There are obviously a ton of issues and concerns now swirling around the National Oceanic and Atmospheric Administration's push to use fishermen's catch shares as the primary tool for regulating New England and other U.S. fisheries.
In no particular order, there are dire examples and concerns that the change pushes independent family-owned fishing boats out of business and cedes control of the seafood industry to corporate outside investors who buy up the shares, much as today's so-called "agri-business" companies drove away America's family farms.
There are significant flaws — admitted by the NOAA's National Marine Fisheries Service — in the landings data being used to set New England fishermen's shares for when the change supposedly takes effect next year.
And then there's the fact that allocation limits outlined by the New England Fisheries Management Council — based on oft-disputed trawling science — are so constricting in some cases they seem destined to doom fishermen's viable shares to near zero, and perhaps doom the catch-share program to failure in the process.
All of those problems, as we've noted in the past, are reasons to push back conversion of the New England fishery to catch shares for at least a year.
Yet, if there is one final nail needed to drive home that point, it's this: The $18 million promised by first-year NOAA chief administrator Jane Lubchenco has not been funded by Congress — and there is no indication it will be.
To that end, Lubchenco — no doubt drawing on her career as a scientist, educator, Pew fellow and vice president of the Environment Defense Fund — is welcoming "fund-raising" efforts by the National Fish and Wildlife Foundation, a public-private philanthropy that is backed by a number of corporate partners.
But, while providing government grants to nonprofit groups and other agencies is one thing, somebody had better tell Lubchenco that it is grossly inappropriate for the government to accept money for its own mandated programs from a foundation whose funding — or investing — "partners" include the likes of Wal-Mart, Anheuser-Busch, Bank of America and the Big Oil gang of British Petroleum, Exxon/Mobil, Marathon Oil, Shell, and Conoco-Phillips.
Even local city councilors, selectmen and municipal administrators know the potential conflict and dangers that can come through letting private entities openly contribute to projects that are government-run and should be government-funded.
Letting Big Oil companies and other corporate entities essentially fund a major government regulatory program — one that has never been given a congressional green light — crosses so many lines it has to be considered far out of bounds, even in today's "stimulus" age of governmental corporate takeovers.
The fact that the head of a government agency — one with the regulatory and enforcement power to make or break thousands of small fishing businesses, and their home communities — fails to recognize that raises a frightening red flag when it comes to Lubchenco's NOAA stewardship.
The manner in which Lubchenco handles a growing anti-catch share cry in the weeks and months ahead will tell volumes about her commitment to truly bridging the gaps of distrust between the fishing industry, its communities and its federal regulators.
That hue and cry includes New England legislative leaders such as Congressman Barney Frank, who rightfully wants to take a fresh look at the entire Magnuson-Stevens Act, the bible of federal fishery regulation; a letter signed by a number of Gulf Coast governors concerned about the impact of catch shares on their communities; and even, to some extent, the Pew Environment Group, which supports a "go slow" policy on implementing catch share programs across Fishing Nation.
But the fact that there is no approved funding to implement these programs — true federal dollars, not contributions or investments by an oil-backed private-public foundation that could buy its way into the feds' regulatory process — should be considered the final straw.
New England's fishery simply cannot be rushed into a catch-share conversion for the 2010 fishing year, and a lot of federal officials had better recognize that.