To the [Gloucester Times] editor:
These are remarks I have submitted to the National Oceanic and Atmospheric Administration for the "public comment" period on the proposed use of "catch shares" as a fisheries management tool:
"I must first admit, that I am confused by the request for public comments on the validity of 'catch shares' as a fisheries management tool, when the agency (NMFS) has already directed the New England Fisheries Management Council to implement the use of 'catch shares' in the New England groundfishery and has used them in other fisheries as well.
"I would think it would be more appropriate to solicit comments from the public in advance and fully vet the strengths and more importantly, the weaknesses, of a program such as 'catch shares' before making any decision to implement such a program.