The site: http://tholepin.blogspot.com/ has a new posting, the Failure of the Restructured Observer Program, wherein he uses NMFS data to show how trawlers were"gaming" the observer/bycatch.
The catcher/processor Golden Fleece now has to have 100% observer coverage and his bycatch now is 9-10 times greater per tow than when he could fullfill his limited (30%) observer coverage requirement doing a few "safe" tows.
The example tholepin cites is king salmon bycatch but it is likely halibut is similar. There was a halibut cap and not a king bycatch cap for bottom trawl till recently so halibut could be worse.
Could this explain the "missing" halibut from the IPHC's models??
So inability to "game" the system reveals a 9-10 fold increase in bycatch over the fake numbers that have been generated in the past.
Looks like the emperor is buck naked.