[Fishlink] >FISHLINK SUBLEGALS 7/26/02<

Thu, 1 Aug 2002 03:49:29 EDT

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                     ~~>FISHLINK SUBLEGALS 7/26/02<~~
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       A WEEKLY QUOTA OF FISHERY SHORTS CAUGHT AND
     LANDED BY THE INSTITUTE FOR FISHERIES RESOURCES 
     AND THE PACIFIC COAST FEDERATION OF FISHERMEN'S
                                        ASSOCIATIONS

  VOL. 06, NO. 04                                           26 JULY 2002
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This week's issue of Sublegals is available in PDF format on the web at 
www.sublegals.net. We have also pasted the text below for those who 
still wish to read it through your email. In the coming weeks we will be 
posting all past issues as well as a search engine. In addition to this new 
look, we are continuing our Sublegals Fundraiser to support the Institute 
for Fisheries Resources and the Pacific Coast Federation of Fishermen's 
Associations in publishing this weekly newsletter free of charge. We 
have recently passed our 100th issue, with very little funding, and are 
looking to our readers to sustain the continuation of this effort. Go to 
www.sublegals.net to donate to this effort. Thank you for your support 
of community fisheries education. 
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"I began a revolution with 82 men.  If I had to do it again, I'd do it with
10 or 15 and absolute faith. It does not matter how small you are if you
have faith and a plan of action."............Fidel Castro
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IN THIS ISSUE.......

PCFFA Proposes "Trident Approach" for West 
Coast Groundfish Crisis. 6:04/01

MLPA Working Groups Finish First Set of Meetings.  6:04/03

Mercury Levels in Tuna May Be Cause for Concern.  6:04/05

Oyster Growers' Carbaryl Controversy Continues. 6:04/06

NMFS Publishes Draft Hatchery ESA Listing Policy. 6:04/09

AND MORE......
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     6:04/01. PCFFA PROPOSES "TRIDENT APPROACH" FOR WEST
COAST GROUNDFISH CRISIS: The Pacific Coast Federation of
Fishermen's Associations (PCFFA) has proposed a three-prong approach
for addressing the current groundfish crisis that has closed a number of
fisheries and threatens to shut down even more (see Sublegals, 5:25/01;
5:23/01). PCFFA made the proposal on 24 July, at a California
Department of Fish & Game (CDFG) sponsored hearing where
testimony for the Pacific Fishery Management Council (PFMC) on the
options for the 2003 groundfish fishery (see Sublegals, 6:03/10) was
given.  Comments were also heard on the 2002 emergency groundfish
regulations for south of Cape Mendocino and CDFG's Nearshore Fishery
Plan. At the Oakland hearing, PCFFA  recommended:

     SELECTIVE GEAR DEVELOPMENT/EXPERIMENTAL
FISHERIES - The first "prong" of the PCFFA proposal calls for the
immediate issuance of experimental gear permits, pursuant to a research
protocol with observers, to allow a select number of fishermen
experiment in areas believed free of the rockfish species of concern (i.e.,
boccacio, yellow-eye, canary, darkblotch).  This study would determine
whether flatfish (e.g., sand dabs, petrale, English sole) can be taken with
trawl nets or Scottish seine with no incidental take of the depleted
rockfish species. The experimental program would also include longline
and hook-and-line gear for species of rockfish that are not of concern. 
The National Marine Fisheries Service's (NMFS) Northwest Region has
failed to implement a full-scale experimental program. The second barb
on this prong is to push for funding for research and development of
more selective fishing gear.  PCFFA has recommended the appropriation
of fishery development monies in the federal Saltonstall-Kennedy Act
(S-K) program for necessary research and development.  Language to
that effect was included in U.S. Representative Sam Farr's
Magnuson-Stevens Act reauthorization bill, HR 2570 (see Sublegals,
4:03/01), a measure currently mired in the House Resources Committee.

     ADDITIONAL/COOPERATIVE RESEARCH - One of the reasons
for the current groundfish crisis has been the lack of complete and timely
research. The Pacific groundfish stock assessments had been occurring
on a tri-annual basis and have not even included the waters south of
Point Conception. Indeed, the coverage of the areas where assessments
were made was hardly comprehensive.  As a result, problems were not
found out until it was too late, and it is still unknown whether stocks are
in better or worse shape than current estimates.

     As part of the effort to improve the stock assessments and research,
PCFFA has proposed, as have many other fishing groups, utilization of
fishermen and their vessels in data gathering.  This would free
researchers from working around the schedule of the few specifically
built research vessels currently available and cost them a fraction of
what it would cost otherwise.  This would also allow fishermen and
researchers to work together and share knowledge.  Moreover, such
cooperation could help those choosing to stay in fishing during a time of
catch cutbacks and stock rebuilding.  PCFFA urged the Pacific Council
to look for opportunities to use fishing vessels for research and requested
NMFS to do the same.

     REDUCING FLEET CATCH CAPACITY/VESSEL BUYBACK -
The third "prong" of PCFFA's approach to the groundfish crisis has been
to promote a groundfish vessel/permit buyback program. PCFFA has
argued that the federal government pay for a substantial part of such a
buyback since it was the government's "Americanization" program that
caused NMFS to promote the build up of the groundfish fleet -
particularly large trawlers and longliners during the late 1970's and early
1980's - without any idea of what level of fishing effort the various
species in the groundfish complex could sustain. Given the recent $190
billion earmarked for U.S. agriculture in the Farm Bill, with $50 million
alone for Klamath Basin growers, PCFFA has argued it is not
unreasonable - "indeed, equity demands" - that a sum of $250 million be
appropriated for vessel buyback programs in the Pacific Coast and New
England groundfish and in the Alaskan crab fisheries. PCFFA chided the
PFMC for its failure to pursue the funds needed to implement the
Council's plan for reducing effort in the fishery by 50 percent.

     At the hearing, PCFFA said it was time to stop blaming the law - the
Sustainable Fisheries Act of 1996 (amending the Magnuson-Stevens
Act) - that prohibits overfishing, or the lawsuits arising out of that
legislation, and instead begin working to rebuild depleted stocks while
allowing for fishing on the more abundant stocks. In its
recommendations for the 2003 season, PCFFA said the Council needed
to develop a recommendation to allow for the maximum amount of
fishing available while meeting protection and rebuilding goals set forth
in the law.  It concluded saying that this did not mean a closure of the
Huntington Flats to the remnant gillnet fleet from San Pedro.   For more
information on the PFMC proposed options for the 2003 groundfish
fishery, go to the Council's website at: www.pcouncil.org. 

     6:04/02.  GROUNDFISH FLEET BUYBACK FUNDING
GUARANTEE PASSED IN HOUSE; EMERGENCY RELIEF
APPROVED FOR NEW ENGLAND; GROUNDFISH RESCUE BILLS
STILL PENDING:  On 23 July, the U.S. House of Representatives gave
final approval to a Supplemental Appropriations Bill (H.R. 4775)
containing several provisions of interest to fishermen.  Section 206
extends the time of the report for the U.S. Commission on Oceans Policy
until 30 June 2003; Section 210 appropriates $11 million to provide
economic assistance and disaster relief to New England groundfish
fishermen as a result of closures and fishing restrictions; Section 211
provides $500,000 in loan guarantees for financing a revolving loan fund
to support an industry paid-for buy-out and permanent retirement of
groundfish permits in New England; Section 212 provides an additional
$500,000 to secure loan guarantees for an industry paid-for groundfish
vessel and permit buyback and retirement program for the west coast
groundfish fleet.  The bill was sent to the President on 27 July for an
expected signature.

     Two bills are still pending in Congress, both called the "Pacific Coast
Groundfish Fishery Preservation Act" (H.R. 2376 and S. 973), that
would formalize a groundfish capacity reduction program, initially to be
funded with loans obtained from private banks using already
appropriated Congressional funds as loan guarantees. These bills are
considered more likely to pass now that initial funding has been secured.
The loans to the fund would be financed through harvest or landings fees
collected from within the industry over time from those fishermen
remaining. However, many fisheries leaders, calling these amounts "a
mere pittance" compared to the recently passed Farm Bill containing
$190 billion in agricultural subsidies, have called for full Congressional
funding of a much more aggressive capacity reduction program, instead
of relying on repayment of loans through fees in an already
overburdened, uncertain and largely closed fishery.

     Both bills would also allow conversion of Capital Construction Funds
(CCF) to Individual Retirement Accounts (IRAs) without tax penalties,
to allow captains who have been paying into those funds for years to use
them toward retirement instead of only for the construction of yet more
boats in a grossly overcapitalized fishery.  For more information on these
bills see the THOMAS system for tracking bills through the Library of
Congress at: http://thomas.loc.gov.

     6:04/03. MLPA WORKING GROUPS FINISH FIRST SET OF
MEETINGS: The working groups comprised of stakeholders, including
fishermen, representing a broad range of constituencies in the
implementation of California's Marine Life Management Act (MLPA)
completed their introductory round of meetings 17-19 July. The working
groups were created in the spring of 2002 in response to concerns about
the initial attempt to implement the MLPA (see Sublegals 5:24/04) to set
up a process for the establishment of marine protected areas (MPAS)
along the California coast. The members were given an overview of the
process, including their responsibilities and duties, which could last until
2005. The meetings included background on the MLPA, an overview of
some scientific reports that have been conducted on Marine Protected
Areas (MPAs), and some of the economic and social factors to consider
during this process. The regional working groups will now focus on their
respective areas, interpreting the goals and meaning of the Act. IFR will
be developing a system to help facilitate this process, as part of its
Sustainable Fisheries Program. Look for updates soon on the IFR
website at www.ifrfish.org and in future issues of Sublegals. To read
more, go to http://www.dfg.ca.gov/mrd/mlpa/working_group.html. 

     6:04/04. PFMC MARINE RESERVES COMMITTEE TO MEET IN
SOUTHERN CALIFORNIA: The Pacific Fishery Management
Council's (PFMC) Marine Reserves Policy Committee will meet 14-15
August at the Hilton Garden Inn in El Segundo, California. The meeting
had originally been scheduled for 1-2 August. Its purpose is to consider
policy recommendations for marine reserve proposals for California
waters of the Channel Islands National Marine Sanctuary. For more
information, go to: www.pcouncil.org. 

     6:04/05. MERCURY LEVELS IN TUNA POSSIBLE CAUSE FOR
CONCERN: A scientific advisory panel to the U.S. Food & Drug
Administration (FDA) recommended on 25 July, after three days of
meetings in Beltsville, Maryland, that the FDA tell pregnant women to
limit their consumption of tuna due to potential high levels of mercury
contaminants. The FDA issued a warning last year that pregnant women
and children should avoid shark, swordfish, king mackerel and tilefish
due to high mercury levels. Critics charged that tuna steaks and canned
tuna should be included on the list. In response to these complaints the
FDA convened the scientific panel to review last year's warnings. High
levels of mercury in mothers can cause birth defects in babies, and
mercury at lower levels can result in lower IQ's and slower development
in babies. Mercury from mining operations and other industries pollutes
oceans and lakes, accumulating in larger fish such as sharks and tunas. 
Smaller tunas, such as albacore, should therefore have lower levels of
mercury and be of less risk. These differences between fish, even species
of the same family, further highlights the need for seafood labeling
allowing consumers to distinguish between potentially harmful foods
and those with the most health benefits.

     One organization, the Environmental Working Group (EWG), has
been advocating for the mercury warnings and claims that the FDA was
influenced by industry lobbyists to specifically leave tuna off its avoid
list.  For more information from EWG about the FDA's mercury policies,
go to: www.ewg.org. EWG recommends pregnant women replace tuna
with other low-mercury level seafood such as wild Pacific salmon and
farmed trout for their beneficial omega-3 fatty acids that help developing
brains. This offsets some of the panelists' fears that these women will
switch to other sources of protein such as bologna, missing out on the
benefits of seafood consumption. The FDA said they would place these
recommendations in top priority when setting guidelines this year. To
see the San Francisco Chronicle article, go to:
http://www.sfgate.com/cgi-bin/article.cgi?file=/chronicle/archive/
2002/07/26/MN229793.DTL.  

     6:04/06. WASHINGTON STATE OYSTER GROWERS' DIRTY
LITTLE BUSINESS: In the last issue of Sublegals, (6:03/07), it was
reported that a Superior Court Judge on 19 July overturned a ban on the
spraying of the pesticide carbaryl on tidal flats in Willapa Bay and Grays
Harbor by oyster growers. Carbaryl, is used by the growers to kill
burrowing shrimp that they claim threaten oysters.  The pesticide is most
toxic to arthropods including honeybees, Dungeness crabs, and shrimp
though it is also moderately toxic to salmon and even to oysters.
Objections to the 40-year old practice of spraying the tidal flats in
mid-summer were initially raised by some organic oyster growers who
complained that the pesticide was affecting their crops and making them
unmarketable for at least part of the year.  One of those growers was
Larry Warnberg who at the time sat on the board of the Pacific Coast
Shellfish Growers Association (not Pacific Coast Oyster Growers as
incorrectly reported in the last Sublegals). As a result of his making an
issue of the carbaryl spraying, Warnberg was removed from the
Association's board and locals saw to it that some of his tidal leases were
cancelled as well. The head of the Willapa Alliance also lost her job in
1994 in part because of concerns she raised about the spraying of
carbaryl as well as an herbicide with a surfactant for spartina in Willapa
Bay and Grays Harbor.

     Following a 2001 federal court ruling that the Washington
Department of Ecology had to issue a National Pollution Discharge
Elimination System (NPDES) permit, pursuant to the federal Clean
Water Act, for the carbaryl spraying, the state agency went ahead and
issued a four-year permit to cover 800 acres.  The Department of
Ecology permit was appealed to the Washington Pollution Control
Hearings Board where it was overturned and that 2-1 decision was
subsequently overturned by Judge Paula Casey on the 19th, citing
"economic hardship" and allowing the spraying to go ahead. Spraying
began on the 22nd and the Department of Ecology increased the area to
1100 acres. Organic oyster growers and the Washington Toxics
Coalition have a hearing in February to challenge the last three years of
the permit.  In addition, a recent court decision, where both PCFFA and
the Washington Toxics Coalition were plaintiffs, requires the U.S.
Environmental Protection Agency (EPA) to formally consult with NMFS
on various impacts on salmon from pesticides, including carbaryl (See
Sublegals 5:16/13). 

     Carbaryl supporters claim the pesticide breaks down quickly in the
marine environment, posing little risk to non-target species. However, a
1999 EPA study showed carbaryl has the potential to disrupt the benthic
food chain.  Researchers found that it lasted longer than previously
suspected, though they did not find it in historically sprayed sites.  Some
suspect also that the high rate of spontaneous abortions the Shoalwater
Indian Tribe has experienced for the last 50 years is related to
environmental toxins.  The Tribe lives on the northeast shore of the Bay
and relies heavily on the area's fish and shellfish. For more information
on carbaryl, go to: http://www.epa.gov/iris/subst/0019.htm. The 1999
EPA study can be found at: http://www.ecy.wa.gov/pubs/99323.pdf; a
2001 EPA study: http://www.ecy.wa.gov/pubs/0103005.pdf. The
question now is, how much longer can the Willapa Bay and Grays
Harbor oyster growers hide behind the otherwise good image (i.e.,
environmentally benign, sustainable) of the rest of the oyster industry?  

     6:04/07. FARM BUREAU AND TIMBER INDUSTRY APPEAL
PRONSOLINO CLEAN WATER ACT DECISION:  The Farm Bureau,
the American Forest & Paper Association and the California Forestry
Association, representing agribusiness and industrial timber interests,
have decided to appeal the landmark Ninth Circuit Court of Appeals
Clean Water Act ruling in Pronsolino v. Nastri (No. 00-16027) handed
down by the Court on 31 May that upheld the power of the federal
government to regulate non-point source pollution (see Sublegals
5:22/03).  The case was perceived as a direct landowner assault on the
Clean Water Act's "TMDL" ("total maximum daily load") pollution
control authority by which sediment, water temperature and various
agricultural pesticides can be regulated under state and federal law.  The
plaintiffs in the case claimed that in spite of its plain language the Clean
Water Act does not in fact give any regulatory authority over non-point
source pollution, and that any effort by Congress to assert that authority
would be unconstitutional.  The three Judge panel of the Ninth Circuit,
however, did not agree.  The Court ruled: "Looking at the statute as a
whole, we conclude that the EPA's interpretation of the [Clean Water
Act] Sec. 303(d) is not only entirely reasonable, but considerably more
convincing than the one offered by the Plaintiffs in this case."  

     The Ninth Circuit Court of Appeals decision, if it stands, settles the
law on this issue throughout the western United States, including all
states with salmon fisheries currently at risk from hot water pollution,
silt and agricultural chemicals. The Plaintiffs are asking for a new
hearing before the Ninth Circuit.  The Ninth Circuit ruling can be found
under "recent cases" for 31 May on the Internet at:
http://caselaw.lp.findlaw.com/data2/circs/9th/0016026p.pdf.

     6:04/08. CENTRAL CALIFORNIA IRRIGATION DISTRICTS
JOIN ESA DELISTING SUIT FRENZY: On 19 June, the Modesto,
Merced, Oakdale, South San Joaquin, Turlock and South Stockton
Irrigation Districts of Central California all filed a joint 60-Day Notice to
Sue against the National Marine Fisheries Service (NMFS), citing the
Alsea Valley Alliance decision (see Sublegals 4:24/19; 4:20/08; 4:18/02;
4:11/02), claiming that not only are anadromous California Central
Valley steelhead genetically indistinguishable from resident rainbow
trout, but that wild fish of both species are genetically indistinguishable
from hatchery fish.  The irrigation districts are asking that NMFS set
aside its listings of steelhead within the California Central Valley as
arbitrary and capricious.  

     These irrigation districts are only the latest groups filing an "Alsea
Valley look-alike" case seeking to overturn ESA protections for some or
all of the 26 distinct stocks of salmon and steelhead that are now ESA
listed in west coast waterways (see Sublegals 4:26/08; 4:13/01).  Most of
these cases are currently stayed, pending the outcome of the appeal of
the original Alsea Valley Alliance decision to the Ninth Circuit Court of
Appeals, which will be argued this fall.  The irrigation districts are
seeking a delisting of Central Valley steelhead to get out from under any
obligations the ESA might require of them to change water diversion
practices, screen irrigation ditches or to return more water to the
Calaveras, Stanislaus or Tuolumne Rivers.  Some of the irrigation
districts also own their own reservoirs.  For more information see the
Stockton Record of 23 July at:
www.recordnet.com/daily/news/articles/4new072302.html.

    6:04/09. NMFS PUBLISHES DRAFT HATCHERY ESA LISTING
POLICY:  On 24 July, the National Marine Fisheries Service (NMFS)
published its first draft of a new policy on how to treat hatchery fish
populations of salmon and steelhead in considering listings under the
Endangered Species Act (ESA).  The previous policy had to be rethought
in light of a federal District Court decision by Judge Michael Hogan in
the Alsea Valley Alliance case which tossed out the ESA listing of the
Oregon coast coho ESU ("evolutionarily significant unit," the genetic
conservation unit upon which salmonid listings are based) because some,
but not all, hatchery stocks in the Alsea Valley were afforded ESA
protection (see Sublegals 4:24/19; 4:20/08; 4:18/02; 4:11/02), a ruling
that was later stayed on an appeal still pending.  

     In its draft policy, NMFS took a middle ground between those who
want only wild fish to be considered in ESA listings and those, including
some property rights advocates, who are pushing for all hatchery fish to
be considered the legal equivalent of wild fish in order to invalidate ESA
listings because of huge hatchery production. NMFS proposed to list
hatchery populations also under the ESA (together with the wild stocks)
where they may be helpful in conserving the wild stocks, but to craft
different protection rules for each through the use of separate 4(d) Rules.
Separate 4(d) rules could allow selective harvest of hatchery stocks and
provide for different levels of protection.

      NMFS also proposes to assess hatchery practices as a gene
conservation tool, but also assessing any adverse effects on wild stocks
that hatcheries might also have, on a case-by-case basis. The proposed
policy would also allow NMFS to require specific hatchery reforms
when those reforms are necessary to avoid impacts on wild populations. 
NMFS will consider comments submitted by states, tribes and other
federal agencies until 16 August, then release a revised draft in
September for public comment.  To see the draft policy:
www.nwr.noaa.gov/HatcheryListingPolicy/HatcheryListingPolicy.html.

     6:04/10. GROUPS THREATEN SUIT OVER WASHINGTON
STATE HATCHERY IMPACTS ON WILD FISH:  On 27 June, two
Northwest regional fishery groups, Washington Trout and the Native
Fish Society, filed a 60-Day Notice to Sue with the Washington State
Department of Fish & Wildlife (WDFW). 

     The groups claim Washington State's state-run chinook hatcheries
throughout the Puget Sound are currently violating the federal
Endangered Species Act (ESA) by harming federally protected wild
Puget Sound chinook populations. The groups claim that ESA protected
chinook are harmed by hatchery practices in a variety of ways, including
through increased predation, competition, dilution of the genetic
integrity of wild fish gene pools through straying and inbreeding, and by
fish passage barriers.         

     The 18 facilities of the Washington State hatchery system are
vulnerable to criticism because of many past reports of problems at these
hatcheries and recent recommendations for reform from a
Congressionally-chartered independent scientific review panel, the
"Hatchery Scientific Review Group."  Those recommendations, which
were issued in a 19 February report, recommended 218 changes at the
WDFW hatcheries, and the closure of at least one of them, in order to
minimize adverse impacts on wild stocks (see Sublegals 5:08/07).  An
earlier 1997 report also contained a prioritized list of fish passage
barriers at WDFW hatcheries which also block ESA-protected fishes
stream passage, but that have still not been corrected. For more
information see: www.washingtontrout.org/hatchnoticepr.shtml.

     6:04/11. CORRECTIONS AND CLARIFICATIONS: The following
corrections have been brought by readers to the attention of Sublegals
staff:  

 *  In "New Study Links Delayed Mortality and Dam Stress" (Sublegals
5:26/10), in characterizing a study to ascertain the impact of dam
passage and delayed salmon mortality in the Columbia's Snake River,
that study was characterized as finding a "direct link" when the authors
of that paper stated "different types of evidence discussed here suggest
that the delayed mortality of Snake River salmon is related to the hydro
system," a conclusion that is far less categorical and more accurately
reflects the degree of scientific uncertainty still surrounding the issue. 
Other studies of the problem indicate contradictory or inconclusive
results, and research on the issue continues.  

  *  In the article on the problem with illegal harvest of Chilean seabass
(Patagonia toothfish) (Sublegals 5:26/10), it was stated: "Unlike U.S.
longliners in the North Pacific, for example, the toothfish fishery does
not use methods and devices to prevent the hooking of albatross and
other sea birds."  Actually, there has been considerable high quality
research on the seabird bycatch issue in the Southern Ocean and there
are now regulations in place to help prevent seabird bycatch in the legal
toothfish fishery. However, there is an illegal harvest that may be far
larger than the legal harvest and it is highly doubtful that the seabird
regulations imposed by CCAMLR are implemented on these illegal
vessels.  Also, it is incorrect to imply that the seabird bycatch problems
in the Alaska longline fishery have been finally solved.  Rather, U.S.
longliners are in the process of developing effective seabird bycatch
avoidance strategies, some of which are now required by regulations, but
only years of statistically rigorous observer data will reveal the
effectiveness of these methods and those used in other fisheries.  

*     In the last week's issue on the oyster industry  (6:03/07) scientist 
Bill
Kier's letter was sent 30 June 2000, not 2002.

     NEWS, COMMENTS, CORRECTIONS: Submit your news items,
comments or any corrections to Michelle Wallar, Editor at:
mw_ifr@pacbell.net or call the IFR/PCFFA office with the news and a
source at either: (415) 561-FISH (Southwest Office) or (541) 689-2000
(Northwest Office).
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[Fishlink] ~~>FISHLINK SUBLEGALS 7/26/02<~~

[Fishlink] >FISHLINK SUBLEGALS 7/26/02<