Follow up to last letter. Text of UASC proposal


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Posted by Bob Humphrey on October 19, 2000 at 23:23:54:

Sorry to flood this BB with so much text but it is really an important issue, I'm sure to many of you, as it is to me. Here is the text of the United Anglers proposal. If you aren't able to make the meeting, please write in support.

If you would be interested in being added to a list of recreational divers and fishermen who are dedicated to being involved in future fisheries management decisions, drop me a line and I'll add you to the list. It is strictly recreational, so I would need a short bio along with your e-mail address.

Thanks for your support!

Bob Humphrey
CENCAL Marine Resources Director

Here's the text:

Here is the text of our proposal. Please read it and show your support. For
those in the San Diego area, we need you to go to the meeting, sign a
speaker card, and speak out against the DFG proposals and in favor of the UA
COMPROMISE.

For those who live up north, letters to the Commission are better than
nothing. Here's the address with proposal following:

Bob Humphrey

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 meeting to be held October
20, 2000 in San Diego, California.

Proposal
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





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