Thursday, January 26, 2017


The long, winding path of menhaden management is approaching another crossroads.

On the afternoon of February 1, the Atlantic States Marine Fisheries Commission’s Atlantic Menhaden Management Board will meet for a scheduled three hours.  One of the topics that the Management Board will discuss is the proposed Amendment 3 to the Interstate Fishery Management Plan for Atlantic Menhaden, which has the potential to initiate a real sea change in the way menhaden are managed.

Atlantic menhaden are almost certainly the single most important forage fish—that is, fish that other fish (and other animals) eat—on the East Coast.  While other species such as sand eels and mullet may, in some times and places, assume greater significance, no one fish has the same impact when all waters between northern Maine and southern Florida are considered.

However, current menhaden management doesn’t emphasize the species forage role; instead, it is managed in the same manner as high trophic level predators, with the emphasis on maintaining high but sustainable levels of harvest.

Amendment 3 to the management plan has the potential to turn that around; the Management Board is considering the adoption of ecological reference points that would allow the species to fulfill its role as a primary forage species by leaving more menhaden alive in the water to serve as food for various fish, birds and marine mammals, rather than allowing such menhaden to be caught and turned into various industrial products, including the dried fish food used in Chinese fish farms.

The process of amending a fishery management plan is long and complex, and the final version of Amendment 3 is, at best, many months away.  Since last November, ASMFC has been holding public hearings to determine how folks would like to see menhaden managed.  The concept of ecological reference points has achieved wide support, which crossed traditional lines to be shared by many commercial and recreational fishermen, along with conservation groups, whale-watching operations, birders and others concerned with the overall health of the marine environment.

A summary of the public comment prepared by Meagan Ware, ASMFC’s Fishery Management Plan Coordinator for Atlantic menhaden, reveals that out of 25,554 letters received by ASMFC, all but one supported some form of ecological reference points.  25,530 of the letters supported adopting menhaden-specific ecological reference points once the data needed to determine such reference points are developed, and adopting more generalized ecological reference points in the interim, 8 did not support using interim measures but did support menhanden-specific reference points and 7 supported managing menhaden with reference points generally appropriate for forage species. 

226 of the letters supporting ecological reference points were written by individuals, 71 were submitted by various organizations and 25,248 represented individuals who signed on to one of 10 different form letters. 

The sole letter supporting the status quo came from Seafreeze Ltd., a Rhode Island-based commercial fishing operation that specializes in catching large quantities of relatively low-value fish, many if not all of which are important  forage species.  

Omega Protein Corporation, the only industrial harvester and processor of menhaden on the East Coast, was remarkably, and perhaps ominously, silent on the issue.

Other issues are also being considered in the draft Amendment 3, but from a purely conservation standpoint, the adoption of ecological reference points is the big issue.  If the Management Board ultimately goes the wrong way on that one, its actions on the other issues will have relatively little import.  On the other hand, if ecological reference points are adopted, none of the other issues, no matter how they’re decided, can do the resource all that much harm.

Thus, February’s meeting is important, not because a final decision will be made at that time—it certainly won’t be—but because the Management Board is expected to decide which options will be included in—or left out of—the next draft of the Amendment, which will probably be released for public comment in late winter or early spring.

Despite strong public support for ecological reference points, there is undoubtedly other folks politicking behind the scenes.  

Although Omega Protein did not actively engage ASMFC during the public comment period, its representatives were making their opinions clear in the press.  One piece, written by Omega Vice President Monty Diehl, was posted as a rebuttal to an op-ed that appeared in The Virginian-Pilot not long ago.  There, Diehl expressed Omega’s opposition to ecological reference points, saying

“scientists believe that there are sufficient levels of menhaden left in the water for the species to fulfill its ecological role.  The fishery leaves over 93 percent of the fish in the water for just this purpose.  And while special interest activists and sport fishermen like to talk up menhaden’s role as forage for predators, a 2015 study from the University of Maryland Center for Environmental Science found that the bay anchovy is actually the most important forage fish in the Bay.  Meanwhile, menhaden was not even in the ‘top three or four.’”
Like most Omega statements, Diehl’s is a garden of misdirection.  If scientists really believe that the number of menhaden available today is sufficient to fulfill the species’ ecological role, then the ecological reference points won’t put any crimp on Omega’s fishing at all, so there is no need to oppose them.  The only reason for Omega to stand against such reference points is that it’s afraid that too many fish really are being removed from the sea.

Certainly, Diehl’s statement that 93% of menhaden are left in the water is a meaningless figure.  The question isn’t how many menhaden we do leave in the ocean under today’s management, but rather how many menhaden should be left in the ocean under tomorrow’s new, hopefully improved management program that matters.  Let’s not pretend that Omega is leaving 93% of the menhaden in the water so that the fish can fulfill their role as forage.  They leave the fish in the water because ASMFC says that they have to, although Omega keeps trying to increase its kill.

And yes, fish in Chesapeake Bay were found to eat things other than menhaden.  If your preferred food isn’t available, you eat something else.  But one study, done at a time when small menhaden weren’t particularly abundant, doesn’t demonstrate what fish would be eating if menhaden were more abundant.

Even though Diehl’s response isn’t particularly convincing, if you’re familiar with all of the relevant data, a lot of people can be swayed by “alternative facts” if they’re presented in an appealing package.  There’s no doubt that Omega will be out there warning Management Board members that if further restrictions—which ecological reference points might or might not require—it will cause them to shut down a part of their operation, lay of fishermen, etc.

What Omega will undoubtedly leave out of that story is that the company has been doing so well that, for the first time in its history, it will pay a dividend to all of its stockholders, which means that any layoffs that might occur will be a matter of corporate priorities, not financial necessity.

So the public has sent in a lot of letters, and appeared at all of the hearings, and argued for ecological reference points.  

That’s good.

But the public must also understand that big outfits such as Omega, Seafreeze and probably others based down in New Jersey will be working in the background right up to the final vote, trying to stem the tide and keep management just as it is.  If the public quits now, ecological reference points might not make it into the next draft of the amendment.

So this is the time to make just one more push.  Go to and find out who your state’s commissioners are.  Give them a call, or send them an e-mail, and let them know that ecological reference points matter to menhaden, matter to the East Coast ecosystems and matter to you.

Ask them to keep ecological reference points—Option 1D—in the next draft.

Menhaden management is at a new crossroads, and we need managers to make the right turn.

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