EDF consultant Richard B. Allen has written to both Rhode Island Senators claiming that, "[New Bedford, Massachusetts] Mayor Lang's crusade is emotionally and politically attractive, but it is short on facts and logic."
Mayor Carolyn Kirk of Gloucester, New England's oldest port and #11 in the nation, will join Lang, of the nation's top fishing port and the largest in New England, for Tuesday's meeting at the U.S. Capitol. It will be attended by at least 35 industry representatives and several Members of Congress and the Senate.
In advance of the meeting, Gloucester 's Mayor Kirk was blunt in her outright dismissal of Allen's claims for a lack of economic damage, citing his work for environmental interests with a long demonstrated opposition to the economic concerns of fisheries.
"Follow the money," she told Saving Seafood. "How is this gentleman funded? He's pimping for his clients."
In a copy of the letter obtained by Saving Seafood, Allen argues that claims of harm are undercut by data showing that New Bedford and Massachusetts have, "done quite well under Amendment 16." He writes that ground fish landings are up 116% and revenue is up 129% for May 1,2010 through January 31, 2011 in New Bedford when compared to the same period in 2009, prior to the regulations taking effect. In addition he says that revenue per time at sea has increased "significantly", arguing that this indicates a rise in revenue as production costs declined.
He also attacks the economic impact report submitted to Commerce Secretary Gary Locke by Massachusetts Governor Deval Patrick for failing to consider possible increases in one catch area for individual fisherman who catch multiple species, arguing that only decreases were counted.
Dan Georgianna, the University of Massachusetts Dartmouth's Economics Department Chair who helped write Governor Patrick's report, took strong issue with Allen's analysis that sectors are proving economically effective and a boom to New Bedford, noting a lack of data showing profits are higher or that local economies are better off with the sectors regulations. He countered that local businesses are saying the exact opposite.
"There is virtually no data that supports most of his claims, especially about the success of sectors," Georgianna said via email. "The bottom line here is that New England groundfish landings are down 15% from last year, revenues are slightly higher only because prices have risen substantially. The large difference between quota allocation and landings remain probably due to the small quotas for "choke" species."
In an interview with Saving Seafood, Allen acknowledged the limited data about the economic impact of Amendment 16, noting that this limits claims made by all sides of the debate. He also cites the need for longer-term economic analysis as driving his overarching argument for giving more time to measure the impact of the regulations versus shorter-time industry concerns that being recognized by local and state-level critics.
"I'm maintaining that we have to look at longer period of time," Allen told Saving Seafood about claims of economic harm. "How about comparing 2010 to the last ten, fifteen years or more?"
"I'm (also) making another one (argument) that it depends if you are looking at an individual fishing business or whether you are looking at the local economy," he said.
One of the major issues pointed to by Lang and other critics of the NOAA regulations to demonstrate their negative impact on local fisheries is the number of once operating boats that are now idle because fisherman found it more financially beneficial to sell their lease quotas to other, typically larger commercial fishing operations. Allen claims in his letter that press reports blaming this on Amendment 16 are misleading and inaccurate, citing data from an unknown source:
"In fact, however, the MA report states that 'The number of inactive vessels in 2010 increased by 17 vessels over the average number of inactive for the first five months of the fishing year from 2005 through 2009'," he wrote. "What the report does not tell the reader is that the number of MA groundfish vessels that called in on a groundfish DAS declined from 385 in 2005 to 266 in 2009, an average decline of 30 boats per year. If there were 17 more inactive groundfish boats in 2010 compared to 2009, that would represent a slowing of the decline compared to the previous management system."
Emily F. Keiley of UMass Dartmouth's School of Marine Science and Technology said that Allen's claims about the slowing of the decline in inactive vessels "is simply not true." Citing National Marine Fisheries Service data supplied by local fishermen through December 2010 and made available to the Massachusetts Division of Marine Fisheries, Keiley says that the total revenue data shows there were 218 inactive commercial fishing boats in 2009 and one more total inactive in 2008. The number of inactive vessels in 2010 was 243.
"Of the 500 vessels that qualify for sectors, 99 are not fishing for ground fish, 27 not fishing at all," Keiley told Saving Seafood. "I just went through the data again and in 2005, of the 500 vessels we have data for, 227 were inactive (the most until 2010) – In fact more vessels fished in 2006, 2007 (223 vessels), and even more were active in 2008."
Allen argues more broadly that it is improper to even consider leasing in economic impact estimates for the regulations because it does not truly function as a cost of doing business but part of the impact towards greater efficiency that catch shares can provide the industry if properly implemented. He notes in the letter that if somebody was doing well under the old system, their catch history was sufficient to get as much allocation as they were catching in 2009.
"Leasing is just a different distribution of the problem," said Allen. "It's a natural thing to be upset about it. The lease cost of the individual fisherman may appear to him that he's taking in less money but from the standpoint of the economy of New Bedford, the economy of Massachusetts, lease costs do not reduce economic benefit to the fisherman, in fact they probably produce more economic benefit for the local economy,"
Allen and his critics do agree on a few things, including the fact that no one can yet fully understands the economic impacts of Amendment 16. It's also certainly a matter of perspective in ways as to what the total impact has been. If the response to his letter is any indication, there is also an unavoidable emotional component to the economic issue for local and state fishery interests.
"We can tell you people are not fishing and people are losing their jobs," Kristin Decas, executive director of the New Bedford Harbor Development Commission, told Saving Seafood. "He's arguing for consolidation. We can tell you we don't want to see consolidation, we want to see a lot of people going to work."
In his letter and subsequent interview, Allen argues that the efficiencies provided by consolidation under Amendment 16 will benefit the industry as whole and fishery economies in the long run. Citing past National Marine Fisheries Service research on the impact of external costs like fuel and insurance that economic benefits of which he argued tend to go to interests outside of a given state or locality, he said that leases will help ensure a greater level of revenue be spent locally. He also noted that Gov. Patrick and the critical mayors have yet to indicate how any further government assistance would be spent.
"That's just fundamental economic theory," he said before acknowledging the "transitional costs" to local economies from increased efficiency. "It's a downside to becoming more efficient. Again, the mayor and the governor are arguing about the economy of the city and the states and they have not said how they are going to use any assistance to help people that are being harmed in the transition."
When asked about his motivation for sending the letter, Allen – who owns a commercial industry consultancy that includes the Environmental Defense Fund among its clients, is a former Marine Fellow for the Pew Charitable Trusts (http://www.pewenvironment.org/research-programs/marine-fellow/id/8589940671), was a member of the New England Fisheries Management Council 1986-1995, and ran his own lobster vessel – said he sent it as a personal attempt to provide background information for his own congressional delegation.
"It just seems to me that what Mayor Lang and his group are putting out doesn't really tell the whole story," said Allen, arguing that he's always been "troubled" by the number of fisheries representatives that he claims do a "disservice" to the industry because they fail to understand the economics and dynamics that determine the fate of fisheries.
"People don't recognize the history of fisheries and actually don't recognize what would really create a viable fishery," he said. "It has been a problem for a lot of years."
Allen further argues that Lang and other critics don't "know what they want" instead of catch shares, offering no competing plans.
"They are just trying to stir things up and be popular because everyone who attacks the government is popular," said Allen. "It's very disturbing to me having tried to improve the status of the fishing industry for the last 40 years to see people coming at it this way."
Despite his being driven by a self-professed higher cause, Kristin Decas, executive director of the New Bedford Harbor Development Commission made it clear that Allen's description of Mayor Lang and the broader sector concerns he, Mayor Kirk, and Govenor Patrick are presenting reflect the real-world impact on everyday businessman and families.
"The Mayor is not on some emotional tirade," Decas told Saving Seafood. "He's campaigned for a very authentic issue that needs to be addressed. That need has been recognized by the scientists and the Mayor's Oceans and Fisheries Council. NMFS doesn't have the (total economic impact ) data. How can this guy have the data?"
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Text of Mr. Allen's letter:
Dear Senators Reed & Whitehouse:
It is my understanding that New Bedford Mayor Lang and his fishery advisors will be holding a meeting in the U.S. Capitol in the near future. As a Rhode Island fisherman who has been deeply involved in the fishery management process since 1972, I would like to offer the following background information concerning the current situation in the New England groundfish fishery.
Mayor Lang and Massachusetts Governor Patrick have claimed that Amendment 16 to the Fishery Management Plan for Northeast Groundfish has harmed New Bedford and/or Massachusetts economically. The available data suggests that New Bedford and Massachusetts have done quite well under Amendment 16. New Bedford groundfish landings are up 116% and revenue is up 129% for May 1,2010 through January 31, 2011 compared to the same period last year, before Amendment 16 went into effect. The data also shows that revenue per time at sea is up significantly, indicating that production costs are down while revenues are up.
Some opponents of catch shares claim that lease costs reduce the benefits of increased revenues. Lease costs arise from agreements between willing buyers and willing sellers who recognize the "gains from trade;" both parties expect to be better off or they wouldn't do the deal. From a community perspective, if fish can be caught with less expense by one boat rather than two, more revenue will stay in the local economy than would be the case if the boats spent more on fuel, insurance, and other inputs. That's because a big chunk of those expenses would accrue to vendors outside the local economy, possibly outside the country. Higher revenues with lower production costs make more of a contribution to the local economy. Lease costs are more likely to increase than decrease the contribution of the fisheries to the economy of New Bedford because they indicate that more fishery profits are staying in the local economy.
Massachusetts has been the recipient of multiple fishery assistance payments dating back to 1791, when a delegation of Marblehead vessel owners convinced the First Congress of the United States to enact a subsidy for the New England groundfish fleet. In 2008 Massachusetts simply divided the assistance money in proportion to the days-at-sea allocated to the groundfish permit holders. This approach helped the larger operators more than the smaller operators. Massachusetts now admits that the larger operators have fared well under Amendment 16, but have not explained how financial assistance would be used to benefit those most in need.
The economic analysis that MA submitted to the Secretary of Commerce presented calculations of economic loss as a result of the Amendment 16 allocations, but failed to consider the economic gains, either at the individual fisherman level or at the state level. A fisherman whose allocation of cod was lower than his recent landings might have had an allocation of haddock that was higher than his recent landings. Only the decrease was counted. For the NE fleet as a whole, we know that the total FY 2010 commercial annual catch limits were about 120 million lb higher than 2009 groundfish landings. That means that someone received allocations valued at $148 million more than 2009 landings, using the $1.23 average price from the MA report.
The press reports lead one to believe that large numbers of boats were idled by Amendment 16. In fact, however, the MA report states that "The number of inactive vessels in 2010 increased by 17 vessels over the average number of inactive for the first five months of the fishing year from 2005 through 2009." What the report does not tell the reader is that the number of MA groundfish vessels that called in on a groundfish DAS declined from 385 in 2005 to 266 in 2009, an average decline of 30 boats per year. If there were 17 more inactive groundfish boats in 2010 compared to 2009, that would represent a slowing of the decline compared to the previous management system.
Claims concerning the concentration of groundfish landings among a small number of vessels ignore the historic concentration of landings that has been evident in the groundfish fishery for decades. Like many other activities, the groundfish fishery tends to follow the 80:20 rule, which says that 80% of the production will likely come from 20% of the boats. That is not a new phenomenon that results from Amendment 16, but it has been cast as such.
With regard to the status of smaller boats compared to larger boats, it is important to recognize that the offshore stocks of Georges Bank haddock and Gulf of Maine redfish have shown the most rapid rebuilding. That means that the greatest opportunity for increases in landings will be available to larger, offshore boats that can access those stocks. In contrast, the stocks available to smaller, inshore boats have been slower to rebuild relative to the number of boats fishing for them. That fact has limited the expansion opportunities available to the inshore fleet. Future years will likely see increases in the allowable catch for inshore stocks, but it is not yet clear whether the current fishing capacity of the inshore fleet still exceeds the productivity of inshore stocks.
There is no question that the costs associated with sector management could be a problem for fishermen in the future. The fishery management council needs to look at ways to reduce the costs and the intrusiveness of groundfish monitoring programs, especially for smaller boats. To date, however, increased costs have been largely subsidized by NMFS.
It is also clear that many of the sector costs are the result of decisions by the sector organizers and leadership and are not inherent in the management system. Sectors could streamline their operations and reduce costs.
The bottom line that many critics fail to recognize is that the sector system gave fishermen greater authority to self-manage the groundfish fishery. Fishermen have been asking for more involvement in the management system since the beginning of federal fisheries management in 1977. To the extent that the sector system is not working the way fishermen want it to, they have the power to change it because the sector members can change many of the management rules on their own. They can also develop and implement more cost efficient procedures for monitoring and reporting catches.
Fishery representatives who object to catch shares and sector management seem to be saying that they would rather have the government tell them how, when and where to fish than to take the responsibility to manage their own catches. Progressive fishermen in RI and MA have shown that sector management can produce real benefits in terms of increased profitability and reduced discards. The critics of catch shares have no viable alternative to suggest.
I don't agree with all of the decisions that have been made by the New England Fishery Management Council or by the National Marine Fisheries Service. I have no doubt that there will always be new and improved science that can be applied to the determination of annual catch limits. I am equally certain that catch shares give fishermen the best opportunity to adjust to changing resource conditions, whether real or perceived.
Mayor Lang's crusade is emotionally and politically attractive, but it is short on facts and logic.
I hope that this information is helpful to you.
Sincerely, Richard B. Allen