Comment from Julie Bonney, Alaska Groundfish Data Bank

Comments on: Proposed Rule to revise the pollock trip limit regulations in the Gulf of Alaska The processor and shoreside trawler members of Alaska Groundfish Data Bank support the proposed rule to close a loophole in the regulations in order to achieve the actual intent of the 300,000 pound trip limit: 300,000 pounds per vessel per 24 hour period. The original regulation was put into place as a Stellar Sea Lion (SSL) protection measure to temporally distribute the pollock harvests. We believe closing the loophole that allowed trawlers to land more than the 300,000 pound limit in one calendar day is appropriate and suits the purpose of the problem statement. However, we feel the need to point out that trip limits contribute to regulatory discards and harvest inefficiency. Trip limits are really only a band-aid to address the overarching problem of temporal distribution of pollock harvest to address SSL issues. The best solution to address the problem would be to rationalize the GOA pollock fishery. The BSAI AFA pollock fishery rationalization program has demonstrated the benefits of allocating harvest privileges to cooperatives. Removing the race for harvest shares smoothes the harvest rate over time and more evenly distributes catches temporally which would be beneficial to SSL. Individual quotas and vessel accountability would reduce the race for fish and the currently perceived need to over-catch then discard the excess. At some point it is our hope that the North Pacific Fisheries Management Council will develop a comprehensive solution to the problem and rationalize the GOA pollock fishery. Thank you for the opportunity to make comments regarding this proposed rule. Sincerely, Julie Bonney Executive Director Alaska Groundfish Data Bank