NOAA released FB09-016 today. It is a notice letting everyone know that NOAA has received what it terms “two requests for emergency rulemaking to reduce loggerhead sea turtle bycatch.”
Two “requests”? One is a petition from Oceana. How did Oceana publicize this issue and gather the “signatures”? Did Oceana tell the people they got to “sign” the petition how many turtles had actually been observed? Did they use the most accurate science available and the most up to date figures available?
No, No and No.
The other “request”? Well, that was more of a threat to sue if NOAA didn’t imediately toe the line drawn in the sand by The Center for Biological Diversity, an extremist environmental group with a legal department approximately the size of Texas. I have no idea how many “pending” legal actions they have but a site search of their web site returns 82 hits for “pending litigation”….everything from snails to desert tortoises to sea turtles to saving California Salamander and stopping water pipelines. That’s one busy bunch of lawyers.
The question I have is, why is either of these things worthy of a “Fishery Bulletin” unless NOAA fully intends to use them as an excuse for shutting down an otherwise healthy fishery whose main target species is neither “overfished” nor “undergoing overfishing”? Do either of these “requests” come with some good figures to support this sort of action?
No, again.
They have all been using figures from half of 2006, and all of 2007. I see on the NMFS site that the figures for Jan to July of 2008 are now available.
http://sero.nmfs.noaa.gov/pr/pdf/UpdatedSEFSC2008AppB.pdf
So…..
Using those figures we see that one trip — one that wasn’t even a strictly bottom longline trip but was a trip observed by an observer from the Shark Bottom Longline Observer Program and a trip on which no notation of the target species for each particular observed set was made — that one trip had a remarkable and completely anomalous total of 7 turtle interactions. If that one anomalous outlier from 2006 is thrown out (as it would be and should be by any decent statistician or scientist attempting to arrive at an honest estimate of the real numbers) we have a total of 14 observed turtle takes over 25 months. Of those, 11 were marked by the observers as “loggerhead” or “Caretta caretta”. Of those, 9 were marked as released alive while two were noted “unknown” and two were “comatose”. Of the 14 observed takes, 10 were taken with “Unknown” bait, 1 with skate, 1 with shark and two with possible squid bait (although both of those listed multiple bait possibilities).
Yet, somehow NOAA is taking as credible the petition submitted by a group that uses the following in order to gather those “signatures”?
“observer data from the fleet reveals that virtually one out of every two longline sets has at least one loggerhead sea turtle take, and furthermore, the mortality level of these takes may be equal to or greater than 50 percent,”
“One out of every two longline sets”?
In fact, the initial report posted on the NMFS site states that “Approximately 24% or trips and 3% of sets captured turtles”. (Page 4, paragraph 2)
By whose math does that even come close to equating to “one out of every two”? Nobody’s, that’s whose. The petition collected signatures based on complete lies.
“Mortality level may be equal to or greater than 50%”? Out of 14 observed takes 9 were released alive. Even if you want to call ALL of the others deceased (although the observers did NOT do so), in whose interpretation of math does this equate to “equal to or greater than 50%”?
These are the figures they used to gather the signatures on a petition that NOAA now wants to give any kind of credence to? A petition NOAA apparently plans to use to justify closing down a healthy fishery whose main target is neither overfished or undergoing overfishing? A petition that, simply put, gathered signatures based on lies.
“For the emergency measure,
Oceana is specifically asking for a prohibition of the
use of bottom longline gear in waters less than 55
fathoms and a prohibition on the use of squid as bait
when fishing with longlines in waters deeper than
55 fathoms.”( NMFS Bulletin)
“less than 55 fathoms”?? What do they base that on? The only figures I’ve seen about location of the captured turtles doesn’t support this in any way.
Prohibition on the use of squid? What do they base that on? A study of the pelagic longline fishery, is what they base it on.
Do they have a clue that when a bottom longliner in the Gulf of Mexico uses “squid” for bait he is using chunks of a waste product from a Pacific fishery, not whole squid and that more often than not it is salted? No, of course they don’t because NONE of the figures they have seen have told them that. Do they have any understanding of the fact that when a fish (or turtle) bites on that piece of squid it is likely to stay on the hook while when that fish (or turtle) bites on softer bait it is likely to be knocked off the hook? Do they realize that because of this simple fact, they can’t look at X number of captures and only see “squid” or “unknown” as bait and make any determination at all as to which bait works better (or worse, depending on your position). Do they have any idea that every one of those “unknown” baits in the observer book is more likely a piece of mackerel than a chunk of that tough squid wing? No, of course they don’t. They have no idea, yet they are so sure of their imminent success that they have no qualms about trying to dictate exact terms of the closure they demand to the regulatory agency that is charged with regulating the industry using the best available science and with regulating the industry taking into consideration the economic impact on the fishery and the fishing communities.
Ask yourself, if they aren’t planning on meekly acquiescing to this demand, why else would NOAA use an official Fishery Bulletin to tell people they had received such a petition, a petition so obviously based on false and dishonest numbers that it should have been thrown out with the rest of the morning’s trash.
The litigation machine of the Center for Biological Diversity is another story and speaks for itself. It is growing more and more accustomed to getting its way by intimidation and threat and cares not one bit for the truth of its “causes” or the number of people whose lives it interacts with and impacts detrimentally while providing an excellent and comfy living for its huge boatload of lawyers.
The so called “Fishery Bulletin” (in pdf format) is available here.