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June 4, 2004
Admiral James D. Watkins, Chairman
U.S. Commission on Ocean Policy
RE: Comments on Final U.S. Commission on Ocean Policy Preliminary Report
Dear Admiral Watkins:
The Massachusetts Fishermen's Partnership (MFP) respectfully submits the
following comments on the preliminary report by the US Commission on Ocean
Policy.
The MFP is an umbrella organization of 17 commercial fishing associations
representing all gear and geographic sectors of the Massachusetts fishing
industry. The organization was created to promote the common interests and
economic viability of commercial fishermen and fishing families. The MFP is
sponsor of the Fishing Partnership Health Plan, which provides comprehensive
healthcare coverage for almost 2000 members in the fishing community. The
MFP’s Collaborative Research Program establishes research partnerships among
fishermen and scientists to promote improved knowledge and understanding
through research in a variety of disciplines.
The MFP applauds the Commission’s focus on an ecosystem approach and the
research required to develop this policy shift. The MFP strongly endorses the
Commission’s recommendations to double federal investment in oceans research,
including funding the establishment of an Integrated Ocean Observing System.
The MFP especially urges the Commission to further elaborate how to improve
oceans and fisheries science through collaborative research as an essential
first step towards achieving sensible reform in fisheries management.
The MFP promotes the following positions:
- Suspend all offshore renewable energy projects in the pipeline until a
regulatory framework is in place;
- Protect traditional water-dependent permissible uses that serve the
public interest;
- Establish a permitting process for offshore development that fairly
considers the economic and environmental costs and benefits of a proposed
project;
- Enact National Standards to govern management approaches utilizing
dedicated access privileges that check consolidation, protect communities,
require that the support sustainable fisheries, and require approval by a
super majority before they can be implemented;
- Establish an independent process to ensure that all National Standards
are rigorously enforced in all regulations;
- Establish criteria for "best scientific information available" that is
linked with independent peer review and especially the participation of
fishermen;
- Fund collaborative research to adequate levels and ensure that
fishermen are involved in the research process;
- Definitions describing conditions of fish stocks must clearly separate
stocks that are declining due to causes other than fishing;
- By-catch and discarded fish are not the same and should not be treated
as the same;
- Adequate observer coverage for higher confidence in assessments must be
provided;
- Fishery regulations should minimize adverse social and economic impacts
to fishing communities by including input from community-based social
science while protecting the ongoing sustainability of fish stocks;
- Support a pilot program for one fishery ecosystem plan from each region
provided the effort is adequately funded, based on a scientific framework
that has been developed involving fishermen through collaborative research,
and a reasonable amount of time is allowed for effective plans to be
created;
- Disadvantages to US fishermen in relation to foreign imports as a
result of conservation and management should be minimized;
- Members of fishery management councils should be more accountable to
fishermen and people in the fishing communities.
It is critical that a comprehensive ecosystem-based approach is developed
that builds a sound scientific foundation with the continuous involvement of
fishermen to bridge the current lack of consensus on marine environmental
well-being. In addition, appropriate ocean uses must be delineated in a
rational manner that considers the human component of biodiversity as an
essential factor in its management.
The MFP is well positioned within the commercial fishing industry to serve
as a liaison and is willing to assist as the Commission moves forward. It is
our sincere hope that ecosystem-based collaborative research will be one of
the primary tools used to help succor the ocean and its potential to sustain
a variety of permissible uses.
Sincerely,
MASSACHUSETTS FISHERMEN’S PARTNERSHIP
David Bergeron , Executive Director
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