At the October 2008 meeting of the
RAAC, committee members
were presented with something the Department of Fish and Game has been cooking
up in partnership with commercial abalone divers. What they had been working on
is an abalone tagging system modeled after the sturgeon tagging system.
Effectively, this means the tags are a water-proof "paper" tag the fisher/diver
is required to attach to an abalone. Twenty-four tags are being added to the
current Abalone Report Card. The result is a much
larger Abalone Report Card with small (tiny?) abalone tags.
The tags were requested by Wildlife Enforcement as a new means of cracking down on sport to commercial poaching. That is, having wrung out everything possible from the Abalone Report Card system that was clearly doomed to failure, adding tags is the next step at trying to catch the hopelessly stupid poachers, the smarter poachers being quite capable of stepping around the proposed tag system. As a sport diver myself and having heard a lot of bad stories from the "good guys" caught by draconian enforcement of the current Abalone Report Card, my concern is that Abalone Tags enforcement will necessarily be even more draconian. The problems I see with the proposed tag system include:
- The proposed tags are tiny and you're expected to fillout the same information on each of the tags as you are for each abalone on the Report Card half. That is, you enter month, day, time and a location code in four seperate spaces. Each space is small when sitting at a dining room table. After time diving, with cold wet hands and an iffy ink pen, those small spaces will shrink by at least half.
- Continuing with the "tiny" complaint, I started using reading glasses about 8 years ago, I think. Without those reading glasses, I can't SEE the writing on the abalone tags much less fill them out. Lucky me, I have a $250 dive mask that actually has bifocals in it so it should be possible for me to fillout these tags while sitting on a beach wearing my dive mask. How about you?
- The Abalone Tag, being as small as it is, has a small hole for attaching the tag to an abalone. The instructions suggest using a tie wrap, string or other method of attachment. Forget the tie wrap; tie wraps small enough to fit through the attachment hole are too short to be used on abalone and, probably, too fragile anyway. But, presumming you do find long enough and skinny enough tie wraps to work with, I know from decades of experience with electronics that the smaller tie wraps will barely fit in the attachment hole. This means that that edges of the tie wrap will act as a dull knife to slice through the Abalone Tag. All of which makes me seriously wonder who exactly comes up with these brilliant ideas.
- I figure you'll have to use bailing wire to attach these tags to abalone. That should alleviate the problem with the attaching method jeopardizing the tag's attachment. With that problem solved, how durable are these tags going to be when a limit of 3 have been stuffed into a float or gunny sack and then transported on the bottom of a boat, up a cliff, across fields and down the road in the back of my truck. When I pull up to a roadside checkpoint, will the tag I attached an hour or two earlier still be attached? And how much strict liability is involved if one ripped off? That is, having done everything exactly right and as directed by the regulations, will I get cited if one rips off? Based on current enforcement of the abalone regulations, I wouldn't bet on getting much leeway.
- So what's the point of the Abalone Tag? Of course, it's to catch the bad guys and, short of that, make their unlawful activities harder. Unfortunately, just like the Abalone Report Card, getting around the Abalone Tags is child's play. During the presentation of this system, it took me 20 minutes to come up with and point out a way around the Abalone Tags. The response I got was that my comments are part of the public record and, maybe, it's a bad idea to "reveal" my idea. I was pretty incredulous at that. Do they really think it would take a smart poacher even 20 minutes to come up with a better idea than mine? So, like the Abalone Report Card, I expect the Tags will mean a few more stupid poachers are caught along with a whole bunch more sport divers/pickers who truly want and try to obey the law but get nailed anyway.
The intent of the Abalone Tag system is good. The execution leaves a lot to be desired. There are alternatives but they tend to interfer with the fishery in ways that would upset coastal businesses and those alternatives would be even more expensive to implement. As it is, the increased size of the Abalone Report Card/Tags along with additional perforations and serial numbering of 24 tags increases the printing costs from around $12,000 for the current Report Card by a factor of 3. The costs of making/printing Abalone Report Cards/Tags comes out of the funds generated by Report Card sales. To cover the costs of a more complex and fail proof system will put a bigger hit on abalone research and law enforcement or will require a substantial increase in the Abalone Report Card.
I've asked the Department of Fish and Game to verify the durability of the proposed abalone tags. Fish and Game biologists handle a lot of abalone and it should be simple matter to have them mock up some abalone tags out of the right material and see how they stand up. This, of course, should be verified before there's a change in the regulations. Unfortunately, that's probably not going to happen; Abalone Tags are now on a fast track to get them into the regulations in time for the 2008 season. That means there will be only a couple of hearings on the issue:
- November 2, 2007 Discussion Hearing in Sacramento, CA
- December 7, 2007 Adoption Hearing in San Francisco, CA
So it's probably a done deal in the next 45 days.
For those interested in seeing some preliminary documents supplied the RAAC just a few weeks ago, here are a couple of PDF files for your enjoyment. Yes, you'll need a PDF reader to see these.
- September 24, 2007 Cover Letter from CDFG to FGC
- Initial Statement of Reasons for Regulatory Action
- Abalone Report Card and Tag
- Abalone Report Card and Tag instructions (note the many "gotcha" details, lots of ways to screw up filling out the tags and/or report card)
- Abalone Report Card and Tag example use (slated to appear on the Abalone Report Card/Tags itself)
Last Modified: October 18. 2007
