Valuable west coast fishery to close July 1

Poor recruitment, thought to be the result of unfavorable ocean conditions, has resulted in a perilous drop in the Pacific sardine of the Pacific sardine off the U.S. West Coast.  Just to note, contrary to recent claims and reports – the Council’s Scientific and Statistical Committee states the fishery is NOT overfished nor is it subject to overfishing.  On April 12, the Pacific Fishery Management Council faced the extremely painful decision of whether or not to allow a directed commercial fishery for sardine for the season beginning July 1, 2015.  Because of how the fishery is managed, the decision was not a difficult one.  According to the Coastal Pelagic Species fishery management plan, there is to be no directed fishery for sardine if the estimated biomass falls below 150,000 metric tons (mt).  The latest biomass estimate, as reported in the ASSESSMENT OF THE PACIFIC SARDINE RESOURCE IN 2015 FOR U.S.A. MANAGEMENT IN 2015-16, is either 132,884 mt or 96,688 mt depending on how the 2014 year class is estimated.  For terms of setting a directed fishery harvest guideline, it doesn’t matter which figure is chosen as they both fall below the 150,000 mt cutoff level – as a result there will be no directed fishery for sardine between July 1, 2015 and June 30, 2016.  At either of those two levels, incidental allowances still need to be determined and provided for.  Consistent with the conservative and precautionary approach to managing of Coastal Pelagic Species targeted off the U.S. West Coast, the Council adopted the 96,688 mt biomass for purposes of determining reference points for allowed take of sardine while the directed fishery is closed.  Allowable takes will include:

1. incidental take of sardine when prosecuting other fisheries;
2. Tribal allocations;
3. Allowances for take of sardine for live bait purposes.

Over the course of the last month, we spoke with NMFS, state representatives, bait providers, sport boat operators and commercial interests in order to ensure continued access to sardines for use as bait.  We made a conscious decision to not publicize our actions under the assumption that the focus on incidental take would overshadow live bait during discussions.  For the most part, this was true; but there was a request to limit the take of sardine for live bait purposes to 400 mt.  We had comments prepared which presented a compelling argument highlighting that the relocation of sardines, without ever removing them from the ecosystem, does not amount to a take which needed to be accounted for.  During the Council’s questioning of the requesting party, it became obvious that our comments were not going to be necessary – and in the interests of time, we opted against providing them.  A representative from SAC did provide comments which were helpful and effective.

The key reference points for the 2015 – 2016 non-directed fishery include:

Overfishing Limit (OFL) – 13,227 mt

If take reaches this level, overfishing will be occurring in the fishery.

Annual Catch Limit (ACL) – 7,000 mt

The catch level at which further management measures may be required and/or implemented.

Annual Catch Target (ACT) – 4,000 mt

This is the management target of the fishery.  For this particular management action, this applies to incidental landings of sardines in prosecuting non-treaty CPS and non-CPS fisheries.

It is presumed the Quinault Indian Nation’s request for a 1,000 mt allocation will be granted.  The Council also approved the following management measures as it relates to defining percentage limitations on the amount of sardines allowed per delivery:

• An incidental per landing allowance of 40% Pacific sardine in non-treaty CPS fisheries until a total of 1,500 mt of Pacific sardine are landed.
• When the 1,500 mt is achieved the recommended incidental per landing allowance would be reduced to 30%.
• When the ACT (4000 mt) is reached the incidental per landing allowance would be reduced to 5% for the remainder of the 2015-2016 fishing year.
• A 2 mt per landing allowance in non-CPS fisheries.
• The Council will add to its September Agenda a placeholder where these percentages can be adjusted (up or down) depending on how much sardine is taken incidentally during July and August.

Because CPS species (sardine, mackerel, anchovy and squid) tend to be taken incidentally when targeting other CPS species, it is imperative to the survival of CPS fishermen, and the markets they serve, that some incidental take of sardine be allowed when prosecuting other CPS fisheries.  A lot of discussion and debate went in to defining the above percentage limitations.  It is important to note, under current rules, the incidental per landing allowance is 45%.  The industry supported lesser incidental allowance of 40% shows the public that everyone is concerned about the current status of the sardine stock.  The incidental allowance had to be high enough so as to not promote waste and dumping of fish – if, for example, the percentage limitations were too low (say 10 – 15%) it could effectively shut down the mackerel fishery as in recent years there are times when the percentage of sardine included in mackerel catches has approached 50/50.  The lower percentage limitations will force fishermen to be more selective when targeting mackerel schools.  Market squid, during the last 4 – 5 years has been one of the two highest value fisheries for California and its fishermen (alternating with Dungeness crab for the top spot).  Traditionally, landings of market squid have lesser amounts of sardine landed incidentally and ensuring access to the squid resource resonated throughout the Council.

I cannot emphasize enough how seriously the Council, it’s advisory bodies, and the public took this.  While the decline of the population wasn’t a total surprise (it has been trending downward since the beginning of the most recent cold water event); no one wants to have to shut down such a valuable fishery to the fishermen, processors, fishing communities, markets and consumers of the U.S. West Coast; but there really was not other alternative.  For 2013, California commercial fishermen took 7,074 mt of Pacific sardine worth $1,501,919 (see here). Oregon commercial fishermen took 26,288 mt worth $6,298,778 in 2013 (see here). Washington commercial fishermen landed 29,381 mt of sardine for an unknown value (see here) – we can roughly estimate worth at or near $7,000,000 based on Oregon’s landings and ex-vessel values.

With an exception (or two) it was nice to see all stakeholders (industry, processors, sportfishing interests, eNGOs) and fishery managers working together to ensure an acceptable level of incidental take be authorized with management measures implemented that will ensure the OFL wont be met.  Later today (April 13) the Council will consider whether to schedule consideration of emergency in-season changes in the current Pacific sardine fishery.  A request was made during Open Comment for immediate Emergency Action to close the current Pacific sardine fishery (which remains open until June 30 or the remaining quota of roughly 2,900 tons is landed – whichever is earlier).  If the Council feels the request has merit, it will schedule a discussion later in the week (Wednesday or Thursday), after providing public notice giving interested parties a chance to offer public comments.  We have reviewed the request and studied the applicable law and policies (Magnuson-Stevens 305(c) and NMFS Policy Guideline for the Use of Emergency Rules) and believe the reasons provided in the request, which amount to a corrective action, do not rise to the level of an emergency as that term is contemplated in the law and rules.