New England's Herring Problem

Updated April 3, 2005

An Example of One of the Herring Mid-Water Trawlers Now Fishing in New England Waters

The pictures above were taken from the Gulf of Maine Aquarium web site at The boat is the mid-water herring trawler, F/V Providian (fishing out of Portland, Maine) owned by Walter Raber and his son, Ryan. She is just shy of 113 feet long, has a beam of 40 feet, draws 18 feet of water and has a fish hold capacity of 20, 000 cubic feet. Launched late in 1998, she has been mid-water trawling for herring since and is quite commonly seen on the same fishing grounds where we catch our groundfish. The picture on the right was taken aboard the F/V Providian and shows her hauling back her nets.

Photo & Text by Tim Tower


The biggest challenge, as I see it, to the New England Fishery Management Council, the body that is responsible for managing the fishery off the coast of Maine, is the proper management of the herring stocks. Herring is the bait fish that all our best groundfish (cod, haddock, pollock, etc.), our marine mammals (whales and dolphins) and all our best pelagic fish (bluefin tuna, bluefish, striped bass, etc.) depend on for a food source. Without the healthy herring stocks, I believe our near coast groundfish and pelagic stocks will become unattainable. Right now there are about fourteen or more boats larger or smaller than the Providian (shown above) - and including the Providian - taking herring and mackerel from our waters at a rate that is too high for the fishery to withstand. The mid-water trawler bait fish fishery remains the most significant fishery detrimental to the recovery of our major New England fish stocks. The following represents the facts about this fishery in hopes that someone will wake up and realize what is going on before it is too late. Why the powers that be, including the New England Fishery Management Council, are not doing more to protect the herring stocks is beyond me. I urge anyone who is concerned about our fishery to let your Senators and Congressmen know about this issue and how important it is to everyone along our coast.

My goal is to keep this page updated as new things occur that relate to this problem.

Wednesday, February 2, 2005

At 5:30 AM EST, the air temperature was 12F, the wind was out of the northeast at less than ten knots, the sky was clear and the visibility was excellent. An hour later, the air temperature went down to 10F but then started to climb. The air temperature went over the freezing mark again and by noon, it was 35F. Temperatures stayed mild (or what seems mild) all day, the sky stayed clear and the visibility remained excellent. Add to this light winds out of the northeast (The top wind speed of the day was about fifteen knots - at noon. After that, and before, the wind was ten knots or less.) and you have a relaxing beautiful winter day in Maine. The high air temperature at the Portland International Jetport, Portland, Maine was 35F (with a low of 5F) today. In Gray, Maine the high was 37F (with a low of 15F). Concord, New Hampshire's high temperature was 39F (with a low of -4F).

I spent a significant amount of time working on completing the requirements needed to pass the fire inspection for the two Barnacle Billy's restaurants. My brother, Court, and I worked back and forth on this until it was done. Now all we have to do is get the Code Enforcement Officer and the Fire Chief down there to see that things are completed and both buildings in order.

Computer work and phone calls made up the rest of the day for me while Ian and Jared Keniston worked at the Bunny Clark.

At 7:00 PM, I met representatives from all the industry user groups for a meeting on how New England is going to eliminate the dirtiest fishery that has ever graced our waters, namely the herring mid-water trawling industry. Mid-water trawlers drag huge nets behind the boat (sometimes in tandem - with two boats towing a net that is larger than a single boat can haul). These nets have small mesh and will catch anything in it's path. The industry representatives at the meeting included herring seiners, tuna fishermen, recreational anglers, party/charter boats, hook (longline) fishermen, lobstermen, groundfishermen, whale watch groups, the Coastal Conservation Association and conservation groups (including the Conservation Law Foundation and Oceana). This is the first time I have seen so many groups of varied fishery related interests in the same room working together for the same goals. Our concern is that these herring trawlers are catching up the herring at an alarming rate and, in effect, are moving those fish that depend on herring as a food source out of the reach of every user group that is left along the coast. Not only that, but in so doing, the mid-water boats (most of which are over 100 feet long and as much as 150 feet long) are also catching everything else that feeds on the herring. These are some things that have been happening in this mid-water trawler herring fishery:

  • Since the mid-water trawlers showed up on Jeffrey's Ledge in 1991, the herring populations have declined at an alarming rate. Where before one could tell when they were on Jeffrey's by the enormous schools of herring found there, now, you are lucky to find a school of herring at all and, when you do, it's big news. Of course, Jeffrey's Ledge, as most of you know, is a closed area for commercial groundfish boats, a protected area so groundfish can live, grow and multiply with limited harvest. If there are no herring there, obviously, the fish will move where there are herring or where they can eat. This makes the idea of a groundfish protected area moot and moves these groundfish into areas that are commercially fished on a regular basis. Indeed, our tuna fishery almost ceased to exist in New England last season (a first - the tuna fishermen - the General Tuna Category specifically - never met the governments quota for total catch! This is the second year in a row that the tuna seiners and harpoon tuna boats did not meet their quota!), most of the tuna caught were found in Canadian waters where they have a sustainable fishery on herring (purse seine only).
  • The bycatch (other organisms that are caught with the herring) is huge. Tons of groundfish including haddock, cod and pollock have been caught with the herring. There were so many small haddock landed on so many occasions, lobstermen became used to seeing haddock in the barrels of herring bought to be used for lobster bait - I know, I was one of them. It was less than ten years ago that we (party boats) started to see the return of haddock to our waters. Can we allow these boats to undermine the haddock recovery efforts at this time? Can we afford it? No, we can't. Since the mid-water trawlers showed up in 1991, the numbers of small juvenile pollock have declined on Jeffreys Ledge. Large numbers of seals, some porpoises and a few whales have been killed in the process of catching herring by these boats. They caught so many dogfish (a Federally protected species of small shark) during the summer of 2004 that they had to hire lobster boats and the like to haul off large quantities of these fish to dump them. Federal enforcement doesn't know about this (or is turning a blind eye) even though it is common knowledge up and down the coast. Where there hasn't been a whiting fishery for years (whiting populations have declined to an unfishable level), whale watch boats are reporting seeing acres of dead whiting floating on the surface during the time that the mid-trawlers are working the area. When mid-water trawlers felt free to talk on the radio, I overheard trawler captains talking about ripping the belly out of their nets. The reason; these boats were towing so close to the bottom (where the groundfish and herring were) that they were catching their gear on unknown wrecks lying on the bottom! Indeed, last season, some of these boats were seen using eighteen inch rollers. You don't use rollers on dragging gear unless you are working the bottom.
  • There was talk around the table last night that of the herring that are caught and landed, this only represents about half of the herring killed. The reason for this is that regulations and market value prohibits landing herring in certain biological stages. In better times, I have heard these boats on the radio (again) talking about dumping a load of fish (tons of herring) because they were too small and had no market value. Every fish that is caught in the process is killed whether they are used or discarded. These herring don't go back alive. Tons of herring are dumped because they are "feedy", or the organisms that the herring are feeding on cause them to spoil too quickly so they shouldn't be taken. Herring are routinely dumped because they are in spawning condition. The law doesn't permit the taking of these fish. If caught, they are also dumped and killed. Such a waste.
  • Lobstermen have lost a lot of lobster traps, warps and buoys to these mid-water trawlers without being compensated. These trawlers will tow at night in areas close to shore where the lobstermen are fishing and run over set after set of gear. Lobster trap buoys don't show up on radar. When these traps are cut, they fish and potentially kill a lot of lobsters before the vents erode and drop out allowing lobsters to escape. Many lobsters will die as they are also cannibalistic. Left too long in the traps together, they will eat each other to survive. Also, wolffish will go into the traps after the lobsters, eat them and then die themselves because they too can't get out of the trap.
  • Government scientists tell us that there are plenty of herring left, diametrically opposing the views of every fisherman I know (except the mid-water trawler boys). And yet, in the last two years the Total Allowable Catch (TAC - the poundage of herring that can be harvested by law within a year) has been reduced from over 180,000 metric tons (a metric ton is approximately 2200 pounds), to 150,000 metric tons. It may be interesting to note that this mid-water trawler fleet has never reached a TAC of 150,000 metric tons of saleable herring. The key word here is saleable as you know that many more herring are killed than are counted. Last season they reached 92 metric tons. They peaked at about 120,000 metric tons in 2000 and possibly 2001 (I believe that more boats got into the fishery during those years) and it has declined every year after.
  • Observer coverage is scant. These trawlers are left to roam the ocean anywhere they want. Although there has been a call to have people aboard to monitor the activities of these boats (observers), the Federal government has only funded enough money to give us about 12 percent coverage and that has only happened recently. Of those observers, few are trained well enough to report what is really going on and none have been given the guidance to report the most significant facts. Face it, where are you going to find a person that is aware of all the little things that belong or don't belong in a fishery. Most observers don't have the time on the ocean it takes to know what to look for. In the end, the captain is going to couch the trip any way he sees fit in self preservation, with regard to the weather or concerning what is best for business.
The solution: We don't want to end the herring fishery. Herring are a viable source of protein, the best lobster bait and, fished correctly, a sustainable fishery that a fisherman should be able to make a living at. To this end, herring have been caught with seines for years without hurting the population and this is the way it should go. It is not necessary to cut back on the TAC if mid-water trawlers were prohibited from fishing. Seining is a clean fishery: bycatch is released to go back alive, unwanted herring (after or before close inspection) can be released alive if unwanted (it's in the herring fisherman's best interest anyway), seiners don't catch groundfish with some minor exceptions (and those fish can be released alive as well) and there is no gear conflict between the seiners and other user groups (fishermen).

What can we do about this problem? I don't know other than writing your Senators and Congressmen. When I come up with the best idea, I will put it on this page. Until then, know that we have a serious problem here that directly effects catching groundfish in New England. And remember, it's not just groundfish. It's tuna, it's other fish that eat herring, it's lobster bait, etc. etc. We need a sustainable fishery for herring. The mid-water trawling for herring is not such an industry.

Something else to think about: If the mid-water boats were to be stopped today, would there still be enough herring for a guy to make a living from seining? I'm not sure. If the mid-water trawling keeps going at this pace, there will come a time in the near future when no one will be able to catch a significant enough amount of herring from seining. I believe this. Unfortunately, we may get to this point.

Thursday, February 10, 2005

I came across a great article written by Michael Flaherty a recreational fisherman from Wareham, Massachusetts. The following is his article which appeared on Page A14 of the The Standard-Times on February 4, 2005. This is an excellent article:

Conflict of Interest Rife on Fishery Council

A recent article in The Standard-Times titled "Put Fishermen In Charge" that ran on Jan. 30 reported how several commercial fishermen from around the country attended a conference in California and then concluded that in order to find long-term solutions to conservation problems, they should be given more power. While I'm not familiar with how things operate in California, I am certain that the last thing commercial fishermen in New England need is yet more power.

For years now we have read how fishery management councils are rife with conflict of interest and that regulations resulting from them often amount to what is expected from a "fox in charge of the henhouse" management approach. It is claimed that this is especially true of the New England Fisheries Management Council. In fact, conflict of interest within the NEFMC has been documented in many newspaper articles, book chapters and most notably in the recent report by the Presidential Commission on Ocean Policy.

If anyone still doubts the degree to which commercial fishing industry conflict of interest is a real problem within the NEFMC, then they need look no further than the events that have shaped the council's proposed herring specifications for 2005 and 2006 fishing years.

Conflict of interest occurs when those who vote on fisheries issues have more than a 10 percent stake in the outcome. The following is a list of folks who have been active advisers on a joint herring advisory panel during NEFMC's herring specification process. They are listed here with the credentials they gave during their introductions. Al West - Stinson Seafood, Bumble Bee LLC; Bob Wescott - commercial fisherman for 36 years; Peter Moore - American Pelagic Association; Mary Beth Tooley - East Coast Pelagic Association; Dave Ellenton - Cape Seafoods (chairman of advisory panel); Jeff Reichle Lund's Fisheries, Cape May, N.J. and Garden State Seafood Association; Jim Kendall - New Bedford Seafood Consulting, working with Norpel; Rich Ruais - East Coast Tuna Association; Peter Mullen - herring fisherman; Bud Brown Coastal Conservation Association; Dave Turner - been in the herring business a long time. Clearly, more than a few folks on that list exceed a 10 percent financial stake in the outcome of this process. More importantly, they are more than simply advisers because each one of them actually has a vote in the outcome of the proposed herring specifications. Literally, many of these so-called advisers have been drafting and then voting on their own wish list of total allowable catch and quota allotments.

Consider the following remarks overheard at a herring advisory panel meeting and then look again at the list of advisers above. "With the exception of the Bumble Bee proposal, which is new, the council has already approved the East Coast Pelagic Association proposal and the American Pelagic Association proposal to move forward for further consideration in this amendment." This was stated by Lori Steele, NEFMC Herring Fishery Management Plan Coordinator, at a NEFMC Herring Advisory Panel Meeting on Aug. 20, 2004. Given the makeup and power of the herring advisory panel, it shouldn't surprise anyone to learn that they voted to double expected landings. In addition, they opted for the riskiest alternative on the table with regard to near-shore depletion of the resource. This was against the advice of the management council's own science and statistical committee. Clearly the commercial fishermen in charge of this process went out of their way not to take a prudent approach toward addressing long-term conservation issues of herring.

Even more disturbing were the discussions by the herring advisory panel regarding U.S. at sea processing quota. Here was the case where several herring processors (and fishermen who service them) voted monolithically to preemptively ban competition in the form of off-shore processing boats. Shore- side processors on the panel asserted publicly that they must be afforded protection from potential entry of off-shore processors. They argued that they simply could not compete with them due to the inherent lower costs of off-shore processing (no property taxes). I realize that New Bedford's economy does rely significantly on its many shore- side processing plants However, don't lower costs benefit consumers in the form of lower retail prices and better quality too since these off-shore processors are mobile and closer to the fish and fishermen? Aren't consumers everywhere valid stakeholders in this process as well? While the act of assembling in order to stifle competition may pass for advising on a NEFMC advisory panel, in the real world this is called "collusion" which is per se illegal and it carries serious anti-trust consequences. At least that's what I have learned in business school and also at employee awareness training for each job I've held whether it be within banking, defense contracting or telecommunications.

The council system is broken and it needs to be fixed. Folks can debate the existence of conflict of interest among the formal membership of the regional councils, however, there can be no doubt that "back-door" conflict of interest in the form of "voting advisers" definitely exists and indeed thrives today on the NEFMC. But don't take my word for it. Consider the public statement of Jim Kendall, a "voting adviser" with New Bedford Seafood Consulting, when he clarified for everyone during a herring advisory panel meeting how the system truly works "We all know damn well that what the advisers bring forward from here has a huge impact on how the committee, and finally the council, sees it. We all know that and we all know that everybody has been putting their mark in the sand and marking their places. You can look at the dates on the proposals and you can tell who wrote them just by looking at the dates. It's no secret and I don't know why we keep trying to bandy around about it. If my boats aren't in there then I'm going to fight you every damn inch of the way!" Mr. Kendall, a voting adviser representing Norpel at the NEFMC Herring Advisory Panel, said this at the Aug. 20, 2004 meeting.

Folks, I can't make this stuff up. The information that I have presented here is a matter of public record and available upon request from the NEFMC. Members of the 109th Congress who are working on the re-authorization of the Magnuson- Stevens Fishery and Conservation Act need to be mindful of the negative impact that conflict of interest clearly has on the current council system, and they must do what they can to eliminate it. Clearly, strengthening the role of council science and statistical committees in the decision making process would be a good step toward that end.

The End

Tim's Note: Something I wanted to mention before this, but didn't have the right introduction, was the fact that John Williamson's Maine seat on the NEFMC becomes vacant at the end of this term. John did an excellent job as a Council member. As is the SOP, Maine's Governor, John Baldacci (D), sends a list of individuals who he supports for this vacant seat to the Secretary of Commerce. This is supposed to take place on or before February 15, 2005. Basically, the choice for the seat is taken from the top of the list. The number one person on that list gets the seat. This means that everyone else on that list is, essentially, window dressing unless number one gets cold feet or, for some other reason, declines the position. It just so happens that Mary Beth Tooley, the Director of the East Coast Pelagic Association (i.e. basically a paid lobbyist for the mid-water herring fleet) is running for the seat. And, the word on the commercial fishing streets of Portland, Maine says that it's a done deal for her to get the number one position on the list and, thus, the seat. This would be a tremendous conflict of interest bordering on being illegal. To my knowledge (and this is only what I have heard), she is not well rounded in the New England fishery in general, has no concept of the needs of recreational fishermen and is concerned in only one thing: herring. Why shouldn't she be. I would urge any Maine resident who is concerned about this to call Dick Davies at the governor's office at 287-3531 and tell him that we need someone very much more well rounded to fill the position at the NEFMC level and please not allow Ms. Tooley to hold this seat. At this time, we need seat holders who can bring our fishery back to sustainable levels and not those interested in feathering their own beds. You might suggest that Bud Brown be given a closer look. He represents the Coastal Conservation Association, has grown up in Maine around the commercial fishing industry and is a recreational fisherman himself. His sole interest is in sustainable fisheries and my opinion is that he would do an excellent job for both the commercial and recreational fisherman alike and (the bottom line) wants to see the fish come back to New England. I can't recommend a person more highly suited for a seat. He has run for a Council seat two other times that I know of and has never been appointed. Lets see if we can get this management thing back on track.

Thursday, February 24, 2005

At 5:30 AM EST, the air temperature was 10F, the sky was clear, the wind was blowing out of the northwest lightly and the visibility was excellent. The air temperature warmed up to about 20F by mid morning but never cracked the 30F all day - a least in Maine. I was down in Rhode Island until 4:00 PM and it did reach 30F down there at one point. The sky was sunny all morning with clouds coming in at noon and overcast conditions after that. The ocean stayed calm (so I heard) all day with light winds from the east. The high air temperature at the Portland International Jetport, Portland, Maine was 22F (with a low of 2F) today. In Gray, Maine the high was 25F (with a low of 4F). Concord, New Hampshire's high temperature was 25F (with a low of -2F).

I attended a closed meeting of industry representatives in Warwick, Rhode Island today. The meeting started after noon and ended at 4:00 PM. It was designed as a meeting to give us a heads up on what the future of may look like with regards to regulation and the status of the New England groundfish stocks. Paul Howard, the Executive Director of the New England Fisheries Management Council gave us a presentation on our present management scheme and a look at mortality rates with a focus on cod. It turns out that cod are still over fished and it doesn't look like we are doing enough to curb this trend. Of course, if management of the cod stocks in it's present form isn't enough, the law suit against the National Marine Fisheries Service is still going on which means a judge could severely limit cod take to the point of stopping all fishing for cod - worst cast but a very real possibility. So the question remains; what do we as users do to protect our own? Allocation. In other words, (putting it very simply) there is only a finite total allowable quota of cod that can be caught. If we don't become proactive and secure of "piece of the pie" for our industry, other user groups may use it up. We want to be able to fish for our entire season and, basically, regulate ourselves and maintain a viable industry. With proper conservation, the cod should come back to produce a healthy fishery. Anyway, without going into too much detail, this was what the meeting was about.

I can tell you that it was a very excellent meeting with excellent discussions and a good choice of individuals (excluding myself, of course) to be involved. A lot was accomplished in a short well run meeting.

And then I got a copy of a letter that Rich Ruais, the Executive Director of the East Coast Tuna Association, wrote to our Regional Director, Patrica Kurkel. With permission, I have included it below. It would help if you wrote a letter to Ms. Kurkel expressing your concerns about the decline of our number one forage fish. Common sense, I would think, should tell you that if these mid-water trawlers are not landing the total allowable catch (TAC) that the optimum yield (OY) is much too high for this species. It seems ridiculous to me to have a closed area and then allow boats to come in and rape the bait resource (to put it mildly) in that area. Anyway, the letter follows. Anything you can do or write will help.

East Coast Tuna Association
P.O. Box 447, Salem, N.H. 03079
(603) 898-8862 Fax 898-2026

February 22, 2005

Patricia Kurkel, Regional Administrator
National Marine Fisheries Service
One Blackburn Drive
Gloucester, MA 01930
Re: Proposed Herring Specifications for 2005-2006

Dear Pat:

We believe the NMFS proposal to maintain the 2005-2006 herring quota specifications at 60,000 mt for Area 1A poses exceptionally high risk of further damaging the discrete inshore herring spawning stock and is also not consistent with the Council's adopted objectives to encourage development of underutilized herring resources on the offshore fishing grounds of Georges Bank.

Recognized herring scientists Dr. Vaughn Anthony and Dr. Andy Rosenberg have both stated publicly their views that 60,000 mt was too high for the inshore resource and the Council's Scientific and Statistical Committee formally reported on June 19, 2003 that "the current concentration of harvest in the inshore Gulf of Maine is of concern and may be excessive". If 60,000 mt annual TAC is "of concern" and "may be excessive" what damage to the discrete inshore spawning component was done by newly revised (and dramatically higher) reported catches from this resource of 83,303, 95,485, 88,069, 75,533 respectively for the years 1995, 1996, 1997 and 1999. These catches amount to 112,390 mt above the level of catch deemed risky for the inshore component by highly qualified scientists.

NMFS is also aware of the views of many herring purse seine, tuna fishermen, groundfish fishermen and whale watch naturalists that the Jeffrey's Ledge spawning stock has already been wiped out by the midwater trawl fleet similar to the "Trinity Ledge" (formerly the closest spawning/fishing grounds to Yarmouth, N.S.) stock collapse in Canadian waters. It is not a new phenomenon for near-shore sub-stocks to be damaged while offshore resources remain underutilized. The NMFS spring survey in 2003 and 2004 for the inshore grounds reported the lowest findings of herring both in number and weight since 1990. The inshore acoustic survey in 2002 provided evidence of a sharp drop in herring availability as well. We are shocked and puzzled by the NMFS proposal to continue this gross overfishing situation not for one more year, but for at least two more years.

Further, NMFS has been aware of a major disagreement between Canadian and U.S. estimates of biomass and likely MSY levels for the Atlantic herring resource complex. NMFS has chosen to essentially ignore the alternative Canadian stock assessment view in favor of the more optimistic (i.e. biomass 3 times the Canadian estimate) U.S. assessment but the passage of time is likely betraying that reality is closer to the Canadian perception of herring biomass.

Despite a very substantial buildup in domestic harvesting capacity including the introduction of 23 very large (e.g. 1 million lb. fish holds) and efficient single and pair midwater trawl fishing vessels, total U.S. herring landings peaked in 2001 at 121,332 mt. Despite a strong and increasing domestic (with chronic bait shortages) and international marketplace, landings have declined substantially since the peak and with the 2004 total catch representing nearly a 30% decline in production at 93,722.

The Canadian experience with searching for the theoretical incredible large biomass offshore has also been disappointing. Making an exception to a 25-year old ban on midwater gear, Canada issued one "experimental" permit authorizing midwater trawl gear for the deep water fishing grounds off Georges Bank with 100% observer coverage. The catches were reported to be so low, the vessel owners are contemplating not continuing the experiment.

The need for adequate forage in the Gulf of Maine is another reason to take a more conservative approach with TAC in coastal waters. The suspected collapse of the Jeffreys Ledge spawning component is also likely having impacts on species such as cod, haddock and other demersal finfish that depend upon herring eggs and brit (age 1 juveniles) for rebuilding and sustainability. Alternative sources of forage in the Gulf of Maine are scarce: populations of sand eels, mackerel and menhaden are not as available as they once were making herring more critical as NMFS rushes rebuilding plans for numerous species.

The EFH FEIS concludes that because of uncertainty associated with herring stock size, the amount of "surplus" herring available for forage for predators is unknown. This uncertainty should be ample motivation for a precautionary approach particularly for the inshore components already under heavy fishing pressure and where demand for forage for bluefin tuna, groundfish and mammals is high. The EFH also notes that in some years, spiny dogfish alone (in a so-called depressed stock condition) consumed more herring (e.g. 148,197 mt) then all sources of commercial fishing combined. The TAC for Area 1A should be reduced to provide the forage necessary for recovery and sustainability of equally important and mostly much more valuable fisheries.

These herring specifications violate, at least, two of the management objectives adopted by the New England Fishery Management Council in Amendment 1 to the Herring FMP:

2. Prevent the overfishing of discrete spawning components of Atlantic herring.

4. Provide for the orderly development of the herring fishery in inshore and offshore areas.

The proposed specifications by NMFS reduce the Council's OY recommendation from 180,000 mt to 150,000 mt to prevent any opportunity for TALFF to protect U.S. industry. It is particularly disappointing given the NMFS need to reduce the TAC that the entire reduction comes from offshore fishing grounds leaving coastal Area 1A with the largest TAC. This is perverse and obviously counterproductive to providing incentive to develop the offshore fishery and no doubt will exacerbate the "race for the fish" problem on coastal fishing grounds. We urge NMFS to reconsider and split the 30,000 mt reduction in OY between the inshore and offshore fishing grounds.

Finally, we are aware that these comments will at least serve the purpose of providing NMFS and NMFS scientists with evidence, including anecdotal evidence over several years, that the herring stock is in trouble in the Gulf of Maine.


Richard P. Ruais

Executive Director

CC: Dr. Bill Hogarth

Tuesday, March 8, 2005

I heard more good news today. A new mid-water trawler was recently launched - a boat of 140 feet. The other day they landed 800,000 pounds of mackerel. I can see it now; there will be no mackerel or herring at this rate. Please keep writing those letters!

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