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
Gareth Evans, Rector
Stephen T. Ayres, Vicar
Environment Group of the
Jenny Fleming –Ives
Environmental Task Force of the Hampshire Interfaith Council
Religious Leaders (as individuals)
Pastor Sarah J. Anderson, Pastor
Christ the
Rev. Stephen Cook, Reverand
Unitarian Society of
Ellen Bernstein, Founder
Rev. Georganne Greene, Reverand
Unitarian Universalist Society of Greater
Recreational Groups
David Prescott, Chairman
Andrew Krupa, Chairman
Jenny Miller Garmendia, Director
Project AWARE Foundation
Heather L. Knowles, Captain
North Atlantic Dive Expeditions, Inc.,
Jason Schrwratwiesler, Conservation Director
International Game Fish Association,
Roy Chamberlain, Vice President
Scientists
Dr. Manuel A. Morales Dr. Joan Edwards Dr. Timothy Downs Dr. Halina Brown Dr. Mark McMenamin Dr. Jody Emel Dr. Jennie C. Stephens Dr. Curtice R. Griffin UMASS Dr. Guy Lanza UMASS Dr. Maria Rodrigues Holy Cross Dr. Boyd Kynard UMASS Dr. Buzz Hoagland Dr. Theresa McBride Holy Cross Dr. John T. Finn UMASS Dr. Paulette M. Peckol Dr. Robert Bertin Holy Cross Dr. Rob Goble |
Environmental Groups:
Frank Gorke, Director,
Environment
Matt Rand, Director,
Conserve Our Ocean Legacy Campaign,
Gerry Leape, Vice president,
Marine Conservation, National Environmental Trust,
Peg Harrington,
Conserve Our Ocean Legacy Campaign,
Norris McDonald, President,
African American Environmentalist Association
Erika Staaf, Advocate
Environment
Matt Auten, Advocate
Environment
Renata von Tscharner, President & Founder
The
Michelle Hohensee, Administrative Coordinator
Save Our Shores
Charlie Lord, Executive Director
Urban Ecology Institute,
Julie Crockford, President
Emerald Necklace Conservancy,
Paul G. Johnson, President and Chairman of the Board
Reef Relief,
Mike Hanauer
Lauren Finan
REEF Environmental Education Foundation
Pine DuBois, Executive Director
Bill Mott, Director
The Ocean Project
Jim Bourque, Regional Campaign Director
Earthshare
Community Leaders (as individuals)
Sue Sutter,
Lonna Maratty,
Lori Tsuruda, Founder
People Making a Difference,
Student Groups
Amanda O’Brien, President
Husky Environmental Action Team,
Lani Gedeon
Sierra Club,
Emily Lewis, Co-President
Students for Environmental Action, Northeastern University
BU Organic Gardening Club,
Business Leaders (as individuals)
Gib Chase,
Eco Consultants, International
Tedi Dickinson
Earth Economics
Elena Saporta
American Society of Landscape Architects,
Other Organizations
Mike Gravitz, Oceans Advocate
USPIRG,
Sharon B. Young, Marine Issues Field Director
The Humane Society of the
Diane Buccheri, Publisher
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