Re BYCATCH 14-004 — C-2: GOA Trawl Bycatch Discussion Paper, EDRs

North Pacific Fishery Management Council (NPFMC)

April Plenary Session — For the Record by Fax to 907-271-2817

April 7-14, 2014         Hilton Hotel; Anchorage, Alaska

Public Comment by Stephen Taufen, Groundswell Fisheries Movement

Groundswell is an advocate for public rights and accountability and transparency in USA fisheries.

Thurs. April 10 thru Friday April 11, 2014 from 8:00 to 5:00 pm (8 hours+)

  Secretary Pritzker, Chairman Olson, and Council Members: I’m Stephen Taufen, founder of the Groundswell Fisheries Movement, public advocates since the early 1990’s for what is best for the economy and social goals of the United States. We believe that any Alternative to the Groundfish fishery management plan (FMP), even as particular as for Trawl fleets fishing pollock and cod, must enforce and contain the following elements:

  1. Lay Share Laws – 46 U.S.C. §10601, §11107 of the United States Coast Guard’s bill of 1988, the Fishing Vessel Safety Act.
  2. EDR data and historical review must include gathering the facts to quantify the trip settlements for trawling since 2006 and capture the true percentage of the adjusted gross, pre-leasing, of the Captains and Crew – said to be between 35% and 40%.
  3. No IFQ permit holders should be allowed to rent quotas as a top-line expense that diminishes the shares split by the Captains and Crews, Vessel Owners/Operators – in accordance with historical participation.  I.E. no leasing should be allowed until after crewmen are settled from the traditional “net adjusted gross after fuel, bait and other direct costs.”
  4. No Fishing Community Entities should be allowed to go forward with their proposals without describing, first and foremost: the type of business, its bylaws and election methods, and how Communities actually hold rights as members or stockholders.  The public should know all as part of “the Social Contract,” and Transparency should be complete, unlike Western Alaska CDQs.  No private inurement should be allowed, as well.
“Fisheries are a human phenomenon. fisheries are places where human activities are linked with marine ecosystems and renewable resources. Human fishing activity is the defining attribute of a fishery. [and] if fisheries management is to be more successful in the future it must integrate social and cultural concerns with the management of natural resources and ultimately the level of its success will rest upon how well it promotes the well-being of people living in fishing communities.” –– The Food and Agriculture Organization of the United Nations: Understanding the Cultures of Fishing Communities: A Key to Fisheries Management and Food Security, 2001. Repeating important reminders: The issue is Bycatch Reduction – for Sustainability and Conservation needs – not allocations: giveaways of the national Commonwealth.  The bycatch reduction toolbox already has tools

available, especially when considering new technology, and the restrictions of TAC setting, of course.

  • 50 CFR § 600.345 NS#8—Communities: states “This [national] standard does not constitute a basis for allocating resources to a specific fishing community nor for providing preferential treatment based on residence in a fishing community.” It does not get any clearer than that.
  • Allocations – even to Communities – are not bycatch reduction tools, and cannot provide for meaningful reductions in the bycatch of halibut, king salmon, and other species.
  • 50 CFR § 600.345 NS#8—Communities: provides for sustained participation … but “This standard requires that an FMP take into account the importance of fishery resources to fishing communities. This consideration, however, is within the context of the conservation requirements of the Magnuson-Stevens Act.”
  • Fishing Community Entity allocations are a poor substitute for direct allocations to those who fish – the captains and crew (historically 35-40%) & local boat owners (historically 60-65% of adjusted gross revenues): i.e. those who spend in the community.
  • Tying a catch share to a community would be better achieved by setting an amount of quota that can only be awarded to historical participants: actual fishermen who supply fish.
  • Awarding or tying quotas to Processing companies who are Buyers of the fish has an Anticompetitive effect, shores up their market powers and lowers ex-vessel prices.  Awarding IPQs to foreign-owned and –controlled corporations ensures Alaska is a resource exploitation colony, a branch economy of a foreign nation(s), whose interests are not in leaving wealth nor producing secondary products in the USA, nor marketing products outside their guarded industrial realm.
  • Referring to a 20 year history in Alaska with IFQs simply demonstrates the deliberate march, species by species, to privatize a national resource without recipients paying for it.  It does not demonstrate a means of bycatch reduction, nor a tool. [It is a public larceny!]
  • No Fishing Community Entity approach can ever be successfully designed until the CDQ program is properly, fully assessed and its lessons learned.
  • The FCE subset called “the CFA proposal” currently in play at the NPFMC outlines Boards that will inevitably prove to fail Kodiak.  That entire proposal is a cart before a horse with no nose, and reflects improper public process.
  • [At the very least, proponents should have to answer whether municipalities will enjoin as members of a non-profit or stockholders in a for-profit venture – and how, if at all, the public will share in the proceeds of quota rents.  Groundswell opposes all IFQ, IBQ, and IPQ privatizations.]

Conclusion:   Groundswell supports full Transparency and opposes a public larceny of the crews’ historical shares.  We oppose the CFA proposal as presented.  We also oppose any private ownership of GOA fisheries.   Respectfully, Stephen R. Taufen, Groundswell Fisheries Movement

Comment here