So that fishermen and others, policy makers and interested citizens, may have the opportunity to review and reflect upon these important matters, here is the sign-on letter that will shortly begin circulating throughout Alaska and the Pacific Northwest. Composed by a coalition of concerned fishermen, it seeks to expose and redress failures in the 'Restructured Observer System." Please take the time to read and add your name and voice to the sign-on letter when it comes around. Changes to the way the Gulf of Alaska is managed must occur before its productivity and sustainability are forever damaged/destroyed. The current system is badly broken. NMFS continues to be derelict in its duty to protect our resources.
Feel free to print this letter and add a place for signatures and send it off to your representatives or the ones listed on the letterhead. W.
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November 12, 2012
To: Governor
Sean Parnell
Senator Lisa Murkowski
Senator Mark Begich
Congressman Don Young
Subject: Restructured North Pacific Observer
Program and 2013 Deployment Plan
Dear Alaska Leaders,
In 2010 the North
Pacific Fishery Management Council (Council) approved restructuring the North
Pacific Observer Program. A final rule
to implement the program is scheduled for early December publication. The undersigned members of the fishing
industry cannot support this program that doubles costs, reduces
coverage in high volume fisheries with substantial Chinook and halibut bycatch, and fails to provide a workable
monitoring system for small vessels.
We are willing to
pay our fair share of observer coverage costs and recognize that at-sea data is
needed for conservation and management of the resource. We are concerned about salmon and halibut
bycatch and believe fisheries with high bycatch must be the priority for
observer coverage. We believe at-sea
data can be collected from Alaska’s previously unobserved, community based
vessels without causing fleet consolidation, job loss, or disruption of
business operations. We have identified
electronic monitoring as the tool that works for the small, fixed gear boats.
The National
Marine Fisheries Service (NMFS) has consistently ignored the concerns of
fishermen most affected by the program.
NMFS is ready to implement a plan that reduces coverage in high volume
fisheries with substantial Chinook and halibut bycatch, doubles the cost of an
observer day relative to current levels, assigns over half the observed trips
to vessels that account for less than 12% of the catch, and places the largest
economic burden on the 1,300 small boats that operate out of Alaska’s coastal
communities.
NMFS has provided
insufficient opportunity for public comment on the 2013 observer deployment
plan, no specificity and therefore no opportunity for comment on deployment
logistics for small boats, and little to no analysis of logistical costs
imposed on individual fishing businesses.
The undersigned individuals
cannot support full implementation of the restructured observer program as
proposed for 2013. We request your assistance in holding NMFS
accountable for addressing stakeholder concerns prior to implementation of the
restructured program or, at minimum,
prior to deployment of observers on the small fixed gear vessels assigned to
the “vessel selected pool.” Our
concerns are detailed in the attached document.
Thank you for
your support of Alaska’s coastal fishermen.
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(Sign up section deleted...)
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Concerns with the
Restructured Observer Program and 2013 Deployment Plan
A final rule to restructure
the North Pacific Observer Program is scheduled for early December publication
with implementation in January 2013. The
2013 Observer Deployment Plan was revealed in October 2012 after observer
contracts had been signed, allowing only minimal opportunity for public comment
and only minor revisions. Deployment
details for small vessels still have not been revealed, effectively preempting
public comment. Despite active and
informed participation by Alaska’s coastal fishermen, the restructured program in
general and the 2013 Deployment Plan in particular fail to meet resource
objectives, control costs, or minimize impacts to Alaska’s small fishing
businesses.
Throughout the two-year
process to restructure the North Pacific Observer Program, fishermen have
consistently advocated for:
·
Establishing
observer coverage levels on a fishery specific basis with emphasis on high
impact bycatch fisheries;
·
Incorporating
deployment strategies that maximize cost effectiveness;
·
Providing
small vessels with electronic monitoring as an alternative to human observers concurrent
with program implementation.
The Council has
heard these concerns and often endorsed them. In October 2012 the Council recommended the
National Marine Fisheries Service (NMFS) amend the 2013 Deployment Plan to
prioritize coverage in bycatch limited fisheries and to do so by reducing
observer assignments in the “vessel selected pool.” The Council also requested NMFS provide a
cost accounting report and a strategic plan for implementing electronic
monitoring, but did not tie these requests to the 2013 Deployment Plan. Throughout the restructuring process, the
Council has deferred to NMFS to address concerns raised by stakeholders instead
of engaging in the normal process of identifying alternatives and incorporating
stakeholder input to develop workable solutions. The result of this unusual process is that
NMFS has not been held accountable for addressing concerns prior to implementation.
While we support the Council’s October 2012
recommendations, we need assurance that observer coverage will be
re-prioritized to high bycatch fisheries, that program costs will be
controlled, and that observers will not
be deployed on small vessels until deployment details are revealed, analyzed
and resolved, and electronic monitoring is available as an alternative to human
observers.
More
specifically, our concerns with the 2013 deployment plan are the following:
1. Equal
probability of deployment—the
deployment plan assigns all fishing trips with an equal probability of observer
coverage—whether the trip is taken by an 80 foot vessel that harvests hundreds
of thousands of pounds or a 42 foot boat harvesting 500 pounds. As a result, over 50% of the observed trips will
be assigned to small fixed gear vessels that account for less than 12% of the
groundfish and halibut harvested off Alaska.
Shifting deployment to small fixed gear boats reduces coverage on high
volume and high bycatch fisheries—most notably Gulf pollock fisheries that
account for Chinook bycatch. The
Council’s recommendation to “prioritize” coverage of PSC limited fisheries
restates objectives NMFS has ignored to date. While we support the Council’s recommendation,
NMFS’ response to the recommendation remains unknown—yet NMFS intends to
implement the program in two months.
2. Failure
to contain costs— In
October 2012 fishermen learned that the deployment plan increases the cost of
an observer day from the current $467 to approximately $1,000. The deployment plan emphasizes a random
deployment approach to obtain unbiased data and does not sufficiently consider
alternative stratified sampling approaches that could provide unbiased data in a
more cost effective manner. Doubling the costs halves the number of observer
days and undermines bycatch management objectives that are vitally important to
Alaska’s fisheries. The Council has
requested a detailed cost accounting but has taken no action to control
observer coverage costs in 2013.
3. No alternative to human observers for the small boat fleet—Stakeholder
testimony and Council motions for the past two years, including the Council’s May
2011 comment on the proposed rule, requested an alternative to human
observers for the small boat fleet. Electronic Monitoring (EM) was
identified in EA/RIR as the alternative that minimizes impacts to the small
boat fleet. In Alaska, EM project
collaborators specifically designed a pilot program in partnership with NMFS to
evaluate EM in the halibut and sablefish fisheries to ensure EM would be operational
in 2013. Yet the restructured observer
program fails to provide this alternative and makes no commitment to ever providing an alternative to human
observers. NMFS has not devoted the necessary resources to provide a
viable alternative to human observers despite three years of notice and good
faith industry cooperation.
4. Definition
of a fishing “trip”--The
definition of a fishing trip still allows “gaming” of the system. Cod vessels that deliver to tenders will be
able to complete an entire season before ending a “trip,” since trip is defined
as a shore-side delivery. As a result,
vessels not selected for observer coverage on their first trip can deliver
off-shore to tenders until the season ends and thereby avoid coverage for the
entire season. The definition also still
lacks quantity of gear set or fish harvested, which allows a vessel to fish for one day in a non-productive area,
satisfy the observer “trip” requirement, drop off the observer and then join
the rest of the fleet to fish in areas with higher catch and, of more concern,
bycatch.
5. “Vessel selected” boats have 100% coverage for two or three
months-- Stakeholders
have repeatedly commented that the proposed requirement for boats
in the “vessel selected” pool to carry observers for all trips during a three
months period is overly burdensome and inequitable, particularly when compared
to "trip selected" vessels that have a 13% probability of being
selected one trip at a time. The Council’s recommendation to reduce the
requirement to two months still assigns the most burdensome observer
requirements to the smallest fixed gear boats.
Until electronic monitoring is
available as an alternative to human observers, observers should be assigned to small boats on a trip by trip basis.
6. No
Logistical details for the “vessel selected” pool---Logistical deployment details for the
“vessel selected” pool still have not been revealed, hence the industry has not
been able to evaluate or comment on these critical and potentially costly provisions. Potential costs include room and board for an
observer between trips and insurance to protect against liability. These costs have never been analyzed. While logistical details are specified for
vessels in the “trip selected pool” (over 57.5 feet), the deployment plan
directs fishermen in the “vessel selected pool” to work with the observer
contractor to resolve logistics. The
selected observer contractor is based on the East Coast and has no prior
experience in Alaska.
Again, we cannot support deployment of observers in the vessel
selected pool until these concerns have been addressed by NMFS. We are willing to pay the observer fee in
2013 and we are willing to work with the agency to resolve the concerns
identified above.
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Keep yer head down and yer flippers wet.
