Opinion

UMass paper shows that assumption were not 'risk neutral', but 'risk averse'.  This contradicts Magnuson act requirements. Given that hundreds of millions are available for law suits, it is natural to expect that the bureaucracy would err on the side of being risk averse, instead of upholding the risk neutral requirements of Magnuson.

SEAFOOD.COM NEWS by John Sackton – Oct 29, 2010 – The request from Gov. Patrick of Massachusetts to Secretary Locke to revise New England catch limits within the context of existing conservation law has substantial scientific backing.

A paper completed by scientists at the University of Mass. School for Marine Science and Technology (SMAST), along with analysis by the Mass. Division of Marine Fisheries, show that the assumptions used to mandate ACL's in New England groundfish in 2010 were not 'risk neutral', but were in many cases 'risk averse'.

This contradicts current Magnuson act requirements for annual catch limits require that models be analyzed in a manner that are neither risk averse nor risk prone, but are risk neutral.

The report provides substantial evidence that many of the choices made for New England groundfish stocks – such as the required uncertainty buffers, the estimates of stock size, and the application of retrospective data, were made in a 'risk averse' mode rather than a risk neutral mode.

In short, the authors claim that the New England ACL's generally are more risk averse than other ACL's adopted in other management regions.

This is the basis of the request for review.

While not ordinarily supporting a Washington override of council decisions, the situation in New England represents a perfect storm, in that overly conservative management assumptions which have served to reverse stock declines and are ending overfishing, nevertheless have also exacerbated allocation decisions made in the implementation of catch shares, so that according to Massachusetts officials, about two-thirds of vessel owners are operating on 50% to 60% or less of their harvest rates from 2007 to 2009.

The relief sought from Commerce Secretary Locke would compensate those permit holders who have been most impacted by the switch in 'currency' from days at sea to catch history; and would seek to implement less precautionary catch limits that are still consistent with the conservation requirements of Magnuson.

The issue of 'risk averse' versus risk neutral decision making is important, because NMFS is frequently sued, and reacts by attempting to avoid potential law suits from environmental stake holders claiming that their models do not sufficiently account for risk.

Given the fact that hundreds of millions of dollars are available for law suits, it is natural to expect that the bureaucracy would err on the side of being risk averse, instead of upholding the risk neutral requirements of Magnuson.

 

John Sackton, Editor And Publisher
Seafood.com News 1-781-861-1441
Email comments to jsackton@seafood.com
 

We’ll be depending on Congressman Frank and his colleagues in the House and Senate to make sure that representative members of the fishing industry are full participants in the process that Secretary Locke has set in motion. If that’s the case, we can all look forward to a fishing future far less bleak than the one that we are now facing.

First off, I have to salute Congressman Barney Frank, not just for his unflagging support of the fishing industry in his district and nationally, not just for the central role he has played in getting the Secretary of Commerce to pay attention to the fishermen as well as the fish – something that NOAA head Jane Lubchenco has been unwilling to do – but also for recognizing that there are, in his terms, “extreme anti-fishing groups” involved in fisheries management. If you have an interest in fish and fishing, I can’t recommend too highly that you invest 9 minutes in listening to Phil Paleologos’ October 15 interview of the Congressman on WBSM radio’s Saving Seafood show and use it as a gauge of what effective political support is all about (the “extreme anti-fishing groups” quote is at 4:52). Later in the interview (7:44) he states “whether it takes a fish stock thirteen years or nine years to replenish is not a great moral issue.” These words should be carved into Mt. Rushmore, or at least displayed by every restaurant and fish market whose manager’s are tired of trying to explain what pangasius and tilapia are and trying to describe where they come from to customers who want local fish.

Then, like everyone else who thinks fishermen are as important as the fish they catch, who recognizes the value of fishing communities up and down our coastlines and who is opposed to the blatant takeover of our national ocean agency by ENGOs and the billion dollar foundations that support them, I applaud Commerce Secretary Gary Locke’s commitments to the commercial fishing industry in the Northeast and nationally as he set them forth in a letter to Congressman Frank in a letter on October 14 . Needless to say, the announcement of these commitments was accompanied by much fanfare by the industry, as it should have been.

However, this is one of those instances where the devil is definitely in the details.

Read the complete opinion piece from Fish Net Lite.

 

 

 

 

 

 

We win.

It isn't often that commercial fishing gets a fair deal from the federal government, but on Thursday, that is exactly what happened in New Bedford.

A lot of people, from the mayors of New Bedford and Gloucester to Sen. John Kerry and fishermen from throughout the region, deserve great credit for making this fight.

However, it was won thanks to the efforts of Barney Frank, who has been steadfast and determined in protecting the economic and cultural interests of coastal communities like this one.

He championed this cause and as a result, the rules protecting both fish and fishermen will be fairer than they were before.

That is a win-win for everyone.

For a year, Frank has led the assault on the National Oceanic and Atmospheric Administration and its arbitrary and heavy-handed enforcement of regulations that have unfairly punished Northeastern fishermen. He has pushed Locke to overrule NOAA Director Jane Lubchenco and consider issuing emergency orders easing federal limits on catch shares and limits that are hurting ground fishermen in New Bedford, Gloucester and elsewhere.

Locke finally gave in and conceded that he does have the authority to order such revisions, and now an independent and comprehensive scientific review of fish stocks will be undertaken to determine whether the existing limits make sense.

Further, Locke has agreed to relax restrictions on fishermen who are fishing near the U.S.-Canada border, which could allow fishermen to bring home more fish.

Finally, Locke agreed to spend $15 million on a nationwide assessment of fish stocks that should align the industry more closely with scientific research and help sustain the fishery along both coasts.

A national fishing science summit will examine how fishing data is gathered and analyzed.

Taken together, Locke's agreement should not only help restore the fishing industry's confidence in the regulatory agencies, but should help lessen the conflict between conservationists and fishing interests by establishing sensible regulations that better protect both fish and fishermen.

Read the complete editorial from The South Coast Today.

 

 

 

 

 

Since the implementation of the Sector Management type of Catch Shares in New England, the majority of Gloucester and New Bedford vessels are tied to the dock, with crews unemployed, and lease payments that do not cover anywhere near the value of their enterprises.  MA fishermen in Gloucester and New Bedford, and their political leaders, have been saying a true emergency exists.

The situation is like ten guys in a bar, 9 who are unemployed, and one pulling down $1 million per year. A bureaucrat looks at the bar and says things are great; the average income is $100,000 per year. But in fact, the 9 guys who are unemployed are ready to kill anyone who says they are doing fine. They are not. It is only the million-dollar guy who is doing okay.

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SEAFOOD.COM NEWS (news commentary) by John Sackton – Oct 11, 2010 – 'When I read what you wrote Friday , I nearly threw up', said Daniel Bubb, owner of two gill netters in Gloucester.

'We are desperately seeking aid, not as a handout, but just because we want to keep fishing. And when Gov. Patrick and others are fighting to get Locke to help us, you say 'it's hard for Gov. Patrick to be crying emergency when groundfish revenues in Mass. are up 25%.'

'Nothing could be farther from the truth' said Bubb.

He's right.

Although the overall revenues are up most of the vessels are not fishing; they are tied up in port or limping along on small allocations. The increase in revenues is from the fact that bigger boats, especially out of state boats, have been landing in Gloucester – so to say port revenues increased is a slap in the face to the vessels tied up and unable to fish, desperately trying to hang on to the only livelihood many have ever known.

The same is true in New Bedford. There, 68% of the New Bedford fleet is not fishing, says Jim Kendall, an active industry participant from New Bedford.

So when the majority of Gloucester and New Bedford vessels are tied to the dock, with crews unemployed, and lease payments that do not cover anywhere near the value of their enterprises, Massachusetts fishermen in Gloucester and New Bedford, and their political leaders, have been saying a true emergency exists.

At stake is the survival of traditional fishing in a number of New England ports.

So, it is clear that in our article , as Jim Kendall says, 'what you are reporting may be true enough, but you don't go far enough and report that approximately 68% of the NB fleet is not fishing! These landings that are coming in are from only 32% of the NB fleet, plus whatever other boats are landing in NB.'

'Does that seem to you like it's a success? Perhaps it would if you are one of those fishermen on the 32% side of the issue, but if you were on the 68% losers side, you would be reporting something totally different. This can only be described as a sin of omission as I have tried to stress this fact to you several times previously.'

The situation is like ten guys in a bar, 9 who are unemployed, and one pulling down $1 million per year. A bureaucrat looks at the bar and says things are great; the average income is $100,000 per year. But in fact, the 9 guys who are unemployed are ready to kill anyone who says they are doing fine. They are not. It is only the million-dollar guy who is doing okay.

Something of a similar situation exists in New England. That is why those who have been cut out of this catch share system are so mad, and also why they need help, despite the fact that there are some who are winners in the region.

It is a truism is that every allocation decision creates winners and losers. The subtext is that the losers just have to buck up and accept the new system, like they would if their business went under or could not make it. But in this case, the business failures are due to government action – not poor decision making on the part of the small boat owners.

How did we get to this point where the facts on the ground – widespread frustration and fury on the part of fishermen who feel cheated and abused by NMFS – contradict the optimistic bureaucrats who say the system is working because values and revenues are up.

The problem is the way in which the New England system created winners and losers had a fatal flaw.

The fatal flaw was that not all permits were treated equally. Prior to the catch share system, there were about 1200 to 1400 active permits, all with various days at sea allocations; and about 700 vessels were using these permits either as owners or leasing, to land fish.

The days at sea system, designed by NMFS and the council, treated all permits equally. When first allocated, each permit was assigned the same number of days at sea – although over time through consolidation various permits came to represent different amounts of days at sea – the fact was that basically each permit was treated equally.

When the council adopted the catch share system, they voted to use only fishing history – i. e. the allocations were to be made 100% on the landings history associated with a permit, not the days at sea. Suddenly, two permits each with 30 days at sea were worth wildly different amounts. The one with little history was inexpensive, the one with substantial catch history was not.

As small boats in New England struggled to stay afloat in the years leading up to catch shares they bought or leased more permits – and since the days at sea permits appeared equal – i. e. one 30 day permit gave you as much fishing time as another 30 day permit, the smaller boat owners naturally gravitated towards the least expensive permits.

Meanwhile larger vessels and fleets with access to capital were snapping up the more expensive, and more valuable, permits with history. They gave them no short term benefit – only a long term potential payoff based on the new allocation system.

The upshot was, as Daniel Bubb says, that in the year before catch shares he was landing over 200,000 lbs of cod – as a day boat operator from Gloucester. He was subject to the trip limit of 800 lbs per day, but had enough days at sea to fish most of the year.

After the catch allocation was put in place, his two vessels were allocated 9,200 lbs and 11,000 lbs of cod.

He went from a fishery that employed several crew to one that couldn't fish. On one boat, his 'allocation is 30,000 lbs, and every species is a choke species.'

To be cut from 200,000 lbs to less than 30,000 lbs seems extremely unfair – and this situation was repeated throughout the groundfish fleets in both New Bedford and Gloucester. This was a far greater cut than needed to rebuild stocks.

As Bubb says, if NMFS had simply said last year you caught 250,000 lbs and this year we are cutting that to 100,000, but you can fish in the most efficient way – he would have been jumping up and down with relief.

The council had an option of considering vessel fishing power or days at sea permits as well as history, and it could have looked more closely at the impact and consequences of devaluing the existing currency which was days at sea.

But that did not happen. One reason was that so much fury was directed at the change to the catch share system itself that the people most hurt by it were not willing or in the mood to try and make it work.

Now the system is in crisis, due to the fact that traditional small boat fishing in Gloucester and New Bedford is under extreme threat. Most politicians and even those who advocate catch shares, don't want to be held responsible for the death of a 400 year old fishing tradition at the same time as regional fishing stocks rebound.

But to save it, the reality has to be faced: the initial allocations set up an unacceptable system of winners and losers, and one of the most important aims of government aid or intervention is to stabilize the fleets most severely hurt – which are the smaller day boat fleets in Gloucester, New Bedford, and other small ports up and down the coast.

The proposed solutions – increasing allocations of yellowtail or other species, are not enough to do the job, because the benefits will flow primarily to the winners in the allocation system.

The reality of the suffering of these fleets is a wake up call, and I for one will not write again about catch shares, which when properly designed are still in my opnion are the best long term fishing solution, without acknowledging the inequities that have put the New England fisheries into crisis and the need to correct them.

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John Sackton, Editor And Publisher Seafood.com News 1-781-861-1441 Email comments to jsackton@seafood.com

 

 

 

 

The industry appears to be fully behind a bill that will, for the first time, mandate safety inspections of all commercial fishing vessels. Currently, the safety inspections are voluntary. Yes, voluntary – in the most dangerous occupation in the nation.

The bill, sponsored by U.S. Rep. Barney Frank, D-Mass., in response to fishing deaths off the New England coast, was approved in both the House and Senate and is awaiting President Barack Obama's signature. The president is expected to sign it.

In addition to mandatory U.S. Coast Guard safety inspections twice in every five-year period, the bill will require safety training for vessel operators, new construction standards for boats longer than 50 feet, and the addition of a "load line" (to show how low in the water a loaded boat can go before becoming unstable) on boats longer than 79 feet.

The bill also allows some leeway for older vessels that can't meet all the standards for new vessels. The industry was concerned that the new rules could drive some boats out of business. That seems reasonable – depending on the amount of leeway granted. After all, the age of the nation's fishing fleet is, in fact, a key component of the safety problem.

But it is a good sign that Congress has finally addressed this problem – and that the fishing industry is behind it. Too many have already died – nine alone aboard vessels fishing out of Cape May, the Lady Mary and the Sea Tractor, in 2009. The port of Point Pleasant Beach lost two fishermen aboard the Alisha Marie in that same year.

Read the complete editorial from the Press of Atlantic City.

 

 

 

 

 

An opinion piece by Mike Flaherty laid blame for the demise of East Coast river herring on the midwater trawl sea herring fishery. I respectfully disagree with his assertions that the midwater trawl fishery for herring and mackerel is essentially the smoking gun.

There are many sources of river herring mortality. We are actively addressing ours, discussed in more detail below. I also trust that the Massachusetts Division of Marine Fisheries will choose to set the record straight as their lead anadromous fisheries biologist was quoted by Flaherty from a 2004 meeting and taken out of context of today's body of knowledge.

Much has been learned since 2004 about river herring mortalities. As an industry, we have taken a proactive approach to minimizing our interactions with river herring stocks. As well, the public deserves to hear some rarely heard facts about interactions of river herring with commercial fisheries:

    • Incidental catch of river herring is not a new phenomenon. National Marine Fisheries Service surveys since 1960 consistently document river herring catches in the bottom trawl survey from Maine to North Carolina.
    • Other fisheries throughout the northeast catch and kill an amount of river herring equivalent to the midwater trawl fishery.
    • No river herring stock assessment exists to provide a benchmark for recovery efforts, so determining the conservation cost-benefit of any remedial actions, as required by the National Environmental Policy Act known as NEPA, is very difficult and further complicated by natural mortality of river herring and habitat destruction.
    • As the lead management agency with jurisdiction over river herring, the Atlantic States Marine Fisheries Commission is working through its science-based technical committee to address the issue region-wide among all fisheries with documented river herring interactions.

In 2004, some midwater vessel operators began experimenting with voluntary bycatch reduction efforts. Success with these efforts has led to the funding of a more formal, multi-year river herring avoidance project.

Developed by the midwater trawl industry in partnership with the UMass Dartmouth School for Marine Science and Technology and the Massachusetts Division of Marine Fisheries, and endorsed by Alewife Harvesters of Maine and the Environmental Defense Fund, this project will start in October.

Read the complete opinion piece from the South Coast Today.

 

 

 

 

 

The reforms to the fishing system in New England are a step in the right direction for the future of the fisheries and the fishermen who are losing out are victims of past mismanagement of the fisheries, not the new system.

The trouble is that fish stocks are indeed collapsing all over the world, for the most part because governments have encouraged, by subsidy and other misjudged policies, overfishing to a level that private ownership of fisheries would never have tolerated.  Fisheries are a textbook example of the tragedy of the commons – fishermen are inclined to take as many fish as they can because if they don’t, someone else will.  The textbook answer to a tragedy of the commons is to assign ownership rights, but governments all over the world have refused to do that, or have interfered in traditional arrangements for protecting fisheries.  Moreover, governments have subsidized fishing fleets in order to “protect traditional industries” and for other reasons, which has exacerbated the problem by making fishing fleets far too large.

As John Tierney put it in the New York Times, “The Canadian and American governments devastated one of the world's most productive fisheries, the Georges Banks off the coast of New England, by helping to pay for bigger boats. Now, even as scientists urge limits on lobstering, state and federal governments continue to offer tax breaks and other incentives to the lobstermen at Point Judith.”

Read the complete opinion from the Washington Examiner.

 

 

 

 

 

Jane Lubchenco, career environmental activist and author of a cap-and-trade plan for America’s fisheries, is the most controversial director ever to run the National Oceanic and Atmospheric Administration.

She is at the center of a classic Washington Iron Triangle that includes wealthy liberal foundations, radical environmental nonprofits and multiple government officials, many of whom, like Lubchenco, came out of the foundations or activist groups.

Lubchenco has done so much to kill the New England fishing industry that 300 angry Gloucester, Mass., citizens protested outside the regional office of the federal fisheries service last October.

They didn’t hang Lubchenco in effigy. Instead, they mounted an ugly mannequin representing her, looming over a gallows where she was the one hanging two fishermen in effigy. The signs pinned to their heavy weather gear read, “Betrayed by government.”

Read the complete opinion piece from The Washington Examiner.

 

 

 

 

 

 

 

Sorry, Mr. Juliand.  It's not about you. It's about an out-of-control, arrogant agency that "lost critically important perspective on their duty and obligations" and has been tormenting the citizens whose taxes and fines paid their salaries and expenses and (maybe) their bonuses.

STONINGTON, CT – Sept. 26, 2010 – NOAA Senior Attorney Charles Juliand has, through his federal employee union, issued comments in response to the Inspector General's report on NOAA Enforcement in the Northeast . The report referenced statements, notes and actions taken from cases he prosecuted in the past several years.  It noted that, among numerous other colorful notes and comments, his proclivity for referring to defendants as “lying sack[s] of s***” created the perception that he "– along with the office—has lost proper perspective and harbors bias."

Mr. Juliand notes that he received a NOAA Administrator’s Award “for worldwide leadership in establishing the legal soundness of new satellite technology – vessel monitoring systems – in law enforcement actions against marine resource violators” and the Department of Commerce’s Gold Medal Award “for distinguished achievement in the federal service”. 

He expects us to believe that these awards — Oscars-on-the-Potomac given by government agencies to career employees with the frequency that Kindergarten teachers hand out Kleenex™ — actually mean he did good work, rather than serving as a cog in a self-congratulatory, corrupt system.

He offers no response to charges verified by the Inspector General, but would like us to believe that twenty pages of detail — showing how the Inspector General investigated 27 complaints and painstakingly either confirmed, failed to substantiate, or found the allegations inconclusive — was a coordinated effort by a "small group of lawbreakers and their minions" aimed at making scapegoats of those "who have faithfully carried out the dictates of the law."  He ignores the Inspector General's detailed findings that many "individual complaints we examined are credible, have merit, and we consider appropriate for further review."

I guess he'd like the public to believe that the fishermen, the shoreside businesses, the Office of the Inspector General, the Congressional oversight committees, Congressional delegations from Maine to North Carolina, the mayors, governors, lawyers, judges, reporters, columnists, scientists and researchers are all in a conspiracy of "false and unsubstantiated charges" in order to "smear" him and his colleagues. 

Now there's an ego!  Methinks the man doth protest too much.  That's the kind of ego that can lull someone to believe that they're above the law.  To believe that the law doesn't apply to "dedicated public servants", only to the "regulated community".

The reality is simple.  Mr. Juliand doesn't rate the energy that would be needed to organize a conspiracy on the level he is implying.

What he doesn't "get" is that this is not about him.  "Nothin' personal", —although he's hurt a lot of people.  He's a cog in the much larger and more sinister, powerful, and oppressive agency that we're fighting.  An agency which corruptly and wrongly allowed people like him to misuse their "virtually unchecked prosecutorial discretion."  An agency which is now focused on an insane push to "profitize" our ocean resources.

There is a reason that the Inspector General is "initiating a formal review of NOAA’s progress in implementing the corrective action plans".  This isn't about  Mr. Juliand.  This isn't a case of one rogue attorney working without "management attention, direction, and oversight."  It's about an out-of-control, arrogant agency that "lost critically important perspective on their duty and obligations" and has been tormenting the citizens whose taxes and fines paid their salaries and expenses and (maybe) their bonuses..  That is why the Inspector General found "a compelling basis to look back at NOAA’s enforcement cases to determine whether there are individual complaints and cases that require action to correct unfair enforcement."

As much as many of us wish we could take credit for being among the "minions" responsible for exposing NOAA attorneys whose "serious lack of judgment" allowed them to  take actions that constitute "conduct unbecoming a federal government attorney charged with enforcing the law," the reality is simpler.  Eventually, our system works.  This this is a case of good government — eventually and after a long, long, time —  ferreting out bad government.

But Mr. Juliand's conspiracy-theory laden response has given me one idea.  Perhaps fishermen should take a cue from Hollywood and the Federal Government and start giving out routine self-congratulatory awards.  Then, when we find that we made an honest mistake, resulting from what the Inspector General observed as "fishing regulations promulgated by the Fisheries Management Councils [that] are complex and can change significantly", we can argue: "Ok, maybe I made a mistake, but look at my record, in 2006 I was awarded the Golden Twine Top Medal!"

Sorry, Mr. Juliand.  It's not about you.

Then again, never ever trust anyone that calls us "fishers".

Dick Grachek is a "fisherman" based in Stonington, Connecticut

 

 

Perhaps he didn’t read the same IG report I did. Perhaps he made the comments before the IG report was released. But as Deputy Assistant Administrator for Regulatory Programs for the National Marine Fisheries Service, Mr. Samuel Rauch should have had a better grip on the issues involving the agency he purports to oversee

 Perhaps he didn’t read the same Inspector General report I did. Perhaps he made the comments before the report was released. But as Deputy Assistant Administrator for Regulatory Programs for the National Marine Fisheries Service, Mr. Samuel Rauch should have had a better grip on the issues involving the agency he oversees — especially those so serious as to evoke an investigation from the Department of Commerce’s Office of Inspector General — regardless of what particular aspect of that agency he may directly manage.  I do not work for NMFS. But I have read the report.

According to a Feb 24, 2010 “status” and “issues” briefing on the Inspector General’s report into law enforcement (read the transcript here).  Mr. Rauch made statements that contradict the intent of the investigation and its findings. First of all, Mr. Rauch attempted to downplay the significance of the Northeast fishing fleet in the report. He used phrases like “some pressure in the northeast”, and “comprehensive nationwide review of policies”, “nationwide review of all the policies that were going on” and emphasized not looking at the northeast “in isolation”. This glosses over the fact that the report itself-  spawned by complaints of unfair law enforcement in the Northeast and requested by the Massachusetts Congressional delegation, later joined by the North Carolina delegation – states in its  opening that it is responding to concerns “particularly in the Northeast Region”. (See the report at: http://www.oig.doc.gov/oig/reports/2010/OIG-19887.pdf). While it is true that the Office of Inspector General spoke with individuals from across the nation, a good portion of the report focuses on the Northeast, and with good reason. When NOAA is levying fines in New England and the Northeast twice as often and with penalties up to 500% higher  than elsewhere in the country, NOAA has a problem.

Mr. Rauch apparently does not see this. His interpretation of the situation is as follows: "There had been some pressure in the northeast, particularly some defendants have claimed that they had been unfairly singled out, which is actually quite common with any law enforcement effort where potential defendants try to in order to defray the focus on them, try to make public announcements.  But they were particularly successful given all the things that are going in the northeast….”

Instead of  being concerned with the abuse of power uncovered by the report — and all one needs to do is read the report to read accounts of this abuse — Mr. Rauch  attributes widespread corruption across his agency to  a few upset fishermen attempting to throw a smokescreen over their  cases. He contends this was only successful due to the hype surrounding industry outrage over sector management. I did not read about sectors in the IG report. But I did read accounts of highly dysfunctional law enforcement, not just in a few cases, but many. Terms used by the report to describe the scenario were “systemic” issues, and “particularly in the Northeast”.

He said that “you will see from the results most of the things that the industry raised, the IG did not find it meritorious to address". I did not see that from the results of the investigation. Actually, I read in the report that “[m]ost of the complaints…received from fishing industry parties, particularly in NOAA’s Northeast region, fell into…three categories”. Those three categories just happened to be the three investigative topics of this first IG report. Not to mention that two additional areas of inquiry- excessive fines and abuse of authority/discriminatory treatment by NOAA enforcement personnel- that were continually mentioned by dozens of fishermen interviewed in the process of compiling the first report led to a second, follow up, report. Why? In order to address these exact matters.

Further, Mr. Rauch made this assessment “the IG went and interviewed a lot of various people they called the complainants. They did not make an effort to verify the individual complaints." I may not be able to personally verify every one of the various complainants whose cases were described by the IG. But I know for a fact that two have been verified and widely documented, one being the Gloucester Seafood Display Auction, which is actually mentioned by name in the report. Correspondingly, if complainants were merely making personal excuses intended to “defray the focus” their own cases, or inventing bogus stories, the final findings of the report would not be what they are. Nor would there have been a second report as equally justifying to fishermen as the first.

It is a widely used adage that, “The first step towards recovery is admitting you have a problem.” If top NOAA employees such as Mr. Rauch do not acknowledge the severe failures within their agency and make a true effort to rectify them, true change will not come any time soon.

Meghan Lapp is employed as a net-maker at Reidar's Manufacturing in Fairhaven, Massachusetts.