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Originally published in Fly Fishing in Saltwaters, June/July 2012



A new report tells us everything we already knew, and managers will still drag their feet


Regular readers of this column will note that I’ve covered the forage fish (aka baitfish) issue here more than once in the last several years.  I hate to beat a dead horse, but I’m going to have to do it again, because it’s important, really important, yet managers continue to procrastinate.  


If you’ve followed any commercially-fished low-trophic-level species’ decline (e.g. menhaden, herring, mackerel, butterfish etc.) than you have probably come to the same conclusion that many of us have.   The lack of prompt and definitive action is likely due to a large, powerful, well-funded commercial fishing industry which targets such species in great quantities and for great profit. 


Quite recently, The Institute for Ocean Conservation Science at Stony Brook University put together a group of highly regarded scientists to address forage fish management.  The directive was to provide science-based, practical advice for the management of such low trophic-level species.  The scientists reviewed the available science, including information on forage fish populations, predators and approaches to forage fish management.  It carried out several different analyses in 9 different case studies.   What it found was ridiculously obvious.


First, forage fish are particularly vulnerable, having biological and ecological characteristics that make them very susceptible to overfishing. The most obvious being their schooling characteristics (e.g. their ill-fated survival technique of forming tight schools vying for center position, affording them protection, while their weaker brethren get picked off from the perimeter).  While such behavior may serve such forage populations well in the wild (as well as the predators that feed on them), it allows them to be taken in large numbers by commercial netters, which can scoop up tons of such fish in a single haul


Second, forage fish populations fluctuate greatly.  Abundance is often unpredictable, and sensitive to changes in environmental conditions.  Due to their schooling characteristics, commercial fishermen can kill large numbers of forage fish during a natural population decline, greatly increasing the possibility of a stock collapse.  Thus, even during periods of low abundance, commercial fishermen often use their continuing high harvest levels to successfully argue that fish remain abundant and that there is thus no reason to reduce fishing mortality.  In some fisheries, where landings records are the primary indicator of stock health, such arguments are the primary obstacle to needed management measures. 


The third, and probably the most obvious finding is that forage fish are valuable as prey.  Predators decline when forage fish decline.   I’m not clear why fisheries managers needed a Task Force to tell them that, but some complicated modeling was used to bring the team to what most anglers would probably consider an obvious conclusion. 


Lastly, the Task Force compared the economic value of the commercial forage fish harvest with the economic benefits produced if such fish were allowed to remain in the ocean as prey for other commercially valuable species.   It found that, globally, forage fish, if left in the ocean to serve as prey, provide triple the economic benefit that they provide if harvested and sold. 


The Task Force also compared the management strategies currently being employed, which emphasize maintaining maximum sustainable yield (MSY - the max number of fish you can take out of the population while still allowing it to reproduce)  with more “precautionary” strategies that also consider forage species’ role as prey.  The Task Force analyzed several food-web models to compare the various management strategies and, predictably, found that only precautionary management approaches adequately protect both predators and prey.


In addition to such findings, which are more-or-less intuitive, the report also makes specific recommendations that fishery managers could use to ensure the sustainability of low-trophic-level species.  The first is to cut fishing mortality by half for most forage species, a reduced fishing level derived directly from the Task Force’s food-web simulations, which suggest that, at a minimum, forage fish abundance should be equal to 40 percent of each species’ unfished biomass.  That’s twice the minimum population level currently accepted by fisheries managers!  When there is insufficient data about a forage fish stock, its interaction with predators and its overall role in the environment, which is the case with most forage species, the Task Force recommended that populations be maintained at no less than 80 percent of their estimated unfished biomass.  Fisheries in the “high information tier” can be subject to higher levels of harvest, but even there, the Task Force recommends that managers should maintain the population at no less than 30 percent of unfished biomass to account for uncertainty in the stock assessment.  The Task Force also recommends that managers consider when and where to allow fishing, and possibly close forage fisheries during spawning season or around concentrations of predators that rely heavily on a particular forage species.


Will fisheries managers implement any of the Task Force’s practical recommendations?  Unlikely.  As a fisheries management Council member I’ve been down this road before.  Some of the most obvious, even benign solutions to the forage problem (such as institutionalizing the option for a “conservation buffer”) are beaten back with ferocity by the fishing industry’s hired guns.   I can say with some certainty that there isn’t a Council out there that would move toward reducing fishing mortality by 50%, or consider doubling the minimum biomass left in the water, unless the old conventional MSY standard indicated that the forage stock was being overfished enough to justify such a drastic reduction.   Industry would likely go berserk if such a discussion were even to take place.   Time and area closures are a non-starter also.  Industry has been able to argue successfully that fish move around and such closures would be useless.


Certainly the concept of working with industry to cooperatively manage fisheries is a good one, but things go very wrong in the execution. Self interest always comes to the fore and people who make money off the exploitation of the resource fight tooth and nail against what should be obvious.  For decades, those in the commercial fishing industry who target forage species have denied that fishing has any impact at all, and they have received some support, from both NMFS and the Councils’ Science and Statistics Committees.  Because, in the case of many forage species, fishing mortality is relatively small when  compared to “natural mortality,” industry has argued, with some success, that such fishing is insignificant.  But in the case of low-trophic-level fish, which by definition are “forage” and thus are eaten by a wide variety of predators, natural mortality would of course be very high.   To argue that the wanton massive take of low-trophic –level species, taken by huge small-mesh nets and/or purse-seines which scoop up tons of fish at a time has no effect seems ridiculous, but managers are indeed buying such arguments. 


Even the scientific process, which is supposed to be objective, gets corrupted by self-serving anecdotal information supplied by  “performance reports” produced by industry participants on Council and Commission Advisory Panels, and by industry consultants who are allowed to take too much of a prominent a role in various stock assessment workshops.  Such input, originally intended to provide more context for the raw data, can and have resulted in larger commercial quotas.  What regular Joes, like you and I witness on the water simply doesn’t make it into the process, because we don’t have hired guns paid to make sure it gets in there, although there are now efforts to get recreational fishermen on some of the forage-fish advisory panels.  


All this may sound frustrating, because it is. The good news is that there are efforts underfoot within the Councils to implement ecosystem-based-management which could, if done correctly, sufficiently account for predator/prey relationships.  The North Pacific Council seems to be at the forefront, having completed an ecosystem based fishery management plan, but my understanding is that it is not yet near the implementation phase.  The Mid Atlantic Council is currently producing a “Guidance Document”, but it will likely have no teeth, as Councils generally don’t have the political will to reduce harvest unless they are forced by law to do so.  The New England Council is moving forward with a regional plan as well, although all of these documents are extremely complicated and come with their own unique sets of cross-boundary management problems.   Ecosystem-based management did come into play, to some extent, when the Atlantic States Marine Fisheries Commission (ASMFC) recently decided to significantly reduce fishing mortality on menhaden, but we’re still a ways from seeing any specific management measures adopted, so the devil remains in the details there. 


It was nice to see the Forage Fish Task Force report, and I suppose there is some utility in getting scientists together to prepare such a document, even though it doesn’t tell us anything new.   From grade-school on we’re taught that big things eat little things and that in any wild setting there are webs of interdependence.  Yet, somehow, many fisheries managers seem to have missed that message.   So while the report was mentioned in the press, and may have raised some awareness among the general public, I have to question whether it will do any further good.   Fishery managers are likely to just brush it aside and continue with business as usual, without upsetting a fishing industry that has become so much a part of the process that it can usually prevent any meaningful reductions from occurring (the recent action on menhaden being a notable exception).  Thus, for the immediate future, we are stuck with a system that will probably continue to allow too much fishing on forage stocks, while not sufficiently accounting for predators’ needs.  I doubt that will change, at least on the Federal level, until it is explicitly required by law, and right now that simply isn’t the case. 


If this annoys you as much it does me, feel free to let your Council and/or ASMFC state representatives know about it.  Their contact information is readily available.