|
Washington, D.C. --- U.S. Rep. Frank Pallone, Jr. and John Adler, sent the following letter to Dr. Jane Lubchenco, Administrator of the National Oceanic and Atmospheric Administration and Undersecretary of Commerce, to express their concern over the use of catch shares as a way to manage recreational fisheries. The New Jersey lawmakers believe an independent peer review should be conducted to better understand the cost factor and enforcement issues that may arise with implementing catch shares.
September 21, 2009
Dr. Jane Lubchenco
Administrator, National Oceanic and Atmospheric Administration and Undersecretary of Commerce
1401 Constitution Avenue, NW
Room 5128
Washington, DC 20230
Dear Dr. Lubchenco:
First we would like to thank you for taking steps to partner with the saltwater recreational fishing community. Your recent announcement that the National Oceanic and Atmospheric Administration (NOAA) is creating the position of senior policy advisor for recreational fishing is welcome news and will go a long way in developing a strong relationship with recreational anglers.
However, today we are writing to express concern over the use of "catch shares," or Limited Access Privilege Programs (LAPPs), as a way to manage recreational fisheries. We believe there needs to be extensive research on the economic impacts and practicality of such a management system before implementation.
Our chief concern with catch shares is the cost to local fishermen. By assigning a dollar value for recreationally-landed fish based on market value, we run the risk of driving up the cost. It could become cost prohibitive for anglers to engage the specific fishery because it would be reserved for only those financially privileged enough to afford shares. If not administered correctly this approach could be a violation of the Public Trust Doctrine, which is the legal doctrine that protects the interests and rights of the public to free access to the nation’s marine resources.
We are also concerned with the enforcement of such a management system. A catch share policy in the North or Mid-Atlantic would mean a new enforcement mechanism to ensure people are not exceeding their share. There are some questions as to how government will be able to properly enforce these new management provisions.
Due to the lack of consistent data, we would like to see NOAA and the National Marine Fisheries Service request that the National Research Center of the National Academy of Science conduct an independent peer review of recreation catch share programs before moving forward. It’s incredibly important we get all the facts before we implement a fundamental change in how we manage our fisheries.
Thank you for your attention to this matter. We look forward to discussing this with you further.
Sincerely,
FRANK PALLONE, JR. JOHN ADLER
Member of Congress Member of Congress
C.C: Dr. James W. Balsiger, Acting Assistant Administrator for Fisheries
Mr. Richard B. Robins, Jr., Chairman, Mid-Atlantic Fishery Management Council
Mr. George D. Lapointe, Chairman, Atlantic States Marine Fisheries Commission
|
