The GOM cod spawning stock biomass was estimated to be at 11,868mt in 2010. The SSC has stated that if the SSB that falls below 7,300mt, the lowest SSB ever recorded (1999), the situation would represent “a state never encountered and therefore in the SSC’s judgment presents a significant risk.” The fundamental goal in the near term should be to minimize risk of further SSB or B declines while mitigating short-term economic/social consequences on the most affected fishermen.
The 6,700mt to 7,500mt ACL range proposed by the NEFMC carries with it an estimated 33% chance that SSB could go below 7,300mt and therefore place the fishery at significant risk. It also appears to guarantee that ACLs would be so low in FY2013 that even by-catch fisheries on GOM cod might have to close. The Council recommendation of opening additional closed areas without any analysis of GOM cod (or GB cod) impacts and with complete disregard for the 8 years of work undertaken by the NEFMC Habitat Committee is incomprehensible. The recommendation also fails to provide any compensation for the differential economic and social impacts of managing this emergency through ACLs alone. The net present value (NPV) analysis available to managers of this and other ACL scenarios does not factor in any of the known risks of further SSB declines. Those are simply unacceptable management actions given current information before the agency; they put inshore fish populations, fisheries, and the smaller fishing communities at significant long-term and perhaps irreversible risk.
The 2012 & 2013 ACLs, management measures, and emergency relief should be structured with a goal of minimizing the risk of further SSB declines; protecting the small vessel, inshore fleet from collapse; reducing the potential revenue differential between the FY 2012 and FY2013 ACLs; and providing emergency financial assistance during the bridge period. This could be done with an tolerable reduction of 5-year NPVs for the fleet and with a distributed economic impact across the groundfish fleet.
The management strategy should not and does not need to be based on an approach that either assumes that the near-term assessment science will significantly change the GOM cod biomass estimates or that there will have to be a full or close to full closure in FY2013. Available GOM cod ACLs should be targeted toward small inshore boats to reduce the disproportionate impacts of ACL reductions on this sector of the fleet. See text and Tables 1 and 2 attached below. See also National Standards 4, 6 & 8.
Read the complete position paper from The Conservation Law Foundation