November 20, 2012 — The Northeast Seafood Coalition issued the following statement to clarify their position on Amendment 18.
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.
The Northeast Seafood Coalition (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. Consistent with its longstanding support for family-owned businesses and a diverse fishery, NSC sponsored and designed the Northeast Fishery Sectors to be inclusive of the full diversity of fleet and community demographics that were representative of the entire groundfish fishery. Small, medium, and large vessels each occupy key niches of the industry, and they together keep the entire industry operational. We believe one niche without the others dooms the whole industry.
NSC has and continues to work hard to forge solutions that have help to preserve all segments of the groundfish fleet through immense stresses the industry has faced over the past decade. Highlights of recent NSC action items include, but are not limited to:
· Leading the effort with NOAA Fisheries to implement an Emergency Action interim rule for Gulf of Maine cod for the current fishing year, which prevented a much larger cut in the stock and thus preserved the inshore Gulf of Maine fleet;
· Proposing a successfully implemented modification to a closure for inshore gill-net vessels, which enabled gill-net fishermen to harvest during October and November while preserving marine mammals;
· Engaging independent, highly-respected scientists to participate in the scientific process for stock assessments such as of Georges Bank and Gulf of Maine cod, the winter flounder benchmark assessment, and NSC was involved in other independent scientific reviews of Atlantic sturgeon and Georges Bank yellowtail flounder;
· Spearheading the effort to provide access to haddock for the groundfish fishery by working closely with offshore lobster fishermen who set traps in Closed Area 2 to establish an offshore lobster and groundfish mobile gear sector industry agreement, which disperses fishing effort and helps ensure offshore vessel viability;
· Persistently and successfully pursued an in-season adjustment for Gulf of Maine winter flounder, a former “choke” species for much of the groundfish fleet, based on updated scientific evidence;
· Actively engaging in issues related to the Georges Bank yellowtail fishery including scientific, management, and sub-ACL discussions;
· Continuously advocating for federally funding for sector operations including monitoring funding—an essential need for the survival of the small boat fleet.
· NSC has been the leader in the groundfish fishery’s effort to establish an inshore Gulf of Maine declaration, which has been supported by all sectors in the Northeast region.
NSC is concerned that 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 Magnuson-Stevens Act (MSA). NSC notes that the agency has made a definitive legal determination that the sectors are not LAPPs as defined in the MSA and that sector allocations are not permanent. With these points in mind, NSC has adopted the following position:
“It is NSC’s position that 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.”
Read the Northeast Seafood Coalition's public comments on Amendment 18