The Northeast Seafood Coalition has expressed six observations regarding the NMFS Final Interim Rule.
1. The Final Rule is an improvement from the previously proposed NMFS measures but falls short of the Council’s plan. Furthermore, we cannot lose sight that these measures present an enormous loss from where we are today.
2. The manner in which the economic figures in the Final Rule are represented masks the devastation these measures will have on the groundfish fishery. The figures appear to incorporate the revenue of all fishing in aggregate including scallops, lobster, rather than examining groundfish revenue only.
3. NMFS’s election to go beyond Magnuson requirements for an Interim Rule, especially for Southern England winter flounder, contributes to a substantial portion of these negative impacts.
4. NMFS refers to this Final Rule as a "bridge"; however, we need to fully understand where this "bridge" is leading. It cannot be a bridge to nowhere. A bridge to an undefined future provides no benefit.
5. Any discussion of a "bridge" needs must not be theoretical. This "bridge" must be built immediately, and public investment is required. The fishery needs transitional assistance; funding and other responsibilities cannot fall on a fishery that has been financially crippled by regulations and unrealistic law. NMFS must lead this effort by committing substantial human and financial resources.
6. The completion of Amendment 16 and the development and implementation of “Sectors” is threatened if the Southern New England winter flounder assessment is allowed to stand. NMFS needs to focus 2009 resources towards updating this assessment.