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Groundfish Catch Share Comments GROUNDFISH CATCH SHARE COMMENTS I would like to submit the following comments about the ongoing Groundfish Catch Share Program Review to the full New England council: Good morning all, Amendment 18 (catch share ownership cap for groundfish) was remorselessly lobbied against by those who controlled excess shares, and those that aspired to do so in the future. The Council enlisted Lexicon to report on the issue with a resulting recommendation of an ownership cap of a maximum of 15%. The NMFS chose to ignore that and has allowed ownership concentration in certain entities. For instance Carlos Rafael owns 25% of Georges Bank black-backs. Individual sectors also have accumulated overly large percentages of different stocks, with “umbrella” sectors magnifying the problem. This basic flaw in the New England groundfish catch share system needs to be corrected immediately. We need to fix this basic fundamental fault in the foundation of New England groundfish catch shares now. Yes, the council talked about it ad nauseam but always with the anti-accumulation limit lobby hard at it. It is time to do the right thing, no matter if it seems to be unpopular. In light of Raphael's crippling effect on much of New Bedford (akin to the effect of Gulf King Shrimp on Aransas Pass, Texas) it is blatantly obvious now that a reasonable, real, accumulation limit is needed. Much like the 5% ownership cap for scallops that we already have here in New Bedford. Thank you, Respectfully, Lawrence Patrick Kavanagh Jr President K&K Fishing Corp Fishing vessels Mary K, Moragh K, and Atlantic, New Bedford, Mass NEFMC, I am writing to express my concern over the New England Catch Share program. As you are conducting a formal review of the program it should be fairly clear that Catch Shares have not achieved any of the alleged "benefits" of Catch Share programs. According to your website Catch Share programs have to following benefits: • Ensuring annual catch limits are not exceeded to support rebuilding and sustaining U.S. fisheries. • Reducing the costs to produce seafood. • Reducing market gluts and increasing dockside prices. • Extending fishing seasons. • Reducing bycatch. • Improving fishermen’s safety. It should be clear that NONE of these benefits have been obtained. And further that the disadvantages of Catch Shares have materialized in the time since they were implemented. Ensuring catch limits are not exceeded has not been accomplished. In fact the system encourages vertical integration which makes the type of chicanery perpetrated by Carlos Rafael more likely. Catch limits are in and of themselves a means to limit overfishing. Catch Shares do nothing to make that more likely to occur, and as we have seen make it actually less likely to occur. Furthermore, there is little if any evidence that since the implementation of Catch Shares that any of the species under management is now more rebuilt or sustainable. And please do not point to Haddock as a success story. A single species abundance is not the sign of a healthy fishery. Catch Shares have not reduced costs to produce seafood. Catch Shares by definition INCREASE costs. Fish that were previously caught for the price of a permit now have to be leased as quota. There has been essentially no change in the price for fish, despite increased costs. Market gluts are largely a function of bad fishing regulations. In reference to haddock abundance above, haddock are being sold as lobster bait because the market is full of 16" haddock that fisherman cant sell. Again, a direct result of catch shares. Extending fishing seasons has not happened. Catch Shares created choke species which limits most fishermen's ability to fish year round. Reductions in bycatch can and are being obtained through better gear and technology in most fisheries around the world. Catch shares does nothing to reduce bycatch. As noted recently by Dave Goethel ( https://www.fosters.com/news/20190801/hidden-cost-of- fishery-monitoring) more bycatch death occurs due to the observer program than would from normal fishing practices. Again, where is the evidence of this Catch Share benefit? And finally Catch Shares have done NOTHING to increase safety at sea. Has the program funded any safety initiatives? Catch Shares has not changed the market dynamic that drives fishermen to go out in bad weather in order to get a higher price. Catch Shares has not funded safety seminars, vessel inspections or any other single program that could be said to increase safety. Its actually somewhat pathetic to argue Catch Shares somehow increase safety while making fishermen less money. Catch Shares are an unmitigated disaster for the New England groundfishery. The real "benifits" of Catch Shares is commodification and privitization of a public resource. In that you have succeeded. I see no other benifit to this tragic program. Simply put, there are less fish, less fishermen, same or lower dock prices, more corruption, more consolidation and less safety under Catch Shares. To see it any other way is willful blindness. Catch Shares do not work in New England, they do not work in other fisheries. Sincerely Sean Sullivan Marblehead, MA The most catastrophic problem of catch share fishery management in New England is that the stock assessments and actual fish stocks are disconnected. Fisherman are trying to find areas to avoid choke stocks, rather than find fish! The problem is: • Price to lease choke stock fish goes up, because of the low inventory • Price paid to boat is low, wholesale buyers can’t get enough to make it a marketable product • Fishermen lose money and risk the entire fishery shut down Another problem is the observer program which only exists because of catch shares. Among many issues, there is no routine opportunity for the observer data logs and landings to reconcile. On a recent trip the observer weighed a certain species and arrived at 1600lbs (she said). When landed it was only 1100lbs. My last concern with the catch share program is that fishing permits with landings in the qualifying years are once and for all the ones that have value. This has created arm chair fisherman and put a price tag on quota that frankly will never be undone. In summary, catch share management was never intended or designed for a multi species fishery, the observer program is flawed and the system gave ownership to a public resource. Brian Pearce F/V Gracelyn Jane Portland, Maine From: Bore Head <[email protected]> Sent: Monday, August 19, 2019 2:21 PM To: comments <[email protected]> Subject: Groundfish Catch Share Program Review, Public Comment Greetings. We started following fishery issues over twelve years ago in various social media settings to engage with the general public and fishermen from every region throughout the world. One thing I have gotten out of reading hundreds of these articles, besides scorn, from New England to New Zealand about catch shares and fishery management was from a fishery manager discussing perversions in the process. The two words that should be in the front of minds of the deciding peoples that control the fait of others was "unintended consequences" of decisions made in the Gulf Red Snapper fishery, which seems to spill into every fishery management decision. Here are links to four pages of catch share articles. It was intentional to post these articles, hoping there would be positive results as people realized catch shares saved not one single fish. If these pages are reviewed by the council, we will feel that will be a step in the right direction. Thank you, Carol Breadmore http://fisherynation.com/?s=Catch+Shares http://fisherynation.com/page/2?s=Catch+Shares http://fisherynation.com/page/3?s=Catch+Shares http://fisherynation.com/page/4?s=Catch+Shares Theres more! Sector 13 landed 2.9 million lbs of groundfish in 20120 with 33 permits In 2018 with 63 permits it landed 2,057,000 lbs of groundfish. doesn't look like a success to me! Fishing effort was 77% in 2010 Fishing effort in 2018 was 13% Doesn't look like a success to me! John Haran I’m a life long commercial fisherman from Scarboro Maine. I’m 50, and fished since age 14. I’ve participated in many fisheries and spent 13 years exclusively ground fishing, from 2005-2018. The majic decade of 96 to 06 for qualifying quota may have worked for some but not for me I’ve spent 20 to 30% of my business gross income on leasing quota, many times from people who don’t groundfish at all. This is wrong on so many levels. Jobs fishing are good jobs Fishing boats contribute greatly to local economies and give jobs for dozens of people both on and off water A lease lord makes his money and is the sole beneficiary and this is wrong It’s time to re-allocate! The quota needs to go to those who fish! To those who own and maintain boats and offer jobs!!! When I started in 05’ I was allowed 40,000 GOM cod a year now I have 300! The GOM cod are back and the quota is too low for me to operate. The lease price is higher then I can sell it for much of the time. Catch shares has forced me out of groundfishing temporarily, I now fish for lobster, scallops and squid. Luckily I have these options but it cost me significant financial investment. As a small business man. Catch Shares has nearly ruined me. It’s time for a change! Robert M Odlin Owner/operator F/V Maria and Dorothy As a 62 year old lifelong fisherman I can tell you that this was the one major factor that made me decide this life was no longer going to be what I wanted to do.
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