Thanks to an email I received from Robert Klavins at Environment Massachusetts, I wanted to post the text of the letter a coalition of religious leaders, scientists, divers, fishermen, and many more, sent to the Director of the National Marine Fisheries Service... Re: Comments on Proposed National Standard 1 Regulations and Guidance
Dear Dr. Hogarth:
Our organizations represent over nine million Americans who are concerned about the health of our ocean, its fish, marine mammals like whales, dolphins and porpoises, and sea turtles. We are scientists, religious leaders and congregations, scuba divers, business leaders, recreational fishermen, fishing related businesses, environmental organizations, students, ecotourism providers, beach goers, and tourism organizations, united in our concern for healthy oceans and fish populations. We were pleased at the passage of the Magnuson-Stevens Fishery Conservation and Management Act of 2006 (MSA) because it gave us hope that the National Marine Fisheries Service (NMFS) and the Regional Fishery Management Councils would manage the public’s fishery resources in much better ways.
It is now incumbent on all of us --citizens, fishermen, scientists, and business people-- who want healthier oceans and fish to put that good law to work on the water, in fishing boats and at regional fishery management council meetings. First, we are pleased by the conservation oriented tone of your public statements and those of others in the Bush administration about the issue of ending overfishing. This indicates a true appreciation of the tough problems that our fisheries face today and a willingness to challenge ‘business as usual’ in the management of fisheries.
We believe that National Standard 1 guidance should make the following changes in the way that your agency and regional councils conduct business. Specifically:
· The independent science committees on each council should set science based annual catch limits that incorporate a precautionary approach or buffers to keep actual catch below the level of overfishing with a high percentage of certainty. NMFS and the regional councils cannot continue the practice of managing up to the edge of what’s theoretically sustainable without breaking the law that bans overfishing. There is too much uncertainty in the ocean about how many fish are really out there and how well they are reproducing and growing to allow for that approach.
· Fishery managers should create clear, equitable, and consistent accountability measures that keep fish stocks out of trouble if annual catch limits are exceeded. Penalties or compensatory action for going over the annual catch limit should be done immediately (ie., in season’) or no later than the next year. Accurate, timely reporting and aggregation of total catch from all sectors (commercial, charter, and recreational) is a key building block of any successful accountability system. To that end, data from each fishery should be collected as soon as possible after landing the fish. This will mean less overshooting and undershooting of annual catch limits.
· You must preserve full environmental reviews and opportunity for public comments on fishery management plans. Preparing environmental reviews and fishery plans can and should be done in a smooth, useful, coordinated fashion.
In sum, we are very pleased with the proposals that NMFS has considered so far in revising the NS1. We hope to see as many of these good ideas embedded in the final regulations and guidance as possible. We have a unique opportunity to make a quantum advance in the way we manage our fisheries. As you know, that opportunity only comes along once every decade. Let’s make that quantum advance and guarantee healthier oceans for all.
Thank you,
Religious Organizations
Rev. Roger Burkhart, Reverand
Spirituality and Earth Stewardship Committee of the New Hampshire Conference of the United Church of Christ
Gareth Evans, Rector
St. John's Episcopalian Church, Charlestown, MA
Stephen T. Ayres, Vicar
Old North Episcopalian Church
Boston, MA
Environment Group of the Unitarian Universalist Church of Medford
Medford, MA
Jenny Fleming –Ives
Environmental Task Force of the Hampshire Interfaith Council
Northampton, MA
Religious Leaders (as individuals)
Pastor Sarah J. Anderson, Pastor
Christ the King Lutheran Church, Springfield, MA
Rev. Stephen Cook, Reverand
Unitarian Society of Northampton & Florence
Ellen Bernstein, Founder
Hebrew College
Rev. Georganne Greene, Reverand
Unitarian Universalist Society of Greater Springfield, Springfield, MA
Recreational Groups
David Prescott, Chairman
Surfrider Foundation, Rhode Island Chapter
Andrew Krupa, Chairman
Surfrider Foundation, Connecticut Chaper
Jenny Miller Garmendia, Director
Project AWARE Foundation
Heather L. Knowles, Captain
North Atlantic Dive Expeditions, Inc., Beverly, MA
Jason Schrwratwiesler, Conservation Director
International Game Fish Association, Dania Beach, FL
Roy Chamberlain, Vice President
South Shore Neptunes Dive Club, Marshfield, MA
Scientists
Dr. Manuel A. Morales Williams College Dr. Joan Edwards Williams College Dr. Timothy Downs Clark University Dr. Halina Brown Clark University Dr. Mark McMenamin Mt. Holyoke Dr. Jody Emel Clark University Dr. Jennie C. Stephens Clark University Dr. Curtice R. Griffin UMASS Amherst Dr. Guy Lanza UMASS Amherst Dr. Maria Rodrigues Holy Cross Dr. Boyd Kynard UMASS Amherst Dr. Buzz Hoagland Westfield State College Dr. Theresa McBride Holy Cross Dr. John T. Finn UMASS Amherst Dr. Paulette M. Peckol Smith College Dr. Robert Bertin Holy Cross Dr. Rob Goble Clark University |
Environmental Groups:
Frank Gorke, Director,
Environment Massachusetts
Boston, MA
Matt Rand, Director,
Conserve Our Ocean Legacy Campaign, Washington, DC
Gerry Leape, Vice president,
Marine Conservation, National Environmental Trust, Washington, DC
Peg Harrington, New England Representative,
Conserve Our Ocean Legacy Campaign, Salem, MA
Norris McDonald, President,
African American Environmentalist Association
Erika Staaf, Advocate
Environment New Hampshire
Matt Auten, Advocate
Environment Rhode Island
Renata von Tscharner, President & Founder
The Charles River Conservancy
Cambridge, MA
Michelle Hohensee, Administrative Coordinator
Save Our Shores
Charlie Lord, Executive Director
Urban Ecology Institute, Chestnut Hill, MA
Julie Crockford, President
Emerald Necklace Conservancy, Brookline, MA
Paul G. Johnson, President and Chairman of the Board
Reef Relief,
Mike Hanauer
Massachusetts Environmentalists for Sustainable Population
Lauren Finan
REEF Environmental Education Foundation
Pine DuBois, Executive Director
Jones River Watershed Association, Kingston, MA
Bill Mott, Director
The Ocean Project
Jim Bourque, Regional Campaign Director
Earthshare
Community Leaders (as individuals)
Sue Sutter, Boston, MA
Lonna Maratty, Cape Neddick, ME
Lori Tsuruda, Founder
People Making a Difference, Boston, MA
Student Groups
Amanda O’Brien, President
Husky Environmental Action Team, Boston, MA
Lani Gedeon
Sierra Club, Hampshire College Chapter, Amherst, MA
Emily Lewis, Co-President
Students for Environmental Action, Northeastern University
Boston, MA
BU Organic Gardening Club, Boston, MA
Business Leaders (as individuals)
Gib Chase,
Eco Consultants, International
Tedi Dickinson
Earth Economics
Elena Saporta
American Society of Landscape Architects, Cambridge, MA
Other Organizations
Mike Gravitz, Oceans Advocate
USPIRG, Washington, DC
Sharon B. Young, Marine Issues Field Director
The Humane Society of the U.S.
Diane Buccheri, Publisher
OCEAN Magazine