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

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GOA GROUNDFISH TRAWL SUBSECTOR OBSERVER PROPOSAL

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 tholepin.blogspot.com 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.

Signature:

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