Sunday, April 30, 2017


The Management Board will receive an update on Draft Amendment 3 to the Interstate Fishery Plan for Atlantic Menhaden.  That’s an important action, because the Draft Amendment is expected to include ecological reference points that will allow managers to manage menhaden for their value as a forage fish, a big step away from the single-species management practiced today, which is focused only on sustainable harvest.  Such a management approach represents an big step forward that, if implemented, could potentially be emulated for other forage species managed by ASMFC and by the regional fishery management councils, including but not limited to river herring, Atlantic herring and Atlantic mackerel.

The Management Board will also “Consider Hilborn et. al. 2017 Paper for Technical Review.”

If the conclusions of such paper are ultimately accepted as the best available science, something that would only happen after review by the ASMFC’s Atlantic Menhaden Technical Committee and further action by the Management Board, perhaps at its August meeting, the efforts to establish ecological reference points will probably come to a screeching halt, and menhaden will continue to be managed as a commercial commodity.

Since the Hilborn paper could mark a watershed in the management of Atlantic menhaden, and perhaps forage fish generally, a little background is in order.

The best place to start is probably with an organization called IFFO (2012) Ltd., organized under the laws of England, which refers to itself as “The Marine Ingredients Organization.”  According to its website,

“IFFO is the international ‘not-for-profit’ organization that represents and promotes the fishmeal, fish oil and wider marine ingredients industry worldwide.  We are globally respected and regularly represent the industry at international forums, as well as holding observer status at the UN Food and Agriculture Organization (FAO) and the EU Commission and Parliament.
“Acting on behalf of the fishmeal and fish oil producers and their trade associates, IFFO works to strengthen the global standing of the industry, while supporting responsible supply worldwide.  With a network of members reaching across 55 countries, our members account for over 50% of world production and 75% of the fishmeal and fish oil traded worldwide.  While these products are the core of our industry, recent years have seen a widening to include marine algae cultivation and the production of meal and oil from krill.  Our members include producers, traders, feed companies, edible oil refiners, retailers, financial institutions, governmental and non-governmental organizations.”
In other words, if you’re a player in the business of hoovering up various forage species and turning them into chicken feed, anywhere in the world, IFFO are your kind of folks.

It would hardly be surprising to find that IFFO wasn’t pleased with the report Little Fish, Big Impact, prepared by the Lenfest Forage Fish Task Force about five years ago.  

The Task Force was composed of 13 PhD level biologists, from five different nations, who came to together

“to provide practical, science-based advice for the management of forage fish because of these species’ crucial role in marine ecosystems and because of the need for an ecosystem-based approach to fisheries management,”
And recommended that

“Because many animals and humans depend on forage fish, it is important to manage fisheries that target them in a precautionary manner that accounts for their high degree of variability and importance to the ecosystem.”
That couldn't have made the "marine ingredients" folks very happy.

It’s also not surprising the Omega Protein Corporation, which purse seined over 300,000,000 (yes, 300 million) pounds of menhaden in 2015, which were “reduced” into fish meal and other industrial products, is a member of IFFO

Now, here is where things get interesting.

According to IFFO’s website,

“IFFO was recently approached by Professor Ray Hilborn of the University of Washington regarding a project to develop the scientific knowledge of forage fish stocks.  The long term health and effective management of these stocks is essential to our industry and, after considering the project objectives, the IFFO Board has agreed to provide some funding…We are now asking members to confirm any particular fish stocks of interest that should be investigated by the project team.  Please also advise the names and contact details of any fishery scientists with knowledge of those stocks who may be of assistance. 
“IFFO, the trade organization for the global marine ingredients industry, is delighted to see a research project launched by the University of Washington, led by Professor Roy Hilborn, to refine and expand some of the initial work already done on the management of Forage Fish stocks.  In response to a call to support the project, IFFO has agreed to provide information to support the research and financial assistance towards the costs incurred.   [emphasis added]”
It turns out that the paper prepared by Dr. Hilborn and his team, “When does fishing forage species affect their predators?”, only addressed seven forage species, Pacific chub mackerel, Pacific hake, Pacific sardine, Atlantic herring, Atlantic mackerel, Atlantic menhaden and Gulf menhaden, all of which are important to the “marine ingredients” industry.  

The primary harvester of both Atlantic menhaden and Gulf menhaden is, not coincidentally, Omega Protein.

Predictably, the industry-funded research team

“found little evidence that the abundance of individual species of forage fish was positively related to the per capita rate of change in their predator populations.”
It's reminiscent of the tobacco industry-funded research that found no clear connection between cigarettes and lung cancer.  But it is perhaps more relevant to remember a comment by University of California researcher Elisa K. Tong, who noted that

“It’s not just about fighting smoke-free regulations.  Our analysis of the [internal tobacco industry] documents indicates an industry that also wants to influence the debate about how ‘reduced-harm’ tobacco products should be evaluated.”
Putting that into a fisheries context, we have an industry that was somewhat set back on its heels by the Lenfest report, and needed a way to find a way to influence the forage fish management debate at a fundamental level.  Seen in that context, industry funding of the Hilborn report was a no-brainer.

Dr. Hilborn falls out of the current mainstream of fisheries scientists.  In 2006, he published a paper entitled “Faith Based Fisheries”, in which he criticized much of the work then being published, which generally supported precautionary management and ecosystem-based management measures.  He wrote that

“before we congratulate ourselves too much for the triumph of the scientific method over belief, I suggest the fisheries community needs to look at itself and question whether there is not a within our own field [sic] a strong movement of faith-based acceptance of ideas, and a search for data that support those ideas, rather than critical and skeptical analysis of the evidence.
“This faith-based fisheries movement has emerged in the last decade, and it threatens the very heart of the scientific process—peer review and publication in the top journals.  Two journals with the highest profile, Science and Nature, clearly publish articles on fisheries not for their scientific merit, but for their publicity value.  Beginning in at least 1993 with an article I co-authored…Science and Nature have published a long string of papers on the decline and collapse of fisheries that have attracted considerable public attention, and occasionally gaining coverage in the New York Times and the Washington Post.  I assert that the peer review process has now totally failed and many of those papers are being published only because the editors and selected reviewers believe in the message, or because of their potential newsworthiness…”
He then goes on to make specific criticisms of papers that, at the time, had recently been published.

I won’t, and from a purely academic perspective, probably can’t, make an informed comment on whether any of his criticism of the journals or the peer review process is justified.  However, anyone looking for flawed data in a peer-reviewed paper, that perhaps influenced its results, need go no farther than Dr. Hilborn’s teams’ recent forage fish study.

Again, I lack the knowledge to question all of the information therein, but I did take a look at the data related to fish that I’m personally familiar with, and noticed that a few things seem askew.

For example, there are four graphs (numbers 42-45), which purport to show the relationship between spiny dogfish and four forage fish species.  The line showing the abundance of spiny dogfish is the same in all four charts, which compare it with the abundance of Atlantic menhaden, Atlantic herring, Pacific hake and Atlantic mackerel.

When I saw that for the first time, I felt as if I was a very young child again, playing the picture-puzzle game “Which one doesn’t belong?”  

While it was perfectly understandable that the abundance curve for spiny dogfish would be the same for all three Atlantic forage species, it is difficult to believe that the spiny dogfish that regularly fed on Pacific hake would follow an identical pattern of abundance and decline over the many years of data.  A far more likely explanation was that the graph was either applying Atlantic abundance data to the Pacific stock of dogfish, or vice versa. 

In other words, some of that graphed data just had to be wrong.

And then, there was the paper’s reliance on research that supposedly showed that

“the mean size of Atlantic menhaden (Brevoortia tyrannus) eaten by striped bass (Morone saxatilis) in Massachusetts was 8.4 cm [or, less than 3 ½ inches]”
which apparently led to a chart suggesting that striped bass didn’t feed on menhaden more than 20 cm, or about 8 inches, long.

The paper then used that data to suggest that, since the mean size of the menhaden taken in the commercial fishery was 28 cm,

“the fishery harvests only those individuals that have survived and grown large enough to escape most of their predators.”

I've been a participant in the striped bass fishery for about fifty years, and can say from five decades of observation that, while one study might say that striped bass only eat little fish (perhaps it was a study of little striped bass, or big menhaden were scarce at the relevant place and time), Dr. Hillborn et. al. definitely should have obtained a little more information before making such a sweeping conclusion.

In a few weeks, big schools of Atlantic menhaden will start moving along the Long Island coast, and take up temporary residence off my home waters around Fire Island Inlet.  Few of those menhaden will be as small as 8 inches long, and all will be larger than 3 ½ inches.  Even so, those menhaden will be targeted and harassed by pods of striped bass, which will avidly spend their nights and days sucking down foot-long (more than 30 cm) fish.  

Bluefish, weakfish and a host of sharks, ranging from small sandbars to quarter-ton common threshers, will be eating those big menhaden, too.

At 12 inches/30 cm, menhaden have most certainly not “grown large enough to escape most of their predators.”  A two-pound bluefish will still chop off their tails…

So some of the data in the Hilborn team’s paper was definitely a little off. 

And the paper itself seems to reflect a sort of bias, although a bias that appears to be the antithesis of what Dr. Hilborn wrote in “Faith Based Fisheries.”  After presenting conclusions that reflected the data used in the study, the paper went beyond the data to note

“It must be remembered that small pelagic fish stocks are a highly important part of the human food supply, providing not only calories and protein, but micronutrients, both through direct human consumption and the use of small pelagics as food in aquaculture.  Some of the largest potential increases in capture fisheries production would be possible by fishing low trophic levels much harder than currently.  While fishing low trophic levels harder may reduce the abundance of higher level predators, that cost should be weighed against the environmental cost of increasing food production on other ways…”
Such a statement seems to have little direct bearing on the predator/forage relationship that the paper was supposed to examine.  It may even contradict the paper's findings a bit, as it admits that “fishing low trophic levels harder may reduce the abundance of higher level predators,” while the paper proposed claimed that the researchers “found little evidence that the abundance of individual species of forage fish was positively related to the per capita rate of change in their predator populations.”

But it does seem to reflect a certain faith-based belief that forage fish harvest is a good thing.

There can be little doubt that it pleased the industry sponsors.

And no doubt at all that industry-funded research can, at times, get out of hand.

For a long time, such research assured us that Roundup, Monsanto’s flagship weed killer, is perfectly safe.  Some non-industry research suggests that it may cause cancers, including non-Hodgkins’ lymphoma.  Right now, no one knows for sure.

According to the New York Times, company documents unsealed pursuant to a California lawsuit included an e-mail in which

“William F. Heydens, a Monsanto executive, told other company officials that they could ghostwrite research on glyophosphate by hiring academics to put their names on papers that were actually written by Monsanto.  ‘We would be keeping the cost down by us doing the writing and they would just edit & sign their names so to speak,’   Mr. Heydens wrote, citing a previous instance in which he had said the company had done this.”
Such action by Monsanto, if it occurred, would be far, far beyond acceptable norms, even for industry-supported projects.  No one is suggesting that the Hilborn team’s paper is the result of anything except an analysis of the relevant data.  Instead, as noted by Dr. Carl Safina in “Ocean Views,” a blog of National Geographic,

“Everyone uses data to back their claims.  But what one is looking for affects what one looks at.  Fisheries scientists like Hilborn often look for how many fish can be caught, while fish- and ocean ecologists look for how many fish must be left in the sea, or how to get them back.  We now know that while some deeply depleted fish have been unable to rebuild, many others have indeed rebuilt when fishing pressure is lessened.
“…Ray Hilborn is a darling of the fishing industry and a hero to extraction-oriented fisheries scientists because he thinks like they do, seems to excuse excesses, and seems to give them permission to do what they want to do: catch fish and not worry too much about it.”
“When does forage fish fishing affect their predators?” should be read with those thoughts in mind.

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