Fishing Industry Leader
Addresses NEFMC on
Cod Assessment Update Report

Council Members,

This new, updated cod assessment from the Science Center is the end result of a fundamentally flawed process, both procedurally and scientifically. By springing a surprise assessment on the public, the Science Center has further alienated those in the scientific and fishing communities who are concerned with the lack of transparency and collaboration in the current assessment process, and has led to flaws in the assessment’s models and methods going unaddressed.

The update assessment clearly runs afoul of several of the tenets of the Magnuson-Stevens Act’s National Standard 2, raising valid questions about the integrity of the process. Among other requirements, National Standard 2 states that stock assessments should be transparent, inclusive, and undergo peer review. In the case of this update assessment, none of these requirements have been met.

This assessment was not transparent. It was conducted practically in secret, and most of New England’s scientific and fishing communities were unaware of the assessment until its results were presented to the public. Only a small number of officials were actively involved in planning and executing this assessment. This has given outside experts and the general public little input into the details of the assessment, and little information on how it was actually conducted.

This breakdown in fostering an open stock assessment process is only likely to increase the levels of mistrust that exist between the government and fishing communities. If fishermen suspect that an assessment was conducted with a lack of transparency and openness, they cannot be expected to support the decisions that are the result of that assessment, especially if it threatens their livelihoods.

This assessment was not inclusive. Only a select group of scientists even had knowledge of the assessment’s existence prior to its completion. Collaboration between independent scientists, the industry, and the government has led to some of the greatest successes in fisheries management in recent years, and is essential to producing reliable, trusted, and broadly accepted stock assessments. This assessment not only fails to adhere to that proven model, but also takes a giant step backward in encouraging effective collaboration.

This assessment did not go through the appropriate peer review process, nor did it follow the process that was set up to handle precisely these kinds of updates. Gulf of Maine cod was not previously scheduled for an update assessment, the assessment was not conducted under the “operational assessment update” process previously established by the Science Center, and it lacked much of the information that would normally be included in an operational assessment update. The assessment did not go through the usual, established peer review channels, having been reviewed by an ad-hoc SSC panel rather than by the SARC. Of equal importance, there was no meaningful input or consultation from fishermen.

The Science Center also acted improperly by publicizing the results of the assessment before it had completed any peer review. This had the potential to bias the conclusion of the peer review panel, and certainly created the perception among many that it had in fact biased the outcome, further eroding trust in the impartiality of the assessment.

Faith in the integrity of the process is critical for the wider acceptance of the results of any stock assessment. When an assessment violates that process, it weakens the faith that fishermen have in both the assessment and the system, no matter how well intentioned the efforts. To conduct an assessment with such irregular and unprecedented methods on a species like Gulf of Maine cod, which is already mired in controversy and disputes over the veracity of its stock assessments, will only widen the fissures between management and the industry.

Flaws in the process of conducting this assessment has led to flaws in the assessment’s models and methods going unaddressed. There remain valid concerns about the assumptions used in the stock assessment model. These include assumptions about the natural mortality rate, the structure and boundaries of the Gulf of Maine cod stock, and rebuilding targets. There are concerns that some of these assumptions, especially with regards to natural mortality, are producing estimates that are inaccurate enough to be considered unreliable for management advice. Developments since the last cod assessment—such as insights suggesting that current stock boundaries should be redrawn—were not factored into this assessment but should be considered when determining future cod management measures.

Fishermen are currently being asked to accept an assessment whose administration and results they have good reasons to distrust, and for which several unaddressed concerns persist. Given the nature of how this assessment was developed, and the potentially dire consequences we face as a result of it, that skepticism is entirely warranted.

– Richie Canastra
BASE New England