Opinion

The Better Seafood Board's review of the invoices and accusations in the Globe story reveals North Coast delivered correctly labeled fish to all of its customers. There is nothing “technical” about this important fact.

December 10, 2012 — When the Boston Globe began its efforts to help root out fish fraud by investigating and reporting on economic integrity in the seafood industry more than a year ago it was at the forefront of shining a light on an issue many consumers knew little about. The series was initially a good example of how investigative journalism can help drive regulators while policing producers, processors, restaurants and retailers alike.  Unfortunately, with its latest installment on this subject the Globe missed the mark.

While fish fraud concerns often revolve around ambiguity and misunderstanding, the facts of the case-study presented in the latest report are neither ambiguous nor misunderstood. The article began by noting that North Coast, both a seafood processor and distributor at the center of the Globe’s investigation, “technically did supply the fish indicated on most invoices.”  Our review of the invoices and accusations reveals North Coast delivered correctly labeled fish to all of its customers. There is nothing “technical” about this important fact.  Likewise, all of the fish names on those invoices were accurate and labeled exactly as the U.S. Food and Drug Administration requires.

When the Globe’s DNA testing revealed mislabeled menus at four New England restaurants the traditional finger pointing began. But in this case the establishments and the Globe pointed at the wrong company. North Coast is not involved in fraud. The narrative described in the Globe’s report is fundamentally flawed and suggests distributors like North Coast who provide correctly labeled seafood should be responsible for policing the menus of its customers. With 1,000 customers and with 10 items or more on each customer menu, North Coast would be tasked with reviewing 10,000 menu lines to ensure its customers were not involved in defrauding their customers.

The Massachusetts Food Code is clear that restaurants and regulators – not distributors —  are responsible for accurate menu labels. It is illegal for establishments to “mislead or misinform the consumer” (105 CMR 590  §590.001.) As we know from Gisele Bundchen, Tom Brady is only responsible for throwing the ball; Wes Welker and company are responsible for catching it. The regulations and the division of responsibilities are clear and demonstrable, pointing fingers and shifting blame does not get at the heart of the issue. In fact it obscures the real challenge.

Just as obtuse reporting ignores realities in the market, it obscures solutions. Pointing out that rose snapper was invoiced by North Coast as snapper suggests a violation of some sort. The fact is the FDA says labeling rose snapper as snapper is accurate and the more acceptable name.  Likewise while the Union Oyster House lists fresh Boston Scrod on the menu, the FDA does not consider “scrod” as an acceptable name for labeling either haddock or cod.  

In October of 2011 the CEO of the Massachusetts Restaurant Association, Peter Christie, told the Globe, “some [restaurant] operators were knowingly, for whatever reason, substituting one species with another. This is unacceptable.’’ It is unacceptable but pointing fingers at distributors, hand wringing and musing about creating redundant regulations will not successfully address the issue. The Better Seafood Board, as the leading organization driving to rid the full seafood supply chain from cheats, welcomes the opportunity to work with the Massachusetts Restaurant Association and Massachusetts regulators on an integrated program to effectively use resources and accurately target bad actors.

Pointing the innuendo-filled finger of blame at a distributor who didn’t do anything wrong and is committed to providing restaurants and retailers with the right fish at the right price is “technically” fit to print but we feel is a fraud upon Globe readers.

Lisa Weddig is the secretary of the Better Seafood Board (BSB.) Begun in 2007 the BSB is an industry-led group devoted to fighting fraud in the seafood community. Members of the National Fisheries Institute, the country’s largest seafood trade association, are required to be members of the BSB.

 

 

December 10, 2012 — Let’s move past the false accusations and find solutions that protect the forage engine driving our fisheries and ecosystems. Our west coast fishing communities, the California Current ocean ecosystem, and ultimately our coastal economy depend on it.

The California Wetfish Producers Association (CWPA) is in the business of catching small fish, but they also sure know how to tell a whopper.

In her opinion article, “Oceana claims controversy on sardines, but scientists disagree”, CWPA’s Executive Director, D.B. Pleschner, wrongly accuses Oceana of creating a controversy over the recent Pacific sardine stock assessment in order to “achieve its agenda of shutting down fishing.”  Oceana has never had an agenda of shutting down fishing.  We strongly believe in healthy oceans that can support a variety of uses including sustainable fisheries and vibrant coastal communities.
Oceana does not dispute the recent 2012 Pacific sardine stock assessment, rather, we believe this assessment represents the best available science. It is this assessment that outlines that the sardine population has been in continuous decline for the past six years and that the population is 33% lower than was estimated last year.  We are not “claiming the sky is falling.”  It is undisputable that Pacific sardine populations are plummeting.

What is more, we did not call on the Pacific Fishery Management Council to shut down the sardine fishery.  We are however concerned that the only option considered by the Council in setting the 2013 quota, has been acknowledged by the Scientific and Statistical Committee (SSC) and NMFS scientists (McClatchie et al. 2010) to need significant revision.  For years, the SSC has called for a full “management strategy evaluation” to revise the sardine harvest control rule, including the harvest rate, the proportion of the stock in U.S. waters, and key economic and ecological factors.  The crux of the problem is that sardines are managed under the assumption that we can predict when sardines will boom or bust, yet science indicates otherwise.

The most recent stock assessment showing that the sardine population is in decline is consistent with the findings of a scientific paper published by two of the NMFS stock assessment authors (Zwolinski and Demer 2012, "A cold oceanographic regime with high exploitation rates in the Northeast Pacific forecasts a collapse of the sardine stock").  In this paper, the authors write that the Pacific sardine population has “declined precipitously” and that similar to the crash in the mid-1900s, “alarming is the repetition of the fishery’s response to a declining sardine stock—progressively higher exploitation rates targeting the oldest, largest, and most fecund fish.”  The paper establishes a critical spawning stock biomass of 740,000 metric tons (mt) below which the population is at serious risk from fishing pressure.  Alarmingly, the stock assessment estimates the current 2012 spawning stock biomass to be only 435,351 mt.

Pleschner further obfuscates the truth by factually misrepresenting the current coastwide catch rate as 5%, when in fact the stock assessment showed it is currently three times that.  According to the federal government’s own fishery model, removing 15% of the sardine population every year reduces the population over time to less than half of what it would be without fishing.  In other words, since the fishery has been removing sardines for the last two decades, the annual removals do not indicate what is left.  Therefore, Pleshner’s claim that the industry “leaves 95% of the species for predators and ecosystem needs” is a statistical lie.

Further flawed is the calculation of the proportion of the sardine stock in U.S. waters versus in the waters off Mexico and Canada.  Without any formal agreement, U.S. managers assume 87% of the stock is in U.S. waters, 13% is in Mexico and 0% is off Canada.  Canada, however, assumes 27.2% of the population is in its waters off Vancouver Island, while fleets off northern Baja California, Mexico are taking nearly 40% of the coast-wide landings.  With three countries setting arbitrary harvest assumptions for their neighbors, it is no wonder we have coastwide overfishing.

Fortunately, forage fish—such as sardines and squid—have wide natural fluctuations and ultimately we should be talking about managing the forage base as a whole.  The ability to switch between forage species will allow the industry to capitalize on these natural booms. What Pleschner fails to mention is that the same “wetfish” industry seeking to maintain high sardine harvests amidst a collapse is actually making more money than ever.  This year is the third of three consecutive years of the highest market squid catch (and revenues) ever.

Let’s move past the false accusations and find solutions that protect the forage engine driving our fisheries and ecosystems. Our west coast fishing communities, the California Current ocean ecosystem, and ultimately our coastal economy depend on it.
 
 

Geoff Shester and Ben Enticknap are with Oceana, the largest non-profit organization dedicated solely to protecting the world’s oceans.

Citations:

Hill, K.T., Crone, P.R., Lo, N.C.H., Demer, D.A., Zwolinski, J.P., and Macewicz, B.J. 2012.  Assessment of the Pacific sardine resource in 2012 for U.S. management in 2013.
 
McClatchie, S. R. Goericke, G. Auad, and K. Hill. 2010. Re-assessment of the stock-recruit and temperature-recruit relationships for Pacific sardine (Sardinops sagax). Can. J. Fish. Aq. Sci. 67: 1782-1790.
 
Zwolinski, J. and D.A. Demer. 2012. A cold oceanographic regime with high exploitation rates in the Northeast Pacific forecasts a collapse of the sardine stock. Proceedings of the National Academy of Sciences (PNAS) 109 (11). 4175-4180.
 

December 7, 2012 — We're left scratching our heads over the time that's passed since Swartwood told Bryson his report should be done soon. Changes in policy have begun to erode industry dissatisfaction. Transparency on enforcement — even if the agency has to take its own medicine — will hasten the process.

Enforcement changes were implemented after Inspector General Todd Zinser's report on whether different regions were being punished differently under NOAA, and on whether administration of the Asset Forfeiture Fund was appropriate, but the pace of the agency's attempt to make good on inappropriate enforcement is holding back greater progress.

The work of Special Master Charles B. Swartwood III to root out cases of improper enforcement came out of the inspector general's report. Payments were made after Swartwood's first report, and an appeals window was opened in March 2011 for those who needed it.

Swartwood wrote to the secretary last February — at the time, John Bryson — to tell him that there were 66 cases submitted by the special master to NOAA for responses. He wrote that his final report would be ready in less than two months, with all but five of the cases having already been returned to Swartwood.

Sen. John Kerry wrote to acting Commerce Secretary Rebecca Blank this week urging the release of Swartwood's latest report on grounds that transparency would work to improve the relationship between NOAA and fishermen. It would also help fishermen know where they stand with changes to NOAA enforcement policies.

In an industry where everything changes — the rules, the equipment, the environment, the quarry — a stable enforcement environment means one less variable for already challenged fishermen in an industry that's hard enough without regulatory challenges.

We're left scratching our heads over the time that's passed since last winter when Swartwood told Bryson his report should be done soon. Changes in NOAA's fisheries policy and implementation of cooperative scientific methods have begun to erode industry dissatisfaction with the powerful federal agency. Transparency on enforcement — even if the agency has to take its own medicine — will hasten the process.

We echo Sen. Kerry in asking that the agency release the report to clear the air and bring a clean slate.

 

Read the full story in the New Bedford Standard Times 

 

 

 

 

December 4, 2012 — Any true aid to address this admitted fisheries economic disaster should come from the appropriations for NOAA and Commerce — the folks who, after all, created it right from the start.

Congressmen John Tierney, Barney Frank and William Keating — Massachusetts’ three U.S. House allies of the fishing industry — are certainly justified to try to ensure that the industry’s recognized “economic disaster” finally conceded by the Department of Commerce in September is entitled to disaster relief.

But with all due respect to them and their legislative colleagues, tacking any such aid onto a bill aimed at sending federal disaster aid to the Mid-Atlantic states still grappling with the after-effects of superstorm Sandy may be misplaced at best. And that’s not just because it would be a shame to complicate aid desperately needed for the storm-stricken people and communities in New York and coastal New Jersey.

Lumping in fishermen’s economic disaster aid with money going to recovery from a true natural disaster would miscast the fishery disaster as some sort of natural catastrophe as well, and it’s not. The New England and Northeast fishery disaster is a man-made, intentional economic collapse that was not just caused, but truly engineered by NOAA and administrator Jane Lubchenco, who, still propped up by the White House, have driven Gloucester’s, New England’s and America’s own fishermen right out of their jobs and their way of life while the president himself hypocritically proclaims he wants “jobs, jobs, jobs” for American working families.

The idea of Acting Commerce Secretary Rebecca Blank declaring an “economic disaster” without even hinting at offering any money or other solutions for addressing it is absurd in the first place. But no more so than her failure to even suggest that NOAA’s mad science and built-to-fail catch share management policies are at the root of the problem.

 

Read the full story at the Gloucester Times

 

 

December 3, 2012 — There are a few personnel changes – and the potential reauthorization Magnuson-Stevens – that will have some consequence.

Now that the dust has settled from the national elections, many of us in the fisheries world are turning our attention to the new session of Congress and what it means for the issues we care about.

Ocean issues rarely occupy a spot in the national conversation, and this year was no different. And given that the party makeup of both the House and Senate remains largely unchanged, we can expect much of the same posturing and gridlock we have seen in recent years.

Nevertheless, there are a few personnel changes – and the potential reauthorization of the Magnuson-Stevens Fishery Conservation and Management Act (MSA), the law that governs our nation’s fisheries policy – that will have some consequence on these issues, for better or worse.

In the Senate, the Committee on Commerce, Science and Transportation, which has jurisdiction over all federal fisheries policy, will see Senators Kay Bailey Hutchison (R-TX) and Olympia Snowe (R-ME) retire at the end of this year. Sen. Hutchison – the committee’s current Ranking Member – and her staff have worked well in a bipartisan manner on ocean issues. Sen. Jim DeMint (R-SC) will likely succeed her as the top Republican on the committee. While we don’t know exactly how this will affect fisheries issues, Oceana hopes that he will show leadership in his new position and be mindful of the coastal communities in South Carolina that rely on healthy oceans and fisheries.

In Sen. Snowe, the committee – and the Senate as a whole – is losing not only a partner in bipartisanship but also a strong fisheries advocate. She has been intimately involved in New England fishing issues over the years, serving as Ranking Member on the Subcommittee on Oceans, Atmosphere, Fisheries, and Coast Guard for the past few years and as chair when the Republicans controlled the Senate. She supported many of the bills Oceana supported, including those addressing illegal fishing and seafood fraud. Her knowledge of and passion for fishing issues, even if we didn’t always agree, will be missed. Sen. Roger Wicker (R-MS) will likely succeed her as Ranking Member of the subcommittee. Oceana is hopeful that Sen. Wicker will become an advocate for sustainable management of fisheries around the country, including those who fish in the Gulf of Mexico near Mississippi.

In the House, while leaders are still determining committee chairs and membership, the biggest change comes with the retirement of Rep. Barney Frank (D-MA). Rep. Frank has been a tireless advocate for the fishing industry, particularly in New England. We expect other representatives to fill some of that gap, but none will be as vocal or as influential as Rep. Frank. Along with Rep. Ed Markey (D-MA), he was a lead sponsor of the Safety and Fraud Enforcement for Seafood (SAFE Seafood) Act, which would require traceability of the seafood supply chain. Rep. Frank did not always share Oceana’s views on fishery management issues, but he was a strong advocate to end seafood fraud, which hurts commercial fishermen and our oceans. Oceana offers our encouragement to Rep. William Keating (D-MA), who now represents the valuable port of New Bedford, and we hope that he will continue to be the strong voice for modern fisheries management in the new Congress that he has been in the past.

 

Read the full story on the Oceana website 

 

 

 

 

December 2, 2012 — Since the beginning of the industrial era, humans have pumped increasing amounts of carbon dioxide into the atmosphere. This has led not only to a warmer climate but also to significant changes in the chemistry of the oceans, which have long acted as a sink for carbon emissions but are being asked to absorb more than they can handle. The result is ocean acidification: increasingly corrosive seawater that has already ruined many coral reefs and over time could threaten the entire marine food chain.

The State of Washington is now trying to tackle the problem in new and inventive ways. It has good reason to worry. Its economically important aquaculture industry specializes in shellfish, especially oysters. Shellfish are highly vulnerable to increased acidity, which kills them by preventing them from creating or maintaining their shells. Washington’s coastal waters are also polluted by urban and farm runoff, as well as an unusual regional threat: wind patterns that cause the upwelling of deep, nutrient-rich ocean currents loaded with carbon dioxide.

The state’s plan — an offshoot of the National Shellfish Initiative created by the National Oceanic and Atmospheric Administration in 2011 — acknowledges that the only long-term solution to acidification is for the world to reduce industrial emissions of carbon dioxide, allowing the ocean to reach a less acidic equilibrium. But because this is not likely to happen any time soon, Washington has decided to try to “buy time” for itself and, in doing so, provide valuable lessons for other parts of the world.

The first step will be to monitor ocean acidity with greater breadth and accuracy and to create an acidity budget — an assessment of just how much acidity is contributed by whom. Next it will seek to reduce carbon pollution from land-based sources, including agricultural and urban runoff. There will also be practical, site-based steps to offset carbon, like planting sea grasses (which themselves are endangered globally) in shellfish hatcheries. And there will be an extensive campaign to educate the public, business leaders and policy makers about the risks of increasing acidification.

 

Read the fully story at The New York Times

 

 

December 2, 2012 — No one should believe that this ruling marks the end of the fight over catch shares, or other aspects of the gross mismanagement of New England’s and America’s fisheries.

The news that the U.S. First Circuit Court of Appeals in Boston has stood by a 2010 ruling by Judge Rya Zobel, and thus rejected the challenge by the cities of Gloucester, New Bedford and other fishing interests to NOAA’s and the New England Fishery Management Council’s Amendment 16 with its catch share fishery system, should hardly be a surprise.

Appeals Court rulings generally focus on whether the initial decision was systematically flawed — not on the arguments for or against the differing sides of the actual case. And while we can long argue over whether Zobel made the right decision, there seems little doubt that she arrived at in logical fashion.

Yet no one should believe that this ruling marks the end of the fight over catch shares, or other aspects of the gross mismanagment of New England’s and America’s fisheries by the administrator Jane Lubchenco and her National Oceanic and Atmospheric Administration, as we know it. For in standing by Amendment 16 and catch shares, Chief Judge Sandra Lynch — who wrote the decision or the court – cited a December 2011 announcement by the regional fishery council that it is developing rules aimed at “reduc(ing) the likelihood that groundfish permit holders will acquire or control excessive shares or fishing privileges.”

 

Read the full story at the Gloucester Times

 

 

December 2, 2012 — Environmentalists and fishermen concur: Atlantic States Marine Fisheries Commission regulators should use the best available science. Unfortunately, Chris Moore omits key scientific facts in his argument for “more aggressive steps” and a “robust” conservation plan for Atlantic menhaden.

Should regulators limit the catch of Atlantic menhaden?

The science isn’t conclusive

By Monty Deihl

Deihl, a native of Reedville and fifth-generation menhaden fisherman, is director of fishing operations for Omega Protein.

Environmentalists and fishermen concur: Atlantic States Marine Fisheries Commission regulators should use the best available science. Unfortunately, Chris Moore omits key scientific facts in his argument for “more aggressive steps” and a “robust” conservation plan for Atlantic menhaden.

He accuses the industry of questioning ASMFC science. Actually, the ASMFC itself raised concerns, noting flaws that “cast considerable doubt” on the most recent assessment’s accuracy.

Moore states that menhaden experienced overfishing for 32 of the past 54 years. But 30 of those years occurred more than 15 years ago. In the last nine years, overfishing occurred just once and only by 0.4 percent. Because menhaden live a maximum of 10 years, statistics from the 1970s and ’80s are less relevant than recent findings.

Noting correctly that “the number of young fish entering the population has remained low for nearly 20 years,” he does not account for other environmental factors. The ASMFC concluded in its 2010 assessment that population fluctuations “are almost entirely driven by non-fishery sources.”

The expression “the most important fish in the sea” was coined by a Rutgers English professor. There is no scientific evidence that any one species is most important. That is the author’s opinion, not scientific consensus.

Moore implies that the fishery has consolidated to a single facility in Virginia as a result of overharvesting. In fact, economic pressures such as fluctuations in the price of fishmeal and fish oil and land-use concerns, such as restrictions brought on by increased waterfront development, have been key drivers of industry consolidation since the 1980s.

The industry has not taken an unreasonably hard line, as Moore implies. Instead, we have suggested a cap based on three-year average landings, which would result in harvests about 7 percent lower than in 2011. This would protect both the menhaden stock and fishing communities.

Conservation will bring recovery

By Chris Moore

Moore is Hampton Roads senior scientist for the Chesapeake Bay Foundation.

Omega Protein’s Monty Deihl calls for sound science to guide menhaden conservation but then uses half-truths, outdated information and job-loss scare tactics to argue for the status quo.

For example, he cites Atlantic States Marine Fisheries Commission data to contend menhaden overfishing has occurred only twice since 1993. However, these figures are based on outdated standards that the commission has since changed. Using the new fishing rate standards, the 2010 assessment would have found that menhaden overfishing occurred in 52 of the previous 54 years. Further, the commission’s Menhaden Technical Committee says that if the new population standards it recommends are adopted, the population would be considered overfished.

Deihl argues a modest 7 percent harvest cutback from heightened 2011 levels “will allow the menhaden stock to continue its growth.” But the population is not growing — it’s at an all-time low and has reproduced poorly for the past 20 years.

Science and history demonstrate that when significant conservation steps are taken to help troubled fisheries, they recover to everyone’s benefit.

 

Read the full story at the Roanoke Times

 

 

 

November 30, 2012 — Markey is right, Lang is right and Mitchell is right: This fight had to be fought. NOAA needed to be challenged because once again it was making decisions with disregard or even contempt for the fishing communities it tells us that it cares for.

Former New Bedford Mayor Scott Lang was not inclined to accept the court's reasoning. "I think our points were extremely valid. I think the agency acted as a renegade when it comes to laws and the day-to-day implementation of fishing regulations."

It was Lang who called for the Commerce Department's Inspector General to look into the rulemaking process at the National Oceanic and Atmospheric Administration. He never got it, but who can tell what lies ahead?

There's something else we're looking forward to, as well: Part 2 of the scathing Charles Swartwood III "special master" investigation, ordered by the Commerce Secretary, into fishery law enforcement in the Northeast.

Whatever is in there must be truly awful because Commerce has been keeping the report top secret while everybody waits around speculating on how bad it must be.

After all we've been through, here's a quote from the No. 1 sector advocate, the person who came from the Environmental Defense Fund to become administrator of NOAA, Dr. Jane Lubchenco, on the announcement in September of a fishery state of emergency in the Northeast:

"Fishing is the lifeblood of many coastal communities, providing jobs, a continuation of an historic tradition and culture, recreational opportunities for millions of anglers, and contributing to food security for the nation. Finding solutions will not be easy but, by continuing to work together, we can have healthy fish stocks, profitable fisheries and vibrant fishing communities."

Those sure are nice words. We've heard a lot of nice words from NOAA in the past two or three years, haven't we?

The real lesson runs counter to the lofty pronouncements about caring and cooperation. Instead, it is, Don't challenge anything NOAA does or says, or question its motives as it buries embarrassing reports, or point out the bugs in the science, or wonder why no one has lost their job over the law enforcement fiasco.

And if you want to take it to court, then remember: The law makes it almost impossible to overturn a regulation, which is what New Bedford and Gloucester and all the others were trying to do to save their communities and save their livelihoods.

P.S. Credit where credit's due: the briefs in the lawsuit and appeal were written by attorneys Mikaela McDermott, Julie Peterson and Pamela Lafreniere.

 

Read the full story at the New Bedford Standard Times

 

 

November 28, 2012 — For going on two centuries, residents of hard-working communities along the Atlantic coast have made their living in the menhaden industry. For many of these towns, it is the only industry and the foundation of the local economy. Severely reducing (or worse, halting) Omega Protein’s operations would have a catastrophic economic effect on the area.

As the partner/owner of a small business, I am deeply concerned about the proposed menhaden fishing limitations as outlined in the Atlantic States Marine Fisheries Commission’s (ASMFC) Draft Amendment 2. The unprecedented harvest cuts within this amendment will severely and negatively impact Omega Protein’s operations in Reedville. Omega Protein has been a long and important customer of Courthouse Construction, Inc. Any hardship imposed on them will negatively affect our business.

The data being used to support this proposed amendment are questionable at best and those making these important decisions must do so without full confidence in their conclusion. Reports that menhaden are at their lowest levels in years are contradicted by many experts, whose scientific data strongly negates this assumption. ASMFC’s own and latest menhaden stock assessment, conducted this year, was deemed unsuitable for management purposes by their own Menhaden Technical Committee. With stakes this high, the ASMFC cannot afford to play guessing games with our area’s economic future. Given this high degree of uncertainty, I strongly oppose the proposed cuts to menhaden harvest levels; at least until and when conclusive, reliable and substantive findings regarding the menhaden fishery’s status become available.

For going on two centuries, residents of hard-working communities along the Atlantic coast have made their living in the menhaden industry. For many of these towns, it is the only industry and the foundation of the local economy. Anyone even vaguely familiar with the Town of Reedville, Northumberland and the surrounding counties knows that severely reducing (or worse, halting) Omega Protein’s operations would have a catastrophic economic effect on the area.

Hundreds directly, and likely thousands indirectly, of vendors and contractors like Courthouse Construction, Inc., serve this industry. Our businesses support Omega’s operations and, to a significant degree, depend on their success. Our company’s future and that of my employees should not be jeopardized by a decision based on questionable and inconclusive findings. It is inconceivable that ASMFC would even consider acquiescing to the pressure tactics of special interest groups, and use limited scientific data to make a decision that will so negatively harm our already struggling economy. Rather than a "rush to judgment," it is our responsibility to demand that any decision directly affecting this economy be based on sound, definitive, peer-reviewed and verifiable scientific findings.

 

Read the letter at the Gloucester-Matthews Gazette-Journal