Fishermen’s Finest, Inc. 570 Kirkland Way #200 Kirkland, WA 98033 TEL: (206) 283-1137 www.fishfinest.com Mr. Josh Keaton & Ms. Gretchen Harrington February 3, 2023 Sustainable Fisheries Division Alaska Region NMFS, Attn: Records Office P.O, Box 21668 Juneau, AK 99802-1668, Re: Fishermen's Finest, Inc. comments on proposed Amendment 123 to the BSAI FMP, proposed rule to implement Amendment 123, and associated EIS, NOAA-NMFS-2022-0088. Dear Mr. Keaton & Ms. Harrington: Fishermen’s Finest, Inc. (FFI) is a minority, woman-owned company that operates three catcher-processors in the Amendment 80 sector (A80) and employs 250 crew. FFI supports the comments submitted by Groundfish Forum, Inc. on the National Marine Fisheries Service's (NMFS) proposed Amendment 123 to the Bering Sea Aleutian Islands (BSAI) Fishery Management Plan (FMP). The Proposed Action is an ill-advised and arbitrary attempt to allocate the catch of a species from one fishery to another fishery without a conservation benefit, without a benefit to the directed halibut fleet, and with a significant and substantial harm to the A80 sector, which has already dramatically reduced halibut bycatch over decades. It is fundamentally a politically based fish allocation imposed by the Alaska supermajority on the Washington stakeholders. It takes Pacific Halibut from the Washington State based A80 fleet, where itis both well-managed and needed to prosecute the largest flatfish fishery in the world, and attempts to deliver it to where it is not needed, the Alaska based fleet, which received a record-high harvest allocation for the BSAI fleet in 2022 and only used 67% of that allocation, This forced reallocation will have substantial adverse impacts on the A80 sector crew, who are 66% Minority People of Color,' as the EIS clearly states A80 companies that cannot remain viable under this action will eventually exit the fishery, A80 vessels provide these American men and women middle class, blue collar, career path jobs, and the painful impacts of contraction of the sector will be borne by these hard-working American fishermen and their families. Sacrificing their jobs without a clear conservation benefit is ethically repugnant and should be unacceptable to the Agency. NMFS should disapprove Amendment 123 in full, maintain the status quo by selecting the no-action alternative. Thank you for your consideration of my comments. Aru Auman Annika Saltman Director, Government and Regulatory Affairs Fishermen’s Finest, Inc. " Appendix 1: Socal Impact Assessment (SIA), Final Environmental Impact Statement (FEIS) forthe BSAI Halibut Abundance-Based Management ‘of PSC Limits, Non Pacific Fishery Management Council (NPFMC), Table 84, p. 188, April 2022. 2 Final Environmental Impaet Statement (FEIS) forthe BSAI Halibut Abundance-Based Management of PSC Limits, North Pacific Fishery ‘Management Couneil (NPFMC), p. 237, December 2022.