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June 4, 2004
Admiral James D. Watkins, Chairman
U.S. Commission on Ocean Policy

RE: Comments on Final U.S. Commission on Ocean Policy Preliminary Report

Dear Admiral Watkins:

The Massachusetts Fishermen's Partnership (MFP) respectfully submits the following comments on the preliminary report by the US Commission on Ocean Policy.

The MFP is an umbrella organization of 17 commercial fishing associations representing all gear and geographic sectors of the Massachusetts fishing industry. The organization was created to promote the common interests and economic viability of commercial fishermen and fishing families. The MFP is sponsor of the Fishing Partnership Health Plan, which provides comprehensive healthcare coverage for almost 2000 members in the fishing community. The MFPís Collaborative Research Program establishes research partnerships among fishermen and scientists to promote improved knowledge and understanding through research in a variety of disciplines.

The MFP applauds the Commissionís focus on an ecosystem approach and the research required to develop this policy shift. The MFP strongly endorses the Commissionís recommendations to double federal investment in oceans research, including funding the establishment of an Integrated Ocean Observing System. The MFP especially urges the Commission to further elaborate how to improve oceans and fisheries science through collaborative research as an essential first step towards achieving sensible reform in fisheries management.

The MFP promotes the following positions:

  • Suspend all offshore renewable energy projects in the pipeline until a regulatory framework is in place;
  • Protect traditional water-dependent permissible uses that serve the public interest;
  • Establish a permitting process for offshore development that fairly considers the economic and environmental costs and benefits of a proposed project;
  • Enact National Standards to govern management approaches utilizing dedicated access privileges that check consolidation, protect communities, require that the support sustainable fisheries, and require approval by a super majority before they can be implemented;
  • Establish an independent process to ensure that all National Standards are rigorously enforced in all regulations;
  • Establish criteria for "best scientific information available" that is linked with independent peer review and especially the participation of fishermen;
  • Fund collaborative research to adequate levels and ensure that fishermen are involved in the research process;
  • Definitions describing conditions of fish stocks must clearly separate stocks that are declining due to causes other than fishing;
  • By-catch and discarded fish are not the same and should not be treated as the same;
  • Adequate observer coverage for higher confidence in assessments must be provided;
  • Fishery regulations should minimize adverse social and economic impacts to fishing communities by including input from community-based social science while protecting the ongoing sustainability of fish stocks;
  • Support a pilot program for one fishery ecosystem plan from each region provided the effort is adequately funded, based on a scientific framework that has been developed involving fishermen through collaborative research, and a reasonable amount of time is allowed for effective plans to be created;
  • Disadvantages to US fishermen in relation to foreign imports as a result of conservation and management should be minimized;
  • Members of fishery management councils should be more accountable to fishermen and people in the fishing communities.

It is critical that a comprehensive ecosystem-based approach is developed that builds a sound scientific foundation with the continuous involvement of fishermen to bridge the current lack of consensus on marine environmental well-being. In addition, appropriate ocean uses must be delineated in a rational manner that considers the human component of biodiversity as an essential factor in its management.

The MFP is well positioned within the commercial fishing industry to serve as a liaison and is willing to assist as the Commission moves forward. It is our sincere hope that ecosystem-based collaborative research will be one of the primary tools used to help succor the ocean and its potential to sustain a variety of permissible uses.


David Bergeron , Executive Director

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