Editors, Vineyard Gazette:
The following letter was sent to Gov. Deval Patrick from Cape and Islands Rep. Timothy Madden and Barnstable Fourth District Rep. Sarah K. Peake.
We are writing out of concern for the fishing industry on Cape Cod and the Islands, specifically for the fishermen who target conch in state waters in the commonwealth. It has come to our attention that there are proposed management changes to the conch fishery that are now being reviewed by your office. We are troubled by both the proposal and by the approach being taken by the Division of Marine Fisheries (DMF) to manage this fishery. Over recent years, this sustainable day-boat fishery has provided a crucial opportunity for many of our fishermen to be able to continue to fish. Many of our constituents have been forced out of other commercial fisheries by diminished fish stocks, the rising cost of fishing permits and ever-tightening restrictions. The conch fishery is now one of the top 10 highest-value commercial fisheries in Massachusetts. Because fishing effort has increased in the conch fishery, some managers and fishermen believe that changes in the management of this fishery are needed to ensure that the resource remains healthy and robust. We certainly support efforts to support a sustainable and profitable fishery. However, we feel strongly that any management changes must be based in science and on comprehensive information on the biological status of the conch resource. In addition, full consideration of the economic and social impacts of the proposed action must be studied and considered.
Currently, this has not happened so any changes in the management plan are premature and lacking a scientific basis. Conch management measures proposed recently by the Division of Marine Fisheries lack clearly-articulated management goals. We also note that a meaningful analysis of the economic and social outcomes that these actions will have on individual fishing businesses and on our coastal communities has not been undertaken. Finally, these measures lack a planned performance evaluation to determine whether these proposed measures will achieve their objective and what, if any, unintended consequences may occur. The commonwealth should not move forward to implement new management measures without these crucial components of science-based and responsible fisheries management. Therefore, we respectfully ask you to direct the Division of Marine Fisheries to take the following steps prior to identifying preferred management measures for this fishery:
• Work with commercial conch fishermen and stakeholders to define specific goals and objectives with regard to the conch management and fishery.
• Develop a fishery status report identifying potential biological, economic or management problems that currently exist.
• Conduct a comprehensive analysis of the conch resource including stock biomass, annual recruitment, relative size composition, specific growth rates and recent landings trends.
• Develop and initiate a cooperative research plan to partner with the fishing industry to address lingering biological questions to improve long-term conch management.
• Conduct and publicly present a thorough analysis of the biological, economic and social impacts of each proposed management alternative (e.g. a reduced minimum size or reduction in latent permits) so that each can be considered appropriately based on the best information.
Our shared goal of protecting the commonwealth’s marine resources and the marine fisheries depends on a deliberative and data-driven management process that includes active input from the affected commercial fishermen as well as other stakeholders at each step in the development of management measures. This input and analysis is crucial to ensuring a positive outcome for all. Thank you for your attention to this important matter. We are available to discuss this matter further with you.
Timothy Madden, Nantucket
Sarah Peake, Barnstable