WASHINGTON (Saving Seafood) Dec. 17, 2012 – The Northeast Seafood Coalition (NSC) today submitted comments to the New England Fishery Managment Council with recommendations for the Council to consider as they deliberate on Framework 48. NSC emphasizes the overall state of the industry and the fundamental flaws of the system under which the fishery is currently operating. In addition, NSC provides recommendations that may serve to partially mitigate the impending crisis in 2013.
The following is excerpted from the NSC comments.
Our fishermen were promised that if by some miracle they were still in business at the end of this extraordinary and overly ambitious experiment they would enjoy the fruits of their struggles and sacrifices. Instead, they find themselves the subject of a cruel joke which, for many fishermen, will likely end once and for all in fishing year 2013. For whatever reasons—in some ways it really doesn’t matter—the stock assessment process indicates that notwithstanding this incredibly painful effort many key stocks are simply not responding. The proposed ACLs are simply insufficient to sustain this fishery in 2013. This is indeed a disaster on top of a disaster.
Efforts by our Congressional Delegations to secure economic assistance will be critical to help get at least some of our fishermen through this—to get over the bridge from ‘here to there’. But where is there? At some point everyone in the groundfish community—the scientists, managers and policy-makers—need to accept the reality that the current process is just working. We need to step back out of the weeds and look at the bigger picture. There are critical elements of the science, management and law that all need to be fixed. We cannot remain in the same box, performing the same rituals and expect a different result. The ‘there’ needs to be a very different place.
The Northeast Seafood Coalition (NSC) has asked for the following:
1) Interim Measures for Gulf of Maine cod and Gulf of Maine haddock
NSC strongly recommends that the Council initiate this process by submitting a request to the agency to implement interim measures for Gulf of Maine haddock to reduce overfishing in fishing year 2013 pursuant to Magnuson-Stevens Act (MSA) section 304(e)(6).
In summary, the NSC memo also concludes that there is a very clear and sound legal basis for the Council to request and for the agency to implement interim measures to reduce rather than end overfishing for Gulf of Maine cod for a second year in fishing year 2013. In accordance with MSA section 304(e)(3), the Council has initiated the process to ‘prepare and implement’ a revised rebuilding program for Gulf of Maine cod and has up to two years to complete this process. Section 304(e)(6) clearly contemplates that the Council may request and the agency may implement interim measures to reduce rather than end overfishing during this revised plan development process.
Also pursuant to section 304(e)(6), such interim measures are to be promulgated according to the MSA section 305(c) process for ‘Emergency Actions and Interim Measures’. This process allows for a specific Interim Measure to be implemented for a total of 366 days. It is critical to understand that MSA section 305(c) does not in any manner preclude the agency from implementing a second Interim Measure for a second year immediately following the first.
2) Interim Measures for Southern New England winter flounder (SNE WF)
NSC strongly recommends that the Council replace the current measures for Southern New England winter flounder with “similar” interim measures that will prevent overfishing yet mitigate the impacts of the catch reductions for other stocks under Framework 48 in fishing year 2013.
3) Georges Bank Yellowtail Flounder (GB YT)
In the absence of an Scientific and Statistical Committee recommendation for an allowable biological catch / overfishing limit, the Council is left with selecting an annual catch limit (ACL) that meets management needs for 2013.
NSC strongly recommends that the Council select an ACL based upon 1,150 mt. and to direct the US Transboundary Management Guidance Committee (TMGC) to request the Canadian TMGC to reconvene a special meeting to consider the recommendation to modify the 2013 US / CA trans-boundary shared total allowable catch for 2013.
Read the complete letter from the Northeast Seafood Coalition
See the August 2012 memo referenced in the comments