Friday, October 1, 2010

Fallacies of Trawler Arguments to Kodiak City/Borough

Fallacies in the Trawler Paper Written for the Kodiak City Council:

Central Gulf of Alaska Tanner Crab Bycatch

1) FALSE: Tanner crab bycatch in the GOA trawl fisheries is not a conservation concern. Because observed bycatch is poor, gamed, and generally unreliable, arguments about the low level of bycatch percentages of total abundance are specious and a poor defense of a dirty fishing gear type. Gross data gaps on trawler bycatch of tanner crab prevent serious consideration of such arguments. More convincing is: 1) the photographic evidence coming to light of excessive bycatch of mature tanner crab, 2) the reported abundance of tanner crab in non-trawled sanctuaries, 3) the commonly heard complaints by trawler crews of waste.

2) FALSE: Closures to protect tanner crab will have adverse economic impacts. Projection of economic impact is always a crap shoot. Tanner crab protection closures in the long run most likely will result in greater legal and deliverable tanner crab catches, as well as raising the productive rate of halibut and codfish. Short term trawler deliveries and economics have the long term consequences of damage to other fisheries that in the long run will destroy the economic viability of the community. A look at the east coast fisheries clearly shows the disadvantages of short sighted management.

3) FALSE: Too many trawl closures. Actually, there are too few. With trawl impacts well known on crab grounds, many formerly productive brooding and fishing areas remain without protection from hard-on-the-bottom trawling. This is widely believed to be responsible for, or contributory to, the reduction of king crab to the status of nearly extinct, the known destruction of 2000 MT of halibut every year, more than 20 thousand Chinook salmon annually, and the crimping of the comeback of tanner crab we are discussing here. And all this is based on poor observer data. If we really knew how bad it is, we might not be so complacent to limit this widespread destruction.

4) FALSE: Crab predation by commercial groundfish, trawling is actually good for crab. This argument is closely related to the same old arguments used to put bounties on bald eagles and seals in the bad old days, and the wholesale shooting of sea lions more recently. These days will be bad old days too, in the future, especially if you buy into these arguments. Natural predation in a natural system should not be used as an argument to absolve responsible parties from the damage wrought by trawling. Pacific cod and Pacific halibut can be caught by fixed gear sectors with far fewer impacts to the environment, and have a greater economic benefit to the fishing community. To argue that trawling benefits crab production is preposterously absurd.

5) FALSE: Wait for better observer data. There is no reason to believe that future changes in observer data will change the impacts of trawling on tanner crab. We have been waiting for these many years for the Council to take action to protect the species under its prevue and responsibility. To delay action until some further action elsewhere can be considered is a poor way to be responsible for a species under duress.

6) FALSE: New science lowers mortality rate of trawl crab bycatch. Until science is peer reviewed, it must remain suspect. Hastily designed studies, unexamined, and unreviewed that are used to defend potentially damaging practices is completely irresponsible. Placards don’t prevent overboard oily bilge discharges, and they don’t stop crab and other species from being crushed and killed in cod ends. Throwing a dismembered tanner crab or dead halibut or Chinook salmon down a newly designed discharge chute is not a conservation measure, it is a travesty.

7) FALSE: Trawlers offer flexibility and innovation. The proposed closures are reasonable and prudent to protect the rebuilding of tanner crab stocks. Permanent or seasonal closures are the only way that protection of rebuilding tanner crab stocks can be reasonably assured. If stocks move across lines, perhaps the lines need expansion. If trawlers were innovative, they would petition the council to convert at least some of their high impact gear to less damaging gear such as pots or longline. Modified sweeps using bobbins simply mean the damaged species are not retrieved to the surface for observation. Juvenile pollock excluders are not catching the juveniles, but damaging them and failing to count that damage. Like modified sweeps, these innovations simply hide the real damage wrought.
We can't blame these inventive spinning spiders for their attempts to portray trawling as a a tolerable, even benefitial gear. They have, like other purveyors of dreams and distortions, come to believe their own deceptive thinking. They have become delusional. Profitably delusional, I might add.

"A delusion is a fixed belief that is either false, fanciful, or derived from deception. In psychiatry, it is defined to be a belief that is pathological (the result of an illness or illness process) and is held despite evidence to the contrary. As a pathology, it is distinct from a belief based on false or incomplete information, dogma, stupidity, apperception, illusion, or other effects of perception." Wikipedia.

Keep yer flippers wet.


Anonymous said...

Dear Assemblymember Jeffrey;
I was quite disappointed that the Kodiak Island Borough took a position counter to the long awaited conservation measure protecting Kodiak's recovering tanner and king crab stocks from bottom trawls. Mayor Selby recently wrote a letter on the Kodiak Island Borough's behalf which competely dismisses the fact that this proposal (which is up for final approval by the Council) has had its genesis in the NPMC science committee and was a result of data that none of us in the private or Borough sectors have access to due to the confidentiality regulations in place.

But rather than argue the pros or cons of this proposal here, I have a problem with the PROCESS. I have a deep suspicion that this policy decision by the Borough Mayor has neither the transparency or opportunity for the public to comment which both Alaska's Open Meeting laws and Kodiak Island Borough ordinances require. I have talked to persons who attended recent City/Borough fisheries Advisory meetings, KIB Borough Assembly workshop meetings and regurlarly scheduled KIB Assembly meetings and to their best memory are unable to recall a specific instruction to Mayor Selby to write such a position statement on behalf of the Kodiak Island Borough on this matter.

1) When was Mayor Selby authorized to issue this position statement on KIB's behalf?
2) if it is unauthorized action by the Mayor, when will the KIB either retract it or retroactively hold a public hearing and take an official position on this matter? The problem with holding a public meeting at this point is that most of the persons on the Island concerned about this issue will be travelling to Anchorage shortly to participate in the NPMC process.

If this position is unauthorized or was polled and approved in a non-public process, it should be recinded immediately. If this letter is an unauthorized act, a public remand of the Mayor by the Assembly would also seem appropriate.

I look forward to your comment on this.

(Name withheld by Wiglaf)

Anonymous said...

Mayor Selby's letter was sent on Monday, September 27, and indicates that he
and the "Kodiak Island Borough (KIB) and it residents" are "opposed to any
seasonal or annual closure areas proposed in the GOA Tanner crab bycatch

Despite the significant nature and impact of this issue, and the high
interest that this issue holds for the entire Kodiak community and for a
great number of Kodiak fishing industry participants, the public was not
notified that Mayor Selby intended to write or send this letter to the
Council. Neither was the public consulted on the content of the letter, or
asked to provide comment on the wisdom of Mayor Selby's recommendation, on
behalf of the "Koidak Island Borough and its residents", to the Council.

Moreover, the letter was not presented to the Kodiak Island Borough Assembly
for their consideration, nor was it included on the agenda of any KIB
Assembly Work Session or Regular Meeting. It appears that several members of
the KIB Assembly were not aware of this letter.

The letter states, in part:

"KIB is opposed to any seasonal or annual closure areas proposed in the GOA
Tanner crab bycatch alternatives. These closures are large and would
negatively affect both the pot and trawl sectors. The analysis shows that
high CPUE occurs for flat fish in the proposed closure areas, so moving the
trawl fleet outside the areas would likely increase bycatch, reduce ex-
vessel value to the vessels, reduce landing to the KIB and reduce raw fish
tax revenues. In addition, the logic of reducing the catch of the crab
predator fish swimming above the crab areas does not seem likely to result
in more crab."

Importantly, as you are likely to be aware, the Council analysis indicates
that "The purpose of this action is to provide additional protection to Gulf
of Alaska (GOA) Tanner crab from the potential adverse effects of groundfish
fisheries, in order to facilitate rebuilding of Tanner crab stocks. This
would be achieved by closing areas around Kodiak Island that are important
to the Tanner crab stocks. Areas would be closed to some or all groundfish
fishing, depending on the vessel¹s gear type or gear configuration. . . ."