September 16, 2019 Mr. Simon Kinneen, Chaleman North Pacific Fisheries Management Council 605 W. 4th Ave, Suite 305 ‘Anchorage, AK 99501-2252 RE: Sablefish Bycatch in the Bering Sea and Aleutian Islands Dear Chairman Kinneen: ‘This letter is written on behalf of the members of the Fishing Vessel Owners’ Association. (FVOA) and the Deep Sea Fishermen's Union (DSU). Over the summer, we became aware of the magnitude ofthe trawl bycatch of sabefish inthe Bering Sea. The numbers are greatly increased and present serious concerns about accountability and the impact these bycatch levels will have on the directed fishery and rebuilding efforts for this important resource ‘We were informed as of September 4 that the total byatch of trawl sabefish was 2,259 Mt. Additionally, we were informed that 1,281 Mt had been discarded, 979 Mithad been ‘retained and 450 Mt had been sold for human consumption. We understand that hal of this, bycatch is from the Pollock fishery and half from the Amendment 20 fleet. ur first concern is that, by allowing the bycatch to reach these levels, any assumption that we were saving fish to help rebuild this resource cannot be sustained, It fs well known that sablefish have significant migration patterns. itis believed many ofthe younger fish in the Bering Sea ultimately migrate to the east throughout the Gulf o Alaska, Our second concern, considering that the trawl quota is 633 Mt In the Bering Sea, how sit explained that 979 Mt was retained? ur third concern is that, by allowing the total mortality of sableish to reach close tothe overfished level, all directed and non-directed fishing could face regulatory closures. ‘The sablefish resource has recently been blessed with several above-average year classes, beginning in 2013/14. These young fish put on about 1 pound per year for females, less for males. It takes a year class 6-to-9 years to reach optimal market size before the pot and longline directed fishery can take advantage ofthese new-year classes, Having nearly § millon, pounds of bycatch of juvenile sablefish is not acceptable, ever, and particularly if this is. becoming an annul event.Charman simon kinneen September 16, 2019 Page2 Be assured that we will pursue the appropriate remedies, if these bycatch numbers persist, resulting in the directed fishery having more precautionary harvest limits without verifiably effective, mitigating efforts by the tral fleets We request thatthe Council prepare a discussion paper on these bycatch levels and review any precautionary actions that can be taken in order to reduce and minimize the bycatch levels. We ‘also request 2 full explanation of how the accounting is done wit atraw/ quota level of 633 Mt, Yet a retention level permitted of $79 Mit and what management response, if any, ae being Undertaken, Sincerely, Sincerely, mM CO OMB Rav CQ \) Robert D. Alverson James Johnson FISHING VESSEL OWNERS’ ASSOCIATION DEEP SEA FISHERMEN’S UNION Manager Executive Director ROA:cb