145 



3. ACC proposed joint State, federal, and industry cooperation on research 

 and management during and after the development of the Bering Sea/Aleutian 

 Islands King and Tanner Crab FMP, 1987-1990. 



II. Description of crab management problems with the State of Alaska. 



1. Criticisms are focused on the State system, which is overwhelmingly con- 

 cerned with managmement of salmon fisheries. 



2. Recent problems with the Alaska Board of Fisheries actions regarding con- 

 sistency with the Crab FMP and the MFCMA. 



a. Repeal of the pot gear limits in 1992. 



b. 1993 designation of the Norton Sound "superexclusive registration 

 area" which is inconsistent with the FMP and is, therefore, illegal. Only ex- 

 clusive and non-exclusive areas were included in the final FMP. 



1. Industry associations vehemently opposed superexclusive designa- 

 tion in the formulation of the FMP, 1986—1989. (Administrative 

 record, NPFNC.) 



2. ACC appeal has requested expedited federal review from NMFS 

 and Crab interim Action Committee, and Federal Court. 



3. Board of Fisheries changed season opening date from August 1 to 

 July 1, without proper notice or record. 



c. Board members are lay persons. Although most have good intentions, 

 these individuals have littfe-to-no experience with crab management and 

 EEZ fisheries. They also have an apparent objective to make decisions for 

 the benefit of the State of Alaska. 



III. Description of management problems with the Alaska Dept. of Fish and 

 Game. 



1. Regional autonomy system within ADF&G has resulted in Kodiak West- 

 ward Office being in charge of Bering Sea crab management. Reduced coopera- 

 tion with industry has been a serious problem. 



a. Refused ACC good faith offers for developing long term industry-fund- 

 ed applied research on life history and mortality issues, after completion of 

 a successful project in 1990. 



b. Refusea ACC assistance with implementation of voluntary logbook 

 program to aid in bio-mass estimates. 



c. Discontinued an ACC led voluntary catch reporting program that en- 

 couraged an orderly fishery and aided in-season management. 



2. Kodiak Office has been ineffective and counter-productive. 



a. Kodiak Island and Bering Sea pot limits imposed to facilitate orderly 

 fisheries. 



b. Total collapse of Kodiak EEZ tanner crab, since State of Alaska as- 

 sumed management after 1987. However, pot limits were ostensibly imple- 

 mented for conservation. 



c. Bristol Bay king crab fishery, 11 years after the collapse, still at record 

 low depressed stock levels. 



d. Little-to-no new applied research on mortality problems, early life his- 

 tory. 



e. Reluctant lowering of a record snow crab quota for 1992, after pressure 

 from the ACC, despite declining stock forecasts. 



f. Recent opening of scallop dredging in the Bering Sea, with no crab 

 bycatch restrictions and no observer coverage. 



3. The State has taken in much more from the fisheries than it has put into 

 them. 



a. State of Alaska has been collecting over $15 million in raw fish and 

 fuel taxes and permit fees from Bering Sea crab fisheries per year, in the 

 last 3 years. 



b. Industry-funded observer program has been paying $2.5 million for ob- 

 servers producing in-season catch and bycatch data. 



c. State of Alaska has only been investing approximately $1 million in 

 crab management, (excluding resource-basea sell-funding crab surveys), a 

 part of the State's massive budget reduction for fish and game resource 

 management that could jeopardize long-term sustainable use. 



d.ACC recognizes that ADF&G has exceptional staff persons in Juneau, 

 dealing with the interjurisdictional fisheries, Mr. Carl Rosier, Ken Griffin, 

 Dr. Gordon Kruse, Earl Krygier, David Benton, and the new Commercial 

 Fisheries Director, Dr. Jeff Koenigs. 



e. Need for reorganization of Bering Sea crab management with direct 

 line of authority between Juneau Headquarters, NMFS Alaska Region and 

 the NPFMC in Anchorage. 

 TV. Problems with the State of Alaska Crab Observer program. 



