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Letter to National Marine Fisheries Service
Dear Dr. Hogarth: I
am writing to submit comments on the Notice of Intent that was recently
issued (2/14/07) by the National Marine Fisheries Service on possible
changes to National Standard 1 on Fishing. This is a critical time for
the health of our oceans. Your leadership is vital for ensuring that
our ocean ecosystems are protected and that ocean fish management is
improved as your agency moves forward to issue rules for the
reauthorized Magnuson-Stevens Fishery Conservation and Management Act
(MSA).
A strong and effective MSA is crucial for the sake of
healthy oceans and the communities that depend on them. We believe that
the revised National Standard 1 guidance should make the following
changes in the way that your agency and regional councils conduct
business:
* Let science, not special interests, set fishing
limits. Every regional council must have a strong, independent,
technically proficient Science and Statistical Committee (SSC) that has
the resources and data to make conservative, science-based decisions.
Appointments to these councils should be tracked carefully by NMFS to
ensure competence and independence. These committees should set
science-based annual catch limits (ACL’s) that incorporate a
precautionary approach or buffers to keep fish stocks healthy or
recovering from depletion with a high level of certainty.
*
Create accountability for overfishing. Managers should create clear,
equitable, consistent, and concrete accountability measures that keep
stocks out of trouble if annual catch limits are exceeded and
conversely potentially reward fisheries in some cases where annual
catches are under the limits.
* Require fishermen to report
their catch levels in an accurate, timely fashion. Without accurate,
timely catch data, it’s impossible to determine if a fish has been
overfished. With this information, we can take the necessary steps to
ensure that overfishing in our oceans is less likely to occur. To that
end, data from each fishery should be collected online soon after
landing the fish.
* Stop overfishing as quickly as
possible. NMFS should maintain the10-year rebuilding requirement for
recovering depleted fish stocks. Congress clearly considered and
rejected changes to this requirement in the MSA reauthorization process.
In
sum, we are very pleased with the proposals that NMFS has considered so
far. We hope to see as many of these good ideas embedded in the final
regulations and guidance as possible. We have a unique opportunity to
make a quantum jump in the way we manage our fisheries to protect our
oceans and our fish.
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