My vote is NO.

March 14, 2014golden towers

It’s difficult to give a “brief” explanation because there are so many things so terribly wrong with this proposal.  In fact most of it is insulting and infuriating!

First of all, I would not vote for, or put my name on, anything that had Cape Cod Commercial Fishermen’s Alliance in the opening paragraph as one of the authors.  This organization has consistently taken money from the environmental groups that have caused more damage to our fisheries than any other element.  CCCHFA the Cape Cod Commercial Hook Fishermen’s Association or humorously known as the “hookers” were the “poster children” for catch shares which NOAA and EDF and CLF fostered and then pointed to as proof that we absolutely needed catch shares in New England.  Catch shares and ridiculous stock assessments and consequent impossible Total Allowable Catch constrictions are the reason that we have a disaster!

Besides that, the specifics of this proposal are completely counter to every one of its own three stated accomplishment goals.

(1) Offer a regional spending plan to ensure consistency in the treatment of fishing

businesses affected by the disaster.

Direct assistance to permit/vessel owners is going to be based essentially on the years 2010, 2011, and 2012. Why? Why these dates? Why use a qualification period after the industry devastating catch shares were imposed? Many vessels were pretty much allocated right out of the groundfish business by the inequitable initial catch shares allocation process. Do they get left out of the “relief” if they don’t measure up to the “minimum groundfish landings threshold” because their allocation was not enough for them to make a trip to Georges after the catch shares allocation debacle? Some user groups fared better than others and allocation criteria were certainly not consistent for all groups. Using these catch share years as criteria will only perpetuate the inequities which have tied up the majority of the fleet and created a few wanna’ be moguls.  Remember…winners and losers?

Is locking in those devastating inequities by using these catch share years as qualification criteria what you consider “…a regional spending plan to ensure consistency in the treatment of fishing businesses affected by the disaster”?

(2) Mitigate the economic injury incurred to those commercial fishing businesses that have been impacted by the groundfish disaster.

Allocating $11 million plus $2 million for crew out of $33+ million leaves approximately $20 million…for what?  Buybacks?  Buyouts? Relief money is for the purpose of making fishing operations whole and helping them to survive as viable businesses and who knows maybe even profitable businesses someday: but certainly this money should not implement their disappearance for a one time buy out of their permits. The “redistributions” will benefit the “winners” who own more of the allocation to begin with.  This further consolidation of an already much too consolidated industry will be the end of our ports and the shoreside businesses necessary to support the local fleet.  Unless some consideration and respect is given to the shoreside businesses which are highly specialized and dependent on a minimal volume of vessel business and fishermen are dependent on them to get back to sea in the shortest time possible;  unless this insane consolidation and shrinking of the fleets is stemmed, we are not going to have any “industry” to worry about.  Buybacks will not “mitigate economic injury”—they will cause it!

(3) Improve the future viability of the commercial groundfish fishery.

Buybacks of permits with the allocations from those permits redistributed, will improve the “future viability” of which segment of the “commercial commercial groundfish fishery”?  Just who do you suppose will benefit the most from this redistribution?  Will it benefit the single vessel, single permit holder with a .00076% allocation of the TAC?  Or will the redistribution benefit go to the “businesses” that already have the highest percentage of the TAC locked in anyway: the multi-permit, multi-vessel owners, the permit  banks, the “winners”?

The rich get richer…?


NSC could have stood up for the small boat fleet years ago and “Worked Together on the Future of the Fisheries” by presenting a unified resistance to these devastating catch shares.  Instead NSC ascribed to the compliant position of “Hey, this (privatization) is inevitable; so might as well get a seat at the table and make the best of it.” In case you haven’t noticed, there is a grand push for wind farms, oil and gas rigs, and aquaculture installments up and down the coast; will you opt for a place at that table as well?

This Spending Plan is hostile to supporting a diverse and profitable independent small boat fleet, which is, and always has been, key to healthy local fishing communities and a healthy ocean and healthy fish stocks.

What would be useful is a very doable grant program for businesses that are about to go under due to regulations and low catch shares allocations.  Also what would help is a very low cost and accessible loan program, so that operations that have lost income since the imposition of catch shares and the impossible TAC’s, can refinance some of the high interest debt accumulated in trying to survive.


Dick Grachek

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