Monday, December 12, 2011

MCManman and Keaton Conspire to Confuse Less Careful Readers

On page six  and seven of December's 2011 Pacific Fishing Magazine's Don McManman starts a twisted apology (probably mostly to advertisers) about having passed on information Wiglaf pulled from official NMFS numbers (although McManman seems to confuse Wiglaf and Medred).  Josh Keaton of NMFS also weighs in to twist Wiglaf''s flippers over the posting.  Admittedly, Wiglaf has been pretty hard on NMFS for not protecting the resources of the GOA.  McManman even includes some palaver from Merrick Burden, of MCA, a wholly owned and operated extension of the draggers and processors serving as a thinly guised propaganda service to promote DP interests.  Ordinarily, I wouldn't bother to respond, but since this is a clumsy attempt to gut our credibility, here goes.   I do appreciate that this need to fill two pages in Pathetic Fishing means we hare having some effect, or no one would mention us.

No projections of the Alaska Beauty's catch was made by Wiglaf.  Straight off NMFS's report.  No application to the fleet was made by Wiglaf; the Alaska Beauty is regularly dirty, owns no IFQ halibut and so is apparently disinterested in taking care of that resource.  (Don't you love the way Keaton apologizes for the Alaska Beauty?)  We have to wonder though, what happens when Alaska Beauty doesn't have an observer aboard.  Keaton says one observed bad tow, NMFS records show there were five.  NMFS numbers: 43% of his catch of cod was PSC halibut.  Beauty, eh?  A black mark on Alaska to be sure.

The fleet-wide catch was officially extrapolated with an approved NMFS model by NMFS number crunchers and published as such.  That they adjust these numbers regularly as they feel the pressure by the industry to deflate them or find errors in their methods (are there many?) should be our concern, but we publish as the information surfaces.
24 September 2011
This link has weekly bycatch rates/mortality by area and gear type. (Thanks, GF)

As far as to what Craig Medred says (we saw the error in his report), we have little care.  Medred is devoutly anti-commercial fishing, and so is hardly an ally, except that "the enemy of my enemy is my friend" occasionally makes him useful.  Nobody, after all, informed of the horrific bycatch waste in the Gulf of Alaska fails to flinch.  And while it is true we all have bycatch, whether pot, longline, seine, troll, jig, gillnet; the fact remains that trawl bycatch is beyond what anybody should tolerate, and while we argue, trawlers are busily degrading the GOA, its habitat and ocean inhabitants.  NMFS is comfortable with its own models and sincerely does not have the will to change the modus operandi of GOA trawling.  Some say they sincerely don't care.  Too much trouble and too much well financed opposition with no political backbone in DC to back them up.  Fisheries science is up for sale.  Wake up. 

"At times the GOA trawl fleet seems more intent on avoiding halibut (PSC bycatch) than actually catching its target species.  The fleet voluntarily stood down for three weeks in September because of high (observed) halibut bycatch."  Don McManman says.  Oh, Don, come on, you are not really that simple are you?  They had damn well better be careful.  If they exceed the PSC they will be forcibly shut down by Federal law.  Their behavior is called self interested self preservation.  McManman kisses on...

"The GOA trawl fleet also voluntarily took on 100 percent observer coverage---paid for out of their own pockets---to ensure an accurate and timely count of halibut bycatch."  Really?  Don, they didn't do that out of the goodness of their hearts, it is called CYA.  A PR ploy that worked on you and didn't cover anymore time than they needed it to, operating as an informal co-op.  Part of this was to stopper their 'pirate' or sloppy skippers who can't avoid bycatch because they are too unskilled or impaired.  It was also a demonstration of what they could do if we give them the Gulf as IFQ.

Years ago, Al Burch said we had to hang together as commercial fishermen or the greenies and the tree huggers and PETA would hang us all separately.  It is a simple argument that has appeal if you are basically distrustful or paranoid, but not if you are more willing take a chance with honesty with the fish consuming public.  It is the public's ocean.  We need to clear the air, fish as cleanly as we can and change how we catch fish if we need.  If dragging is unable to clean up its act, it needs to go the way of the dinosaurs...extinct.  That restricting trawlers might affect Pacific Fishing's bottom line, or anyone else's, is meaningless in the long run, and that is what we care about, the future of fishing.  We look east of us and see it is mostly gone or a shadow of its former health/wealth.  We don't want to look back at the good old days.  We want them from here on into the future.  You got a problem with that?

Bycatch is an emotional issue, you say?  Damn right.  To see the future swept away by the lust for profits, to see the passive response of NMFS and the NPFMC to such criminality of wasting this year 1829 metric tons of halibut.  One metric ton is 1000 kilograms, so a metric ton is roughly 2205 pounds, so 1829 X 2205 = 4,032,945 pounds.  Check that Don.  No bullshit.
This is straight off the internet.  Try it, you'll like it.  And if what we believe is true, this is a fraction compared with what is really being killed off as bycatch in the Gulf. 100% observed trawling for an entire year will get us some ground-truthing of what the real cost to the resource is for complacency over trawl bycatch.

Journalists are dependent on economics to survive.  Fishing magazines (all small magazines) are under stress.  They need every advertising dime they can garner.  The smaller the outfit the more dependent they are on their advertisers.  Advertisers hate controversy.  It is hard on the bottom line.  So most journalists are not very independent, they depend on advertising dollars for their daily bread.  Bloggers are not dependent on cash made from their journalism.  They can speak the truth as they see fit without the compromise of fearing offending groups (except for violent threats).  The blog is a leveler.  Wiglaf is saying nothing that hasn't been said before on the docks, but for the first time, you can read it out loud and online.  This news can get beyond the shorelines of this little fish town.  That shakes things up.

Last. Anonymity is for self protection.  What's a name, anyway?   Call me Wiglaf.   Judge the argument.   If you want to get a hold of me, use the comment link, but otherwise don't waste my time.

Keep your flippers wet.

Wednesday, December 7, 2011

Proposal: 100% Observer Coverage an All GOA Trawl Vessels for One Year

Submitted Repeatedly for Six Years
on the Official Record of NPFMC/NOAA Fisheries
D-3 Groundfish Issues and D-5 Staff Tasking-Requesting Placement on the Agenda

Applying National Standards: 
NS #1  Issues of rebuilding, optimum yielding, preventing overfishing
NS #2  Best science and providing most current, comprehensive information
NS #3  Close coordinated management
NS #7  Minimize costs (damaged stocks, wasted fuel, etc.)
NS #8  Sustained community participation
NS #9  Minimize bycatch and mortality on non-target species.  For multispecies management to maximize net national benefits from Kodiak fisheries

Name of Proposer: Ludger W. Dochtermann
Date: (orig. June 1, 2005) December 7, 2011

Brief Statement of Proposal:
Full (100%) Observer Coverage on All Gulf of Alaska Trawl Vessels for the Year 2012, and once in every 3 years, thereafter.  By "Year 2012," I mean "year-1 deployment" - i.e., before any further Rationalization or Catch Share regulations are promulgated.  So, inherent in this proposal is a halt to further action until the best (adequate) scientific data is made available.

Objectives of Proposal (What is the problem?):
To accurately evaluate the trawl fishery subsector's entire catch performance regarding the bycatch of non-targeted species and the on-board management conduct of the fishery's prosecution.  There us a serious need to have years of full knowledge regarding bycatch for several reasons, not the least of which is for comparison with other years of reduced coverage where the Nation relies upon self-reporting during non-observer hauls.

Need and Justification for Council Action (Why can't the problem be resolved through other channels?):
Due to the nature of the extraordinary value of bycatch-often exceeding the value of targeted species, and due to the nature of massive discards when incidents of "bad hauls" occur, NOAA Fisheries and the Council need a more accurate base, of first data year statistics.  Absent the presence of constant recording cameras and other means of improving data collection-and given the need for human confirmation of such 'remote sensing' were it to occur-the 2012 fishery would be a first start in accurate measurement.

Human behavior, swayed by overwhelming economic rewards and absent effective comparison data and enforcement, demands that NOAA base its decisions on more accurate data, and confirm that said behavior is not incorrectly reported when observer coverage is not at 100%.  The Council and NOAA are also aware of the uselessness of GOA bycatch data.  The OMB needs to review Compliance with Data Quality Act in the self-reporting system.

The recent submittal of pictures of tanner crab bycatch in the Kodiak groundfishery at the June 2009 session clearly demonstrates the need for 100% observer coverage, full time for one base year.  The pictures from simply reinforce this message.  While some have historically considered Bering Sea crab pod encounters to be rare, true or not, around Kodiak, trawlers do fish shallow bays and other grounds that increase the likelihood of pod encounters or are simply dragging through crab abundantly concentrated on the ocean floor.

Foreseeable Impacts of Proposal (Who wins, who loses?):
The program would arguably be costly and operationally inconvenient to many vessels, however government could cover much of the costs in return for the knowledge gained.  For the cost of not having full and complete knowledge-at least every 3 years, and at least once in 2012-before creating any further arbitrary resource allocation (property rights shifting) regulations (such as rationalization schemes) may be a grave loss to society and regional economies as heavy impact, intense methods of fishing, i.e. hard on bottom trawling, proceed unabated and unwatched.

The question of  'who loses' has been answered by the profound losses suffered by crab and halibut fishermen unless a 100% observer program for one base year is put in place.  Considering that Kodiak was once the 'king crab capital of the world' and its restoration continues to be severely harmed by trawl subsector bycatch incidents, the Council needs this base year to analyze such comparable loses.
The question of  'who wins and who loses' is also moot under the logic that the Public resource is an invaluable asset for the Nation, and no one loses when we all know what are the true conditions of the prosecution of such fisheries.  Everyone wins when regulations are based on the best data, and when they follow the National Standards in the Magnuson-Stevens and Sustainable Fisheries Acts, in their spirit and intent-especially when the regulatory process proceeds on science, not politics and greed.

Are there alternative solutions?  If so, what are they and why do you consider your proposal the best way of solving the problem?:
There is another means of keeping an eye on the prosecution of the fishery, but the cost of having numerous Coast Guard vessels on site, around the clock, along with random boarding fair observer coverage would be much higher than instituting a full coverage year stratification program that operates only once every 3 years.

Supportive Data and Other Information (What data are available and where can they be found?:
This is a complex matter, as NOAA has not had adequate budgets for better research.  But the conduct of the trawl fishery and the witnessing of its highly destructive prosecution are well known among NOAA personnel, Alaskan communities, and fishing crews.  The Council and NOAA have greater insight on data collection and statistical need, and that could all come out during discussion of this proposal were the Council to specifically request NOAA to go forward with 100% observer coverage in 2012 (or 2013).

I ask you to please take this into discussion on Groundfish Issues, and to make your motion for prioritization of a 100% observer coverage Year 1 deployment, specifically in the GOA trawl sector.

Ludger W. Dochtermann,  F/V North Point, F/V Stormbird- Kodiak, Alaska

Monday, December 5, 2011

Unaccounted for Halibut Mortality Explained?


The announcement by the IPHC that halibut predicted by the stock model have gone missing in following years has led me to think about where they may have gone.  When Doug Hoedel was on the NPFMC (and had a huge halibut PSC problem while trawling cod), he said, at an informal meeting in Kodiak, that trawlers needed 8,000 metric tons of halibut for their bycatch needs. Later, at another meeting, Julie Bonney of GFDB repeated the same number.  Now I wonder how they both came up with that specific number? 

Most people familiar with this fishery realize that the present 2,000 metric ton PSC cap on Gulf trawlers is nearly meaningless due to gaming of the observer program, potential sampling problems, and industry involvement in the generating of bycatch numbers that appear to always lead to reductions.  Could it be that the 8,000 metric tons (17,600,000 pounds) of halibut bycatch desired by the GOA trawler is closer to the actual number that they know they catch?  If it is true, 6,000 metric tons (13,200,000 pounds) of mortality would be missing from the IPHC management model each year from this one fishery in the Gulf of Alaska. Each year the model would recommend a directed catch that was substantially too high.  The next year's survey and directed fishery CPUE data would see this but the model would produce a new harvest goal that was still wrong due to the unaccounted for mortality.

Unaccounted for bycatch leads to poor modelling by stock managers.

I would recommend to IPHC director Bruce Leaman that his staff retrospectively run the model calculations with 8,000 metric tons of gulf trawl bycatch to see if the model predictions are corrected.  Knowing the magnitude of the "missing" halibut would be a good start to finding them.