Wednesday, October 10, 2007

A letter to National Marine Fisheries service

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


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


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

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