Alliance of Communities for Sustainable Fisheries
256 Figueroa Street #1, Monterey, CA 93940
(831) 373-5238
www.alliancefisheries.com

 

July 4, 2007

 

The Honorable Sam Farr
US House of Representatives
1221 Longworth House Office Bldg.
Washington DC 20515-0517

Dear Congressman Farr:

Please find below our comments regarding HR21.  As an organization representing fishermen throughout the Central Coast, the Alliance of Communities for Sustainable Fisheries wants our marine resources and ecosystem managed to preserve long term ocean health and for sustainable resource use.  There certainly are regions of the nation that have suffered from poor management decisions and a lack of coordinated efforts.  However, we would say that these factors are not true for the West Coast, particularly not now.  We believe that ecosystem based management is now being advanced substantially through the Magnuson-Stevens Sustainable Fishing Conservation Act.  It should also be noted that Federal Fishery Management Councils throughout the nation are now required to follow the advice of their science committees.  Lastly, it should be noted that coordination of national policies and the elevation of ocean issues as a national priority has been substantially accomplished through the President’s executive order creating a committee on ocean policy which generally follows the recommendations of the U.S. Commission on Ocean Policy.  In short, compared to twenty years ago, or even ten, ocean health is improving, except perhaps in the area of water quality.

Generally we have significant concerns that the language of this bill as currently written would create large new unfunded bureaucracies and create enormous confusion over fishery management decisions.  It also only indirectly affects international fisheries, which is, in our opinion, where much of the true crisis in fisheries lies.

 

Our specific comments are as follows:

           

Section 2 - Findings

First it should be noted that “by-catch” is not in itself a threat to ecosystem health.  Every fishery in the world, no matter how clean, has some by-catch.  It should be noted that the current Magnuson –Stevens Act now requires total catch accounting.  This should lay the foundation to solve one of the most pressing problems with by-catch.  Therefore, the reference to “by-catch” in this section should be removed.

 

Importantly, the “findings” section fails to recognize the many improvements in resource management and in the condition of fish stocks that have occurred over the past ten years

 

Title I - NATIONAL OCEANS POLICY

This Section is racked with problems centered around definitions of healthy ecosystems and “natural environments”.  These definitions provide no flexibility to account for natural

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