NOAA fisheries has released their draft Bocaccio and Yelloweye Rockfish recovery plan this afternoon, and I think it may be worth taking the time to look into, and send comment on a portion of their recovery strategy that is calling for establishing MPA's throughout Puget Sound to protect these species. Specifically, it appears there will be a call for broad scoping MPA's in the San Juans and Straits that will directly impact our Ling Cod and Halibut fisheries, and likely Salmon and Shrimp fisheries to a certain degree.

The recovery plan in full can be found here:
http://www.westcoast.fisheries.noaa.gov/...covery_plan.pdf

The significant referencing of instituting MPA's can be found on page 79.

"Therefore, in the areas we have assessed to have remaining high risk of bycatch despite the regulations put into place by WDFW in 2010 to limit bycatch (areas are the San Juan Basin and the eastern Strait of Juan de Fuca (generally east of Port Angeles)) (see Table 15), we recommend beginning the scientific and public process to establish marine protected or rockfish conservation areas to protect listed rockfish. These areas also have the most rockfish habitat. In other areas where further information is needed, we recommend further assessment to determine whether spatial protection or other improved fisheries management protections are needed. "

Comments can be submitted here until November, 14th:
https://www.regulations.gov/docket?D=NOAA-NMFS-2016-0083

Anyone who fishes recreationally following the current 120 foot depth restriction is aware of the extremely low incidence of encounter with the species of concern in the recovery plan. Although encounters DO occur with various other species of rockfish, some 90+% of viable rockfish habitat throughout Puget Sound is deeper than 120 feet. This means that under current regulation over 90% of the current existing habitat is already protected. Institution of MPA's would not only be a redundancy, it will greatly jeopardize fishing opportunities throughout the region.

And do not forget the efforts to provide and encourage use of descender devices in both the deep water ling and halibut fisheries.

I will be reading the draft to see if their MPA/RCA language includes any of the informal fishing community input regarding Sunset provisions tied to several conditions including (but not limited to):

1. Recovery to a specific level which may be ESA delisting - it goes away.
2. Population analysis from each MPA/RCA compared to adjacent areas to see if there is a measurable positive impact. If not - it goes away.
3. Failure to perform the required analysis - it goes away.
4. Failure to achieve recovery within a specified period - it goes away (as being indicative that the species is unrecoverable or that the MPA/RCA is not a meaningful tool).

In short, insofar as this plan recommends using MPAs/RCAs it should also include criteria leading to their elimination - rather than rockfish recovery becoming the rallying cry leading to the establishment of permanent MPAs/RCAs - in addition to the areas already off limits by the 120 foot rule.

In multiple locations in the report they site the fact that accurately producing abundance estimates and determining distribution have both been spotty at best. The data is just not there to tell us what these populations are doing, and for a long lived species not enough time has passed to see a signal in relation to the existing measures that have been taken (since 2010, and prior).

On page 38 they have clear language stating that the descender devices are quite effective, even maintaining breeding fitness in adult females.

"A study of yelloweye rockfishes indicated that when they are caught and released at the surface, the mortality rate is high; however, when they are released with a decompression device, survival may be high (Hochalter and Reed 2011). Other studies of rockfish released at depth indicate good short-term survival of released fish (Parker et al. 2006; Jarvis and Lowe 2008). One recent study found that short term (48 hours) survival for recompressed yelloweye rockfish was good (80 percent or higher) at a variety of depths of capture."

Without realistic/accurate abundance and distribution estimates, and no real evidence to state that MPA's even work, we really need to stand up and let them know the closures are a horrible idea.

If the purpose of their proposed zones is for rockfish recovery then that needs to be clear in the naming and supporting discussion. Marine Protected Area and Rockfish Conservation Area are simply too generic and imply permanence.

Permanent is always a concern. If I understand correctly, California set up some MPAs with the understanding of the sport fishing community that the areas could go away if recovery efforts were successful. Saw something a while back that the CA FW Commission was going to make them permanent.

Even of more concern was the part of informal discussions that intimated that should initial MPAs not be shown to be effective then they (obviously) need to be bigger.

In face to face meetings we were told Recs were not the problem. Tribal Longlines were. Tribal treaty rights are going to trump these closures.

Ray Hilborn-UW Professor disagrees with MPAs

“There’s this idea that the only way you can protect the ocean is by permanently closing parts of the ocean to fishing, with no-take areas,” said Ray Hilborn, a professor in the UW’s School of Aquatic and Fishery Sciences. “You protect biodiversity better by regulating fisheries over the country’s entire economic zone.”

“If the problem is overfishing or bycatch, then fisheries management is much more effective than establishing MPAs because you regulate the catch over the entire economic zone,” Hilborn said. “I don’t see how anyone can defend MPAs as a better method than fisheries management, except in places where you just can’t do management.”

Read this link for counterpoints.

http://www.washington.edu/news/2016/07/1...ine-ecosystems/

Ray hit the nail so squarely on the head that it hurts.


"I don't see how anyone can defend MPAs as a better method than fisheries management, except in places where you just can't do management." Like WA.

Ipso facto the MPA's will only impact the rec fisherman whom are not the problem.

I hope everyone who fishes the marine waters is taking this very seriously and will take the time to send comment.

Some talking points:

- NOAA's rockfish abundance/distribution science is not sound.
- The functionality of MPA's is too be determined in outof region areas they have been instated.
- The use of descent devises have proven to be effective in curbing mortalities.
- Their plans set no recovery standard or timeframe MPA instatement.
- The MPA's do not account for treaty fisheries.
- DFW has already instated fishing rules for the rec's that have all but curbed incidence of encounter with species of concern.

This is classic management just to manage and this kind of runaway science needs to be stopped.

I think characterizing the rock fish recovery plan as runaway science that has to be stopped is disingenous. One could say the same about climate change, ocean acidification, pollution, cancer, or any number of other potential problems that have been studied. Science, something we humans are better at than most life forms, provides information based on verifiable facts. Scientists may use those facts to recommend potential solutions to problems but the adoption of those recommendations is always a political choice.

The focus on MPA’s in this discussion is a perfect example. There is an extensive body of science addressing MPA’s worldwide. In the USA with the exception of the large MPA in Hawaii only about 3% of the MPA’s are no take areas. The MPA in Hawaii is based on cultural and species protection. We have more than 20 federally recognized MPA’s in Puget Sound. Agencies responsible for rockfish recovery have limited options, they can work to improve fish populations or they can restrict fisheries. In both cases they can only regulate how humans interact with the fish and their habitat. There many examples of MPA’s that have improved recreational and commercial fisheries.

The Ray Hilborn argument does not apply to most coastal marine waters. He is talking about managing for food sustainability. Another way to say it is managing to for long term commerical fisheries. The salmon, halibut, and other bycatch in the Alaska trawl fisheries is justified by ecosystem management. One could say the same thing about logging on the Olympic Peninsula. If logging was allowed in Olympic National Park on some basis the economy would improve.

I in no way assert that the Recovery Plan itself is runaway science. I was referring specifically to the topic at hand in this thread, the use of MPAs or, let's call it for what it is, closure areas to manage 2 specific fish species that are currently being properly managed.

The use of descent devices would bring the recreational incidental mortality to nearly 0 under current restrictions.

If this is for the recovery of two ESA listed rockfish species then any discussion of set aside areas should be solely to that goal. Call them Rockfish Recovery Zones with appropriate Sunset provisions. Otherwise, once established they NEVER go away.

I can tell you four locations within Puget Sound -Admiralty Inlet where Yelloweye Rockfish can be caught. But I won't. None are shallower that 180 feet deep. Most are closer to 240.

Our fisheries management of bottom fish is a joke and always has been.

The horse was long gone before management did anything about Puget Sound Rockfish dating back to the early 1980's.

I was one of the two commercial handline jigger fishermen who testified to WDF urging that commercial handline jigging be closed to Puget Sound waters in the very early 1980's.

It was at the same meeting that two commercial trawler fisherman joked that "does WDF really believe were are fishing where we told them".

I don't feel that additional MPA's are the solution.