FISHERYNATION.COM

The question should actually be “how much is FishNet USA worth to you?”

I’ve been writing stuff for the commercial fishing industry for over three decades. That’s a lot of words, and I suspect that no one who is on the present distribution list, who has read my columns in National Fishermen or on Saving Seafood, or has FishNet issues forwarded to them from someone on the list has not benefitted from some of them.

One of their most valuable contributions to the domestic commercial fishing/seafood industry has been to let “outsiders” know that someone is out there watching and reading and researching, and if they write anything that isn’t spot-on accurate or that is too far removed from the real world that we live in, they might get publicly called out on it. And they might get called out with well researched references, links, charts, and etc.

Below are links to mostly randomly chosen pieces I’ve written that are available on the web (I’m working on a compilation of what I’ve written on commercial fishing since the early days. It’s up to 2,500 or so pages and still growing). Take a look.

https://www.fishnet-usa.com/COVID19pt2.pdf (Written when, at the beginning of the still-ongoing Covid pandemic, NOAA/NMFS, which had tied their research fleet up, was trying to force on-board observers onto commercial fishing vessels).

https://fisherynation.com/fishnet-usaso-how-are-we-doing-2017-edition

https://fisherynation.com/fake-news-incomplete-inaccurate-reporting-intentional-misdirection-and-fishing

https://www.fishnet-usa.com/All%20Stolpe%20Columns.htm (These are Different Perspective columns I wrote for National Fisherman ending in 2011. If there is any subject or situation that was important to you back then, use your browser’s “find” function to see if I addressed it. I’d recommend “black helicopters,” “barndoor skates,” “anti-fishing movement,” and “law enforcement” for starters. Or just browse round.

https://www.vikingvillage.net/post/where-are-all-of-the-self-styled-ocean-saviors The so-called Precautionary Principle, which had been one of the primary weapons employed by the anti-fishing activist individuals and organizations in their efforts to destroy the domestic commercial fishing industry, was left by the wayside in their rush to cozy up to the multinational mega corporations and their $billions.

Thanks to the Covid mess, and also thanks to what seemed to me to be some philosophical differences between me and some prior sponsors who were part of a commercial fishing consortium that was trying to get into the windmill business, my industry support has dwindled down to the point where the funds coming in just about cover my internet/telecommunications costs. Unlike just about all of our domestic fisheries, this is not sustainable.

Folks, I’ve been here for most of forty years, and I think that the threat the commercial fishing industry in the U.S. is facing today, the massive development being planned for what seems to be virtually all of our inshore/offshore areas, is greater than it’s ever been. This includes pre-Magnuson foreign factory trawler fleets in our EEZ, the mercury contamination scare, the anti-fishing campaigns by the enviro orgs and the accompanying demonization of commercial fishermen, the rampant bureaucratization (and the “greening”) of our federal and state management agencies, and anything else that we’ve dealt with.

There is a new organization that is working on some of these looming development-read that “ocean turf wars”-issues, and I salute the effort. But they’re going to need all the help that they can get, and then some.

I’ve built up a reasonable amount of credibility, and I’d like to continue to make that available to all of you in the future. But that’s not going to happen without your financial support. Look over the linked material above. We need more of that, and we need more people to see it. If you have a particular issue, contact me and if I’ve addressed it, I’ll let you know where and when. But I can’t work for free. That’s what I’ve been doing of late and it can’t continue.

I’ve done a lot for the industry, and I’ve addressed a lot of issues without your support, but that was then, and now is now.

If you are interested in helping to continue my efforts to continue to support you and your industry, please contact me at [email protected], or at 609 731 3368. If my phone doesn’t recognize your number, your call won’t be answered. (my car is still covered under the original warranty). Please leave a message.

It’s been suggested that I do a “go fund me” site for FishNet. If that would be convenient for you, let me know. Also, if you have any other ideas for making FishNet sound and economically viable, please let me know.

In addition to my regular distribution of FishNet, in 2019 the three websites that I created and maintain had 66 thousand visitors who downloaded 151 thousand pages. Ten years ago, if my memory is still working accurately, the sites had over 300,000 visitors annually. That’s a lot of eyes, particularly considering that I haven’t done anything to promote the sites for going on 5 years. This could be a tremendous starting point and I would like nothing better than to update and promote these sites.  The sites are FishNet USA (http://www.fishnet-usa.com), FishTruth (http://www.fishtruth.net) and FishingNJ (http://fishnetnj.org).

I designed the sites to allow quick and easy updates, and each would be a great tool to get messages to the masses-perhaps limited masses, but the people who visit are all interested in fish and/or fishing. They could be the start of a pro-fishing of people we should be targeting

Take a look at them, bearing in mind that they’re all a bit out of date. There’s a tremendous potential for growth there, but it will take a lot of work, and at this point that work is not going to get done.

PS – Thanks to the folks at Viking Village in Barnegat Light, NJ and at Fishery Nation.com for helping to disseminate my stuff. Viking Village has been a “founding supporter” of Fishnet USA from the beginning until this Covid mess and Fishery Nation has provided and continues to provide and invaluable (and too often unrecognized) service to our commercial fishing industry. And thanks as well to The Fishermen’s Dock Cooperative, Viking Village, Lund’s Fisheries, Atlantic Capes Fisheries, Saul Phillips, Marc Agger and a handful of other individuals and organizations for seeing the need for an electronic publication like FishNet USA, for getting it started and for keeping it going for 20+ years.

Thanks for your attention, Nils Stolpe

Nils E. Stolpe/FishNet USA
July 27, 2017

(Note that I am only addressing the NOAA/NMFS reliance on bottom trawl survey data in finfish stock assessments. I am not questioning the value of the wealth of biological and physical data that this long – running series of surveys generate.)

“The spring and autumn bottom trawl surveys conducted by the Northeast Fisheries Science Center are the longest running continuous time series of research vessel sampling in the world. The autumn survey began in 1963; the spring in 1968 (Azarovitz 1981). These surveys cover the ocean environment from 5 to 200 fathoms deep, from Cape Hatteras, North Carolina to well beyond the Canadian boarder [sic]. About 300 half-hour trawl sets are made at sites (stations) randomly chosen prior to the beginning of each survey. The objective of each tow is not to catch large numbers of fish, but to capture a representative sample of the various species and relative numbers in a given area. The distribution of trawling locations is allocated according to a statistical method that divides the region into a number of smaller areas (strata) with similar depth characteristics. The method is a stratified-random sampling design, and is commonly used for a wide variety of statistical estimates, including exit polling for elections. In the history of the trawl surveys, only three research vessels — NOAA’s FSV Henry B. Bigelow, FRV Albatross IV and the FRV Delaware II — have been used to conduct these surveys.” Click here .

“The NEFSC bottom trawl survey is a fisheries independent, multi-species survey that provides the primary scientific data for fisheries assessments in the U.S. mid-Atlantic and New England regions,” NOAA National Centers for Environmental Information, Click here

For the fishing industry in the mid-Atlantic and New England the results of the two annual – with three annually for a few years ending in 2008 – bottom trawl surveys are more important than any other factor in determining what the upcoming harvest in several dozen fisheries will be.

According to NOAA/NMFS these surveys have provided and continue to provide “the primary scientific data” for fisheries assessments from North Carolina to Maine (fisheries assessments are the periodic – generally held every 3 to 5 years – scientific/bureaucratic exercises. In NOAA’s words “NOAA Fisheries’ scientific stock assessments are critical to modern fisheries management. Using data gathered from commercial and recreational fishermen and our own on-the-water scientific observations, a stock assessment describes the past and current status of a fish population or stock, answers questions about the size of the stock, and makes predictions about how a fishery will respond to current and future management measures.”)

Needless to say, these stock assessments are of overriding importance to anyone who is dependent on fish and fishing, and the annual bottom trawl surveys provide the scientific underpinnings for management decisions in those fisheries for the majority of species in the Northeast region.

This being the case, I thought that it would be instructive to examine the relationship between the survey results and the commercial landings for some of the species which the surveys sample. I used what I judged to be the twenty-one most valuable/important species and ignore several (sculpin, little skate, etc.) which I judged to be of less commercial significance.
So how accurate are these bottom trawl surveys – and the stock assessments which depend on the information they generate? I doubt that there are easy answers to these questions, and I’m certain that if there are, I don’t have them. But in an attempt to provide you with enough information to at least begin to consider such questions I’ve charted the survey results and commercial landings going back to 1963 for twenty mid-Atlantic/New England fisheries. As in my last FishNet, (So how are we doing? (2017 edition) A Report on our Domestic Commercial Fishing Industry (click here) instead of considering the actual survey results and landings I’ve charted each annual datum as a percentage of the maximum for that species (i.e. the 1977 total survey count for scup – blue line – was 18,549, 30% of the maximum total count of 61,818 in 2015, the 1977 total survey weight – red line – was 830 kilograms, 35% of the maximum of 2,387 kilograms in 2010, and the 1977 commercial landings – green area – were 8,699 metric tons, 35% of the maximum landings of 19,015 metric tons in 1963).

In 1963 when only one trawl survey was done the total weights/counts for that survey were used, in subsequent years when two or three surveys took place the total weights/counts were divided by two or three respectively.

Beneath each species chart I have recorded the maximum (100%) numbers for fish sampled each year, weight of sampled fish, and commercial landings.
Below are thumbnails of twenty-one charts.

Larger images are available. Click here

While the charts are all similarly sized, keep in mind that they represent fisheries with landings that ranged from 3,000 to 120,000 metric tons valued at $2 million to almost $200 million per year.

The table below details the maximum survey results (count and weight) for each fishery (the 100% point in each chart above), maximum landed weight and value (corrected for inflation), the weight and value of the 2015 landings and the percentage of the maximum landed weights represented by the 2015 weights.

Among the secondary questions that this raises are 1) are the trawl surveys – at least in the Northeast – worth their cost, 2) should the trawl survey results be accorded the importance in stock assessments that they are, 3) is the situation similar in the other NOAA/NMFS regions, and 4) is there a more cost effective way to generate more useful/relevant data?  But the most important question – particularly in view of the last column in the above table (2015 landings as % of Max) is how much the of the domestic commercial fishing industry is being sacrificed on the NOAA/NMFS/ENGO alter of sustainability? The commercial landings of these 21 species in 2015 were on the average only 21% of the maximum landings for each species since 1963. Such a level of underfishing surely isn’t what sustainability –  or conservation – is supposed to be about.

Finally, for reference, I used a random number generator to get 53 random numbers between 1 to 100 and treated the generated numbers as I did the survey weights and numbers. Below I superimposed the graph of these numbers over the Atlantic Croaker landings graph. (There was no particular reason I used croaker landings. Any of the 21 species would have served the same illustrative purpose.)

The most obvious take-away message I could glean from all of this is that, at least to a statistically unsophisticated eye there is no apparent relationship between the trawl survey results and commercial landings among all twenty-one species that I focused on. I can’t say that when the sample numbers and/or weights go up the landings will increase correspondingly or that when the landings go up the sample numbers and/or weights will go down correspondingly. In fact the random numbers chart, to my perhaps untrained eye, could be substituted for any of the twenty-one other charts and nothing about it would jump of the page at a reader.

Among the secondary questions that this raises are 1) are the trawl surveys – at least in the Northeast – worth their cost, 2) should the trawl survey results be accorded the importance in stock assessments that they are, 3) is the situation similar in the other NOAA/NMFS regions, and 4) is there a more cost effective way to generate more useful/relevant data?  But the most important question – particularly in view of the last column in the above table (“2015 landings as % of Max”) is how much of the domestic commercial fishing industry is being sacrificed on the

NOAA/NMFS/ENGO alter of sustainability? The commercial landings of these 21 species in 2015 were on the average only 21% of the maximum landings for each species since 1963. Such a level of underfishing surely isn’t what sustainability –  or conservation – is supposed to be about.

(I’m encouraging comments on this FishNet and will distribute those that I receive, either pro or con. Thank you,)

The comments are open on this page.

Nils E. Stolpe

FishNet USA/December 4, 2015

“At the global scale, probably the one thing currently having the most impact (on the oceans) is overfishing and destructive fishing gear.” (former National Oceanic and Atmospheric Administration head Jane Lubchenco in an interview on the website Takepart.com on April 7, 2010.) The Deepwater Horizon oil spill catastrophe began on April 20, less than two weeks later.

Each year in the U.S. hundreds of millions of tax dollars are spent on what is called fishery management. It’s called fisheries management in the Magnuson-Stevens Fishery Conservation and Management Act. The federal administrative entities which implement the mandates of the Magnuson-Stevens Act are designated in the Act as Regional Fishery Management Councils, and the bureaucrats and scientists who are involved in those mandated activities are referred to as fishery managers.

But all things considered, can what the Magnuson-Stevens Act mandates, what the Regional Councils are charged with and what the managers do be considered fishery management?

Let’s consider what management of either naturally occurring or cultured living organisms (other than fish and shellfish) actually entails. The most obvious requirement of managing them is the provision of something between an adequate and an optimum environment, including both the living and the non-living components of that environment, for the species/species complexes being managed. This is regardless of whether the management process is aimed at optimizing the production of one (or a few) species or at maintaining an area in a so-called “natural” state (though how close any area can be to natural, considering humankind’s pervasive impacts on virtually the entire biosphere, is open to argument).

Whether it’s a herd of dairy cattle, a field of poppies, a national park or an entire watershed, the involved individual or collective managers are charged with maintaining an appropriate environment for the organisms/systems being managed.

How does “fisheries” management fit in with this? Quite obviously and not so surprisingly, not all that well.

When we are considering maintaining (or ideally, increasing, though in the U.S., Canada and the EC in particular we’re far from ready for the “giant step” of increasing the harvest) capture fisheries in natural systems, there is a host of both natural and anthropogenic factors that play a significant role in determining the population levels of particular species. Among them are:

· Water quality · Entrainment/impingement  · Water temperature  · Disease/parasites  · Wind direction/duration  · Parasitism  · Upwelling

· Turbidity  · Food availability  · Competition · Predation  · Cannibalism  · Essential habitat availability  · Reproductive success  · Fishing

And there are undoubtedly others.

So what do the people in the ENGOs who, with a bunch of help from their foundation keepers, have become so adept at manipulating the press, the pols and the public do when there aren’t enough fish? They demand that the managers reduce (or eliminate) fishing. This is regardless of the effect of any other factor on the particular fish stock or the effectiveness of reducing or limiting fishing in rebuilding the stock in question (and “rebuilding” the stock almost always means returning it to maximum population levels).

And the managers for the most part go along because they have to do something to justify their positions, and thanks to federal legislation controlling (or eliminating) fishermen is a lot easier than controlling just about anything else. It’s easier politically, it’s easier scientifically, it’s easier economically and it’s easier technologically. So what if it isn’t effective? Thanks to the extensive efforts of anti-fishing activists over the last two decades (see Pew and the media Click here), cutting back or eliminating fishing is just about a guarantee of positive media coverage, and there are few politicians, reporters or members of the public who have enough of a grasp of the involved complexities to know the difference. Besides which there will be enough tilapia and swai and cultured shrimp produced overseas to keep the consumers fed – if not in culinary nirvana.

This has cost and is costing the domestic fish and seafood industry untold millions of dollars every year in uncaught fish that could be sustainably harvested. It is denying U.S. consumers the health benefits and the undeniable pleasures of dining on ocean-fresh, locally produced seafood and it is costing our coastal communities tens of thousands of jobs every year.

With what seems a monomaniacal fixation on the effects of fishing, a fixation which has been successfully – and tragically – spread virtually everywhere in this country, many other factors of equal or greater potential to temporarily or permanently interfere with vital ocean processes or the health of our fish stocks have been largely or completely ignored.

At the time it sounded good, at least to the un- or ill-informed

I started this FishNet with a quote from Jane Lubchenco from less than two weeks before the Deepwater Horizon catastrophe began to unwind in the Gulf of Mexico. At the time she was the newly appointed head of NOAA, the agency in the US Department of Commerce that is in charge of about everything non-military in the US Exclusive Economic Zone. Her academic background was as a tide pool biologist. She was a Pew Ocean Fellow and a member of the Pew Oceans Commission and in keeping with the Pew spin on the oceans and their misuse, appeared to believe that she and her ideas could save the world’s fisheries – from the fishermen.

As the quotation demonstrates, she was so concerned with the supposed evils of fishing that she assumed that everything was more than fine with our federal policies regarding the safety of our offshore energy systems. I won’t rehash it here but I’d strongly recommend that you go over the FishNet on this issue I did while the Deepwater Horizon well was still gushing an eventual 5 million barrels of oil into the Gulf of Mexico, Fish and Oil: NOAA’s Attitude Gap, Click here (and delayed Exxon Valdez impacts were still being revealed by researchers in the agency she now headed – see http://www.nwfsc.noaa.gov/news/features/delayed_effects_oilspill/index.cfm.) Perhaps if Dr. Lubchenco and the people she brought with her from the ENGO world weren’t so myopically focused on overfishing, offshore oil wells would have received some of the governmental scrutiny that was, and still is, so illogically directed at commercial fishermen. What are the chances that doing so would have saved the U.S. taxpayers a few bucks and spared the Gulf of Mexico – and the businesses that are dependent on its ecological integrity –the possibly irreversible damages caused by the huge oil spill?

The situation vis-a-vis on-board observers is the most dramatic indication of how skewed perceptions have become regarding ocean/fishery protections. In just about all federally regulated fisheries there are requirements for on-board federal observers, who are increasingly being paid for by the vessel owners/operators. These observed trips range in frequency from 100% coverage of all of the vessels in a fleet to vessels being assigned to carry an observer on a trip once a month or so, and with charges – often to the vessel – approaching a thousand dollars per day at sea. In fisheries in which landings are severely limited, observer costs can force vessels into bankruptcy.

These observers are there to track the catch and bycatch of the vessel to insure that quotas are not exceeded and that the take of protected species are accurately accounted for. There are also requirements for at-sea and at-the-dock reporting, so the catch of a vessel may be reported three separate times.

Surprisingly, or perhaps not so surprisingly considering the attitude of federal policy-level folks like Dr. Lubchenco, there are no requirement for any official observers on oil tankers, drilling rigs or other offshore vessels or structures that could have a negative environmental impact in our EEZ. As we have seen in a history of maritime accidents extending back for at least a half a century, these disasters can cause hundreds of millions of dollars or more in damages.

The following table is from The International Tanker Owners Pollution Federation Limited website (cached by The Wayback Machine at http://tinyurl.com/osw5slv). These were only spills from tankers, not drilling rigs or pipelines. Note that the Exxon Valdez spill, while included, ranked only number 35 in spill size. Note also that the authors assumed that offshore spills “caused little or no environmental damage.” The cached version of the website was from 2007/08.
The table below gives a brief summary of 20 major oil spills since 1967. A number of these incidents, despite their large size, caused little or no environmental damage as the oil did not impact coastlines, which is why some of the names will be unfamiliar to the general public. The Exxon Valdez is included because it is so well known although it is not the twentieth largest spill but rather the 35th.

Position     Shipname              Year                Location                               Size (in tonnes)

1        Atlantic Empress          1979      Off Tobago, West Indies                    287,000

2           ABT Summer             1991     700 nautical miles off Angola            260,000

3     Castillo de Bellever        1983   Off Saldanha Bay, South Africa           252,000

4         Amoco Cadiz               1978        Off Brittany, France                          223,000

5             Haven                       1991             Genoa, Italy                                    144,000

6           Odyssey                      1988  700 nautical miles off Nova Scotia      132,000

7        Torrey Canyon             1967             Scilly Isles, UK                               119,000

8           Sea Star                      1972             Gulf of Oman                                 115,000

9       Irenes Serenade            1980       Navarino Bay, Greece                      100,000

10         Urquiola                     1976          La Coruna, Spain                            100,000

11      Hawaiian Patriot          1977  300 nautical miles off Honolulu         95,000

12      Independenta               1979           Bosphorus, Turkey                        95,000

13     Jakob Maersk                1975          Oporto, Portugal                             88,000

14         Btaer                            1993         Shetland Islands, UK                     85,000

15       Khark 5                         1989 120 nautical miles off of Morocco       80,000

16     Aegean Sea                    1992             La Coruna, Spain                         74,000

17      Sea Empress                1996             Milford Haven, UK                      72,000

18        Katina P                     1992        Off Maputo, Mozambique               72,000

19          Nova                         1985    Off Kharg Island, Gulf of Iran            70,000

20        Prestige                     2002              Off Galicia, Spain                       63,000

35      Exxon Valdez             1989     Prince William Sound, Alaska           37,000

As we saw in the Deepwater Horizon episode, effective federal oversight was sorely lacking, and I’ve yet to see much progress there other than some bureaucratic rearranging and changing the name of the agency in charge. Human nature is human nature, whether the human is on an oil tanker, an offshore drilling rig or a commercial fishing vessel. But the potential for damages with the tanker or the drilling rig can range into the many billions of dollars while a fishing boat might kill a couple of thousand dollars’ worth of over-quota fish. And the income earned by a drilling rig or tanker every year is many orders of magnitude greater than the fishing vessel. Yet we don’t have a federal observer on the bridge of every tanker or on board every rig in the Gulf.

(It’s important to note here that the Pew Charitable Trusts, which has been directly responsible for much of the anti-fishing efforts over the last two decades, is largely controlled by heirs of Joseph Pew, the founder of Sun Oil/Sunoco.)

Gulf of Maine cod – again it’s not just fishing, and again it’s Jane Lubchenco

“We need a rapid transition to sectors and catch shares. Catch shares are a powerful tool to getting to sustainable fisheries and profitability. I challenge you to deliver on this in Amendment 16, to include measures to end overfishing. I will commit the resources to my staff to do their part to ensure Amendment 16 is passed in June. We are shining a light on your efforts and we will track your progress. There is too much at stake to allow delay and self-interest to prevent sectors and ultimately catch shares from being implemented. We are shining a light on your efforts and we will track your progress. There is too much at stake to allow delay and self-interest to prevent sectors and ultimately catch shares from being implemented.” (Ms. Lubchenco on April 8, 2010 while telling the New England Fisheries Management Council how her policies were going to fix the New England groundfish fishery – by Julie Wormser on the Environmental Defense blog EDFish/.)

What she said the day after her less than prophetic statement that fishing was the biggest threat to the world’s oceans was yet another demonstration of Ms. Lubchenco’s commitment to the naïve idea that just about any problem with the world’s oceans could be solved by adequately controlling fishing.

Six and a half years after her “catch shares revolution” that she kicked off by inflicting it on the New England groundfish fishery, the fishery is in a shambles and New England has lost much of it’s fishing infrastructure. This has all happened as fishing effort has been reduced so many times that far too many fishermen can no longer afford to fish for their own quota or to buy or lease quota from other fishermen in similar straits. So what was wrong with Ms. Lubcheco’s foresight this time?

The recent media mini-frenzy brought about by the release of a study relating the decline of codfish in New England to increasing ocean temperatures will give you some idea. The study was titled “Slow adaptation in the face of rapid warming leads to collapse of the Gulf of Maine (GOM) cod fishery.” Not incidentally, it was funded by the Lenfest Foundation, the fisheries-related grants of which are “managed” by the Pew Trusts.

For an idea of the misdirected zeal with which the people at Lenfest pursue their “scientific” objectives, in their report on Subsidies to U.S. Fisheries, Lenfest researchers R. Sharp and U.R. Sumaila (who was also a Pew Oceans Scholar) list “Fuel Subsidies” as the largest category. They describe these as “exemptions from federal and state fuel taxes and some state fuel sales taxes.” In reality they are refunds of federal and state highway use taxes available to fishermen or any other commercial/industrial users who are “exempt” from the tax. This is because they do not use the federal/state highway systems (http://tinyurl.com/RoadUseTax).

Sharp and Sumaila also include “sales tax exemptions,” which also aren’t fishing-specific subsidies but exemptions from sales taxes which are provided to any businesses for qualified purchases. The authors apparently believe that having fishermen pay taxes that the federal and state governments don’t intend them to pay would eliminate a “harmful subsidy” and “could improve the health of fisheries in the U.S.”

The following quotes were taken directly from the paper (my emphasis added):

· Recovery of this fishery (GOM cod) depends on sound management, but the size of the stock depends on future temperature conditions.

· Based on this analysis, the Gulf of Maine experienced decadal warming that few marine ecosystems have encountered.

· The Gulf of Maine cod stock has been chronically overfished, prompting progressively stronger management, including the implementation of a quota-based management system in 2010. Despite these efforts, including a 73% cut in quotas in 2013, spawning stock biomass (SSB) continued to decline.

· The Gulf of Maine is near the southern limit of cod, and previous studies have suggested that warming will lead to lower recruitment, suboptimal growth conditions, and reduced fishery productivity in the future.

· Gulf of Maine cod spawn in the winter and spring, so the link with summer temperatures suggests a decrease in the survival of late-stage larvae and settling juveniles. Although the relationship with temperature is statistically robust, the exact mechanism for this is uncertain but may include changes in prey availability and/or predator risk. For example, the abundance of some zooplankton taxa that are prey for larval cod has declined in the Gulf of Maine cod habitat. Warmer temperatures could cause juvenile cod to move away from their preferred shallow habitat into deeper water where risks of predation are higher.

· The average weight-at-age of cod in the Gulf of Maine region has been below the long-term mean since 2002, and these poorly conditioned fish will have a lower probability of survival.

· Temperature may directly influence mortality in younger fish through metabolic processes described above; however, we hypothesize that predation mortality may also be higher during warm years. Many important cod predators migrate into the Gulf of Maine or have feeding behaviors that are strongly seasonal. During a warm year, spring-like conditions occur earlier in the year, and fall-like conditions occur later. During the 2012 heat wave, the spring warming occurred 21 days ahead of schedule, and fall cooling was delayed by a comparable amount. This change in phenology could result in an increase in natural mortality of 44% on its own, without any increase in predator biomass.

An article in the Boston Globe about the study reported that “the authors… say the warmer water coursing into the Gulf of Maine has reduced the number of new cod and led to fewer fish surviving into adulthood. Cod prefer cold water, which is why they have thrived for centuries off New England. The precise causes for the reduced spawning are unclear, the researchers said, but they’re likely to include a decline in the availability of food for young cod, increased stress, and more hospitable conditions for predators. Cod larvae are eaten by many species, including dogfish and herring; larger cod are preyed upon by seals, whose numbers have increased markedly in the region.” (Climate change hurting N.E. cod population, study says, David Abel, October 29, 2015.)

While Mr. Abel neglected to mention it, post-larval cod up to maximum size are also consumed by adult spiny dogfish, as are the fish and shellfish that cod feed on. From Bigelow’s and Schroeder’s classic Fishes of the Gulf of Maine, “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…. At one time or another they prey on practically all species of Gulf of Maine fish smaller than themselves….”

The authors of the report recognized a number of temperature-related factors which might have been contributing to the GOM cod decline and went so far as to state that the earlier warming in GOM surface waters in 2012 “could result in an increase in natural mortality of 44% on its own, without any increase in predator biomass.”

So a group of researchers published a paper in Science that showed that it wasn’t just fishing that was responsible for decreasing populations of cod in the GOM. That’s a good thing, right?

But then, according to an article in The Plate, National Geographic’s food blog, the study predicted that “if fishing mortality is completely eliminated (that is, a complete closure of the cod fishery, such as took place in Newfoundland), Gulf of Maine cod could rebound in 11 years. If some fishing is allowed, recovery would take longer: from 14 to 19 years, depending on how fast the water warms.”

Hard as it is to credit, in spite of all of the indications of the severity of the effects of warming on the GOM cod that the authors identified, the paper that they published in what is supposed to be one of the most important scientific journals in the world couldn’t get past the “it’s got to be fishing” creed as espoused by Ms. Lubchenco and others that has turned managing fishermen into the only “effective*” tool in the fishery managers’ toolbox. Not only has fishing, according to them, reduced this stock to its current depleted status, reducing fishing even further or eliminating it appears in their collective estimation to be the only way to fix it.

I have to get into some fisheries management basics here before proceeding farther. First off, the goal of fisheries management is to have enough fish in a stock after fishing to be able sustain itself (most simply, removals from the stock = additions to the stock). This amount of fish is represented as Bmsy, the biomass (B) that is required to produce the maximum sustainable yield (msy).

If we are dealing with a static environment Bmsy will remain constant. But when the environment changes – as when the temperature changes – with fish that are approaching either end of their comfort range Bmsy will change as well (the authors of the paper provided us with a number of factors related to water temperature which I reproduced in the bullet list above that would explain at least some of these changes). Thus, as the water temperature in the Gulf of Maine (GOM) increased, the cod Bmsy decreased. In plain English, the GOM is capable of producing fewer cod today than it was ten years ago.

For another fishery management basic, all of those factors that account for mortality in a fishery are considered either natural and indicated by M, or due to fishing, indicated by F. For convenience (meaning the scientists don’t have a clue and it’s too much trouble to figure it out what it really is) M is usually assumed to be constant.

“However, in most cases, a single value—usually 0.2—for natural mortality is assumed for stock assessments, despite evidence to the contrary (Pope 1979, Quinn and Deriso 1999, Jennings et al. 2001).” From A Review for Estimating Natural Mortality in Fish Populations, Kate. I. Siegfried & Bruno Sansó

“The traditional assumption of a constant M may be appropriate when only mature fish are of explicit interest in the assessment.” From Estimating Natural Mortality in Stock Assessment Applications, edited by Jon Brodziak, Jim Ianelli, Kai Lorenzen and Richard D. Methot Jr., NOAA Technical Memorandum NMFS-F/SPO-119, June 2011. (I have to point out that in a GOM that’s getting hotter a constant M isn’t even appropriate when “only mature fish are of explicit interest in the assessment.” – NES).

Because, according to management dogma or due to management convenience, natural mortality remains constant by definition regardless of what it actually is, when a stock decreases it must be due to fishing. Accordingly, in spite of the authors having provided at least seven reasons why natural mortality for GOM cod is increasing as GOM temperatures are increasing, and in the face of the inarguable fact that the amount of cod fishing and the cod fishing mortality have plummeted at the same time, the authors conclude that reducing fishing for cod even further than it has been or eliminating it will “fix” the cod stocks.

Predation has and will continue to increase as the water temperature rises. The condition of the cod has declined and will continue to decline as the water temperature rises. Spawning success ditto. Also the survival of late-stage larvae and settling juveniles. And prey availability. And predation on the cod will increase. An example that the authors note is that seals, which are apparently quite fond of a diet rich in cod “have increased markedly in the region.” (For the significance of seal predation on cod stocks, see Seals threaten Scottish cod stock recovery at http://tinyurl.com/SealPredation-Cod.) Yet cutting back on fishing effort again and again and again is still the modus operandi of choice for recovering the GOM cod stocks, regardless of its impact on New England’s fishermen, fishing communities and fishing traditions and regardless of its lack of impact on the recovery.

That’s about all that needs to be said about the efficacy of fisheries management as espoused by the anti-fishing claque and as embraced by our modern fisheries management regime.

This definitely doesn’t bode well for fishing in any waters that are or will be warming, and that supposedly is or is going to be all of them, but it’s fishing-centric management at the most painfully obvious.

In how many fisheries being “managed” is that the case today? More importantly, in how many of fisheries in which natural mortality has increased due to ocean temperature increase has the permitted fishing mortality been correspondingly adjusted downward? As ocean temperatures continue to increase, how long will it take the fisheries management establishment – at least that part of it that doesn’t depend on foundation funding for hundreds of millions of dollars of “lets keep on beating the overfishing drums” funding, many of them provided by Pew – to admit that the whole idea of “overfishing” and its actual causes needs to be reconsidered.

* “Effective” from the managers’ perspective because it’s all they are allowed to do to manage fisheries.

When the commercial fishing industry didn’t agree with NOAA/NMFS on the status of the monkfish stocks

(Part of the ongoing controversy with New England/Gulf of Maine cod is centered on the difference in opinion between members of the fishing industry and the management establishment about the health of the stocks. I thought it might be instructive to review how a similar disagreement, only this time dealing with monkfish, was resolved fifteen years ago.)

In Framework Adjustment #1 to the Goosefish (monkfish) Fishery Management Plan published in 2001 it was announced that the directed monkfish fishery off the Northeast states would be permanently closed in 2002 due to the low number of fish that were being captured in the annual Northeast Science Center’s bottom trawl surveys (http://www.nefmc.org/library/framework-1-2). The participants in the directed fishery disagreed with the survey results and objected strenuously to the proposed closure, reporting that there were plenty of fish available, and for whatever reason(s) the NOAA R/V Albatross was not capable of catching them. Participants in the fishery – primarily in the Mid-Atlantic – formed the Monkfish Defense Fund (MDF) which convinced NMFS leadership that the fish were there but were not being taken by the researchers. A collaborative industry/NMFS pilot survey validated the industry’s claims that the stock was more plentiful. As a result, Congress provided funding for a collaborative, comprehensive NOAA/NMFS/MDF monkfish survey, again using commercial vessels with a history of successful participation in the monkfish trawl fishery and using their experienced captains and crews and their own gear to conduct the survey. On board the commercial vessels would also be NMFS and state personnel and academic researchers.

The first large scale cooperative monkfish survey took place in early 2001 with two modern trawlers, F/V Drake (out of Portland, ME) and F/V Mary K (out of New Bedford, MA). The commercial vessels did catch the monkfish that the Albatross couldn’t and provided a more accurate biomass estimate. The difference in the monkfish catch between the commercial vessels and the NOAA/NMFS vessel was significant enough that the managers reversed their decision to permanently close the directed fishery. Subsequent cooperative monkfish surveys on commercial vessels were held in 2004 and 2009. The series stopped after the 2009 survey because NOAA/NMFS personnel decided that their new survey vessel, R/V Bigelow, would adequately sample the monkfish stock.

And for an update on spiny dogfish….

(If you missed it, in Dolphins and seals and dolphin, oh my! from this past January I wrote about the almost totally ignored impacts of predation on commercial and recreational fish stocks in New England and the Mid-Atlantic (http://www.fishnet-usa.com/Dogfish%20and%20seals%20and%20dolphin.pdf). Since then the Mid-Atlantic Fishery Management Council has recommended that the spiny dogfish Total Allowable Catch be reduced significantly, based on the results of an assessment update which evidently couldn’t find a whole bunch of these highly efficient predators that were there until a few years back (for a discussion of how efficient they are follow the previous link). Last July Dr. James Sulikowski’s research group at the University of New England in Biddeford, Maine published The Use of Satellite Tags to Redefine Movement Patterns of Spiny Dogfish (Squalus acanthias) along the U.S. East Coast: Implications for Fisheries Management which reported the results of their work to more accurately describe the spiny dogfish stock(s) of the Northeast U.S. (http://journals.plos.org/plosone/article?id=10.1371/journal.pone.0103384),

But before getting into their research I’m going to take a slight detour to discuss the Northeast Fisheries Science Center’s two annual bottom trawl surveys, the primary data source for the assessments of commercially and recreationally important fish species from Cape Hatteras to Maine. These surveys are so influential in assessments because they collectively comprise a time series going back to the early 1960s. In that time NOAA vessels have made approximately the same number of tows of approximately the same nets of approximately the same duration over approximately the same pieces of bottom on approximately the same dates every year. The annual variations in the numbers/weights of the various species being sampled are assumed to be an (approximate) indication of the variations of the total populations of those species. The nets that are used fish on the bottom and don’t sample the entire water column.

The total area sampled is identical from year to year, and the area sampled does not necessarily represent the full range of the species (or stock) being sampled.

The assumption is that the catch of particular species each year is going to be proportional to the total population of that species. Hence, if the trawl survey took 5,000 pounds of scup, for example, in one year and 3,000 pounds of scup the following year, in year two the biomass of scup would be estimated to be 60% of what it was the previous year (the weight used is often the average of several recent years – as specified in the FMP).

This seems to be reasonable if the distribution of the species (or stock) doesn’t change significantly from year to year. But what if it does? What if, for example, the population shifts to the north and to the east, which would be one of the expected reactions to warming ocean temperatures? It seems obvious that the part of the population sampled by the trawl survey(s) will no longer by representative of the total population as it is today, only as it was. And considering that not all of the species sampled are restricted to living in close association with the bottom but at times might move up and down in the water column, it might well be that with a changing temperature regime some species will not be equally susceptible to capture by the bottom tending gear utilized in the trawl surveys.

Getting back to the University of New England spiny dogfish work, from the abstract of the report, “vertical utilization also suggests distinct diel patterns and that this species may not utilize the benthos as previously thought, potentially decreasing availability to benthic (bottom tending gear as used in the NMFS bottom trawl surveys) gear.” In Conclusions the authors write “the results suggest that the estimated spiny dogfish movement patterns calculated from satellite tag data are possibly spatiotemporally asynchronous with the NEFSC bottom-trawl surveys, thus a potentially large percentage (horizontal and vertical “availability”) of these sharks may be unaccounted for in this survey.”

What would be a consequence of underestimating the total biomass of spiny dogfish off the Mid-Atlantic and Northeast states? Obviously one would be underestimating what they were eating, which includes both codfish and the species that codfish eat. But as fishing management is accomplished today, spiny dogfish predation is irrelevant, because even if it were known, nothing could be done about it. The spiny dogfish fishery must be managed like all of our other fisheries, with a harvest limited to what would yield MSY every year. This is in spite of the fact that spiny dogfish are worth pennies a pound to the fishermen while the other commercial species like cod whose populations spiny dogfish are significantly impacting are worth at least an order of magnitude more.

While the Magnuson-Stevens Act, the federal legislation that controls fishing in the U.S. Exclusive Economic Zone, pays lip service to the Optimum Yield in a fishery, something which should allow fisheries to be fished to below the MSY level if that is economically or socially warranted, the Act actually precludes that. As I wrote in 2009:

“One of the requirements of the Magnuson Stevens Act, the federal legislation that controls fishing in the US Exclusive Economic Zone, or more accurately one of the implied requirements of the Act, is that all fisheries be at the level that will produce MSY.

The first of the 10 National Standards that are applied to Fishery Management Plans put in place through the provisions of the Act is “conservation and management measures shall prevent overfishing while achieving, on a continuing basis, the OY (Optimal Yield) from each fishery for the U.S. fishing industry.”

From the Act (16 U.S.C. 1802, MSA § 3): 104-297

(33) The term “optimum”, with respect to the yield from a fishery, means the amount of fish which—

(A) 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; and

(C) in the case of an overfished fishery, provides for rebuilding to a level consistent with producing the maximum sustainable yield in such fishery.

(34) The terms “overfishing” and “overfished” mean a rate or level of fishing mortality that jeopardizes the capacity of a fishery to produce the maximum sustainable yield on a continuing basis.

The definition of OY supposedly allows for departures from the MSY. However, as even the casual consideration of the above section of Magnuson indicates, that is not the case, or more accurately, that is only the case when a stock isn’t at the MSY level. In that case the stock is considered to be overfished, and if it is considered to be overfished, it must be “rebuilt” to the MSY level by having the

Watch Dr. Steve Cadrins presentation “Strengthening the Scientific Basis of the 2006 Management Requirements: Optimal Yield from Mixed-Stock Fisheries” Click here

harvest level reduced.

But will having every stock of fish in the U.S. Exclusive Economic Zone being managed at the MSY level be economically, socially or ecologically “optimum?” Will it automatically provide “the greatest overall benefit to the Nation, particularly with respect to food production and recreational opportunities?” Economically and socially, emphatically no. Is it even possible? Ecologically a not so emphatic “maybe.” Considering all of the good intentions, all of the effort, all of the pain and suffering and all of the money – both from the public and the private sectors – that is being expended in efforts to reach what are perhaps undesirable and unattainable goals, the results of being tied to the Magnuson concept of OY can be and in demonstrable instances are far from optimum. (from MSY and effective fisheries management, http://www.fishnet-usa.com/maximum_sustainable_yield.htm).

One of the demonstrable instances in which the results are far from optimum is having spiny dogfish at the MSY level in waters off the Mid-Atlantic and New England.

So why is it important to call it fishing management or fishermen management or something similar?

Because no one has much of a clue of the effects of water quality or water temperature or wind direction/duration or upwelling or food availability or of much of anything else on fish stocks. As a matter of fact they lump all forms of non-fishing mortality together, call it Natural Mortality – as opposed to Fishing Mortality – and assume that it is a constant. Natural Mortality plus Fishing Mortality is by definition equal to total mortality. So obviously the authors at the Gulf of Maine Research Institute can report that fishing mortality is what’s driving the Gulf of Maine cod population, because that’s what fisheries science and their models demand. It doesn’t matter how many codfish the burgeoning stocks of spiny dogfish eat nor does it matter how much of the prey species that codfish depend on is left after the dogfish get done with them, because codfish mortality that isn’t due to fishing doesn’t vary. All that varies is fishing, and the only way to have more fish is by reducing fishing. And if it can’t be reduced enough, then stop it.

The only way real fishery management has a chance of working will be by identifying and quantifying all of the major forms of mortality on each fish stock being managed, and by either controlling at beast or at least allowing for all of those other sources of mortality – which in no way in the natural world can add up to a constant year after year.

Once we’re at that point we’ll never have to look at a fishery that continues to decline, regardless of how much we cut back on fishing mortality, and force the fishermen to continue to pay the price for other factors that we either can’t or that we feel that it’s too inconvenient to control.

As I concluded in MSY and effective fisheries management six years ago (cited above):

“The so-called conservationists involved in fisheries would have us believe that there’s some sort of “natural balance” possible in our inshore and offshore waters and that, if fishing is reduced adequately across the board, this mythical balance can be reestablished. That is far from the case.

In their Rousseau-inspired misconception of what the oceans should be, they look at anthropogenic effects as categorically bad, with fishing in general and not harvesting every stock at the MSY level in particular among the worst. This is not necessarily the case. Fishing can be an effective management tool. In the case of species like herring, menhaden and dogfish, allowing – or encouraging – harvest levels above what would be considered “sustainable,” and then maintaining the populations at lower than maximum levels by carefully regulating harvest might be all that is necessary to return “overfished” stocks of much more valuable species back to their OY levels.

Take, for example, the current situation regarding the New England groundfish complex. Fishermen have been hit with a seemingly interminable series of harvesting reductions extending back well over a decade. These cutbacks have been so severe that, if the most recent “management” proposal by NMFS is instituted, boats will be allowed to fish only 20 days a year.

This is due to the fact that several of the groundfish stocks haven’t been recovering as they were expected to (at least by the managers) following previous drastic reductions in fishing effort. At the same time, as we’ve seen above, the stock of spiny dogfish, notoriously voracious predators on groundfish and their prey species, have been allowed to increase unrestrictedly. And the even larger Atlantic herring stock could be impeding the groundfish recovery as well.

Reduce the number of spiny dogfish? Of course not. The Magnuson Act won’t permit it. Reduce the number of herring? Ditto, but for political rather than biological reasons.

But what if we could? Using such an approach, the economy will benefit, the ecosystem will benefit (through increased biodiversity), and the fishing communities that are dependent on “balanced” fisheries will benefit as well.

And there are other fisheries that are facing ever more stringent harvesting restrictions each year because they aren’t performing as the fishing-centric computer models predict that they should. The summer flounder fishery in the mid-Atlantic is one. What’s the impact of spiny dogfish on the summer flounder stock?

An EEZ that is being managed to provide the optimal harvest from a complex of interacting species would seem to be preferable to what we have today. The way we’re doing it today, our most valuable fisheries are increasingly subject to the depredations of other, less valuable species that enjoy the protection of a management regime that is totally stacked against rational management. If fewer spiny dogfish, fewer Atlantic herring or fewer menhaden will mean an increase in more valuable, more desirable or more threatened species, then why shouldn’t the people responsible for fisheries management be provided with the administrative wherewithal to allow this? Legislation mandating that they can’t isn’t benefitting anyone beyond the few anti-fishing activists who have built careers on saving fish stocks that clearly don’t need saving, and it’s certainly not benefitting the ecosystem. So why do we have it?”

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

Regional Fishery Management Council Coordination Committee

June 18, 2014

Gib Brogan, Fisheries Campaign Manager, Oceana 1350 Connecticut Ave., NW

5th Floor

Washington, DC 20036 USA

Dear Gib:

The Regional Fishery Management Councils recently became aware of Oceana’s Wasted Cate/11 report (“the report” hereafter). Through actions such as time/area closures, gear modifications/prohibitions, bycatch caps, participation in take-reduction groups, and modifications to rules that result in regulatory bycatch, the Councils have been leaders in promoting (and requiring) bycatch reduction. At any given time there are often multiple efforts of some type at each Council tied to bycatch reduction, and non-governmental organizations (NGOs) play an essential role in the Council process as environmental advocates. n

However, after comparing the report to core reference documents, the Councils are concerned that a variety of substantial errors, omissions, and organizational approaches in your Wasted Catch report may seriously miscommunicate bycatch information. Accordingly, We recommend that you retract the report until you have the time and/or resources to develop a better understanding of the data summarized in the report. Misinformation in reports like Wasted Catch undermines those productive relationships between industry, management, and NGOs that have been effective in reducing bycatch. lf your goal is to accurately communicate information, and to avoid such issues in the future, We strongly recommend that Oceana consider adopting a standardized peer review process to ensure that reports like this accurately and objectively represent the best available science.

While the Councils realize that some problems in the report are related to difficulties Oceana had in interpreting the National Marine Fisheries Service’s (NMFS) National Bycatch Report and its 2014 update, relying so much on any one document to describe a complex issue is unlikely to result in a full representation of the best available science. There are a Wide variety of NMFS and Council documents that describe and contextualize bycatch information, such as stock assessments, Stock Assessment and Fishery Evaluation (SAFE) reports, environmental assessments, environmental impacts statements, technical memoranda, and articles in scientific journals. To illustrate the kinds of issues We identified based on a quick reading, some examples are provided below. They by no means represent a full review of the document by the Councils.

I http://oceana.org/sites/default/files/reports/BycatchHReporLFINAL.pdf

Mid-Atlantic

The report said the Mid-Atlantic Bottom Trawl Fishery consists of vessels catching “summer flounder, soup and black sea bass as Well as dogfish and skates (p. 34). Depending on the kind of bycatch numbers

the report referenced from the National Bycatch Reports (fish, turtles, or marine mammals), this broad gear type actually represents many other fisheries or parts of fisheries including but not limited to scallops, croaker, squids, mackerel, bluefish, and monkfish. This issue leads to readers being very misinformed about Which fishery is responsible for what bycatch (and to what degree), and also means that the listed “yearly numbers of vessels and fishery Values do not at all match the fleets from which the report describes bycatch numbers.

For example, a reader would conclude that 95 vessels primarily targeting summer flounder, scup, and black sea bass (as Well as dogfish and skates) cause 350 turtle deaths (there is no page number to reference but it is the page on “Mid-Atlantic Bottom Tran Fishery”). However, even a casual reading of the primary literature leads to a different conclusion. The National Bycatch Report Update (p. 22)4 does state the average turtle interaction rate for Mid-Atlantic bottom trawl (fish and scallop) fisheries to be 353. However, only 110 of those are in the summer flounder, scup, and black sea bass fisheries (scallops and croaker account for most of the rest), and that 110 is composed of 60 turtles estimated caught and 50 turtles that Were estimated to have interacted/escaped with turtle excluder devices.

In addition, in the 2012 summer flounder, soup, and black sea bass specifications environmental assessment, it notes that for 2008-2010 there were 12 actual (versus extrapolated) observed sea turtle takes (all loggerhead) and that 10 of those Were released alive (83%) and 2 (17%) were dead. Thus a more accurate (but less sensationalistic) description of this fishery would have been that turtle excluder devices appear to be reducing turtle catches in this fishery by about 45%, and of the remaining 60 turtles estimated to be caught by the fishery, most are likely released alive (83% on observed trips).

Similar fishery mischaracterizations occurred with both the marine mammal and bycatch parts of the “Mid-Atlantic Bottom Trawl Fishery” section, in both cases leaving readers seriously misinformed compared to the actual information in the cited reference documents.

New England

The summary of discards for the Northeast bottom trawl fishery (p. 32) and the New England and Mid-Atlantic gillnet fishery (p. 36) contains a number of statements that are misleading to the reader. For example, the placement of halibut as the first target species for the bottom trawl fishery is a misrepresentation as current regulations allow vessels to only land one halibut per trip.

The report states that the New England and Mid-Atlantic gillnet fishery is responsible for “more than 1,200 mortalities” of sturgeon (p. 36). While “more than 1,200” is applicable to total bycatch, observer

“data indicates that mortality rates of Atlantic sturgeon caught in… gillnet gear is approximately…20%”⁷, again confusing bycatch Versus mortality.

The reference provided for the bottom trawl observer coverage level of 22% is incorrect; it can only be assumed that the authors meant to reference the “Summary of Analyses conducted to determine At-Sea Monitoring Requirements for Multispecies Sectors FY2013”8, Which refers to an at-sea monitoring coverage of 22% providing reliable estimation of catch based on a coefficient of Variation precision standard of 30%. lf this is indeed the appropriate source, it is important to note that this report refers only to the New England multispeies fisheries and not the Northeast bottom trawl fishery as implied in the report.

The report references the U.S. National Bycatch Report Update and provides an estimate of 350 sea turtle mortalities in the New England and Mid-Atlantic gillnet fisheries. This is a misrepresentation of the data as it implies 100% of the turtles are killed; the legend for the referenced table indicates that the bycatch estimate includes both mortalities and individuals released alive and does not distinguish between the two.

In the “Problems” sidebar in the northeast bottom trawl fishery (p. 32), too many sea turtle mortalities are said to occur. According to the Endangered Species Act Section 7 Consultation for 20139, there was one interaction with a sea turtle within the Gulf of Maine/Georges Bank region for trawl gear (Zero for gillnet) in the provided analyses. As noted in the Consultation, interactions with sea turtles in this region are unlikely because sea temperatures are colder than those preferred by sea turtles. It is unclear why this is included as one of the problems for the northeast bottom trawl fishery.

The report states that shrinking quotas encourage discarding (p. 32); the logic used to construct this statement is not intuitive and should be further explained. If available quotas, and subsequently fishing opportunities, are reduced it is unclear how this could increase bycatch. In a recent management action (Framework 48 to the Multispecies Fishery Management Plan), the minimum fish size of a number of groundfish species was reduced in order to reduce regulatory discards; this Was done at a time of decreasing groundfish quotas. In addition, the alternative (not reducing quotas when science suggests We should) Would seem untenable.

The report states that the discarding of millions of skates in the bottom trawl fishery will likely cause a change to the population and the ecosystem, however, no supporting reference is provided. Recent research, incorporated into management by NEFMC (Framework 2 to the Northeast Skate Complex), indicated that discard mortality rates for 3 of the 7 skate species in the Northeast Skate Complex was lower than the assumed 50% for trawl gear; smooth skate increased to 60%. Winter and little skates are the most abundant skate species in the Northeast region. Discard mortality rate estimates for winter and little skates were determined to be 9% and 22% respectively (Mandelman et al. 201312).

The report advises to replace gillnets with cleaner gears such as harpoons in the California drift gillnet fishery targeting swordfish. Unlike documents developed by Councils that analyze biological and socioeconomic impacts, the report does not reveal that harpoon gear is comparatively inefficient, and the method is considered artisanal rather than commercially viable. In other Words, a harpoon fleet could not sustain the fishing community.

Unfortunately, the National Bycatch Report Update, which is extensively used in the Oceana report, lacks sufficient detail and this distorts the summaries in the report. For example, the national report uses observed individuals expanded for sampling rate, While the SAFE document13 for the California dritt gillnet fishery also notes that 98% of the ocean sunfish (molas) are returned alive and undamaged. The ocean sunfish catch represents 91% of the total bycatch in the California drift gillnet fishery (in individuals; mola are large fish and probably represent an approximately similar proportion of fish bycatch by Weight). The National Bycatch Reports do not provide that level of detail, and the Oceana report made little effort to incorporate readily available and more detailed information on many of the fisheries and species described.

The report states that in 2010, an estimated 49 dolphins and 16 endangered sperm Whales were seriously injured and killed in the California drift net fishery (p. 3 l) and that these numbers could be underestimates because observers cover less than 20 percent of the total fishing effort and almost half the boats are never observed at all. As mentioned above, the estimates from the National Bycatch Reports are expanded. for sample rate, and therefore may be underestimates or overestimates.

Western Pacific

The report omits U.S. purse seine fisheries operating primarily in the Western and Central Pacific, which make a considerable number of sets on aggregating devices (PADS). FAD sets are known to have substantial bycatch of juvenile bigeye tuna, and a range of other non-target pelagic species, most of which are all discarded. Some of the discarded species are valuable food fishes caught in Pacific Islands troll fisheries. The issue of purse seine bycatch and its impact on the food security of the Pacific Islands has been raised as a research topic at the Western and Central Pacific Fisheries Commission (WCPFC) Science Committee.

The tacit assumption that bycatch leads to depletion of stocks is naïve and uninformed, and should not be applied uniformly to all species in a stock complex. For example, some bycatch species in the Hawaii longline fishery are showing marked increases in abundance (e.g., lancetfish, sickle pomfret, escolar, and snake mackerel)¹⁵. Such changes may result from the complex interaction of fisheries across different trophic levels and climate Variability in the sub-tropical ocean ecosystem.

The report identifies longline fisheries as one of the three “harmful” gear types. However, longline fisheries, with sufficient gear modification and monitoring can be a “clean gear, as demonstrated by the

13 http://wWW.pcouncil.org/highly-migratory-species/background/

Polovina J .1., M. Abecassis, E.A. Howell, and P. Woodworth. 2009. Increases in the relative abundance of mid-trophic level fishes concurrent with declines in apex predators in the subtropical North Pacific, 1996-2006. Fishery Bulletin. 107(4): 523-531.

Hawaii longline fishery. The Hawaii longline fishery has shown how seabird and sea turtle interactions can be reduced by over 90% with relatively simple gear and fishing technology modifications ^16,17. Green sea turtle interactions have also been significantly reduced in the American Samoa longline fishery simply by positioning all hooks to at depths greater than 100 m¹⁸. Furthermore, not all longline fisheries pose a threat to sharks. The American Samoa longline fishery has a small shark bycatch of less than 5%, While the shark bycatch in the Hawaii longline fiishery has been reduced by approximately 50% and approximately 98% of sharks are released alive¹⁹.

The Hawaii fishery is now recognized globally as the benchmark for environmentally responsible pelagic longline fisheries. Its turtle and seabird technologies have been adopted by two Pacific tuna regional fishery management organizations (WCPFC & Inter-American Tropical Tuna Commission). Further, WCPFC has adopted the Swordfish sea turtle interaction rate from the Hawaiian fishery as the minimum standard against which other shallow set longline fisheries are evaluated.

The comments in the report regarding the increased loggerhead take limit in the Hawaii longline Swordfish fishery are erroneous. The report argues that turtle take limits were increased despite

“compelling evidence of continued decline”, and NMFS should act according to the best and most recent scientific evidence. In reality, the North Pacific loggerhead nesting population has shown a dramatic sustained recovery of the population since the late 1990s²⁰ with over 14,000 nests laid annually in Japan in recent years”. Furthermore, the increased take limits have been evaluated using a new climate-forcing model, which concluded that the interactions are unlikely to have significant impacts on the long-term population trends. Such a conclusion should not come as a surprise given that the fishery has only had on average less than eight loggerhead interactions per year since 2004 (with 100% observer coverage), all of which Were released alive and most of them Were juveniles (there is less of an effect on the population if a juvenile is impacted Versus an adult). NMFS acted on the best available science when it increased the number of sea turtles allowed to be taken by the Hawaii Swordfish fishery, as opposed to the outdated references cited by the report.

16 Gilman, E., D.R. Kobayashi, T. Swenarton, N. Brothers, P. Dalzell, and I. Kinan-Kelly. 2007. Reducing sea turtle interactions in the Hawaii-based longline Swordfish fishery. Biological Conservation, 1390-2): 19-28.

Gilman, E., D. Kobayashi, and M. Chaloupka. 2008. Reducing seabird bycatch in the Hawaii longline tuna fishery. Endangered Species Research, 5(2-3):309­323.

l* FederalRegister v01.76,N0. 164,Augu5124,2011 52888-52889.

Walsh, W., K. Bigelow & K. Sender. 2009. Decrease in shark catches and mortality in the Hawaii-based longline iishery as documented by ñsheries observers. Marine & Coastal Fisheries: Dynamics, Management and Ecosystem Science, l, 270-282

NMFS. 2012. Biological Opinion for the continued operation of the Hawaii-based shallow-set longline Swordfish fishery under Amendment 18 to the Fishery Management Plan for Pelagic Fisheries ofthe Western Pacific Region. ([email protected]/Library/PUBDOCs/biological_opinions/SSLL_2012_BiOp_1-3 0-2012-Fina1_Amended_5-29­13.pdÍ)

2l Asuka Ishizaki, Western Pacific Regional Fishery Management Council, personal communication based on unpublished data ůom

the Sea Turtle Association of Japan.

NMFS. 2012. Biological Opinion for the continued operation of the Hawaii-based shallow-set longline swordñsh fishery under Amendment 18 to the Fishery Management Plan for Pelagio Fisheries ofthe Western Pacific Region` (www.fpir.noaa. gov/Library/PUBDOCs/biological_opinions/SSLL_20 l 2_BiOp_l -3 0-2012-Fina1_Amended_5-29-13.pdi)

Gulf of Mexico

Estimates that shrimp bycatch is l0 pounds for every pound caught (p. 23 and p. 24) neglect to include the efforts to reduce bycatch since the l990’s (when this ratio was estimated). Since the implementation of many management measures, bycatch estimates have been reduced to somewhere between 4:1 and 6.5 :1, and, just as importantly, reduction efforts are still ongoing23.

Turtle Excluder Devices (TEDs) are required in all shrimp otter trawls in the of Mexico (with the exception for royal red shrimp trans in depths exceeding 100 meters). The statement “fisherman who are required to use Turtle Excluder Devices frequently install them incorrectly or intentionally tie them shut, leading the government to underestimate the number of sea turtles killed each year” (p. 30) lacks a citation and misleads the reader. The only report cited regarding compliance is an Oceana-produced report (Oceana, 2011, with a dead link provided). In direct contradiction, NMFS found that 75% of inspected Vessels Were fully compliant with TEDs and that those that were non-compliant were because ofthe angle of the TED. None of the vessels had its TED sewn shut²⁴. The NMFS 2014 biological opinion also concluded that the continued implementation of the sea turtle conservation regulations applicable to shrimp trawling was not likely to jeopardize the continued existence of listed sea turtles, sturgeon, or sawfish.

According to the NMFS National Bycatch Report Update (p. 12), there were an estimated 6,199 turtle mortalities in 2010 for the Gulf of Mexico shrimp trawl fishery and the Southeastern Atlantic shrimp trawl fishery combined, nearly an order of magnitude (8 times) lower than described in the Oceana report. The report also fails to include the latest permit numbers, which have declined in recent years. In the of Mexico, federally permitted shrimp Vessels number fewer than 1,500 and approximately one third of the fleet has electronic logbook monitors so that effort can be more accurately estimated.

On page 19, there is no delineation that the bycatch estimates of dusky sharks are based on bycateh Values spanning 4 years from the NMFS bycatch report.

The statement that the southeast snapper-grouper longline fishery “likely” causes “significant mortalities” to sea turtles (p. 28) is false; sea turtles were not listed as heavily affected by the southeast snapper-grouper bottom longline fishery²⁵.

The report also fails to recognize that the NMFS southeast region has been conducting an independent statistical review of the of Mexico Reef Fish Observer program and has increased at sea observer coverage. The claim of a 66% discard rate in the bottom longline fishery is not validated by the NMFS National Bycatch Report Update²⁶, which does not present a bycatch ratio or percentage; these values cannot be estimated because landings are reported as pounds, and bycatch are reported as individuals.

South Atlantic

Combining the Gulf of Mexico and South Atlantic renders the numbers useless for any meaningful discussion given the differences in the fisheries in these two Councils’ areas. The basis of this problem lies with NMFS for combining these areas in the U.S. National Bycatch Reports, which Oceana primarily relied on for data.

On page 25, the table should separate Snapper-grouper longline into Gulf reef fish longline and South Atlantic Snapper-Grouper bottom longline. The shrimp fisheries should also be separated. On page 27, placement of the graphic showing Southeast Snapper-Grouper Longline Fishery gives the public the impression this occurs in the South Atlantic Council’s area which is not the case. In reality, the South Atlantic Snapper-Grouper Bottom Longline fishery consists of 19 golden tilefish endorsement holders and 12 blueline tilefish vessels who cannot fish south of St. Lucie Inlet, Florida or in waters shallower than 50 fathoms north of St. Lucie Inlet, Florida. Proposed regulatory changes for blueline tilefish Will reduce the number of bottom longline vessels in the fishery. Bottom longlines are prohibited for wreckfish, and they can only fish for the following deepwater species: snowy grouper, yellowedge grouper, misty grouper, golden tilefish, blueline tilefish, and sand tilefish; possession of all other snapper grouper species is limited to the bag limit. In addition, bottom longlines are prohibited in Special Management Zones: the Oculina Bank Habitat Area of Particular Concern (HAPC), all Deepwater Coral HAPCs, and all Marine Protected Areas (MPAs)²⁷.

On page 28, the statement that “Seven out of eight targeted species in this fishery are still being overfished in the South Atlantic, and bycatch estimates remain unknown” is not factually correct. The Council’s 2010 Snapper Grouper Amendment 17A is cited which did at the time reference species that were overfished. However, of these species, only snowy grouper are targeted by the South Atlantic Snapper-Grouper Bottom Longline fishery. Snowy grouper are under a rebuilding plan and are ahead of schedule in terms of biomass rebuilding. The only other two snapper grouper species listed as overfished in the first quarter 2014 NMFS report are red porgy and red snapper²⁸.

Finally, the South Atlantic Council requires that any snapper grouper permit holder carry an observer if selected by NMFS²⁹. Currently approximately 20% complete a bycatch logbook form and those numbers are used to estimate bycatch for each stock assessment. There have been several observer studies on bycatch in the South Atlantic and those numbers are used in stock assessments. The Council also requires dehooking devices, non-stainless steel circle hooks north of 28 degrees north30, and sea turtle conservation measures all geared to reduce bycatch3l. In addition, the Council is awaiting guidance from NOAA General Counsel on how to proceed with a comprehensive bycatch monitoring program through Comprehensive Ecosystem-Based Amendment 3³².

32 http://safmc.net/resource­library/ce-ba-3-comprehensive-ecosystem-based-amendment-3

Conclusion

As monitoring and technology improves, almost every fishery Will have opportunities to examine and/or reduce bycatch in the future. The Councils in no Way suggest otherwise, and look forward to Working with fishery participants and interested parties to reduce bycatch. However, misinformation will only distract from actual conservation needs and efforts. While we acknowledge that there are no laws requiring Oceana reports to accurately represent the best available scientific information or to undergo peer review, to do so would be in the best interest of all involved parties. This is why we suggest that you retract the report until it is reviewed and corrected.

On behalf oft he eight Regional Fishery Management Councils,

Richard B. Robins, Jr.

2014 CCC Chairman

cc:        RFMC Chairs, Vice Chairs, and Executive Directors

Eileen Sobeck

Lee Benaka

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.

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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

A Pathetic Joke Reaffirm’s that some Politicians are Clueless

So. I’m sitting here listening to the Webinar/phone meeting that has just ended, approximately 1 hour and 25 minutes early!

Can’t even imagine holding a webinar session with no sound, but, heh, that’s our government for ya!

If I wanted to listen, (I did) I needed to tie up my telephone! I did!

There were probably twenty five listeners, and three or four asked question’s.

Earlier in the week, Senator Warren wrote an op – ed piece about the $10 Million in S-K dough NOAA was gonna “grant” back to the industry.

Guest View: Tide begins turning fishermen’s way

For the past two years, I have made many visits to Massachusetts fishing communities in New Bedford, Gloucester and the South Shore to hear about the challenges facing the industry. I’ve listened to boat owners and fishermen who face devastating catch allocation cuts, and I’ve spoken with net makers and icemen whose businesses depend on a strong fishing fleet to make ends meet. The message I’ve heard has been clear:

The truth is, she didn’t get it, and there are a few poli bum kisser’s (they know who they are) that trumpet her message as progress, instead of leaning in hard and making her get it.

Ray Lamont at the Gloucester Daily Times is not one of them.

Editorial: Fishing aid package far short of even basic needs

She did replace someone that did get it, and I’d bet Scott Brown would never patronize the fishermen he stood up for.

That’s all that op-ed was. Patronization of the desperate.

Grant is the key word here, and no clue when it comes to Liz Warren!

Today’s display of the S-K funding Folly was revealing to say the least.

Let the Competition Begin!

The guest list had nary a fisherman that needs relief attending the session, but plenty of professional grant hounds, with a few amateurs thrown in.

Today’s exercise was another example of fishermen getting the shit end of the stick.

 

 

Comment here

 

The Pew Charitable Trusts says Atlantic cod stocks are at “perilously low  levels,” and suggested that even the best fishing boat captains in the fleet  couldn’t find enough cod during the last fishing season to meet match their  quotas.

Pew also said the same law being used to replenish the ground fish stocks was  successful in rebuilding the scallop fishery, keeping New England fishing  revenue strong.

“The cod population is clearly in free fall, and if we over fish then we may  push them into extinction,” said Jeff Young, a spokesman for The Pew Charitable  Trusts.

“Even if we could find that flexibility, we really have to rebuild these  fisheries,” Bullard said. “That takes very painful measures to cut back these  stocks and that’s what we’re going to do.”

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Just chop the vegetables and shut up, will ya?

Chef Holly Smith of Café Juanita in Kirkland is one of dozens of local chefs that have joined “Chefs for Seals,” part of the Humane

Society of the United States’ Protect Seals Campaign. 

What is it about these chefs that makes them think the seals are going to support them as they serve up tilapia and Asian farm raised shrimp?

The seals will not tolerate eating that crap, no matter how hard the cook try’s to mask that swill.

Even seals have standards!

I realize that parody may offend the chefs but, shrugs, who care’s?

The Humane Society of the United States’ Protect Seals Campaign., and the chefs, who appear to be snobby towards people, and prefer to raise an issue strictly based on vanity, and decorative icon’s.

If the chefs are doing this to take a stand, why won’t they take a stand against world hunger?!

As the new trend in fishery management is eco based management, the seals cannot be removed from the equation. They are now a primary predator in the eco system because of a number of reasons, one in the United States being the Marine Mammal Protection Act, and another being the un palatable appeal of environs, pro and amateur, and the anti fur movement.

I know that the idea of eco based management will appeal to them in the spirit of being “in tune” with the eco system.

It will be interesting to watch them try to separate a top predator in the eco based management system in the name of vanity, because this is apparently what they have taken a stand against, to the point of a boycott of Canadian fish products.

They will now be forced to accept the fact that seals will be on the menu, as there is an over abundance of this resource having a detrimental affect on other species in the eco system.

To focus on fur products and ignore the protein that seals would provide, utilized by the hungry people of planet that don’t get enough of it will expose the chefs as just trendy interlopers looking for attention or humanitarians toward their fellow human beings.

Comment here

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The contentious issue of seals, marine mammal population’s and public comment ignorance.

Posting link’s to story’s for fisherynation.com viewer’s today, and over the past few day’s, some issues stand out and I thought I’d address them. These are my opinion’s, and mine only.

If you agree, or disagree, you have an opportunity to present your opinion. Submit them through the contact, located on the blue menu bar, and they will be featured. Keep it civil, and on point, please, with no insults or vulgar language.

During the week, I posted three articles about “Study shows depleted fish stocks can come back from the brink”, with the claim cod will never recover in Canada because there are no management measures in Canada to foster a recovery, and besides, it’s to late for them.

Two articles contained the doom and gloom analysis of fisheries scientist Jeffrey Hutchings at Dalhousie University.

In two articles, it appears the authors who interviewed Mr. Hutchings were content to accept his opinion without questioning of any other factors related to the cod issue. These were “blame the fishermen”, ignore the problem’s forums.

The third article posted about the study, appeared at Pys.org.

It was like I had never read the first two!

I am used o the articles that are pointed. with the fisheries being the only factor when it comes to fish stock’s, even though I suspect it’s more complicated, but almost simple enough for me to understand.

Why is it that the scientist’s, and the environmentalists choose to ignore the thing’s we can control to increase cod stock’s in the North Atlantic, east and west? They can’t be in denial forever, and they will be forced to deal with reality if they want to eat fish, or if the fishing industry is going to survive.

We are on this sustainability thing, right?

Marine Mammals are increasing in numbers that are now detrimental to the fish stock’s we prefer to see the populations of, increase.

There are seal issues along the Western Atlantic, and on the East Atlantic, also.

Alaska with the exploding populations of Sea Otter’s is having problem’s, getting the Wanted – “Dead or Alive” posters ready.

They too are having a negative effect on species we desire to harvest and consume.

The population has doubled in the last decade which would mean it would double again in five years.

These stock’s and various species provide livelihoods that are even further in jeopardy if these issues continue unabated.

We will discuss the other predatory species of cod herring, dogfish skates and lobster another time.

An interesting event occurred in American Samoa regarding a predatory specie, and three US Government agencies, decided that eradication was worth implementing as the Crown-of-Thorn starfish became a threat to coral, and it was decide euthanasia was the only option. This is a precedent setting event.

A predatory species is predatory species, whether it’s a starfish or a marine mammal.

The comments at the article “EU ban on trade in seal fur set to be overturned” – European court expected to back attempt by pelt traders and sporran makers to reverse 2010 ruling, are a good indication of the general publics’ opinion.

What they tell me is, these people, all of them food consumers, have no sense of the gritty reality of food production, or, life in general.

These are the people that would say eat more chicken, or just vegetable’s, but if they invested 25 minutes into Ray Hilborn, and they were honest, they’d realize fish consumption in a burgeoning human population cannot be replaced. It’s irreplaceable!

The basis for the opposition to harvesting marine mammals is shallow.

To them, it’s about human vanity. Why else would the headline focus on fur and sporrans?

All I see is references to outrage over vanity,

No outrage for the people in Nambia that eat these seals to survive, as the Seals of Nam’s group threatens Adventure Travel and Trade Association (for the upcoming travel summit in Namibia in October); the Namibian embassy in the United States; the Henties Bay municipality; Namibian Ombudsman John Walters; the Ministry of Fisheries and Marine Resources; and numerous other businesses, travel agencies,” to further their shallow campaign.

I really doubt the African nation of Nambia, or it’s hungry people care about the fur, or even sporrans for that matter, but leave it up to people that have warped senses of purpose to threaten a country of poor people by holding back “tourist” dollars!

Based on,,,,,ideology?

Let’s talk about cruelty!

EU ban on trade in seal fur set to be overturned

Namibia: Seal Campaigners Continue With Harvest Protest

Stopping spread of crown of thorns is to kill it

Draft SE otter population assessment out

 “Canada’s cod, and many other depleted fish, unlikely to recover”

“Study offers bleak outlook for fish recovery” 

Study shows depleted fish stocks can come back from the brink

Comment here

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NOAA Fisheries Service? No such agency!

First off, I’m a cranky old person.

I wasn’t always like this, but time and events have taken their toll.

I’m not ready for the dirt sandwich, although, ya never know!

For quite a while now, something has really been bugging me, and it has nothing to do with my crotchetiness.

NOAA, and the National Marine Fishery Service have pulled a MMS.

Recall before Deep Water Horizon, the agency overseeing the offshore drilling operations were under the MMS moniker

Following revelations of cozy industry / agency interactions of lewd behavior, the administration abandoned MMS and changed it to BOEM, trying to erase it’s shameful past.

I guess strippers, drinking bashes and cocaine abuse between regulators and industry had something to do with that if I recall correctly.

In NOAA’s case, the shameful OLE debacle of NMFS must have had the same affect.

It appears NOAA is ashamed of the National Marine Fishery Service name, and avoid using it when ever possible.

They can’t though, and every time I get information about anything, it is communicated through an un official agency called NOAA Fisheries Service, an agency that does not exist!

Looking at the attractive logo, and the ease of pronouncing NOAA Fisheries, it reminds me of slick tobacco packaging.

You know, pretty colors with attractive font’s and graphics, hiding the negative impacts, or in some cases , death from it’s use.

I wanted to know when the official transition had taken place, because they have websites all over the place with the “un official” logo and non name, and as close as I’ve become to them, I didn’t recall any notices about it.

I made an inquiry.

On Wed, Apr 10, 2013 at 1:45 PM,  <[email protected]> wrote:

I would be interested in seeing the official documentation regarding the shift to the title “NOAA Fisheries Service”Thank you.

I received this.

from: Allison McHale – NOAA Federal <[email protected]>

to: [email protected]

cc: Paul Jones – NOAA Federal <[email protected] _mce_keep=”true”>

date: Thu, Apr 11, 2013 at 5:24 PM

subject: Re: inquiry

 Important mainly because of the words in the message.

Our official name is still the National Marine Fisheries Service.  NOAA Fisheries Service or NOAA Fisheries has for many many years been our common use name since we are the fisheries part of NOAA.

Thank you, Allison, for the response. I appreciate that. BH

I knew that the official name is still National Marine Fisheries service because every time I get a notice with the fancy logo, directly below, it usually announces, “The National Marine Fisheries Service” today,,,” You get it.

With sequestration causing the agency to shut down, yes shut down – The National Oceanic and Atmospheric Administration plans to shut down most agency operations for four mandatory furlough days in July and August in response to sequester-related budget cuts, according to the agency’s acting chief. continued!, I can’t help but to wonder how much money has been spent on converting all the websites, all the stationary, all the everything’s it has been un officially attached to.

That’s one thing cranky old people do. Bitch about the cost.

Comments can be made here

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As grim fishing year approaches, industry tries to deal with new catch limits

BOSTON –  Deep cuts in catch limits will  hit New England’s fishing fleet in less than three weeks, and there’s little  hint any real relief is coming. But regulators and fishermen are still seeking  ways to lessen a blow fishermen warn will finish them off.

As time grows short, Gloucester’s Al Cottone said he and his fellow fishermen  seem to be facing the future in a sort of “state of shock.”

“Everyone’s in denial. They still think, you know, someone’s going to come in on  their white horse and save us,” he said.

“What are people doing to help the industry?”

I’ve tried to mount up and be a rider. I have not been successful.

What I see is herds of black horses being ridden by hypocritical green cowboys riding rough shod over a bunch of un organized fishermen, manipulating natural phenomena, and cherry picking snippets of information to further the cause of the anti fishing conservation groups.

I’ve watched an endless parade of politicians exclaim they would do everything possible to preserve a 400 year old industry that’s reputation has been skewed by a well organized highly financed special interest sector that operates as an army of non profit, tax deductible lawyer assholes who believe they have all the answers. To everything.

Which leads to this.

Plan to open no-fishing zones faces opposition

Allowing commercial fishing in closed areas would bring stocks even closer to ruin, said John Crawford, science and policy manager for the Northeast Fisheries Program of the Pew Charitable Trusts, which is spearheading an effort to slow down NOAA’s approval process long enough to ensure that in-depth environmental impact studies will be done. More than 70,000 residents up and down the Atlantic Coast and 100 scientists have expressed opposition to the plan in comments to NOAA.

“The habitat has to be protected,” Crawford said. “This is the opposite response of what a rational person would have.”

That’s seventy thousand progressives that had nothing better to do than respond to a mega campaign staged by Pew, and  CLF non profit, tax deductible, NOAA insider Peter Shelley, and his for Cods Sake appeal where he ignores facts about the Cod Stocks, as in like, they move?

The big mystery has been solved by an old fisherman in Newfoundland, and he has the answer about where the cod went. His back yard!

Hasn’t seen fishing like this in almost fifty years!

Of course, Shelley’s in denial, and would rather utilize the short comings of the fishery “science”.

“The habitat has to be protected,”

Unless Crawford opposes offshore wind farms along the New England coast, he should keep his Pew mouth shut.

Your View: Polluter blockade of New Bedford wind jobs finally falling

The senior communications manager for the National Wildlife Federation decided he should communicate his feelings about his support of habitat destruction.

Ocean Industrialization is exactly that. Habitat destruction.

I realize Miles Grant, another green energy, crony envirocapitalist, thinks he knows what’s best for the planet, but that’s only because as a communicator, he’s not a listener, or a researcher, because if he were, he would clam up and oppose the destruction caused by pile driving, cable trenching, and chemical spills associated with the construction he endorses.

His masterpiece of hypocrisy is literary pollution in it’s purest form.

Same with Peter Shelley. I’m quite sure he’s a Cape Wind rah rah kinda guy.

I know his boss is!

Which lead’s to this.

Meet John Kassel CLF President / Cape Wind Shill / Advocate of Ocean Destruction, and a crappy blogger, too.

Also included in his article,

Just as there is no doubt that our oceans are treasures, so too is there no doubt that they are being damaged. Bottom trawlers damage huge swaths of the ocean floor with their heavy chains, doors and dredges, likened by some scientists to a bulldozer scraping the delicate floor of a pristine forest. New England’s oceans are rising much faster than predicted. They are also becoming more acidic from harmful greenhouse gas emissions. Recent record increases in precipitation may even be fundamentally altering plankton production, jeopardizing the very productivity of our marine web of life.

As it stands, the commentary of ocean acidification is a legitimate argument.

As far as fundamentally altering plankton production, Kassel mentions nothing of pollution, like estrogen, and chemicals flushed through our bodies being injected into the ecosystem via sewerage treatment, which also have negative affects.

He does hammer away at the fishing industry’s methods of modern day harvesting methods that he finds unpalatable.

I will argue, the notion is unfounded, while he bulldozes his Cape Wind preference as a harmless project that with just the right amount of pixie dust sprinkled on it, will deliver energy to New England with no environmental consequence!

11 years. That’s how long we’ve been waiting for the promise of Cape Wind: clean, renewable energy; new, green jobs; reduced air emissions and carbon pollution; energy at a predictable price over the long-term; and energy security. At a time when the evidence of global warming is overwhelming, and the need for jobs critical, unleashing the potential of this home-grown offshore wind project can only be a good thing.

Now this is rhetorical hyperbole at its finest!

I wrote that on Oct 4, 2012

I posted this on April 14,2013

Which lead’s to this.

Noise Pollution from an Ocean Idustrialization Shill

Your View: Polluter blockade of New Bedford wind jobs finally falling, Miles Grant lives in New Bedford and is senior communications manager for the National Wildlife Federation. Offshore wind energy can and must be developed in a wildlife-friendly manner. Plenty of baloney in this guys display case! Read it here.

Miles Grant’s article has an uncanny familiarity to it. Like it reads like Kassel’s!

Barbara Durkin tie’s this up this loose end nicely.

Which lead’s to this.

BARBARA DURKIN – Your View: Cape Wind offers only empty promises so far. Spanks the communications manager of National Wildlife Federation

April 16, 2013              ENGO, Letter to the Editor, New England, Offshore Wind/Industrialization

Her response to this drivel.  Your View: Polluter blockade of New Bedford wind jobs finally falling continued

NWF makes jobs claims on behalf of Cape Wind that are unfounded. For 22 months, from April 1, 2011, to Dec. 31, 2012, the Massachusetts Clean Energy Center Wind Technology Testing Center has created zero jobs, according to the federal government’s Recovery Tracker. The MACEC ratepayer surcharge program is the source of the $13.2 million used to develop the testing center. The center also received a $2 million DOE grant, and funding by U.S. taxpayers through ARRA stimulus of $24.7 million. We have no jobs to show for our $40 million spent. continued

Supporting article by Menakhem Ben-Yami  https://fisherynation.com/battlefrontoffshore-wind-industrialization

Nothing will destroy habitat like ocean industrialization. What’s it going to be Mr. Crawford?  Mr. Shelley? Mr. Kassel? More hypocrisy?

(calling Dr. Moe, Dr. Larry, Dr. Curley)

The politicians, if they were honest instead of opportunistic vulture pretenders would realize there is no possible way to support two industries that are non conducive, but because of pie in the sky green wet dreams of “free “energy which is not cost effective, driven with tax incentives, they say the right words hoping they can fool everyone into thinking they can be all things to all people.

Ya know what? They can’t be.

They need to be put on the hot seat, and grilled.

They need to decide.

http://www.foxnews.com/us/2013/04/14/as-grim-fishing-year-approaches-industry-tries-to-deal-with-new-catch-limits/print#ixzz2QRsrXkJd

http://www.southcoasttoday.com/apps/pbcs.dll/article?AID=/20130414/OPINION/304140310

http://www.pressherald.com/news/fishermen-questioning-plan-to-open-new-areas-_2013-04-15.html?pagenum=full

http://bore-head007.newsvine.com/_news/2012/10/04/14224982-meet-john-kassel-clf-president-cape-wind-shill-advocate-of-ocean-destruction-and-a-crappy-blogger-too

Noise Pollution from an Ocean Idustrialization Shill  https://fisherynation.com/archives/7260

Leave comments here

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Industry Transformations

I used to jump like an electricians apprentice getting his first jolt every time I’d get an email alert from certain places.

I’d drop everything and post it on newsvine, and in the beginning, fisherynation.

I’m not so jumpy anymore.

I got one today about The Gulf of Maine Research Institutes Trawl to Table rsvp for permit holders and Captains to rub elbows with chefs, restaurant owners, and food service professionals for the day.

The permit owners and captains that do any kind of reading must realize that fishermen and chefs in recent times have meant chefs ripping and gutting fishermen as unsustainable louts, at least in Europe and in Canada, anyway, not to mention the Save the Swordfish days.

The mission is to build awareness of the sustainability of the groundfish ground fish resource and improving the  profitability and resilience of fishing businesses.

There will also be interactive gear displays, the latest in gear research and quality handling technology, and important information on accessing restaurant and food service markets, with an emphasis on the value of promoting underutilized species!

The chef’s will show off the latest in potato peelers, the latest latex glove for safe handling, and pass on important information!

The permit holders will be wondering how to squeeze a couple of extra nickel’s from of a pound of a shrinking commodity, and will be eager to find that margin advantage. Where will it come from, and who will pay for it? That is the question.

One thing you’ll notice about the fishing industry is richness of statistics. For everything, but, here’s one I did not know.

Restaurants sell 70% of the seafood consumed in the United States.

This from the email alert:

Chefs and restaurant owners influence what consumers want. Successful  chefs are most concerned with quality of product, traceability, and  sustainability. Yet, they often lack access to the latest and most  accurate information on Gulf of Maine seafood and the industry that  harvests it. This is your opportunity to have a conversation with chefs  from your area about the importance of sourcing locally and supporting  Gloucester’s fishing fleet.

So. Back to the question. Who is going to get filleted for that margin advantage?

From my seat, it looks like the auctions are the ones that are about to see a drastic transformation.

There is already a drive for fishermen to increase their profit margins by selling direct to savvy consumers.

There are innovate company’s that are offering alternatives to fishermen that remove some of the risks of being a hero, or a zero, depending on whether they “hit the market” or not.

We have been watching this industry transform rapidly.

Which industry entity will experience the next transformation?

I think it will be the fresh fish auction.

Leave comments here

03/23/2014

We can’t win…if we don’t fight! 

This is a response (and hopefully an alternative) to the position of “Well, it’s coming anyway, it’s inevitable; so’s we might as well take whatever we can get out of it…go on home, and call it good”

In fact, we probably won’t survive at all…if we don’t fight. 

Are we willing to give over our fisheries to the barnstorming energy industrialists looking for a new pair of financial roller skates? Are we willing to let them turn our fishing grounds into oilfields and windfarms, where for “security reasons” they’ll install multi-mile buffer zones preventing any and all craft from entering—except the “officially authorized” of course?  Are we willing to let a bunch of Conservation Law Foundation lawyers take over our fisheries management and influence public opinion and cowed officials to regulate fishing into oblivion?  These are groups of lawyers that are operating under the false neutral flag of environmental non-governmental organizations, but in reality are working directly or indirectly for mega-industry agenda driven entities such as the Pew oil company money spawned Environmental Defense Fund.   These CLF and Natural Resource Defense League lawyers, for instance, are getting rich collecting fees from both ends: from the government when it’s an EPA issue and then of course from whatever beneficent mega-corporation funded eco-group they happen to be representing at the time.  They move the scams from one “endangered marine species” to another.

NOAA Fisheries is steered by lawsuits; it’s quite obvious.  Pew and CLF lawyers will stand up at a Regional Fisheries Council Meeting and openly threaten the council with a law suit if they dare to consider this or that proposal which might actually not constrict the fishing industry. CLF and company make their living from going to court collecting fees from the NGOs that hire them and again collect fees from the government (that they are suing) when they win the EPA suit.  The lawyers are working for big biz, mostly the oil industry through “Foundation” money with many profit-securing directive strings attached.

Are we willing to give over fisheries management to this kind of destructive trickery, the shilling for the minerals hungry energy industry and the choking regulations that result and then presented as what?—as an inevitable consequence of the greedy fishermen overfishing and discarding their by-catch“due to “unfavorable market prices”?  Fishing operations are in the way and as citizens and members of the “public trust” are we willing to turn over the precious ocean resource to the perpetrators of Exxon Mobil Valdez, Deepwater Horizon and many, many other oil spill atrocities that have largely been kept out of the complicit media?  Are we willing to sacrifice our food producing resources to our increasingly addictive “energy needs”?  What about our increasing (clean and edible non-GMO) protein needs?

If you think this is all nothing but “conspiracy theory paranoia”, keep in mind that when a conspiracy is hatched in a corporate board room it is known as an “Upstream Profit Business Plan” and this top floor meeting room thinking is never paranoid but considered ivy-league clever strategizing. 

So if it’s not conspiracy paranoia then what is the connection then between the Oil-igarchs and the corrupt and absurdly destructive fisheries “management”?  The systematic dismantling of the fishing industry is a crime.  If proof is needed of that, just visit one of our nearly empty fishing ports and talk to one of the remaining fishermen.  What you will find and hear there is on its face a crime.  How would we normally analyze any crime to find the villain? Probably the first question to ask is who is it that would gain from committing a particular crime? 

Who would, in this case, gain from getting rid of the US fishing industry on the east and west coasts, Alaska, and the Gulf of Mexico?   A fishing industry that might, for instance, be seen as small fleets of whistle blowers bobbing around the oil slicks and constantly calling in reports of leaks and spills, and maybe even bring their own law suits—all very troublesome and undesirable. Who also is having some geo-political difficulty stealing raw (crude) material from countries around the globe as they’ve done for generations?  Who needs to “bring it all home” where the “booked reserves” and the drilling is secure and even more profitable?  Who has switched the focus form oil to domestic natural gas (in order to tout clean energy) and avoid the extra expenditures for shipping and building gas liquefying factories and infra-structure in foreign lands, countries which might nationalize their resources at any time?  And who is on their second “5 year Plan for the OCS”?  That is, a plan to exploit the entire U.S. Outer Continental Shelf where there is abundant gas and oil reserves—especially in the North East and especially on Georges. Connect the gooey dots.  Not only is the fishing community and our vital national food security at grave risk, but our precious oceans and seashores are about to be turned into an industrial wasteland.  This is no time to roll over and play “agreeable compromiser”.

It’s not an option to be compliant and sign up for the handful of jobs maintaining the oil and wind structures—minimal compared to the tens of thousands of jobs lost to a polluted ocean.  It’s also not a desirable option (unless there’s no alternative) to elect to accept a onetime buyout at the expense of the entire fishing industry by contributing to the resulting port-destroying consolidation.  Those are not options if we care about the ocean and about an industry that supplies thousands of jobs and hundreds of millions of pounds of local, clean, healthy, unadulterated protein.  

People around the rest of the world are taking to the streets to stop this kind of injustice; how long are we willing to put up with this kind of resource grabbing corporate greed?  Where’s the democracy? Where’s the fight for it?  Anyone who cares anything about fishing or about their own general health and the health of their neighbor, or for that matter anyone who cares about the world economy functioning for all the world’s people, has to speak out against this corporate takeover and privatization of everything—of our lives!  

I realize that this campaign to eliminate fishing has already cost many fishing families their livelihoods, and we need to speak out and advocate for those people in order to make sure they are made whole and get some actual “relief” from the coveted disaster relief funds.  For those still standing though, we owe it to the people who have already lost their ability to fish, to use whatever energy and skills we have to truly “Save the Oceans”.  Not from “overfishing”; but from GREED!

Stand up! Speak out! Write comments; make calls; talk to neighbors; talk to friends; go to meetings; send emails or letters.  Let uninformed and misled people know what’s going on here—give them a fillet and a message!  Show up; don’t stay home and lament! Pull the covers off the reprehensible scams of the “non-profits”.

“Democracy is not what governments do.  Democracy is what people do.”  Howard Zinn

We can’t win…if we don’t fight!

Comment Here

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DeepWater Wind and Europol ‘Threat Assessment Italian Organized Crime’

July 5, 2013 

 Narragansett Town Council

25 Fifth Ave.

Narragansett, RI  02882

 RE:  DeepWater Wind formed by UPC First  Wind

 Dear President Callaghan and Members:

 There is a new report from  Europol ‘Threat Assessment Italian Organized Crime’ that should elevate your concerns about DeepWater Wind formed by UPC First  Wind.  As I stated to you in my letter of May 8, 2013, (that  followed by in person testimony to Narragansett Town Council), in  part:     

 The business history of UPC First Wind affiliates and  subsidiaries is remarkable because their wind projects consistently fail to  produce energy, yet developers continue to collect public subsidies, from Italy  to Hawaii; or their wind projects have been seized by anti-Mafia Police during  Operation “Gone With the Wind” as (7) Italian Vento Power Corporation IVPC  projects in Italy, with office located at “Via Circumvallazione  108, Avellino.”

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Aloha Fishery Nation,

If Town of Narragansett shoots down cable access it moves up to near Quonset Point  however most people are missing the boat with DeepWater Wind and Block Island  demonstration offshore wind farm (5 ea 6MW wind turbines) 30MW name plate project.

What most people don’t know is State of Hawaii has been exploring alternate energy since  1960s and at one time had the world’s largest wind turbine in test operations. If it deals  with alternate energy it has been tested and documented in Hawaii. HI is an international  alternate (green) energy testing center. All except for offshore wind farms which was state-wide rejected as cost prohibitive, damaging to ocean environment and endangerment to  marine life, high cost of maintenance, unsightly and artificially driving electric rates higher  (they wanted $0.20/Kwh. Purchase Price Agreement (PPA) when burning diesel fuel cost  $0.09-$0.11/Kwh.). HI does have wind farms but they are land based also HI has U.S.  patents for interfacing wind farms to legacy electrical power grids (grid with no modern  smart grid components).

In 2007 President George W. Bush tasked the Department of Energy (DOE) to work with  State of HI to lower dependence on imported oil and to become a model of low carbon  footprint to rest of the nation. As such State of HI enacted the Hawaii Clean Energy  Initiative which requires state-wide reduction of imported oil 70% (40% alternate energy  and 30% energy efficiency) by year 2030. Currently of 100% imported oil HI uses 40% to  power buildings and 60% for transportation.

HI has a number of firsts in the world, first in the nation alternate energy project  demonstrations to commercial production on the record books and is constantly adding to  the portfolio. It is awesome living here in HI being on the cutting leading edge of alternate  energy independence.

HI is unique in the United States in that 6 of the main 8 islands have their own standalone  electrical power grids not inter-connected to each other with a high volume of various  alternate energy resources feeding into the individual power grids. Remaining 2 islands one  is private and other was used by military for bombing practice and is off-limits to visitors.

According to the DOE no utility power company in the world has completed a test to  determine how much fluctuating (non-firm power) alternate energy can be allowed on a  legacy electrical power grid before grid destabilization and protective shut down. Currently  Hawaiian Electric Company (HECO) allows the industry de-facto standard of 15% alternate  energy on a legacy grid before expensive additional safeguards are required to be  implemented.

2012 State of HI, University of Hawaii, Natural Energy Laboratory of Hawaii Authority  (NELHA), HECO, DOE, and two foreign countries and scientists formed a signed partnership  to utilize State of HI power grids real-time under normal loads to; a) fully test and  document over the next two years how much fluctuating (non-firm power) alternate  energy can be allowed on a legacy electrical power grid before grid destabilization and  protective shut down, b) Fully test and document over the next two years electric grid  smart grid components and life-cycle, c) Fully test and document over the next two years  electric grid smart grid components security requirements; d) Fully test and document over  the next two years how electric grid smart grid components change a legacy power grid  and e) fully test and document over the next two years how much fluctuating (non-firm  power) alternate energy can be allowed on a smart grid electrical power grid before grid  destabilization and protective shut down. Testing should be completed around 2015 or  2016 with international published results.

Some points about Block Island, Block Island Power Co. (BIPCo), DeepWater Wind and  electric power:

1. BIPCo has a legislative charter to be the exclusive distributor of electricity on Block Island  and supplies the electricity by operating diesel generators.

2. Wednesday, January 28th, 1998, The E.P.A. and the U.S. Department of Justice  announced that they have settled a civil case with the BIPCo regarding the utility’s  violations of the Clean Air Act that began in 1981. BIPCo must install nitrogen oxides (NOx)  scrubber on all and illegally installed diesel generators or install an undersea power cable  from mainland (RI) power utility company and remove diesel generators plus pay a $90,000  fine.

3. A National Renewable Energy Laboratory “A Preliminary Analysis of Block Island Power  Company’s Use of Clean Distributed Resources to Provide Power to Its Customers”  Technical Report was completed August 1998:  http://www.nrel.gov/docs/fy00osti/27513.pdf

4. BIPCo opts to install nitrogen oxides (NOx) scrubber on all and illegally installed diesel  generators at a cost of approximately $42 million verses approximately $40-$47 million to  have undersea power cable installed. This thought to or estimated to effectively protect  investor rates of returns. If BICo had installed a cable then it would have to try and recoup  the cable cost from Block Island only residents after it had just purchased new diesel  generators and there are hints of problems with current underground diesel fuel storage  tanks.

5. BIPCo operates a legacy power grid designed to be powered by firm-fixed diesel  generators providing fixed voltage, fixed ampacity and fixed frequency (Hz). Maximum  peak power demand is approximately 11MW. It is neither cost effective nor prudent  catastrophic maintenance wise to operate diesel generators at 50% or lower of rated  power demand.

6. DeepWater Water offshore wind power turbines provide constantly fluctuating (non-firm power) alternate energy power voltage, ampacity and frequency (Hz) due to constant  changes in wind direction and speed.

7. DeepWater Wind indicates in statements they can power Block Island up to 90% of  power needs and allow National Grid to supply 10% of power via undersea cable and sell  excess power to National Grid from wind farm (Jeffrey Grybowski, CEO of Deepwater Wind  is blowing smoke in everyone’s ears because he doesn’t know as it has not been tested nor  accomplished on a small island scale).

8. A review “Study on maximum permissible intermittent electricity generators in an  electricity supply network based on grid stability power quality criteria” by Michael Knopp  dated January 10. 2012 study about adding wind farm to St. Vincent Island 2013:  http://www.credp.org/Data/MT-VRE-12-mknopp.pdf

indicates between 20% and 40% allowable maximum intermittent power on the small  island diesel power legacy electric grid before grid instability.

9. By adding the bidirectional power cable from National Grid allows DeepWater Wind to  mask the amount of power being supplied to Block Island from offshore wind turbines and  percentage required trying to stabilize the grid before grid trip out by National Grid plus  pass the cost of the undersea cable on to all RI ratepayers except Block Island ratepayers  who will see a reduction of rates by 40% while everyone else electric rates rise.

10. DeepWater Wind is proposing to use Siemen’s new untested new design and new  technology 6MW direct-drive large offshore wind turbines for the Block Island  demonstration project. Three blade balanced turbines require very expensive special  ocean-going jack-up barges for installation and maintenance.

11. Underwater supporting structures for the wind turbine farm have never been  constructed or tested for New England area North Atlantic Ocean.

12. DeepWater Wind has never completed or built a project.

13. DeepWater Wind exhibits total disregard for human safety by design to run 35KV  power lines 10 ft. under the beach sand at pristine Narragansett Town Beach where  children play, dig in the sand and the unknown interface requirements to the power grid  and cable run near or through Little League ballpark, family park and wetlands.

14. DeepWater Wind has not indicated many barrels of oil and lubricant must be supplied  and stored to each wind turbine in the water and if an offshore electrical transformer  platform will be required that possibly would be oil filled for cooling. Storage of so much oil  could pose an ecological problem for the pristine waters of RI and Narragansett Bay marine  life in case of an accidental spill, hurricane or tropical storm damage. 

15. First Wind which is a company partner of DeepWater hooked up the last grid power  interface for a HI ground based wind farm which suffered three fires, last one of which  burned for three days releasing toxic materials (lead) into air and burned the steel interface  building to the ground and destroyed storage units effectively taking the wind farm totally  off-line.

16. DeepWater Wind is installing nameplate 30MW of which 40% maximum (12MW) will  provide constant power to Block Island. Block Island peak power usage average is 11MW.  30% average usable intermittent wind power to Block Island without causing legacy grid  instability would be 3.3MW of wind power usable on the Block Island legacy power grid  leaving 9.7MW being sold to National Grid’s trunk grid. In return, National Grid would need  to provide 8.7MW firm-fixed conditioned (baseload) power via bidirectional cable to Block  Island so diesel generators could be shut down, diesel tanks drained and removed and  diesel generators sold as second-hand.

17. Block Island residents will see a 40% rate reduction and rest of state of Rhode Island  resident ratepayers would see increase in rates (up to $0.46/Kwh) paying approximately  $415 million to $430 million surcharge for the 30MW demonstration offshore wind farm  over next 20 years that will only be supplying an estimated maximum 3.3MW (unless the  legacy grid is fully upgraded to smart grid at extra cost) to Block Island however, Block  Island residents will get a free mainland (RI) power cable installed, cheaper electric rates,  less air pollution and more dependable electric service through BIPCo and National Grid.

18. One has to answer the question; “Does having the mainland (RI) state population pay  approximately $415 million to $430 million surcharge and additional unspecified charges  and operating costs plus creating 6 full time jobs over the next 20 years for an estimated  3.3MW (2ea-6MW wind turbines at 28% power) of clean alternate energy for  approximately 1,000 residents a good fit and economic sense for RI?

19. One also must ask; “Is the demonstration offshore wind farm really necessary when it  will be only supplying estimated 30% power (limited by legacy grid stability) and mainland  (RI) cable is supplying 70% firm-fixed (baseload) power?”

Hope this has provides some insight!

Am so I happy I moved out of RI!!!! The electric rates will be highest in the nation in RI;  higher than in HI if DeepWater Wind ever completes this project and finally gets it  operational within safety standards!

See attached Email sent to Narragansett Town Council.

Aloha,

Ken Williamson

See attached Email sent to Narragansett Town Council here

Subject: Ocean Policy

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M. Ben-Yami Column                                          WORLD FISHING, MARCH 2013

BLOWING IN THE WIND

The American commercial fisheries seem to find themselves in a sort of a siege. According to voices coming from the affected fishermen and the local press serving fishing ports and communities, on the top of being plagued for the last four years by the adverse catch-share system, they had been hurt by the mega-spill of oil in the Mexican Bay, severely injured by the recent hurricane Sandy and struggled, evidently in vain, for obtaining their share in the related federal damages.

The way the wind blows. Recently, the East Coast fishermen have been alarmed by a new threat hanging over their heads: the plans of constructing a gargantuan network of offshore wind-power farms that would be stepping hard on their fishing tows. For example, in Southern New England off Connecticut, Rhode Island, Massachusetts, and Long Island, two hundred 150-180-m tall wind turbines are supposed to be erected on lease sites overlapping the spawning and fishing grounds of loligo squid and other species, including, e.g., yellowtail flounder.

The proposed lease area offshore Rhode Island and Massachusetts covers approximately 164,750 acres (666.7 sq. km) and is located about 9.2 nautical miles (17 km) south of the Rhode Island coastline. The area will be auctioned as two leases, referred to as the North Zone and South Zone. The North Zone lease will consist of about 97,500 acres,

(394.7 sq.km), and has the capacity to support more than 1,000 MW of wind generation. The South Zone lease will consist of about 67,250 acres (272.1 sq.km), and is capable of supporting a project of between 350 – 1,000 MW. Together, these zones could support enough electricity to power 700,000 homes.

Ill winds. It seems that the industry is facing a hard uphill struggle against the marine fraction of the national campaign for clean energy advancing under the umbrella of Bureau of Ocean Energy Management (BOEM).  All the more that the planned development seems attractive to several other direct and secondary shareholders. For example, according to New Bedford Standard Times, John Mitchell, the mayor New Bedford, which is one of the main American fishing ports, views offshore wind turbines as a development opportunity not for just the Cape Wind project but also as generating a much larger development of an industry all along the New England’s coast of which New Bedford is the industrial center. “Our goal ultimately is to maximize job opportunities for folks living in the city of New Bedford” he said. When one looks on the investments scope, with a quoted price of just one wind turbine ranging from US$ 2mn to 4mn plus installation costs offshore, the initial investment in the installation of the 200 planned turbines will probably cross the 1/2 billion of US$. With the consequent maintenance and other services added no wonder that some leaders would weigh the potential benefits to their communities against the existing, hard pressed and consequently shrinking local fisheries. For the coastal fisheries it may be an ill wind that blows nobody good…

There goes a buzz among the East Coast fishermen that BOEM is too close to corporations associated with the wind/oil/gas/minerals business. They also looking with a wary eye on the contractor that is going to lay the underwater power line leading from the offshore wind farms to the consumer centres of “Big Dig” (a major tunnel project), the Bechtel group. This, because this group, according to the Department of Justice and the Massachusetts Attorney General, hasagreedto pay along with its subcontractors $407 millions to resolve its criminal and civil liabilities in connection with the collapse of part of the I-90 Connector Tunnel ceiling and other defects in the Tip O’Neil tunnel, other construction deficiencies and false reporting.

Cape Wind. In the meantime both the federal and the state authorities, after several years of negotiations and litigations, have approved the Cape Code wind farm at Nantucket Sound, on the Horseshoe Shoal, the construction of which is set up to start this year. The proposed project covers 24 sq. miles (62 km²) and envisions 130  wind turbines, each having a hub height of 285 feet (87 m). The blade diameter is 364 feet (111 m), with the lowest blade tip height at 75 feet (23 m) and the top blade tip height at 440 feet (130 m). The turbines would be sited between 4–11 miles (6.44-17.71 km) offshore depending on the shoreline. At peak generation, Cape Wind is expected to produce an average of 170 MW of electricity, about 75% of the average electricity demand for Cape Cod, Martha’s Vineyard and Nantucket island combined.

Currently 45% of the Cape region’s electricity comes from the nearby Canal Generating Plant in Sandwich, which burns bunker oil and natural gas. According to an optimistic estimate, Cape Wind could offset close to a million tons of CO2 every year and its electricity production would reduce the annual consumption of fuel oil by 430,000 m³.

However, Nantucket Sound constitutes essential fish habitat for many important species of finfish and invertebrates, including bluefish, striped bass, scup, summer flounder, black sea bass, and squid. Their commercial and recreational harvest adds millions of dollars to the local economy. Horseshoe Shoal, which comprises spawning and nursery grounds, as well as abundant hunting grounds for piscivores and a target area for commercial and recreational fishermen, is the most prominent ecological bottom feature in the Sound.

Problems. Not that the wind-power industry doesn’t have its problems. As a fishery activist Barbara Durkin reported: Cape Wind represents an unreliable energy source as turbines manufactured by GE AND Siemens and projected also for Cape Wind are “discontinued”, “sinking”, shifting” and “corroding”.  It appears that in many Dutch, Danish and German wind farms faults in the Europe-wide design standards have been identified, and towers are shifting several centimeters under the impact of harsh offshore conditions. According to Angela Jameson, writing in Times Online, hundreds of offshore “monopile” wind turbines could be suffering from a design flaw that makes them sink into the sea.

Gone with the wind? Another setback is, according to Sunday Times, the failure of wind farms to generate enough electricity even in windy conditions when many turbines were forced to shut down in winds of 56 knots, with power from wind turbines slumping by 2/3in hurricane-force winds. On the other hand, in 2010, lack of wind caused most of Britain’s turbines to stop producing.

Rhode Island Coastal Resources                        February 1, 2013
Management Council
Oliver H. Stedman Government Center
4808 Tower Hill Road
Wakefield, RI 02879

Re:  Objection to Deepwater Wind Requested Waiver of Application Fee

Dear Sir/Madam,

Please be advised that I respectfully request that my objection to Deepwater Wind’s request for waiver of application fee be recorded and be a matter of record in this matter.  In addition to objecting to Deepwater’s requested waiver, I am also requesting that a public hearing be scheduled in order that the public be afforded the opportunity to be heard and to witness the process as CRMC considers Deepwater’s request.

In September of 2012, Deepwater filed an application with CRMC seeking a Category B Assent relating to its proposed construction of an offshore wind farm located approximately three miles southeast of Block Island.  The application specifically relates to the installation of a transmission cable in State waters.  Traditionally, the fees attended for such application must be paid prior to the issuance of any assent by the Council.  The required fees in question here total approximately $750,000.  Deepwater elected not to render payment of fees upon submission of its application and has requested a credit for funds it alleges it contributed to a fund managed by the RI Economic Development Corporation.

Significantly, Deepwater is not a public or quasi public entity, eligible for a waiver of filing fees by CRMC.  Deepwater and its investors stand to earn an incredibly handsome return from their proposed project.  Such return is partially due to the fact that National Grid will be compelled to pay 24.4 cents per kilowatt hour for power generated by the Deepwater project.  Remain mindful that currently consumers pay about 7 cents per kilowatt hour. Coupling the aforementioned factor, with investment tax credits totaling approximately $55,000,000, which Deepwater stands to gain, it is abundantly clear that this is not simply a public works project designed to serve the consumers’ interests.

CRMC has been placed in a uniquely awkward position as the “Joint Development Agreement” of January 2, 2009, initiated by the Economic Development Corporation and the Office of the Governor, designated Deepwater as a “preferred developer”.   Essentially, the State handpicked the developer and through the JDA is postured to positively influence any outcome of the proposed project.  It is arguable that the CRMC, being an agency of the Government of the State of Rhode Island, is equally obligated, under the JDA, to influence any outcome relative to the Deepwater project. While I have the utmost respect for the integrity of the Executive Director and staff as well as the Council itself, this is certainly a situation which presents “cause to pause”.  It appears the Council is being used to justify a preordained result.  The credibility of CRMC is of paramount concern.

One must question how CRMC can accept and process Deepwater’s incomplete application, in violation of its own regulations.  Transparency in Government is essential.  If a Government agency, such as CRMC intends to entertain the request of a private developer to have $700,000 in application fees waived, the public has a right to know and hear arguments pertaining to same.

Respectfully submitted,
James E. O’Neil, Esq.
Former Attorney General,
State of Rhode Island

U.S. Army Corps of Engineers                        February 1, 2013
New England District
Attention:  Michael Elliot
696 Virginia Road
Concord, MA 01742-2751

Re:  Deepwater Wind
File Number NAE-2009-789

Dear Mr. Elliot,

I am respectfully requesting that the Corps comply with the National Environmental Policy Act (NEPA) and applicable Federal regulations by compiling an objective, independent environmental impact statement relating to the Deepwater application.  Deepwater’s proposed project will consist of five wind turbines, measuring approximately 660 feet in height, covering 117 acres of ocean located three and a half miles, south, southeast of Block Island, Rhode Island.  Dredging which will be essential to the project as well as the obstruction of navigation will be significant.  The recent concern regarding the decrease in Winter Flounder and the impact the Deepwater project will have on that precious population is clearly an issue.  Some have argued that the turbine structures will create a reef which will attract a greater population of fish.  If in fact such premise has a ring of truth, one must then wonder how can the hard working members of our fishing fleet harvest fish in waters being “beaten” by turbines. This is not simply a public works project; this is a project by a private developer who stands to earn millions.

As I am certain you agree, transparency in Government is essential to gaining the public’s confidence in Government.  The State of Rhode Island’s Economic Development Corporation, joined by the preferred developer, Deepwater, commissioned the Special Area Management Plan, (SAMP) apparently, in an effort to develop an environmental impact statement concerning Deepwater’s proposal.    It is my understanding that under the Joint Development Act entered into by the State with Deepwater, CRMS is required to adopt the SAMP findings and to use such findings to support the acquisition of Federal permits and approvals.  I certainly do not question the fact that many dedicated scientists have put great effort into SAMP.   However, the fact that Deepwater and the Economic Development Corporation commissioned SAMP, presents a conflict of interest as the vendor, Deepwater, has had a role in funding and selecting the very entity which is designed to evaluate its proposal. NEPA requires an EIS that is absolutely objective and devoid of any appearance of conflict.

Recognizing that the Deepwater project will significantly affect the quality of our environment and NEPA commands the Corps to offer an explanation to the public concerning the environmental issues which have been analyzed it is clear that the Corps should properly commission an independent, objective environmental assessment of the Deepwater project.   The “harm” of concern in NEPA situations is not simply the harm to the environment, but the “harm” incurred due to the failure of decision makers to take environmental factors into account in the manner in which NEPA mandates [emphasis added].  NEPA requires the Corps to do more than simply rely upon environmental analysis commissioned by the applicant.

Therefore, based upon the aforementioned reasoning, it is respectfully submitted that the Corps has the obligation to conduct an independent, unbiased assessment of the impact of the Deepwater project upon our environment.

Respectfully Submitted,

James E. O’Neil, Esquire
Former Attorney General,
State of Rhode Island

The enemy is government in partnership with industry cooking science and posing threats to our food source, ecology, economic engine, our use rights, and public safety. Barbara Durkin