current technologies to monitor, monitor bottom contact in an effective manner. Fishermen are key to this process, and I hope they would be included in every step, or perhaps even guiding those steps. Furthermore, enforcement of bottom contact is challenging, so we would encourage consultation with NOAA Office of Law Enforcement in the development, process as well. The incentive behind an appropriate performance standard is to monitor and perhaps encourage minimum seafloor contact by gear, therefore minimizing impacts to crab and the surrounding ecosystem.

We understand that pollock fishing needs to happen at or near the seafloor to maintain sufficient CPE, while at the same time the Council has acknowledged that the Bristol Bay red king crab stock is at a level of conservation concern. The Council could consider what an acceptable contact threshold for pollock trawl could be in areas that are open to bottom trawling. The discussion paper should explore the range of what this could look like, incorporating updated contact adjustments. Attainable contact thresholds are not intended to shut down the pollock sector, but again, a tool used to incentivize the pollock industry to fish with minimal seafloor contact while continuing to meet their CPE needs. Maintaining the high standards of the Pollock midwater fishery.

Taking action on these proposed short-term and midterm steps is important to set the stage looking ahead to the long-term collaborative research to quantify and understand the potential impacts of unobserved fishing mortality imposed on crab that interact with Pollock trawl gear. This was identified as one of the council's top research priorities. A focused study is needed to reduce existing uncertainties. Importantly, the collaborative part of this study cannot be overstated, as success is derived from industry sectors working together, perhaps with academic, state, and federal research partners. I believe all fishing sectors and all gear types have a responsibility to be upstanding stewards of Alaska's marine resources and the ecosystems that support our fisheries.

We all have an impact, and it's up to all of us to share the burden of conservation. ABSC wants all sectors to be able to continue fishing, harvest all allocations, and to maintain the sustainable fisheries associated with the Alaska brand. In closing, I ask the council to initiate a discussion paper to take the necessary steps to begin exploring the management measures that have been outlined. Thank you, Madam Chair, and happy to answer any questions. Thank you very much for your testimony.

Ms. Vanderhoeven has a question. Thank you, Madam Chair. Thank you, Mr. Lesher. Um, my question is regarding your request for further discussion of sensors in a discussion paper, and it's not clear to me from your letter or your comments what you would be looking to have come back that we haven't already received in presentations with the status of sensors and sensing technology, um, and in previous discussion papers. So I'm, I'm not clear what you're looking for in that regard in a discussion paper.

Through the chair, uh, Ms. Vanderhoeven, thank you for the question. Um, yes, my, my thoughts are to, um, to explore options to use current technologies or modify, innovate to take what's available and create something that is practical in a commercial setting. This is in regards to performance standard. So just one thought that bottom contact monitoring technologies, be it contact sensors, sonars, etc., the discussion paper could explore different ways to modify existing technologies to implement performance standards that are measuring bottom contact. And I think working with industry to identify what those pathways could be, how we could get an accurate accounting of contact.

And so my, my thought in, in those— how I laid that out is to, to explore options and ideas. We've been stuck in this, the cycle of going back and forth what's available and what's not available. I want to look forward, I want to move forward and take this idea to say we understand that current configurations are not practical, practicable for the current fishery operation. How can we get there? And I think in a discussion paper, could start exploring that.

Thank you, Mr. Ritchie. Thank you, Madam Chair. Thank you, Mr. Lesher, for your testimony. Um, I heard you say that in the discussion paper that you're recommending the council initiate, um, it would be beneficial to explore what would be acceptable contact and bottom trawl closures, if I got that right. And in, I think the, my understanding regarding the bottom trawl closure that we talk about the most, which is the red king crab savings area, that was established based on bycatch control.

So I guess I'm wondering if you think that that paper would benefit most from looking into bycatch, unobserved mortality, or effects on, on benthic habitat, or do you think it would be all three, or do you think there would be something that would be prioritized there?

Through the Chair, Mr. Ritchie, thank you for the question. This is, this is a topic that I think that has several layers to it and is difficult to parse out, you know, what comes first. Contact thresholds are a way to potentially manage for bottom contact in an effort to protect the benthic ecosystem, including crab. So if there, if there's motivation to, to continue minimizing contact from pelagic trawl gear, identifying outside of areas that are closed to bottom trawling what those contact thresholds could be if we're monitoring bottom contact. And I really look forward to seeing what is presented in February regarding the updated contact adjustments.

Our estimates based on gear configurations, and how can we use that as a standard to continue encouraging best practices, minimal contact, while allowing the pollock industry to continue catching high CPE rates of their target fish, avoiding salmon, and also minimizing what we hope to be able to quantify, but potential impacts to crab.

Thank you. And Ms. Goehn. Thank you, Madam Chair, and thank you, Mr. Lesher, for your testimony. I just want to make sure I, I heard the ask correctly on encouragement to continue with the voluntary measures to avoid the red king crab savings area and the red crab in there until longer-term solutions are found here for performance standards. Is that right?

Through the chair, Ms. Cohen, that's correct. I second what Mr. Dockterman spoke to previously. I really applaud the efforts by the pollock industry to, to work with the best available science, work with the crab industry and crab science scientists to avoid areas, and understanding that, that at times those areas might have provided higher CPE pollock. And lower salmon bycatch rates. And I fully acknowledge the efforts there and, and hope that those efforts can continue.

Okay, thank you for your testimony.

Ben and Ticknath and Lauren Hines, followed by Heather Mann.

Sorry, Ben, I struggle with your last name.

Sorry. You turned your mic off. Is this on? Yeah, thank you. It is on.

Good morning, Madam Chair, members of the council. I am Ben Entiknap, and with me is Lauren Hines, and we are representing Oceana. It's a pleasure to be here today. We do have a PowerPoint, if you could bring that up for us. But we are, we are here today to request that the Council initiate an analysis to close the loophole that allows pelagic trawling to continue dragging chain foot rope along the seafloor inside habitat conservation areas and areas closed to protect crab and crab habitat.

People are often you know, asking us why in this forum are we so focused on trawling, and that's because the science shows that trawling reduces habitat productivity, diversity, and complexity, and repeated trawling can change shifts in the overall makeup of these ecological systems and seafloor habitat communities. Next slide, please. And the overall scale of impact in the Alaska region is undoubtedly driven by trawl gear, where 97% of the contact-adjusted footprint, as shown in this figure, which is from the National Marine Fisheries Service Fishing Effects Analysis, is trawling, including pelagic trawl, which is over 148,000 square kilometers of that trawl footprint on the seafloor, which is an area greater than the country size of Greece. Thank you. Next slide.

What we now know from the National Marine Fisheries Service fishing effects analysis is that pelagic trawl gear is frequently in contact with the seafloor. The width of that foot rope can be in contact for the entire duration of a trawl, of the tow, and anywhere of 40% of that width to 100% of that width of that gear is dragged along the seafloor. And while these numbers might change with more analysis, what's not going to change is that this gear is on the bottom. What we know is that there is no pollock trawl fishery that can operate without significant bottom contact. Next slide, please.

The Trident EFP testing is commendable, and we'd like to see that work continue,, but we do take issue with the suggestion that just a 2-inch clearance of the foot rope is significant for the protection of crab, which we know just on their own can be, you know, up to 6 inches, or potting crab as shown in this picture here, which could be 2.4 meters high, or benthic invertebrates. The study from Roper et al., 2016 documented the height of benthic invertebrates on the Eastern Bering Sea shelf and slope and found, you know, corals that are feet high and sea whips that are over 2 meters high. A 2-inch foot rope is not going to provide adequate protection for those habitats or those crab. It's not sufficient clearance. Thank you.

Thank you through the chair. For the record, my name is Lauren Hines, also representing Oceana. Next slide. Thank you. This map here shows that a majority of areas in the Bering Sea and Gulf of Alaska that are closed year-round to bottom trawling to protect crab and sensitive habitat are open to pelagic trawl gear, and these areas are highlighted in green.

That exemption exists because of the assumption that pelagic gear stays off the seafloor, unlike bottom trawl gear,, and the science before the council and testimony received from pelagic trawl fishermen at this meeting confirms that that assumption is not correct.

Um, this is a map of the Gulf of Alaska. It's the Middleton Island Habitat Conservation Area, closed to bottom trawl specifically to protect high-relief bottom habitat and coral communities, and it's overlaid with AIS vessel tracking data showing apparent trawl activity inside it, which is currently legal for pelagic trawl gear. And some have pointed to the fishing effects model finding that less than 4% of Alaska's seafloor is disturbed as evidence that there is no concern. But that same model acknowledges over 28% of the seafloor across Alaska has been physically contacted by gear, nearly all of it by trawl, as stated by Ben earlier. And that gap is not observed recovery, it's modeled assumptions built on sediment type as a proxy for habitat rather than data on where corals and sponges occur, with no accounting for continuous trawling that prevents habitat maybe from ever recovering.

Independent expert reviewers have raised concerns about this model's assumptions that still remain unresolved today, and they've stated that it, it should be used as a tool and not a decision-making standard. This model cannot distinguish between a tow or a pelagic trawl gear is 2 inches from the bottom and one that is dragging on the seafloor. It cannot tell us that the gear is what the gear is doing to the seafloor inside conservation areas. Its use as a reason for inaction on pelagic trawl performance standard is not appropriate, and a performance standard analysis can begin to answer the questions this model cannot. Next slide.

And I'll keep it really quick on this. Um, we, um, did an analysis on the Red King Crab Savings Area, which is closed to bottom trawling, outside of the southern subarea highlighted there to protect Bristol Bay red king crab. And the issue that we highlight in here is that the directed fishery leaves this area, their fishing season ends January 15th, and the pollock season begins 5 days later during the most sensitive period of this crab's life cycle. And then I'll just close up on the last slide here. Um, so essentially, um, all Oceana is asking for is an analysis, um, looking at a quantifiable performance standard and a zero-contact standard in conservation areas closed to bottom trawl, among the other things listed below there.

Thank you.

Thank you for your testimony. I'll see if there are any questions. Yes, Mr. Tsukada.

Yes, thank you very much for your testimony. On several of your slides, uh, they were labeled apparent trawl activity. I was wondering what assumptions were made to make them apparent versus definitive trawl activity. Um, thank you, Madam Chair. So The— what we use is the Global Fishing Watch data, which uses a complex algorithm to identify apparent fishing activity, and they can tell if it's trawling based on, you know, vessel speed and heading, and it's using, you know, AIS vessel pings.

Because we don't have access to VMS, we can't say 100% for sure that was trawling activity, but we can say with high confidence based on the AIS data that it's apparent trawl activity. You know, we don't have actual eyes on the boat or the water, but we, we do have the, the science that shows and the data that shows that it's most likely.

Quick follow-up on, is this model or the Global Watch thing publicly available?

Yes, sir, it is publicly available data.

Thank you. And Ms. Kimball. Thank you for your testimony. I guess even just on the first slide, I'm— is that supposed to— what are we trying to accomplish there with the first slide on the contact-adjusted footprint? I mean, I see the Pelagic trawl, which is what we're talking about here, at 148 square kilometers, but the EEZ that we're talking about is over 3 million square kilometers.

So, So the footprint is, it is actually very small when you provide the denominator there. It's, you know, 0.04%. So is this just supposed to give us a context against other gear types, or is this number supposed to spur to action when, when if I do the math, the footprint is very small?

Thank you, Madam Chair, Ms. Kimball.

Maybe that's perspective. I mean, my perspective is 148,000 square kilometers is a very large area. As I said, it's, you know, larger than the country size of Greece. This, though, your question does raise some concerns that we have with the fishing effects model in that these impacts on the seafloor get averaged over broad regions, and while you look at the the fishing impact model, it shows very large impacts in localized areas that are significant, and then National Marine Fisheries Service says, well, they're not more than minimal or temporary because they get averaged over broad areas of the shelf or broad areas of essential fish habitat. But we very much have concerns about this extent of this footprint and the localized impacts that it's having in particular areas in habitat conservation areas.

And then, yeah, you know, we're focused on trawling because of this and because of the science showing that trawling has very significant impacts on seafloor habitats, and we want to be able to find a solution forward that protects these sensitive habitats and species.

Thank you. And I'm— this is somewhat related to that, but, you know, part of the presentation we got yesterday and our previous presentations on the work that NOAA does on— for the EFH evaluation, and that includes in the FE model this literature review to try to account for cumulative effects, things that don't recover in the time frame of the first evaluation are carried over into the second. So we have some opportunity to look at cumulative effects. And I guess what I'm wondering is if you have ideas of how— because you're concerned about the averaging, which I think we know is the way that that evaluation is done now is to meet the letter of the law, meet the regulations. But are there different questions we can answer and still use that same tool that would maybe get at what you were concerned about?

More finite areas or more concise areas in which to do that evaluation. I feel like the tool is there to be used, but we're not asking maybe the right questions for the things that you're concerned about. And not that that needs to go in the EFH evaluation, but it's still a tool to be used for other things as well. I apologize, Madam Chair, that was long. Okay, thank you, Madam Chair.

Well, yeah, so right now we run the model on, for example, essential fish habitat for, you know, pollock, any other groundfish species. But what we could be doing is looking more specifically at the effects on long-lived habitat features like coral, sponges, sea whips, on those habitat features more directly than what we're doing, because what's happening now is these impact scores are getting averaged between a very long-lived feature that could be hundreds of years old with very fast recovering features that might, you know, recover in less than 1 year, and so that lowers the overall scale of of the impact, but you can use this tool in other ways, as you suggested, to really focus in on, on specific habitat features and areas, and we would like to see that work done. And I just want to also add that, you know, this model's constantly under development and constantly being changed, but it really does need a review by the Center for Independent Experts, which the SSC has recommended in the past, that this model undergo independent review And we would very much like to see that happen.

Thank you. I, I think the sensitivity analysis that was— we were told we would get takes care of that averaging, but now that's not a question, so we can talk on the side. Thank you. Yes. Thank you.

We have a couple more questions, but I just wanted to clarify on slide 2, um, just as far as the scale that we're looking at, that was over a 5-year period as well, not a 1-year period. As far as the, um, the calculated footprint, the calculated—. Sorry, which slide are you talking about? Slide 2, or 1, I guess, your first substantive slide.

Um, do you know? I don't— I'm not sure what year, how many year period that is.

Um, I— through the chair, I, I believe where this data was pulled from was the Yeah, I, I see the citation at the bottom. Um, so this contact-adjusted footprint is the overall average. I don't know the exact years that this goes through, but this is taking all of the contact-adjusted footprint for all gear types and then breaking it out into sector. Um, but I am not positive on the exact years, but I know it's not for one year.

Okay, thank you. Yeah, I'm— we can follow up on this, but I'm guessing it's over the review period, which would be a 5-year total calculation.

So, but yeah, well, we can talk on the side about that. Ms. Cohen. Thank you, Madam Chair, and thank you for the presentation. My question is on slide 4, where you brought up in this concept of clearance. I mean, To date, largely we've been hearing concern over bottom contact, but you brought up issues with clearance.

Um, I'm—. But then I didn't see it in your recommendations for a performance standard analysis. It was just focusing on bottom contact. So do you see a need to address clearance as well as part of a performance standard?

Sure, thanks, Ms. Gowan, through the chair. I think that this, this kind of builds on exactly as Ben said, something that we've been bringing up about the fishing effects model is that we're looking at all of this habitat in a very 2D way when we know seafloor habitat is extremely 3D. And this is one of those issues that we go through with when we're comparing reality to a model that cannot do everything that we need it to do. And this also goes into why we believe it should be used as a tool and not as the end-all be-all management decision.. But as far as the contact, or as far as the looking at, you know, the foot rope, the trawl foot rope above the seabed, I mean, we definitely believe that that should be something that is considered, and maybe that should be something that is considered in the analysis.

But I think for us to move in that direction, we also have to be very clear that this is the same thing that we're seeing with bottom trawl vessels that are assumed only 26% of the entire width of a bottom trawl is impacting the seafloor, contacting the seafloor, when we know these invertebrates and seafloor features are much taller in the Bering Sea and Gulf of Alaska than 2 to 2.5 inches.

Thank you. And another question on your recommendations for performance standards. Were you envisioning those are just for habitat protections or for bycatch reduction or one or the either or both?

Um, thank you for the question. I think it's really difficult to disentangle the, the habitat and the bycatch issues. I mean, in my mind, they're completely related, right? The habitat impacts is our bycatch impacts. You're, you're damaging, you know, sea whips and corals, and that's in a way that is also bycatch, and same with, with the crab.

And so I, I have a very hard time separating those and saying that they're, they're different. We're concerned about the impacts to crab habitat and where the impacts of crab habitat or crab themselves and unobserved mortality, all of it is intricately related.

Thank you. And Ms. Baker. Thank you, Madam Chair, and On that very point, um, I also had a question. I think it was Mr. Antiknap about your portion of the testimony related to the clearance issue, and I'm going to ask you maybe to clarify. I thought you were commenting on the EFP report that we received suggesting there was some sort of assertion in that report that, uh, the, the configuration that's being tested for the foot rope was asserted to provide some sort of clearance to avoid crab.

I didn't hear that at all. My understanding is that the purpose of the design of the modified foot rope was to reduce bottom contact, which this council has heard repeatedly is the most important metric we need to worry about. So can you please repeat your recommendation relative to clearance, and please correct me if you weren't referring to the EFP presentation. I really appreciate it. Thank you, Madam Chair, Ms. Baker.

So in the EFP presentation, there was a slide, and Dr. Joachim was referencing King, a study by King, 2019, I believe, that said that there was no seafloor contact as long as the foot rope was 2 inches or greater. And so what we're saying is that 2 inches is not significant for the purpose of crab habitat protection, crab themselves, or other, other invertebrates. So when we get to talking about we want to see zero contact inside habitat conservation areas, like Essential Fish Habitat Conservation Areas or the Bristol Bay, Red King Crab Savings Area, that's got to be more than 2 inches in our mind. We need to make sure that we're substantially off the bottom if they can continue to fish in those areas demonstrating they're off the bottom. Does that, does that make sense?

I answer your question. Thank you.

Through the Chair, thank you, and yes, that's very helpful, and I hope I'm not out of order, Madam Chair, but I interpret that to mean, to your response to also confirm something that I felt like I heard yesterday, is that bottom contact does not necessarily equate to impacts on species and features that we care about. I mean, that's a really basic question. What is your opinion on that?

Thank you, Madam Chair, Ms. Baker. I think for these high relief, you know, habitats, well, really anything, you know, that's maybe a foot or higher, like, that's going to get impacted by that chain as it's dragging along the seafloor. So we are concerned about that impact, not just on the sediment, but on the crab and the habitat features that are rising up above that sediment. In outside the conservation areas, our concern is a little bit less because we know that there's, you know, bottom trawling is also occurring in those, those same areas outside the conservation areas. We would like to see, though, ways to minimize that habitat impact, and I do think that the Trident EFP is promising in reducing that, that contact.

It won't be zero, it's going to be something greater than that for sure, but where there's also bottom trawling, our concern is going to be less than inside conservation areas.

Thank you. And one last question, Ms. Vanderhoeven. Thank you, Madam Chair. Um, my question is with your letter, um, the section the phishing effects model is not justification for inaction. I wasn't following with the references to the 2004 CIE review.

And if I remember correctly, that was the old long-term effects model that was replaced with what we've been using for several rounds of review now with the phishing effects model. And I wasn't making that connection. If you can walk me through that and, and why then the reference to the 2004, since the model has changed so substantially since then. Yeah, through the Chair, thanks, Ms. Vanderhoeven. It's a great flag.

So yes, there was a previous model. It was the LIE model that was used to create the current fishing effects model. And so when this model was reviewed, the things that were flagged in that previous model that our current model is built off of are the same things that were input back into the new fishing effects model. And so it's It's the same concerns that they brought up about recovery rates being, you know, used for being averaged over habitat features, you know, averaging a rock with, say, a 400-year-old coral. It's the same concerns that they had then that we have in this current model.

And I think that's also why Ben has brought up and the SSC has brought up that we would like I would like to see another CIE review of this current model because in its current form, it has not had an independent review outside of our SSC.

Okay. Thank you. Thank you for your testimony. Thank you for your attention.

Our next testifier is Heather Mann, followed by Matt Tinning and Austin Estabrooks. Good morning, Madam Chair. Can you hear me? Yes, good morning. Good morning, Madam Chair, council members.

My name is Heather Mann. I'm the executive director of the Midwater Trawlers Cooperative. MTC represents 32 trawl vessels that participate in fisheries in the Bering Sea and Gulf of Alaska. MTC strongly supports the AP motion, which passed with an overwhelming majority. Also, you heard 3 very detailed presentations yesterday with excellent science-based information.

I appreciate Dr. Harris noting that public perception is important to acknowledge and address. This is happening both through the GII work and the Trident EFP, and also through the great work that Scott Goodman and the Research Foundation are involved in. And for Scott's benefit, if he's listening, the Red Sox did lose yesterday. It is premature to do anything more than continue to support these efforts currently. Please do not allow people who are philosophically opposed to trawl to push you to do something more.

The work being done is groundbreaking, and it's precedent-setting in an international forum. You'll hear a lot of public comment this morning asking for an analysis to define a performance standard or a regulatory change to the definition of pelagic trawl gear. But if you listened closely to the presentations, you would have heard Dr. Harris describe that just because a gear touches the bottom, it does not mean there is a negative impact. We also should not be using pelagic gear as a general term, and it is well accepted, according to Dr. Harris, that pelagic gear is not about where the gear fishes in the water column, but how it fishes. It's believed that many are purposely confusing the public altogether.

You'll also hear things like, we don't want to put anyone out of business, we just want the trawl fleet to be accountable. And this is coming from groups that have either zero or very low observer coverage and large amounts of discharge that go unmonitored, or it's coming from organizations who are literally getting paid to eliminate the trawl sector. Most all gear touches the bottom. All gear has bycatch. This current fight against the trawl industry has created a toxic and frankly dangerous environment, and that's touched me personally.

People will say, well, don't talk about that in public, but actions matter. Words matter. What this council does matters. It's one thing to recognize public concern and address it through scientific methods like this council did with the Coral and Canyons action many years ago. It's another to capitulate to public pressure to do something when the scientific basis for doing that something has not been proved.

There's no evidence that pelagic gear impacts red king crab populations or damages habitat any more than a 20-mile of bottom, bottom-tending longline or even a 700-pound crab pot does. Why are we considering management measures when the question of whether pelagic gear is impacting species or habitats has not been determined? Speculation is not empirical science. Pelagic gear is not bottom trawl. If pelagic gear touches the bottom, it is not fishing like bottom trawl.

Citing studies that describe impacts from bottom trawl and equating that to pelagic trawl is literally spreading misinformation. For people to continue to express that pelagic gear is hard on bottom or it must be treated as bottom trawl because it touches the bottom is concerning. Even the public perception of hard on bottom, bottom trawl is misinformed as that gear has undergone significant changes with raised sweeps and the use of pelagic doors. Touching the bottom does not mean impact. The FEM represents the best available science, and this council has repeatedly confirmed that.

It is peer-reviewed. I find it especially concerning members of the public continue to question that model that is used all over the country to determine gear impacts, including all gears, not just trawl in the North Pacific. A model model that is constantly evolving with additional inputs and scientific scrutiny and SSC review and approval. If the Council chooses to move forward with a regulatory process at this time before it can be informed with the outcomes of ongoing rigorous research, it will be the third process in recent years where, in my opinion, public perception without scientific evidence of benefit is driving management. This Council has always been at the forefront of science-based fisheries management.

We need to course correct before it's too late. There's nothing in the national standards that says we must address public perception with a regulatory action. As Dr. Harris noted, we acknowledge public perception, we translate that into a scientific question, and then we develop an evidence stream which informs the FEM, which has an audit stream to back that up. Please do not weigh the opinions of people not involved with pelagic fisheries telling you how our gear works the same as those who are experts in the gear. Acknowledge their concerns, but instead of acting on them, also listen to the captains and boat owners who are taking time to comment, some calling in from the ocean telling you how their gear works.

They cumulatively, cumulatively have hundreds of years of experience with gear. Ask them questions. Ask them the difference between bottom trawl and pelagic trawl. If the council chooses to, to do more than the AP motion, MTC strongly recommends that a regulatory action is not begun. At most, a discussion paper that encompasses the recommendations in the AP report is most appropriate currently.

If management measures are considered in a discussion paper, details of unintended consequences based on potential future management measures should be included. Included, whether it's socioeconomic, that is to harvesters and processors and impacts to the food production system, or biological, such as impacts on prohibited species catch. Thank you for your leadership on this issue, and I'm happy to answer any questions. Thank you for your testimony, Ms. Mann. Are there any questions?

Yes, Ms. Kimball.

Thank you, Ms. Mann, for your testimony, and there was a lot packed in there. One thing that I wanted to ask about is, I can agree on the use of the fishing effects model, and we have a very good idea about impacts to habitat. What I feel like we have less evidence on are the unobserved mortality of crab, and so I guess, can you expand on that a little bit more in terms of saying you know, we don't have an issue that we don't need to deal with when it feels like the level of uncertainty around our system here is really right there on the unobserved mortality impacts of crab. But if you disagree, I'd be glad to hear that too.

Oh, Ms. Mann, I think you're muted.

But I think what you asked is— okay, we lost connection. Okay, we'll give it just a couple more seconds. Am I back? Yeah, we can hear you. Sorry, I'm in a bad spot for the internet.

So thanks for the question. I heard some of it, not all of it, but I think you're asking me about unintended, um, or unobserved mortality. And I, I agree to some extent that, um, there is still a lot to be known, but we do have an unobserved mortality committee that met and had some recommendations. I guess my point is, why are we just focused on Pelagic trawl when we know that there are other gear types that are on the bottom. And if we really want to look at unobserved mortality, let's do it holistically versus just pointing to pelagic trawl.

We also know that with pelagic trawl, we have these large, you know, mesh sizes in the front of the net where the crab are coming through. Whether or not that net is actually touching those crab when they're in molting and mating, I guess we don't, we just don't know what that impact might be. I just have a very difficult time believing that it's just pelagic trawl and not all the other fisheries that also have an impact, including the directed fishery.

Thank you.

Thank you. Thank you for joining us. Thank you, Madam Chair. Matt Tinning and Austin Esterbrooks. Next, followed by Jim Simon.

Thank you, Madam Chair. Thank you, members of the Council. Very much appreciate the opportunity to testify on this important agenda item. For the record, my name is Matt Tenning, and I'm proud to serve as CEO of the ATSE Processes Association. In our comment letter on this agenda item, we tried to really unpack four key questions relating to the operation of pelagic trawl gear.

In my comments today, I want to do two things. I want to talk about the past and I want to talk about the future. I want to talk about the past because I think there's been a lot of misunderstanding and misinformation about the pelagic trawl gear definition, the performance standard, and some of the history around area-based conservation measures as they relate to pelagic trawl gear. And admittedly, I wasn't in the Council process in the 1990s, but we've carefully reviewed the record on these, and we think the record is very clear in terms of the history and why those actions occurred. And so our comment letter speaks to this, but Pollock was being trawled using bottom trawl gear, and the concern of this Council and regulators was bycatch of halibut and crab.

And so we had a few turns of the wheel to effectively regulate that gear and pelagic trawl gear. And we think that the, ultimately, the 1993 regulation that implemented the current performance standard and the performance— the pelagic trawl gear definition achieved the objective of reducing halibut and crab bycatch. And so that record, we think, is clear and important to understand. We think it's operating as intended because pelagic trawl pelagic trawl gear has performed very well in terms of halibut and crab bycatch reduction. So, from our view, that record is clear and effective.

We also think the history is important in terms of area-based closures, and so I think it's important to understand that pelagic trawl gear has been closed out of Area 512, which was created to to protect juvenile red king crab, and that was done with full understanding that pelagic trawl gear made contact with the sea floor. That was the rationale for closing pelagic trawl gear out of Area 512. Area 516 similarly has been closed to conserve molting and mating crabs on a seasonal basis, and once again, this Council understood the pelagic trawl gear made contact with the sea floor and made the decision to close pelagic trawl gear out of those areas for that region— reason. A different decision was made in the Red King Crab Savings Area, and the reason that different decision was made was because of bycatch. It was an entirely rational decision for this Council to close that area to non-pelagic trawl gear, given that many orders of magnitude of bycatch differential between pelagic and non-pelagic trawl gear.

As a reminder, pelagic trawl gear encounters about 350 Bristol Bay red king crab on average in any given season. As Austin said in his testimony, the number of Bristol Bay red king crab encountered in the A season, I think, was zero. So that's a very rational decision for differential regulation in those areas. It is not a loophole. It is not a loophole that this Council needs to fix.

So the question is not about the past, Madam Chair, it is about the future. And so the question— on that question and in terms of how we move forward, we want to be full partners with this Council and regulators in the path forward and ensuring that we design a path forward that is focused on conservation and management outcomes and clearly defined objectives. And so on that front, Madam Chair, we are committed to research and we've heard a lot about the Girra Innovation Initiative research that we have supported and are pleased to see continue to move forward. And as you've heard from Austin this morning, we've also fully implemented the dynamic closures in the Bristol Bay red king crab savings area and appreciate the acknowledgement of that work. Madam Chair, the Pollock— the Pollock fishery for 50 years has been fishing approximately at this level of intensity in the Eastern Bering Sea on exactly the same fishing grounds.

These are the most productive— some of the most productive fishing grounds in the world. They are predominantly sandy and muddy bottom. They're constantly churned by sea by storm and other ocean events. Peer-reviewed science from our region tells us that these areas, um, recently trawled versus non-recently trawled, are often indistinguishable soon after trawling events occur because of that storm surge. The amount of area swept by our gear, whether on the sea floor or off, amounts to approximately 1.8 of the Eastern Bering Sea in any given year.

It is a small footprint, members of the council. We have the best benthic science in the world in this region, and it tells us that 96% of the area off the coast of Alaska in federal waters above 1,000 meters in depth is undisturbed by fishing activity. The alter— the, the The number from the Eastern Bering Sea, I think, is 94.8%. We think these are things that we can be very proud of, and I think the Council is committed to doing even better, and so is the pollock industry. Happy to take any questions.

Thank you very much for your testimony. See if there are questions. Yes, Miss Vanderhoeven. Thank you, Madam Chair. Thank you, Mr. Chinning.

Um, I, I appreciate your your comments about looking forward and the work that you and other sectors in industry have done in response to Council concerns. I didn't hear you mention unobserved mortality. Is that some— that's another piece that this Council has expressed interest. Is that something that you or APA have given any thought to? Thanks, Ms. Vander Hoeven, through the Chair.

Yes, that's a— certainly there is uncertainty in a lot of aspects of fisheries, including in relation to any unobserved mortality. I think that Ms. Mann mentioned the recommendations of the Unobserved Committee work that's been done, and we do think that they are good. We also think it's important to understand the extent of potential unobserved mortality by pelagic trawl gear. So, you know, I think we can be confident that these are not driving observed stock trends. And we did do some analysis in response to the emergency petition that the Alaska Bering Sea Crabbers filed in 2022 to close the Red King Crab Savings Area.

What we did at that time was we overlaid the pelagic trawl footprint in the Red King Crab Savings Area with the distribution of red king crab across its range. And I think that during the time series we that the range— the overlap was 0.65%. So I think that, you know, certainly unobserved mortality is a legitimate issue to discuss and to research. I also think it's important to look at the kind of likely range of unobserved mortality impacts. And also I agree with Ms. Mann that it's important to consider all sources of unobserved mortality.

Across all gear types.

Thank you, Mr. Tinney. I have a just more of a global question and something I think we're, we're struggling with, um, on this particular issue. We've— you've articulated a lot of the, the history involving the, the rationale of performance standard, the evolution of the performance standard, and the changes in gear that took place to address some of the initial issues with crab bycatch, as well as the context for some of the spatial closures and why pelagic trawl wasn't necessarily included.

We are— and I also heard a commitment from you and your sector for innovation and partnership with the Council. I think I'm trying to understand our, our role in that and how we can assure the public that we're, we are continuing to partner on that continual improvement and put the appropriate amount of influence and pressure on the industry to continue to innovate and improve upon practices, even absent, you know, concrete signals from some perspectives on habitat impacts or crab. So I just wanted to know if you could share a little bit of your perspective on that.

Austin, do you want to take that one?

I guess that I'm happy— Austin's obviously our research lead and, you know, is right across all the research that's occurring. I think that we, you know, we have good investments in research from our sector and good collaborations outside of our sector, and we want to build on those. In terms of, you know, the Council's role, I think that we, you know, encourage guidance and partnership on those, but I'm not sure I have any specific comments beyond that.

Yeah, I also— I mean, that's a difficult question to answer. I mean, I'm just— I would just highlight that, you know, I'm going to the flume tank next week and committed to, you know, further investigation, field study work on, on the, the bottom contact question in particular, and just trying to get a better understanding. I think this Gear Innovation Initiative, it's totally changed my perspective on on, on how our gear operates. And, and, and so I think, yeah, just the continued work will further help elucidate where we can improve and what are the factors that are most important in that improvement. So, I mean, I just think the, the initial effort of the Gear Innovation Initiative has been just incredibly helpful to this point.

Thank you. Thank you both for your testimony.

Jim Simon is up next, followed by Matt Upton.

Thank you, Madam Chair, members of the council. My name is Jim Simon, and I'm speaking on my own behalf, not my employer. Firstly, I'd like to bring to your attention the letter uploaded to accompany this testimony. From Senators Cronk and Yount, which I'm sharing with you at the request of my friend Mike. I'm testing before you as a member of the ignorant public.

In my 23 years of staffing meetings of Fish and Wildlife regulatory management systems, rarely have I witnessed such condescension and disrespectful references toward the public by industry and scientific technical support representatives. No increase in the Pollack Industries communications, public relations, or marketing budget allocations will mitigate the blatant misrepresentation of so-called midwater pelagic trawl gear. It's egregious to blame an uninformed public for this council and NOAA Fisheries blatant promulgation 33 years ago of, quote, midwater pelagic trawl gear, um, regulations, which apparently redefine the meaning of the term pelagic to something other than what the word has meant for more than 370 years. It is also interesting to learn yesterday that a pelagic trawl net's foot rope is actually a chain. One way to mitigate the pesky noise from an ignorant public is to be truthful and transparent.

With that, I'd like to thank the member of the industry who finally spoke look truthfully at the AP and said pelagic trawl gear has always been on the bottom and has to be on the bottom. The American people deserve better than what I've witnessed in the past week. The Fishing Effects Model is being used for 7 different applications, and yet I haven't heard a word about our actual data inputs related to habitat productivity, non-target fish, or benthic species compositions or age structures, then thick food web services to forage fish or non-target fisheries, just some proxy indicators of mud and sand and seemingly unrealistic recovery rates. The SSC's repeated request for independent peer review should no longer fall on deaf ears because some gear innovation initiative isn't done yet. The structure, processes, and systems supporting your decision-making require increased public scrutiny.

An independent critical review to evaluate the degree to which they are post hoc accommodative to industry's interests alone. Public concerns about the long-term sustainability of the Bering Sea and Gulf of Alaska pelagic trawl pollock fisheries appear much more justified after what I've learned in the past week. The Council needs a performance standard to reduce midwater trawl impacts. It should be enforceable and it should drive the industry to reduce their impact to crab and habitat everywhere. It has never been clearer to me that pelagic trawl gear should not be allowed in areas closed to bottom trawling, full stop.

Thank you.

Thank you for your testimony, Mr. Simon. See if there are any questions. Yes, Miss Goan. Thank you, Madam Chair, and thank you, Mr. Simon, for your testimony. Um, You were referencing some elements of the fishing effects model, I think, and the inputs that go into that.

I'm wondering if you can elaborate more. Are you wanting more information on that?

Yeah, I can't say that I fully comprehend it. I've been generally when I, in my work for the past 23 years and look at models, which I understand are simplifications of reality, the first step in evaluating it is looking at the data inputs. And I, as a member of the ignorant public, do not have a clear understanding of what those data inputs are. Um, generally, when I have had conversations about my concerns about the impact of bottom contact, you know, I then end because of who I have worked for in these spaces, getting, uh, basically threats of, well, it's going to increase bycatch of salmon if we're off the floor because the, the bycatch rates of prohibited species catch will increase. And that makes me think, if, if it's simply a trade-off between, you know, habitat disturbance impacts to crab or impacts and increase prohibited species catch, maybe we really should be talking about the long-term sustainability of the pollock trawl fishery.

This pitting one organization's interest in a particular resource over another doesn't seem appropriate. It happens in all spaces, not just this space, but, um, you know, who— can't we find win-win situations? Isn't that a possibility? Hopefully that answers your question. I can't really speak to the more specifics of the fisheries effect model.

It would have been nice to have the time from those from the SSC speaking about it to stop advocating and disrespecting the public and actually give us more specifics on that model.

Thank you. Ms. Baker has a question. Through the chair, thank you, Dr. Simon, for your testimony. That actually, your final statement there was the subject of my question. And so it's more process.

Focused. And I understand this is another point, uh, sometimes of sensitivity, but we have limited time in this process, and the issue in front of us isn't review of the fishing effects model. And so that happens at a particular time in our agenda. We have the EFH review scheduled. So I I fully appreciate and, and would like to be responsive to your request for transparency and having public access to the information we use.

I think that's vital. And, and so the, the week that you're here for this meeting, do you have any ideas, or maybe we can talk offline, what is the best way then if we're not— if we as a council are not scheduled to get sort of an in-depth review of the fishing effects model at this meeting because there's an EFH review currently ongoing. What is the best way for us then to make that information accessible to the public while you're here at the meeting? Have somebody to talk to, kind of, um, look at what's available, be available to answer questions. I'm, I'm just really— I want to be responsive to this, but I, you know, and the very simple answer is we didn't do that because that wasn't on our agenda, but that's not a satisfying answer, I understand.

So I really appreciate if you can help work through how we might better be able to do that. Yeah, through the chair, thank you, um, Ms. Baker, for the question. Um, I have endeavored to, uh, attend the SSC meetings, but the concurrency with the AP makes it really challenging for a very small organization staff-wise, you know, representing 44 sovereign governments. And most of our focus is in river, you know, with our staffing and the resources that we have, which is why we do work with coalitions, right, to help who spend all of their time and have vast teams engaging in this process for years. Um, it's very unfortunate of how that has been represented by multiple people in this process.

But, and, and I know the resources are limited coming from NIMPS, you know, to separate those concurrent meetings so that the public could not have to choose between attending the advisory panel, which seems to be more open. That's sort of the more public, open doors to come in and engage in the system. Uh, and it's hard to choose one or the other to really be able to, to dive into the, the depths of the details with the, the scientists. Um, I wish I had more time in a day You know, but I don't. And so I don't really have concrete solutions for you because I know there are not the federal resources to extend these meetings even longer so that you have serial meetings of the SSC for— and then the AP, you know, so that we— the one person from an organization representing 44 tribal governments could attend both.

So it's an unsatisfactory answer, but it's, it's the best I can do.

Thank you for your testimony, Dr. Simon.

Matt Upton is up next.

Good morning, Madam Chair. Matt Epton with Great West Seafoods. I think it's really important that fisheries management needs to be based on science and data, not assumptions about the impact of gear. I think there's a lot of misinformation right now about the pollock trawling that's happening, and that's why I'm really excited about all the gear innovation work that's happening. Fishermen are trying to be really transparent with the public and provide information about their nets, how they're being fished.

And I think that's really going to help the EFH model be better and help the council make better decisions. I think that's going to be the appropriate time for the council to look at some of the things that's on their docket around this. I'm really worried about some of the calls I'm hearing for closing the entire red king crab savings area right now through the dynamic closure. About 60% of the area is closed. Hopefully that's helping the crab.

It's really hard to tell because over the last 16 years, only 60 crab total were caught by catcher vessels in that area. So hopefully that's getting at it, although it was a little scary yesterday because during Shawn's presentation, he showed some data that the crab were actually to the northeast of that area. But either way, I think that's going to be the most effective way to get at some of the concerns about where crab are rather than kind of a static fixed closure. That area has about 13% of the, um, a-season pollock is taken out of there, and there's really low salmon rates in that area. So it's really important, um, fishery.

One of the things I also heard yesterday that I'm really supportive of is looking at some of the information about swept area and the food that's being created and also the time of toes. I think that's going to be really important data, and I think it's going to help build on some of the information that the public should really be considering when they're evaluating this fishery. I was really kind of disappointed to hear about the apparent trawling activity, and I think what's going on there is they're probably looking at when a trawler leaves Dutch and heads up to the fishing grounds and considering that being the entire kind of footprint versus probably the hour that the net's actually in the water. And so I think the council can really work to actually look at what the actual trawling activity is, because I, I think the pollock fishery is one of the most efficient fisheries in the world, and the amount of food that's being created is astounding. And then when you look at the actual footprint of that, I think if it's more like 13,000 square kilometers, about the size of the Seattle metropolitan area, and that's, that's why I We really want to have some good data on it.

Last, I think the most important way you can get at minimizing bycatch is efficiency. I thought Dr. Yokom and Dr. Harris had really good information about how if you push a fishery into other areas, you can lead to additional toes. Like, for example, if we're closed out of the red king crab savings area, how many additional toes are going to be needed to get that 13% of the pollock? Are you going to be catching more salmon? Are you going to have more of an impact?

Thanks for considering these comments.

Thank you, Mr. Upton. Any questions? I guess on that last point, I— can you elaborate a little bit on the bottom contact as it relates to CPEs as well? Yeah, through the chair, that's, that's something that I've really been thinking about is, you know, every time you have a tow, there's a potential for there being some bottom contact. And so if in your efforts to kind of reduce bottom contact in an area, for example, the Red King Crab Savings Area, you end up having to do 2 to 3 tows to catch that pollock, you could end up actually having more bottom contact.

I think another thing is to really make sure we understand where the crab are. I mean, one of the things I heard in the presentation that the crab are moving and that there's a lot of research being done and that when you ask some of these researchers when the molting time for crab is, it's anywhere from January 20th to June 20th. And so it's really hard with crab to be able to evaluate, are we actually having a measurable benefit to the crab or are we just shifting effort. And when you shift effort, one thing that you know that happens is that additional risk is being created because every time there's an extra tow, there's a chance that you could catch some salmon.

Okay, thank you, Mr. Olson. Appreciate it.

Hey, I think we're in a good spot to take our mid-morning break. Let's come back at 10:30 and we'll begin with Paul Olson. Thanks. Or actually, we'll begin with Richard Peterson. He needs to testify time certain, and then we'll go to Paul Olson.

Thank you.

Council members, please come back to order.

Welcome back, everyone. So we'll be continuing our public testimony on D1. We'll begin with Richard Peterson. I think he's joining us on the phone, and followed by Paul Olson.

Good morning. Can you hear me? Yes, good morning. Good morning, Chair and members of the North Pacific Fisheries Management Council. For the record, my name is Richard Peterson, President of the Central Council of Tlingit Haida Indian Tribes of Alaska.

Tlingit Haida is the regional tribe of Southeast Alaska and the largest tribe in the state, representing more than 38,000 tribal citizens. Since time immemorial, Tlingit and Haida peoples have stewarded our lands and waters through traditional customary harvest practices that sustain our communities and support our physical, cultural, and spiritual well-being. Today, I want to speak directly to agenda item D1 on pelagic trawl gear. Tlingit and Haida strongly opposes the continued mischaracterization of this fishery as mid-water When we know, based on your own records and the best available science, that repeated seafloor contact is occurring. This is not a new issue.

This is not a data gap. The assumption that pelagic trawl gear avoids the seafloor is no longer credible. NOAA Essential Fish Habitat Analysis, independent science, and council discussions all point to the same conclusion. This gear can and does interact with the seafloor, degrading benthic habitat and affecting ecosystem function. The burden should not fall on tribes to prove impacts after the fact.

The council's own discussion paper acknowledges uncertainty, enforcement gaps, and the inability to verify compliance with existing standards. Where there is uncertainty about impacts to essential fish habitat, subsistence resources, and benthic ecosystems that support halibut, crab, and salmon food webs, precautionary management is warranted. These resources are not just important, they are protected by law. They are tied to federal trust responsibilities, and they are essential to subsistence lifeways across Alaska. Yet the current management framework allows ongoing unverified seafloor impacts to continue.

Under the Magnuson-Stevenson Act, the council is required to base decisions on the best available science and minimize adverse effects to essential fish habitat. A standard that is not measurable, not verifiable, and not enforceable is not a standard at all. The existing 10% bottom contact threshold was never intended to function as a true regulatory standard for the Gulf of Alaska, yet it has been treated as one. I'm going to be very direct. The council is also failing to meet its obligation to protect resources and communities.

This concern is not isolated. It is being voiced by lawmakers, tribes, fishermen, and Alaskans across the the state. I understand it may be difficult to hear that level of criticism, but it reflects a growing lack of confidence in the current management. The question is no longer whether these concerns exist. The question is how the council chooses to respond.

If the council is unwilling to acknowledge these shortcomings and take meaningful corrective action, then it must seriously consider whether its current composition is equipped to meet this moment. Because what is at stake here is not hypothetical. These decisions are contributing to the erosion of cultures that have been— that have depended on these resources since time immemorial. We are Salmon People, and when salmon decline, so do our communities, our traditions, and our future. Without a clear enforceable standard, our marine ecosystem remains vulnerable to ongoing destruction from industry trawlers.

So I want to be equally clear about what needs to happen. Tlingit and Haida is calling on the Council to initiate a formal regulatory analysis and adopt a clear enforceable pelagic trawl performance standard based on verified seafloor contact. At a minimum, that standard must limit seafloor contact to only incidental contact in closed areas, establish a strict measurable cap on seafloor contact in open areas, and require that fisheries exceeding those thresholds be managed as bottom contact fisheries. And critically, this must be supported by real monitoring and verification, not assumptions or fancy lobbyists. Without accountability, the distinction between pelagic bottom trawl gear is functionally meaningless.

Now, I also want to briefly connect this to your broader work on climate and ecosystem management. Climate change, I'm not afraid to say it, is already stressing these systems. We are seeing shifts in productivity, distribution, and ecosystem function across Alaska. That makes habitat protection even more important, not less. If we continue to allow avoidable impacts to benthic systems, we are compounding climate pressures with management decisions that we control.

At the same time, your climate work must fully incorporate Indigenous knowledge. Our knowledge is backed by more than 10,000 years of research. Our communities have observed and adapted to environmental change for generations. That knowledge is not supplemental, it is essential to understanding ecosystem change and making informed decisions. And right now we are not seeing that knowledge fully integrated as a co-equal component in management.

Continued inaction on pelagic trawl impacts is not neutral. It is a decision to allow ongoing habitat degradation and to continue to shift the burden of that impact onto tribal and rural communities. The Council has both the authority and the obligation to address this, and frankly, the current framework is becoming increasingly difficult for you to try and defend scientifically, legally, and publicly. We expect the Council to take this issue up now and move forward with a real enforceable performance standard. Anything less continues a status quo that is not working.

Thank you.

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

Yes, Miss Gohan. Thank you, Madam Chair. Thank you for the testimony.

I heard in your testimony request for the council to move forward with a regulatory analysis on performance standards. The piece I want to hear more about is this way to verify bottom contact. I think I heard you say we need real verifiable methods. Can you speak a little bit more to what you're expecting there?

Yeah, at the standard, we feel like, um, at a very minimum, that the standard must limit seafloor contact to only incidental contact in closed areas, establish a strict measurable cap on seafloor contact in open areas, and lastly, require that fisheries exceeding those thresholds be managed as bottom contact fisheries, and obviously having sensors and sonars to verify that.

Thank you, and Ms. Gone has a follow-up. Yeah, thank you for that. Do you have recommendations on what that threshold would look like? I think we can get back to you on that, if that's okay.

Thank you. I'm not seeing any other questions. Thank you, President Peterson. Thank you all very much.

Okay, Paul Olson is up next, followed by Craig Rose.

Good morning, Madam Chair, members of the council. My name is Paul Olson. I'm here on behalf of The Boat Company. We do sport fishing and eco tours in Southeast Alaska, and we're also a conservation organization. Um, I've been before the council a lot over the years, and I'd like to talk about forests, um, because I haven't been before you as much in recent years because we're working on protecting the Tongass National Forest, which is the world's largest intact stretch of coastal temperate rainforest, which makes it increasingly economically valuable.

Natural resource economists have worked over the past several decades to quantify the value of different habitats based on the ecosystem services they provide. Tongass is about 1,200 an acre in terms of biodiversity, food it provides for people. Um, your FMP identifies the North Pacific as one of the most productive ecosystems in the world. And why is that? I know I'm not supposed to ask you questions, so I'll answer it.

It's, uh, in large part because of the undersea forests that are part of the Gulf of Alaska and Bering Sea ecosystems. They consist of various species— sponges, corals,, and they're even more rare. They're even more valuable. What is the most valuable ecosystem in the world? It's these guys.

Um, they're worth up to $143,000 an acre because of their rarity and because of the ecosystem services they provide, particularly as habitat for fish for various purposes— foraging, rearing, refuge. And because These are valuable— well, let me back up. These are vulnerable ecosystems. They're more fragile than old-growth forests, and they take a long time to recover from disturbance. Some of them are several hundred years old, and their recruitment processes are infrequent.

And often when they are damaged, they can cease reproducing in order to repair themselves. So they're very vulnerable, and I'd like to point to One thing I want you to consider with this action, and that's that the North Pacific is a rapidly changing environment. The ocean heat content globally reached a record high in 2025. Um, that is the— from surface to depths, that's what ocean heat content is— reached a record high the year before that and the year before that and the year before that. Um, we got a little reprieve, as your ecosystem reports show, over the last few years from La Niña, but nonetheless it didn't cool it as much as normal because the North Pacific is warming faster than all other oceans.

The impacts of this to corals are largely unknown, but they think there is mass mortalities that occur during marine heat waves, and there's even less known about sponges. Um, we all have also crossed ocean acidification thresholds, which are also important to these species. These changes are nonlinear. If you read your ecosystem reports, they talk about compound extreme events. Those are when ocean acidification upwellings and marine heat waves occur simultaneously.

And again, we don't know what these are doing to our coral habitats, but it's not good. So I'd like to request that you, uh, act cautiously when you're thinking about protecting these habitats, and that you, uh, consider this for both FMP areas, Gulf of Alaska and Bering Sea. Thank you very much, Madam Chair. Thank you very much for your testimony, Mr. Wilson. Yes, Miss Cohen.

Thank you, Madam Chair, and thank you, Mr. Olson, for your testimony. I'm curious how you got a value per acre of habitat. I haven't heard that before, and just— I think you mentioned $143,000 per acre. Yeah, and that's even a 2012 dollars. It's from a study by a gentleman named Rudolph de Groot, and there's a number— there's a number of economists that have started by an economist named Robert Costanza during the 1990s.

It's, uh, it's not uncommon. Uncontroversial, but what they do is they add up the different ecosystem services. There's provisioning services, which is food. There's cultural services, which is recreation, and so there's some value added to that because people like to go diving and look at corals. There's also regulating services, such as climate uptake.

Sponges, for example, filter bacteria in the water up and down the water column. They clean the water. Um, and I'd like to add, we had a significant loss of Gulf of Alaska sponges. It's in your ecosystem report. Um, your scientists, I hope if you continue on with this action or considering this, which I hope you do, I think you'd really benefit from having your deep sea coral program scientists, um, talk about these species.

Thank you. I'm not seeing any other questions. Appreciate your testimony. Thank you.

So Craig Rose is up next, followed by Gus Mullen.

Craig, can you unmute yourself, please?

Now can you hear me? Yes. Good morning. Okay, hi, my name is Craig Rose, and I'm speaking from what's going on 50 years of fisheries research in support of Alaska fisheries, most of which has focused on cooperative research with the fishing industry to reduce trawl bycatch and its effects on habitat. Have several main points that I'll just briefly cover.

The first one, Matt Tinning covered pretty well, that the pelagic trawls definition really achieved much of its original goal of reducing halibut and crab bycatch, and that's really due to the large meshes in the front of the gear, not about avoiding sea floor contact. Bottom contact itself, second point, is not a goal in itself but is a proxy for the Council's efforts to minimize bycatch, including unobserved mortality, or effects on habitat used by fish. This is the same point that's been summarized as contact is not impact. I think that's a really important point here. I appreciated the presentations by Dr. Yokom with her work with Seamus Melly on gear modifications.

They are really being developed to eliminate most of the potential for unobserved mortality and habitat TAD effects of trawl fishing for pollock in the Bering Sea. Research on the bottom trawl impact, on bottom trawl sweeps that we did many, more than a decade ago, provides the best current proxy for understanding both the effects of pelagic trawl footropes and the potential for reducing them. Those sweeps were originally at 20 2-inch diameter weighted line pulled across the seafloor, and we found that effects on both crabs and sea whips were reduced by changing from continuous contact to a few widely separated contact points, establishing 2 to 4 inches of clearance. And I— and that was scientifically studied and demonstrated. I believe that even higher clearances are likely in the Pollack trawl modification.

Any such developments are going to be precluded if there's a threshold of no bottom contact established for legal Pollack fishing. This is either the zero contact or the 10% of the time with any part of contact. And finally, accurately assessing the effects of— on crabs or habitat must consider the area of contact, not in the context of distributional overlaps, as well as the effect and recovery rates, not presumptions that every seafloor contact causes gear-wide mortality or removal, which is what I think what the Fishing Effects Program does. And that being said, I'll take any questions you may have.

Thank you, Dr. Rose. Um, Ms. Vanderhoeven. Thank you, Madam Chair. Thank you, Dr. Rose. Um, my question is your next to last point about any such development will be precluded if a threshold of no bottom contact is established.

Um, I, I thought you would maybe speak to that, but I didn't hear anything beyond that. Can you Can you explain why you think that's the case? Oh yeah, thank you. Uh, 3 minutes is a really short time, so I was zipping through the points, um, and through the chair, sorry, and thank you for the question. Um, the— to do this kind of a modification where you establish small separations from the seafloor, not several, you know, tens of feet of distance, but inches, tens of inches, requires some contact with the seafloor, you know, and in Noel's system, that's the chain loops that provide the contact and establish and regulate the height of the rest of the gear off of the bottom.

If you have no bottom contact allowed, or assume that any bottom contact means all of the gear is in bottom contact, it ignores what that gear does.

Yes, and Ms. Cohen. Thank you, Madam Chair, and thank you, Dr. Rose, for the testimony and for your years of research that you've contributed to this this process. Um, my question is on the clearance. You may have heard in previous testifiers some concern over the amount of clearance that some of these gear modifications may be allowing for. I'm wondering if you can speak more— your testimony, you spoke to 2 to 4 inch clearance with the raised sweeps.

Um, just, you're curious on hearing your thoughts more on this clearance concern. Yes, I heard that other presentation and I think it kind of follows the concept of any contact is impact.

However, our research showed otherwise. 2 To 4 inches, yes, many of those crabs were contacting the gear on soft bottom and of the vast majority of them survived. Even for, you know, this was even with the unmodified gear, we had perhaps only 5 to 10% mortalities, whereas raising them reduced those mortalities to by large amounts, by approximately half. So yeah, I think the concept of any contact— and we did research on Sea Whips as well, which obviously 2 to 4 inches, they're going to be contacted. But we came back through the area and looked at how many Sea Whips were down in a day, week later, a month, and a year.

And, um, yeah, it was nowhere near 100%. It was more like 25% with the regular gear and maybe, uh, 15, uh, after modification.

Thank you for your testimony, Dr. Rose.

Thank you for listening. Gus Mullen is up next, followed by Scott Goodman.

Good morning, Madam Chair and members of the council. Thank you for the opportunity to testify today. My name is Gus Mullen. I'm a second-generation Bering Sea captain, and I have spent my entire life in this fishery, but I've also fished salmon, cod, and other fisheries throughout the state. I grew up aboard Pollock vessels, and I'm currently the captain of the 165-foot Pollock catcher vessel, the Northern Patriot.

The vessel I operate averages approximately 110 tows per year. During this past A season, we completed 41 tows with an average tow duration of approximately 1 hour. Our total harvest of pollock was 17.5 million pounds. That comes out to approximately 41 hours of tow time for 17.5 million pounds of pollock harvested. When our gear is in the water, we actively follow fish through the water column based on information from our sonar and echo sounders.

Throughout a tow, we are constantly adjusting wire length and net depth in response to fish behavior. While there are certainly times when pollock move closer to the seafloor and we follow them downward. When contact occurs, the doors, sweeps, and much of the foot rope remains elevated above the bottom. Pelagic gear is not deployed and left hard on the seafloor for the duration of the tow. It is a dynamic fishing method that requires constant adjustment to efficiently target fish.

Because pelagic nets are designed to fly through the water, they are very sensitive to a lot of variables, including surface and bottom currents, waves, and weather, all of which impacts whether and when seafloor contact occurs. If I could ask the council to keep one thing top of their mind in their decision-making, it would be the importance of efficiency. There are periods when pollock are concentrated near the bottom. If vessels are restricted from effectively targeting those fish, a tow that currently takes 1 hour could potentially take several hours to achieve the same result. More towing time means greater potential for seafloor contact and bycatch of PSC species.

It also means increased fuel consumption, operating costs, and more time at sea for crews, often in challenging weather conditions. In my view, maintaining the ability to efficiently target pollock is one of the most effective tools we have for reducing fishing effort, minimizing fuel use, and limiting opportunities for bycatch. Management measures that unintentionally reduce efficiency can often produce results opposite of those intended. I ask the Council to consider those trade-offs as you evaluate your potential actions moving forward. Thank you for your time and opportunity to testify today.

Thank you very much for your testimony, Mr. Nolan.

Mr. Nolan, I, um, We received a presentation from Trident Seafoods on their EFP yesterday. Are you, um, is your boat one of the boats using the new gear design? Yeah, through the chair, or to the chair, uh, yes, we are. We, we have the, the modified foot rope on both of our nets and have for a couple years now. We were one of the, one of the first boats to, to, to do that, to implement that for Just a quick follow-up, and this may have been covered yesterday too, but you mentioned how important efficiencies were to keep in mind as we move forward.

What is— what were your observations as far as efficiencies and in that, in maintaining efficiencies with the new net design, and how did you determine that from a baseline? Were you looking at like sister vessels fishing in the same area? Yeah, thanks for the question. Short answer is yes, absolutely has maintained efficiency. Being a fisherman and gear innovation is amazing, and I love what the public industry has done with gear innovation through the years, but if something isn't efficient, fishermen will give up on it very quickly.

Um, and so the foot rope has definitely maintained that efficiency for us, uh, to use. And yes, often you are comparing yourself to other boats directly around you. So if you're only catching half of what they're catching, uh, for the same tow time in the same area, it becomes very frustrating. And, uh, it's not financially viable for us either to do that. That.

And so, no, it's, it's definitely been very efficient with the new foot rope.

Yes, Ms. Vanderhoeven, then Ms. Baker.

Thank you, Madam Chair.

I think you're the first vessel operator we've had who's used that modified foot rope, and my question is, regarding the sensors, and we've, we've heard back and forth some concerns about being able to use those in the real world under not research conditions but real fishing conditions. And from your experience with the project, can you just talk a little bit about how you see those sensors working or not in their current state?

Through the chair, I can't speak too much to sensors. I don't have, I don't have a whole lot of experience with sensors, so I'm sorry, I can't. We were, we were not the test boat that used the sensors. We were the first boat after that when they had a working model. So thank you.

And Ms. Baker.

Thank you, Madam Chair. Thank you for your testimony. And I, I think my question follows up on the Chair's question in terms of— and you mentioned in your testimony there has been a lot of gear innovation for pelagic trawl gear, and because that is often always happening in the background Sometimes the details don't make it into the public arenas like here. So what I wanted to ask is, since our worlds intersect, um, like this, what is the best way for the council to continue to encourage, incentivize that continual improvement? Is it really keeping in mind the efficiency factor, like you say, is that the most important thing?

Because sometimes that doesn't translate exactly into regulations. Do you have any thoughts about that? I realize it's a tough question. Thanks for the question. Through the chair.

Yeah, I, I think it's a combination of a lot of things. Efficiency, absolutely. It's very hard to get an industry to adopt something if it cuts their efficiency drastically.

We're all there to make a living. And so when you cut some efficiency by that much, not only does it hurt you financially, but like I said in my testimony, often it pushes us, pushes us into different aspects that we weren't— we're trying to not catch. Also, like, like I said, with like PSC bycatch, if we're you know, 6 times less efficient with that tow, we're dragging a net around with an opening for 6 hours longer than we needed to. I don't know if I'm exactly answering your question here, but I think when— I think identifying an issue is the first thing with gear modification. So if everything's working great and we're, you know, in our industry bycatch is the big thing, but if there's no bycatch being caught, then there's not a whole lot of change happening.

So I think identifying an issue, coming up with models that keep the efficiency and still get to the end goal is huge.

Thank you for that. And Ms. Gowan. Thank you, Madam Chair, and thank you, Mr. Mullen, for testifying today, and just really want to appreciate you as an active fisherman coming up here and speaking to us. I think fishermen are the ones that have the best solutions for some of these challenges, so I appreciate you being willing to testify. My question is if you could speak a bit on the technology you have on the boat to understand where your net is in the water column.

I know not all of us are as familiar with the technology that's on a pollock vessel, so if you could just speak a little bit to that.

Yes, through the chair, thanks for the question, Ms. Gunn. Yeah, so we have a net sounder. There was a picture in Dr. Joachim's presentation yesterday that is a net sounder that shows the opening of the net in relevance to the bottom.

It— you get a good idea of it, but then again, when you're within about 1 meter of the bottom, there's a good bounce of the sonar off the bottom where you get an echo back. And so there's kind of a gray zone in the bottom. You know, it's about 6 feet toward the bottom, but that's, that's how we know where that is. We have door spread sensors, so we have sensors on our doors that tell us the depth. They don't tell us how far off the bottom they are, but they can tell us where relatively to the surface, how deep those, those doors are.

But that's how we judge where our net is, is the net sounder itself and the picture we're seeing.

Thank you. And Mr. Thome. Yeah, thanks, Madam Chair. Thanks, Mr. Mullen. I was curious, and this goes back to some of the presentations we saw yesterday and sort of the input to the Gear Innovation Initiative.

You mentioned in your presentation a little bit about the variability of fishing and this, you know, you're following the fish and that doesn't necessarily mean you're on the bottom all the time or not. But can you talk us through that? Because my sense is we get rolled up into sort of the absolutes, and I'd be curious of your perspective of— just walk us through a little bit of that thinking and how you track the fish and the time on bottom or not. Through the chair, thank you, Mr. Tom, uh, for the question. Uh, yeah, so it, it's a very dynamic fishery, um, and what I referenced in my testimony was that pollack move up and down through the water column drastically, even during the same 1-hour tow.

Um, you— they, they change depths. And so it's not the, the fundamental design of a mid-water net or a pelagic net is— differs from a bottom net in the way that a bottom net is made to be on the bottom. That's how the structure of it is with, with floats. And a mid-water net flies through the water column, and so it— I'm chasing that, that school of fish up and down depending on where I'm seeing it under the boat, and I'm adjusting wire accordingly to bring the net up into the fish or down into the fish, uh, yeah, depending on where we're, where we're seeing them.

Thank you very much for your testimony. I appreciate it. Scott Goodman is up next, followed by Alex Jackson.

Thank you, Madam Chair and council members. Scott Goodman from the Bering Sea Fisheries Research Foundation. Thank you again for an opportunity to come up and talk about the crab research in more depth yesterday. I just wanted to briefly follow up here to highlight a few positive things that I think were inferred from yesterday, but to just speak clearly about a few good things. And to also draw a little bit of attention to a written comment that we submitted.

If you haven't taken a read through, please do.

My comments here, I think, are relatively short, but we want to definitely say that the collaborations with the Pollock folks, with APA and UCB and others, is a very positive thing in our mind. Our board is really strongly supportive of these is supportive of these efforts, and I think we see great value in acknowledging what we did in the first go at sharing some information and then seeing what we could do and agree on and how to go forward together. So we look forward to more of that. Um, but just to just very clearly say that's, um, pretty important in our mind, and to say thank you to the Pollock folks. Secondly, um, we would also say kind of the same thing about Trident Trident has undergone a tremendous effort here to undertake an EFP to experimentally change their gear and reduce the physical potential footprint impact on the seafloor.

We very much appreciate Dr. Joachim's abilities here. She is a great asset to industry here coming from her experience at NOAA, and it's benefit to Trident and to the industry to have access to work with Noel. So we want to say thank you there and to acknowledge that is a very positive thing.

Thirdly, I would say you heard yesterday that much of our research has been focused in a particular area, and I just want to make a brief comment there that even amidst some of the uncertainties about ongoing research and, you know, why was this savings area set up in the first place, what can we say about it, what do we know about it, I think much of our recent research has still highlighted that it, in general, it's a very significant and major area for mature king crab activity in Bristol Bay. So I think it's very important. There's still some uncertainties, of course. You know, how do we access fish and crab in it? And we have some ideas, lots of details, and lots of things to figure out.

I want to note one thing directly that Dr. Harris mentioned in his work. I very much appreciated all of the collaborative presentations.

I would say that the issues here, you know, these are things that are best dealt with by fishermen. We just heard from a young person, a captain on a pollock boat. These are the guys that know. So the fishing industry, as I have learned, working with them on collaborative research. They're excellent at finding ways to fix problems and deal with challenges, and I don't think that the science or the regulatory bodies or anything should really prescribe or limit that.

So I think it's very important for research to help advise and answer questions at times. So I would say that we are not going to say this is what the council should do, this is what needs to be done. We would, we would hope that that gets primarily left to the fishermen, to the people who know, but also it's important to help at times answer questions and maybe give some advice. Dr. Harris's presentation was very good. Again, I commented earlier, but I just wanted to highlight one brief thing.

In one of his slides, he notes the importance here, and this again is part of the balancing act of how do you deal with this stuff and what do you do. His comment, or his bullet, is how gear is fished matters as much as what gear is fished. So that sits kind of at the midst of this. Um, lots of challenges for sure. Um, crab are on the bottom, uh, fish are right there in the same time and space.

With a final comment, I would just say that we are also always looking forward to more ways to collaborate and more ways to help. We've definitely appreciated kind of a new but ongoing interaction with the Trawl folks. And part of our also new engagement is to— our board just recently committed to kind of step into an engagement with Dr. Harris and the FAST Lab. So we're looking forward to that opportunity more in the very near future of working with Brad closely on some of these things. And I think that's all I wanted to share.

I'm open to questions. Thank you. Thank you very much for your testimony. See if there— Ms. Vanderhoeven. Thank you, Madam Chair.

That's the first I've heard of you engaging with the FAST Lab. Can you give us any characterization of what that work might be? Thank you. Through the Chair, yes, Ms. Vanderhoeven.

We have, uh, over time engaged with different academics and different research groups. I think you're aware of that, but we've had a number of connections and, uh, areas to explore with Dr. Harris. And just recently our board met with him and talked with him through a couple of meetings over the last 6 or 8 months. And I don't think we can say here's what we're going to do yet, but we want to work with Brad. So we've, um, our board has approved kind of stepping in.

I would say the context is right in the middle of this, you know, it— the gear initiative, innovation, and all, all that Brad is doing for research that helps catalog gear, um, set up simulations that are well-informed and helpful, and then for, for testing, field testing, and reconciling everything. Um, I don't know exactly what we're going to do together, but we're talking about a number of options that could be related to some of the big challenges. You know, what is clearance? What is contact? It's— I could only say Brad characterized this very well.

Contact is not an on-off. It's not a light switch on a wall. It's a whole bunch of different things. It's gear-dependent, method-dependent.

Time and space dependent. So there's a whole bunch of things that are potential areas for us to work on, but I can't tell you exactly what we're going to do yet.

So there's not a specific project, so there's not a specific timeline, so there's not anything that would necessarily fit in the timeframe we're looking at for this current action., or the current, update to the phishing effects model. This would be something farther out timewise. Great question. Through the chair, unfortunately, I would answer yes, but I'd give you a quick qualification and say we understand the urgency. We're trying to do stuff as fast as possible.

So I would say I would— I will be reporting more on this ASAP.

Yeah, thank you. Ms. Cohen. Thank you, Madam Chair, and thank you, Mr. Goodman, for the testimony. You mentioned that fishermen are best at finding solutions, and I couldn't agree more. What I see as our role as a council is setting what the goal is and what the expectation is for that gear.

Turning to my question is actually from your comment letter where you speak to challenges of using cameras, bottom contact sensors, and other means as being very real, and you say that there could be tractable options within the next 2 to 3 years to help our understanding of fishing gear and its proximity to the seabed. So I'm wondering what you envision within the next 2 to 3 years.

Thank you for the question, Ms. Goehn. Yes, through the Chair, I want to acknowledge the challenges here. I, I've held bottom contact sensors in and worked with cameras quite a bit on a completely different context. So the surveys that the Crab Foundation has run for many years, we've done a lot of camera work and a lot of sensor work. So we— I know some, but I don't know enough to say that some solution that would fit some of these devices for full-time or regular use for Pollack gear or other gear could ever be done.

But what I do think, and, and I think to give you an answer, I think there are some tractable things to try. And if they lead to positive ways that you can overcome the challenges of how does a device talk in real time to an acoustic receiver, or how does a potentially entangling device get wound onto a reel, those are the big challenges. The public industry is absolutely correct in pointing those out, but there could be some tractable solutions to work on together to figure it out in a couple years.

Okay, thank you very much for your testimony. Thank you again. Appreciate it.

So, Alex Jackson is up next, followed by Megan Williams.

Alex isn't online, so we'll circle back. Alex, Megan Williams followed by Shannon Carroll.

Good morning. My name is Megan Williams. I am a scientist, and I'm the Associate Director of Arctic Science and Policy at Ocean Conservancy. Um, we urge the Council at this meeting to revise the performance standard to eliminate bottom contact in areas closed to bottom trawling and to limit bottom contact in the pelagic trawl fleet overall. The current performance standard is outdated.

It's biologically flawed and it's unenforceable, and it's time for the Council on the North Pacific to move forward with tangible steps that reduce the impacts of pelagic trawl bottom contact on crabs, on seafloor, and dependent fisheries and fishing communities. We focus this ask on pelagic trawl because the midwater pollock fleet is responsible for roughly a third of the contact-adjusted footprint in Alaska.

Based on all estimates and extensive industry testimony at this meeting, significant levels of seafloor contact confirm that this fishery is not operating like a midwater fishery, and this is a problem because this fleet is doing so in areas closed to bottom trawling. Habitat Conservation Areas were designated, um, and closed to bottom trawling through both scientific and regulatory processes. Reasons for these closures, as listed from council documents that I referenced, included protecting red king crab habitat and red king crab in the savings area, protecting relatively undisturbed benthic habitats in the northern Bering Sea, protecting undisturbed benthic habitat and blue king crab around St. Matthew and St. Lawrence. By allowing trawl bottom contact in these areas where bottom trawling is prohibited, We feel the council is failing to meet its own stated management objectives. This further diminishes transparency and accountability and thereby stakeholder confidence in all council processes.

So a performance standard should establish a zero contact threshold in these areas with existing bottom trawl closures. This represents the most straightforward and transparent approach and will close a significant loophole in trawl fishery management in Alaska. This is a feasible management unit for improvement, and as we note in our letter, these areas closed to bottom trawling represent less than 5% of pollock harvest overall from 2005 to 2024, demonstrating that the council can take meaningful action to reduce seafloor impacts without substantially constraining pollock harvest opportunities.

Um, changing gears just a bit, because the fishing effects model is so often referenced, uh, to refute concerns about trawling impacts to the seafloor, I would like to consider the model briefly as it relates to this action. The fishing effects model is designed to assess adverse impacts to core essential fish habitat at the stock level for groundfish or crab. So that's really scale-specific, and Dr. Harris confirms this, right? We're looking at stock levels, we're looking at core EFH, and the fishing effects model should not be treated as a management tool that is a catch-all for determining all adverse impacts to habitat, to more localized regions, to the seafloor ecology, and then to the broader ecosystem. Again, the fishing effects model is a really specific tool that addresses broad areas of core EFH over huge areas of the Bering Sea and Gulf of Alaska.

In presentations yesterday, we heard about public perception and stakeholder engagement on this issue, suggesting that concerns with trawling and seafloor impacts are based on misunderstanding and lack of access to information. And I would like to push back on that today. Our concerns really reside with unobserved crab mortality, as well as the uncertainty associated with the fundamental lack of habitat data., and therefore associated uncertainty with recovery and susceptibility. As you heard, this is where external literature is used to develop proxies, and this is necessary again because we don't actually have that habitat data. Furthermore, the fishing effects model doesn't account for that vertical height and structure, and I raise these concerns to remind the council that this model exhibits a high degree of uncertainty across many of its parameters,, and we need to take that into account.

It's not to say it's not an important tool. This is to say that experimental studies that assess actual habitat have found real impacts and effects from trawling, such as cropping, reduced benthic diversity, reduced benthic biomass, and, um, and benthic productivity. And we feel that these studies should certainly factor in as additional components to consider in the best available science. When considering these trawling impacts. Um, so as we move forward and consider the performance standard, I think I would like to simplify this a bit to focus on what we do and we do not know.

We do know that bottom contact is occurring in the pelagic trawl fleet, even in areas close to bottom trawling, but we really don't know as much about crab mortality or habitat in the Bering Sea and Gulf. I think we can agree actually on those simple elements, and given that equation, we land that a performance standard is needed. The fact that we know contact is occurring but do not fully understand its consequences for crab and habitat is not a reason to delay action. It is precisely the reason to begin it. And so to close, um, the North Pacific needs a functioning and enforceable performance standard.

That limits seafloor contact. Areas close to bottom trawling should not allow trawling bottom contact. It's that simple. We urge the Council to advance an analysis that considers alternatives for revising the standard based on quantifiable and verifiable metrics. And thank you for your time today.

Thank you very much for your testimony. Yes, Miss Gohn. Thank you, Madam Chair, and thank you, Dr. Williams, for your testimony. Um, I'm wondering if you can elaborate on— you mentioned performance standard looking at habitat in the Bering Sea and Gulf, but we heard, and I don't know if you were listening under the previous agenda item for Gulf Tanner, that pelagic trawl gear fishes very differently in the Gulf versus the Bering Sea. So I'm curious if you can elaborate on why you think both Bering Sea and Gulf need to be covered.

Through the chair, thank you for the question, Ms. Gowan. I think at this stage it's really important that we consider all regions, and this is exactly the type of information that we could really flesh out when we review via analysis, via discussion paper. We can look at what are the appropriate metrics and thresholds, and it may vary. It may vary based on a closure designation that may have much stricter requirements. And, you know, to repeat, I think I think areas close to bottom trawling should not allow trawl bottom contact from any type of trawl gear.

Um, so I would argue that in those regions you would look for the most stringent requirements and thresholds set. It may look a little different, um, for areas that are not enclosure designations. You may have to address something different in the Gulf of Alaska, but I think it's incredibly important at this junction that The Council has this opportunity to set a clear direction. You have ongoing gear innovation that can really— is promising and will do good things, I think, truly. But if the Council doesn't set a direction to and really ask for increased innovation and reduce seafloor contact, it's much less likely that this gear innovation will get us where we need to go.

So the Council has this incredible position an opportunity to help steer that work in a way that really protects crab and habitat.

Thank you. And second question, we'll go to Miss—. Mr. Escobar can go first. Thank you.

Thank you, Madam Chair. Second question is, uh, on an earlier part of your testimony, you mentioned the fishing effects model, and I'm not sure I tracked what you were getting at. You were speaking about that that covers core habitat at the stock level. But I wasn't sure what you were getting at with that. Through the chair, a fair question.

It's something that I've been, you know, I listened very intently to presentations yesterday and trying to wrap my brain about around how this model should and should not be used. And I think what I'm trying to communicate is that The fishing effects model was originally designed to look at core EFH and then to look at impacts on a groundfish or crab level. So, and we learned about the various stages to get there, but what we can't get at is some of those more localized impacts over smaller regions. And something that we've been thinking a lot about is, you know, like for smaller regions that multiple species rely on for core EFH. So there are— I just think it's really important that we recognize that the scale was determined with something else in some levels in mind.

And so if we walk it back, perhaps we should be looking more at some of the earlier model output before we drop into recovery and susceptibility, because that's where a ton of the uncertainty is introduced. I think that contact-adjusted footprint estimate is actually really important. To this conversation, and especially in light of what we don't know about how some of these seafloor habitats and species assemblages are recovering. So I think both elements need to be included in these conversations, and then we need to remember what the tool is designed to address and what it wasn't. And I think the scale and the resolution that we're looking— keep that in mind.

It's just not the catch-all for everything. It's a great tool. We need to, you know, use it amongst other things.

Thank you. And Ms. Kimmel.

I'm sorry, Mr. Bunge. Thank you, Madam Chair. Thank you for your testimony. I think in the, in the last EFH review we had, none of the stock assessments actually concluded the fishing effects on their species were more than minimal and not temporary, and none of those stock assessments recommended elevating their species to the plant teams or the SSC for possible mitigation. Um, so I'm just trying to follow here.

I'm also reading your comment letter. Um, you're saying because there's uncertainty in the FE model and in EFH, uh, given that uncertainty, there should be an analysis on the efficacy of a prohibition of bottom contact in the pelagic trawl sector. Given that we have this GII work happening and that's ongoing and habitat mapping is iterative and it's variable and it's spatial resolution, which we heard about yesterday, do you think that an analysis on prohibition of bottom contact would be more beneficial to this body than, than actually looking at a range of acceptable contact that's informed by the information we have and that's that, you know, the information that's actually forthcoming. Do you think that it would be acceptable to look at a range, or are you strictly looking for an analysis on prohibition? Through the Chair, thank you for the question, Mr. Ritchie.

I would— I will repeat that I think, and I will— that we should be looking and directing our energy towards is eliminating bottom contact, trawl bottom contact in areas close to bottom trawling. However, under an analysis, I do think it is appropriate to look at a range of options there. I do think it's also important that we take action now to signal intent. I do not think we need to do another full analysis, you know, like I'm not suggesting something separate. I'm suggesting a performance standard at this meeting and, and I And, and so yeah, I would, I would land with that.

I think we have enough information though to set a reasonable range and also to encourage improvements. I think that is where, where we also all can meet, right? We're trying to constantly improve performance, reduce negative ecosystem impacts, support community and fishery sustainability. So if we meet on those, reducing bottom contact is a, is a reasonable I think, goal. And so I think this measure will help us get there.

Thank you, Dr. Williams.

Thank you. And just a brief follow-up. I think you did mention in your testimony and maybe in your letter, I'm just trying to get a reminder of the extent of the closures that we would be talking about that are where non-plagic trawling is prohibited and plagic trawling is allowed. There's been a lot of focus on the Red King crab savings area, of course, and some voluntary measures. And I think over, you know, between 60-65% of that area wasn't used.

Sorry, minse go in. This year by the CV and CP fleets. And it seemed like, you know, we've been getting a lot of positive feedback from crab participants on the collaboration that's taken place. Um, and then there are a few remaining areas that I'm less familiar with and we get less attention on, but I think you mentioned that there is less than 5% of pawlik harvested there. Was that, um, can you clarify, was that on an annual basis or what?

Yeah, what time period were we looking at there? Through the chair, thank you for the question. So that is from Kachinaria's database, um, and 2005 to 2024. And so, and that was is for the Bering Sea. And so looking at areas that are where bottom trawling is prohibited and where pelagic trawling is currently permitted.

So that was for the— over the whole time period, A and B seasons, etc. So, and that is to reflect that we think this is a feasible management unit, especially to, to take a real hard look at in terms of bottom contact. Again, because I think there you can still maintain really effective operations and some of that efficiency component that folks are concerned about. Thank you for that clarification. Yes, Ms. Kimball.

Thank you. And this is similar to a question I asked a previous, previous testifier, but back to the fishing effects model and its use. This, the scale, I believe, is determined at a level determined through the Magnuson Act and the implementing regulations. It's It's, it's created to answer specific questions we're required to answer in the Magnuson Act. And so because it then gets SSC and outside peer review, I feel like we're answering that question.

But it seems like you and others maybe want to ask or use that to answer a different question. So is there a kind of a clear question that you want to ask on a more refined scale that we could use that tool to help get to that? Answer. I, I feel like we're going back and forth on the usefulness or the efficacy of the, of the model when really it's answering the question we are required by law to answer. But there's clearly other questions that, that folks want to get at.

And is that possible to kind of develop that and, and provide that to the council so we know other uses for a tool that is very, very effective at getting some good answers on habitat? Through the chair, um, thank you for the question, Ms. Kimball. Uh, yes, so, um, in full comprehension that the application with regards to EFH processes is, is set out and, and stream and done in regulation. And, and so, and that, that seems very clear to me, um, where I, and, and sort of, My— where I find— where I sort of take issue with it, excuse me, is when it's refused or it's used to refute all questions of potential impacts in trawling, like through the whole Bering Sea and Gulf of Alaska, and we, we can say definitively that we have no adverse impacts to habitat. And I think in answer to it more directly to your question, yes, we I would love to be part of an exercise where we reframe some of those questions to, for instance, look at some of those more long-lived species, to, for instance, look at areas with really high habitat disturbance because they exist.

And we did this, we presented some information on this to the SSC, I think a little bit to the Ecosystem Committee even, where we overlaid very high disturbance areas that were also very important to a core number of, of core EFH for a number of species. So I I think there are definitely opportunities to reframe, and I think that would help us qualify a little bit what we can and can't say about trawling and habitat impacts, and how much we actually do and don't know about habitat. And we're still working off sediment as a proxy, and that's all we have available. But that's a big data gap in a habitat model. So, but there are things we can look at, especially for, like, fishing effort is strong, gear innovation is getting stronger, has, you know, with this ongoing work.

So I would love to use that model to change the spatial scale in some instances, to look maybe at certain species, to look more closely at some closure areas, you know, whatever it ends up being. But I think there's lots of room to do some different— to change the scale.

Thank you very much for your testimony. So I think Alex Jackson is online. So after Alex, we'll circle back and start with Shannon Carroll.

Alex, can you unmute yourself? How about now? Yes. Good morning. Sorry, I'm a fisherman, not that great with electronics, but okay, here it goes.

Madam Chair and members of the council, my name is Alex Jackson. I am the owner-operator of the fishing vessel Karen Ivich, a 58-foot trawler. We fish for pollock and cod in the Gulf of Alaska using both pelagic and non-pelagic gear. These two gear types are very different. Pelagic nets are relatively fragile, so I'm always very cautious when fishing near the bottom.

I want to be clear, I make every effort to fish off the bottom whenever possible When there's bottom sign only, I try to get as close as I can without making hard contact and risking a snag. On our boat, we have a wire that attaches from the boat to a NetSonar, which is tied into our electronics. This gives me a real-time display showing the top, bottom, and sides of the net. While monitoring all my electronics, I can see when the bottom starts to get shallower or deeper. This gives me time to adjust my winch controls, paying out or hauling in main wire to raise or lower the net accordingly.

However, the net sonar has limitations. There's a dead zone within about 1 meter of the seafloor, so the exact bottom reading isn't always accurate. Because the rocky surface is so destructive to the net, we have to use the sonar conservatively and stay well clear to avoid damage. For those who may not be familiar with trawling, when the net snags on the bottom, it is very obvious. In bad cases, the boat comes to a complete dead stop.

I specifically fish in the western Gulf of Alaska. Some tows have softer bottom where light contact is possible, but most areas are rocky and hard. Pollock often hold on steep banks where towing on the bottom would be extremely difficult without damaging the net. As a 58-foot boat, we have limited deck space to repair pelagic nets. Any unnecessary bottom contact means net damage, which results in lost fishing time and lost revenue for our operation.

These nets are expensive. If I were to lose my net, cod, and doors, electronics, it would cost around $250,000 or more to replace. For a small boat fisherman, this is gear I cannot afford to lose. My vessel participates in the Trolley M program and was one of the vessels that piloted it from the very beginning through the full regulation process. Our fleet is actively engaged in cooperative research on multiple fronts.

We were involved in the GII project and are currently in discussions about future projects to continue this important work. We are genuinely interested in improving our fishing practices, but we want to do it in a way that makes sense, isn't rushed, and actually solves real problems. A zero contact standard is not reasonable for any gear type. Rushing into a new monitoring program or enforcement regime that hasn't been properly vetted will set us up for failure and could have serious consequences for the small boat fleet. Our 58-foot boat participates not only in trawling but also in seine and pot fisheries.

All gear types have bottom contact. In closing, I ask the council to work with small boat fishermen like me to develop rules that are practical, effective, and fair to the fleet that depends on these fisheries. And thanks for the opportunity to testify, and I'll answer any questions. Thank you very much for your testimony, Mr. Jackson. Ms. Kimball has a question.

Thank you, Mr. Jackson, for calling in. I, I, I think you said, is your, your boat less than 58 feet and, and that you were involved in the GII project? So has your gear already been characterized and tested through that project, or are you in the queue to do that? I, I sent in some stuff for that project, so I would assume it's already been categorized. Through the chair, sorry.

Thank you. And follow-up, you are on a less You are a less than 58-foot boat or a 58-foot boat? Through the chair, yes, we're a 58-foot boat. Thank you.

Thank you, Mr. Jackson. Um, found your testimony very helpful there. Um, I've been really trying to understand the characteristics, uh, the different characteristics in the Gulf and the Bering Sea and the feasibility of bottom contact with pelagic nets, and I think you described that That very well. You also said, I think that you mentioned at the beginning of your testimony that you, you fished with non-pelagic gear. I was wondering if you could just help me understand the differences in the design that would allow you to fish on bottom with non-pelagic gear, which it's designed to do, versus pelagic gear.

To the Chair, so the bottom net the foot rope is designed to allow you to fish on hard bottom. I don't know, as opposed to the pelagic net, the foot rope is just a chain and it's not meant to go on hard rocky bottom. I don't know if that answers your question or not. It does. I guess I was also interested in the sensitivities or the robustness of of the foot rope designs, if you could.

Yeah, so I don't know if you've seen like a picture of a bottom net, but there's the rollers on the bottom are rubber and I'm sorry, I don't really know how else to describe it, just that if you saw a picture of it, you would understand how it can handle hard rocky bottom as compared to a pelagic net.

Okay, thank you for that.

Yeah, I'm not seeing— oh, Miss Goin.

Thank you, Madam Chair, and thank you for the testimony. And as I did with the previous testifier, I just really want to appreciate an active fisherman testifying. I think it enhances this process, so thank you for your willingness. You described your net sonar and how you know the net's relation to the bottom, but that there's this 1-meter dead zone zone. Can you describe, is your goal then when you're fishing to stay, you essentially stay above that 1-meter dead zone when you're fishing with pelagic trawl?

Yeah, through the chair. Yeah, like I said, is that I'm extra cautious when I'm using my pelagic net just because of what it takes to repair it, especially for a 58-foot boat. So knowing that there's a dead zone, uh, There is times when there's only fish on the bottom, but, but I always try to leave space so that I'm not going to snag up and tear up my net, which is then going to lose me fishing time. So does that answer your question?

It does. Thank you.

Not seeing any other questions. Shannon Carroll is up next, and then we will take Kelsey Ivanoff before we break for lunch.

Thanks, Madam Chair, members of the Council. My name is Shannon Carroll. I'm testifying today on behalf of Trident Seafoods, who is a seafood company with significant stakeholders' responsibilities with crab and pollock and cod in the Bering Sea. I want to start by saying that I think that there is uncertainty with respect to unobserved crab mortality from pelagic trawl and with respect to the variability of how our gear operates. And I do think that the Council should, should address those areas of uncertainty.

But I think it's really critical to note that this uncertainty does not mean that the current management is failing or that there's significant impacts on our status quo. We have robust protections in place. Seafloor contact by pelagic trawl has been managed by the Council and the agency since those definitions were, were put in place in the '90s. It's been publicly reviewed and assessed through multiple different lenses, including EFH analyses, area closure actions, and performance standard reviews. So I want to be clear that the status quo already provides significant protections vulnerable benthic species and habitat and will not result in significant adverse effects.

I, I guess just— I also want to note that there seems to be a trend in, in the council grappling with issues around uncertainty and how to measure impact, and it might be worth considering on a, on a, you know, broader scale how to deal with those in a more structured way. And I just think that might be relevant as we move forward with these kinds of issues. Trident's been working on a solution to this issue for several years, both with our EFP and also with the GII work, but I am concerned that the outcome-driven narrative around this issue is undermining that process, the council process, and invalidating good faith efforts to really find a workable solution. All gear in the Bering Sea has unobserved and observed bycatch of crab. All gear in the Bering Sea is mobile bottom contact gear.

Um, yes, trawling can have a large impact, but that's reflected in the way that it's managed. Framing it as inherently destructive or killing everything in its path is counter to the science and the way the gear is designed, operated, and managed. The reality is there's no study that conclusively shows or demonstrates the impact of trawl as being inherently good or bad at all times. What the studies do show, and I think what is really important, is that where you fish, how you fish, and how the gear operates is the critical thing that you need to evaluate when considering evaluating fishing impacts. And that nuance is the basis of how the council manages impacts in the North Pacific and needs to remain the focus as you move forward to try to deal with this uncertainty.

I don't have a lot of time left, so I, I would have probably preferred to talk about sensors and why a no-contact solution I don't think is, is important, but I'll just close by saying I think whatever the council does do, they need to really consider not coming up with something that's overly prescriptive in how they define the gear so that they can encourage innovation over time. We just dealt with a pelagic gear definition issue last year, and I think that the rigidity of it is one of the reasons that there hasn't been as much innovation as I think possible. There's a lot of innovation outside of what Trident's doing, and I think that you should really try to encourage that. Lastly, just, I think, also considering efficiency and displacement impacts is critical too. Thanks.

Thank you very much for your testimony. I'll see if there are any questions. Yes, um, Miss Kimball.

Thank you, Madam Chair. I thank you, Mr. Carroll, for your testimony. I guess that last comment is something that we've all been thinking about more based on people's testimony in the presentations on efficiency, and I'm starting to think about other testimony about in the Gulf of Alaska in particular, staying above the dead zone in order to avoid rocky habitat and avoid damaging your net. Is that, is that a scenario or something that Bering Sea vessels could undertake, staying above the dead zone, or are we now then creeping into the losing efficiency argument so you're on the water longer? Through the Chair, thank you for that question, Ms. Kimball.

Yeah, I think, I think it would— it seems attractive to, to look at what we have for current technology and just ask captains to stay to fish conservatively above the dead zone, recognizing that it may not be accurately reflecting where the, the foot rope is by up to 3 or 4 feet, sometimes more. But I, I think what's critically important is there's a lot of times a year where 95% of the biomass is within within a few feet of the seafloor. And if you're requiring captains to fish off of that, then they are in the areas where there are more salmon, where there are smaller fish and more juvenile pollock, and where the CPUE is just, you know, I mean, maybe to the point that it's not even economical to fish. I also think what's critical to understand too, particularly if you're using the dead zone as sort of your no-contact standard or some sort of threshold is the variability of the gear is really important. And so you have all these different factors that are affecting how the foot rope is behaving, sea surface disturbance, currents on the surface and on the seafloor, speed, a variety of different factors.

And so So if for enforcement purposes you're maintaining that, that sonar dead zone floor is what your limit is, then you're going to have to add another buffer for, to be conservative, to stay above that, which puts you further above the PAWLC. And as I think, you know, I guess to cite myself, but Dr. Yokum's, or Trident's presentation yesterday, I think Dr. Yokum provided a very good, just simple example of how losses of efficiency can really result in more impacts. And, um, and, and I think that's just critical to understand. So thanks.

Thank you. And Mr. Ritchie. Thank you, Madam Chair. Thank you for your testimony. Um, I think I heard you mention that you thought the council would benefit, benefit from, um, dealing with uncertainty in a more structured way.

And I've, I've been thinking about this a lot lately and a lot over the last year. I was wondering And if you could just briefly expand on that a little bit. Through the Chair, I think admittedly it's not like a well-thought-through idea. I'm just recognizing that there is— we exist under status quo that I think is doing a good job to make sure that we're not having significantly adverse impacts. We are— we have this robust process under harvest control rules, ecosystem status reports to monitor what were the impacts beyond just EFH.

Um, but, but there is uncertainty, right? And, um, there's a lot of people are compelling the council to take action on areas where there is uncertainty. And I think, as I mentioned in my testimony, I agree that there's need to tackle some of these areas of uncertainty, but doing so in a way that you can actually monitor what your— what, what the impact of the management changes and whether it's achieving the, the results that you want in a more structured way than simply, um, I mean, right now we have it such that the council can always review what it's done in the past, but that's not a very structured way to look at it. And I guess what I had in mind a bit was like, you know, just thinking through the risk table process that we have have, um, it's evolved to try to be something that's more transparent and clear about how we're evaluating those types of things that are less quantifiable. And maybe there's some process through which the Council could develop something like that, but I just, I think it's hard as a stakeholder in a business that's, um, you know, invested in the long-term sustainability of our fishery, but also invested in the consistency of the process to have that uncertainty be part of your business planning.

So I'm struggling with that a bit. Thanks.

Thank you for your testimony.

So Kelsey Ivanov, and we'll break for lunch after we take Kelsey's testimony.

Thank you, Madam Chair, and thank you for being accommodating. My daughter and I are flying out to our next meetings, um, here soon. Uh, but good morning. Good morning, members of the council, as well. My name is Kelsey Ivanoff.

I work for Native Peoples Action. I am their Indigenous Stewardship Director, and, um, NPA is a statewide organization dedicated to uplifting Alaska Native voices and protecting our ways of life. We're based all across Alaska. We don't have one single office, but we have a small, a tiny but mighty team who works in different areas of the state. I was raised in Unalakleet, which is on the Norton Sound of Alaska.

I also have roots in Kotzebue, Nulato, and St. Michael. I actually graduated across the river from Portland State, so it was kind of exciting to have a reason to come back to the area. After I spent years away, I moved back to Ummukleet, where I'm raising my 7-year-old daughter. My family participates in the Norton Sound red king crab fishery as well as the salmon fishery. We've fished commercially since I could remember, and the man who's taught my brother and I everything we know You know, my dad Steve has fished since the '70s.

So I understand the lifestyle, I understand the ups and downs and the need to provide for your family. I also understand the adaptability needed to be a fisherman. Umluqleet had a booming herring fishery, a strong Chinook fishery, both of which we no longer have. Then we relied heavily on the coho and the chum run At some point, my dad had to get a year-round job, and I had to teach a man who fished his whole life how to print and save documents from a computer. He could no longer provide for a family of 5 solely as a fisherman, but he adapted.

Now with the weak salmon runs, our communities can no longer depend on the salmon fishery, and our family has had to move our focus to the crab fishery, of which we consider ourselves very lucky to be able to participate in. Participate in. My point of all this is we didn't have the technology to adapt nor tons of money to do so, but we did, and I appreciate the trawl industry's efforts to do so. The performance standard has not been updated since 1993, and it has not adapted with time and technology. We all know the length of time these processes take, uh, so it's MPA's position That action needs to be taken now, whether it's in the form of a discussion paper or initiating an analysis.

With the proven contact pelagic trawl has at the bottom, we believe it should be closed in areas closed to bottom trawling, and the performance standard, by the definition of pelagic, should be no bottom contact for all other areas of the Bering Sea. I will close with something that I've said before. It's not our responsibility to feed the nation at the expense of Alaskans and Alaska's habitat. We hear efficiency means less impact, but at one point— at what point does efficiency become too efficient? If you look at other fisheries across the state, the goal is to provide more opportunity for more fishermen.

You see limits on net lengths, depths, number of pots, number of permits. Our small king crab fishery, for example, is limited to 40 pots with only roughly 30 participants. We have a sole buyer and a CDC, and they will only buy from fishermen who are residents of the Norton Sound. I've heard testimony at APE and here that trawl is targeted under the strictest regulations, but the truth is the people on the rivers are. The people on the Yukon cannot fish at all.

If you're operating the largest nets with the biggest footprint and the highest yield, it should be expected to be under strict regulations and high standards. And with that, thank you for your time and again for being, for being accommodating. Thank you very much for your testimony. I'll see if there are any questions.

Ms. Cohen. Thank you, Madam Chair, and thank you, Ms. Ivanoff. Thank you for the testimony. You spoke to the definition of pelagic trawl and expecting no bottom contact, and I'm just curious. I mean, we know there's bottom contact with this gear, so, you know, would it help if it was defined as like a semi-pelagic?

And then maybe— I'm just, I'm curious. There seems to be this tension with calling it pelagic and then what the expectation is for the gear.

I, uh, thank you for the question. Through the chair, I do think there are, um, I think by definition the public does see it as confusing because they're told pelagic is mid-water, but it's also touching the bottom. Um, so I, yeah, I, I do think adjusting that would be, would be helpful for the public's understanding. I'm I'm by no means an expert, and I, in my work, I try to digest what I read from the council and from NIMMS and make it digestible for the public, for our people to be able to come into these spaces, because it's really hard to do so. So I think making that, adapting that to fit what the definition or to fit what it actually is, would be helpful.

Yes, thank you. And Mr. Muller?

Yeah, thank you, Madam Chair. Um, thank you, Miss Ivanoff, for your testimony. I just want to make sure I understand the statement you made, um, in your testimony regarding a discussion paper and then the follow-up conversation with Miss Gowan here, uh, relative to, you know, maybe some of the confusions or the, uh, some of the unknown and the data gaps that we have in, in this discussion that we're having here. Your hope is, is that a discussion paper will flesh out some of these. Um, uh, is it— did I hear your comments correctly?

At the very least, yes. Um, I— it's our stance that just like what I said with the length of time that these processes take, that that something needs to happen. Something needs to move forward.

Okay, thank you for your testimony. Safe travels. Thank you.

Hey, so that will break for lunch and come back at 1 PM and resume public testimony with John Henderscheidt followed by Chris Garbrick. Thank you.

Welcome back, everyone. So we will resume public testimony on D1. Starting with John Henderscheidt, followed by Chris Garbrick.

Good afternoon, Madam Chair, members of the council. My name is John Henderscheidt. I am the president of Phoenix Processor. We operate the mothership Excellence. Phoenix Processor supports the advisory panel's recommendation on this agenda item.

First and foremost, I want to highlight the value and the importance of Dr. Brad Harris's presentation yesterday in informing the Council's next steps. His work can and should support the Council's increased understanding of the behavior of contemporary pollock trawl gear. The Council should carefully consider Dr. Harris's comments describing the potential value and utility of the GII and the fishing effects model to inform future management actions. Once completed, we look forward to an examination of those GII results and, and an exploration of how those outputs might inform future management decisions, including consideration of trade-offs between target catch rates and efficiency and potential PSC bycatch outcomes. I urge the Council to avoid the pitfall of treating the pelagic trawl issue as one based on semantics and a perceived need to ensure that pollock gear's contact with the bottom is reduced or eliminated on the basis of the Council's choice decades ago to label our gear as pelagic.

I again refer to Dr. Harris's comments that in his view, the term pelagic describes gear gear that can be fished anywhere the pollock are. As simple as this point may be, it is a critical one. There are many times when pollock are tight against the bottom. Without bottom, bottom contact by pollock gear, there is no pollock fishery.

I also remind the council that bottom contact by pollock gear is well documented and extensively integrated into to our existing management portfolio, including both earlier actions under Essential Fish Habitat and description of the fishery in the programmatic EIS. And to refer to bottom contact by, um, pawlet gear as a loophole is really a disservice to all the work the Council has done to understand this gear to date. We encourage the Council to allow the GII work being led by Dr. Harris and supported by the pollock industry to inform its next steps and to guide continuous improvement of fishery performance. Thank you. I'd be happy to address any questions.

Thank you very much for your testimony. Let's see. Yes, Mr. Pamplin. Thanks, Madam Chair. Good afternoon, Mr. Henderscheidt.

Thanks for being here. You mentioned the trade-offs that we need to consider and And I heard that was also raised by a couple other testifiers, Mr. Mullen and Mr. Upton. I'm just wondering if you could just speak to that in a little more detail. I mean, we're kind of hyperfocused right now on bottom contact, but as a council, we need to be tracking a wide variety of issues, including thinking about implications to PSC. So could you just elaborate a little bit further, please?

Through the chair, uh, Mr. Pamplin, thank you for your question.

I think it's broadly acknowledged that gear efficiency and high CPUE, whenever that can be achieved, is the best path, the most direct path to reducing impacts of all sorts, including bycatch of other species. And in particular, with with salmon bycatch, for instance, which is obviously a high priority of the Council and of industry, it's really a question of reducing the amount of water strained to achieve TAC. And to the extent that that is— to the extent that that efficiency is reduced, the risk of higher bycatch rates of other species goes up significantly.

Thank you. Any other questions?

Seeing none, thank you for your testimony. So Chris Garbrick is next, followed by Jeff Crane.

Thank you, Madam Chair, members of the council. My name is Chris Garbrick. I started fishing in the early 1980s, and I have two sons that are career fishermen. I'm lucky enough to have fished multiple gear types, including bottom nets for yellowfin sole and cod, pelagic gear for pollock and hake, and pot gear for crab and cod. Of all those fisheries, pollock is the one I feel the best about from a low-impact and bycatch standpoint.

In my opinion, our pollock gear has by far the lowest impact. Pollock nets are fragile compared to bottom nets or a 700-pound crab pot. If I laid down and had a pelagic net drag— drug over me, it would probably tickle. A bottom net might give me some bruises, but a crab pot being dropped on me wouldn't be survivable. Our boats average about 12 to 15 trips in the A season.

Each trip is about 4 days apart and has an average gear deployment of less than 6 hours per trip. And for B season, about 20 trips, um, gear deployment less than 24 hours per trip. So that's like 4 days of gear in the water for the winter season and less than 20 days of gear in the water for the summer season. The rest of the year out of the water. I think that's pretty low impact.

B season trips are dependent on making bottom contact it's light for 20 hours a day and the fish are driven down and spread out on the bottom, this idea of a performance standard that only lets us touch bottom a certain percentage of the time isn't a realistic management tool. It takes— if it takes 1 hour of bottom contact to fill our cod in and we have a percentage allowance of time on the bottom, what are we supposed to do with the rest of the towing time? It would just be towing around with no economic or environmental benefit, only loss. I'm proud of the innovation and complex management programs the pollock fishery works under. I support the GII initiative and the work that Trident's doing, and we support the AP motion.

I wish some of the crabbers would have some self-reflection instead of projecting their problems with crab stocks on the pollock fishery. They talk about how female and juvenile crab are gently gently released back to the sea. That's true for the most part, but first they go through a violent process of being dragged across the bottom before being hauled to the surface, spinning, spinning the pot on the rail, slamming it into the launcher, shaking the crab out, and then gently returning them before dropping the 700-pound pot back on top of them. Um, this happens thousands of times every day. And then in the pot cod fishery, where some of the larger crab boats, they go up in the, in the fall, right off Port Moller, where we saw charts of where all the female and juvenile crab are, and they start pot codding up there.

And we've all seen and heard the stories of what that bycatch is like up there, and it just, it feels really frustrating to get blamed for crab mortality in the pollock fishery when we're so low impact and stuff like that's going on.

And finally, from a benefit to the nation standpoint, nobody's pulling $100 a pound king crab out on a Wednesday night to feed their family, but they are pulling out pollock. Thank you for hearing my testimony. Thank you very much for your testimony, Mr. Garber. Oh, go ahead, Miss Kimball.

Thank you, Mr. Garber, for your testimony and And I heard really clearly your statements about it not being reasonable to expect no bottom contact, but you also did say that you supported the gear modification work that Trident's doing or other companies are doing. So is that the way you see continual improvement in this fishery, or are you just saying the fishery is fine as is, we don't need to go any further? Through the Chair, Ms. Kimmel, Thank you for the question. I think there's been gear innovation going on since I started, started in this, in the, like, in the '90s. Our gear was way heavier.

We didn't have as good of electronic, you know, we've talked a little bit about the, how we can see good on our sonars or our net sonars. We used to just have a down-facing thing, so that was really hard to see what your net was doing. There's been Electronic innovation, gear innovation, lightness. We're really focused on making our nets lighter, but that, that's always been going on and it was going on when the— it was going on and we had much more impactful gear, I'd say, back in the '90s when the pelio quota was flying up to like over 300 million pound biomass. And so Um, I'm just going a little— anyway, I support that because I think there's some really good stuff in there.

I don't know that that work's done yet. Um, I got maybe some concerns about how some of that gear is going to hold up without having those chains go this way instead of, you know, some more structure in your net. Um, probably okay for shore plant boats if you have some damage, you can, you know, they're short trips and can get in, but the offshore fleets might have some problems with it. But But it's super exciting. I mean, it's pretty cool.

Look how much reduction of contact that that made. And just letting the industry work with their gear, we're always going to try and work and be more efficient. And that's happened my whole career.

Thank you. I think Ms. Kimball asked my question, but your answer to her question flagged another for me. And I guess maybe in part you, you did answer this, but I've heard from others too that there's been a, a constant evolution of gear, you know, beyond, beyond triggers that were based in regulatory changes. So, and we, I think right now we, we're all recognizing the value in this public discourse and some of the, you know, some of the concerns and pressure involved in that and how that is really making us think differently about management, making industry think a little bit differently about ways to improve. And so I think that that appears to be, you know, getting— initiating some, you know, some initiatives and exploration of different gear modifications.

But what, what has in the past, what has really driven the, the gear changes over time that we haven't specifically tracked in the council process? What is the primary driver of, of why you've seen gear change and improve over time? Yeah, thank you for the question. I think that The main driver would be efficiency, and they have gotten a lot more efficient. Efficient.

The other thing is that these nets are, are, are very expensive. So we've done a lot of work with changing different materials, trying different things that can wear differently.

Just— yeah, I think probably efficiency is the biggest thing, though. I mean, we want to be able to get in and get out, especially with $5 a gallon fuel.

Thank you. Thanks. That was helpful. Thank you. Appreciate it.

So Jeff Crane is up next, followed by Oyston Loan.

Jeff isn't on. Okay.

Is Oyston on? Okay. I'll circle back to Jeff. Oyston, can you unmute yourself, please?

How about now?

Yes, good afternoon. Yeah, for the record, my name is Oysten Lone, and I entered a letter as well to the council. I'm a longtime fixed gear fisherman in Alaska. I own two crab vessels that participate in the Bering Sea crab. I fish salmon for many years, and I currently also operate a factory longline vessel.

There are a few things I'd like to clear up. There seems to be a coordinated effort to bring crab pots and longline gear into this discussion, and while I think it's important to evaluate all gear interactions on crab. The agenda item in front of the council today and the past number of years is focused on pelagic trawl gear. Additionally, we heard from the BSFRF. Their upcoming research aimed at evaluating UFM in the pot fishery and the issues of ghost pots.

All pots that are required by regulation have an 18-inch number 30 cotton twine panel that rots out in approximately 2 to 3 weeks. Once the twine deteriorates, the pot opens and can no longer continue fishing. To put things into perspective, if all the crab pots in the entire fleet were placed side by side, they would cover only about a quarter mile area. This is a relatively small footprint on the seafloor. Midwater trawl cannot stay the same.

Regarding longline fishing for cod, we use a 9.2mm groundline that's set on the ocean floor. And retrieved along the same path. Testimony claiming that longline gear is dragged up to half a mile across the bottom during retrieval does not reflect how this gear is actually fished. If that were true, fish would be torn off the hooks and the gear itself would be severely damaged. The Freezer longline fleet has some of the lowest bycatch rates of any fleets in Alaska because of specialized gear, numerous bycatch avoidance measures, and there are many additional tools and practices used by this fleet to fish sustainably.

I would also point out that the longline fishing is one of the oldest fisheries in North America. Cod were caught on the longline before founding of the United States. It has proven to be a sustainable fishery for well over 250 years. We are here to discuss midwater trawl, which in practice is often a bottom contact fishery. For many years, I misunderstood the way this gear operates, as it sounds much of the public has misunderstood as well.

I appreciate, I appreciate the acknowledgment and acceptance that bottom contact occurs more frequently, frequently by this gear type than many others have previously realized. I'm concerned by testimony that suggests the public and fixed gear fishermen do not understand what is happening on the water. Alaska fishermen, coastal communities, and the public have valuable firsthand experience and observations, particularly when it comes to changes they have witnessed in local fisheries and salmon returns. The public is paying attention. Fixed-gear fishermen are struggling.

We are here to express legitimate concerns about the future of Alaska fisheries. Midwater trawl gear regulated or periodically contacts the bottom should be classified as semi-pelagic trawl gear and restricted from sensitive habitat areas. Some form of monitoring or enforcement should Technology should be required to document when nets contact the seafloor. With fishing in sensitive areas, we need to have proof that midwater trawls are not hitting the bottom. Pollock fishing is an important part of Alaska's economy and provides jobs for many people.

I recognize that this is a difficult issue. My hope is that you can find solutions that allows the pollock industry to continue operating while protecting many other fisheries, resources, and communities that make Alaska unique. Week. Thank you. And with that, I'll take questions.

Thank you very much for your testimony. Are there any questions?

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

So Keith Colburn is up next, followed by Therese Vicente.

Sorry, it's been a while since I testified. Madam Chair, members of the council, my name's Keith Coleman. I've been working in the Bering Sea fishing virtually every gear type for the last 40 years. I am a crab boat owner and still active fisherman, so I'm on the ground seeing what's going on. Um, it took 50 years for people to admit there was climate change, okay?

Right now, we've been dealing with conflict in the Bering Sea for the last 40 or 50 years. This isn't new, okay? But the primary problem with conflict It's Mother Nature. Her sick sense of humor put all the zoa and phytoplankton as a primary food source for all of our fisheries. And so we're all sharing the same habitat and bottom.

It's created an issue where we have gear types competing for the same things.

Over the last few years, one— there's a couple of other things that Mother Nature's done. That is, in the last 20 years, we've had 12 of the warmest years ever, which has allowed the fleet, being the Pelagic Trawl Fleet, to move further and further north because there was no ice coverage. So during the A season, they weren't restricted in where they could fish. The other thing is this: we went from 200 boats Averaging maybe 25 square miles of area with just 150 pots, um, to 20 or 30 pots. So at this point, pelagic trawlers are moving further and further north because of climate change.

Our crab are moving at a slower pace to adapt, and we're seeing rookeries being impacted by bottom contact. I mean, When you look at nets today compared to 20 years ago in Dutch, there's no chafing gear on pelagic trawl foot ropes. You know, the bigger fish are on the bottom, they're the strongest. In order to get a trawl down there, you've got to get to the bottom. But I don't want to kick the trawlers to the curb.

We need everybody. We need to survive together. All the fisheries need to find a way to coexist. We need to find a way to utilize areas where we have rookery surcrab and protect them. Modifying gear?

Yeah, let's modify gear for the trawlers, but don't try and do it over the course of 5 or 10 years. Right now we have Sullivan, Murkowski, Cantwell, Murray, We have the strongest delegation in the Senate that is willing to help Alaska and the Northwest. And they're the chairs of all of these committees that are making a difference. And they want to help the small communities. They want to help the fishermen.

They want us all to survive. They want to help the state. We need to find a way to get people to work together. At the same time, admit the fact that, yeah, we're conflicted and we've got problems, and we all know what they are.

Thank you. Thank you very much for your testimony. See if there are any questions. Yes, Mr. Mueller.

Thank you, Madam Chair. Thank you, Mr. Colbert, for your testimony. We heard in Thanks, Jamie.

We heard in previous testimony or in a report on the collaboration between the crab fishing, the crab fishermen that are out there currently and the trawlers relative to, you know, maybe areas of crab and whatnot, and my understanding is that hopefully will someday get incorporated into a a management tool of some sort for the trawlers and whatnot. Assuming you're familiar with that collaboration, my question to you, Mr. Coburn, is, are you a part of that effort? Currently, I'm not part of that. But the thing is, is that, yeah, we need all sectors to work together without question. I mean, small communities are dying in the west of Alaska, and we can't have that happen.

Economics are horrible right now, and as we're seeing our fisheries move further and further north, the cost to catch that fish and crab is more expensive. So yeah, as fishermen, what we're going to do, we're going to maximize our catch regardless of our impact on the bottom or what we're doing. So I would suggest that we Standardized reporting areas. The data is there, okay? Right now, Fish and Game and NMFS are in conflict too as to who's going to manage these fisheries.

Standardized reporting. We report small areas, and they know exactly where our catch has been for years, decades. The same thing with groundfish, although their reporting areas are much bigger. I mean, it is simple. To put this stuff together.

The data is there. It's all stored electronically now. Utilize VMS to find out where we're having conflicts, where the rookeries are, and where the high-impact areas are, and keep people off of it. You know, fishermen are going to modify their fishing practices in 2 days after it takes you 5 years to give us some new ruling. That's how smart us knuckleheads are.

So thank you for the question. Through the Chair, Mr. Long.

Yes, Ms. Gordon. Thank you, Madam Chair, and thank you, Mr. Colburn, for your testimony. I particularly appreciated hearing you say we need all fisheries to coexist. I share that sentiment. I'm curious 2, with you as an active fisherman, you may have heard me ask questions of some of the pelagic trawl active fishermen, and you as an active fixed gear fisherman, do you see ways to collaborate together to better understand unobserved fishing mortality across gears?

You know what, this might sound crazy, and don't hit me anybody in the crab fleet, but you know what, the big fish are on the bottom. They're going to have bottom contact. Let's find a way to put them in areas where they can still survive but not be in high-density crab rookeries. I think the opportunity for us to work together is immense, but we've been fighting each other for decades before Johnny was out there in Dutch Harbor, you know. So yeah, we can work together instead of working against each other.

Thank you, Ms. Kimball. Thank you for your testimony. Debated answering this because as a council we can't advocate for any appropriations or anything like that, but you mentioned working with our delegation. Did you have ideas behind that? We have a bycatch reduction engineering program to deal with these exact questions through NOAA that is severely underfunded.

So are you thinking of things other than appropriations to deal with helping fishermen design basically solutions to the problems that we're identifying? Well, I think Trident is exempt. They're, they're trying to modify their gear to see what they can do. I think as fishermen, we can fast-track this. I mean, you don't have to put sensors on every boat, but let's see historically what they've caught, all right?

And in a minimal effort, see how to get trawlers to stay off the bottom where they have to but still utilize the area where they need it. Um, and you know, the same thing with crab fishing. I mean, we can work together to consolidate our gear, to give the trawlers more area to fish in around us. I mean, I've fished before where I wasn't even on the radio and surrounded by the entire trawl fleet and never lost one pot because they know exactly where I'm at. They— you all have the data and you know exactly where the crab and the pollock are.

Now it changes from year to year, but the data is I think it's easily accessible and wouldn't be a financial burden to anybody to start overlaying surveys and all those things together and get a better picture of where we can work together to make things work for every— everybody's benefit.

Thank you. I think that's exactly why they're doing the winter pot surveys, to see where the overlap is in both space and time. So thank you. To the Chair, Madam Kimball, thank you. Thank you.

Thank you for your testimony.

So Therese Vicente is up next, followed by Trent Hartill.

Good afternoon, members of the Council. For the record, my name is Teresa Facente. I am the Policy and Programs Director for the Kuskokwim River Intertribal Fish Commission, which is an intertribal nonprofit that seeks to support the federally recognized tribes of the Kuskokwim River drainage in fisheries management, research, and monitoring as guided by our tribes' Alaska Native knowledge and the best available Western science. The Kuskokwim Fish Commission supports the establishment of a regulatory, measurable, and enforceable pelagic trawl performance standard that clearly distinguishes that this gear type is different from bottom trawl gear because it is not meant to be fishing on the seafloor. At this meeting, we have several asks of the Council.

First, prohibit pelagic trawling in areas of the North Pacific closed to bottom trawl gear. Second, Second, establish a threshold of 0% allowable bottom contact by pelagic trawl gear in all other waters of the EEZ. Third, require the use of technology such as bottom contact sensors or cameras on pelagic trawl nets to measure and enforce this bottom contact performance standard. Fourth, institute regulatory and financial penalties for one-time and repeated violations of this threshold. And fifth, reduce and set precautionary maximum lengths, depths, and widths of pelagic trawl gear fished in the North Pacific in the regulations.

This last February, you heard a respected elder from the Yukon-Kuskokwim Delta region describe the Bering Sea as the bowl of the Yup'ik people. The food that feeds our communities, nourishes cultures and languages, and supports the interconnected human ecosystem wellbeing comes from this bowl. But if the bottom of the bowl is consistently being scraped in ways that cause damage, how can it hold food? This council needs to realize that there is a multi-species collapse occurring in the Bering Sea. Populations of wild Alaska salmon, crab, marine mammals, seabirds, and more are disappearing all around us, with existential implications for Alaskan fishing communities and Indigenous ways of life.

These are signs of an ecosystem in alarming and potentially irreversible distress. This council also needs to realize that there needs to be a fundamental change from a policy of maximum industrial trawl fishery production and disregard for impacts to ecosystems, habitats, and subsistence communities, to one that is centered on shared responsibility for stewarding our ocean home. One of the ways the council ought to act from these realizations is by setting a strict and enforceable standard for the operation of pelagic trawl gear in Alaska's marine waters. It is clear to the Kuskokwim Fish Commission that pelagic trawl nets are intended to be different than bottom trawl nets. Nets.

As noted in the GII presentation yesterday and underscored by the Council last June, the design of pelagic trawl nets is different from bottom trawl nets, including in that there are no seafloor protective devices allowed on pelagic trawl gear. So in our minds, pelagic trawl nets should not be on the seafloor regardless of where the fish are, and they certainly should not be on the seafloor in areas that have been long closed to bottom trawling to protect habitat and reduce bycatch, and yet they are. This is a glaring loophole that needs to be rectified by prohibiting the use of pelagic trawl gear in these closure areas and establishing a threshold of 0% bottom contact by pelagic trawl nets in all other federal waters of the North Pacific. In order to monitor bottom contact, it will be necessary to require the use of some sort of technology on nets. Bottom contact sensors should be considered for this.

Violations of the contact threshold should be met with regulatory and financial penalties, and these should be graded so chronic offenders have higher penalties. And finally, the council should consider setting maximum depth, length, and width limits for trawl nets in the regulations. Deeper, bigger, and wider nets may be efficient for the pollock industry to meet its but they are also efficient at damaging critical seafloor habitat and indiscriminately catching species that our communities rely on for food, culture, and economy. Shallower and shorter nets may be less likely to contact and impact the seafloor, thus protecting the foundation of the North Pacific ecosystem that our salmon, marine mammals, crab, halibut, and people depend on. And with that, I'm happy to take any questions you may have.

Thank you very much for your testimony. Let's see if there are any questions. Yes, Miss Cohen. Thank you, Madam Chair, and thank you, Miss Vicente, for the presentation. Um, partway through, you were talking about the ecosystem in distress, and then I heard you mention kind of balancing or a trade-off between maximum industrial extraction versus subsistence.

Can you explain a little bit more what you were getting at with those trade-offs.

Yes, thank you, Ms. Cohen. Through the Chair, I think what's come to mind for our Fish Commission in this conversation is this question that's being asked, you know, can the pollock fishery balance these trade-offs between protecting bycatch species, reducing bycatch, also minimizing impact to the seafloor, and also maintain its efficiency? And it's been seeming like the answer is no, it can't do, it can't do it all. Somehow this industry cannot do it all. So then that, in our mind, there's, there's two pathways forward from that.

One, you could continue to prioritize the efficiency of the Pollock fleet and their, their industrial production, their maximum profit, and that would come at the expense of the ecosystem, which is collapsing around us. It comes at the expense of protecting Alaskan tribal communities' traditional foods, um, also the expense of non-trawl small boat fishing livelihoods and of the preservation of living habitat. And I also think this risks violating some of the national standards, and one in particular that was interesting to me is National Standard 5, which is about efficiency. And directly on NOAA's website, um, this statement is said: Conservation and management measures shall, where practicable, consider efficiency in the utilization of fishery resources, except that no such measure shall have economic allocation as its sole purpose. So that to me means efficiency cannot be based solely on economic considerations, and yet it seems in this discussion that it is.

However, another response to this could be asking, is the scale of the, the trawl fishery in Alaska and the prosecution of pollock— has it become too big to be able to also protect species that are considered bycatch, which are also traditional foods to communities? Um, has it become too big to also be able to protect sensitive habitat areas that are the foundation of the ecosystem?. So then maybe it is worthwhile and necessary in order to protect this ecosystem and collapse to scale back pelagic trawling. And one way to do that, and this is I think the question before this council at this meeting, um, is to set a performance standard, performance metric on its allowable benthic habitat contact. Um, so I hope that answers some of your question.

Any further questions?

Appreciate your time. Thank you.

Trent Hartle is up next, followed by Andrea Kajkala and Susie Sikorski.

Good afternoon, members of the council. My name is Trent Hartell, for the record, representing American Seafoods today. Um, this agenda item appears to be focused on a consideration of a performance standard. However, when I listen to the public testimony and when I read the written public comments, I hear considerations for eliminating or reducing bottom contact, interesting crab protections, concerns over sensitive areas. Concern over habitat impacts, in addition to a few requests for a variety of different performance standards.

To me, when I hear these, I, I think back over the last 2 years where the council has considered an action focused on the red king crab savings area, uh, recently considered bottom contact and gear innovation last year, and then here we are this year now presumably considering a performance standard. And then further, I think about what is the new information that is informing all of these considerations, and perhaps the only new piece of information that the Council has to inform these considerations is the GII work, which is going to be fed into the updated fishing effects model and presented to us, uh, this coming February. Given this, I think that if the Council does decide to move forward with the discussion paper, it is critical to be very clear about what conservation and management objectives the council is trying to address. What is the problem that we're trying to fix? In addition, I think it's also critical that if the council does decide to move forward with something, that an action includes several elements for consideration.

One, PSC trade-offs. We know that when you move fleets around, you can have different impacts on prohibited species. Two, the scope of the action at a vessel level or a sector level has entirely different and, and huge impacts to your objective as well as to the, to the affected fleets. 3, The scale of the, the action or the approach. Where is this focused on?

I think that we've heard very clearly that the focus is on sensitive areas where pelagic— where non-pelagic trawl gear is prohibited but pelagic gear is, is permissible. 4, Efficiency trade-offs. I think that a number of other testifiers have really hit this home, but this can have counterintuitive impacts on the objective that you're trying to achieve. It must be carefully considered. And then 5, the linkage between whatever your conservation and management objectives are and the Fishing Effects Model.

That's the best available science. It's new information that can help you effectively calibrate what you're trying to achieve. I think with the last few seconds that I have in my testimony, I just want to highlight that this these considerations that I've laid out here and that other testifiers have touched on represents a significant amount of uncertainty in the, the issues identified with the available information that you have to make informed and calibrated decisions. And I think it's worthwhile for the council to consider that as we see additional climate change-induced complex, very, very complicated problems, that you think about having a, a more structured or holistic approach to deal with these types of issues, specifically geared towards trying to close the— that uncertainty gap to make informed decisions. That's all I have.

I'm happy to take any questions.

Thank you, Mr. Hartell. Yes, um, we'll go to Mr. Pamplin and then Ms. Kimmel. Thanks, Madam Chair. Thanks, Mr. Hartell, for being here today. Um, you mentioned in the list of things that we should consider in a potential action for at this meeting is a vessel level or sector level.

And that's kind of all you put. There's probably a lot to unpack there. I have some assumptions on what you mean by that, but I thought it'd be better if I asked you, what do you mean by that? Thanks. Yes, through the chair, Mr. Pamplin, I didn't have a lot of time to elaborate, but I think at its core, from my perspective, a through line of consideration that the public and the councils consider considering is impact.

And I think impact is a cumulative measure, and that is best specified if you decide to go down the road of some regulatory action or some request of the industry that it's done at a broad level. So I think at the finest scale approach would be at the sector level, but preferably at a fishery level. I think if you, if you look at it at an individual vessel level, it gets really complicated, and it, it essentially divorces your ability to look at cumulative impact on habitat on sensitive species, you know, on crab protection, whatever it may be, whatever your conservation management objective is, it eliminates that connection and it focuses on an individual vessel, which we've heard the operation differences are vast. So I think that the best approach would be to evaluate, for evaluation, either a sector or a fishery level consideration.

Thank you. And Ms. Kimball?

Thank you. I'm trying to figure out how to phrase this question. Mr. Hartfield, thanks for your testimony. I think you talked about not just the scope in the, in the vessel or sector level, but this, the scope of the areas we're talking about. But correct me if I'm wrong, that I think what I keep hearing is take some action in areas that are already closed to non-pelagic trawling, to prohibit or minimize pelagic trawling in those areas.

And when I look at the actual data, there are areas open to non— to pelagic trawl, they're closed to non-pelagic trawl, but they are not where the pollock fleet fishes, not in the Northern Bering Sea, not in most of the Aleutians. So it really comes back down to the red king crab savings area. So is that— I guess I'm trying to get at, is that an unreasonable kind of scope of action, or are you saying that we've looked at that already and we should move on from that? I just want to understand if that's helpful in your mind to try to narrow down what areas we're really talking about. Through the chair, Ms. Kimball, I think that, that to the extent that the council can be very specific in the scale and scope of what action they're considering, it is helpful for the industry to inform how we engage in the process, what in What innovation do we choose to pursue?

What actions would we have? Uh, previously we— the— you heard a report earlier in this agenda item on the voluntary dynamic closures. Those are, those are spatially discrete. So I do think that it is reasonable to focus on that fundamental mismatch where pelagic gear is, is, is allowed and non-pelagic isn't allowed. You've heard that consistently through public testimony, so I think that's a reasonable step for the council to take.

Thank you. And Miss Vanderhooven. Thank you, Madam Chair. Thank you, Mr. Hartill. Um, and if you're not prepared to discuss it, that's okay, but Dr. Harris in his presentation yesterday referenced some new trawl doors that you're trying, and I think it If it's fair to ask, if you could describe those, and I'm sorry if that's out of scope, Madam Chair.

Through the chair, Ms. Vanderhoeven, Dr. Harris did mention that those new doors being used specifically by our company, and I think that in this context, it's worth, you know, noting that they represent a meaningful step in innovation that has high potential for improvements in bottom contact as well as bycatch. It's a new technology where a hydrophone is hull-mounted that can communicate to the doors to specify their location, and, you know, in conversations with Dr. Brad Harris, he's identified that that is a meaningful— provides meaningful resolution for his fishing profile plans that can improve their understanding of bottom contact. So I think for the council's benefit, you know, we purchased these as a matter of, you know, continuing to innovate in our— for our company, continuing to try to do better at what we do, but they also represent a meaningful improvement in the fishing effects model in understanding what impact is.

Thank you for your testimony.

So Andrea Kakela and Susie Zagorski are next, followed by Glen Merrill.

Good afternoon, Madam Chair and members of the Council. For the record, my name is Andrea Kajkala. I'm the Executive Director of the United Catcher Boats, and with me today is Susie Zagorski, the AFA Catcher Vessel Inter-Co-op Manager, also with the UCB. UCB represents represents the majority of the Ketcher vessel fleet fishing for pollock and cod in the Bering Sea. UCB appreciates the significant investment in time, resources, and expertise that independent researchers, fishermen, industry, and managers have devoted to the ongoing work reviewed under this agenda item.

We believe the AP's motion reflects the appropriate path forward: complete the research currently underway, continue updating the FE model, support ongoing crab habitat and distribution work, and maintain collaboration throughout the process. We appreciate the AP's recognition that the Council has already initiated the scientific work needed to address these questions and that those efforts should be allowed to reach completion before additional management measures are considered. I would like to focus on 3 points. First, the Pollock fleet responded to the Council's direction. Last year, the council requested development of dynamic spatial closures in the RKCSA.

Through collaboration and inclusion of data from BSFRF and other sources, the pollock fleet identified areas for avoidance that implemented closure measures during the 2026-A season, which had salmon avoidance provisions and maintained pollock fishing efficiency. That experience demonstrated the value of dynamic management measures built through industry collaborative, uh, collaboration that can evolve alongside new and emergent, emerging scientific information rather than relying on static measures established prior to the inclusion of relevant ongoing research. Second, the research the council requested is underway and beginning to provide important information. These efforts are improving our understanding of pelagic trawl gear, seafloor interaction, and crab and crab habitat and distribution. But the work is not finished.

The sequence of this work is important, especially when it comes to informing policy considerations. The council has already established a science-based process to evaluate these questions, and we implore the council to support the completion of the research, evaluation of the results, refinement of the models, and the SSC scientific review. Then, and only then, consider whether additional management measures warranted. We have not reached the end of that sequence, and the future management decisions will be stronger if they are informed by a complete body of work currently underway. Before moving to my third point, if the council elects to proceed with a discussion paper, UCB urges the council to ensure that any evaluation of potential management measures includes consideration of PSC trade-offs and unintended consequences.

The policy The public fishery currently operates under extensive bycatch avoidance programs and accountability measures for salmon, herring, crab, and other species. Management actions designed to address one concern can have unintended trade-offs to fishing behavior, timing, and location in ways that affect performance in other PSE programs. This is not a threat, it is just reality. Evaluating those trade-offs is essential to understanding the full implications of any future management actions. As Council recognizes— as Council has recognized in many previous actions, fisheries management decisions are often about balancing competing conservation objectives.

Any discussion of future measurements should therefore consider not only potential benefits to unobserved mortality and habitat impacts, but also the potential effect on salmon avoidance, PSE management, fishing safety, operational feasibility, and overall fishing efficiency. Third, collaboration is key. The GII, Trident's EFP, BSFRF's crab research, and other ongoing efforts have brought together expertise across sectors to better understand these issues and identify practical and feasible solutions. The pollock industry is being encouraged to collaborate and work together on improving the collective understanding of gear interactions and crab movement and habitat in RKCSA. Collaboration is more likely to create opportunities for adaptive management approaches that evolve alongside new scientific information.

Before I conclude, I would like to recognize the collective efforts that have been made, that have been made possible. Thank you to Dr. Harris, the APU FAST Lab team, the students and researchers who have dedicated substantial time and expertise to the GEAR Innovation Initiative. Thank you as well to the fishermen and companies who have supported this for this work and provided gear and vessel data to the GII research. We also appreciate the continued collaboration with the Bering Sea Fisheries Research Foundation and their commitment to understanding, uh, improving the understanding of crab habitat and distribution. Finally, and to reiterate, UCB supports the AP's recommendation in full.

The AP's recommendation appropriately recognizes that the public and council concerns are already being addressed through ongoing research, model refinements, and scientific review. Via the MSA-mandated EFH process, the council has an established framework for evaluating habitat interactions, gear performance, and potential impacts. UCB supports continuing that work, allowing the science to reach its conclusion and using those determinations to inform future management actions. In the meantime, collaboration among pollock and crab industry industry, scientists and managers remains one of the greatest strengths of this effort and will be essential as new information becomes available. Thank you for your time, and we are happy to take any questions.

Thank you very much for your testimony. Are there any questions?

Yes, Miss Gorn. Thank you, Madam Chair, and thank you for the testimony. Um, just really want to appreciate all the effort UCB has put into the avoidance of red king crab crab in the Red King crab savings area this past season, and just curious your thoughts on whether that is something that could continue as an effort moving forward. Thank you for the question, Ms. Gowan. I think it does take a substantial effort.

I know that Suzy does manage those efforts, so I'm going to have her elaborate a little more on that.

Through the Chair, Ms. Gowan, thank you for that question. I think my Answer would obviously be similar to a similar question during our presentation in the morning on the dynamic closure areas. Obviously, the, the pollock fishery is well-versed in dynamic management measures, and a lot of effort had went into the dynamic management measure this A season, both in understanding the information to inform it, collecting it, and then determining what could be feasible there is some effort by the fleets to be able to add that into their, their toolbox and management or fishing decisions, as well as to our managers' plates. It's certainly something that can be considered, but I think we would want to be able to understand some of the efficacy and any new information that may be able to— that's emerging that could potentially inform any management measures or fishing decisions. So it would, it would be worth considering potentially.

Thank you for your testimony.

Glenn Merrill is up next, followed by Edward Poulsen and Dan Martin.

Thank you, Madam Chair, members of the Council. My name is Glenn Merrill. Today I'm representing Glacier Fish Company. We participate as a catcher processor in the pollock fishery, and the focus of my testimony today is the use of pelagic trawl gear in areas closed to non-pelagic trawl gear. And for the Bering Sea pollock fishery, that really is the red king crab savings area.

I want to provide a little context, however. Um, the savings area was one of three actions that the Council adopted 30 years ago in an effort to help rebuild crab, king crab, after several years of high harvest rates and poor surveys resulted in closures. 30 Years ago, the savings area was designed to manage bycatch in a race for fish, very different than today, non-pelagic fishery, in an area that was considered important for crab. We knew that pelagic trawl gear had bottom contact and would continue to operate in the savings area. I think really today you're faced with 3 policy questions.

How do you want to define successful pelagic trawl gear operations in the savings area? What are the trade-offs for any action that you take? And how do you monitor and adapt moving forward? I think you've heard already from the two previous testifiers about the importance of defining what success looks like and the need to gain information in order to be able to answer that question. You have the GII work, you have ongoing research that's being done by the crab sector, You have EFPs that are being conducted.

We have a lot of research that is on the way. That needs to be in place in order to have an informed policy decision. Simply put, I think the best thing that the council can convey at this meeting today is that you support those ongoing efforts to gather data and information. That is what is required for an informed policy decision. Question 2, trade-offs.

You know how to do that. You've done lots of these analyses in the past. You already know from the previous analysis you did in the Red King Crab Savings Area that if you move the fishery out of the savings area, it has severe and significant adverse impacts. Third, and I think this is something that I'd really like to focus on, which is monitoring and adapting. You just took an action under your previous agenda item to look at considering ways in which you might begin to think about improving or understanding the impact of your fixed area closures moving forward.

Creating some criteria for understanding if you're moving forward with a policy action, what success looks like at the time you adopted the action and what it looks like in the future, I think is critical. One of the challenges I think that we face here today is expectations or thoughts or considerations of what was intended or thought to be intended 30 years ago are still guiding our policy decisions today. Finally, and I really do want to focus on this, I think you have an adaptive effective, cooperative, non-regulatory, and rapid policy response that incorporates the considerations of both the pollock fishery and the crab fishery, and that's known as the Dynamic Spatial Closure, which the industry adopted this last year. That effective and, I believe, well-received policy tool seems to have been a bit lost as a potential management solution for the issues that we face in the savings area. Thank you for your time.

Happy to take any questions.

Thank you for your testimony, Mr. Merrill. Um, I guess I wanted to expand a little bit on your third point as far as monitoring, um, how we measure success. We're— we've heard a lot of public testimony, um, and received a lot of correspondence requesting verifiable, enforceable measures related to a performance standard, understanding, you know, the the one in place right now has some limitations.

We've also heard a lot of, I think, affirmation from individuals on, you know, working both in the, you know, technology side of things, Pollock fishery, crab fishery, that the sensor technology main has limitations with its commercial applicability.

I'm wondering if you could expand upon areas of any thoughts or considerations on other areas of verifiable measures that we could look at specific to the questions in front of us right now.

Considering the distinction of this action and the last action that we took, we were really focusing on observed crab mortality, and we have limitations here in that there's some uncertainty with the level of unobserved crab mortality. So I'm not sure the same metrics apply from the last action to this action.

Thank you, Madam Chair. I'll try. I think there's a lot packed into that question. I guess I look at it a couple of ways. One, which is the performance standard, at least my understanding of the performance standard that was adopted many years years ago was to try and create some way using the limited technology that existed at the time to be able to measure if the gear, pelagic trawl gear, was being fished in a way that we thought it was going to have more impact on the bottom than we desired.

And I think what we've seen over time is that there have been very, very, very few cases where there have been issues of that performance standard being exceeded. You can look at that a couple of ways. You could look at that as failure of compliance, or you could look at that as it is functioning the way that it is intended and that the gear is operating differently than we understand it to have been of concern in the past, that the gear is operating as we want it to and not in a way that causes additional contact with the bottom. So I think part of the challenge is that that performance standard is— it is a creature of its time. Designed to address the policy concerns of that time.

And so moving forward, I guess my question is, when you think about a performance standard, trying to define gear and how gear operates— I can speak from some experience— is incredibly difficult to do. It sounds really easy, but defining gear and how it operates takes a lot of time. And I think you do have some recent experience with that concerning the, the slight revisions you've made to Pelagic your definitions concerning the cod end issue. I raise that, I guess, because I think we can get to another way to think about it, which is a more of a sector level or a fishery level type of standard or performance or activity that you want to see in an area. And particularly speaking of the savings area, maybe that's looking at something like a certain amount of contact by a given sector is going to be allowable.

Allowable, or a certain amount of fishing effort is allowable. That's one way to get at those issues. I think you can also get at those issues somewhat differently. We've had some experience with the raised trawl sweeps in non-pelagic trawl gear, but again, that was a multi-year effort informed by information and a lot of studies to develop something that we think worked and addressed a concern that the Council had at that time for that that year. So I think you have a couple of examples out there, but to also echo some of the previous testifiers, whatever you do has to be something that's tractable, manageable, and understandable by us in the sector and allows us to have flexibility in how we operate.

Thank you for that. Can you, can you remind me, is there a performance standard attached to the elevated sweeps for MMA or for the Non-palliative trial gear? Madam Chair, in a sense, in that it defines how the gear— the degree of lift that you have to have over time for the elevated sweeps, and they can provide you the regulations over time.

I don't have them with me at the moment. So it's— if I understand, that was more of a A gear specification performance standard, so identified it. Okay, correct. Okay, thank you for that clarification. Are there any other questions?

Seeing none, thank you. Thank you.

So Edward Poulsen and Dan Martin are now up next, followed by Michelle Stratton.

Members of the council, my name is Edward Paulson. I'm a part owner in 3 Bering Sea and Aleutian Island crab vessels, and I'm here with Dan Martin. And, um, I bet you didn't expect to see a crabber and a pollock fisherman sitting up here together, so we're going to try to figure this out the old-fashioned way and arm wrestle it out. No, I'm here to provide support for the pollock industry's efforts as well as announce the intent to collaborate between crabbers and pollock stakeholders.

I specifically wanted to support the voluntary short-term efforts that the pollock fishery committed to in order to avoid red king crab in the savings area, and second, I wanted to thank Trident for their leadership in devising and testing modified modified gear that could provide a long-term solution to dramatically reduce the footprint of their gear without increasing bycatch. Having said this, we're still struggling with what to do over the midterm, and a better understanding of unobserved mortality of red king crab is critical. To help with this, both Alaska Boat Company and Trident have agreed to collaborate with the Bering Sea Fishery Research Foundation to conduct research on unobserved red king crab mortality regarding plagiac gear. As crabbers and pollock fishermen, neither of us can say that this unobserved mortality is meaningful or meaningless. We expect it isn't driving the bus with red king crab, as this fishery is experiencing recruitment failures.

But regardless, it's unknown and a high priority, and we intend to work together to understand it. Finally, as a crabber, we can't only point fingers at the trawl sector. We need to also ask the pot cod sector to improve as well as a directed crab fishery. As commercial fishermen, we are all in this together and should strive to always do better. And with that, I'll turn it over to Dan.

Uh, thanks, Edward. Madam Chair, members of the council, for the record, my name is Dan Martin. I'm the general manager of Alaska Boat Company. Alaska Boat Company manages 6 AFA pollock trawlers as well as 3 crab vessels that operate in the Bering Sea and Aleutian Islands. I would like to begin by stating that I do not I do not speak for the broader public sector.

I only speak for myself and the fleet that I manage. I believe the makeup of my fleet provides me with unique perspective and a deep understanding of the council's position with respect to this agenda item by having vessels in both sectors. There are valid points being made on both sides, as well as questions that deserve answers. As Edward has alluded to, Regardless of all the great research that is occurring right now, there are still going to be data gaps, not the least of which being the question of unobserved fishing mortality. I believe that all sectors are operating under assumptions related to UFM, and those assumptions lead to conclusions that aren't necessarily facts-based.

I sincerely appreciate the opportunity to collaborate on this project with Trident and DSFRF. Staff, both of whom have proven to be extremely innovative, innovative in their approaches to problem solving. The challenges will be considerable but not insurmountable, and regardless of the level of, of success we are able to achieve, as the old adage goes, you can't get to your destination without taking the first step. Thank you.

Thank you both for your testimony. Yes, Ms. Kimball. Thank you for your testimony. I didn't know if this is just your first step in determining that you're willing to work together or if you have a plan in place to either test gear similar to the EFP or something different with your fleet. Um, yeah, through the chair, Ms. Kimball, we, um, there's been a lot of talk over the years, there's been a lot of thought in terms of what different projects would look like.

I wouldn't say we have detailed plans figured out, but we have concepts figured out. We're discussing concepts. I think the key is we have the right people that are all trying to do the same thing, which is really understand what's going on here with the foundation and, you know, Trident and Alaska Oil Company. It's a, it's a good group that we can actually make a lot of progress.

And if I could just add to that a little bit, realizing that this is in its infancy, and right now it is, it is a glimmer of hope that we're going to be able to get some kind of result out of this, because like I, I said, this— the challenges are going to be significant, you know, as you've heard about sensors and all these limitations that we have. But believe that we have the right group in place, you know, and it's also in direct response to, the Unobserved Fishing Mortality workgroup and their final draft of their paper. So if you look at it, we have of the 4 objectives that were laid out where there's data gaps, you know, the first one being estimated bottom contact of all the gear, we think that, you know, through the GII work, that's being accomplished. Um, number 2 was the spatial and temporal distribution of crab, which we think is also being dealt with through the tagging studies done by BSFRF. Kind of putting number 1 and number 2 together then becomes like the area swept or the impacted area, which we think that the research done by Dr. Yoakam is really making advancements there.

So while we're gonna still need to be able to analyze total area swept,, but then maybe a diminished area swept based on that study. So the only leg of this table that's missing is the UFM portion, and I think that what we've endeavored to achieve anyway is, uh, to, to at least take that task head-on. And Miss Vanderhoeven, thank you, Madam Chair. Thank you. Both, um, for trying to find ways to work together and, and try to answer one of the questions that we still don't have answers to.

I, I guess because this council has expressed interest in this, um, my question is, like with the other research projects in this category, as your project develops, would you be willing to come back and provide periodic updates like the other research projects are doing.

Uh, through the chair, thank you for the question, Ms. Vanderhoeven. Um, I think that while Edward and I are basically sponsors and advocates, and, um, you know, I have a fleet of vessels that I can— at least, uh, we can utilize for some of these studies— I think that the updates would would most likely be coming from both Scott Goodman and Dr. Yokom. If there are, you know, if there are anything conclusive that would, that would actually be able to come out of this, which is our greatest hope. But if you're looking for updates along the way, that, that methodology or that structure hasn't been defined yet. And we're looking, uh, for direction from, uh, Dr. Harris, who will be— yeah, and I also want to say in this case, this is, um, a little different in that we have CRAB and public collaborating together to hold each other accountable.

And I think that that also does go a long way to try to make sure that, um, you know, updates or hard data doesn't need to be reported regularly to the council because we are trying to solve this ourselves. In a lot of ways, that takes some of the burden off of the council in terms of reporting to the council. We could provide some updates in terms of we're still working on this, it's going to take some time. We don't have a project that's like ready to go, we're going to start tomorrow. This is going to be something that's going to take some patience on behalf of, of Crabbers and the council to try to, you know, get this answered.

But, you know, some, some sort of updates and where we are is reasonable in terms of providing updates to the Council that, you know, these are the data. Probably I'm not sure that's a correct expectation.

Thank you. And Ms. Cohen. Thank you, Madam Chair, and thank you both for your testimony. This is really exciting to see collaboration between the two industries and appreciate that. Also appreciate that it's directly responsive to one of the Council's research priorities, one of our top research priorities, and Mr. Martin, as you mentioned, the Unobserved Fishing Mortality Work Group's concerns.

So thank you for being responsive to that. My question is, we heard that the crab industry is looking at pot gear on Unobserved Fishing Mortality. That research is going to start in the fall. Are you envisioning that you would kind of collaborate and coordinate there for like field work between the two gears, or is there any interaction and sharing of information that you envision there?

Through the chair, Ms. Scallon, are you referring to the ghost fishing studies that the foundation is doing? I think, yeah, that I think because that is really impacting our own directed fishery, obviously that's, we'd be collaborating with ourselves. I think with the podcod sector, I'd love to have them collaborating more, and I, both the over and under 64 foot sector. I think having more engagement in that, um, with that study would be helpful. To be honest, I probably need to understand exactly what kind of interaction has happened, but, but I think more, more collaboration is better.

Yeah, thank you for your testimony.

So our next testifier is Michelle Stren, followed by Ben Lee. Is Michelle online? Good afternoon, can you hear me? Yes, good afternoon.

Good afternoon, Chair and Council members. For the record, my name is Michelle Stratton, Executive Director of the Alaska Marine Community Coalition. Before I begin, I want to acknowledge the substantial work that has gone into both the fishing effects models and pelagic trawl gear innovation. The Council, NOAA, industry, researchers, and stakeholders have invested years in improving our understanding of habitat interactions, gear performance, monitoring technologies, and enforcement challenge. That work has been valuable.

It has improved the information available to the council, and it should continue. The core question before the council is straightforward: what measurable performance distinguishes pelagic trawl gear from non-pelagic trawl gear, bottom contact gear, and mobile bottom contact gear? AMCC is asking the council to initiate an analysis, or at minimum, a discussion paper exploring how to define, measure, and enforce the performance characteristics that differentiate pelagic trawl gear from non-pelagic trawl gear in the context of its interaction with the benthic habitat. Currently, pelagic trawl gear is treated differently because it is understood to operate differently. That distinction affects access to areas, management measures, habitat protections, enforcement, and public trust in the council process.

If that distinction matters for management, it should be measurable and enforced. Acceptable. We have heard that pelagic shell gear has always contacted the seafloor to some degree. We have also heard testimony that some degree of bottom contact is operationally important to the fisheries and in some cases that without bottom contact vessels might as well not go fishing. That raises an important management question.

If bottom contact is operationally necessary to successful fishing operations, then the Council should define what level of contact is acceptable and what that means for fishing area access. A performance standard is the exact tool that allows the Council to resolve these questions. Flagged trawl gear is not classified as mobile bottom contact gear, and that has real consequences. It provides for access to areas closed to mobile bottom contact gear, which has eroded the credibility of established habitat protections. The public needs confidence that gear distinctions and closure protections mean what they say and are managed intentionally.

In areas close to mobile bottom contact gear or non-flaggable gear, verified off-bottom operation should be the condition of access as that is consistent with the closure intent. Outside those areas, the council should determine an appropriate threshold and how to define, measure, and enforce it. The fishing effects model is useful, but it is important to understand what it does and does not tell us. The FE model evaluates broad-scale habitat risk across large areas and long time periods. It can estimate cumulative effects and relative habitat vulnerability, but it is not designed to assess how a specific fishing operation is functioning or under what standards.

It cannot tell us whether a vessel is operating off bottom, whether a performance threshold has been exceeded, or whether gear is operating consistent with the assumptions that justify pelagic management. A modeled finding of minimal and temporary effect is not the same as direct verification of gear performance or the existing of actual regulations. Those questions require a performance standard and monitoring framework, not a habitat model. I understand that monitoring technology has limitations. The answer to imperfect technology is not zero standards.

It is a phased standard with clear performance goals, monitoring requirements, implementation timelines, and a process for improving technology over time. The Council should not wait for technology to define the management objective. The Council should define the management objective and then evaluate the technologies necessary to verify AMCC is asking the council to initiate an analysis, or at minimum a discussion paper, exploring how to define, measure, and enforce the performance standards that evaluate bottom contact in areas closed to non-pelagic trawl or mobile bottom contact gear, a measurable threshold outside those areas, required monitoring technology and data standards, and consequences for gear that cannot meet those standards, including whether continued access to certain closures remains appropriate. A performance standard should serve as a destination, not the byproduct of innovation. The council should first define acceptable flagging trowel gear performance and then encourage innovation, monitoring technologies, and gear modifications to demonstrate and achieve that outcome.

Thank you.

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

Seeing none, thank you for joining us this afternoon.

So, Ben Lay is up next, followed by Curt Cochran. Hello, can you hear me? Yes, good afternoon. Okay, good afternoon. Thank you.

My name is Ben Lay. I own and operate a 50-foot/8-foot combination vessel out of King Cove in the western Gulf of Alaska. I want to start out by just saying I'm a full participant in the GII, you know, being a small trawl vessel. We—. I think it's important to remember that this project is encompassing all sizes and facets of the industry here.

And I kind of just want to take off from Alex Jackson's testimony there and not reiterate a lot of the same things, but maybe try to clarify on a few of the points that maybe he got asked. But First, I want to just— I think they were asked, uh, the difference from the, the mid-water trawl to the bottom trawl. You know, the, the two designs are vastly different, and, and specifically in the Western Gulf, you know, our bottom trawls are designed with rockhopper gear, three sets of chains through there, and it's stuff that wears out, and it's very evident of bottom contact all the time. And you— I mean, it's, it's, it's seen and it wears out. You know, the mid-water trawls uh, being only a chain on the foot rope, especially in the Western Gulf, they are not, um, they are not designed to be something that's going to spend a lot of time on, on the bottom.

They're just— that's just not the way they're built. I mean, Alex kind of explained how in the event of, of tearing up, how expensive that can be. And I guess I'd like to point out, you know, our fleet, that small Western Gulf 58-foot fleet A lot of these vessels only have one net, so it's not something you're, you're taking unnecessary risk with bottom contact on a regular basis and expecting to have longevity and, and, and be involved in these fisheries. I think that's important to note. I know there's the assumption that the Western Gulf, 100% of the tows see bottom contact, and that was kind of misrepresented assumption and I can tell you is 100% not true.

Um, you know, then I'd like to iterate there that we are combination boats, and I think hearing some testimonies here, it's refreshing to hear like, uh, different sectors, uh, willing to collaborate and work together and not point fingers. Because personally, I, I think it's exhausting here to, to see one sector, one gear type, you know, placing blame all around to others when when something's not working for them. But, um, you know, us being combination boats, uh, seining, pot fishing, longlining, um, I can tell you, and trolling, every single one of them there's incidental bottom contact unintended. And, and I can tell you across the board there, there's, there's mortality. So to, to, to throw one sector under the bus, um, not saying, you know, if, if the, the goal is to to, you know, bottom contact and, and habitat.

I just think it has to encompass a lot more, um, a lot more sectors at that point, um, I guess. And then would be happy to answer any questions.

Thank you very much for your testimony, Mr. Lay. See if there are any questions. Miss Kimball. Thank you, Mr. Lay. I mean, I appreciate people from the Western Gulf testifying today because we're not— we're getting more Bering Sea, I guess, input.

And I guess, was a lot of your testimony very similar to the previous testifier in trying to say that you are part of the Gear Innovation Project, you're putting your gear through that work to see what the real bottom contact score is, but you are very different, I guess, in habitat types in the Western Gulf in particular from the Bering Sea, different size vessels, different ability to carry more than one net. I'm wondering if you're asking to not be included in anything that goes forward, or if you're just trying to highlight the differences in the Gulf from the Bering Sea. Thank you, Ms. Kimball. Through the chair, I honestly, I'd probably say both. I mean, it's, it's, I'd like to highlight, and, and I'm not saying that because I'm afraid to pass the red face test and, and be innovative and, and do things to, to minimize bycatch, bottom contact, all that stuff.

As a, as a fisherman, you know, we have to be stewards of the sea, and I think, you know, across the board. Um, but I do see that when I'm hearing this, I'm, I get a little panicky in the fact that this is, this is, um, if we kind of get swept in here with a, um, you know, we are a trawler. I'm not going to say we're not a trawler, but we're not— where we— the design is generally the same, but we're vastly different, um, and, and operate in two different— two completely different areas. To where, um, yes, I guess short answer, yes to both. But I mean, it's not— it's not for the wrong reasons, I guess.

And, you know, so we are— we are part of the GII. And, um, and I've actually the, the Western Gulf seat. I, I represent the Western Gulf, so I'm in on all those meetings. And, and it's really encouraging. Like, I, I will say, like, it's for us, it's— there's so much of, of— we have a lot of sensors.

And I do know there's the, you know, like Alex uses a third wire, um, we do not. So there's a— there's one difference right in there on a 58-foot boat. And, and the majority of our fleet It doesn't. Now, there's, there's sensor manufacturers that love to sell us sensors, you know, when— and they're very expensive, but they would love to sell us sensors to put on the bottom of our net. I can tell you, they— all the sensors are great and, and they do help understand things, but they're not there as far as like bulletproof or, or accurate.

You know, we'll have a door sensor that will be, you know, a fairly expensive door sensor that will be flying mid-water door, and all of a sudden you're looking at that thing and it's giving you information that, you know, there's you assume there's no way that's true, like it's turned sideways, all this and that. But I just envisioned like, okay, now if this was a bottom contact sensor that is acting up and enforceable— not saying the technology might not be able to get there, but it's sure not there yet to where I'm like, man, right there. Like, and this happens on a daily basis, you know, um, you know, what, what happens in that, in that scenario. But the, the GII, I think, is, is— I'm just very excited to be a part of it because we're learning a and, and, uh, and being as proactive as we can be here, I guess. Thank you.

Thank you for your testimony, Mr. Lay. Thank you. So Kurt Cochran is up next, followed by Linda Banken.

So Kurt's not online. Okay, we'll circle back to Kurt.

So Linda Banken is up next.

Thank you, Madam Chair, members of the council. Linda Banken, testifying for Alaska Longline Fishermen's Association. We submitted lengthy comments on this issue that included retracing the history of this pelagic trawl gear definition stretching back to the '90s. I wasn't here for all of that, but I was here for most of it. It is interesting to hear the broad acknowledgement now of seafloor contact by pelagic gear and the surprise expressed by some trawl testifiers that the, that the public ever thought that pelagic trawl gear was pelagic.

Clearly our, uh, mistake. At least that narrative has run its course. We all now know that the foot chain of pelagic trawls at least are in contact with the seafloor across a broad area of the Gulf and Bering Sea, including in areas that were closed by this council or past councils to bottom trawling to protect habitat and bycatch of vulnerable species. From our perspective, that's a problem this council should address. The EA brought forward to this action acknowledges that the existing performance standard is ineffective.

Pelagic nets are designed with large mesh in front to allow crab to fall through with unknown mortality. That's also a problem. In the Gulf, the foot rope of a pelagic gear is defined to have no more than 10 50% seafloor contact, but that definition or performance standard is also ineffective. Again, that's a problem the Council should address. Finally, numerous, numerous regulations within Part 679 rely upon the pelagic and non-pelagic trawl definitions as a foundation for subsequent management measures, as the June 25th analysis says on page Page 31.

Several regulations involving area closures for the protection of seamounts and corals rely upon the mobile bottom contact gear and bottom contact gear definitions, which are in turn based upon the pelagic and non-pelagic gear definitions. That's a quote. Since the pelagic gear definition is ineffective, again, that seems like a problem the council should address. To recap, You have gear operating extensively on the seafloor that is defined as pelagic, known to have more than 10% seafloor contact in contradiction of your existing definitions. You have an ineffective performance standard for that gear that is the basis for closures to protect coral, which are the most productive and one of the most vulnerable habitats on the planet, and to protect crab or other Gulf and impairing sea habitat.

That's also a problem. To us, these identified deficiencies seem like a clear mandate for council action. We ask that the council initiate analysis of an enforceable performance standard to broadly limit seafloor contact by pelagic trawls and to prohibit all trawling in areas close to bottom trawling, or all contact with the seafloor, until vessel operators can document that their gear is contacting the seafloor. Because balls of crab and so much of the important benthic habitat that the north— in the North Pacific extends well over a few inches in height, we ask that the council also consider clearance or distance from the seafloor in creating alternatives and options for analysis. I want to speak for a minute as to why Alpha so strongly supports limiting sea to floor contact by pelagic trawls and to why the habitat disturbance results of the Fishing Effects Model did not alleviate our concern.

First, from the scientific literature, trawling is universally recognized the most impor— impactful form of widespread benthic disturbance throughout the world. And a NAS consensus study report by independent experts found that bottom trawling is the most widespread cause of reduced sea floor habitat complexity along the North American shelf. A paper presented to you in February 26th as part of the ecosystem report flagged the ongoing decline in coral and sponge habitat in the North Pacific, as well as the importance of that habitat to the crab and groundfish. As you have heard in previous testimony, trawling is responsible for over 97%— of the fisheries footprint off Alaska, and pelagic trawling for a significant component of that footprint. The impact on seafloor productivity and the fisheries that depend on that productivity should not be ignored, particularly in a time of rapidly changing climate and ecosystem stress.

Relative to the Fishing Effects Model, others have spoken to the limitations of that model and the fact that it's It's as good as the assumptions that are fed into it. Rather than recap those limitations, I will simply add our voice to that of the SSC and others in asking for another CIE review. In closing, you have a nonfunctional performance standard, a nonfunctional gear definition, and a trawl gear operating on the seafloor that has long been publicly presented, marketed, and managed as pelagic. Those are the problems we ask you to address. Again, we ask you to initiate analysis of a performance standard that broadly limits seafloor contact in the Gulf and Bering Sea by pelagic trawls and prevents contact by all trawls in areas close to bottom trawling.

Thank you. Happy to answer any questions.

Thank you for your testimony. See if there are any questions. Yes, Ms. Gone. Thank you, Madam Chair, and thank you, Ms. Behnken, for the testimony. Um, I heard in your last points there about limiting seafloor contact, but earlier in your testimony, you brought in the newer concept we've been hearing at this meeting about clearance.

Um, can you speak to whether you would expect to see something on clearance in the performance standard work? Yeah, thank you for that question., and for staying at the table. I can tell you're not feeling your best. Um, I, I would say that what we are seeing both in the fishing effects model and some of the work being done is a definition of contact that only looks at contact that's within a few inches of the seafloor. And since we know that there's a lot of things that live on the seafloor that are well over 2 inches in including sea whips, corals, sponges, even balls of crab.

King crab, I think, can probably be taller than that. Just that as you look at what constitutes impact and how we should manage for that impact, that you think about clearance off the seafloor of a bit more than the standard 2 to 2.5 inches that's currently included in the fishing effects model. Thank you.

Yes, Miss Kimball. Thank you for your testimony, um, Miss Banken. I, I just wanted to drill down a little bit more into the idea of, or the advocacy for, for 100% no bottom contact with pelagic gear in places where we prohibited non-pelagic gear, because all of the same literature that you're citing when I look at it, provides the background for why that was still allowed, understanding the complete differences in how that gear contacts the bottom and then any of the potential impacts. And so there's a record on understanding that the gear is different and still allowing not just pelagic gear but POC gear and longline gear that also contact the bottom in those areas. So we, given that we, we're starting to really understand how we might negate conservation benefits by raising it 100% off the bottom.

I just still want to hear why that is the important component of your advocacy. Yeah, thank you. Through the chair, thank you for that question. I think, um, a lot of the concern that we have and that you're hearing expressed has to do with the degree of impact that has been reported from trawling and the amount of footprint from that gear type that currently exists in the Gulf and Bering Sea, and recognizing that given that scope and magnitude, that it's really important to look at a range of alternatives that includes that 0%, and to have a clear estimate of what that impact is at anything over 0%. Thank you.

Thank you for your testimony.

So Doug Walls is up next, followed by Hannah Heimbook.

Doug, can you unmute yourself, please?

Can you press star 6, please?

Okay, we can see you online, but can't hear you yet.

Okay, I will circle back. After we hear from Hannah.

Hannah Heinbach.

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

Chair and members of the Council, for the record, my name is Hannah Heinbach, testifying on behalf of the Under 60 Cod Harvesters. I want to first acknowledge the substantial work that has gone into the Gear Innovation Initiative, the Fishing Effects Model, and related industry efforts. This work is highly valuable, and I sincerely hope that it continues with strong support and input from the council. I am concerned, though, that we are increasingly discussing modeling and management as interchangeable rather than complementary. In Dr. Harris's presentation, we heard the statement, simulations are now useful management tools.

Respectfully, no, they are not. They are immensely valuable assessment tools, but they are not a replacement for management. The question today is whether and how the Council will manage the mobile bottom contact of pelagic trawling, and we can't catalog or model our way to a management mechanism. We ask that the Council initiate a discussion paper on potential objectives, performance standards, and enforcement mechanisms for pelagic gear bottom contact. That work should be informed by and help to guide innovation and modeling with the goal of a successful fishery.

All of my group members and myself, as a fisherman and an Alaskan, want the pelagic trawl fishery to be successful. Addressing management gaps can and should be a functional part of that. The FE model can estimate broad potential outcomes and patterns. Flume testing can help us assess gear behavior. Gear cataloging can help us understand the variability and functionality that should be considered.

But none of those are management measures. They can't determine what level of bottom contact is acceptable or how compliance should be measured. If a model is the only target we provide to industry at this moment, we risk ending up with their with research innovations and reporting designed more to target favorable model outputs rather than verifiable performance around real guidelines. And the need for those guidelines is simple. If periodic bottom contact versus sustained bottom contact differentiates pelagic trawl from mobile bottom contact gear in terms of benthic interaction, that difference should be defined, monitored, and enforceable statewide.

And we are not in any way prescribing what exactly those regulations should be or how they should apply, suggest that they should exist. It has been made very clear that the Pelagic Trawl Fleet is asking us to understand and respect that they have always had, always intended to have, and absolutely need some degree of mobile bottom contact to be successful. That is heard, and I genuinely appreciate the candor. Well, we are simultaneously hearing that we can't or shouldn't set guidelines around that contact, and that is the contradiction the Council needs to sort out, because this fishery occurs a scale that requires unambiguous regulatory guidance. Off bottom, sometimes on bottom, always on bottom but not always impactful, whatever it is, it needs regulation that defines, monitors, and enforces.

And so we support a discussion paper exploring those management considerations. I'd also urge you to keep that a full North Pacific discussion. Operation designs may vary, but there are pollock fisheries in both the Gulf and BSAI, bottom trawl closures in both, including those currently under review, and many elements affecting fishing effort management tie them together. The coast-wide designations for black cod and halibut, for example. So this is a systems-wide question and a management fundamental and really needs to be holistic.

We also strongly support implementation pathways throughout and timelines that minimize negative impact to operators, in particular smaller trawl vessels that are more vulnerable when adapting to changing regulations I think this process should make sure that it's functional for, for those operators, and I think that's better achieved by beginning the process of management development in parallel to the innovations occurring in the industry. Next, I'd like to speak to how the COD group takes positions like this. Our members fish across the state through all seasons, so we communicate primarily by email. I send draft positions a few weeks before council meetings for consideration. The group established a position on a pelagic trawl performance standard for bottom contact contact 4 years ago, and we have commented consistently since.

I notified the group about the meeting and the position each time, but that position remains unchanged, and to date I haven't gotten any member feedback opposing exploration of an enforceable performance standard for bottom contact. I'm clarifying that because during my testimony to the Advisory Panel, I was asked whether my group unanimously supported the position I shared. That caught my interest because in the past few months Other active participants in this process have taken the time to call my members to say that I am misrepresenting them. That has not been limited to the COD group. Industry clients I work for outside of this process have received phone calls and clearly related online harassment questioning my professionalism and authenticity.

This experience is of course not unique to me. It's the kind of schoolyard politics that happens all the time within the Council process and I normally wouldn't even bother to mention it. But because I got that question as a part of my AP engagement this week, and because I believe it's directly related to these other patterns, I wanted to at least share the group's process for position-taking. Personally and professionally, I work very hard to follow ethical standards and especially to testify respectfully and constructively, and I want that intent to be clear to the Council. Beyond that, I truly believe the Council is committed to improving and increasing constructive public engagement, not mitigating public perception, which was a strong theme of opening reports and seemed aimed at minimizing public concern before the public had an opportunity to speak, whether that was intentional or not.

But when it becomes common practice, overtly or subtly, intentionally or not, to intimidate or undermine the credibility of the public, their representatives, or peers at the table because they disagree, that deters public engagement. It deters it by those experiencing it and to those who are just listening to it. I am not deterred by that, and the Council can't control all or maybe even much of it, but I think that we can all work to discourage it in all its forms. And lastly, just as individuals and communities, myself included, we are all works in progress. I offer these comments in the spirit of collective improvement, recognizing that we are navigating incredibly difficult topics.

Thank you very much.

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

Yes, Miss Cohen.

Um, I thank you, Madam Chair, and thank you, Miss Heimbach, for your testimony. Um, and I just want to appreciate that you brought forward these concerns, and I'm sorry to hear that happened, and just encourage us all to work to be respectful as we're working through these difficult situations.

Through the Chair, um, thank you, Miss Gowan. I, yeah, again, this is not special to me at all. It's not a unique experience, but I do think it's one worth us collectively working on as a group.

Thank you, Ms. Heimbach. I will follow up with you to better understand your concerns as well. Um, thanks for joining us.

So Patty O'Donnell is next, followed by Emily Scott.

Madam Chair, members of the council, good afternoon. My name is Paddy O'Donnell. I'm speaking today on behalf of Alaska Whitefish Trawlers Association. Alaska Whitefish Trawlers is a Kodiak-based trade association representing family-owned businesses that operate primarily in the Gulf of Alaska as well as the Bering Sea and West Coast groundfish fisheries. Uh, 37 out of the 39 vessels in the Gulf have participated in the gear cataloging with a total of 64 trawls, and the fishing practices profiles have been submitted by 38 out of 38 vessels.

I don't know why the numbers are off, but that's the information, the presentation. The Gulf of Alaska is very different from the Bering Sea, and our pelagic nets are not on the bottom up to 70% of the time. GII data will help inform that. The GOA continues to be involved in the GII projects and waiting for the results of that makes sense prior to setting any standards. We need science-based management when discussing bottom contact, and we need the Council to help educate the Board of Fish and the Joint Protocol Committee about ongoing work on this issue because there's a persistent mistaken impression that nothing has been done and that's simply not the case.

In the Gulf, we do not trawl on the bottom with pelagic trawl nets. The only bottom contact we may have is when one pays out too much wire and one is not paying attention, which in turn in most cases will end up with damage to the trawl, ending your trip and leading to costly repairs. Putting a mid-water trawl on the bottom with a light foot rope, you run the risk of encountering wrecks, derelict pots from the Tanner crab fishery, the pot cod fishery, as well as encounters with lost longline gear and doing damage and/or losing your net. The regulations state in the Gulf of Alaska, no person trawling in the GOA area limited to pelagic trawling under 679.22 may allow the foot rope of the trawl to be in contact with the seabed for more than 10% of the period of any tow. We fish steep edges and a canyon outside of town in Marmot and also off the shelf Gulf where it is steep.

On the bottom that is flat, we— if you do make bottom contact, you will most likely destroy your net. Also, the bottom is volcanic sand and very abrasive, which causes wear to mid-water trawls that are built very lightly in order for small horsepower vessels to tow such a net. We are allowed under the regulation in the Gulf to use non-pelagic trawl for pollock in areas that are open to non-pelagic trawl. However, 4— only 4% of the pollock caught is caught with this gear type, and that's on page 5 of the discussion paper. Under EM, we have all but one vessel in Kodiak participating.

The cameras are on 100% of the time when logged into EM. In the shellac off, in the event that you have bottom contact, you will encounter sea whips. This can be captured by those who review the EM video, so you will see them on the foot rope in the bosom of the net. Requiring additional electronics to monitor bottom contact for pelagic nets for the small vessels in the Gulf will be cost prohibitive. We are small family businesses with tight margins.

It is unreasonable to expect us to buy expensive electronics that at this point are really used for on an experimental basis. We cannot afford it. My vessel lost a net sonar last year, and to date I've not been able to replace it at the cost of $35,000.

You've seen in the Trident presentation the acoustic dead zone beneath the foot rope of the trawl. There's something we've been dealing with for many years. We've learned that when you blend the echo from the foot rope with the echo from the bottom, you are still 1 to 2 fathoms off, off the bottom. Also noting in the Trident EFP slide 18, I don't know any CVs that use bottom trawl doors in the Gulf. To the best of my knowledge, most vessels use pelagic doors.

There's also a lot of assumptions as to how the trawl fleet operate, the pelagic trawl in the Gulf. It is assumed that we operate the same as the Bering Sea, and that's not the case. I will state again that the Gulf of Alaska is very different from the Bering Sea, and that needs to be recognized in any regulations that are proposed and developed on this issue. And I'd just like to say one thing: I'd love to read the text to see if they understand my language or accent, because because when I try to use the voice app in my truck, it just doesn't happen. Thanks.

Thank you, Patty. It is catching it surprisingly well. So I have— I've seen some interesting spellings for sure of the transcript. I'll see if there are any questions for you. Yes, Mr. Ricci.

Thank you, Madam Chair. Thank you, Patty. I guess just in regards to you Stating that there's differences in operations between the Bering Sea and the Gulf of Alaska, I think we heard in the EFP presentation from Dr. Joachim that they were using a 2-inch chain, which I would call a half-inch chain, the 2 inches across, but that seems like a big chain to me, but maybe that's on a different size vessel than we usually see around Kodiak or in the Gulf, and I'm wondering what's a standard size chain that you, you would see. I think that might kind of demonstrate the difference.

That's true. The chair— Mr. Ritchie, I believe the chain I have on my net is also half inch, and it's half inch diameter, the thickness of the chain. And I don't know what the length is, but probably 2, 2.5 inches in length, something like that, or, or from link to link, 2 inches. But, uh, what I found out with Pelagic Gear— and I have a lot of 3/8 chain, if you ever need 3/8 chain, I a lot of it. It's too light when you're using a pelagic trawl, and, and we ended up having it roll around the meshes because it was a smaller diameter, diameter, and it's substantially lighter weight-wise from a, from a half-inch chain.

So possibly the 58-foot vessels in the Western Gulf may be using a 3/8 chain or even maybe 5/16 because again they're smaller vessels and smaller horsepower vessels. But, uh, I, I think when I was referring to the difference, uh, it's more to do with the bottom structure and, and the shelf. We fish a lot off the shelf, off the continental shelf. We fish outside of town, area 630, in, in a gully, in a canyon basically, and, and steep sides on it. And, and the only flat bottom we have is over on the Shalagoff.

But then again, depending on where the pollock aggregate, you may— we also have a steep bank over there next to mainland, you may be up against that bank. So the bottom changes and it's just something we don't practice putting gear on the bottom. And I will tell you, I did have one of my vessel captains a few years ago out in Area 610, touched the bottom and left exactly 40% of the net on the bottom. It's still out there, and it was a $45,000 repair, plus he had to go to Dutch and borrow a net off of a different boat. So it's not something we intentionally do or practice.

Thank you for your testimony.

Emily Scott is up next, followed by Loretta Brown.

Good afternoon, Madam Chair and members of the council. Thanks for bearing with us. You're almost there. My name is Emily Scott. I live in Sitka, where I've been fortunate enough to build a life rooted in the traditional ways of life of Southeast Alaska.

I started fishing as a deckhand on a salmon troller— with an O, um, and since then I've been immediately hooked and have become engaged in fisheries policy recently to better understand the challenges and risks facing my community and our fisheries that we depend on. Across Alaska, commercial fishermen have accepted or even proposed restrictions, closures, monitoring requirements, and other conservation measures when concerns arise about habitat impacts, bycatch, and stock health. Yet pelagic trawl gear continues to receive different management treatment based on the assumption that it operates off the bottom, despite evidence that significant bottom contact is occurring. If a fishery receives special access exemptions or management treatment, be— because it is expected to operate differently, that difference should be measurable, enforceable, and verifiable. As you consider this action, I urge you to ensure that seafloor contact by pelagic trawls is limited to incidental, that reliable monitoring tools are implemented to verify compliance, and that pelagic trawl gear is prohibited from areas closed to bottom trawling unless those operators can demonstrate that their gear is not contacting the seafloor.

Living and fishing in Sitka, I have seen firsthand how habitat protections can work The Southeast Alaska trawl closure is a successful example of proactive conservation that has delivered long-term ecological and economic benefits to fishermen and coastal communities alike. It demonstrates that protecting habitat and supporting sustainable fisheries are not competing goals. They go hand in hand. The same precautionary approach is needed in the Gulf of Alaska and Bering Sea particularly in areas closed to bottom trawling to protect crab-sensitive habitat and other important ecosystem values. If these protections are important enough to restrict one gear type, they should not be weakened by allowing another gear type to make bottom contact with trawl gear in those same areas.

Finally, this issue extends beyond any single fleet. The strength of Alaska seafood depends on public confidence and the integrity of our fisheries management system. Most consumers do not distinguish between gear groups or fisheries the way industry participants and managers do. When concerns arise about habitat impacts, bycatch, or accountability in one sector, they can affect perceptions of Alaska seafood as a whole. Alaska fishermen have spent generations building a reputation for responsible harvest, strong stewardship, and science-based management.

Maintaining that reputation requires transparent standards, credible monitoring, and a commitment to ensuring that all fisheries are held to the same expectations for conservation and accountability. Thank you for your time.

Thank you very much for your testimony. Yes, Ms. Kimball. Thank you for your testimony. I, I was caught by the, by the comment on on special treatment, and I just want to understand kind of what your understanding is of how other gear types are treated. This fleet in particular has more monitoring requirements, observers, cameras, closed areas, PSC limits than any other fishery.

So I guess I'm trying to reconcile that with your statements. We have so many other fleets that, especially the fixed-gear fleets that are nowhere near the level of these requirements and still have significant impacts in, like, discards. So is there something I'm missing about that different treatment?

Through the chair, thanks, Ms. Kimball, for the question. I think I'd like to just focus it back on what we're talking about here. So I think specifically I'm speaking to the differences between bottom trawl and pelagic trawl throughout this past week. I have heard that the, the gear fishes very differently, but what I'm hearing that feels new information to me is that we're confirming that these pelagic trawls are significantly operating on the bottom, and it seems in many fisheries is necessary to be making that significant bottom contact. So specifically to the action at hand, thinking about those areas that have been closed to protect sensitive seafloor habitat and other ecosystem values.

I think it's really imperative we look at that right now.

Thank you.

Thank you for your testimony.

So Loretta Brown is up next, followed by Chris Cooper, and then I'll circle back to Jeff Crane, Curt Cochran, and Doug Wells.

Hello, this is Loretta Brown. Can you hear me okay? Yes, we can. Good afternoon. Excellent.

Thank you for the opportunity to comment. So for the record, my name is Loretta Brown and I am testifying this afternoon on behalf of Salmon State. Salmon State is an Alaska-based conservation effort with staff living throughout Alaska communities. We work alongside Alaska Native groups, commercial fishing entities, and recreational fish groups keep Alaska a place where wild salmon and the people who depend on them thrive. Madam Chair and members of the council, Salmon State submitted written comments on this agenda item, and in addition to the issues raised in that letter regarding the need for an update to the performance standard for pelagic trawl gear and it's— and it— and the fact that it is inappropriate for the updates such as you got in the last 2 days regarding the fishing effects model and results of gear changes skip SSC review at this stage.

I also want to echo requests for an independent CIE review of the fishing effects model and the fishing effects evaluation process. This was requested by the SSC after the first iteration of the FE model in 2018 and then again in 2022 and is now well overdue. You are charged with the management and protection of a public resource. Section 2 of MSA states, one of the greatest long-term threats to the viability of commercial and recreational fisheries is a continued loss of marine, estuarine, and other aquatic habitats. Habitat considerations should receive increased attention for the conservation and management of fishery resources of the United States.

Our Bering Sea and the Gulf of Alaska ecosystems are in crisis. Benthic habitat and organisms are the foundation of the food web for ocean ecosystems and support ocean, anadromous, and eventually terrestrial Fish and Wildlife. We are lucky enough in Alaska to have time and opportunity to respond to and manage some of what is impacting our ecosystems, including our federally managed fisheries. A meaningful and enforceable performance standard for pelagic trawl gear can help support the resiliency and aid in the recovery of these ecosystems by protecting that foundational habitat and organisms for all life in Alaska. In 1978, after MSA was first passed and the Council and the EEZ were established, the Council and NMFS differentiated pelagic and non-pelagic trawling, defining pelagic trawl as a trawl in which neither the net nor the otter boards operate in contact with the bottom.

This prohibition, oh, and prohibited non-pelagic trawl for a portion of the year. By 1990, the Council and NMFS were so concerned with the bycatch of benthic species by trawlers targeting pollock that they promulgated an emergency definition of pelagic trawl gear, which explicitly stated that that gear should not operate in contact with the seabed. In 1993, the Council on Nymphs had to further alter that definition in response to trawlers modifying gear to look pelagic to be able to fish inside areas closed to non-pelagic trawling. It is important that this Council intent of disallowing trawling on the bottom with pelagic gear is not lost now. The Council originally imposed a performance standard for pelagic trawl gear in 1993 also, and that was to prevent and discourage pelagic trawl gear from trawling on the seafloor.

Over the past 30 years, this performance standard has been cumbersome for enforcement, and now as we have completed the exercise of updating the pelagic gear parameters through gear definition revisions in the last 2 years, it is time to also update performance standard? Well, the performance standard was set 30 years ago using the best available information at the time. Since that time, the pollock fishery has advanced in gear modifications, increased efficiency, safety, and technology used on every tow. These advancements in technology, scientific information, and testimony by pelagic trawl fishers indicate that pelagic gear is operating on the seafloor against Council intent.

To borrow from one of your presenters yesterday, how the gear is fished is just as important as the gear is, as what the gear is. Management decisions by the Council and NMFS depend on the distinction between pelagic and non-pelagic trawl gear and how it is fished. For example, in the BSAI under Amendment 57 in 2000, the Council prohibited targeting pollock by non-pelagic trawl gear. Here the Council indicated that the performance Here, the council included a performance standard in order to prevent fishermen from using pelagic gear to trawl on the bottom. An update to the performance standard is not dependent on the results of the GII or other gear modifications.

A performance standard signals to the fleet and to the public what the expectations are of the council and NMFS regarding the behavior and operation of this gear, and in furtherance of the underlying intent of the council model when it distinguishes pelagic and non-pelagic trawl gear in the 1970s. The changes to the fishing effects model and gear can continue while the Council proceeds to determine that, if any, what, if any, is the acceptable interaction of pelagic trawl gear with the seafloor. The Council has the opportunity here to update the performance standard to provide enforceable and clear measures that incentivize the pollock fleet to fish off the seafloor, especially in areas that are closed to protect habitat and benthic species. If the Council does not update the performance standard, then the gear should be managed as it is fished, which is mobile bottom contact gear.

And I just wanted to also point out there are two things that I think were not, have not been mentioned yet in testimony or during, or during presentations. One is that there's been a main focus on EFH in the discussions over the last several days, and EFH does not encompass all of the habitat of the Bering Sea and the Gulf of Alaska, only the habitat that is important to fish resources managed by this body. The ecosystem encompasses much more habitat than that. And so I think that habitat impacts are— it is important to also include habitat impacts across the whole of the ecosystem and not just EFH. And secondly, Amendment 114 and 126 which is the amendments that opted-in program for electronic monitoring for catchable vessels, included an exemption for CVs, an exemption for CVs that opt into pelagic gear performance standard, from the pelagic gear performance standard.

As you heard from the B reports and also in testifiers earlier, only 2 vessels did not opt into the EM program in the Gulf of Alaska. That means that 2 vessels are exempt, all but 2 vessels are exempt for the performance standard, or 95% of the pollock fleet is exempt. This means that almost the whole of the Gulf of Alaska— Ms. Brown, your timer has expired. If you have a concluding statement, please go ahead. Thanks.

Sure. This means that the whole of the, almost the whole of the Gulf of Alaska is effectively has no performance standard for pelagic trawl gear at this time. That'll be my conclusion. Thank you. Thank you for your testimony.

Not seeing any questions. Thank you.

Chris Cooper is up next, followed by John. Can you hear me? Yes. Good afternoon, Madam Chair and members of the council. For the record, my name is Chris Cooper.

I'm the owner owner and operator of the fishing vessel Predator, a 90-foot inshore catcher vessel. My family owns two vessels that participate in the Bering Sea and the GOA pollock fisheries. I'm a fourth-generation fisherman and have operated my family's vessels in the Bering Sea for the past 23 years. I'd like to express my support for the AP's motion and to support the ongoing work being done by Dr. Harris. I also like to acknowledge the gear modification efforts by Trident Seafoods and Dr. Yokom, and I also appreciate the ongoing research by the crab industry to better understand crab distribution.

I really find it amusing that many people not in the industry with zero experience with acoustic sensors have such faith in enforcing bottom contact by these sensors. While this could be a useful tool for an operator to adjust their gear performance, it is not sufficient to be used as enforcement. Bottom line is the signal from a sensor isn't guaranteed.

Things that happen interrupt that signal— weather and other factors. The signal from a sensor to the vessel might be lost for long periods of time during fishing operations. It is not just the configuration of sensors or applying them to the fishing gear that don't work. It's the issue of acoustic signal making it from the bottom of the net to the vessel in a consistent manner deemed accessible for enforcement. I would also like to repeat Dr. Harris's comment that contact does not equal impact.

Let's, let's be clear about one other thing here too. There is no evidence supporting that the pollock fleet is having the impact that it's accused of on crab stocks.

As I sit here composing these comments today, I couldn't help but think about last year in Newport when we had the gear display and the industry put together for the council down at the port docks. As I spent a few hours there explaining to many of you the difference parts of midwater gear and the differences between bottom gear. My biggest takeaway from that was the surprise that many people had at the size of the material in these nets. They're just way smaller than, than what they imagined. I actually got a comment from one of the ladies that the ground line they use for longlining is larger than most of the material in these midwater nets.

Freshwater nets. While they look, may look like huge piles and big line and rope on the dock or on the reel, the individual components are just not built to have or withstand constant contact with the seafloor.

A single silted-in crab or cod pot on the bottom has capabilities of causing mass destruction to these nets and resulting in tens of thousands of dollars of repairs. So I just want to really, really hammer down and differentiate the difference between the gear, between mid-water pelagic nets and bottom nets, and the impacts and the differentials of the impacts that they have on the seafloor. With that, I see I'm out of time here. Thank you for the opportunity to offer input. I'm happy to answer any questions.

Thank you. Thank you very much for your testimony. See if there's any— are there any questions? Seeing none, thank you for joining us. Thank you.

Jeff Crane is up next, followed by Kurt Cochran.

Okay, Jeff's not on. That was our last call. Curt Cochran, and then Doug Wells will be our last testifier. Okay, Curt, um, you got me? Yes, Madam Chair, members of the council, I'm Curt Cochran.

Our family operate trawlers in the Gulf of Alaska. I would ask you to support the AP motion as presented. Don't stop or change the direction of the research that's going on by all the groups. Listening to the conversation today, the questions are changing. Started out as what's the bottom contact or disturbance of a, of a pelagic trawl.

Now we're talking about unforeseen crab mortality. The Observer data shows the pollock fleet doesn't catch many crabs. 2013-2022 Average of 13 animals. But, um, fishery in that time is 111,000 animals plus. Longline is 7,000 animals plus.

That is the science, so that's what we have. Last year in Newport, you got a look at the pelagic trawl, how fragile they are. If we were hard on the bottom, the nets would not last the season. The cooperation between the public fleet and the crab fleet. And the dynamic closures is a great step to reduce interactions.

As we heard today, or no, we've had presentations, the research by Dr. King that shows the nets we use today are not hard on the bottom. Most of the time they're off, even when guys think they're on. The work by Trident and Dr. Yokom that is changing the plastic trawl foot rope in a relationship to the bottom is huge. And we also know that, um, on bottom trawl sweeps, the 2.5-inch gap— and you heard Mr.— our Dr. Craig Rose today— is enough for sea whips and other benthic bottom creatures to be unharmed by the trawl and the crabs. I'm saying this to point out that the unforeseen crab mortality is a good good question, but it's not an emergency to put it ahead of the research that is going on right now.

Let the research happen and don't drive the outcome. Um, the dead zone you keep hearing about, uh, is there on the— on our net sounders and different things. It just makes the net look like on the bottom when it's not. Um, I can talk to that if people are curious. My question is, what little bottom disturbance there is of the Platschig Trawls and the fleet, is it any more than a winter storm?

I think if you look at that compared to the rest of the world and how it operates, the Bering Sea or Alaska is so far below that we're really chasing something here. The other point, I guess, is You know, we're multi-generation families. We are the stewards of that ocean. As our family business, as generations, just like you hear from other groups, we do take care of it, take and responsible for it.

Public and being transparent, I understand that, but you're talking to a man that doesn't do— oh boy, that went quick— doesn't do Facebook. I want to point out the last thing is The testimony from Oceana Day is not truthful. The slide with Milton Island is me where I fish. Those are my lines. The bottom is 300 to 800 fathoms in that area.

I can't even get my trawl down to those type of depths, and yet they're saying I'm using a plastic net on the bottom out there. Things need to be truthful. Thank you. Thank you for your testimony. Oh, and you can't talk on on YouTube.

Sorry, that's why you didn't get me.

Okay, thank you.

Got it. Okay, um, are there any questions?

Okay, seeing none, thank you for your Doug Wells will be our last testifier.

How about now? Can you hear me? Yes, good afternoon. Hallelujah. I don't know what that was about.

Yeah, thanks, Madam Chair, council members. My name is Doug Wells. I'm speaking for the CP Baronoff from Onza Fishing Company. I also sit on the board of the Bering Sea Fisheries Research Foundation. The collaborative efforts of the crab industry, the BSRF, and the pollock harvesting industry in the 2026A season was a great success.

We much appreciate the pollock industry's efforts to limit its fishing inside the Red King crab savings area, and I look forward to continuing this effort and fine-tuning preferred areas of concern using information provided by the collaborative movement research being conducted by the Foundation, the Department of Fish and Game, and the Fishery Service in the tagging of red king crab and the follow-on work of Shawn Hardison. Moving forward in this work to better understand trawl impacts on red king crab and other Bering Sea crab species. The questions before the council are: what is the nature and magnitude of the bottom contact? What's the nature and magnitude of the unobserved fishing mortality on Bering Sea crab stocks? And what is an appropriate performance standard for trawl gear in the Bering Sea pollock fishery?

As the Gear Innovation Initiative— and the excellent work Trident is doing on trawl modification move towards completion, a possible appropriate midterm approach for the council is a discussion paper, I guess, examining C4 impacts, attainable performance standards, and bottom contact thresholds for pollock gear. In the Bering Sea. It's important that this effort also begin to study unobserved fishing mortality associated with pollock trawling. This will depend on understanding the nature and magnitude of bottom contact of the pollock trawl gear and the overlap with red king crab stock.

This, I assume will depend on some form of combination of bottom sensors, cameras, and perhaps underbag, another updated underbag study. The paper should pay particular attention to the critical need to protect red king crab in the molting and mating seasons. The crab when crab obviously are particularly vulnerable to any interaction with fishing gear. Thanks for hearing my testimony and also for keeping this important work moving forward. Thank you.

Thank you very much for your testimony, Mr. Wells. See if there are any questions. Okay, seeing none, that's our last testifier of the, of the day, and that completes our Um, testimony on D1. Let's, uh, stand down for about 45 minutes. We'll aim to come back at 4:15 to see if the council wishes to choose action, um, or take action.

We will, um, yeah, just, uh, keep an eye on the, um, the YouTube screen to see whether or not we need additional time. That was a message for Kurt in particular. So since we know he knows how to use YouTube now, so we will see you back here at 4:15. Thanks.

Regulatory measures and intends to work with the public industry on adaptive approaches that focus on reducing uncertainty as well as incentivizing gear modifications. The council requests a discussion paper identifying options for viable and enforceable mechanisms to reduce bottom contact. Building on the June 2025 discussion paper by identifying areas that are currently closed to vessels using non-pelagic trawl gear and open to vessels using pelagic trawl gear, summarizing pelagic trawl effort in those areas during the most recent 10 years, and characterizing baseline bottom contact using the best available information. To form the basis for regulatory alternatives, the paper should address ways to operationalize and implement in regulation reduced bottom contact in specific management areas, such as whether a maximum bottom contact rate based on best available information is feasible to regulate at a vessel, sector, or Bering Sea Cooperative level, the feasibility of implementing a swept area cap at a vessel, sector, or Bering Sea Cooperative level, and/or verifiable pelagic trawl gear modifications or operational standards. The paper should discuss each identified mechanism above for reducing pelagic trawl bottom contact relative to its effects on the amount of bottom contact, CPUE, fishing time, effort displacement, and total impact per unit of target catch.

Further, the paper should consider and describe any potential tradeoffs that may result in changes in PSE associated with reduced bottom contact measures. The Council reaffirms its June 2025 motion that the Fishing Effects Model be updated with refined bottom contact estimates as a baseline from which to improve. The Fishing Effects Model is the peer-reviewed best available tool to assess the effects of fishing on benthic habitats in Alaska, and the most recent review concluded that the adverse effects, effects of fishing activity on EFH are no more than minimal or temporary. The Council recognizes the fishing effects model is a habitat effects tool and does not by itself estimate unobserved crab mortality from fishing. The Council also endorses the continued work and completion of the gear innovation work, relevant ongoing EFPs, and BSFRF crab habitat and species distribution research.

For the second, I'll speak to the motion, Madam Chair.

Thank you for the second, Mr. Kerland. Ms. Baker. Thank you, Madam Chair. Thank you, Mr. Kerland, for the motion. And, and just walking through the components of this motion, uh, initially I am requesting, uh, preparation of a discussion paper from staff, uh, the— I'm requesting that the discussion paper include, uh, both the Gulf of Alaska and the Bering Sea.

And I just want to speak to that here at the beginning because we heard a fair bit of testimony about that. I fully acknowledge that public comment and our general knowledge about the differences between the Gulf of Alaska and Bering Sea related to the seafloor features, the vessels involved, size, things like that. But I note that I'm very pleased that Gulf of Alaska pelagic trawl vessels are participating in the Gear Innovation Initiative project at this stage, and I think that's really good, and I think it makes sense to include the Gulf of Alaska at this stage in this discussion paper, but just really want to acknowledge that I understand the differences between the Gulf of Alaska and the Bering Sea and appreciate that testimony. I want to highlight that I am suggesting we move forward in this manner with a focus on protection of red king crab. I acknowledge, again, significant testimony we received expressing concerns about habitat protection, and I think given the ongoing essential fish habitat review process and our continuing concerns about red king crab stocks in the Bering Sea particularly, I'm electing to suggest we focus this discussion paper on addressing addressing the uncertainty related to unobserved mortality.

Again, some of which, some of those, the red king or the red king crab stocks in the Bering Sea are among historically low levels. I again recognize concerns about pelagic, potential pelagic trawl gear impacts on benthic habitat, but given the in-depth evaluation of the effects of our fisheries on essential fish habitat that we are currently undertaking as required by law, I'm suggesting that we move ahead at this time with a focus on addressing and trying to address the uncertainty of unobserved mortality of crab due to interactions with pelagic trawl fisheries. And finally, just wanted to highlight it at a high level that I'm suggesting that we start focusing on areas in the Bering Sea and the Gulf of Alaska that are closed to non-pelagic trawl gear and open to pelagic trawl gear. This is consistent consistent with a lot of the testimony that we heard for this agenda item and have been hearing along. I think it makes a lot of sense.

The areas were closed to non-pelagic trawling due to certain concerns at the time. I would envision, you know, when the discussion paper comes back, just, it seems like a simple request, but at least we will have in front of us all the areas that we're talking about here in both FMP, the Bering Sea, and the Gulf of Alaska. Which areas are we talking about that are closed to non-pelagic trawl gear but open to pelagic trawl gear? And I think that will be really helpful to focus the discussion.

The motion notes that really the rationale for moving forward again with this action is, is just really acknowledgement that it's important for the Council to follow through. On its commitment to continually improve our management. We have really good support and cooperation with our fishing industry on that, and, and I think this is another step in following through on that commitment, and, and also again aiming to reduce pelagic trawl fishery impacts on crab stocks and particularly the uncertainty related to unobserved crab mortality. Uh, the motion identifies 3 potential options, uh, sort of at this stage, uh, to operationalize and implement in regulation reduced bottom contact by pelagic trawl gear. The first option would consider the feasibility of a maximum, maximum bottom contact rate for pelagic trawl gear that potentially could be applied at a vessel sector or in the Bering Sea at a cooperative level.

And, and just a little note, I, I came into this meeting perhaps thinking that for this particular option, perhaps we would be able to use the bottom contact adjustment score used as an input to the fishing effects model. And just based on conversations here and, and the presentation we had yesterday, I'm, I'm beginning to understand that that bottom contact adjustment score is really used as an input to that fishing effects model. And is likely not an appropriate performance metric for fishing. And so I have suggest we make that first bullet more general in terms of the metric, perhaps something model-based related to a maximum bottom contact rate based on the best available information.

The second option would consider the feasibility of a cap on swept area by pelagic trawl gear, again, in areas closed to non-pelagic trawl gear. And, and as a reminder, swept area is the product of the gear width multiplied by fishing track's length, I think, as determined using VMS. It's, it's basically the maximum area over which gear and seafloor interactions may occur. And so we have looked at that information, I think, as produced by the Fishing Effects Model, not just for EFH reviews in the in the past, but for specific council analyses. So it is a metric that we have looked at before, and I think it might be worth considering the feasibility of using that, establishing a, a maximum area swept, perhaps again applied at a vessel, sector, or cooperative level in the Bering Sea.

The third option just really acknowledges that gear modifications may be a fruitful approach to reducing bottom contact, and we heard about a really exciting example yesterday in, in Trident's report on its ongoing EFP for a modified foot rope, with full acknowledgment in that presentation that might not be widely applicable. So, but it is an option here because I think it's, it's a really valid one to consider.

Finally, just moving on, trying to be relatively concise here, Madam Chair. I think, oh, there are some additional requests in addition to asking for a discussion and, and sort of looking at the feasibility of a few of these options, uh, to, to ask the analyst to include some additional information that, that a lot of this came through public testimony, that if we indeed are going to be looking at, at some sort of performance standard for bottom contact, that it would be important to understand, um, at a high level, because this is a discussion paper, you know, potential impacts on CPUE and fishing time, effort displacement, things like that.

And then a couple final things, Madam Chair, before questions. Uh, just wanted to again reiterate that I'm suggesting we focus this discussion paper, uh, on addressing uncertainty related to unobserved crab mortality rather than including concerns about impacts of pelagic trawl gear on habitat. So we— I really just wanted to reiterate that the fishing effects model is the best available tool to assess the effects of our fisheries on benthic habitats in Alaska, and that that review is ongoing. I wanted to speak to the AP recommendation and just note, I— there might be questions about this, but I really appreciate and acknowledge that the AP recommend recommendation was not to take this step, step to request a discussion paper, um, and that the members supporting that AP motion really did not feel this was the appropriate time to consider modifications to the performance standard. Um, I, I really understand that and note, um, that I have a slightly different perspective in that I, I do think this is the right time to request this information, uh, for the council and public, again, to understand the areas we would be looking at, closed to non-pelagic trawl gear, open to pelagic trawl gear, what options we have to operationalize and implement reduced bottom contact.

I think there's a lot to think about and understand there. And again, in requesting this discussion paper, my thinking is, is that the council can start to think about these options While the bottom contact adjustments for pelagic trawl gear are updated and presented, our expectation is those will be presented to the SSC along with other essential fish habitat review information in February 2027. And those new bottom contact adjustments will really provide the Council with the updated baseline and help us determine how much more improvement should be made from the status quo. And then finally, Madam Chair, I just really wanted to be clear in the motion and highlight the Council's continued endorsement of an appreciation for the, the work on the Gear Innovation Initiative project, the ongoing EFPs that we've discussed, and really the BSFRF crab habitat and species distribution research we heard about yesterday. And with that, Madam Chair, I'd be happy to answer questions.

Thank you for the motion and the rationale, Miss Baker. I'll see if there are any questions. Yes, Mr. Ritchie. Thank you, Madam Chair, and thank you, Miss Baker, for the motion and for the rationale. It's always easy to follow your rationale.

Um, my question is in regards to the first sentence in the motion there, and just as Is the intent to include state waters where non-pelagic trawling is closed but there's parallel fisheries for pelagic pollock fishing? Is that— is the intent to include that in it, or is it to focus on areas more like the Red King Crab Savings Area? I'm just looking for some clarification.

Through the Chair, thank you, Mr. Ritchie. My intention is for this discussion paper to cover areas closed to non-pelagic trawl gear, but open areas closed to non-pelagic trawl gear by this council, if that helps. That's very helpful. Thank you.

Yes, Ms. Kimball. Thank you, Ms. Baker, for the motion. I was also on the first sentence. I heard your rationale about including the Gulf of Alaska.

I think that's solid rationale at this point. I can't argue with that, but, but there are such significant differences. I, I wondered if in getting this paper back, that still leaves open the door for either addressing the Gulf of Alaska on a different timeline or using different potential regulations than you've listed here, some of which would only maybe be applicable at a— in a fishery that has a co-op. I'm just wondering if it leaves the door open for treatment differently in the Gulf of Alaska the next time we see the information come back.

Through the chair, thank you, Ms. Kimball. Yes, that is my intention, and, and again, very appreciative of the testimony that we've received, uh, we received today and, and throughout this process. And I think the, the GEAR Innovation Initiative in and of itself will remind us the differences between the Gulf Fleet and the Bering Sea Fleet. So yes, it keeps that door open in my view.

Yes, Ms. Kimball. My second question is on the second paragraph. Very clearly have stated your focus on unobserved crab mortality, a focus on reducing uncertainty there, and something that we should try to address. In the second paragraph, You are including all areas that are currently closed to non-pelagic trawl gear and open to vessels using pelagic trawl gear, so that is not just focused on crab. I wanted to make sure I understood that there may be other areas closed to non-pelagic trawl gear for other reasons, and so my assumption is this paper will just kind of give us the catalog of those, and we would understand the reasons for those closures and what the history is behind those and make a determination whether it fits your overall purpose.

But if that's not how that's intended, please correct me.

Through the chair, thank you, Ms. Kimball. That is my intention. I realized as I was thinking through for myself what areas were we talking about here, both in the Bering Sea and the Gulf, and some of these closures have been around for quite some time and off the top of my head, I don't know what the original objectives were for the closure or were the original reasons. And so yes, I think that's why I felt like it would be a really useful exercise to ask staff to bring a list back of all of the areas in the Gulf of Alaska and Bering Sea that are closed to non-pelagic trawl gear and open to pelagic trawl, along with the reasons for those closures. And yes, then it— at that point, the council could evaluate if what areas best met its objectives for this action, which I'm proposing at this stage, are really to focus on reducing uncertainty related to unobserved crab mortality.

And so my guess is not all of the areas that will be brought back will necessarily be relevant to the objective that I'm proposing for this discussion paper here. Thank you. And Ms. Vanderhoeven. Thank you, Madam Chair. Thank you, Ms. Baker, for your motion.

Um, maybe I— maybe it's late in the day, but maybe I have a just kind of a fundamental misunderstanding.

Um, I, I thought we didn't have a baseline for unobserved mortality, and that's why the stock assessment models considered it in natural mortality. And so when I read this, it looks to me like we're inferring that bottom contact implies some connectivity to unobserved mortality. And I'm thinking about the caution we got from Dr. Harris that contact doesn't necessarily mean impact, and to further extend that to something that we already can't quantify. And so I'm, I'm not I'm not quite following what the linkage is there to then think about how this discussion paper might help us determine acceptable levels of impact or unobserved mortality, and by extension then how we would think about developing performance metrics if we were to develop a package further. And so I'm just kind of stuck at that first step, if you can help me there first.

Through the chair, thank you, Ms. Vanderhoeven, for the question. And yes, I see your point. Um, when I was referencing a baseline, I was referring to the bottom contact adjustment scores and not to unobserved mortality— unobserved mortality of crabs with pelagic trawl gear. So I fully acknowledge and agree with the statement you referenced that bottom contact does not equate to impacts. However, because we have a great deal of uncertainty though related to the impacts of pelagic trawl gear on unobserved mortality of crabs, I am continuing— we heard in testimony today, and I share that view, uh, that in, in the past with the current performance standard that Council has used bottom contact as a proxy for impacts.

And again, I, I think we're moving along to try to address that uncertainty because we are concerned about potential impacts of pelagic trawl gear on unobserved mortality of crab. And I think on research is ongoing to help us understand that a little bit more. But in the absence of a baseline for that unobserved crab mortality, I think bottom contact is the best proxy we potentially have right now, and that's why I'm suggesting we explore these options to, uh, to look at that potentially for revising the performance standards.

Thank you. Um, Mr. Kerlin. Thanks, Madam Chair. Um, Ms. Baker, um, question about the 3 bullets in the central part of your motion. Um, so those are— and I don't think you addressed this in your rationale, so that's why I want to ask, just to be clear.

So those are ways to— potential ways to operationalize and implement in-regulation reduced bottom contact. And it's phrased as such as, so just to clarify, I think your intent would be that if staff in their creativity and knowledge come up with other ways to help operationalize this, that that would also be included in the discussion paper, that it wouldn't necessarily be limited to these three things. Is that correct?

Through the chair, thank you, Mr. Curland. I don't want to preclude that, but I also don't want to establish that as an expectation, if that makes sense. I, I'm a little bit worried because, uh, would— I don't know how to deal with this procedure.

My intention was Yes, in, in considering, uh, these 3 options, if there is something that very clearly rises to the top as staff is looking at information that might be another way to consider this, um, that is not— it's at a discussion paper level, we're not— I'm not asking for an analysis. I think that would be great if staff could highlight that for us. But again, I, I don't The main focus is these 3 options, and if none of these 3 options seem viable, I don't want staff to assume that I'm asking them to do a lot of extra work to come back with options that might be, if, if that makes sense. That helps. Thank you.

Thank you. And Ms. Cohen.

Thank you, Madam Chair, and I have several questions. We'll see how far I get before I have a coughing fit. Um, I'll start with one that leads off of Mr. Kerlin's, um, and thank you, Miss Baker, for the motion. Really appreciate your work here. With that third bullet on the verifiable gear modifications or operational standards, could this include technology such as what we heard about today?

There's net sensor technology, or perhaps other technology that's practical Could it include solutions like that?

Through the chair, Ms. Cohen, certainly I think that would be within my intent here.

Would it be appropriate to try an amendment to add the word technology in there? Maybe we should get through questions first. And yeah, good idea. You just flagged it, so yeah. Yep, thanks.

Um, starting back at the top of your motion on, uh, you know, we heard in testimony that it'd be helpful if the council were clear on our intent for how this gear operates. We were clear last year under this agenda item that we acknowledge that the gear will be in contact with the bottom at times. What we haven't stated clearly yet is that it's okay and how much time is okay. Hi, so I see in your motion that you speak to closed areas, closed to non-pelagic trawl in the Bering Sea and Gulf. Do you envision this discussion paper would help us understand what percent of time or area is acceptable bottom contact, say from 0 to maybe 10% like is allowed in state waters or some other number?

Do you, do you envision this discussion paper would start kind of getting at that?

Through the chair, Madam Gowan. No, I don't, I don't think so. I don't think we're there yet. I think this is really outlining what areas we're talking about here that are closed to non-pelagic trawl gear but open to pelagic trawl in the respective areas. And I think it's exploring, particularly for the first two bullets, a maximum bottom contact rate or the, or a cap on swept area feasibility of even using those as a performance standard.

And, and so no, I don't think— I wouldn't expect staff to be able to get into that level of evaluation at this stage.

Thanks for that explanation. And then on moving on down, you focus on red king crab only because it's at a depressed state, but I noticed in the Bering Sea at least all 3 major crab stocks are at a depressed state, Tanner and snow crab included. So I'm just curious why just the focus on red king crab.

Through the Chair, thank you, Ms. Gowan. In my preparatory review of the areas that we're talking about, I am not aware of any areas closed to non-pelagic trawl that were closed due to concerns about those other crab species. Um, but in the review, all the areas will come back to us if this motion passes. I could be proven wrong.

Thanks for that. Um, you also mentioned towards the end of that paragraph, I believe, about adaptive approaches. And I know we heard a report on the use of spatial dynamic closures to avoid Bristol Bay red king crab and the red king crab savings area. And it seemed like an effective tool, but I don't see that in the suite of options here that you've outlined. Wondering if you could speak to why that's not in there.

Through the chair, thanks for that question, and I, I do appreciate it. I, I didn't speak to it, and I have, I have struggled a little bit. I'm very supportive and appreciative of, of the public fleet's effort this year to undertake the dynamic closure area program. But I— it's different than what we're talking about here in terms of we're talking about ways to really address bottom contact with pelagic trawl gear. And there's— and I've heard, this council's heard, and I agree that it's very important for the council to be clear about if it is considering action, what is— what are we concerned about?

And what are the approaches that we'd like to take and just be really focused about that. And so I, while I support the dynamic closure program, I felt like it wasn't within the scope of what I'm suggesting here, and so I did not include.

Thanks for that. Um, moving down, I think it's your, in your third paragraph from the bottom where you speak to changes in PSC, so prohibited species catch, and recognizing that prohibited species catch is not a great metric for crab, as we've found out through this work. I'm wondering if you can speak more to how you see that being handled. Like, would we be looking at unobserved fishing mortality? Like, how would you get at measuring PSC for crab, I guess, is what I'm getting at.

Through the chair, thank you for that. I think you've already spoken to the challenges there. I think we have PSE data, and that is the extent of what we can take a look at. I think the lack of information and the uncertainty related to unobserved crab mortality from impacts with pelagic trawl gear is, is what we're trying to get at. So acknowledging that we're— we have limited data there.

And then on your statement about the fishing effects model, does this include— the fishing effects model is also going to be looking at, I think we heard from Dr. Harris, this sensitivity analysis to better understand how some of these long-lived species like and like corals and sea whips may have differential impacts. So I'm wondering if your, your statement there about the fishing effects model would include those updates as well.

Through the Chair, Ms. Gowan, again, I focused here in this bottom contact issue on the bottom contact estimates that I anticipate will be updated for the fishing effects review. But yes, also acknowledging that the full scope of what is planned for the phishing effects update that we are going through is on the timeline that we're currently undergoing, and there will be updates. And so I, I believe my answer is yes to your question. Yeah, thanks. And that was my understanding from Dr. Harris's responses, that would all be coming through um, the fishing effects model work.

And my last question is just noting that this motion speaks to bottom contact, but I don't see anything in the motion about clearance, which we heard concern about today, both for crab mortality and for habitat. I'm wondering if you can speak at all to this concept of better understanding clearance.

Through the chair, Ms. Gohan, I, I heard that testimony as well. It's my understanding that that is an area of focus within the EFP process that we received a report on yesterday. Beyond that, I don't have information to share, and therefore that's why I didn't feel I was able to include it here. In this motion.

Thank you. And Ms. Kimball.

Thank you. Um, Ms. Gowan's question spurred one for me. I, I thought in the paragraph below the bullets, the paper was— it's not logical to me that it— that's looking at trade-offs that may result in changes in crab PSE. I thought that was referencing other PSE like salmon. And so I just want to make sure that that is also intended in that sentence?

Through the chair, yes, Ms. Kimball. Sorry, I didn't— yes, I did not catch that when responding to Ms. Gowan. That was the intention, other PSE other than crab, which in this case would be salmon largely.

Thank you. I think, I think I have 2 more.

Um, you know, one is just an overall question. The language in here is, you know, evaluating and reducing. It's, it's looking at reducing bottom contact in specific management areas. And based on one of your responses to Ms. Cohen, I— maybe it is too early, but the wording here looks to me like there is acknowledgement that you are not trying to prohibit all bottom contact by pelagic gear, but trying to create a new performance standard, particularly in those first 2 bullets, that would reduce or minimize contact in certain areas. So if, if I'm reading too much into the approach, please tell me, but I think it's a really important thing to be setting expectations about at this meeting, if possible.

Through the chair, thank you, Ms. Kimball. It is my intent and And I think we've heard very clearly, and I agree that zero bottom contact is not a reasonable objective for this, this action that we're— that I'm requesting a discussion paper for. I think we've heard a fair amount of testimony about the variability of the operations of pelagic trawl gear, particularly following the schools of pollock and also avoiding salmon. Uh, that I— yes, I think, um, looking at the options that we have here, I would see the primary objective being improvement on, uh, the current level of bottom contact that we have, but not zero.

Any other questions?

Any amendments?

Miss Gone, I would offer an amendment to that third bullet to add the word technology after modifications, and with a second, I could speak to it.

Do we want to—. Let's get that up on screen so people can see it.

I think she wants to put technologies after modifications on the second bullet, or excuse me, the third bullet.

It would be after modifications.

PAMA Technologies.

Madam Chair, I'll second. Thank you, Mr. Pamplin. And Ms. Goehn. Thank you for the second, Mr. Pamplin. My intent here is just to be clear for staff.

I appreciate that Ms. Baker answered my question that she saw that that could be considered in the discussion paper. So it's just to add in and really not looking for an array of all new technologies that could be available, but really looking at what is already used in the fleet and what might be practicable within the next 2 to 3 years.

Yes, Ms. Kimball. Thank you, Ms. Gona. Is that—. So is that technology relevant to detecting bottom contact? Are we having the bottom contact sensor conversation again.

Can you explain? Thanks. Yeah, thank you for the question. I was more thinking along the lines of— there were several testifiers today that spoke to— they, they know where their net is in the water column and where it is with regard to the seafloor. So looking at what technology is already on the boats, um, if there's bottom contact sensors that may be commercially available within the next 2 to 3 years, then maybe.

But I was thinking more of technology that's already available and being used by the fleet.

So, Ms. Cohen, in the paper that was— I just have a question. The paper that was reposted for this from last year, there was a section on sensor technologies, for example. Would your intent be to just bring that information back? I think that section just largely spoke about the state of the technology and the limitations currently. So is that what you'd want that kind of refreshed and brought back here?

Yeah, I would say look at that and update it with new information that we have.

Any other questions?

Any comments on the amendment?

Is there any objection to the amendment?

Seeing none, that amendment passes.

Okay, any further amendments?

Any comments on the motion?

Ms. Vanderhoeven. Thank you, Madam Chair. Thank you again, Miss Baker, for your motion. Um, I, I really prefer the approach that AP took on this. I think we've got so many projects that are close to being done that will be informative, um, and really help us dial in on what's possible and realistic.

I think one of the big pieces that I'm really waiting to see is some of the BSFRF data with crab presence, and that's, that's the other part of the equation. If the crab aren't there, there's not an impact. If the crab aren't there, there's not an observed mortality, and I'm, I'm a little concerned about going down this road without a ground-tested baseline and guessing at what improvement we might be making without that crab presence piece of information. I'm—. That's really kind of the stick in my craw at this point on going this route.

I I have doubts about how helpful the information in the discussion paper might be coming back, um, and so I'm, I'm not gonna oppose the motion, but I guess I'm just really skeptical how helpful this is going to be when it comes back until we have some of those research updates that we're expecting in the spring. So I'll, I'll reluctantly support it. Thank you, Ms. Baker.

Thank you, Miss Vanderhoeven. Any other comments on the motion? Mr. Pamplin.

Thanks, Madam Chair. Uh, thanks, Miss Baker, for all your work on the motion. Um, just wanted to speak to a little bit of about the section in the motion regarding the potential trade-offs that we're asking staff to consider in this discussion paper. I get that we're looking at a potential narrow issue of modifying performance standards for pelagic trawl gear, but the context and implications of a future action resulting from this process are potentially far-reaching. Yes, the trade-offs include economic and safety considerations of spending longer time fishing, and it includes biological trade-offs where prohibited species catch levels could be increased because how the gear is operated in the water column where it is fished, and how long it is fished.

Um, I also really appreciate you distinguishing this work from the analyses underway to inform the EFH review. I'm optimistic about the fishing effects model and some of the future work we heard about yesterday of potentially adding units of yield in the impact measure as another way to quantify, evaluate, and compare gear impacts. Um, I also share some of the reservations Miss, uh, Vanderhoeven relayed, but in some I plan to support the motion. Thank you.

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

Miss Gone.

Thank you. Um, I want to commend the presenters under this agenda item. From both the pollock and crab industries and Dr. Harris for all the great research happening. It's clear that groups are working to address council and public concerns regarding potential fishing impacts on species and habitat and to address council research priorities. That's much appreciated.

I also want to acknowledge the helpful public testimony received from lots of perspectives. It's an important part of our process as we work to find the best path forward, and I appreciate the time and effort the public provides in written and oral testimony. I also want to pause and acknowledge a shift that I'm hearing through testimony, one towards more collaboration between groups and fishing sectors, and I encourage that to continue and to lean on the expertise and knowledge of the fishermen on the water. And thank you, Miss Baker, for the motion. What I'm looking for in this motion is making meaningful progress towards clarity on our expectation for pelagic trawl gear with regard to bottom contact and bottom clearance.

And work towards an effective enforceable performance standard or other management measure for accountability. And this motion goes a long way toward that, which I greatly appreciate. Regarding unobserved fishing mortality, I recognize the unobserved fishing mortality work group report and appreciate hearing the new research getting started on unobserved fishing mortality to better understand pot gear impacts and potentially pelagic trawl gear impacts that we heard about, which is responsive to Council research priorities and the Council Council's Unobserved Fishing Mortality Workgroup report highlighting the need for more research. I encourage those folks to report back to the council as their progress continues and encourage all sectors to pursue research to better understand their gears on observed fishing mortality. We heard in testimony that redefining pelagic trawl gear as either semi-pelagic or mobile bottom contact gear may help improve transparency in how this gear operates and provide clarity for the public.

Well, I don't see that in this motion. My understanding is that we can revisit that, that renaming of the gear as we work through the discussion paper and next steps, if we think that is appropriate. As I said, I think this motion is a strong step forward. The part where I'd like to see us go further and include in a discussion paper is a look at thresholds from 0 to some defined percent of acceptable bottom contact and protected areas. And I think we need to be clear on that for all protected areas, whether they're protected to reduce bycatch or to protect important habitat or ecosystem functions.

I would also have liked to see something exploring that question of acceptable clearance off the bottom. I do, however, think this motion is a step forward in addressing our concern over the current performance standard for pelagic trawl gear, which has proven to be not effective and is no longer applicable to all pelagic trawl vessels given electronic monitoring. And with that, I will be supporting the motion. And thanks again for the motion, Ms. Baker.

Thank you, Ms. Gowan. Ms. Kimball.

Thank you, Madam Chair. Thank you, Ms. Baker, for the motion. Um, I, I agree with Ms. Gowan that we got a lot of really good and helpful testimony and, and presentations to start this agenda item off. I'll support the motion in, in that I do like the sentence. Here's the sentence I like in the last paragraph.

I mean, the first paragraph about considering regulatory measures, which I know some really don't think is the best way forward on this action, and some really do, but also the intent to work on adaptive approaches, and it gives us some time to see if those may be more meaningful steps, as well as incentivizing gear modifications, which I think I think we're kind of well on our way to looking at that and seeing that as a meaningful, quicker step. So, so I like that about this motion. I also understand these first 2 bullets as being essentially like a new performance standard. And if the purpose is to then have something that's viable and enforceable, I think we need to go into this eyes wide open on not having technology like bottom contact sensors to be able to use, at least currently. To enforce or, or look at those two kinds of new standards.

So I think we do have to think about model-based approaches or other approaches that may be more novel.

I also, you know, I didn't mean to be nitpicky on, on Ms. Cohen's amendment, though my only hesitation there was I, I heard that same testimony and I really didn't see any new information to come forward. What I heard from testifiers was there's a clear and understandable dead zone for the equipment and sensors that they do have, and that they understand that they, in at least in the Western Gulf, need to stay well above that or they'll wreck their gear. But in other situations, especially in the Bering Sea, you need to be a lot closer to the bottom in order to have high CPUE, to be done with your fishing and get off the water faster. So you, so you can, try to mitigate all these other impacts that we're trying to mitigate. So I, I'm just— that was my concern with that amendment.

I, I've said my piece. I think there's not going to be a lot of new information there, but having it in there is not harmful at this point. Um, I guess that's all. I really do like at the end continuing to endorse the work, um, the collaboration that Ms. Cohen mentioned as well is, um, very hopeful, I think, um, not just from the Trident EFP but from the foundation work and and a couple testifiers that came up saying they were looking at new work to, to answer some of the remaining questions in the unobserved fishing mortality work group. For us, I hope this motion doesn't disincentivize that continued work, collaboration, and research that, that we don't really control or fund, but that the industry, crab industry and pollock industry, are doing on their own.

So that said, I'll support the motion. Thank you, Ms. Baker. Thank you, Ms. Kimball. Any other comments on the motion?

Okay. Um, I'd also like to express my appreciation for all the public testimony and, um, uh, presentations that we received, as well as all the, the leadership in, um, the amount of research, uh, being conducted, as well as EFP. I think these are incredibly important and responsive to both the public's concerns as well as the council's concerns. I recognize a high level of interest in this issue and understand why so many people are focused on the council process for solutions. This is a challenging time in our region and North Pacific.

We have significant ecosystem stressors and a lot of struggling fisheries and resource issues. It's also a time, a very difficult time to be in these leadership roles. So I really appreciate Miss Baker's efforts on this motion and all the work on this issue. I think many testifiers reminded us that despite all the challenges that we're facing right now, we have some of the best managed fisheries in the world, supported by strong science and strong regulations and extensive collaboration with partners. I'm going to support this motion because it addresses areas where additional improvement is warranted with a focus on reducing uncertainty associated with unobserved crab mortality, while remaining grounded in our best available science and our understanding of habitat impacts.

From my perspective, and I know that this is also just a discussion paper, I think it's important to also highlight that our objective at this point is not to establish a zero-contact standard. Considering everything that we heard in public testimony and presentations,, and all the potential limitations, uh, and imp— implications in doing so, but rather it's to reduce uncertainty and improve upon existing practices. Um, I also appreciate the motion, uh, affirms the strength of our EFH process, um, and our best available science while recognizing that uncertainties remain. Um, and I believe it's appropriately structured to focus on gathering more information to inform steps in our process for reducing those uncertainties. So thank you again, Ms. Baker.

So with that, I will see if there's any objection to the motion.

Seeing none, that motion passes without objection. Are there any other actions? Mr. Pamplin. Uh, thanks, Madam Chair. Yes, I have a motion.

I'll just ask that it be brought up.

Thanks. Life take 2. Uh, the motion reads, the council appreciates the Pollock industry responding to the council's request to implement dynamic spatial closures in 2026 for crab avoidance. In the Bering Sea Red King Crab Savings Area, RKCSA, and for the briefing at the June meeting. The council requests the pollock industry to continue to implement dynamic spatial measures for crab avoidance in the RKCSA during the 2027 pollock A season based on recent winter pot surveys and best available information, and provide a postseason report to the council at a subsequent meeting.

The council notes that similar to 2026, salmon bycatch should be the highest priority for avoidance that would override identified closures. If there's a second, I can briefly speak to it.

Sorry, I heard some squeaking. Ms. Gowan, thank you for the second. Mr. Pamplin. Great. Thank you for the groan, Miss Goin.

I'll start with a thank you to the pollock industry for the responsiveness to the council's previous request, their collaboration with the research community and crab industry in designing the framework, and for the transparent and concise briefing provided at this meeting. I recognize that this was a big request last June, and I recognize that this is a big ask again. I've opportunistically chatted with a few industry representatives at this meeting, and they've indicated they're willing to do it again. This seems like a meaningful collaborative step that we can take while the Gear Innovation Initiative, the updates to the fishing effects model, and the discussion paper adopted a few minutes ago plays through. In terms of report writing, just want to note that we need the A season to wrap up and also provide time for data analysis.

And so thus, perhaps this could come as early as next May., but I think it is more likely that it would come before the council at the October meeting. My primary point here is that I would request council staff to work with the policy industry leads on the scheduling of the report presentation, ensure— and ensure it is presented at a noticed public meeting of the council. Thanks. Thank you, Mr. Pamplin. Are there any questions on the motion?

Any amendments?

Any comments? Ms. Gone.

Thank you, Madam Chair, and thank you, Mr. Pamplin, for accepting my squeak as a second and for making the motion. Again, just want to recognize the Pollock Fleet for their great efforts and collaboration and avoidance of Bristol Bay red king crab and the red king crab savings area this past season through dynamic spatial management. To reduce any potential impacts on crab mortality by working to fish where the crab aren't when practicable. I think this is a great example of flexible fisheries management, which I, I think is something we should be working towards, using current information on crab location and movement. And given growing uncertainties with stock dynamics and environmental conditions paired with our sometimes slow Council and NOAA fisheries process, I think this type of flexible, responsive management is a really important tool.

I appreciate seeing it continue as the Council and industry work towards workable performance standards. Thanks.

Thank you, Ms. Gohen. Any other comments?

Seeing none, thank you very much for your work on this, Mr. Pamplin. Is there any objection to the motion?

Okay, seeing none, that motion passes without objection. Any further actions on D1?

Okay, so we will break for the day. Um, we'll come back at 8:00 AM beginning with our E1 agenda item. We will have to make it through the remainder of our items tomorrow because we're only noticed through Tuesday.

So might be a pretty long day, but we'll, we'll see. We'll be working with staff on trying to make sure we have as focused presentations as possible, and we'll have to ask for the council's assistance in managing time tomorrow. So appreciate everyone's engagement throughout the day, and we will see you tomorrow at 8 AM. Beginning with our E-1 agenda item. Thank you.