“Thomas A. Nies, Executive Director
New England Fishery Management Council
50 Water Street, Mill 2
Newburyport, MA 01950
RE: DEIS for Amendment 23 to the Northeast Multispecies FMP – Joint Comments from the Cities of Gloucester and New Bedford, Massachusetts
Dear Mr. Nies,
We are writing to express our shared opposition to the measures being considered under Amendment 23 to the Northeast Multispecies Fishery Management Plan, and accompanying Draft Environmental Impact Statement (DEIS).
The Council’s preferred option of 100% At Sea Monitoring (ASM) target for groundfish sectors is excessive. Pursuing such regulatory action is completely misplaced when considering the social and economic impacts our communities are actively facing with the COVID-19 pandemic.
We strongly urge the Council to take a more mindful and realistic approach when considering monitoring requirements in the groundfish sector fishery. Such approaches should consider cost-effective monitoring programs that offer true benefits to those businesses required to cover the expenses. These approaches should be based on sound – quantitative analyses.
The Council should be following guidance as set forth in federal statutes such as National Standard 8:
§600.345 National Standard 8—Communities.
a. Standard 8. Conservation and management measures shall, consistent with the conservation requirements of the Magnuson-Stevens Act (including the prevention of overfishing and rebuilding of overfished stocks), take into account the importance of fishery resources to fishing communities by utilizing economic and social data that are based upon the best scientific information available in order to:
1. Provide for the sustained participation of such communities; and
2. To the extent practicable, minimize adverse economic impacts on such communities.
The Council should be focusing on regulatory actions that work to strengthen and enhance fishing operations and promote seafood security.
Notwithstanding the continued competitiveness of the Port’s scallop fleet, the makeup of the groundfish fleet is but a fraction of what it has historically been in the port of New Bedford. The port of New Bedford had 90 groundfish vessels in 2010 and by 2018 only 28 remained a loss of 70%. Currently New Bedford only has a few groundfish sectors whose members are landing ground fish in New Bedford. The list includes Sustainable Harvest Sector, Northeast Fishery Sectors 7, 8 and 13. Some of these sectors are represented by membership organizations, Northeast Seafood Coalition and the Associated Fisheries of Maine who have shared their serious concerns with the Amendment 23 measures and DEIS analyses.
The annual catch limit (ACL) reductions have made groundfish fishing less profitable. ACL reductions on stocks that were once key to New Bedford namely George’s Bank yellowtail, have led to loss markets and fishermen have either left the fishery, shifted fishing effort to George’s Bank haddock (underutilized) or moved on to other fisheries. In 2010 the port of New Bedford had $32 million of groundfish landings revenue compared to groundfish landings revenue of $10.4 in 2018 a loss of $22 million.
The proposed action would devastate the groundfish businesses that remain, as they will be unable to absorb the cost of monitoring against the backdrop of depressed prices and operating margins the industry has experienced. The groundfish sector monitoring costs range between $650.00 to $700.00 per person per day which translates to several thousand dollars per trip. Again, at a time when the unemployment rate is so high and our communities are facing the social and economic devastation from COVID- 19 pandemic, imposition of additional costs is inadvisable.
Similarly, the City of Gloucester has lost nearly two-thirds of the active groundfish fleet since the inception of sectors in 2010. The remaining vessels, operating predominately under NEFS II, simply do not have the ability to absorb the additional expenses of monitoring. Almost all of the vessels in NEFS II would go out of business if they had to pay this cost out of pocket. NEFS II would no longer be economically viable.
The DEIS is incorrect in asserting that electronic monitoring (EM) is a viable alternative to offset costs of human ASM. The devil is in the details on the EM programs. For a groundfish sector such as NEFS II, whose membership make the majority of their fishing revenue from groundfish fishing, the DEIS fails to provide critical details to rationally map out the viability of EM as a tool and the true costs that could be incurred if adopting EM to replace the human ASM program. The audit EM program is not a viable option for the vast majority of the membership of NEFS II. The members who have been using this program have identified numerous issues, such as fish handling and the loss of the opportunity to pursue fishing. Max retention EM may be an option in the future but it is in its infancy. DEIS should not have proposed EM as a viable mechanism to offset expected monitoring costs in the DEIS until it was fully developed, analyzed and approved by the Agency.
Based upon the Council’s Amendment 23 public hearing presentation, Gloucester has the highest concentration of active groundfish vessels (34) and revenues from groundfish trips ($1.6 million) throughout the region. This action is poised to disproportionately impact Gloucester’s fishing community.
The Cities of Gloucester and New Bedford cannot support the Council taking action on Amendment 23 at this time. We believe the proposed changes will adversely affect ground fishermen at a time when our fleet is facing uncertainty due to the pandemic.
If you have any questions or require any additional information please let us know.
Sincerely,
Mayor Sefatia Romeo Theken
City of Gloucester
Mayor Jon Mitchell
City of New Bedford
