As I have said, no one saw it coming, including the RFA, and we are trying to do something about it. Get off your high horse.
As for "illegal undue influence," what is illegal about a group trying to influence public policy? Our various trade and recreational fishing groups do that all the time. Is it illegal simply because you disagree with what they want to do?
Mr. Brownlee,
You may have the opinion that NGOs have the right to "buy" our fisheries policy, (and they are "buying" it through the $500 million dollars spent to date by these NGOs to push Catch Shares), but I disagree. That money would have been better spent fulfilling the Congressional mandate for better data, but the NGOs/NMFS really don't want better data, do they? Lubchenco even siphoned millions of dollars AWAY from cooperative research to put into Catch Share promotion. Disgusting.
Why is it when I point out something regarding the possibly illegal actions of EDF and/or NMFS that people want to make it a personal issue with me? If there is nothing possibly illegal with their actions, why is the IG's office investigating that very thing?
The Commerce Department inspector general's office has notified NOAA administrator Jane Lubchenco that the investigation sought by two Massachusetts congressmen into the influences of non-government organizations on the National Oceanic and Atmospheric Administration and its regional fishery management councils is going forward.
The inspector general's new investigation, as it pertains to the New England Fishery Management Council, arrives as a federal lawsuit against the work of the council and NOAA in creating the catch share regimen for the groundfishery heads into the First U.S. Circuit Court of Appeals in Boston.
The plaintiffs, more than two dozen organizations and individuals, failed in U.S. District Court after arguing that the government had contrived to deny fishermen the right to a referendum on whether to adopt the catch share system by creating a limited access privilege program, a legal structure defined by the Magnuson-Stevens Act, while calling it something else.
Underlying the suit and the decision of the plaintiffs to take the case to the Court of Appeals is an explicit concern about undue influence of environmental non-government organizations — notably thee Environmental Defense Fund — that are financially fueled by giant foundations, including those derived from the success of the Hewlett-Packard, Intel and Wal-Mart corporations.
Fisheries journalist Nils Stople has produced research showing that the foundations have invested more than $500 million to influence and shape fisheries policy in recent years. Among the most pervasive ideas was the push for catch share systems that open the door to fishermen and groups buying, selling or trading shares of an allotted catch for each fish stock.
The net effect — including in New England, according to NOAA's own figures — has been to consolidate more quota and control in fewer hands, while driving many small independent fishing boats and businesses to the sidelines. NOAA figures show that the first year of catch shares essentially shut down some two dozen of Gloucester's then 95-vessel fishing fleet.
Lubchenco, then a board officer with the Environmental Defense Fund, helped obtain foundation funding for catch shares studies and helped write a policy paper for EDF that, financed primarily by the Walton Foundation, urged President Obama to transform U.S. fisheries into catch share markets without delay (Oceans of Abundance).
Obama then named Lubchenco to head NOAA and since she has pushed for catch share systems in New England and across America's three coasts.
Acceding to her demand, the New England council in 2009 quickly approved the system now under legal challenge, and put no accumulation caps on ownership of the industry.
Lubchenco needs to be fired - period. EDF needs to get the hell out of our fisheries management NOW.
Capt. Thomas J. Hilton
Last edited by Tom Hilton; 03-12-12 at 10:56 AM.
Tom,
No one denies that EDF and others are spending a lot of money to push catch shares! That is obvious! It is also their right to do so, and disagreeing with their goals is a legitimate concern. It's when we bridge the gap between lobbying, and conspiracy, that the argument gets out of hand. They simply have more money than we do and are better organized.
Perhaps the IG investigation will uncover if there is any "conspiracy" or not.
What I do not agree with is the "revolving door" of government employees "retiring" then going to work for these NGOs, using their contacts to then push the NGO's agenda from the inside.
Worse, people currently working for the federal government, using their positions to affect issues that are important to the NGOs while they are in a position to affect change, THEN going to work after they retire for these same NGOs.
Certainly has the appearance of impropriety, and opens the door for corruption due to the enormous amounts of money being poured into these issues such as Catch Shares. Who knows what is being promised to these government employees if they carry the NGOs' water?
This is what needs investigating, as this "revolving door" BS needs to stop.
Capt. Thomas J. Hilton
Last edited by Tom Hilton; 03-12-12 at 01:05 PM.
Two quibbles, "overfished and overfishing are not, strictly speaking related terms. You have correctly defined "overfished" but "overfishing" occurs when the harvest of a species exceeds the quota set for that species. So any given species can be "overfished" but not experiencing "overfishing" and conversely any species can be subject to "overfishing" but not be "overfished."
The cause of the decline is, again strictly speaking, mortality, which may come from fishing or may be a combination of fishing and many other related causes.
Not so, MakoMike. "Overfishing" is a measure of the rate of fishing. Think of it as the day-to-day fishing pressure on a stock. Quotas are the fishery managers' allowable upper limit of catch (the Annual Catch Limit) generally for an year's worth of fishing measured at the end of the season (or for the "fishing year" such as April thru Dec for Southeast Region's snapper\grouper fisheries). US fisheries' quotas are set based on expert scientific advice from stock assessment panels using recent catch and effort data.
As an example, if the fishing pressure on a fishery is twice as high as the fishery managers were expecting, that fishery would likely be closed after just half of the fishing year had been completed. If so, the annual quota would not be exceeded but excessive "overfishing" would have been the cause of the early closure, probably with severe economic consequences. If your interpretation of these terms were correct, there would be no "overfishing" occurring here since there was no "harvest exceeding the quota set for that species."
There is another point to consider as well when thinking about quotas. In international fisheries (such as those for Atlantic highly migratory species "managed" by ICCAT which I used to explain the difference between "overfished" and "overfishing"), annual catch limits are recommended by a team of stock assessmnent experts based on scientific modeling results. Quotas, in contrast, are set by the commission members (3 political appointees from each nation) and, in most cases, are based in large part on economic interests of the countries involved. Those with much revenue at stake (such as Japan) secure the political support (votes) from small or poor member countries alllowing the establishment by ICCAT of much higher quotas or total limits than recommended by ICCAT's scientific experts and thus higher country-specific annual catch quotas (often several times higher than is safe biologically). This is the situation for Atlantic bluefin tuna, blue marlin and white marlin. All are excessively "overfished" and all have been experiencing day-after-day "overfishing" resulting in perpetually "ovefished" populations. All three are, in fact, so severely "overfished" that they are approaching extinction, as I've explained elsewhere.
If this weren't bad enough, ICCAT chooses not to punish offending members who exceed their annual quotas, so there is no reason many countries pay any attention to their daily rate of fishing or their total annual catch. And non-member countries have been free to dip into these fisheries with impunity.
No wonder we have lost an estimated 90% of the fishery biomass of the world's oceans already, particularly the largest and most valuable species.
www.BigMarineFish.com
what did I say that contradicts anything you just said? Forget about ICAAT, ICAAT does not define the term overfishing, but if it did, then by ICAAT standards there would be no "overfishing" if the approved quotas were not exceeded. The definition I gave of overfishing, i.e. when the actual catch of a species exceeds the quota set for the year, is NOAA/NMFS's definaition. In your example, whether that species was subject to overfishing, would depend on what the catch for the fishing year was, not what the catch for the first half of the year was.
Don't get me started on what is biologically acceptable and stock assessments/ definitions of an unfished population, Bmsy, etc. Suffice it to say, that will all of the assumptions, modeling errors, sampling errors, and inference drawn, they are far from a model of what "science" is supposed to be.
OK, I'll point out the difference again. "Overfishing" means simply that the rate of removal from a stock is too
high. "Overfished" means the population is too low, below an established threshold.
You say the definition of overfishing is "when the actual catch of a species exceeds the quota set for the year." That's actually the definition of "overfished" not "overfishing." Overfishing during the fishing year produced the overfished condition of the stock at ther end of the year. Overfishing is a measure of the rate of mortality during the fishing season caused by fishing. It can be estimated at any time during the fishing year, not just at the end when the quota is reached.
NMFS's Annual Report to Congress on the Status of the Stocks states the dfference as follows:"A stock that is subject to overfishing has a fishing mortality (harvest) rate above the level that provides for the maximum sustainable yield (i.e., rate of removals is too high). A stock that is overfished has a biomass level below a biological threshold specified in its fishery management plan (i.e., the population is too low)." See http://www.nmfs.noaa.gov/stories/201...011_report.pdf
Moreover the terms (overfished and overfishing and their component terms like Bmsy, Fmsy, etc.) are not employed by just ICCAT's scientific advisors to model population changes for its stock assessments but by stock assessment scientists worldwide. I have used the stock assessment results for swordfish, bluefin, blue and white marlin as examples of how to interpret such complex stock assessment results in terms understandable to non-population modelers. However, the same terms are used for all stock assessments at least where we have sufficient data on catch and effort to do so.
Repeating it doesn't make it correct.Yes "overfishing" refers to the rate of removal, but there is also a time period involved. In other words "overfishing (at least as used by NOAA/NMFS) refers to the rate of removal for the fishing year. So in your example if the catch rate during the first half of the year is on track to exceed the ABC, but falls during the second half of the year, and the ABC is not exceeded, NOAA/NMFS will NOT classify that species as being subject to "overfishing."
Again you missed my point. When the actual catch of a species exceeds the quota set for the year the species is subject to "overfishing" but if the species is at Bmsy it will NOT be "overfished." Once again a species can be subject to "overfishing" (i.e. the harvest exceeds the ABC) but not be "overfished" (i.e. population is at or above Bmsy). Conversley a species can be "overfished" (i.e. the population is less than Bmsy) but not be subject to "overfishing" (i.e. the ABC for the fishing year is not exceeded. In fact the later situation is where almost all of the stocks that NOAA/NMFS lists as "overfished" fall. The populations are below Bmsy, but NOAA?NMFS has adopted a rebuilding plan to bring the population back to Bmsy within a give time period. If the ABC is exeeded for the fishing year NOAA/NMFS will list those stocks as being subject to "overfhsing" but if the ABC is not exceeded they will be classifies as NOT being subject to "overfishing."
That is generally correct except for "overfished" stocks that are subject to a rebuilding plan. Stocks subject to a rebuilding plan are only considered as being subject to "overfishing" if the ABC is exceeded. By definition those stocks are already "overfished" since the whole goal of the rebuilding plan is to bring the population back to Bmsy, which is the biological threashold in ALL fishery management plans and mandated by the MSA.
OK I thnk we have beaten this topic to death.