June 8, 1999
Senator Edward M. Kennedy
315 Russell Senate Office Building
Washington, DC 20510
Dear Senator Kennedy:
The Massachusetts Fishermen's Partnership (MFP) requests an emergency
meeting with your staff and the fisheries staff of the Massachusetts
congressional delegation to review our analysis of National Marine Fisheries
Service (NMFS) information.
As you know NMFS has lowered the daily trip limit for cod in the Gulf of
Maine to 30 lbs. per day. The New England Fishery Management Council (NEFMC)
has formally requested an Emergency Action by the Secretary to increase the
trip limit to 700 lbs. per day with adjustments to running clock provisions.
This Emergency Action is needed immediately to stop the wanton slaughter of
codfish through discards. Unexpected abundance of cod has created this
emergency where this excessively low daily allowance makes it impossible to
fish for other species in the Gulf of Maine without catching substantial
amounts of codfish as a by-catch that must now be discarded at alarming
rates. If this Emergency Action is not implemented immediately, the cod stock
will collapse.
NMFS own 1999 spring survey data shows improvement for Gulf of Maine cod,
and the state of Massachusetts Division of Marine Fisheries 1999 survey also
indicates increasing abundance of young codfish. Fishermen unanimously
testified at the NEFMC May 26, 1999 meeting in Plymouth to increasing catches
of cod in areas where cod have not been found in past years and with less
fishing effort even when this effort is directed on to other species. These
consistent reports from fishermen and scientists support the NEFMC request
for Emergency Action. Furthermore, we are requesting a meeting with the
delegation as soon as possible to review the alarming results of our analysis
of NMFS data.
The MFP has found that contrary to Sustainable Fisheries Act (SFA)
requirements that fish stocks be rebuilt within 10 years, the rebuilding
schedule for Gulf of Maine cod is less than 5 years. This rapid rebuilding
schedule is being justified by an arbitrary control law created by the
Department of Commerce that is not mandated by Congress but which violates
SFA requirements that stock rebuilding must protect the participation of
fishing communities as long as such rebuilding is accomplished within 10
years. Our finding indicates this SFA provision is not being applied and
Total Allowable Catch (TAC) targets for Gulf of Maine cod are set at levels
that are more conservative than what the SFA permits. The 4 to 5 year
rebuilding schedule being implemented to rebuild codfish is having an
unnecessary and devastating impact on the fishing communities of the Gulf of
Maine.
Therefore, NEFMC's request for secretarial Emergency Action to increase
the daily trip limit for cod in the Gulf of Maine is justified by the present
facts as well as by the precautionary approach of rebuilding the stock within
10 years as mandated by Congress. We must demand that TAC targets for cod
rebuilding in the Gulf of Maine be immediately adjusted upward to provide for
a 10 year rebuilding schedule and that the daily trip limit be recalculated
using the adjusted TAC.
Secondly, NMFS has cautioned that codfish catch rates have increased in the
Gulf of Maine because the stock is aggregating into smaller areas than has
been the case historically. If this were to be true, than comparison of maps
of where the NMFS trawl surveys have found cod through the years would
support this conclusion.
The MFP has mapped the NMFS 1999 spring survey data for cod and compared
it to NMFS maps of the distribution of codfish in previous years. NMFS data
does not support the claim that cod are aggregating into smaller areas where
fishermen are catching the last of the remaining cod. In fact, the map of
NMFS data of the distribution of where codfish were found in 1999 is very
similar to distribution of where NMFS data showed codfish were found from
1979 to 1984. The claim that cod are concentrating into a smaller area is
simply not supported by NMFS own data.
All together, the MFP insists that the Secretary of Commerce immediately
implement the Emergency Action that was requested by the NEFMC to increase
the daily cod trip limit for Gulf of Maine cod to 700 lbs. per day.
Thank you.
Sincerely,
MASSACHUSETTS FISHERMEN'S PARTNERSHIP
David Bergeron, Coordinator
cc: Senator John Kerry
Representative William Delahunt
Representative Barney Frank
Representative John Tierney
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