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CHOIR Coalition Herring "Sign on" Letter
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Received 05/20/08 |
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I received the below from
Chris Weiner of CHOIR this morning. All you have to do
is email Chris (click on his name above) that you want you, your business or group's name
included at the bottom of the letter.
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May 20, 2008
Patricia Kurkul, Regional Administrator
National Marine Fisheries Service
One Blackburn Drive
Gloucester, MA 01930
RE: Herring Amendment 4 Scoping Comments
Dear Ms. Kurkul,
I am writing to you today on behalf of the undersigned CHOIR
Coalition supporters to provide scoping comments on
Amendment 4 to the Herring FMP (“amendment”). CHOIR is an
industry coalition made up of commercial and recreational
fishing organizations, fishing and shore side businesses,
and eco-tourism companies. CHOIR is recognized as a
stakeholder in the herring fishery and is a leading voice
for the responsible management of the herring resource.
First and foremost, this amendment must be used to create
and implement an effective government and/or third-party
monitoring system for 100% of the catch in the herring
fishery. Furthermore, catch must be clearly defined to
include the entire contents of the net. The current system
is entirely inadequate: observer coverage is far too low and
erratic; there is not enough shore-side monitoring; landings
data is neither accurate nor timely; there is too much
reliance on unverified industry reporting; and loopholes in
the regulations allow for partial or whole codends to be
dumped at sea without being sampled, even on observed trips
(slippage).
To address these and other problems, the amendment should
ensure that there is 100% catch monitoring. Everything in
the net when it is brought to the boat must be accounted for
and sampled, whether it is retained or not. There are
multiple methods that could allow for this level of
monitoring, including the use of more observers, electronic
monitoring, a combination of both, or other tools. While
maximized retention would be ideal, if catch is dumped at
sea, it must be sampled before it is dumped. Finally, the
amendment should put in place a landings system that
provides for certified offloads and actual weights, with the
data reported in real time (or as close to real time as
possible). There are multiple funding solutions for these
changes, including quota set-asides, application of Magnuson
Stevens Reauthorization Act herring research funds, industry
funding, and increased NMFS funding.
Second, this amendment should be used to further promote the
offshore herring fishery and to protect inshore herring
stocks and the predators and people that interact with and
rely on them. This could be done by using inshore time and
area closures (including gear restricted areas), by
prohibiting midwater trawling in Groundfish Closed Areas
(including rolling closures), and by creating new measures
to pace out the fishery so as to avoid temporal and spatial
forage depletion. You should also use these tools to address
the longstanding gear conflicts between inshore fishermen
and the herring fleet. For too long we have watched as the
inshore areas (and those who rely on them) have been
devastated by parts of this fleet and it is time for this
problem to be fully addressed.
Finally, we strongly urge that the Council does not attempt
to use this amendment for allocation purposes. Until you
install an accurate monitoring system you will not have the
data needed to go forward with allocation; at this time, any
allocation would likely be both difficult and wrong as it
would be based on faulty data. The impact this would have on
fishing communities would be negative, both because it would
possibly drive out many of the owner/operators in the
fishery, while also serving to disrupt the price and supply
of bait for the lobster industry. Attempting to do
allocation in this amendment will also slow the process down
and further delay the important monitoring and conservation
needs that need to be addressed as soon as possible.
We urge the Council to use this amendment to fix the many
problems within the herring fishery.. The herring resource
is far too important for it to be managed with a system as
inadequate as the one in place today. Time and time again
this system has shown its glaring weaknesses and the time
has come to fix it, once and for all. This amendment should
also promote the offshore herring fishery we all expected by
addressing the longstanding concerns regarding inshore
depletion of herring stocks, bycatch, and gear conflict. And
lastly, this amendment should exclude allocation by delaying
it to a future vehicle. This region relies on herring and
there is no excuse for further delaying these important
changes.
Thanks for your time,
Steve Weiner, Chair
On behalf of the undersigned groups, businesses and others:
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