Electronic Logbooks: At its meeting in Tampa last week, the Gulf Fishery Management Council adopted by a strong vote of 10-3 a motion to direct its staff to prepare a white paper to evaluate a broad range of options for funding the electronic logbook program (ELB). This final motion actually represented the strongly preferred substitute offered by Council Member Harlon Pearce to a motion originally offered by NMFS Southeast Regional Administrator Roy Crabtree that would have required the Council to develop a plan to assess the cost of the program on the shrimp industry. SSA strongly opposes any effort to assess the cost of the ELB research program on the shrimp industry and opposed Mr. Crabtree’s motion.
SSA is deeply grateful to Mr. Pearce for his leadership in successfully championing this measure on behalf of the shrimp industry. Mr. Pearce has been a steadfast “go-to” champion for the Gulf shrimp fishery and other commercial fishing interests in Louisiana for many years as a leading commercial industry appointee to the Gulf Council. SSA also greatly appreciates the support for Mr. Pearce’s motion from Shrimp Committee Chairman Corky Perret and full Council Chairman Bob Gill, along with many other members of the Council.
“The ELB program is literally one of the main reasons why the shrimp fishery continues to exist today”, explained SSA Executive Director John Williams. Over the past decade, numerous federal actions have been proposed that would have shut down all or portions of Gulf shrimp fisheries in different times and areas as a blunt tool for protecting different bycatch species of concern including red snapper, sea turtles, smalltooth sawfish and blacknose sharks. In each case, the precise data generated by the ELB program has enabled fishery scientists and managers working with the shrimp industry to either improve the science and/or develop precise management measures that completely avoided the need for any closures at all. In addition, ELB data is a key tool for NMFS to conduct its annual shrimp stock assessments which are vital to the sustainability of these fisheries. Mr. Williams added, “There is no more valuable or broadly used scientific research program in the Gulf. We can’t thank Harlon enough for his tireless support for our shrimp industry.”
Fishery science generally breaks down into two categories; fishery-independent data such as scientific surveys performed government research vessels, and equally-valuable fishery-dependent data collected from the fishery itself. Both sources of scientific data, if available, form the scientific core of the assessments of fish stock status relative to a range of statutory mandates to end and prevent overfishing, rebuild overfished stocks, and protect various bycatch species covered by the Endangered Species Act and the Marine Mammal Protection Act.
Indeed, the performance of essential stock assessments for the vast majority of fisheries managed in the US rely on some form of fishery-dependent data including such parameters as catch, effort, catch per unit of effort (CPUE), bycatch, bycatch rates and size selectivity, among others. With this in mind, just like fishery-independent data collected on government research vessels, the collection and analysis of fishery-dependent data from commercial and recreational fisheries is the fundamental responsibility of the federal government. It is the federal government’s job to both perform and fund such core scientific analyses as fish stock assessments and protected species bycatch estimates.
The ELB program is fundamentally a fishery-dependent research program at the core of the NMFS scientific research mission. The program analyzes fishery-dependent data including catch rates and landings to generate very precise estimates of the time and location of shrimp fishing effort. The data is collected by electronic logbooks installed on over 500 cooperating vessels in the shrimp fleet. As is appropriate, the cost of the ELB program has been borne by the federal government since its inception.
From 2005-2010 SSA successfully lobbied Congress for a total of $5.8 million to maintain funding for the program. Consistent with numerous directives from Congress, beginning in FY 2011 and again in FY 2012, NMFS covered the cost of the program from its own budget. Nevertheless, in reply to a letter from the Gulf Council supporting continued full agency funding for the program, NMFS indicated it intended to shift this cost onto the backs of the shrimp fishery. (Click the following links to view: Council Letter to Rauch, Rauch response letter to Council) This was the basis for Mr. Crabtree’s unsuccessful motion before the Council last week.
While creative options can and should be explored under the current budgetary environment, the cost of collecting and analyzing this data is and must remain the responsibility of the federal government. As for any core fishery-dependent data used by the agency to perform its responsibilities, these costs should not be forced by regulation onto the industry to pay as an expedient way for the agency to address its budgetary challenges. If the shrimp industry is held responsible for funding something so fundamental to the agency’s scientific mission as is the ELB program, at what point will the line be drawn on the fishing industry’s responsibility to pay for NMFS functions? Again, SSA expresses its profound appreciation to Mr. Pearce and the Council for its work to defend the shrimp industry against the agency’s unfortunate efforts.
Finally, SSA is extremely grateful to Senators Thad Cochran (R-MS) and Roger Wicker (R-MS) who have championed a specific directive for NMFS to maintain full funding for the ELB program in FY 2013. This directive is set forth in the Senate Appropriations Committee report accompanying the Senate’s FY 2013 Appropriations legislation covering NMFS. This language provides an unequivocal expression of consistent Congressional intent for the agency to assume responsibility for performing and funding this core function. This may represent our best hope for a positive resolution of this issue, but it is clear that this legislation will not be enacted prior to the end of the current fiscal year. Thus, SSA looks forward to working with Senators Cochran and Wicker and other Members of Congress, and the agency’s leadership to ensure that the agency maintains the program from the beginning of FY 2013 (October 1, 2012).
SSA TED Funding Proposal: Pursuant to the Natural Resources Damage Assessment program under the Clean Water Act, BP is required to fund early restoration projects approved by NOAA. SSA took the opportunity to submit a $10.8 million proposal on behalf of the shrimp industry at large to provide funding to equip (at no cost to the industry) the entire Gulf shrimp fleet with new TEDs. (Click the following links to view: NRDA Proposal-SSA, Project Cost Estimate) The project funding would not go to SSA but would likely be administered either through the States or directly from NMFS. Although SSA has raised serious concerns about the agency’s recent proposal to require TEDs on skimmer trawls, SSA’s project proposal to the NRDA program would also cover the cost of those TEDS if the regulations become final. Said SSA Executive Director John Williams, “While we’ve had a lot of concerns about the agency putting TEDs on skimmer trawls, we wanted to make sure these costs were covered at no cost to skimmer trawl fishermen if those regulations are ultimately imposed by NMFS. Providing all our fishermen with a new set of TEDs will also help the rest of the Gulf shrimp fleet stay in compliance with the TED requirements which is now the central focus of NMFS turtle protection efforts “.
At the recent Gulf Council meeting, Gulf States Marine Fisheries Commission Executive Director Larry Simpson championed a motion before the Gulf Council to send a letter to NMFS strongly endorsing SSA funding proposal. The motion was adopted with the unanimous support of the Council. (Click the following link to view: Council letter to Schwaab support for SSA NRDA proposal) SSA expresses its great appreciation to Mr. Simpson who has been a great leader and friend of the Gulf shrimp fishery for decades.