The Magnuson-Stevens Fishery Conservation and Management Act (MSA) requires that “Conservation and management measures shall prevent overfishing while producing, on a continuing basis, the optimum yield from each fishery for the United States fishing industry.”
MSA also states, in part, that “The term ‘optimum,’ with respect
to the yield from a fishery, means the amount of fish which (A) will provide
the greatest overall benefit to the Nation, particularly with respect to food
production and recreational opportunities, and taking into account the
protection of marine ecosystems; [and] (B) is prescribed as such on the basis
of the maximum sustainable yield from the fishery, as reduced by any relevant
economic, social, or ecological factor… [internal formatting omitted]”.
Given that language, one might think that, before establishing
annual catch limits for all managed species, the regional fishery management
councils would engage in meaningful discussion of how to achieve optimum yield
from each fishery.
In the real world, that doesn’t happen.
The Mid-Atlantic Fishery Management Council (MAFMC) does a very
good job of explaining how annual catch limits are calculated. Using the 2020 summer flounder
specifications as an example, calculations begin with the
overfishing limit. The MAFMC’s Scientific and Statistical Committee, reducing
that figure to account for scientific uncertainty, then sets the acceptable
biological catch (ABC), which is then allocated to the commercial and
recreational sectors. Each sector’s expected discards then deducted from its
allocation, to establish the commercial quota and the recreational harvest
limit.
Both the MAFMC’s staff and the biologists who sit on the Summer Flounder, Scup, and
Black Sea Bass Monitoring Committee (Monitoring Committee)
prepared detailed reports outlining how they made such calculations; neither
report even employed the term “optimum yield,” much less discussed it in
detail, despite its relevance to the annual catch limit.
Such lack of optimum yield analysis is typical, not only at the
MAFMC, but also at all of the regional fishery management councils. The focus
is always on harvest; despite being specifically mentioned in the MSA,
considerations like increased recreational opportunities, or social and
economic considerations that might lead to reduced landings, are rarely
considered.
It’s hard to place blame for the lack of meaningful optimum
yield analysis on the regional fishery management councils. NOAA Fisheries’
website includes a page “Setting an Annual Catch Limit,”
which is subtitled “Learn how annual catch limits are set for U.S. fisheries.”
That webpage sets out a process indistinguishable from that used by the MAFMC.
The NOAA Fisheries web page doesn’t even mention the concept of
optimum yield, even though the MSA directs that producing optimum yield is the
goal of fishery management measures.
As a practical matter, omitting a detailed optimum yield
analysis probably makes sense for summer flounder, as well as for other
species, such as cod and the various groupers, which are targeted by both
commercial and recreational fishermen because they are valued as food. While
summer flounder, for example, might be fun for anglers to catch, those anglers
pursue them because they want to bring them home for dinner, and not just for
the sport of catching them, and then letting them go.
In such situations, there are no economic, social, or
environmental considerations that might justify reducing optimum yield below
maximum sustainable yield; the key considerations of maximizing food production
and recreational opportunities are best addressed by keeping both the
commercial quota and recreational harvest limit at the highest sustainable
levels.
That isn’t the case with recreational fisheries that include a
significant catch-and-release component. For those, an optimum yield analysis
is needed, but very rarely performed. Regional fishery management councils
instead still focus on yield, with little or no thought given to the economic
and social considerations that might justify setting optimum yield well below
maximum sustainable yield, or the benefits that might accrue to the nation if a
recreational species were managed for abundance and recreational opportunity,
rather than solely for landings and food production.
Such issues have emerged in connection with the Bluefish
Allocation and Rebuilding Amendment (Bluefish Amendment) that is being prepared
by the MAFMC.
While bluefish support a small commercial fishery, their oily
and often strong-tasting flesh cause them to be less popular table fare than
white-fleshed fish such as summer flounder, black sea bass, or cod; they
command a much lower price when brought to market. The scoping document for
the Bluefish Amendment reported that between 2013 and 2017, fishermen received,
on average, only 71 cents per pound for bluefish, far less than the four
dollars per pound that markets paid for striped bass and summer flounder
at that time.
Many recreational fishermen also dislike eating bluefish but
very much like to catch them because of the fight that they put up when hooked.
As a result, more than 60 percent of
all bluefish caught by recreational fishermen are released. In such a fishery,
“the greatest overall benefit to the Nation” comes not from focusing on food
production, but on maximizing recreational opportunities.
And maximizing recreational opportunities means maximizing the
abundance of live bluefish in the water, not the number of dead bluefish lying
on the dock.
Estimates of angler effort, provided by the Marine Recreational
Information Program (MRIP), make that very clear. Bluefish were relatively abundant In 1985, when anglers made about 13,890,000
directed bluefish trips, including about 465,000 trips made by the
for-hire sector. As bluefish abundance declined, trips declined, too.
By 2000, in response to low abundance; directed trips had fallen
to 5,110,000, including just 154,000 made by the for-hire fleet. Then, as
abundance rose modestly, angler effort showed a modest increase as well, rising
to 7,530,000 directed bluefish trips in 2010. Then, as the population fell to
near time-series lows in 2019, trips fell again, to 5,330,000 trips, with fewer
than 46,000 of those made on for-hire vessels.
With such a clear correlation between bluefish abundance and
directed recreational bluefish trips, the MAFMC seems obliged to consider
whether the optimum yield for bluefish should be reduced well below maximum
sustainable yield, in order to capture the economic and social benefits conferred
by an abundant bluefish population and the recreational opportunities that such
abundance would provide.
Yet the MAFMC has given, at best, only cursory consideration to
the issue. The MAFMC website provides 20 separate documents relating
to the Bluefish Amendment, created over the course of 38 months, that include
two scoping documents, one public hearing document, a MAFMC staff memo, and the
summaries of three bluefish fishery management action team meetings.
Across all of those documents, despite its importance in the
MSA, the term “optimum yield” appears only twice,
once in a summary of comments that I made at the first scoping meeting, and the other in a
presentation to the MAFMC which stated why the Bluefish Amendment is needed.
But the MAFMC never took a good look at what managing for
optimum yield would look like in the bluefish fishery.
MAMFC staff did acknowledge that,
at the first scoping meetings, recreational fishermen argued that “Recreational
management should focus on maximizing abundance over landings,” and also argued
that managers should “Offer consideration to the economic and intrinsic value
of bluefish to the recreational fishery.” Such concerns were included in a Supplemental Scoping and Public
Information Document released late in 2019, after an operational stock assessment found
the stock to be overfished.
But the MAFMC members gave those concerns little consideration,
and instead focused on maintaining bluefish landings, rather than bluefish
abundance. At a May 2020 joint meeting of
the MAFMC and the Atlantic States Marine Fisheries Commission’s Bluefish
Management Board, Dustin Leasing, the Atlantic States Marine Fisheries
Commission’s Bluefish Fishery Management Plan Coordinator, noted that “A lot of
comments [at the scoping hearings] talked about identifying the intrinsic value
of fish left in the water, as well as the catch and release aspect of the
fishery. A lot of people called for maximizing abundance…”
That was the last time that the word “abundance” was uttered at
the meeting.
Thus, it’s hardly surprising that, when the Public Hearing Document for the
Bluefish Amendment was released in February 2021, the analysis
of the social and economic impacts were heavily skewed toward food production,
and ignored recreational opportunities.
The Public Hearing Document’s discussion of different
commercial/recreational alternatives notes that “an increase in allocation to
the recreational sector could allow for the liberalization of [management]
measures, potentially providing positive social impacts.” It only considers the
“positive social impacts” that might be generated if anglers are able to keep additional
fish; nowhere in the document is there mention of the positive social impacts
generated by greater abundance, that would allow anglers to catch, but
not necessarily harvest, more bluefish.
Yet any comprehensive analysis of optimum yield should demand
that such benefits be considered.
The Public Information Document’s economic impacts section shows
the same bias, considering only the impacts of landings, and not of abundance.
The document states that “Increases in bag limits might increase angler
satisfaction as well as recreational for-hire and independent angler trips
which would result in increased expenditures and effort,” completely ignoring
the MRIP data that strongly links recreational effort, in both the private and
for-hire sectors, to abundance, not to bag limits.
The Public Information Document also says, “In theory, if the
decision to transfer [recreational quota to the commercial sector] is based on
a pattern of underutilization by the recreational sector, negative
socioeconomic impacts to the recreational sector from such transfer may not be
realized,” again equating the concept of “utilizing” a fishery with harvesting,
and not merely catching, fish. No mention is made of the negative socioeconomic
impacts of reduced abundance that might result, at either a coastwide or local
level, from a transfer of fish that would otherwise go unharvested, in the form
of reduced recreational opportunity and a reduction in fishing effort linked to
lower bluefish availability.
In what may be the most tone-deaf passage in the entire Public
Hearing Document, the MAFMC states that recreational management measures “are
frequently adjusted in order to strike an appropriate balance between
conservation and angler satisfaction,” a statement that completely ignores the
fact that in the recreational bluefish fishery, conservation that leads to
greater abundance increases both angler satisfaction and angler participation
in the fishery, as demonstrated by the MRIP effort data.
A rigorous optimum yield analysis would reveal that truth, for
bluefish and for other primarily recreational species. But to regional fishery
management council members who are focused only on yield, such a concept is
seemingly beyond their comprehension.
Optimum yield is arguably the core concept of the MSA, the hinge
around which all of the laws’ other provisions pivot. Yet it is also a concept
that is given little more than lip service in council discussions and in
fishery management plans.
If the nation’s living marine resources are to be managed
properly, and in full compliance with the law, that needs to change.
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This
blog first appeared in “From the Waterfront,” the blog of the Marine Fish
Conservation Network, which can be found at http://conservefish.org/blog/
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