NSC believes any and all groundfish management measures must be highly sensitive to the potential for unintended consequences to all segments of this fragile fishery.
WASHINGTON (Saving Seafood) October 12, 2012 -- On Wednesday, October 10, the Gloucester Daily Times reported that "NOAA's regional administrator, joined by the Environmental Defense Fund, the Pew Environment Group, the North Atlantic Marine Alliance and Food & Water Watch, is supporting a belated effort by the federal government to limit the accumulation of catch shares and thus provide safeguards to smaller independent boats in the Northeast groundfishery..."
Quoting from the Northeast Seafood Coalition Groundfish Amendment 18 Scoping Comments, the Times reported "NSC (the coalition) 'believes that legitimate goals concerning diversity, excessive shares and consolidation should and will be most effectively addressed by the individual sectors rather than through a council regulatory process,' the coalition said in its written submission to NOAA."
The Northeast Seafood Coalition has released the following statement expanding and clarifying their long-held position on this issue:
GLOUCESTER, Mass -- October 12, 2012 -- The groundfish fishery is currently faced with an overwhelming number of challenges, including massive reductions in annual catch limits (ACLs) for numerous core stocks in the Gulf of Maine and Georges Bank and the obligation to reduce interactions with protected species. The management responses to these challenges threaten to destroy many fishing businesses and force far greater changes in the demographics, diversity and consolidation of our fishery than anything the sector management system ever can or will. Consequently, the financial viability and future of this fishery is in serious jeopardy as never before.
NSC believes any and all groundfish management measures must be highly sensitive to the potential for unintended consequences to all segments of this fragile fishery. NSC's efforts have consistently focused on the need to prevent excessive shares of groundfish resources and the need to preserve fleet diversity.
While the issue of excessive shares is a valid concern within a Limited Access Privilege program ("LAPP") or a non-LAPP management system, NMFS has made a definitive legal determination that the sectors are not LAPPs as defined in the Magnuson-Stevens Act ("MSA") and that sector allocations are not permanent. NSC is concerned the consideration of accumulation limits and other concepts being discussed in the context of Amendment 18 may be driven by the desire by some to "backfill" Amendment 16 sector management to qualify as a LAPP under the MSA. With these points in mind, NSC has adopted the following position:
"A LAPP should not be developed unless and until fishermen themselves develop and propose a LAPP through the petition process set forth in section 303A(c)(6)(B) of the Magnuson-Stevens Act (MSA), (rather than being developed from the "top-down" though a Council-initiated process), and that all elements of the Amendment 16 sector system including the allocation formula are on the table for reconsideration in that process. If Amendment 18 develops into an effort to retrofit the current Amendment 16 allocations and the sector system to qualify as a LAPP, then NSC must oppose it."
NSC is also committed to the need to preserve fleet diversity and has invested deeply in achieving this objective. The NSC has played a pivotal role in the "Northeast Multispecies" (groundfish) fishery and its management as the sponsor of 12 of the 19 sectors now operating in the fishery including one serving as a 'lease-only' sector. Consistent with its longstanding support for family-owned businesses and a diverse fishery, NSC sponsored and designed the NEF sectors to be inclusive of the full diversity of fleet and community demographics that were representative of the entire groundfish fishery. Each sector is rooted in a particular community, with communities defined by localities, fishing styles, and other commonalities that include vessel size, gear, target stocks and home ports throughout the full range of the fishery. The opportunity to join NEF sectors was open to all groundfish permit holders regardless of the size of their initial allocations or whether they were members of NSC.
NSC's work during A16
NSC worked diligently during the Amendment 16 process to advocate for alternative baseline formulas other than pure catch history.
NSC was the only organization who took the initiative to commission an independent report to analyze the impacts of the different baseline formula options.
Many of our fishermen are concerned that Amendment 18 could place additional layers of fishery input controls and constraints on sector operations, including their essential ability to trade or lease ACE. Such external controls might undermine the intended benefits of 'output control' management including the individual ability of each sector to pursue economic viability and preserve their unique demographic identities. As explained above, NSC went to great lengths to ensure that Northeast Fishery Sectors were provided with a critical level of local, small business control and the tools for sector self-determination as a deliberate alternative to imposing rigid external fishery input and sector operational controls.
NSC urges very careful consideration of these issues and general caution for any unintended, if well-intentioned, consequences of such controls. Sector management has been characterized as an opportunity for fishermen to have greater control over the manner in which they harvest and manage their ACE. The Council should maximize opportunities/flexibility for sector and fishermen in Amendment 18.
Read the NSC's Groundfish Amendment 18 Scoping Comments from April 2012