Yesterday was the first day of the North Pacific Fisheries Management Council's Advisory Panel's work on the proposed halibut PSC bycatch rollback. Testimony by draggers yesterday was for the the most part passionate, immature and indefensible. It ranged from blaming the IPHC for the decline in halibut numbers, or claiming there was more halibut in the Gulf than ever before. Draggers lashed out at longliners for wasting more halibut than draggers do and for being poor stewards of their own resource. Then they turned to fear mongering by claiming the Kodiak economy will collapse if they have to save any more halibut and by trying to excite fear in processor workers for the loss of their jobs, while the processors themselves lobby for more foreign workers. Only one drag skipper said he could do better, if given the "tools," (dragger talk for quota share of the groundfish in the Gulf.) He was the only one to admit a rollback on bycatch was doable. He was the only credible dragger to testify.
Except for the factory longliner representative, the rest of the testimony was for a 15% cut in the PSC bycatch of hailbut. Many people are here in Kodiak to participate in the NPFMC process from out of town. Audience included Council members Chairman Eric Olson, Dan Hull, and Roy Hyder.
Letters to the Council included one from the IPHC, quoted below. Let us hope the Council will do its duty. We expect things to heat up as the process goes forward.
----------
Dear Chairman Olson,
The staff
of
the
International
Pacific
Halibut
Commission (IPHC) provides the following comments and recommendations regarding your scheduled decision
on revisions to the Gulf of
Alaska (GOA) Pacific halibut Prohibited
Species Catch (PSC) limits. The basis
for
the Commission staffs comments is the biological and conservation aspects
of the issue, i.e., how the halibut resource is affected
by
bycatch.
We
also
wish
to
clarify
some
misconceptions regarding juvenile halibut abundance in the GOA and relationship
of the stock
status
to the female spawning
biomass reference points.
As we have previously stated to the Council, bycatch
has a significant biological impact on the halibut
stock. This occurs
through impacts on the female spawning biomass (FSBio)
and on overall stock productivity (yield
or CEY). The magnitude of these impacts
is driven by the size of the fish when it is taken as bycatch. As our 2011 analysis (Hare et al., 2012; Appendix
5 to the EA/RIR/IRFA) demonstrated,
the impacts
are either immediate, in the case of the larger 026 halibut, or delayed, for the
smaller
U26
halibut.
The
mortality
of
the
U26
fish,
and
the
subsequent delayed impact on CEY and FSBio,
is
particularly
important
to
the
health
and potential for recovery
of
the stock from the current low level
of
exploitable
biomass.
Our analysis showed that for every pound of PSC reduction, 2.155 pounds of FSBio would be gained, primarily from the savings on U26 mortality. It is important
to note that the FSBio multiplier is larger than 1.00 not only because
growth outpaces mortality for juveniles but because females also spawn more
than once during
their lifetimes, contributing
to the stock over a number
of years. Directed fishing
on this size of fish would not be contemplated in halibut harvest
policy because it would clearly
constitute growth overfishing, as well as including the negative aspects
of fishing sexually immature
fish.
As
such,
we
believe
that
reducing
mortality
on
the U26 component
will
provide
opportunity
for
the
stock
to
rebuild
through
increased
survival
of
juvenile recruits, a greater female
spawning biomass, and increased yield to directed
fisheries.
Under several
likely migration scenarios, analysis by the IPHC staff shows that
the impact of 026 bycatch is primarily in the area in which the bycatch
is taken, whereas
the impact of U26 bycatch
is felt more downstream, Migration
is a dynamic process, one that changes with stage of
life history, area, and time of year. It is perhaps further driven
by environmental factors,
such as availability of prey, competition for space and food, water temperature and related conditions, or other factors.
The
difficulty
of
precisely
estimating migration rates does
not
mean
that downstream impacts do not occur and the impacts
on the coastwide stock have been described to the Council in previous IPHC reports and presentations. The Council can expect that PSC reductions would extend to 'downstream'
areas, as is described
in Section 3.2.3.1
(pages 26-33) in the EA document, and as was also described by IPHC staff
at
the
April
NPFMCIIPHC workshop.
An
additional
concern
is the potential
underestimation
of halibut
bycatch in GOA groundfish
fisheries. It is widely acknowledged that current observer
coverage requirements are inadequate for providing accurate estimates of bycatch, but the true level of mortality on the juvenile
portion of the stock may never be known.
We believe a proper
management
response
to inaccurate
estimates is to follow a precautionary principle
on bycatch management, which justifies
both a reduced set of PSC limits and coincident improvements in bycatch estimation. In
other jurisdictions and in the Bering Sea, the operating
standard for observer
coverage has been at the 100% level, as
well as including specific tools (individual bycatch quotas) to allow individual
harvesters to control
and benefit from bycatch reductions.
Summary of impacts
- From
discussions
with
agency
staffs,
stakeholders,
and
others,
it
is apparent that some are confused
regarding
the magnitude and type of impact which bycatch
imposes on the resource. The table below,
extracted from Dr. Steven Hare's presentation at the recent
NPFMCIIPHC Workshop, summarizes the impact of one pound of bycatch
mortality on lost CEY and lost FSBio.
|
CEY(lb)
|
FSBio (lb)
|
Gear
|
026
|
U26
|
Total
|
Total
|
Trawl
|
0.625
|
0.427
|
1.052
|
2.155
|
Hook-and-Line
|
0.752
|
0.226
|
0.978
|
1.208
|
Some primary conclusions:
• Bycatch mortality affects both
the
available
yield
(CEY)
and
the
female
spawmng biomass (FSBio).
• These impacts differ
by gear type, which is driven by the size composition of the bycatch for each gear type.
• The impacts are both immediate, in the case of the 026
component of the bycatch,
and long term, in the case of the U26 component.
• Increases to FSBio accrue
entirely from the U26 component
of bycatch and would
be cumulative over 30 years.
• There would be an immediate increase in CEY equaling 62.5% of any reduction in the trawl
PSC limit, and 75.2% of any reduction
in the hook-and-line PSC limit.
• Cumulative increases in FSBio would amount to 2.155 times the amount
of any trawl
PSC limit reduction. Although
not shown in the table,
the cumulative increase
in FSBio of U26 in the bycatch.
• Cumulative
increases in FSBio would amount to 1.208 times
the amount of any hook and-line PSC limit reduction. Although not shown in the table, the cumulative increase
in FSBio would be 4.9 times
the amount of any PSC limit reduction
relative to the current amount of U26 in the bycatch
For these reasons,
the IPHC staff supports a 15% reduction in the GOA PSC limits
for all sectors (Alternative 2, Option 2, Suboptions 1-3 (c)). We have no position on the sub-options for apportionment of the trawl PSC limit.
Juvenile halibut abundance. Recently, there
has
been
commentary
that
the
abundance
of
juvenile halibut has been increasing
and
is
currently
quite
high.
While
the
basis
for
these statements is unknown, our review and analysis of NMFS bottom
trawl survey results
does not support these
claims for the
GOA (see
Fig. 1, attached).
Results
for the Bering Sea surveys
conducted on the southeastern
flats, which encompasses Areas
4A and 4CDE, do show such an increase; however, a similar increase
has not occurred
for IPHC regulatory areas in the GOA (3B, 3A, and 2C).
Female spawning
biomass. Female
spawning
biotnass
(FSBio)
is estimated on a coastwide
basis, i.e., for the entire stock. IPHC
harvest
policy
employs
the
approach
of
avoidance
of
dropping below the minimum historic level
of
FSBio.
As
such,
the
policy
identifies
two biological reference points of FSBio at which action is taken to reduce harvest rates: a threshold reference point, and a limit reference point. The former has been established as B30, or 30% of unfished FSBio, whereas the latter is B20, or 20% of unfished FSBio.
The IPHC staff currently estimates the coastwide FSBio at B42,
or 319 Mlbs, for 2012.
Recent analyses of our assessment
have shown that FSBio was likely overestimated during 2006-2009, in part because
the threshold and limit points are dynamic, being re-estimated annually, and potentially because of a retrospective bias in the stock assessment. Thus, although we currently estimate
the stock is at
B42, future analyses
may show the FSBio is actually at a
lower point, which places increased
importance on taking a conservative position on bycatch as it affects future FSBio.
Status of the
Pacific halibut stock. The EA contains a summary of the most recent IPHC assessment and a
review of the harvest policy (EA Section
3.2.4, pages 34-42). The summary accurately discusses the decline in coastwide exploitable biomass (EBio), which has been driven by the weaker recruiting classes of 1989-1997, as well as a continuing decline in size at age. The recruiting classes since
1998
are potentially much stronger
than
1989-1997,
and higher than average (EA Fig. 3-24,
page 39), which is a positive sign. We stress
that the year class strength,
however, won't be known for certain until after those year classes
have fully recruited. However, any recovery
by
the resource is going to depend on strong incoming recruit
classes,
so
we believe that
protection of the juveniles
is necessary. The size-at-age
issue is being monitored
through our fishery
and survey sampling,
and research into our
otolith archives for similar occurrences in earlier time periods. The cause of the size-at-age decline is the subject
of much discussion, as occurred
at the April NPFMCIIPHC workshop, and
will be an area of ongoing IPHC research. However, it is unlikely that any simple management action will provided a rapid solution to this problem.
Thank
you for the opportunity to provide these
comments. Gregg Williams
and I plan to attend the Council's upcoming meeting in Kodiak and will be prepared to answer any questions
the Council
may have.
Sincerely yours,
Bruce M. Leaman
Executive Director
KYFW
All rights reserved by 
