THE PRECAUTIONARY PRINCIPLE PROJECT
ONLINE CONSULTATION
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From: Rob Cozens
Affiliation: Ocean Wildnerness Network
Remote Name: compression03.oak.mdsg-pacwest.com
Time: 16:09:17 +0100
[My testimony to the U.S. Pacific Fisheries Management Council may exceed 500 words. Skip past "*******" if you are not interested in background on the Ocean Wildnerness Network]
Agenda Item C.3.d
Public Comment June 2005 Ocean Wildnerness Network Testimony On Essential Fish Habitat
Rob Cozens, Strategic Intervention Coordinator
I am speaking on behalf of the Ocean Wilderness Network (OWN), a cooperative effort among nine organizations to build on existing national, state & regional efforts to establish a Pacific Coast network of marine reserves. Our mission is to secure an effective system of Marine Protected Areas on the Pacific Coast, including substantial fully protected areas, that protect biodiversity, maintain ecosystem integrity and contribute to sustaining fish populations and communities. OWN has previously submitted written comments supporting Council action to:
* increase protection of habitat that is essential to groundfish,
* minimize the effects of fishing on groundfish habitat & seafloor animals, and
* make it easier for fishermen to change to less destructive gear.
In addition, a number of OWN's member organizations [Environmental Defense, Marine Conservation Biology Institute, National Audubon Society, Natural Resources Defense Council, Oceana, The Ocean Conservancy, SeaWeb, The Surfrider Foundation, World Wildlife Fund] have shared, or will share with you, their unique perspectives and recommendations regarding EFH, HAPC, and other Alternatives presented in the DEIS. My remarks today represent the consensus of OWN's Executive Committee. *******
While our constituent organizations may favor different Alternatives, we are of like mind in advocating that a precautionary approach be employed as the Council determines its list of Preferred Alternatives. A precautionary management approach demands action to reduce potential threats even when scientific evidence is incomplete or not definitive. Coupled with adaptive management--the use of management measures explicitly designed to increase information, and the adjustment of management measures based on such information--precautionary management is the surest way to protect the productive capacity of fish stocks, the integrity of the ecosystems on which they depend, and the sustainability of fisheries. (I note parenthetically for your information that an IUCN Conference on precautionary management principles is underway through June 19th at <http://www.pprinciple.net/econference.html> ). Most particularly, we caution against allowing short-term socioeconomic issues to override precautionary management approach as you make decisions that affect the long-term health and productivity of groundfish EFH. While the temptation and pressures to do so are understandable, experience in other fisheries clearly shows this strategy fails everyone in the longer term. In From Abundance to Scarcity: A History of U. S. Marine Fisheries Policy, Michael Weber quotes former NOAA General Counsel, Eldon Greenberg,
I don't think we did a good job of managing New England groundfish...
I'm not sure they've ever done a good job in managing that fishery.
We did not impose the kind of strict management measures,
which in retrospect it seems clearly were needed.
Adopting a precautionary management approach as you deliberate will help Eastern Pacific groundfish escape the fate of their New England cousins.
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