On
the afternoon of May 9, the Atlantic States Marine Fisheries Commission’s
Atlantic Menhaden Management Board will meet to address a number of matters. Two are particularly important.
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.”
Well…
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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