| I wanted to share with everyone here, a proposal a group of
recreational divers and fishermen has been working on that is finally
receiving a hearing. The proposal may be viewed at the bottom of this
e-mail. I apologize for its length but the DFG asked us to provide
justifications.
To provide a quick background, we have been fighting hard at the Fish
and Game Commission level to preserve the nearshore rock and benthic
fish populations and our access to them. Many of us have been
witness to the rapid depletion of this resource. For the last year
or so we have been pushing this proposal or one like it but up until
now, our efforts were in vain. In fact, we felt like we were looked
at as being minor pests who were to be ignored. It seemed clear to
us that there was an obvious bias toward the commercial fishery in
the nearshore. In the meantime, the gear being used by the commercial
fishery expanded in its efficiency to the point where reefs were
being "saturation bombed" and depletion rates were incredibly high.
At the last meeting we went to, we were surprised when we were told
that they were willing to let our proposal receive consideration. We
need to take advantage of this opportunity but we need your help.
This proposal will be presented at the October 20th Commission
meeting. We need to let the Commission know, this isn't just some
idea a few people are supporting, but rather a growing coalition of
recreational and environmentally oriented people.
The proposal originates with United Anglers and is supported by the
following groups:
Central California Council of Dive Clubs (Cencal)
Sonoma County Abalone Network (SCAN)
Recreational Fishing Alliance (RFA)
Center for Marine Conservation (CMC)
Will you please unite with us and write to the Fish and Game
Commission in support of this proposal?
E-mail Robert Treanor, Executive Director of the Fish and Game
Commission at, rtreanor@dfg.ca.gov
John Duffy, the Assistant Director at, jduffy@dfg.ca.gov.
When you write, will you also CC the
following individuals and anyone else who you think would have any
potential impact?
Robert Hight (DFG head) RHight@dfg.ca.gov
David Bunn (Deputy Director for Legislative Affairs) dbunn@dfg.ca.gov
L.B. Boydstun (DFG intergovernmental Affairs Rep)
lbboydst@hq.dfg.ca.gov
Assemblyman Fred Keeley fred.keeley@asm.ca.gov
It's time to take the responsibility for the preservation of this
resource into our own hands. Please write now.
Thanks,
Bob Humphrey
Here it is:
October 2, 2000
Fish and Game Commission
1416-9th Street
Sacramento, CA 95814
FAX: (916) 653-5040
Attention: Mr. Robert Treanor
Subject: Proposal for Interim Measure to Manage the Commercial
Nearshore Fishery
Dear Commissioners:
This letter provides an interim measure to manage the nearshore
commercial fishery. It is the intent of this proposal that it be
considered at the Fish and Game Commission to be held on October 20,
2000 in San Diego, California.
The proposal is as follows:
Part A - Nearshore commercial fishing for nearshore fish species
(those species within 1 nautical mile of the shore as defined by the
Marine Life Management Act) shall be limited to the use of rod-and-
reel or hand lines with no more than five (5) hooks allowed per
line. All lines must be attached directly to a person or vessel and
free to drift with the vessel. A maximum of two (2) lines per person
and a combined maximum of four (4) lines per nearshore permitted
vessel are allowed. Lines must be flexible, similar to that used
with typical pole and line gear. The bottom weight or jig may be no
greater than 12-inches in length.
Part B - Midwater rockfish, including but not limited to blue, black,
olive, and squarespot, taken in the nearshore by permitted nearshore
vessels shall be limited to a daily commercial limit of no more than
20 per day in combination for each permitted nearshore vessel.
Rationale:
Part A – Due to recent declines in nearshore fish abundance,
divers and anglers have expressed alarm over the growing likelihood that
severe depletion of nearshore fish species is occurring under
existing fishery conditions. Further, Dept. of Fish and Game (DFG)
data from the early 1990's has led DFG scientists to list several
nearshore species as "species of concern" due to a scarcity
of adult fish and/or declining catch rates (Reilly, 1998). Consequently, we
believe the catch of nearshore fish must be substantially reduced to
avoid overfishing nearshore stocks. Similar to the nearshore
rockfish quota, DFG has proposed as an interim measure a quota for
nearshore non-rockfish species including cabezon, greenling, and
sheephead. However, for a quota and/or allocation system to be
effective, especially when highly efficient gear types are being
used, intensive management attention to the fishery is required
including elaborate and costly procedures to verify quota
compliance. We consider it highly unlikely that such a system will
be operational in the near future, and recent options presented to
the Commission do not appear to include either quota verification
mechanisms or the funding necessary to pay for them. Therefore as an
interim alternative, we believe that lowering the efficiency of
commercial fishing gear has the best potential to avoid resource
depletion without expensive quota monitoring measures. Additionally,
we believe the proposed gear restriction would achieve the following:
1. An immediate and significant reduction in the overall take of
nearshore fish. This would improve the prospects for both a
sustainable nearshore commercial and recreational fishery.
- This reduction would be achieved due to the mobile nature of rod-
and-reel/hand line gear when fished from a vessel. When a vessel is
drifting it becomes less able to attract those fish which tend to be
more vulnerable to anchored baits, such as cabezon and greenling.
Further, if a vessel is anchored, fishing effort is limited to the
area immediately below the vessel.
- Fishing would be limited to those time periods when fishers are
actively engaged in fishing. The ability to fish traps or set gear
overnight would be eliminated. This would have the added benefit of
reducing the potential for gear loss due to bad weather.
- The overall number of allowed hooks would reduced from the current
150 to a maximum of 20 per vessel and the use of fish traps would be
eliminated thereby reducing the overall fishing power of each vessel
2. Inability to "blanket" individual reefs with fishing gear.
Under the current system traps and "stick gear" (with a 150
hooks and 50 traps allowable maximum) are commonly deployed in a concentrated
arrangement effectively saturating individual reefs and coves with
fishing gear. As populations of slow growing, residential fish
become fished-out fishing effort moves on to other areas. Under a
general quota system this practice continues. We believe our
proposal would greatly reduce the ability to deplete areas by
lessening the geographic intensity of fishing effort. Further, the
proposed gear restriction would very likely make fishing in
marginally productive areas unfeasible setting the stage for
rebuilding of depleted stocks. An overall quota system does not take
into consideration the residential nature of nearshore fish,
consequently the prospect for ongoing and systematic geographic
depletion of residential fish continues under a quota system.
3. Creation of "de facto" refugia in kelp forest areas.
A major benefit of the proposed gear restriction would be the
difficulty of fishing with handlines or rod-and-reel gear in kelp
areas. The difficulty of fishing in kelp provided by this gear
restriction would create de facto refugia in areas of kelp forest and
rugged bottom topography.
4. Reduced Gear Conflicts.
Similarity of fishing gear between fishing sectors would likely
reduce user conflicts while providing more equitable and fair access
to the nearshore resource by various fishing sectors.
5. A simple, effective and easily enforceable regulation.
Enforcement would be greatly simplified by providing easy visual
verification of conformance to the gear restriction. We believe this
proposal could also simplify the interim process by making
allocation, quota, area closures, and seasonal closures less critical
issues in the near-term. These more complex issues are perhaps
better handled during the Nearshore Fishery Management Plan (NFMP)
process.
Part B –Regulations which reduce fish catch often displace
fishing
effort to other species.
Midwater rockfish are currently considered
fully utilized and even locally overfished. As proposed, Part B
anticipates a commercial shift from benthic species, which are the
primary target of the nearshore fishery, to nearshore midwater
rockfish. Although these fish are currently included within an
annual PFMC nearshore rockfish quota, managing by this quota suffers
from the same problems of geographic depletion discussed previously.
Rod-and-reel gear can be highly effective at catching long-lived,
residential midwater fish, which tend to form dense schools.
Consequently Part B of this proposal is intended to proactively
reduce commercial interest in shifting to midwater fish while still
provide for retention of incidental catch.
Discussion
Nearshore Fishery in Other Regions
To provide some perspective on our proposal, it is useful to consider
management approaches utilized in other West Coast regions. In
British Columbia (Straits of Georgia) the commercial live-fishery is
conducted almost exclusively with rod-and-reel gear. Further, the
number of commercial fishers has been greatly reduced by a limited
entry permit system, and fishers have strictly enforced quotas.
Quotas are verified by requiring that all catches be landed at
designated landing sites and ONLY when a fishery technician is
present to monitor and sample the catch. The commercial fishery
fully funds its management costs by an annual permit fee and hourly
landing fee. Despite the high cost of fees, inefficient gears and
tight quotas the commercial fishery remains viable and valuable.
In 1999 Washington State concluded that its nearshore groundfish
resource was fully utilized by the recreational fishery.
Consequently, Washington State banned the commercial nearshore
"live-
fishery" from Washington State waters.
Closing Remarks
We consider this proposal to be a meaningful first step. No doubt
other measures will be required as part of the NFMP to effectively
manage the nearshore fishery over the long-term. These future
measures could likely include a commercial limited entry, a
verifiable quota system and many of the other measures included in
the interim options put forward by DFG at the September Commission
meeting. However, we believe as an interim measure this proposal has
the promise of being simple, effective in the near-term (particularly
regarding ongoing geographic depletion), easily enforceable and
requiring minimal agency resources at a time when DFG efforts are
needed to complete the NFMP.
In light of the strict commercial nearshore regulations utilized in
other regions and the increasing body of evidence indicating
California's nearshore fish stocks are becoming depleted, we
believe
our proposed interim measure is balanced and fair. If enacted on an
interim basis this proposal should hopefully improve the potential
for healthy nearshore fish stocks, a reduced but sustainable
commercial fishery, and both a satisfying recreational fishery and
non-consumptive diving experience. We urge you to give this proposal
your most serious consideration.
Respectfully yours,
Mike Malone – United Anglers of Southern California Legislative
Committee
cc:
Robert Hight – Director DFG
Diana Jacobs – Special Assistant to the Director
Rob Collins – DFG Nearshore Ecosystem Coordinator
David Bunn – DFG
L.B. Boydstun - DFG
Eric Knaggs – DFG
Assemblyman Keeley
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