James W.  Balsiger; Ph.D. — Regional AdministratorLu Dochtormann

NOAA Fisheries’ NMFS Alaska Region

Cc: Glenn G. Merrill — Sustainable Fisheries Administrator

P.O. Box 21668

709 W. 9th St., Rm 420 UPS/FedEx only

Juneau, AK 99802-1668

907-586-7221 Email: [email protected]


Cc: Penny Pritzker, Secretary

U.S. Department of Commerce

1401 Constitution Ave., NW

Washington DC, 20230

Main Tel: 202-482-2000


From: Ludger W. Dochtermann, fishing vessel captain/owner – Kodiak, AK

Monday, 17 October, 2016

Bering Sea/Aleutian Islands Crab & Halibut Biomass Loss

Impacted by Hard-on-Bottom Trawling Fleet

Dear Sirs:

You are both aware of our vessels, F/V North Point and F/V Stormbird who fish BSAI & GOA halibut, crab, and tender salmon in Bristol Bay — and of my significant investment in vessels, pots, gear and quotas for those grounds. Likewise, that my investment is enormously impacted when unforgiving behavior in the trawl groundfish industrialized mega-sized effort strikes at the heart of the sustainability for other bottommost stocks.

I am currently studying a few charts of the drag fishing going on in Bristol Bay – where between 20 and 30 million pounds of Halibut are caught by the drag fleet.  One chart for the Amendment 80 fleet — Figure 4; Page 435, labeled NOAA Fisheries Page 9 — circled in particular for the Proportion of 90th Percentile Hauls (between 2011 and 2014) from north of Unimak Island westward to Unalaska, shows a 90-mile wide swath of destruction in the primary area my vessels do selective pot crab and longline halibut fishing.

We do not in any way negatively impact trawler groundfish targets, yet they devastate our halibut stocks and smashingly annihilate pods of crab.  Their penny-worth poundings on the ill-defined Optimum Yield meaning “as many tons as possible” are economically indefensible compared to our value-defined OY.  That is, our catches and their values to American consumers far outweigh their excuses to squish fish by the dozens of metric tons into ‘cod ends’ to produce whitefish paste and other foreign bound protein.

The worst part of this demise is that since we kicked out the foreigners, foreign money and control has done increased damage to the halibut stocks across Alaska waters — as most illuminated by the Amendment 80 fleet.  The result is a drastic decline in the USA economic zone just to serve foreign economies, as most of their product transfers overseas to related parties in undervalued trade, denying US taxes and profit retentions.  The worst form of global Capital Flight, all too common to resource exploitation industries, is when Alaskans themselves hold less and less of the quota rights for our fish!  The substitution of access privileges for asset commoditized private fisheries.

In the GOA, for over 10 years, myself and others proposed 100% full-time Observer coverage on the trawl fleet on all catchers and catcher processors.  Over a dozen times the proposals were presented at NPFMC sessions, to the council and its panels, without any results.  A planned delay tactic occurred whereby Observer committees and time-wasting NOAA employees simply dithered around while providing year after year of official excuses for no real action.

The fisheries most negatively impacted by un-observed bottom trawling were made to pay a price by taking aboard their smaller vessels the very observers that should have been on groundfish industrial boats.  It was a waste of money and a deliberately designed waste of our time.  The worst result being that coverage on trawlers dropped from around 30% to 11% or less, and we still do not know —10 years later— what is really going on with their devastating practices.

I won’t even step in the poop of the trawlers’ insane reasoning that they need “another tool in the toolbox” — “we need our own ITQs” to resolve bad fishing practices; i.e. paper ownership dreamlike economic satisfactions for free, would then fix on-the-grounds fishing practices in the real world’s oceans.

In terms of fishing behavior, there are still a few of us who are “real” fishermen, thankful for and protective of the bountiful blessings of the ocean’s fish stocks of all species.  Fishermen who don’t scrape up everything in sight; men who look to the long term result of fishing behaviors.

Studying the Amendment 80 Page 435 chart for bottom draggers in Bristol Bay, it is really a wonder that we still have any crab left at all.  And that halibut survive.

My livelihood is made by selective-gear targeting on a particular species, without the incessant harm that a giant scoop-up drag net fishes against good practices.

We, the responsible, do not target on “all other fish is shit to us” as does the hard-on-bottoms.  They have no respect for the Precautionary Principle, and never have to prove that their practices are worth the damage and economic losses they cause to all other fishermen and the Nation.  NOAA Fisheries fails to calculate those tradeoffs, as well; and at no NPFMC session will you see the worksheets —appropriate analysis— outlining the economic comparisons, or hear discussion of Burden of Proof by trawlers to justify their failures to follow the Precautionary Approach.

We are continually deprived —by NOAA and the NPFMC— of intelligent evaluations of “the negative impacts on affected stocks; incomes accruing to participants in directed fisheries, both in the short and long term; and incomes accruing to participants in fisheries that target the bycatch species” that Title 50 Wildlife and Fisheries, Sec. 600-350 assuredly promises.

It is apparent that the answering to all these overlooked and mishandled problems will come in “the empty future,” when there will only be junk fish left on the table because the giant factory trawlers and the BSAI and (GOA) Kodiak bunch will have finally devastated the rest of the grounds.

Maybe I should just propose to the Board of Fisheries that they next open up Southeast Alaska waters to trawling.  After that proposal hits the deck, then you’ll be able to hear the howling cries in Juneau from both Southeastern fleets and watch the Canadians march west to stop the wanton destruction in adjacent waters that will also devastate their fisheries.  Share and share alike! — doesn’t that apply to the pain of unobserved hard-on-bottom fisheries for all Alaskans, and Canada too?

Yes sir, the graphics of Figures 4-6 on pages 435-437 (prox.) for the Amendment 80 sector alone are eyes-wide-open focus on the damage meganet-draggers do to our fisheries.  When arises “Enough is enough?”  When “do, not try?”  Fair would be that your taxpayer subsidy fat salaries drop annually by the same percentages as crab and halibut — then maybe you’d wake up!

In perspective with the fact that “Greed is Good” is increasingly the main motivator in all aspects of economic societies, it is particularly seemly omnipotent in the globalized fishing business, where “bigger is always better” and “the little guy” is meant to be squeezed out as the ‘market liberalization’ theory’s resource corrupt room gets smaller.

It is impossible for you to be administrators at NOAA without clearly seeing that catch share sealords and exclusive-cooperatives’ thieves are recklessly stealing fish nationwide —usually with privatized go-aheads in government monopolized quota worlds— especially on the East Coast, with Alaska communities right behind.  One only hopes for real “Justice,” and that can only start with freedom from the mistaken management ‘no think’ hypotheticals of experiments in fisheries.  The market destroying fact inherent is hypothetical “market-based solutions economics,” and the incredulity that any professional might posture that greed based monopolizations and asset commodification of quota share ownership is somehow an actual fishery management tool, boggles a real fisherman’s mind.

Opilio crab is the lowest quota in history and Bairdi crab has disappeared, the snow crab TAC dropping 50% to a mere 21.57 million pounds, and there are still no suitable pot limits in place.  When I am finally put out of business, which seems an unstoppable near future, when Halibut is down, Crab is down, and in all aspects the money is drying up!  St. Matthew crab is dead — the Pribilofs are dying too.  Another year and we close shop on crab.

Now, we have very little and soon NOTHING!  “Thank you, Jim for all the help!”  But it is time to stop mere trying and start doing.

Madame Secretary, won’t you please bring back some reality and real solutions, to save hundreds of real fishermen and our fishery dependent economy, before it is too late?

Respectfully yours,

Ludger W. Dochtermann; POB 714; Kodiak, AK 99615

Tel: 907-486-5450 Cell: 206-245-5153