New Bedford, Massachusetts mayor Scott Lang wrote a second letter to NOAA Administrator Jane Lubchenco on April 20, 2010, urging a delay in implementation of Sector Management. The letter is a follow-up to his original letter written a month ago that remains unanswered. The letter was copied to Commerce Secretary Gary Locke, Eric Schwaab, National Marine Fisheries Service and over 70 members of Congress.
The text of the letter follows: I am writing to express my extreme concern that the catch share / sector program remains scheduled for implementation on May 1, 2010. In my letter dated March 22, 2010, I focused on several key points suggesting the necessity of delaying the start of the catch share /sector program. I have not received a formal response from the National Oceanic and Atmospheric Administration (NOAA) [A copy of the March 22, 2010 letter is enclosed herein]. With a short ten days (10) outstanding, I remain steadfast in my position that NOAA is not ready to move forward with the catch share /sector program, and that the start must be postponed.
I believe a number of significant issues remain unaddressed and jeopardize the sustainability of fishing communities in the New England region. Of utmost concern is the lack of collaboration and buy-in from the fishing industry. NOAA as a government entity is tasked to work for the public good. The catch share /sector management regime is highly controversial and untested in a major multi-species fishery, such as New England. There is no clear understanding of how the program will lead to conservation and rebuilding of fish stocks. This is exacerbated by the fact that there has not been a thoughtful study or understanding by the Agency of the socio-economic impacts of the catch share / sector program as required under Rule 8 of the Sustainable Fisheries Act (SFA). With institution of the catch share / sector program, it has been predicted that we will see over 50% of the fishing fleet adversely impacted and result in irreversible economic harm to fishing communities during one of the nation’s most challenging economic periods.
I maintain there is a much better approach than rushing the implementation of NOAA’s “work in progress” management program. Setting new and more flexible rebuilding programs under the SFA as is advocated by US Congressman Barney Frank and other members of the federal delegation will lead to more effective and strategic rebuilding measures. Improved science will allow for the implementation of catch allocations that meet both the goals of conservation and sustaining the economic vitality of fishing communities. It is premature to implement a program without allowing time for increased flexibility and improved science.
With the effective date fast approaching, I request an accounting from NOAA on the following:
· A detailed analysis of how the catch share/sector program will impact New Bedford, the nation’s number one fishing port;
· A list of the number of fishermen participating in the common pool;
· A list of the number of fishermen participating in the sector program;
· The scheduled adjustments, if any, proposed for species catch allocations;
· A list of the number of fishermen that attended seminars to prepare for the implementation of the catch share / sector program and the dates and locations of the seminars; and
· A complete accounting of all federal funds spent on implementing the catch share program in New England thus far and a proposed budget for future expenditures.
Based on very real concerns, I urge you to delay the implementation of the catch share/sector program until such time that by working together we have addressed these issues and have a reasonable likelihood for the successful implementation of this program. Collaboratively we can build an action plan that uses credible science and effectuates transition to new management procedures. We must also implement a plan that takes into account due process, fairness, timely modification of stock assessments, and provides adequate infrastructure for management. I believe your current timetable is irresponsible and a disservice to fishing communities and the public good. I request your prompt response. Read Saving Seafood's coverage of Mayor Lang's March 22 letter