New England groundfishermen are once again finding themselves caught between the fishery they are operating under today and the management system regulators expect them to use tomorrow.
More than a year after the New England Fishery Management Council submitted Amendment 25 and Framework 72 to NOAA Fisheries, both actions remain under federal review, leaving fishermen and sector managers trying to plan for a four-stock cod management system that has not yet been approved.
The situation has become increasingly frustrating because quota leasing decisions, catch accounting and fishing plans are already being influenced by a management structure that technically does not exist.
"It's difficult because we're managing both to the real allocation and the phantom upcoming allocation that doesn't actually exist yet," said sector manager Hank Soule.
For fishermen, the issue is not whether the transition to four cod stocks will happen. Most industry leaders support the change and expect it to move forward. The problem is the uncertainty surrounding when federal regulators will finally act.
"We're fishing on the promise of tomorrow's fish," said sector manager David Leveille.
Amendment 25 would change Atlantic cod management from the current two-stock system to four biologically distinct stocks, while Framework 72 would establish the catch limits and Annual Catch Entitlement allocations needed to implement the change.
Both Soule and Leveille support the move.
"It should have been done a long time ago. It's just better management of the stock,” Leveille said.
The challenge, they say, is that fishermen are already being asked to prepare for changes that remain stuck in the federal approval process.
One of the biggest concerns involves catch accounting under the future stock structure. Fish currently counted as Georges Bank cod in groundfish Statistical Area 521 would be reassigned under the new management system, requiring sectors to account for quota differently once Amendment 25 takes effect.
"We know this conversion is going to be made," Soule said. "We need to make sure that our fishermen do not exceed this upcoming quota."
As a result, sector managers are effectively tracking both current and future management systems at the same time.
The uncertainty is also creating challenges for quota leasing. Fishermen are trying to make decisions about allocations that could change once the new cod management structure is implemented, but no one outside of the federal government knows when that transition will occur.
"We never have any clarity until one day they announce it's going into the Federal Register," Soule said.
The delay has drawn comparisons to other recent Northeast management actions that spent months in federal review while fishermen waited for updated allocations and specifications.
Soule stated that sector allocations of Gulf of Maine and Georges Bank cod totaled roughly 332 metric tons last year. Under current default specifications, that combined allocation is about 228 metric tons.
Sector managers believe additional quota could become available once Amendment 25 and Framework 72 are finalized.
The concern is that a prolonged delay could eventually create operational challenges as the fishing year progresses.
"Right now it's easy because we're in the beginning of the year," Leveille said. "When you get around September, we're going to have a real problem."
National Fisherman asked NOAA Fisheries whether Amendment 25 and Framework 72 had moved beyond NOAA to other stages of federal review and whether the agency could provide an estimated timeline for completion.
In response, NOAA Fisheries communications specialist and public affairs officer Andrea Gomez said only that both actions remain under review. The agency did provide one clarification. "NOAA Fisheries intends for Amendment 25 to be finalized before Framework 72," Gomez said.
According to Gomez, NOAA has developed planning displays and quota-tracking tools to help sectors prepare for the transition, including an online ACE trading tool that allows managers to see how trades made under the current two-stock system would translate under the future four-stock structure.
For fishermen on the water, however, the larger issue remains unresolved.
After years of scientific review, council action and industry debate, few participants are questioning whether the four-stock cod model is coming. What fishermen want to know is when.
Until then, the fleet remains stuck between two management systems, making business decisions today based on regulations that have yet to be approved.
