Goethel Reads Statement into
NEFMC Record

Seabrook, New Hampshire fisherman, biologist and past New England Fisheries Management Council member David Goethel read into the record the following statement on October 2, 2014 at the full NEFMC meeting in Hyannis, MA

David Goethel. No ecosystem reference points were provided despite a binding vote of the council in April 2012 requesting them in all future assessments. Fishermen’s Voice photo

To: Mr. John Bullard, Dr. Bill Karp, Gene Martin, Esq.,

Gentlemen, I am addressing these comments to you and not the council because I believe you are the people that have to address the issue. From my perspective, as a scientist, NOAA committed two unpardonable sins with its press release on Gulf of Maine cod on August 1. Science was replaced with advocacy that day when statements were made about the condition of cod, and that immediate action must be taken after a secret, experimental stock status update before peer review. Indeed no supporting data was released for almost three weeks. The second sin was that fishermen in the Gulf of Maine were tried, convicted, and executed by their own government without one shred of evidence being offered. As someone who has always extolled science based management to fishermen as the proper way to move forward, my belief has been shaken to the core and cannot and will not be restored any time soon. I have struggled and continue to struggle with conveying to you the seriousness of this situation without appearing overtly hostile.

For the record, I feel the people who performed the assessment genuinely believe their results and that is the problem. I am here today to tell you unequivocally that what is described in this document is not what is being seen on the water. I believe the problems with the assessment, that all of us are witnessing, stem from an overreliance on the trawl survey combined with little fishery dependent data being available because the fishery was essentially shutdown by the last management action. Catch per unit effort data can no longer be used as a tuning index because the unreasonably high price of leased fish in so many of the stocks prevents fishermen from filling the quotas. This is being misinterpreted as lack of fish, when in fact vessels would drive themselves to bankruptcy catching cod, haddock, plaice, graysole and yellowtail all of which have lease prices that exceed their landed values even before accounting for the expenses of fishing. My son stated the problem succinctly in his PhD. dissertation, “Modelers must familiarize themselves first-hand with the realms they model”. If that had occurred in this assessment we would not be sitting here today.

My request, then, is that you pull this update back from consideration as advice for management and initiate the beginning of the benchmark assessment that is scheduled for 2015. Absent this being done, I must lay out for the administrative record the list of reasons that this process has not met the burden of National Standard 2, the so called best available science standard.

First, despite having a number of highly qualified cod scholars in New England this update was conducted in secret with input from only a handful of handpicked unknown people. Since none of those people were included or consulted none of the numerous, outstanding issues surrounding the last assessment were addressed or corrected.

Second the press release, wide dissemination, and extensive commentary made independent peer review impossible. To paraphrase Dr. Pat Sullivan chair of the review committee, there are problems with this assessment but if we reject it we will be seen as the people who gave up on Gulf of Maine cod.

Third, the information available to the reviewers and the public was insufficient to verify the results. Although several modelers were part of the review committee they had to request a science center employee do model runs at the end of the first day of the review because they had insufficient information to do tests in advance of the meeting. This violates the most basic tenet of science that sufficient information be provided so other scientists can verify the results.

Fourth the issue of M ramp and how M is going miraculously return to .2 next year was not scientifically explained. Miracles are the realm of religion, not science.

Fifth, issues related to outstanding cod assessment issues were dismissed with the statement that this is an update not a benchmark. This is particularly relevant to the stock boundary issue. Peer reviewed journal articles are now available which show through DNA analysis that cod off Rhode Island and in the Great South channel are Gulf of Maine not Georges Bank cod. If the stock boundaries are wrong, the management measures will unfairly penalize people in the Northern Gulf of Maine while sparing people in other regions. This violates National standard 4.

Sixth, No ecosystem reference points were provided despite a binding vote of the council in April 2012 requesting them in all future assessments.

Finally, although not part of the actual assessment, work by the councils plan development team has produced a second miracle to rebuild cod by 2024. With cod catches set essentially at zero they can only achieve the spawning stock biomass reference point by 37 to 40% annual growth for all of the next ten years. By their own words, F-rebuild projections may be overly optimistic. This is probably the understatement of the decade.

This is not an inclusive list of issues, but rather in the interest of time, a sample of outstanding issues surrounding this current process.

In order to end on a somewhat positive note I have brought with me a journal article from Marine Policy By P. Macdonald et al. titled “Fishers’ Knowledge as an indicator of spatial and temporal trends in abundance of commercial fish species” in which the authors describe and prove that fishermen are as good or better than modern analytical assessment methods in predicting current and near future trends in distribution and abundance of fish. I will leave the paper with the staff and would suggest everyone in this room should read it. We need experienced fishermen far more involved in the stock assessment process then they are now.

Thank you very much for your time.