Board of Selectmen
Town of Harwich
732 Main Street
Harwich, MA 02645

March 4,1999

Hon. Richard M. Daley, SECRETARY UNITED STATES DEPARTMENT OF COMMERCE
Mr. Jon C. Rittgers
Acting Regional Administrator
NATIONAL MARINE FISHERIES SERVICE
1 Blackburn Drive
Gloucester, MA 01930-2298

Re: Comments on Proposed Rule for Amendment 9 to the NE Multispecies FMP

Dear Secretary Daley and Mr. Rittgers:

The Town of Harwich, Massachusetts would like to take this opportunity to stress the importance of its small-boat fishing fleet to the community. Harwich is home to approximately 40 commercial fishing vessels, mostly 38 feet and under. Almost all are involved in single day hook fishing trips, mostly for groundfish. The hook fishery is renowned for having been environmentally sustainable and providing the finest quality fish to Cape Cod for hundreds of years.

The Magnuson-Stevens Fishery Conservation and Management Act requires fishery managers to consider social and economic factors in regulating fisheries and to take into account the importance of fishery resources to fishing communities in order to provide for the sustained participation of such communities, and to the extent practicable, minimize adverse economic impacts on such communities.

Besides the economic benefits of fishing to those directly involved, Harwich's fleet provides significant indirect benefits to the community. There is a long history of cultural interconnection between Cape Cod and its fishing industry. There aren't many other places in the world named for a fish. Cape Cod is a unique tourist area. "Quaintness" is what sets it apart -- and what makes it quaint are old Cape Cod ways that continue to this day. Key among these is a small-boat fishery for codfish, some aspects of which have not changes in hundreds of years. The small-boat fishery, most of which makes single day fishing trips, supplies the freshest, best quality fish to the family tables and restaurants of the area for residents and visitors alike.

Fishing regulations that adversely effect the small-boat fishery would have devastating consequences for Cape Cod after the summer visitors go home. There are a substantial number of people directly involved in small-boat fishing here. In addition to the fishermen themselves, the local fleet supports baiters, gear suppliers and repairers, fuel suppliers, boatyards, fish buyers/markets, consumers, shopkeepers, marine insurance agents, and banks, etc. who would all feel the pain of restrictions on the local fleet.

In an area without many other identifiable year round "industries," there is little besides fishing and tourism to support the local economy. Unemployment and attendant social distress, long a problem during Cape Cod winters, would be exacerbated. Despite an outward appearance of affluence, Harwich and other Cape Cod towns would experience economic and social suffering in a concentrated way that those from urban ports with more diverse year-round industrial bases might not feel.

The Town of Harwich feels very strongly about its small-boat hook fishing fleet and is very concerned about any regulations that would cause them discriminatory harm.

Very truly yours,

Sandra B. Daniels, Chairman
Peter Hughes
Dana DeCosta
Peter J. Luddy
Cyd Ziegler

cc.

The Honorable William Delahunt
1517 Longworth House Office Building
Washington, D.C. 20515

CAPT Paul J. Howard
Executive Director, New England Fishery Management Council
5 Broadway
Saugus, MA 01906-1036

MUNICIPAL POLICY RESOLUTION

At a special Town Meeting of the Town of Harwich was held in the High School gymnasium on October 27, 1994. At 7:00 P.M., a quorum had not assembled, so the meeting was not called to order until 7:15 P.M. At that time, with 362 registered voters attending, Michael D. Ford, Moderator, instructed the Town Clerk, Anita N. Doucette, to read the Warrant and return of Warrant. Afterwards, Tom Leach read the following Resolution:

WHERE AS:
THE NEW ENGLAND FISHERIES MANAGEMENT COUNCIL HAS MADE A PROPOSAL TO CLOSE THE ENTIRE FISHING GROUND EAST OF 70 DEGREES WEST LONGITUDE UNTIL FURTHER NTOICE DUE TO THE NON-SELECTIVE OVER HARVESTING OF GROUNDFISH BY U.S. FISHING VESSELS.

AND WHERE AS:
THE HOOK AND LINE FISHERIES OF HARWICH AND CHATHAM, MASSACHUSETTS HAVE SELECTIVELY HARVESTED QUALITY FISH AT MANAGEABLE LEVELS UNDER THE HOOK QUOTA.

AND WHERE AS:
THE RESULT WILL BE A CATASTROPHIC LOSS OF INCOME TO BE SUFFERED BY OVER 250 HOUSEHOLDS ON THE LOWER CAPE REPRESENTED DIRECTLY BY BOAT OPERATORS AND THEIR CREW MEMBERS OF ABOUT 100 FISHING VESSELS BETWEEN HARWICH AND CHATHAM.

AND WHERE AS:
IT IS BELIEVED THAT HEAVY EXPLOITATION BY DRAGGER FISHING, TOWING NETS INDISCRIMINATELY ACROSS THE OCEAN BOTTOM HAS BROUGHT US TO THIS STATE OF THE FISHERIES.

NOW IT BE RESOLVED THAT:
THIS HARWICH TOWN MEETING, OCTOBER 27, 1994 VOTES TO SUPPORT THE SELECTIVE HARVESTING OF GROUNDFISH BY THE HOOK AND LINE (TUB TRAWLING) METHOD ONLY IN THE AREA EAST OF 70 DEGREES WEST LONGITUDE TO LICENSED COMMERCIAL FISHING VESSELS UNDER FIFTY FEET LENGTH OVERALL.

This resolution is accepted and adopted, duly seconded, by the voters present at this October 27, 1994 Special Town Meeting.

Trawler impact must be faced


In regards to trawler impacts on the ocean bottom, the latest framework document of the New England Fishery Management Council states that "... the number of individuals in gravel areas was reduced by 48 percent following disturbance by bottom-tending mobile fishing gear, while the number of individuals in sand areas was only reduced by 5 percent. Similarly, the number of species present in gravel areas was reduced by 32 percent, while the number of species present in sand areas was reduced by 14 percent." It is my understanding that "individuals" refers to fish whereas the word "species" here refers to bottom vegetation. This does not give the impression of tires bouncing happily over cobblestone streets, the image Michael Matulaitis paints of "rockhopper" gear in his March 11 letter. Rockhoppers are a recent innovation used by trawlers to access very rocky areas which would have shredded their nets previously. The areas where marine vegetation is most prolific are the formerly untrawled areas. In other words, bouncing harmlessly over cobblestones is one thing, but driving a front-end loader through a vegetable garden is quite another. As the council moves to restrict cod mortality on Georges Bank and Nantucket shoals, it is faced with a vexing problem: poor recruitment. Recruitment is the success rate at which spawned fish grow to reproductive size. Fish need places to hide in order to avoid being eaten when they are very young. But now there is literally no place left to hide, and recruitment suffers. When recruitment suffers we (fishermen) all suffer. The plight of cod fishermen in Atlantic Canada and now the Gulf of Maine are good examples of this. Some have suggested that part of the recruitment problem involves trawler impacts on habitat. The trawlers are faced with a choice: to openly explore the issue and suggest knowledgeable ways to mitigate gear impacts, or deny the problem exists and let people who are not knowledgeable make sweeping rules and closures which affect all fishermen. The issue needs to be addressed one way or the other.
ERIC HESSE
West Barnstable

Trawlers having global impact


For a long time I have listened from the sidelines to the issues surrounding the collapse of the New England ground fishery. I have sat through talks at Woods Hole and read with interest articles about the impact of various types of fishing technique. The Cape Cod Hook Fishermen's Association is, of its nature, a self-interest group. However, it has attracted a special breed of fishermen who for the large part are concerned with keeping the ocean and its ecosystem intact. Many of these guys have left other styles of fishing to concentrate on this method of using lightweight line gear to settle lightly to the bottom for a few hours of slack in the tide, then retrieve their equipment. Nothing could be more environmentally sound. I've seen the videotapes showing the pounding that the bottom takes from heavy roller gear and chain sweeps of draggers, frothing up the vegetation from the sea bottom, and studied the U.S. Geologic Survey photographs comparing the dramatic difference between dragged bottom vs. unswept bottom. I was at the Woods Hole Oceanographic Institution in 1994 when the disturbing revelation was first spoken about how clouds of hydroids disturbed by dragging on the banks had a dramatic impact, devastating cod larvae. It wasn't fishermen showing us these things, but the impartial community of scientists. Not just some scientists think there is a problem. In a statement entitled "Troubled Waters," over 1,600 prominent scientists from 65 countries stated "bottom trawling is scouring continental shelf seabeds from the poles to the tropics." This is a global problem, not a gear dispute over who gets to use "the channel," as Michael Matulaitis intimates in his letter. He states that he has been fishing the same area for 20 years. While it may be true the areas that are fished today he fished 20 years ago, many of the areas that he used to fish 20 years ago no longer have fish there.
THOMAS LEACH
Harwich

No fish? Blame it on the seals


Seals are now the reason that groundfish stocks are unable to recover on Georges Bank and other fishing grounds, not the draggers and the dredges that have raped the ocean floor from Long Island to Canada. Not those who destroy millions of pounds of catch annually, and have the money and the political backing to perpetuate the destruction. Longline and jig fishermen employ methods that yield a bare minimum of the catch. Their trips last only a day. The quality of their fish is superior. They cause zero destruction to the habitat. But soon, longline and jig fishermen will become part of our past, when all methods of fishing will be treated as one, blamed as one for the extinction of the cod. Cape Cod will become like a neighborhood devoid of trees where all the streets have been named after the trees that were cut down to make room for the neighborhood. But in the meantime, let's go kill some seals. Maybe that will distract us from the truth for a little while longer.
GLEN WOODWORTH
Osterville