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	<h2>Letter to National Marine Fisheries Service</h2>







	Dear Dr. Hogarth:<br /><br />I am writing to submit comments on the Notice of Intent that was recently issued (2/14/07) by the National Marine Fisheries Service on possible changes to National Standard 1 on Fishing. This is a critical time for the health of our oceans.&nbsp; Your leadership is vital for ensuring that our ocean ecosystems are protected and that ocean fish management is improved as your agency moves forward to issue rules for the reauthorized Magnuson-Stevens Fishery Conservation and Management Act (MSA).&nbsp; <br /><br />A strong and effective MSA is crucial for the sake of healthy oceans and the communities that depend on them. We believe that the revised National Standard 1 guidance should make the following changes in the way that your agency and regional councils conduct business:<br /><br />* Let science, not special interests, set fishing limits. Every regional council must have a strong, independent, technically proficient Science and Statistical Committee (SSC) that has the resources and data to make conservative, science-based decisions. Appointments to these councils should be tracked carefully by NMFS to ensure competence and independence. These committees should set science-based annual catch limits (ACL&rsquo;s) that incorporate a precautionary approach or buffers to keep fish stocks healthy or recovering from depletion with a high level of certainty. <br /><br />* Create accountability for overfishing. Managers should create clear, equitable, consistent, and concrete accountability measures that keep stocks out of trouble if annual catch limits are exceeded and conversely potentially reward fisheries in some cases where annual catches are under the limits. <br /><br />* Require fishermen to report their catch levels in an accurate, timely fashion. Without accurate, timely catch data, it&rsquo;s impossible to determine if a fish has been overfished. With this information, we can take the necessary steps to ensure that overfishing in our oceans is less likely to occur. To that end, data from each fishery should be collected online soon after landing the fish.&nbsp; <br /><br /><br />* Stop overfishing as quickly as possible. NMFS should maintain the10-year rebuilding requirement for recovering depleted fish stocks.&nbsp; Congress clearly considered and rejected changes to this requirement in the MSA reauthorization process.<br /><br />In sum, we are very pleased with the proposals that NMFS has considered so far.&nbsp; We hope to see as many of these good ideas embedded in the final regulations and guidance as possible.&nbsp; We have a unique opportunity to make a quantum jump in the way we manage our fisheries to protect our oceans and our fish.&nbsp; <br /><br /><br />Thank you,<br />