To the members of Congress:
We the undersigned are members of the Northeast Seafood Coalition and active operating members of Northeast Fishery Sectors. We are writing today to express our very serious distress over the recent decision by policy-makers to accept the lowest of low allowable catches for our fishery in 2013 and beyond while simultaneously expecting an industry on the brink of economic ruin to absorb monitoring costs. We are in immediate need of your help.
The forced transition of our New England groundfish fishery to catch share management and hard TACs (total allowable catch) came with all sorts of rosy promises of resource abundance and economic stability. Maybe even prosperity.
That transition itself was difficult enough to survive, and many of our friends simply didn’t make it. But for those of us left standing the situation today is simply unbelievable. There is no stability. There are only repeated, record reductions in catch limits. Prosperity is a discarded dream. This is a real disaster.
Three weeks ago, NMFS Regional Administrator John Bullard told us at the council meeting that this was our day of reckoning. This is not our day of reckoning – we’ve done nothing wrong to reckon. We didn’t cause this problem. The problem was caused by the failure of government policies and programs to accept and adequately contemplate the reality that current scientific capabilities are inadequate to manage this “fishery” safely. For too long we’ve been subjected to the volatility and futility of pretending to know the unknowable. For nearly a decade now our fishery has fished at or below every catch limit set by the government on every stock. We lived within their quotas, but it is now our businesses, our families and our communities that will be paying the price.
This totally unpredictable process for developing catch advice has destroyed all prudent attempts by industry to develop business plans that may have created at least some limited capacity to accept a level of financial burden for monitoring. Government cannot expect our industry to continue to be subjected to drastic cuts in allowable catches while placing additional, government imposed expenses upon us.
When Amendment 16 was being developed and implemented, the Northeast Seafood Coalition (NSC) repeatedly warned the council, NOAA Fisheries and Congress that the success of the groundfish catch share program would depend on adequate federal funding and sufficient allocations to sustain a fishery. Sure enough, here we are — less than 3 years after sector implementation — and the agency is telling us there is not enough money to monitor or enough fish to sustain our fishery. It’s difficult for many of us to believe that this was just a coincidence.
The secretary of commerce finally declared our fishery a disaster last September. More than a year before that many members of Congress had already told NMFS there was no way we could afford to bear the cost of the at-sea or dockside monitoring programs. That was before anyone really knew just how bad things were going to be for fishing year 2013.
Nevertheless, Mr. Bullard delivered the second blow to us three weeks ago when he announced we have yet another price to pay — that we will have to pay at least half of the agency’s cost of at-sea monitoring in fishing year 2013. This is incomprehensible. If we couldn’t afford the cost of at-sea monitoring before the fishing year 2013 cuts were announced, how does anyone think we can afford it now?
We know that you have worked very hard and closely with our representatives at the NSC to help us survive this travesty. And maybe the only reason we are still standing here today has been all that hard work combined with our guts and determination. We can never thank you enough for all your efforts and support. Fishing is in our blood – it always had been and always will be. But we cannot go fishing unless something is done—a lot is done. We are standing on the edge of a cliff and there is no bridge. We need a bridge.
First, NMFS should reconsider their decision to reject the council’s request for interim measures on Gulf of Maine cod and haddock and should adopt the ABC (acceptable biological catch) for GB yellowtail as recommended by the council for fishing year 2013. For many of us, this is a bridge. How are we – those who have endured the brunt of efforts to rebuild groundfish stocks for over two decades now — expected to survive until all those promises of stock abundance are fulfilled? Who are the fishermen who will be catching those fish? Not our sons or daughters, or their children. Did the NMFS lawyers really get it right? Or, was this just an unfortunate policy decision influenced by non-governmental organizations or the threat of litigation?
Second, NMFS simply must cover the cost of at-sea monitoring in FY 2013 and continue to do so until things really turn around. That’s a given. We know you know that. All we can do is ask you to do whatever is necessary to make that happen in time. Fishing year 2013 begins on May 1.
Third, NMFS needs to fix their stock assessments. We have paid closer and closer attention to the assessment process and the more we see and understand, the worse it looks. Everything— the stocks and our lives — ultimately depend on the science and all we see are problems. The situation is simply unacceptable. The Magnuson-Stevens Act now demands more from the science than it can produce. That law also needs to be fixed, and Congress can do it. No more arbitrary goals that have no basis in biological or economic reality.
Finally, we ask you to please continue your hard work to find a way for Congress to fund the fishery disaster declarations. We fear we have become a political football and we know you are fighting hard against that. We have seen this great nation step up time and time again to help those that have suffered disasters at the hands of nature to get back on their feet. Our disaster is the same. Again, we need a bridge.
Thank you for your consideration. For many of us this is probably our last shot at survival.
Signed by 175 fishermen who are members of the Northeast Seafood Coalition and run boats from ports around New England.