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Old 08-27-2019, 05:11 PM   #1
Joe Evens
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Default Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

I had hope that members of Ifish with political skill, connections and will would take this notice and read deep enough to understand the implications of the impact this legislation will have on our community when it becomes law.

This is a huge notice of proposed rule making to absorb when the effort is made to read and understand the seemingly endless path and process that leads to the current and evolved version of even one tiny segment. I just finished another ten hour session and have just scratched the surface.

The deeper I go, the worse it looks. I have reduced my ignorance about A 28 somewhat and urge others to do the same. I will c&p the diatribe I posted to another thread recently to this dedicated thread. Perhaps it may gain traction while there is still time, perhaps not.

As a commercial fisherman, I have much to gain when this becomes law. As a sport fisherman, there is no upside, only loss, so I break even on the ten year plan. More money and on the short term, more fish, five years on?, not looking good. Less fish. In ten years I'll be 77 and probably slowing down anyway.

The vast majority of this big, extended family on Ifish are Sport fishermen and really should try to understand the implications. It's worth an hour of reading the first page or three of the links below. Or not.

Bottom contact trawling was stopped in the RCA when created in 2002, protecting the entire coasts of Oregon and Washington, and California, from the 30 fathom line to the about the 100 fathom line, essentially the whole continental shelf, from the imminent disaster that we were facing. Our coastal fisheries were saved and are still recovering.

This act also helped protect the area inside the 30 f line from destruction by making it only marginally profitable for trawl fishing this narrow sliver of coastline.

Without this quick and decisive action to stop the pillage of this treasure, OUR national resource, wholly in the interest of enriching the few, there would be no recovery, only continued collapse until unrecoverable, certainly within our lifetime.

In the 17 year interim, the big seafood corporations have been continually lobbying, gaining allies, now apparently including our governing agencies, CDFW, and ODFW and are now on the cusp of getting most it back.....on the pretext that trading the much larger and less profitable areas far outside The Shelf for the gold mine, the Continental Shelf itself, will somehow be beneficial for our coastal fisheries.

It seems that WDFW has at least partially opted out of this nonsense. The Wa RCA will remain closed to bottom trawling for all the right reasons. I believe this is a recent decision. Perhaps this can be a model for Oregon.

Without a miracle this is already a done deal. This thing has so much momentum that it is a virtual certainty. The only glimmer of hope visible is that the public comment period has been extended a month. It was until August 15, and has been bumped to September 15.

21 days is not much time to stop this greed driven insanity. Your personal comment will help, but the real chance now is to reach and convince the very few who can possibly help, our Senators and Congress.

As a commercial fisherman, parts of this legislation would be beneficial to me personally, quite beneficial. As a hook and line fisherman, I am restricted to inside the 30 fathom line. That restriction will be dropped. Those schools of midwater rockfish that you sport fishermen enjoy will be ours, and will be exploited. Deep water rockfish and lingcod will be exploited.

When trawled to the point of collapse in the future, I'm happy to know that a decent amount of critical habitat is to be set aside, so whole species will eventually recover, depending, of course, on the extent of habitat destruction from grid trawling habitat.

I just can't convince myself that a few years of personal profit should traded for the destruction of the resource that really belongs to our kids and theirs'.

Here is some light reading, but I doubt it will help you sleep.

Pay close attention to the allocations for each fish species for the new trawl fleet in the final pdf. Mostly between 90 and 99%for the trawl fleet. They did give the Sport Fishermen a big break on Starry Flounder though, Sporty's get 50% of the Starry flounder.

Understand and KNOW that although halibut are a prohibited species for the new and large trawl fishery expected, that many are caught as bycatch. With the very optimistic expected mortality rate of 15%, the initial allocation of halibut to the new trawl fleet for mortality is set at 130,000 lb. It could increase or decrease, but don't expect the latter. This comes out of the area 2A allotment.

Verify my numbers, they are to be found in the two documents below. I'm pushing twenty hours straight on this subject and my math is getting a bit fuzzy.

This thing can sink or swim from here. I'm done with it. If it passes, fine. My commercial fishing opportunities increase. If, by some miracle, it goes down in flames? Fine again. My future Sport fishing opportunities may even improve. Your ball.
JE.

https://www.federalregister.gov/docu...t-states-pacif

https://www.pcouncil.org/wp-content/...2010_Final.pdf

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Old 08-27-2019, 07:04 PM   #2
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Thanks for taking the time and effort to ferret this out. I'll be contacting my rep and senators and urging them to block this from happening.
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Old 08-27-2019, 07:51 PM   #3
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Contact DeFazio as well. The guy is a fighter for a good cause, and has serious clout.
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Old 08-27-2019, 08:04 PM   #4
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

WOW. Heavy stuff. Too bad it has to come down to this from the lack of good practices over the years.
I too will be attempting to contact our reps.
Once I was a commercial fisherman, but have been strictly sport for MANY years.
So can kind of understand your side of the story.
And thanks very much for posting this. Hopefully it will open many more eye's and some good action will result.
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Old 08-27-2019, 10:18 PM   #5
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Thanks for the info!
I haven’t seen a CCA call to action for this.
It makes it nice and easier to contact the right “leaders”
And increases the number of responses.
Hopefully it’s in the works?
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Old 08-28-2019, 04:15 AM   #6
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Thanks Joe for the fair warning. I'm planning to dig into the details later today. I'm very curious to here if there are any groups/lobbying organizations opposing this? On the cover it seems like the potential negative impact for recreational fisherman, as well as the ecology of the ocean, is larger than any of the other issues out there.
Thanks again!
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Old 08-28-2019, 08:47 AM   #7
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Washington is the Key. How, when, and why does Washington State keep their RCA protection and we lose it.

Surely someone here knows someone at WDFW and can help get that information. In fact, Any major politician of Wa should know this critical info.

I have to suspect that at some point, Washington State became fully aware and just said NO!!!

The only reason or excuse I have found in print is that YE are more important as a fishery in Wa.

Can anyone reach Governer Insely? He has the answers and his recent national exposure clearly shows that he cares deeply about the natural world and the people.
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Old 08-28-2019, 10:15 AM   #8
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Thanks again for posting this originally and keeping on it. I can't believe that we're not hearing more outcry about this.

I'm working now to craft a good comment.

Just reading more, it is scary to see how misleading and underhanded this amendment is.

Here is how it starts out in the abstract:

"The proposed action would establish new and revised areas closed to bottom trawling to conserve and protect Pacific coast groundfish essential fish habitat, and re-open areas that were closed to bottom trawling to rebuild previously-overfished groundfish stocks. Combined, these two changes are anticipated to increase protections for groundfish essential fish habitat and provide additional flexibility to participants fishing with bottom trawl gear in the groundfish trawl rationalization program."

Sounds great. Protect essential fish habitat. That's good. But, read below on the extra "protection" provided by this amendment.

"The proposed rule would close over 123,000 square miles (318,569 square km) seaward of approximately 1,900 fathoms (3,500 m) to fishing with bottom contact gears. Currently, there is no known bottom contact fishing activities occurring there, and there would be no adverse economic impact on any small business."
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Old 08-28-2019, 11:52 AM   #9
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Quote:
Originally Posted by fishrepellor View Post
Thanks for the info!
I haven’t seen a CCA call to action for this.
It makes it nice and easier to contact the right “leaders”
And increases the number of responses.
Hopefully it’s in the works?
CCA was made aware soon after I raised the first alarm a couple months ago.

Not a word.
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Old 08-28-2019, 12:27 PM   #10
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Quote:
Originally Posted by Joe Evens View Post
CCA was made aware soon after I raised the first alarm a couple months ago.

Not a word.
That's odd. I wonder why?

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Old 08-28-2019, 01:12 PM   #11
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

This has so clearly been done behind closed doors and without representation from the Sport sector that I suspect that a lawsuit could be effective in at least delaying implementation and even if it failed, could very well get us a few rule changes that would let us survive as a group and part of the local economy.

At this point they could still throw us a bone, such as,.."Zero trawl fishing inside the 50 fathom line. This would at least leave the coastal ecosystems intact". These ecosystems are so intertwined that damage to one directly impacts the others. Everyone sees the rocks, reefs, kelp and intertidal areas and can understand their place in the puzzle, but very few know or care that the sand flats are a huge and easily damaged ecosystem and are likely the glue that holds it all together, the true base of the food chain.

Now that it has finally recovered after 40+ years of slow rebuilding, the sand flats, mostly inside the 40, are a vital ecosystem, the top several feet is full of life of many types, including some likely unknown to science.

Feasting on all that life are flatfish in the millions and billions. Sand dabs, petrale and halibut eating them.

The seafood corporations want this bounty and will drag the sand to get them. This destroys the sand ecosystem, the base of it all...

As it stands, bottom trawling is planned all the way to the surf line, eliminating my favorite fish and fishery almost overnight. Petrale move from the coast to off the Shelf in winter. They can only come back to the coast if there is something to eat. Drag the sand, kill the base, nothing for the sand dabs, petrale, and their predators to return to. Just sand.

To date, the only concession I see that has been granted the Sport Fishing and subsistence sector,"us", it that generous concession of 50% of the Starry Flounder fishery. When one reads the rationale behind that decision, it is starkly clear that we were not represented or even considered as a share holder. The Starry Flounder is presented as an important sport and food fish, making it clear that they have no concept of who and what we are. This was pulled from 70 year old texts and ruling.

Anyone who has not been enjoying the petrale fish and fishery should do it. It took forty years to recover and will again.
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Old 08-28-2019, 01:25 PM   #12
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Thanks for bringing this to my attention Joe.

Joe
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Old 08-28-2019, 03:03 PM   #13
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

The only starry flounder I've caught in the last 10 years was because it crawled into one of my crab pots and couldn't get out.
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Old 08-28-2019, 03:54 PM   #14
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Thanks Joe, I was not aware of Amendment 28 until I read your post, been sending emails all afternoon, hope it helps.
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Old 08-28-2019, 05:10 PM   #15
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Quote:
Originally Posted by edsr View Post
Thanks Joe, I was not aware of Amendment 28 until I read your post, been sending emails all afternoon, hope it helps.
Will greed never stop?
Thank you Ed, I sure hope something changes the trajectory of this bomb. I typically support ODFW and would think of them as a potential ally, but purely commercial interests seem to be their agenda on this, to the point of actually hiding this and excluding the Sport and subsistence fishermen from the process.

They do have a link to the legislation on their website, but it is pretty well hidden. Not in a place where we would be likely to stumble across it. This should have been front page news long ago and allowed debate by all users, not accidentally found by me while researching something else.

I am not even remotely the person to organize opposition, even if it is possible at this late date. Several of those who typically lead our IFISH political concerns and battles were made aware of this well over a month ago when I first brought it up, and are conspicuous in their absence from this conversation.
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Old 08-28-2019, 06:41 PM   #16
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Quote:
Originally Posted by DoryDrifter View Post
Thanks Joe for the fair warning. I'm planning to dig into the details later today. I'm very curious to here if there are any groups/lobbying organizations opposing this? On the cover it seems like the potential negative impact for recreational fisherman, as well as the ecology of the ocean, is larger than any of the other issues out there.
Thanks again!
Thank you Greg. You are right in saying this issue is larger than any of the others. This one is potentially life changing, and is imminent. Indeed, it is upon us.
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Old 08-28-2019, 10:48 PM   #17
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

FYI, I've not tried this on my laptop as I live on my android, but you may gain some facts by looking at the website. Phones will not work.

From NOAA:
We have an*online mapping tool for this action*that can show you existing closed areas and how they are proposed to modified or added to. It wasn't designed to use on a smartphone, so computer would be best.*

http://www.soundgis.com/efh/efh2018eis-metrics/

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Old 08-29-2019, 07:31 AM   #18
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

So ODFW has a voting representative on the PFMC where Amendment 28 apparently was developed, and I think it would be interesting to ask them why this is happening. After all, any economic harm from the current closures happened years ago, and presumably all those harmed got on with their lives and found other opportunities. So why does the department feel the need to support renewing potentially damaging fisheries which currently don't exist. I'm not aware that it's the Oregon Department of Fisheries and Wildlife. There does seem to be a strong bias towards commercial fisheries in the department, despite the fact that sportsmen's dollars pay the majority of their salaries. I suspect that in part that bias comes from the marine sector of the department's participation in PFMC as well as their management of commercial fisheries within the state. You start to think a lot like the people you associate with the most. Maybe they need a reminder about who's paying their salaries.

From PFMC council membership roster:

OREGON DEPARTMENT OF FISH AND WILDLIFE (voting)
MELCHER, MR. CURT State of Oregon Principal Official Director, Oregon Dept. of Fish and Wildlife 4034 Fairview Industrial Drive SE Salem, OR 97302 Telephone: 503-947-6000 Email: [email protected]
1st Designee: Mr. Chris Kern [email protected]
2nd Designee: Dr. Caren Braby [email protected]
3rd Designee: Ms. Maggie Sommer [email protected]
4th Designee: Mr. Troy Buell [email protected]
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Old 08-29-2019, 09:12 AM   #19
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Quote:
Originally Posted by Joe Evens View Post

Now that it has finally recovered after 40+ years of slow rebuilding, the sand flats, mostly inside the 40, are a vital ecosystem, the top several feet is full of life of many types, including some likely unknown to science.

Feasting on all that life are flatfish in the millions and billions. Sand dabs, petrale and halibut eating them.

The seafood corporations want this bounty and will drag the sand to get them. This destroys the sand ecosystem, the base of it all...

As it stands, bottom trawling is planned all the way to the surf line, eliminating my favorite fish and fishery almost overnight. Petrale move from the coast to off the Shelf in winter. They can only come back to the coast if there is something to eat. Drag the sand, kill the base, nothing for the sand dabs, petrale, and their predators to return to. Just sand.

To date, the only concession I see that has been granted the Sport Fishing and subsistence sector,"us", it that generous concession of 50% of the Starry Flounder fishery. When one reads the rationale behind that decision, it is starkly clear that we were not represented or even considered as a share holder. The Starry Flounder is presented as an important sport and food fish, making it clear that they have no concept of who and what we are. This was pulled from 70 year old texts and ruling.

Anyone who has not been enjoying the petrale fish and fishery should do it. It took forty years to recover and will again.



Joe I appreciate your passion about this subject. However, I get the sense that additional due diligence is necessary in order to understand the proposals.


I put one statement of yours in big red letters, because....I don't think this is technically true. Other than opening up small areas of soft bottom, the inside-100 fathom trawl fishery is not going to change much at all (it is already allowed, but not utilized a whole lot). Now, I am still trying to learns the key facts about this amendment as it pertains to Oregon. So I could still be wrong. But I don't think this is going to cause unrestricted trawling inside 100 fathoms. My current understanding (which may change by the hour) is:


  1. The zone of 100 - 150 fathoms will be opened up to trawling.
  2. Certain new areas of "essential fish habitat" will be designated outside of 100 fathoms; and everything outside of 3500 meters will be closed to bottom-contact gear.
  3. Existing areas of EFH inside of 100 fathoms will be expanded (including Stonewall Bank, Daisy Bank, Heceta Bank)
  4. Some new areas of SOFT BOTTOM ONLY inside of 100 fathoms will be opened for trawling; but those are very few and small areas. Otherwise, the trawl rules (inside 100 f) remain the same.
Therefore, the rockfish of (sport) concern....yelloweye, yellowtail, widow, canary, etc. will not be impacted because no new prime habitat for those fish (i.e. hard bottom inside 100 fathoms) will be opened for trawl; rather..the EFH / restricted area will actually INCREASE.


Again, I am still trying to get the facts. But in my view the way it has been presented here is not entirely accurate.


Also, to one thing you said:



Quote:
Originally Posted by Joe Evens View Post
As a commercial fisherman, parts of this legislation would be beneficial to me personally, quite beneficial. As a hook and line fisherman, I am restricted to inside the 30 fathom line. That restriction will be dropped. Those schools of midwater rockfish that you sport fishermen enjoy will be ours, and will be exploited. Deep water rockfish and lingcod will be exploited.



I'm not sure that (part in red) is correct. If you would Joe, please cite one reference to support this.


Thanks, Mark
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Old 08-29-2019, 09:18 AM   #20
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Default No so bad

I have to retract my statements. In fact I deleted them because it would have been to hard to correct them.

Yesterday I heard back from someone at ODFW who gave me a good explanation of why Amendment 28 isn't actually bad. I don't feel at liberty to cut and paste it here but I'll go over some of the finer points.

I'll start by saying that I largely dislike bottom trawling because it simply damages the bottom. However, the way this is organized, there are really no high relief areas allowed to be fished. Draggers don't want to fish those areas anyway because it damages their nets. Plus, this amendment reduces the size of the rollers to 8" on the leading edge of the net inside 100 fathoms (don't remember what they are called) on the bottom of the nets for large areas which also means they have to be very careful where they fish so that they don't damage their nets. This also reduces the damage done by those nets in general.

Most of what they are opening up is between 100 and 150 fathoms, far deeper than us sporties fish and there aren't as many yellow eye. Which brings me to my next point. Commercials are VERY careful about yellow eye. In fact they catch a very very little YE. Last year they caught a combined .1 metric tons. Sport boats catch between 7 and 9 metric tons. This should stand out to you. Commercials have such a small YE allowance that they know exactly where to fish to avoid them.

You should also read up on IQF. Individual Fishing Quotas. This is the reason they are able to open up some of these areas that have been closed for the last 17 years. The IQF system has proven MUCH more effective in reducing bycatch of species like YE. See here:
https://www.govinfo.gov/content/pkg/...2019-16493.pdf

Under the IQF system, each fishing boat has 100% paid observers/electronic monitoring. No exceptions. That means they aren't cheating. This has helped enormously with data and this amendment is based on much that data.

Some good short videos but this one sums it up.

- Oregon State University/Foulweather Trawl on bycatch excluders in trawl nets
https://youtu.be/UCSRCIFOzMo - Environmental Defense Fund on trawl net modifications to reduce bycatch

https://www.psmfc.org/bycatch/videos.html - showing underwater clips of excluder research that the Pacific States Marine Fisheries Commission is conducting


This is the most intensively monitored fishery on the West coast. These decisions are not being made lightly.

I retract my opposition to this amendment. Joe, I will send you something via PM to help you understand why I have changed my mind.

Chass
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Old 08-29-2019, 01:15 PM   #21
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Maggie said I could share her response so here it is:

**************************
Hi Chass,

Thanks for your email and good questions. ODFW supports the proposed changes under Amendment 28, and we are confident that it will not result in a large increase in yelloweye rockfish bycatch in the trawl fishery. Seeing the yelloweye rockfish stock continue to rebuild is a priority for ODFW, and we would not support any management action that we thought would jeopardize that.

The changes under Amendment 28 include reopening the area between 100-150 fathoms off Oregon and California that has been closed to bottom trawling for groundfish since 2002 in order to support the rebuilding of rockfish stocks that were overfished at that time. The primary reason for this reopening is that since the groundfish trawl fishery moved from trip limit management to individual fishing quotas (IFQ) in 2011, the IFQ system has proven to be vastly more effective at reducing bycatch of species such as yelloweye rockfish than the trawl RCA closure ever was. There is a description of this in the proposed rule text (https://www.govinfo.gov/content/pkg/...2019-16493.pdf), on the third page (page 41820) under “Changes to Fishery Management Measures”. Sorry for not just pasting in the relevant text here so it’s easier to find – the formatting was not cooperating when I tried.

Here are a few numbers to illustrate the relative amount of yelloweye bycatch in the trawl fishery: the trawl sector’s mortality of yelloweye rockfish on the entire west coast (OR, CA, WA) was 0.1 metric tons last year (2018). For comparison, yelloweye rockfish mortality in the recreational fisheries has been between 7-9 metric tons per year in recent years (i.e., the sport fisheries take 70 times the amount of yelloweye rockfish that the trawl fishery does). Oregon’s recreational fishery alone is projected to result in ~4.5 metric tons of yelloweye rockfish mortality in 2019. The IFQ system, not the trawl rockfish conservation area (RCA) closure, is responsible for this level of yelloweye rockfish mortality in the trawl fishery.

Under the IFQ system, each groundfish trawl vessel has a limited amount of quota for each species they catch, including bycatch species. Many boats have a very small amount—less than ten pounds—of yelloweye rockfish quota. If a trawl vessel catches more than it has quota for, it must find some tradeable quota to buy from another vessel to cover its catch, and must stop fishing until it does. There is a limit on how much it can buy each year, so it won’t be able to cover a large catch even if it could find quota to buy (and it can be difficult to find quota—many vessel owners want to hold onto their quota throughout the year in case they need it themselves). If a vessel can’t find quota to buy, or needs more than the annual limit, then it has to stop fishing for the remainder of the year. The risk of having to forego potential harvest of a lot of target species, potentially for a long time, is a significant economic incentive for trawlers to avoid yelloweye rockfish.

Trawlers are required to have 100% observer coverage at their own expense (observers cost $500 or more per day) – there is always a human observer or an electronic monitoring system onboard watching all fishing activity at sea, and a human catch monitor onshore at the fish processors watching each trawl landing as it is offloaded, sorted by species, weighted, and documented. All catch of target and bycatch species is fully accounted for, and there’s no potential for hiding it. This was an important part of the IFQ system design, and one reason for its effectiveness at reducing bycatch.

In addition, since yelloweye rockfish generally live in pretty high-relief rocks, trawlers avoid those areas so they don’t damage their nets. Inshore of 100 fathoms, trawlers have to use “8-inch footrope” nets…nothing on the leading bottom edge of the net can be larger than 8” in diameter, effectively meaning the net won’t run over rocks of any significant height. The potential net repair bill (new nets cost many thousands of dollars; repair cost would depend on extent of damage), plus the loss of fishing time during repair, is another incentive for trawlers to avoid yelloweye habitat.

I have personally spoken with a number of trawlers this summer about their plans to fish in the RCA once it’s reopened next year, and each one said they’ll be very cautious about it specifically because of the risk of catching yelloweye rockfish. Some of those who have been trawling a long time pointed out areas they just aren’t going to go (and/or are going to tell the newer captains to avoid) because they recall catching yelloweye there before the RCA took effect 17 years ago. There are some areas of soft bottom and low relief that they are interested in getting access to, for example for flatfish such as petrale or English sole.

Trawling is currently allowed shoreward of 100 fathoms in Oregon (with exceptions such as Essential Fish Habitat Conservation Area closures and Oregon’s Marine Protected Areas), and the Amendment 28 proposed rule will not change that. There has been some bottom trawling in this depth zone, although not a lot in recent years. There’s no reason the Amendment 28 changes would likely alter the recent pattern – it’s driven by market demand for the inshore flatfish species, vessel size and target strategy, etc.

Finally, I’d like to offer my perspective on selectivity in the trawl fishery, which differs from your statement that “bottom trawling is completely and totally indiscriminate”. While trawling is certainly less selective than some other fishing methods/gears, I have seen through fishery data and the results of various research projects and industry efforts that there are ways to avoid or reduce bycatch of non-target species. These are being used today, and more are in the works. The catch numbers I gave above demonstrate the ability of trawlers to avoid yelloweye rockfish by choosing where they fish carefully, even in areas that are fully open by regulation. Many trawlers are working with net makers and researchers to design and use excluders to keep certain species out of their catch.

These videos are well worth checking out when you have time:
- Oregon State University/Foulweather Trawl on bycatch excluders in trawl nets
https://youtu.be/UCSRCIFOzMo - Environmental Defense Fund on trawl net modifications to reduce bycatch
– Oregon Public Broadcasting on groundfish recovery
and several on this page: https://www.psmfc.org/bycatch/videos.html - showing underwater clips of excluder research that the Pacific States Marine Fisheries Commission is conducting

The groundfish trawl fishery is the most intensively managed and monitored fishery on the west coast. It has evolved from an overcapitalized fleet that was overfishing some stocks decades ago, through an economic disaster in the early 2000’s that led to a big reduction in the number of trawlers, to a much more sustainable and progressive fishery today. Together with the sacrifices made in the recreational fisheries and other commercial sectors to reduce bycatch of yelloweye and other rockfish stocks that were overfished, this has contributed to the success story described in the OPB video. Coastal communities in Oregon benefit from viable commercial fisheries including trawling, and consumers benefit from the availability of local trawl-caught seafood harvested in fisheries subject to stringent U.S. regulations. ODFW supports a mix of recreational and commercial fisheries that meet conservation goals first, and provide for the use and enjoyment of fishery resources by current and future generations.

I hope this helps answer your questions. If you have more, you are welcome to give me a call or email.

Maggie

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Old 08-29-2019, 03:36 PM   #22
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Thank you Chass. I will begin by multi quoting the most obviously(to me at least) deceptive parts of the document sent you by ODFW. This will take a while, so try to keep an open mind until you read my thoughts about the document that has swayed your opinion.

I freely admit that my information is based on a fraction of this omnibus proposal. No one person could possibly absorb the entire thing. Every path leads to several more. I believe however that I have read thru the parts that concern us. Very certainly there are gaps in my knowledge and may have some other details wrong. Spend an hour or two reading the section on revisions. you will see that hundreds of parts have been revised, tweaked eliminated, added and inserted. This continues on a daily basis.

Some of this might help clear up questions Mark Mc has brought up about certain of my statements, or may not. If I am guilty of overstating some of my concerns or have been mistaken on a detail, then I'm guilty, and if I read something wrong or got it mixed with another, then I'm mistaken. This is not an apology, just a statement. I was born without the perfection gene.

This thing has been on my table for two months, I've read countless pages, some of which may well have been revised. This is not something I want to do, but someone had to try to unravel the scope and intent, and raise some awareness.

I've done my best, and as of now, my opinion is unchanged.

Now I must take another hour or three of MY time to poke holes in the document that ODFW is sending to inquiring Sport Fishermen.

I see it as misinformation. Masterfully done, a work of wordsmith art. It isn't easy to use facts and true statements to obscure and slip by more important facts and details, but it is a profession these days. Whoever wrote this is way out of my class, but I think I can shed some light on what I'm saying.

I should have something by tomorrow. Right now I have to put the rest of this day into my boat. Priorities.
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Old 08-29-2019, 05:46 PM   #23
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Quote:
Originally Posted by Mark Mc View Post
Joe I appreciate your passion about this subject. However, I get the sense that additional due diligence is necessary in order to understand the proposals.


I put one statement of yours in big red letters, because....I don't think this is technically true. Other than opening up small areas of soft bottom, the inside-100 fathom trawl fishery is not going to change much at all (it is already allowed, but not utilized a whole lot). Now, I am still trying to learns the key facts about this amendment as it pertains to Oregon. So I could still be wrong. But I don't think this is going to cause unrestricted trawling inside 100 fathoms. My current understanding (which may change by the hour) is:


  1. The zone of 100 - 150 fathoms will be opened up to trawling.
  2. Certain new areas of "essential fish habitat" will be designated outside of 100 fathoms; and everything outside of 3500 meters will be closed to bottom-contact gear.
  3. Existing areas of EFH inside of 100 fathoms will be expanded (including Stonewall Bank, Daisy Bank, Heceta Bank)
  4. Some new areas of SOFT BOTTOM ONLY inside of 100 fathoms will be opened for trawling; but those are very few and small areas. Otherwise, the trawl rules (inside 100 f) remain the same.
Therefore, the rockfish of (sport) concern....yelloweye, yellowtail, widow, canary, etc. will not be impacted because no new prime habitat for those fish (i.e. hard bottom inside 100 fathoms) will be opened for trawl; rather..the EFH / restricted area will actually INCREASE.


Again, I am still trying to get the facts. But in my view the way it has been presented here is not entirely accurate.


Also, to one thing you said:








I'm not sure that (part in red) is correct. If you would Joe, please cite one reference to support this.


Thanks, Mark
To the best of my knowledge, this is the case.

Mark, As it it stands and has since 2003, the area between the 30 f line and the 100 is open to trawling(with local closures and exceptions) but NO BOTTOM CONTACT TRAWLING.

The area inside the 30 IS and has been open to bottom contact trawling(local closures and exceptions, plus bottom gear restrictions that can't just steamroll over rock and reef.

Amendment 28 opens the area inside the 100 f to BOTTOM CONTACT trawl, including areas already open.(inside the 30)

To date, the sliver of bottom between the 30 and the main reefs and surf line on sandy shore line has been open, but is only marginally profitable to exploit by the older, smaller 90s type trawlers and non profitable for the huge trawlers of today. Yes, the small boats work some areas, but spotty and occasional, and very occasionally one of the trawl ships will show up and make a pass with gear down, then leave.

This has, in my area and certainly others, allowed recovery to continue to a large extent. We have had a trawl presence off and on, but only one or two and gone, nothing industrial.

That very irregular sliver of sand, when it opens from the 100 f to the 30, becomes not a sliver, but the inside edge of the new outside boundary, big difference. Essentially, the whole shelf opens.

I've approached those giant trawlers, a dozen men scattered across the very wide stern. Very impressive. with gear down, they are MOVING The gear is wide. I'm guessing that they are covering at least 10 times the acreage per hour. They can gps grid cover vast areas quickly and completely.

In 1968, I watched four small trawlers for two weeks as they appeared, trawled the sand flats between Cascade Head and Cape Lookout in industrial fashion, and disappeared. It was thirty years before I saw another Petrale or dab and another 5 to 10 years before major recovery. Now the sand flats are loaded with life. Vibrating with life.

From 160 ft to the mud line, about 240 ft, the sand ecosystem is feeding an amazing density of fish. Dabs by the million. square miles if flatfish so thick that a sabiki will ladder up within 20-30 seconds to maybe a minute and seldom ten seconds from hitting bottom before a bite. I've been picking up 25 to 50 petrale on rod and reel when I concentrate and work at it. On at least half of the days I drift thru huge schools of juvenile canary that load my gear and cost me up to an hour by the time I descend the damn things and relocate. I've caught three halibut on my 3" grubs and most days have halibut grabbing dabs off my lines at some point. These halibut from inside the 30.

So yes, I'm defensive of and for the sand ecosystem. The sand flats are thought of as a desert. Few even consider that the life filling the top several feet of sand can feed that density of fish and that it is fragile. Until I have reason to believe differently, I can only believe that the sand dwelling life is the base of this important ecosystem and fishery.

Regarding my statement that we would be no longer restricted to inside the 30, it is an assumption, possibly a presumption, based on the only reason I was given when asking the question WHY. I was told that as bottom contact commercial, we were restricted along with the bottom contact trawlers. This answer was not from ODFW, where I got no answer, but from a long time commercial fisherman who should know. It may be presumptive to assume that the hook and line, open access guys would be allowed back outside the 30, but seems reasonable to me.
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Old 08-29-2019, 06:17 PM   #24
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Quote:
Originally Posted by Mark Mc View Post
Joe I appreciate your passion about this subject. However, I get the sense that additional due diligence is necessary in order to understand the proposals.


I put one statement of yours in big red letters, because....I don't think this is technically true. Other than opening up small areas of soft bottom, the inside-100 fathom trawl fishery is not going to change much at all (it is already allowed, but not utilized a whole lot). Now, I am still trying to learns the key facts about this amendment as it pertains to Oregon. So I could still be wrong. But I don't think this is going to cause unrestricted trawling inside 100 fathoms. My current understanding (which may change by the hour) is:


  1. The zone of 100 - 150 fathoms will be opened up to trawling.
  2. Certain new areas of "essential fish habitat" will be designated outside of 100 fathoms; and everything outside of 3500 meters will be closed to bottom-contact gear.
  3. Existing areas of EFH inside of 100 fathoms will be expanded (including Stonewall Bank, Daisy Bank, Heceta Bank)
  4. Some new areas of SOFT BOTTOM ONLY inside of 100 fathoms will be opened for trawling; but those are very few and small areas. Otherwise, the trawl rules (inside 100 f) remain the same.
Therefore, the rockfish of (sport) concern....yelloweye, yellowtail, widow, canary, etc. will not be impacted because no new prime habitat for those fish (i.e. hard bottom inside 100 fathoms) will be opened for trawl; rather..the EFH / restricted area will actually INCREASE.


Pretty sure you are drinking too much of their cool-aid on much of the above.
There are some new closed areas. Some very good reefs, they are mapped and listed in the second? link of the two, that I recently posted.

The way I read it, most of it will be open, including apparently, because it is not included, major gravel banks like our traditional PC halibut bed, where I have been catching canary for market weekly, Inevitably, as I drift the North part, working canary schools with two rods with 6-8 jigs each, for 20 to 50 fish in an afternoon, I also catch and descend two to four nice YE and several juvenile fish. On sonar, their is no relief.



Again, I am still trying to get the facts. But in my view the way it has been presented here is not entirely accurate.


Also, to one thing you said:








I'm not sure that (part in red) is correct. If you would Joe, please cite one reference to support this.


Thanks, Mark
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Old 08-29-2019, 07:58 PM   #25
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

[quote=Chass;16100457]Maggie said I could share her response so here it is:

**************************
Hi Chass,

Thanks for your email and good questions. ODFW supports the proposed changes under Amendment 28, and we are confident that it will not result in a large increase in yelloweye rockfish bycatch in the trawl fishery. Seeing the yelloweye rockfish stock continue to rebuild is a priority for ODFW, and we would not support any management action that we thought would jeopardize that.

The changes under Amendment 28 include reopening the area between 100-150 fathoms off Oregon and California that has been closed to bottom trawling for groundfish since 2002 in order to support the rebuilding of rockfish stocks that were overfished at that time.

A 28 also opens the area from the 100 f, in to the 30 f, making it one with the already open area from the 30 to the reefs and to the surf line on sandy shores. A very convenient omission.



The primary reason for this reopening is that since the groundfish trawl fishery moved from trip limit management to individual fishing quotas (IFQ) in 2011, the IFQ system has proven to be vastly more effective at reducing bycatch of species such as yelloweye rockfish than the trawl RCA closure ever was.

The new and existing reef closures ensure that YE will survive and thrive in the closures. As some know YE habitat is much more than the major reefs. they are many, many uncharted YE habitats. Many are not even found with sonar. I find them on hard bottom flats and gravel often. I hope the IFQ system works. From a selfish viewpoint, YE are a secondary concern.



There is a description of this in the proposed rule text (https://www.govinfo.gov/content/pkg/...2019-16493.pdf), on the third page (page 41820) under “Changes to Fishery Management Measures”. Sorry for not just pasting in the relevant text here so it’s easier to find – the formatting was not cooperating when I tried.

Here are a few numbers to illustrate the relative amount of yelloweye bycatch in the trawl fishery: the trawl sector’s mortality of yelloweye rockfish on the entire west coast (OR, CA, WA) was 0.1 metric tons last year (2018). For comparison, yelloweye rockfish mortality in the recreational fisheries has been between 7-9 metric tons per year in recent years (i.e., the sport fisheries take 70 times the amount of yelloweye rockfish that the trawl fishery does). Oregon’s recreational fishery alone is projected to result in ~4.5 metric tons of yelloweye rockfish mortality in 2019. The IFQ system, not the trawl rockfish conservation area (RCA) closure, is responsible for this level of yelloweye rockfish mortality in the trawl fishery.

Gotta love this one: yelloweye bycatch in the trawl fishery: the trawl sector’s mortality of yelloweye rockfish on the entire west coast (OR, CA, WA) was 0.1 metric tons last year (2018)

Forgot to mention that bottom contact trawling is and was prohibited on the entire coast of OR, CA, WA...Could that explain the low number of YE caught by the MIDWATER trawl fleet? WA will continue the prohibition.



Under the IFQ system, each groundfish trawl vessel has a limited amount of quota for each species they catch, including bycatch species. Many boats have a very small amount—less than ten pounds—of yelloweye rockfish quota. If a trawl vessel catches more than it has quota for, it must find some tradeable quota to buy from another vessel to cover its catch, and must stop fishing until it does. There is a limit on how much it can buy each year, so it won’t be able to cover a large catch even if it could find quota to buy (and it can be difficult to find quota—many vessel owners want to hold onto their quota throughout the year in case they need it themselves). If a vessel can’t find quota to buy, or needs more than the annual limit, then it has to stop fishing for the remainder of the year. The risk of having to forego potential harvest of a lot of target species, potentially for a long time, is a significant economic incentive for trawlers to avoid yelloweye rockfish.

Trawlers are required to have 100% observer coverage at their own expense (observers cost $500 or more per day) – there is always a human observer or an electronic monitoring system onboard watching all fishing activity at sea, and a human catch monitor onshore at the fish processors watching each trawl landing as it is offloaded, sorted by species, weighted, and documented. All catch of target and bycatch species is fully accounted for, and there’s no potential for hiding it. This was an important part of the IFQ system design, and one reason for its effectiveness at reducing bycatch.

In addition, since yelloweye rockfish generally live in pretty high-relief rocks, trawlers avoid those areas so they don’t damage their nets. Inshore of 100 fathoms, trawlers have to use “8-inch footrope” nets…nothing on the leading bottom edge of the net can be larger than 8” in diameter, effectively meaning the net won’t run over rocks of any significant height. The potential net repair bill (new nets cost many thousands of dollars; repair cost would depend on extent of damage), plus the loss of fishing time during repair, is another incentive for trawlers to avoid yelloweye habitat.

I have personally spoken with a number of trawlers this summer about their plans to fish in the RCA once it’s reopened next year, and each one said they’ll be very cautious about it specifically because of the risk of catching yelloweye rockfish. Some of those who have been trawling a long time pointed out areas they just aren’t going to go (and/or are going to tell the newer captains to avoid) because they recall catching yelloweye there before the RCA took effect 17 years ago. There are some areas of soft bottom and low relief that they are interested in getting access to, for example for flatfish such as petrale or English sole.

SOME areas? The vast majority of The Shelf fall under soft bottom and low relief. The sablefish/blackcod fishery is to be massive.

Trawling is currently allowed shoreward of 100 fathoms in Oregon (with exceptions such as Essential Fish Habitat Conservation Area closures and Oregon’s Marine Protected Areas), and the Amendment 28 proposed rule will not change that. There has been some bottom trawling in this depth zone, although not a lot in recent years. There’s no reason the Amendment 28 changes would likely alter the recent pattern – it’s driven by market demand for the inshore flatfish species, vessel size and target strategy, etc.

HUH?The whole Continental Shelf Is inside the 100, and 90+% opens to bottom contact trawl. This the primary area of interest. The blackcod, The petrale and minor flatfish are a, if not THE prime fishery, and, IF you read, the trawl fleet is poised and eager to exploit it. The Shelf is the Gravy.

And yes, there has been some bottom trawling in this zone, shoreward of 100 fathoms, primarily inside the 30, where it was and is legal.


Finally, I’d like to offer my perspective on selectivity in the trawl fishery, which differs from your statement that “bottom trawling is completely and totally indiscriminate”. While trawling is certainly less selective than some other fishing methods/gears, I have seen through fishery data and the results of various research projects and industry efforts that there are ways to avoid or reduce bycatch of non-target species. These are being used today, and more are in the works. The catch numbers I gave above demonstrate the ability of trawlers to avoid yelloweye rockfish by choosing where they fish carefully.

Many trawlers are working with net makers and researchers to design and use excluders to keep certain species out of their catch.

[No doubt that a few are working on this, voluntarily, looking forward to the day when certain fish stock collapse, and THEN when required, they will be used.

All this about YE and not a peep about the big Shelf edge rockfish, like Rough Eye and a half dozen more, that were fished to full collapse and have barely began the long path to recovery. These fish are incredible. Big enough to eat big YE. Some live over 200 years. Truly amazing.....History buffs?

What was happening 200 years ago? That was long before the CIVIL WAR. This is a very very tough neighborhood. Any fish that is tough enough to live there, eat or be eaten, making a daily living since the War of 1812, deserves more than to be scraped off The Wall by a machine.

Seriously, the document sent out to us by ODFW is fraught with misinformation. No need to lie to misinform. A professional wordsmith can craft documents to lull us into complacency, light the fire of passion, sow distrust, and fan the flame of rage, all using the same words. I find it insulting that they consider us to be so easily swayed. ..Move along now, nothing to see here.
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Old 08-30-2019, 06:12 AM   #26
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

ODFW got a lot of questions over the last couple days so they put this together.
I haven't even read it yet. I'm just relaying the information.

***********************
Background:
NOAA Fisheries has issued a proposed rule for Pacific Coast Groundfish Fishery Management Plan (FMP) Amendment 28 that would change bottom trawl fishing closures in federal waters off the west coast, re-open historically important fishing grounds, and close deep waters off California to protect deep-sea corals from bottom-contacting gears. The proposed rule is open for public comment through 09/16/2019.

Under the Magnuson-Stevens Fishery Conservation and Management Act, regional Fishery Management Councils must identify and describe Essential Fish Habitat (EFH) for each life stage of each managed species, and minimize to the extent practicable adverse effects of fishing on EFH. Councils must periodically review and update their EFH provisions.

The Pacific Fishery Management Council (Council) conducted a public review of groundfish EFH from 2010-2014 and concluded that changes were warranted based on new scientific information. From 2014-2018 the Council, in cooperation with NOAA Fisheries, state and tribal co-managers including ODFW, industry, NGOs, and the public, developed changes to EFH provisions and fishery management measures collectively described in Amendment 28. Concluding an extensive process, the Council adopted the final suite of changes in 2018, and NOAA Fisheries is now proposing to implement them in federal rule.

What the NOAA Fisheries Proposed Rule Does:
Amendment 28 would add or modify EFH Conservation Areas (EFHCAs) which are closed to bottom trawling (and in some cases, other bottom contact gears) to protect habitat, and reopen the depth-based trawl Rockfish Conservation Area (RCA) that was established in 2002 to support rebuilding of overfished rockfish.

Revisions to EFHCAs would expand existing and add new closures to protect important habitat features, including submarine canyons, seamounts, methane seeps, and stationary sponges and corals. It would reopen some portions of EFHCAs in habitats with lower sensitivity and faster recovery to disturbance. In federal waters off Oregon, Amendment 28 would close an additional 340 square miles to bottom trawling, and reopen 30 square miles of existing EFHCAs. See the attachment for an illustration of proposed changes off Oregon.

Amendment 28 also proposes reopening the trawl RCA, because of the success of the trawl rationalization program, established in 2011. This program significantly increased trawlers’ accountability through individual fishing quotas (IFQ) and improved monitoring, and has successfully reduced bycatch of overfished and protected species. Since 2011, five of the seven overfished groundfish stocks are now rebuilt, and one more (cowcod) is expected soon based on the positive results of a 2019 stock assessment. Yelloweye rockfish remain in rebuilding status; however, there is a low risk to this stock from the proposed RCA reopening because they are not found in large numbers in that depth.

The areas proposed to reopen were historically important fishing grounds, and it is anticipated that trawlers will have more flexibility and opportunities to improve the efficiency of their operations, which will benefit coastal communities.

Amendment 28 also closes waters deeper than 3500 meters off California to all bottom contact gear. This depth zone off Oregon and Washington has been closed since 2006. Deep-sea habitats are sensitive to disturbance and slow to recover. The Council values the role of deep-sea habitats in trapping greenhouse gases, slowing the rate of climate change, and providing nutrients (through upwelling) that fuel fisheries. The proposed rule would prevent prospective fishing activities that could damage deep-sea ocean floor and sensitive deep-sea coral habitats.


Here is a link to the public online EFH mapping tool that allows users to see and get statistics about the variety of alternatives that were considered in Amendment 28, as well as the Council’s preferred alternative which is embodied in the proposed federal rule: http://www.soundgis.com/efh/efh2018eis-metrics/.
When you open the mapping tool link, here are a few steps that I find a good way to get started:
1. On the right, uncheck all the boxes. These include alternatives considered but not adopted by the Council (the Council’s final preferred alternative merged many parts of the other proposals). It is confusing to look at the map with all of them turned on.
2. To see existing area closures for the trawl fishery:
a. Hover over the small square white box that says reference layers in the top right of the map, and check “EFH Conservation Areas”. This will show the existing EFHCAs that are closed to bottom trawling to protect essential habitat for groundfish.
b. In the reference layers, if you check the box called “Trawl RCA, 2015”, it will show the Trawl Rockfish Conservation Area that is closed to groundfish trawling to reduce bycatch of certain rockfish species. (It’s the same today as in 2015, so disregard that year in the label)
3. To see the changes proposed under Amendment 28 to the groundfish fishery management plan, leave the above in place, and also:
a. On the right under Trawl RCA Alternatives (it looks shaded out but you should be able to check boxes), check the box called 2d. Preferred – Remove Trawl RCA. This won’t look very different on the map—it just highlights the trawl RCA in a different color now, indicating that it is proposed for removal.
b. Under EFHCA Alternatives, check 1h. Preferred. This shows the changed proposed to the Essential Fish Habitat Conservation Areas – some are adjustments to existing EFHCA boundaries, and some are entirely new. If you hover over each colored area, on the right side at the bottom of the screen you will see stats on that area.
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Old 08-30-2019, 08:06 AM   #27
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Once again, is it the Oregon Department of Fish and Wildlife or the Oregon Department of Fisheries and Wildlife. ODFW is run in a reactive manner, not proactively. They allow things to happen, then take a step back and react to negative impacts...sometimes very slowly. PFMC...that's a FISHERIES management council, created to save fisheries from themselves. The restrictions currently in place have apparently been very successful in rebuilding stocks, and we have what...17 years of the results of them in place. Coastal communities and commercials are not currently dependent on the changes proposed under Amendment 28. But they will be, and if things don't turn out as rosy as Maggie predicts, there will be a lot of outcry and political wrangling trying to maintain the new status quo. I particularly thought it was a bit disingenuous that she paraphrased the ODFW mission statement, somehow implying that a harvest method not currently in place would " provide for the use and enjoyment of fishery resources by current and future generations. " (The actual mission statement doesn't mention fishery resources, it is : Our mission is to protect and enhance Oregon's fish and wildlife and their habitats for use and enjoyment by present and future generations.) ODFW has a long history of allowing things to happen, then reacting slowly. There were literally no limits on harvest of groundfish in the 50's when I was a kid. Now we have the current restrictions on both sport and commercial harvest. The amendment will theoretically roll back a portion of commercial fisheries to some of the "good old days" but with protections in place that assure past abuses don't occur. I don't trust that ODFW has the inclination or authority to do that if things don't proceed as rosily as they predict. If this amendment is not allowed to proceed, we don't need to find that out.
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Old 08-30-2019, 08:36 AM   #28
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Quote:
Originally Posted by Joe Evens View Post
CCA was made aware soon after I raised the first alarm a couple months ago.

Not a word.
Thanks for calling out CCA old friend.

If you had ever been involved with CCA you might understand that we dont discuss a lot of strategy on internet forums. Or with non members.

But feel free to go ahead and criticize what you dont know.
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Old 08-30-2019, 08:52 AM   #29
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Joe, once again you are a prophet among us. You alone have raised the alarm, and pointed out that we are caught with our pants completely down on this. You have shown that we (and certainly me), have neglected the federal side of fisheries management. It is a glaring hole in our awareness and strategy.

The role of a prophet is to point out inconvenient truths, to awaken a group to their blindness, and to call them to action. Historically, people resist the prophet's message, preferring to look the other way, make excuses, or just plain avoid the hard work of change. I for one am guilty on all counts on this issue.

You brought this to me months ago, and I sidelined it (looked the other way). I said it was probably too late to have any impact (made excuses). I said I would look into it but didn't (avoided the hard work of change). But I recognize and honor your prophetic role. Let this be a wakeup call for all to engage in federal fisheries issues, not just state and regional issues.

Thank you for your diligence and for raising the flag on this. I can't begin to unpack this issue and arrive at any sort of conclusion. I can offer no valid opinion on the matter. Your lasting influence, for me anyway, will be much greater awareness of federal fisheries issues.
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Old 08-30-2019, 10:17 AM   #30
Joe Evens
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Quote:
Originally Posted by Gun Rod Bow View Post
Thanks for calling out CCA old friend.

If you had ever been involved with CCA you might understand that we dont discuss a lot of strategy on internet forums. Or with non members.

But feel free to go ahead and criticize what you dont know.
Bruce, this was just a simple and direct answer to a simple, direct question. Criticism not intended.

I've said from the beginning that I'm the wrong person for this task, that I don't wish to do it, and asked for someone qualified to carry this instead. Even a hint of organized support would help lift the load, which frankly is crushing.
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Old 08-30-2019, 11:07 AM   #31
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Thanks again JE. It has certainly been a wake up call for me. If I'm going to care deeply about these things, I'd better get active and make the effort to stay informed.

After digesting much more information on the amendment, I am still strongly opposed. Hopefully the damage to fish stocks will be mitigated somewhat by the IFQ system, but the 4000 sq miles of habitat that was previously protected will now be subject to extensive damage. I see this as a big win for commercial fishing, and a big loss for the habitat and fish.

Selfishly, I am also sad to see the 8 sq mile area south of stonewall banks being opened to bottom contact trawling. I imagine that it will no longer be worth fishing there for sport boats, and this was really my only area that I'm familiar with.

Such is the way of the world, and I'm not surprised. But I'm disappointed with ODFW for supporting this, as it directly contradicts their mission statement.
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Old 08-30-2019, 11:27 AM   #32
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

No worries here...it's "historically important".


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Old 08-30-2019, 12:19 PM   #33
Joe Evens
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

The hell of this is that I tend to believe that The Shelf should be exploited, responsibly, and not all at once. A good steward of the resource would at least take a large cross section, say 25%, work it per A 28 for ten years to see how things go, change what is needed for sustainability, and then work the rest on a hundred year plan.

I'm even more sure that bottom contact should stay outside 50 fathom. The inside is fragile. As a nursery for the outside and inside it should be protected. I find no indication that the sand flats are considered as an ecosystem not a desert. It should be obvious by the density of fish on recovered areas that it is not a desert.

Amendment 28 will be implemented. It is not stoppable IMO. The amount of effort that has gone into A 28 is staggering. Considerable protection is built into it for some areas of concern. More is needed

I hate that the very nearshore area has been lumped in with the rest. The inside is so different and has so much importance and impact on the people that use it that it should be managed on a very different plan, A plan that includes those that use it. Not a plan that excludes input from local concerns and is kept hidden until too late, and then only found by accident.

We were not represented or apparently even considered as users and equals. That stinks.
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Old 08-30-2019, 12:34 PM   #34
Kingkiller
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

The Council, NOAA, National Marine Fisheries Service (NMFS), scientists, tribes, fishermen, and non-governmental organizations laid the analytical groundwork for this review through a multi-year synthesis of new data sets and analyses.

The above is some of the information concerning A28. Folks that were involved in developing this A28.

I sent out e-mails to my representatives months ago when this was brought up. Asking why not continue to protect the RCA's and other area's. Also not allow bottom dragging as I have witnessed 7 drag boats lined up trolling down the whole inside area of the Stonewall. That was years ago but still sits in my mind. Not sure why there is a need to drag the bottom. Any thing that stirs up the bottom in my mind can't be good. I have not got one response back from any representatives but that is par for the course. Politically I think this stuff is way over their heads. No understanding of how the fish and wildlife world goes around.


Also concerning CCA and non members. That alone makes me not want to be a member but for the good CCA does I would never say that. IMO informing non members is what makes members.


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Old 08-30-2019, 12:44 PM   #35
Joe Evens
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Quote:
Originally Posted by Tinman View Post
Joe, once again you are a prophet among us. You alone have raised the alarm, and pointed out that we are caught with our pants completely down on this. You have shown that we (and certainly me), have neglected the federal side of fisheries management. It is a glaring hole in our awareness and strategy.

The role of a prophet is to point out inconvenient truths, to awaken a group to their blindness, and to call them to action. Historically, people resist the prophet's message, preferring to look the other way, make excuses, or just plain avoid the hard work of change. I for one am guilty on all counts on this issue.

You brought this to me months ago, and I sidelined it (looked the other way). I said it was probably too late to have any impact (made excuses). I said I would look into it but didn't (avoided the hard work of change). But I recognize and honor your prophetic role. Let this be a wakeup call for all to engage in federal fisheries issues, not just state and regional issues.

Thank you for your diligence and for raising the flag on this. I can't begin to unpack this issue and arrive at any sort of conclusion. I can offer no valid opinion on the matter. Your lasting influence, for me anyway, will be much greater awareness of federal fisheries issues.
Thank you Charles. This thing is so big, so complex that I have few conclusions. My main intent was raising awareness, then trying to raise my own as it evolved.

One day I feel that I'm helping, the next it seems like a waste, the next day it seems that I'm tilting at windmills, again.

It is out of my hands. I'll try to just play it as it lays. I was lucky enough to live in 'the good old days' and suspect they will continue for a while. That is about all one can ask for.
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Old 08-30-2019, 05:29 PM   #36
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Quote:
Originally Posted by Gun Rod Bow View Post
Thanks for calling out CCA old friend.

If you had ever been involved with CCA you might understand that we dont discuss a lot of strategy on internet forums. Or with non members.

But feel free to go ahead and criticize what you dont know.
I’m a CCA member and supporter.
Is there a stance leadership is taking or at least in discussions with the ODFW.
Do you see this amendment as bad?
Just looking for more info since you’re always on top of things. Not trying to bash.
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Old 08-30-2019, 06:43 PM   #37
Gun Rod Bow
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

It has been in conversation among the CCA chapters of the 3 states for a couple of months.

I’ll just say that I don’t think anyone can say with a straight face that bottom contact trawling is good for conservation of fish or habitat.

You will be seeing more on this
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Old 09-03-2019, 12:48 PM   #38
Chass
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Default Re: Amendment 28 Revisited. Comment period has been extended. 20 days remaining.

Quote:
Originally Posted by Gun Rod Bow View Post
.

I’ll just say that I don’t think anyone can say with a straight face that bottom contact trawling is good for conservation of fish or habitat.

You will be seeing more on this
Thanks for that Bruce. I agree that any bottom contact is generally a negative thing.

I'm very curious to hear a public stance on this.

As Joe has pointed out, it's huge. I started reading and got lost a few times. Not sure I'll have time to digest all of it . . . ever. I went to those that I usually trust to share their side of the ODFW reasoning behind it. I got that and shared it here. While it does seem a little peachy, I certainly hope that the general mistrust of the ODFW is misplaced in this case. I'm not sure of that though.

I sure see a lot of people talking or rather writing here without having read it or referencing the facts. I may be wrong but I suspect very few people posting about this have even read the Executive Summary. I hope I'm wrong . . .

Chass
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