on the Draft Environmental Impact Statement/Regulatory Impact Review/Initial Regulatory

• Main Authors: George J. Mannina, Robert D. Mecum, Acting Administrator
• Other Authors: The Pennsylvania State University CiteSeerX Archives
• Format: Text
• Language: English
• Published: 2009
• Subjects: Bering Sea; Pacific; Aleutian Islands
• Online Access: http://citeseerx.ist.psu.edu/viewdoc/summary?doi=10.1.1.175.385; http://alaskafisheries.noaa.gov/sustainablefisheries/bycatch/salmon/chinook/deis/comments/C39_Mannina,%20George_Nossaman%20LLPpdf.pdf

catcher-processors, motherships, and on-shore processors involved in the Bering Sea Aleutian Islands (“BSAI”) pollock fishery. Their members rely on the pollock fishery for their economic livelihood. The issues presented by the proposals pending before the North Pacific Fishery Management Council (“NPFMC”) are extraordinarily complex. APA, PSPA, and UCB each recognize the importance of, and are dedicated to, reducing salmon bycatch. Indeed, the pollock fishery has had a long history of working to reduce the incidental bycatch of Chinook salmon. In 1996, the BSAI Groundfish Fishery Management Plan was amended to close three areas to trawling when 48,000 Chinook salmon were incidentally taken. The pollock industry supported this proposal. In 2000, this program was refined through Amendment 58 to the BSAI Groundfish Fishery Management Plan to lower the closure trigger from 48,000 to 29,000 and to refine the closure dates and areas. Again, the industry supported this measure. In 2001, the pollock fleet voluntarily implemented a Voluntary Rolling Hotspot System (“VRHS’) in which chum salmon bycatch is monitored on a real time basis so the fleet can move to different areas to avoid bycatch. In 2002, the fleet voluntarily extended VRHS to include Chinook salmon. In