Comment from Diane Pleschner-Steele

May 14, 2009 Mr. Rodney McInnis, Regional Administrator Southwest Region NMFS 501 West Ocean Boulevard Suite 4200 Long Beach, CA 90802 RE: Docket No. 090421699-9797-01 Sardine – Annual Specifications Modification Dear Mr. McInnis, The California Wetfish Producers Association (CWPA) represents the majority of active wetfish fishermen and processors from both Monterey and southern California. We very much appreciate this opportunity, once again, to address the subject of Pacific sardine research. As we testified to the Pacific Fishery Management Council in November 2008 and March 2009, we believe developing a second index of sardine abundance is essential to expand understanding of the sardine resource and improve sardine resource management. We very much appreciate the Council’s interest in this industry-sponsored aerial/acoustic research plan, leading to its recommendation to the National Marine Fisheries Service (NMFS) to increase the research set aside by an additional 1,200 mt to provide a robust and scientifically defensible semi-synoptic survey extending into California. Since the March 2009 PFMC meeting we have worked closely with principal investigators of the Northwest industry survey to combine the two Experimental Fishing Permit (EFP) applications into a single Pacific coast sardine survey, extending from Cape Flattery to Monterey Bay. The California portion of the survey is now an integral part of the EFP proposal submitted for adoption by the PFMC and approval by NMFS. We’re making progress to execute the research plan, anticipating Council adoption of the final EFP proposal and NMFS issuance of experimental fishing permits and approval of the additional research set aside. Our planning to date includes identifying participating boats and processors, committing substantial resources (more than $80,000 to date) to purchase required camera system and hydroacoustic equipment, and initiating coordination and timing of the survey itself. In short, we are well on our way to readiness to begin implementing the research plan as soon as the July fishing season begins and the weather and Mother Nature cooperate – subject to final adoption and issuance of the EFP application and fishing permits, and Secretarial approval of the proposed rule modifying annual harvest specifications. In planning for this project, we attended the recent aerial survey methodology STAR panel meeting, and were pleased with the overall outcome and recommendations of the panel. Borrowing from the report: 4) Implementation of Survey Protocols An important question is whether the total EFP allocation (and how it is allocated to each area) is sufficient to achieve a useful survey. • At 1200 tons from each area, the suggestion of the Technical Team (i.e., a total EFP allocation of 2400 tons), the Panel concluded that there is a good outlook for successful calibration. The panel also voiced concerns similar to the Science and Statistical Committee’s earlier discussion questioning the scientific value of the initial 1,200 mt set aside, in essence reaffirming the rationale for the Council’s recommendation to increase the research allocation: • The Panel doubts whether sufficient precision would be achieved if only 600 tons were taken from each area (a total of 1200t is currently allocated for an EFP). In the case where a total of only 1200 tons was available, the Panel recommends that the entire 1200 tons be used in only one of the two possible survey areas. Moreover, the Panel saw no compelling reason to recommend that the tonnage be assigned to a particular area of the two areas, and would prefer that the Technical Team decide how they would best use the allocation, were it only 1200t. However, the Panel would not expect that an estimate based on a small number of point sets would provide a sufficient basis for a robust and precise estimate of abundance. If all of the allocation was taken from one area, this would provide a basis to estimate the relationship between school size and tonnage for that area, but it could not be used to estimate abundance for the entire survey area (Canadian border to Point Conception). Clearly, this industry-sponsored research plan holds great promise to expand knowledge of the sardine resource IF it is conducted in the manner described in the revised Pacific coast EFP application, including the full 2,400 mt research allocation, apportioned 1,200 mt to the PNW and 1,200 mt to California. CWPA, California’s wetfish industry and the CA members of the CPS Advisory Subpanel recognize the importance of this research and urge NMFS and the Secretary of Commerce to approve the Council’s recommendation that the original 1,200 mt research set aside be increased to 2,400 mt to provide sufficient point sets in each area to enable a robust survey that has the potential to be considered as a minimum estimate of absolute abundance of Pacific sardine. We further urge you to approve the Pacific coast sardine EFP as amended and issue the experimental permits expeditiously, so the research can occur during the July-August window. The data from this survey must be compiled and submitted in time for the mid- September sardine STAR panel, and the results of this survey may be very useful to inform the 2009 sardine stock assessment. Moreover, by continuing the survey over multiple years, this summertime survey will provide a basis for a new relative index of sardine abundance. We are fully committed to ensure the success of this research project, both in 2009 and in the future. In CA the use of the research set aside will be taken under the guidance of CA scientists, in coordination with PNW scientists and in daily communication with NMFS to assure strict accountability of the research set aside. The goal of this research set aside is to achieve representative samples of school height and volume in relationship to aerial photo-imagery. In addition, we will also use our Biosonics DT-X, deployed with both down-sound and side-looking capabilities to better quantify school height and density. Further, the SW Fisheries Science Center is interested in participating in expanded hydroacoustic research, and has offered to deploy its state-of-the-art acoustic equipment in conjunction with our summer survey, with the intent of developing an acoustic estimate of abundance that can be expanded into southern CA in the fall. Again, we appreciate the Council’s interest in this research, and we urge NMFS and the Secretary to approve the additional 1,200 mt research set aside as recommended by the Council. In addition, we ask you to approve the revised Pacific coast sardine EFP application and research fishing permits as itemized in the EFP application. Such approval will enable CA to participate fully in this research project after the summer directed fishing period has closed. Thank you for your consideration. Best regards, Diane Pleschner-Steele Executive Director