Charlie Hutchinson from MSSA with some thoughts on the menhaden management situation along the East Coast with his Critique of the new ASMFC Proposed Menhaden Fishery Plan.
At the last meeting of the Menhaden Management Board, the commissioners directed a Plan Development Team be assembled whose mission would be to create a draft addendum to the present plan. The new plan would be based on the agreed upon goal of increasing the menhaden breeding stock to the equivalent of 15% of an unfished stock from its present level of +/- 8%. The team is composed of members who are diversified geographically as well as professionally. Their proposed plan consists of two segments, the technical (fishery biology) side and a section on social/economic issues.
The technical side of the document is extensive and detailed. Based on the concept of a 15% maximum spawning potential as a threshold measure, the plan lays out the use of a target to which the fishery is to be managed. The threshold becomes a mandatory action point to reduce harvest to obtain the target level of landings if they ever exceeded the threshold limit. For this method to be successful, the target must be more conservative (smaller catch) than the threshold by a statistically significant amount. The team proposed a range of targets, from 20% to 40%. The breadth of the range recognizes the degree of uncertainty encountered in the inputs to the computer model which calculates effects. One of the major factors is estimating the change in natural mortality resulting from more forage available to predators. Given the fact that predators are currently considered under fed at present stock levels, the wide range is not unexpected. The Board will have to determine the extent of conservatism they wish to employ. The draft document outlines a host of tools the Board would have available to effect the reduction in harvest that would be required to achieve the goal. The Plan Development Team seems to favor a hard cap as the best method of control. They also note the need for improved monitoring/reporting to make any of the available methods work, primarily in the bait segment of the landings. So, on the technical side the work seems to be complete and realistic.
When it comes to the social/economic issues which might result from more stringent regulation, the work seems to be much less rigorous than the technical side. The first controversial point has to do with the predictions of effects on the reduction industry without a corresponding evaluation of the impact on the bait industry and its customers. Cited as reasons for the lack of consideration of the bait industry is a lack of data. The “data” is available, although some skepticism exists with respect to accuracy and completeness. Simply put, no effort was made to do the work it might require.
The second point of controversy has to do with the description of effects on the reduction industry. The document cites the predominate negative effect on jobs would be borne by “ the least skilled ,least educated, marginally employed and poorest sections of the affected communities.” Such an analysis doesn’t seem reasonable in an economic sense. First, if volume of business decreases one normally decreases the acquisition of raw materials to balance demand. In this business that would be accomplished by reducing the number of vessels utilized to supply the factory. Affected would be the crews on the vessels who are skilled and their wage scale is much higher than the wage scale in the factory .In addition there is not much known about the degree of automation employed in the factory. It may be that a reduction in throughput does not necessarily translate to a similar reduction in the labor force. So in essence, reductions could be made in that segment of the work force that is directly variable with volume and at the same time the average labor cost is decreased by reductions in the most costly element. All in all the social /economic portion of this document seems to portray an emotional response rather than an accurate picture of probable effects. Given the fact that decisions will be made on both technical and economic outputs, the economic aspects of this document should be treated with considerable skepticism.