To the editor:
This is an open letter to our U.S. senators and congressional representatives.
It is critical to understand that the apparent status of the Gulf of Maine cod stock is not a failure of fishermen to comply with the law. Not once has the catch limit for the groundfish fleet been exceeded in the eight years of this rebuilding plan.
Further, this is not a failure of fishery managers to embrace the science they were provided. The New England Fishery Management Council's catch limits were designed specifically to prevent overfishing and rebuild stocks in the 10-year time frame consistent with the law and the science they were provided. Only retrospective analyses performed years after the fact have suggested that these original catch limits (with which the fishery complied) were insufficient to prevent overfishing and rebuild the stock.
Instead, the GOM cod situation represents a flaw in fishery policy that places demands on science that exceed its capacity to predict nature. Science cannot sufficiently or reliably predict six, eight, much less 10 years into the future what recruitment, natural mortality, growth or the dynamics of the Gulf of Maine ecosystem will be. Nor can it sufficiently predict how these parameters affect overall stock productivity over time.
For the immediate term, it is clear the GOM cod situation also reflects some critical areas for making improvements to the science of groundfish stock assessments. These include data input as well as the assumptions and methodology of the modeling analyses.
This is not a criticism of the stock assessment scientists who clearly did the best job with what was available to them within the constraints of their terms of reference. However, there are important limitations to the GOM cod assessment that must be openly acknowledged and addressed prior to the agency or the Council taking a definitive long-term management response.
The following represent some of the key elements that we feel must be reevaluated by the agency and/or the Scientific and Statistical Committee (SSC) as part of any "new" or revised GOM cod stock assessment process:
For a very long time there have been questions about the need to continually update and improve upon the groundfish trawl surveys performed by NOAA research vessels for the purpose of generating fishery-independent indices of stock abundance which are central to the assessments for all groundfish stocks including GOM cod.
Serious issues still remain as to the correct calibration of the new Research Vessel Bigelow to the previous RV Albatross as well as the effectiveness of the new RV Bigelow to catch certain sizes (ages) of certain stocks. Among other efforts, this strongly suggests the need for a "side-by-side" trawl survey using an industry vessel(s) to help calibrate the RV Bigelow.
For a long time there has also been the recognition that a fishery-dependent index of abundance using the fishery's catch-per-unit-effort (CPUE) data would be a critical addition to the stock assessment process.
Among other things, a CPUE-based index of abundance can provide an important cross-check to the trawl survey-generated index of abundance. For GOM cod, this could provide an important basis for resolving why the fishery-independent trawl surveys suggest such a very stark difference in stock status when compared to the performance of the fishery.
Groundfish stocks are part of a very complex and dynamic ecosystem and environment. A re-evaluation of the current assumptions regarding the stock structure of GOM cod must be a priority and may have the most profound implications of all.
Finally, a major revision in the collection and estimation of recreational catch is in process and the results will be available in early 2012. This, along with a re-evaluation of the assumptions for post-release mortality in all hook fisheries, are priorities which may have a very significant impact on the results of a new or revised GOM cod assessment.
In the interim, and during this scientific process, we strongly urge that the SSC not be requested to provide a formal recommendation for an acceptable biological catch that would trigger the Council process for setting a definitive annual catch limit. We fear this rigid process would produce an immediate, devastating result for our fishery from which the fishery would never recover.
Instead, we strongly recommend that the SSC be encouraged to adopt an "interim catch level" that achieves at least in the short term (one year) the overarching intent of Congress in the MSA to strike a balance between the goals of achieving a sustainable resource and a sustainable fishery.
JACKIE ODELL
Executive Director
Northeast Seafood Coalition
Gloucester
Police: Gunman Has Hostages in Realty Office
Fugitive Penguin Caught, Returned to Aquarium
50 Years Later, Underground Fire Still Burning
Light Show Transforms Sydney Opera House
Raw Video: Unruly Passenger Restrained in Miami
Raw Video: Robber Uses Drive-thru Window
Raw Video: Dragon Arrives at Space Station
Calif.'s Coronado Named Nation's Best Beach
CEO Salaries Become Sore Issue in Labor Disputes
Raw Video: Fight Erupts in Ukrainian Parliament
Texan Ranchers Remain Wary of Drought
Raw Video: Soldiers Plant Flags at Arlington
Police: Man Arrested in Etan Patz Disappearance
NYC Protests: the Revolution Will Be Scripted
Chicago U.S. Attorney Fitzgerald Resigns
Neighbors of Etan Patz's Suspect: It's Shocking
Gulf Fishermen Reel From Seafood Troubles
Stuntman Makes Skydive Without Parachute in UK
Raw Video: Bride Who Faked Cancer Released
Raw Video: Passed Out Man Robbed
