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A Needs Assessment for Fisheries Observer Programs

The Marine Fish Conservation Network advocates for national policies to achieve healthy oceans and productive fisheries. The Network is the largest national coalition solely dedicated to promoting the long-term sustainability of marine fish. With almost 200 members—including environmental organizations, commercial and recreational fishing associations, aquariums, and marine science groups— the Network uses its distinct voice and the best available science to educate policymakers, the fishing industry, and the public about the need for sound conservation and better management practices. 600 Pennsylvania Avenue, SE · Suite 210 · Washington, DC 20003 telephone: 202.543.5509 · toll free: 866.823.8552 · fax: 202.543.5774 network@conservefish.org · www.conservefish.org The Marine Fish Conservation Network is supported by many individuals, businesses, and foundations. This report and our work in general is made possible by the generous support of The Pew Charitable Trusts, Curtis and Edith Munson Foundation, Ocean Foundation, Marisla Foundation, David and Lucile Packard Foundation, Walton Family Foundation, and Patagonia Inc. Credits: Lead author: Kenneth Stump, Marine Fish Conservation Network Policy Director Contributing Author: Rebekah Hamed Research Assistant: Cade London The authors gratefully acknowledge the technical advice of The Ocean Conservancy, Cape Cod Commercial Hook Fishermen’s Association, Association for Professional Observers, and Oceana. Photo Credits: Where indicated, photos are from the National Oceanic and Atmospheric Administration and National Marine Fisheries Service.

1.

A Needs Assessment for Fisheries Observer Programs

Meeting the Information Demands of 21st Century Fisheries:

Introduction

Until the end of the 20th century there were few limits on most ocean fisheries,1 but advances in fishing technology and growth in fishing capacity have necessitated the increased use of regulatory controls to address widespread overfishing and prevent fisheries from exceeding sustainable limits.2,3 In the U.S., successive reauthorizations of the Magnuson-Stevens Fishery Conservation and Management Act (MSA) since 1996 have mandated management actions to minimize bycatch and waste, place limits on allowable annual catch, establish rebuilding plans for overfished stocks, and limit fishing effort or access to fisheries.4 All of these management objectives require timely, accurate scientific information and effective monitoring of fisheries in order to make responsible management decisions, and that depends in significant part on the deployment of trained fisheries observers to quantify and characterize catches and bycatch at sea and provide biological data for compliance monitoring, scientific stock assessments, and other management needs.5,6 Multiple mandates for the conservation of fisheries, marine mammals and endangered species authorize the deployment of observers on fishing vessels and processors to provide reliable catch and bycatch data for the management of species under the jurisdiction of the National Oceanographic and Atmospheric Agency (NOAA) and its sub-agency, the National Marine Fisheries Service (NMFS). The MSA’s mandates for bycatch minimization and annual catch limits (ACLs) require reliable estimates of total fishing mortality and species composition of the catch that include economic or regulatory discards at sea.7 In addition, the growing use of “catch share” management programs for individual quota share holders increases the demand for accurate catch data in order to ensure that individual vessels or fishery sectors stay within their annual limits. Implementing these management objectives will increase the need for fishery

Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs 3

catch data provided by at-sea and dockside observers, and place greater information demands on the monitoring and enforcement capabilities of fishery managers. Our findings indicate that current observer program funding and coverage levels are inadequate in most U.S. fisheries. Current funding supports at-sea observer programs in more than 40 broadly defined fisheries categories nationwide,8 only 23 of which were considered to have adequate levels of observer coverage in 2009.9 The total number of fisheries evaluated for observer coverage by the agency has varied from 84 broadly defined “fisheries” in a national bycatch report in 200410 to 90 in more recent unpublished updates.11 In other words, NMFS has been able to deploy observers in about half of the fisheries that the agency has assessed for coverage to monitor bycatch, and is only able to provide adequate coverage in one-quarter of those fisheries at present. In some cases, however, recent increases in funding have enabled NMFS to expand coverage in targeted fisheries.

Program goals for observer coverage have dominated the program historically, but the majority of fisheries have little or no observer monitoring of bycatch. Courtesy NOAA/NMFS.

4 Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs

NMFS has been deploying observers on fishing vessels for nearly 40 years. At-sea catch sampling programs were first established in the large groundfish fisheries in the Northeast and Southeast 59 North Pacific and later expanded to the tuna fisheries of the Eastern Tropical Pacific to document HMS 52 tuna-dolphin interactions. In 2003, NMFS released an updated National Bycatch Strategy to Northeast 49 monitor and reduce bycatch within the Nation’s fisheries.12 A central pillar of that strategy is Western Pacific 20 the deployment of at-sea fishery observers to collect reliable information about catch, bycatch West Coast 15 and discards. Today NMFS deploys more than 700 observers annually to collect biological and Alaska 12 economic data for more than 40 fisheries nationwide.13 All federal fisheries observer programs National 28 are authorized by one or more of several legal mandates (see inset, page 6). The NMFS Office of Science and Technology (OST) coordinates observer programs through the National Observer Program (NOP). The NOP’s mission is to provide a formalized mechanism for NMFS to address observer program issues of national importance and ensure that regional observer programs are fully supported.14 Fig. 1 - U.S. Fishery Catch Discarded At Sea as a Percentage of Total Landings (2002)
100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% Southeast Highly Migratory Species Northeast

2.

NMFS Observer Programs: An Overview

59%

52%

49% 28% 20% Western Pacific 15% West Coast 12% National Alaska 

According to Harrington et al. (2005), U.S. fishery discards at sea averaged 28% as a percentage of landings in 2002, meaning that more than 1 in every 4 fish caught was discarded at sea, but in some regions as much as 50-60% of the catch was discarded. In all, this study estimated a total of 1 million tons of fish discarded compared to the 3.7 million tons of fish landed that year.15

Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs 5

Legal Authority: Mandates for observers under the MSA, MMPA, and ESA
Magnuson Stevens Fishery Conservation and Management Act (MSA, 16 U.S.C. § 1801 et seq.) The MSA includes multiple mandates for minimizing and accounting for bycatch,16 establishing annual catch limits and accountability measures that prevent overfishing,17 rebuilding overfished stocks as quickly as possible,18 protecting vulnerable ocean habitat,19 and granting limited access privileges to fisheries20 – all of which require reliable information about the quantity and composition of the catch as well as biological data for scientific assessment. The MSA provides the authority to require observer coverage as part of a fishery management plan (FMP),21 and authorizes the establishment of industry user fees to recover the costs associated with observers in several provisions.22 Marine Mammal Protection Act (MMPA, 16 U.S.C. § 1361 et seq.) The MMPA prohibits the “take” of marine mammals in U.S. waters with limited exceptions, and establishes the goal of reducing incidental mortality or serious injury of marine mammals in commercial fishing operations to insignificant levels approaching zero.23 Each year NMFS reviews and revises its List of Fisheries, which classifies U.S. commercial fisheries into one of three categories based on the level of serious injury and mortality of marine mammals that occurs incidental to each fishery.24 The MMPA authorizes placing observers on board vessels engaged in commercial fishing operations that incidentally take marine mammals.25 Fisheries that have frequent (Category I) or occasional (Category II) takes of marine mammals are required to carry an observer if so requested by NMFS or its contracted or certified service provider, while fisheries with only rare or no known incidental takes (Category III) may be asked to carry an observer on a voluntary basis. The Endangered Species Act (ESA, 16 U.S.C. § 1531 et seq.) NMFS has jurisdiction over nearly 70 ESAlisted species of fish, sea turtles, marine mammals, as well as several invertebrates (elkhorn and staghorn coral, white abalone) and one marine plant species (Johnson’s seagrass). Although there are no direct ESA requirements to monitor fisheries using observers, observer programs are often required as a Term and Condition of authorizing federal fisheries to incidentally take threatened or endangered species, as part of Section 7 consultations.26 NMFS has identified 19 fisheries as a high priority for observer coverage in the agency’s 2010 Annual Determination of commercial fisheries which would be required to take observers if requested by NMFS based on their interactions with ESA-listed sea turtles.27

6 Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs

Regional Programs
NMFS oversees the operation of observer programs in each region. In a majority of regions, NMFS scientists (in coordination with observer program staff) determine sampling protocols and coverage levels for each fishery that will provide statistically robust estimates. However, the largest program in the nation (the North Pacific Groundfish Observers Program in Alaska) establishes its coverage levels through regulations that have not changed in 20 years. NMFS provides training to all new and returning observers in species identification, sampling methods, conflict resolution, and safety. NMFS staff oversee the administration of the programs, debriefing observers after each fishing trip and reviewing the quality of the data before it is used in the management of the fishery.

Alaska Center, Seattle, WA Northwest Center, Seattle, WA

North Pacific groundfish

Northeast Center, Falmouth, MA
New England (NE) groundfish, NE & Mid- Atlantic gillnet and trawl fisheries, Atlantic scallop dredge

West Coast groundfish/at-sea hake

Southwest Region, Long Beach, CA Pacific Islands Region, Honolulu, HI

National Observer Program Silver Spring, MD
National coordination

Pelagic longline, drift gillnet

Pelagic and deep-set longline

Southeast Center, Panama City, FL

Shark gillnet, bottom longline

Alaska Region, Juneau, AK
Salmon set gillnet

Southeast Center, Galveston, TX

Southeast Center, Miami, FL
Pelagic longline

Reef fish, shrimp trawl

Fishery observer programs are administered by each of the six NMFS regions
(adapted from NMFS 2009)

Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs 7

Disparities in coverage between regions and fisheries are linked to availability of funds
Current funding levels support at-sea observer programs in more than 40 “fisheries” nationwide,28 as defined by NMFS in the national bycatch report of 2004.29 But observer coverage varies widely by region and fishery, from levels of 30-100% in most Alaska groundfish fisheries (except for vessels under 60 feet in length) and 17-30% in the Pacific Coast groundfish fisheries to as little as 1-3% in the majority of fisheries along the Atlantic and Gulf of Mexico coasts.30 In some cases, however, recent increases in funding have enabled NMFS to expand coverage in targeted fisheries. For instance, the Northeast Fishery Observer Program has a 2010 target coverage goal of 30% in the limited-access sector fisheries and 8% in the non-sector fisheries of New England. Similarly, the Southeast Region has increased its target observer coverage level in the bottom longline component of the reef fish fishery to 7% in 2010.31 To some extent, regional disparities in coverage reflect differences in history, fisheries and observer program goals and objectives,32 but the actual level of coverage is often dictated largely by the availability of funds. Inadequate funding in the Northeast Region forced NMFS to scale back observer days at sea in 2009 and fall far short of target coverage levels needed to achieve statistically adequate confidence in estimates of bycatch and discards at sea.33 Commercial fisheries in which industry funding pays a significant share of the cost of deploying observers have consistently higher observer coverage levels as a percentage of fishing trips, but they are few in number.34

3.

Observer Program Funding: Assessing Adequacy, Need and Cost Fig. 2 - Enacted Appropriations for Regional Observer
Enacted appropriations for regional observer program budget lines, 2000-2010 ($ milllion) $50 $45 $40 $35 $30 $25 $20 $15 $10 $5 $0 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 National Observer Program West Coast South Atlantic/Gulf Shrimp Pacific Observer Program N. Pacific Marine Resources Hawaiian Longline East Coast Atlantic Coast New England Groundfish

Programs, 2000-2010 ($ millions)

Limited federal funding for regional observer programs was available before 2000. Congressional appropriations for NMFS observer programs increased slowly in the early to mid-2000s, and saw a significant increase in the FY 2010 President’s request (Figure 2). The National Observer Program began receiving appropriations in 2000. Most of the money appropriated for the NOP is

Enacted appropriations by year ($ milllion)

8 Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer ProgramsPacific Observer

Total Enacted Appropriations (in millons of Groundfish Fiscal Years New England dollars) Coast East Coast Hawaiian Longline N. Pacific Marine Resources Atlantic Program South Atlantic/Gulf S West 1999 2.45 2000 0 0 0.324 0 1.733 0.393 0 9.453 2001 0 3.342 0.349 1.197 1.871 0.424 13.998 2002 0 3.35 0.35 2.982 1.875 0.65 0

distributed to the eight regional observer programs. Most regional programs are funded almost entirely with federal appropriations and NMFS contracts directly with private observer provider companies to hire, equip and deploy observers. In the Alaska Region, however, industry funding accounts for nearly three-quarters of the total program cost.35 Other fisheries with significant industry funding of observers are the at-sea sector of the West Coast Pacific hake fishery and the Atlantic sea scallop fishery. The Omnibus Appropriations Act of 2009 funded NMFS observer programs at the President’s requested FY 2009 level of $32.7 million and the FY 2010 appropriations increased that funding level to $41 million, spread across eight line items (Table 1). All regions have at least one dedicated budget line supporting observer program activities except the Southwest Region, which has never had a dedicated budget line. Similarly, the Alaska Marine Mammal Observer Program (covering statewaters salmon fisheries) has no dedicated Congressional budget line. In addition to funding under the Magnuson-Stevens Act (MSA), observer programs may receive funding from programs under the American Fisheries Act (AFA), Endangered Species Act (ESA) and Marine Mammal Protection Act (MMPA).36 Observer programs may be funded by more than one budget line, and many observer programs are funded through a combination of funding sources.37 Table 1. – Observer Funding in Omnibus Appropriations Acts of 2009 and 20101 Observers/Training Atlantic Coast Observers East Coast Observers Hawaii Longline Observer Program N. Pacific Marine Resources Observers/N. Pacific Observer Program NE Groundfish Court-Ordered Observers National Observer Program S. Atlantic/Gulf Shrimp Observers West Coast Observers Total
1

FY 2009 Million $ 3.423 0.353 4.046 5.609 8.634 3.785 1.804 5.026 32.680

FY 2010 Million $ 3.484 0.354 7.100 5.732 8.695 8.823 1.833 5.053 41.074

Funds appropriated for the “Reducing Bycatch” budget line and other federal funding may be used to deploy observers but are not included in the regional observers budget lines and totals.

In 2008, the most recent year for which published data exist, appropriations from Congress accounted for approximately three-quarters of the direct funding for U.S. fisheries observer programs (Table 2). In addition, the majority of the $2.738 million appropriated for reducing bycatch in the NOAA FY 2008 budget was used to deploy at-sea fisheries observers to monitor the levels of bycatch of sea turtles, marine mammals, seabirds, and non-target fish.38 The remainder of the funding came from the fishing industry ($15.6 million in 2008), and most of that came from the Alaska groundfish industry, which pays the salaries of observers while at sea, as well as travel expenses and insurance.

Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs 9

Table 2. – 2008 NMFS Observer Program funding and coverage summary1
Region Funding (Million $) Observer DAS

Northeast region Southeast region Southwest region Northwest region Pacific Islands Alaska region NOP national Total all sources Total federal funding2
1

14.060 6.538 0.619 5.941 5.724 18.772 1.456 53.110 37.442

13,208 4,593 329 4,596 9,739 39,000 NA 71,465  

NMFS National Observer Program Annual Report for FY 2008. 2 Includes $1.693 million from “Reducing Bycatch” budget line that is dedicated to observer deployment and $4.257 million of other federal funding.

Observer Coverage Adequacy and Need: A Baseline for Evaluation
In 2004, NMFS published its first national bycatch report in which 84 broadly defined fisheries were assessed for observer coverage, of which only 21 (25%) were identified as having “adequate” or “near-adequate” coverage levels.39 Thirty-two (38%) fisheries were considered to be at “baseline” or pilot program levels, with observer coverage ranging from 0.5% to 2%. The remainder (37%) had no observer programs or coverage.40 More recent unpublished information from NMFS in 2009 puts the number of fisheries with adequate or near adequate coverage at 24, and those with minimal baseline or pilot-level coverage at 20, out of a total of approximately 90 fisheries that we identified using NMFS’s broadly defined list of “fisheries.”41 In short, more than half (46 fisheries, 51%) assessed by NMFS have no observer coverage and nearly three-quarters (73%) have negligible (i.e., 0.5% to 2%) or no coverage at present (Figure 3). Only one-quarter of fisheries assessed for bycatch are considered to have adequate or near-adequate coverage today.

Credit NOAA/NMFS

10 Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs

Fig. 3 - Observer Coverage Levels by Fishery and Region, 2009 (Based on Fisheries Evaluated by NMFS in 2004)
100% 3 2 75% 5

1 24 3 6 9 1

1 50% 30 25% 3 1 9 4 2 0%
t t t es as es ka hw he as w th Al

20

Adequate/Near-Adequate Baseline/Pilot None

6 46

3

1
st nd ea io A ll R eg ns s ci Pa fic Is la

ut

ut

So

So

or

Our review indicates that the Southeast region has the greatest number of fisheries that need observers and the lowest levels of observer coverage overall, followed by the Pacific Islands region. The Southwest region also has low levels of coverage and very limited funding although it has substantially fewer fisheries. The Northeast region has minimal pilot-level coverage (3% or less) in many of its Mid-Atlantic fisheries. Overall, more than half (51%) of the fisheries that we identified have no observer coverage and nearly three-quarters (73%) have little or no coverage at present.

Funding needs are linked to observer coverage requirements, but there is no single recommended observer coverage level that can be applied to every fishery – the level of coverage needed will depend on the purpose for which the observer data is being used, the size of the fishery, distribution of catch and bycatch, and spatial stratification of the fishery.42 In some cases, 100% observer coverage may be necessary and appropriate – for example, to monitor fishery incidental catch of a highly endangered species, or to monitor compliance with individual catch shares in a Limited Access Privilege (LAP) program. For bycatch and discard estimation under the New England Standardized Bycatch Reporting Methodology, NMFS scientists calculated the level of coverage needed to achieve estimates of bycatch with a 30% margin of error for fishing gears and species groups in the Northeast region.43 Babcock and Pikitch (2003) suggested that coverage levels of at least 20% for common species, and 50% for rare species, would give reasonably good estimates of bycatch.44 Beerkircher et al. (2009) concluded that 40% observer coverage in the Gulf of Mexico pelagic longline fishery would provide estimates of bluefin tuna bycatch with the desired level of precision.45

Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs 11

N

N

or

th

Defining “Fishery” – A Primer
Both the MSA (16 U.S.C. § 1802(13)) and MMPA (16 U.S.C. § 1362(16)) define “fishery” broadly as one or more stocks of fish which can be treated as a unit for purposes of conservation and management based on geographical, scientific, technical, recreational, and economic characteristics, but estimates of the number of U.S. fisheries vary depending on the criteria used to define a fishery. The annual MMPA List of Fisheries for 2010 identified nearly 270 fisheries, but the LOF includes aquaculture pens and lumps some fisheries into a broad gear type category, such as “Northeast bottom trawl,” which encompasses numerous speciesspecific target fisheries. In the 2004 national bycatch evaluation report, NMFS identified 84 “fisheries” nationwide, but the agency’s broad definition of “fishery” included many individually managed fisheries under a single regional observer program umbrella, such as the North Pacific groundfish “fishery,” which has many directed fisheries (both single species and stock complexes) with specified catch limits and other management regulations within the groundfish “fishery” as a whole. This report defines a fishery as an actively managed target fishery in a fishery management plan (FMP) or annual catch specifications document subject to specified catch limits and/or other management regulations. Based on those criteria, more than 350 marine fisheries qualify – this list includes the salmon fisheries of the West Coast and Alaska as well as the fisheries managed by the Atlantic States Marine Fisheries Commission but does not distinguish commercial from recreational fisheries. To determine how many have

observer coverage, we cross-referenced lists of fisheries compiled in the National Observer Program Annual Report (2008), the national bycatch report (2004), the annual MMPA and ESA lists of fisheries, as well as regional FMPs and other management documents.

All told, based on our comparison of actively managed target fisheries to the list of fisheries covered by observer programs in the 2008 National Observer Program annual report, we estimate that nearly 200 fisheries were not covered by observers or had negligible (<1%) coverage. For many of the remaining ~150 “fisheries” that fall within NMFS observer program categories, the number of observed days at sea (DAS) is a small fraction of the total DAS in the fishery – generally 3% or less. Overall, more than half of the fisheries that we identified have no observer coverage and nearly three-quarters have little or no coverage at present.

12 Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs

Although individual fisheries will have different observer coverage requirements, at present these coverage requirements are not clearly quantified for most fisheries in most regions. Target observer coverage levels have historically been based on bycatch or discard monitoring goals, and rarely on other management goals. Target coverage levels generally have not reflected the demands for accurate and timely data on total catch created by the new ACL requirements or by individual vessel or sector quotas in a “catch share” program. Based on our analysis, using a more common management definition of “fishery,” more than half of the nation’s approximately 350 fisheries have no observer coverage at all (See inset, page 12). Of those that do, many do not have adequate coverage to meet specific management objectives for catch and bycatch accounting as well as compliance monitoring and scientific information for management. A systematic analysis of catch monitoring needs for each fishery is necessary to determine the coverage levels required to achieve management objectives. Target observer coverage requirements should be established for each fishery and observer deployment prioritized for fisheries that lack adequate observer coverage.

Expanding Observer Coverage: How Much Will It Cost?
Based on internal budget recommendations prepared by NMFS in 2003, the agency projected the need for an additional $100 million above the FY 2003 funding level by 2009 to meet the NMFS bycatch monitoring objectives.46 Recent Congressional appropriations have ranged from $32-41 million for NMFS observer programs – far short of the projected need. Although determinations of adequate observer coverage and costs will vary by fishery and region, our analysis indicates that observer program funding will need to increase significantly in future years to keep pace with the demand for timely, high-quality fisheries data. To estimate how much more funding is needed, we used an approximate average cost estimate of $1,200 per observer day at sea47 and projected the cost of achieving higher levels of coverage in fisheries that currently require at-sea monitoring. Observer coverage targets of 10%, 20%, 30% and 50% were selected for purposes of illustration. Based on this analysis (Table 3, page 14), it could cost approximately an additional $70 million above current funding to bring all currently observed fisheries up to a level of at least 20% coverage.48 In addition, it could cost at least $15.5 million to bring fisheries identified by NOAA as having no coverage or minimal “baseline” coverage in the 2004 bycatch report up to the next level of coverage, generally 0.5% to 2% coverage.46 This cost estimate does not account for the levels of observer coverage needed in fisheries to manage catch share programs or annual catch limit (ACL) requirements.

Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs 13

Table 3. – Summary of sea days observed and total funding by region for 2008, and projected costs of scaling up observer coverage(1)
2008 actual sea days observed2 13,208 4,593 329 4,596 9,739 39,000 NA 71,465 2008 total funding amount3
(in $ millions)

Additional cost — scaling up to 10%
(in $ millions)

Region Northeast Southeast Southwest Northwest Pacific Islands Alaska National Total
1

20%
(in $ millions)

30%
(in $ millions)

50%
(in $ millions)

14.1 6.5 0.6 5.9 5.7 18.8 1.5 53.1

7.3 - 9.5 12.2 NA NA NA NA NA 19.5 - 21.7

30.5 - 34.7 28.2 0.1 0.7 - 13.7 0.4 NA NA 59.9 - 77.2

53.7 - 60.1 44.7 0.3 - 0.4 1.5 - 23.5 4.8 NA NA 105 - 133.3

100 - 110.6 77.8 0.7 - 0.8 4.7 - 40.7 13.5 NA NA 196.8 - 243.5

Based on National Observer Program report for FY 2008. Totals may not sum due to rounding. Projected costs calculated using an averaged total cost of $1,200 per observed day at sea. These costs include administration, training, costs associated with deployment (including travel, insurance and observer wages), and data management. The total number of days in each fishery is not currently published by NMFS. We calculated the number of days for each fishery using the number of sea days observed and the percentage of days at sea covered. The percentage coverage is expressed as a range in a number of fisheries, resulting in estimates of additional cost that are also expressed as a range. Funding includes federal appropriations and any industry funding.

2

3

While there is a need to ensure that fishery monitoring requirements are met in all fisheries, limitations in funding may require NMFS to prioritize fisheries for expanded observer coverage based on a needs assessment. In regions and fisheries that have had persistently low observer coverage rates, relatively small increases in funding for targeted fisheries could result in significantly higher coverage and improvements in the quality and precision of information for management. The Gulf of Mexico reef fish fishery observer program, for example, covered only about 1% of fishing trips in 2008, but coverage could be increased 10-fold with an investment of less than $5 million annually.50 While being the best method for monitoring bycatch, observer programs can also be costly. Cost reductions may come from internal program efficiencies or by using lower cost monitoring methods where available and appropriate (see inset, page 15). A Department of Commerce Inspector-General’s review of the NMFS observer program in 2004 suggested that it may be possible to decrease observer training costs through reducing staff turnover, standardizing training materials and consolidating training centers.51 Fisheries with higher levels of coverage also tend to have a lower cost per day observed, which indicates that it is possible to achieve economies of scale.52

14 Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs

Alternatives to Observers: Electronic Monitoring
Electronic monitoring (EM) shows promise as a cost-effective way of supplementing monitoring by at-sea observers. These systems can be deployed on fishing vessels to monitor fishing location, catch, catch handling, fishing methods, and protected species interactions. Vessel monitoring systems (VMS) are already widely used to transmit information about vessel position during fishing trips, providing a cost-effective way to monitor compliance with seasonal and area closures. Other forms of EM, particularly video-based monitoring, have been touted as a cheaper alternative to at-sea observers but their application is limited thus far. Video monitoring, in conjunction with port sampling of the catch, can be used to monitor compliance

in fisheries where vessels are required to retain all catch at sea. One example of the use of video monitoring in conjunction with port sampling is the shore-based West Coast hake electronic monitoring program, which is estimated to cost one-quarter or less of deploying at-sea observers.54 Not everyone agrees with these cost estimates. In addition, the cost structure for EM is different than traditional observer programs involving relatively high up-front equipment costs but lower daily operating costs. The use of electronic monitoring technologies warrants more attention, but there are a number of considerations that could limit its expansion in the short-term. While EM can serve a similar role to that of an at-sea observer, trained observers cannot be replaced by EM for tasks such as biological sampling and, in many cases, species identification.

4.

Improving Recreational Fisheries Data Collection and Data Quality: MRIP and Beyond

Marine recreational fisheries contribute an estimated $80 billion annually to the U.S. economy, including expenses related to travel, food, lodging, purchase of gear, and boat rentals.55 While recreational fisheries represent a small percentage of total U.S. marine fishery landings annually, saltwater anglers are a significant source of fishing mortality for many marine species and better assessment of that mortality is required for successful management of those species.56 Despite their often sizeable economic and biological impacts, however, much less data are collected from recreational fisheries than commercial fisheries.57

Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs 15

Existing sources of funding for recreational fisheries data collection are inadequate. The 1984 Wallop-Breaux Amendment to the Sport Fish Restoration Act of 1950 established an Aquatic Resources Trust Fund that distributes as much as $250-400 million annually to the states from an excise tax on fishing tackle and motorboat fuel — but data collection is not one of the objectives of the Fund. The Marine Recreational Fisheries Statistics Survey (MRFSS) is the primary recreational fishery data collection system for federally managed fisheries, but the program has long been criticized as inadequate. In 2006, the National Research Council (NRC) issued a report calling for a major overhaul of the MRFSS program to address data quality issues.58 The MSA was amended in 2006 to (1) implement a regionally based registry program for recreational fishermen in each of the 8 fishery management regions, and (2) improve the quality and accuracy of information generated by the Marine Recreational Fishery Statistics Survey (MRFSS).59 The revamped program, known as the Marine Recreational Information Program (MRIP), establishes a regionally based saltwater registry and data collection program for recreational fishermen with the goal of achieving acceptable accuracy and usefulness of MRFSS data for each individual fishery.60 The Omnibus Appropriations Act of 2010 includes $9 million in total funding for MRIP, well short of the estimated $20 million per year needed to fully implement the MRIP and expand the National Registry to state and federal waters.61 However, the MRIP is not designed with the intent of providing timely in-season data needed to prevent recreational fisheries from exceeding annual catch limits. While the deployment of observers on board individual recreational fishing vessels is not generally feasible, dockside sampling of catches could be expanded. In addition, the expanded use of VMS, electronic logbooks and other electronic technologies may provide cost-effective ways to obtain more real-time recreational data for management and stock assessments. New or additional funding and changes in MRIP will be needed to establish such an information collection system. The amendments to the MSA of 2006 (16 U.S.C. § 1891b) authorized the establishment of a new Fisheries Conservation and Management Fund which could be used for this purpose.

5.

Observer Service Delivery Models: Getting Program Design Right

Most U.S. observer programs currently operate in a system in which NMFS, using federal dollars, contracts directly with observer providers to recruit and deploy observers as well as cover insurance and other costs associated with data collection. The North Pacific Groundfish Observer Program (NPGOP) and the At-Sea Pacific hake fishery off the West Coast use a different approach in which the fishing industry makes direct payments to observer provider companies and provider companies are under no contractual obligation to NMFS. The least

16 Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs

common approach is for NMFS to contract directly with an observer provider, with funds to pay for observer days collected from industry. This has been the case for the Atlantic sea scallop fishery, where vessels assigned an observer are allowed to increase the catch amount to offset the cost of deploying the observer. The preferred approach is for NMFS, as the client, to contract directly with the observer service provider. That way NMFS is able to set out performance criteria and directly oversee contractor performance, rather than through the passing of regulations in a lengthy and difficult FMP amendment process at the regional fishery management councils. In addition, a system of industry fees will be critical to achieving adequate levels of coverage in many cases. Existing legal mandates in the MSA authorize the establishment of a system of industry fees to pay the cost of deploying observers and other forms of fisheries monitoring, under certain circumstances. However, they have not been implemented in any region at present (see inset).

MSA authority to collect user fees for observer costs
MSA § 304(d) (16 U.S.C. § 1854(d)) authorizes the collection of fees (not to exceed 3% of the ex-vessel value of fish harvested) to recover the direct costs of management, data collection and enforcement of fisheries in LAP (“catch share”) programs. MSA § 313 (16 U.S.C. § 1862) authorizes the establishment of a fisheries research plan for any fishery under the North Pacific Fishery Management Council’s jurisdiction which requires observers to be stationed on fishing vessels and fish processors for the purpose of collecting data necessary for the conservation, management, and scientific understanding of any fisheries under the Council’s jurisdiction, as well as system of fees to pay for the cost of implementing the plan. Sec. 208 of the MSA reauthorization of 2006 (16 U.S.C. § 1891b) established a new Fisheries Conservation and Management Fund whose purposes are, among other things, to improve fishery harvest data collection, including expanding the use of electronic catch reporting programs and satellite tracking systems such as VMS on small vessels; and improving data collection under the Marine Recreational Fishery Statistics Survey (MRFSS).

Observer Program Design Issues: the Alaska and Northeast Regions
Program design has become a focal concern in some regions, most recently in the Alaska Region and the Northeast Region. The issues raised in each region highlight the need for consistency with national standards in which NMFS has direct oversight of the performance of observer provider companies through contractual agreements and sciencebased sampling protocols are established to achieve statistically reliable data. NMFS, working with the regional fishery management councils, should establish target observer coverage levels for each fishery and develop options for implementing an equitable system of industry fees to ensure that funding is adequate to achieve target coverage levels.

Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs 17

Restructuring the North Pacific Groundfish Observer Program
The North Pacific Groundfish Observer Program (NPGOP) is the largest fishery observer program in the country, and is unique in that industry funding accounts for nearly three-quarters of total funding.62 Under the current NPGOP, observer coverage levels are established by regulation, with 30% coverage of fishing trips for vessels >59 feet in length and 100% coverage for vessels >124 feet in length. NMFS receives federal appropriations to pay for the overall administration of the program, including the training and debriefing of observers and the management of the data. The fishing industry is responsible for making arrangements with one of the certified observer service providers for placement of NMFS-certified observers and for paying the contractors for direct observer costs. Although the NPGOP provides wider coverage than any other program in the nation, longstanding problems in the structure and delivery of the program disadvantage owners of smaller vessels (who pay a higher percentage of their earnings on observer costs) and could lead to biased data and conflicts of interest.63 Concerns about data quality arising from this model prompted NMFS to contract an independent review of the NPGOP by MRAG Americas in 2000, which concluded that the service delivery model of the NPGOP should be avoided and recommended that the program be restructured.64 A U.S. Department of Commerce Inspector General’s report in 2004 reached similar conclusions, finding that NMFS lacks control over deployment of observers in the “30% fleet,” that potential biases in vessel selection could jeopardize the statistical reliability of catch and bycatch data, and that the program lacks an adequate performance monitoring and reporting process of observer provider companies.65 The North Pacific Fishery Management Council and NMFS are currently proposing to restructure the program in accordance with the objectives of the research plan outlined in MSA § 313 (16 U.S.C. § 1862) (see inset, p. 17). The main differences from the current program model would include: (1) a shift from a regulatory to science-based observer deployment, based on a determination

18 Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs

of statistical reliability by NMFS; (2) NMFS would be the entity responsible for contracting for observer coverage rather than the vessel owner; (3) the program would establish an industry fee based on ex-vessel value of unprocessed fish, which is more equitable to smaller vessels; (4) all funds collected would be used to pay for the direct costs of the deployment of observers; and (5) all vessels in the groundfish fleet would pay into the fund. Importantly, the proceeds from the industry fee would not replace the federal contribution through the NPGOP: under a restructuring plan, NMFS would continue to assume its current responsibilities, which are essential to data quality control.

The Proposed Northeast At-Sea Monitoring and Dockside Program
The Northeast Region is proposing a new Northeast Fisheries At-Sea and Dockside Monitoring Program as part of the implementation of Amendment 16 to the Northeast Multispecies FMP. The plan would make industry responsible for meeting its monitoring needs and, presumably, contracting directly with an observer service provider. The plan also includes the potential use of at-sea monitors with lower eligibility requirements and less training than NMFS-certified fisheries observers. While there could be cost savings from reduced training and data collection, this could be offset by poorer quality data. Past use of inadequately trained fishery monitors has generally not been a success.66 The proposed Northeast At-Sea and Dockside Monitoring program design is similar to the flawed North Pacific groundfish observer program in at least two important ways. First, the fishing industry would be responsible for making arrangements with thirdparty observer service providers and for paying the contractors for direct observer costs related to deployment at sea – an arrangement that has limited NMFS’s ability to set performance standards for companies in the North Pacific. Second, at-sea monitoring levels do not appear to be based on any statistical protocol and dockside monitoring of landed catches would be capped by regulation at only 20% of fishing trips after 2010. The problems with the proposed design of the Northeast monitoring plan underscore the need for national program standards that are consistent among regions and provide performancebased criteria for achieving the goals and objectives of management for each fishery.

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6.

Summary Findings and Recommendations

Sustainable fisheries management in the 21st century requires timely, reliable fisheries data and effective monitoring of fisheries in order to make informed, responsible decisions. The deployment of at-sea fishery observers is a central pillar of the National Bycatch Strategy, and the 2006 amendments to the MSA added new requirements for annual catch limits (ACLs) and authorized the expanded use of limited access privilege (LAP) programs, popularly known as “catch shares,” all of which will increase the need for fisheries information provided by at-sea and dockside observers.

Key Findings
Reliable fisheries information provided by trained fishery observers is essential to manage bycatch, develop and update stock assessments, implement annual catch limits (ACLs) and monitor “catch share” programs. While vessel selfreporting is commonly required, the reliability of self-reported information is uncertain. Electronic monitoring (EM) technologies can supplement observers but are unlikely to substitute completely for observers. Observers are the only independent source for some types of fisheries information, such as species composition of bycatch, discards at sea, and interactions with other marine species.67 More than half of all U.S. fisheries assessed for observer coverage by NMFS have no observer coverage at all, and nearly three-quarters have minimal pilotlevel coverage or no coverage. Barely one-quarter of fisheries assessed for bycatch in 2004 have adequate or near-adequate coverage today. A majority (51%) of U.S. fisheries have not even established pilot-program coverage levels to collect baseline information so that statistically robust sampling plans can be developed, and nearly three-quarters (73%) have little or no coverage at present. Although individual fisheries will have different observer coverage requirements, at present these requirements are not clearly quantified for most fisheries in most regions. Although many regions currently lack the data-collection and monitoring infrastructure to account adequately for catch and bycatch, many also lack specific target coverage levels and have not conducted systematic analysis of catch monitoring needs to determine the coverage levels needed to achieve management objectives.

20 Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs

Key Findings (cont.)
A combination of increased federal funding and new sources of industry funding will be needed to meet observer needs in the coming years. Our analysis shows that program funding will need to increase significantly in future years to keep pace with the demand for high-quality fishery data. Direct federal funding will be necessary to oversee program administration and ensure data quality, but industry funding of the costs of deploying observers, including travel costs, days at sea and insurance, is also necessary if significantly higher coverage levels are to be achieved. Relatively small increases in funding for expanded observer coverage in targeted regions and fisheries with very low levels of observer coverage could produce large gains in observer coverage and data quality. Even limited increases in funding could benefit regions with low levels of observer coverage and large numbers of fisheries, such as the Southeast and Mid-Atlantic regions. The Gulf of Mexico reef fish fishery observer program, for example, covered only 1% of fishing trips in 2008, but coverage could be increased 10-fold with an investment of less than $5 million annually. NMFS needs to have direct oversight of regional observer programs and contract directly with observer service providers in order to ensure that a high standard of data quality and observer conditions are maintained. External and internal reviews of NMFS observer programs have highlighted issues with vessel selection and bias, retention of experienced observers, and disproportionate cost issues among various sectors of fishing fleets. Improved agency oversight of observer provider companies through performance-based contractual agreements will enable NMFS to address these concerns directly, rather than through the passing of regulations.

Recommendation #1:
Establish target observer coverage requirements for each fishery and prioritize observer deployment for fisheries that lack adequate observer coverage.
NMFS should produce an updated list of fisheries identifying those with adequate observer coverage and a priority list of fisheries in need of observer coverage and other forms of fisheries monitoring, including estimates of the resources required for expanded coverage. 

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All eight regional fishery management councils should work with NMFS to establish target observer coverage goals adequate to achieve management objectives for each federally managed fishery, and develop plans with specific timelines for achieving those goals. NMFS should work with state agencies to establish target coverage levels for state fisheries that interact with protected species (marine mammals and ESA-listed species).

Recommendation #2:
Increase federal funding to support expanded observer coverage, ensure data quality, and improve national coordination.
Congress should significantly increase federal funding for the NMFS Observer Programs from current levels of $41 million in FY 2010 to at least $60 million in FY 2011 in order to support the growing demand for increased levels of observer coverage in FY 2011. Increases in federal funding will be needed beyond 2011 to keep pace with the demand for data and provide overall administration of programs in future years.68 Our findings indicate that it could cost approximately an additional $70 million above current funding to bring all currently observed fisheries up to a level of at least 20% coverage. Additional funding would be required to extend observer coverage to fisheries which are not currently observed.

Recommendation #3: Identify appropriate industry funding mechanisms to cover the direct cost of deploying observers and other monitoring systems.
All eight regional fishery management councils should work with NMFS to establish equitable industry-funded mechanisms to support expanded observer coverage, such as a user fee based on the ex-vessel value of fish landed. The MSA authorizes the establishment of fees to pay for the cost of deploying observers and other monitoring systems to collect data in several provisions relating to limited access privilege (LAP) programs, North Pacific Research Plan, and a Fisheries Conservation and Management Fund.69 However, a specific amendment to the MSA may be needed to fully implement industry funded observer programs.

22 Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs

Recommendation #4: Standardize regional observer program design and ensure that NMFS contracts directly with observer service providers to oversee the performance of the companies through their contractual obligations.
NMFS, working with the fishery management councils, should address observer program design issues including vessel selection and bias, retention of experienced observers, and disproportionate cost issues among various sectors of fishing fleets.70

Recommendation #5: Consider cost-effective alternative monitoring approaches such as electronic monitoring for use as a supplement to observer coverage where appropriate. 
Alternative monitoring techniques such as electronic monitoring should be evaluated for use as a supplement to at-sea observers where appropriate. Vessel monitoring systems (VMS) technology are already widely used to transmit information about vessel position during fishing trips, providing a cost-effective way to monitor compliance with seasonal and area closures. Other forms of electronic monitoring, such as video-based monitoring, can also be used (in conjunction with port sampling of the catch) to monitor compliance in fisheries where vessels are required to retain all catch at sea.

Recommendation #6: Establish an information collection system to provide timely and accurate catch data to manage recreational fisheries in compliance with the MSA requirements for annual catch limits.
Fully implementing the Marine Recreational Information Program (MRIP) and expanding the National Saltwater Angler Registry to state and federal waters will help to increase the amount of recreational fishery information available to decision-makers. However, MRIP is not presently designed to provide more timely in-season data needed to manage recreational fishing quotas in-season to prevent the fisheries from exceeding annual catch limits, rather than learning of overages months after the fishing season has closed. Alternative data collection methods are needed.

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In recreational fisheries with larger commercial charter boats and headboats, deployment of observers may be feasible as a way to provide data on catch, bycatch and discards. In fisheries where deployment of at-sea observers is not practical, expanded use of video monitoring equipment, electronic logbooks, and dockside sampling of landings should all be considered.

Recommendation #7: Maintain public access to fisheries observer data to ensure that fisheries management decisions are made in a manner consistent with public trust management of the nation’s marine resources.
Section 402(b) of the MSA addresses confidentiality of fisheries information and the existing rules at 50 C.F.R. §§ 600.405-425 permit public access to observer data and other fisheries statistics where the identity of individual vessels or other information is not disclosed. Pending revisions to the NMFS regulations on confidentiality of fisheries statistics must ensure that the revised rules continue to support public access to fisheries observer data and other fisheries information.

24 Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs

Endnotes
1 2 The U.S. Commission on Ocean Policy. An Ocean Blueprint for the 21st Century. Final Report. Washington, D.C., 2004. See pp. 274-304. U.N. Food and Agriculture Organization (FAO). State of World Fisheries and Aquaculture, 2008 United Nations, Rome, 2009. 176 pp. Overall, 80% of the world fish stocks for which assessment information is available are reported as fully exploited or overexploited, and the maximum wild capture fisheries potential from the world’s oceans has probably been reached. Boris Worm et al. Impacts of Biodiversity Loss on Ocean Ecosystem Services. Science 314 (2006): 787-790. If the trends in overfishing are not reversed by policies to curb fishing mortality and protect ocean biodiversity, it is possible that most major fisheries could be commercially extinct by mid-century. See Magnuson Stevens Fishery Conservation and Management Act (16 U.S.C. § 1801 et seq.). NOAA/NMFS, Evaluating Bycatch: A National Approach to Standardized Bycatch Monitoring Programs, NOAA Technical Memorandum NMFS-F/SPO-66, October 2004. 108 p. See the U.N. FAO, Code of Conduct for Responsible Fisheries (1995). See Articles 7.7.3; 8..4.3. Available at: ftp:// ftp.fao.org/docrep/fao/005/v9878e/v9878e00.pdf. Economic discards are species caught but discarded because they have no economic value. Regulatory discards are species caught that may not be retained by regulation. NOAA/NMFS, National Observer Program FY 2008 Annual Report (2009). 30 pp. See President’s FY 2010 Budget Request, Congressional Submission, Exhibit 13, p. 245.

3

4 5 6 7 8 9

10 NOAA/NMFS, Evaluating Bycatch (2004). 11 Based on our comparative analysis of the NMFS national bycatch report of 2004 and more recent unpublished agency updates. 12 National Standard 9 (NS9) of the MSA requires fishery managers to minimize bycatch and to minimize the mortality of bycatch that cannot be avoided (16 U.S.C. 1851(9)). Section 303 of the MSA requires Fishery Management Plans to establish a standardized reporting methodology to assess the amount and type of bycatch occurring in the fishery, and to include measures consistent with NS9 to minimize bycatch (16 U.S.C. §§ 1853(11)). 13 NOAA/NMFS, National Observer Program FY 2008 Annual Report (2009). 14 Available at: http://www.st.nmfs.noaa.gov/st4/nop/Outreach/NOPFactSheet_FINAL.pdf. 15 J.M. Harrington et. al., Wasted Resources: Bycatch and Discards in U.S. Fisheries. Prepared by MRAG Americas, 2005. 16 16 U.S.C. §§ 1851(a)(9), 1853(a)(11), and 50 CFR § 600.350. National Standard 9 of the MSA requires that conservation and management measures minimize bycatch or the mortality of such bycatch that is unavoidable. 17 16 U.S.C. 1851(a)(1). National Standard 1 of the MSA stipulates that conservation and management measures shall prevent overfishing while achieving, on a continuing basis, the optimum yield from each fishery. See also 16 U.S.C. § 1853 (a)(15) and 1853 note. 18 16 U.S.C §§ 1853(a)(10), 1854(e). 19 16. U.S.C. § 1853(a)(7). 20 16 U.S.C. 1353A(c)(1)(H). New MSA § 303A specifies that a LAP program must include an effective system for enforcement, monitoring and management of the program, including the use of observers or electronic monitoring systems. 21 16 U.S.C. § 1853(b)(8). 22 16 U.S.C. §§ 1854(d), 1862, 1891b. 23 16 U.S.C. §§ 1383a(a)(1); 1387.

Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs 25

24 16 U.S.C. § 1383a(b)(1)(A)(i-iii). 25 16 U.S.C. § 1383a(e)(1). 26 Available at: http://www.st.nmfs.noaa.gov/st4/nop/Outreach/NOPFactSheet_FINAL.pdf. 27 National Marine Fisheries Service (NMFS), Proposed rule for 2010 Annual Determination for Sea Turtle Observer Requirement, 75 Fed. Reg. 59508-59519, November 18, 2009. 28 NOAA/NMFS, National Observer Program FY 2008 Annual Report (2009). 29 NOAA/NMFS, Evaluating Bycatch (2004). 30 NOAA/NMFS, National Observer Program FY 2008 Annual Report (2009). 31 NMFS personal communication. 32 See Recommendations from the Summary Report of the NMFS Fisheries Observer Coverage Level Workshop, Seattle, WA, July 29-21, 2003. 33 NMFS, NEFSC Response on SBRM Re-Prioritization to the NRCC. April 1st, 2009. Available at: http://www.nefsc. noaa.gov/fsb/SBRM%20Annual%20Discard%20Report/2009_Prioritization_response_to_comments.pdf 34 Fisheries with significant industry funding include the Alaska groundfish fisheries, the at-sea sector of the West Coast Pacific hake fishery, and the Atlantic sea scallop fishery. 35 NOAA/NMFS, National Observer Program FY 2008 Annual Report (2009). 36 NOAA/NMFS, National Observer Program FY 2008 Annual Report (2009). 37 NOAA/NMFS, National Observer Program FY 2008 Annual Report (2009). 38 NOAA/NMFS, Annual Report to Congress on the Bycatch Reduction Engineering Program, pursuant to Section 316(d) of the MSA as reauthorized and amended by the MSRA of 2006 (2009). 39 NOAA/NMFS, Evaluating Bycatch ( 2004), Tables 4.1-4.6 and Table 5. The observer coverage classifications used were “mature,” “developing,” “pilot,” and “baseline.” For simplicity, we assumed that the levels ‘mature’ and ‘developing’ are equivalent to the current classifications of ‘adequate’ and ‘near adequate.’ 40 NOAA/NMFS, Evaluating Bycatch (2004), Table 5, p. 75. 41 Based on President’s FY 2010 Budget Request, Congressional Submission. Exhibit 13, p. 245, personal communications with NMFS, and independent comparative analysis of NMFS national bycatch report of 2004 and more recent unpublished updates. 42 Elizabeth A. Babcock, Ellen K. Pikitch, and Charlotte Hudson, How Much Observer Coverage Is Enough to Adequately Estimate Bycatch? Pew Institute for Ocean Sciences (2003). 43 S.E. Wigley, P.J. Rago, K.A. Sosebee, and D.L. Palka, The Analytic Component to the Standardized Bycatch Reporting Methodology Omnibus Amendment: Sampling Design and Estimation of Precision and Accuracy (2nd Edition), U.S. Dep. Commerce, Northeast Fisheries Science Center Reference Document 07-09, May 2007. 156 p. 44 Babcock et al. Pew Institute for Ocean Sciences (2003). 45 Lawrence Beerkircher et al., Pelagic Observer Program Data Summary, Gulf of Mexico Bluefin Tuna Spawning Season 2007 and 2008, NOAA Technical Memorandum NMFS-SEFSC-588, April 2009. 33 p. 46 NOAA/NMFS, NOAA’s National Marine Fisheries Service Requirements for Improved and Integrated Conservation of Fisheries, Protected Resources and Habitat, January 2003. 47 NMFS National Observer Program personal communication. These costs include administration, training, costs associated with deployment (including travel, insurance and observer wage), and data processing. 48 Above current funding of ~$51 million in combined federal and industry funding in FY 2010. 49 Based on the cost of bringing all fisheries listed in the NMFS (2004) Evaluating Bycatch report as having “baseline” (<1%) or “none” levels of observer coverage up to the next level of coverage identified by NMFS, generally pilot program level (i.e., up to 2% coverage).

26 Observing and Managing 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs

50 Costs of deploying observers on 10% of fishing trips could range from $1.68 million to $4.76 million, depending on assumed costs. Current pro rata cost of deploying observers per day at sea in the Gulf reef fish fishery is $425. Our estimate is based on assumed national average cost per day at sea of $1,200. 51 U.S. Dep. of Commerce (USDOC), Office of Inspections and Program Evaluations, National Oceanic and Atmospheric Administration: NMFS Observer Programs Should Improve Data Quality, Performance Monitoring, and Outreach Efforts. Final Audit Report No. IPE-15721, March 2004. 64 pp. 52 These include the Hawaii Pelagic Longline Fishery (20% tuna, 100% swordfish coverage); North Pacific Groundfish Fishery (100% vessels over 120’ 30% vessels 60’-120’ 0% under 60’); the At-Sea Hake Mid-Water , , Trawl Fishery (100%, two observers on every vessel). 53 Electronic Fisheries Monitoring Workshop Proceedings (2008), p. 2. 54 Total cost estimated at $250 per sea day. See H. McElderry, At-Sea Observing Using Video-Based Electronic Monitoring. Archipelago Marine Research Ltd. Prepared for: NMFS Electronic Monitoring Workshop, Seattle, WA, 29-30 July 2008. 55 NOAA/NMFS, Fisheries Economics of the United States 2006: Economics and Sociocultural Status and Trends. 166 p. Available at: http://www.st.nmfs.noaa.gov/st5/index.htm. 56 National Research Council (NRC), Committee on the Review of Recreational Fisheries Survey Methods, Review of Recreational Fisheries Survey Methods, Executive Summary: http://books.nap.edu/catalog/11616.html. 57 The U.S. Commission on Ocean Policy, An Ocean Blueprint for the 21st Century, Final Report, Washington, D.C., 2004. See pp. 274-304. 58 National Research Council (NRC), Review of Recreational Fisheries Survey Methods, Washington, D.C., 2006. 59 MSA 16 U.S.C. § 1881(g). 60 MSA 16 U.S.C. § 1881(g)(3). 61 NMFS, personal communication. 62 National Marine Fisheries Service (NMFS), National Observer Program FY 2008 Annual Report (2009), p. 9 and Table A2. Industry funding totaled approximately $13 million out of $18.4 million in funding in 2008. 63 National Marine Fisheries Service (NMFS), Draft Observer Restructuring Implementation Plan, February 2010. 64 MRAG Americas, Independent Review of the North Pacific Groundfish Observer Program, Prepared by MRAG Americas, Inc., May 2000. 120 pp. 65 USDOC, Office of Inspections and Program Evaluations, March 2004. 66 USDOC, Office of Inspections and Program Evaluations, March 2004. 67 USDOC, Office of Inspections and Program Evaluations, March 2004. 68 In 2003, the agency projected the need for an additional $100 million above the FY 2003 funding level by 2009 to meet the National Observer Program bycatch objectives. See: NOAA/NMFS, NOAA’s National Marine Fisheries Service Requirements for Improved and Integrated Conservation of Fisheries, Protected Resources and Habitat, January 2003. 69 See: MSA §§ 1854(d), 1862, 1891b. 70 USDOC, Office of Inspections and Program Evaluations, March 2004.

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