Aliance of Communities for Sustainable Fisheries
P O Box 1309, Carmel Valley, CA 93924 (831) 659-2838

April 1, 2003

The Honorable Dede Alpert
California State Senate
State Capitol
Sacramento, CA 95814

Re: SB 236

Dear Senator Alpert:

The Alliance of Communities for Sustainable Fisheries represents fishermen and ports off the California Coast wish to comment on SB 236 and put the fishing practice of trawling into its proper context.

Trawling is not a new fishing technique in the world or off of the California coast. Europeans have been trawling in the Atlantic Ocean for hundreds of years, while trawling began in California in 1876. Trawl gear is a very efficient method of harvesting fish and allows the production of seafood at reasonable prices.

The use of trawls has long been attacked by other fishermen. In 1948, W.L. Scofield wrote in the California Fish and Game Bulletin No. 72, "The other methods of fishing cannot compete successfully with trawling, hence the hatred of trawling through the years and the bitter denunciations heaped upon the trawl."

The simple fact is that trawls can catch more fish than other gears and some fish caught in trawl fisheries can only be caught using trawl gear. If the consumer wishes to enjoy fillet of flatfish sole, salad shrimp, or prawns then trawl gear must be used. We need trawls to catch the amount of fish needed by local communities. For some stocks, trawl is the only economically viable method of fishing.

Over the past decades, as fishery managers began to more intensely regulate all fishing activity, quotas were set. In some cases these quotas were allocated between the various gear groups and between commercial and recreational fishermen. Once again trawlers found themselves under attack. This time however, their attack motive was to better position themselves for increased allocations of fish that are caught by trawlers and other users. This practice of trawl bashing generally took the form of making outrageous claims of bycatch and waste. The intent was to smear trawlers in the eyes of regulators so that trawling would be viewed with disfavor and these fish that trawlers caught would be made available to anther user group. In response, the trawl industry on the Pacific Coast participated in several studies to document the level of bycatch. These studies demonstrated that the amount of fish caught and not retained was much lower than attackers would like to believe and in fact the majority of fish caught and discarded was directly related to the regulations themselves, by cutting back on fish retention.

There are a number of definitions of bycatch. But, generally these focus on fish that are caught and not part of some ill-defined concept of target species. The fact is, when fishermen go fishing, they would like to keep everything that they catch, however, very often regulations require fish may not be retained and mandates it be discarded.

Last summer the Department of Fish and Game prepared a report concerning the
catch of rockfish and other groundfish in the state managed trawl fisheries. Unfortunately, because of how this data was sorted and then aggregated, not all of their work is useful. For example, the data was sorted for all landings that contained California halibut, this resulted in including those landings by fishermen who fish for groundfish that also legally landed a California halibut. To be useful the data should have been sorted one more time, removing the deliveries of fishermen fishing with Federal groundfish permits. Similarly, the data for ridgeback and spot prawn were lumped together even though they are very different fisheries. Since then the spot
prawn fishery has been closed by Fish and Game Commission. [Emphasis added]

Fortunately, the data was useful for the Ocean (Pink) shrimp and Sea cucumber fisheries. In both cases the amount of rockfish or groundfish caught was less than 1%. The shrimp fishery requires the use of fin-fish excluders. These devices are so effective at releasing any fin-fish that the Oregon Department of Fish and Wildlife in their 2003 Annual Pink Shrimp Review stated that the Pink shrimp fishery is one of the cleanest fishing trawl fisheries in the world. Some fishermen in the Pink shrimp fishery are
talking about petitioning for Marine Stewardship Council Certification.

CONTINUED