Nils Stolpe/FishNet USA

December 18, 2016

Over the past several years there has been much discussion, debate, posturing, misrepresentation, exaggeration and incipient empire building on and around the subject of illegal, unreported and unregulated (IUU) fishing. Most of this has been driven by ENGOs and the mega-foundations that support them because they have all of these fish saviors on the payroll with, since the demise of overfishing, not an awful lot to do. Not surprisingly the Obama administration has been complicit in this.

Starting out with a point of clarification, IUU fishing is, or should be, a concern in some areas of the world’s oceans – but for reasons that I’ll get to an a bit, it isn’t, or shouldn’t be, in the U.S. Exclusive Economic Zone (EEZ). In spite of this you can bet dollars to donuts that that’s where all of the ENGOs will be focusing their IUU efforts, because it’s a lot more comfortable, convenient and safe to assault domestic fishermen from their cushy digs in Philadelphia or Washington DC than from some tropical or sub-tropical Hell hole where most of the IUU activity is based. And, I’m sure the feeling in those cushy digs in Philadelphia and Washington is that the public and the pols aren’t sophisticated enough to realize this, and in all likelihood – thanks to the mega-million dollar PR juggernaut that is backstopping their efforts – never will be.

That being the case, IUU fishing has become the boogeyman employed by the latest generation of “ocean saviors’ to keep the consuming public convinced that domestic fishermen shouldn’t be trusted, and to keep the millions of dollars needed to support their bloated bureaucracies rolling in.

Cutting through the hype – ‘cause what would an anti-fishing program in the U.S. be without the excessive and expensive hype? – how real is the threat of IUU fishing, who or what does it threaten, and how effective will the control measures that are touted by the anti-fishing ENGOs and directed against domestic fishermen be at doing anything substantive to protect U.S. fisheries or the millions of folks who still consume U.S. fish and shellfish?

Should there be any concern about IUU fishing in our federally managed EEZ fisheries?

Emphatically NO! U.S. commercial fishermen and U.S. commercial fisheries are among the most intensively managed in the world. What this means is any fish or shellfish caught out of season, caught in the wrong place, beyond a definite aggregate weight, of the wrong size, with the wrong gear, with the wrong gear on board, by a boat that is outside of specification, moved from boat to boat, landed at the wrong time or in the wrong place or out of compliance with any of a number of other restrictions is more than likely going to come to the attention of the state and federal authorities. When they do, significant penalties – ranging to hundreds of thousands of dollars in fines, loss of the right to fish, the confiscation of boats and catch, and imprisonment – can and almost always do ensue. Such big-brother-ish mechanisms as on-board observers, satellite tracking (of the fishing vessels, not yet of the fishermen), random and routine inspections at sea and at the dock, night vision optics and aerial surveillance are all used to detect illegal fishing. And, coupled with the significant penalties for infractions, they are effective deterrents.

And the Magnuson-Stevens Fishery Conservation and Management Act mandates that commercial fisheries be managed sustainably. That means that federal fisheries cannot be overfished or, if they are they must be managed with the goal of being rebuilt by a time certain.

(I’ll note here that a diminished fish stock can be declared “overfished” even when fishing is not the culprit. That and inadequate science seem to be the causes of the wildly seesawing summer flounder fishery that I reported on last month. With increasing ocean temperatures we can look forward to an increasing number of “overfished” stocks that are classified that way in spite of the fact that terminating fishing on them will have no impact on their classification.)

Buying domestically produced seafood that was harvested by federally licensed commercial fishermen is a guarantee that it was from a sustainable fishery. Traceability from the ocean to the plate won’t change that one iota.

Is increased traceability necessary to protect consumers of domestically produced seafood?

If it’s domestically harvested seafood, and if it’s harvested by licensed commercial fishermen, traceability will do nothing to make it safer.

Since 1997 the federal Food and Drug Administration has required that domestic businesses that process, handle or transport seafood in the U.S. adopt the Hazard Analysis and Critical Control Point (HACCP) management system. In the HACCP system “food safety is addressed through the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product” (http://www.fda.gov/Food/GuidanceRegulation/HACCP/). It “focuses on identifying and preventing hazards that could cause foodborne illnesses rather than relying on spot-checks of manufacturing processes of finished seafood products to ensure safety. FDA’s 1997 science-based HACCP regulations initiated a landmark program designed to increase the margin of safety that U.S. consumers already enjoyed and to reduce seafood related illnesses to the lowest possible levels,” (http://www.fda.gov/Food/GuidanceRegulation/HACCP/ucm114930.htm). As long as the seafood in question is “in the system” it works.

So it’s easy to write with full assurance that fish or shellfish harvested by permitted fishermen in U.S. waters is both sustainably harvested and safe for consumers, and no amount of traceability will make it either safer or “more sustainable.”

But where should increased seafood traceability be required?

There are some big oceans out there with an awful lot of boats and even more fishermen. The probability that all of their waters are going to be adequately policed and all of the fish and shellfish harvested from them are going to be adequately inspected in the foreseeable future hovers right around zero. But fortunately that’s not necessary to guarantee that the health of U.S. seafood consumers is protected or that fish and shellfish imported into the U.S. are harvested sustainably. All that’s required is the same level of rigorous policing of those fisheries and the same HACCP requirements – or their equivalent – that domestically produced seafood meets.

Alas, this is nowhere near the actual case.

From the Food and Water Watch 2016 report TOXIC BUFFET – How the TPP (Trans-Pacific Partnership) Trades Away Seafood Safety (http://www.foodandwaterwatch.org/sites/default/files/rpt_1609_tpp-fish-web_2.pdf)

• The FDA inspects only 2 percent of imported seafood; more than 5.3 billion pounds of seafood entered the U.S. food supply without even a cursory examination in 2015;
• Less than 1 percent of seafood imports are tested by the FDA at a laboratory for pathogens like Salmonella or Listeria or the presence of illegal veterinary drugs;
• Although few imports are examined, the FDA rejected 11 percent of inspected shipments for significant food safety problems;
• Salmonella, Listeria, filth and illegal veterinary medicines were the most common reasons that imported seafood was rejected; and
• The number of imports rejected for illegal veterinary drugs nearly tripled over the past decade, and made up one-fourth of all FDA refusals between 2014 and 2015.

(The fact that the Trans-Pacific Partnership is dead in the water doesn’t alter any of these points.)

So why is there a push for domestic seafood traceability?

Aside from being yet another  ENGO “make work” project, there isn’t any rational reason. By definition, domestically produced seafood is sustainable and our HACCP-based inspection system has proven to be virtually 100% effective. It’s difficult to look at the traceability efforts as anything more than another punitive measure by ENGOs and their corporate controllers to further burden an industry that is already overburdened by expensive, intrusive and largely unnecessary federal requirements.

And at the last minute….

NOAA/NMFS announced a new program on December 8 that “will trace specific fish and fish products from harvest to entry into U.S. commerce.” From the announcement:

“Today, the U.S. established additional protections for the national economy, global food security, and the sustainability of our shared ocean resources. NOAA Fisheries will administer the Seafood Import Monitoring Program to further curb Illegal, Unreported and Unregulated (IUU) fishing practices and to identify misrepresented seafood imports before they enter the U.S. market.

The program requires that importers report information and maintain records about the harvest, landing and chain of custody of imported fish and fish products for certain priority species identified as especially vulnerable to IUU fishing and seafood fraud. The program will eventually expand to include all species.”

The full announcement is at http://tinyurl.com/jyc5hrm (when I want to direct readers to web pages with prohibitively lengthy URLs I use the Tiny URL website – see the Wikipedia Tinyurl entry  at https://en.wikipedia.org/wiki/TinyURL – to generate a shorter URL that links to the original.

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More “falling skies” from Pew

The latest bits of doom and gloom in the oceans caused by commercial fisheries deals with so-called “forage species,” which is an interesting bit of media manipulation in and of itself, considering that in the oceans everything, alive or dead,  is eventually forage for something else. But then, with hundreds of millions of dollars from the Pew private bank on Philadelphia’s Main Line (https://www.glenmede.com/our-history) to spend, such manipulation can be frighteningly effective.

So, the latest Chicken Little initiative created by Pew’s stable of “ocean experts” involves Pacific sardines and anchovies.

From the Pew Trusts website:

New research suggests that the population of California anchovies—a critical food source for ocean wildlife such as whales, salmon, brown pelicans, and sea lions—has dwindled to levels not seen since the early 1950s. The research, funded in part by Pew (emphasis added), was conducted by scientists with the Farallon Institute for Advanced Ecosystem Research in Petaluma, California. The study, currently in press with the journal Fisheries Research, was also recently submitted to the Pacific Fishery Management Council. It concludes, “Although current annual catch levels of a few thousand tons are small by historical standards, current exploitation rates could be high given the low stock abundance, and should be taken under consideration by fishery managers.”

This latest expression of over-the-top hype is part of a major ongoing Pew initiative which has been in the making for at least five years.

With anchovies, sardines, menhaden and herring – which have all been anointed as uber-necessary forage species by the Pew claque – proposed restrictions have been predicated on the fact that their harvest negatively impacts populations of the critters that eat them.

Statistics on the harvest of these “forage” species are undoubtedly more reliable than they are for most commercial species because they are generally caught by a limited number of larger vessels and landed in only a handful of ports. Accordingly, they are much easier to keep track of.

Thus it would seem a simple matter for members of the Pew claque to come up with correlations between landings of “forage” species and fluctuations in the populations of the fish, marine mammals, birds or other critters that are supposed to be dependent on them. In an hour or so I can get the annual landings data for any commercially fished species, including these “forage” species, going back to 1950. It shouldn’t be much more trouble to collect the corresponding data for the landings of supposedly negatively impacted gamefish or populations of supposedly negatively impacted seals or whales or ospreys. Yet this hasn’t been done, or if it has been the Pew PR machine hasn’t shared any of the results with the rest of the world.

Once again borrowing from Wendy’s 1984 advertising campaign, “where’s the beef?”

Below is a piece I wrote back in 2012 on astroturf activism as it applies to the Pew forage fish initiative. While the focus then was on menhaden and herring, it has since grown to include anchovies and sardines.

The forage fish fake out

In a column urging that menhaden management be overhauled on the Pew Environment Group website,  Peter Baker wrote “according to a report issued this year by a panel of 13 eminent ocean scientists, forage fish are twice as valuable left in the water as they are caught in a net.” He is referring to the Lenfest Forage Fish Task Force. Forage fish include menhaden and herring.   

The people at the Pew Trusts and more lately the Pew Environment Group don’t like menhaden or herring fishing. That’s not very startling news. In fact, the people at the Pew Trusts/ Pew Environment Group don’t appear to like any kind of fishing, because they’ve spent hundreds of millions of dollars – of course, that’s hundreds of millions of dollars earned by someone else – to curtail fishing in just about any way, shape or form that fishing happens.

The way they’re expressing their dislike of forage fishing has become par for their course of expressing dislike of just about every other fishery; what appears to be a loose confederation of independent researchers and stakeholders and grass roots organizations coalesce into some sort of committee or task force or whatever united behind the righteous cause, which invariably involves either stopping or significantly cutting back some form(s) of fishing, supposedly saving some critical part of some ocean ecosystem or other.

But in the case of saving the East coast ecosystem from the depredations of the supposedly ruinous menhaden purse seiners, how independent are these saviors and the people like Peter Baker who are flogging their “cause?”

Peter Baker is the Director of the Northeast Fisheries Program of the Pew Environment Group. Prior to that he worked for the Cape Cod Commercial Hook Fishermen’s Association. Prior to that he was with the Sierra Club’s Environmental Public Education Campaign. Earthjustice, from which Oceana spun off, was spawned by the Sierra Club.

The Pew Trusts have given $1.5 million to the Cape Cod Commercial Hook Fishermen’s Association, at least $60 million to Oceana and over $23 million to Earthjustice.

I’ve written about the Herring Alliance on the FishTruth.net website at http://www.fishtruth.net/Herring.htm. The original member organizations had received well over $100 million from Pew.

Consider the projects funded by the Pew Trusts (available on the FishTruth website database at http://www.fishtruth.net/ENGO SPENDING.xls) designed to curtail menhaden/herring harvesting listed below. Herring and menhaden are both considered forage fish – fish that serve as food for other fish species – and, though all of the save the menhaden/herring rhetoric studiously ignores it, are also voracious predators of the early life stages of fish and shellfish species that feed on them as adults.

• 1998 – Conservation Law Foundation – $30,000 – “To promote responsible herring management.”
• 2004 – National Coalition for Marine Conservation – $558,000 – “To secure an amendment to the Interstate Menhaden Management Plan that would reduce or eliminate fishing of menhaden in the Chesapeake Bay, in order to protect the broader ecosystem of the Bay.”
• 2004 – Aquatic Farms Limited – $142,000 – “To assess the amount of competition between catch of small forage fish for direct human consumption and for reduction into fishmeal and fish oil for use as aquaculture and agriculture feed.”
• 2004 – Research Foundation of the State University of New York, Stony Brook – $750,000 – “To establish the Lenfest Forage Fish Task Force that will develop and recommend ecosystem-based standards for the sustainable management of forage fisheries.”
• 2004 – Research Foundation of the State University of New York, Stony Brook $145,000 – “To advance ecosystem-based fishery management by evaluating the status of understudied fish and other marine species in several regions of the United States that are impacted by the commercial fishing industry.”
• 2005 – National Coalition for Marine Conservation – $200,000 – “To ensure a new regulatory cap on the industrial harvest of Atlantic menhaden is implemented and enforced.”
• 2006 – National Coalition for Marine Conservation – $100,000 – “To support efforts to initiate new regulatory actions that will preserve adequate populations of forage fish which support healthy populations of predators, including numerous species of marine mammals, seabirds and fish.”
• 2006 – Gulf Restoration Network – $210,000 – “To support efforts to stop overfishing, secure conservation-based limits on unintended bycatch of marine life, and to conduct research and prepare a report on management reforms needed in the Gulf of Mexico menhaden fishery to reduce harvests to protect the forage needs of menhaden predators and reduce bycatch of sharks and marine mammals.”
• 2007 – Cape Cod Commercial Hook Fishermen’s Association – $180,000 – “To provide general operating support policy reform campaigns for herring and groundfish.”
• 2007 – Cape Cod Commercial Hook Fishermen’s Association – $596,000 – “To support a New England forage fish campaign to ban or severely restrict destructive trawling, reduce allowable herring catches.”
• 2008 – Research Foundation of the State University of New York, Stony Brook – $3,000,000 – “To conduct scientific research regarding sustainable fisheries management and conservation of threatened and endangered fish.”
• 2008 – Cape Cod Commercial Hook Fishermen’s Association – $722,000 – “To support activities to reform the Atlantic herring fishery.”
• 2008 – Earthjustice – $212,000 – “To reform New Englands Atlantic herring fishery.”
• 2008 – Marine Fish Conservation Network – $125,000 – “For work intended to ensure the full implementation of the Magnuson-Stevens Reauthorization Act and to promote the sustainable management of forage fish species ($100,000) and for general support ($25,000)”
• 2009 – National Coalition for Marine Conservation – $30,000 – “To develop guidance for conservation of forage fish through an ecosystem-based approach to fisheries management.”

That’s just under $7 million Pew dollars going directly to “save” menhaden and herring.

Of the thirteen “eminent ocean scientists”  on the Lenfest Forage Fish Task Force, nine can be directly tied to Pew funding via academic programs that have received well over $30 million in grants from the Pew Trusts, and four are Pew Marine Conservation Fellows to boot (see http://www.fishtruth.net/Pauly.htm and http://www.fishtruth.net/Pikitch.htm).

The source of funding for the Lenfest Forage Fish Task Force, the Lenfest Ocean Program, is administered by the Pew Environment Group.

The Project Director of the Lenfest Forage Fish Task Force is Christine Santora She was previously employed for five years as a Senior Research Associate with the Pew Institute for Ocean Science.

So we have two ostensibly “grass roots” initiatives supposedly representing the views of a large group of constituents but which are in reality the handiwork of a handful of activist organizations in large part – to the extent of tens of millions of dollars – supported by the Pew “Charitable” Trusts. The Pew Trusts were founded with dollars from Sun Oil’s Pew family and are still largely under the control of the Pew family.

“Astroturf roots” seems a much more accurate descriptor (and I was pleasantly surprised to see that Wikipedia has an entry for “astroturfing,” which it describes as “political, advertising or public relations campaigns that are designed to mask the sponsors of the message to give the appearance of coming from a disinterested, grassroots participant. Astroturfing is intended to give the statements the credibility of an independent entity by withholding information about the source’s financial connection.”)

Unfortunately, at its regularly scheduled meeting last week the Atlantic States Marine Fisheries Commission in what was an obvious bow to public pressure – pressure driven by mega-bucks foundations and the activist organizations they support – rather than sound science, voted for drastic cuts in the menhaden harvest.

The fishermen, the fish and the consuming public deserve much better.

This effort has now been expanded to include Pacific sardines and anchovies, involving the same people, the same unsubstantiated arguments, the same reliance on the fact that hardly anyone has any idea of what’s going under those waves, and the same overfull pots of foundation money. Diane Pleschner-Steeler, executive director of the California Wetfish Producers Association, has been engaged in a campaign to counter this latest chapter in the “we have to stop fishermen from ruining the world’s oceans” playbook. Her most recent effort was an opinion piece in the Monterey Herald titled Extremists manufacture anchovy ‘crisis’ where none exists. It’s at http://tinyurl.com/grpgsup and I strongly recommend you read it, because no one can predict which fishery is going to be targeted next.

An afterword –

I studiously avoid any appearance of politics in FishNet. Fisheries issues are far too complex and much too easily misunderstood without the addition of any further complications, and rest assured that this afterword has nothing to do with the presidential election. What it does have to do with is a compelling demonstration of the fallibility, the out-of-touchedness, the arrogance and the ignorance that permeates our mass media today.

The graphic below was posted on the New York Times website in The Upshot: Who will be President by Josh Katz on November 8 at 10:20 pm. It’s hard to imagine any exercise in prediction being more wrong than the New York Times was here. Going by the election results and a lot of the post-election analysis, Ms. Clinton apparently never had much of a chance of winning. This is the newspaper with the motto “all the news that’s fit to print” displayed on the front page every day, the newspaper with the second largest circulation in the U.S.

So what does this have to do with fishing? For at least the past 30 years the New York Times has been “reporting” on fisheries issues with the same degree of accuracy and inattention to reality that it brought to its coverage of the recently concluded presidential election. Swallowing the doom and gloom predictions of a few foundations and a handful of ENGOs hook, line and sinker, the Times – and a handful of other influential publications – have presented a one-sided view of fisheries issues and have for the most part sloughed off any attempts to have any distortions corrected. We can only hope that in the future Times’ readers will bear in mind just how capable the Times can be of printing news that is about as far as possible from being fit to print.

Last year I wrote After 35 years of NOAA/NMFS fisheries management, how are they doing? How are we doing because of their efforts? (http://www.fishnet-usa.com/After        35 years of NOAA.pdf) I concluded with:

Our collective fisheries were never as badly off as grandstanding ENGOs convinced the public and our lawmakers that they were. Regardless of that, they are unquestionably in great shape now. Are the fishermen – the only people who have paid a price for that recovery – going to profit from it? At this point there aren’t a lot of indications that they are going to. Ill-conceived amendments to the Magnuson Act, the ongoing foundation-funded campaign to marginalize fishermen and to hold them victims of inadequate science, and a management regime that is focused solely on the health of the fish stocks and is indifferent to the plight of the fishermen effectively prevent that.

That having been a year ago, and statistics measuring the performance of our commercial fisheries for 2011 being available (http://www.st.nmfs.noaa.gov/st1/commercial/landings/annual_landings.html), I thought I’d check back to see what, if anything, had changed.

Nationally, the total adjusted (to 2010 dollars) value of landings continued a gradual upswing that’s gone on intermittently since 2002/03. The post Magnuson (1976) low point in 2002 was under $4 billion, and by 2011 it had risen to over $5 billion, an increase of 35%. The adjusted value of the 2011 catch, $5.176 billion, was 76% of the highest total catch (in 1979) of $6.83 billion and 22%  above the average landings (from 1950 to 2011) of $4.25 billion.

All in all, the big picture is mostly positive. Unfortunately, the big picture is made up of a lot of smaller pictures, and some of them aren’t so good.

In the following chart I separated the value of the total landings in Alaska and the separate values of landings in American lobster, sea scallops and Southern shrimp (all species combined) from all other species.

For total value of landings in 2011 Alaska is at about 70% of where it was at its post Magnuson high ($1.84 billion vs $2.58 billion). Atlantic sea scallops were at their all-time record value ($485 million) and American lobster were at 89% of their all-time high ($405 million vs $456 million in 2005). Unfortunately the 2011 (Southern) shrimp landings were valued at only 34% of what they were at their highest ($472 million vs $1.333 billion in 1979).

In 1950 the Bureau of Commercial Fisheries reported landings of 223 distinct species or species groups (i.e. Shrimp, Dendrobranchiata  ). In 2011 the National Marine Fisheries Service reported landings of 460 species or species groups.
The 20 most valuable fisheries in 1950 and in 2011 and the percentage of their value to the total value of landings for that year are listed below:

In the Mid-Atlantic in 2011 the total value of landings, $220 million, were 79% of the highest landings value reported ($279 million in 1979). However, sea scallops made up more than half of the total landings value (56%, $143 million v. $114 million). While the overall picture looks positive, the value of the landings in the Mid-Atlantic minus the sea scallop production have been in a steady decline since the late 90s and are at the lowest point ever.

In New England the situation is comparable, but both American lobster and sea scallop production are responsible for the overall “healthy” appearance. There was a slight upswing in the value of the other fisheries in recent years but it appears that with the planned – and in part implemented – reductions in the groundfish TAC, it seems as if this slight upswing won’t carry over.

 

Conservation and management measures shall, consistent with the conservation requirements of this Act (including the prevention of overfishing and rebuilding of overfished stocks), take into account the importance of fishery resources to fishing communities in order to (A) provide for the sustained participation of such communities, and (B) to the extent practicable, minimize adverse economic impacts on such communities. National Standard #8, Magnuson-Steven Fisheries Conservation and Management Act (As amended through October 11, 1996).

A looming problem in both the Mid-Atlantic and New England is a pending cutback in the sea scallop quota for the next fishing year that at this point is expected to approach 40%. While the effects of a cut of this magnitude will obviously be significant to the scallop fleet, there will be not so obvious but potentially devastating effects on the other fisheries and on fishing communities as well.

A complex of ancillary businesses is required to operate a commercial fishing dock. These include vessel/equipment maintenance and repair facilities, ice plants, chandleries and shippers/truckers. Obviously it requires a certain level of business – a minimum amount of revenue coming “across the dock” –  for them to stay open. In the Mid-Atlantic a 40% cut in scallop revenues will be more than a 20% cut in commercial fishing revenues in a single year. In New England it will be somewhat less than that, but it will be combined with whatever additional cuts result from the proposed groundfish cuts.

I’m not that familiar with all of the fishing ports in the Mid-Atlantic and New England but have a fairly good understanding of those in New Jersey, and in New Jersey there isn’t one commercial port that lands fish from the ocean-going fleet that is mostly – or even largely – focused on scallops. They all handle a mix of fish and shellfish. A large part of their longevity is due to the fact that they have maintained a reasonable amount of flexibility thanks to their diverse fleets. But a drastic cutback in scallop revenues, particularly if it is coupled with the continuing decline in the revenues from other fisheries, will threaten that longevity.

The proposed scallop cutback has been presented as a temporary  measure, and the Fisheries Survival Fund – representing the majority of limited access scallop fishermen in New England and the Mid-Atlantic and other industry groups are working to ameliorate the proposed cuts, but when it comes to businesses that are waterfront dependent a two year temporary reduction could easily become permanent before the cutbacks are restored. Except for the lull over the past several years there have been intense development pressures at the Jersey Shore and on most of the waterfront areas from Cape Hatteras North. It’s just about assured that they will be back to their customary levels very shortly.

Originally the Magnuson Act placed much more emphasis on business- and community-supportive aspects of federal fisheries management. Those aspects have been eroded by the lobbying activities of the handful of ENGOs that have come to dominate the world of fisheries/oceans activism. They, and for the most part NOAA/NMFS  as well, address fish issues on a case by case, species by species basis. More importantly, the people at NOAA/NMFS tend to shy away from cumulative economic impacts when they have analyses done, and cumulative impacts are what most of the commercial fishermen, the people who depend on them and the businesses they support have to deal with – and in New England and the Mid-Atlantic (at least, and this isn’t to slight the industry elsewhere, because I doubt that it’s different in many other ports) in spite of increasing total landings value, it could be getting a lot worse really soon.

Comment here

Nils Stolpe is our Honored Guest. Click on the fishnetUSA icon to open the window to his website.

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Towards rationalit​y in fisheries management​/FishNet USA

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Bearing in mind that each edition of The Economist has a print circulation of about 1.5 million, its website attracts about 8 million visitors each month, and that the people who read it are among the world’s most influential, consider the “take home” message that anyone with little or no knowledge of fisheries – maybe 99% of the readers – is being given; that stability of production in a fishery is an indication  of overfishing, and even more importantly, that overfishing is unacceptable because it limits  production.
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Now we all know that sustainability is the managers’ goal in our fisheries. In fact, this goal is part of the legal underpinnings of each of the fisheries management plans in effect in – and sometimes beyond – the US Exclusive Economic Zone.
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According to the legislation controlling fisheries management in US federal waters, the first National Standard for Fishery Conservation and Management is that “conservation and management measures shall prevent overfishing while achieving, on a continuing basis, the optimum yield from each fishery for the United States fishing industry.”  This is fine up to a point. The optimum yield from a fishery is defined in the Act as “(A) the amount of fish which will provide the greatest overall benefit to the Nation, particularly with respect to food production and recreational opportunities, and taking into account the protection of marine ecosystems; (B) is prescribed as such on the basis of the maximum sustainable yield from the fishery, as reduced by any relevant economic, social, or ecological factor.” No problems so far, the law recognizes that the optimum harvest from a fishery is not necessarily the maximum sustainable harvest.But then we have “(C) in the case of an overfished fishery, provides for rebuilding to a level consistent with producing the maximum sustainable yield (MSY) in such fishery.”
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Adding their interpretation to this, the people at NOAA/NMFS, with the enthusiastic support of the various and sundry anti-fishing activists who pull way too many of the strings in Washington, have added as an administrative guideline that “the most important limitation on the specification of OY (optimum yield) is that the choice of OY and the conservation and  management measures proposed to achieve it must  prevent overfishing.”

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So while OY from each fishery, determined with consideration given to relevant economic, social, or ecological factors, seems to be the goal of federal fisheries management, that is just window dressing. The real requirement is for each and every fishery to be at MSY.

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From an administrative perspective, a perspective that has far more to do with the influence that the aforementioned activists had and continue to have than on the real-world needs of commercial and recreational fishermen and the communities and businesses that they support, this probably makes a certain amount of sense. After all, who could possibly argue about every fishery faithfully producing at maximum levels year after year? As the people at The Economist, at the ENGOs whose bank accounts are bloated with mega-foundation cash, and in the offices of Members of Congress who don’t have – or who don’t value – working fishermen as constituents want to convince us all, overfishing is something akin to the eighth deadly sin.

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But is it?

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From a real world perspective, a perspective that is shared by an increasing number of people who are knowledgeable about the oceans and their fisheries and who value the traditions and the communities that have grown up around them as well as the economic activity that fisheries are capable of producing, this proscription against “overfishing” is an ongoing train wreck.

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And at this point, because it’s The Law, nothing can be done about it.

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A hypothetical situation:

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Suppose there was an important fishery that was the basis of a large part of the coastal economy as well as the cultural cement that held coastal communities together. Then suppose that fishery started to decline. If you were a fishery manager and you were in charge, what would you do? Though not in what should be the real world, that’s a simple question with an even more simple answer in today’s world of federal fisheries management. Regardless of any other factors you would cut back on fishing effort.

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Suppose that didn’t work, suppose that the fishery continued to decline. What would you do then? Because you have no other realistic options you’d cut back on fishing effort even more.

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And suppose even that didn’t work. If there were still any fishermen fishing, you’d cut back their fishing effort yet again. And again and again and again until you had gotten rid of them all, in spite of whether the cutbacks had any noticeable effects of the fish or not.

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As we saw above, this would all be based on a so-called fishery management “plan” that was created under the strict requirements of a surprisingly short and what has become an even more surprisingly short sighted bit of federal legislation and the administrative interpretation of that legislation. The Magnuson-Stevens Fisheries Conservation and Management Act (MSFCMA) – which was written initially with good intentions towards US fishermen and signed into law in 1976 – has been purposefully distorted by outside groups and individuals with no legitimate ties to or empathy with the businesses and people dependent on fishing but with huge budgets provided by mega-foundations which themselves are provided with a convenient government-supplied coordinating mechanism (See http://www.fishnet-usa.com/All%20Stolpe%20Columns.htm#CGBD).

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Why is it a “so-called” management plan? Back a few more years than I’d like to acknowledge I spent some time in the graduate planning department at Rutgers University, concentrating on environmental planning. Not too surprisingly, one of the topics that came up repeatedly was rational planning; what it is and how to do it. Putting together a bunch of definitions and some foggy recollections, in creating a rational plan you 1) define a problem or a goal, 2) design                  alternative actions to solve the problem/achieve the goal, 3) evaluate each alternative action, 4) chose and implement the “best” alternative action, and 5) monitor/evaluate the outcome and adjust if necessary.

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This seems pretty simple and straightforward. How does it apply to fisheries management plans? If the problem with the New England groundfish fishery is that there are people making a living based on harvesting groundfish and if the goal is to stop them from doing that, then the managers and the management plan are right on target. But I suspect that most involved individuals/organizations aren’t purposely planning to solve that problem/achieve that goal.

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So why, after a seemingly endless series of less groundfish can only be fixed by less groundfish fishing iterations, are the groundfish fishermen – those who are still working – and the communities that depend on them just barely hanging on with fewer fish to catch following each cutback in fishing effort?

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While this idea is going to be ridiculed by all of  those anti-fishing activists whose careers are predicated on blaming just about every ocean ill on overfishing, perhaps it’s because overfishing isn’t the problem that they’ve built multimillion dollar empires on by convincing the world – and the U.S. Congress – that it is.

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But for the moment let’s pretend that we don’t have a fisheries management system that has been torqued into something worse than ineffectuality by their lobbying clout. Let’s pretend that the people responsible for creating fisheries management plans in general and the groundfish plan – actually the multispecies plan – in particular were trying to do some rational planning. Where would they go from here?

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What about competition between species?

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Obviously, having lived with the effectiveness – or  the lack thereof – of continuously cutting back on groundfish fishing, they’d look for an alternative or two (and no, opening parts of several previously closed areas of the EEZ while demanding full-time, industry paid observer on every vessel that fishes in them isn’t anything approaching a reasonable alternative). It’s hard to imagine that early on they wouldn’t consider the idea that other, competing species might be in part responsible for declining stocks. That’s the way the natural world has worked,  is working and will continue to work.

1953 – Spiny dogfish biomass unknown – “Voracious almost beyond belief, the dogfish entirely deserves its bad reputation. Not only does it harry and drive off mackerel, herring, and even fish as large as cod and haddock, but it destroys vast numbers of them. Again and again fishermen have described packs of dogs dashing among schools of mackerel, and even attacking them within the seines, biting through the net, and releasing such of the catch as escapes them. At one time or another they prey on practically all species of Gulf of Maine fish smaller than themselves, and squid are also a regular article of diet whenever they are found.” (Fishes of the                      Gulf of Maine, Bigelow, H.B. and W.C. Schroeder)

About ten years ago fishermen started complaining about the impact that the huge numbers of spiny dogfish off our coast were having on other much more valuable fisheries. As a result I organized a workshop on spiny dogfish/fisheries interactions in September of 2008 (see A Plague of Dogfish at http://www.fishnet-usa.com/dogforum1.htm) and have attempted to keep informed of spiny dogfish biology since then. One of the ways that I do this is by keeping an eye on things like landings and survey data, which NOAA/NMFS makes readily available via various web pages.

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Among the most interesting data sets I have found are the reports of the bottom trawl surveys which have been carried out by Northeast Fisheries Science Center vessels every year for over half a century (to access the recent reports go to http://www.nefsc.noaa.gov/femad/ecosurvey/mainpage/  and click on “Cruise Results” in the menu on the left). The assumed reliability and reproducibility of these surveys is such that they are one of the primary data sources in the stock assessments for many of our important fisheries. In recent years spiny dogfish at times have comprised upwards of 50% by weight of all of the fish taken in these surveys.

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Looking for another way of addressing the spiny dogfish situation, I put together a spreadsheet of the percentage (by weight) of spiny dogfish and Atlantic cod caught in the Spring and Autumn bottom trawl surveys for the last ten years and graphed the results (because the annual Winter survey was discontinued half way through this time period, I omitted it).

I was surprised to see how well the high abundance levels of spiny dogfish coincided with the low abundance levels of Atlantic cod – the primary groundfish species – and vice versa. (Note that this relationship wasn’t apparent in prior years.)
It seems in-your-face obvious that in recent years there been something going on between spiny dogfish and Atlantic cod abundance (I looked at the trawl survey results for a number of other species relative to spiny dogfish and none of them exhibited such a dramatic apparent relationship).

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Of course this could be an example of post hoc ergo propter hoc (basically correlation doesn’t equal causation). But then again, it could not as well.

1992 – Spiny dogfish biomass estimated at 735 thousand metric tons: “given the current high abundance of skates and dogfish, it may not be possible to increase gadoid (cod and haddock) and flounder abundance without `extracting’ some of the current standing stock.” (Murawski and Idoine, Multi species size composition: A conservative property of exploited fishery systems in Journal of Northwest Atlantic Fishery Science, Volume 14: 79-85)

James Sulikowski at the University of New England in Biddeford, Maine has been intensively involved in shark and ray research for twenty years. He is currently focusing on spiny dogfish and along with population and distribution work has begun to look at prey and predation. According to Dr. Sulikowski “preliminary analysis of stomach content data suggest  a high degree of dietary overlap between dogfish and Atlantic cod as Atlantic herring, Cluepea harengus, was found to be the primary prey item of both species. In addition, preliminary stable isotope data suggests evidence of niche overlap between cod and dogfish, although the extent of overlap may change seasonally. Collectively, the stomach content and stable isotope data suggests dogfish and cod are in competition for resources within this ecosystem.”

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How does this apply to the current Northeast Multispecies (groundfish) Fisheries Management Plan?

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In fact, it doesn’t apply at all. The multispecies plan is based on the assumption that fishing is the only thing influencing the groundfish stocks – including Atlantic cod. Considering that fishing is the only thing that federal legislation permits the New England Fishery Management Council to manage, its members have become quite adept at managing it. The fact that an extensive and still ongoing series of fishing cutbacks hasn’t stopped the decline of the primary groundfish species – led by Atlantic cod – seems to be irrelevant to them doing that.

1994 – Spiny dogfish biomass estimated as 514 thousand metric tons: “…preliminary calculations indicated that the biomass of commercially important species consumed by spiny dogfish was comparable to the amount harvested by man. Accordingly, the impact of spiny dogfish consumption on other species should be considered in establishing harvesting policies for this species.” (18th Stock Assessment Workshop, Northeast Fisheries Science Center).

The graph below shows the spiny dogfish total biomass estimates from the Northeastern Fisheries Science Center’s spring bottom trawl surveys. The highest estimated biomass, 1.131 million metric tons (or about 2.5 billion pounds), was in 2012 (from data in in Table 7 of Update on the Status of Spiny Dogfish in  2012 and Initial Evaluation of Harvest at the Fmsy  Proxy by Rago and Southesby and MAFMC staff and identified as not representing “any final agency                  determination or policy”). For reference, the total allowed catch (TAC) of spiny dogfish will be under 20,000 metric tons (the solid red line) a year for the next three years.

2008 – Spiny dogfish biomass estimated at 657 thousand metric tons: “All told, 87% of the stomach contentsfrom these particular Gulf of Maine caught dogfish (401 adult dogfish collected by University of New England researcher James Sulikowski and his students)  consisted of bony fish – with cod, herring, and sand lance being the top three species.” (J. Plante, Dogfish in the Gulf of Maine eat cod, herring, Commercial Fisheries News, May 2008).

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The two graphs below – from the Northeast Fisheries Science Center’s web page Status of Fishery Resource off the Northeastern US – Atlantic cod (http://www.nefsc.noaa.gov/sos/spsyn/pg/cod/) show the decline of cod abundance calculated from both the Spring and Autumn bottom trawl surveys in the Gulf of Maine and on Georges Bank. Note that as the calculated spiny dogfish biomass (above) is increasing the biomass indices for Atlantic cod in both the Gulf  of Maine and on Georges Bank are decreasing correspondingly.

It has been reported that spiny dogfish consume 1.5% of their weight per day. That translates to them eating about 17000 metric tons of anything slower/smaller/less voracious than they are every day.

2009 – Spiny dogfish biomass estimated at 557 thousand metric tons: “our reason for ontacting you is to draw your attention to a severe and growing problem that we are all facing because of the supposed constraints imposed on the federal fisheries management system by the most recent amendments to the Magnuson Act. Because of the supposed necessity of having all stocks being managed at OY/MSY, all of our fisheries are and have been suffering from a plague of spiny dogfish (Squalus acanthias).” (Fishermen Organized for Rational Dogfish Management letter to NOAA head Jane Lubchenco).

Since 1950 the annual Atlantic cod landings in all US ports exceeded 50,000 metric tons only in 1980, ‘82 and ‘83. In 2011 they were 7,900 mt.

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If there was one rational step that could be taken to try to return the Atlantic cod stocks off our Northeastern coast to former levels, it’s hard to imagine anything with more of a likelihood of success than significantly cutting back the population of spiny dogfish. But this isn’t possible because if the spiny dogfish stock is not at a level that could produce the maximum sustainable yield it would be overfished – and thanks to the successful lobbying of the anti-fishing claque managed fish stocks can’t be overfished.

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In the face of all of this it’s kind of hard to think that the federal fisheries management system has as a goal anything but the elimination of New England’s codfish fishermen. Otherwise, how could an alternative to further futile decreases in fishing for cod not be an increase in fishing for spiny dogfish? That would seem to be a rational action, wouldn’t it (and rest assured that spiny dogfish impact many more species than Atlantic cod).
But it’s not, and with the MSFCMA written and interpreted the way it is it can’t be.

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But the spiny dogfish plague isn’t the only fly in the “blame it all on overfishing” ointment. There’s an explosion in the population of seals in New England coastal waters as well. With the ability – or more  accurately, with the need – to consume 6% of their body weight per day, the almost 16,000 gray seals off Cape Cod are consuming far more fish than Cape Cod’s recreational and commercial fishermen could ever hope to catch. If they aren’t competing directly with the fishermen for cod and striped bass and flounder they are competing indirectly by eating the prey species that the fishermen’s targeted species eat. For a succinct and fairly balanced examination of the developing Cape Cod seal crisis see Thriving in Cape Cod’s Waters, Gray Seals Draw Fans and Foes by Bess Bidgood in the NY Times on August 17th. And there are burgeoning populations of other marine mammals as well as cormorants, birds that are protected by the federal Migratory Bird Treaty Act. They are all highly efficient predators on smaller fish.

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The Act will be reauthorized this year. In the reauthorization, unless the managers are once again given the ability to use their judgment we won’t be able to most effectively manage our federal fisheries  to maximize the benefit we can derive from them. The Magnuson management process was designed to benefit from the knowledge that people in the fishing industry and marine scientists have gained through uncounted years of on-the-water experience in dealing with an environment that is as strange to the rest of us as outer space and a lot more complex. The benefits of  that knowledge have been lost to the process because of legislated changes by people who and organizations  that are sorely lacking in that hands-on experience and think that there is one answer to every fishery-related problem – to cut back on fishing. Without that changing, without discretion being returned to the managers, our fisheries will increasingly follow the trajectory that the New England groundfish fishery is on. None of us – except perhaps for the ENGOs and the foundations that support them – either want or can afford that. Magnuson must be amended. Flexibility, with adequate safeguards, to deal with situations like the current dogfish plague must be restored to the management process. Rationality demands it.

Comment Here

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Seafood certificat​ion – who’s really on first?

“Sustainability certification” has become a watchword of people in the so-called marine conservation community in recent years. However, their interest seems to transcend the determination of the actual sustainability of the methods employed to harvest particular species of finfish and shellfish and to use the certification process and the certifiers to advance either their own particular agendas or perhaps the agendas of those foundations that support them financially.
It doesn’t take an awful lot of sophisticated insight to recognize that a “sustainable” fishery is one that has been in operation in the past, is in operation presently, and will be in operation in the future. That’s what sustainability is all about – for lobsters, for fluke, for surfclams, for guavas, for hemp, for alpacas, in fact for anything that can be grown and/or harvested.

(Of course “marine conservationists” would have us believe that  a fishery that has a noticeable impact on the marine environment isn’t really sustainable. Imagine, if you can, a farm that has no environmental impact; in essence producing crops without interfering with the natural flora and fauna that “belong” there. That would get beef, cotton, soybeans, corn, mohair and what have you off the tables or out of the closets of perhaps 6 billion of the people who we share the world with, but if you are a committed marine conservationist, so what? The marine conservation community, and the foundations that support it, has been frighteningly successful in convincing people that  “sustainable fishing” is actually “no impact fishing,” but as we learned quite a few years ago, even hook and line fishermen catching one fish at a time can have a far from negligible environmental impact.)

Several recent events have increased the focus on sustainability and its use – or misuse – in attempts at influencing the buying  habits of the seafood consumers.

In the first of these, Walmart (the world’s largest retailer) now requires its fresh and frozen fish/seafood suppliers to “become third-party certified as sustainable using Marine Stewardship Council (MSC), Best Aquaculture Practices (BAP) or equivalent standards. By June 2012, all uncertified fisheries and aquaculture suppliers must be actively working toward certification.”

In the second, the National Park Service in the US Department of the Interior announced that all of its culinary operations “where seafood options are offered, provide only those that are ‘Best Choices’ or ‘Good Alternatives’ on the Monterey Bay Aquarium Seafood Watch list, certified sustainable by the Marine Stewardship Council, or identified by an equivalent program that has been approved by the NPS.” Senator Lisa Murkowski questioned Park Service Director Jonathan Jarvis about this “recommendation” (the term he used) at an Energy and Natural Resources Committee. She asked whether NOAA (the National Oceanographic and Atmospheric Administration) was involved in formulating this recommendation. He responded that he didn’t know. Senator Murkowski responded “NOAA is the agency that makes the determination in terms of what’s sustainable (as far as fisheries are concerned) within this country”

When considered in a vacuum these are both interesting comments on the importance that is being put on “sustainability” by fish/seafood providers, and is indicative of a positive trend by consumers who are increasingly demanding that the products they  buy are produced in an environmentally acceptable manner.

And the fact that a federal agency, the National Park Service, would demand – or as Director Jarvis waffled – would recommend  that its vendors provide only seafood certified sustainable by two non-governmental organizations while ignoring the de facto certification that is implicit in federally managed fisheries is not likely to surprise anyone with any familiarity with the morass that the federal bureaucracy has become. However, neither Walmart nor the US Department of the Interior exists or operates in a vacuum, and it seems as if there is a bit more at work here than is obvious.

The Marine Stewardship Council (MSC) is the largest international organization – headquartered in London – providing fish and seafood sustainability certification. It was started in 1996 as a joint effort of the World Wildlife Fund, a transnational ENGO, and Unilever a transnational provider of consumer goods.

The chart below lists recent grants to the MSC by the Walton Family Foundation and the David and Lucille Packard Foundation in recent years.

Grants to MSC from Walton Family Foundation
2007    $1,640,000
2007    $820,000
2008    $1,675,000
2009    $1,700,000
2009    $1,700,000
2010    $4,622,500
2011    $3,122,500
2012    $1,250,000
Total    $16,530,000
http://www.waltonfamilyfoundation.org/about/2009-grants            

Grants to MSC from David and Lucille Packard Foundation
2005    $1,750,000
2006    $1,500,000
2006    $100,000
2006    $87,900
2007    $1,500,000
2008    $1,506,000
2008    $250,000
2009    $4,050,000
2010    $125,000
2011    $1,900,000
2012    $250,000
2012    $550,000
2013    $250,000
Total    $13,818,900
http://www.packard.org/grants/grants-database/            

The Monterey Bay Aquarium was established with an initial grant of $55 million from David and Lucille Packard. Their daughter Julie is Vice Chairman of the Packard Foundation. She is also Executive Director and Vice Chair of the Monterey Bay Aquarium’s Board of Trustees.

The MSC also lists the Resources Legacy Foundation as one of its supporters. The Resources Legacy Foundation has received $99 million from the Packard Foundation. One of its programs is the Sustainable Fisheries Fund, which along with its other activities provides funding ”reducing the financial hurdles confronting fishing interests that wish to adopt sustainable practices and potentially benefit from certification under MSC standards.”
According to CampaignMoney.com Ms. Packard donated $75,000 to the 2012 Obama Victory Fund.

In both of these initiatives NOAA/NMFS, the organization that provides virtually all of the data and other information that sustainability determinations are based on, that is required by  federal law to stop unsustainable fishing in federal waters, and that performs its own sustainability analyses on those fisheries, has been completely left out of the picture.

All things being equal, this could just be passed off as business – and government ineptitude – as usual. However, when tens of millions of dollars in donations by mega-foundations with “marine conservation” agendas that are looked at skeptically by so many in the fishing industry are thrown into the mix, should this be considered as just more business as usual or does it warrant a much closer look?

Comment here

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Fisheries Management​–More Than Meets The Eye

Last year I wrote After 35 years of NOAA/NMFS fisheries management, how are they doing? How are we doing because of their efforts? (http://www.fishnet-usa.com/After        35 years of NOAA.pdf) I concluded with:

Our collective fisheries were never as badly off as grandstanding ENGOs convinced the public and our lawmakers that they were. Regardless of that, they are unquestionably in great shape now. Are the fishermen – the only people who have paid a price for that recovery – going to profit from it? At this point there aren’t a lot of indications that they are going to. Ill-conceived amendments to the Magnuson Act, the ongoing foundation-funded campaign to marginalize fishermen and to hold them victims of inadequate science, and a management regime that is focused solely on the health of the fish stocks and is indifferent to the plight of the fishermen effectively prevent that.

That having been a year ago, and statistics measuring the performance of our commercial fisheries for 2011 being available (http://www.st.nmfs.noaa.gov/st1/commercial/landings/annual_landings.html), I thought I’d check back to see what, if anything, had changed.

Nationally, the total adjusted (to 2010 dollars) value of landings continued a gradual upswing that’s gone on intermittently since 2002/03. The post Magnuson (1976) low point in 2002 was under $4 billion, and by 2011 it had risen to over $5 billion, an increase of 35%. The adjusted value of the 2011 catch, $5.176 billion, was 76% of the highest total catch (in 1979) of $6.83 billion and 22%  above the average landings (from 1950 to 2011) of $4.25 billion.

All in all, the big picture is mostly positive. Unfortunately, the big picture is made up of a lot of smaller pictures, and some of them aren’t so good.

In the following chart I separated the value of the total landings in Alaska and the separate values of landings in American lobster, sea scallops and Southern shrimp (all species combined) from all other species.

For total value of landings in 2011 Alaska is at about 70% of where it was at its post Magnuson high ($1.84 billion vs $2.58 billion). Atlantic sea scallops were at their all-time record value ($485 million) and American lobster were at 89% of their all-time high ($405 million vs $456 million in 2005). Unfortunately the 2011 (Southern) shrimp landings were valued at only 34% of what they were at their highest ($472 million vs $1.333 billion in 1979).

In 1950 the Bureau of Commercial Fisheries reported landings of 223 distinct species or species groups (i.e. Shrimp, Dendrobranchiata  ). In 2011 the National Marine Fisheries Service reported landings of 460 species or species groups.
The 20 most valuable fisheries in 1950 and in 2011 and the percentage of their value to the total value of landings for that year are listed below:

In the Mid-Atlantic in 2011 the total value of landings, $220 million, were 79% of the highest landings value reported ($279 million in 1979). However, sea scallops made up more than half of the total landings value (56%, $143 million v. $114 million). While the overall picture looks positive, the value of the landings in the Mid-Atlantic minus the sea scallop production have been in a steady decline since the late 90s and are at the lowest point ever.

In New England the situation is comparable, but both American lobster and sea scallop production are responsible for the overall “healthy” appearance. There was a slight upswing in the value of the other fisheries in recent years but it appears that with the planned – and in part implemented – reductions in the groundfish TAC, it seems as if this slight upswing won’t carry over.

 

Conservation and management measures shall, consistent with the conservation requirements of this Act (including the prevention of overfishing and rebuilding of overfished stocks), take into account the importance of fishery resources to fishing communities in order to (A) provide for the sustained participation of such communities, and (B) to the extent practicable, minimize adverse economic impacts on such communities. National Standard #8, Magnuson-Steven Fisheries Conservation and Management Act (As amended through October 11, 1996).

A looming problem in both the Mid-Atlantic and New England is a pending cutback in the sea scallop quota for the next fishing year that at this point is expected to approach 40%. While the effects of a cut of this magnitude will obviously be significant to the scallop fleet, there will be not so obvious but potentially devastating effects on the other fisheries and on fishing communities as well.

A complex of ancillary businesses is required to operate a commercial fishing dock. These include vessel/equipment maintenance and repair facilities, ice plants, chandleries and shippers/truckers. Obviously it requires a certain level of business – a minimum amount of revenue coming “across the dock” –  for them to stay open. In the Mid-Atlantic a 40% cut in scallop revenues will be more than a 20% cut in commercial fishing revenues in a single year. In New England it will be somewhat less than that, but it will be combined with whatever additional cuts result from the proposed groundfish cuts.

I’m not that familiar with all of the fishing ports in the Mid-Atlantic and New England but have a fairly good understanding of those in New Jersey, and in New Jersey there isn’t one commercial port that lands fish from the ocean-going fleet that is mostly – or even largely – focused on scallops. They all handle a mix of fish and shellfish. A large part of their longevity is due to the fact that they have maintained a reasonable amount of flexibility thanks to their diverse fleets. But a drastic cutback in scallop revenues, particularly if it is coupled with the continuing decline in the revenues from other fisheries, will threaten that longevity.

The proposed scallop cutback has been presented as a temporary  measure, and the Fisheries Survival Fund – representing the majority of limited access scallop fishermen in New England and the Mid-Atlantic and other industry groups are working to ameliorate the proposed cuts, but when it comes to businesses that are waterfront dependent a two year temporary reduction could easily become permanent before the cutbacks are restored. Except for the lull over the past several years there have been intense development pressures at the Jersey Shore and on most of the waterfront areas from Cape Hatteras North. It’s just about assured that they will be back to their customary levels very shortly.

Originally the Magnuson Act placed much more emphasis on business- and community-supportive aspects of federal fisheries management. Those aspects have been eroded by the lobbying activities of the handful of ENGOs that have come to dominate the world of fisheries/oceans activism. They, and for the most part NOAA/NMFS  as well, address fish issues on a case by case, species by species basis. More importantly, the people at NOAA/NMFS tend to shy away from cumulative economic impacts when they have analyses done, and cumulative impacts are what most of the commercial fishermen, the people who depend on them and the businesses they support have to deal with – and in New England and the Mid-Atlantic (at least, and this isn’t to slight the industry elsewhere, because I doubt that it’s different in many other ports) in spite of increasing total landings value, it could be getting a lot worse really soon.

Comment here

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A staggering loss to U.S. fishermen and U.S. seafood consumers.

Nils E.Stolpe  FishNet USA/June 26, 2013

 It was back in June of 2008 that I first became aware of Richard Gaines’ work in the Gloucester Times in a three part series exploring the interplay between fishermen, feds, ENGOs and the mega-foundations that funded them in a controversial move to close Stellwagen Bank to fishing (see http://tinyurl.com/n8m3voh for the first installment). A letter about the series I wrote to Times Editor Ray Lamont started “kudos to Richard Gaines for reporting what is going on behind the smoke and mirrors obscuring the struggle to maintain the historical fisheries that have thrived on Stellwagan Bank for generations. He couldn’t be more on-target when writing ‘Pew is associated with public information campaigns against fishing and fish consumption.’”

This started a friendship between Richard and me that, I was amazed to discover, had lasted for less than five years. I know it enriched my life. I can only hope it enriched my writing as well.

Returning from a business trip on Sunday, June 9, Nancy Gaines found her husband Richard dead of an apparent heart attack at their home just outside of Gloucester.

Richard was a journalist’s journalist. Unlike the average “reporter” covering fisheries/ocean issues today, he gave press releases – and the contacts they provide – the minimal initial credence that they generally deserve. He was always looking for the story behind the press release and with a combination of integrity, skill and tenacity he usually found it. In five years he developed a surprisingly sophisticated understanding of what has become a cumbersomely complex federal fisheries management process – and of the political machinations behind it. Whether it was about the multi-billion dollar foundations behind the environmental activist organizations that have become so adept at making life miserable for fishermen, or a federal fisheries enforcement establishment that was allowed to enrich itself with tens of millions of dollars coerced from the fishing industry, Richard was covering it, covering it thoroughly and covering it well.

It’s going to be harder on all of us because he’s no longer there to do it.

Richard was memorialized fittingly by Ray Lamont in Community, industry mourn loss of a champion at http://preview.tinyurl.com/mmjbuae, North Carolina Congressman Walter Jones honored him with a statement to the U.S. House of Representatives available in the Congressional Record (http://thomas.loc.gov/cgi-bin/query/z?r113:E12JN3-0009:/ and I can’t add much to what they and dozens of other folks have written in the last week other than offering his wife Nancy, his family and coworkers my deepest sympathy. And I’d suggest that after reading this you spend a few minutes watching an interview of Richard done by Good Morning Gloucester at http://preview.tinyurl.com/lg8ohll. If you weren’t lucky enough to know him this will tell you much of what you should know about him and his work.

And while on the subject of press releases….

“The Attorney General is wrong on the law and she is wrong on the facts,” said Peter Shelley, senior counsel with CLF, who has been actively engaged in fisheries management for more than 20 years. “Political interference like this action by Attorney General Coakley has been a leading cause of the destruction of these fisheries over the past twenty years, harassing fishery managers to ignore the best science available….We need responsible management which includes habitat protection and a suspension of directed commercial and recreational fishing for cod. We also need some serious leadership from our elected officials. Going to court or getting up on a political soapbox will not magically create more fish.” (from a Conservation Law Foundation press release on May 31.”

It’s kind of hard to believe that just about immediately after this press release went out the  Conservation Law Foundation – along with the Pew spawned Earthjustice (recipient of some $20 million from the Pew Charitable Trusts) – filed suit in federal court to prevent NOAA from cutting the groundfish fishermen the tiniest bit of slack, perhaps allowing more of them to survive a largely management manufactured slump. It seems that in the release Mr. Shelley must have meant “other people going to court or getting up on a political soapbox will not magically create more fish. However if  it’s me or my foundation funded buds going to court, watch out ‘cause those fish will shortly be on the way.”

I usually stay away from New England issues because my colleagues up there are more than capable – in spite of the gross inequities resulting from the mega-foundation mega-buck funding of organizations like the Conservation Law Foundation and Earthjustice – of representing their own interests. However I couldn’t sit back and not comment on the CLF position voiced by Peter Shelley in an article, Conservation group sues NOAA to block openings, byRichard Gaines on June 6.

Explaining how the CLF/Earthjustice position wasn’t hypocritical, Mr. Shelley explained “the distinction for me is that I have seen time and time again when politicians — in this case the attorney general — hasn’t participated in the (fisheries management) process, and then comes in to try to influence the process in litigation. They’re not taking a legal position, there’s not much there except politics.”(http://preview.tinyurl.com/mnzgsnu).

To suggest that this is a more than slightly puzzling statement for an attorney to make would be an understatement. Mr. Shelley must believe – or must want other people to believe – that Attorney General Coakley was acting on her own when filing the suit. Apparently he believes – or wants us to believe – that because she has never personally participated in the fishery management process her suit has no merit. He is and has been, it would seem, in attendance at many meetings in New England at which fish are discussed and it appears as if in his view this makes his suit de facto righteous and hers nothing more than political posturing.

Massachusetts  Attorney General hasn’t participated in fisheries management?

Let’s examine his contention that the Massachusetts Attorney General hasn’t participated in the (fisheries management) process in a little more depth. First off, I doubt very much that Attorney General Coakley  brought the suit on her own behalf. In fact, I’d bet dollars to donuts that she brought it on behalf of the Commonwealth of Massachusetts. Even Mr. Shelley must know that the Commonwealth, via a succession of capable and effective representatives, has for at least the last forty or so years participated heavily in federal fisheries management via the Magnuson Fisheries Conservation and Management Act. Either Paul Diodati, Director of the Commonwealth’s Division of Marine Fisheries, or David Pierce, the Deputy Director, are at every meeting of the New England Fishery Management Council and Dr. Pierce is a member of that Council’s Groundfish Committee (as well as its Herring, Sea Scallop and ad hoc Sturgeon Committees and the Mid-Atlantic council’s Dogfish and Herring Committees). Mr. Diodati is also the Chairman of the Atlantic States Marine Fisheries Commission and the Co-Director of the Massachusetts Marine Fisheries Institute. They aren’t on these bodies on their own behalf either. They are there representing the Commonwealth as well. And before they were there, their predecessors were, and they were just as deeply involved.

This commitment to and participation in the fisheries management process by the various representatives of the Commonwealth of Massachusetts began long before Mr. Shelley, the CLF and the Pew Trusts discovered each other. The Commonwealth, as represented in the current suit by the Attorney General whose participation Mr. Shelley seems so intent in marginalizing, established its bona fides in fisheries management at least a century ago (and will hopefully remain involved far beyond the point when Mr. Shelley, the CLF and Pew move on to “greener” pastures).

In fact the groundfish management measures that Mr.Shelley’s justifiable (in his estimation) suit is aimed at were a work product of the New England Fisheries Management Council, an institution which was established by the Magnuson Act in 1976 that has been in continuous operation – with overlapping changes in membership and administration –  since then. And in spite of Mr. Shelley’s so apparent disagreement with this fact, the Council is mandated by the Act to manage for the benefit of the fish, the fishermen and the fishing communities. The Council members voted by an over 75% majority (13 to 3) to support the measures that Mr. Shelley et al are now going to court – of course in a non-political fashion – to prevent. As opposed to Mr. Shelley’s “more than twenty years” trumpeted in the CLF press release,how many hundreds of years of collective fisheries science and management experience do the Council members and staff possess? How many collective years of management experience do the Council members whose votes Mr. Shelley and his pals are going to court to nullify have.

Evidently it isn’t fisheries management experience that Mr. Shelley finds so valuable. It’s whose management experience that matters.

These are the people, the agencies, the institutions, the experience and the actions behind the Commonwealth’s lawsuit – the one that Mr. Shelley wants us to believe is based on nothing more than “political posturing.”

And what of the constituencies being represented? Attorney General Coakley’s constituency is made up in large part of Massachusetts fishermen, all of those people, families and businesses that depend on them, all of the Commonwealth’s consumers who, apparently unlike Mr. Shelley et al, realize that a seafood dinner should involve something more satisfying and wholesome than a several-times-frozen lump of imported shrimp, tilapia or swai, and all of them, and us, who seriously appreciate fishing traditions going back to colonial times.

On the other hand, from what I’ve been able to discover (see http://www.fishtruth.net), Mr. Shelley’s, CLF’s and Earthjustice’s “constituents” are a handful of mega-foundations and well-to-do-donors, and I’d imagine a lot of internet “click here if you don’t like fishermen or fishing” residents of anywhere (but I’ll again bet those same dollars to those same donuts that very few of them are in coastal Massachusetts).

So few groundfish?

Then Mr.Shelley brings up what he wants us to consider the “fact” that there are so few groundfish available to the fishermen that they are no longer filling their annual quotas. To the uninformed (those “click here” constituents, for example) this probably seems a compelling argument for shutting down the fisheries, Mr. Shelley’s often stated goal. It must make sense to many people who are unfamiliar with our modern fisheries “management” regime as it has been distorted by lobbying by environmental activist organizations like CLF. In fact, however, there are other and much more believable causes of uncaught quota than not enough fish.

The first of these would be the existence of so-called “choke” species. Much more valuable fisheries can be shut down because of unavoidable bycatch of other species with much lower quotas. Take the situation in which two species – the targeted species and the “choke” species – are inextricably mixed during part of the fishing year. Fishermen, tending to be rational even when dealing with an irrational system such as the one that Mr. Shelley and his cronies have built, will avoid the target species in spite of its abundance because they know full well that when the catch limit for the “choke” species is reached both  fisheries will be shut down. In essence they are leaving the uncaught quota “in the bank” for later harvest. Needless to say, that later harvest isn’t guaranteed and it’s easy to imagine that in many instances it remains uncaught.

Then there are the meager trip limits for some stocks. Catch shares or not, in instances it just isn’t worth it for some fishermen to run their boats offshore for a few hundreds of pounds – or less – of fish. They’ll remain tied to the dock or will target other species with quotas that will allow them more income.

And we can’t forget low prices at the dock. Fish markets have adjusted to the recent vast swings in supply of some of the traditional species (a testament to the lack of effectiveness of our fisheries management system) by switching to alternative products. With the most productive fishing grounds in the world in our EEZ it’s hard to imagine that tilapia is the most heavily consumed finfish in the U.S., but it is. Compensating for these often low prices is a large part of the reason for the development of alternative markets for our domestic fisheries, but it’s somewhere between extremely difficult and impossible to move large quantities of fish in small lots.

Then there’s the impact of changing environmental conditions on the traditional availability of species, Said most simply, fish aren’t necessarily where they have been found by fishermen for generations. Though Mr. Shelley apparently want you to think that means they’re not there at all, that’s not necessarily so. Fish stocks are dependent on water temperatures, as are the critters they feed on, and water temperatures have been changing significantly in recent years. Some areas that used to reliably produce a particular species of fish at a particular time of the year no longer do so. With the meager quotas and the continually increasing costs of running a boat a fisherman isn’t as likely to search for where the water temperature changes have driven the fish. Economics won’t allow it.

Additionally, fish surveys are operated as if our U.S. coastal waters exist in a steady state; that conditions today  are as they were when the survey was started. The same spots are sampled at the same time every year, and when a particular species is no longer  taken in the sample or is taken in reduced numbers, the automatic assumption is that fishing is the cause of “the problem” and that reducing or curtailing (ala Mr. Shelley) fishing is the solution. Compounding the real problem, the reduced availability of research funds, the probability of extending the scope of the surveys is pretty low.

In a follow-up article on June 10, Shelley elaborated that the suit filed by Attorney General Coakley was “political ‘soapbox’ posturing” while“our suits are not political… they’re strictly based on the facts, and we do it as a last resort”(http://preview.tinyurl.com/mysrlbz).

Attorney General Coakley, Governor Patrick et al, please keep on keeping on. Effective fisheries management should involve much more than happy fish and happy ENGOs. When Congress passed the Magnuson Act in 1976 the Members realized this and it’s about time that the pendulum gets pushed back in the direction that it was intended to swing in. Fish count, but so do fishermen, fishing communities and seafood consumers. If the U.S. fishing industry is to survive, the initial balance that was amended out of the Act by intensive lobbying by foundation funded activists claiming to represent the public must be restored.

For more information on Shelley’s/the Conservation Law Foundation/Earthjustice lawsuit see Conservation Law Foundation & Earthjustice Make Unfounded Claims in Lawsuit Filing   at http://preview.tinyurl.com/pwaaabu.

…………………………………..

For those of you who were interested in the FishNet piece (available at http://www.fishnet-usa.com/Bluefin tuna and Pew.pdf ) on the ongoing attempts by the Pew Trusts, one of Mr. Shelley’s benefactors, to steer the Bluefin tuna management meeting this week in Montreal, the critique of the claims of the Pew people attempting the steering are available on the Saving Seafood website at http://preview.tinyurl.com/nc59z3q. I’d suggest that you take the time to read it and the Saving Seafood special report on Bluefin tuna at http://preview.tinyurl.com/ojo5jne.

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FishNet – USA/June 24, 2013         Nils E. Stolpe

On August 13, 1997 Josh Reichert, then Director of the Pew Trusts Environment Program and now Executive Vice President of the Trusts, in an op-ed column in the Philadelphia Inquirer titled Swordfish technique depletes the swordfish population wrote “the root problem is not only the size of the (swordfish) quota, the length of the season, or the  number of vessels involved. It is how the fish are caught…. Use of longlines must be barred…. the fishery should be open to all – provided that swordfish are caught with hand gear, including harpoons and rod and reel. No swordfish should be taken until it has a chance to breed at least once, meaning that the minimum allowable catch size should be no less than 100 pounds. Such measures…. would put the  Atlantic swordfish population back on the road to recovery.

” http://articles.philly.com/1997-08-13/news/25567968_1_swordfish-big-fish-commercial-long-liners

In what has become typical Pew style, Mr. Reichert’s article was just a small piece of a frightfully well-funded campaign to “save the swordfish” from the depredations of the U.S. pelagic longline  fleet. Involving scientists who had been willing riders on the  Pew funding gravy train, enlisting restaurateurs into the campaign who hadn’t the foggiest idea what swordfishing or pelagic longlining was all about, and using the formidable Pew media machine which had earned its legitimacy with tens of millions of dollars in grants to journalism schools and broadcast outlets, Mr. Reichert and his minions set out to destroy an entire fishery and the lives of the thousands of hard working Americans who depended on it.

This could have dealt a devastating blow to the U.S. longline fleet. Exacerbating a bad situation, it would have also resulted in the transfer of the uncaught quota from the strictly regulated U.S. boats to other vessels whose regulation was much less rigorous. Without question removal of the U.S. longline fleet would have had a negative impact on swordfish conservation.

Fortunately a swordfish management program to reduce fishing effort to where it was in balance with the resource had been put in place by the International Commission for the Conservation of Atlantic Tunas (ICCAT) years before Mr. Reichert and Pew “discovered” swordfish. By the time the Pew people and the Pew dollars entered the fray this program was already paying obvious conservation dividends. Then a closure of swordfish nursery areas off Florida, a closure which was supported by the U.S. longline fleet, was also put in place. This assured the recovery of the swordfish stock in the Western North Atlantic.

This was a testament to fisheries management based on sound science, not on media hype only affordable by multi-billion dollar corporations and foundations.  In spite of self-serving claims to the contrary, the Pew peoples’ prodigious yet misguided efforts to scuttle the pelagic longline fleet – and their obvious lack of understanding of swordfish management – changed virtually nothing about the fishery or about how it was being managed.

But what has changed in the intervening years is the way in which the rest of the (non-Pew) world looks at pelagic longlining in general and the U.S. pelagic longline fleet in particular. Thanks to significant efforts by the U.S. participants  in this fishery, they have become the undisputed world leaders in developing and implementing fishing gear and fishing techniques to drastically reduce or eliminate the incidence of bycatch in their fishery. And despite Mr. Reichert’s dire predictions and those of Pew’s stable of scientists, the doom and gloom predicted for swordfish if longlining was allowed to continue never developed. Today, as the pelagic longline fishery continues, the swordfish stock is fully rebuilt. In fact, the fishery is in such good shape that it was recently certified as sustainable by the Marine Stewardship Council.

So now Bluefin tuna     

To quote the inimitable Yogi Berra, “it’s déjà vu all over again.” Fifteen years later the same cast of characters and the same organizations are using the same tired and ineffective strategy funded by the same sources to derail the management of another highly migratory fish species, the Atlantic bluefin tuna (ABT).

The International Commission for the Conservation of Atlantic Tunas (ICCAT), the same body that is responsible  for swordfish management in the Atlantic, is holding a meeting of fisheries scientists and managers in Montreal at the end of this month to review the ABT stock assessment. The outcome of this review will have much to do with determining what the total allowable catch (TAC) of these valuable fish will be in the coming years. The TAC is divided between rereational fishermen, rod and reel commercial fishermen, harpooners, purse seiners (currently none are in the U.S. fishery) and pelagic longliners (who don’t target ABT but do take some incidentally).

While the public’s view of the value of these fish has been purposely distorted – each year one fish, supposedly the first and the best of the year, is sold at a Japanese auction for hundreds of thousands of dollars as a marketing ploy – they      are valuable, with a prime fish bringing thousands of dollars (the National Geographic Channel offers a largely accurate portrayal of the rod and reel ABT fishery in its series Wicked Tuna).

In what is no surprise to anyone with even a nodding acquaintance with fisheries management issues, the folks at Pew have mounted yet another well-funded campaign to influence the outcome of this ICCAT assessment review. They are using the same flashy and expensive techniques and have enlisted a similar claque of experts to “save the tuna” as they used in the late 90’s to save the swordfish.

As was so convincingly  demonstrated by the complete recovery of the swordfish stocks in spite of continued harvesting by the longline fleet, Pew science as voiced by Pew scientists was then far from the last word in the world of  fisheries      management. That hasn’t changed. Nor has their strategy. The same hackneyed messages of doom and gloom by the same overwrought scientists are presented as if they represent the main stream of fisheries research.

Rather than being swayed by their efforts to make the playing field at the upcoming meeting in Montreal as uneven  as the billions of dollars backing them up will allow, it’s crucial that the independent science as espoused by the independent scientists speak for itself.

As with swordfish almost a generation ago, we trust that the scientists and managers in Montreal this week will not be swayed by all of the hyperbole that they will find aimed directly at them, will evaluate the existing science for what it is, not for what the Pew people will try to tell them it is, and make decisions that are right for the fish and right for the fishermen.

We should note here that there seems to be no limit to what the people at the Pew Trusts will spend in their attempts to convince anyone who will listen to reduce or eliminate fishing but when it comes to investing even negligible resources into efforts to more accurately and extensively sample the fish stocks they seem so intent on saving, something that everyone agrees is necessary for more effective management, they seem singularly uninterested.

Comment here

FishNet-USA/04/01/06 – The entire focus of what is considered fisheries management today is on first blaming (generally commercial) fishing for any situation involving the perception that there are not enough fish, and then controlling (generally commercial) fishing to return a population of fish to what is presumed to be some optimum level. And most recently this has even been extended to restoring once healthy habitat that has been supposedly compromised by (generally commercial) fishing.

Why this focus on fishing? The logical answer would seem to involve an old adage dealing with smoke and fire. Is that necessarily so, or are there other factors at work instead?

A very brief history of wildlife management in general

Even before we in the colonies were attempting to hunt bison and passenger pigeons and anything else that was fit to eat or wear or shoot into extinction, the folks in Europe were realizing that such a strategy didn’t bode well for the future of small furry and finny creatures. Accordingly, the creatures were all claimed by members of the aristocracy, who proceeded to manage them (or more correctly, to have them managed) on their estates and on public lands. Needless to say, this was a fairly simple undertaking, aimed at controlling fairly simple and fairly artificial systems to “sustainably” produce a handful of desirable critters for the lords and ladies of the manor and their guests to eat or catch or shoot. Apply a few simple rules – don’t shoot too much, don’t catch too much and keep the peasants out – and you’d be in business for decades. This was because there were few factors affecting the highly controlled forests or lakes or rivers other than harvesting.

Moving forward – or perhaps not, at least as far as effectively managing fisheries was concerned – a few hundred years, in a lecture given at the Fisheries Centennial Celebration in 1985 (The Historical Development of Fisheries Science and Management, http://www.nefsc.noaa.gov/history/stories/fsh_sci_history1.html), William F. Royce quoted Milton C. James, who wrote in 1951 “The fishery administrator starts his functioning with a background of a vast, unorganized ignorance, illuminated by occasional flashes of traditional legend, hearsay, inference, assumption, guesswork, and praise be, an increasing backlog of scientific theory and fact coupled with the experience gained from trial and error. The administrator, having no firmly fixed starting point of fact, must then chart some sort of course in the hope of arriving at the only definite landmark in his harassed existence — that represented by a stable, sound, productive fishery. This part of the job, nevertheless, might be considered relatively simple, calling for nothing more than a system of Spartan, conservative restraints and restrictions upon the taking of fish. By always leaning over backward in regulating, giving the resource the benefit of the doubt, he might come up with reasonable assurance of protecting the resource, except that the economic survival of thousands of individuals, hundreds of communities, and dozens of counties, may be affected by the administrative action taken.”

Royce followed this with “the dry wit of Milton C. James, who for many years was the Assistant Director for Fisheries of the U.S. Fish and Wildlife Service, is as pertinent today as it was in 1950 when he made that statement at the Gulf and Caribbean Fisheries Conference.” We agree with Royce completely here, but probably not for the same reasoning. What James wrote wasn’t pertinent in 1951, it wasn’t pertinent in 1985 and it isn’t pertinent today. At least back in 1951 we didn’t know any better, but by 1985 it should have been obvious that there were many other factors, both man-caused and natural, that affected our fish stocks.

 Have we grown out of it?

A rational and well-informed person, one who was familiar with the advances that have been made in the last half a century in understanding ecosystems, how they function and what our effects on them are, would assume that fisheries management had gotten beyond the simplistic view that (mostly commercial) fishing was invariably the major determinant of the health of fish stocks. With increasing knowledge of the downstream impacts of what goes on upstream, with the detection of various chemical pollutants in marine organisms far removed from any identifiable source, with the identification of weather/climate cycles and the attendant regime shifts that they bring about, and with a realistic grasp of the importance of wetlands and estuaries to inshore and near shore fisheries, it’s hard to imagine that we haven’t moved beyond the “blame it all on fishing” paradigm.

Unfortunately, the belief that if you can limit fishing you’ll be able to protect the fish is still at play in marine fisheries management today. In spite of the fact that estuaries and oceans are tremendously complex systems affected by myriad natural and anthropogenic activities, our fisheries management system is still based on controlling the fishery by controlling the harvest.

This is most convincingly demonstrated by the fact that in fisheries management only two sources of mortality are recognized. One of these is – you guessed it! – fishing mortality. The other is termed natural mortality, though it is defined as “that component of total mortality not caused by fishing, but by natural causes such as predation, diseases, senility, pollution, etc.¹”

“Refining” this definition of natural mortality, we have from NMFS “that part of total mortality applying to a fish population that is caused by factors other than fishing. It is common practice to consider all sources together since they usually account for much less than fishing mortality.²” While it’s kind of hard to imagine that fishing is “usually” the major cause of mortality in a fish population (of all of the hundreds or thousands or millions of eggs that a fish produces each year, a very, very small proportion survive to be caught by fishermen), and while it’s guaranteed to skew every discussion of mortality in fisheries against fishing, that’s the official government position.

Note that pollution is considered a part of natural mortality, as are any other anthropogenic effects other than fishing. We’ll get back to that later, but for now, consider the ramifications of recognizing only two sources of mortality, one “natural” and the other caused by fishing, when dealing with a fish population.

It’s been ingrained in modern society that anything that is “natural” is considered to be good and desirable, and woe to anyone who would dare to trifle with the natural order of things. Who could forget the “it’s not good to fool Mother Nature” margarine commercials of a few years back? Of course, the average person doesn’t have any idea that when it comes to fisheries management, mortality brought about by pollution, in fact mortality brought about by anything other than fishing, is considered “natural,” and is automatically considered “good,” leaving fishing as the only “unnatural” factor affecting fish stocks.

Is this the wrong way to manage?

If commercial fishing were the only, or even the predominant, source of mortality impacting a fish stock, then no one could argue that focusing on managing commercial fishing wouldn’t be the most effective way of managing it. On the other hand, it seems equally inarguable that if commercial fishing weren’t the only or the predominant source of mortality, then to focus solely on commercial fishing wouldn’t be effective. Rather, such a focus would be a virtual guarantee that commercial fishing on that stock would be “managed” into oblivion.

As evidenced by commercial fishery after commercial fishery enduring ever-increasing restrictions for year after year with no relief in sight, managing fish stocks by relentlessly cutting back on commercial fishing effort isn’t working the way it’s supposed to be. The anti-fishing activists blame this on a fishery management system that is compromised by conflicts of interest and is therefore unwilling or unable to impose the strong medicine that, in their estimation, curing our fisheries requires. Accordingly, they are in the midst of a campaign to amend the Magnuson Fisheries Conservation and Management Act to remove the slight bit of flexibility from the management process that at this point is the only thing allowing a number of commercial fisheries to survive.

But what if there are factors at work on particular fish stocks, factors that would be considered “natural” by the fisheries managers and thus unworthy of their attention, that are significantly influencing the health of those stocks?

A major “natural” source of mortality

We’ll start with the easiest and most understandable factor with the potential to significantly affect our fisheries, human population growth on the coasts, or more precisely, the impact of that growth on the productivity of inshore and near shore waters. If you’ve bought into the fisheries managers’ vocabulary, this is a “natural” source of fish mortality that is insignificant when compared to fishing mortality. But is it?

In the U.S. the population on the coasts has been and continues to increase at a greater rate than the general population. This is a worldwide trend. Every year there are more people, and every year more of them are living on the coasts.

Crossett, Culliton, Wiley and Goodspeed (2004, Population Trends Along the Coastal United States: 1980-2008, US Dept. Of Commerce/National Ocean Service) document the dramatic increase in population in coastal counties in the U.S. from 1980 to 2000. The only state that didn’t experience a significant increase in its coastal population density during this period was Alaska. Regionally, the coastal population density increased 18% in the Northeast, 58% in the Southeast, 45% along the Gulf coast and 45% for the Pacific states (including Alaska and Hawaii).

This coastal population explosion is unquestionably accompanied by increases in non-point source pollution, in recreational boating, in harmful algal blooms and so-called dead zones³, in the loss of productive wetlands, in the amount of household chemicals and pharmaceutical “residues” making their ways into coastal waters, in the amount of impervious ground cover and the corresponding increase in water borne sediments, with a host of side effects with the demonstrated potential to directly or indirectly impact the health of fish stocks.

In the U.S. “five of the 10 most populated watersheds are located from southern Virginia to New England. The Hudson River/Raritan Bay and Chesapeake Bay watersheds were the most populated overall, with over 13 million and 10 million people, respectively.” (from Crossett, Culliton, Wiley and Goodspeed). We’re not making much of a leap when we assume that this coastal population increase has had negative impacts on inshore and near shore water, nor that there would be an accompanying effect on the resident and migratory fish stocks.

 How does this apply to New England Groundfish?

With cut after cut being inflicted on the groundfish fleet, there still aren’t enough fish – at this point cod and yellowtail flounder in particular – to meet the rigid “rebuilding schedules” imposed after the passage of the Sustainable Fisheries Act. Under the latest management proposal, boats are to be allowed on the order of twenty days a year to fish for groundfish. The fleet average in the ‘70s and early ‘80s was perhaps 200 to 250 days. The proposed cuts represent a reduction of perhaps 90% in fishing time per vessel over several decades (without even taking into consideration what have been significant reductions in the fleet size). As Chart #1 indicates, since the passage of the Magnuson Act in 1976, the landings of these two species have declined dramatically in spite of the drastic and ongoing reductions in fishing effort.

This isn’t just characteristic of the cod and yellowtail flounder fisheries. In Chart #2, landings of the various species that make up the groundfish complex are depicted. In all of them fishing effort has being ratcheted downwards continuously (the increase starting in the late 1970s was an artifact of the passage of the Magnuson Act in 1976). Looking at this chart, it’s awfully difficult to believe that, along with fishing, there aren’t other factors influencing the stocks. If not, with such drastic reductions in fishing effort as the landings data indicate, why haven’t a greater proportion of the stocks recovered? At the same time, the coastal population in the Northeast continues to increase – as does the loss of wetlands, the amount of non-point source pollution, the recreational use of our waterways, etc. The attendant and undoubtedly increasing impacts on the fisheries, because they are considered to be part of the “natural” mortality and because the focus of fisheries management has always been on fishing, escape the managers’ scrutiny and the public’s attention while the groundfish industry faces cutback after cutback with no sign that relief is on the way. (For another example of this total focus on fishing, see “Brief history of the groundfishing industry of New England” on the Northeastern Fisheries Science Center website at http://www.nefsc.noaa.gov/history/stories/groundfish/grndfsh2.html).

If we assume that there are other factors that are negatively impacting the groundfish stocks, and if the fisheries managers continue to reduce fishing effort in a futile attempt to counteract them, what lies ahead for the New England groundfish industry?

The Chesapeake Bay

In spite of this, there has been a recent movement to blame the ills of the Chesapeake on the overharvest of two filter-feeding commercial species, oysters and menhaden. Landings in both of these fisheries have declined significantly in the Chesapeake in recent decades. As shown in Chart #3 below, menhaden landings have been declining for well over a decade and oyster landings since the 1950s. The menhaden fishery is not being overfished, though there are recognized problems with recruitment (the addition of young fish to the stock). The view being pushed by anti-fishing groups is that decline in the productivity of the Chesapeake isn’t responsible for the decline in these fisheries but vice versa. Understandably, some of the most vehement critics of the Virginia and Maryland commercial fisheries are among those 16 million people who live around, play on and flush into the Bay. Their endeavors on behalf of the Chesapeake would be far more effective if each of them, in company with a dozen or so neighbors, packed up and moved to North Dakota.

The one fisheries “success story” in the Chesapeake – the resurgence of the striped bass population – has been tarnished by recent reports that a large part of the population has been afflicted with mycobacteriosis a lethal bacterial disease that has been increasing in the Bay’s striped bass for at least a decade.⁵ Mycobacteriosis is linked to degraded water quality.

The situation regarding coastal development in Alaska is unique. With such a sparsely populated coastline, it’s hard to imagine that there are any impacts from coastal development, and though the coastal population density has increased slightly, according to the U.S.D.O.C. it won’t reach two people per square mile until 2008 (the following chart lists the state-by-state coastal population density). This is in strong contrast to the other coastal states, with coastal population densities ranging from 60 people per square mile (Maine and Georgia) to 1,777 (New York). While Alaska’s fisheries are considered to be among the world’s most well managed, as they rightfully should be, isn’t there another message in there as well? Why is managing fishing mortality effective in managing Alaska’s fisheries while it’s for the most part inadequate in other fisheries? New England and the Chesapeake Bay estuary are in no way unique. In fishery after fishery and for year after year, commercial fishing effort is reduced because fisheries management is all about reducing fishing mortality and not about much else. And while fishing effort is continuously reduced, the coastal population continues to climb and the attendant “natural” mortality continues to increase.

 And Natural cycles in fish populations

Some fish stocks vary cyclically. Among the most well-known examples of this are the extremes exhibited by west coast sardine/anchovy stocks. Sardines off California go through a “boom or bust” cycle, to be replaced by anchovies as their populations plummet. This cycle, which was responsible for the collapse of the sardine fishery that had supported Cannery Row in Monterey, is driven by changes in oceanographic conditions brought about by a short-term “climatic” cycle of a 50 to 60 year duration and has been tracked back several thousand years.⁶

Related to the El Niño cycle and other factors, regime shifts in the Pacific drive periodic fluctuations in fish stocks. While research is not as well advanced, regime shifts are at work on fisheries in the Atlantic as well.^7,8

One might argue that, in the face of declining fish stocks, rational fisheries management would demand a reduction in fishing effort, and in some instances that’s surely the case. But one could just as well, and more convincingly argue, that in rational fisheries management all sources of mortality should be identified and quantified and, to the extent possible, controlled. That should be one of the primary underpinnings of ecosystem management, but it isn’t happening. According to the management establishment, it’s only about fishing. Our fishermen and our fish are paying the price.

1  http://www.fishbase.org/Glossary/Glossary.cfm?TermEnglish=natural%20mortality

2  http://www.nefsc.noaa.gov/sos/intro/

3 http://www.whoi.edu/oceanus/viewArticle.do?id=2487

4 http://erf.org/user-cgi/conference05_abstract.pl?conference=erf2005&id=146

5 http://www.dnr.state.md.us/fisheries/oxford/stripedbass/

6  http://news.nationalgeographic.com/news/2003/01/0109_030109_fisheries.html

7 http://www.ices.dk/iceswork/asc/2004/abstracts/abstracts/M.pdf

8 http://tinyurl.com/n7e8x

http://www.undercurrentnews.com/2014/09/11/nfi-california-industry-cry-foul-over-oceana-backed-seafood-mislabeling-bill/

Further Thoughts on Oceana’s “fight seafood fraud” Campaign:

What is this “mislabeling” and “seafood fraud” scuffle all about these days? Why, you might ask, is Oceana suddenly so concerned about “truth in packaging” for fish? And what is behind their somewhat baffling concern for the fish-consuming public?

Actually, Pew, Oceana, EDF, NRDC, and CLF (and too long a list of their additional subsidiaries to cite here) have for many years been doing some of their own “mislabeling” and “seafood fraud”. They’ve been “mislabeling” fishermen as overfishing-greedy-habitat-destroyers. In addition, these public welfare-minded NGOs perpetrated “seafood fraud” and violated any “truth in packaging” ethic when they poured millions into campaigns of misinformation and outright lies promoting the privatization scam of ITQ’s or catch shares. In the years leading up to their imposition on the New England Fishery in May of 2010, Pew/Oceana/ EDF employed “untruth in packaging” when they wrapped their catch shares product in the fallacious claim that “catch shares were a fish conservation effort and were guaranteed to enhance fishermen’s profitability and safety”. They were also “mislabeling” this Individual Transferable Quota System as “catch shares sector management” which was a legalese semantic maneuver clearly designed to skirt statutes in the Magnuson Stevens Act which would have required a 2/3 referendum vote by permit holders, a vote which, in all likelihood, would have stopped this privatization scam in its tracks. But Pew, EDF, and Oceana got catch shares installed. They worked the media and “worked it from the inside” through the “you’re getting’ catch shares …like it or not” decrees from NOAA director Jane Lubchenco, a Pew Fellow and former EDF Board Member.

But Oceana is an Environmental Non-Profit, Right? You know, Protecting The World’s Oceans?

Non-profit indicates non-taxable, and a tax deductible status for donations. It’s an IRS designation. But, non-profit does not indicate non-revenue or non-fat salaries and compensation packets for the non-profit’s corporate-style executive officers. If the “executives” that run these “non-profit” NGOs were not donation-plowing in order to “increase the market value of their Fund” and lining their pockets with six and seven figure salaries under the guise of “free-market-environmentalism” or “doing good while doing well” or getting very wealthy while saving the ocean from the greedy fishermen; if they were not so hostile to domestic fishing and were not pouring their resources into dismantling the US domestic fishing industry, there wouldn’t be such a vacuum in the domestic market and there wouldn’t be such a gaping hole in domestic supply for the inferior imported fish to pour into.

If the so very concerned NGOs were not working overtime to do all they can to eliminate local fishermen along with the abundant supply of local fresh fish that they provide, the consumers they’re so worried about becoming victims of “seafood fraud” would have plenty of affordable fresh domestic and properly labeled fish at their local fish monger or supermarket fish case. If domestic product was not choked off, distributors wouldn’t be so desperate for fish to fill their orders. Imported, mislabeled, unhealthy contaminated product, in most cases, would not be any competition for fresh local quality fish. Mislabeling would not be an issue if U.S. domestic fishermen were respected and not seen as the eco-villains; and if they were not being prevented from supplying the public’s demand for healthy fish protein.

But how did this antagonistic attitude toward domestic fishing come about?

Clearly, NOAA’s posture of “too many greedy fishermen chasing too few endangered fish”, and the consequent impossible constrictive fishery management posture, originates with the NGO blitzes of the endangered-species-of-the-month-club media campaigns. One month the NY Times, The Boston Globe, PBS TV, and the internet blogosphere will be inundated with NGO warnings of impending doom for a particular fish species, or category of species, or a type of reef coral, all on the brink due to overfishing and destructive fishing techniques. Next an amendment to a regulation which would save from extinction and protect for perpetuity the chosen endangered fish (or coral or turtle or dolphin or sturgeon or essential forage fish or the forage fish’s predators— depending on the month) mysteriously appears “on the table” for discussion at a regional council meeting. Add the threat of a lawsuit from some vociferous Pew lawyers in the audience and several (not particularly impartial when it comes to commercial fishing) council members grumbling their limited understanding of the intent and spirit of Magnuson statutes, “Spawning Biomass” and “Maximum Sustainable Yield”… and there you have it, a new more restrictive and long overdue management measure and “conservation tool”. And the NGO headline… Ocean Creatures Saved from the clutches of the “greedy industrial fishers! Accomplished through your Ocean Donation! And by concerned scientists and conservationists and dedicated government fish managers working through regional councils just full of stakeholder representatives!  And…Eureka, Fisheries management is Working Great! See? So, more of the same, Please.

The ridiculous regulations are bad enough which along with the fallacious catch shares have certainly achieved their “consolidation goal” and have already put many fishermen out of business…and counting; but one of the most disheartening aspects of this corporatist NGO war on independent fishing businesses is that it has leached into the general public’s attitude toward U.S. fishermen. Fishermen are right up there with forest clear cutters as they “… drag enormous nets scraping the ocean bottom clean of all life, destroying the habitat as they go further and further offshore seeking new grounds and healthier fish stocks to exploit and destroy” made possible by their technologically advanced electronic fish-finders”.

So again, if the regional fish management councils and NOAA’s legal department was not so cowed by the intrusion of Pew’s anti-fishing litigation mercenaries, i.e. the Conservation Law Foundation and their looming threat of endless lawsuits. If the “Commerce” Department didn’t roll over for big biz and advocate reprehensible trade scams like the Trans Pacific Partnership which would supersede tariff, safety, and probably most FDA inspection regulations. If U.S. fishermen were not prevented from supplying fish, then cheap and unhealthy Pangasius, Tilapia, and farmed Shrimp would not be found on our menus and would never be significantly competing with domestic landings in our venerable fish market auctions.

As W.C. Fields says, “You can’t cheat an honest man…” or if the product being scammed wasn’t so inferior, if it was honest fresh domestic fish, it wouldn’t require any “seafood fraud” in order to sell it. It wouldn’t have to cheat and be “mislabeled” as quality fish.

It really wouldn’t make a great deal of sense to mislabel a domestic fresh product such as Atlantic Haddock and Cod or Pacific Flatfish and Pollock as Panga, or Yellowtail Flounder as Tilapia, or fresh Southeast Atlantic and Gulf of Mexico Shrimp as a product of Viet Nam. It works in the other direction. The “seafood fraud”, the sleight of hand, the mislabeling of the imported product as local fresh quality fish, becomes a marketing ploy in order to move inferior fish by some unscrupulous dealers and big chain-store buyers when the market is blitzed with “dumped” imported uninspected and contaminated Tilapia, Pangasius, and pond-raised Shrimp.

Well then, what is behind this expensive Oceana media and legislative campaign to “fight seafood fraud”?

This is not a case of legislating 1,827 names for our fish that already have names. That is not the fix for this problem. This is not a problem of a lack of specificity in labeling as the mindless Oceana campaign advocates. This is the same old problem of corporation/government corruption and the big-biz-shill NGO’s’ self-serving exploitation of an unsuspecting public through the usual scapegoating of the domestic fishing industry.

If altruistic Oceana is so concerned and wants to “fight seafood fraud” they should look to their own Ocean Programs first. It’s fraudulent to spawn a full media blitz declaring Swordfish and Tuna as full of mercury and as an overfished and endangered species with nothing to back up such preposterous claims as Oceana and the Natural Resources Defense Council have done in the past—not to mention the “endangered” Sturgeon. It’s fraudulent to use their own propaganda articles as a reference (or even worse Worms’ and Pauly’s bought and paid for Pewian “science”) and declare saving the “forage fish” as the basis for a campaign to constrict fishing on prolific stocks such as Butterfish, Sardines, Menhaden, and Herring. It’s fraudulent to characterize small independent family-owned and family-funded fishing vessels as “industrial trawlers taking way too much and destroying the ocean habitat in the process”. It’s fraudulent to fund, with tens of $millions, a fraudulent campaign to impose a fraudulent privatization ITQ scheme fraudulently called catch shares and then fraudulently justify the resulting “fleet consolidation” or the elimination of the majority of the local fleet as a conservation measure helping the fish and making the fishermen “more profitable”. Now that is “seafood fraud”!

If Oceana or any other NGO is truly interested in protecting the fish-consuming public and wants to guarantee them a safe fresh healthy fish product, they might stop trying to kill U.S. fishing on some of the most productive fishing grounds in the world. They might work on getting the government to abandon sleazy trade agreements and instead demand the enforcement of existing tariffs that were designed to protect domestic fishing and enhance marketing for the domestic fresh product. This would then go a long way to prevent the inferior imported fish from entering the U.S and would make obsolete the need for any marketing scams of “seafood fraud” mislabeling.

Saving the consumer from mislabeled domestic fish is just another “easy-to-catch” media straw man created by NGOs like Oceana. This endeavor is nothing but more fund–raising public opinion manipulation along the way of their well-engineered and very well-funded mission to discredit and remove the local domestic fishing industry from the U. S. Continental Shelf.  Such a clearing-off might just be of some interest to the oil industry—just a thought.

http://www.offshore-mag.com/articles/2011/11/boem-announces-proposed.html and http://www.noia.org/offshore-energy/access/

http://www.undercurrentnews.com/2014/09/11/nfi-california-industry-cry-foul-over-oceana-backed-seafood-mislabeling-bill/

And how might anti-fishing Oceana be connected to big oil?

Oceana was established in 2001 by a group of leading foundations — The Pew Charitable Trusts, Oak Foundation, Marisla Foundation (formerly Homeland Foundation), and the Rockefeller Brothers Fund. http://oceana.org/en/eu/about-us/history

Pew Foundation, as most people interested in ocean matters are aware, is the Joseph N. Pew Sunoco Oil fortune, with holdings in Exxon Mobil and other major oil corporations.
Oak Foundation was started by Alan M. Parker the current President of Government Group of ENERGYSOLUTIONS, INC a natural gas consulting firm.
Marisla Foundation is the Getty Oil fortune.
Rockefeller Bros. Fund: Rockefeller? Standard Oil and Exxon Mobil should ring a bell.

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