Cod, NOAA, and Existence

February 24, 2013

This is an expanded response to John B.’s posted comment on a Standard-Times, New Bedford, article by Steve Urbon titled:  “Petition seeks closing of NOAA fisheries regional office”,  a comment in which John B. states that the New England fishermen’s troubles are due to “over harvesting” and that NOAA is not the cause of the fishermen’s troubles.”, NOAA’s role he contends, “…is only the bearer of bad tidings” and so NOAA then, quite innocently, didn’t “cause” any of this mess; instead, he warns fishermen that “…unless the [fishing] industry takes an unflinching look at the realities that it is facing” or, “Ignore the realities, and the New England fishing industry may well go the way of Newfoundland’s, which fished itself out of existence some years ago.”

John, there’s that old familiar refrain again, “…too many fishermen chasing too few fish”, overfishing, over harvesting?  No, sorry, that’s not “…an unflinching look at the realities” that’s an ENGO talking point.  This fishery is a disaster due to inadequate surveys and ambivalent assessments, plus the fact that many fishermen were put out of business by cock-eyed catch share allocations and the consequent fleet consolidation imposed by NOAA’s EDF Jane Lubchenco and sustained by lawsuit threats from such enviro-luminaries as Conservation Law Foundation, Pew, Oceana, Center for Biological Diversity, and the Natural Resources Defense Council, to name a few. 

Fishermen’s troubles are a direct result of mismanagement: inadequate science, unreasonable Maximum Sustainable Yield-crisis centric regulations, NOAA’s single species approach to a complex multi-species fishery, and then, of course, our beloved “returning profitability to fishermen” catch shares, a disastrous campaign to privatize and turn the fish resource into a Wall Street commodity at the expense and demise of working fishermen.  Additionally, NOAA has traditionally ignored environmental factors, such as climate change, predation, and natural cycles, focusing solely on managing the fishermen, not the fish in their environment. If this cod stock is indeed “collapsing”, it is certainly not due to “over harvesting”—the groundfish managers’ Total Allowable Catch has been under-harvested for years, sometimes by 75%, but consistently underfished by at least 50%.

NOAA’s responsibility goes way beyond simply being the “bearer of tidings”.  NOAA has now micro-managed the fishermen almost completely out of existence.  These “troubles” are not caused by coastal small boat fishing operations following a business plan of “over harvesting”. 

NOAA, steered by the ENGO’s, has mis-managed this groundfishery for decades.  Simplistic Maximum Sustainable Yield management of a complex multi-species groundfishery has contributed greatly to the undermining of stock stability.  MSY jeopardizes a stock’s reproductive ability by encouraging the take of large prolific egg bearing fish, and then estimating stock population health by counting the recruitment of juveniles.  It is the large mature fish in the stock population that influences stock stability and health. Managing from the MSY perspective does nothing but remove large fish from the stock, replacing them with a large class of young fish which assures stock population volatility. 

As for Newfoundland’s cod fishery, it was shut down in 1992.  Arguably the collapse was a result of the previous decades’ freezer/trawler excesses.  National Sea Products, Ltd. a large Canadian integrated fish company, for example, operated several large capacity trawlers in the post 200mi. limit bonanza of the late 70’s and 80’s. In 1987 National Sea Products, Ltd. generated more than $450 million in annual sales, employed 8,000 workers, and executed fishing operations in all four Atlantic Provinces and three U.S. states in addition to its growing overseas units.  As a result of this increased industrial style fishing pressure the average size of the fish decreased and they became harder and harder to find until the Canadian government closed the fishery in 1992.  The smaller private fishing operations were penalized for the industrial offshore factory freezer/trawler fleet’s activities. 

The Newfoundland cod collapse is in no way analogous to what’s going on in the dismantling of our fishery here in New England.  The only parallel is perhaps between the Canadian Department of Fisheries’ faulty management posture, (i.e., inviting in Canadian and foreign industrial exploitation) and the similar posture of NOAA’s promulgation of catch shares quota management.  NOAA’s push for catch share ITQ consolidation is similar Canada’s opening the door for exploitation by companies like Canada’s National Sea Products, Ltd., and NOAA’s push could have an even worse result of collapsing more species than just cod.  NOAA it seems is in the process of privatizing all of our fisheries, and is currently working on catch shares for Monkfish. 

When any fish becomes a tradable commodity on the “open market” a global moneyed-monster such as the Pacific Andes’ China Fishery, with limitless “market capitalized” resources, can buy up limitless amounts of quota and with input restrictions and daily limits removed, they can bring in their factory trawlers and proceed to collapse the fish stocks. These huge integrated fishing companies also have a limitless appetite.  They can always use more cod, more anything, to increase profit and bolster stock prices.

Industrialization is what caused the Canadian cod collapse and it will be the fate of all our local fisheries if NOAA’s privatization plans are allowed to continue. Far from the independent fishermen “fishing themselves out of existence”, it’s the choking regulations and fleet consolidation which is clearing the way for the financialization/industrialization of the fish and the ocean environment.  This is what is destroying the vital New England fishing industry.

Faulty MSY management, quota give-away consolidation, and only-profit-matters exploitation by market-capitalized companies, causes collapse, not the efforts of independent family owned coastal fishing boats.

NOAA should stick to weather forecasting and navigational charting and give fisheries management over to a Department of Fisheries employing some personnel that know and care something about fishing.

From the petition to close NOAA’s office in Gloucester, MA: “On January 26, 2013, the Associated Press reported that John Bullard, the Northeast Regional Administrator for the National Marine Fisheries Service (NMFS), stated, ‘failures by fishery managers are ultimately to blame for weak stocks that haven’t rebounded.’ The AP went on to quote Mr. Bullard as saying, ‘we set the rules and clearly the rules have failed. There’s no other conclusion.’

How refreshing! The above statement by Bullard, aside from the discovery by the Inspector General of the corruption in the NOAA Office of Law Enforcement and the consequent reparations by Secretary Gary Locke, is the first time anyone at NOAA Fisheries has even approached admitting the “realities” of NOAA’s management failures.  Usually NOAA gives off self-congratulatory statements like those from departed Under Secretary Lubchenco declaring on her way out how she saved the fish and returned the fishing industry to prosperity.

However, when this petition attempts to take the NOAA director’s admission of regulatory failure into actions which might actually fix some of the faulty management and get some relief to the fishermen who have been most harmed, Bullard responded to Steve Urbon in the Standard-Times article with: “this is very serious business that we’re dealing with, and that petition is not serious. So I don’t want to waste any time on it.”  (Pat Kurkul could very well have said these things—we didn’t need a new regional director for this kind of disrespect!)

From the Petition:

“By closing the Northeast Regional Office in Gloucester and redirecting these funds to relief and programs benefitting the Northeast groundfish fleet, the Committee [Senate Committee on Appropriations] stands to support and advance important scientific research, particularly cooperative research and surveys conducted by non-NMFS scientists – such as those where fishermen are working together with the University of Massachusetts School for Marine Science and Technology (SMAST) and the Virginia Institute of Marine Science (VIMS), as well as much-needed more frequent assessments of the condition of managed species.
We further urge the Committee to reduce and redistribute current Regional Office operations to minimally staffed offices located in port communities such as New Bedford, Gloucester, and Portland so that necessary permits may still be issued as needed.”

When the people who have been most harmed petition to mitigate the devastating effects of inept, “arbitrary and capricious”, and the ENGO-agenda-driven “failures by fishery managers” by closing the office of origin from where, as Bullard admits, “…we set the rules and clearly the rules have failed”; and when they suggest in the petition that the rescued funds, resulting from such a closure, can be used for some long awaited Disaster Relief and also for supporting the trust-restoring remedy of stock assessments which are based on cooperative research and co-governance—that petition is not a “waste of time”.  In fact, it is quite serious. 

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