Scallop industry group argues:
* Discard mortality assumptions not based on empirical evidence
* SSC did not provide an ABC or DAS projections
* NMFS presentation to PDT was inaudible
* Mortality level estimates and actual landings don't add up
WASHINGTON (Saving Seafood) — September 24, 2013 — On Friday, September 20, the Fisheries Survival Fund (FSF), which represents the majority of the full-time Limited Access scallop fleet, wrote to Ernest Stockwell, Acting Chair of the New England Fishery Management Council (NEFMC), outlining their concerns and recommendations on rules and specifications for the scallop fishery for the 2014 fishing year. FSF particularly emphasized the "fundamental breakdown of the scientific process" ahead of the NEFMC's September 25 meeting on changes to the scallop Fishery Management Plan and the need to maintain a consistent supply of scallops to domestic and international markets. The main points of FSF's letter are outlined below:
– The NEMFC has not been given a scallop Acceptable Biological Catch (ABC) level from its Scientific and Statistical Committee, which lacked a quorum at its September 16 meeting and was thus unable to render a decision. The Council also lacks projections for the scallop fishery's 2014 allocations for days at sea and access area trips. FSF criticizes the process, noting, "the Council has nothing valid and of any management value to consider as it begins discussing annual catch specifications."
– FSF is highly critical of the work that the National Marine Fisheries Service (NMFS) has presented to the Council's Scallop Plan Development Team (PDT). NMFS has only given the PDT interim estimates for the ABC and the Annual Catch Limit (ACL). NMFS' presentation was given over a conference call with poor reception, making it "utterly impossible for the PDT and other listeners to understand what was being presented." NMFS also made changes to the scallop assessment model in a way that FSF states "lacks any transparency or critical review."
– FSF calls for the Council to develop a "bridging strategy" that would allow the scallop fishery to maintain a consistent level of catch until the 2015 fishing year. While the 2014 fishing year will likely see reduced catch levels for the second year in a row, estimates of scallop recruitment indicate that the population will likely increase enough to allow for larger catches in 2015.
– FSF believes that the Council needs to reexamine current assumptions about discard mortality. Currently, discard mortality takes into account estimates of scallops accidentally destroyed by scallop gear. FSF contends that, based on video survey data, there is no evidence that these discards exist. FSF also states that scallop mortality in general may be overestimated.
– In order to ensure that the catch level remains stable, FSF proposes allowing a greater level of access to areas that currently limit entries by scallop vessels, such as the Delmarva area. The organization also recommends that the Council complete the Essential Fish Habitat Amendment, which would potentially allow access to areas that have been off-limits to scallopers since 1994.
– FSF also raises concerns with the model used to estimate the scallop population. There is an observed difference between the mortality rate used in the scallop population models and recorded landings. Specifically, scallops are currently estimated to have a mortality level only slightly below the Overfishing Limit (OFL). But 2012 scallop landings were only 91 percent of the ABC level. This implies that the models being used in the assessment are overestimating fishing mortality.
– FSF notes that the "assumed discard" rate for the scallop fishery is growing. This contradicts the known discard rate, which is based on observer data, and the fact that the assumed discard rate is based off calculations made in the 1970s, when the fishery was much less efficient. FSF concludes, "incidental mortality levels are grossly overestimated."
Read the letter from the Fisheries Survival Fund here