BULLARD, SHELLEY, and COD: or Fish Being and Nothingness

May 6, 2013             

“Returning Our New England Fisheries to Profitability”: “You’re doin’ a great job, Brownie” aka, Janie, Johnny, Petey.  You should be proud.  Mission Accomplished?

In her resignation email Lubchenco made the gravity-defying claim that she had made “notable progress” in “ending overfishing, rebuilding depleted stocks, and returning fishing to profitability”; but soon after, John Bullard “In an interview at the Times, Bullard said the telling figure was that the fleet caught only 54 percent of the allowed catch in 2012, and reasoned from that statistic that there is a dearth of inshore cod, a situation that warrants serious action to reverse.”  Richard Gaines March 8, 2013 Gloucester Daily Times, “NOAA head explains stock stand” 


Peter Shelley of Conservation Law Foundation explains the Cod Dilemma in a wormy little video he so humorously named “For Cod’s Sake”. The video has him standing next to an innocently squeaky white board with a drawing of a cute little codfish (I guess the drawing was needed so his audience wouldn’t mistake this for the endangered Menhaden, Tuna, Abalone, or Sturgeon sales pitch).  After some enlightening statistical scribbling next to a simplistic graph indicating a dive in landings over the last decades (except of course for the leveling off due to the effect of CLF’s beneficent suing of NOAA in the early 90’s), Shelley concludes from this that since the New England Fishermen landed less than 50% of their Total Allowable Catch it’s because they couldn’t find the other 50% and that “…the reason they can’t find them is because they’re not there” they don’t exist—they have devolved into the nothingness dimension through the overfishing portal.  Feeling his oats and justified by his ever so rational and reasonable presentation, he stout-heartedly issues the coup de grace: the fishery should be completely shut down, a 77% TAC reduction just doesn’t go far enough. (Actually a complete shutdown might have illuminated the ridiculousness of the entire matter sooner than this slow death of a thousand bogus regulations.)


Bullard’s and Shelley’s approach to stock assessment is reminiscent of the studies done by the eco-luminary fisheries-theorist authors of “Oceans of Abundance” fame, when they observed a decline in landings and “reasoned” from there that a global fisheries apocalypse was imminent; one which would be so severe as to render only jellyfish to harvest by 2048.

Wrong, Wrong, Wrong, this reasoning cause and effect from sequence is an established logical fallacy, in this case an eco-logical fallacy.  Because fishing and declining landings appear in sequence does not mean that fishing causes declining landings.  (Or that decreased landings causes increased fishing—for that matter.)

Could it be that data from NOAA’s Oversized Research Vessel the O/R/V Much Too Bigelow and their admittedly inadequate survey attempts at a universal sample of all the species in the ecosystem, during one “cruise”, using the same net, might not be accurate and worthy of use in assessments?  Or is the fact that fishermen are not landing their Allowable Catch the “Smoking Gun”, the “Mushroom Cloud” that would indicate the imminent danger of extinction, “…that there is a dearth of inshore cod, a situation that warrants serious action to reverse” says Bullard, and according to Shelley requires a complete shutdown of the cod fishery?

Using the fallacious equation fish landings=stock health in an assessment and then as a basis for regulations, as employed here by the apparent new theoretical alliance of NOAA’s John Bullard and Conservation Law Foundation’s Peter Shelley, is a completely disingenuous argument; for it would then have to follow that just about all groundfish must be endangered including Haddock, Pollock, and Yellowtails, since those landings are down and haven’t fulfilled the Total Allowable Catch limits for years.

In fact, Black Back or Winter Flounder must be totally extinct since absolutely none have been landed in recent years (the fishery had been shut down for years by NOAA)

—they must be all gone then, right?  If the fishermen have not landed them, then the fishermen couldn’t find them, and that must mean they’re just not there.  Looks like they’ll trust fishing effort or CPUE as a reliable indicator of stock population as long as it can be interpreted to indicate no fish, I guess in that case the anecdotal information from fishermen becomes reliable.

Did it ever occur to Bullard or Shelley that many years of absolutely unnecessary and disproportionate over-regulation plus a totally dysfunctional catch shares management regime might have something to do with the amount of fish landed or in this case not-landed?

Consider the following specific situation:  My vessel is an 80ft. dragger which I purchased in late 2005 and spent most of 2006 refitting.  Once fishing, we landed approximately 300K+ pounds of groundfish per year for 2007, 2008, 2009, mostly Yellowtail and Haddock and Cod.  However after the paltry allocation of catch shares in 2010 of less than 10% of what we were catching (the allocation was figured on landings records from the previous owner who did not fish primarily for groundfish during the 1996 to 2006 “qualification period”) after NOAA decreed that paltry individual quota for my vessel, she’s made only two groundfish trips both in 2010.  They were both brokers due to leasing allocation costs and gambling the $10K fuel bill that the purchased fish poundage of Yellowtail would actually show for us when we happened to be on the Georges Bank grounds and then also that the catch would yield a decent ex-vessel price—neither of which worked out.  My boat has not been back to Georges and has not landed any amount of groundfish since.

 Now plug these facts into Bullard’s and Shelley’s simplistic equation of fish landings = stock health and the 1 million or so pounds of groundfish that my vessel has NOT landed for 2010, 2011, 2012 —not because the fish weren’t there; but because of catch shares and the ever-tightening trip and daily allocations previous to that.  Then add to that the poundage that other vessels did NOT land since 2010 and before, vessels that were subject to the same choking daily and trip limits and got the same catch shares allocation “deal” that my boat got, and Eureka! There you have it. Through the fractured reasoning of Bullard and Shelley this decline in landings becomes an indication that the fish are missing and presumed extinct— and yes, more than ample proof that the fishery should be shut down completely—once and for all.

NOAA is busily trying to prove a negative, trying to prove nothingness. They are trying to prove that the fish if not landed have never existed, never possessed being. They are obsessed with showing the world that there’s no fish due solely to commercial fishing.

NOAA seems able to deal only in negations; constant destructive burrowing, diligently undermining an entire industry and way of life.  But trying to manage from landings data takes the absurdity cake:

Some of the inherent management absurdities in emphasizing landings as an indicator of stock health for assessments and regulation:

  • Increased landings: evidence of overfishing and stock depletion; therefore, more restrictive regulations needed.
  • Decreased landings: evidence of overfishing and stock depletion; therefore, more restrictive regulations needed.
  • Landings data exactly fits projections and holds steady: evidence of restrictive regulations working perfectly, overfishing effectively being thwarted; therefore, more restrictive regulations needed.

What this kind of destructive management buffoonery does to individual families and businesses is obvious, they cease being; but, it also has devastating consequences for the entire industry, the fresh fish market, and therefore the consumers’ ability to access the cleanest and healthiest food on the planet.

Since the market abhors a vacuum, enter then the foreign fresh caught product (but often frozen and thawed) and the uninspected aquaculture imports: Pangasius, Tilapia, Shrimp, and all manner of pond-raised chemicalized belly-bombs:

From Undercurrent News


 US cod quota cuts have processors scrambling for supply

March 11, 2013, 3:43 pm

Tom Seaman

The steep cuts in US cod quotas have east coast processors scrambling for supply and planning to use more Pacific and Canadian cod, as well as imports from Norway, Iceland and maybe Russia.

With the 77% cut in the Gulf of Maine quota and the 55% cut in the George’s Bank quota, taking allocations down to 1,550 metric tons and 2,002t respectively, US cod processors have no choice but to switch supply, said Chuck Anderson, in charge of retail sales for New Bedford-based Pier Fish Company.

Times are very tough for US fishermen, he told Undercurrent News, because they are being hit with lower quotas that are not compensated with increased prices, because of the abundance of cod on the global market.

“We’re trying to work on solutions that work for the fishermen and us. We are all in this together,” said Anderson, at the Boston seafood show.

The company is also looking to gets it clients to use other US-caught fish, such as pollock, ocean perch, and haddock.  However, the company has no choice but to look to alternative sources for some of its supply.  Pier Fish is buying Pacific cod from Alaska-based suppliers, as well as importing more from other sources.

“It takes three days to truck fresh from Seattle, so we airfreight the fresh fish in,” Anderson told Undercurrent.  The company is also buying more fresh and frozen product from Iceland and Norway, as well as looking for suppliers in Russia.

Using more farmed whitefish, such as pangasius and tilapia, is also a possibility. The company would prefer to use cod, preferably US-caught, said Anderson. (Underlines are mine)

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