Dear L. Ryan Broddrick
Director: California Department of Fish & Game
1416 Ninth Street,
Sacramento, CA 95814
(916) 653-7667
(916) 653-7387 fax
Executive Assistant:
Lisa Toof
(916) 651-9702
Steve Martarano, Supervising Information Officer
smartara@dfg.ca.gov
(916) 654-5866
Troy Swauger, Information Officer
tswauger@dfg.ca.gov
(916) 654-2096
Patrick Foy, Information Officer
pfoy@dfg.ca.gov
(916) 651-9130
Carrie Wilson, Associate Biologist, Marine Region
Communications Coordinator
cwilson@dfg.ca.gov
(831) 649-7191
First I would like to
include a special thank you for keeping our Salmon season open within the 3
mile state limit at least for the opener we can still fish. Please keep up the
good work.
This letter is in regards to the proposed Marine Reserves for the California coast. In specific, I am addressing Restricted Take and No Take Marine Protected Areas. “Restricted and No take” MPAs (hereafter referenced as nMPAs) are those from which hook and line harvest is severely restricted or not allowed. According to several environmental groups including the Pew foundation and the Packard foundation, establishment of nMPAs is supposed to have numerous beneficial purposes. However, as a tool for fisheries management, where optimal and/or maximum sustainable yield is the objective they claim is their goal, nMPAs are proven not to be as effective as the traditional management measures we already have in effect here in California, These ocean reserves are proven not to be appropriate for the vast majority of marine species, and what follows is why.
NMPAs are predicated on two
fundamental components: keeping harvesters out and keeping the species in. The
first of these is primarily an enforcement, compliance, and education issue and
not to be discussed herein. The second is wholly a scientific issue, that is,
whether the biology of the species is such that they will remain within an nMPA
for a period of their life long enough to accrue the protection desired. The
majority of fish that are in danger of being over fished or are already being
over fished are very mobile, with large territories and mass migrations.
In addition, for an nMPA to be an effective management tool, the clear implication is that management is needed. If the stocks are healthy, and projected to remain so, that is they are neither over fished nor is over fishing occurring, the need for nMPAs as a management tool is nil.
Examination of the
scores of coastal species of the US Pacific coasts reveals that very few
species are known to be both over fished and/or experiencing over fishing, and
are sedentary. Those candidates that are in both categories, and may possibly
benefit from and nMPA are found in widely differing geographic ranges, with
optimal potential nMPA sites far apart (e.g. lingcod and surf perch in the
Pacific). To establish an nMPA for the benefit of those few species would
remove harvest potential of the scores of sympatric forms, most of which are
not over fished. And while this may not reduce the overall harvest of these
species, it would definitely reduce efficiency and increase fishing effort in
other, adjacent areas.
Far better would be
to impose more traditional methods to restore the over fished stocks, as has
been done for many species here in California for the past 30+ years. This
becomes more and more successful as we adopt more precautionary harvest levels;
improve our methods of stock assessment, stock/recruit relationships, and life
history information.
Current plans or
suggestions regarding closure of large areas of the California continental
shelf to hook and line harvest are simply not scientifically supportable from a
fishery management perspective. The suggestion, for example, that as much as 40
% of the California shelf should be designated an nMPA is totally without merit
from a fishery management perspective. The closure of such areas will have a
substantial negative economic impact on more than just the commercial fishing,
recreational fishing and tourist industries. California is the 6th
largest economy in the world. The negative economical impact caused by the
closing of these areas especially to privately owned boaters will cause huge
losses for boat manufactures, tackle manufactures, fuel stations, motels, toll
bridges, boat registrations, sales tax and thousands of small business’s across
the united states. This will result in the loss of millions of dollars in tax
revenue, thousands of jobs lost and many US owned companies going bankrupt.
Below the actual pacific species that are
supposed to be protected by the nMPAs are listed as facts as reported by Robert
L. Shipp, PhD. Robert is chair of the Department of Marine Sciences,
University of South Alabama and Director of the Alabama Center for Estuarine
Studies. He administers more than $2,000,000 annually of marine and estuarine
research funds. He served nine years on the Gulf of Mexico Fishery Management
Council, twice as chair, and was chairman of the Council’s Essential Fish
Habitat Committee. He edited Systematic Zoology for 4 years, and was a governor
of the American Society of Ichthyologists and Herpetologists for five years. He
has published some 40-refereed papers and one book on marine fishes, and has
been asked to testify before Senate and National Research Council Committees on
fisheries and fishery management.
Pacific Coast fisheries (excluding Alaska)
Pacific Coast Pelagic Species.
There are five species included within the Pacific pelagic group (northern
anchovy, Pacific sardine, jack mackerel, chub mackerel, and Pacific herring,
NOAA, 1999). All are listed as under or fully utilized, none over fished. Therefore,
because of their healthy stock conditions and pelagic life history, they would
receive no benefits from creation of nMPAs.
Pacific Coast Ground fish Fisheries.
The Pacific ground fish assemblage is a diverse group of species, principally
flatfishes and rockfishes. These are mainly long-lived, slow growing species,
subject to harvest by both commercial and recreational fishers. Included are
about 60 species of rockfishes, principally Sebastes and several species
of thornyheads (Genus Sebastolobus), several cods, the sablefish (Anolopoma
fimbria) and the lingcod (Ophiodon elongatus). Recently, life
history data were provided to the Pacific States Marine Fisheries Commission of
the near shore fishes of California (Cailliet, 2000). This, along with several
supplementary references, and combined with the NOAA document (1999) and the
Report to Congress NMFS 2001) provide the background for determination of the
possible impacts of nMPAs on these species.
The Pacific whiting (=Pacific hake, Merluccius productus), is a mid to moderate depth species, with relatively extensive movement patterns. It is considered fully but not over exploited, and with extremely variable year class strengths. Because of these factors the species is not likely to benefit from establishment of an nMPA.
The sablefish (Anaplopoma fimbria) is an important commercial species, ranging from Japan and the Bering Sea to Baja. The stock status is considered fully exploited, and stock levels are below optimum. However, it is a deep water, often-migratory species, thus not likely to benefit from an nMPA.
The lingcod (Ophiodon elongatus) is a large member of the greenling family, ranging from Kodiak Island to southern California, but is most abundant in the northern part of its range. It is an extremely important recreational and commercial species, with a high food value, although representing only about 2 % of the Pacific Coast ground fish catch. This species is considered to be over exploited, with stock levels well below that necessary to maintain the long-term projected yield. The species is relatively sedentary, usually in rocky reefs at depths of 10 to 100 m. It is a nest building species, and the males become extremely aggressive during this time, particularly vulnerable to attack by marine mammals. The species is also cannibalistic. The life history and stock condition indicate that this species could benefit by an nMPA in the more northern part of its range. However, other management measures have been put in place, including protection of spawning and nesting sites during spawning season, minimum size requirements to ensure at least one spawn before subject to harvest, and restricted catch limits through recreational bag limits and commercial quotas. Though recovery is likely to be slow because this is a long-lived species (up to 25 years), these measures are thought to be sufficient to effect recovery (Alaska Dept. of Fish and Game, 1994).
Pacific cod (Gadus macrocephalus) is a wide ranging, highly migratory species of commercial importance in the North Pacific. It is considered underutilized, although stock status and long term potential yield are unknown. Therefore, the species would not benefit from establishment of an nMPA.
Pacific Flatfishes.
Pacific halibut (Hippoglossus stenolepis) is a carefully managed
species, with its center of abundance in the Gulf of Alaska. Landings from the
US Pacific Coast (excluding Alaska) average about 570 metric tons, representing
a little more than 1% of the total harvest (NOAA, 1999). The species is well
managed throughout its range by traditional methods, and recent harvest has
been near record. Thus the species would not likely benefit from establishment
of an nMPA.
The status of four other US Pacific Coast flatfish species (arrowtooth flounder [Atheresthes stomias], Dover sole [Microstomas pacificus], English sole [Pleuronectes vetulus], and petrale sole [Eopsetta jordani]) are considered individually while the many additional flatfishes are grouped together (NOAA, 1999). Of these four, none is listed as over fished, and all are wide ranging with extensive offshore movement patterns. For this reason, none would benefit from nMPAs. For the many remaining flatfish species, their stock status is unknown.
Rockfishes.
There are about 65 species of rockfishes endemic to the US Pacific coast, most
in the genus Sebastes. They live in a diversity of habitats, from clean bays,
to depths greater than 400 M. They are long-lived species, with some living well
over 50 years. Thus, annual exploitation to attain the management goals of
35-40% spawning biomass per recruit is often as low as about 5- 10%. In recent
years, the surplus present in most of these stocks has been fished down,
resulting in reductions in recommended annual harvest (NOAA, 1999).
In its report to Congress, NMFS (2001) lists 52 species of rockfish. For four
species (Pacific ocean perch [Sebastes altos], bocaccio [S.
paucispinus], canary rockfish [S. pinniger], and cowcod [S. levis],
all but the latter are major stocks) the stocks are over fished but over
fishing is not presently occurring and rebuilding programs are in place or
under development. These species are all wide ranging forms with extensive
portions of their populations in very deep water. Thus for fishery management
purposes, nMPAs are likely not needed Only nMPAs of impractical extent both
longitudinally and bathymetrically would have any impact on the stocks as a
whole.
For three species (darkblotched rockfish [Sebastes crameri], silvergrey rockfish [S. brevispinis], and yelloweye rockfish [S. ruberrimus], all major stocks) over fishing is occurring, but for the former species the stocks are not currently over fished, and for the latter two stock conditions are unknown. Reduced mortality will be required, but currently, rebuilding plans are not yet in place. These three are also very wide ranging, from the Bering Sea to southern California, and out to depths of well more than 500 M, thus nMPAs would be impractical as a management tool. And in fact, due to the bathymetry of the eastern North Pacific coast, many of the areas inhabited by rockfishes are such as to prevent extensive fishing effort, or create a “natural refuge” (see Yolklavich et al. below).
For eight species (seven of which are major stocks) for which assessments
exist the stocks are not overfished, nor is overfishing occurring. For the
remaining species, most of which are minor stocks, their status and rate of
fishing mortality is unknown. Therefore, particular management measures are
premature.
The Pacific Fishery Management Council has implemented limits for individual
vessels, as well as other measures in an attempt to maintain a year round
harvest for most rockfish species. Life history data and stock assessments for
most species are not yet determined. Cailliat (2000) lists data on about 30
species, and about half are known to be resident species. Of the overfished or
species experiencing overfishing, movement data are available only for the
canary rockfish which is considered transient/resident, with tagged movements
of over 259 km documented, and the yelloweye, which is considered a resident
species.
General Life History Comments Regarding Rockfish.
In their study of the Soquel Submarine Canyon, off Monterey California,
(Yoklavich et al., 2000) suggested that “rock outcrops of high relief
interspersed with mud in deep water of narrow submarine canyons are less
accessible to fishing activities and thereby can provide natural refuge for
economically important fishes.” Their study was represented by 52 fish species,
of which rockfishes were represented by a minimum of 24 species. In addition,
they concluded that “There was remarkable concordance between some of the
guilds identified in Soquel Canyon and the results of other habitat-specific
assessments of fishes along the west coast of the United States from central
California to Alaska.” Certainly this suggests that there is an inherent
control of fishing effort in these habitats and consideration of more extensive
areas designated as nMPAs is pre-mature and likely unnecessary.
Soh et al. (2001) studied the role of marine reserves on Alaskan rockfishes.
Although Alaska is beyond the scope of this report, the findings are likely
applicable. While predicting that harvest refugia (=MPA) can be used to greatly
reduce discards and serial overfishing, they state that the effectiveness of
marine refugia “in fisheries management is poorly understood and concepts
regarding their use are largely untested.”
End Robert L. Shipp, PhD
Thank you for taking the time to support this highly important cause.
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