We represent fishing communities in New England who are eager to work with you on the NOAA Catch Share Task Force’s development of a Catch Share policy. The two objectives that it is appropriate for us to comment upon are #1, the full consideration of Catch Shares in fishery management plan amendments and #3, Catch Share design for the best possible environmental and economic performance. We fully agree with your 22 June 2009 press release that states, “we must all work together to end overfishing and rebuild fisheries to improve the economics of fishing and fishing communities and to protect the ecosystems that sustain them.”
With the creation of the recent Catch Share website, we are pleased to see a first generic definition for “Catch Shares.” We urge you, however, to go further in clarifying the scope of Catch Shares. For example, do you envision Catch Shares as able to rebuild depleted fish stocks as a stand-alone measure or in combination with other fisheries management tools? Shouldn’t Catch Shares always be defined within a specific spatial limitation? How will Catch Shares help us achieve ecosystem-based management? We highlight our concerns for the general application of Catch Shares, and suggest why New England offers specific challenges.
We remain concerned that the August deadline, albeit extended slightly, is too ambitious for a subject of such momentous import to both fish stocks and fishing communities, and leaves inadequate opportunity for public process and essential deliberation. A thoughtful, informed, analysis of the natural and social sciences relevant to this policy is essential to avoid yet more poor fisheries management decisions.