Dear Patricia A. Kurkul:
I write to urge the National Marine Fisheries Service to proceed without delay and adopt strong conservation measures as part of Amendment 13 to the Northeast Multispecies Fisheries Management Plan. It is critical that Amendment 13 incorporate the fundamental reforms necessary to stop overfishing and rebuild depleted groundfish populations in a time and manner consistent with federal legal requirements.
Specifically, Amendment 13 should incorporate provisions that:
(1) End Overfishing. Overfishing continues to be a chronic and significant problem in the New England groundfish fishery. The proposed rebuilding plan has not been adequately evaluated to ensure its effectiveness and may lead to even more overfishing.
(2) Provide enforceable, stock-specific catch limits (hard TACs.). The recommended plan lacks mandatory annual catch limits for most groundfish. Without mechanisms to stop fishing once the sustainable target catch limits are met, there is no way to prevent overfishing and ensure that the mortality targets will not be exceeded.
(3) Adopt enforceable bycatch limits. Amendment 13 does not, but should include adequate at-sea observer coverage on fishing vessels to monitor catch and bycatch and incorporate other measures to significantly reduce the wasteful bycatch of non-target species.
(4) Update fishery infrastructure and information systems. Amendment 13 should update existing fishery information systems to support real-time monitoring and implementation of management and conservation reforms. Amendment 13 should require electronic vessel monitoring systems and mandatory daily electronic dealer reporting.
(5) Timely and effective implementation. Amendment 13 should adopt a precautionary approach that sets rebuilding schedules and targets on a species-by-species basis to rebuild stocks as quickly as possible, using the best available science.
(6) Protect sensitive cod nursery grounds from destructive fishing practices. Amendment 13 fails to protect sensitive cod nursery grounds from bottom trawling and scallop dredging. Such measures are crucial to keep these essential breeding grounds intact and to improve the historically low survival rates of juvenile cod that scientists are presently observing.
I believe that Amendment 13 affords an unprecedented opportunity to reform fisheries management in New England and ensure a sustainable future for the fishery. This opportunity, however, will be wasted unless the government ensures that Amendment 13 contains the measures necessary to ensure that fishing proceeds in a sustainable manner. By moving forward with a version of Amendment 13 that contains the kinds of measures identified in this letter, we will be one step closer to preserving the ecological, economic and cultural integrity of New Englands groundfish legacy.
Thank you for your attention to this comment letter.