NAMA Weighs In

To facilitate the transformations we seek, we often have to communicate with policy makers. Although sometimes we go solo, our goal is to join others who share our vision for the future of our oceans. Here are a collection of letters that lay out positions taken by NAMA and/or our projects on various issues from fisheries to persistent pollutants to climate change.

From time to time, we'll also upload supporting documents here that are not necessarily NAMA's.

In July 2009, the National Oceanic and Atmospheric Administration announced a new task force that would focus on the creation of Catch Shares systems of fisheries management. The Task Force opened the door for discussions with interested parties on the goals, purpose and process of developing a Catch Share policy for NOAA.

NAMA and our allies submitted a joint letter to the Task Force that focused on two of their stated primary objectives, which are the full consideration of Catch Shares in fisheries management plan amendments; and, Catch Share design for the best possible environmental and economic performance.

We continue to gather signatures, so if you are interested, please contact Boyce Thorne Miller at boyce@namanet.org.

In light of the severe risks posed by endosulfan and the numerous effective alternatives, over 30 organizations, including NAMA has renewed the call for the EPA to cancel all endosulfan registrations. Approximately 1.38 million pounds of endosulfan are used annually in the United States on a wide variety of crops including cotton, apples, tomatoes, potatoes, and tobacco. Like DDT and other organochlorines, endosulfan bioaccumulates in food chains; contaminates the oceans, food, and drinking water; and poisons children, farmworkers, fish and other wildlife. Endosulfan is so dangerous that it has been banned in over 60 countries, yet it continues to be widely used in the United States to control agricultural pests on a variety of fruit, vegetable and file crops.
To protect and ensure the recovery of the region's groundfish, NAMA once again calls on fisheries managers to prohibit industrial scale fishing for herring in areas closed to groundfishing. Herring are a critical food of the groundfish and evidence shows industrial herring vessels have bycatch of juvenile groundfish.
NAMA submitted these comments to the National Marine Fisheries expressing concerns that the proposed rules for implementing the provisions of the Magnuson-Stevens Reauthorization Act (MSRA) to address integration of the National Environmental Policy Act (NEPA) and fishery management processes could result in such significant failures that the best course is to abandon this rule and start over.
In December 2006, the Area Management Coalition (AMC), consisting of fishing community organizations, advocates and individual fishermen submitted a proposal to the New England Fisheries Management Council requesting that the Council fully analyze and consider Local Area Management as an alternative management system in the Amendment 16 to the New England groundfish plan's supplemental environmental impact statement (SEIS). The AMC believed this plan would lead to greater accountability, ecological sustainability, equitable management, and an enduring fishing industry throughout New England.
NAMA joins 27 other organizations to express our concern about pending revisions to the National Marine Fisheries Service’s (NMFS) regulatory guidelines on Confidentiality of Fisheries Statistics. The recent Obama Administration memorandum halting work on federal regulations left unfinished at the end of the Bush Administration includes the proposed rule on confidentiality of statistics, which has languished at the Fisheries Service for nearly two years. The groups urge NOAA to take the opportunity to thoughtfully review and revise as necessary the draft regulations to ensure that all proposed revisions support public access to fisheries observer data and other fisheries information to the maximum extent allowed by the Magnuson Stevens Fishery Conservation and Management Act (MSA). 16 U.S.C. 1801 et seq. Public access to such information is vital to ensure that fisheries management decisions are made in a manner consistent with public trust management of the nation’s marine resources.
The Northwest Atlantic Marine Alliance comments on the scoping process for Amendment 4 to the Herring FMP. The industrial herring fleet, which was invited into the Gulf of Maine by the federal government in the early 1990s and has expanded significantly since then, presents a particularly troublesome challenge to efforts of local fishing communities to bring back a healthy ecosystem that supports their traditional fisheries. These commercial fishermen are being asked or required time and time again to cut back or cease their normal fishing activities to allow the resource to recover. It’s taking longer than expected and even now more closures are being proposed. And yet, the Atlantic herring fishery is permitted to continue with little change in allowable catch and in what type of gear is taking the majority of the catch. While many community based fishermen are asked to give up their livelihoods to recover one fishery, others, many of them tied to the fiscally and physically mobile international fleet, continue un-hobbled because the New England Fishery Management Council and NMFS Northeast Regional Office fail to make the connections between one fishery and another. In this context, NAMA strongly believes that any areas closed to groundfish fishing should be closed to all fisheries except those that are known not to interact with or have bycatch of groundfish.
A coalition of consumer health, fishing and conservation organizations urge the Senate Committee on Commerce, Science and Transportation to reject language in section 19 of H.R. 4761, or any similar provisions, which could authorize the conversion of unused oil and gas platforms into fish farms. This “rigs to fish farms” provision could jeopardize consumer health and wild fish populations and it represents a give-away to oil and gas companies by allowing them to escape liability, removal and restoration costs associated with expired oil platforms.
NAMA urges the NOSB to reject the Proposed Organic Aquaculture Standards: Fish Feed and Related Management Issues, and Net Pens and Related Management Issues. The latest round of the development of Organic Aquaculture standards -- NOSB Livestock Committee Proposed Organic Aquaculture Standards for Net Pens and Fish Feed -- does not comply with organic principles. Adoption of both proposals would fatally undercut any proposed USDA organic aquaculture standard and we urge the full Board to reject them.
The deregulation of the chemical industry has hurt the United States just as much as the deregulation of Wall Street, with effects likely to last generations. Scientists, physicians, health advocates, worker organizations, parent groups, health-affected groups and many others view the fundamental reform to current chemical regulations and laws as urgent and necessary to protect children, workers, communities, and the environment now and in the future.