Comment by Environmental Defense Fund on XM12

Mark Grant Sector Policy Analyst Sustainable Fisheries Division, NMFS Gloucester, MA 01930 February 23, 2009 Dear Mr. Grant: On behalf of our over 500,000 members, Environmental Defense Fund (EDF) submits the following comments in support of the Georges Bank Cod Fixed Gear Sector (Fixed Gear Sector). We urge the National Marine Fisheries Service (NMFS) to approve their request of an allocation of Georges Bank cod for fishing year (FY) 2009. We thank you for the opportunity to comment. Sectors are a type of “catch share” program, which are proven to end overfishing, increase the productivity of a fishery, boost fishermen’s profits, and reduce the impact of fishing on the environment. By allocating a percentage of the scientifically allowable total catch to a sector, groups of fishermen are free to determine how they can most profitably fish within those limits and fish when the weather conditions are right. By limiting catch to a scientific determined level and removing regulations that lead to wasteful discards, a major problem in the groundfish fishery, sectors reward efficiency and reduce overcapitalization. They give fishermen the incentive to rebuild stocks and fish in a way that maximizes the long-term value of the fishery. For all of these reasons, we strongly support the continued operation of the Fixed Gear Sector. The Fixed Gear Sector has shown signs of success and the NMFS should support them for being proactive for developing a more environmentally responsible and more profitable way to fish. Fixed Gear Sector members are no longer contributing to overfishing of Georges Bank cod and are no longer forced to wastefully discard valuable cod. They are also voluntarily operating at a higher standard of monitoring, reporting, enforcement, and overall accountability, while keeping a small boat fleet active and on the water. This leadership has shaped the direction of groundfish management in New England and that is why the New England Fishery Management Council (NEFMC) is considering 17 new groundfish sector proposals in Amendment 16. We urge you to approve the request for an allocation of Georges Bank cod to the Fixed Gear Sector for FY 2009. Sectors address community and conservation needs and hold the key to solving overfishing in New England. Sincerely, Emilie Litsinger Project Manager, Oceans Program Environmental Defense Fund