"Maine's
groundfishing industry has been working in a collaborative effort with
NOAA and New England Fishery Management Council (NEFMC) to both advance
the New England fishing industry and rebuild the ocean's fisheries,"
said Michaud. "I urge the Secretary to ensure that the 2012 catch levels
are set at a level that prevents a potentially devastating economic
loss to our fishermen. We must all work together to develop a long-term
economic plan that ensures the sustainability of our ocean's fisheries,
while protecting the viability of our coastal
communities."
January 31,
2012
The Honorable John
Bryson
Secretary
Department of Commerce
1401
Constitution Avenue NW
Washington, DC
20230
Dear Secretary Bryson:
New
England's historic Gulf of Maine cod fishery has been subject to an
increasingly complex set of management restrictions intended to reduce
fishing effort and rebuild the stock to sustainable levels since 1994.
In 2008, when the New England Fishery Management Council met for its
September meeting to review the Groundfish Assessment Review Meeting
(GARM III) results, the best available science showed that those
sacrifices had finally borne fruit: Gulf of Maine cod were declared no
longer overfished. Three years later, an updated assessment painted a
dramatically different picture and could not be more ill timed. Proposed
catch levels derived from the 2011 assessment would devastate
the commercial fleet with nascent groundfish sectors constrained by the
ultimate "choke stock."
Under Sections 305(c) and
304(e)(6) of the Magnuson-Stevens Act, Congress provided the Secretary
of Commerce the authority to implement interim measures at the request
of the Fishery Management Councils even if such measures would not
prevent overfishing during this interim period. This authority requires
only that the Secretary reduce overfishing. As you know, the New
England Fishery Management Council (NEFMC) is meeting to review the cod
assessment and possible management actions this week in Portsmouth, New
Hampshire. Should the Council request interim measures, we strongly
urge you to grant this request and set the 2012 Gulf of Maine cod Annual
Catch Limit at a level that would allow the industry to
survive.
In addition, we encourage NOAA Fisheries to
prioritize research in the coming year that will improve the groundfish
assessment process, including the:
Continued review
and analysis of the assumptions and models used in the Stock Assessment
Workshop/Stock Assessment Review Committee 53 process, and the
consideration of analysis provided by Drs. Butterworth and
Rademeyer;
Incorporation of Marine Recreational
Information Program data;
Development of a
catch-per-unit-effort index or similar utilization of fishery- dependent
data; and
Implementation of side-by-side trawl survey
tows using a commercial vessel;
Examination of the
effect of current stock structure on stock assessment data inputs,
modeling, and analyses.
NOAA leadership is to be
commended for the unprecedented approach they took to engage the
fishery's stakeholders while the assessment process was still ongoing.
NOAA Fisheries staff, industry members, and the environmental community
have remained open-minded and continue to seek mutually agreeable
solutions to an exceptionally difficult problem. All involved have
sought to improve the science upon which catch levels are based and have
engaged in this dialogue in good faith. Nothing short of this level of
cooperation will be required to resolve this issue for both the near-
and long-term.
We stand ready to assist you in
achieving a sustainable future for New England's fishing industry, as
well as for the Gulf of Maine cod stock.
Thank you for your cooperation
on this matter.
