It appears that NMFS may have to tweak its policy from using the best available science to the most recently available science.



A 2008 study showed a very optimistic outlook for Northeast cod, which jived with what fishermen were reporting. But the most recent stock study indicates a drastically different picture of the stock, which is in sharp contrast with what fishermen are reporting.



When so many livelihoods are caught in the balance between contradictory assessments, managers must take care rather than taking drastic measures. Unexplainable swings in a biomass that fishermen have been avoiding in order to allow it to rebuild on the 10-year guideline are not the best available science. The current assessment saddles the entire industry, from bureaucrats to managers to fishermen, with question marks that could bring down entire communities.



The catch shares program has wreaked havoc with small fishing businesses. Those prospering are businesses large enough to amass choke species quota. And now we are looking at yet another sound blow to the smaller boats.



NOAA director Jane Lubchenco has promised to take fishing families and economic effects into account when moving forward with measures the council and NMFS are legally required to take to keep the stock on its rebuilding deadline of 2014, which the assessment predicts would not be possible even with a total shutdown.



The New England council''s Science and Statistical Committee opted not to ratify the assessment, which will hopefully lend the council some flexibility in how it responds.



For the long term, groundfish fishermen can only hope that NMFS and the New England council can work to preserve working waterfronts while improving stock assessment tools, perhaps using sonar instead of modeling based on trawl surveys. Time will tell if cod has proven that sound scientific methods are not always accurate.

Thank you for your time.