To the editor:
These are comments I am sending to our federal representatives, state senators, state governors, and mayors of our communities.
Section 312 of the Magnuson Stevens Fishery Conservation and Management Act — Transition to Sustainable Fisheries, provides for the declaration of a fishery disaster at the request of an affected state governor or by the Secretary of Commerce.
The current debate about whether or not it's too soon to evaluate the Amendment 16 catch share program is missing the point and way off the mark for the individual fishermen being negatively impacted.
It's not too soon for me to evaluate the effects of this system on my small fishing business. It's not too soon to know that I'll be done for the year, when my yearly individual allocation of Georges Bank Yellowtail flounder is landed in a two-hour tow.
With that kind of allocation, I don't need to wait another month or two for the total landings in every New England port and for statistical comparisons with previous years in order to evaluate this management scheme.
It's significant to me whether or not I can pay this month's bills, not if the total landings for the month are up or down. The landings could be up for any given month, but if only 20 percent of the fleet had the "privilege" of partaking in those landings and the other 80 percent is going broke, is that a successful program?
If my boat wasn't allocated a sufficient portion of those landings; if I can't fish and can't make a living today, then all the studies and statistical analyses and claims of success don't mean a thing. Amendment 16 is a disaster for me right now, and for the four families of the crew who depend on my business for their income.
The majority of the fishing businesses that I have contact with in New England, New York, and some mid-Atlantic states are in the same predicament. They report that they can't work on the meager catch share allocations and are on the verge of going out of business.
These are seasoned, conservation-minded, reputable, "in it for the long term," fishing families losing a fishing tradition that's been their way of life for generations.
It's the distribution of the allocations of an unnecessarily low Total Allowable Catch that is the most immediate and glaring problem.
Essentially 20 percent of the boats have 80 percent of the Total Allowable Catch; while 80 percent of the boats have 20 percent of the TAC. That 80 percent of the boats can't survive on 20 percent of the TAC. It's a disaster!
Twenty percent of the boats did not catch 80 percent of the fish before Amendment 16. Why is it that after Amendment 16, 20 percent of the boats end up with 80 percent of the fish?
How and why did this happen? What is the purpose behind this? How can NOAA dare call this scheme conservation when they have disenfranchised 80 percent of the working fishermen and their coastal communities?
Does it help the fish to allow 20 percent of the boats to catch the same total amount of fish that would have been landed by 100 percent of the entire fleet of small boats? Is this good conservation, good governance?
The 80 percent of the fishing operations that are "consolidated" in this process are families that are being put out of work and number in the tens of thousands. They have been living in their own NOAA-constructed "financial recession" for many years. They were promised eventual profitability as a dividend of living through the regulation imposed austerity during the now nearly complete stock rebuilding process.
Now Amendment 16 ultimately turns it all over to speculators in the commodities market, inflating share value way beyond the reach of most fishermen.
NOAA's recent Stock Sustainability Survey — which can be viewed at http://www.nmfs.noaa.gov/sfa/statusoffisheries/SOSmain.htm — shows that out of the 250 monitored stocks, 85 percent are free from overfishing and no new stocks have been added to the overfishing list.
The current catch limits for fishing year 2010 were set based on NOAA trawl surveys that date from 2007 in this multi-species fishery. These stale stock surveys have been shown to be inaccurate.
Yet while the newer surveys are still being "assessed and analyzed," family fishing boats are going out of business while they wait for the "better science" and for "further adjustments by ... perhaps August."
There is no demonstrable scientific need for a drastic change in the management regime or for a further reduction of the catch limits at this time. The input control or days-at-sea system has seen the majority of fish stocks return to health.
The declaration of a fishery disaster would buy fishing communities some time while this Amendment 16 catch shares mess is sorted out and the more recent stock surveys are analyzed and incorporated into the process of setting the catch limits.
I sincerely hope we won't need to approach the devastation of the Gulf fisheries before we are able to qualify for some official intervention and support.
DICK GRACHEK
Mystic, Conn.
Owner, F/V Anne Kathryn
