Alexander Stone reefkeeper at
Wed Jan 9 13:39:17 EST 2002

*        R E E F  D I S P A T C H        *
*            January 10, 2002            *
* _____________________________________  *
*         ARE WE GOING TO GIVE UP        *

A Periodic Inside Look at a Coral Reef Issue from
Alexander Stone, ReefGuardian International Director

Dear Friend of Coral Reefs:

If you looked at catch statistics showing that your 1999 grouper fishery
landings had shrunk to less than 25% of what they were in 1985, would
you conclude that you were getting maximum sustainable yield from your
fishery? No? The U.S. Caribbean Fishery Management Council has.

If the last scientific analysis of your fishery had found that your reef
fish populations were continuing to be overexploited -- AND declining
landing trends since then confirmed that finding -- would you adopt
catch level rules that legitimized that status quo and doomed your
snapper and grouper stocks to depleted conditions? No?  The U.S.
Caribbean Fishery Management Council just did.

Is this what the situation must come to?  Do we have to throw up our
hands, give up on rebuilding our reef fish stocks to abundant levels,
and just hope we can keep the stocks from sliding any further down their
depletion path?  ReefGuardian says no.  And I hope you will say no too.

ReefGuardian International is challenging those proposed new reef fish
catch level rules for the U.S. Caribbean. We've formally petitioned the
National Marine Fisheries Service to reject them. And we're asking
groups and individuals to sign on to a rejection petition at
I hope you will do so.

The U.S. Caribbean Fishery Management Council recently approved new
levels of reef fish catch and fishing mortality to meet the Council's
legal requirements under the Magnuson-Stevens Fishery Conservation and
Management Act.  Under this federal law, fish stocks must be managed to
prevent overfishing, end overfishing where it is occurring, and
institute rebuilding plans for species that are overfished. Instead of
doing that, the approved reef fish catch levels would legitimize present
depleted reef fish populations and promote overfishing.

The National Marine Fisheries Service, the federal agency ultimately
responsible to Congress for overseeing Council actions and managing U.S.
fisheries, is reviewing those reef fish catch levels for possible
implementation in 2002.  ReefGuardian has formally petitioned the
National Marine Fisheries Service to reject the catch levels, which are
contained in proposed Amendment 3 to the Fishery Management Plan for the
Reef Fish Fishery of Puerto Rico and the U.S. Virgin Islands.

ReefGuardian has presented 3 major complaints against the proposed reef
fish catch rules, which you can read in full at

The fishery's latest stock assessment report, prepared by the Council's
own Scientific and Statistical Committee, concludes that "...there is
reasonable evidence to suggest that many [reef fish] species continue to
be overexploited."  This is the best scientific information available
for this fishery.  Under the Magnuson-Stevens Act, the proposed reef
fish catch rules violate National Standard Two of the Act by not being
based on that best scientific information available.

The Council assumed -- without providing any basis for the assumption --
that current catch rates and current reef fish population sizes are both
at Maximum Sustainable Yield levels.  That the evidence points to
overfishing was not even considered. Under the Magnuson-Stevens Act,
that means that the proposed reef fish catch rules violate National
Standard One of the Act because they will not prevent overfishing.

The Council approved the proposed reef fish catch rules without
presenting and evaluating ACTIONABLE alternative management measures
that could be compared against the proposed reef fish catch rules. And
that means that the National Environmental Policy Act was violated
because the Act requires that the Council consider a reasonable range of
actionable alternatives to any actions they propose.

It would be an understatement to say that I am flabbergasted by the
Council's actions. ReefGuardian warned Council staff and voting members
of these legal shortcomings not once but FOUR different times between
the first airing of the draft rules in June and the Council's approval
vote in August.  We are shocked and outraged. And I think you should be

We're doing the only thing we can do.  ReefGuardian International is
asking the National Marine Fisheries Service to immediately reject
Amendment 3 and its reef fish catch rules, and to direct the U.S.
Caribbean Fishery Management Council to begin development at once of
true sustainable catch rules for U.S. Caribbean reef fish.

I hope you'll join us in this demand by signing the petition at

Thanks for caring,

Alexander Stone
Executive Director
ReefGuardian International
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