ALL FISHERIES STAKEHOLDERS ARE EQUAL, BUT SOME ARE MORE EQUAL THAN OTHERS

 

Sometime during our school years, maybe in junior high or maybe in high school, we were probably all exposed to George Orwell’s Animal Farm, an allegorical fantasy of a once-idealistic government gone tragically wrong.  It’s safe to say that most remember the novel’s pivotal line:

“All animals are equal, but some animals are more equal than others,”

given that, since the book came out in August 1945, it has proven applicable to far too many political situations.

Now, given some of the things that we’ve heard at the Atlantic States Marine Fisheries Commission, we have to wonder whether it applies to fisheries management, too.

I’ve already dedicated a couple of essays to last Tuesday’s meeting of the ASMFC’s Atlantic Menhaden Management Board, and though today’s blog focuses on menhaden too, it shouldn’t be read in such a narrow context.  What it really talks about is whether the public should have a greater say in how public resources are managed, or whether the relative handful of people who derive private profit from such public resources should be given greater sway. 

Still, last Tuesday’s meeting is a good place to start, because it included some troubling comments that illustrate how that question is being answered at the ASMFC.

In supporting the motion to set the annual catch limit at194,400 metric tons, a level of landings that the management board knew waslikely to exceed the fishing mortality target that the same management boardset just two months before, one state manager said that

“If we do it gradually…we will be able to bring all of our stakeholders with us as we move forward,”

with the “it” she referred to being reducing such landings to a level that will have at least a 50 percent probability of achieving the target fishing mortality level.

On its face, that comment might not seem so bad, but that changes when it’s read in the context of recent menhaden management actions, and stakeholder input on the actions that were or were not taken.

At its August meeting, the Atlantic Menhaden Management Board unanimously adopted so-called “ecological reference points” for menhaden management.  For the first time, menhaden landings wouldn’t be merely constrained by the amount of menhaden that could be removed from the population without harming the stock.  Instead, landings would be limited to the amount of menhaden that could be removed without causing harm to the fish, birds, and marine mammals that depend on the species as an important part of the forage base in Atlantic coastal ecosystems.

Striped bass were used as a proxy, or as some management board members said, an “indicator species” for the broad array of predators that feed on menhaden, because striped bass are more dependent on menhaden than any other fish species examined.  Thus, the menhaden abundance target was set at the level that would support the striped bass stock at its target level, while the abundance threshold was set at the level needed to support a striped bass stock that had declined in abundance and was teetering on the edge of becoming overfished.

The adoption of such ecosystem reference points was the culmination of an advocacy effort that began more than a decade ago, and was broadly supported.  In a presentation made by ASMFC staff to the menhaden management board at last August’s meeting, staff noted that

“Many comments were submitted on [ecological reference points,]”

including 16 letters signed by more than 100 organizations, more than 1,000 form letters, and over 200 individual comments.  Staff also noted that, out of all of those letters, an

“Overwhelming majority:  approve [environmental reference points] to manage Atlantic menhaden.  [emphasis added]”

While many who commented did not state just what such ecological reference points ought to be (which is a perfectly logical position, given that the matter is best determined by qualified biologists), others wanted to see reference points that

“Specified [environmental reference points that allowed striped bass to rebuild”

and/or noted that menhaden are an

“Important forage species that supports recreational fisheries and coastal economies.”

So, based on the ASMFC’s own comments, it appears that just about all of the stakeholders, whether anglers or not, were concerned with menhaden’s impact on coastal ecosystems, and wanted to see ecological reference points adopted—and presumably wanted to see the menhaden management board take those reference points seriously, and establish harvest limits that were intended to achieve the reference point target.

And that is what makes the comment about “bringing all of our stakeholders with us” by not managing to the fishing mortality target, but instead establishing annual catch limits that will knowingly exceed that mark.

Because, in the ASMFC’s own words, it seems like the “overwhelming majority” of stakeholders were already on board with setting a harvest level that would achieve the fishing mortality target. 

Of course, not everyone agreed with that overwhelming majority.  The ASMFC publishes all of the comments that it receives on fisheries issues, and a review of the materials for the August meeting reveals that there were two letters in opposition to the ecological reference points.  One of those letters came from the Menhaden Fisheries Coalition, an organization that describes itself as

“a group comprised of bait and reduction fishermen, dealers, and processors who rely on Atlantic menhaden to support themselves, their families, and other fisheries,”

and includes entities such as the Garden State Seafood Association, Long Island Commercial Fishing Association, Lund’s Fisheries, Massachusetts Lobstermen’s Association, North Carolina Fisheries Association, Omega Protein Inc., the Virginia Watermen’s Association and a number of smaller entities.

The other letter came from a group called the Science Center for Marine Fisheries, which claims to represent

“a federal initiative to bring together academic researchers and industry members to fund projects improving our understanding of the scientific uncertainties around fisheries assessments and evaluating economically important issues for fishing communities.”

There is substantial overlap between the Menhaden Fisheries Coalition and the Science Center for Marine Fisheries; Greg DiDomenico, who chairs the Science Center’s Industry Advisory Board, is also the Executive Director of the Coalition member Garden State Seafood Association.

While such organizations, and particularly the Menhaden Fisheries Coalition, claimed to support the adoption of ecological reference points, they also clearly supported maintenance of a status quo catch limit of 216,000 metric tons for the years 2021 and 2022.

And they were the only stakeholders who took such a position.

The same dynamic carried over into last Tuesday’s meeting.  

Although there were far fewer comments made overall, perhaps because many believed that, after adopting ecological reference points in August, the ASMFC would act consistently, and adopt a landings limit that was consistent with those reference points two months later, the only comments seeking to maintain the status quo, and not act in accord with the reference points, came from the Menhaden Fisheries Coalition and from the Massachusetts Lobstermen’s Association, which is a Coalition member.

Once again, the majority of the stakeholders who commented were part of a broad coalition of anglers, conservation groups, and science professionals who supported setting a landings limit with at least a 50 percent probability of constraining harvest to or below the fishing mortality target.  The only ones who opposed such action were either menhaden harvesters, menhaden processors, menhaden wholesalers, or lobstermen who used menhaden as bait—in other words, were people who, in one way or another profited from dead menhaden.

And while the memberships of such financially interested parties isn’t small—the Massachusetts Lobstermen’s Association alone claims 1,800 members—the organizations who supported managing to the fishing mortality target didn’t have small memberships, either.  They included angling organizations such as the Coastal Conservation Association and International Game Fish Association, trade groups such as the American Sportfishing Association, American Saltwater Guides Association, and National Marine Manufacturers Association, conservation organizations such as Wild Oceans, the National Audubon Society, National Wildlife Federation, Conservation Law Foundation, Wildlife Conservation Society, The Nature Conservancy, and the Theodore Roosevelt Conservation Partnership. 

Thus, even when membership is taken into account, the number of stakeholders who supported managing to the fishing mortality target far outweighed the number who supported less effective management.  Yet there was no concern about adopting a harvest limit that would "bring" that overwhelming majority of "stakeholders along."

Instead, the ASMFC’s Atlantic Menhaden Management Board opted to support the menhaden industry’s short-term financial interests, rather than the long-term interests of both the public and the Atlantic coast's ecosystems.

The only explanation for that is that the Atlantic Menhaden Management Board doesn’t view all stakeholders equally, but instead favors those who profit from a public resource, and elevates their concerns above those expressed by everyone else.

That shouldn’t come as a surprise.  ASMFC has a long history of elevating narrow, short-term economic concerns above scientific advice, the health of fish stocks or, as we see with menhaden, even ecosystem-wide concerns. 

The failure to manage menhaden to the fishing mortality reference point is just a new symptom of a very old problem, which manifested itself when the ASMFC ignored scientific advice with respect to the southern New England stock of American lobster in 2010,  permitted the now-collapsed northern shrimp stock to be overfished through 2013, adopted a 2017 amendment to the tautog management plan that allowed overfishing to continue in Long Island Sound until 2029 and, in a chain of events stretching back to 2011, ignored both scientific advice and the requirements of its own management plan to rebuild the striped bass spawning stock, decisions that left the stock both overfished and subject to overfishing at the end of 2017; even now, the weak measures adopted by its Atlantic Striped Bass Management Board a year ago have only a 42 percent chance of returning fishing mortality to the target level by the end of this year, partly because of concerns to protect Maryland’s for-hire and commercial fishing fleets.

Some stakeholders truly are more equal than others in the ASMFC’s eyes.  Those who profit from harvested fish, even when they constitute a very small minority of stakeholders, are and have always been “more equal” than those concerned with the long-term welfare of fish stocks.

That’s wrong.

And, one way or another, it needs to change.