Calculating discards, an essential component in the fishery management system, has evolved into a knot of absurdities which helps explain the poor quality of NOAA fisheries science, says David Goethel, a commercial fisherman and member of the New England Fishery Management Council.
Because only a fraction of the fishing trips are monitored for NOAA by private contractors, whose employees keep records of the number and weight of the fish discarded, their calculations are then extrapolated and applied universally no matter what fish are targeted and what fish are discarded.
Worse still, Goethel has written in a letter to top officials of the agency, it is a practical impossibility for these monitors to get true weights while a boat is rolling and pitching on the high seas. Yet, those projected weights work their way into the stock assessment system and bias the conclusions, distorting the findings about the profile of stocks and even their overall vitality, Goethel says.
In a technical letter to William Karp, director of the NOAA Science Center at Woods Hole, John Bullard, NOAA’s Northeast regional administrator, and Rip Cunningham, chairman of the New England Fishery Management Council, Goethel analyzes the flaws in the incumbent system of attempting to determine discards which is anchored to the system of at sea monitors on a fraction of the commercial trips.
He proposes abandoning at-sea monitors completely and instead suggests requiring all fish brought on board to be landed at the dock where monitors would weigh the “discards” and the fishermen would be paid for the fish that would become the possession of the monitoring companies, but no longer would be charged against the allocation of the fisherman.
“If you want compliance,” wrote Goethel, “ you have to have rules that benefit fishermen. Paying fishermen without removing the fish from the annual catch limit, will turn a loss into a reward. Maybe then we can get accurate information on catch which will benefit the entire process with minimal cost.”
His letter cites the costly fallacies of the current system of assigning at-sea monitors to a fraction of the trips and having them weigh and count the discards and compare them to the weight of landings.
Goethel said this approach is absurd since it applies across all species targeted and all species discarded even though what is targeted and discarded self evidently effects the actual kept/discard ratio.
That’s more than an academic issue to fishermen. Goethel said he is typical of commercial fishermen who must acquire quota to cover the assumed discards that spew from the kept/discard ratio.
“Buying yellowtail to cover discards that never existed in the first place” is a very frustrating exercise, costly and wasteful too, he added.
Goethel provided a case study from his recent experience.
“I have landed 10,141 pounds of yellowtail flounder with assumed discard rate of 3,669 pounds,” he said. “Since I was gifted half of those yellowtail in my allocation this year, I have had to purchase the balance at a cost of 50-60 cents a pound. I quit fishing for yellowtails in October when my manager told me that my assumed discard rate combined with my landings was near the total of my allocated fish.”
Goethel said he changed gears to minimize yellowtail retention, but due to the universality of the kept/discard ratio, the volume of dogfish he caught determined the assumed volume of yellowtail discarded even though “one has nothing to do with the other.”
“During this time,” he said, he has landed cod and dogfish without landing catching any yellowtail.
“I have to buy yellowtail allocation to cover discards that never existed and were never killed,” he said. “You can imagine how phantom fish can bias a stock assessment. The root of the problem is that fishermen process their catches differently depending on whether or not monitors are on board, and in part this is true because the assumed discard rate is so important and based on the records made by the monitors, so they are incented to bias their monitored trips in ways that will benefit themselves and other fishermen made subject to the assumed discard rate.
Goethel said there are ways to create a more accurate and honest system.
First, he proposed moving discarded fish from (annual catch limits) to scientific uncertainty which already account for about one-third of the annual catch limits.
“Stop penalizing people for discards,” he said,, “and maybe they will tell you what they catch,” he said.
Second, Goethel suggested ending at-sea monitoring and having the monitors weigh and measure all fish brought on board, and third paying fishermen for their landings that cannot be sold in the normal course of events.
“Paying fishermen, without removing the fish from the annual catch limit, will turn a loss into a reward,” he wrote. “Maybe then, we can get accurate information on catch which will benefit the entire process with minimal cost.”
Richard Gaines can be reached at 978-283-7000, x3464, or at firstname.lastname@example.org.