ATLANTIC MENHADEN: DEAD IS DEAD, AND ALLOCATION IS NOT CONSERVATION

 

One of the biggest disappointments at the Annual Meeting of the Atlantic States Marine Fisheries Commission last October was the Atlantic Menhaden Management Board’s failure to adopt meaningful reductions in menhaden landings.

The 2025 stock assessment update had found an error in the estimate of natural mortality, and determined that the natural mortality rate was lower than previously believed.  As a result, the estimate of stock fecundity (the overall number of eggs produced, which is used in lieu of a spawning stock biomass estimate) dropped substantially, while the estimated fishing mortality rate increased.  Thus, while the stock status remains

“not overfished and overfishing is not occurring.”

the assessment update noted a marked change in the perceived condition of the stock.  Previous to the update, it was believed that fecundity was above the fecundity target, and that the fishing mortality rate was below the fishing mortality target, which suggested that the stock was in something close to perfect health.  But the stock assessment update informed managers that, in fact,

“The fishing mortality rate for the terminal year of 2023 is below the [ecological reference point] threshold and above the ERP target…and the fecundity for the terminal year of 2023 is above the ERP threshold and but [sic] below the ERP target.” 

Thus, while the stock is neither overfished nor experiencing overfishing, it is also at suboptimal abundance and being fished at a somewhat excessive rate.  Somewhat ominously, fecundity was low enough—just 105% of the fecundity threshold—at the end of 2023 that it is entirely possible, depending on the number of new fish recruited into the stock, that a new stock assessment might find that Atlantic menhaden are overfished today.

Last October, the Management Board had a chance to remedy that situation, as they sat down to debate the total allowable catch for the years 2026-2028.  The existing TAC, for the years 2023-2025, was 233,550 metric tons; in order to have a bare 50% probability of keeping the fishing mortality rate at or below the target level, the total allowable catch would have to be reduced to no more than 108,500 metric tons, a reduction of nearly 54%.

The menhaden fishing industry, and particularly the “reduction fishery,” which purse seines menhaden by the ton and “reduces” the fish to fish oil and fish meal, was naturally opposed to such a large reduction, particularly if it was made in a single year.  Some New England states were also opposed to reductions, not because they had lucrative menhaden fisheries, but because their lobstermen needed the menhaden for trap bait, since the traditional bait, Atlantic herring, became overfished and are far less available than they once were.

So instead of taking any sort of meaningful action, the Management Board engaged in a sort of sleight of hand that made it appear that they were doing something, when in fact they did nothing at all to lower menhaden landings (although they did keep landings from increasing):  They lowered the total allowable catch for 2026 by 20%, to 186,840 metric tons.  However, the menhaden fishery wasn’t catching its entire quota, but instead were falling short by…about 20%, so the reduction in TAC, while looking substantive on paper, did nothing to cut menhaden landings in the real world. As Robert LaFrance, proxy for Connecticut’s Governor’s Appointee, commented,

“I think we have to recognize that when we set the TAC at 233,000 metric tons…[w]e did not know what we know now about the natural mortality of the species.  The fact that we’re looking at a 20% reduction from that number seems to me to be, it’s almost like a false compromise…”

Despite the near-meaningless impact of the motion, it passed on a vote of 16 to 2.

The only good thing was that, instead of setting the total allowable catch for 2026 through 2028, as originally intended, the Management Board only set the TAC for a single year, 2026, and will revisit future years when they meet again.

That has created a situation ripe for clashes between the menhaden industry and those trying to rein in menhaden harvest.

As I’ve noted before, menhaden are a “political fish” where emotional arguments have taken over the management debate, and largely drowned out the rational voice of science.  Menhaden have often been in the news this year, as advocates for reduced landings and advocates for the menhaden industry throw accusations back and forth.   Lyrics from that old Buffalo Springfield song, “For What It’s Worth, are probably applicable:”

“What a field day for the heat

A thousand people in the street

Singing songs and a-carrying signs

Mostly say, ‘Hooray for our side.’”

As the August and October Management Board meetings draw closer, the volume of the rhetoric has been going up.

That’s not necessarily bad, as anecdotal reports indicate a lack of menhaden along much of the East Coast, something that is somewhat predictable when the fishing mortality rate is well above target and biomass—or in menhaden’s case, fecundity—is dangerously close to dropping below the threshold.

But what we’re seeing, particularly from the folks who purport to support menhaden conservation, are videos and press releases intended to evoke emotion rather than rational thought and, from some with an economic axe to grind, self-serving proposals with public relations appeal, which are not, at their heart, really conservation-oriented proposals at all.

For when we talk about conservation, we need to keep two basic precepts in mind:

1)      If you want to have more fish, you need to kill fewer of them, and

2)     It doesn’t matter to the fish who kills it; either way, it’s still dead.

Many of the people involved in the menhaden debate seem to be missing those points, and thus make it more difficult to adopt management measures that everyone—most particularly the menhaden—can live with.

I was reminded of that the other day when I happened across a video released by the Theodore Roosevelt Conservation Partnership, titled “A Tiny Atlantic Fish—A Major Controversy.”  The interesting thing about the video is that it hardly mentioned conservation at all—something that seems somewhat startling in a video released by an outfit calling itself the “Theodore Roosevelt Conservation Partnership.”

Instead, after a few cameo appearances from anglers and fishing guides who merely provided their views on how important menhaden were to coastal ecosystems and to fishing success, the only mention of conservation occurred when Jaclyn Lunaas, a Theodore Roosevelt Conservation Partnership Employee responsible for the organization’s forage fish program, noted that the ASMFC was responsible for menhaden management, and that

“In order to have ecological and economic resilience across the entire East Coast, we need fair allocation of this public resource between states…Right now, the Atlantic States Marine Fisheries Commission is going to be debating two decisions:  First, whether or not to reduce the total amount of menhaden that can be caught coastwide, and second, how to reallocate how that catch is divided between Atlantic states.”

There was almost no further messaging on the need to reduce the total allowable catch, and no mention of the need to get fishing mortality down to the target level.  Instead, the majority of the video was all about allocation, with Ms. Lunaas continuing,

“We just want a fair share of a public resource.  This resource keeps ecosystems healthy, boats running, businesses open, and communities out on the water.  We need a reallocation of menhaden quota in order to stabilize bait supply, particularly in northern states.  This would lower costs for lobstermen and charter captains, and it would keep economic value in coastal communities, while a modest reduction in overall catch would ensure that the resource remains healthy for everyone coastwide and long-term.”

That’s a somewhat strange position for any group that holds itself out as a conservation organization to take.  After all, if the concern is reducing menhaden landings—as it should be—it makes no difference whether those landings take place in Virginia, which is currently allocated 75% of the landings, or in Delaware, South Carolina, Georgia, or Florida, which are each allocated roughly 0.25%. 

Wherever a menhaden is landed, it is killed, and will make no further contribution to the growth or fecundity of the stock.

And a broad ireallocation doesn’t even make much sense from a practical standpoint.  If we look at the ASMFC’s review of the 2024 menhaden fishery—the last such annual review available—we find that one state, Massachusetts, exceeded its base menhaden quota by about 20% (although it made up the overage by receiving quota transfers from other states), and Maine came close to harvesting its quota, but the other states’ landings fell far short.  At best, a couple states harvested less than half of their quotas, New York landed about 25%, but the other states landed far less—anywhere from about 3% in Connecticut to 19% in North Carolina.

So, in the case of most states, it’s hard to understand how reallocation is going to do more to keep “ecosystems healthy, boats running, shops open, and communities out on the water,” when those states aren’t coming close to landing the allocations that they already have.

Of course, if the annual catch limit was cut significantly, more states would come close to landing their full quotas, but even a 50% reduction would only have a material impact on three states—Maine, Massachusetts, and Virginia—with the other states’ landings, based on landings in 2024, still falling at or below their quotas.  And TRCP has already demonstrated that it couldn’t care less whether Virginia takes a cut.

So what would seem to make sense, from a strategic and a conservation standpoint, would be to reallocate some of Virginia’s menhaden to the northern New England states that need lobster bait, in exchange for their support of an annual catch limit—which might have to be phased in over two or three years—that would have a reasonable chance of reducing fishing mortality to the target level.

But a general reallocation to other states, which are already falling far short of filling their quotas, makes no sense at all.

Still, when it comes to the Theordore Roosevelt Conservation Partnership video, parhaps the most startling thing is that it calls for nothing more than a “modest reduction” in menhaden landings.  Since it’s hard to imagine anyone calling a near-50% reduction “modest,” it would seem that the TRCP isn’t all that concerned with real conservation—that is, getting landings down to the point where they’d have a 50% probability of keeping fishing mortality at or below target—and far more concerned with a largely unnecessary allocation.

Again, that seems to be a somewhat surprising stance for a supposed conservation organization to take.

But then, when we look a little deeper into the video, things become a little more clear; the reallocation effort is less an attempt to conserve menhaden, as it is a way to cripple the menhaden reduction fishery, long a boogeyman for many of the menhaden advocates, which is based in Virginia and would take a significant economic hit if Virginia’s state quota was cut. 

The buzzwords are all there.

The narrator talks about the Virginia quota being

“caught by a single industrial company,”

while the video streams pictures of reduction boats setting their seines, and multiple vessels returning to port, as if the menhaden would be somehow less dead if they were caught by anyone else.

The narrator goes on to say,

“So even though it’s a coastwide fishery, most of the pressure is happening in one place, and that’s largely coming from a single industrial organization.  Whether you’re a recreational angler, a fishing guide, charter captain, or tackle shop owner, it’s one industrial company that’s taking a significant portion of the most important fish that’s the key and the backbone to our fishery and all the small businesses that rely on it.”

The narrator can’t seem to say “industrial” too many times; he knows that it evokes a knee-jerk reaction.

But the question is why a purported conservation organization would take such a position, given that reallocation would have no impact on menhaden populations.

Part of the reason might be that reallocation would make it easier to convince Maine and Massachusetts to vote for a landings reduction, but the Theodore Roosevelt Conservation Partnership had already stated that it supported a “modest” reduction, so scraping up votes probably wasn’t a major motivation.

A more likely answer can probably be found in another TRCP press release, which announced that

“$1.5 Billion in Annual Economic Output Generated from Recreational Angling That Involves Atlantic Menhaden as Bait,”

and begins

“As the Atlantic States Marine Fisheries Commission prepares to set a new menhaden catch limit and considers whether to initiate a reallocation process among the states, a new study shows that recreational anglers rely on this keystone species as one of the most important baitfish.”

Once again, it’s hard to understand why the Theodore Roosevelt Conservation Partnership would be making conservation policy decisions based on economic considerations in the recreational fishery, until one realizes that the “new study” mentioned in the press release was not commissioned by the TRCP, but by the American Sportfishing Association, the big fishing tackle trade organization, which is very concerned with maintaining the recreational fishing industry’s income stream, and which might logically be concerned about landings reductions making menhaden less available, and about local shortages of menhaden leading to anglers fishing less and the tackle industry selling less stuff.

And the Theodore Roosevelt Conservation Partnership tends to march hand-in-hand with the American Sportfishing Association on fisheries issues, with the TRCP consistently echoing the ASA’s economic concerns (e.g., the Theodore Roosevelt Conservation Partnership’s October 2025 opposition to a reduction in striped bass landings, in part because of potential “unwarranted economic disruption,” in a letter that seems to pirate its themes from the comments submitted by the ASA).

The economic study took the broadest possible measure of economic impact, economic output, which an economist quoted in the press release described as

“the full spectrum of spending that occurs for fishing trips where menhaden are used as bait, from direct purchases of equipment, food, fuel, and the many other items needed for a day of fishing, to the downstream effects that spending has on retailers, manufacturers, and countless other businesses,”

while the study itself advised that

“This report does not suggest that these fishing trips and the associated spending would not occur without the availability of menhaden; some of the anglers who currently fish in saltwater using menhaden might instead use different saltwater baits, target different saltwater fish or decide to go freshwater fishing.”

So, while I wouldn’t be shocked to hear some of the less responsible members of the advocacy community start putting out press releases screaming something like, “Coastal communities to lose $1.5 billion from menhaden crash!” which would be pretty much in line with the sort of thing that they’ve been putting out already, the truth is, as usually the case, less extreme.

Menhaden are an important forage fish.  Menhaden are important to anglers, in part because they make fishing easy—menhaden schools typically concentrate predators, and tossing a live menhaden into the schools is often an easy way to entice a bite—and in part because they are a popular bait and chum.  And tackle shops sell quite a bit of menhaden and menhaden-derived products. 

But—and pay close attention to this one—even with landings cut in half and no reallocations of any kind—the bait fishery in all but a couple of New England states would be largely unaffected, and still able to supply anglers’ needs, because those states are not coming close to catching its quota today.

And to those who might want to argue that some states aren’t catching their menhaden quota because the fish aren’t present in their waters, I will make the obvious reply that reallocating fish that aren’t there isn’t going to increase local landings. 

However, making more than “modest” cuts to coastwide landings very likely will restore menhaden abundance.

I hate to use an already overused cliché, but reallocating menhaden among the states is much like rearranging the deck chairs on the Titanic.  Neither action addresses the core problem.

If you wanted the Titanic to keep floating, you would have needed to reduce the amount of water inside the hull, and put it back in the ocean.

And if we want more menhaden, whether to supply forage to predators, supply more bait for anglers and lobstermen, or provide easier fishing for guides, charter captains and recreational fishermen alike, we need to reduce the amount of menhaden ending up dead on boats of various sizes, and keep more in the ocean.

Changing who kills the menhaden won’t make a difference, because they’ll still be dead.

Changing where the menhaden are killed won’t make a difference, because they’ll still be killed.

The only way to increase menhaden numbers, which is what legitimate conservation organizations surely want to do, is to reduce landings, and kill fewer fish. 

The sooner all of the various advocacy groups accept that basic truth, and start working together to get fishing mortality back to its target level, the sooner something meaningful might get done.

 

 

 

 

 

 

 

 

 

 

 

 

ACCIDENTAL REEFS

 

There isn’t much hard bottom in the mid-Atlantic Bight.  According to one study of the habitat requirements of black sea bass,

“The mid-Atlantic Bight stretches from North Carolina to Massachusetts…The nearshore continental shelf is composed primarily of unconsolidated sediments consisting of sand, silt, shells, and small gravels.  Bedforms consist mainly of sand waves, small hills, and gullies created by ancient riverbeds, with rare outcroppings of rock, consolidated sand, and clay.”

That doesn’t leave much to attract and hold structure-oriented fish such as black sea bass, nor to help fishermen find concentrations of such species.  As a result, fishermen tend to focus on various forms of man-made structure.

For decades, many of the states have conducted artificial reef programs, where they sink various items in hopes of creating structure that will hold sessile life forms such as mussels and sea anemones, which in turn create habitat used by crabs, other crustaceans, and bait fish, which then attract and hold recreationally important food and sport fish.

Years ago, many such reefs were created by filling bundles of tires with cement and dropping them in designated areas, or dumping chunks of broken up concrete or unwanted steel from demolished buildings, but that didn’t work all that well, with the former often breaking up and washing ashore during storms and the latter getting covered over with shifting sand and losing its utility.

But after a while, the states began to understand what they needed to do, and started sinking unwanted steel vessels of various sorts (after first scrubbing out any oil, grease, or other potential pollutants), surplus armored military vehicles, train cars, pieces of demolished bridges, and even “reef balls” and other items purpose-built to create artificial reefs.

There is no question that fishermen love artificial reefs, as they attract and concentrate fish and make them easier to find and catch.  Whether the artificial reefs also benefit the fish by creating additional habitat, particularly in regions where hard-bottom habitat is scarce, is a very different question, and one that remains open for debate.  As one scientific paper noted,

“Productivity in real terms in relation to artificial reef deployment relies on the assumption that artificial reefs provide additional critical habitat which increases the environmental carrying capacity and thereby the abundance and biomass of reef biota.  The reef potentially provides substrata for benthic fauna and, thereby, additional food and increased feeding efficiency; shelter from predation or tidal currents; a recruitment habitat for individuals that would otherwise be lost from the population; a reduction of harvesting pressure on natural reefs.  It can also serve to be purely an aggregating device, whereby the behavioral preferences of fish result in aggregation on and around artificial reefs, without any increase in biomass.  [citations omitted]”

The answer to that question may depend on the species of fish involved, the availability of suitable alternative habitat, the design of the reef itself, and other factors.  However, experts believe that, at least in some cases, artificial reefs do provide benefits such as additional spawning habitat.

Then, there are the unintentionally created artificial reefs, which take the form of shipwrecks.  Such wrecks abound off some areas, which were known for treacherous navigation conditions—particularly during the years before electronic navigation aids became commonplace—or were places where heavy shipping traffic created a target-rich environment for German U-boats during the Second, and to a much lesser extent, the First, World War.  The approaches to New York Harbor, ranging from eastern Long Island to southern New Jersey, earned the name “Wreck Valley” from scuba divers, for the hundreds of wrecks lining the bottom.

The fish are attracted to wrecks as much as, or more than, they are attracted to intentionally-created artificial reefs.

And then there are the “accidental” reefs—man-made structures that were intended for other purposes, but ended up attracting a plethora of fish, as well.  The oil rigs in the Gulf of Mexico are a well-known example, and need no further discussion here.  Instead, I’ll concentrate on a relatively new phenomenon, the attraction that recently-constructed wind farms hold for various species of fish.

Wind farm development off the East Coast of the United States has been controversial, for multiple reasons.  Real estate and resort interests consider them eyesores.  They can block commercial fishermen from using some gear types in traditional fishing grounds.  There have been allegations, so far completely unsupported by any kind of biological evidence, that they lead to cetacean deaths.  And they have become a sort of political litmus test, damned at one end of the political spectrum and praised at the other.

There has been concern that wind farms might harm fishing, with some real-world evidence that they may have negative impacts on fishing efforts during the construction process, although not once the structures have been built.

Otherwise, wind farms seem to have had little to no adverse impact on East Coast fish populations, although they are new enough that not too much post-construction research has been concluded and published.

One study that has been published, “Fish distribution in three dimensions around the Block Island Wind Farm as observed with conventional and volumetric echosounders,” which appeared in the October 31, 2023 issue of Marine and Coastal Fisheries, seemed to suggest that wind farm structures have about the same impact on fish as do intentionally created artificial reefs.  That article concluded,

“We observed enhanced levels of fish abundance within 200m of wind turbined at the [Block Island Wind Farm] during a 4-day survey in August 2023.  However, these higher levels were similar to abundance further away (i.e., hundreds to thousands of meters).  These observations suggest that the turbines are acting as aggregators at scales of tens of meters but that the effect tends to be limited at broader scales.  There was an indication that the turbines influenced (1) vertical distribution, with the acoustic center of mass being deeper within proximity to turbines, and (2) aggregative behavior, with the fish being more loosely distributed within proximity to turbines.  Our survey was conducted five years after completion of the BIWF, and our results may be indicative of established wind areas, where the fauna may have adapted to the presence of the turbines.  However, the BIWF consists of only 5 turbines, so it may not be large enough to affect broadscale distribution or population level changes.  In addition, other features of the habitat, such as wrecks, rocky reefs, or physical and biological oceanographic attributes that we did not measure, could affect distributions independently of the BIWF.”

Another, slightly earlier paper, “Demersal fish and invertebrate catches relative to construction and operation of North America’s first offshore wind farm,” published in the March 29, 2022 issue of the ICES Journal of Marine Science, which reported the findings of a more elaborately structured and longer-term trawl survey, had similar findings.

“Demersal fish and invertebrate [catch per unit effort] varied spatially between the [area of potential effect of the wind farm] and two reference areas and temporally between baseline [prior to wind farm operation] and operation time periods; however interactions indicating reduced CPUE at the [area of potential effect] were not apparent.  The CPUE of several fish species were higher near the wind farm during the operation time period relative to the reference areas, providing evidence for an artificial reef effect.  For example, black sea bass CPUEs were statistically higher during the operation period near the wind farm relative to a reference area, reflecting the structure-oriented behavior of this species.  Black sea bass were observed near the BIWF turbine foundations in diver-based photographic transects, are targeted near the turbine foundations by recreational fishermen, and increased nearly ten-fold in CPUE in trawls conducted at the [area of potential effect] over the reference areas in the first two years of wind farm operation…Atlantic cod CPUE also were higher near the wind farm after turbine installation.  Cod are targeted by recreational fishermen at BIWF, as they use underwater structure as refuge and foraging habitat…  [references omitted]”

The same study found that the wind farm seemed to have no impact, positive or negative, on Atlantic herring, scup, or butterfish, might have had a negative impact on two species of skate, little skate and winter skate, although that was far from certain, and might have had a positive impact on the abundance of spiny dogfish, although that, too, was not completely clear.

Anecdotal evidence regarding the impact of wind farms on fish has been generally positive.  One study, “Anglers’ support for an offshore wind farm:  Fishing effects or clean energy symbolism,” published in the May 2023 issue of Marine Policy, found that

“a quantitative survey of 199 anglers from Rhode Island, Connecticut, New York, and Massachusetts moderate support for the [Block Island] wind farm.  Experience fishing at the wind farm is associated with more positive beliefs regarding the development’s effects on catch-related aspects of fishing…”

While I’ve never fished the Block Island wind farm, Rhode Island anglers that I’ve spoken with have only good things to say about fishing around the site, and at least one well-regarded Montauk party boat regularly makes the long trip to the wind farm, rather than stay in local waters, when seeking black sea bass and big fluke, so I have to believe that the wind farm has a positive impact on fishing.

But what I find truly remarkable is how quickly fish will respond to the turbine installation.  Last year, construction began on a big wind farm located roughly south of Long Island’s Jones Inlet.  It only took about two weeks for black sea bass to move onto the structures, and maybe a month or so before local party boats began fishing within the wind farm, finding the area more productive than the scattered wrecks and artificial reefs that they had been fishing on before.

So it’s pretty clear that the wind farms really have turned into extensive, accidental artificial reefs that can hold real benefits for anglers.

Unfortunately, it appears that the current administration is doing all it can to discourage further wind farm development, and given how the United States has now tried to weasel out of signed agreements to develop new projects and reneged on licenses previously issued, it’s not at all clear that any corporation will trust the U.S. enough to enter into new agreements, even when this administration is gone.

But those anglers who live in areas with access to existing projects will still be able to enjoy what promise to be productive new fishing grounds well into the foreseeable future.

 

 

 

 

SENSIBLE TALK ABOUT SOUTH ATLANTIC RED SNAPPER

 

There are a lot of words that one might used to describe the current debate over South Atlantic red snapper, but “moderate” wouldn’t be the first that comes to mind.

Jeff Angers, the president of the Center for Sportfishing Policy, a umbrella group representing the fishing tackle and boating industries, wrote that

“red snapper has been managed by federal overlord bureaucrats.”

A feature article in the online publication Water World Wire said that

“For recreational anglers in the South Atlantic, red snapper management has long felt disconnected from reality.”

And another article, this one in the online publication Wired2Fish, told readers that

“offshore anglers in the South Atlantic have been completely handcuffed from targeting and keeping red snapper for years.”

That’s somewhat provocative language, and all three articles, while critical of federal red snapper management, were somewhat shy on all the details, particularly those that don’t necessarily support their underlying premise.

Of course, it’s hard to blame writers from using somewhat inflammatory language when public officials are even worse.  For example, the executive director of the Florida Fish and Wildlife Conservation Commission wrote to Commerce Secretary Howard Lutnick to support a scheme to do an end run around the Magnuson-Stevens Fishery Conservation and Management Act, so that Florida—and other South Atlantic—anglers could exceed the red snapper annual catch limit with complete impunity.  In his letter, he used language like

“we want to reinforce our appreciation for your unswerving commitment to rein in bureaucracy and return the power of fisheries managers to the states where it belongs…based on precedent, career NOAA staff will inevitably create a bureaucratic blockade at the behest of status-quo defending adversarial interests to prevent Florida’s EFP from going into effect in May 2026…

“Based on Florida’s experience in seeking assignment of state management authority in the Gulf of America, much of NOAA’s response appears to potentially delay action under the guise of ‘data’ collection—the same tactics that led Congress to force NOAA to accept and approve state EFPs in the Gulf of America given the weaponization of NOAA under President Obama…  [emphasis in original]”

It was a style that combined unhinged MAGA phrasing with the bold print and underlines of a schoolgirl writing her bestie a note about her latest crush.  Yet it was used in what was supposed to be professional correspondence.

And like an adolescent schoolgirl throwing a hissy fit when she didn’t get her own way, the Florida Fish and Wildlife Conservation Commission responded to a federal judge issuing a temporary injunction prohibiting anglers in Florida and the other South Atlantic states from fishing for red snapper pursuant to the exempted fishing permits by issuing a petulant statement saying that

“a rogue federal judge sided with activists”

by doing his job and interpreting the law to the best of his ability.

Of course, that language might be more understandable when one considers the language used by Florida Governor Ron DeSantis with respect to the court’s order:

“How disrespectful is it to rule when people have already made plans to come down and to do this?...I just think that it’s really disrespectful to pull the rug out from under them, especially when there’s so many fish in the sea…

“You know who brought the charge were the commercial fishermen.  They don’t want recreational anglers to be able to go out and fish.  They want it all for themselves.”

Apparently, DeSantis never considered that what was really disrespectful was pressuring NOAA Fisheries to issue the exempted fisheries permits quickly, so the season could open for Memorial Day weekend, knowing that there was a very good chance that issuing such permits was very probably illegal and that various organizations were almost certain to sue. 

That what was really disrespectful was leading Florida anglers and charter boats to believe that the season was going to open on Memorial Day weekend, knowing that the season would certainly be challenged, and then calling the judge “disrespectful” for doing his job.

But that’s the sort of language that has characterized the South Atlantic red snapper debate, and there is little reason to believe that is going to change.

Thus, it was refreshing to have a post on the subject come across my Facebook feed, that actually try to explain both sides of the issue in a rational manner.  It was written by someone named Justin Hawkins who, like me, regularly comments on fisheries issues.  In his initial post on the topic, Hawkins observed,

“…For years, recreational fishermen have argued that federal regulations dramatically underestimate the number of red snapper swimming offshore.  Many charter captains report seeing more fish than ever, describing reefs covered in red snapper so thick that targeting other species can be difficult…

“…NOAA Fisheries approved experimental, state-managed recreational seasons through a series of exempted fishing permits (EFPs).  The permits would have allowed Florida, Georgia, South Carolina, and North Carolina to manage longer recreational seasons while gathering new harvest data…

“For anglers, it felt like a long-overdue victory…

“Commercial fishing organizations challenged the permits in federal court, arguing that the expanded seasons could lead to unsustainable harvests.  Conservation organizations, including Ocean Conservancy and Earthjustice, joined the fight, warning that the expanded seasons could violate federal fisheries law and jeopardize decades of rebuilding efforts.

“The legal challenge centered on a fundamental question:

“How many red snapper can anglers catch before the stock begins declining again?

“Conservation groups argue that the answer is far fewer than many fishermen believe.”

And that is the South Atlantic red snapper fight in a nutshell, stripped of the hyperbole, stripped of the animus, stripped of the political posturing.  Anglers are seeing a lot of red snapper, and think that current management measures are too strict.  Conservation groups, along with the commercial fishermen who brought the action, think that liberalizing the regulations, without supporting data, could do real harm to the red snapper stock.

The commercial fishermen, the conservation groups, and the anglers (but not necessarily the industry-connected organizations that purport to represent them) are all acting in good faith, based on what they believe the situation to be.  The fact that they disagree is no justification for the sort of language and name calling that is coming—one might notice—largely from politicians and folks with a pecuniary iron in the fire.

As Hawkins correctly notes,

“The result is a fishery now trapped between competing visions of conservation, economics, and access.

“And neither side appears willing to back down.”

If that was all Hawkins wrote, it would have been a worthwhile piece that could allow people, who weren’t familiar with all the details of the issue, to understand what is going on.  But he wrote one more, follow-up comment, in which he did a pretty good job of setting out the need for effective fisheries management, and the obstacles that stand in its way. 

He notes that

“Everyone agrees on one thing.

“Healthy fish populations require responsible management.

“Yet one of the most common complaints heard from recreational anglers and charter captains today has little to do with conservation goals themselves.  Instead, it centers on how those goals are implemented.

“When state and federal regulators fail to align, fishermen often find themselves dealing with confusion, uncertainty, and economic hardship.”

He then raises six issues that he feels should be considered as managers try to remedy the problem.  I agree with some, and disagree with others.  But one point he makes is unquestionably true:

“The debate is often portrayed as a conflict between conservation and fishing opportunity.

“In reality, most fishermen support sustainable fisheries management.

“What they want is consistency.

“They want regulations that are scientifically justified, clearly communicated, and implemented in a way that allows businesses and anglers to plan ahead.

“Conservation objectives and public access are not mutually exclusive.”

Applying those thoughts to the South Atlantic red snapper debate, it becomes obvious that much of the problem, much of the controversy, and much of the hardship that occurred in the last two months could have been avoided had state politicians and fisheries managers not pressured NOAA Fisheries to issue the EFPs quickly, and had NOAA Fisheries not acted so hastily in issuing the EFPs.

If NOAA Fisheries had taken the time to observe its own regulations—for example, if it had .required the states to estimate the number of red snapper that would be landed under the EFPs and had not allowed the states to refuse to provide such information—and if NOAA Fisheries had responded in good faith to stakeholder concerns about overfishing, it is likely that the EFPs would not have been issued as soon as they were.  There is a very good chance tht they wouldn’t have been issued at all, since the states’ estimates of red snapper landings, and NOAA Fisheries response to the stakeholder concerns, would almost certainly have indicated that overfishing would occur, and that issuing the EFPs would thus be illegal.

Instead, NOAA Fisheries’ actions created false expectations among anglers, charter boat captains, and the rest of the recreational fishing community, which expectations were shattered when the judge decided that the EFPs were not validly issued.

The situation was made worse by the bombastic language used by both industry advocates and state politicians, which might have played on anglers’ emotions, but conveyed few of the critical facts that led to the temporary injunction.

Thus, it was good to know that Justin Hawkins, at least, could describe the conflict in moderate language, and argue for a solution that would benefit all concerned. 

I doubt that the people who make the decisions will listen, but it was good to read, even so.

FISHERIES ADVOCACY: IF YOU HAVE TO DISTORT THE TRUTH...

 

Forage fish—the small, low trophic level fish and, in some cases, crustaceans and cephalopods—that serve as food for larger predators, are a critical part of marine ecosystems.  Unfortunately, many important forage fish, including Atlantic and Gulf menhaden, Atlantic herring, and Atlantic mackerel, have become the targets of high-volume, low-value fisheries that remove too many fish from the water, depleting forage fish populations and having potentially negative impacts on marine predators and recreational and commercial fisheries.

Other forage fish, such as alewives and blueback herring (collectively, “river herring”), American shad, and hickory shad, are killed as bycatch in other fisheries, collateral damage in mid-water trawls and other fisheries directed at other forage fish species.

While a few biologists have argued that forage fish fisheries create no threat to predator populations, most notably Dr. Ray Hilborn, et al., whose 2017 paper, “When does fishing forage species affect their predators?” argued that natural variations in forage fish populations have much more impact on forage fish abundance than do directed fisheries, the consensus is that directed forage fish fisheries need to be carefully managed, in order to prevent harm to marine predators.

Thus, the Atlantic States Marine Fisheries Commission’s Amendment 3 to the Interstate Fishery Management Plan for Atlantic Menhaden, adopted in 2017, established the use of “ecosystem” reference points, rather than the traditional single-species reference points, to determine the health of the menhaden stock, acknowledging the importance of the menhaden’s role as a forage species.

In the same vein, also in 2017, the Mid-Atlantic Fishery Management Council adopted its Unmanaged Forage Omnibus Amendment, which, according to the Council,

“prohibits the development of new and expansion of existing directed commercial fisheries on unmanaged forage species in mid-Atlantic federal waters until the Council has had an adequate opportunity to assess the scientific information relating to any new or expanded directed fisheries and consider potential impacts to existing fisheries, fishing communities, and the marine ecosystems.”

The Omnibus Amendment was intended to protect important forage fish that don’t have the “celebrity” status of menhaden or river herring, forage fish that most people don’t think about, and many people haven’t even heard of, such as argentines, greeneyes, halfbeaks, lanternfish, pearlsides, sand lances (“sand eels”), cusk-eels, Atlantic saury, krill, etc.

Because forage fish are unquestionably important, it didn’t come as a particular surprise when I learned of the formation of a new organization calling itself “The Forage Fish Campaign.”  According to its web page,

“The Forage Fish Campaign is a united coalition of captains, business owners, recreational anglers, and small-boat commercial fishermen.

“We’re concerned about the health of our coastal communities—and we’re fighting back.

“We’re engaging at the local, state, and federal levels to address the root of the problem:  not our hard-working Americans—but industrial exploitation of our shared resources.”

That all sounds fine.  There is a list of folks who have signed up as members, some of whom I know, many of whom I don’t.  But I tend to get very nervous when I hear the word “campaign,” and here’s why:  I believe that fisheries management ought to be based on the best available data.  Sometimes that data isn’t available, and in such case, it’s entirely appropriate to worst-case the uncertainties, and take a more precautionary approach, but to the extent that the data is there, it ought to drive the decisions.

But that’s not exactly how “campaigns” function, because data and statistics are boring.  Instead, campaigns are all about public relations, about catching the public’s attention, appealing to their emotions in an attempt to gain their support.  And often, when people do that, the truth can be sacrificed for a more appealing story line.

And that’s what seems to have happened here.

I had heard of The Forage Fish Campaign, but wasn’t paying too much attention to it, when one of its videos happened to come across my Facebook feed.  I let it play with the sound off, and noticed some graphics that just didn’t ring true.  Like the proclamation, etched in stark black and white, that

“OVERHARVESTING OF FORAGE SPECIES HAS COLLAPSED COMMERCIAL FISHERIES COAST-WIDE”

Really?  Which fisheries would those be?  And what data did they have to support that claim of collapse?

So, the next time, I watched the video with the sound on, and heard the narrator, a New York charter boat captain and commercial fisherman, say,

“Used to go out in the fall, from deep in the heart of Raritan Bay, OK, towards Keyport, all the ways to Fire Island, there was bunker.  Like 30 miles of bunker.  Where are they today?  I think it’s pretty obvious to say that the lion’s share of the bunker are being harvested by the bunker boats.  The scale of their operation is enormous.  The impact they’ve had is unbelievable.  You could just talk to any fisherman, what’ll they say: “Oh, fishin’s terrible.  Oh, there’s no bait.  No bait!”

That might sound heartfelt, and some might even find it convincing, but it is not exactly the sort of hard science that should be underlying fisheries management decisions, yet when paired with video of a menhaden reduction boat setting nets, it probably is effective “campaign” material. 

(It’s interesting to note that the same fisherman posted, independently and on his own Facebook page, a photo of himself shaking President Trump’s hand, overlaid with the text

“What Happened to the bunker executive order you promised me?”

which was introduced with the legend,

“At your request you asked me to meet you at your golf course.  You assured me come Monday morning you would have in place an Executive Order to remedy the slaughter unchecked.  Well its been quite sometime Sir with all due respect we need your help.  Now I understand you have a lot on your plate…

“Let’s revisit this.  Lunch is on me.”

So it’s clear that, even outside The Forage Fish Campaign, this particular fisherman is really trying to shut down the menhaden reduction fishery.)

But getting back to the Campaign, the rest of the video was a bit more disturbing than the start.

After all, the beginning merely reflected one fisherman’s honest belief that the menhaden reduction fishery had a negative impact on the quality of fishing in his region.  But some of the rest seemed misleading, although whether through intent or mere negligence and sloppy research isn’t clear.

The problems come in the form of another graphic, this one showing a pair of mid-water trawlers pulling a net.  Superimposed over the image of the net are the images of seven species of forage fish, all but menhaden bearing a designation of either “depleted” or “overfished”—which is almost true, although describing Atlantic mackerel as “overfished” is incorrect; the stock is still rebuilding, but the population has already risen above the threshold that denotes an overfished stock.

The biggest problems arise on the right side of the screen, where the images of 16 fish species, all now or formerly important to the commercial and/or recreational fishery, are shown, also overprinted with “depleted” and “overfished” designations, below the image of the two pair trawlers.  The narrator says,

“A net is indiscriminate, so if they eliminate the baitfish from either entering the bay or on our fishing grounds, the fish aren’t going to come in.  They have nothing to eat.”

The implication of the graphic and narration, when heard/seen in concert, is that a lack of baitfish caused the various targeted food and recreational species to become overfished, even though that was never explicitly stated. 

In fact, there is no documented, statistical connection between a shortage of forage fish and the decline of any of the species listed on the graphic.  Most of the listed species, in fact, are themselves victims of overharvest.

Some of them don’t even eat fish on a regular basis, making them pretty immune to a forage fish shortage, even if one occurred.

But they’re listed on the graphic anyway.

Consider the two sturgeons.  The National Marine Fisheries Service tells us that

“Atlantic sturgeon were once found in great abundance, but their populations have declined greatly due to overharvesting and habitat loss.  Atlantic sturgeon were prized for their eggs, which were valued as high-quality caviar.  During the late 1800s, people flocked to the eastern United States in search of caviar riches from the sturgeon fishery, known as the ‘Black Gold Rush.’  By the beginning of the 1900s, sturgeon populations had declined drastically…  [emphasis added]”

There is no reason to believe that a decline in forage fish abundance contributed to the Atlantic sturgeon’s decline at all—not to mention that pair trawlers and menhaden reduction boats didn’t even exist at the start of the 20^th century, when the Atlantic sturgeon population had already crashed. 

NMFS also tells us that

“historical landings records differentiate between Atlantic sturgeon and the smaller shortnose sturgeon,”

making it likely that the reasons behind the shortnose sturgeon’s demise were similar to those leading to the Atlantic sturgeon’s decline. 

And anyway,

“Atlantic sturgeon are bottom feeders.  They typically consume invertebrates such as crustaceans, worms, and mollusks, and bottom-dwelling fish, such as sand lance,”

none of which are targeted by mid-water trawls.  Shortnose sturgeon feed almost entirely on in vertebrates.

So it’s pretty misleading to include either species in a video talking about mid-water trawls and forage fish depletion.

And then there’s the “white flounder,” which seems to be a case of a public relations typo, because despite doing a bit of research, I couldn’t come up with any creature bearing that name; what the graphic depicts appears to be a winter flounder, which is not overfished, although it does have severe recruitment issues.  Winter flounder also have little association with forage fish, as they are small fish themselves, and their mouths are so tiny, optimized for feeding on worms, tiny shrimp, and the like, that it would be difficult to fit the tip of an adult’s pinky finger between a fish’s forced-open lips.

Summer flounder, of “fluke,” aren’t overfished either.  The last stock assessment found spawning stock biomass at 83% of target, well above the threshold denoting an overfished stock.  Summer flounder are aggressive fish-eaters, but their lower abundance is largely attributable to more than a decade of below-average recruitment, although slightly above-average recruitment in 2023 and 2024 may bode well for the future.  There is no indication that a shortage of forage is impacting the population.

Thus, including either flounder in the video is also misleading.

So is including white marlin, blue marlin, dusky, and shortfin mako sharks.  All of them are badly overfished, but a shortage of forage fish have nothing to do with that.  Atlantic blue marlin are victims of pelagic longlines, as well as small-scale recreational and commercial fisheries.  White marlin are also victims of pelagic longline bycatch, as are dusky sharks and shortfin makos.  All are direct victims of fishing activities, not indirect victims of forage depletion.

Similarly, sandbar sharks are considered

“very vulnerable to overfishing,”

and, as the State of New York noted,

“The sandbar shark was historically taken in commercial and recreational fisheries along the Southern Atlantic Coast of the U.S. and in the Gulf of Mexico, which expanded rapidly in the last 20 years and led to significant population declines.”

Once again, there is no suggestion that the population decline of two decades ago was due to depleted forage fish populations, so there was no reason for them to be mentioned in a video talking about forage fish management.

It seems that a trend is emerging here.  Atlantic bluefin tuna are not only not considered overfished, contrary to the  video’s assertions, but the population is doing well enough that the International Commission for the Conservation of Atlantic Tunas increased the western Atlantic quota when it met last November.  Far from suffering from a lack of forage fish, weakfish are depleted because they have become a forage fish, with natural mortality levels extremely high, very possibly because of increased predation by bottlenose dolphin.  Striped bass are overfished for the simple reason that people have been killing too many, with the fishing mortality rate exceeding the overfishing threshold in 1996, 2004-2006, and 2010-2017; add that level of fishing mortality to the worst seven years of recruitment ever recorded in 2019-2025, and there’s no need to try to blame forage fish shortages for the striped bass’ overfished state—they’re overfished because of overfishing.  Finally, there’s the Atlantic halibut; it’s been overfished since the early 1900s, well before the “industrial” fisheries cited in The Forage Fish Campaign’s video began to target forage fish.

I could go on, but I think my point is made.

The Forage Fish Campaign has implied that pair trawling and other high-volume fisheries have driven down forage fish populations, and so led to the depletion/overfishing of 16 named fish stocks.  But with even a modicum of research, it’s simple to disprove that implication.  Some of the fish named aren’t overfished.  Some don’t regularly feed on fish at all.  And of the ones which do feed on various forage fish species, their depletion is almost universally due to overfishing, either in directed fisheries or as bycatch; there is no strong statistical connection between forage fish depletion and any of those fisheries declines.

Yet The Forage Fish Campaign’s video suggests that there is.   

The video ends with more stark black and white text:

“THE US FISHERIES CRISIS IS REAL”

“COLLAPSING OCEAN FOOD SYSTEMS”

“DEVASTATING COASTAL ECONOMIES”

“THIS STOPS NOW”

“PROTECTING US FISHING JOBS IN THE ATLANTIC OCEAN & GULF OF AMERICA”

As a “campaign,” it’s reasonably good stuff.  It’s designed to generate an emotional, rather than an intellectual, response, that will goad people into donating to the cause, writing letters to politicians, etc.

But as a factual discussion of the problem, it falls pretty short.  And that’s a problem, from multiple perspectives.

First, if someone is going to ask me to donate as much as $1,000—plus a little extra to cover administrative expenses—I need to know that they are knowledgeable and capable advocates.  When The Forage Fish Campaign calls stocks overfished when they’re not, and suggest that forage fish are the cause of depletion that can be easily traced to other causes, they seem woefully ignorant of basic facts relevant to their campaign, and certainly aren’t anyone I’d want to pay to represent my interests.

Beyond that, the failure to master basic facts will leave them with little or no credibility with regulators and other fisheries managers, who by and large are very conversant with the facts governing the fisheries that they oversee.  Making such blatant false assertions makes it appear that The Forage Fish Campaign is either ignorant of the truth about coastal fisheries, or that they are trying to distort that truth in order to mislead the very people who they are trying to influence.

Which leads to the final point, and that is the facts really do speak for themselves.  If we were truly looking at a “crisis” in our fisheries, there would be no need to make spurious claims or false implications; the data would easily show that a lack of forage fish was causing a decline in predator species.  One only needs to distort the facts if the unvarnished truth alone is not enough to support one’s arguments, and embellishment was necessary to make a convincing case.

And that’s a bad place to be, because forage fish conservation is a real and pressing need.  Not because a decline in forage fish has “collapsed ” fisheries, but because forage fish are a critically important part of marine ecosystems, and such ecosystems couldn’t function without them.

Distorted truths and fatuous claims, although perhaps made with the best of intentions, can undercut the work of legitimate forage fish advocates who work with the science to seek better regulation and management of forage fish fisheries, and plays into the hands of those who would overexploit the resource, who can point out the less than forthright claims in efforts to discredit the entire conservation community.

Thus, in my opinion, The Forage Fish Campaign’s video does forage fish no service and, by distorting the facts, only plays into the hands of those who oppose forage fish conservation.