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Agenda Item: C3 – Pelagic Trawl Gear Definition
Submitted by: B&J Sporting Goods
To: North Pacific Fishery Management Council
Attn: Diana Evans, Council Coordinator & Council Members
605 W 4th Ave, Suite 400
Anchorage, AK 99501
Date: May 26, 2025
Dear Members of the North Pacific Fishery Management Council,
Thank you for the opportunity to provide comments on Agenda Item C3: the proposed redefinition of pelagic (midwater) trawl gear. As the Owner of B&J Sporting Goods—Alaska’s largest fishing tackle and bait shop—I write on behalf of our business and the many Alaskans we serve who depend on healthy, accessible fisheries for food, livelihood, and cultural identity.
This proposal is of deep concern to us and to the broader fishing community across Alaska. The public has repeatedly expressed frustration with how destructive industrial trawl practices are being allowed to continue—often shielded by opaque definitions and unenforced standards. Rather than addressing the ecological harm caused by “midwater” gear that drags the seafloor, the Council is now considering a regulatory change that would redefine the gear in ways that would allow continued bottom contact—even in areas closed to bottom trawl.
This proposal does not solve a problem. It legalizes it.
The existing definition of pelagic trawl gear is based on performance, requiring no bottom contact. But as the Council’s own gear innovation and analysis documents admit, this standard has not been enforced. Instead of restoring accountability, the proposed change would make contact-based enforcement obsolete. This puts essential fish habitat (EFH), vulnerable species like crab and halibut, and currently protected zones at even greater risk.
When gear intended to “hover” ends up dragging six square miles of ocean bottom per vessel, per day, the result is large-scale, unrecorded mortality and habitat destruction. If even a fraction of this bottom contact were occurring on land—in a protected forest, for instance—it would be headline news. Yet at sea, we are being asked to call it “midwater” fishing. This is a dangerous precedent. If the gear acts like bottom trawl, it should be regulated as bottom trawl.
Our customers are already grappling with repeated closures, declining stocks, and mounting frustration over a regulatory system that increasingly seems disconnected from ecological and economic realities—and from the voices of Alaskans who feel ignored in decisions about the future of their fisheries.
As a business, we are not against commercial fishing. But we are for accountability, ecosystem health, and fairness in fisheries management. What’s currently being proposed under Agenda Item C3 undermines those values.
We urge the Council to:
Alaska’s fisheries belong to the people of this state and the nation—not to regulatory loopholes or out-of-state industrial fleets. If we don’t protect them now, we risk losing them—species by species, net by net.
Thank you for your commitment to stewarding Alaska’s fisheries with care and integrity. We appreciate the opportunity to share our perspective and remain committed to supporting sustainable, science-based, and Alaska-first solutions.
Sincerely,
Troy Arnold
Owner
B&J Sporting Goods, Anchorage, AK
B&J’s Tackle Repair Center, Anchorage, AK
B&J’s Tackle Box, Whittier, AK
bnjsg.com | https://bnjsg.com/tacklerepair | https://bnjsg.com/WhittierTackleBox
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