Comments on Pacific Sardine Harvest Parameters

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1 Agenda Item E.2.c Supplemental Public Comment 3 Electronic Only November 2014 Comments on Pacific Sardine Harvest Parameters Geoff Shester, Ph.D. November 15, 2014 Presentation to the Pacific Fishery Management Council, Agenda Item E.2

2 We request the PFMC select Alternative 2a as PPA CalCOFI more accurately predicts recruitment as intended Alt 2a is only alternative whose performance falls within the status quo range, yet allows greater harvest more of the time than status quo Changes to FRACTION bounds are unjustified Draft EA analysis insufficient Evidence of exceeding target harvest rates Evidence of inadequate forage Failing to achieve OY and prevent overfishing

3 Retrospective comparison of % of years each alternative would have had higher and lower harvest rates than under No Action (SIO) -100% -50% 0% 50% 100% 2a (5-15) 2b (10-20) Higher than no action Lower than no action 2c (5-20) 2d (0-20) Data from CPSMT presentation to SSC 11/14/14 Harvest rate: Alt 1 < Alt 2a < Alts 2b,c,d

4 Alternative 2a is most similar to status quo. Alternatives 2b, 2c, and 2d are MORE AGGRESSIVE than status quo: Higher catch and lower biomass Alt 1 * (No Action) Alt 2a Alt 2b Alt 2c Alt 2d Fraction 15% 5-15% 10-20% 5-20% 0-20% Mean B1+ (tmt) Depletion 77% 78% 75% 75% 76% Mean catch (tmt) Data from Draft EA. Agenda Item E.2, Table 1 *Alt. 1 (No Action) from Scenario code 22, Table 4, Hurtado-Ferro & Punt 2014 (March 2014), bounding No Action as per SSC recommendation.

5 Optimizing fishing quotas to meet target fishing fractions of an internationally exploited stock of Pacific sardine (Sardinops sagax) North American Journal of Fisheries Management, 2014 D. A. Demer and J. P. Zwolinski (NMFS/SWFSC) the current harvest control rule for sardine has not consistently maintained a total fishing fraction below the US target value because the distribution parameter, which is intended to account for the proportion of the stock in the US exclusive economic zone (EEZ), has not adequately accounted for landings of the stock at Mexico and Canada. U.S. Landings as proportion of coastwide landings from : Differentiated landings of Northern stock only: 70% Undifferentiated landings of N and S stocks: 53%

6 The Repercussions Proportion of Target Coastwide Harvest intended by US HCR US Mex & Can Total Assumed (Draft EA) 87% 13% 100% Actual ( N. stock only) 87% 37% 124% Actual ( both stocks) 87% 77% 164% Actual harvest on average exceeds target (OY) by 24-64%, counteracting the predicted benefits provided by U.S. CUTOFF

7 Performance measures are highly sensitive when Mexico and Canada don t follow U.S. HCR Status quo* Alt 2a Alt 2b 2a (MF)* 2b(MF)** Fraction 15% 5-15% 10-20% 5-15% 10-20% Mean B1+ (tmt) Depletion 77% 78% 75% 46% 42% Mean catch (tmt) *Sensitivity Run corresponding to Alternative 2a when Mexico and Canada do not follow US Harvest Control RuleTable 6, S14, Hurtado-Ferro & Punt 2014 ** Additional Sensitivity Run of Alternative 2b (Oceana Public Comment)

8 Need to Update Distribution The Workshop noted that the current 87% was based on an examination of CalCOFI data from and aerial spotter data from , and that the distribution of the stock had changed markedly since then. It therefore agreed that any new basis for defining DISTRIBUTION should focus on data from the most recent decade or at the most, the last two decades. PFMC Sardine Workshop Report, Feb. 2013

9 Sardine Collapse: The Role of Fishing Decline ( ): 1,050,000 mt (74%) drop Fishery Removals: 715,000 mt Fishery removals: 715,000 mt US Fraction was at 15% through 2013 No surplus production, low recruitment

10 Evidence of Inadequate Forage Specifically Sardine and Anchovy California Sea Lions 2013: Unusual Mortality Event (Melin et al., NOAA, 2014) 2014: Double average pup mortality Brown Pelicans 5 consecutive years of nesting failures (Harvey 2013) 2014: First range-wide nesting failure in 25 years of monitoring Draft EA does not take a hard look at effects of action on these predators Ingrid Overgard/TMMC Ingrid Taylar Primary forage: sardines & anchovies Geoff Shester/Oceana

11 Less Forage than Previously Thought Predicted Average Forage Contribution of Sardines to Ecosystem under Existing Harvest Guideline Average Annual Forage Production (mt) % lower Annual Forage production = Natural Mortality = 33% of total biomass 0 Amendment 8 Analysis (1998) Hurtado-Punt Analysis (2014)

12 Please Support Alternative 2A Consensus on using CalCOFI to determine FRACTION Increasing FRACTION would be a mistake at this time. Sardine population just plummeted by 74% while recruitment and biomass are at 20-year lows The problem is that the current rule has been overestimating productivity in the HG for the last 7 years New published NMFS science shows Mexico and Canada taking far more sardines than assumed in US HCR, target F is being exceeded Warning signs in key indicators of adequate forage for predators without hard look at the consequences of fishery and proposed action on predator reproductive failures 4,604 CA, 620 OR, 891 WA, and 94 ID residents Support Alternative 2A