Menhaden Muddle Part 1
This column will be the first in a series describing the increasingly serious problem of a declining stock of menhaden. First order of business is to define the problem. While that ought to be simple and straightforward, it is anything but. In reality there are several problems when combined have a significant effect on East Coast fisheries now and is getting more serious as time passes. The overriding physical problem is the abundance of menhaden on a coast wide basis is declining. The extent of decline is such that the available biomass now is insufficient to meet the needs of a bait fishery, a reduction fishery, a variety of predator finfish, a variety of fish eating birds, and last, but not least, filtration capacity to reduce nutrients in the Chesapeake Bay waters.
Regulation of the menhaden harvest is the responsibility of the Atlantic States Marine Fisheries Commission (ASMFC). They have failed to properly assess the needs for menhaden jn relation to the stock abundance. More about the ASMFC in an upcoming article. It is doubtful that many people involved in saltwater fishing know that there is a problem and those not along the coast have no interest in the issue. For at least a decade or more, the official document on the health of the menhaden stock known as the stock assessment has declared the stock as “not over-fished and overfishing is not occurring”. This permits the ASMFC to declare that there is no problem with menhaden abundance hence no management action is required based on the best available science.
The trouble here is that the stock assessment is not necessarily the best available science and it is by no means the only available science that concludes that there is a problem. The stock assessment tool box is composed of a complex computer model into which data on fish caught, natural mortality and other factors and estimates are fed to obtain an estimate of abundance. The reference points on which to judge condition of abundance have to do with reproductive capacity, not biomass. Since the model is driven primarily by the catch at Omega’s Reedville reduction factory, what the output is telling us is that there is sufficient stock to cover the needs of the reduction fishery with a safety margin. It does not deal effectively with the other needs for menhaden.
The stock assessment team is responsible to and controlled by the ASMFC. Up until the 2009 stock assessment there has been a perceived unwillingness to make changes in the stock assessment process. This year a change in the mortality factor ( due to including more data on predator effects) has resulted in a preliminary report that the stock is on the brink of overfishing. Only three species of predator fish were included ( striped bass, bluefish and weakfish). Remember that menhaden migrate up and down the coast and in Federal as well as State waters and therefore are the target of a variety of ocean fish such as king mackerel, dolphin, and tuna to name a few whose appetites are not even considered in the stock assessment. If they were, there can be no doubt that overfishing is occurring. What will the Menhaden Management Board do now?
Our next article will deal with the ASMFC and the political aspects of the Menhaden Issue.
Menhaden Muddle Part 2
Menhaden were initially used as fertilizer for the Colonists crops As the nation grew an industry developed to fish for the menhaden in both the Atlantic and the Gulf of Mexico. Since our concern here is for Atlantic menhaden our analysis and opinion is limited to that species. Gulf menhaden are a different variety entirely .Over time the menhaden were processed and utilized as ingredients in commercial products as well as fertilizer and feed stock for other animals. Today menhaden are largely utilized as animal feed stock, aquaculture and probably best known for Omega3 fish oil used as a human food supplement.
The early menhaden reduction factories were small facilities numbering in excess of 100 spread out along the East Coast from Maine to the Carolinas. They were simplistic operations, labor intensive, utilizing relatively small vessels to catch the fish. Today there is only one factory remaining, that belonging to Omega Protein located in Reedville, Virginia.
What happened to all these factories? For the most part they failed economically. Additionally, some were shut down as the waterfront property became more valuable as residential property, particularly as profits declined. The catch declined also. In their heyday more than 500,000 metric tons were harvested annually while currently only about 160,000 metric tons are being harvested and plant capacity is not the limiting factor. The methods used to catch the fish are much more efficient as are the processing facilities leading to survival of only the most technologically proficient. Today, the only remanent of the small operations are the bait fisheries scattered along the coast. .Menhaden are used as bait for lobsters and crabs as well as fin fish in the charter boat business. Still, the harvest of menhaden is the largest in the entire US. Reedville’s harvest is reported to be the largest of any species on the East Coast. Some say it is as big as all other fisheries combined.
Obviously we are not dealing here with a peanut size business. And Omega is roughly 85% of the US industry. With 4 plants, 3 on the Gulf and the one in Reedville, Omega is the 800 lb. gorilla of the industry. They are a sophisticated operation with an amazing amount of political clout both in Virginia and Washington. In Virginia, as in no other state, regulation of menhaden is controlled by the legislature as opposed to a department of natural resources or similar agency. Makes it much easier to exert their influence.
Omega Protein has made a name for themselves as the largest supplier of Omega3 oil .These oils are reportedly very useful as a food supplement with medicinal benefits. These are apparently well founded claims. Most oily fish have these attributes but menhaden are preferred source because a higher percentage of the fish’s weight is in oil. Reedville is the only plant which processes the oils to extract Omega3 because the Atlantic menhaden are larger and contain more oil. Availability of Omega 3 oil is not limited to menhaden, or to fish for that matter. The oil can be made from flax, or it can be obtained by the fermentation of algae. The point here is that continuation of the menhaden harvest is not essential to the production and marketing of Omega3 oils.
Omega Protein has done much to influence the ASMFC. One technique is to push the concept that menhaden decisions be made on “the best available science”. Fishery science is imprecise at best but by insisting that ASMFC abide by its code that decisions will be based on the “best available science”,. that ploy has worked well for them in terms of regulatory action. Watch what happens if the same science declares that the stock is in trouble or other sciences are given equal status in the regulatory process
For a complete understanding of the menhaden industry read The Most Important Fish In The Sea Written by Bruce Franklin it can be purchased from Island Press.
Menhaden Muddle Part 3
At the center of the menhaden controversy is the Atlantic States Marine Fisheries Commission (ASMFC). It is central to this issue because it is the regulatory authority over menhaden and many other species as well. ASMFC was created by congress in 1942 by what is termed the Atlantic Coastal Fisheries Cooperative Management Act. The act defines the role of ASMFC as follows” The responsibility for managing Atlantic Coast Fisheries rests with the States, which carry out a cooperative program of fishery oversight and management thru the ASMFC. It is the responsibility of the Federal Government to support such cooperative interstate management of fishery resources”. The role of the Feds is to support financially the activities of the commissioners and staff. While the Feds fund the operations they have no oversight responsibility with respect to whether or not the actions of ASMFC are productive. Hence there is no accountability for their performance. This is a poor situation from the perspective of the public who have no where to turn when they are dissatisfied with the management of their resources.
The ASMFC manages many species and the format is the same for all species. Each species has a Management Board. The Board is composed of three commissioners from each of the 15 states plus a representative from National Marine Fisheries Service, US Fish and Wildlife, and from the Potomac River Commission. To assist the Boards There is a professional staff in Washington which serves all the management boards as well as two committees. One is the Technical Committee to advise on technical matters, and the second is the Advisory Panel which is intended to provide input from the various stakeholders. The commissioners from each state are the Director of Fisheries, a state legislator, and an appointee by the Governor of the state.
The Menhaden Board has set forth it’s objectives as follows ”to manage the Atlantic Menhaden fishery in a manner that is biologically, economically, socially and ecologically sound, while protecting the resource and those who benefit from it.” They don’t seem to have done a very good job of achieving these objectives. There are probably a number of reasons for the poor performance. Some that come to mind quickly are:
1 The ASMFC as an organization is responsible to no one but themselves. As a practical matter if one is not responsible or accountable what incentive is there to actually “manage” which inherently means making decisions and taking action which will be unpopular with some stakeholders.
2 Congress, who set up the organizational structure, failed to build in accountability and either doesn’t recognize this flaw or does not feel it necessary to correct it. ASMFC should be a part of one of the major departments such as Commerce. The public needs to have some recourse when it’s resources are being mismanaged and no such avenue is currently available.
3 Take a look at the composition of the commissioners. At least 70% are bureaucrats. As such they are generally not proactive and shun risk .In the case of menhaden there is the additional problem of the state of Virginia and Omega Protein. Any action of substance to increase stock size by reducing harvesting will impinge on Omega’s operation and perhaps their bottom line. They will vigorously oppose any such move thus putting the Management Board in an uncomfortable position which they would rather avoid.
There could hardly be a situation more conducive to failure than to have a quasi government agency populated by risk adverse managers with no accountability for their performance.
Menhaden Muddle Part 4
The role of the Federal Government in menhaden regulation is harder to fathom. When Congress created the ASMFC some decisions had to be made as to who would regulate what. If the fish were characterized as inshore the ASMFC was given regulatory responsibility. If the species was offshore the responsibility remained with the Feds. Menhaden are primarily an inshore species, but do travel and reside in Federal waters as well. The dividing line for jurisdictional purposes is the 3 mile limit. From 3 miles offshore to 200 miles is the EEZ which is under Federal control. Beyond 200 miles they are International Waters which is another nightmare entirely.
For our purposes the waters up to the 3 mile limit are of primary concern and the “ States Rights” issue tends to keep the Feds out of it. Menhaden are not regulated in any fashion in the EEZ. Records show that increasingly the reduction industry (Omega) is finding fishing in the EEZ more profitable and less restrictive. Now more than 50% of the harvest is offshore. That has created some interesting effects. Much of the catch is off the New Jersey coast resulting recently in increased concern by New Jersey residents by what is occurring in their waters as Omega efficiently reduces the menhaden abundance in their area. As the fishing pressure increases offshore, some of the migratory habits of the menhaden are changing. Most notable is the absence of menhaden off the coast of North Carolina in the winter months and an increase in the Chesapeake Bay. Notable also is the absence of stripers in NC since bait is harder to find and an increase in large migratory stripers in the Chesapeake Bay. There are reports of decreasing catches of stripers in the northeast, particularly in Maine and Massachusetts. All of these conditions are good indicators that the availability of menhaden to support predators is becoming a problem over a wide area.
It is a fact that Federal legislation can override state regulations as demonstrated by the newly reauthorized Stevens Magnuson Act which has provisions for rebuilding stocks classified as overfished that states find onerous. It is also a fact that the Feds could at any time prohibit the harvesting of menhaden in Federal Waters but have shown little desire to do so. Part of this reluctance is the recognition that to do so would probably result in an uproar from the State of Virginia and more directly from Omega. Omega would claim such an action would put the Reedville operation out of business. If such a regulation were applied to Federal waters, and if the ASMFC has not taken any measures to restrict harvesting in VA waters, then Omega could harvest there up to the limit of the present cap. Since Omega and the ASMFC continue to say there is no problem with menhaden stock the effect on Omega should be minimal. They can’t have it both ways.
Legislation to halt the harvest of menhaden was introduced in 2008 in the House by representatives Saxton(NJ) and Gilchrest(MD) and got a sparsely attended hearing by the subcommittee on fisheries. It died there. Similarly a 2009 bill in the Senate by Cardin(MD) for improving restoration of Chesapeake Bay water quality contained a provision for eliminating the commercial fishing for menhaden in the Bay which died before it was introduced. Unmentioned was the opposition from VA which had much to do with its removal.
Basically its a catch 22 problem. The Feds have delegated responsibility to the ASMFC and wish to avoid the States Rights issues that might arise by enacting legislation to override ASMFC. There are also jurisdictional issues at play here but in reality it is more of the political baloney that seems to be overwhelming in Washington. The power to do what is needed is there but the political will to do so is not.
Menhaden Muddle Part 5
Given the fact that the ASMFC is the body with the power and responsibility to effectively manage menhaden, it would seem that the public at large should be able to communicate their needs to them. That is not so easy. There is very little interaction between Joe the Plumber and the people making decisions, supposedly,on their behalf. The ASMFC holds its Management meetings on, roughly, 90 day intervals. That is the only time business is conducted. These meetings are open to the public, held in various locations on the east coast, with Washington being the most frequent. Travel expenses for the commissioners, staff and other associated personnel are paid for by your tax dollars, all others are on their own. Costs may be one reason the attendance is generally low. Most of those who do attend are representatives of various fishing or environmental groups. Obviously they represent their stakeholders and thus can serve at least some segments of the public.
One of the unique features of these meetings is that at the beginning of the meeting the public is requested to comment on anything not on the agenda. That gets the public out of the way so the business of business can be carried out with minimal interference. If in the course of the meeting a motion is put forward requiring a vote. the public MAY be permitted to address the subject. This doesn’t always happen, its at the discretion of the chairperson and the time is very limited. Public comment can be submitted before a meeting to the ASMFC staff. In 2005, 26,000 comments were received relative to the then proposed cap on menhaden harvest in the Chesapeake Bay, more by far than were submitted on any subject before or since. The public rejected the cap and asked for restrictions on the reduction harvest. The effect was nil. As history will show, no action was taken on restricting harvest, the cap was put in place, and the public no longer seems willing to participate significantly.
How, then, can the public influence the management board? The lead commissioner from each state, generally, is the Director of Fisheries or similar position. He/she is the spokesperson for the three person team. In order for the states vote to count, a majority have to be in agreement. So perhaps a way to get something done is to bombard these individuals with requests that your state propose or support a motion to take measurable and positive action to increase the stock of menhaden by reducing the harvest. Following is a current listing of these lead commissioners. G Lapointe(ME), Doug Grout(NH), P Diodati(MA)< Mark Gibson(RI), David Simpson(CT), James Gilmore(NY), Peter Himchak(NJ), P Emory(DE), Tom O’Connell(MD), Jack Travelstead(VA), Louis Daniel(NC), Spud Woodward(GA), Jessica McCauley(FL). As many letters as possible should be sent to these administrative appointees so that they are aware that people in their state know who they are and want positive action taken. Copies should go to the Secretary of Natural Resources for your state so that both know what the mood of the public is.
There is at the ASMFC offices a coordinator for each Management Board. For menhaden it is Braddock Spear. His address is 1444 Eye St. NW Washington, DC 20005 His email address is Bspear@ASMFC.org. He keeps tab on how many comments are being received. For example, total comments received in regard to extending the cap beyond the 2010.experation date was 222 (long way from 26,000) of which 186 were against extending the cap which was extended never the less. From the preceding you can see that public input has been routinely ignored. That may be because it has been directed to the more or less amorphous Management Board as a whole. Perhaps if the commentary is more directly aimed at the state representatives who are the direct beneficiaries of our taxes and are more readily reachable we may become more effective. At least its a place to start. More on an organized approach in a future article.Menhaden Muddle Part 6
Pressure on the ASMFC Grows
In the week of May 3, the ASMFC Menhaden Management Board will have its first meeting of 2010. The backdrop for this session will be a bit different than what has been the norm. For one thing, menhaden are getting considerably more attention in the media. Most of it has been unfavorable to the ASMFC and to Omega Protein. Omega recently produced a video extolling the virtues of their company which indicates they are more nervous about slippage in their ability to control the menhaden harvest. They even got the executive director of the ASMFC to appear on their behalf. Poor ethics on his part, but perhaps indicative of the concern Omega is exhibiting.
The State of Virginia has become a hot bed of interest in pushing for change in the management of menhaden. Led by CCA-Virginia, a substantial coalition of mainly marine oriented groups have tried hard to get control of the menhaden fishery out of the legislature and into the hands of the VRMC. Again, the legislature killed the effort, but many of the politicians may suffer as a result. Never the less, it is anticipated that this coalition will now direct their efforts at the ASMFC stating that neither the legislature nor their representatives on the Management Board are representing the wishes of the people of Virginia
In New England, another issue has arisen which could have a significant impact on the menhaden harvest. The North East Fishery Management Council has taken action to substantially reduce the allowable harvest of sea herring. This was made necessary by the overfishing of herring. About 2/3 of the herring harvest is used for bait for the lobster industry. There is considerable concern, particularly in the Gulf of Maine, that there might not be enough herring available for lobster bait. If so, menhaden may be the bait of choice to make up the shortfall. The quantity could be substantial, perhaps as much as the menhaden bait business in the mid Atlantic states.
The stock assessment for menhaden has been completed and forwarded for peer review. As of this writing, the results are not known and not much about the assessment itself is known. What is known, or at least commented on, is that the stock is close to the overfished limit. Further, the harvest level of age 3+ stock is severely overfished. Maybe that is why recruitment has been so poor. Heretofore this fact has been buried in the composite of the stock ages, and therefore did not stand out so sharply. Also of concern is whether the reference points used to judge abundance and mortality are still relevant under low abundance and low recruitment conditions.
All of the above is to advise all the interested parties that for the first time in many years, the science which has been saying that the stock is not overfished is now presenting a different picture, and the ASMFC should be reacting accordingly. However, the history of fishery management tells us that before action is taken to correct problems, things generally get chaotic.
So if we are to take advantage of a much improved platform from which to advocate for physical reductions in harvest, and start a rebuilding program, the time to get an advocacy program started is NOW.
The first order of business is to show that the States of Virginia and Maryland are united on this issue. The best way is by physical demonstration at the May meeting. The commissioners need to see this to stop the concept that this is a MD vs VA problem that doesn’t require Board action.
The second order of business is to get a well thought out motion before the board to reduce fishing pressure on menhaden until the mortality is at the target level. This stays within the ASMFC system, is consistent with their stated objectives, and history tells us that this measure has been violated consistently over time.
To support the substantial action required to start conserving menhaden rather than exploiting them will require a massive communication effort. It will be a political effort because we are dealing, not just with technical numerology, but also with human beings charged with responsibilities to be sure there are enough menhaden to fulfill their ecological role. That role should place the need for forage first, not secondary to commercial interests. It will require all of us to correspond with a variety of people. Numbers count! If we fail to do our homework on this issue, we have no one to blame but ourselves. Details will be the subject of Menhaden Muddle #7.Menhaden Muddle Part 7
Hopefully this will be my final article concerning menhaden management. While Omega Protein has been much vilified in the media, the real villains are the commissioners of the ASMFC. They allow the practices to continue which decimate the menhaden population and indirectly screw up other species as well. Omega simply does what they are permitted to do and make a living off of our resources. The ASMFC is supposed to be acting in the public interest and protecting our resources. They have been unwilling to do so hiding behind a science which is not up to the task of providing the data required for a decision process based on science.
What to do about this? MSSA has had enough of this wait and see game that has gone on for the last decade. We will again require action to set more realistic standards by which to judge stock abundance in relation to demand by both directed and non directed fisheries. Providing these more sophisticated and accurate measurement criteria may take quite some time, so it would be appropriate to manage the catch to halt the rapid decline while this is being accomplished. In order to bring about the desired action, the proposed changes in management methodology will require support on a coastwise basis. While the legislature in Virginia is not supportive of change, the people of Virginia are and are increasing their efforts to see that menhaden are actually managed as opposed to control by Omega.
How to bring about the change? The Menhaden Management Board needs to receive letters, thousands of them, calling for favorable consideration of new management methods. Numbers here count! If no effort is made to saturate the ASMFC with a clear message we can expect the same old same old. Writing to the commissioners from your state is likely to be more effective. By the way, email is not the most effective method of communication. We hear that the delete button is too convenient and the message has been deleted from the recipients brain, even if it was read before deletion. Similarly the governors of each state should be addressed in writing asking them to consult with the commissioners and request their commitment to action. Additionally the Secretary of Natural Resources should receive a letter asking support for decisive action In short we need to contact every person in the chain of command with responsibility for management of fisheries in a very personal way to get their attention. The message is to require them to respond to public demand in a positive measurable fashion at the May 4 ASMFC meeting.
As individuals all we can do is to express ourselves clearly and forcefully as to how we want our resources managed For the first time in many years the technical data show that the stock has declined to historic low levels ,the breeding stock is overfished and recruitment continues to be unacceptable. There are clear signs that dependant predators are undernourished and that forage needed for other species is being detoured into other products at an unsustainable rate. Fishery management historically has been one of do nothing until the stock crashes and then regulations take the form of severe restrictions or moratoriums to bring back stocks. That can work to a degree with single species but not for forage species. We cannot afford to allow that to happen with menhaden. If we stand by and let inaction to bring about a complete fiasco, we have no one to blame but ourselves.
What’s Next for Menhaden Stock Rebuilding?
Menhaden Muddle Part 8
I thought that the Menhaden Muddle series of articles would cease with #7, but there is more work to be done. The coastal population of menhaden has declined 88% since 1984 to an all time low.
At the ASMFC May 6 meeting of the Menhaden Management Board, the commissioners decided that new reference points were necessary to provide more protection for menhaden, The motion for their action was initiated by the state of Maine, although it is clear that Maryland was heavily involved in formulating the motion. The motion includes the following:
1. Technical Committee to develop alternative biological reference points, if possible, for the August 2010 meeting.
2. Reference points to include protection for spawning stock biomass.
3. Multi-species Committee to work with the Technical Committee to account for predation in the new reference points.
4. New reference points to consider those currently employed for other stocks of pelagic forage fishes.
It is clear that the Management Board recognizes that the present fishery management methods for menhaden are not working. Their solution is to raise the bar as to what are acceptable abundance levels for a forage species. While this is going in the right direction, there are a host of obstacles to overcome. An attempt will be made here to outline what some of them are.
First, the Technical Committee is being asked to develop new standards in 90 days which reflect predator needs. The facts are that the data does not currently exist to include a much more representative group of predators. There would be a lot of research required over a fairly long time frame (years) and many dollars which are not easily obtained. The Technical Committee has an easy way out on the Boards request, as it is simply not possible to do this kind of work in the short term.
If the experience of other fisheries for forage fish is utilized as the basis for setting abundance and mortality criteria, it is likely that the Technical Committee would reject this approach as lacking scientific basis. In effect they would put the ball back in the Management Board’s court by indicating that this approach is clearly not in their purview, but they could evaluate the effects for the Board of a decision of this type. A white paper outlining how this methodology can be used was submitted over a year ago by the National Coalition for Marine Conservation. Thus far it appears to have been ignored.
Assuming that new reference points are created, by whatever means, by the nature of what they are to include, it would be inevitable that the stock would be considered overfished. That determination would require remedial action. The only way to rebuild the stock is to reduce the commercial harvest. If the reduction is significant, and it would have to be to make any headway in a reasonable time frame, the next issue is how to implement the change. This will be a very contentious issue particularly for the reduction industry since they are responsible for about 80% of the harvest. This kind of decision making will not be easy, and one wonders if the Management Board is up to the challenge.
Menhaden Muddle Part 9
Reviewing the outcome of the Menhaden Management Board meeting in May, something struck me as unusual and caused me to do a little research. Following the report of Dr. La Tour, Technical Committee chairman, there were a number of questions posed by various commissioners. Among them were ones directed to why recruitment continued to be so low and was that related to abundance which in turn is influenced by mortality. Dr. LaTour’s reply was that they(technical committee) could not find any correlation between mortality and recruitment. He further explained that reproductive success seems to be more influenced by environmental conditions. Since spawning takes place off shore the resultant larvae are transported into major nurseries such as Chesapeake Bay by tides and winds. These are random actions, not predictable and not manageable. Subsequent discussion among commissioners indicated they had concluded that mortality, especially caused by fishing, was not an important factor in recruitment. If so, there is a serious misconception which could lead to faulty decisions.
Just because the scientific community cannot find a link between fishing mortality and recruitment it doesn’t translate to the view that fishing mortality is not important. On the surface, a plot of abundance vs. recruitment indicates both move in the same direction, ie. both decline. The recruitment curve is more ragged, due no doubt to the environmental factors previously noted. Also noted is that fishing mortality (at least from the directed fishery) has been relatively stable over the last decade while recruitment declines.
An unknown quantity in this comparison is the mortality by predators but it is believed to have increased substantially due to programs to increase predator stocks both in finfish and birds. It could be postulated that if mortality data were available and factored into these comparisons the picture might look a lot different The lack of data for all the creatures consuming menhaden is one of the most glaring shortcomings in the evaluation of sustainable abundance.
Since abundance is the major issue with respect to menhaden and since mortality (by whatever means) is certainly a factor in abundance, an F based reference point seems appropriate. Commissioners need to establish a target for abundance and then determine what level of mortality will permit the restoration of the stock to that level over a given time frame. Since we cannot determine which factor, recruitment or mortality, is the dominant factor in abundance and since directed fishing mortality is the only one manageable this real time experiment needs to be undertaken. We have little information on how these various factors interact at higher levels of abundance and it is unlikely that we will know by simulation exercises. There is no painless solution to the issue of menhaden abundance.
Menhaden Muddle Part 10
Menhaden Muddle #9 touched on the issue of abundance but did not attempt to describe its importance in menhaden regulation. The present methodology utilizes fecundity( the ability to produce eggs) as the basic criteria for determining whether the stock is “healthy”. Fecundity deals with the theoretical capacity to reproduce. Reproductive capacity doesn’t necessarily equate to reproductive success This has been demonstrated by declining reproduction to unacceptable levels for menhaden. There is an obvious relationship between the number of spawners and the likely number of eggs produced. The current method of judging whether or not there is sufficient replacement involves using fishing dependent data (due to a lack of natural mortality data) to determine whether or not there is sufficient reproduction to satisfy the demand as determined by directed removals, If the calculations say there is then the stock is not overfished.
What we are dealing with here could be described as an inventory problem. One starts with an opening stock level, deducts shipments(removals), adds back production (recruitment) and ends up with a new inventory level. Simplistically this is what we have and the calculated results are a shrinking inventory (abundance) from a continuing low level of production(recruitment). Setting aside the calculations for a moment, the answers suggest that shipments are exceeding production and no surprise the inventory continues to decline.
While the above is dramatically oversimplified it does provide a rational answer that fits the observed situation. The recruitment number is a calculated value utilizing an index to determine whether recruitment is increasing or decreasing. Some error is inherent but the same methodology and sampling plan has been in place for some time, so it is considered reliable. The removals however are another story. Landings from the bait and reduction industries are routinely reported and also are considered credible. What is missing is a credible number for natural mortality by predators, so that in our inventory analogy our removals are believed to be substantially understated. Again, the results seem to support the hypothesis.
Abundance is the key element. As it stands the available information suggests that we do not have enough menhaden to support predation and fishing mortality. The only thing important to predators is biomass. If we as a public feel that having forage to support our predators is most important, then we must opt to create a substantially greater biomass. This can only be achieved by meaningful decreases in removals. There probably are science based measures available to guide the decision making process. But the heart of the matter facing the Menhaden Management Board is to set a target for abundance which is reasonable, achievable and satisfies the need to rebuild a badly diminished resource.
Menhaden Muddle Part 11
Generally the Atlantic States Marine Fisheries Commission (ASMFC) does not get involved in allocation issues. While they direct overall policy, such as setting harvest limits, it is left up to the individual states to develop and implement regulations that conform to the ASMFC rules. That may not be so easy with respect to menhaden.
The acknowledged need for new management methods, described as revised reference points, comes about by the recognition that the stock is at an unacceptably low level To rebuild the stock to an acceptable level will require a reduction, probably severe, in the harvest. There are two components to the removals. First, the directed fisheries for bait and reduction, for which data exists which defines the volumes they represent. Second is mortality (generally classified as natural mortality) generated by all the predators. Here data is sketchy at best so this components volume is largely unknown.
All fifteen states share in the bait fishery and in natural mortality, but only one state (Virginia) participates in the reduction industry. Of this directed or measured mortality roughly 80% is through harvest for reduction. This leads to the possibility that 80% of the reduction in harvest would come from the industrial fishery. The balance could be shared equally (percentage wise) among the states participating in the bait fishery .Obviously the heaviest burden would fall on Virginia due to the location of the industrial fishery. Depending on the size of the cut in the overall harvest the continuation of the reduction operation may be in jeopardy. That in turn may mean some loss in employment in a period of economic instability. The severity in the reduction in employment is dependent on the severity of the cut in harvest and the point at which the reduction operations are no longer profitable. This situation makes for a very difficult decision by the Management Board. It is not likely that a decision will be made at the meeting scheduled for August 3 because the ramifications of the choices to be made will not have been evaluated by then.
What will be necessary to be considered in the decision process? For the most part the biological information normally used to determine fishery regulations will not be the determining factor: economics will, coupled with the values associated with menhaden. There are a substantial number of people who believe that the predators should be given first priority for the consumption of menhaden. There those directly or indirectly involved in the commercial side of menhaden consumption whose livelihoods will be adversely impacted by a reduction in harvest. Finally, and what is no doubt the largest group, those who just don’t care. A study of those factors was initiated three years ago by the state of Virginia and is underway. It appears that the results will be available this fall but not in time for the August meeting .The Board for the first time is going to have to step out of the comfort zone of a biological basis for management into the real world of economic factors which is new ground for them. It is way overdue.
Menhaden Muddle Part 12
What’s next for Menhaden management?
Now that the Atlantic States Marine Fisheries Commission has recognized that the present management methods are not working, what action should we demand from the Management Board? At the very least we should expect that this regulatory body fairly and impartially manage the resource for the benefit of the public to whom this resource belongs.
Much of the current regulations for various species is based on maximum sustainable yield and that philosophy has been used for menhaden. It is not appropriate for forage fish .It has not worked for herring and it is not working for menhaden .The fact that we have the lowest abundance ever pretty much proves the point
Those of us who are concerned with this situation need to contact the commissioners from our state and make it clear to them that business as usual is not acceptable. Neither are halfway measures such as the Bay cap It simply provided a reason for more investigation at our expense, yielding no guidance, but looked good on paper.
What we should demand are the following:
1 Regulations which actually rebuild the stock to a point where predators needs are satisfied.
2 Abundance should be at a minimum halfway between the 1981 high and the 2008 low.
3 New abundance target to be met in a reasonable time.
4 Regulations to be in place by early 2011.
5 Provide a means of tracking progress on an annual basis.
6 Use economics and the course of least damage to those affected by new regulations to resolve conflict
Menhaden Muddle Part 13
This is the 13th in a series of articles on menhaden. The August 4 meeting of the Menhaden Management Board was distinctly different in character from most previous meetings. The attitude of the commissioners was more directed to cutting thru the technical jargon and getting a proposal in place to begin a restoration process. A motion was made to draft an addendum to the present fishery management plan for action at the November meeting. The motion calls for consideration of a range of % of maximum spawning potential from present level,15%, 25% and 40%. Presently we are at less than 10%. It would seem that to accomplish these goals reductions in harvest would have to be significant depending on what level of stock is to be preserved. The motion carried by 16 to 0.
That is the good news. However it may not be as good as it appears on the surface. Again we are dealing with reproductive capacity. Recruitment has not been good although theoretically there are supposed to be enough of a brood stock out there to sustain the stock .Our scientific community cannot explain why this unsatisfactory condition persists. The explanation is that environmental conditions have more influence in successful reproduction than spawning potential and these factors are unpredictable and unmanageable. Published information suggests that for forage species such as menhaden more than 50% of the spawning stock must remain. Given guidelines of that magnitude, why was the upper limit restricted to 40%, with much more modest levels given equal chances of adoption?
A second factor is more of an observation than a comment on the particulars of the action. For the second consecutive meeting of this body, motions were passed unanimously in what has been a contentious issue. That is highly unusual and raises my antenna a bit. Lifting it further was the lack of reaction by Omega representatives present to what would appear to be an adverse regulatory process developing. Perhaps what is being considered here is not what we think it is and while looking good on paper doesn’t do much for restoring menhaden.
Listed below are the addresses of the commissioners for all of the states in the ASMFC. Letters should be in their hands by July 26 2010.
Charlie Hutchinson is a leader in the Maryland Saltwater Sportfishermen’s Association and a longtime advocate for Chesapeake Bay fisheries. He is a valuable adviser to the Menhaden Coalition, an organization of 34 groups, which advocates for Menhaden. He lives in Cambridge, MD.