Thursday, September 10, 2015
ASMFC GETS DEFENSIVE ABOUT STRIPED BASS MANAGEMENT
I was looking through the August/September edition of Fisheries Focus, the Atlantic States Marine Fisheries Commission’s bimonthly newsletter, when I came across a piece written by Robert Beal, ASMFC’s Executive Director.
I’ve known Robert Beal for quite a few years, in the way that anyone who does fisheries advocacy knows folks at the Commission. He’s always tried to do the right thing for the fish he’s entrusted to manage, and his column usually highlights some new effort or management action.
But this time, his subject and tone caught me fully off-guard. It could only be described as defensive.
He started right off talking about eating striped bass, and how
“For many recreational anglers, professional chefs and amateur cooks alike, Atlantic striped bass is the East Coast’s most sought after fish. It is just as likely to be spotted at your neighborhood fish market as on the menu of the region’s top restaurants.”
And maybe that’s true or maybe it isn’t, but it seemed kind of strange when he started to criticize those “professional chefs” for deciding not to serve stripers, writing
“Recently, Atlantic striped bass management has come under criticism from a group of “celebrity” chefs. Some have even gone so far as pledging not to serve wild Atlantic striped bass in their restaurants…
“As you may know, the United States imports up to 90% of its seafood every year. By buying and eating locally caught seafood like Atlantic striped bass, you are choosing a sustainable, environmentally responsible product that supports American fishermen and fishing communities…It is important to know where your seafood comes from, and with Atlantic striped bass, you can be confident that it is harvested responsibly.”
That’s just weird on a number of levels.
First, ASMFC’s job, and by extension its Executive Director’s job, is to manage, conserve and rebuild Atlantic coast fish stocks, not to promote the harvest, sale and consumption of any particular species.
We never heard equivalent criticism of folks who opposed management measures that scientists told us were needed (with respect to southern New England lobster, perhaps, or American shad, northern shrimp or maybe tautog), but the guns came out firing when some chefs suggested precaution.
Perhaps if ASMFC spent more time worrying about restoring fish stocks, instead of killing, cooking and eating them, they might have restored a few more of those stocks since ’95, instead of, well, none…
And exactly what did the chefs do to earn ASMFC’s attention and wrath?
Well, it was pretty admirable, as described in a story in Forbes.
“Kerry Heffernan, the former executive chef of Eleven Madison Park and Southgate, and the current impresario of the new Manhattan restaurant, Grand Banks, is obsessed with fishing for striped bass. But like countless recreational anglers up and down the East Coast, he’s noticed, with growing despondency, that fishing for stripers has grown worse and worse over the last few years. His personal tipping point came, he says, during the 2014 iteration of the Manhattan Cup, a New York City inshore catch-and-release fishing tournament…’I caught a puny eighteen-inch striper and it won the tournament in the fly fishing division,' he says. 'Even the guys fishing with artificials had pitiful results.' He decided then that something had to be done…
“Heffernan decided to embark on a new campaign, something called #SaveOurStripers. Leveraging his many years in the restaurant business…Heffernan cajoled nine of his fellow celebrity chefs to join him in making a pledge to take striped bass off of the menus in their respective restaurants…
“The SaveOurStripers campaign is, at once, both simple and powerful. Taking stripers off the menu is a relatively easy task, but the implications of such a move are much grander. Chefs, in general, have more visibility and power than ever before. They have become celebrities and cultural tastemakers. The campaign sends a strong message that they will no longer participate in the overharvest of fish…”
And when you look at it that way—which is the right way, I think—what the chefs did seems like something noble, and hardly worthy of criticism.
So what, exactly, is going on?
When you read Robert Beal’s column again, and combine it with the fact that ASMFC felt a need to announce on Twitter that
“Our Executive Director responds to criticisms of striped bass management,”
you might start to believe that ASMFC was feeling a bit defensive. And you usually don’t get defensive unless you have a least a suspicion—or maybe a fear—that your critics might have a point.
After all, ASMFC says that
“Since the Atlantic states orchestrated the historic comeback of Atlantic striped bass beginning in 1984…”
(Which we must note, was three decades ago; it’s probably past time that the Commission stopped looking back at the past, when it once recovered a stock, and started looking, instead, to the future.)
“…sustainable management has always been goal number one.”
That sounds good, but doesn’t clearly jibe with reality.
Addendum IV to Amendment 6 ofthe Interstate Management Plan for Atlantic Striped Bass, adopted by the Commission late last October, adopted harvest cuts on the coast that were so small that they only had a 50% chance of reducing fishing mortality to the target level—and the reductions taken in Chesapeake Bay couldn’t even achieve that.
A 50-50 chance of success—at best—truly sets a very low standard. If you sustainability is your primary goal, you might not want a management plan that’s as likely to fail as succeed.
In federal fisheries management, a 50% chance of success is the absolute minimum allowed; anything else is patently illegal. Federal plans frequently have 60%, 65% or even higher likelihoods of success in an effort to assure sustainability. But at the Commission, a mere 50% of failure seems to be viewed as something to laud…
It should also be noted that Amendment 6 to the Interstate Fishery Management Plan for Atlantic Striped Bass contains management triggers which require action when any such trigger is tripped.
One of those triggers was tripped when fishing mortality exceeded the target for two consecutive years, and spawning stock biomass dropped below target for at least one. It was that trigger that ultimately led to last October’s harvest reduction.
However, there is another trigger, which reads
“If the Management Board determines that the female spawning stock biomass falls below the target for two consecutive years and the fishing mortality rate exceeds the target for either of those years, the Management Board must adjust the striped bass management program to rebuild the biomass to a level that is at or above the target within [ten years] [emphasis added]”
But “must” apparently means something different to ASMFC than it does to the rest of us, because this trigger was also tripped, but no action to rebuild the stock to target within the ten year deadline was even discussed.
If sustainable management was really “goal number one,” you might think that rebuilding stocks mattered. Again, under the federal system, it is required, but at ASMFC…
Other claims made by ASMFC are equally subject to question.
For example, there’s that tired old assurance that
“Atlantic striped bass are not overfished and are not experiencing overfishing.”
Today, that may not be true.
It was true, back in 2013, when the benchmark stock assessment and the Update of the Striped Bass Stock Assessment using Final 2012 Data were issued. But the Update also noted that
“If the current fully-recruited [fishing mortality] (0.200) is maintained during 2013-2017, the probability of being below the [spawning stock biomass] reference point increases to 0.86 by 2015…If the current fully-recruited [fishing mortality] increases to Fthreshold (0.219) and is maintained during 2013-2017, the probability of being below the [spawning stock biomass] reference point reaches 0.93 by 2015…If the fully-recruited [fishing mortality] decreases to the current Ftarget (0.180) and is maintained during 2013-2017, the probability of being below the [spawning stock biomass] reference point reaches 0.77 by 2015…”
We don’t know exactly what the fishing mortality was in 2013 and 2014, but we do know that it probably wasn’t reduced to 0.180 until the new harvest cuts went into effect on January 1 of this year. Based on the stock assessment Update, at best, there is more than a 77% chance that the stock will be overfished—if it isn’t already—at some point this year.
In fact, since National Marine Fisheries data shows that recreational harvest in 2013 and 2014 was 24 million and 23.5 million pounds, respectively, considerably higher than the 19.5 million pounds landed in 2012, and since the biomass was still declining during those years, fishing mortality was very probably above 2012’s 0.200, which would push the likelihood of the stock being overfished this year into 90%-plus territory.
Thus, if ASMFC was being perfectly forthright, it would not make the claim that “Atlantic striped bass are not overfished and are not experiencing overfishing.” Instead, it would have admitted that
“The stock was not overfished, and was not experiencing overfishing, on December 31, 2012. However, based on the best available science, it is much more likely than not that it is overfished today.”
We should get a little more clarity on that at the November ASMFC meeting, when the Striped Bass Technical Committee provides a report on the state of the fishery as of the end of 2014. But even that won’t necessarily tell us whether the stock is overfished now.
Finally, we should also take issue with ASMFC’s claim that
“to reduce the downward trend and ensure the fishery remains sustainable, ASMFC initiated coastwide reductions in Atlantic striped bass harvest with the goal of harvest with a goal of protecting the strong 2011 year class and increasing [spawning stock biomass]…”
While that was certainly a stated intent in Addendum IV to Amendment 6 of the Interstate Fishery Management Plan for Atlantic Striped Bass, once again, the reality didn’t live up to the addendum’s aspirations.
Addendum IV was intended to reduce striped bass harvest by 25%, and on the coast, it did just that. However, in Chesapeake Bay, the required reduction is just 20.5%. And Chesapeake Bay is the only place where the 2011 year class can be harvested before the fish get to be 28 inches long, a size that most won’t attain until 2017.
And why did ASMFC allow Chesapeake Bay to take a lower reduction?
Why, so they could kill more of the 2011s, of course.
As Rob O’Reilly, representing the State of Virginia, noted quite clearly at the October 2014 Management Board meeting when arguing against a one-year, 25% reduction for the Chesapeake Bay jurisdictions
“The principal reason for wanting to go to three years [to reduce fishing mortality to the target level, instead of the one year mandated by the management plan] is that we do have small fish in the bay…
“These small fish include what Tom O’Connell mentioned that in 2015 45 percent of the 2011 year class will be under 20 inches. The small fish are not only part and parcel of commercial fisheries, but also of recreational fisheries. There are certainly areas in Virginia where all they see are small fish…”
Virginia and the other Chesapeake jurisdictions didn’t get to phase in the 25% harvest reduction over the course of three years. However, they didn’t get a 25% harvest reduction, either, but instead a smaller 20.5% cut.
That smaller cut will allow them to kill more of what Rob O’Reilly described as “small fish”—the very members of the 2011 year class that ASMFC claims it is protecting.
So once more ASMFC’s story doesn’t ring true.
Given so many holes in so many of their positions, it’s not surprising that ASMFC is sounding pretty defensive when it comes to striped bass.
On the other hand, Kerry Heffernan and the chefs aren’t defensive at all. Having right on their side is an adequate shield.