Tuesday, June 5, 2012

Draggers to AP: We Need to Waste Halibut

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 (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.

FSBio (lb)

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


No comments: