The 1989 North Pacific Joint Observer Program

Introduction In 1989, following a mandate from the U.S. Congress as required by the Driftnet Impact Monitoring, Assessment, and Control Act 1987, agreements were concluded with Japan, Korea, and Taiwan to initiate a pilot program to jointly monitor the commercial driftnet fleets in the North Pacific. Japan agreed to place nine United States and five Canadian observers on board 14 of its commercial squid driftnet vessels during the 1989 season (Japan/US Agreement 1989). Only 4% of the Japanese fleet was covered. Agreements with the Republic of Korea and Taiwan were concluded too late to implement a foreign observer program for 1989. ROK agreed to deploy "at least 13" United States observers on board its "commercial driftnet vessels for at least 45 days each to observe 45 or more driftnet retrievals on each vessel" (ROK/US Agreement 1989). Taiwan agreed only to deploy "observers of the parties ... aboard commercial driftnet vessels ... for at least 30 days to observe 30 or more driftnet retrievals on each vessel" (AIT/CCNAA Agreement 1989). The 1989 pilot program placed one U.S. observer on one Taiwanese squid driftnet vessel.

Methods Data from the joint Canadian-Japan-United States observer program were collected between early June and early October 1989, by observers on board commercial Japanese driftnet vessels chosen by lot fishing between 170 deg E and 145 deg W, and between 36 and 45 deg N.

Results The results were released on June 30, 1990 (Joint Report 1990). In summary, 1,402 operations were observed involving 1,427,225 tans of net (50 meters each). The catch included 3,119,061 neon flying squid, 914 dolphins, 22 marine turtles, 9,173 seabirds, and 1,580,068 non targeted fish, including 79 salmonids, 1,433,496 pomfrets, 59,060 albacore, 10,495 yellowtail, 7,155 skipjack, and 58,100 blue sharks. (Table 7) The data did not indicate the percentage of the huge incidental catch of assorted fishes actually brought on board and kept. By-catch from the 1989 squid driftnet observer program included birds from at least five species listed in the Annex to the Migratory Bird Convention of 1972 (Japan and the United States are parties), including 331 Laysan albatrosses, 38 northern fulmars, 20 horned puffins, five tufted puffins, and 17 Leach's storm petrels.

The 1990 North Pacific Joint Observer Program

Introduction In August 1989, Taiwan and the United States agreed to establish a joint program for 1990 that included verification by Taiwan that its vessels were complying the agreed regulations, and placed 14 U.S. and 10 Taiwan observers on board 24 Taiwanese driftnet vessels. In October 1989, the Republic of Korea and the United States concluded an agreement for the 1990 season that placed 13 U.S. and 13 Korean scientific observers on board 26 Korean Squid driftnet vessels in 1990 and provided that verification of Korean compliance with agreed fishing regulations would be done by the U.S. Coast Guard. In April 1990, Canada, Japan, and the United States concluded a monitoring agreement for the 1990 season that provided: (1) 25 U.S., 10 Canadian, and 29 Japanese scientific observers would be placed on 74 squid vessels to monitor 4,380 operations, (2) 12 North American and 12 Japanese scientific observers would monitor the operations of 24 large-mesh driftnet vessels, and (3) seven North American scientists would participate in four research cruises in the squid driftnet fleet and one in the large-mesh driftnet fleet.

The Japanese Squid Fishery - Methods Observer data collection methods were essentially the same in the squid and large-mesh driftnet fisheries. Data collected included the catch of target species, by-catch of nontarget species, environmental and meteorological conditions (sea surface temperature, sea state, wind speed and direction), fishing methods (date, location, direction, and configuration of the driftnet sets, the number of other vessels within 15 nm of the monitored vessels), gear specifications (mesh size, length and depth of a driftnet tan, number of tans per driftnet section, and total number of driftnet sections deployed per driftnet operation) and observed fishing effort (number of tans monitored).
Ten percent of just the Japanese commercial squid driftnet fleet was covered in 1990. Not all sections in an operation monitored by an observer were counted. If ten or more sections were set, seven were monitored; if less than ten were set, only six were monitored. By-catch in the first three sections was never counted. By-catch was only recorded if it was still in the net when the net cleared the water. Therefore, the part of the net that was observed and recorded was the part that had been dragging through the water the longest with the most opportunity for by-catch, dead or damaged and alive, to drop out in the water before being counted. Albacore fishermen have noted that driftnets rarely have albacore in the lower half of the net, even though nets dropped experimentally down two meters do not show any decrease in the catch of albacore. In addition, by-catch entangled in a section not randomly chosen ahead of time to be monitored, was not counted. For rare species or species with a patchy distribution, such as whales, sampling 10% of the fleet in this manner is not sufficient (sample size is too small) to yield reliable by-catch data.

Since the amount of Pacific pomfret and pelagic armorhead caught was very high, not all of these species were counted in the net sections chosen to be monitored. Thus, the total catch of these species was under reported. However, even though the total by-catch of fish was under reported, the data still reveals that for every two flying squid caught (the target species), at least one fish or shark was caught as by-catch. (Table 8) Most of these fish were probably discarded dead or damaged, even though they could have been used to feed humans if they had been caught live by a more targeted and sustainable fishery. Since it took 8 to 14 hours to retrieve the net, most of the tuna by-catch probably had putrefied, since tuna must swim to breath. In some cases the net was so long it was left in the water two days before complete retrieval could be accomplished.

In addition, the data was recorded as numbers of individuals. Since many of the fish caught, such as tuna and shark, grossly out weigh a flying squid, the data indicates that by-catch in gross tonnage is probably equal to the tonnage of the "targeted" species. Such a catch indicates a non targeted fishery.

The Japanese Squid Fishery - Results The results of sampling 10% of only the Japanese squid fleet revealed some appalling numbers. In order to catch 7.9 million neon flying squid, an incidental by-catch was taken that included 3.2 million Pacific pomfret, 379,618 pelagic armorhead, 162,631 skipjack tuna, 90,011 albacore, 81,956 blue shark, 7,595 other sharks, 12,983 yellow tail, 9,747 salmonids and 3,640 ocean sunfish. The number of seabirds totaled 30,464 despite the fleet having fished many hundreds of miles from land. Other by-catch included 3,472 dolphins and porpoises, 22 whales, 545 fur seals and 35 turtles. (Table 8)

The Japanese Squid Fishery - Analysis and Implications The by-catch included a number of protected species such as loggerhead and green turtles, fur seals and whales. Whales are listed as "unidentified cetaceans" in Table 8. An observer reported unofficially that a female sperm whale and infant were caught. Many of the birds caught are protected migratory species listed in the Annex to the Migratory Bird Convention of 1972, including the Laysan albatross, Leach's storm petrels, northern fulmars, horned puffins and tufted puffins.

Total by-catch estimates, based on a harvest of approximately 106 millions neon flying squid, indicate that over 41 million other individuals from over 100 different species were taken (Yatsu and Hayase 1991). The estimated by-catch includes over 39 million fish, over 700,000 blue shark, over 270,000 sea birds, over 141,000 salmon, nearly 26,000 marine mammals and 406 sea turtles. If the total by-catch from the Japanese squid fishery is combined with the by-catch from the squid fisheries of South Korea and Taiwan, the by-catch from the large-mesh fisheries of Japan and Taiwan, and the by-catch from the Japanese land-based salmon fishery, and then adjust for dropout estimates that could raise the total by as much as 50%, the result is staggering.

The Republic of Korea Squid Fishery - Methods Eleven U.S. and 13 Korean observers were actually placed on 24 Korean commercial driftnet vessels in 1990. Fishing vessels were chosen by the Korean Deep-Sea Fisheries Association and the Korean Deep-Sea Squid Gillnet Fisheries Association. Vessels fished in areas selected by the vessel captains. Observers stayed on the vessels one to two months. The commercial ROK squid fleet numbered 142 vessels in 1990.

Of the 13 Korean observers, three monitored all sections of each retrieval, six omitted one or two sections daily, and five observers monitored only half of the sections set. Selection was determined in a non-random way by the individual observer. If the Korean observer helped retrieve the net, catch data was supplied by the captain. The U.S. observers monitored five out of every six days of operation. Catch information from sections not monitored was not recorded. Korean driftnet vessels set 56 long net sections. U.S. observers treated these as 1012 subsections of which they monitored seven. The monitored sections were chosen randomly. U.S. observers also randomly selected two subsections from each operation for dropout monitoring, but selected only among those sections being retrieved when there was some daylight to see by. Squid and pomfret were not counted during dropout monitoring if they were very abundant in order to facilitate species identification. The joint report did not elaborate on the procedures that the Korean observers used for monitoring dropouts.

The Republic of Korea Squid Fishery - Results and Analysis U.S. observers recorded 2,330,763 neon flying squid, 36,975 Pacific pomfret, 15,248 blue shark, 20,664 skipjack tuna, 8,635 bullet tuna, 1,338 albacore, 1,960 pelagic armorhead, 713 seabirds, 316 ocean sunfish, 88 dolphins and 3 turtles. (Table 9) Korean observers recorded 3,044,442 neon flying squid, 15,770 boreal clubhook squid, 164,706 Pacific pomfret, 6,005 blue shark, 26,123 skipjack tuna, 3,430 albacore, 12,070 mackerel, 3,425 mahi mahi, 496 seabirds, 207 ocean sunfish, 27 dolphins and 3 turtles. (Table 10)

Over 336,665 non target fish were recorded taken by the 24 vessels monitored. (Joint Report - Korea 1991) More than 72 different species were observed in the by-catch. Differences in the recorded catch of squid and pomfret by the U.S. and Korean observer teams can be accounted for by differences in methods. The more reliable squid to fish ratio is probably that which compares the counts recorded by the Koreans: one fish for every 14 squid taken. Presumably most was discarded. However, the U.S. observers reported more than three times the number of dolphins killed and two and half times the number of blue sharks taken.

The Taiwanese Squid and Large-Mesh Fisheries - Methods Twelve U.S. observers and nine Taiwanese observers were actually placed on Taiwanese commercial driftnet vessels in 1990. One U.S. observer monitored driftnet operations on two vessels, another was on a vessel which changed from the squid to the large mesh fishery while he was on board (Joint Report - Taiwan 1990). Twelve squid vessels and eleven large mesh vessels were monitored. Observers stayed on board an average of four weeks. There were approximately 138 Taiwanese vessels fishing for squid and 123 vessels fishing for tuna and billfish in the North Pacific in 1990. Observer vessels were chosen by lot and fished in areas chosen by the captain.

Taiwanese observers monitored all driftnet operations, and the entire operation, unless they selected one section not to monitor. Taiwanese gear is deployed in two to four long net sections instead of six to twelve shorter net sections. U.S. observers monitored operations for five out of every six days and treated each long section as three shorter sections. U.S. observers were required to monitor six to seven net subsections during any one net retrieval, depending on the number of sections actually deployed. Observers did not record catch information from operations not monitored. To insure that the by-catch was accurately identified not every squid or Pacific pomfret was recorded by the U.S. observers.

Only dropouts that were still entangled when the net cleared the water were counted. The Taiwanese observers counted dropouts "when possible". The U.S. observers randomly selected two subsections to record dropouts from each set of seven to twelve subsections monitored. Dropouts were not counted in the first three subsections due to darkness.

The Taiwanese Squid Fishery - Results U.S. observer data indicated that in order to catch 1,088,796 squid, 47,248 pacific pomfret, 36,338 skipjack tuna, 6,398 blue shark and 198 ocean sunfish were taken. Other by-catch included 4,116 other fish, 20 other sharks and rays, 139 seabirds, 56 octopus, 9 dolphins, 1 whale, and 1 green turtle. (Table 11) Data recorded by Taiwan observers indicated that a catch of 1,322,305 squid resulted in a by-catch of only 369 pacific pomfret, 20,469, skipjack, 4 blue shark, and 17 ocean sunfish. Other by-catch included 8,072 other fish, 65 sharks, 91 seabirds, 9 dolphins, and one turtle. (Table 12)

The Taiwanese Large-Mesh Fishery - Results U.S. observer data indicated that 54,409 albacore, 39,163 Pacific pomfret, 7,004 skipjack tuna, 5,449 blue shark, 818 ocean sunfish and 841 other tuna and bill fish were taken. U.S. observers recorded as additional by-catch 2,286 other fish, 289 other sharks and rays, 382 squid, 124 dolphins, 10 whales, 34 turtles and 39 seabirds. (Table 13) Taiwan observer data indicated that 98,516 albacore, 607 Pacific pomfret, 5,576 skipjack tuna, 691 blue shark, 187 ocean sunfish and 622 other tuna and billfish were taken. Taiwanese observers recorded an additional by-catch of 8,603 other fish, 2,502 other sharks and rays, 328 squid, 196 dolphins, 42 turtles and 17 seabirds. (Table 14)

The Taiwanese Squid and Large-Mesh Fisheries - Analysis The catch/by-catch ratios obtained by data recorded by U.S. observers and that recorded by Taiwan observers differs markedly in both the squid and large-mesh programs. Presumably it can be attributed to differences in methods and poorly trained Taiwanese observers and not to an intent to minimize the impact of driftnet fishing on non targeted resources. It does indicate the importance of foreign observer coverage.

U.S. data for the Taiwanese squid fleet indicates that 1,088,796 squid were taken by the vessels its observers monitored compared to a by-catch of 94,523 other individuals, for a ratio of 11.5 to 1. Taiwanese data indicates that 1,322,305 squid were taken compared to a by-catch of 29,097 other individuals, for a ratio of 45 to 1. U.S. data for the Taiwanese large-mesh fleet indicates that 62,254 tuna and billfish were taken by the vessels monitored by its observers, compared to a by-catch of 48,595 other individuals, for a ratio of 1.3 to 1. The Taiwan data indicates that 104,714 tuna and billfish were taken compared to a by-catch of 13,173 other individuals, for a ratio 8 to 1. Comparison of the squid fishery and large-mesh fishery catch per units of effort (CPUE) indicates that the large-mesh fishery caught 1820 times more dolphins and 50 times more turtles that the squid fishery.

The 1990-1991 Japanese Large-Mesh Fishery - Methods The Joint Report publishing the results of the 1990 Japanese large-mesh observer program was not submitted until April 10, 1992. It should be noted that the terms of the observer agreements did not mandate that the catch and by-catch data for the previous year be provided before the driftnet fleets left for the fishing grounds the following year. Thus information learned about the status of the stocks could not be factored into any management plan until two years after the data was collected, a time schedule that was and is incompatible with effective management of the resource and resulted in over fishing and enormous risk to the pelagic ecosystem.

Twelve U.S. and 12 Japanese observers were actually placed on board 24 commercial large-mesh vessels between September 1990 and May 1991. The 149 large-mesh vessels licensed by Japan to operate during the 1990-1991 season were divided by the Japan Fisheries Agency into several regional groups and observers were assigned to each group in proportion to the number of licensed vessels in each region. Geographical and temporal observer coverage was not optimized; vessels fished in areas and at times chosen by the commercial fishing masters, who also selected mesh size and type, the number of tans in each section, the total number of sections deployed, depth, and soak time. Net retrieval took eight to twelve hours. Except for one instance when some net sections were left to soak two nights, the nets were deployed for one night only.

Observers were instructed to monitor operations for five consecutive days and take the sixth day off. As with the squid fleet not all sections in an operation monitored by an observer were counted. If ten or more sections were set, seven were monitored; if less than 10 were set, only six were monitored. The monitored sections were chosen randomly. Two of the monitored sections were randomly selected to record the fish dropouts when five or more sections were set. Flying squid, Pacific pomfret, and pelagic armorhead were not counted when these species were so abundant they interfered with dropout monitoring. Accordingly, the number of recorded dropouts for these species is less than actually observed. Dropouts of marine mammals, seabirds, and turtles were recorded in all monitored sections. As with all the other observer programs, "dropouts" were only those animals that emerged from the water still entangled, but fell back into the water before they could be landed. Therefore, the numbers do not include the many that probably came loose from the net as it was being pulled through the water. Dropouts were not counted in the first three net sections due to darkness. During some net section retrievals, dropout monitoring was apparently done in conditions of marginal visibility.

The Japanese Large-Mesh Fishery - Results Catch and/or bycatch of squid and fishes refer to numbers of animals hauled on deck. The bycatch recorded for marine mammals, birds and turtles refer to the total number of animals seen entangled in the net. Small seabird entanglements, especially dropouts, were difficult to see under adverse conditions, so the count was conservative. The results of sampling a portion of the fishing effort of only five percent of only the Japanese large-mesh fleet yielded 252,918 skipjack tuna, 39,425 albacore, 59,863 mahi mahi, 5,133 marlin, billfish and spearfish, 1,945 other tuna and mackerel, 277,458 Pacific pomfret (under reported), 88,592 neon flying squid, 67,516 other fish, 9,137 sharks and rays, 1,241 dolphins, 390 seabirds, 289 turtles, and 82 whales. (Table )

The Japanese Large-Mesh Fishery - Analysis The results indicate that the bycatch in the large-mesh fishery exceeds the catch retained for market. Enormous quantities of food fish were wasted. Several protected and endangered species were taken. The large-mesh nets posed a particular danger to marine mammals and turtles. Since only five percent of just the Japanese fleet took 82 whales, it can safely be assumed that the large-mesh fleets in the aggregate probably killed thousands each year. In addition, the sampling methods provided for too much opportunity for the vessel master to skew the results, since he had control over location and time of deployment. As a result, the sampling was neither random nor systematic; it was also quite small. In 1990, the Japanese large-mesh fleet numbered 459 vessels. The Joint Report contains the results from only 23 observers monitoring a portion of their vessel's nets effort for an average of 56 days. Furthermore, since sunrise normally began well after retrieval began, dropouts could not be monitored during the early portion of retrieval. Since those sections that were monitored for dropouts were those sections that had been dragged through the water the longest, the actual dropout rates probably were much higher than those recorded. Finally, the Report indicates that on some days retrieval began around midnight, meaning that dropouts from those settings could not be monitored at all.

The 1991 North Pacific Joint Observer Program

The Japanese Squid Fishery - Introduction and Methods In 1991, Japan, South Korea and Taiwan renegotiated their cooperative monitoring and enforcement agreements with Canada and the United States regarding driftnet vessels operating in the North Pacific. The agreement with Japan provided that 10 Canadian, 21 Japanese and 30 U.S. observers would be placed on 45 vessels over 100 GRT and 16 on vessels less than 100 GRT. A minimum of 2,626 operations would be monitored. Data collection methods would be the same as in 1990. In the 1991, season joint observer coverage of the Japanese North Pacific squid driftnet fleet shrunk to seven percent. According to a U.S. marine mammal population scientist, this sample size is not large enough to be statistically significant for species such as whales with populations that tend to have a patchy distribution and reproduce slowly (Smith pers. comm. 1991).

Observer data collection methods were essentially the same as in previous years. Data was collected from late May to December. Seven sections were monitored when ten or more were set. Six were monitored when seven to nine sections were set. When six or fewer sections were set, observers monitored all sections or took a break during the retrieval of one section. The monitored sections were chosen randomly. Dropout monitoring procedures were the same as those used in the 1990 observer program.

The Japanese Squid Fishery - Results and Analysis The catch and bycatch included 3.71 million flying squid, 2,599 salmon, 82,459 blue sharks, 4,719 other sharks and rays, 188,316 albacore, 43,312 other tuna (including 220 bluefin), 21,888 yellowtail, 1,565,767 pomfret (under reported), 82,885 pelagic armorhead (under reported), 581 swordfish, 1,792 ocean sunfish, 11,540 other fishes, 10, 538 sooty shearwaters, 7,073 other seabirds (including several endangered and protected species), 385 fur seals, 1,787 dolphins, 16 "other cetaceans", and 44 turtles. (Table )

The Joint Report - Japan Squid (1991) notes that the 1991 squid driftnet observer program was improved over the 1990 program, particularly with regard to species identification. Photographs were taken by most observers to improve accuracy. The Report cautions against comparisons of differences in bycatch rate from year to year, and this author agrees. While identification techniques may have improved, distributions of bycatch populations are generally clumped and most populations had already been fished heavily by driftnets for a number of years.

The Japanese pledged to deploy research vessels in 1992 in the squid fishing area and invited U.S. and Canadian scientists to participate. They indicated they would. Canada also indicated that it would deploy a research vessel to study high seas salmon distribution. The results of these studies were not available for inclusion in this compendium.

The Republic of Korea Squid Fishery - Introduction and Methods The agreement with the ROK and the United States provided that 13 U.S. observers and 13 Korean observers would be placed on board 26 vessels during the 1991 season to monitor 45 or more driftnet retrievals each. Ten U.S. and 13 ROK observers were actually on board 23 Korean commercial driftnet vessels in 1991. Observers stayed on the vessels one to two months.

U.S. observers were instructed to monitor operations for five consecutive days and omit observations on the sixth day. Observers did not record catch or bycatch from operations not monitored. Korean observers monitored all operations made by the vessel while they were on board. Sampling procedures followed those in previous years. Korean vessels usually set five or six net sections; U.S. observers treated these as 10 or 12 subsampling sections of which seven were monitored. Some monitored subsampling sections were randomly selected for dropout monitoring. Observers were not required to count the catch of flying squid, and, if abundant, the bycatch of Pacific pomfret. U.S. dropout sampling procedures were similar to those employed on the Japanese squid vessels, with the same limitations.

The Republic of Korea Squid Fishery - Results U.S. observers recorded 1,094,770 neon flying squid, 15,587 Pacific pomfret, 8,235 blue shark, 42,411 tunas and mackerels, 18,257 armorhead, 14,719 other sharks and fishes, 947 birds, 51 dolphins (including one pygmy sperm whale), 8 fur seals and one turtle. (Table ) Korean observers recorded 1,285,398 neon flying squid, 91,226 Boreal clubhook squid, 2,413 blue shark, 24,130 tunas and mackerels, 5,874 Pacific pomfret, 5,181 other sharks and fishes, 249 birds, 12 seals, 29 dolphins and one whale. (Table )

The Taiwanese Squid and Large-Mesh Fisheries - Introduction and Methods The agreement between Taiwan and the United States provided that 11 U.S. observers would be placed on board 11 Taiwanese vessels to monitor 45 driftnet retrievals. Nine Taiwanese observers would be placed on board nine vessels to monitor 60 driftnet retrievals. Distribution between squid and large-mesh vessels would be in proportion to the number of each type licensed for the 1991 season. Eight U.S. and nine Taiwanese observers were actually placed on board 17 Taiwanese commercial driftnet vessels in 1991, accounting for 20 cruises. U.S. and Taiwan observers monitored 363 and 415 operations respectively. Observers were on the vessels approximately two months. Observations took place between early May and December. Vessels fished in areas chosen by the fishing captain. Monitoring and sampling procedures were the same for the squid and large-mesh fisheries and the same as in previous years, except that all Taiwanese observers were provided with cameras for photographing species for later verification. As in the other observer programs flying squid and Pacific pomfret were not always counted.

The Taiwanese Squid Fishery - Results U.S. observers recorded 361,744 neon flying squid, 32,601 tunas, 2,773 blue shark, 11,189 Pacific pomfret (under reported), 2,478 other sharks and fishes (including 18 sunfish), 344 seabirds, 44 dolphins and porpoise, 20 fur seals and 8 turtles. (Table ) U.S. data indicates a catch/bycatch ratio of at least 7:1. Taiwanese observers recorded 1,748,672 neon flying squid and Robust clubhook squid, 12,385 tunas, 20,263 other fishes, 225 seabirds, and 13 dolphins. (Table ) Taiwanese data indicates a catch/bycatch ratio of 53:1.

The Taiwanese Large-Mesh Fishery - Results U.S. observers recorded 40,951 tuna, 6,827 blue shark, 347 billfish, 4,515 Pacific pomfret (under reported), 2,373 other sharks and fishes, 661 cephalopods, 36 birds, 387 dolphins, 15 whales, and 13 turtles. (Table ) U.S. data indicates a catch/bycatch ratio of at least 3:1. Taiwanese observers recorded 51,608 tunas, 5,130 sharks and rays, 1,246 billfish, 218 ocean sunfish, 2,034 pomfret (under reported), 635 squid, 31 seabirds, one seal, 129 dolphins, and 44 turtles. (Table ) Taiwanese data indicates a catch/bycatch ratio of 6:1.

Analysis of the Data Collection Programs Through 1990

In June 1991, scientists from Australia, Canada, Japan, Republic of Korea, Taiwan, the United States, and the INPFC met in Sydney, British Columbia, Canada, to consider the results, not only of the 1990 North Pacific Joint Observer Program, but also the results of all the other data collected in previous years by the various research and commercial observer programs. The FAO, the Forum Fisheries Agency, New Zealand, the People's Republic of China and the U.S.S.R. were invited to attend also. "The data presented at that meeting highlighted the wasteful and destructive nature of this fishing method" (U.S. Summary Report 1991). The report recommended that the UN moratorium go into effect "without consideration of further delay. The continued use of large-scale pelagic drift nets cannot be justified. Alteration of large-scale drift nets has not been shown to reduce significantly the overall indiscriminate destruction and waste associated with its use."

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