the future of america’s first fishery

8/2/2019 The Future of Americas First Fishery

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The Future of Americas First FisheryImproving Management o the New England Ground sheryMichael Conathan May 2012

www.amer icanprogress .o rg


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The Future of AmericasFirst FisheryImproving Management o the New EnglandGround shery

Michael Conathan May 2012


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Contents 1 Introduction and summary

6 A history of management in the New England groundfisher

30 The groundfisherys damaged relationships

38 Making sectors work for the future

49 Conclusion

50 About the author and acknowledgements

51 Endnotes


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1 Center or American Progress | The F t re o Americas First Fisher

Introduction and summary

Be ore Chris opher Columbuss grandparen s were born, early European explorersrom he Vikings o he Basques had already discovered an un old weal h o sh

in he corner o he nor hwes A lan ic now known as he Gul o Maine. Here heproximi y o seemingly limi less s ocks o cod ha could be readily sal ed, dried,and ranspor ed back across he ocean helped es ablish communi ies ha laid hegroundwork or our modern-day socie y.

oday here is no more iconic pro ession in eas ern New England han shing.From he Ocean S a e o hode Island, o he Sacred Cod ha has hung in heMassachusets House o epresen a ives chamber since 1784, o he lobs er haepi omizes coas al Maine, sh are in egral o New Englands cul ure and economy.

oday his sherywhich was once so robus , legend says, ha shermen couldhaul in a heal hy ca ch jus by dropping a weigh ed baske over he side o a ski is s ruggling o recover rom decades o over shing.

Coas al communi ies hroughou New England rely on shing as a undamen alsource o employmen , revenue, and cul ural iden i y. And in eres in his shery expands beyond he shores rom Eas por , Maine, o Poin Judi h, hode Island. As consumers become ever more educa ed abou heir sea ood rying o balance

ac ors such as local sourcing, environmen al impac s o di eren shing gear, mer-cury and heavy me al con en , and overall sus ainabili yrees ablishing one o he worlds mos produc ive sheries is o in eres o more people han ever be ore.

Tis repor begins by summarizing managemen o he nor heas mul ispecies sh-ery, which is more commonly known as he New England ground shery and whose

par icipan s are re erred o as ground shermen.1

(Tese erms will be used hrough-ou his repor .) Te shery is comprised o 15 botom-dwelling species o sh suchas haddock, ounders, and he iconic cod, which in some cases are ur her dividedin o dis inc popula ions known as s ocks.2 A lan ic cod, or example, is managedas Gul o Maine cod, Georges Bank cod, and Georges Bank cod eas .


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Te documen de ails a sea change ha occurred when he ground shery shi edo a managemen sys em known as sec or managemen , or simply sec ors, a he

beginning o he 2010 shing year.3 I hen provides an overview o looming chal-lenges acing he shery including he s a e o sheries science, how o moni or andoversee he shery in a cos -e ec ive manner, and how o preven socioeconomic

upheaval in radi ional shing communi ies during he ransi ion o a new manage-men sys em in ended o end he recen his ory o over shing in he region.

Te repor concludes wi h recommenda ions or improving bo h he managemeno he shery and he rela ionships among shery s akeholders, which are cri ical

o he sherys u ure.

Todays management in the groundfishery: Sectors

Sec or managemen , implemen ed a he s ar o he 2010 shing year, is argu-ably he mos dras ic change he shery has undergone since passage o hena ions rs overarching sheries managemen law, he Fishery Conserva ion andManagemen Ac o 1976. A i s core, sec or managemen is a orm o a so-calledca ch share sys em. In such sys ems, regula ors se a limi on he overall amouno sh he indus ry is allowed o ca ch or he year, which is hen par i ionedamong par icipa ing shermen so each receives a percen age o he o al.

Ca ch share sys ems in general, and sec or managemen in par icular, are highly con roversial. Suppor ers o ca ch share managemen poin ou ha by assuringeach sherman ha he will have access o a secure percen age o sh annually, hesys em gives shermen a long- erm s ake in he heal h o he resource. Leavingmore sh in he wa er oday will direc ly bene he shermen omorrow. Te ideais ha his akes away he perverse incen ive o ca ch every sh as quickly as pos-sible be ore someone else does.

Ye many shermen, par icularly hose who eel ini ial alloca ions are no airly assigned, oppose ca ch shares on he belie ha he sys ems o en lead o consoli-da ion as shermen accumula e shing quo as in ewer hands o ake advan age o

economies o scale. Tey con end his reduces he number o boa s on he wa er,cos ing jobs, and hrea ening communi ies.

Sec or managemen has jus comple ed i s second year o opera ion. Tis repor will provide a brie overview o year one and compare i o opera ions under he


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previous managemen sys em. I will also address common cri icisms o sec ormanagemen and delve in o undamen al challenges acing he indus ry including

he increased cos o moni oring opera ions and a sudden unexpec ed down urnin he scien i c assessmen o he heal h o a key sh s ock: Gul o Maine cod.

A key elemen o his review will be de ningin admitedly broad, sweepingerms he posi ions o various s akeholder groups, including shermen (bo hhose who suppor and oppose he sys em), regula ors, poli icians, scien is s, and

environmen al groups. By unders anding he perspec ives o all user groups, wecan help o illumina e a pa h orward, clear he hurdles o he pas , and nd our way o a mu ually bene cial u ure.

Sec or managemen represen s he bes hope or he u ure o his his oric shery.Te sys em has i s limi a ions, and improvemen s are undoub edly necessary. Ye

here is near-universal dis as e or a re urn o he old sys em o managemen a

sys em where shing was con rolled by limi ing he number o days per year sh-ermen were allowed o shand no o her viable al erna ive has emerged, even

rom hose who sugges sec or managemen will resul in hyperconsolida ion o he shery in o a ew hands, nancially suppor ed ei her by corpora e en i ies or

environmen al groups and ounda ions.

Troubled relationships in the fishery need to be fixed

Te rela ionships among shery regula ors, scien is s, indus ry members, andenvironmen al groups are more con en ious in New England han in any o herregion o he coun ry. Every one o he groups involved has played a role in hede eriora ion o hese rela ionships, which in urn has led o he lack o rusamong s akeholders in he region.

Beginning in he la e 1980s, regula ors imposed increasingly s ric limi s on hishis oric shery designed o allow deple ed sh popula ions o recover. Congress bols ered hese e or s by enhancing he conserva ion requiremen s in law.

Fishermen and heir poli ical allies o en resis ed hese e or s, disparaging he sci-ence ha sugges ed ca ch reduc ions were necessary.

Scien is s s ruggled wi h imper ec da a and he uncer ain y o atemp ing o quan-i y and unders and a resource consis ing o a dozen di eren species ha are mos ly

invisible, highly mobile, and spread across ens o housands o square miles.

Ultimately, sect

management

represents the

best hope or

the uture o th

historic shery.


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Environmen alis s, worried ha sh s ocks were approaching a ipping poin beyond which hey migh never recover, pushed back agains indus ry e or s o weaken res ric ions.

And regula ors became ensnared in an escala ing maels rom o con ic ing argu-

men s, legal manda es, and increasingly convolu ed regula ions born o atemp so broker a compromise ha could appease a dispara e se o s akeholders.

As we atemp o rebuild deple ed sh popula ions, hese human rela ionshipsnow labor in a oxic soup ha has poisoned dialogue, expunged rus , and madera ional progress all bu impossible o achieve. Te undamen al source o u uresuccess in he ground shery mus s ar wi h improved rela ionships among s ake-holder groups. No managemen s ruc ure s ands a chance wi hou some degree o buy-in and coopera ion o all par icipan s.

Recommendations for improving stakeholder relationshipsand management

Tese recommenda ions will be explained in grea er de ail in he repor , bu hereare he s eps necessary o improve rela ionships and managemen s ra egies or

he ground shery. Tese will ensure he sys em can con inue o build on heimprovemen s made in i s rs wo years, par icularly in ligh o budge cons rain sand bel - igh ening aking place across he ederal governmen as well as new chal-lenges ha have emerged involving scien i c review o sheries and how o collecda a ha will be in egral o he u ure success. Tese recommenda ions will alsohelp overhaul he rela ionships among he dispara e s akeholder groups so ra ionaldialogue can once more ake he place o bombas ic rhe oric.

New personnel hired o ll leadership posi ions wi hin he Na ional Oceanicand A mospheric Adminis ra ion he governmen agency wi h jurisdic ionover our na ions sheriesin he nor heas region mus priori ize changing hepercep ion o he agency among shermen and o her s akeholders.

Every s akeholder group, including he Na ional Oceanic and A mospheric Adminis ra ion, scien is s, shermen, poli icians, and environmen al nongov-ernmen al organiza ions, mus ake s eps o improve communica ion and makea grea er e or o unders and he perspec ive o hose who disagree wi h hem.


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All shery s akeholders mus collabora e o improve shery da a collec ion andanalysis o provide more accura e assessmen s o sh popula ions and reduceuncer ain y ha may ar i cially reduce o al allowable ca ches.

Te Na ional Oceanic and A mospheric Adminis ra ions Nor heas Fisheries

Science Cen er mus work wi h shermen and ex ernal organiza ions oreduce he cos o shery moni oring, including by developing me hods oimplemen elec ronic moni oring sys ems as a replacemen or supplemen orhuman shery observers.

Te Na ional Oceanic and A mospheric Adminis ra ion and he New Englandshery managemen council mus ake s eps o analyze he validi y o consolida-ion concerns in he sec or managemen sys em and address hem as necessary,

including hrough explora ion and developmen o permi banks o ensure ageographically diverse group o shermen re ain access o he shery.


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A history of management in theNew England groundfishery

The Magnuson-Stevens Act

Te Fishery Conserva ion and Managemen Ac o 1976, la er and morecommonly re erred o as he Magnuson-S evens Fishery Conserva ion andManagemen Ac , or Magnuson-S evens Ac , was ini ially conceived as a meanso orcing oreign ee s ou o our exclusive economic zone, which ex ends 200miles rom shore. Prior o he laws passage, oreign shing boa s were regularly

visible rawling wa ers as close as hree miles o American beaches. In he yearsha ollowed, he governmen subsidized hrough a program o low-in eres

loans he developmen o domes ic shing ee s o replace he shing capaci y o oreign vessels no longer permited o opera e in our wa ers.4

As a resul , ca ch o ground sh (re erred o as landings) by U.S. shermensoared o unpreceden ed levels by he early o mid-1980s. Tough ew shermenrecognized i a he ime, his cres was he beginning o a slide ha would lead o

he severe deple ion o a resource ha jus decades be ore had been deemed soplen i ul ha no shing e or could ever scrape he botom o he barrel.

Despi e ongoing improvemen s in echnology, he amoun o sh brough omarke began o precipi ously decline. In shor , here were oo many shermenchasing oo ew sh. Annual ca ches o he nine species ha oday are included insec or managemen peaked a 159,000 me ric ons in 1982, ell o 86,000 me ric

ons in 1990, and botomed ou a jus 25,000 me ric ons in 2006less han one-six h o i s peak harves level.

As landings plumme ed, he scien is s sugges ions ha shing had o be cur ailed

were drowned ou by he cry rom poli ical orces ueled by shing cons i uen seager o replica e he boom years o he 1980s. Fishermen, buoyed by ederal sub-sidies, had inves ed heavily in business plans ha required massive and ul ima ely unsus ainable ca ch levels in order o be success ul. When he governmen even u-


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ally urned around and old hem hey had o cu back heir shing o a level ha would compromise he viabili y o heir businesses, i plan ed he seeds o whahas blossomed in o deep mis rus and resen men .

In addi ion o ou lawing oreign shing, he Magnuson-S evens Ac also es ab-

lished an innova ive and unique managemen s ruc ure. Te law divides hena ions sheries in o eigh regions and crea es a sys em o regional shery man-agemen councils ha developand approve shery manage-men plans or each shery ini s given region.

Under he council sys em,indus ry members comprisea majori y o each councils

members, and hus he indus-ry in many ways es ablisheshe regula ions under whichhey will opera e.

Te New England shery man-agemen council, or example,is comprised o he Na ionalMarine Fisheries Servicesregional adminis ra or, eachs a es principal shery man-agemen ofcial, and quali edindividuals rom he commer-cial, recrea ional, and char er

shing indus ries and conserva ion groups. Te nongovernmen al pool consis s o people nomina ed by s a e governors and appoin ed by he secre ary o commerce

o ensure a air and balanced appor ionmen .5

Te members o he regional shery managemen councils direc he councils

ull- ime s a s o esh ou he de ails o managemen proposals ha ul ima ely become shery managemen plans. Tese plans are hen amended and vo ed on by council members a public mee ings. Once approved, hey are sen hrough

he Na ional Marine Fisheries Service he division o he Na ional Oceanic and

Fish landings plummet

Fish landings and value in New England ground ishery, 1970-2010

0

10000

20000

30000

40000

50000

60000

70000

80000

90000

100000

110000120000

130000

140000

150000

160000

1970 1975 1980 1985 1990 1995 2000 2005 2010

Weight (metric tons) Value ($ mil

Weight (metric tons)

Value ($ million)

Source: National Oceanic and Atmospheric Administration


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A mospheric Adminis ra ion and he Depar men o Commerce responsible orhe s ewardship o he na ions marine resources and habi a o he secre ary o

commerce or approval or rejec ion.

In prac ice, he secre ary will vir ually always approve a plan i i mee s he

requiremen s o he law. While possible, i is ex remely rare or he secre ary odisapprove a legal plan.

In addi ion o annual ca ch limi s and accoun abili y measures, he plan mus con-ain all he parame ers ha will govern shing, including coun less variables such as:

Te species covered by he plan How ha ca ch will be appor ioned be ween commercial and recrea ional

shermen and among di eren gear ypes Which gear ypes are permissible Te boundaries o open and closed shing areas How byca ch he acciden al ca ch o non arge specieswill be managed How ca ch accoun ing will occur

The beginnings of conservation

In i s ini ial i era ion, he Magnuson-S evens Ac said litle abou conserva ion.Bu ollowing a series o amendmen s in he 1980s and early 1990s designed o

ur her Americanize sheries, s reng hen en orcemen provisions, and enhancein erna ional managemen me hods, Congress and Presiden Bill Clin on alas made conserva ion a priori y wi h passage o he Sus ainable Fisheries Acin 1996.6 Tis law ook he rs signi can s eps oward iden i ying and endingover shing. I also es ablished a con roversial requiremen o rebuild deple ed shs ocks wi hin 10 years excep under narrowly de ned circums ances.

Opponen s o he 10-year imeline argue ha he hard deadline is arbi rary anddoesn adequa ely accoun or di erences in sh biology, environmen al condi-

ions, or he inheren ly uncer ain na ure o sheries science. While some conser-

va ionis s may concede ha he ime period lacks any scien i c ounda ion, hey righ ly argue ha he law lacked any ee h un il he ins i u ion o his provision.Managers ended o err on he side o allowing over shing o con inue and hoping

or a more posi ive ou look rom he nex s ock assessmen .


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aking he ground shery as an example, he New England shery council repea -

edly vo ed or managemen plans ha , while legal, ignored or cherry-pickedhe advice o scien is s, resul ing in res ric ions insufcien o curb he rampan

over shing ha con inued in o he early 2000s. Te 10-year imelinewi h he backing o a hand ul o judicial rulingsul ima ely orced he council o reduce

he shing pressure and give sh s ocks a chance o bounce back.

Te batle over he 10-year imeline carried over in o he mos recen deba e aboureau horiza ion o he Magnuson-S evens Ac , which concluded in 2006 wi h

he passage o he Magnuson-S evens Fishery Conserva ion and Managemeneau horiza ion Ac .7 While deba e over he 10-year imeline and o her conserva-ion issues raged in Congress and delayed passage o he law by several years, he

2006 law ul ima ely re ained he conserva ion provisions es ablished in 1996 andook signi can addi ional s eps.

Speci cally, he 2006 law required councils or he rs ime o se annual ca chlimi s in all over shed sheries by 2010 and in all o her sheries by 2011 and oes ablish accoun abili y measures ha apply in he even an annual ca ch limi isexceeded. Fur her, i included a legal manda e ha he annual ca ch limi s cannoexceed scien i c recommenda ions.

A ypical accoun abili y measure would be deduc ing he weigh o any sh caughin excess o an annual ca ch limi rom he subsequen years ca ch limi . So i he2012 ca ch limi o a species is 10,000 me ric ons and shermen ca ch 11,000 me -ric ons, he 2013 ca ch limi would be reduced by 1,000 me ric ons. Addi ionally,

The terms over shed and over shing are obviously related butthey have very di erent meanings in terms o shery management.

Over shing is the act o catching more sh in a given time period(usually one year) than the population can naturally replace.

Over shed re ers to a state o beingan over shed shery meansthe sh population is below sustainable levels, due to shing activity.

A shery can be over shed even i over shing is not occurringbecause o over shing activity in past years. It can be experienover shing without being in an over shed condition because th

population is large enough to handle a small amount o temporover shing, but continued over shing will lead to an over shedcondition. It also can be both, or it can be neither.

Overfished vs. overfishing


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in sheries wi h recrea ional and commercial componen s, he annual ca ch limi oreach species mus be subdivided be ween hese separa e groups.

As no ed above, he 2006 Magnuson-S evens Ac reau horiza ion changed he law o clari y ha councils mus se ca ch limi s ha may no exceed he shing level

recommenda ions o i s science and s a is ical commitee.8

As his commiteesname would indica e, his is he body ha analyzes scien i c s ock assessmen sand de nes how many sh can be caugh while ei her main aining a heal hy s ock or, in he case o a shery ha is over shed, keeping he shery on i s rebuilding

rajec ory o mee i s 10-year deadline.

While many o he Magnuson-S evens Ac s manda es have changed over ime, hes ruc ure or implemen ing a shery managemen plan ou lined in he previoussec ion remains basically in ac .

Clearly, he sys em is convolu ed and complex, and when i comes ime o makedifcul decisions based on science ha inheren ly con ains a high degree o uncer ain y, i s easy o see how a managemen body comprised in large par o represen a ives o he indus ry being regula ed can be open o con ic -o -in erescri icism. Managing a single-species shery is difcul enough, bu looking a heNew England ground shery means atemp ing o simul aneously balance heneeds o more han a dozen species o shan exponen ially s ickier wicke hahas led regula ors and shermen hrough decades o hell.

Transitions in the groundfishery: From days at sea to sectormanagement

Prior o he s ar o he 1994 shing year, he New England shery managemencouncil approved Amendmen 5 o he ground sh managemen plan. Under hesenew rules shermen were gran ed a ni e number o days a sea in which hey could sh. Te idea was ha regula ors would limi ca ch by limi ing shing. Tis began a sys em ha would las 15 years and en rench dys unc ional rela ionships be ween shermen, regula ors, scien is s, and o her shery s akeholders.

In choosing o manage based on days a sea, regula ors be on an imprecisemanagemen sys em ri e wi h unin ended consequences. Ul ima ely i requiredan increasingly arcane series o secondary rules o ur her con rol shing ac ivi y.From 1994 hrough 2009, 11 major amendmen s and 43 lesser changes, called

The 2006 law

required councils

or the rst time

to set annual

catch limits in alover shed sher

by 2010 and in a

other sheries by

2011.


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ramework adjus men s, ollowed Amendmen 5 o ne- une he sys em and closeone loophole a er ano her weaking gear res ric ions, closing areas o pro echabi a and spawning grounds, and es ablishing limi s on he amoun o sh hacould be caugh in a day or on a single rip. Ul ima ely, his sys em proved cum- bersome, inefcien , and a imes coun erproduc ive.

For ins ance, because ime (or days) a sea was he commodi y, some shermenop ed o overexploi shing grounds closer o shore, minimizing heir ravel ime

o maximize heir shing ime. More consis en shing in hese areas obviously a ec ed he sh s ocks as well as he ecosys em o hese areas.

Managers hen imposed a rule asser ing ha each day spen shing in cer ain near-shore areas would coun as wo days a sea. While his succeeded in reducing e orin wha came o be known as he 2- or-1 areas, i proved an excessive burden onsmall-boa shermen whose vessels didn have he abili y o ravel ur her o shore.

rip limi scaps on he amoun o a species shermen could ca ch during asingle day a sea, or over he course o a mul iday ripbecame par icularly con en ious because hey o en orced shermen o dump large quan i ies o legal-size sh overboard. Te limi on cod, or example, was even ually reduced o800 pounds per day, bu here was no requiremen ha he sherman s op shing when his limi was achieved. So shermen could con inue o sh o ge he maxi-mum value rom a day a sea by ca ching o her species like haddock and ounder, bu hey would have o hrow back any hing more han 800 pounds o cod.

Tis regula ion ailed o accoun or he biology o cod. A er i s hauled up romhe sea botom, a cod will likely be dead by he ime i hi s he deck. Te end resul

was ha shermen were discarding hrowing overboarddead, marke able cod.

Tis requiremen o hrow back legal-size, already dead sh was a major con ribu-or o he indus rys rus ra ion over he old managemen sys em. Fishermen

despised he idea o wa ching dead, marke able sh dri o he botom o becomelobs er oodno jus because i was ea ing in o heir botom line, bu also because o he e ec i was having on he resource.

Tis period was also ri e wi h lawsui s. Environmen al groups alleged he coun-cil and Na ional Marine Fisheries Service had ailed o achieve he conserva-

ion arge s es ablished in he law.


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Te mos signi can o hese sui s was brough in 1999 a er he New Englandshery managemen council ook i s rs ac ion o implemen he 1996

Sus ainable Fisheries Ac es ablishing he 10-year imeline or sh s ock rebuild-ing. Te sui accused he council and he Na ional Oceanic and A mospheric Adminis ra ion o ailing o mee he condi ions o he law by no seting ca ch

limi s a a level ha would allow rebuilding o over shed popula ions wi hin heimeline required by law. In 2001 a judge ruled in avor o he plain i s.

Te decision in his case orced he New England shery managemen council odevelop Amendmen 13, which ook e ec in 2004 and se new s ric er arge s and

imelines or rebuilding ha me he condi ions o he law. I also allowed shermeno lease days a sea among one ano her or he rs ime. In an implici acknowl-

edgemen ha he days-a -sea sys em likely wouldn achieve i s goals or manda es, Amendmen 13 also included a provision s ipula ing ha he council would developa new managemen sys em or he ground shery in ime or he 2009 shing year.

Amendmen 13 crea ed he ounda ion o he nex major ransi ion in he shery.I es ablished a sys em o approval or shing sec ors or groups o shermen hacould organize and pe i ion he council o receive a share o sh based on heirca ch his ory in exchange or shing under a hard ca ch limi and under a s ricplan es ablished speci cally o govern par icipan s in ha sec or. One such sec or was speci cally named in he amendmen : he Georges Bank hook sec or, com-prised mainly o shermen rom Cha ham, Massachusets, on Cape Cod.

Te council hen announced in 2006 ha i was beginning delibera ion on plans or Amendmen 16, he managemen ac ion ha would reshape he ground shery onceagain by crea ing a comple ely new, innova ive managemen sys em. Bu in ypical

ashion he road would no be smoo h. By 2008 i became clear ha while he coun-cil was considering mul iple op ions or new sys ems o replace days a sea, i s work would no be comple ed in ime o begin he nex shing year on May 1, 2009.

Back in 2004 he Na ional Oceanic and A mospheric Adminis ra ion had only approved he provisions in Amendmen 13 because hey were ied o he under-s anding ha 2009 would mark he ransi ion o a newand heore ically

betersys em. Tus, in he absence o a new sys em, he councils inabili y ocomple e i s work mean he agency would be orced o implemen an in erim rule by execu ive ac ion ha would dras ically reduce each shermans days a sea opo en ially ewer han 20 or he en ire year in order o keep landings a a level ha would achieve he rebuilding arge .


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Be ore he s ar o he 2009 shing year, he New England congressional delega ion brokered a deal wi h he Na ional Oceanic and A mospheric Adminis ra ion, heNew England shery managemen council, and environmen al groups ha avoided

he dras ic cu s o days a sea and allowed he council one more year o nish i s work on Amendmen 16.

On January 21, 2010, he Na ional Oceanic and A mospheric Adminis ra ion or-mally approved Amendmen 16 o he Nor heas Mul ispecies Fishery ManagemenPlan, ushering in a new era in New England ground sh managemen .

On April 30, 2012, he shery comple ed i s second year under sec or manage-men , and while here are ample de rac ors o he sys em who decry wha hey perceive as i s endency o consolida e shing ac ivi y a he expense o some sh-ing communi ies, one hing is cer ain: In he rs year o he plan, he por ion o

he ground shery opera ing under sec or managemen did no exceed i s annual

ca ch limi on any species.


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Timeline: History of the New England groundfishery

1976 Congress passes the Fishery Conservation and Management Act.

1977The rst shery management plans or ground sh species take e ect. With no limit on how many

shermen can participate, the plan incentivizes shing as quickly as possible. The cod shery closeswithin ve months and the haddock shery within six months when catch limits are hit.

1982The interim ground sh shery management plan is implemented. Catch limits are abandoned in

avor o gear restrictions designed to make shing less e cient.

1984The U.N. World Court sets the boundary between the U.S.-Canadian exclusive economic zones,dividing the richest shing grounds on Georges Bank between the two countries.

1986Individual ground sh species are managed jointly or the rst time under a multispecies sherymanagement plan. It includes witch founder, plaice, pollock, and winter founder.

1990Congress passes the Magnuson Fishery Conservation and Management Act. It is the rst legalacknowledgement o the need or scienti c data to establish the health o sh stocks.

1994Amendment ve to the multispecies shery management plan establishes days-at-sea manage-ment in the ground shery with the goal o reducing sh mortality by 50 percent rom 1993 levels.

1996Amendment seven to the multispecies shery management plan reduces the total number o daysat sea and establishes rebuilding targets or yellowtail founder, cod, and haddock.

1996Congress passes the Sustainable Fisheries Act. It ocuses on eliminating over shing, sets a 10-yeardeadline to rebuild over shed stocks, and requires shery managers to consider the socioeco-nomic impacts o shery management decisions.

1999Amendment nine to the multispecies shery management plan sets catch limits or 12 ground shstocks in an attempt to bring the plan into compliance with the Sustainable Fisheries Act.

1999Environmental groups sue the U.S. Department o Commerce or ailing to meet the SustainableFisheries Act requirements. The U.S. District Court rules in avor o environmentalists in 2000.

2004Amendment 13 to the multispecies shery management plan is implemented. It acknowledgesover shing, sets new rebuilding timelines, and allows trading o days at sea among shermen orthe rst time.

2006The New England shery management council releases a notice o intent to prepare amendment16 or implementation in 2009, which ultimately leads to sector management.

2006Congress passes the Magnuson-Stevens Fishery Conservation and Management ReauthorizationAct. It urther strengthens environmental sa eguards and requires annual catch limits or all sher-ies by 2011.

2008The New England shery management council announces it will not complete work on amend-ment 16 on schedule. The National Marine Fisheries Service is orced to implement an interim rule

or the 2009 shing year.

2009 Amendment 16 passes, implementing sector management or the 2010 shing year.

2010A provision o the Magnuson-Stevens Fishery Conservation and Management Reauthorization Acttakes e ect requiring all sheries subject to over shingincluding the ground sheryto imple-ment strict annual catch limits and accountability measures in the event that limits are exceeded.

May

2010Sector management begins.

2011A provision o the Magnuson-Stevens Fishery Conservation and Management ReauthorizationAct takes e ect requiring implementation o strict annual catch limits in all sheries regardless o over shing status.

NOTE: Dates shaded in blue represent actions and developments at the ederal level. Unshaded dates are speci c to the New England ground shery.


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How sector management works

A i s core, sec or managemen allows shermen he op ion o opera ing under aca ch share sys em in which regula ors se an overall amoun o sh he indus ry isallowed o ca ch or he year, and he annual ca ch limi is hen par i ioned among

par icipa ing shermen so each receives a percen age o he o al. Fishermen havehe choice o ei her join and opera e in sel -selec ing ca ch share coopera ivescalled sec ors in which shermen pool heir alloca ions, or sh independen ly using he old days-a -sea sys em.

Fishermen who choose he later op ion are re erred o as being in he com-mon pool. Bu here aren many o hem. By he ime Amendmen 16 wasimplemen ed, he days-a -sea sys em was resoundingly considered a ailure.Fur hermore, regula ions on common-pool shermen are more conserva ive han

or hose opera ing in sec ors due o he grea er uncer ain y o es ima ing land-

ings based on shing as opposed o coun ing he ac ual amoun o sh caugh . As he 2010 shing year wore on, he already igh regula ions on common-pool

shermen became increasingly s ric er, and his inspired many shermen o join asec or he ollowing year. In 2010 more han 98 percen o he ca ch his ory in he

shery ended up in sec ors, and ha percen age increased o 99 percen in 2011.9

Tis repor ocuses on he 99 percen o shermen who opera e under sec or man-agemen . Each sec or is comprised o a sel -selec ing group o shermen, usually wi h some commonali ygear ype, home por , or vessel size. When shermen

orm a sec or, hey es ablish a managemen plan wi h ground rules ha mus hen be approved by he Na ional Marine Fisheries Service.

Each permi in a sec or is alloca ed a percen age o each species o al allowableca ch based on a ormula ha accoun s or he ca ch his ory aflia ed wi h hapermi rom 1996 o 2006. Tis percen age is afxed o each permi in perpe ui y unless he council vo es o change he ini ial alloca ion ormula.

In simpli ed erms, his means ha i a sherman caugh 1 percen o all he GeorgesBank cod harves ed during he period o ime used o calcula e he permi s ca ch

his ory, 1 percen o each years annual ca ch limi or ha species will be assigned ohis permi every year he par icipa es in a sec or or as long as he sec or managemensys em is in place. Tis percen age o sh, re erred o as he annual ca ch en i le-men , only becomes e ec ive once he permi holder agrees o join a sec or, a which ime he en i lemen becomes he sec ors, no he shermans.

Sector managem

gives shermen

the choice to eith

join and operate

in sel -selecting

catch-share

cooperatives call

sectors in which

shermen pool th

allocations, or s

independently us

the old days-at-se

system.


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While his sounds like a echnicali y, i is a cri ical poin . Te 2006 reau horiza-ion o he Magnuson-S evens Ac included a provision allowing councils andhe Na ional Oceanic and A mospheric Adminis ra ion o implemen ca ch share

programs, which he law re ers o as limi ed access privilege programs. Tis provi-sion o he law includes a requiremen or he council o conduc a re erendum

o permi holders be ore implemen ing such a program in ei her New Englandor he Gul o Mexico. Bu because sec ors ra her han individual shermen holdhe quo a, he sys em does no echnically include an individual shing quo a.

S ill, each sec or mus decide how o alloca e i s quo a among i s shermen, and ishould come as no surprise ha he mos common manner o doling ou quo a osec or members is o assign hem he amoun o sh ha heir permi or permi s brough in o he sec or. Bu because sec or managemen does no cons i u e alimi ed access privilege program, no re erendum was required.

Opponen s o he sec or sys em, led by he ci ies o New Bed ord and Glouces er,

challenged his nding in cour , claiming he Na ional Oceanic and A mospheric Adminis ra ion relied on a convolu ed in erpre a ion o he law o ge around here erendum requiremen . Tey would like o see he sec or managemen sys eminvalida ed because i i remains in place hey eel i will resul in a loss o shing jobs, par icularly or shermen opera ing smaller vessels. In June 2011 a dis ric judge upheld he legali y o sec ors as es ablished in Amendmen 16.10 Te plain-

i s are curren ly appealing ha decision.

Once he sec or de ermines how o alloca e i s sh, he members can ca ch heir shin as many or as ew days as hey are able provided hey opera e wi hin he groundrules se by he sec ors bylaws. One new and consis en regula ion across all sec ors is

ha shermen mus keep every legal-size sh hey ca ch. Tis elimina es all legal-sizediscarding, which was rampan under he days-a -sea sys em wi h i s s ric rip limi s.

Te shermen in a sec or become join ly and severally liable or any overage, orca ch in excess o he sec ors annual ca ch en i lemen , which helps hem becomesel -policing. Each sec or has a manager responsible or repor ing heir ca ch o heNa ional Marine Fisheries Service on a weekly basis. Tese gures are veri ed by moni ors on board roughly 25 percen o he vessels and via repor s rom licensed

sh dealers. Tese da a are hen veri ed by he Na ional Marine Fisheries Service.

Sec ors can also rade quo as wi h o her sec ors, hough some have implemen edan in ernal righ o rs re usal in he even a sherman wan s o lease ou his sh.


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Fishermen in he common pool do no receive quo as rom heir permi s. Ins ead,hey receive an amoun o days a sea ha hey can hen use under a di eren se o

res ric ions.

As previously men ioned, hose res ric ions were exceedingly igh in 2010. When

he shing year s ar ed on May 1, each common-pool sherman had an averagealloca ion o 24.2 days a sea or he en ire year, and he aced rip or daily limi s onseven di eren sh s ocks. Tings very quickly wen rom bad o worse as sher-men were ca ching more sh earlier in he season han regula ors an icipa ed.

In order o keep he common-pool shermen on rack o s ay wi hin heir ca chlimi s, on July 20 he rip limi on Gul o Maine cod was reduced by 75 percen .Ten, on Sep ember 2, regula ors began coun ing days a sea on a 2- o-1 ra io,meaning hose 24.2 days a sea were now wor h jus 12.1 days. On Sep ember22 he Gul o Maine cod rip limi was reduced by an addi ional 50 percen , he

Georges Bank yellow ail ounder rip limi was cu by 96 percen , and he daily limi on whi e hake was cu by 95 percen .

A er opera ing under days a sea or years, mos shermen unders ood ha heres ric ions on heir shing would be severe, bu ew who op ed o remain in hecommon pool or couldn nd a sec or o join expec ed he res ric ions o be asharsh as hey were. Te resul is ha less han 1 percen o he po en ial annualca ch es ima e or 2011 was gran ed o shermen who op ed no o join a sec or.

Criticisms of sector management

Sec or managemen was already wildly unpopular wi h a segmen o he shingindus ry even be ore i ook e ec .

Te mos prevalen cri icism o sec or managemen is ha i is causing widespreadshing consolida ion in ewer vessels in he shery. In par icular, smaller shing

opera ors, primarily in New Hampshire and Massachusets, express grave con-cerns wi h he councils ailure o impose accumula ion limi s capping he amoun

o quo a a sec or or group o sec ors can con rol.

Sec or opponen s poin o a s a is ic in a Na ional Marine Fisheries Service reporabou he rs year under sec ors: Approxima ely 20 percen o ground sh vessels

The most prevale

criticism o sect

management is

that it is causing

widespread shi

consolidation in

ewer vessels in

shery ... but, o

vessels operating

under sectors,

there was actuall

less revenue

consolidation in

2010 than in 200


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accoun ed or 80 percen o he revenue, while in 2009, he las year under days asea, 68 percen o he revenue wen o he op h o shing boa s.11

Bu looking back ur her han 2009 shows ha rom 1996 o 2007 he op 20 per-cen o vessels landed 78 percen o he sh, much closer o he 2010 dis ribu ion.

Fur her, he op 20 percen o vessels shing under sec or managemen in 2010(represen ing 98 percen o he o al alloca ion o ground sh) accoun ed or jus67.3 percen o sec or revenues.12 Tus, or vessels opera ing under sec ors, here was ac ually less revenue consolida ion in 2010 han in 2009.

I s unques ionable here are ewer boa s shing primarily or ground sh now han here were in years pas , bu his reali y represen s a more- han-decade-longrend ha s independen o sec or managemen . From 2001 hrough 2009 heo al number o vessels in he ground shery declined by 54 percen . Ta rend

con inued under sec ors bu has no accelera ed, and i is no direc ly rela ed o

he sec or sys em. a her his consolida ion is a direc resul o pas over shing.

ecall ha in he la e 1970s and early 1980s, he governmen subsidized hegrow h o he domes ic shing ee a er he original Fishery Conserva ion andManagemen Ac pushed oreign shing pressure ou o our exclusive economiczone. As a resul here were more boa s on he wa er shing more efcien ly han

sh popula ions could suppor . Tis increase in shing pressure led o poli icalpressure on shery managers o se limi s ha were likely o be unsus ainable over

he long erm. Ten as regula ors, promp ed in some cases by lawsui s, reducedca ch limi s o end over shing, shermen were aced wi h ca ch res ric ions hamade heir businesses no economically viable. Tey ough back by convincing

heir elec ed ofcials o apply poli ical pressure, which resul ed in ca ch limi sremaining oo high and ul ima ely he perpe ua ion o over shing.

Tis vicious cycle came o a close in 2010. In addi ion o being he rs year o sec or opera ions, 2010 was also he rs year regula ors were required o imposes ric , science-based annual ca ch limi s in he shery, including accoun abili y measures in he even a limi was exceeded. Tis requiremen , comple ely inde-penden o sec or managemen , mean ha no only did shermen have o adjus

o a new managemen sys em, bu heir abili y o sh would be ur her res ric ed. And his would have been he case no mater wha sys em was in place.

S ill, many members o he media have seized on shermens argumen s as aex book s ory o big governmen cracking down on he small-business ownerin


22/56


his case, he small-boa sherman. Teir perspec ive is espoused voci erously inheGloucester Daily Timesa news ou le whose coverage has become severely

slan ed agains he Na ional Oceanic and A mospheric Adminis ra ion and i s cur-ren adminis ra or, Dr. Jane Lubchenco. I s edi orials resoundingly cas iga e heagencys decisions and have gone so ar as o single ou Lubchenco as a unnel-

visioned pseudo-scien is .13

Massachusets poli icians hold up heir cons i uen s concerns as proo ha heNa ional Marine Fisheries Services one-dea ness remains acu e, and i s policies,including promo ion o ca ch shares, are puting shermen o he wa er.

Tis ati ude has led o a series o con en ious hearings in bo h he House and Sena eand caused some elec ed ofcials o advance ill-conceived legisla ion, including heSaving Fishing Jobs Ac o 2011, a bill in roduced by Sens. Kelly Ayote ( -NH) andScot Brown ( -MA) ha would invalida e any ca ch share managemen sys em i i

resul s in he loss o more han 15 percen o jobs in a shery.

In addi ion o such legisla ionand he lawsui led by he ci ies o New Bed ordand Glouces er aimed a invalida ing Amendmen 16 because no re erendum wasconduc ed prior o i s implemen a ionnumerous o her cri icisms have been lev-eled a sec or managemen since i s implemen a ion.

One o he mos prevalen allega ions is ha sec or managemen is Lubchencos brainchild, and ha her adminis ra ion has orced ca ch shares on he shery. Bu while he agency cer ainly made developmen o ca ch shares in U.S. sheries apriori y, Lubchencos policy pre erences have litle o do wi h he councils deci-sion o develop sec or managemen .

Amendmen 13 es ablished he rs sec ors in 2004, and he New England shery managemen council announced i s in en ion o develop sec or managemen in Amendmen 16 in 2006 wo years be ore Lubchencos con rma ion as NOAA adminis ra or. Te council, he agency, and o her s akeholders worked on devel-opmen o he sys em or more han hree years, holding more han 61 publicmee ings be ore puting he nal measure o a vo e in June 2009. Numerous al er-

na ives o sec or managemen were considered and ul ima ely rejec ed. And in heend he council approved he nal measure by a vo e o 15-1.

Meanwhile, he Na ional Marine Fisheries Service made a legi ima e commi meno make sec or managemen work. Since 2009 he agency has:


23/56


Spen more han $47 million on programs o ease he ransi ion o sec ormanagemen , including paying or moni ors and observers in he shery, andsuppor ing developmen o sec or managemen plans, science and s ock assess-men s, and research on new gear ypes14

Suppor ed he success ul work o he New England congressional delega ion, led by Sen. Olympia Snowe ( -ME), o enac legisla ion clari ying a echnicali y hagave a compe i ive advan age o Canadian shermen in a shared area o GeorgesBank, his orically among he riches shing grounds in he Gul o Maine15

Increased o al allowable ca ch levels whenever he science permited, including boos ing he harves limi or pollock, a cri ical componen o he shery 16

Shelved a proposal o implemen a new research area closed o shing wi hin heS ellwagen Bank Na ional Marine Sanc uary when da a showed he ac ion could

cos up o 123 shing jobs

Commited o und 100 percen o he cos o a -sea moni ors and observers or he2012 shing yearan expense projec ed o save he indus ry millions o dollars

A he same ime, here were miss eps on he Na ional Oceanic and A mospheric Adminis ra ions par ha while perhaps no more han symbolic provide odder o

hose who don believe he coopera ive spiri is credible.

For ins ance, a er es i ying a a eld hearing o he U.S. Sena e Commitee onCommerce, Science, and ranspor a ion in Glouces er in Oc ober 2011, called

o review Massachusets shery managemen plans, Lubchenco le he hearing be ore he second panel o wi nessescomprised o he Massachusets direc or o marine sheries, wo local shery scien is s, he New England council chairman,and a local shermancomple ed i s es imony.

Lubchencos early depar ure, while common prac ice a hearings in Washing on, was rumpe ed by an isec or shermen and heir allies as evidence ha he agency has no in eres in anyones perspec ive bu i s own.

Par ly in response o hese cri icisms and he momen um seemingly buildingoward an overhaul or even abandonmen o sec ors, in November 2011 a group

o more han 100 shermen sen a leter o he New England congressional delega-ion sugges ing ha he key o a unc ional u ure or heir shery is managemen


24/56


s abili y. As such, hey asked ha sec or managemen remain in place, bu hey also s ipula ed several areas ha could be improved including increased oppor u-ni ies o arge robus s ocks, reduced cos o opera ions, and addi ional unding

or s ock assessmen s and science.17

Tis las concernaccess o adequa e unding or shery s ock assessmen sispoised o become a major s icking poin or sec or managemen and he u ure o he ground shery in ligh o he Gul o Maine cod s ock assessmen bombshellha exploded in November 2011. Te nex sec ion o his repor will examine heallou rom ha assessmen and address addi ional challenges o he u ure o

sec or managemen .

Results of sector managements first years

Fishermen hold vas ly diverse opinions abou whe her or no sec or managemenhas been an improvemen over previous sys ems, hough i s elling ha vir ually no one suppor s a re urn o days-a -sea managemen .

o ci e one example, in 2011 he Gul o Maine esearch Ins i u e, an independenmarine science cen er, conduc ed polling o gauge shermens percep ion o hesys em in i s rs year. According o he resul s o heir s udy, a plurali y o shermen(46 percen ) el hey were beter o under sec ors han hey would have been underdays a sea. Tir y-six percen believed hey were worse o . Ye despi e making

ewer rips, nearly hree-quar ers o responden s repor ed an increase in opera ingcos s, ci ing higher uel prices and he cos o leasing quo as as he mos increasedexpenses. Addi ionally, 55 percen repor ed a decrease in revenue or he year.18

Te overlap in percen ages o hose who el hey were beter o under sec orsdespi e decreasing revenue shows once again jus how ine ec ive he days-a -seasys em had become. Even some shermen who los money acknowledged hey would have los more money i days-a -sea had remained in place.

According o he Gul o Maine esearch Ins i u es polling, nearly all sec or mem-

bers who shed in 2010 planned on remaining ac ive in 2011, and many sher-men who joined a sec or bu leased ou all heir quo a plus a signi can por ion o ac ive common-pool members planned on joining hem.19


25/56


Te preponderance o shermen who con inue o par icipa e in sec ors sugges sha hey recognize value in he sys em, hough no one dispu es ha here is ample

room or improvemen in he coming years as shermen and regula ors adap .

Te Na ional Oceanic and A mospheric Adminis ra ions Nor heas Fisheries

Science Cen er also issued a repor on rends in he ground shery in he rs yearunder sec ors ha showed mixed resul s. While i appears sec or managemen didno reverse all he nega ive rends in he sherysuch as declining numbers o vessels par icipa ingi also didn accelera e any o hose rends. Te price sh-ermen received or heir ca ch was higher on average han in years pas , so despi eca ch levels being lower, gross revenues were nearly equal o 2009.20

Nei her o hese s udies, however, could comple ely address he e ec sec or man-agemen had on ne revenues o vessel owners or crew. While he Na ional MarineFisheries Service keeps s a is ics on he value o sh landings, i does no rack

expenses, so here are no concre e da a on whe her shermen are making moremoney under sec ors han hey were under days a sea.

Te Gul o Maine esearch Ins i u es survey ound nearly hree-quar ers o respon-den s repor ed an increase in opera ing cos s compared wi h [days-a -sea] wi h hemos requen ly men ioned ac ors being increased uel, quo a leasing, and landingcos s. Fur her, 55 percen o responden s repor ed a decrease in annual revenue (a

hird indica e drama ic revenue loss), while 24% repor ed increased revenue.

I is unclear wha por ion o hese changes are atribu able o sec ors (i.e. leasingcos s) and wha por ion would have occurred regardless o he change in manage-men (i.e. uel and reduc ions in annual ca ch limi s).

While ull-year da a is no ye available or shing year 2011, many o he rendseviden in 2010 appear o have con inued. In 2011, 11 o he 16 sec or-manageds ocks saw heir annual ca ch limi s increase while he o her ve declined. Bunone o he reduced ca ch limi s was or a s ock ha came close o i s ca ch limi in2010, so hese reduc ions have no signi can ly changed shermens behavior.

Te sum o he annual ca ch limi s in 2010 was abou 95,000 me ric ons, o whichshermen caugh 32,000 me ric ons or sligh ly more han a hird. For 2011 he

sum o ca ch limi s was cu back o 84,000 me ric ons. O ha reduc ion 9,000me ric ons came o he ca ch limi or Georges Bank haddock, bu his reduc ion

The preponderan

o shermen

who continue

to participate in

sectors suggeststhat they recogni

value in the syste

though no one

disputes that ther

is ample room

improvement.


26/56


has no a ec ed shing ac ivi y. Fishermen caugh jus 20 percen o heir allowedhaddock in 2010, and hrough he rs 11 mon hs hey have only caugh 11 per-cen o heir new, lower alloca ion.

0 20,000 40,000 60,000 80,000

95

32,765

84,077

30,825

2010

2011

Annualcatch limit

Landings

Annualcatch limit

**Landings

Georges Bank cod Gulf of Maine cod Georges Bank yellowtail ounder Georges Bank haddock Gulf of Maine hadock Pollock

0

1,000

2,000

3,000

4,000

5,000

2 0 1 0 A C L

2 0 1 0

l a n

d i n g

2 0 1 1 A C L

* * 2 0 1 1 l a n

d i n g

0

1,000

2,000

3,000

4,000

5,000

2 0 1 0 A C L

2 0 1 0

l a n

d i n g

2 0 1 1 A C L

* * 2 0 1 1 l a n

d i n g

0

300

600

900

1,200

1,500

2 0 1 0 A C L

2 0 1 0

l a n

d i n g

2 0 1 1 A C L

* * 2 0 1 1 l a n

d i n g

0

10,000

20,000

30,000

40,000

50,000

2 0 1 0 A C L

2 0 1 0

l a n

d i n g

2 0 1 1 A C L

* * 2 0 1 1 l a n

d i n g

0

200

400

600

800

1,000

2 0 1 0 A C L

2 0 1 0

l a n

d i n g

2 0 1 1 A C L

* * 2 0 1 1 l a n

d i n g

0

8,000

12,000

16,000

20,000

2 0 1 0 A C L

2 0 1 0

l a n

d i n g

2 0 1 1 A C L

4,000

Georges Bank cod Gulf of Maine cod Georges Bank yellowtail ounder Georges Bank haddock Gulf of Maine haddock Pollock

* Other includes Georges Bank cod east, Plaice, Georges Bank winter ounder, Gulf of Maine winter ounder, Witch ounder, Cape Cod/Gulf of Maine yellowtail ounder, Southern New England yellow tail oundGeorges Bank haddock east, White hake, and Red sh** 2011 landings through March 31, 2012Source: National Oceanic and Atmospheric Administration

FIGURE 2

Catch limits not exceeded

New England ground ishery annual catch limits and landing by species, 2010-2011


27/56


Looming challenges

Tis sec ion will examine wo major hurdles o sec or managemen in he ground-shery: es ablishing ca ch limi s based on sound science ha simul aneously

provide a semblance o s abili y o shermen, and providing adequa e moni oring

o shing ac ivi y ha ensures hose limi s are being ollowed.

Regulatory uncertainty

For he mos par shermen unders and here is a cer ain amoun o na ural uc-ua ion buil in o heir chosen pro ession. When hey leave he dock, hey never

know how heyll do. As any recrea ional angler knows, some days he sh are bi -ing, some days heyre no . Bu wha rus ra es hem mos is drama ic variabili y inregula ions ha akes place be ore hey even ge ou o sea.

Tis is o par icular concern in a ca ch share shery ha essen ially amoun s o acap-and- rade sys em. A i s mos basic level, a ca ch share sys em is one in whichregula ors se a limi on overall amoun o sh he indus ry is allowed o ca ch or

he year. Tis annual ca ch limi is hen par i ioned among par icipa ing shermenso each receives a percen age o he o al. Fishermen hen decide o ei her ca ch

heir por ion o he quo a or sell or lease i o o her licensed shermen.

Teir business plans are based on how much o a given species hey hink hey can ca ch, and execu ing hese plans requires a cer ain amoun o in-year s abil-i y so hey can decide whe her o lease heir quo e or ry o ca ch i . Tey alsomus decide whe her or no hey wan o buy or sell permi s, and hese decisionsrequire some semblance o longer- erm s abili yeven more so i he shermandoing he buying needs a bank o back him wi h nancing.

A couple o recen examples have illumina ed some o he difcul y inheren inproviding shermen sufcien s abili y while requiring hem o adhere o s ric ,science-based annual ca ch limi s.

In 2010, he rs year o sec ors, he ca ch limi or pollock was se a jus less han2,500 me ric ons. As shing began, shermen were erri ed o his cap, as hey were cer ain he pollock s ock was ar heal hier han scien is s hough , and as aresul hey wouldn be able o avoid ca ching ha rela ively small amoun o sh


28/56


qui e rapidly. O course, once hey hi ha cap, heir sec ors would have o shudown as s ipula ed in he managemen plan.

Te Na ional Oceanic and A mospheric Adminis ra ion heeded shermens warn-ings and agreed o accelera e i s new s ock assessmen o pollock. Sure enough, i

ound ha he popula ion was in much rosier shape han he old assessmen hadpredic ed. As a resul hey were able o make an in-season adjus men and raised heca ch limi o more han 16,000 me ric onsmore han a 600 percen increase.21

Te pollock limi increase was gree ed wi h remendous relie by shermen and heirelec ed represen a ives bu here was also an undercurren o mis rus and annoy-ance. Some shermen had already paid o s ockpile pollock quo a, beting ha a pol-lock increase wouldn come and hey would hen be able o cash in on selling o he valuable harves righ s a a premium. Fur her, he ac ha he ini ial es ima e wasso ar o he mark did any hing bu inspire con dence in he Nor heas Fisheries

Science Cen ers abili y o correc ly assess he heal h o sh s ocks.

Te pollock si ua ion may have le a bad as e in some shermens mou hs bu i wasno hing compared o he nex surprise announcemen rom he science cen er.

In he second year o sec ors, managers increased ca ch limi s on 12 ground shs ocks, including he iconic Gul o Maine and Georges Bank cod. For a brie momen i appeared he New England ground shery was a long las on a rackalbei a bumpy one o long- erm viabili y.

According o he previous s ock assessmen in 2008, Gul o Maine cod in par u-icular looked like a marvelous success s ory. According o da a, including samplescollec ed in he Na ional Oceanic and A mospheric Adminis ra ions research

ows, i appeared he species experienced a bumper crop o juveniles in 2005, which mean he sh and he sherys u ure looked rosy. egula ors increasedca ch limi s accordingly and he prospec s were good ha he s ock would be ully rebuil by i s arge da e o 2014.22

Ye when scien is s upda ed ha assessmen in 2011, i showed he 2008 assess-

men was no hing bu a mirage. Te supposed boom year o 2005 urned ou o be no more han a couple o lucky research ows ha had been given oo much weigh by researchers. Tis error combined wi h new, ner-scale da a on com-mercial and recrea ional landings led o a new, ar gloomier assessmen leavinge ec ively no chance ha he species will mee i s 2014 deadline.23

According to theprevious stock

assessment in

2008, Gul o M

cod in particular

looked like amarvelous succe

story ... Yet when

scientists update

that assessment i

2011, it showed t

2008 assessment

was nothing but

mirage.


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Te only hing preven ing he New England shery managemen council rom alegal manda e o e ec ively shu down he shery is a clause allowing he sec-re ary o commerce o promulga e emergency regula ions or in erim measuresnecessary o address he emergency or over shing.24 In January 2012 he council

ormally reques ed and received such secre arial in erven ion, which allowed he

Na ional Oceanic and A mospheric Adminis ra ion o implemen an overall ca chlimi o 6,700 me ric ons or Gul o Maine cod. Tis ransla es o abou 4,000me ric ons or sec or shermen, wi h he remainder dis ribu ed among commonpool shermen, recrea ional shermen, and o byca ch in o her sheries. While

his limi represen s a 22 percen reduc ion rom he 2011 level, i is s ill ar higherhan he law would o herwise require.

In 2010 shermen caugh more han 4,500 me ric ons o Gul o Maine cod, andin he rs 11 mon hs o 2011, hey had already caugh more han 4,400 me ric

ons, meaning heir nal harves would likely be close o heir limi o 4,800 me ric

ons by years end. Tere ore, even a 4,000-me ric- on cap in 2012 will necessarily lead o reduced shing or all ground sh s ocks.

Tis reduc ion will likely hi small-boa shermen especially hard. Smaller boa s, also known as dayboa s, are no equipped o make he mul iday rip ou

o Georges Bank, so hey mus rely on he s ocks closer o shore in he Gul o Maine. As hese res ric ions become igh er, inshore dayboa s will nd i harder omake ends mee .

Te cu is roubling enough or he sherys economic ou look in 2012 bu loomslarger in 2013 and beyond. Te Magnuson-S evens Ac only allows an emergency or in erim ac ion o remain in place or one year. I s designed as a pressure-relie valve ha allows shery managemen councils ime o reac and adap o suddensurprising revela ions. Now he council mus use he nex ew mon hs o developa new rebuilding plan or he s ock including a ca ch limi or 2013 ha will meescien is s recommenda ions or how o pu he sh on a rebuilding rajec ory ha will lead o sus ainabili y. Absen any legisla ive in erven ion rom Congress orunpreceden ed crea ivi y on he par o shery managers, he levels required oachieve he arge or 2013 and beyond may be so low ha hey will jeopardize he

viabili y o he en ire shing ee .

Te Na ional Oceanic and A mospheric Adminis ra ion released new numbersin March or Georges Bank cod and 10 o her s ocks in he ground shery. Whilenone o he new assessmen s is as horrible as he Gul o Maine cod ca as rophe,


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he new assessmen es ima es ha here is 46 percen less Georges Bank cod hanscien is s believed exis ed in 2008.25 While he council could reques ano herin erim or emergency ac ion on Georges Bank cod or 2013, such an ac ion wouldno make much di erence as shing will already be cons rained by he expec edlow levels o Gul o Maine cod.

Tis challenge o seting ca ch limi s based on science ha also mee shermenseconomic needs will have o be deal wi h going orward.

Effective oversight

Fishermen mus adhere o scien i c res ric ions i hey are o achieve heirin ended ou come o rebuilding deple ed sh popula ions. Ensuring shermen doso is one o he undamen al difcul ies o implemen ing he managemen sys em.

Tough he days-a -sea sys em was inefcien a precisely limi ing ca ch, i wasrela ively easy o police. Fishermen had o repor o he Na ional Marine FisheriesService when hey were going ou , and each boa was equipped wi h a vessel-mon-i oring sys em ha allowed he Coas Guard and NMFS o con rm he vesselsloca ion. In e ec , regula ors simply had o es ablish whe her he boa was shingor no and make sure i s ayed ou o closed areas. Ten when he boa landedi s ca ch, he regula ors could con rm ha i had no exceeded i s rip limi ( heamoun o a given species allowed o be caugh per day o shing) or any species

ha had one, and ha was ha .

Under sec ors, each sh caugh mus be coun ed no jus agains he overall ca chlimi or ha species bu agains each sec ors allo men as well. Te sys em alsorequires shermen o keep every legal-size sh hey ca ch. In he pas shermen would o en hrow back a por ion o heir ca ch ei her because hey already reached

heir rip limi or a par icular species or in some cases because hey wan ed o llheir hold wi h higher-value sh. Te requiremen s o sec ors mean more da a mus

be collec ed abou each rip and ed back in o he managemen sys em.

In shor his means shermens ac ivi ies on he wa er mus be more closely moni-ored or compliance wi h regula ions as well as or scien i c purposes. Tere are

ac ually wo di eren ca egories o a -sea moni ors in he ground shery shery observers who oversee opera ions and also collec da a or scien i c s ock assess-

The levels requir

to achieve the

target or 2013 a

beyond may be

so low that theywill jeopardize

the viability o t

entire shing e


31/56


men s, and a -sea moni ors who lack he scien i c raining o collec usable da aand ocus exclusively on regula ory compliance.

A -sea moni ors are used regularly in many sheries and hey have been par o heground shery in he pas as well. Bu under sec or managemen heir presence has

been increased. In 2012 shermen are required o have observers on 17 percen o sec or rips in addi ion o he 8 percen o rips carrying scien i c observers.

Scien i c observers are more expensive han moni ors, wi h cos s per day es i-ma ed a $1,487.22 or he ormer compared o $917.65 or he later.26 o da e,

he Na ional Oceanic and A mospheric Adminis ra ion has covered 100 perceno he cos s o observers or sec or shermen, bu he indus ry had o gh oensure ederal unding would con inue hrough 2012, he hird year o he pro-gram. Tere is no guaran ee such suppor will be or hcoming in u ure years.

Tese cos s represen a major obs acle o sec ors, and un il he conversa ion abouhe new s ock assessmen o Gul o Maine cod rose o prominence, moni oring

cos s were considered he single-bigges hurdle or he sys em. While cod hasascended o claim he dubious honor o he sherys primary hrea , he moni or-ing issue has no gone away and will remain a problem in search o a solu ion.

In addi ion o he added cos , bringing observers on board vessels can resul inpersonal difcul ies. Some shing boa s are as small as 40 ee or less, so when

hese vessels ake overnigh rips o shore, he presence o an ex ra person can bean inconvenience and even a sa e y hazard given he limi ed amoun o space bo habove and below deck. Even on larger boa s, personali y con ic sor worsecan arise. In February 2011 a Glouces er sherman was indic ed on chargeshe assaul ed and sexually harassed a emale observer a sea.27 Such cases haveoccurred in o her regions o he coun ry as well.

One way o reduce he need or human a -sea observers and moni ors is by devel-oping elec ronic or video moni oring echniques. Such a sys em involves ins allingcameras on vessels ha record wha happens on deck when shermen are work-ing. Cameras documen wha shermen discard, wha goes in o he hold, and

essen ially ake he place o human observers.

In such a sys em he moni ors job would migra e rom he boa o shore. Ins eado going o sea, he or she would si in a room and wa ch a randomly selec edsample o he video recorded on a given rip. I he video shows any anomalies or


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sugges s viola ions, he vessel owner would hen be responsible or paying or harips en ire video record o be reviewed. Such sys ems are being developed or use

in numerous o her sheries including he Paci c ground shery, and halibu andpollock sheries in Alaska, and have been success ully implemen ed in mul iple

sheries in Canada and in erna ionally.28

Te complexi ies o he mul ispecies ground shery will make developmen o a success ul elec ronic moni oring sys em difcul , bu he Nor heas FisheriesScience Cen er is already conduc ing a pilo s udy.29 Expec a ions are mixed:Many par icipa ing shermen are exci ed abou he possibili ies bu some scien-

is s in charge o he projec seem skep ical.

As reluc an as shermen may be o welcome he unblinking eyes o video camerasaboard heir vessels, he majori y will nd i pre erable o hos ing ano her body, par-

icularly on smaller vessels where every square inch o space is a a premium. Given

he already complex rela ionships among shermen, regula ors, scien is s, and o hershery s akeholders; complain s rom cap ains abou observers showing up la e, ge -ing seasick, and o herwise a ec ing heir opera ions; and coun er-complain s rom

observers abou heir rea men a he hands o some shermen, replacing humanobservers wi h cameras could easily be a winning ormula.


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The groundfisherys damagedrelationships

Te rela ionships among shery regula ors, scien is s, indus ry members, andenvironmen al groups are more con en ious in New England han in any o herregion o he coun ry. Fu ure success in he ground shery mus s ar wi himproved rela ionships among hese groups. Any managemen s ruc ure will acean uphill batle wi hou he buy-in and coopera ion o all s akeholders.

NOAA Adminis ra or Jane Lubchenco admited in a dialogue wi h Sen. Olympia

Snowe ( -ME) during her con rma ion hearing in 2009 ha he rela ionships were seriously dys unc ional. Lubchenco and Sen. Snowe agreed ha i was ime

o crea e a new clima e o rus in he region.

Fishermen, par icularly in Massachusets, have been ed a complex cock ail o vi riol by elemen s wi hin he local media ha con inually play up Lubchencos ies o envi-ronmen al nongovernmen al organiza ions. Tey men ion a every oppor uni y herprevious posi ion on he board o he Environmen al De ense Fund, an organiza ion

ha advoca es aggressively or implemen a ion o ca ch share managemen .

Un il some much-needed perspec ive is brough o bear and such groundlessconspiracy heories are discredi ed and abandoned, here will be an undercurreno mis rus in he indus ry ha does a disservice o everyone involved.

Every one o he groups involved has abeted he de eriora ion o hese rela-ionships, which in urn has led o he lack o rus among s akeholders in he

region. Te ollowing are broad generaliza ions o he roles each group hasplayed in he process. Tere are ample grey areas wi hin each ca egory bu hereis an overall percep ion o he si ua ion showing how each group has con rib-

u ed o he absence o rus in his shery.


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Fishermen

For ar oo long, shermen, including heir represen a ives on he council, resis edhe clear need o make hard decisions by reducing ca ch limi s when he science

showed ha s ocks were declining. Tey accused scien is s o ailing o collec

decen da a and sugges ed ha wha hey were seeing on he wa er didn agree wi h he increasingly dire s ock assessmen s.

Ins ead o s riving o unders and peer-reviewed science and heeding he warningsha heir ac ions would only dig hem in o a deeper hole and reduce u ure ca ches,shermen o en op ed o pu ai h in he rosies possible scien i c predic ions. Te

New England shery managemen council ypically se ca ch res ric ions a or evenabove he mos lenien levels wi hin he range o he scien i c es ima es even in he

ace o warnings ha he probabili y o such parame ers resul ing in s ock rebuild-ing was ex remely low. Tey would hen hope ha he nex s ock assessmen would

show a brigh er u ure. When his process ailed, hey blamed scien is s or shoddy work and managers or imposing excessively harsh regula ions.

Regulators

egula ors, o en cons rained by he angled red ape o bureaucracy, ailed oadequa ely explain heir mo ives and me hods in a manner he shing indus ry could unders and, oo o en leaving he impression heir ac ions were driven no by requiremen s bu by he environmen al communi y or heir own alleged preju-dice agains he shing indus ry.

In he early 1990s i was becoming clear ha rampan over shing had decima edhe Gul o Maine and Georges Bank sh s ocks. Bu he New England shery

managemen council ailed o gh o poli ical pressure and impose s ric , scien-i cally de ensible policies ha migh have correc ed he downward rend in sh

popula ions. When he Na ional Oceanic and A mospheric Adminis ra ion riedo in ervene, i ran up agains a brick wall o poli ical opposi ion rom elec ed

ofcials. While hese cu s would have imposed hardship, i is possible hey migh

have helped avoid some o he u ure difcul ies s ill being visi ed on he indus ry as i ries o resurrec i sel rom decades o over shing.

Te Na ional Oceanic and A mospheric Adminis ra ion has also ailed o developa communica ions ne work capable o adequa ely explaining he ra ionale behind


35/56


i s requen ly unpopular decisions while lis ening o and allevia ing he legi ima econcerns o he indus ry.

In he mos recen example o he agencys one-dea ness, in 2010 he Depar meno Commerces inspec or general ound widespread mismanagemen in he

Na ional Oceanic and A mospheric Adminis ra ions sheries law en orcemenarm. In a series o inves iga ions, he inspec or general discovered nes paid by shermen ha had been used o purchase vehicles or use by en orcemen agen s,

collusion be ween prosecu ors and judges on sheries en orcemen cases, andexcessive nes and en orcemen levied agains New England shermen.30

Bu ha wasn all. While he inves iga ion was ongoing, he head o he Na ionalOceanic and A mospheric Adminis ra ions Ofce or Law En orcemen hired adocumen -shredding company o des roy les. Despi e hese egregious ac ions, undercurren law governing ederal personnel managemen , he Na ional Oceanic and

A mospheric Adminis ra ion could no nd grounds o re he employee. Ins ead, heand his six- gure salary were rans erred o ano her depar men , enraging shermen who righ ully wondered how hey would have been rea ed i he ables were urned.

Tis cul ure o closed-mindedness and ailure o communica ions runs deep inhe region and mus be changed i rela ionships wi h indus ry members are o

be improved.

Politicians

Poli icians, driven by howls o pro es rom heir commercial shing cons i u-en s who aced he hrea o los revenue, jobs, and ul ima ely an en ire indus ry, backed ques ionable managemen solu ions.

Teir e or s included pursuing wo separa e ederally unded buyou s o permi sand vessels in ended o give shermen who wan ed o ge ou o he indus ry ameans o do so while s ill geting some value or heir vessels and permi s.

Un or una ely, he programs were poorly designed and resul ed largely in he pur-chase o permi s rom shermen who weren shing anyway. Many who allowed

heir vessels o be bough ou o he ground shery jus rans erred heir e orin o o her sheries, crea ing excess capaci y in hose sheries ins ead.


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In he bes cases poli icians sough a legi ima e balance be ween oday and omor-row, and in he wors cases hey wen o he ma o pro ec odays shing a heexpense o omorrows.

Tis ati ude carried over in o he early years o sec or managemen . Various

pieces o ill-advised legisla ion were in roduced ha would ei her override sher-ies science or orce he abandonmen o he sec or managemen sys em wi houproviding a viable al erna ive.

ecen ly he Massachusets congressional delega ion priori ized a declara ion o ashery managemen disas er in heir s a e a er Gov. Deval Pa rick pe i ioned he

secre ary o commerce or such a dis inc ion given wha he describes as severeeconomic hardship due o he implemen a ion o he ca ch shares program.31

Gov. Pa rick reques ed $21 million in aid or his s a e despi e he value o ground-

sh landings in Massachusets increasing rom $72.3 million in 2009 o $73.3 mil-lion in 2010.32 Gran ed, his increase does no re ec an increase in opera ing cos s

ha shermen ci e under sec ors, nor is his value evenly dis ribu ed. Bu i isdifcul o perceive an increase in revenue as a sheries disas er by any de ni ion.

Environmental groups

As shermen used heir clou on he council o main ain lenien ca ch res ric-ions, environmen al groups became caus ic in heir e or o orce he indus ry o acknowledge he reali y o sh s ock decline. Facing he lack o accep ance o

scien i c advice, hey ramped up heir rhe oric and heir ac ics.

Ul ima ely he groups el hey had no o her op ion bu o le lawsui s, several o which were success ul a orcing regula ors o implemen s ronger ca ch res ric-

ions han he New England shery managemen council had approved. Someindus ry members saw his as an e or o shu down heir shery and pu hem o

he wa er. Tey accused environmen al groups o valuing sh over people.

Te environmen al communi ys involvemen in he shery has also led o somespec acularly inven ive conspiracy heories. One o he mos ar- e ched belie s is

ha he Pew Environmen Group he conserva ion arm o he Pew Chari ablerus s and unded originally by he ounder o Sunoco Oilis only in eres ed in

pushing i s conserva ion agenda in he Nor heas o orce shermen o he wa er,

As shermen

used their clout

on the council to

maintain lenient

catch restrictions

environmental

groups became

caustic in their

efort to orce

the industry to

acknowledge the

reality o sh sto

decline.


37/56


hereby elimina ing poli ical pressure keeping Georges Bank and o her areas in heGul o Maine o -limi s o oil drilling.

oday, some environmen al groups have become public enemy number wo(behind he Na ional Oceanic and A mospheric Adminis ra ion) on many o New

Englands shing piers or heir dogged pursui o ca ch shares as an equi able,sus ainable shery managemen me hod.

Scientists

Scien is s mus ga her and process incomple e da a, spend mon hs i no years run-ning i hrough models ha canno possibly accoun or all he variables o a mul i-species ecosys em, produce es ima es ha hen mus be peer reviewed or accuracy,and come ou wi h a recommenda ion or a o al allowable ca ch ha includes a

sufcien bu er o accoun or he uncer ain y o he resul o heir e or .

All his means ha by he ime shermen are ac ually opera ing under he ca ch limi sscien is s have produced, he da a used o es ima e popula ion levels is a leas wo o

hree years old. In e ec , shermen are ca ching odays sh under yes erdays rules.

Along he way, scien is s a he Nor heas Fisheries Science Cen er also madea ew high-pro le mis akes, including one inciden ha came o be known as

rawlga e. In order o provide da a or heir s ock assessmen s, scien is s par ici-pa e in research cruises where hey rawl wi h commercial shing gear and coun wha hey cap ure. Bu in he win er o 2000, a sherman no iced ha heir gear was se improperly, and in e ec , scien is s were shing wi h a ne ha was hal -closed and hus no ca ching a ruly represen a ive sample o sh. When he news broke, he scien is s credibili y ook a remendous hi .

As poin ed ou earlier, even in he bes cases, sheries science doesn always lineup wi h reali y simply because i s inheren ly inexac . In 2010, or example, a errevisi ing he da a used o se he ca ch limi on pollock, scien is s revised heirs ock assessmen and were able o increase he o al allowable ca ch o pollock

by nearly 600 percen . Tough his change bene ed shermen, i did litle oenhance heir con dence in he scien is s work.

By con ras , in November 2011 he Nor heas Fisheries Science Cen ers new assessmen o Gul o Maine cod e ec ively reversed he ndings o i s 2008 s ock


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assessmen ha showed he s ock o be on rack o mee i s 2014 10-year rebuild-ing deadline. Ins ead he 2011 work ound ha no only was he s ock in ar worseshape han previously hough , bu even i all shing was hal ed, he sh would no be able o rebuild wi hin he required ime period.

Ul ima ely, he science cen er has been unable o adequa ely explain he concep s o uncer ain y hey mus incorpora e in order o develop scien i cally accep able resul s.

Congress has inves iga ed concerns abou he validi y o he work a he Nor heasFisheries Science Cen er mul iple imes over he pas decade, including com-missioning eigh reviews be ween 1999 and 2009 by he Na ional Academy o Sciences, he Governmen Accoun abili y Ofce, and he Na ional Academy o Public Adminis ra ion.

Te mos recen o hese was a 2009 inves iga ion by he Depar men o

Commerce inspec or general, and he upsho o he repor is ha while heNor heas Fisheries Science Cen er opera es wi h less- han-ideal da a, i generally does he bes i can wi h wha i has o work wi h. In o her words i does precisely wha he law requires hem o do.

Te problem is ha sh are hard o coun , and as a resul , sheries science in gen-eral jus isn very good. According o he inspec or generals repor , one seniorNMFS ofcial s a ed ha bes available science as required by he [MSA] doesno necessarily mean good science.33

The Touchstone report

Mos recen ly, he Na ional Marine Fisheries Service and he science cen er werehe subjec s o an independen analysis commissioned by he Na ional Marine

Fisheries Service and published in April 2011 by he SR- ouchs one Consul ingGroup. Te repor , A eview o he New England Fishery Managemen Process,compiled in erviews wi h 179 shery s akeholders in o a s ark assessmen o heproblems acing he ground sherys managemen s ruc ure.

Te repor ocused on he hree ederal componen s o he shery: he Na ionalMarine Fisheries Services Nor heas regional ofce, he New England shery managemen council, and he Nor heas Fisheries Science Cen er. I broke downspeci c posi ives and challenges or hese ins i u ions and ound ha each organi-


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za ion had pocke s o s a who were very help ul or high-per orming bu ineach case he challenges or nega ives vas ly ou numbered he posi ives.34

Many o ouchs ones recommenda ions come down o communica ion, ranspar-ency, and accoun abili y, all o which are undamen al o developing an apprecia ion

or where he o her side s ands on a given issue. Some key ndings rom he reporclearly poin o his se o problems and make i clear ha every group involved musshare he blame or he evolu ion o he curren s a e o dys unc ion:

Lack of stability in the regulatory structure is a problem. Te repor s au horss a e: Fishermen also expressed rus ra ion abou he lack o s abili y in hesys em. we cannot create a business plan when everything is always changing (emphasis in original). Ye he repor also asser s, poli ical in erven ion over

ime has con ribu ed o unpredic abili y and rapid changes o he decisions.In o her words, shermen see an ever-changing sys em as a problem, bu hen

hey rely on heir poli ical allies o drive addi ional adap a ions.

Lawsuits are not helping. Te repor explains, Lawsui s have also becomean e ec ive ool used by bo h indus ry and environmen al nongovernmen alorganiza ions (NGOs) agains he Na ional Marine Fisheries Service. As aresul , NMFS has become more rigid and s ric in i s in erpre a ions o he law and policy. When poli ical in erven ion ails, or moves oo slowly, he nex levelo recourse becomes he cour sys em. Te agency, leery o he increasing hreao legal recourse, hen eels he need o ensure every is crossed and every i doted. Tis akes ime and crea es a posi ive eedback loopdelays lead omore complain s, more lawsui s, and more delays.

Fishermen dont feel heard by regulators. Tis s a emen cap ures he si u-a ion in a nu shell: Across he board, indus ry eels NMFS does no seek ohelp hem. over ime his ension has grown o levels ha bo h NMFS andindus ry eel are unproduc ive.

Te repor de ails numerous sugges ions or improving he si ua ion.Communica ions, da a-sharing, and ransparency are lis ed as key o improv-

ing rela ionships. A his poin , he s akeholders in he region no longer rus wha regula ors and scien is s ell hem abou why cer ain decisions have o bemade. Tey mus be shown he me hodology in a orma ha doesn require anadvanced degree o comprehend.


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O course, communica ion is a wo-way s ree . Jus as he agency and sciencecen er mus do a beter job puting in orma ion in o he hands o he indus ry, heindus ry mus be willing o commi o receiving he in orma ion and accep ha

heir regula ors aren delibera ely rying o pu shermen ou o business.

No able among he ouchs one repor s recommenda ions was an impliciacknowledgemen o one o shermens undamen al argumen s: h

the future of america’s first fishery

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