Meeting the Information Demands of 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs

8/9/2019 Meeting the Information Demands of 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs

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A Needs Assessment for Fisheries Observer Programs


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The Marine Fish Conservation Network advocates or national policies to achievehealthy oceans and productive fsheries. The Network is the largest nationalcoalition solely dedicated to promoting the long-term sustainability o marine fsh.With almost 200 membersincluding environmental organizations, commercialand recreational fshing associations, aquariums, and marine science groupsthe Network uses its distinct voice and the best available science to educatepolicymakers, the fshing industry, and the public about the need or soundconservation and better management practices.

600 Pennsylvania Avenue, SE Suite 210 Washington, DC 20003telephone: 202.543.5509 toll ree: 866.823.8552 ax: 202.543.5774

[email protected] www.conservesh.org

The Marine Fish Conservation Network is supported by many individuals, businesses,and oundations. This report and our work in general is made possible by the generoussupport o The Pew Charitable Trusts, Curtis and Edith Munson Foundation, OceanFoundation, Marisla Foundation, David and Lucile Packard Foundation, Walton FamilyFoundation, and Patagonia Inc.

Credits: Lead author: Kenneth Stump, Marine Fish Conservation Network Policy DirectorContributing Author: Rebekah HamedResearch Assistant: Cade London

The authors grateully acknowledge the technical advice o The Ocean Conservancy,Cape Cod Commercial Hook Fishermens Association, Association or ProessionalObservers, and Oceana.

Photo Credits: Where indicated, photos are rom the National Oceanic and AtmosphericAdministration and National Marine Fisheries Service.


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Observing and Managing 21st Century Fisheries: A Needs Assessment or Fisheries Observer Program

Meeting the Inormation Demandso 21st Century Fisheries:

A Needs Assessment for Fisheries Observer Programs

1.IntroductionUntil the end o the 20th century there were ew limits on most ocean sheries,1 but advancesin shing technology and growth in shing capacity have necessitated the increased use oregulatory controls to address widespread overshing and prevent sheries rom exceedingsustainable limits.2,3 In the U.S., successive reauthorizations o the Magnuson-Stevens FisheryConservation and Management Act (MSA) since 1996 have mandated management actions tominimize bycatch and waste, place limits on allowable annual catch, establish rebuilding plansor overshed stocks, and limit shing eort or access to sheries.4 All o these managementobjectives require timely, accurate scientic inormation and eective monitoring o sheries inorder to make responsible management decisions, and that depends in signicant part on thedeployment o trained sheries observers to quantiy and characterize catches and bycatch atsea and provide biological data or compliance monitoring, scientic stock assessments, and

other management needs.5,6

Multiple mandates or the conservation o sheries, marine mammals and endangered speciesauthorize the deployment o observers on shing vessels and processors to provide reliablecatch and bycatch data or the management o species under the jurisdiction o the NationalOceanographic and Atmospheric Agency (NOAA) and its sub-agency, the National MarineFisheries Service (NMFS). The MSAs mandates or bycatch minimization and annual catchlimits (ACLs) require reliable estimates o total shing mortality and species composition othe catch that include economic or regulatory discards at sea.7 In addition, the growing use ocatch share management programs or individual quota share holders increases the demandor accurate catch data in order to ensure that individual vessels or shery sectors stay withintheir annual limits. Implementing these management objectives will increase the need or shery


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

catch data provided by at-sea and dockside observers, and place greater inormation demandson the monitoring and enorcement capabilities o shery managers.

Our ndings indicate that current observer program unding and coverage levels are inadequatein most U.S. sheries. Current unding supports at-sea observer programs in more than 40broadly dened sheries categories nationwide,8 only 23 o which were considered to haveadequate levels o observer coverage in 2009.9 The total number o sheries evaluated orobserver coverage by the agency has varied rom 84 broadly dened sheries in a nationalbycatch report in 200410 to 90 in more recent unpublished updates.11 In other words, NMFS hasbeen able to deploy observers in about hal o the fsheries that the agency has assessed orcoverage to monitor bycatch, and is only able to provide adequate coverage in one-quarter othose fsheries at present. In some cases, however, recent increases in unding have enabledNMFS to expand coverage in targeted sheries.

Program goals or observer coverage have

dominated the program historically, but themajority o fsheries have little or no observermonitoring o bycatch. Courtesy NOAA/NMFS.


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Legal Authority: Mandates or observers under

the MSA, MMPA, and ESAMagnuson Stevens Fishery Conservationand Management Act (MSA, 16 U.S.C. 1801 et seq.)

The MSA includes multiple mandates orminimizing and accounting or bycatch,16establishing annual catch limits andaccountability measures that preventovershing,17 rebuilding overshed stocksas quickly as possible,18 protecting

vulnerable ocean habitat,19

and grantinglimited access privileges to sheries20 all o which require reliable inormationabout the quantity and composition othe catch as well as biological data orscientic assessment. The MSA providesthe authority to require observer coverageas part o a shery management plan(FMP),21 and authorizes the establishmento industry user ees to recover the costsassociated with observers in severalprovisions.22

Marine Mammal Protection Act (MMPA, 16U.S.C. 1361 et seq.)

The MMPA prohibits the take o marinemammals in U.S. waters with limitedexceptions, and establishes the goal oreducing incidental mortality or seriousinjury o marine mammals in commercialshing operations to insignicant levelsapproaching zero.23 Each year NMFSreviews and revises its List o Fisheries,

which classies U.S. commercial sheriesinto one o three categories based on thelevel o serious injury and mortality omarine mammals that occurs incidental

to each shery.24 The MMPA authorizesplacing observers on board vesselsengaged in commercial shing operationsthat incidentally take marine mammals.25Fisheries that have requent (Category I)or occasional (Category II) takes o marinemammals are required to carry an observeri so requested by NMFS or its contractedor certied service provider, while sherieswith only rare or no known incidental takes

(Category III) may be asked to carry anobserver on a voluntary basis.

The Endangered Species Act (ESA, 16U.S.C. 1531 et seq.)

NMFS has jurisdiction over nearly 70 ESA-listed species o sh, sea turtles, marinemammals, as well as several invertebrates(elkhorn and staghorn coral, white abalone)and one marine plant species (Johnsonsseagrass). Although there are no direct

ESA requirements to monitor sheriesusing observers, observer programs areoten required as a Term and Condition oauthorizing ederal sheries to incidentallytake threatened or endangered species,as part o Section 7 consultations.26 NMFShas identied 19 sheries as a high priorityor observer coverage in the agencys2010 Annual Determination o commercialsheries which would be required to takeobservers i requested by NMFS basedon their interactions with ESA-listed sea

turtles.27


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Regional Programs

NMFS oversees the operation o observer programs in each region. In a majority o regions,NMFS scientists (in coordination with observer program sta) determine sampling protocols andcoverage levels or each shery that will provide statistically robust estimates. However, thelargest program in the nation (the North Pacic Groundsh Observers Program in Alaska)establishes its coverage levels through regulations that have not changed in 20 years. NMFSprovides training to all new and returning observers in species identication, sampling methods,confict resolution, and saety. NMFS sta oversee the administration o the programs, debriengobservers ater each shing trip and reviewing the quality o the data beore it is used in the

management o the shery.

Fishery observer programs are administered by each o the six NMFS regions

(adapted rom NMFS 2009)

Alaska Center,Seattle, WANorth Pacifc groundfsh

National ObserverProgram Silver Spring, MDNational coordination

Pacic Islands Region,Honolulu, HIPelagic and deep-set longline

Southeast Center,Galveston, TXRee fsh, shrimp trawl

Southwest Region,Long Beach, CAPelagic longline, drit gillnet

Southeast Center,Miami, FLPelagic longline

Northeast Center, Falmouth, MANew England (NE) groundfsh, NE& Mid- Atlantic gillnet and trawlfsheries, Atlantic scallop dredge

Northwest Center,Seattle, WAWest Coast groundfsh/at-sea hake

Southeast Center,Panama City, FLShark gillnet, bottom longline

Alaska Region,Juneau, AKSalmon set gillnet


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Disparities in coverage between regions and fsheries are linked to

availability o unds

Current unding levels support at-sea observer programs in more than 40 sheriesnationwide,28 as dened by NMFS in the national bycatch report o 2004.29 But observercoverage varies widely by region and shery, rom levels o 30-100% in most Alaska groundshsheries (except or vessels under 60 eet in length) and 17-30% in the Pacic Coast groundshsheries to as little as 1-3% in the majority o sheries along the Atlantic and Gul o Mexicocoasts.30 In some cases, however, recent increases in unding have enabled NMFS to expandcoverage in targeted sheries. For instance, the Northeast Fishery Observer Program has a2010 target coverage goal o 30% in the limited-access sector sheries and 8% in the non-sectorsheries o New England. Similarly, the Southeast Region has increased its target observer

coverage level in the bottom longline component o the ree sh shery to 7% in 2010.31

To some extent, regional disparities in coverage refect dierences in history, sheries and observerprogram goals and objectives,32 but the actual level o coverage is oten dictated largely by theavailability o unds. Inadequate unding in the Northeast Region orced NMFS to scale back observerdays at sea in 2009 and all ar short o target coverage levels needed to achieve statisticallyadequate condence in estimates o bycatch and discards at sea.33 Commercial sheries in whichindustry unding pays a signicant share o the cost o deploying observers have consistently higher

observer coverage levels as a percentage o shing trips, but they are ew in number.34

3.Observer Program Funding: Assessing Adequacy, Needand CostLimited ederal unding or regionalobserver programs was availablebeore 2000. Congressionalappropriations or NMFS observerprograms increased slowly in the earlyto mid-2000s, and saw a signicantincrease in the FY 2010 Presidentsrequest (Figure 2). The NationalObserver Program began receivingappropriations in 2000. Most o themoney appropriated or the NOP is

$0

$5

$10

$15

$20

$25

$30

$35

$40

$45

$50

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

New England Groundfish

Atlantic CoastEast CoastHawaiian LonglineN. Pacific Marine ResourcesPacific Observer ProgramSouth Atlantic/Gulf ShrimpWest CoastNational Observer Program

Fig. 2 - Enacted Appropriations or Regional ObserverPrograms, 2000-2010 ($ millions)


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distributed to the eight regional observer programs. Most regional programs are unded almostentirely with ederal appropriations and NMFS contracts directly with private observer providercompanies to hire, equip and deploy observers. In the Alaska Region, however, industry unding

accounts or nearly three-quarters o the total program cost.35

Other sheries with signicantindustry unding o observers are the at-sea sector o the West Coast Pacic hake shery andthe Atlantic sea scallop shery.

The Omnibus Appropriations Act o 2009 unded NMFS observer programs at the Presidentsrequested FY 2009 level o $32.7 million and the FY 2010 appropriations increased that unding levelto $41 million, spread across eight line items (Table 1). All regions have at least one dedicated budgetline supporting observer program activities except the Southwest Region, which has never had adedicated budget line. Similarly, the Alaska Marine Mammal Observer Program (covering state-waters salmon sheries) has no dedicated Congressional budget line. In addition to unding underthe Magnuson-Stevens Act (MSA), observer programs may receive unding rom programs underthe American Fisheries Act (AFA), Endangered Species Act (ESA) and Marine Mammal Protection

Act (MMPA).36

Observer programs may be unded by more than one budget line, and many observerprograms are unded through a combination o unding sources.37

Table 1. Observer Funding in Omnibus Appropriations Acts o 2009 and 20101

Observers/TrainingFY 2009Million $

FY 2010Million $

Atlantic Coast Observers 3.423 3.484

East Coast Observers 0.353 0.354

Hawaii Longline Observer Program 4.046 7.100

N. Pacic Marine Resources Observers/N. Pacic

Observer Program5.609 5.732

NE Groundsh Court-Ordered Observers 8.634 8.695

National Observer Program 3.785 8.823

S. Atlantic/Gul Shrimp Observers 1.804 1.833

West Coast Observers 5.026 5.053

Total 32.680 41.074

1 Funds appropriated or the Reducing Bycatch budget line and other ederal unding may be used to deployobservers but are not included in the regional observers budget lines and totals.

In 2008, the most recent year or which published data exist, appropriations rom Congressaccounted or approximately three-quarters o the direct unding or U.S. sheries observerprograms (Table 2). In addition, the majority o the $2.738 million appropriated or reducingbycatch in the NOAA FY 2008 budget was used to deploy at-sea sheries observers to monitorthe levels o bycatch o sea turtles, marine mammals, seabirds, and non-target sh.38 Theremainder o the unding came rom the shing industry ($15.6 million in 2008), and most o thatcame rom the Alaska groundsh industry, which pays the salaries o observers while at sea, aswell as travel expenses and insurance.


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Table 2. 2008 NMFS Observer Program unding and coverage summary1

Region

Funding

(Million $) Observer DAS

Northeast region 14.060 13,208Southeast region 6.538 4,593Southwest region 0.619 329Northwest region 5.941 4,596Pacic Islands 5.724 9,739Alaska region 18.772 39,000NOP national 1.456 NATotal all sources 53.110 71,465

Total ederal unding2 37.442

1 NMFS National Observer Program Annual Report or FY 2008. 2 Includes $1.693 million romReducing Bycatch budget line that is dedicated to observer deployment and $4.257 milliono other ederal unding.

Observer Coverage Adequacy and Need: A Baseline or Evaluation

In 2004, NMFS published its rst national bycatchreport in which 84 broadly dened sheries wereassessed or observer coverage, o which only21 (25%) were identied as having adequate ornear-adequate coverage levels.39 Thirty-two (38%)

sheries were considered to be at baseline or pilotprogram levels, with observer coverage ranging rom0.5% to 2%. The remainder (37%) had no observerprograms or coverage.40 More recent unpublishedinormation rom NMFS in 2009 puts the number osheries with adequate or near adequate coverageat 24, and those with minimal baseline or pilot-levelcoverage at 20, out o a total o approximately 90sheries that we identied using NMFSs broadlydened list o sheries.41 In short, more than hal(46 sheries, 51%) assessed by NMFS have noobserver coverage and nearly three-quarters (73%)

have negligible (i.e., 0.5% to 2%) or no coverageat present (Figure 3). Only one-quarter o sheriesassessed or bycatch are considered to haveadequate or near-adequate coverage today.

Credit NOAA/NMFS


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0%

25%

50%

75%

100%

South

west

South

east

North

west

Alaska

North

east

Pacific

Isla

nds

AllRegio

ns

24

1

96

3

3

2

20

1

9

13

5

1

46

6

1

4

2

30

3

NoneBaseline/PilotAdequate/Near-Adequate

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

Our review indicates that the Southeast region has the greatest number o sheries thatneed observers and the lowest levels o observer coverage overall, ollowed by the PacicIslands region. The Southwest region also has low levels o coverage and very limited unding

although it has substantially ewer sheries. The Northeast region has minimal pilot-levelcoverage (3% or less) in many o its Mid-Atlantic sheries. Overall, more than hal (51%) othe sheries that we identied 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 singlerecommended observer coverage level that can be applied to every shery the level ocoverage needed will depend on the purpose or which the observer data is being used, the sizeo the shery, distribution o catch and bycatch, and spatial stratication o the shery.42 In somecases, 100% observer coverage may be necessary and appropriate or example, to monitorshery incidental catch o a highly endangered species, or to monitor compliance with individualcatch shares in a Limited Access Privilege (LAP) program. For bycatch and discard estimationunder the New England Standardized Bycatch Reporting Methodology, NMFS scientistscalculated the level o coverage needed to achieve estimates o bycatch with a 30% margin oerror or shing gears and species groups in the Northeast region.43 Babcock and Pikitch (2003)suggested that coverage levels o at least 20% or common species, and 50% or rare species,would give reasonably good estimates o bycatch.44 Beerkircher et al. (2009) concluded that40% observer coverage in the Gul o Mexico pelagic longline shery would provide estimates o

bluen tuna bycatch with the desired level o precision.45


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Defning Fishery

A Primer

Both the MSA (16 U.S.C. 1802(13))and MMPA (16 U.S.C. 1362(16)) deneshery broadly as one or more stockso sh which can be treated as a unit orpurposes o conservation and managementbased on geographical, scientic, technical,recreational, and economic characteristics,but estimates o the number o U.S. sheriesvary depending on the criteria used to denea shery. The annual MMPA List o Fisheriesor 2010 identied nearly 270 sheries, but

the LOF includes aquaculture pens andlumps some sheries into a broad gear typecategory, such as Northeast bottom trawl,which encompasses numerous species-specic target sheries. In the 2004 nationalbycatch evaluation report, NMFS identied84 sheries nationwide, but the agencysbroad denition o shery included manyindividually managed sheries under a singleregional observer program umbrella, suchas the North Pacic groundsh shery,which has many directed sheries (bothsingle species and stock complexes) with

specied catch limits and other managementregulations within the groundsh shery asa whole.

This report denes a shery as an activelymanaged target shery in a sherymanagement plan (FMP) or annual catchspecications document subject to speciedcatch limits and/or other managementregulations. Based on those criteria, morethan 350 marine sheries qualiy thislist includes the salmon sheries o theWest Coast and Alaska as well as the

sheries managed by the Atlantic StatesMarine Fisheries Commission but does notdistinguish commercial rom recreationalsheries. To determine how many have

observer coverage, we cross-reerenced lists

o sheries compiled in the National ObserverProgram Annual Report (2008), the nationalbycatch report (2004), the annual MMPAand ESA lists o sheries, as well as regionalFMPs and other management documents.

All told, based on our comparison oactively managed target sheries to the listo sheries covered by observer programsin the 2008 National Observer Programannual report, we estimate that nearly 200sheries were not covered by observers orhad negligible (


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Although individual sheries will have dierent observer coverage requirements, at present thesecoverage requirements are not clearly quantied ormost sheries in most regions. Target observer

coverage levels have historically been based on bycatchor discard monitoring goals, and rarely on othermanagement goals. Target coverage levels generallyhave notrefected the demands or accurate and timelydata on total catch created by the new ACLrequirements or by individual vessel or sector quotas ina catch share program. Based on our analysis, using amore common management denition o shery, morethan hal o the nations approximately 350 sherieshave no observer coverage at all (See inset, page 12).O those that do, many do not have adequate coverageto meet specic management objectives or catch and

bycatch accounting as well as compliance monitoringand scientic inormation or management. A systematicanalysis o catch monitoring needs or each shery isnecessary to determine the coverage levels required toachieve management objectives. Target observercoverage requirements should be established or eachshery and observer deployment prioritized or sheriesthat lack adequate observer coverage.

Expanding Observer Coverage: How Much Will It Cost?

Based on internal budget recommendations prepared by NMFS in 2003, the agency projectedthe need or an additional $100 million above the FY 2003 unding level by 2009 to meet theNMFS bycatch monitoring objectives.46 Recent Congressional appropriations have rangedrom $32-41 million or NMFS observer programs ar short o the projected need. Althoughdeterminations o adequate observer coverage and costs will vary by shery and region, ouranalysis indicates that observer program unding will need to increase signicantly in uture

years to keep pace with the demand or timely, high-quality sheries data.

To estimate how much more unding is needed, we used an approximate average cost estimateo $1,200 per observer day at sea47 and projected the cost o achieving higher levels o coveragein sheries that currently require at-sea monitoring. Observer coverage targets o 10%, 20%,

30% and 50% were selected or purposes o illustration. Based on this analysis (Table 3, page14), it could cost approximately an additional $70 million above current unding to bring allcurrently observed sheries up to a level o at least 20% coverage.48 In addition, it could costat least $15.5 million to bring sheries identied by NOAA as having no coverage or minimalbaseline coverage in the 2004 bycatch report up to the next level o coverage, generally 0.5%to 2% coverage.46 This cost estimate does not account or the levels o observer coverageneeded in sheries to manage catch share programs or annual catch limit (ACL) requirements.


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Table 3. Summary o sea days observed and total unding by region or 2008, andprojected costs o scaling up observer coverage(1)

Region

2008actual

sea daysobserved2

2008 totalfundingamount3

Additional cost scaling up to

10% 20% 30% 50%

(in $ millions) (in $ millions) (in $ millions) (in $ millions) (in $ millions)

Northeast 13,208 14.1 7.3 - 9.5 30.5 - 34.7 53.7 - 60.1 100 - 110.6

Southeast 4,593 6.5 12.2 28.2 44.7 77.8

Southwest 329 0.6 NA 0.1 0.3 - 0.4 0.7 - 0.8

Northwest 4,596 5.9 NA 0.7 - 13.7 1.5 - 23.5 4.7 - 40.7

Pacifc Islands 9,739 5.7 NA 0.4 4.8 13.5

Alaska 39,000 18.8 NA NA NA NANational NA 1.5 NA NA NA NA

Total 71,465 53.1 19.5 - 21.7 59.9 - 77.2 105 - 133.3 196.8 - 243.5

1 Based on National Observer Program report or FY 2008. Totals may not sum due to rounding. Projectedcosts calculated using an averaged total cost o $1,200 per observed day at sea. These costs includeadministration, training, costs associated with deployment (including travel, insurance and observer wages),and data management.

2 The total number o days in each shery is not currently published by NMFS. We calculated the number odays or each shery using the number o sea days observed and the percentage o days at sea covered.The percentage coverage is expressed as a range in a number o sheries, resulting in estimates oadditional cost that are also expressed as a range.

3

Funding includes ederal appropriations and any industry unding.

While there is a need to ensure that shery monitoring requirements are met in all sheries,limitations in unding may require NMFS to prioritize sheries or expanded observer coveragebased on a needs assessment. In regions and sheries that have had persistently low observercoverage rates, relatively small increases in unding or targeted sheries could result insignicantly higher coverage and improvements in the quality and precision o inormation ormanagement. The Gul o Mexico ree sh shery observer program, or example, covered onlyabout 1% o shing trips in 2008, but coverage could be increased 10-old with an investment o

less than $5 million annually.50

While being the best method or monitoring bycatch, observer programs can also be costly.

Cost reductions may come rom internal program eiciencies or by using lower cost monitoringmethods where available and appropriate (see inset, page 15). A Department o CommerceInspector-Generals review o the NMFS observer program in 2004 suggested that it may bepossible to decrease observer training costs through reducing sta turnover, standardizingtraining materials and consolidating training centers.51 Fisheries with higher levels o coveragealso tend to have a lower cost per day observed, which indicates that it is possible to achieveeconomies o scale.52


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Alternatives to Observers:Electronic Monitoring

Electronic monitoring (EM) showspromise as a cost-eective way osupplementing monitoring by at-seaobservers. These systems can bedeployed on shing vessels to monitorshing location, catch, catch handling,shing methods, and protected speciesinteractions. Vessel monitoring systems(VMS) are already widely used to transmit

inormation about vessel position duringshing trips, providing a cost-eectiveway to monitor compliance with seasonaland area closures. Other orms o EM,particularly video-based monitoring, havebeen touted as a cheaper alternative toat-sea observers but their applicationis limited thus ar. Video monitoring, inconjunction with port sampling o thecatch, can be used to monitor compliance

in sheries where vessels are requiredto retain all catch at sea. One example othe use o video monitoring in conjunctionwith port sampling is the shore-basedWest Coast hake electronic monitoringprogram, which is estimated to costone-quarter or less o deploying at-seaobservers.54 Not everyone agrees withthese cost estimates. In addition, thecost structure or EM is dierent thantraditional observer programs involvingrelatively high up-ront equipment costsbut lower daily operating costs. The useo electronic monitoring technologieswarrants more attention, but there are anumber o considerations that could limitits expansion in the short-term. WhileEM can serve a similar role to that o anat-sea observer, trained observers cannotbe replaced by EM or tasks such asbiological sampling and, in many cases,species identication.

4.Improving Recreational Fisheries Data Collection andData Quality: MRIP and BeyondMarine recreational sheries contribute an estimated $80 billion annually to the U.S. economy,including expenses related to travel, ood, lodging, purchase o gear, and boat rentals.55 While

recreational sheries represent a small percentage o total U.S. marine shery landings annually,saltwater anglers are a signicant source o shing mortality or many marine species and betterassessment o that mortality is required or successul management o those species.56 Despitetheir oten sizeable economic and biological impacts, however, much less data are collectedrom recreational sheries than commercial sheries.57


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Existing sources o unding or recreational sheries data collection are inadequate. The 1984Wallop-Breaux Amendment to the Sport Fish Restoration Act o 1950 established an AquaticResources Trust Fund that distributes as much as $250-400 million annually to the states

rom an excise tax on shing tackle and motorboat uel but data collection is not one o theobjectives o the Fund. The Marine Recreational Fisheries Statistics Survey (MRFSS) is theprimary recreational shery data collection system or ederally managed sheries, but theprogram has long been criticized as inadequate. In 2006, the National Research Council (NRC)issued a report calling or a major overhaul o the MRFSS program to address data qualityissues.58 The MSA was amended in 2006 to (1) implement a regionally based registry programor recreational shermen in each o the 8 shery management regions, and (2) improve thequality and accuracy o inormation generated by the Marine Recreational Fishery StatisticsSurvey (MRFSS).59 The revamped program, known as the Marine Recreational InormationProgram (MRIP), establishes a regionally based saltwater registry and data collection programor recreational shermen with the goal o achieving acceptable accuracy and useulness oMRFSS data or each individual shery.60

The Omnibus Appropriations Act o 2010 includes $9 million in total unding or MRIP, wellshort o the estimated $20 million per year needed to ully implement the MRIP and expandthe National Registry to state and ederal waters.61 However, the MRIP is not designed with theintent o providing timely in-season data needed to prevent recreational sheries rom exceedingannual catch limits. While the deployment o observers on board individual recreational shingvessels is not generally easible, dockside sampling o catches could be expanded. In addition,the expanded use o VMS, electronic logbooks and other electronic technologies may providecost-eective ways to obtain more real-time recreational data or management and stockassessments. New or additional unding and changes in MRIP will be needed to establish suchan inormation collection system. The amendments to the MSA o 2006 (16 U.S.C. 1891b)authorized the establishment o a new Fisheries Conservation and Management Fund which

could be used or this purpose.

5.Observer Service Delivery Models: Getting ProgramDesign RightMost U.S. observer programs currently operate in a system in which NMFS, using ederal dollars,contracts directly with observer providers to recruit and deploy observers as well as coverinsurance and other costs associated with data collection. The North Pacic GroundshObserver Program (NPGOP) and the At-Sea Pacic hake shery o the West Coast use adierent approach in which the shing industry makes direct payments to observer providercompanies and provider companies are under no contractual obligation to NMFS. The least


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common approach is or NMFS to contract directly with an observer provider, with unds to payor observer days collected rom industry. This has been the case or the Atlantic sea scallopshery, where vessels assigned an observer are allowed to increase the catch amount to oset

the cost o deploying the observer.

The preerred approach is or NMFS, as theclient, to contract directly with the observerservice provider. That way NMFS is ableto set out perormance criteria and directlyoversee contractor perormance, ratherthan through the passing o regulations ina lengthy and diicult FMP amendmentprocess at the regional shery managementcouncils. In addition, a system o industryees will be critical to achieving adequate

levels o coverage in many cases. Existinglegal mandates in the MSA authorize theestablishment o a system o industry eesto pay the cost o deploying observers andother orms o sheries monitoring, undercertain circumstances. However, they havenot been implemented in any region atpresent (see inset).

Observer Program Design Issues:the Alaska and Northeast Regions

Program design has become a ocalconcern in some regions, most recentlyin the Alaska Region and the NortheastRegion. The issues raised in each regionhighlight the need or consistency withnational standards in which NMFS hasdirect oversight o the perormance oobserver provider companies throughcontractual agreements and science-based sampling protocols are establishedto achieve statistically reliable data.

NMFS, working with the regional sherymanagement councils, should establishtarget observer coverage levels oreach shery and develop options orimplementing an equitable system oindustry ees to ensure that unding isadequate to achieve target coverage levels.

MSA authority to collect user eesor observer costs

MSA 304(d) (16 U.S.C. 1854(d))authorizes the collection o ees (not toexceed 3% o the ex-vessel value o shharvested) to recover the direct costso management, data collection and

enorcement o sheries in LAP (catchshare) programs.

MSA 313 (16 U.S.C. 1862) authorizesthe establishment o a sheries researchplan or any shery under the North PacicFishery Management Councils jurisdictionwhich requires observers to be stationedon shing vessels and sh processors orthe purpose o collecting data necessaryor the conservation, management, andscientic understanding o any sheries

under the Councils jurisdiction, as wellas system o ees to pay or the cost oimplementing the plan.

Sec. 208 o the MSA reauthorizationo 2006 (16 U.S.C. 1891b) establisheda new Fisheries Conservation andManagement Fund whose purposesare, among other things, to improveshery harvest data collection, includingexpanding the use o electronic catchreporting programs and satellite tracking

systems such as VMS on small vessels;and improving data collection under theMarine Recreational Fishery StatisticsSurvey (MRFSS).


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Restructuring the North Pacifc Groundfsh Observer Program

The North Pacic Groundsh Observer Program (NPGOP) is the largest shery observerprogram in the country, and is unique in that industry unding accounts or nearly three-quarterso total unding.62 Under the current NPGOP, observer coverage levels are established byregulation, with 30% coverage o shing trips or vessels >59 eet in length and 100% coverageor vessels >124 eet in length. NMFS receives ederal appropriations to pay or the overalladministration o the program, including the training and debrieng o observers and themanagement o the data. The shing industry is responsible or making arrangements with oneo the certied observer service providers or placement o NMFS-certied observers and orpaying the contractors or direct observer costs. Although the NPGOP provides wider coveragethan any other program in the nation, longstanding problems in the structure and delivery o theprogram disadvantage owners o smaller vessels (who pay a higher percentage o their earnings

on observer costs) and could lead to biased data and conficts o interest.63

Concerns about data quality arising rom this model prompted NMFS to contract an independentreview o the NPGOP by MRAG Americas in 2000, which concluded that the service deliverymodel o the NPGOP should be avoided and recommended that the program be restructured.64A U.S. Department o Commerce Inspector Generals report in 2004 reached similarconclusions, nding that NMFS lacks control over deployment o observers in the 30% feet,that potential biases in vessel selection could jeopardize the statistical reliability o catch and

bycatch data, and that the program lacks an adequate perormance monitoring and reportingprocess o observer provider companies.65

The North Pacic Fishery Management Council and NMFS are currently proposing to restructurethe program in accordance with the objectives o the research plan outlined in MSA 313 (16 U.S.C. 1862) (see inset, p. 17). The main dierences rom the current program model would include:(1) a shit rom a regulatory to science-based observer deployment, based on a determination


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o statistical reliability by NMFS; (2) NMFS would be the entity responsible or contracting orobserver coverage rather than the vessel owner; (3) the program would establish an industryee based on ex-vessel value o unprocessed sh, which is more equitable to smaller vessels;

(4) all unds collected would be used to pay or the direct costs o the deployment o observers;and (5) all vessels in the groundsh feet would pay into the und. Importantly, the proceedsrom the industry ee would not replace the ederal contribution through the NPGOP: undera restructuring plan, NMFS would continue to assume its current responsibilities, which areessential to data quality control.

The Proposed Northeast At-Sea Monitoringand Dockside Program

The Northeast Region is proposing a new Northeast

Fisheries At-Sea and Dockside Monitoring Programas part o the implementation o Amendment 16 tothe Northeast Multispecies FMP. The plan wouldmake industry responsible or meeting its monitoringneeds and, presumably, contracting directly with anobserver service provider. The plan also includes thepotential use o at-sea monitors with lower eligibilityrequirements and less training than NMFS-certiedsheries observers. While there could be cost savingsrom reduced training and data collection, thiscould be oset by poorer quality data. Past use oinadequately trained shery monitors has generally

not been a success.66

The proposed Northeast At-Sea and DocksideMonitoring program design is similar to the fawedNorth Pacic groundsh observer program in at leasttwo important ways. First, the shing industry wouldbe responsible or making arrangements with third-party observer service providers and or paying thecontractors or direct observer costs related to deployment at sea an arrangement that haslimited NMFSs ability to set perormance standards or companies in the North Pacic. Second,at-sea monitoring levels do not appear to be based on any statistical protocol and docksidemonitoring o landed catches would be capped by regulation at only 20% o shing trips ater

2010.

The problems with the proposed design o the Northeast monitoring plan underscore the needor national program standards that are consistent among regions and provide perormance-based criteria or achieving the goals and objectives o management or each shery.


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6.Summary Findings and Recommendations

Sustainable sheries management in the 21st century requires timely, reliable sheries dataand eective monitoring o sheries in order to make inormed, responsible decisions. Thedeployment o at-sea shery observers is a central pillar o the National Bycatch Strategy, andthe 2006 amendments to the MSA added new requirements or annual catch limits (ACLs) andauthorized the expanded use o limited access privilege (LAP) programs, popularly known ascatch shares, all o which will increase the need or sheries inormation provided by at-sea anddockside observers.

Reliable fsheries inormation provided by trained fshery observers is essentialto manage bycatch, develop and update stock assessments, implement annualcatch limits (ACLs) and monitor catch share programs. While vessel sel-reporting is commonly required, the reliability o sel-reported inormation is uncertain.Electronic monitoring (EM) technologies can supplement observers but are unlikelyto substitute completely or observers. Observers are the only independent source or

some types o sheries inormation, such as species composition o bycatch, discardsat sea, and interactions with other marine species.67

More than hal o all U.S. fsheries assessed or observer coverage by NMFShave no observer coverage at all, and nearly three-quarters have minimal pilot-level coverage or no coverage. Barely one-quarter o sheries assessed or bycatchin 2004 have adequate or near-adequate coverage today. A majority (51%) o U.S.sheries have not even established pilot-program coverage levels to collect baselineinormation so that statistically robust sampling plans can be developed, and nearlythree-quarters (73%) have little or no coverage at present.

Although individual fsheries will have dierent observer coverage requirements,

at present these requirements are not clearly quantifed or most fsheries inmost regions. Although many regions currently lack the data-collection and monitoringinrastructure to account adequately or catch and bycatch, many also lack specictarget coverage levels and have not conducted systematic analysis o catch monitoringneeds to determine the coverage levels needed to achieve management objectives.

Key Findings


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A combination o increased ederal unding and new sources o industry undingwill be needed to meet observer needs in the coming years. Our analysis showsthat program unding will need to increase signicantly in uture years to keep pacewith the demand or high-quality shery data. Direct ederal unding will be necessaryto oversee program administration and ensure data quality, but industry unding o thecosts o deploying observers, including travel costs, days at sea and insurance, is alsonecessary i signicantly higher coverage levels are to be achieved.

Relatively small increases in unding or expanded observer coverage intargeted regions and fsheries with very low levels o observer coveragecould produce large gains in observer coverage and data quality. Even limited

increases in unding could benet regions with low levels o observer coverage andlarge numbers o sheries, such as the Southeast and Mid-Atlantic regions. The Gulo Mexico ree sh shery observer program, or example, covered only 1% o shingtrips in 2008, but coverage could be increased 10-old with an investment o less than$5 million annually.

NMFS needs to have direct oversight o regional observer programs andcontract directly with observer service providers in order to ensure that ahigh standard o data quality and observer conditions are maintained. Externaland internal reviews o NMFS observer programs have highlighted issues withvessel selection and bias, retention o experienced observers, and disproportionatecost issues among various sectors o shing feets. Improved agency oversight o

observer provider companies through perormance-based contractual agreements willenable NMFS to address these concerns directly, rather than through the passing oregulations.

Key Findings (cont.)

Recommendation #1:

Establish target observer coverage requirements or each fshery and

prioritize observer deployment or fsheries that lack adequate observercoverage.

NMFS should produce an updated list o sheries identiying those with adequate observercoverage and a priority list o sheries in need o observer coverage and other orms osheries monitoring, including estimates o the resources required or expanded coverage.


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All eight regional shery management councils should work with NMFS to establish targetobserver coverage goals adequate to achieve management objectives or each ederallymanaged shery, and develop plans with specic timelines or achieving those goals.

NMFS should work with state agencies to establish target coverage levels or state sheriesthat interact with protected species (marine mammals and ESA-listed species).

Recommendation #2:

Increase ederal unding to support expanded observer coverage, ensure

data quality, and improve national coordination.

Congress should signicantly increase ederal unding or the NMFS Observer Programs romcurrent levels o $41 million in FY 2010 to at least $60 million in FY 2011 in order to support thegrowing demand or increased levels o observer coverage in FY 2011.

Increases in ederal unding will be needed beyond 2011 to keep pace with the demand ordata and provide overall administration o programs in uture years.68 Our ndings indicate thatit could cost approximately an additional $70 million above current unding to bring all currentlyobserved sheries up to a level o at least 20% coverage. Additional unding would be requiredto extend observer coverage to sheries which are not currently observed.

Recommendation #3:

Identiy appropriate industry unding mechanisms to cover the direct costo deploying observers and other monitoring systems.

All eight regional shery management councils should work with NMFS to establish equitableindustry-unded mechanisms to support expanded observer coverage, such as a user eebased on the ex-vessel value o sh landed.

The MSA authorizes the establishment o ees to pay or the cost o deploying observers andother monitoring systems to collect data in several provisions relating to limited access privilege(LAP) programs, North Pacic Research Plan, and a Fisheries Conservation and Management

Fund.69 However, a specic amendment to the MSA may be needed to ully implement industryunded observer programs.


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Recommendation #4:

Standardize regional observer program design and ensure that NMFS

contracts directly with observer service providers to oversee the

perormance o the companies through their contractual obligations.

NMFS, working with the shery management councils, should address observer programdesign issues including vessel selection and bias, retention o experienced observers, anddisproportionate cost issues among various sectors o shing feets.70

Recommendation #5:

Consider cost-eective alternative monitoring approaches such aselectronic monitoring or use as a supplement to observer coverage whereappropriate.

Alternative monitoring techniques such as electronic monitoring should be evaluated or useas a supplement to at-sea observers where appropriate. Vessel monitoring systems (VMS)technology are already widely used to transmit inormation about vessel position during shingtrips, providing a cost-eective way to monitor compliance with seasonal and area closures.Other orms o electronic monitoring, such as video-based monitoring, can also be used (inconjunction with port sampling o the catch) to monitor compliance in sheries where vesselsare required to retain all catch at sea.

Recommendation #6:

Establish an inormation collection system to provide timely and accurate

catch data to manage recreational fsheries in compliance with the MSArequirements or annual catch limits.

Fully implementing the Marine Recreational Inormation Program (MRIP) and expanding theNational Saltwater Angler Registry to state and ederal waters will help to increase the amount

o recreational shery inormation available to decision-makers. However, MRIP is not presentlydesigned to provide more timely in-season data needed to manage recreational shing quotasin-season to prevent the sheries rom exceeding annual catch limits, rather than learning ooverages months ater the shing season has closed. Alternative data collection methods areneeded.


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In recreational sheries with larger commercial charter boats and headboats, deployment oobservers may be easible as a way to provide data on catch, bycatch and discards. In sherieswhere deployment o at-sea observers is not practical, expanded use o video monitoring

equipment, electronic logbooks, and dockside sampling o landings should all be considered.

Recommendation #7:

Maintain public access to fsheries observer data to ensure that fsheries

management decisions are made in a manner consistent with public trust

management o the nations marine resources.

Section 402(b) o the MSA addresses condentiality o sheries inormation and the existingrules at 50 C.F.R. 600.405-425 permit public access to observer data and other sheriesstatistics where the identity o individual vessels or other inormation is not disclosed. Pendingrevisions to the NMFS regulations on condentiality o sheries statistics must ensure that therevised rules continue to support public access to sheries observer data and other sheriesinormation.


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Endnotes

1 The U.S. Commission on Ocean Policy. An Ocean Blueprint or the 21st Century. Final Report. Washington, D.C.,2004. See pp. 274-304.

2 U.N. Food and Agriculture Organization (FAO). State o World Fisheries and Aquaculture, 2008 United Nations,Rome, 2009. 176 pp. Overall, 80% o the world sh stocks or which assessment inormation is available arereported as ully exploited or overexploited, and the maximum wild capture sheries potential rom the worldsoceans has probably been reached.

3 Boris Worm et al. Impacts o Biodiversity Loss on Ocean Ecosystem Services. Science 314 (2006): 787-790. Ithe trends in overshing are not reversed by policies to curb shing mortality and protect ocean biodiversity, it ispossible that most major sheries could be commercially extinct by mid-century.

4 See Magnuson Stevens Fishery Conservation and Management Act (16 U.S.C. 1801 et seq.).

5 NOAA/NMFS, Evaluating Bycatch: A National Approach to Standardized Bycatch Monitoring Programs, NOAATechnical Memorandum NMFS-F/SPO-66, October 2004. 108 p.

6 See the U.N. FAO, Code o Conduct or Responsible Fisheries (1995). See Articles 7.7.3; 8..4.3. Available at: tp://

tp.ao.org/docrep/ao/005/v9878e/v9878e00.pd.7 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.

8 NOAA/NMFS, National Observer Program FY 2008 Annual Report (2009). 30 pp.

9 See Presidents FY 2010 Budget Request, Congressional Submission, Exhibit 13, p. 245.

10 NOAA/NMFS, Evaluating Bycatch (2004).

11 Based on our comparative analysis o the NMFS national bycatch report o 2004 and more recent unpublishedagency updates.

12 National Standard 9 (NS9) o the MSA requires shery managers to minimize bycatch and to minimize themortality o bycatch that cannot be avoided (16 U.S.C. 1851(9)). Section 303 o the MSA requires FisheryManagement Plans to establish a standardized reporting methodology to assess the amount and type o bycatchoccurring in the shery, 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.nms.noaa.gov/st4/nop/Outreach/NOPFactSheet_FINAL.pd.

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 o the MSA requires thatconservation and management measures minimize bycatch or the mortality o such bycatch that is unavoidable.

17 16 U.S.C. 1851(a)(1). National Standard 1 o the MSA stipulates that conservation and management measuresshall prevent overshing while achieving, on a continuing basis, the optimum yield rom each shery. See also 16U.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 species that a LAP program must include an eective system orenorcement, monitoring and management o the program, including the use o observers or electronic monitoringsystems.

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.


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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.nms.noaa.gov/st4/nop/Outreach/NOPFactSheet_FINAL.pd.

27 National Marine Fisheries Service (NMFS), Proposed rule or 2010 Annual Determination or Sea Turtle ObserverRequirement, 75 Fed. Reg. 59508-59519, November 18, 2009.


29 NOAA/NMFS, Evaluating Bycatch (2004).


31 NMFS personal communication.

32 See Recommendations rom the Summary Report o 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.nesc.noaa.gov/sb/SBRM%20Annual%20Discard%20Report/2009_Prioritization_response_to_comments.pd

34 Fisheries with signicant industry unding include the Alaska groundsh sheries, the at-sea sector o the West

Coast Pacic hake shery, and the Atlantic sea scallop shery.35 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 Section316(d) o the MSA as reauthorized and amended by the MSRA o 2006 (2009).

39 NOAA/NMFS, Evaluating Bycatch ( 2004), Tables 4.1-4.6 and Table 5. The observer coverage classicationsused were mature, developing, pilot, and baseline. For simplicity, we assumed that the levels mature anddeveloping are equivalent to the current classications o adequate and near adequate.

40 NOAA/NMFS, Evaluating Bycatch (2004), Table 5, p. 75.

41 Based on Presidents FY 2010 Budget Request, Congressional Submission. Exhibit 13, p. 245, personalcommunications with NMFS, and independent comparative analysis o NMFS national bycatch report o 2004 and

more recent unpublished updates.

42 Elizabeth A. Babcock, Ellen K. Pikitch, and Charlotte Hudson, How Much Observer Coverage Is Enough toAdequately Estimate Bycatch? Pew Institute or Ocean Sciences (2003).

43 S.E. Wigley, P.J. Rago, K.A. Sosebee, and D.L. Palka, The Analytic Component to the Standardized BycatchReporting Methodology Omnibus Amendment: Sampling Design and Estimation o Precision and Accuracy (2ndEdition), U.S. Dep. Commerce, Northeast Fisheries Science Center Reerence Document 07-09, May 2007. 156 p.

44 Babcock et al. Pew Institute or Ocean Sciences (2003).

45 Lawrence Beerkircher et al., Pelagic Observer Program Data Summary, Gul o Mexico Bluen Tuna SpawningSeason 2007 and 2008, NOAA Technical Memorandum NMFS-SEFSC-588, April 2009. 33 p.

46 NOAA/NMFS, NOAAs National Marine Fisheries Service Requirements or Improved and Integrated Conservationo 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 unding o ~$51 million in combined ederal and industry unding in FY 2010.

49 Based on the cost o bringing all sheries listed in the NMFS (2004) Evaluating Bycatch report as havingbaseline (


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50 Costs o deploying observers on 10% o shing trips could range rom $1.68 million to $4.76 million, dependingon assumed costs. Current pro rata cost o deploying observers per day at sea in the Gul ree sh shery is $425.Our estimate is based on assumed national average cost per day at sea o $1,200.

51 U.S. Dep. o Commerce (USDOC), Oice o Inspections and Program Evaluations, National Oceanic andAtmospheric Administration: NMFS Observer Programs Should Improve Data Quality, Perormance Monitoring,and Outreach Eorts. Final Audit Report No. IPE-15721, March 2004. 64 pp.

52 These include the Hawaii Pelagic Longline Fishery (20% tuna, 100% swordsh coverage); North PacicGroundsh Fishery (100% vessels over 120, 30% vessels 60-120, 0% under 60); the At-Sea Hake Mid-WaterTrawl 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 ElectronicMonitoring. Archipelago Marine Research Ltd. Prepared or: NMFS Electronic Monitoring Workshop, Seattle, WA,29-30 July 2008.

55 NOAA/NMFS, Fisheries Economics o the United States 2006: Economics and Sociocultural Status and Trends.166 p. Available at: http://www.st.nms.noaa.gov/st5/index.htm.

56 National Research Council (NRC), Committee on the Review o Recreational Fisheries Survey Methods, Review

o Recreational Fisheries Survey Methods, Executive Summary: http://books.nap.edu/catalog/11616.html.57 The U.S. Commission on Ocean Policy, An Ocean Blueprint or the 21st Century, Final Report, Washington, D.C.,

2004. See pp. 274-304.

58 National Research Council (NRC), Review o 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 andTable A2. Industry unding totaled approximately $13 million out o $18.4 million in unding in 2008.

63 National Marine Fisheries Service (NMFS), Drat Observer Restructuring Implementation Plan, February 2010.

64 MRAG Americas, Independent Review o the North Pacic Groundsh Observer Program, Prepared by MRAG

Americas, Inc., May 2000. 120 pp.65 USDOC, Oice o Inspections and Program Evaluations, March 2004.

66 USDOC, Oice o Inspections and Program Evaluations, March 2004.


68 In 2003, the agency projected the need or an additional $100 million above the FY 2003 unding level by 2009to meet the National Observer Program bycatch objectives. See: NOAA/NMFS, NOAAs National Marine FisheriesService Requirements or Improved and Integrated Conservation o Fisheries, Protected Resources and Habitat,January 2003.

69 See: MSA 1854(d), 1862, 1891b.



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Meeting the Information Demands of 21st Century Fisheries: A Needs Assessment for Fisheries Observer Programs