Saving Seafood has submitted this response to the Boston Globe's March 27 editorial "Bring this Fishery Back".
Also, read Jessica Burrows' letter to the editor.
by Robert B. Vanasse, Executive Director
The Globe’s March 27 Editorial “Bring this Fishery Back” correctly assessed the one-year “Interim Rule” proposed by the National Marine Fisheries Service for 2009 as “restrictions that come close to shutting the fishery down”; but nonetheless urges the NOAA administrator Dr. Jane Lubchenco to impose them.
The Globe states that the NOAA Administrator “could offset some of the financial loss to the industry by paying fishermen for their work in making the transition to the new management system.” Perhaps she “could” do this if there were funds available under the direct control of the Administrator for this purpose, but there are not.
While the system proposed for 2010 onward is expected to improve safety by alleviating the current system’s pressure to work in foul weather, the Interim Rule’s closed areas and restrictions decrease safety by encouraging fishermen to travel further than usual in small boats.
The Globe mischaracterizes the one-year rule as being “designed to give groundfish stocks … a chance to rebound [before 2010]”. Species with a 7-12 year lifespan do not rebound in a single year. The 2010 system is expected to provide incentives to rebuild stocks, but the 2009 rule is a stop-gap measure for a single year. It is not expected to achieve the management reforms and resource improvements that the 2010 system intends. A stop-gap measure should not shut down an industry.
The editorial did not mention that there is an alternative interim plan for an 18% cut that passed the New England Fisheries Management Council by a 15-1 vote — with the support of both industry and environmental advocates. The lone vote against this plan was cast by the regional NMFS administrator, who advanced the more severe plan against the advice of her statutorily-mandated advisory council.
The Globe correctly observed that Marine Fisheries scientists limit the total allowable catch to amounts they believe are sustainable. But it ignored the long history of regulation that prevents fishermen from actually catching to these limits. Only two species (monkfish 101% and white hake 87%) of the ten species for which NMFS statistics are available had commercial landings at levels near the total permitted. For most species, fishermen landed only 4%-52% of the allowed catch. For haddock and cod, two mainstays of the New England Fishery, only 32% and 48% of the limits were landed.
Uncaught fish are not sold at auction. Uncaught fish translate to dollars that did not go to working families, and taxes that were not paid to struggling municipalities during difficult times. Poor regulatory schemes have forced New England fishermen to leave half of their potential legal within-limit earnings in the sea.
The Globe’s position, like the NMFS proposed interim rule, ignores National Standard 8 of the Magnusen-Stevens Act: “Conservation and management measures shall… take into account the importance of fishery resources to fishing communities in order to (A) provide for the sustained participation of such communities, and (B) to the extent practicable, minimize adverse economic impacts on such communities.”