Businesses and governments have become quite accomplished at articulating impressive sounding mission and goal statements. Executives invest tremendous energy in communicating “their vision.” Unfortunately, organizations typically do not do the work necessary to align their actions with their high level goals. Organizations often fail to recognize the link between work processes and results, let alone the disconnect between carefully crafted enterprise goals and the unintended consequences of day-to-day behaviors.  

An example of a misalignment of goals is painfully evident in the New England Fisheries Industry where the current regulatory system is based on days at sea and daily quotas of landed fish. An unintended yet government sanctioned consequence of that system is that each day fishing boats dump thousands of pounds of dead fish back into the sea in the name of “conservation.”  The fishermen have been clamoring for a weekly quota system that would allow them to simply stay ashore after they reach their quotas, which would in fact result in fewer fish harvested, a cleaner marine environment, lower expenses and safer operations. The government rejected that proposal in favor of another management system. 

The National Oceanic and Atmospheric Administration (NOAA) under the Dept. of Commerce, with the full support of the Obama Administration, is instituting Catch Shares as the New England management system in May 2010 for the purpose of meeting the arbitrary target date of full stock recovery by 2014. In a classic example of the disconnect between goals and behaviors, NOAA is doing this despite the fact that 1) there is no scientific evidence that Catch Shares will speed stock recovery and 2) the multi-species fishing stock is already recovering, and in some cases recovered, under the current regulations. Additionally, there are certain “goals” and expected results of Catch Shares which are the polar opposite of our national goals. 

Let’s compare the Obama Administration high level goals with the goals and anticipated  results of the NOAA Catch Share policy:

1. 1.Promote small business
   

2. •Catch Shares is a business model designed to rapidly reduce the New England fleets by approximately 70%. This reduction is on top of the 80% fleet reduction over the past 15 years. Each fishing vessel is a small business. Directly and indirectly, reductions in the fleet have a profound negative impact on many other small businesses and the regional economy.
   
   

2. 2.Support individual and national financial independence
   

3. •The owners of the new fleet will be a few large license holders in a corporate commodities market - the type of market where “productivity” has a very narrow meaning. The American fishermen will either become employees earning less money or the new corporations will turn to third world fishermen to work their “American” boats, which may become increasingly foreign owned in much the same way American real estate has transferred to foreign control. 
   
   

3. 3.Protect the environment and husband our resources
   

4. •There is no scientific evidence that Catch Shares rebuilds fish stock or protects marine environments. However, remarkable innovations by American fisherman in fishing gear over the past decades do both. There is nothing to incentivize the financiers to use the environmentally sensitive gear. Additionally, Catch Shares will be replacing a system that is rebuilding stocks with expected full recovery in sight, albeit after the Congressionally legislated target date. Scientists, economists, environmentalists and fishermen agree that Catch Shares will have unintended and negative consequences.
   
   

4. 4.Quality food, locally produced
   

5. •Currently, due to our stringent regulations, 80% of the fish in America is imported. This percentage is expected to increase. Imported fish is often treated with chemicals or carbon monoxide to keep it “fresh.” Farmed fish frequently originates in polluted waters. The Catch Shares re-organization of the Fisheries will be as irreversible as is Corporate Farming, and some fear the negative repercussions will be even worse.
   

W. Edwards Deming said, “Management is always the problem.”  In this case, it is certainly true. The Catch Shares policy that is meant to manage the New England Fisheries is neither in alignment with our high level national goals nor likely to benefit anyone but speculative investors. Saying otherwise is simply untrue. 

The above is a public review comment submitted to NOAA on Catch Share policy.

View 16 March 2010 Catch Share Congressional Hearing.