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Minister LeBlanc Accepts Key Recommendation of Advisory Panel on LIFO

<b>Comment here

CNMI Got ‘Jacked,’ Fishery Management Council Is Told 

HONOLULU (19 March 2014) The Western Pacific Regional Fishery Management Council, which has authority over federally managed fisheries in Hawai`i, American Samoa, Guam, the Commonwealth of the Northern Mariana Islands (CNMI) and the US Pacific remote island areas, began its week-long meeting March 17 and 18 at the Fiesta Resort, Garapan, CNMI, and will conclude the meeting March 20 and 21 at the Hilton Hotel, Tumon, Guam. As part of the Council meeting, a Fishers Forum on the Malesso (Merizo) community-based management plan and on shark management will be held Thursday night from 6 to 9 p.m. at the Hilton Guam. Council recommendations are transmitted to the Secretary of Commerce for final approval. For the full Council meeting agenda and background documents, go to meetings section of the Council’s website at www.wpcouncil.org.

CNMI Submerged Lands and Militarization

 

CNMI Gov. Eloy S. Inos opened the Council meeting Monday noting fishery-related issues of concern to the Commonwealth. Key among them was President Obama’s Jan. 15, 2014, Presidential proclamation that withholds the transference of submerged lands 0 to 3 miles around five of the 14 islands that comprise the Commonwealth, i.e., Farallon de Pajaros (Uracas), Maug, Asuncion, Farallon De Medinilla (FDM) and Tinian.

 

U.S. Public Law 113-34, enacted in September 2013, conveyed title to the submerged lands around the 14 Northern Marianas Islands to the government of the Commonwealth. But President Barack Obama’s proclamation temporarily withholds transfer of the lands around Uracas, Maug and Asuncion (i.e., the Island Units of the Marianas Trench Marine National Monument) pending an agreement for “coordination of management that ensures the protection of the marine national monument within the excepted area.” Similarly, lands around US military leases on the islands of Tinian and FDM will be transferred upon an agreement that “ensures protection of military training within the excepted area,” the Proclamation says.

 

Inos said it is possible for NOAA and US Fish and Wildlife Service to continually disapprove any management agreement so they can retain control over the submerged lands within the monument. He asked the Council to support Commonwealth efforts to have the submerged lands “presently being held hostage by the US Departments of Commerce and the Interior returned to their rightful owners.”

 

“CNMI got jacked,” noted Arnold Palacios, Council chair and Secretary of the CNMI Department of Lands and Natural Resources (DLNR). “They gave us the submerged lands and then they took it back …. I don’t think they [Departments of Commerce and the Interior] are interested in co-management. The Antiquities Act [used to create the monument] doesn’t allow the co-management that was promised to us by the White House envoy.”

 

The Marianas TrenchMonument was created by President George W. Bush by Presidential proclamation on Jan. 6, 2009. The monument includes 95,216 square miles (60,938,240 acres) of submerged lands and waters in various places in the Mariana Archipelago and no dry land area.

 

“We got slapped, NOAA got slapped,” said John Gourley, a CNMI resident providing public comment. He noted that the Department of the Interior has sole management of the Volcanic and Trench Units of the monument, which contain two-thirds of the monument area.” While the Council membership includes a representative from the US Fish and Wildlife Service, that person was not present at the meeting. “We were blind-sided and treated unfairly,” Gourley said, adding that the authority of the withheld submerged lands should be returned to the Commonwealth.

“I’m angry, disappointed and frustrated,” said Lino Olopai, a CNMI resident of Carolinian descent. The Carolinian along with the Chamorro are the two indigenous peoples of CNMI. Olopai noted that their ancestral land predates the legal teachings that came “out of the blue” and were imposed upon them despite the language barriers for those who still use their native language as their primary language. He noted that the ancestral land, which was understood to include the water, was “handed down generation to generation without legal title. … Why can’t the American government understand and give the submerged lands back to me and then we will sit down and share it together …Give back what is rightfully ours with or without a legal document.”

“It is encroachment,” noted Council Executive Director Kitty Simonds, referring to FDM. A prime bottomfish fishing ground that is accessible to Saipan residents, FDM was occasionally closed to fishing by the military out to 3 miles for live-fire training, then 7 miles and now 10 miles with talk of permanent closures out to 12 miles.

 

“We aren’t asking the military to leave [CNMI],” said Commonwealth resident Rosemond Santos, a member of Guardians of Gani, former CNMI legislator and attorney. “But they have taken enough. We want them to respect us.” Gani is a Chammoro term for the islands in the CNMI north of Saipan, including FDM, Pagan (another island the military has been considering for training use) and the other northern islands, including the three contained in the monument.

“We do not own the land and ocean around our islands, we belong to it,” said Genevieve S. Cabera, another Guardians of Gani member. “The primary concern now is militarization … the military pushing the envelope.”

CNMI resident Gary Sword noted that the militarized waters around Guam and Tinian take away huge fishing areas. He said the average annual income per family in CNMI is $23,000. “We are not rich,” he noted. He also pointed out that residents cannot fish within 500 yards around Naval ships that utilize 11 prepositioning sites offshore Saipan. He said the heavy chains and anchors are killing the reefs, which are habitat for the fish. “Our fishing industry is dying because we don’t have anywhere to go fish,” he said.

 

Sword continued, giving a short history of the military in the CNMI. He said the Battle of Saipan during World War II included 524 ships and 30 days of warfare, leaving only 300 Chamorro living in caves. Then they were put into internment camps for two years. “The people of the CNMI have suffered a lot,” he said. “We have given a lot.” He noted that Tinian is the island from where the planes left with atomic bombs to stop the war. “Can we get some recognition for that? … Our children’s future is at stake. CNMI is crying out.”

 

The Council directed its staff to work with the CNMI government in its efforts regarding the submerged lands restricted by the President’s proclamation. The Council will also request that the Departments of Defense (DOD) and the Interior provide maps to the CNMI showing specifically the placement of CNMI’s 3-nautical mile boundary and CNMI submerged lands throughout the archipelago. The Council also directed its staff to continue monitoring DOD activities in relation to fishing access regarding potential closures around FDM, Tinian and Guam and request that the DOD and other entities provide financial support to the Marianas Integrated Management Committee, established to facilitate communication between the military and communities.

 

The Council also will urge the DOD to review the placement of their prepositioning ships in the CNMI; collect additional information from existing anchorage sites, to review changes in the anchorage and non-anchorage zones; promote a permanent mooring system, which would minimize further damage to the benthic environment, thereby allowing recovery of coral reef habitat; continue to pursue avenues to mitigate damage to benthic resources; and revisit and revise memorandum of understanding between the US Navy and CNMI, which allowed the Navy to anchor  the prepositioning ships without payment to the CNMI but may be expired. The Council recommended that the DOD provide the aforementioned assessments to the CNMI government upon completion.

 

Coral Reef Fisheries Annual Quotas

 

The 2006 reauthorized MSA requires that all federally managed fisheries have ACLs. Exceptions include fisheries that are managed internationally, fisheries for species with life cycles of less than one year, and non-targeted species designated as components of the ecosystem. The MSA also requires that the SSC determine the acceptable biological catch (ABC) and that the ACL recommended by the Council not exceed the ABC.

 

The Council reviewed the ABCs specified by the SSC for coral reef fisheries in Hawai`i, American Samoa, Guam and the CNMI and recommended that the ACLs be set 5 percent lower than the ABCs. The reduction takes into account social, economic, ecological and management uncertainty. The ACL is associated with a 25 to 40 percent chance of exceeding maximum sustainable yield (MSY), depending upon the species complex. MSA allows up to 50 percent probability of overfishing. The ACLs will apply for fishing year 2015 to 2018. A complete list of ACLs for coral reef fisheries for 2015 to 2018 can be found on the last page of this document.

 

Conflicting Local and Federal Shark Regulations

 

The Council heard presentations about the conflicting local and federal shark management regulations. The CNMI laws forbid landing of sharks with fins but allow landing of sharks for subsistence use. The federal law forbids the landing of sharks without the fins naturally attached. During a Fishers Forum on the issue of sharks held as part of the Council meeting on Monday night in Saipan, CNMI Congressman Ray Tebuteb noted that the CNMI shark management regulations were developed under a short time with limited information. Council senior scientist Paul Dalzell presented on the continued problem of shark depredation that fishermen have reported since the 1940s. The Council directed its staff to facilitate resolution of the conflict between federal and local shark regulations.

 

 

CNMI Bottomfish

 

The Council heard presentations about the regulation that restricts vessels larger than 40 feet from fishing for bottomfish 50 nautical miles (nm) around the southern islands of CNMI and 10 nm around the northern island of Alamagan. It was noted that, in 2009, the regulation was established to address concerns that larger vessels would enter into the fishery, compete with small boat local fishermen and impact the stock. Given the healthy state of the stock, the impacts of the regulations on the local fishing industry and concerns about the future of the local fishery, the Council recommended that as preferred preliminary alternatives that the bottomfish area closures around the Southern Islands and around the northern island of Alamagan be removed. Before the next Council meeting in June 2014, Council staff was directed to conduct meetings in Rota and Tinian to review the alternatives with those communities.

 

Western Pacific Regional Fishery Management Council: Appointees by the Secretary of Commerce from nominees selected by American Samoa, CNMI, Guam and Hawaii governors: Michael Duenas, Guam Fishermen’s Cooperative Association (Guam) (Vice Chair) ; Edwin Ebisui (Hawaii) (Vice Chair); Richard Seman, education and outreach specialist (CNMI); ); William Sword, recreational fisherman (American Samoa) (Vice Chair); Michael Goto, United Fishing Agency Ltd. (Hawaii); Julie Leialoha, biologist (Hawaii); Dr. Claire Tuia Poumele, Port Administration (American Samoa); and McGrew Rice, commercial and charter fisherman (Hawaii). Designated state officials: Arnold Palacios, CNMI Department of Land & Natural Resources (chair); William Aila, Hawaii Department of Land & Natural Resources; Dr. Ruth Matagi-Tofiga, American Samoa Department of Marine and Wildlife Resources; and Mariquita Taitague, Guam Department of Agriculture. Designated federal officials: Michael Tosatto, NMFS Pacific Islands Regional Office; Bill Gibbons-Fly, US Department of State; RAdm Cari B. Thomas, US Coast Guard 14th District; and Susan White, Pacific Reefs National Wildlife Refuges Complex.

COMMENT HERE

 

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National Marine Fisheries Service, Alaska Region

& United States Commissioner,

International Pacific Halibut Commission

P.O. Box 21668

Juneau, AK 99802

March 5, 2014

Response to February 19, 2014 NEWS RELEASE from NOAA Fisheries: NOAA TIGHTENS HALIBUT BYCATCH LIMITS FOR GULF OF ALASKA GROUNDFISH FISHERIES.

Dear Jim:

While NOAA puts a public spokesperson name on the news release for Amendment 95, let’s face facts — you are the Alaska administrator, and a voting member of the North Pacific Fishery Management Council. Accordingly, your news release was considered insensitive and not well received by disappointed GOA hook and line halibut fishermen: on line with other pro-trawler actions by the NPFMC and NMFS/NOAA.

Amendment 95 is not fair and equitable in practice. You and the agency and NPFMC are not doing what is feasible, not obeying the UN FAO precautionary principle, not balancing the economic impact among sectors, not doing what is best for overall national benefit and not serving USA consumers.

‘To the extent practicable’ — really?

It is high time NMFS and the NPFMC fully grasp that the directed halibut fishery has been reduced from 100% to 27% over the past ten years while Bering Sea/Aleutian Islands and Gulf of Alaska (BSAI, GOA) trawl fisheries continually receive extreme levels (millions of pounds) of halibut bycatch. How does your office square this with sixty (60) or more amendments to the North Pacific Gulf of Alaska Groundfish Fishery Management Plans (FMPs) since 1977 and the role of the far older bilateral agreement based International Pacific Halibut Commission — IPHC?

Does not the latter have treaty precedence over regional fishery management council (RFMC) FMPs or federal fishery legislation such as the Magnuson-Stevens Act (MSA) and related second-rate law? In other words, how does the Secretary of Commerce and RFMC realm dominate over Congressional first-rate Treaty power?

As you know, the NPFMC June 2013 Groundfish FMP supporting document reminds in “5 Relationship to Applicable Law and Other Fisheries—5.2 International Conventions” of the “Convention for the Preservation of the Halibut Fishery of the North Pacific Ocean and the Bering Sea (basic instrument for the IPHC)” of which you are a United States commissioner.

GOA groundfish Amendment 95, was a long time in coming, but about the phrase “to the extent practicable” — what does it mean to you in the dual-management course regarding the halibut specter?  Should we, and consumers, be insulted by how the term is applied or become reassured that continually unwarranted trawl bycatch can in any way help restore halibut stocks? NMFS and the Council seem to be totally impracticable; not only to us, but to any American consumer with whom we discuss halibut bycatch and bilateral legal intentions.

After all, the December 2013 expansion of GOA groundfish total allowable catch (TAC) by 52,000 MT has essentially removed any argument that there is still “a race for fish” that would warrant a trawl catch shares solution — giveaway allocations to the fleet imperiling halibut’s future. So why all this talk of allocation and so little about methods available to reduce bycatch, such as time and area closures, geographic multispecies problem identification and appropriate mitigation, etc.?  We hear the long dragged-out gear modification (excluder) discussion and can’t help but wonder, “when if ever?”

Jim, as NOAA’s representative on the NPFMC, and coinciding IPHC commissioner, we would appreciate you personally leading the way on strongly enforcing the real meaning of “to the extent practicable” in a multispecies, multi-sectored arena.  We expect you to be the strong voice at NPFMC when groundfishery amendments fail to protect the halibut and our directed fisheries. Otherwise, you represent the failure of NMFS on the frontline of destruction.

As the document says, “Many of the management measures contained herein are for the expressed purpose of mitigating a severe crisis in the domestic halibut fishery by recognizing a situation in which the trawl fishery (and possibly the sablefish setline fishery) could be a major contributor to declining halibut abundance.” And “the IPHC was created to conserve, manage, and rebuild the halibut stocks…”

Are you going to push the NPFMC and NOAA to reduce the bycatch of halibut, NOW!?  Does Amendment 95 even come close to making sense?  We’ve been taking huge cuts in the directed halibut fleet, year after year, while this small (almost insignificant) and easily attainable trawl bycatch reduction slowly comes into play by 2016.

Please, what are the real rates of GOA trawl bycatch, and reduction potential, after removing the gaming of the observer system? No one in the trawl fleet has ever come forward with the truth of what is possible, let alone what they actually bycatch. Observer coverage has now gone down from inadequate to miserably low.  Only government can force that fleet to be forthcoming, and NOAA has failed wholly in that regard.  Yes, wholly, because NMFS is still making “to the extent practicable” excuses.

Haven’t longliners have told you for 8 years that we’d pay for 100% trawl coverage? What could you have done to work for the consumers, for the taxpayers, for us and the halibut convention and providing best science, not best delay tactics?

It’s also galling that NMFS spits out in a news release, when stating — absent adequate scientific information and observer coverage — the damning-the-halibut-to-doom phrase, “while preserving the potential for the full harvest of groundfish in the GOA.”  What about preserving the potential for the full harvest of commercial halibut in the GOA and the BSAI, as well?

I meaningfully represent the voice of halibut directed fishers when I say that the trawlers must stop operating on a different playing field from us.  They never take any reasonable bycatch cutback while we take the brunt of the IPHC cutbacks.  Why can’t it be understood that the trawlers are deliberately committing a wanton destruction of our resources, and that is embezzling our IFQ wealth?

Trawlers cried about backing off a meager 7.5%, howled about an insufficient15%, but the real question is how we are going to get the trawlers cut down so that they cannot continue to decimate halibut stocks.  I.E. so that they cannot keep on operating irresponsibly, at the expense of other sectors’ incomes.

Do we run them out of business, since you’ve already ran us almost out of business?  Or can the Agency and Council turn this around while we still have a small chance to recover our halibut, crab and other multispecies stocks?

Optimum Yield means Multispecies:

What about our optimum yield (directed halibut): doesn’t it matter, too? Is it not also practicable to shut trawlers down to the same level as other sectors until they fish responsibly?  Again, I’ll remind you of our struggle to get 100% of the time observer coverage on all GOA trawlers so that the Council would know what is happening.  Not once has it been done; but just one season of 100% observer data would provide best science.

If it shows underreporting has been going on in the GOA compared to the BSAI, as we suspect, then stronger disincentives to abuse halibut are warranted.  If it shows the lower bycatch levels in the GOA are real, that had another effect, and gives the IPHC valuable, essential information to making its annual stock decisions.

Defining MSY re Amendment 95:

For now, there remains a demonstrably incomprehensible gap between the trawl sector’s balance of targeting and bycatch fisheries, when contrasted with the directed halibut fleet’s balance.  The former tilts toward wanton destruction of commonwealth and ecosystem collapse for halibut while the latter tilts toward consumer-serving and wealth producing sustainability. Shouldn’t the Council, with IPCH assistance, do Cost-Benefit analyses, and show value tradeoffs and comparisons, and how the nation and consumers fair under different management scenarios?

As G.P. Goodyear (NMFS 1996) said: “ … setting MSY as a management objective will often be insufficient for developing management advice unless the desire[d]

long-term age composition of the catch or some other qualifying factor is also specified. This is particularly true for the situation in which fisheries with inherently different selectivity compete for a resource …”

NOAA has ‘no data’ sufficiency, and lacks (i.e. we have yet to see) any “deterministic population simulation model.” Please feel free to correct me if that is not true. More to this letter’s context, as Joseph E. Powers states from NOAA’s Southeast Fisheries Science Center, “Perhaps, the most important implication is that before analysts can calculate maximum sustainable yield and associated parameters, management needs to define their desired mix of fishing and what “to the extent practicable” means.”

Powers reminds, “While Goodyear’s analysis was directed at the effects of target fisheries with different selectivities (such as commercial versus recreational), his comments are no less applicable when considering fisheries which discard bycatch of a particular stock in conjunction with other fisheries which target that same stock. The implications of Goodyear’s comments are that: MSY cannot be calculated until management has defined “extent practicable”! (underline added)

He talks in meaningful and reasonable terms, about “the dilemma faced by analysts when bycatch reduction goals (and allocations) are not defined. Additionally, metrics are suggested for evaluating ‘practicable’ bycatch reduction scenarios in terms of biological risk.” Finally, this note encourages debate on socio-economic, biological and ecological implications of bycatch reduction scenarios so that informed definitions of practicable bycatch solutions may be made.”

Imbalanced Public Input, as the GAO found out:

I have repeatedly sat through NPFMC discussions about bycatch and observer coverage, and generally heard scant discussion about such combined implications. The trawlers are unmistakably driving the regulatory boat, demanding first priority in GOA privatization, and

The problem started nearly 40 years ago by emphasizing GOA amendments are for groundfish, and relegating all the other multispecies to second class regulatory status. 60 amendments later, the focus is still on the trawlers’ brass polishing while halibut, crab and other interests clean the bilges and bureaucrats distance themselves from the hard work of going beyond looking at the cod ends, only. Maybe that’s a carryover from the initial focus on TALFF and foreign trawlers and motherships, as foreigners now own the shoreside groundfish plants instead. Trawler allocation focus takes up an inordinate amount of staff time, and budgets.

Jim, is there a calculation for the tens of millions of dollars this has cost Commerce as the NPFMC continues draining taxpayer coffers for this game?

It is primarily longline halibut directed fishers who get a mere 3 minutes, separately, to voice our concerns on the record — only to find the Council has pre-conceived its pro-trawler motion, guided by NOAA catch share mentality.  Therefore, 15% reduction, far too little and too late, instead of a 73% cutback like we have had to take in recent years.  What of the requirement to adapt the precautionary approach?

Over and over we are reminded, but cut short on “to the extent practicable” that 16 U.S.C. 1851-1852 MSA §§ 301-302; Public Law 104-297 outlines National Standard “(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.” It seems nothing short of draconian to reduce hook and line directed fisheries by 20 to 30% or more annually, year after year, because it is deemed practicable.  Well, to us, it is ‘practicable’ to also have trawlers to share by severe cutbacks in bycatch.

It’s clearly not for Safety nor to end a Race for Fish:

Canadian trawlers have to adhere to more imposing standards.  In addition, studies show that safety among trawlers after catch shares were awarded, decreased.  This contrasts also with the United States P.L. 104-297 Standard stating “(10) Conservation and management measures shall, to the extent practicable, promote the safety of human life at sea.”  Clearly it may not practicable to award quotas to trawlers, despite common perceptions that they serve safety at-sea.

Notably, the recent 52,000 MT increase in pollock TAC for the GOA essentially ended “the race for fish,” as recently confirmed in a Kodiak public fishery meeting by the Alaska Groundfish Data Bank (Julie Bonney), in a moment of truthful clarity.  So what, again, is the reason for GOA groundfish privatization?

The Precautionary Approach:

Returning to C.F.R. § 600.350 (J) Social effects, adds, “(ii) The Councils should adhere to the precautionary approach found in the Food and Agriculture Organization of the United Nations (FAO) Code of Conduct for Responsible Fisheries (Article 6.5).”  In addition, Principle 15 of the Rio Declaration of the UN Conference on Environment and Development and the 1995 United Nations Fish Stock Agreement strengthening the precautionary approach, combined, address “regardless of their jurisdictional nature, recognizing that most problems affecting fisheries result from insufficiency of precaution in management regimes when faced with the high levels of uncertainty encountered in fisheries.”

Recently, voting in favor of my/our proposal, the Alaska Board of Fish closed the final bays around Kodiak Island that were left open to hard-on-bottom trawling, and we hope someday they will exclude all trawling in state waters, like is done in SE Alaska. Halibut and salmon were on their minds.

What is precautionary about reducing overall observer coverage on trawlers from 30% to around 13%, and thereby hogtieing analysis from ever gaining legitimate data?  What is precautionary about a stepped cutback of only 15%, even 50%,

73% reduction, i.e. matching trawl reductions directly to that of the directed halibut ACL/TAC quota? Are you certain that NMFS is in compliance with Article 6.5?

“To the extent ‘able to be’” means…

Foremost, let’s just get clarity on what the adjective “practicable” means: capable of being done, effected, or put into practice, with the available means; feasible, capable of being used, designed or constructed for actual use; workable, achievable, attainable.  Practicable is that which can be done with the means at hand and with conditions as they are and given current and emerging technology, along with more area closures and time adjustments, under greater levels of observation, too.

To a hook and line fisher, regarding trawlers, practicable means trawlers can keep their nets completely off the bottom (not ride there on small disks in order to fake avoidance while knowing halibut stir and end up in their nets), they can not fish at night, and can move away from halibut grounds and find groundfish elsewhere; and they can take a 73% cut in their GOA (and more in the BSAI) fishery income, too.  Is it not feasible, ‘practicable,’ for them to also share with us the overall economic loss?

Bycatch Matters & Data Collection is Imperative:

§ 600.350 National Standard 9—Bycatch: (d) Minimizing bycatch and bycatch mortality, states “The priority under this standard is first to avoid catching bycatch species where practicable.”  It goes on to immediately state “Fish that are bycatch and cannot be avoided must, to the extent practicable, be returned to the sea alive. Any proposed conservation and management measure that does not give priority to avoiding the capture of bycatch species must be supported by appropriate analyses.”

Trawlers cannot return to the sea alive, to any reasonable measure, survivable halibut. And I have never seen anything close to “appropriate analysis.” Based on what expert data, may I ask you to show us?

Rather, we note that in combination with § 600.350, MSA 303(1)(11+12), tells us that you are responsible to “promote development of a database on bycatch and bycatch mortality in the fishery to the extent practicable.”  There’s that adjective again.  Does it have meaning or simply serve as an excuse for NPFMC failures?

To me, obtaining that data has long meant a proposal for100% of the time observer coverage in the GOA, preferably paid for by trawlers — but which hook and line fishermen have long agreed to fund: because we knew that absent that database, our future, now turned into the present — was solely politically doomed.

In that meantime, how many millions has NMFS spent on a slowly developing and far more costly Observer program that has had the effect of reducing Trawl observation by two thirds, to 13% — one ninth of what’s ‘practicable’ and cost effective.

Predictably, we now barely pay seasonal fishery expenses on the highly reduced directed harvest pounds.  It makes me sick to watch my vessels docked while trawlers not only in large part clearly caused the directed halibut quota drop (their propaganda to the contrary) while they got 52,000 MT more groundfish this year in the GOA, which only increases the pressure on destruction of our halibut.

Bycatch reduction is obviously not much of a NMFS or NPFMC priority, despite the many laws.

The October 9, 2012 NPFMC motion on ‘GOA Trawl PSC Tools’ contains many errors.  Regarding the Purpose and Need Statement: Surely safety will not improve just like Canada; and as we experience in BSAI crab, the processing plants will still tightly schedule deliveries and the fleet will continue to fish in questionable weather. It is also rather flagrant to state “This program will not modify overall management of other sectors in the GOA … which already operate under a catch share system.” On paper? What a convenient trawl-faced lie.  Because I can guarantee you that my entire business plan and quota management and accounting (cash inflows and outflows) and financial credit, for Area 3 and Area 4 annual halibut operations has been devastatingly modified. As is true for other halibut longliners.

Regarding the Goals and Objectives: there’s no concern for related species’ “fair and equitable access” or “consideration [of] the value of assets and investments” and what it means to our community when we bring home coast wide halibut income.  Is Goal 5 taken seriously — “Balance interests of all sectors and provide equitable distribution of benefits and similar opportunities for increased value” — by the NPFMC and your office?  How about Goal 13: “Minimize adverse impacts on sectors and areas not included in the program” — how is that happening?

Fair and Equitable would reallocate Groundfish and PSC to Longliners:

It is a simple observation that the NPFMC and Commerce are allowing the trawlers to conduct a massive directed fishery on halibut bycatch, within international jurisdiction.  It is an obvious conclusion that one redress for those harms would be to reallocate a portion of the groundfisheries and PSC — should a catch share system be emplaced, as is the apparently unstoppable political will of NOAA — to the harmed longline sector.

We’d find a way to hire a few clean fishing skippers and put to sea trawlers and crews that truly care about conservation and bycatch reduction.  Then you could compare our 100% observed clean practices to the existing devastation. Allow us to keep the marketable halibut and reward USA consumers with high quality protein, contributing to maximizing the net national benefits.

It would be ‘practicable’ to kindly answer to many questions posed within this letter.

As you know, GOA bycatch rates deviate inexplicably from the BSAI, and the public perception justified by that is “trawlers are raping the ocean.” Likewise, Bering Sea areas that are closed to longliners, to help rebuilding halibut stocks, remain open to trawlers. The top rapists — hard on bottom trawlers — are allowed to operate there. What good does that do?

They have no defense, no facts to warrant this welcome to the school yard management policy.  The facts are on our side, and we are bound to the IPHC convention while they scurry off to the shadows to massacre halibut as bycatch. It hardly needs mentioning again, PSC means “prohibited species catch.”

The trawlers fishing behavior will not improve until the government comes along, like in Canada, and says ‘you will change, now!’ And until they rush to put observers aboard, full time, and finally determine their true level of responsibility for halibut declines.

Government must stop them from fighting the 100% full time coverage, which can only be viewed by ‘a reasonable man’ as concealing the truth.

Jim, retirement approaches and you won’t be with us that much longer on the NPFMC. Isn’t it time you be the one to start pounding a shoe on the table and champion the cause of fair and equitable FMPs “mitigating the severe crisis in the domestic halibut fishery” and holding trawlers’ feet to the responsibility and accountability fire?

We’d like your help, Administrator. Commissioner.

Respectfully yours,

Lu

Ludger W. Dochtermann; F/V North Point, F/V Stormbird

P.O. Box 714; Kodiak, AK 99615

 

Comment here