New England Fisheries

Letter to Secretary Bryson: New England Can’t Afford To Put Gulf of Maine Cod at Risk

The cod ACL for 2013 needs to be reduced drastically to help cod stocks recover (Photo credit: Patrick Gijsbers, Wikimedia Commons, courtesy of EPA).

This post was originally published on the Conservation Law Foundation blog, the CLF Scoop.

Gulf of Maine cod, the lifeline of our inshore fishing fleet up and down the coast of New England, is in a biological crisis. That is why I wrote today to the Honorable John Bryson, Secretary of the U.S. Department of Commerce, calling for federal fisheries disaster relief and interim emergency action. You can read a copy of the letter here, or scroll down to read it below this post.

My letter follows the latest scientific data – data that shows that cod stocks are much more heavily depleted than earlier assessments had indicated. According to the 2011 assessment, based on an improved scientific model, three additional years of survey data and more accurate weights-at-age estimates, Gulf of Maine the spawning cod estimates fell to 12,561 metric tons from 33,877 metric tons in 2008.

In the case of Gulf of Maine cod, the numbers are so close to the bone that a couple thousand metric tons of cod landed either way could spell the difference between a rebounding fishery and a total collapse. Given the economic importance of Gulf of Maine cod to coastal fishermen, what would the appropriate risk be?

Indications are that the National Marine Fisheries Service (NMFS) will set a quota of 6,700 metric tons (mt) for the 2012 fishing year that begins May 1. At this level the risk of the spawning population dropping below critical thresholds is greater than 31%. Drop the catch levels to 4,000mt and the risk drops to less than 10%. Still a risk but a safer bet. That is why as I said in my letter, “Conservation Law Foundation (CLF) recommends a one year 4,000mt catch level for the fishing year which starts May 1, 2012. While that level of catch is  2,700mt less than the lowest level proposed by the New England Fishery Management Council, it still presents a significant risk of further stock declines.”

Setting the catch levels too high on May 1, 2012 creates substantial risk that the whole fishery may have to be closed in the future. This isn’t sheer speculation; when Newfoundland’s northern cod fishery – a close cousin of our Gulf of Maine cod – collapsed in the early nineties, the fishery has had to be closed for decades to allow the cod stocks to rebuild.

As I said in my letter, at 4,000mt, “the estimated gross revenue losses at that catch level are $4,677,000. Importantly, an estimated sixty-six percent of those losses will fall on the smaller, inshore fleet (see attachment), a group that is already operating close to or below the economic break-even point and won’t have alternative fishing options in many cases.” Given this, I asked Secretary Bryson to “set up a disaster relief fund available to all active groundfish companies that would provide some relief for any demonstrated losses that they experience until GOM cod stocks can be rebuilt.”

The livelihoods of New England’s coastal fishermen hang in the balance with the Gulf of Maine cod. A three-part solution is required to protect these fishermen and the fish they depend upon.

  • First, NMFS should limit the risk of further long-term damage to the fishery by setting the quota at no higher than 4,000 metric tons for the 2012 fishing year. That will buy some time to do further analysis to inform catch limits for 2013 as the nature and extent of the crisis becomes better understood.
  • Second, NMFS should allocate those fish to the boats most economically dependent on Gulf of Maine cod, and restrict large trip boats from fishing for them.
  • Third, federal and state authorities should declare an economic fishery disaster and make funds available to assist the coastal fishermen who will suffer significant financial losses under any proposed scenario and look towards broader economic assistance for affected coastal communities.

Failing to take the right action for Gulf of Maine cod at this critical junction may well be failing the region’s fishing future. Fast and effective management steps have to be taken to head off that possibility.

 

A copy of the letter I sent to Secretary Bryson can be found below or as a .pdf here.

February 21, 2012
The Honorable John Bryson
Secretary
U.S. Department of Commerce
14th and Constitution Avenue NW
Washington, DC 20230

RE: Gulf of Maine Cod Federal Fisheries Disaster Relief & Interim Emergency Action

Dear Secretary Bryson:

We are writing to you now to support the earlier requests by Governor Deval Patrick for federal fisheries disaster relief pursuant to section 312(a) of the Magnuson-Stevens Fishery Conservation and Management Act (MSA). The new scientific assessments for Gulf of Maine cod (GOM cod) stocks document that the economic situation in the region is significantly more dire than previously thought. Immediate and aggressive action is needed to avoid any risk of creating a long-lasting biological crisis with GOM cod with widespread, crippling economic implications.

As a result of the recent science assessment, GOM cod catch levels will have to be drastically cut back on May 1, 2012. Even at low catch levels, there still will be a significant risk that the spawning stock levels could decline below the lowest level ever observed. In the words of one of the New England Council’s scientists who has extensively studied the complete commercial collapse of the northern cod stocks in the early 1990’s off Newfoundland, “the similarities [between the two situations] are a bit frightening.” Dr. J.-J. Maguire (email to SSC members and others 1/25/12). Following that collapse, Newfoundland’s cod stock has been largely closed to fishing for decades.

The recent GOM cod reassessment was a unique and highly unusual set of events that was beyond anyone’s control. The scientists exercised their best professional judgment in performing the original assessment in 2008, the managers strictly followed the scientific harvest level advice, and the fishermen appear to have stayed within their prescribed quota limits. And yet, the future of GOM cod is now at an unforeseen but significant risk. These circumstances meet all the criteria in the National Marine Fisheries Service’s disaster relief policy guidance: there is a fishery resource disaster as defined by the MSA; it was caused by events beyond human control; and there will be significant economic impacts stemming from this disaster.

Economic analysis indicates that single-year gross revenue losses for the commercial fleet from current revenue levels could range from  $1,354,000 to $14,620,000, depending on the catch level that is set. Conservation Law Foundation (CLF) recommends a one year 4,000mt catch level for the fishing year which starts May 1, 2012. While that level of catch is 2,700 metric tons less than the lowest level proposed by the New England Fishery Management Council, it still presents a significant 10% probability of further spawning stock declines.

The estimated gross revenue losses at that catch level are $4,677,000. Importantly, an estimated sixty-six percent of those losses will fall on the smaller, inshore fleet (see attachment), a group that is already operating close to or below the economic break-even point and won’t have alternative fishing options in many cases. We ask that you set up a disaster relief fund available to all active groundfish companies that would provide some relief for any demonstrated losses of net revenues that they experience until GOM cod stocks can be rebuilt.

Without relief from the crushing economic circumstances many coastal boat owners are facing, , managers are being tempted to take risks in setting the short-term quotas too high, potentially imperiling the fishery for decades. A further commercial collapse of GOM cod stocks would cripple many of New England’s fishing communities that are wholly dependent on cod. The indirect losses in the maritime support industries multiply those potential direct costs many times. Economic disaster assistance can greatly reduce the pressure on managers to allow short-term overharvesting as the region transitions to a sustainable fishery. Moreover, in addition to direct disaster relief, we encourage you to implement the suggestions of the Commerce Department Economic Development Administration’s recent evaluation of certain New England ports and provide necessary aid and technical assistance for the economic transition of these communities.

CLF supports the New England Council’s emergency action request and the general approach that the National Marine Fisheries Service (NMFS) has proposed in taking interim emergency action to respond to this unexpected and troubling new development. As mentioned above, however, we feel strongly that the quota should be set no higher than 4,000mt. And we have called for the imposition of a series of management measures that would direct the majority of the limited cod quota to the boats that are most dependent on cod. In support of this, we have provided NMFS with a position paper on this issue, which we are also attaching to this letter. Thank you for your careful consideration of the management and economic assistance measures we propose. We look forward to your response and your agency’s further efforts to work towards solutions that help all of New England’s coastal communities weather this tough economic crisis and to thrive in the future.

Sincerely,
Peter Shelley
Vice President


Comments

8 Responses to Letter to Secretary Bryson: New England Can’t Afford To Put Gulf of Maine Cod at Risk

  • doug maxfield says:

    4000 mt won’t make a differance. No one is willing to admit defeat on the catch share fiasco just yet, but it’s time someone put on their big boy pants.
    Sure, everyone can claim that the science in 2008 was flawed. But it does seem coincidental that it confirmed exactly what the fishermen were seeing. Four years later and no one wants to look at what part of the equation has changed. I believe your advice, Mr. Shelley, was to “make it work”.
    Trust me, people are trying. But what happens when the number of boats able to fish is cut in half AND the fish are gone?

  • Peter Shelley says:

    ‘Make it work’ still sounds like a viable, maybe the only, option to me. There is no logic or data to lay the new lower science assessment on GOM cod on sectors. They were not responsible for the changes in weights-at-age that the new assessment used or the high recreational catches. The estimated-to-be-strong 2003 year class, which never recruited into the fishery, would have done so before the start of the expanded sector program in 2009 and didn’t show up then. There is no indication that the sector program caused the loss of the estimated-to-be-strong 2005 year class or was any worse than a days-at-sea program with trip limits would have been in the discard category (and sector trips were observed at much higher levels than DAS boats). More likely that the 2003 and 2005 cohorts just weren’t as strong as estimated.

  • doug maxfield says:

    Trip limits brought this fishery back from the brink. And I think its interesting you should bring up observers…because when you can talk to them in a setting where they are no afraid to loose their jobs for speaking their minds you hear how willing their ‘higher-ups’ are to cherry pick their data to provide numbers on paper for people who have not seen this process unfold first hand. ie. you.
    You’re right…discards were a huge problem in the days at sea fishey with trip limits. The solution should not have been to make it legal for 100 footers to make 20,000lb. tows on Stellwagon with allocation they bought.

  • Peter Shelley says:

    Well, I hear you and that’s your perspective. There are plenty of other fishermen who would disagree with you that “trip limits brought this fishery back from the brink” and you don’t provide any real data to support your claim. The sector program, by the way, does not make the former unreported or regulatory discarding legal; it makes the fishery accountable for that catch for the first time.

    • doug maxfield says:

      What is ‘real data’? You want the logbooks from the last ten years that show plain and simple that fewer nets of greater mesh size were needed to catch more fish? I’ve got that. But ‘data’ seems useless when it can all be swept under the rug with “we were wrong then, we’re right now”. What if we were right then and wrong now?
      BTW, I watched six large, offshore boats cartwheeling in a small area last week and wiping out a massive amount of western GOM haddock. Some of these boats had no haddock allocation and are trying to purchase it now to cover their catch. The price crashed and in less than two days the fish were gone. I guess they just made it work.

  • Peter Shelley says:

    CLF’s position is that those trip boats should not be working inshore areas, period, and we have said so publicly at the mike and in writing. I’ve checked the Amendment 16 record for any written comments you may have made raising this very strong position you hold about the damage some trip boats are causing. I couldn’t find any or maybe you just went to the mike? How come? Were you expecting others to carry your water? Of course, it’s OK to break bad on the internet but it doesn’t mean anything to the people who are making the decisions here.

  • Doug maxfield says:

    Try amendment 18. Also working with Nama when possible. Unfortunately, my job is to fish, not go to meetings which are generally held mid-morning for some reason. And just who are the people ‘making the decisions here’? I guess we’ll see when the IG begins playing his flute.

  • Thaddeus Bigelow says:

    What is needed is a longer term approach but the law seemingly prevents it. CLF’s suggestion of a 4,000 mt ABC in 2012 might be more palatable if that same ABC could be used for another two years. Overfishing would end (in year 3) and we would not have the economic devastation that will result from the 2013 ABC of ~1500 mt that is facing the industry. But the vaunted MSA flexibility that NMFS is bragging about only lasts for one year. 2013 will be a disaster.

    And now what do we do about GB cod? And GOM haddock? And plaice? And witch flounder?

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