Geir Monsen

COMMENTS ON 2012 INTERIM BUTTERFISH SPECIFICATIONS, NOAA-NMFS-2011-0245 First let me give you some background information about butterfish. Our company pioneered the catching of butterfish both along our East Coast and in The Gulf of Mexico. We also pioneered the marketing of both types of butterfish in The Japanese Market. The economic foundation of our operation was built with income from butterfish. I am sure we know more about butterfish harvesting and marketing than any other American organization. We strongly disagree with your determination that we are risking over fishing of the butterfish resource because no overfishing level have been determined. May I remind you that none of the four species in the Mackerel, Squid and Butterfish Plan (MSB) have a specified overfishing level. To claim that the butterfish quota can’t be increased because of the lack of overfishing level is pure nonsense with the only objective of making sure we have no viable fishery. In 2010 we made comments to the proposed specification for MSB for 2011 in great detail with the help of a lawyer to make sure we got all the legal terms right. You answered one comment and told us the rest of the comments were irrelevant. In 2011 we made comments for the 2012 specifications with the help of a marine biologist to make sure we had all the biological terms right. Again you attempted to answer one comment and deemed the rest irrelevant. It seem to be very easy not to reply to any comments that are a bit difficult and require some work for a response or are such that you can’t come up with a reply. You are making a mockery of your own system. One of the principles of this country is that no one person or organization can be the police, prosecutor and judge at the same time. You are certainly by your actions testing if that principle still stands. You are asking for comments and then you are determining what comments are relevant. That makes your request for comments irrelevant. It would be nice if you reply to our comments to this interim specification and all our comments from November 2011 to your proposed rule. It is rude and cowardly, not only to us, but the whole country, not to reply to comments about your governing of our resources. It shows a very arrogant attitude. In your latest request for comments dated March 21, 2012 you state that all comments received are part of the public record and will generally be posted in the Federal Register without change. This was not done for the comments you received on the MSB specifications for both 2011 and 2012. Did you not want the public to see what the comments were? In your reply to comments on the 2012 MSB specifications you stated as follows: You received comments from a scientist on behalf of Seafreeze Ltd. You received comments from The Herring Alliance, an environmental group that represent 42 North East Organizations. You received comments from the Garden State Seafood Association. You received comments from Lund’s Fisheries Incorporated. The choice of wording tell me right away what comments you like and what comments you don’t like. You failed to mention that the Herring Alliance consist mostly of groups that nobody have ever heard of. Some of the organizations have their address as the local library. You also failed to mention that Garden State Seafood Association and Lund’s Fisheries Incorporated is one and the same organization. The assessment of fish stocks is not a very precise science and it will remain so until we find a way to count every fish in the ocean. There are a lot of unknown factors and a lot of uncertainty with the assessment of every fish stock, and it will remain so as long as we use a handful of fish to estimate how many thousands of tons are swimming around under that shiny ocean surface. The stock of butterfish has been assessed using the same ways as you are doing for cod fish. According to your own literature cod live to be over 10 years old and butterfish to be about 1.5 years old. The survey results you are using in your stock assessments are normally 5-7 years old by the time they are used for quota setting. This means that for butterfish we are using information that is 3-4 generations old and for cod about 0.5 generations. If we used the same number of generations for cod as for butterfish we would be looking at cod data from 30-40 years ago to set next year’s quota. I have not heard anybody propose a system like that because they would be the laughing stock of the community. Still we go on and do this for butterfish with straight serious faces every time. We would be more accurate throwing darts at a board with numbers. When is some body going to wake up? Or is it calculated that the non government organizations are more likely to take NMFS to court than the fishing industry is? A few years ago the principal survey vessel used was changed from the “Albatross” to “Henry Bigelow”. Before that change took place an attempt was made to calibrate the catch of fish between the two vessels. The two vessels towed their trawl nets in the proximity to each other and were sometimes as much 1.5 miles apart. From those 300 + test tows an attempt was made to mathematically calculate the difference in catch for each specie of fish and the different size categories of each specie. I think this is about as easy to do that calculation as to calculate what the weather will be on this day 10 years from now. When the numbers of assumptions and unknowns going into a calculation are larger than the number of known facts it is hard to have any kind of confidence in the results. After the “Henry Bigelow” started working by itself it was found that is caught more fish than the scientific crew could handle. The solution for that was to reduce the tow time on bottom from 30 minutes used on “Albatross” to 20 minutes on “Henry Bigelow” and also the tow speed was changed from 3.8 knot to 3knots with a final result of making the tows a little more than half the length of what “Albatross” did. I have not seen the calculation for this, but again it is an absolute impossible task to calculate the difference. Please send out a questionaire to every trawl captain in the world and ask what happen when you change time and speed and you will get one answer and that is that it is impossible to know. In the middle nineties we stopped directly fishing for Atlantic butterfish because catches were low and as a result the Japanese buyers switched to processing other similar fishes. In 2001 we found huge schools of Atlantic butterfish and we decided to try catching and marketing the fish again. We had the best catches we have ever seen and 2 boats caught 2,600 metric tons in 6 weeks before we stopped catching. These catches show up in all your agency’s records. It proved to be a lot harder to get the market back that what we had imagined, and we struggled for 3 years to sell what caught at low prices. When we finally started to get some traction in the market the quota was reduced to low level that killed all the interest in The Japanese Market. Since that time the stock of butterfish seem to have continued to increase, but it is difficult to estimate what catches could be since we have a very low quota coupled with very low trip limits that result in no directed commercial fishing. Whenever I hear butterfish discussed by scientists and managers I hear that the butterfish stock must be in trouble because landings are so low. That is from the same people that supply the information and make the decisions that will perpetually keep the catches low. We are in a vicious circle that it seem impossible to get out of. We need to turn butterfish into export revenue and jobs rather than let it die and fall to the bottom and rot to nobody’s benefit. All the state surveys done along the East Coast show increased abundance of butterfish. All the university surveys that have been done show increased abundance of butterfish and the same shows at all nuclear plants using filtered seawater for cooling. All the recent NEFSC surveys show high and increased abundance of butterfish. The most telling story was published in a Bangor, Maine newspaper last year and told a story about how the tern chicks were dying of starvation because butterfish had replaced the traditional sand eels in coastal waters. The sand eel is long and slim while the butterfish is short and wide and will fit down the narrow neck of a tern chick. The article came with a picture of an adult tern trying to feed it’s chick a butterfish that would not fit. However, the recent high abundance of butterfish is explained away by using the calibration factor between ‘Albatross” and “Henry Bigelow”. In all recent surveys butterfish account for one of the highest catches of any fish that have high quotas. The most glaring example is a 2009 survey where the catch Pollock 108 Lbs. and butterfish is about 9,700 Lbs. At that time the Pollock quota was increased to about 16,000 metric tons while butterfish remained at about 500 metric tons. Our captains are the most experienced catching butterfish and are reporting higher abundance of butterfish than they have ever seen. Other captains are also reporting the same. In the NEFSC fall survey of 2011 butterfish was the second highest catch after dogfish. Several tows of butterfish were around 10,000 Lbs. or more and some were so large they could not brought up on deck. We got this information from several independent sources, but NMFS is treating this as a national top secret and we have not been able to get an official number for the catch of butterfish. Several representatives of different Japanese fishing companies have told me over the years that when they were allowed to fish here they caught about 60,000 Metric tons (132,000,000 Lbs.) each year, and they only reported a fraction of it. There were no on board observers at that time. This created a market and demand for the fish in Japan, and these same fishing companies were the first ones to come here to purchase butterfish after introduction of the 200 mile exclusive zone. In the eighties NMFS made a preliminary management plan for the Gulf of Mexico butterfish and estimated it could handle a yearly catch of 50,000 metric tons. When we stopped catching butterfish in the middle nineties the average selling price was about $2,-/Lb. If we had a quota of 50,000 metric tons (110,000,000Lbs.) and were able to catch and sell that at the same price level that would be equal to $220,000,000 in export revenue per year. To measure total economic impact to the local economy I have seen multipliers use from 4 to 6, and that would result in total impact between $800,000,000 and $1,200,000,000 per year. That again would result in thousands if not tens of thousands of jobs. If you think that the reduction of 2,000 metric tons of cod quota is big problem than it is about time you take a look at this problem. This month the loligo squid fishery also got closed down because the boats were catching butterfish that it is impossible to avoid. If we get a high quota for butterfish the catches will not increase rapidly. They will have to be sold before anybody will put a lot of effort into catching and freezing them. I will take many years to bring the market back and there will be plenty of time to adjust the management if the situation warrants it. Please keep in mind that with a short lived specie like butterfish the natural swings in population can be huge. The recruitment can be very strong and the time line between a stock high and a stock low can be very short. We know some of the bags of butterfish were so large that the crew could not bring them onboard. We got this information confirmed from various sources, but within NMFS it is being treated as a national top secret and we have not been able to get an official number for the butterfish catch. Please do not let us go through another year of millions of dollars of dead fish falling to the bottom of the ocean without creating any jobs and benefits to our country.