A Petition To Amend MAGNUSON-STEVENS ACT

To obtain a comprehensive view of the complex issues treated in this petition, please read the following letter that I sent to Dr. Lubchenco, the new NOAA administrator, on April 22, 2009

RE: New England Fisheries Development

"One of the most important roles of science is to inform, to provide information, so that citizens and decision makers can use that information and understand the full ramifications of a course of action."

JANE LUBCHENCO
Earth's Unruly Tenant

Dear Dr. Lubchenco,

Now that our fisheries have in you, Dr. Lubchenco, a concerned scientist at the helm of NOAA, we are hopeful that we will receive a scientific answer to two scientific questions. The first question is: Why does NMFS not take into consideration much historical, biological, statistical, and scientific evidence that points to the existence of a predator/prey relationship in the marine biomass in general and especially in the relationship between pelagics and bottom fish? The second question is: Why does NMFS not distinguish between the operations of large corporate fishing enterprises and the small family fishing operation?

Clearly, if the overfishing is done by the natural predators of bottom fish and by the large industrial corporations, then NMFS policies in current vigor -- as science indicates and as historical evidence corroborates -- are irrelevant to the health of fish populations and are causing unnecessary devastation in the local fishing communities. Nor is the effect of this devastation of solely local concern. When President Obama is spending billions of dollars to try to create jobs, how can NMFS justify its preventing fishermen to go to work -- free of charge? When even China is balking at buying more of our national debt, how can NMFS justify leaving us no alternative but purchase fish from abroad in order to satisfy our need for this quasi-vital food?

These are not new questions. I and many other people have placed them to NMFS in a variety of contexts.

They are an intrinsic component of an economic development plan, now in consideration by the City of Gloucester, whose intent is to make our community fiscally, socially, and esthetically vibrant.

They are an intrinsic component of a Plan of Fisheries Renewal that, with the help of many people -- led by the Board of Directors of the Gloucester Community Development Corporation (Gloucester CDC) -- over the years has been gradually developed and individually discussed with many public officers, business leaders, and concerned citizens.

Parts of this plan, which  is based on the solid foundation of research carried out by two outstanding scientists, Drs. Herbert Hultin and Stephen Kelleher, have been included in reports to the City Community Development Department, Judge Gladys Kessler of the U.S. District Court in Washington, DC, and the New England Fisheries Management Council.

Parts of this plan have also been presented to the general public via interviews with the local and regional press as well as articles in the Gloucester Daily Times.

Here is some relevant documentation:

A paper titled "Fisheries Renewal: A Renewal of the Soul of Business," which I wrote with Stuart Weeks for the Catholic Social Science Review of 1997, is available at http://www.carmine-gorga.us/id34.htm.

The Final Report for the "Pelagic Fish Economic Development Project" presented to the City Department of Community Development and to EDA in 2001 is available at http://www.gloucestercdc.org/id59.htm.

The financial and natural resources aspects of this study were carried forward by members of the System Dynamics Analysis graduate program at MIT. Drs. Peter Otto and Jeroen Struben published part of this study in the prestigious System Dynamics Review (Winter 2004); the rest of the plan is available at http://www.albany.edu/~potto/GCDC/archive.htm.  

A copy of the letter to Judge Kessler and the letter to Thomas Hill, with supporting evidence, can be found at www.somist.org (Part 4).

Many of the interviews and media articles are reprinted at http://www.gloucestercdc.org/id89.htm. The latest articles I have published in the GDT are available at http://www.gloucestertimes.com/archivesearch.

A survey, organized with David S. Wise and signed by 425 people in three days during 2007 Summer is posted at http://www.polis-tics.com/id38.htm, has been transformed into seven specific resolutions, which were unanimously passed in September 2008 by our City Council, and are currently being analyzed by Mayor Carolyn Kirk's administration. Survey and resolutions can be found at www.somist.org (Parts 5, 6, and 7).

Thank you, Dr. Lubchenco, for allowing me this opportunity to address you with these questions. I trust that in the days ahead you will give your full attention to the many implications for fisheries and community renewal that ensue from the following firm answers:

• Overfishing is not done by local fishermen, but by the natural predators of bottom fish.

• Overfishing is not done by the family fishing operation but by large, generally subsidized, national and foreign fishing operations.

Sincerely yours

Carmine Gorga

President

PS -- On a practical side, would you like to consider three possibilities that might help you immediately restore trust from fishermen in NMFS? First, would you fund a PRO BONO BIN Program? If fishing vessels had the possibility of separating the by-catch into clearly marked special bins to be directed to the pro bono market, they would happily comply. The unacceptable practice of throwing dead fish back into the sea would be stopped, and NMFS would at least get reliable statistics on which to base sound policy in the future.

Second suggestion. Would you be the first person to sign the attached petition? Horrible implementation measures do not stand alone; they clearly derive from badly designed legislation. If the Magnuson-Stevens Act had an appropriate Preamble, in due time the Act itself might collaboratively be transformed into a workable policy tool to be implemented for the benefit of fish and fishermen alike.

Third suggestion. Would you fund research to develop a true multi-species fisheries management plan, a plan that incorporates the dictates of the predator/prey model that has been found to rule natural relationships among all living beings, a plan that follows the trail blazed by, e.g., http://www.albany.edu/~potto/GCDC/index.htm?