Mike,
I am not a scientist, so I'm not going to respond to your comments on
the fishery control rule. I do know that there were some very
knowledgeable fisheries scientists and ecologists involved in
developing the draft fishery control rule. You seem to assume that
they did not work from a conceptual model that took into account
variables such as you describe. I'm pretty sure that you're wrong
about that. The fishery control rule is not at all the fishery control
rule that the advisory committee reviewed in the previous draft.
Frankly, I don't know what you mean to imply by "scientifically
honest answers". Are answers you disagree with or that don't satisfy
dishonest?
Given the intensity of all types of fishing, I don't know of a
management measure that by itself will reduce the risk of geographical
depletion, which itself will vary with the species. MPAs and gear
restrictions can help to some extent, but given the level of fishing,
there will always be some irreducible risk of depletion, particularly
with species whose reproduction can be very episodic.
I suggest submitting written comments on the fishery control rule
that will require a response.

Mike Weber

--- In CAnearshore@y..., Michael <enolamms@p...> wrote:
> Mike:
> In an earlier post you dismissed a post by bob Humphrey regarding the
> residential nature of nearshore reef fish and how the MSY/OY
approach DFG is
> proposing does not address that characteristic. Let me try and
restate the
> issue. As a scientist I have some experience constructing models of
natural
> systems where unquantified variables were present, so I am familiar with
> modeling concepts and construction. What is of utmost importance when
> developing a model, whether the subject of the model are fish
populations,
> timber harvest, stream flow or groundwater budgets is to first built the
> appropriate conceptual model. By that I mean that before any number
crunching
> or computer programming is done one must consider, identify and
incorporate
> into the model the significant variables and conditions which will
influence
> the outcome in a substantial way. What DFG has done with their
approach to
> modeling nearshore reef fish is to ignore conditions which they find
> particularly troublesome. Why? Because if they include, for example, the
> residential nature of reef fish they will have to either develop a
new model
> or substantially modify the one they have and they are uncomfortable
doing
> that. DFG can adjust their model (fish budget if you will) by
reducing the
> withdrawals to accomodate long-lived fish and slow reproduction
rates. But
> they do not know how to address residential fish and their tendency
to become
> depleted geographically. MPAs and regional management WON'T do
that. Over a
> year ago Patty Wolf acknowledged to me the importance of this
condition and
> stated that DFG would address this in the FMP. They have not done
so. When I
> discussed it with Tom Barnes at the Advisory meeting (you were
there) he could
> not respond to this concern. Now you have responded to Bob as follows:
>
> "Somehow, you seem to believe that you are the only one who cares
> about the future of this fishery, and more importantly, of this
> ecosystem. Well, you are flat out wrong about that and I'm really
> tired of being preached at by you."
>
> Ok we admit it we are tireless when we are not getting answers to
legitimate
> questions. We know you and DFG care about this fishery. We want
the DFG to
> succeed. No we demand that DFG succeed, but we don't trust them to
get it
> right without our help, so we will continue hammering on you both
until you
> provide us with scientifically honest answers.
>
> -Mike Malone
>
> spyderweber01 wrote:
>
> > Joe,
> > I agree that the matter of which years should be used in setting the
> > baseline should be revisited. The advantages and disadvantages of
> > using this period or that period should be clearly articulated. The
> > FMP sets up the structure for doing that, and in my book, revisiting
> > the TACs, etc., is one of the most important, first steps in
> > implementing the FMP.
> >
> > Mike W
> >
> > --- In CAnearshore@y..., Joe Ward <jward@v...> wrote:
> > > THE RESTREPPO APPROACH IS MEANT TO PROVIDE A REASONABLE,
PRECAUTIONARY
> > > APPROACH TO MANAGING A FISHERY WHERE INFORMATION IS LACKING. SUCH AN
> > > APPROACH, INDEED ALMOST ANY APPROACH, TO MANAGING A FISHERY WITH
> > > LITTLE INFORMATION IS GOING TO BE ARBITRARY TO ONE DEGREE OR
ANOTHER.
> > > WHAT IS YOUR ALTERNATIVE?
> > >
> > > Mike,
> > >
> > > The Restrepo approach is NOT being followed. Restrepo states that
> > historical
> > > average catch may be a reasonable proxy if you use a "time period
> > when there
> > > is no quantitave or qualitative evidence of declining abundance.(1)"
> > Yet the
> > > DFG is apparently using data from a period when there is some
> > quantitative
> > > and plenty of qualitative evidence of decline. Maybe it is the
> > "best" data
> > > the DFG has, but it is specifically excluded from use under the
Restrepo
> > > approach. The plan fails to identify the problems and attendant risk
> > with
> > > using the data in this way. Instead the plan says both that
there is no
> > > evidence of decline, and that the fishery is collapsing. Really
what I'm
> > > asking for is that the plan call a spade a spade.
> > >
> > > I think it makes an important difference to managers deciding what
> > measures
> > > should be adopted, whether the plan uses a sound scientific approach
> > based
> > > on valid data or a qualitative judgement based on factors x, y, z.
> > Instead
> > > the DFG really makes a defacto and unexamined qualitative
judgement that
> > > stocks are healthy by selecting the catch records from the 90s as
> > the basis
> > > for the TAC.
> > >
> > > If the NFMP's contention is that a reasonable proxy is 50% of recent
> > catch
> > > from a period of no decline, it seems logical that if the period in
> > question
> > > did show quantitative or qualitative evidence of declining abundance
> > then
> > > the TAC calculated based on that period would likely be too high.
> > The 50%
> > > adjustment is intended to deal with the uncertainty in a proxy based
> > on a
> > > period of no decline. That uncertainty is far greater when you try
> > to use a
> > > period of decline as the basis for the proxy instead.
> > >
> > > It would seem more logical to use catch records from the 80s (or
70s, or
> > > 60s, etc) to calculate a proxy for the OY, and then look at how
much the
> > > annual catch has exceeded that OY since then (i.e. during the
90s) as a
> > > measure of how much stocks have been over-fished. Then use a factor
> > based on
> > > the over-fishing to adjust the 80s-based OY proxy downward.
> > >
> > > Joe Ward
> > >
> > > P.S. I would rather give up a year or two of fishing now, than lose
> > it for
> > > 30 years.
> > >
> > >
> > >
> > >
> > >
> > > (1) "Technical Guidance On the Use of Precautionary
Approaches..." V.R.
> > > Restrepo et. al. page 26.
> >
> >
> > To unsubscribe from this group, send an email to:
> > CAnearshore-unsubscribe@e...
> >
> >
> >
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