SECRETARIAL REVIEW DRAFT 

Regulatory Impact Review

for Proposed Regulatory Amendment 

Removing processing restrictions for squids and 

sculpins in the BSAI and GOA 

October 2020 

Lead Agency: National Marine Fisheries Service, Alaska Region 

National Oceanic and Atmospheric Administration 

Responsible Official: James Balsiger, Administrator 

Alaska Regional Office, National Marine Fisheries Service 

For further information contact: Megan Mackey, National Marine Fisheries Service 

P.O. Box 21668, Juneau, AK 99802-1668 

Juneau, Alaska 

(907) 586-7228 

Abstract: This Regulatory Impact Review (RIR) examines the benefits and costs of proposed 

alternatives regarding processing and sale of squids and sculpins as part of the Ecosystem 

Component category in the Fishery Management Plan for Groundfish of the Bering Sea 

and Aleutian Islands Management Area and the Fishery Management Plan for 

Groundfish of the Gulf of Alaska. This RIR considers a regulatory amendment only with 

no FMP amendments necessary. This RIR also assesses the potential impact of the 

alternatives on fishing communities and addresses other social impacts. 

Accessibility of this Document: Effort has been made to make this document accessible to individuals with 

disabilities and compliant with Section 508 of the Rehabilitation Act. The complexity of this document may 

make access difficult for some. If you encounter information that you cannot access or use, please call us at 

907-271-2809 so that we may assist you. 
List of Acronyms and Abbreviations 

Acronym or 

Abbreviation 

Meaning 

ABC Acceptable Biological Catch 

ADF&G Alaska Department of Fish and Game 

AFA American Fisheries Act 

AFSC Alaska Fisheries Science Center 

AKFIN Alaska Fisheries Information Network 

BSAI Bering Sea and Aleutian Islands 

CAS Catch Accounting System 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

Council North Pacific Fishery Management Council 

C/P Catcher/Processor 

CV Catcher Vessel 

E.O. Executive Order 

EA Environmental Assessment 

EC Ecosystem Component 

EEZ Exclusive Economic Zone 

EFH Essential Fish Habitat 

EIS Environmental Impact Statement 

ESA Endangered Species Act 

FMA Fisheries Monitoring and Analysis 

FMP Fishery Management Plan 

FONSI Finding of No Significant Impact 

FR Federal Register 

GOA Gulf of Alaska 

IRFA Initial Regulatory Flexibility Analysis 

LOA Length Overall 

mt Metric Tons 

MSA Magnuson-Stevens Fishery Conservation 

and Management Act 

MMPA Marine Mammal Protection Act 

NEPA National Environmental Policy Act 

NMFS National Marine Fishery Service 

NOAA National Oceanic and Atmospheric 

Administration 

NPFMC North Pacific Fishery Management Council 

Observer 

Program 

North Pacific Observer Program 

PSC Prohibited Species Catch 

PA Preferred Alternative 

PSEIS Programmatic Supplemental Environmental 

Impact Statement 

RFA Regulatory Flexibility Act 

RFFA Reasonably Foreseeable Future Action 

RIR Regulatory Impact Review 

SAFE Stock Assessment and Fishery Evaluation 

SAR Stock Assessment Report 

SBA Small Business Act 

Secretary Secretary of Commerce 

TAC Total Allowable Catch 

U.S. United States 

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Table of Contents 

1 Introduction ...........................................................................................................................................................10 

1.1 Purpose and Need.........................................................................................................................................10 

1.2 History of this Action ......................................................................................................................................11 

1.3 Description of Management Area ..................................................................................................................13 

2 Description of Alternatives ....................................................................................................................................15 

2.1 Alternative 1: Status quo. Squids and sculpins in both the BSAI and GOA FMPs are designated as nontarget ecosystem component species with prohibition on the use of squids and sculpins other than as 

fishmeal. ........................................................................................................................................................15 

2.2 Alternative 2: Squids and sculpins in both the BSAI and GOA FMPs are designated as non-target 

“ecosystem component species”. Preferred Alternative.................................................................................15 

2.3 Meeting the requirements for Ecosystem Component ...................................................................................15 

2.4 Comparison of Alternatives............................................................................................................................17 

2.5 Rationale for Council’s Preferred Alternative .................................................................................................18 

3 Biological and Fishery information ........................................................................................................................19 

3.1 Squids............................................................................................................................................................19 

3.1.1 Squid status and role in the ecosystem..............................................................................................19 

3.1.2 Life History..........................................................................................................................................21 

3.1.3 Trawl survey biomass estimates and distribution ..............................................................................21 

3.1.4 Harvest specifications.........................................................................................................................23 

3.1.5 Catch and retention............................................................................................................................23 

3.2 Sculpins .........................................................................................................................................................25 

3.2.1 Sculpins status and role in the ecosystem..........................................................................................25 

3.2.2 EBS and AI Survey ...............................................................................................................................25 

3.2.2.1 GOA Survey...........................................................................................................................................27 

3.2.2.2 Fishery Catch......................................................................................................................................... 27 

4 Regulatory Impact Review ....................................................................................................................................30 

4.1 Statutory Authority .........................................................................................................................................30 

4.2 Purpose and Need for Action.........................................................................................................................31 

4.3 Alternatives ....................................................................................................................................................31 

4.4 Methods for analysis of impacts.....................................................................................................................32 

4.5 Description of Fisheries .................................................................................................................................32 

4.5.1 Squid...................................................................................................................................................32 

4.5.1.1 Recent Harvests..................................................................................................................................... 33 

4.5.1.2 Description of current management........................................................................................................ 35 

4.5.1.3 Harvesting vessels ................................................................................................................................. 35 

4.5.1.4 Production.............................................................................................................................................. 37 

4.5.2 Sculpin ................................................................................................................................................38 

4.5.2.1 Harvests, Management, and Retained Catch ......................................................................................... 38 

4.5.3 Value of Sculpins and Potential for Markets ......................................................................................39 

4.6 Analysis of Impacts........................................................................................................................................40 

4.6.1 Alternative 1: No action, status quo...................................................................................................43 

4.6.2 Alternative 2 (Preferred Alternative): Remove processing restrictions on squids and sculpins ........44 

4.6.3 Effects on Fishing Communities and Other Social Impacts ................................................................44 

4.6.4 Affected Small Entities........................................................................................................................44 

4.7 Management and Enforcement Considerations.............................................................................................46 

4.7.1 Alternative 1: Status Quo ...................................................................................................................46 

4.7.2 Alternative 2: Squids and sculpins in both the BSAI and GOA FMPs are designated as non-target 

“ecosystem component species” without processing restrictions. ..............................................................47 

4.7.3 Implications for State Fisheries ..........................................................................................................47 

4.8 Summation of the Alternatives with Respect to Net Benefit to the Nation......................................................47 

5 Magnuson-Stevens Act and FMP Considerations.................................................................................................48 

5.1 Magnuson-Stevens Act National Standards ..................................................................................................48 

5.2 Section 303(a)(9) Fisheries Impact Statement...............................................................................................50 

5.3 Council’s Ecosystem Vision Statement..........................................................................................................50 

6 Preparers and Persons Consulted........................................................................................................................51 

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7 References............................................................................................................................................................52 

List of Tables 

Table 2-1 

Table 2-2 

Table 2-3 

National Standard factors a Council should consider when deciding whether stocks require 

conservation and management, and their relevance to sculpins in the BSAI and GOA..........................16 

National Standard factors a Council should consider when deciding whether stocks require 

conservation and management, and their relevance to squids in the BSAI and GOA. ...........................17 

Summary of Management Measures in Alternatives 1 and 2 .................................................................18 

Table 3-1. Squids present in the BSAI and GOA. ........................................................................................................20 

Table 3-2 Survey biomass estimates (“bio” in metric tons) and coefficients of variation (CV) of squids for the EBS 

Shelf, EBS Slope, and AI. Estimates are included for the principal species caught in each survey. 

Numerous species occur on the slope and are included in the “total squid” category for that region. 

From Ormseth, 2016a.............................................................................................................................22 

Table 3-3 Biomass estimates and coefficient of variation (CV) of squid species from NMFS GOA bottom trawl 

surveys, 1984-2017. From Ormseth 2017. .............................................................................................23 

Table 3-4 Squid catch (mt) and total retained (mt) by target species fishery in the BSAI 2009 – 2019........................24 

Table 3-5 Squid catch (mt) and total retained (mt) by target species fishery in the GOA 2009 - 2019.........................24 

Table 3-6 Biomass (Random effects model estimate), total allowable catch (TAC), acceptable biological catch 

(ABC), Overfishing Limit (OFL), catch of the BSAI (top) and GOA (bottom), and catch/biomass ratio 

for the sculpin complex 2011 to 2019. *Catch estimated through February 2019...................................28 

Table 3-7 Total catch in metric tons (mt) of all sculpins by target fishery in the BSAI, 2010– 2019........................29 

Table 4-1. Catch (mt) and retention (mt) of squid by all groundfish fisheries by FMP area 2009-2020........................33 

Table 4-2. Total catch (mt) and retained catch (mt) and the number of vessels retaining squid in the BSAI by 

sector from 2009 - 2018. Total retained and number of vessels is not available for 2019. .....................36 

Table 4-3. Total catch (mt) and retained catch (mt) and the number of vessels retaining squid in the GOA by 

sector from 2009 – 2019. Amount retained and number of vessels is not available for 2019.................37 

Table 4-4. Annual production (in pounds) of squid to fish meal, whole bait, and whole fish/food fish in the BSAI 

and GOA, combined from 2009 – 2018. .................................................................................................37 

Table 4-5. Total production (in pounds) of squid to fish meal, whole bait, whole fish/food fish, and gross first 

wholesale value in the BSAI and GOA, combined, from 2009 – 2018....................................................38 

Table 4-6. Total squid production (mt) by community in the BSAI and GOA, 2009 – 2019..........................................38 

Table 4-7 Retained Catch of Sculpins in the BSAI and GOA Combined by Gear and Sector in metric tons (mt)...39 

Table 4-8 Ex vessel price per pound of catcher vessel (CV) caught sculpin for fish meal for both BSAI and 

GOA groundfish fisheries from 2006 through 2017.................................................................................39 

List of Figures 

Figure 1-1 NMFS regulatory and reporting areas in the GOA..................................................................................13 

Figure 1-2 NMFS BSAI sub-areas for management ................................................................................................14 

Figure 3-1 Random effects model estimates of biomass by region for the six most common shelf sculpins 

(top), slope (middle), and Aleutian Islands (bottom). Error bars represent 95% confidence intervals 

for survey estimates of biomass, and dotted lines represent 95% confidence intervals from the 

random effects model. From Spies et al. 2016. .....................................................................................26 

Figure 3-2 Random effects model estimates of biomass for the five most common sculpins in the GOA 

complex. Error bars represent 95% confidence intervals for survey estimates of biomass, and 

dotted lines represent 95% confidence intervals from the random effect model. From Spies et al. 

2017........................................................................................................................................................27 

Figure 4-1. Squid landings (mt) by date in the BSAI and GOA in 2019. AKFIN accessed December 23, 2019...........34 

Figure 4-2. Cumulative squid landings (mt) by week in the BSAI and GOA in 2019. AKFIN accessed December 

23, 2019..................................................................................................................................................34 

Figure 4-3 Squid landings in the BSAI and GOA for 2009 – 2019. AKFIN 12.23.2019. ...............................................42 

Figure 4-4. Cumulative squid landings (mt) by week in the BSAI and GOA 2009 - 2019. AKFIN 12.23.2019. ............42 

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Executive Summary 

This document analyzes alternatives to reconsider processing restrictions on squids and sculpins, two 

species recently added to the Ecosystem Component (EC) category in the Fishery Management Plans for 

groundfish in the Bering Sea and Aleutian Islands (BSAI) and Gulf of Alaska (GOA). This Regulatory 

Impact Review provides an assessment of the economic benefits and costs of the proposed alternatives, 

and their distribution. 

Purpose and Need 

The Council adopted the following updated purpose and need statement in February 2020. 

Squid is defined in the ecosystem component (EC) category in the FMPs for groundfish 

in the BSAI and GOA. The Council, in October 2019, took action to recommend that 

sculpins be defined in EC category in the BSAI and GOA as well. There are no directed 

fisheries for squid or sculpins in either the BSAI or GOA. Incidental catch of squid is 

retained in some fisheries and often utilized to prevent waste. Typically, sculpins are not 

retained but can be in some circumstances. 

The Council’s June 2017 action to reclassify the squid complex into the EC category in 

the BSAI and GOA groundfish FMPs was based on the best available scientific 

information and was consistent with the revised National Standard 1 guidelines. 

However, the Federal rulemaking to implement the Council’s action prohibited the use or 

sale of incidentally caught squid unless processed into fish meal. The June 2017 Council 

action and supporting analyses indicated: 1) retention of squids would continue at or 

slightly above current levels, and 2) past production types would continue to be allowed 

including whole bait and whole fish/food fish. The purpose of this action is to align 

regulations with the long-standing use of squid, the permissible use of squid based on the 

Council’s June 2017 analysis and preferred alternative, and the permissible use of squid 

under the EC category. 

The Council’s recent recommendation to establish sculpins in the EC category would 

limit the use of sculpins consistent with existing regulations for all other EC category 

species (50 CFR 679.20(i)). The Council does not wish to increase the time required to 

move sculpins into the EC category by modifying that action, but intends to review the 

disposition of sculpins consistent with squids and the flexibility provided by the EC 

category. 

Alternatives 

The council adopted the following alternatives for analysis in October 2019. Alternative 2 is the Preferred 

Alternative (PA). 

Alternative 1. Status Quo. Squids and sculpins in both the BSAI and GOA FMPs are designated as 

non-target ecosystem component species with prohibition on the use of squids and sculpins other 

than as fishmeal. 

Alternative 2. Squids and sculpins in both the BSAI and GOA FMPs are designated as non-target 

ecosystem component species. (Preferred Alternative) 

Because squids are already in the EC category, and the Council took final action to move sculpins into the 

EC category in October 2019, the only real difference in these alternatives is the allowance, in regulation, 

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for processing and sale of squids and sculpins as either fishmeal only (Alt 1) or without the fishmeal-only 

regulation (Alt 2). Table ES 1 provides a summary of the two alternatives considered in this action. 

Table ES 1 Summary of management measures in Alternatives 1 and 2. 

Management 

Measure Alt 1- No Action Alt 2 – No Processing Restrictions 

Prohibit Yes Yes 

Directed Prohibit directed fishing in regulations at Prohibit directed fishing in regulations at 

Fishing 679.20(i) 679.20(i) 

Yes Yes Retention and Retention and sale allowed as fishmeal Retention and sale as any product form Sale only, subject to MRA limits. allowed, subject to MRA limits. 

No No 

- Periodic reports on biomass - Periodic reports on biomass Annual information from current surveys information from current surveys will Harvest will be included in the SAFE be included in the SAFE Specifications - Catch does not accrue to - Catch does not accrue to optimum 

optimum yield cap yield cap 

Incidental Yes Yes 

Catch MRA = 20% for all basis species MRA = 20% for all basis species 

Management 

Yes Yes 

Recordkeeping Require catch reporting Require catch reporting 

and Reporting 

Squids 

There are at least 15 species of squids in the BSAI and GOA regions (Table 3-1). Most species are 

associated with the slope and basin, with the highest species diversity along the Bering Sea slope between 

200 and 1,500 m. As Alaskan waters are warming, market squid (Doryteuthis opalescens) are beginning 

to show up in GOA waters that were previously too cold for them. Although there are no directed 

fisheries for any squids in the BSAI or GOA, the State of Alaska Board of Fisheries has received at least 

one proposal to develop a fishery for market squid, and authorized an exploratory fishing permit under 

conditions of the Commissioner’s Permit. 

The AFSC bottom trawl surveys do not employ the appropriate gear or sample in the appropriate places to 

provide reliable biomass estimates for most squids. Berryteuthis magister, Gonatopsis borealis, and 

Rossia pacifica are the most common squids in the Eastern Bering Sea slope survey (Table 3-2). In the 

GOA, B. magister, is the most common squid species encountered in the survey (Table 3-3). 

Squids are currently managed as EC species in the BSAI and GOA. Ecosystem component species (50 

CFR 600.305(c)(5) & (d)(13) and 50 CFR 600.310(d)(1)) are stocks that a Council or the Secretary has 

determined do not require conservation and management, but desire to list in an FMP in order to achieve 

ecosystem management objectives. Establishing harvest specifications for squids before they were placed 

in the EC category was problematic because reliable biomass estimates for squids do not currently exist. 

Because of data limitations, squids were assessed as a Tier 6 species in the BSAI and GOA. 

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Squids are EC species that are caught incidentally in prosecution of groundfish fisheries in the BSAI and 

GOA. In both the BSAI and GOA, the vast majority of squids are caught in the pollock fisheries. Catch of 

squid in other target species fisheries is minimal (Table 3-4, Table 3-5). Remarkably, in 2019 squid catch 

in the BSAI increased greatly to 5,931 mt, which is more than twice the previous high in 2015, and the 

highest level since 1981. It is difficult to determine the reasons for the dramatic increase in squid catch in 

the BSAI, but may include an increase in squid abundance in the BSAI, release from the fleet’s necessity 

to avoid squids, increased encounters with squids as the fleet avoided salmon and sablefish, and 

potentially the misperception by some processors that squids could be sold as whole bait. Through July 7 

2020, the squid catch in the BSAI is 260 mt, and 101 mt in the GOA. This appears to be similar to the 

cumulative catch in recent years. 

Annual production of squids to fish meal, whole bait, and whole fish/food fish are shown in Table 4-4. 

Overall, whole bait was the most common and valuable product type, followed by whole fish/food fish, 

and fish meal. Squid processed to bait are used by fixed-gear vessels fishing in the BSAI and GOA. Total 

squid production for the main squid processing communities in the BSAI and GOA are shown in Table 

4-6 .The main squid processing communities are Dutch Harbor/Unalaska and Kodiak, with some 

additional processing taking place in Akutan, King Cove, Sand Point, and Seward. Squid do not represent 

a significant proportion of production for any processing community in the BSAI or GOA. 

Sculpins 

Sculpins are small, demersal, teleost fishes that consist of 4 diverse families off Alaska. Sculpins occupy 

all benthic habitats along the continental shelf and slope areas, and occupy depths from the nearshore 

sand and mud bottoms at 20 m to below 1,000 m along the slope and canyon habitats. Sculpins are 

predators of the shelf and slope ecosystems, consuming a wide variety of benthic prey including 

commercially important crabs and fishes. 

Sculpins are managed as non-target species in the BSAI and GOA, but the Council recently took action 

(Amendments 121 to the BSAI FMP and 110 to the GOA FMP, implemented 8/10/2020, 85 CFR 41427) 

to classify sculpins as EC species in both the BSAI and GOA. Sculpins are taken only as bycatch while 

directed fishing for other species. Total catch (retained and discarded) has ranged from 2% to 6% of the 

total estimated biomass (Table 3-6). There is no market for sculpins, and there has not been recent interest 

in marketing sculpin in any product form. 

Analysis of impacts of the alternatives 

Assessing the effects of the alternatives involves a great degree of speculation because effects are likely to 

arise from the actions of individual participants in the fisheries. Predicting individual actions and their 

effects is constrained by incomplete information concerning the fisheries, incomplete economic 

information, incomplete biological information, and lack of models to predict participant behavior. 

Because 2019 was the first year that squids were managed as EC species, there are limited data available 

to predict the impacts of alternatives on catch of squid. Catch of squids in 2019 was approximately 5 

times higher than previous years, and was the highest since 1982. Available data suggest that multiple 

factors, including the overall abundance of squid in the BSAI, release from the fleet’s necessity to avoid 

squids, the effects of avoiding Chinook salmon and sablefish, and the misperception by some processors 

in 2019 that squids could be sold as whole bait likely affected the incidental catch of squids in 2019. 

Alternative 1 

Alternative 1 would continue to manage squids and sculpins as ecosystem component species in the 

groundfish FMPs for the BSAI and GOA, and processing restrictions limiting processing and sale of 

squids and sculpins to fish mean only would be maintained in regulations. Under Alternative 1 processors 

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may experience higher costs associated with discarding squids or converting fish meal plants to be able to 

efficiently process squid. Processors would also forgo revenue from the sale of squids as product forms 

other than fish meal. Overall impacts or forgone revenue from the prohibition of selling squid as whole 

bait is not significant in comparison to the overall value of the BSAI and GOA groundfish fisheries, but 

impacts may be significant to individual operators depending on how much of their annual revenue is 

generated from processing squid. Fixed gear vessels operating in the BSAI and GOA that had previously 

purchased squid processed to bait may experience higher costs to purchase imported bait. 

Because there has never been a significant market for any sculpin products, it is unlikely that imposing 

processing restrictions to fish meal only would affect the level of incidental catch, or the value of 

incidental catch of sculpins in the BSAI or GOA. 

Alternative 2 

Alternative 2 would continue to manage squids and sculpins as ecosystem component species in the 

groundfish FMPs for the BSAI and GOA, but processing restrictions would be eliminated from 

regulations allowing the processing and sale of squids and sculpins in any product form. Under 

Alternative 2 processors may be able to generate additional revenue from the sale of squids as whole bait 

or whole fish/food fish, and fixed-gear vessels purchasing squid bait would have reduced costs relative to 

imported bait. Total additional revenue would depend on individual processors’ decisions to process 

squids to saleable products or discard. Alternative 2 may also reduce the amount of squid discarded. The 

potential economic impacts of allowing squids and sculpins to be sold as products other than fish meal are 

not significant in comparison to the overall value of the BSAI and GOA groundfish fisheries, but impacts 

m ay be significant to individual operators depending on how much of their annual revenue is generated 

from processing squids. 

Effects on fishing communities and other social impacts 

The potential community and social impacts of the alternatives are primarily economic in nature. Analysts 

did not identify any impacts that would create adverse economic impacts on any fishing community or 

cause any other adverse social impacts. 

Affected small entities 

Both alternatives would directly regulate any processor receiving squids or sculpins in the federally 

managed groundfish fisheries in the BSAI and GOA. As described in Section 4.6.2, for processors 

currently participating in these fisheries, the economic impacts of Alternative 2 are primarily beneficial or 

neutral. Processors who wish to process squids and sculpins may still do so in the future, up to the MRAs. 

It is possible that one or more processors in the BSAI or GOA that processes squids or sculpins under 

Alternative 2 could be small entities if the processing company and its affiliates worldwide employ fewer 

than 750 people. Total employment numbers of processing companies and their affiliates worldwide are 

not available to make that determination. 

Management and enforcement considerations 

Under both alternatives, squids and sculpins may be retained up to the MRA of 20% for all basis species. 

Recordkeeping and reporting requirements remain in place under both alternatives. Primary management 

considerations for Alternative 1 include monitoring catch to ensure that the MRA is not exceeded and 

monitoring processing products to ensure that squids and sculpins are not processed into forms other than 

fish meal. Enforcement considerations for Alternative 1 include determining the appropriate penalty for 

exceeding the MRA for squids and sculpins. Primary management considerations for Alternative 2 

include monitoring catch to ensure that the MRA is not exceeded. Enforcement considerations for 

Alternative 2 include determining the appropriate penalty for exceeding the MRA for squids and sculpins. 

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Implications for state fisheries 

Neither alternative would have any immediate implications for state fisheries. The FMPs do not preclude 

development of a directed squid fishery (such as for market squid) in state waters. The State of Alaska 

Board of Fisheries could authorize a state waters fishery for squids as they determine it to be appropriate. 

Summary of net benefits to the Nation 

Net benefits to the Nation relative to the No Action alternative would likely increase marginally under 

Alternative 2 by allowing processing and sale of squids and sculpins products and by helping to prevent 

waste of the incidental catch of these species. Alternative 2 would likely not affect current fishery revenue 

for sculpins, as a small amount of sculpins is retained and marketed as fish meal, but fishery revenue for 

squids may increase by allowing sale of squids as whole bait or whole fish/food fish. 

Changes from Initial Review 

The final review draft differs from the initial review draft to respond to requests and recommendations 

from the SSC and the Council. Updates to the following sections have been made: 

• The document has been updated to confirm that data in Table 3-2 and Table 3-3 are the most up 

to date. The latest assessment of squids in the BSAI and GOA occurred in 2016. Because surveys 

do not use the proper equipment, nor sample in the appropriate areas for squid, those preliminary 

results are not reliable to estimate biomass. 

• Table 4-1 shows the increase in incidental catch of squid in 2019. 

• Tables 3-4, 3-5, 4-2 and 4-3 are updated to include 2019 data for squid catch by target or sector. 

• Section 4-6 has been updated to identify the “other” squid processing communities of Akutan, 

King Cove, Sand Point, and Seward. 

• Section 4.5.1.4 has been updated to indicate that fixed-gear vessels operating in the BSAI and 

GOA are the primary consumers of squid processed to bait. 

• Sections 4.6.1 and 4.6.2 have been updated to reflect the use of bait by fixed-gear vessels in the 

BSAI and GOA, and the increased cost that may be associated with imported bait. 

• Section 4.5.1.2 has been updated to include information about EFP 2019-03. 

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1 Introduction 

This document analyzes alternatives to reconsider processing restrictions on squids and sculpins, two 

species recently added to the Ecosystem Component (EC) category in the Fishery Management Plans 

(FMPs) for groundfish in the Bering Sea and Aleutian Island (BSAI) management area and Gulf of 

Alaska (GOA). 

This document is a Regulatory Impact Review (RIR). The RIR provides an assessment of the economic 

benefits and costs of the proposed alternatives, and their distribution. This RIR addresses the statutory 

requirements of the Magnuson Stevens Fishery Conservation and Management Act (MSA), the National 

Environmental Policy Act (NEPA), and Presidential Executive Order 12866. A RIR is a standard 

document produced by the North Pacific Fishery Management Council (Council) and the NMFS Alaska 

Region to provide the analytical background for decision-making. 

Based on information to date, this action is not likely to, individually or cumulatively, have a significant 

effect on the quality of the human environment and therefore may be categorically excluded from the 

need to prepare an Environmental Assessment (EA). 

1.1 Purpose and Need 

The Council adopted the following updated purpose and need statement in February 2020. 

Squid is defined in the ecosystem component (EC) category in the FMPs for groundfish 

in the BSAI and GOA. The Council, in October 2019, took action to recommend that 

sculpins be defined in EC category in the BSAI and GOA as well. There are no directed 

fisheries for squid or sculpins in either the BSAI or GOA. Incidental catch of squid is 

retained in some fisheries and often utilized to prevent waste. Typically, sculpins are not 

retained but can be in some circumstances. 

The Council’s June 2017 action to reclassify the squid complex into the EC category in 

the BSAI and GOA groundfish FMPs was based on the best available scientific 

information and was consistent with the revised National Standard 1 guidelines. 

However, the Federal rulemaking to implement the Council’s action prohibited the use or 

sale of incidentally caught squid unless processed into fish meal. The June 2017 Council 

action and supporting analyses indicated: 1) retention of squids would continue at or 

slightly above current levels, and 2) past production types would continue to be allowed 

including whole bait and whole fish/food fish. The purpose of this action is to align 

regulations with the long-standing use of squid, the permissible use of squid based on the 

Council’s June 2017 analysis and preferred alternative, and the permissible use of squid 

under the EC category. 

The Council’s recent recommendation to establish sculpins in the EC category would 

limit the use of sculpins consistent with existing regulations for all other EC category 

species (50 CFR 679.20(i)). The Council does not wish to increase the time required to 

move sculpins into the EC category by modifying that action, but intends to review the 

disposition of sculpins consistent with squids and the flexibility provided by the EC 

category. 

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1.2 History of this Action 

The MSA requires that each regional fishery management council develop annual catch limits (ACLs) 

and accountability measures (AMs) for each of its managed fisheries, such that each FMP under its 

jurisdiction has a mechanism for specifying ACLs at a level that overfishing does not occur in the fishery 

(16 U.S.C. 1853(a)(15)). The reauthorized MSA strengthened provisions to prevent and end overfishing 

and rebuild depleted fisheries. NMFS revised National Standard (NS) guidelines at 50 CFR part 600, to 

integrate these new requirements intended to reduce overfishing with existing provisions related to 

overfishing, rebuilding overfished stocks, and achieving optimum yield. On January 16, 2009, NMFS 

issued guidelines for NS (74 FR 3178). NMFS revised those 2009 final NS guidelines on October 18, 

2016 (81 FR 71858). Information in this document regarding the NS guidelines reflects the 2016 

revisions. 

Amendments 96 to the BSAI FMP and 87 to the GOA FMP established the EC category and designated 

prohibited species (defined in Table 2b to 50 CFR part 679, and includes salmon, steelhead trout, crab, 

halibut, and herring) and forage fish (as defined in Table 2c to 50 CFR part 679 and § 679.20(i)) as EC 

species in both the BSAI and GOA FMPs. 

Ecosystem component species (50 CFR 600.305(c)(5) & (d)(13) and 50 CFR 600.310(d)(1)) are stocks 

that a Council or the Secretary has determined do not require conservation and management, but desire to 

list in an FMP in order to achieve ecosystem management objectives. Retention and personal use of 

ecosystem species is allowed, subject to maximum retainable amount (MRA) limits. However current 

Federal regulations at 50 CFR 679.20(i) prohibit the processing and sale of ecosystem component species 

in Alaska unless they are processed as fishmeal. 

(i) Forage fish, grenadiers, and squids—(1) Definition. See Table 2c to 50 CFR part 679. 

(2) Applicability. The provisions of §679.20(i) apply to all vessels fishing for groundfish in the 

BSAI or GOA, and to all vessels processing groundfish harvested in the BSAI or GOA. 

(3) Closure to directed fishing. Directed fishing for forage fish, grenadiers, and squids is 

prohibited at all times in the BSAI and GOA. 

(4) Limits on sale, barter, trade, and processing. The sale, barter, trade, or processing of forage 

fish, grenadiers, and squids is prohibited, except as provided in paragraph (i)(5) of this section. 

(5) Allowable fishmeal production. Retained catch of forage fish, grenadiers, or squids not 

exceeding the maximum retainable amount may be processed into fishmeal for sale, barter, or 

trade. 

When Amendments 96/87 were passed by the Council, the stated intention was that prohibited species 

and forage fish would be in the new EC category, while retaining the current management regime for 

them1

. Because retention, processing, and sale of prohibited species and forage fish was not permitted 

before they were placed in the EC category, retention, processing, and sale was not permitted once they 

were in the EC category. The Council did not indicate whether or not they intended that any other species 

added to the EC category would also be excluded from processing and sale, or whether they intended that 

management measures in place for those species before being moved into the EC category would be 

retained. 

1 Page vi-vii Environmental Assessment for Amendment 96 to the Fishery Management Plan for Groundfish of the Bering Sea and 

Aleutian Islands Management Area and Amendment 87 to the Fishery Management Plan for Groundfish of the Gulf of Alaska to 

Comply with Annual Catch Limit Requirements. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 11 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

In 2015, the groundfish plan team recommended to the Council that consideration be given to moving 

squids to the EC. These recommendations from the plan teams were based on difficulty in establishing 

catch specifications for squid in both management areas and concerns that in the Eastern Bering Sea 

(EBS) pollock fishery, moving away from areas of squid incidental catch interfered with the fleet’s 

avoidance of Chinook and chum salmon and herring prohibited species catch (PSC). Assessment authors, 

the plan teams, and the Council’s Scientific and Statistical Committee (SSC) all agreed that it would be 

highly unlikely that catch levels at the time would result in conservation concerns for BSAI or GOA 

squids. 

In consideration of these recommendations, the Council took a series of actions. In 2015, the Council 

took initial action to move squids and sculpins into the EC in the FMPs for groundfish in the BSAI and 

GOA. However, final action was delayed after June 2016 to allow completion of revised National 

Standard guidelines. In June 2017, the Council took final action to move squids to the EC category in the 

BSAI and GOA (BSAI FMP Amendment 117, GOA FMP Amendment 106) 

In contrast to the Amendment 96/87 analysis, the Council was clear, in Amendment 117/106 in its 

intention when moving squids to the EC category. When describing the Alternative to move squids to the 

EC category, the analysis states the Council’s intention that “By prohibiting directed fishing, maintaining 

the MRA, and maintaining record keeping and reporting requirements, the status quo would effectively be 

maintained while precluding any significant increase in bycatch.” Further, in the analysis of impacts of 

Alternative 2, the RIR2 states that “Much of the retained catch of squid has been processed into whole 

bait and whole fish/food fish in the past, and these production types would likely continue to be processed 

under this option.” However, the final rule revised regulations at 679.20 (i)(5) to limit processing of 

squids into fishmeal, as was done for forage fish and grenadiers. The inclusion of squids in that paragraph 

negated the Council’s intent in the action to continue to allow processing and sale of squids as whole bait. 

At this time, the Council is reviewing whether to recommend revisions to allow processing and sale of 

squids and sculpins in any product form. 

In December 2018, the Council directed staff to produce a discussion paper evaluating the appropriate 

level of conservation and management required for sculpins in the BSAI and the GOA consistent with the 

MSA and NS guidelines. The Council’s motion directed staff to assess whether the best available 

scientific information indicates that sculpins could be managed as non-target species, specifically whether 

sculpins could be identified as “non-target ecosystem component species not in need of conservation and 

management.” 

In April 2019, the Council reviewed the discussion paper evaluating the appropriate level of conservation 

and management required for sculpins in the BSAI and GOA consistent with the MSA and NS guidelines. 

After review and public testimony, the Council initiated an analysis to designate sculpins in the BSAI and 

GOA as non-target, EC species. The Council took final action (BSAI FMP Amendment 121, GOA FMP 

Amendment 110) to move sculpins into the EC category in October 2019. During that analysis, staff 

noted that moving sculpins into the EC category would result in prohibitions on retention, processing, and 

sale of sculpins other than as fishmeal as is the case for all other EC species, including squid. Although 

the Council disagreed with the regulation prohibiting processing and sale of sculpins and squid, they 

chose to proceed with the change in status for sculpins. At the same meeting, the Council initiated this 

analysis to reconsider the processing and sale restrictions on squids and sculpins in the EC category. No 

2 2 Page 93 Secretarial Review Draft Environmental Assessment/Regulatory Impact Review for Proposed Amendment 117 (BSAI) 

and 106 (GOA) to the Fishery Management Plan for Groundfish of the Bering Sea and Aleutian Groundfish and Gulf of Alaska. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 12 
 

 

 

 

 

 

70°0'0"W 

......... . 

O ut s i de t h e 

E EZ = 690 

15o•o·o·w 

Central GOA: 

620 and 630 

Western GOA: 

610 

14o•o·o·w 

other species in the EC category are considered in this analysis, and processing and sale restrictions will 

remain in place for prohibited species, forage fish, and grenadiers under any of the alternatives. 

In February 2020, the Council reviewed the initial review draft of this analysis and reconfirmed its 

selection of Alternative 2 as the Preliminary Preferred Alternative. And in October 2020, the Council 

reviewed the final draft of this analysis and again reconfirmed its selection of Alternative 2 as the 

Preferred Alternative. 

1.3 Description of Management Area 

This action pertains to all management areas in the GOA (Figure 1-1) and BSAI (Figure 1-2). In both 

FMP areas, squids are managed in the EC category, and sculpins will be managed in the EC category if 

the FMP amendments and implementing regulations regarding sculpins are approved by the Secretary, 

which is anticipated to be effective in 2021. 

Figure 1-1 NMFS regulatory and reporting areas in the GOA3 

3 Figure 3 to 50 CFR 679 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 13 
 

0 E 1ao·w 11s·w 110°w 15s•w 15o•w 

524 . j ,)' ; · Chukchi Sea = 400 'O 

60°N -aov :··--.:- .--~· --------, . __ :_) __ _:__ 521 514 << lllil OO"N 

ss· N 

1,'1' ' 

. . : .. . :5s1r :·--'. . 

?~~ : : .. - - - ~ - - ·:-- --,- - -- - -·:·. -.. ' ' ' . ' I I ' I 

- - - ~ ... ~ ... ~ .. ..: .. -; --.:. - -

530 

0 

543 

542 

. 55' N 

.. ~ --<-. -- -----:- - ... --. - --. -. ---. 

,-. ------ ------ ' l __ ·- -~ -¥~--- -- - ' ' ' ' ' ' SO'N L--,:___.___..;__...._ ____ ....___.__~--------------..._-----_.__ __________ ...._ _ _ __ ____, 50'N 

175'E 

' ' 

1ao·w 175'W 170' W 165' W 160'W 

Figure 1-2 NMFS BSAI sub-areas for management4 

4 Figure 1 to 50 CFR 679 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 14 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2 Description of Alternatives 

The Council adopted the following alternatives for analysis in October 2019. Alternative 2 is the 

Preferred Alternative (PA). 

2.1 Alternative 1: Status quo. Squids and sculpins in both the BSAI and 

GOA FMPs are designated as non-target ecosystem component 

species with prohibition on the use of squids and sculpins other than

as fishmeal. 

Under Alternative 1, squids and sculpins remain in the EC category in the BSAI and GOA FMPs, 

establishment of OFL, ABC, and TACs are not required. Directed fishing for squids and sculpins is 

prohibited, and the squids and sculpins maximum retainable amount (MRA) when directed fishing for 

other groundfish species is 20%. The sale, barter, trade, or processing of squids and sculpins is prohibited, 

by regulation, except as fishmeal. Recordkeeping and reporting to monitor and report catch and discards 

of squids and sculpins annually is required. 

2.2 Alternative 2: Squids and sculpins in both the BSAI and GOA FMPs are 

designated as non-target “ecosystem component species”. Preferred 

Alternative. 

Under Alternative 2, squids and sculpins remain in the EC category in the BSAI and GOA FMPs, 

establishment of OFL, ABC, and TACs are not required. Directed fishing for squids and sculpins is 

prohibited, and the squids and sculpins MRA when directed fishing for other groundfish species is 20%. 

There is no prohibition, in regulation, on the sale, barter, trade, or processing of incidental, retained squids 

or sculpins. Recordkeeping and reporting to monitor and report catch and discards of squids and sculpins 

annually is required. 

2.3 Meeting the requirements for Ecosystem Component 

Section 302(h)(1) of the MSA requires a Council to prepare an FMP for each fishery under its authority 

that requires (or in other words, is in need of) conservation and management. NMFS has recently 

published guidelines to aid the Councils as they consider whether a stock requires conservation and 

management, and if so, how the Council s should meet the requirements of the National Standards (NS) in 

section 301(a) of the MSA. The NS general guidelines in 50 CFR 600.305(d) define how stocks should be 

classified in an FMP, and include descriptions of Target stocks, Non-target species and non-target stocks, 

and Ecosystem Component Species. The analyses for Amendments 117/106 (squid to EC) and 

Amendments 121/110 (sculpin to EC) provide detailed application of the NS guidelines for squids and 

sculpins, respectively, and readers are directed to those analyses for that detailed review. The following 

Table 2-1 and Table 2-2 summarize the application of the NS guidelines regarding squids and sculpins. 

If, at any time, the Council wishes to move one or more squid species from the Ecosystem Component 

category to one of the other, managed, categories it can do so by initiating another FMP amendment. For 

example, if the Council determined that viable commercial fishery for market squid became established in 

the Gulf of Alaska, they could initiate an FMP amendment to add market squid to the Target Stock 

category in the GOA Groundfish FMP. The normal analyses would be conducted on the alternatives 

developed by the Council. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 15 
 

 

 

 

 

 

 

 

 

 

 

Table 2-1 National Standard factors a Council should consider when deciding whether stocks require

conservation and management, and their relevance to sculpins in the BSAI and GOA. 

National Standard Factor5 Relevance to sculpins in Alaska 

i. The stock is an important component of the marine • Sculpins are predators of the shelf and slope 

environment. ecosystems in the BSAI and GOA. 

ii. The stock is caught by the fishery. • Sculpins are caught incidentally to other groundfish 

fisheries in the BSAI and GOA. 

iii. Whether a FMP can improve or maintain the • Sculpins are not experiencing overfishing and fishing 

condition of the stock related mortality is low in both the BSAI and GOA . 

• There is no directed fishing for sculpins in either the 

BSAI or GOA. 

• In the absence of directed fishing, sculpins are very 

unlikely to become overfished in either the BSAI or 

GOA. 

iv. The stock is a target of a fishery. • There is no directed fishing for sculpins in either the 

BSAI or GOA. 

v. The stock is important to commercial, recreational, • Sculpins are not considered important to commercial 

or subsistence users. or recreational users in either the BSAI or GOA; 

however, there is some limited ongoing use of sculpins 

for fish meal. There is also some limited use of 

sculpins for subsistence by Alaska Natives in the 

Norton Sound region. 

vi. The fishery is important to the Nation or to the 

regional economy. 

important to the National or regional economy. 

• Sculpins have limited economic value relative to other 

BSAI and GOA groundfish and are not considered 

vii. The need to resolve competing interests and • There is no directed fishing for sculpins in either the 

conflicts among user groups, and whether a FMP BSAI or GOA, no allocations to user groups, and no 

can further that resolution. competing interests or conflicts among user groups 

relative to sculpins. 

viii. The economic condition of a fishery and whether a 

FMP can produce more efficient utilization. 

• Sculpins have limited economic value relative to other 

BSAI and GOA groundfish. 

• Retention of sculpins has varied but is currently less 

than 5% in both the BSAI and GOA. 

ix. The needs of a developing fishery, and whether a • There is currently no developing fishery for sculpins in 

FMP can produce more efficient utilization. either the BSAI or GOA. 

• Existing FMPs could adequately manage any new 

fishery. 

x. The extent to which the fishery is already adequately 

managed by states, by state/Federal programs, or by 

Federal regulations pursuant to other FMPs or 

international commissions, or by industry selfregulation, consistent with the requirements of the 

• Currently, there is no directed fishing for sculpins in 

either the BSAI or GOA in state or Federal waters. 

MSA and other applicable law. 

5 50 CFR 600.305(c) 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 16 
 

 

 

 

 

 

Table 2-2 National Standard factors a Council should consider when deciding whether stocks require

conservation and management, and their relevance to squids in the BSAI and GOA. 

National Standard Factor6 Relevance to squids in Alaska 

i. The stock is an important component of the marine • Squids are important prey species for marine 

environment. mammals, fish, and other squid. 

ii. The stock is caught by the fishery. • Squids are caught incidentally in the BSAI and GOA 

groundfish fisheries 

iii. Whether a FMP can improve or maintain the • Squids are short lived and highly productive. 

condition of the stock • Bottom trawl surveys are considered substantial 

underestimates of true squid biomass in both the BSAI 

and GOA. 

• Fishing related mortality is low compared with 

estimated predation mortality in food web models. 

• Squid are unlikely to become overfished in the 

absence of a directed fishery. 

iv. The stock is a target of a fishery. • There is no directed fishing for squids in either the 

BSAI or GOA. 

v. The stock is important to commercial, recreational, • Squids are not considered important to commercial, 

or subsistence users. recreational, or subsistence users. 

vi. The fishery is important to the Nation or to the 

regional economy. 

important to the Nation or to the regional economy. 

• Squids have limited economic value relative to many of 

the BSAI and GOA groundfish, and are not considered 

vii. The need to resolve competing interests and • There is no directed fishery for squids, no allocations, 

conflicts among user groups, and whether a FMP and no conflicts for an FMP to resolve. 

can further that resolution. 

viii. The economic condition of a fishery and whether a 

FMP can produce more efficient utilization. 

• There is no directed fishing for squids in either the 

• Squids have limited economic value relative to many of 

BSAI or GOA. 

the BSAI and GOA groundfish. 

ix. The needs of a developing fishery, and whether a • There is currently no developing fishery for squids in 

FMP can produce more efficient utilization. either the BSAI or GOA. 

• Market squids have been seen in Southeast Alaska 

and may become fishable in the future. 

• Existing FMPs could adequately manage any new 

fishery. 

x. The extent to which the fishery is already adequately 

managed by states, by state/Federal programs, or by 

Federal regulations pursuant to other FMPs or 

international commissions, or by industry selfregulation, consistent with the requirements of the 

• Currently, there is no directed fishing for squids in 

either the BSAI or GOA in state or Federal waters. 

MSA and other applicable law. 

2.4 Comparison of Alternatives 

Because squids are already in the EC category, and the Council took final action to move sculpins into the 

EC category in October 2019, the only real difference in these alternatives is the allowance for processing 

and sale of squids and sculpins as either fishmeal only (Alt 1) or without the fishmeal-only regulation (Alt 

2). Table 2-3 provides a summary of the two alternatives considered in this action. 

6 50 CFR 600.305(c) 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 17 
 

 

 

 

 

 

 

 

 

Table 2-3 Summary of Management Measures in Alternatives 1 and 2 

Management Alt 1- No Action Alt 2 – No Processing Restrictions Measure 

Prohibit Yes Yes 

Directed Prohibit directed fishing in regulations at Prohibit directed fishing in regulations at 

Fishing 679.20(i) 679.20(i) 

Yes Yes Retention and Retention and sale allowed as fishmeal Retention and sale as any product form Sale only, subject to MRA limits. allowed, subject to MRA limits. 

No No 

- Periodic reports on biomass - Periodic reports on biomass Annual information from current surveys information from current surveys will Harvest will be included in the SAFE be included in the SAFE Specifications - Catch does not accrue to - Catch does not accrue to optimum 

optimum yield cap yield cap 

Incidental Yes Yes 

Catch MRA = 20% for all basis species MRA = 20% for all basis species 

Management 

Yes Yes 

Recordkeeping Require catch reporting Require catch reporting 

and Reporting 

2.5 Rationale for Council’s Preferred Alternative 

This section summarizes the Council’s rationale for its recommendation of the PA compared to the no 

action alternative. This action would help to prevent waste of squid and sculpins bycatch as well as 

reducing the need for import costs for bait. This action would align regulations with the longstanding use 

of squid bycatch as bait. The majority of vessels in the non-pollock federal groundfish fisheries in the 

BSAI, as well as some in the GOA, are responsible for a very small proportion of the reported squid catch 

and a larger proportion (around 50%) of the reported sculpin catch. Only one of the vessels in the BSAI 

and GOA has the capability to process fish into fishmeal, and continuing to prohibit other product forms 

for sculpins would effectively prevent vessels from finding opportunities for sculpin products in the 

future to reduce waste. 

In taking final action, the Council noted that the purpose of the action is to allow the processing and sale 

of squid and sculpins as products other than fishmeal and to help prevent waste of the incidental catch of 

these species. The Council took final action and selected its PA at the October 2020 meeting. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 18 
 

 

 

 

 

 

 

 

 

 

 

3 Biological and Fishery information 

3.1 Squids 

3.1.1 Squid status and role in the ecosystem 

Squid are marine mollusks in the class Cephalopoda (Group Decapodiformes). They are streamlined 

animals with ten appendages (2 tentacles, 8 arms) extending from the head, and lateral fins extending 

from the rear of the mantle. Squids are active predators which swim by jet propulsion. Squids are 

important components in the diets of many seabirds, fish, and marine mammals, as well as voracious 

predators, themselves, on zooplankton and larval fish (Caddy 1983, Sinclair et al. 1999). In the BSAI and 

GOA, squids can be found at depths from 10 m to greater than 1500 m. The vertical distribution of squids 

make some species more available for mammal and seabird predators, and for surveys and fisheries using 

bottom trawls. 

In the BSAI and GOA regions there are at least 15 species of squids (Table 3-1). The most abundant 

species is Berryteuthis magister. All but one, Rossia pacifica (North Pacific bobtail squid), are pelagic but 

B. magister and Gonatopsis borealis (boreopacific armhook squid) are often found near the bottom. The 

vertical distribution of these three species is the probable cause of their predominance in the NMFS 

bottom trawl surveys relative to other squid species, although no squid species appear to be well-sampled 

by NMFS surveys. Most species are associated with the slope and basin, with the highest species diversity 

along the slope region of the Bering Sea between 200 – 1500 m. Since most of the data come from 

groundfish survey bottom trawls, the information on abundance and distribution of those species 

associated with the bottom is much more accurate than that of the pelagic species (Ormseth, 2016b). 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 19 
 

 

 

 

 

 

 

 

Table 3-1. Squids present in the BSAI and GOA. 

Class Cephalopoda; Order Oegopsida 

Family Chiroteuthidae 

Chiroteuthis calyx 

Family Cranchiidae Glass squid 

Belonella borealis 

Galiteuthis phyllura 

Family Gonatidae Armhook squid 

Berryteuthis anonychus Minimal armhook squid 

Berryteuthis magister Magistrate armhook squid 

Eogonatus tinro 

Gonatopsis borealis Boreopacific armhook squid 

Gonatus berryi Berry armhook squid 

Gonatus madokai 

Gonatus middendorffi 

Gonatus onyx Clawed armhook squid 

Family Onychoteuthidae Hooked squid 

Moroteuthis robusta Robust clubhook squid 

Onychoteuthis borealijaponicus Boreal clubhook squid 

Class Cephalopoda; Order Sepioidea 

Rossia pacifica North Pacific bobtail squid 

Class Cephalopoda; Order Myopsida 

Family Loliginidae 

Doryteuthis opalescens Market squid 

As Alaskan waters are warming, market squid (Doryteuthis opalescens) are beginning to appear in GOA 

waters that were previously considered too cold for them (Table 3-1). They have been observed spawning 

in southeast Alaska since at least 20157

. The Alaska Department of Fish and Game (ADF&G) does not do 

any kind of stock assessment on the amount of squid in southeast Alaska waters, so the numbers of 

market squid are not known. 

In contrast to most of the squid in the BSAI and GOA which are not desired for human consumption, 

Market squid are a saleable eating squid and there is an active fishery for these squid in California, which 

is managed by the California Fish and Game Commission. There is no developed fishery for market squid 

fishery in Alaska. In Southeast Alaska, ADF&G has authorized exploratory fishing for market squid 

under the conditions of a Commissioner’s Permit. A proposal was submitted to the Alaska Board of 

Fisheries (BOF) in 2017 to open a state purse seine market squid fishery. The proposal failed at the BOF, 

in part, because of concerns about bycatch of declining king salmon stocks and a general lack of data on 

market squid in Alaska. 

To date, there has not been any interest in directed fishing for the more common species of squid in 

Alaskan waters since they are not desired for human consumption. Some incidentally-caught squid are 

sold as bait. However, should market squid at some point be considered abundant enough to support a 

7 https://www.seattletimes.com/nation-world/alaska-board-receives-proposal-for-southeast-squid-fishery/ 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 20 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Federal fishery, or should markets develop for any other squid species in the BSAI or GOA, the Council 

could consider the appropriate category for them in the BSAI or GOA FMPs. Moving market squid or 

any other squid species back into the targeted category from the ecosystem category would require 

another FMP amendment, and the requisite analysis. 

3.1.2 Life History 

The life histories of squids in the BSAI and GOA are almost entirely unknown (Ormseth, 2016b). Of all 

the species, only Rossia pacifica has benthic larvae and only members of the family Gonatidae and 

Cranchiidae are known to spawn in the Bering Sea region. 

Life history information for BSAI squid can be inferred from data on squid species elsewhere. Relative to 

most groundfish, squid are highly productive, short-lived animals. They display rapid growth, patchy 

distribution and highly variable recruitment (O'Dor, 1998). Unlike most fish, squid may spend most of 

their life in a juvenile phase, maturing late in life, spawning once, and dying shortly thereafter. Many 

squid populations are composed of spatially segregated schools of similarly sized individuals, which may 

migrate, forage, and spawn at different times of year over a wide geographic area (Lipinski 1998; O’Dor 

1998). Most information on squid refers to Illex and Loligo species which support commercial fisheries in 

temperate and tropical waters. Of North Pacific squid, life history is best described for western Pacific 

stocks (Arkhipkin et al., 1995; Osako and Murata, 1983). 

The most commercially important squid in the north Pacific is the magistrate armhook squid, Berryteuthis 

magister. This species is distributed from southern Japan throughout the Bering Sea, Aleutian Islands, and 

Gulf of Alaska to the U.S. west coast as far south as Oregon (Roper et al. 1984). A study completed in 

2008 investigated life history and stock structure of this species in the EBS (Drobny 2008). In the EBS, B. 

magister appear to have an approximately 1-year life cycle. B. magister in the EBS appear to grow and 

mature more quickly than their conspecifics in Russian and Japanese waters. Squid growth appears to be 

heavily influenced by ocean temperature (Forsythe 2004), which may account for some of the regional 

and temporal variability. 

Populations of B. magister and other squid are complex, being made up of multiple cohorts spawned 

throughout the year. B. magister are dispersed during summer months in the western Bering Sea, but form 

large, dense schools over the continental slope between September and October. Three seasonal cohorts 

are identified in the region: summer-hatched, fall-hatched, and winter-hatched. Growth, maturation, and 

mortality rates vary between seasonal cohorts, with each cohort using the same areas for different portions 

of the life cycle. Juvenile and adult B. magister also appear to be separated vertically in the water column. 

3.1.3 Trawl survey biomass estimates and distribution 

The AFSC bottom trawl surveys are directed at groundfish species, and therefore do not employ the 

appropriate gear or sample in the appropriate places to provide reliable biomass estimates for most squid, 

which are generally pelagic or, if demersal, reside off bottom. The largest biomass of squid is found at 

depths below 200 m (Horne and Parker-Stetter 2010). Catches of squid in the EBS shelf survey are highly 

variable and coefficients of variation are high, and it is likely that few squid inhabit the bottom waters of 

the shelf (Ormseth, 2016b). The EBS slope survey, which samples the shelf break area and much deeper 

waters, generally catches greater numbers of squid (Table 3-2), although again coefficients of variation 

are high. Berryteuthis magister, G. borealis, and R. pacifica are the most common squid in the slope 

survey (Ormseth, 2015b). In the Aleutian Islands (AI), B. magister is the only squid species captured in 

abundance (Table 3-2). The latest estimates of squid biomass in the BSAI were reported in 2016 

(Ormseth 2016). Squid are now reported in the Forage Fish update (e.g., Ormseth 2019), and the latest 

update includes information about bycatch, but does not contain an updated biomass estimate. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 21 
 

 

 

 

 

 

 

I I I 

Biomass estimates for the GOA have fluctuated considerably since 1984, with the 2015 biomass estimate 

(14,079 t) the highest ever observed (Table 3-3; Ormseth, 2017). The survey also almost certainly 

underestimates squid biomass. For example, a mass-balance ecosystem model of the GOA estimates the 

squid population at 369,309 mt (Ormseth, 2016a). The latest biomass estimates for squids in the GOA 

were reported in 2017 (Ormseth 2017). 

Squid records from these surveys tend to appear at the edges of the continental shelf in the eastern Bering 

Sea and in the Aleutian Islands. This is consistent with results from 1988 and 1989 Japanese / U.S. 

pelagic trawl research surveys in the EBS that indicated that the majority of squid biomass is distributed 

in pelagic waters off the continental shelf (Sinclair et al. 1999), beyond the current scope of the AFSC 

surveys. It is also consistent with the observation that the largest biomass of squid is found at depths 

below 200 m (Horne and Parker-Stetter 2010). 

Table 3-2 Survey biomass estimates (“bio” in metric tons) and coefficients of variation (CV) of squids for the 

EBS Shelf, EBS Slope, and AI. Estimates are included for the principal species caught in each 

survey. Numerous species occur on the slope and are included in the “total squid” category for 

that region. From Ormseth, 2016a. 

EBS Shelf 

B. 

R. pacifica magister 

bio CV bio CV 

EBS Slope 

G. 

R. pacifica B. magister borealis 

bio CV bio CV bio CV 

AI 

Misc. 

B. magister squid 

bio CV bio CV 

2000 13 0.45 42 0.82 2758 0.18 

2001 20 0.51 280 0.42 

2002 33 0.36 0 52 0.18 1,197 0.12 2 0.74 2,088 0.14 18 0.27 

2003 27 0.37 16 1.00 

2004 6 0.82 0 28 0.19 1,418 0.14 52 0.37 3,2501 0.37 14 0.78 

2005 13 0.67 0 

2006 9 0.74 47 1.00 1,467 0.14 

2007 11 0.71 0 

2008 8 0.52 0 35 0.33 1,675 0.10 5 0.41 22 0.26 

2009 9 0.41 623 1.00 

2010 42 0.60 9 1.00 67 0.25 1,831 0.10 8 0.32 2,444 0.22 17 0.36 

2011 25 0.51 1 1.00 

2012 25 0.43 43 1.00 42 0.23 1,284 0.09 13 0.40 4,011 0.28 7 0.33 

2013 146 0.84 28 1.00 

2014 24 0.49 0 6,178 0.30 

2015 91 0.40 61 0.66 

2016 41 0.52 7 1.00 29 0.30 1,127 0.20 7 0.30 3,808 0.38 7 0.33 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 22 
 

 

 

 

 

 

 

 

 

 

 

Table 3-3 Biomass estimates and coefficient of variation (CV) of squid species from NMFS GOA bottom trawl

surveys, 1984-2017. From Ormseth 2017. 

Miscellaneous squid B. magister All squid 

Year Biomass(t) CV Biomass(t) CV Biomass(t) CV 

1984 546 0.35 2762 0.15 3308 0.14 

1987 577 0.30 4,506 0.34 5,083 0.30 

1990 276 0.43 4,033 0.17 4,309 0.16 

1993 1,029 0.73 8,447 0.13 9,476 0.14 

1996 26 0.28 4,884 0.14 4,911 0.14 

1999 254 0.46 1,873 0.13 2,127 0.13 

2001 703 0.62 5,909 0.30 6,612 0.27 

2003 71 0.23 6,251 0.18 6,322 0.18 

2005 249 0.51 4,654 0.18 4,903 0.18 

2007 359 0.49 11,681 0.20 12,040 0.20 

2009 188 0.61 8,415 0.16 8,603 0.16 

2011 392 0.65 4,040 0.13 4,431 0.14 

2013 568 0.80 9,675 0.16 10,243 0.16 

2015 387 0.65 13,692 0.12 14,079 0.12 

2017 253 0.51 2,042 0.15 2,296 0.15 

3.1.4 Harvest specifications 

Establishing harvest specifications for squid before they were placed in the EC category was problematic 

because reliable biomass estimates for squids currently do not exist. Furthermore, squid are not the target 

of any directed fishery but are caught incidentally. Biomass estimation is further complicated by their 

short-life history. Because of these complications, squid were assessed as a Tier 6 species in the BSAI 

and GOA before they were placed in the EC category in both FMPs in 2018. The status of squids is now 

reported to the Plan Teams every other year, as part of the forage species report. 

Because historical catch has been used to estimate a sustainable level before squids were moved to the EC 

category, there is very little certainty in the abundance of squids in the BSAI or GOA. This also makes it 

difficult to estimate the proportion of the population that has been or may be caught incidentally to 

targeted species fisheries. However, the analysis for Amendment 117 to the BSAI FMP and 106 to the 

GOA FMP that moved squids to the EC category in the BSAI and GOA assumed that conditions and 

incidental catch would remain similar to past patterns, and that future catch would be unlikely to result in 

harm to the squid stocks in the BSAI and GOA. 

3.1.5 Catch and retention 

Squids are EC species that are caught incidentally in prosecution of groundfish fisheries in the BSAI and 

GOA. In both the BSAI and GOA, the vast majority of squids are caught in the pollock fisheries. Catch of 

squid in other target species fisheries is minimal (Table 3-4, Table 3-5). 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 23 
 

 

 

 

 

 

 

Table 3-4 Squid catch (mt) and total retained (mt) by target species fishery in the BSAI 2009 – 2019 

Target Catch Retained 

Arrowtooth flounder 547 4 

Atka mackerel 160 2 

Flathead sole 41 0 

Greenland turbot 129 0 

Kamchatka flounder 343 1 

Other flatfish 20 0 

Pacific cod 6 0 

Pollock 15,414 6,962 

Rock sole 8 0 

Rockfish 410 2 

Sablefish 9 0 

Yellowfin sole 2 0 

BSAI total 17,080 6,971 

Source: AKFIN August 7, 2020 

Table 3-5 Squid catch (mt) and total retained (mt) by target species fishery in the GOA 2009 - 2019 

Target Catch Retained 

Arrowtooth flounder 134 3 

Deep water flatfish 1 0 

Flathead sole 2 0 

Pacific cod 3 3 

Pollock 1,588 1,447 

Rex sole 8 0 

Rockfish 172 5 

Sablefish 9 0 

Shallow water flatfish 1 0 

GOA Total 1,918 1,458 

Source: AKFIN August 7, 2020 

Total squid catch in 2019 in the BSAI is 5,928 mt, and 63 mt in the GOA. The squid catch in the BSAI is 

more than twice the previous high catch in the modern era (2.364 mt in 2015) and is the highest catch 

since 1981. The majority of the squid catch in 2019 occurred in the vicinity of Bering Canyon (Ormseth 

2019) in the pollock fishery. There are likely a number of factors that contributed to the higher than 

expected squid catch in 2019, including potentially increased squid biomass, spatial distribution of squid 

in the EBS, reduced incentive for the pollock fleet to avoid squids, and limitations on the pollock fleet to 

avoid salmon and sablefish in 2019. In addition, there was some confusion regarding the allowable use of 

squids and some squids were retained for sale as bait despite the limitation of processing to fishmeal only, 

at least until NMFS became aware of the practice and informed the processors (M. Furuness, NMFS, 

personal communication). Estimated squid catch through 7 July, 2020 is 260 mt in the BSAI and 101 mt 

in the GOA. This appears to be similar to catch in recent years. 

Current management of squids in the ecosystem component, with processing restricted to fish meal, is an 

effective conservation measure because, while it lacks catch limits that would otherwise prevent 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 24 
 

 

 

 

 

 

 

 

overfishing, limits on retention and processing provide disincentives to avoid large incidental catches. 

Concern has been raised that removing the processing limitation on squids will remove disincentives to 

avoid large incidental catches and may contribute to increased catches of squids in the future. These 

concerns are recognized in this action with retention of the catch limitation of a 20% MRA. 

3.2 Sculpins 

3.2.1 Sculpins status and role in the ecosystem 

Sculpins are relatively small, demersal, teleost fishes with modified pectoral fins that allow them to grip 

the substrate, and they lack swim bladders. They consist of four diverse families off Alaska (Cottidae, 

Hemitripteridae, Psychrolutidae, and Rhamphocottidae). Sculpins are found in both freshwater and 

marine habitats, and are distributed throughout the BSAI and GOA where they occupy all benthic habitats 

along continental shelf and slope areas. Sculpins occupy depths from nearshore sand and mud bottoms at 

20 m to below 1,000 m along broad sloping and steep canyon areas. Sculpins range in size from less than 

10 cm to 80 cm, and size differences may reflect their varied roles in the ecosystem. 

Sculpins are predators of the shelf and slope ecosystems (TenBrink and Aydin 2009), consuming a wide 

variety of benthic prey including commercially important crabs and fishes. Larger sculpin species prey on 

shrimp, crabs, and fishes including juvenile walleye pollock. Smaller sculpin species feed mainly on 

shrimp and benthic amphipods. 

3.2.2 EBS and AI Survey 

The five most abundant species of sculpin from the EBS shelf survey are measured annually: plain and 

great sculpin since 1998, warty and bigmouth sculpin since 2000, and yellow Irish lord since 2003. Size 

compositions of blob, bigmouth, spinyhead, and darkfin sculpin are measured on the slope survey, and 

size compositions of bigmouth yellow Irish lord, and great sculpin are measured on the AI survey. 

Research surveys provide biomass estimates for sculpin species in the BSAI. All three regions of the 

BSAI (EBS shelf, EBS slope, and AI) were sampled in 2004, 2010, 2012, and 2016 (Figure 3-1). The 

EBS shelf survey is performed annually, and the AI and slope surveys are typically biennial, although 

there was no AI survey in 2008 and no slope survey in 2014. The low coefficient of variation for most of 

the biomass estimates of the more abundant species suggests that the EBS shelf bottom trawl survey 

adequately estimates the biomass of these species (Spies et al. 2016). 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 25 
 

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Figure 3-1 Random effects model estimates of biomass by region for the six most common shelf

sculpins (top), slope (middle), and Aleutian Islands (bottom). Error bars represent 95%

confidence intervals for survey estimates of biomass, and dotted lines represent 95%

confidence intervals from the random effects model. From Spies et al. 2016. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 26 
 

 

 

 

 

 

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3.2.2.1 GOA Survey 

Aggregate sculpin biomass estimates in the GOA are derived from the GOA bottom trawl surveys (Figure 

3-2). In the GOA, approximately 97% of the sculpin biomass is comprised of the larger sculpin species: 

great, plain, bigmouth, and yellow Irish lord. Yellow Irish lord is currently the most abundant (59% of all 

sculpin biomass) followed by great sculpin (23%), bigmouth sculpin (14%), and plain sculpin (4%). The 

low coefficients of variation for the survey biomass estimates of the four most abundant species suggest 

that the GOA survey is doing an adequate job assessing the biomass of the more abundant species (Spies 

et al. 2017). 

Figure 3-2 Random effects model estimates of biomass for the five most common sculpins in the GOA

complex. Error bars represent 95% confidence intervals for survey estimates of biomass, and

dotted lines represent 95% confidence intervals from the random effect model. From Spies et 

al. 2017. 

3.2.2.2 Fishery Catch 

Sculpins are currently taken only as bycatch while directed fishing for other target species in the BSAI 

and GOA (Spies et al. 2016). Since 2011, the sculpin complex total catch (retained and discarded) has 

ranged from 2% to 6% of the total estimated sculpin biomass in the BSAI and GOA (Table 3-6). 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 27 
 

 

I 

I 

I 

I 

I I 

I I 

I I 

I I 

Table 3-6 Biomass (Random effects model estimate), total allowable catch (TAC), acceptable biological

catch (ABC), Overfishing Limit (OFL), catch of the BSAI (top) and GOA (bottom), and 

catch/biomass ratio for the sculpin complex 2011 to 2019. *Catch estimated through February 

2019. 

Year Biomass (mt) OFL (mt) 

BSAI 

ABC (mt) TAC (mt) Catch (mt) Catch/Biomass 

2011 199,348 58,300 43,700 5,200 5,377 0.03 

2012 183,942 58,300 43,700 5,200 5,798 0.03 

2013 171,523 56,400 42,300 5,600 5,864 0.03 

2014 189,359 56,400 42,300 5,600 4,902 0.03 

2015 186,386 52,365 39,725 4,700 5,003 0.03 

2016 199,937 52,365 39,725 4,500 4,911 0.02 

2017 188,656 56,582 42,387 4,500 5,338 0.03 

2018 188,656 53,201 39,995 5,000 5,105 0.03 

2019 188,656 53,201 39,995 5,000 5,420 0.03 

Year Biomass (mt) OFL(mt) ABC(mt) 

GOA 

TAC (mt) Catch (mt) Catch/Biomass 

2011 33,729 7,328 5,496 5,496 774 0.02 

2012 34,112 7,641 5,731 5,731 794 0.02 

2013 34,500 7,641 5,731 5,731 1,964 0.06 

2014 35,155 7,448 5,569 5,569 1,182 0.03 

2015 35,823 7,448 5,569 5,569 1,018 0.03 

2016 34,340 7,338 5,591 5,591 1,330 0.04 

2017 32,918 7,338 5,591 5,591 1,316 0.04 

2018 34,943 6,958 5,301 5,301 610 0.02 

2019 33,124 6,958 5,301 5,301 603 0.02 

Source: NMFS AKRO Catch Accounting System, accessed 12/18/2019 

If Amendments 121 to the BSAI FMP and 110 to the GOA FMP are approved by the Secretary, ABC, 

OFL, and TAC will not be identified for sculpins in either the BSAI or GOA. If approved, Amendments 

121/110 are not expected to have any effect on total catch of sculpins since sculpins are not targeted or 

marketed, and are only caught incidentally. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 28 
 

 

Table 3-7 Total retained catch in metric tons (mt) of all sculpins by target fishery in the BSAI, 2010– 2019. 

Target fishery 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 

Yellowfin Sole - BSAI 81 110 93 57 43 8 13 8 9 6 

Pollock - midwater 28 53 46 30 20 50 41 27 10 8 

Pollock - bottom 44 68 68 37 24 2 8 2 0 1 

Rock Sole - BSAI 3 3 1 1 3 3 2 0 37 3 

Pacific Cod 0 1 0 0 0 0 1 0 7 1 

Rockfish 0 1 0 0 0 0 0 1 0 1 

Flathead Sole 3 0 1 0 1 1 0 1 0 1 

Arrowtooth Flounder 1 0 0 1 0 0 0 1 0 0 

Atka Mackerel 2 0 0 0 0 0 1 2 2 1 

Alaska Plaice - BSAI 0 0 0 0 0 0 0 0 0 0 

Total (t) 163 235 210 126 91 64 67 42 66 21 

Source: AKFIN, accessed August 7, 2020 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 29 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

4 Regulatory Impact Review 

This Regulatory Impact Review examines the benefits and costs of proposed alternatives limiting 

processing and sale of squids and sculpins as part of the Ecosystem Component category in the Fishery 

Management Plan for Groundfish of the Bering Sea and Aleutian Islands Management Area (BSAI FMP) 

and the Fishery Management Plan for Groundfish of the Gulf of Alaska (GOA FMP). The RIR also 

assesses the potential impact of the alternatives on fishing communities and addresses other social 

impacts, if there are social impacts distinct from the economic impacts. In the case of this RIR, the 

potential impacts are primarily economic in nature. Analysts did not identify any impacts that would 

create adverse economic impacts on any fishing community or cause any other adverse social impacts. 

The preparation of an RIR is required under Presidential Executive Order (E.O.) 12866 (58 FR 51735, 

September 30, 1993). The requirements for all regulatory actions specified in E.O. 12866 are summarized 

in the following Statement from the E.O.: 

In deciding whether and how to regulate, agencies should assess all costs and benefits of 

available regulatory alternatives, including the alternative of not regulating. Costs and 

Benefits shall be understood to include both quantifiable measures (to the fullest extent 

that these can be usefully estimated) and qualitative measures of costs and benefits that 

are difficult to quantify, but nevertheless essential to consider. Further, in choosing 

among alternative regulatory approaches agencies should select those approaches that 

maximize net benefits (including potential economic, environmental, public health and 

safety, and other advantages; distributive impacts; and equity), unless a statute requires 

another regulatory approach. 

E.O. 12866 requires that the Office of Management and Budget review proposed regulatory programs that 

are considered to be “significant.” A “significant regulatory action” is one that is likely to: 

• Have an annual effect on the economy of $100 million or more or adversely affect in a material 

way the economy, a sector of the economy, productivity, competition, jobs, the environment, 

public health or safety, or State, local or tribal governments or communities; 

• Create a serious inconsistency or otherwise interfere with an action taken or planned by another 

agency; 

• Materially alter the budgetary impact of entitlements, grants, user fees, or loan programs or the 

rights and obligations of recipients thereof; or 

• Raise novel legal or policy issues arising out of legal mandates, the President’s priorities, or the 

principles set forth in this E.O. 12866. 

4.1 Statutory Authority 

Under the MSA (16 U.S.C. 1801, et seq.), the United States has exclusive fishery management authority 

over all marine fishery resources found within the exclusive economic zone (EEZ). The management of 

these marine resources is vested in the Secretary and in the regional fishery management councils 

(Councils). In the Alaska Region, the Council has the responsibility for preparing fishery management 

plans (FMPs) and FMP amendments for the marine fisheries that require conservation and management, 

and for submitting its recommendations to the Secretary. Upon approval by the Secretary, NMFS is 

charged with carrying out the Federal mandates of the Department of Commerce with regard to marine 

and anadromous fish. 

Squids and sculpin harvests in the EEZ off Alaska are managed under the FMPs for Groundfish of the 

BSAI and GOA. The proposed action would amend Federal regulations at 50 CFR 679. Actions taken to 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 30 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

amend FMPs or implement other regulations governing these fisheries must meet the requirements of all 

applicable Federal laws, Executive Orders, and regulations. 

4.2 Purpose and Need for Action 

The Council adopted the following updated purpose and need statement in February 2020. 

Squid is defined in the ecosystem component (EC) category in the FMPs for groundfish 

in the BSAI and GOA. The Council, in October 2019, took action to recommend that 

sculpins be defined in EC category in the BSAI and GOA as well. There are no directed 

fisheries for squid or sculpins in either the BSAI or GOA. Incidental catch of squid is 

retained in some fisheries and often utilized to prevent waste. Typically, sculpins are not 

retained but can be in some circumstances. 

The Council’s June 2017 action to reclassify the squid complex into the EC category in 

the BSAI and GOA groundfish FMPs was based on the best available scientific 

information and was consistent with the revised National Standard 1 guidelines. 

However, the Federal rulemaking to implement the Council’s action prohibited the use or 

sale of incidentally caught squid unless processed into fish meal. The June 2017 Council 

action and supporting analyses indicated: 1) retention of squids would continue at or 

slightly above current levels, and 2) past production types would continue to be allowed 

including whole bait and whole fish/food fish. The purpose of this action is to align 

regulations with the long-standing use of squid, the permissible use of squid based on the 

Council’s June 2017 analysis and preferred alternative, and the permissible use of squid 

under the EC category. 

The Council’s recent recommendation to establish sculpins in the EC category would 

limit the use of sculpins consistent with existing regulations for all other EC category 

species (50 CFR 679.20(i)). The Council does not wish to increase the time required to 

move sculpins into the EC category by modifying that action, but intends to review the 

disposition of sculpins consistent with squids and the flexibility provided by the EC 

category. 

4.3 Alternatives 

Alternative 1: Status quo. Squids and sculpins in both the BSAI and GOA FMPs are designated as 

non-target ecosystem component species with prohibition on the use of squids and sculpins other 

than as fishmeal. 

Under Alternative 1, establishment of OFL, ABC, and TACs are not required. Directed fishing for squids 

and sculpins is prohibited, by regulation, and the squids and sculpins maximum retainable amount when 

directed fishing for other groundfish species is 20%. The sale, barter, trade, or processing of squids and 

sculpins is prohibited, by regulation, except as fishmeal. Recordkeeping and reporting to monitor and 

report catch and discards of squids and sculpins annually is required. 

Alternative 2: (Preferred Alternative) Squids and sculpins in both the BSAI and GOA FMPs are 

designated as non-target “ecosystem component species”. 

Under Alternative 2, establishment of OFL, ABC, and TACs are not required. Directed fishing for 

squids and sculpins is prohibited, by regulation, and the squids and sculpins maximum retainable 

amount when directed fishing for other groundfish species is 20%. There is no prohibition, in 

regulations, on the sale, barter, trade, or processing of incidental, retained squids or sculpins. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 31 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Recordkeeping and reporting to monitor and report catch and discards of squids and sculpins 

annually is required. 

Because squids are already in the EC category, and the Council took final action to move sculpins into the 

EC category in October 2019, the only real difference in these alternatives is the allowance for processing 

and sale of squids and sculpins as either fishmeal only (Alt 1) or without the fishmeal only regulation (Alt 

2). 

4.4 Methods for analysis of impacts 

The evaluation of impacts in this analysis is designed to meet the requirements of E.O. 12866, which 

dictates that an RIR evaluate the costs and benefits of the alternatives, to include both quantifiable and 

qualitative considerations. The analysis should provide information for decision makers “to maximize net 

benefits (including potential economic, environmental, public health and safety, and other advantages; 

distributive impacts; and equity), unless a statute requires another regulatory approach.” The costs and 

benefits of this action with respect to these attributes are described in the sections that follow, comparing 

the No Action Alternative 1 with the action alternative (Alternative 2). A qualitative assessment of the net 

benefits to the Nation of the action alternative compared to no action is also provided. 

This analysis was prepared using data from NMFS’ catch accounting system, which are the best available 

data to estimate total catch in the groundfish fisheries off Alaska. Total catch estimates are generated 

from information provided through an extensive fisher observation program. In 2003, NMFS changed the 

methods used to determine catch estimates from the NMFS blend database (1995-2002) to the catch 

accounting system (2003-present). 

The catch accounting system was implemented to better meet the increasing information needs of 

fisheries scientists and managers. Currently, the catch accounting system relies on data derived from a 

mixture of production and observer reports as the basis of the total catch estimates. The 2003 

modifications in catch estimation included providing more frequent data summaries at finer spatial and 

fleet resolution, and the increased use of observer data. Redesigned observer program data collections 

were implemented in 2008, and include recording sample-specific information in lieu of pooled 

information, increased use of systematic sampling over simple random and opportunistic sampling, and 

decreased reliance on observer computations. As a result of these modifications, NMFS is unable to 

recreate blend database estimates for total catch and retained catch after 2002. Therefore, NMFS is not 

able to reliably compare historical data from the blend database to the current catch accounting system. 

4.5 Description of Fisheries 

4.5.1 Squid 

Before 2019, squid were managed in the fishery as target species in the BSAI and GOA Groundfish 

FMPs. Amendments 117/106 (83 FR 13117) moved squids to the non-target EC category and removed 

the requirements to produce OFL and ABC for squids in either FMP. Most of the information in this 

section summarizes the harvest before squids were moved to the EC category, although 2019 total catch is 

also reported. Detailed data on the amount of squid retained, and the disposition of those squid, will not 

be available until fish ticket and Commercial Operator Annual Report (COAR) data are available later in 

2020. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 32 
 

 

 

 

 

 

 

 

 

4.5.1.1 Recent Harvests 

Squid in the BSAI and GOA were previously managed as a single stock complex that included all known 

squid species in the management area. Although no directed fishery for squid existed, they were caught 

and retained as bycatch in sufficiently large numbers that they were managed as target species. 

Harvest in the BSAI from 2009 – 2013 was less than 1,000 mt (Table 4-1), but increased substantially 

from 2014 – 2018, the last year that squid were managed as a target group. Remarkably, in 2019 squid 

catch in the BSAI increased greatly to 5,931 mt, which is more than twice the previous high in 2015, and 

the highest level since 1981. It is difficult to determine the reasons for the dramatic increase in squid 

catch in the BSAI, but may include an increase in squid abundance in the BSAI, release from the fleet’s 

necessity to avoid squids, increased encounters with squids as the fleet avoided salmon and sablefish, and 

potentially the misperception by some that squids could be sold as whole bait. Some processors were not 

aware of the prohibition on processing and sale of squids as bait under Amendments 117/106 and sold 

squid as bait until they were informed by NMFS that this was illegal under existing regulations. Total 

squid landings in the BSAI and GOA by week is shown in Figure 4-1, and cumulative landings for 2019 

is shown in Figure 4-2. The processors were informed by NMFS that processing and selling squid was 

illegal at the end of July, 2019 (M. Furuness, NMFS, Personal Comm.). 

Table 4-1. Catch (mt) and retention (mt) of squid by all groundfish fisheries by FMP area 2009-2020 

BSAI GOA 

Year Catch Retained % Retained Catch Retained % Retained 

2009 360 181 50.4 337 293 86.7 

2010 410 270 65.8 131 120 91.6 

2011 336 149 44.2 233 188 80.9 

2012 688 471 68.5 18 3 13.7 

2013 299 112 37.4 322 304 94.6 

2014 1,678 993 59.2 94 63 66.6 

2015 2,364 1,951 82.6 411 329 80.1 

2016 1,286 526 40.9 240 139 57.8 

2017 1,996 1,019 51.0 39 12 30.1 

2018 1,736 1,299 74.8 43 9 20.3 

20191 5,928 2,742 46.2 63 48 76.1 

20202 260 101 1Squid managed in EC category. AKFISH_REPORT_V_CAS_NONTARGET_ESTIMATE accessed January 15, 2020. 

AKFIN accessed December 18, 2019 2Squid catch through July 7, 2020 (NMFS, Pers. Comm.). Amount retained in 2020 is not available. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 33 
800

Squid landings (mt) 

700 

600 

500 

400 

300 

200 

100 

0 

Date 

Figure 4-1. Squid landings (mt) by date in the BSAI and GOA in 2019. AKFIN accessed December 23, 2019 

6000 

0 

1000 

2000 

3000 

4000 

5000 

Squid catch (mt) 

Figure 4-2. Cumulative squid landings (mt) by week in the BSAI and GOA in 2019. AKFIN accessed December

23, 2019. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 34 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Squids were first managed as part of the EC category in 2019. As an EC species, stock assessments are 

not conducted, but data are reported every other year, along with the forage fish report. Therefore, there is 

no estimate of squid biomass in the BSAI. As such, it is difficult to determine whether the abundance of 

squids in the BSAI was higher than in recent years, or to understand what proportion of the squid biomass 

was caught in the 2019 fisheries. In 2017, the ABC for squids in the BSAI was 5,184 mt (Ormseth 

2016b), almost exactly the amount of catch in 2019. 

The analysis for Amendments 117/106 concluded that action alternatives to move squid into the EC 

category would not be likely to “decrease nor likely substantially increase the incidental catch of squids in 

groundfish fisheries as squids do not appear to be targeted in any way”, and that “bycatch of squids in the 

groundfish fisheries... would be similar to that under status quo.” In the BSAI, most squid are caught 

incidentally in the pollock fishery, as also occurred in 2019. The large increase in squid bycatch in the 

pollock fishery in 2019 suggests that there are factors that were not considered in the original analysis that 

may be affecting squid bycatch in the BSAI. 

In the GOA, nearly all squid are caught incidentally in the pollock fishery in the central GOA. From 2009 

– 2019 squid catch in the GOA has been lower than in the BSAI, and much lower since 2014 (Table 4-1). 

4.5.1.2 Description of current management 

Squid are currently classified in the EC category in both the BSAI and GOA FMPs. Squid are, therefore, 

not managed in the fishery and no OFL or ABC are specified for squids. Directed fishing for squid is 

prohibited. An MRA of 20% on squids for all target species limits retention. 

In 2019 the Council approved Exempted Fishing Permit (EFP) 2019-03 that evaluates aspects of 

electronic monitoring in the BSAI and GOA pollock CVs using pelagic trawl gear. The EFP requires 

100% retention of incidentally caught species. The effects of the EFP are that all squids caught 

incidentally to pollock fishing would be retained and delivered to shoreside processors. Because squids 

are typically not sorted at sea aboard CVs, this is not substantially different from the way squids were 

treated before the EFP was authorized. 

4.5.1.3 Harvesting vessels 

Both the catcher processor (CP) sector and the catcher vessel (CV) sector catch squid in the BSAI (Table 

4-2). From 2009 – 2018 the CP catch ranged from a low of 156 mt in 2010 to a high of 1,127 mt in 2017. 

Retained catch ranged from a low of 16 mt in 2012 to a high of 395 mt in 2017. The number of CP 

vessels retaining squid ranged from 10 – 18. Most CPs in the BSAI are not able to process squid to fish 

meal. Catch in the CV sector has been more variable, from a low of 91 mt in 2013 to a high of 1,983 mt in 

2015. Retained catch has ranged from a low of 90 mt in 2013 to a high of 1,849 mt in 2015. The number 

of vessels retaining squid ranged from 36 - 82. Not all CVs deliver to a plant that is able to process squid 

to fish meal. 

In the GOA, the CV sector generally catches and retains much more squid than the CP sector (Table 4-3). 

Total squid catch in the CP sector in the GOA ranged from 8 mt in 2010 and 2013 to a high of 42 mt in 

2015. The number of CP vessels retaining squids was as high as 7. Most CPs in the GOA are not able to 

process squid to fish meal. The CV sector squid catch ranged from a low of 4 mt in 2012 to a high of 369 

mt in 2015. Retained squids ranged from 2 mt in 2012 to 329 mt 2016. The number of CV vessels 

retaining squid ranged from 38 – 84. Not all CVs deliver to a plant that is able to process squid to fish 

meal. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 35 
 

Table 4-2. Total catch (mt) and retained catch (mt) and the number of vessels retaining squid in the BSAI by

sector from 2009 - 2018. Total retained and number of vessels is not available for 2019. 

Sector Year Catch Retained Vessels 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

213 

156 

216 

209 

208 

750 

380 

824 

1,127 

532 

3,390 

57 

22 

29 

16 

22 

75 

102 

227 

395 

250 

n/a 

10 

15 

18 

14 

14 

10 

17 

15 

14 

12 

n/a 

CP 

CV1 2009 147 124 36 

2010 255 248 49 

2011 120 119 64 

2012 479 452 77 

2013 91 90 69 

2014 928 914 75 

2015 1,983 1,849 82 

2016 462 297 74 

2017 869 585 68 

2018 1,204 1,041 66 

2019 2,538 n/a n/a 1 Includes CV delivering shoreside and to motherships 

Source: AKFIN accessed August 7, 2020 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 36 
 

 

 

 

 

 

 

Table 4-3. Total catch (mt) and retained catch (mt) and the number of vessels retaining squid in the GOA by

sector from 2009 – 2019. Amount retained and number of vessels is not available for 2019. 

Sector Year 

2009 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

Catch 

* 

8 

12 

15 

8 

* 

42 

11 

22 

28 

14 

Retained 

* 

0 

0 

0 

0 

* 

0 

0 

0 

0 

n/a 

Vessels 

* 

6 

8 

4 

4 

* 

7 

6 

5 

5 

n/a 

CP 

CV1 2009 321 291 38 

2010 123 120 44 

2011 220 188 57 

2012 4 2 70 

2013 313 304 72 

2014 66 62 82 

2015 369 329 84 

2016 228 138 68 

2017 18 12 68 

2018 15 9 57 

2019 49 n/a n/a 

* Data are confidential 

1 Includes CV delivering shoreside and to motherships 

Source: AKFIN accessed August 7, 2020 

4.5.1.4 Production 

This section provides an overview of squid production and value for recent years before squid were 

placed in the EC category. Table 4-4 shows the total production of squids to fish meal, whole bait, and 

whole fish/food fish in the BSAI and GOA, combined, from 2009 – 2018. The number of processors 

processing squid is limited so some production data are confidential. A small amount of other product 

forms (gutted only, mantles, stomachs, other) were also reported but are not discussed further. Although 

most of the fish meal data are confidential, Table 4-4 shows that fish meal was only produced in a few 

recent years. Processing data are not available for 2019. 

Table 4-4. Annual production (in pounds) of squid to fish meal, whole bait, and whole fish/food fish in the

BSAI and GOA, combined from 2009 – 2018. 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 

Fish Meal * * * 

Whole Bait 86,743 389,226 262,897 299,184 277,434 798,976 856,860 * * 832,476 

Whole Fish 313,711 * * 2,690 24,740 * * * * * 

Processors 7 6 8 10 10 4 4 5 3 7 

* Data are confidential 

Source: AKFIN accessed December 23, 2019 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 37 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Overall, from 2009 – 2018, whole bait was the most common product type with 3.8 million pounds and a 

total gross first wholesale value of $2.3 million, or an average of approximately $0.61/pound (Table 4-5). 

Fixed-gear vessels operating in the BSAI and GOA are the primary consumers of squids processed to 

bait. Whole fish was the next largest product type at 0.8 million pounds and a total gross first wholesale 

value of $374,835, or approximately $0.45/pound. 

Table 4-5. Total production (in pounds) of squid to fish meal, whole bait, whole fish/food fish, and gross first

wholesale value in the BSAI and GOA, combined, from 2009 – 2018. 

Product Type Total Production weight (pounds) Gross first wholesale value ($) 

Fish Meal 9,209 7,115 

Whole Bait 3,804,682 2,347,114 

Whole Fish 836,147 374,835 

Source: AKFIN accessed December 23, 2019 

Table 4-6 shows total squid production for the main squid processing communities in the BSAI and GOA 

from 2009 – 2018. The main communities processing squid are Dutch Harbor/Unalaska and Kodiak. 

Other communities where squid have been processed include Akutan, King Cove, Sand Point, and 

Seward. Other communities are combined here to address issues of confidentiality. Squid do not represent 

a significant portion of production for any processing community in the BSAI or GOA. 

Table 4-6. Total squid production (mt) by community in the BSAI and GOA, 2009 – 2019. 

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 

Dutch/Unalaska * 71 42 73 8 592 655 82 320 662 1,271 

Kodiak 296 125 184 2 276 60 318 127 6 4 8 

Other 126 179 80 379 108 324 1,202 226 270 383 1,350 

*Data are confidential 

Source: AKFIN accessed August 7, 2020 

4.5.2 Sculpin 

4.5.2.1 Harvests, Management, and Retained Catch 

Sculpins are currently taken only as incidental catch in fisheries directed at other target species in the 

BSAI and GOA. Since 2011, the sculpin complex total catch (retained and discarded) has ranged from 2% 

to 6% of the total estimated biomass of sculpins in the BSAI and GOA (Table 3-6). 

Table 3-6 shows that in the BSAI catch has slightly exceeded the TAC in all years since 2011 except 

2014. Catch in the GOA has been below the TAC since 2011. Sculpins in the BSAI were moved to 

prohibited species status and required to be discarded on October 6, 2017, but not in any other year. 

Sculpin catch was still substantially below ABC, OFL, and was a small proportion of the biomass in each 

year. 

There is no directed fishery for sculpin species in the BSAI or GOA at this time. Sculpins are caught 

primarily: 

• In the BSAI by: 

o trawl gear in fisheries targeting yellowfin sole, rock sole, and Atka mackerel, and 

o Pacific cod hook-and-line, pot, and trawl fisheries (Table 3-7). 

• In the GOA by: 

o Pacific cod trawl, shallow-water flatfish trawl, and IFQ halibut fisheries. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 38 
 

 

 

 

 

 

 

 

r--

I 

I 

I 

The retained catch of sculpins by gear and sector is shown in Table 4-7, illustrating that most retained 

catch is in the trawl sector. Sculpins, in general, are not retained, and fishery observer data indicate that 

the retention rate has been below 10% in the BSAI, and below 20% in the GOA. Since 2013, the retention 

rate has been below 5% in both the BSAI and GOA. As noted above, sculpin catch has been substantially 

below ABC and OFL, and has been a small proportion of the biomass each year. 

Table 4-7 Retained Catch of Sculpins in the BSAI and GOA Combined by Gear and Sector in metric tons

(mt) 

YEAR 

Catcher Vessels 

delivering to Shoreside 

Processing Plants or 

Stationary Floating 

Processors 

Trawl Nontrawl 

Catcher/Processsors and 

Motherships 

Trawl Nontrawl 

TOTAL 

Trawl Nontrawl Total 

2011 144 4 241 0 384 4 388 

2012 164 11 211 2 375 13 388 

2013 60 5 126 0 187 5 192 

2014 57 16 97 0 154 16 170 

2015 41 4 64 0 105 4 109 

2016 52 11 68 0 120 11 131 

2017 23 8 44 0 67 8 75 

2018 32 8 67 0 100 8 107 

2019 0 0 21 0 21 0 21 

Source: NMFS AKRO Catch Accounting System, accessed August 25, 2020 

4.5.3 Value of Sculpins and Potential for Markets 

Ninety-seven percent (97%) of the round weight equivalent of retained sculpins from 2006 - 2018 were 

processed into fish meal with the small remainder processed as whole fish, headed-and-gutted fish, and 

fillets. Table 4-8 provides ex-vessel price per pound of CV-caught sculpins for both the BSAI and GOA 

from 2006 through 2017. The ex-vessel price for sculpins processed into fish meal has routinely been 

$0.02 per pound or less. 

Table 4-8 Ex vessel price per pound of catcher vessel (CV) caught sculpin for fish meal for both BSAI

and GOA groundfish fisheries from 2006 through 2017. 

Ex-vessel price per pound of CV sculpins that 

was processed into fish meal ($) 

Year BSAI GOA 

2006 0.02 0.02 

2007 0.02 0.02 

2008 0.01 0.02 

2009 0.01 0.02 

2010 0.02 0.02 

2011 0.02 0.02 

2012 0.02 0.02 

2013 0.02 0.02 

2014 0.02 0.00 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 39 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Ex-vessel price per pound of CV sculpins that 

was processed into fish meal ($) 

2015 0.02 0.02 

2016 0.02 0.00 

2017 0.02 0.00 

Source: AKFIN accessed March 6, 2019 

A few Kodiak processors experimented with processing and marketing sculpins between 2006 and 2010, 

with one selling headed-and-gutted sculpins to a market in Eastern Europe. However, most processors 

find them too bony and difficult to process; thus, there is no current interest in developing a market for 

sculpins. 

4.6 Analysis of Impacts 

This section provides a qualitative analysis of the primary benefits and costs of two alternatives: (1) 

Status Quo/No Action, (2) Remove the processing restrictions for squids and sculpins in the Ecosystem 

Component category in the BSAI and GOA FMPs. Assessing the effects of the alternatives involves a 

great degree of speculation. In general, the effects arise from the actions of individual participants in the 

fisheries. Predicting individual actions and their effects is constrained by incomplete information 

concerning the fisheries, incomplete economic information, incomplete biological information and lack of 

models to predict participant behavior. Exogenous factors such as stock fluctuations, market dynamics, 

and macro conditions in the global economy also influence the likely response of the participants to each 

alternative. 

Before 2019, squids that were caught incidental to groundfish fisheries could be processed and sold. 

Section 4.5.1.4 shows that the most common and valuable product type for squids from 2009 – 2018 was 

whole bait, and the analysis for amendments 117/106 concluded that (assuming processing would be 

allowed) those product types would continue to be produced at the same rate as in previous years. In fact, 

despite the prohibition on processing of squids to forms other than fish meal, some processors did 

produce whole bait from squids in the first part of the 2019 season, until they were informed by NMFS at 

the end of July (approximately week 30 in the figures below) that bait production was not permitted. 

Figure 4-1 shows weekly landings of squid in the BSAI and GOA for 2019, and shows that the peak of 

squid landings during week 30 coincides with the time that processors were informed that processing to 

bait was prohibited. 

According to public testimony provided to the Council in December 2019, processing squid to fish meal 

is difficult for processors because it fouls the equipment, so most processors do not wish to process squid 

to meal. Given that difficulty, it would be reasonable to expect that if retention and sale of squid as whole 

bait was affecting squid catch, then landings of squid would decline after processors were informed that 

sale of squid as bait was prohibited, and retained squid must be processed to fish meal. If the prohibition 

on processing and sale of whole bait was affecting squid catch, it would be reasonable to expect that the 

rate of landings (shown as the slope of the line in Figure 4-2) would decline after week 30 when NMFS 

notified processors of the prohibition on processing to bait. However, Figure 4-2 shows cumulative 

landings of squid in the BSAI and GOA for 2019 and does not show an obvious decline in the rate of 

landings in 2019. This suggests that other factors, that may include the overall abundance of squid or the 

effects of avoiding Chinook salmon and sablefish, were likely affecting the rate of squid landings before 

and after the processors were informed of the prohibition on processing and sale as bait. 

Comparing landings in from 2009 – 2019 in Figure 4-3 and Figure 4-4, it does not appear that the 

temporal patterns of squid landings were much different in 2019 (in red in Figure 4-3 and Figure 4-4). In 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 40 
 

 

 

all years shown squid catch started at approximately the beginning of July (week 26) and typically peaked 

at the end of July (week 29-30). The difference in 2019 may be the higher levels of catch after the peak 

that contributed to the overall higher total landings in 2019. It is notable that those levels of catch 

occurred after the processors were informed that processing squid to bait was prohibited, suggesting again 

that other factors, that may include the overall abundance of squid or the effects of avoiding Chinook 

salmon and sablefish, were likely affecting the rate of squid landings in 2019. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 41 
 

 

 

800 2009 

0 

100 

200 

300 

400 

500 

600 

700 

Squid Landings (mt) 

2010 

2011 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45 47 49 51 

Week of the year 

Figure 4-3 Squid landings in the BSAI and GOA for 2009 – 2019. AKFIN 12.23.2019. 

2009 6000 

2010 

2011 

0 

1000 

2000 

3000 

4000 

5000 

Cumulative squid catch (mt) 

2012 

2013 

2014 

2015 

2016 

2017 

2018 

2019 

1 3 5 7 9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39 41 43 45 47 49 51 

Week of the year 

Figure 4-4. Cumulative squid landings (mt) by week in the BSAI and GOA 2009 - 2019. AKFIN 12.23.2019. 

Moving squids to the EC component also had the effect of removing the need for vessels fishing for 

pollock to move away from grounds when the squid encounter rate was high. The analysis for 

Amendments 117/106 noted that a benefit of moving squids to the EC component included greater 

flexibility for the pollock fleet to seek areas of higher pollock CPUE while avoiding prohibited species 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 42 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

such as Chinook salmon, or other species with high encounter rates that could be limiting (e.g., sablefish 

in 2019). If the encounter rates of squid were higher in 2019 than in previous years, and the pollock fleet 

was making decisions to avoid prohibited species and other species without concern for squid catch rates, 

then the total catch of squid could be higher than in previous years. Without an assessment of squid 

abundance in 2019, it is difficult to determine whether those conditions existed in 2019 to explain the 

higher levels of bycatch. Unfortunately, the same lack of data makes it difficult to predict levels of squid 

bycatch in the pollock fleet in the near future. The potential removal of incentives to avoid squid by 

allowing processing and sale further confounds predictions. It would not be surprising if removing the 

prohibition on production and sale of squid products coincided with an increase in total squid catch, but if 

such an increase were to occur, it may not be wholly attributed to this action. 

Because there has never been a significant market for any sculpin products, and because they are caught 

and retained at low levels (§4.5.2) it is unlikely that removing processing restrictions on sculpins will 

change the levels of catch incidental to other fisheries. Fish meal was the most common product from 

sculpins before the Council took final action to move them to the EC component, and that is unlikely to 

change under either alternative. 

4.6.1 Alternative 1: No action, status quo 

Alternative 1 would continue to manage squids and sculpins as ecosystem component species in the 

groundfish FMPs for the BSAI and GOA. Stock assessments would not be conducted and OFL, ABC, and 

TAC would not need to be established. Targeting of squids and sculpins would continue to be prohibited, 

but retention of squids and sculpins up the MRA of 20% would be permitted. Recordkeeping and 

reporting requirements would be maintained. Processing restrictions limiting processing and sale of 

squids and sculpins to fish meal only would be maintained in regulations, consistent with other ecosystem 

component species. 

For the reasons outlined above it is difficult to predict the levels of incidental catch of squid in the BSAI 

and GOA. If the anomalously high levels of squid catch seen in 2019 occurred in the future, under 

Alternative 1 processors would likely experience higher costs associated with discarding squid or 

converting fish meal plants to be able to efficiently process squid. The total cost would depend on 

individual processors’ decisions to discard or process squid to fish meal. Under Alternative 1, processors 

would also forgo revenue from the sale of squid as product forms other than fish meal. As shown in Table 

4-5, revenue from the sale of whole bait from 2009 – 2018 totaled $2,347,114, while fish meal provided 

revenue of $7,115 for the same period. It is unlikely that increased sale of fish meal would be able to 

replace the lost revenue from the sale of whole bait. The overall impacts of forgone revenue from the 

prohibition of selling squid as whole bait is not significant in comparison to the overall value of the BSAI 

and GOA groundfish fisheries, but impacts may be significant to individual operators, depending on how 

much of their annual revenue is generated from processing squid. 

Local, fixed gear fisheries are the main market for squid processed to whole bait. If squid is not available, 

other species such as Pacific saury are used (C. Lowenburg, Pers. Comm. 2/19/20). Under Alternative 1, 

those vessels who had previously purchased squid bait from processors would need to secure other 

sources for their bait. This would likely come at increased cost to the vessels and may also result in 

increased carbon output as bait would be shipped to Alaska from other locations. 

Because there has never been a significant market for any sculpin products, and they are caught and 

retained at low levels, it is unlikely that retaining processing restrictions on sculpins will change the level 

of incidental catch or the value of that catch. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 43 
 

 

 

 

 

 

 

 

 

 

 

 

 

4.6.2 Alternative 2 (Preferred Alternative): Remove processing restrictions on squids 

and sculpins 

Alternative 2 would continue to manage squids and sculpins as ecosystem component species in the 

groundfish FMPs for the BSAI and GOA. Stock assessments would not be conducted and OFL, ABC, and 

TAC would not need to be established. Targeting of squids and sculpins would continue to be prohibited, 

in regulations, but retention of squids and sculpins up to the MRA of 20% would be permitted by 

regulation. Recordkeeping and reporting requirements would be maintained. Processing restrictions 

limiting processing and sale of squids and sculpin to fish meal would be removed. 

For reasons outlined above, it is difficult to predict the levels of incidental catch of squid in the BSAI and 

GOA. If the anomalously high levels of squid catch seen in 2019 occurred in the future, under Alternative 

2 processors may be able to generate additional revenue from the sale of squid as whole bait or whole 

fish/food fish, as well as preventing waste of incidental squid catch. The total additional revenue would 

depend on individual processors’ decisions to process squid to saleable products or discard. As shown in 

Table 4-5, revenue from the sale of whole bait from 2009 – 2018 totaled $2,347,114 while whole 

fish/food fish generated $374,835 for the same period. The potential economic impacts of allowing squid 

and sculpin to be sold as products other than fish meal are not significant in comparison to the overall 

wholesale value of the BSAI and GOA groundfish fisheries (BSAI $3.2 billion, GOA $1.3 billion, in 

2018)8

, but impacts may be significant to individual operators depending on how much of their annual 

revenue is generated from processing squid and sculpin. 

Under Alternative 2, squid processed to whole bait would remain available to local, fixed gear fisheries, 

which may result in lower costs for those vessels. 

Because there has never been a significant market for any sculpin products, and they are caught and 

retained at low levels, it is unlikely that removing processing restrictions on sculpins will change the level 

of incidental catch or the value of that catch. 

4.6.3 Effects on Fishing Communities and Other Social Impacts 

The potential community and social impacts of the alternatives are primarily economic in nature. 

Processing squid to bait provides some revenue to shore-based processors (Table 4-5) and may reduce 

costs to local fleets over imported bait. Because the potential economic impacts are limited, analysts did 

not identify any impacts that would create adverse economic impacts on any fishing community or cause 

any other adverse social impacts. 

4.6.4 Affected Small Entities 

The Regulatory Flexibility Act (RFA), first enacted in 1980 and amended by the Small Business 

Regulatory Enforcement Fairness Act of 1996 (5 U.S.C. 601-612), is designed to place the burden on the 

government to review all regulations to ensure that, while accomplishing their intended purposes, they do 

not unduly inhibit the ability of small entities to compete. The RFA recognizes that the size of a business, 

unit of government, or nonprofit organization frequently has a bearing on its ability to comply with a 

Federal regulation. Major goals of the RFA are 1) to increase agency awareness and understanding of the 

impact of their regulations on small business, 2) to require that agencies communicate and explain their 

82018 Groundfish Economic SAFE Report, Table 5: 

https://meetings.npfmc.org/CommentReview/DownloadFile?p=8fd1517c-cbfc-4455-9453-

c80964179af6.pdf&fileName=D7%20REVISED%20GF%20Economic%20SAFE.pdf 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 44 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

findings to the public, and 3) to encourage agencies to use flexibility and to provide regulatory relief to 

small entities. 

The RFA emphasizes predicting significant adverse economic impacts on small entities as a group distinct 

from other entities, and on the consideration of alternatives that may minimize adverse economic impacts, 

while still achieving the stated objective of the action. When an agency publishes a proposed rule, it must 

either ‘certify’ that the action will not have a significant adverse economic impact on a substantial number 

of small entities, and support that certification with the ‘factual basis’ upon which the decision is based; 

or it must prepare and make available for public review an Initial Regulatory Flexibility Analysis (IRFA). 

Under section 603 of the RFA, an IRFA “shall describe the impact of the proposed rule on small entities.” 

Under 5 U.S.C. 603(b) of the RFA, each IRFA is required to contain: 

• A description of the reasons why action by the agency is being considered; 

• A succinct statement of the objectives of, and the legal basis for, the proposed rule; 

• A description of and, where feasible, an estimate of the number of small entities to which the 

proposed rule will apply (including a profile of the industry divided into industry segments, if 

appropriate); 

• A description of the projected reporting, record keeping, and other compliance requirements of 

the proposed rule, including an estimate of the classes of small entities that will be subject to the 

requirement and the type of professional skills necessary for preparation of the report or record; 

• An identification, to the extent practicable, of all relevant Federal rules that may duplicate, 

overlap, or conflict with the proposed rule; and 

• A description of any significant alternatives to the proposed rule that accomplish the stated 

objectives of the proposed action, consistent with applicable statutes, and that would minimize 

any significant economic impact of the proposed rule on small entities. Consistent with the stated 

objectives of applicable statutes, the analysis shall discuss significant alternatives, such as: 

1. The establishment of differing compliance or reporting requirements or timetables that 

take into account the resources available to small entities; 

2. The clarification, consolidation, or simplification of compliance and reporting 

requirements under the rule for such small entities; 

3. The use of performance rather than design standards; 

4. An exemption from coverage of the rule, or any part thereof, for such small entities. 

When an agency publishes a final rule, it must prepare a Final Regulatory Flexibility Analysis, unless, 

based on public comment, it chooses to certify the action. 

This section of the RIR provides information about the small entities that may be directly regulated by the 

alternatives and the general nature of those effects. This information is useful for the Council to consider 

in selecting among the alternatives analyzed in this RIR and for NMFS to use to prepare the IRFA for the 

proposed rule, should the Council recommend implementation of Alternative 2. 

The thresholds applied to determine if an entity or group of entities are “small” under the RFA depend on 

the industry classification for the entity or entities. Businesses classified as primarily engaged in 

commercial fishing are considered directly regulated small entities if they have combined annual gross 

receipts (revenues) not in excess of $11.0 million for all affiliated operations worldwide (50 CFR 200.2). 

The most recent estimates of the number of fishing vessels participating in the BSAI and GOA groundfish 

fisheries that are small entities are provided in Table 2 in the IRFA for the BSAI and GOA Harvest 

Specifications for 2020-2021 (NMFS 2019). In 2018, there were 182 CVs and 3 C/Ps in the BSAI, 756 

CVs and 3 C/Ps in the GOA, and three motherships that met the definition of small entities. If a vessel has 

a known affiliation with other vessels – through a business ownership or through a cooperative – the 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 45 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

vessel’s gross receipts are measured against the small entity threshold based on the total gross revenues of 

all affiliated vessels. Because public information on business ownership is incomplete, this analysis only 

considers affiliation in the form of membership in a fishing cooperative. Therefore, estimates likely 

overstate the number of small entities in the groundfish fisheries off Alaska because some of these vessels 

are affiliated through common ownership or membership in a cooperative and the affiliated vessels 

together would exceed the $11.0 million annual gross receipts threshold for small entities. 

In addition to directly regulated CVs and CP, it is possible that one or more shorebased processors in the 

BSAI or GOA that processes squids or sculpins under Alternative 2 could be directly regulated small 

entities if the processing company and its affiliates worldwide employ fewer than 750 people. Total 

employment numbers of processing companies and their affiliates worldwide are not available to make 

that determination. Both alternatives would directly regulate any processor receiving squids or sculpins in 

the federally managed groundfish fisheries in the BSAI and GOA. 

As described in Section 4.6.2, for processors currently participating in these fisheries, the economic 

impacts of Alternative 2 are primarily beneficial or neutral. Processors who wish to process squids and 

sculpins may still do so in the future, up to the MRAs. Therefore, NMFS Alaska Region will certify that 

this action does not create a significant adverse impact on a substantial number of directly regulated small 

entities within the classification section of the proposed rule. . 

4.7 Management and Enforcement Considerations 

4.7.1 Alternative 1: Status Quo 

Squids are currently managed in the EC category in both the BSAI and GOA FMPs, and sculpins will be 

managed in the EC category if the FMP amendments and implementing regulations regarding sculpins are 

approved by the Secreatary. There have not been directed fisheries for either squids or sculpins in either 

management area in the recent past, and all catch of squid and sculpins are incidental to other target 

fisheries. Squid is primarily taken in the pollock fisheries in the BSAI and GOA, and sculpins are taken 

primarily in the flatfish trawl and fixed gear Pacific cod fisheries. 

Squid and sculpins may be retained up to the MRA of 20%. The MRA applies at any time for the duration 

of a fishing trip for each vessel and is calculated on a trip-by-trip basis. Vessels are not required to retain 

squid or sculpins up to the MRA, however, the difficulty of manually sorting squids and sculpins from 

catch at-sea has likely contributed to higher retention than may be desired or occur under different 

operating conditions. Processors are not permitted to process squid or sculpins into any product form 

other than fish meal (50 CFR 679.20(i)). 

Primary management considerations for Alternative 1: 

• Monitoring catch at the individual trip level to ensure that the squids and sculpins MRA is not 

exceeded; and 

• Monitoring processing products to ensure that squids and sculpins are not processed into product 

forms other than fish meal. 

Primary enforcement considerations for Alternative 1: 

• Challenge for enforcement to determine appropriate penalty for squids and sculpins MRA 

overages. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 46 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

4.7.2 Alternative 2: Squids and sculpins in both the BSAI and GOA FMPs are 

designated as non-target “ecosystem component species” without processing 

restrictions. 

Under Alternative 2, squids and sculpins would continue to be managed in the EC category in both the 

BSAI and GOA FMPs if the secretory approves Amendments 121 to the BSAI FMP and 110 to the GOA 

FMP to move sculpins to the EC category in both FMPs. No directed fisheries for squids or sculpins 

would be permitted, and all catch of squids and sculpins would be incidental to other target fisheries. 

Squids and sculpins could be retained up to the MRA of 20%. The MRA would apply at any time for the 

duration of a fishing trip for each vessel and would be calculated on a trip-by-trip basis. Vessels would 

not be required to retain squids or sculpins up to the MRA. Processors would be permitted to process 

squids and sculpins into any product form for sale. 

Primary management consideration for Alternative 2: 

• Monitoring catch at the individual trip level to ensure that the squids and sculpins MRA is not 

exceeded. 

Primary enforcement considerations for Alternative 2: 

• Challenge for enforcement to determine appropriate penalty for squids and sculpins MRA 

overages. 

4.7.3 Implications for State Fisheries 

Removing processing restrictions on squids and sculpins would have no immediate implications for State 

fishery management. The FMPs do not preclude development of directed fisheries in State waters. As 

discussed in Section 3.1.1, market squid have been observed in State waters in Southeast Alaska. The 

State of Alaska Board of Fisheries could authorize a State waters fishery for market squid as they 

determine it to be appropriate. In sum, removing processing restrictions for squids and sculpins would 

present no additional management or enforcement burdens on the State of Alaska. 

4.8 Summation of the Alternatives with Respect to Net Benefit to the 

Nation 

Alternative 1 would continue to manage squids and sculpins as ecosystem component species in both the 

BSAI and GOA FMPs. Targeting of squids and sculpins would continue to be prohibited, but retention of 

squids and sculpins up the MRA of 20% would be permitted. Recordkeeping and reporting requirements 

would be maintained. Processing restrictions limiting processing and sale of squids and sculpins to fish 

meal only would be maintained, by regulation, consistent with other EC species. 

Alternative 2 would continue to manage squids and sculpins as EC species in the groundfish FMPs for the 

BSAI and GOA. Targeting of squids and sculpins would continue to be prohibited, by regulation, but 

retention of squids and sculpins up to the MRA of 20% would be permitted. Recordkeeping and reporting 

requirements would be maintained. Processing restrictions limiting processing and sale of squids and 

sculpin to fish meal would be removed from regulations. 

Net benefits to the Nation relative to the No Action alternative would likely increase marginally under 

Alternative 2 by allowing processing and sale of squids and sculpins products and by helping to prevent 

waste of the incidental catch of these species. Alternative 2 would likely not affect current fishery revenue 

for sculpins, as a small amount of sculpins is retained and marketed as fish meal, but fishery revenue for 

squids may increase by allowing sale of squids as whole bait or whole fish/food fish. 

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5 Magnuson-Stevens Act and FMP Considerations 

5.1 Magnuson-Stevens Act National Standards 

Below are the 10 National Standards (NS) as contained in the MSA (16 U.S.C. 1851), and a brief 

discussion of how each alternative is consistent NS, where applicable. In recommending a preferred 

alternative, the Council must consider how to balance the national standards. 

NS 1 — Conservation and management measures shall prevent overfishing while achieving, on a 

continuing basis, the optimum yield from each fishery for the United States fishing industry. 

Under Alternative 1, the status quo, squids and sculpins would remain as EC species in both the BSAI 

and GOA FMPs. Processing and sale of squids and sculpins other than fish meal would remain 

prohibited. Under Alternative 2, processing and sale of squids and sculpins would be permitted in any 

product form. 

Although products from squids or sculpins in the EC are not measured against an OY cap in the BSAI or 

GOA, Alternative 2 may marginally enhance overall OY by reducing the amount of squids or sculpins 

that are discarded. Alternative 2 is consistent with management for maximum sustainable yield from the 

fishery while considering the ecological factors associated with squids and sculpins. 

NS 2 — Conservation and management measures shall be based upon the best scientific information 

available. 

Information in this analysis represents the most current, comprehensive set of information available to the 

Council. Information previously developed on the BSAI and GOA groundfish fisheries, as well as the 

most recent information available, has been incorporated into this analysis. It represents the best scientific 

information available. 

NS 3 — To the extent practicable, an individual stock of fish shall be managed as a unit throughout its 

range, and interrelated stocks of fish shall be managed as a unit or in close coordination. 

Squids and sculpins have been managed in the past as part of the BSAI and GOA fisheries. As part of the 

EC category, harvest specifications are not required for squids and sculpins in the BSAI or GOA, but 

reports on squid and sculpin biomass and catch would be produced in accordance with the current stock 

assessment schedule for ecosystem component species. 

NS 4 — Conservation and management measures shall not discriminate between residents of different 

states. If it becomes necessary to allocate or assign fishing privileges among various United States 

fishermen, such allocation shall be; (A) fair and equitable to all such fishermen, (B) reasonably calculated 

to promote conservation, and (C) carried out in such a manner that no particular individual, corporation, 

or other entity acquires an excessive share of such privileges. 

Nothing in the alternatives considers residency as a criterion for the Council’s decision. Residents of 

various states, including Alaska and states of the Pacific Northwest, participate in the major sectors 

affected by these potential regulations. No discriminations are made among fishermen based on residency 

or any other criteria. It is not necessary to allocate or assign fishing privileges under either alternative. 

NS 5 — 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. 

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The wording of this standard was changed in the last MSA authorization, to consider rather than promote 

efficiency. Efficiency in the context of this change refers to economic efficiency, and the reason for the 

change, essentially, is to de-emphasize to some degree the importance of economics relative to other 

considerations (United States Senate, 1996). The analysis presents information relative to these 

perspectives and provides information on the economic risks associated with the alternatives in the RIR. 

Alternative 2 may increase efficiency by limiting the amounts of squids and sculpins discarded and by 

allowing the processing and sale of product forms other than fish meal. 

NS 6 — Conservation and management measures shall take into account and allow for variations among, 

and contingencies in, fisheries, fishery resources, and catches. 

Alternatives 1 and 2 consider and allow for variations among, and contingencies in, fisheries, fishery 

resources, and catches. No directed fishing would occur under any alternative, although squids and 

sculpins may be retained up to the authorized MRA. The 20% MRA allows for maximum consideration 

of variations among and contingencies in fisheries, fishery resources, and catches. In addition, 

recordkeeping and reporting requirements under all alternatives account for changes in squid and sculpin 

stock size, location, ecological interactions, and habitat changes, or changes in fishing practices to be 

noticed. This establishes some protection against uncertainties. 

NS 7 — Conservation and management measures shall, where practicable, minimize costs and avoid 

unnecessary duplication. 

Alternatives 1 and 2 will continue to impose recordkeeping and reporting requirements on the groundfish 

fishing industry. Neither alternative imposes unnecessary burdens on the economy, on individuals, on 

private or public organizations, or on Federal, state, or local governments. Thus, all of the alternatives 

under consideration appear to be consistent with this NS7. 

NS 8 — Conservation and management measures shall, consistent with the conservation requirements of 

this Act (including the prevention of overfishing and rebuilding of overfished stocks), take into account 

the importance of fishery resources to fishing communities by utilizing economic and social data that 

meet the requirements of National Standard 2, in order to (A) provide for the sustained participation of 

such communities, and (B) to the extent practicable, minimize adverse economic impacts on such 

communities. 

The potential economic and social impacts of the alternatives are primarily economic in nature, with some 

marginal increase in the overall value of the groundfish fisheries projected for Alternative 2 due to the 

removal of processing restrictions. To the degree that this increase in value represents increased earning 

and spending in a fishing community, Alternative 2 would benefit that particular fishing community or 

communities. Analysts did not identify any impacts that would create adverse economic impacts on any 

fishing community or jeopardize the sustained participation of any fishing community, including 

subsistence users, in the GOA and BSAI groundfish fisheries. 

NS 9 — Conservation and management measures shall, to the extent practicable, (A) minimize bycatch, 

and (B) to the extent bycatch cannot be avoided, minimize the mortality of such bycatch. 

Ecosystem component species do not require specification of biological reference points, but should be 

monitored as new, pertinent scientific information becomes available to determine changes in their status 

or their vulnerability to the fishery. Alternatives 1 and 2 would maintain the MRAs as tools to minimize 

bycatch of squids and sculpins in other groundfish fisheries to the extent practicable. Retention of record 

keeping and reporting requirements would provide information necessary to determine whether bycatch 

of squids and sculpins is minimized to the extent practicable. Relative to the status quo, Alternative 2 

would allow processing of squids and sculpins to any product forms rather than to fishmeal only. This 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 49 
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

may remove disincentives to avoid squids and sculpins and may result in increased bycatch of squids and 

sculpins. 

NS 10 — Conservation and management measures shall, to the extent practicable, promote the safety of 

human life at sea. 

None of the alternatives or options proposed would change the way in which any of the GOA or BSAI 

commercial fisheries are conducted, or reduce the flexibility of fishermen to decide when, where, and 

how to fish within established regulations. In addition, none of the alternatives would create 

circumstances that would increase risks to human life at sea. Therefore, the alternatives under 

consideration appear to be consistent with NS10. 

5.2 Section 303(a)(9) Fisheries Impact Statement 

Section 303(a)(9) of the MSA requires that a fishery impact statement be prepared for each FMP 

amendment. A fishery impact statement is required to assess, specify, and analyze the likely effects, if 

any, including the cumulative conservation, economic, and social impacts, of the conservation and 

management measures on, and possible mitigation measures for (a) participants in the fisheries and 

fishing communities affected by the plan amendment; (b) participants in the fisheries conducted in 

adjacent areas under the authority of another Council; and (c) the safety of human life at sea, including 

whether and to what extent such measures may affect the safety of participants in the fishery (16 U.S.C. 

1853(a)(9)). 

The proposed action affects the groundfish fisheries in the EEZ off Alaska, which are under the 

jurisdiction of the Council. Impacts on participants in fisheries conducted in adjacent areas under the 

jurisdiction of other Councils are not anticipated as a result of this action. The proposed action also is not 

anticipate to impact the safety of human life at sea, including the safety of participants in the fishery. 

5.3 Council’s Ecosystem Vision Statement 

The Council’s Ecosystem Approach Vision Statement was approved by the Council in 2014 and is 

intended to be given effect through all of the Council’s work. The Vision Statement states that: 

The Council envisions sustainable fisheries that provide benefits for harvesters, 

processors, recreational and subsistence users, and fishing communities which (1) are 

maintained by healthy, productive, biodiverse, resilient marine ecosystems that support a 

range of services; (2) support robust populations of marine species at all trophic levels, 

including marine mammals and seabirds; and (3) are managed using a precautionary, 

transparent, and inclusive process that allows for analysis of tradeoffs, accounts for 

changing conditions, and mitigates threats. 

Under both Alternative 1 and Alternative 2, directed fishing for squids and sculpins would not be 

allowed. Squids and sculpins could be taken as incidental catch and retained up to the MRA amount, 

which, under Alternative 1would allow for sale as fishmeal within that MRA amount. Under Alternative 

2, squids and sculpins retained up to the MRA amount could be processed for sale as any product form. 

Under Alternatives 1 and 2 data on squids and sculpins would be reported to the Council regularly, as is 

practice for other EC species. 

Both Alternative 1 and Alternative 2 are consistent with the Council’s Ecosystem Approach Vision 

Statement. However, Alternative 2 allows for marginally greater economic benefits by allowing 

processing and sale of squids and sculpins in any product form. This is likely to provide some incremental 

benefit for harvesters, processors, and fishing communities in the BSAI and GOA that is not realized 

under Alternative 1. 

BSAI GOA Squid and Sculpins Processing Restrictions RIR 50 
 

 

6 Preparers and Persons Consulted 

Preparers 

Steve MacLean, NPFMC 

Contributors 

Mike Fey, AKFIN 

Mary Furuness, NOAA/NMFS RO 

Megan Mackey, NOAA/NMFS RO 

Persons (and Agencies) Consulted 

Sam Cunningham, NPFMC 

Anne Marie Eich, NOAA/NMFS RO 

Austin Estabrooks 

Alisha Falberg, NOAA General Counsel 

Jennifer Ferdinand, NOAA Fisheries Monitoring and Analysis Division 

Nathan Lagerway, NOAA Office of Law Enforcement 

Craig Lowenerg 

Scott A. Miller, NOAA Fisheries, Alaska Region Industry Economist 

Molly Watson, NOAA General Counsel 

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