The Union and Fishing Vessel Owners thank the NPFMC for incremental progress made on Bycatch reduction

Progress is being made with the Council as they are now looking at pelagic and non-pelagic trawl separately - but corrective action regarding the tendering observer exemption and the expansion and refinement of a robust observer program for the partial coverage fleets is essential to the sustainability of the fishery...

Please see the copy below of a recent letter to Council calling for action!

June 20, 2018

Mr. Dan Hull, Chairman
North Pacific Fishery Management Council
605 W. 4th Ave., Ste 306
Anchorage, AK 99501-2252

RE: Future Partial Observer Coverage Changes

Dear Chairman Hull:

    We want to thank the Council for the opportunity provided Fishing Vessel Owner’s Association to comment in Kodiak on the partial- coverage observer program under Agenda Item C-1. The Council action to “include an evaluation of observer effects at finer resolution than gear-level strata, so that observer effects in pelagic and non-pelagic trawl can be investigated,” is an appreciated step forward. This resolution should help focus future observer coverage and a better use of limited funds. However, we want to express our disappointment with the Council not following through with the proposed Council correction to the “tendering exemption” and not asking the staff to look at cost associated with getting coverage levels increased to the 30% for the partial- coverage fleets.     

The abuse of the tendering observer exemption, as described on page 105 of the May 2017 Annual Observer Report, describes the outright subversion of the observer program by certain shore-based entities in their efforts to avoid the needed counting of salmon bycatch. We believe vessel operation incentives to avoid coverage are still present for vessels tendering Pacific cod.  We would also inform the Council that the fact the shore-based processors only receive a warning for their manipulation of bycatch accounting has not gone unnoticed by the harvesters.     

The Council’s failure to look seriously at longer-term solutions for increasing observer coverage was disappointing. We believe the following action would provide beneficial information to the Council relative to costs in expanding coverage to partial-coverage vessels. We continue to support a Council discussion paper that would examine a separate program with a “pay as you go” system for pelagic and non-pelagic trawlers while keeping fixed gear operations within the current ADP observer program. We believe random selection can be a design of both formats. One form of the analysis would be the fee necessary to get fixed gear up to 30% of catch or trips and the cost of the trawl fleet to obtain similar coverage of their tows and/or catch.     

In summary, we want to thank the Council for taking a positive step in looking at pelagic and non-pelagic trawl separately. We request that the Council complete its own proposed correction action to the tendering observer exemption, which, as yet, has not been tasked to staff for completion. Lastly, we request the Council examine our request for expanding and developing a more robust observer program for the partial coverage fleets.

Sincerely,

         Robert D. Alverson                                                      James Johnson         Manager                                                                       Executive Director         Fishing Vessel Owners' Association                          Deep Sea Fishermen's Union

        Robert D. Alverson                                                      James Johnson
        Manager                                                                       Executive Director
        Fishing Vessel Owners' Association                          Deep Sea Fishermen's Union