YES, FISH EAT OTHER FISH (AND HAVE, SINCE THE ORDOVICIAN)

I was reading through the Draft Addendum IV to Amendment 6 to the Atlantic Striped Bass Interstate Fishery Management Plan when a somewhat strange passage caught my eye.

It came in Section 2.2.3 of the Draft Addendum, which is entitled “Ecosystem Considerations,” and it said

“When fishery management changes are being contemplated, food web relationships should be considered…Striped bass are predators of other Commission managed species, including weakfish and shad and river herring.  As the striped bass population grows the demand on prey species also increases.  The increased demand on prey species may have impacts on those species undergoing rebuilding plans.  The current addendum’s goal of reducing fishing mortality to target levels may impact predation on other ASMFC-managed species.”

I don’t have any problems with the premise that striped bass eat fish—that’s certainly true—but I do have concerns about the overall tone of the section.

Because the best that I can tell, fish have been eating other fish since the Ordovician Period, about 450 million years ago; at least that’s when the first remains of presumably jawed and piscivorous sharks appear in the fossil record.  

Bony fish (as opposed to the cartilaginous sharks) started eating other fish about ten million years later, when the long-extinct Acanthodians appeared on the scene in the early Silurian.

In his book Discovering Fossil Fishes, Dr. John G. Maisey of the American Museum of Natural History noted that

“The developmental and anatomical complexity attained by gnathostomes [i.e., jawed animals] has been relatively stable at least since the Silurian.  We can view the rise of the gnathostomes as a second punctuated event, followed by more than 400 million years of relative stasis.

“It is quite remarkable that the basic diversity of jawed craniates became fixed so early in their evolution.  Sharks, ray-finned fishes and lobe-finned fishes all appeared about 400 million years ago and have survived to the present day.  Conservatism of design is striking…”

In other words, fish have been eating each other on a regular basis for a very long time.  Yet somehow, they survived—in fact, thrived and radiated out into an ever-changing plethora of species—for hundreds of millions of years, even though for all but a tiniest fraction of that time, predators existed at far higher levels than they did today—at 100% of their spawning potential, the level of an unfished stock.

There were no people around to control predators’ “demand on prey species.”  And there was no worry about predators affecting stock rebuilding plans, because with no people around to overfish forage fish stocks, there were no such plans and no need for rebuilding in the first place.

So let’s put the blame where the blame belongs, and stop blaming striped bass—or any other species—for fisheries problems.

If we’re talking about a lack of weakfish, let’s talk about ASMFC’s refusal to accept scientific advice to put a moratorium in place to assist in their rebuilding.

After being told by ASMFC’s Weakfish Technical Committee that

 “The main discussion was a moratorium is more than likely the best way to go at this time…”

and public comment supported such moratorium by a two-to-one margin, ASMFC’s Weakfish Management Board heard comments such as those of Tom Fote, the current governor’s appointee from New Jersey, who said

“…I’m looking at a situation that doesn’t basically shut down a complete fishery and basically allow the person, if he catches a weakfish of a lifetime or something like that or the kid on a beach actually catches a weakfish on that rare occasion, they can go home with one weakfish.

“…at least they’ll have, you know, one fish to take home…

“You know, we also talk about we’re supposed to build a sustainable fishery for a sustainable industry.  If you start closing down both those industries, it takes a long time for that industry to recover…”

and seemed to consider such argument reasonable.  The Management Board rejected both the Technical Committee’s comments and their endorsement by the public, and left both the recreational and commercial fisheries open, although at much reduced harvest levels.

They didn’t seem to consider the possibility that, if you keep taking fish out of an already badly depleted weakfish stock, the stock will take at least as long to recover as the fishing industry—which, in the end, at least has many viable alternatives to harvesting weakfish.

Weakfish, on the other hand, have no alternatives if they get caught and die.

And now, a lot of the same folks who sat on that management board apparently want to blame the striped bass for the weakfish’s problems…

In the case of American shad, Amendment 1 to the Interstate Fishery Management Plan for Shad & River Herring noted, as early as 1998, that

“Historically, American shad (Alosa sapidissima), hickory shad (Alosa mediocris), alewife (Alosa pseudoharengus) and blueback herring (Alosa aestivalis) (collectively termed alosines) were extremely important resource species and supported very large commercial fisheries along the east coast of both the United States and Canada…large declines in commercial landings were perceived as an indication that management action would be required to restore alosine stocks to their former levels of abundance…”

However, as is so often true with ASMFC plans, managers did not take decisive steps to reduce harvest, and declines continued.  ASMFC allowed many of the river-specific stocks to decline so badly that, in the case of shad in New York’s Hudson River, the latest stock assessment found that

“Over the last 20 years, the Hudson River stock of American shad has shown consistent signs of excessive mortality on mature fish…high adult mortality was caused by fishing and that this excessive fishing has now affected recruitment.

“…Results of this fishing pressure has left the stock in a historically depressed condition with high uncertainty regarding its recovery.  Few year-classes currently remain at high enough abundance to rebuild the spawning stock.”

Twelve years passed, while “high adult mortality caused by fishing” continued to drive down the stocks in the Hudson and elsewhere, before ASMFC finally decided to adopt more effective measures in 2010.  Unfortunately, by then things had gotten so bad that, at least in the Hudson, there is now “high uncertainty” regarding the stock’s recovery.

Yet ASMFC has the temerity to suggest that striped bass are to blame…

In the case of the alewife and blueback herring—the “river herring” referred to in the shad and river herring management plan—ASMFC decided merely to monitor the stocks—effectively, to just watch them decline—in 1989.  

It took them two full decades, after runs in many rivers had all but disappeared and the Natural Resources Defense Council had filed an ultimately unsuccessful petition to have river herring listed under the Endangered Species Act, to finally require states to take regulatory action in Amendment 2 to the Interstate Management Plan for Shad and River Herring.

But, once again, ASMFC wants to blame striped bass for river herring problems…

Yes, striped bass eat some weakfish, American shad and river herring.  They’re opportunistic feeders, which means that they eat most of the species that ASMFC manages—and a lot that it doesn’t—at some point in their travels along the coast.  But they’ve been doing that for millenia before Henry Hudson sailed up his eponymous river, where so many big stripers still breed.

Yet there is no indication that the bass posed mortal threat to weakfish, herring or shad before the first waves of colonists came over from Europe and began to “save” such fish from striped bass (and to save other prey from every other predator that, with a bit of work, could be converted into food, funds or fertilizer).

Somehow, before Europeans arrived to catch the ravenous striped bass (and everything else) with their nets, hooks and lines, “unprotected” weakfish, shad and herring still managed to thrive.  Before the otter trawl, haul seines, purse seines, pound nets, gill nets, fykes and baited lines, striped bass, river herring, weakfish and shad managed to live in a sort of harmony that allowed them all to exist at or near 100% of their spawning potential (although the oldest residents of the east coast, who walked there all the way here from Siberia, did kill a few).

And it wasn’t because the striped bass had been vegetarians before the white man arrived on this coast.

We are far more effective predators than the striped bass could ever hope to be, and we compete with them for every forage species.  Yet when forage declines, it’s always the striper’s fault.

It’s not a pattern unique to striped bass.  On every coast, we hear the same arguments.

In Chesapeake Bay, and down in North Carolina, the talk is all about blue crabs being killed by red drum, with one fish wholesaler saying

“If they don’t do something about this fish population and restoration of this habitat, I don’t see where crabs are going to have a chance.”

Down in the Gulf of Mexico, you hear folks talking about red snapper eating everything else on the reef.

Perhaps the best story came from a former executive director of the Coastal Conservation Association’s Florida chapter, who related a story about being at a shrimp bycatch hearing in Panama City when a woman wandered up to the microphone and said

“You all are trying to stop bycatch, but I’ll tell you that bycatch is good.  Back in the old days, we didn’t worry about bycatch.  We caught jacks and mackerel and things, and there was plenty of mullet and bait and everything was fine.  But now you’re stopping the bycatch, and the fish are eating everything so that there’s no bait around, and the pelicans are starving.

“And that’s why you’ll see the pelicans flying around and eating stray cats on the street in Panama City!”

It’s no less credible than the other tales, which are all aimed at convincing regulators to let fishermen do nature a “favor” and help drive down populations of striped bass, red drum or whatever the species in question might be, so that they can be as depleted as their forage and “balance” can be restored.

Of course, cutting back harvest and restoring the forage base is never a viable option…

That  sort of thinking is probably understandable when it comes from folks looking out for their wallets.

But when it comes from folks who are supposed to be looking out for our fisheries, it’s just not excusable.

IF ALDO LEOPOLD HAD BEEN A FISHERIES MANAGER

It’s a cliché, but nonetheless true:  There’s little new under the sun.

Fisheries managers, and folks who play in the managers’ arena, might try to dispute that.  They’ll describe their field as a pretty new science, with new population models being developed and new approaches to managing stocks being proposed every day.

But in the end, they’re all just variations on a very old theme, for fish are merely wildlife, and the tenets of wildlife management were devised long ago.  

You need good habitat that produces enough forage to support the stock.  

You need enough new individuals recruiting into the stock to replace the older ones removed by nature and by man.  

You can either manage for quantity, and a big kill of mostly young animals, or you can manage for “quality” by leaving the young ones alone and letting them grow big, but there is no magic formula that lets you do both at the same time.

Anyone who hunts ducks or elk or whitetail deer already knows that is true, so fisheries managers should know it as well.  Yet it seems that the fisheries folks keep trying to reinvent the wheel, making the same mistakes and reaching the same “new” conclusions that terrestrial wildlife managers did close to a century ago.

So maybe it’s time to look back, and view fisheries management through the lens of a terrestrial wildlife manager.  I’ll pick Aldo Leopold, because his name and his work are familiar to many, and because his book, A Sand County Almanac, first published in 1949, still stands as one of the best-known musings on the proper relationship between man and the rest of the world.

Today, we can know Leopold only through his writings.  So my intent is to take some of his better-known quotes, and apply them to the fisheries issues that we deal with today.

Figuring out the right thing to do in each case is likely a good place to start.

“Examine each question in terms of what is ethically and aesthetically right, as well as what is economically expedient.  A thing is right when it tends to preserve the integrity, stability, and beauty of the biotic community.  It is wrong when it tends otherwise.”

That quote certainly answers the question I posed last May, when I asked “Do Jolthead Porgies Really Matter?”

Because, of course, they do.  As does every other animal and plant that has evolved over millennia to fill a niche in the various marine ecosystems.  For an ecosystem is nothing more or less than a complex web of life that gains its strength from every interconnected strand.  Weaken too many of those strands, and the entire construct is prone to collapse.

That’s why managing complexes of fish stocks—New England groundfish, or reef fish in the South Atlantic and Gulf of Mexico, is so difficult.  Some folks, their eyes fixed solely on the handful of species deemed recreationally or economically valuable, argue that such complexes are too, well—complex.

They offer superficial solutions to management problems, arguing that less popular or less economically valuable species should be dropped from management plans.  They claim that managing—or, at least, attempting to manage—less common or less economically important species creates a risk that, if any such stock is deemed overfished, fishermen might be denied the ability to fish for, and profit from, healthy stocks in the same complex.  

Some make theoretical arguments that we can’t risk shutting down an economically important snapper/grouper fishery just because tomtate grow scarce.  Others, on the water today, don’t want to stop trawling for haddock because too many yellowtail flounder are killed.

It’s a quintessentially selfish position, which would allow fishermen to carelessly diminish the wonderful diversity that dwells off our coasts, merely to put a few more dead fish on the docks.  

They would deny future generations the opportunity to know the beauty and abundance of healthy marine  communities.  

As a fisheries management approach, it is aesthetically and ethically bankrupt.

For the reefs and the rocks and the kelp beds that lie off our shores have evolved over millennia, filling every niche with life.  Dismantling such wonderfully-wrought structures merely to bring a small bit of profit to a small number of men who will be dead and dust before half a whale’s lifetime is done  would certainly be a great wrong.  

Pioneer ocean explorer William Beebe understood this, saying “when the last individual of a race of living beings breathes no more, another heaven and another earth must pass before such a one can be again.“

I suspect that Leopold would have agreed…

But it’s not just a matter of aesthetics and ethics.  There is a practical side.

“The last word in ignorance is the man who says of an animal or plant, ‘What good is it?’  If the land mechanism as a whole is good, then every part is good, whether we understand it or not.  If the biota, in the course of aeons, has built something we like but do not understand, then who but a fool would discard seemingly useless parts?  To keep every cog and wheel is the first precaution of intelligent tinkering.”

A few years ago, my friend Mike Mucha and I were fishing the patch reefs off Islamorada.  We had been picking some snapper, but as the sun rose and warmed the air, the action began to cool off.  So we let our baits settle down through the chum cloud, hoping to draw a strike.  Mike hooked up right away, to something that acted differently from anything that we had hooked before.

It wasn’t long before a bright blue parrotfish emerged from the water.  When the mate grabbed it, I figured he’d unhook the fish and toss it back into the sea.  Instead, he flipped the nearly iridescent animal into the far corner of the fish box, answering our unspoken question with the reply “See that beak?  They eat the coral.  They’re bad for the reef.”  

Apparently, he was intent on “saving” the reef by killing whatever parrotfish he could.

Of course, research has shown that parrotfish are critically important to the continued health of the reef, as they eat algae that can cover and smother the corals and cause them to die.  By failing to understand the parrotfish’s ecological role, the mate ended up harming the very reef he was trying to save.

Such uniformed action might be excused in a party boat mate; ignorance is far less excusable in a professional fisheries manager.  Yet when I sat on the Mid-Atlantic Fishery Management Council, I heard a former state manager argue against restricting the harvest of spiny dogfish, claiming that the species had little value, and that fewer dogfish meant less competition for “more valuable” species.

And then there are the other creatures…

Once or twice each year, at meetings of New York’s Marine Resources Advisory Council, someone opposed to restrictions on harvest will get up to “inform” us that fishermen aren’t causing problems; instead, the stock (whichever stock is being discussed at the time) is really being decimated by cormorants, and that the solution for all fishery problems is to kill off those hungry black birds.

But up on Cape Cod, something interesting is happening.  

Grey seals, which were killed off on the Cape half a century ago, have returned with a vengeance.  Commercial fishermen claim that they eat all of the herring and cod, and serve as a host for “cod worms” (which, to be fair, appears to be true), while anglers complain that the seals steal just about every fish from their lines.

But, to use Leopold’s analogy, the seals appear to be a lost cog that, having been found, have helped get the local ecosystem up and running again.  

Behind the seals came some of the great predators of the sea—big, adult white sharks, along with some truly huge makos weighing over 1,000 pounds—that that returned to Cape waters to hunt their traditional pinniped prey.

The seals and the sharks have reminded us all that what is ethically and aesthetically right can be profitable, too.  They have spawned new businesses, as thousands of folks take sealwatching tours, and Cape tourist shops sell anything “shark”—coffee mugs, t-shirts, plush toys and more—to visitors enchanted by the wildness that cruises just a few yards offshore.

Even so, income isn’t the sole measure of good management.

“Cease being intimidated by the argument that a right action is impossible because it does not yield maximum profits, or that a wrong action is to be condoned because it pays.”

This is a hot issue in fisheries management right now, as the Magnuson-Stevens Fisheries Conservation and Management Act awaits reauthorization.

Washington Congressman Doc Hastings’ is using short-term economic benefits to justify a bill so bad that it has been dubbed the “Empty Oceans Act”, claiming “This debate today isn’t just about the use of a natural resource – it is about providing a sustainable source of protein as well as providing economic vitality to coastal communities.“.

And various anglers rights groups have teamed up with the recreational fishing industry to work for a weakened law that would permit overfishing and slower rebuilding of overfished stocks in the name of  “diminishing socioeconomic impacts“.

Here on the east coast, as the Atlantic States Marine Fisheries Commission debates measures to stem the decline of the striped bass stock, a professional fisheries manager, Thomas O’Connell of Maryland, is trying to water down ASMFC’s striped bass management plan, to delay need harvest reductions.  Once again, “socioeconomic impacts” serve as an excuse.                                       “.

If we fall back into Leopold’s realm, the lands of America’s interior, it’s hard to conceive of professional managers allowing overharvest of mule deer or bighorn in order to provide greater “socioeconomic benefits” for a handful of guides and sporting goods stores.  But here in New York, where winter flounder are so scarce that they’re threatened by inbreeding, salt water fisheries managers keep the season open to mollify a handful of tackle shops and for-hire boats.

But I shouldn’t put all of the blame on their managers.  Too many anglers also find it hard to do the right thing.

“Ethical behavior is doing the right thing when no one else is watching, even when doing the wrong thing is legal.”

You hear it all the time on the waterfront.

Fish hogs often try to justify their excessive kills by telling critics that the law “entitles” them to a full limit of fish, and that it is their “right” to kill them.  And many fishing websites have adopted the same position, prohibiting criticism of posters who kill within the limits of the law.

The fact that the law is wrong, and needs changing, never enters the picture.

We saw a variation of that maybe here in New York maybe fifteen years ago, after striped bass fishermen failed to convince the state to leave conservative regulations in place.  Over the course of a couple of years, anglers who once argued passionately that keeping the minimum size at 36 inches was the “right” thing to do suddenly felt no shame in killing 28-inch “keepers”; today, as bass populations again decline, the same anglers are discovering that they were closer to right the first time, and are once more asking managers to impose tougher rules.

Because, in the end, they know that a problem exists.

“One of the penalties of an ecological education is that one lives alone in a world of wounds. Much of the damage inflicted on land is quite invisible to laymen. An ecologist must either harden his shell and make believe that the consequences of science are none of his business, or he must be the doctor who sees the marks of death in a community that believes itself well and does not want to be told otherwise.”

Leopold was a formally trained biologist and wildlife manager; most anglers, and most readers of this blog (not to mention its author) are not.  We are the “laymen” that Leopold speaks of.

And yet we are not.

For while we have no formal ecological training, there is no better place to learn of the interrelationships that govern all life than out in the world itself.  After spending half a century and more on the coast, living through collapse and recovery, abundance and loss, anyone with the sense to keep their mind open and their mouth shut for a while will figure out how it all works.

You can’t help but see the hurts, the gaping wound in our bays that the flounder once filled, the slow bleeding along the beach as the great runs of striped bass grow less every year. 

We each face a choice, then.  We can join in the rush to kill what is left before it is gone.  We can turn away and tell ourselves that death is inevitable.  Or we can be bearers of unwanted news, unwelcome wherever we go, trying to convince those who we meet that life can prevail, and health restored, if only we act wisely, and in time.

If Aldo Leopold had been a fisheries manager, I think I know what his choice would have been.

It would have been ethical.

It would have been difficult.

And it would have been "right."

WE DON'T CATCH RED SNAPPER HERE ON LONG ISLAND

This blog post is NOT about red snapper.

It’s about everything except red snapper. 

It’s about New England codfish, haddock and cusk.  It’s about scup off Long Island, fluke off New Jersey and black sea bass off all of the Mid-Atlantic states.  It’s about Georgia dolphin and Texas king mackerel, Pacific rockfish, Alaska halibut and wahoo off Hawaii’s Big Island.

It’s about the National Marine Fisheries Service’s proposed Recreational Saltwater Fisheries Policy, an idea with a lot of potential, and a handful of—well, I have to say those two dreaded words—red snapper anglers and their representatives, who want to hijack that policy and make it all about them, and not about you.

It’s about all of us who don’t fish in the Gulf of Mexico, and don’t fish for Gulf red snapper, and the need for all of us to get up off our tails and make sure that any national Recreational Saltwater Fisheries Policy that NMFS ultimately adopts is truly national in scope, and addresses all fisheries, and isn’t corrupted to serve just one piece of the coast and those who pursue one particular groundfish.

I’ve mused more than once in this blog about the semi-hysterical, borderline irrational rhetoric coming out of the angling community down in the Gulf of Mexico, who seem to have lost all sense of proportion—and maybe reality—as they rant and rave and attack federal regulators unwilling to let them overfish the red snapper stock.

I’ve written about various anglers’ rights organizations and industry trade groups, which are now willing to weaken, and most likely cripple, America’s primary fisheries management law, simply to kill more red snapper.

Now we learn that the proposed national Recreational Saltwater Fisheries Policy is all about them, too (something that all but the most altruistic among us already suspected). 

The revelation came in a letter dated August 20, 2014, which was written by Bill Bird, Chairman of the Coastal Conservation Association’s National Government Relations Committee, and addressed to Doug Boyd, Chairman of the Gulf of Mexico Fisheries Management Council.

It can be found on the Gulf Council’s website, among the comments to Amendment 40 to the Fishery Management Plan for the Reef Fish Resources of the Gulf of Mexico, which I discussed just a week ago. 

Not surprisingly, it opposes the amendment, but some of its language reaches much farther, saying

“…we question the timing of an effort that represents such a significant shift in recreational fisheries management in the middle of NMFS’ attempt to craft the nation’s first Recreational Saltwater Fisheries Policy.  It is highly ironic that passage of Amendment 40 will severely limit the ability of the Council or NMFS to meaningfully implement any such policy for the Gulf recreational red snapper fishery, which is virtually the sole impetus for the creation of the policy in the first place  [emphasis added].”

Many things now become clear.

Most particularly, this admission explains the disjointed language in the Theodore Roosevelt Conservation Partnership’s report A Vision for Managing America’s Saltwater Recreational Fisheries, to which CCA, along with a number of affiliated trade organizations belonging to the Center for Coastal Conservation, contributed.

The TRCP’s “Vision” report was a very disquieting read, because on one hand it said all the right things, correctly noting that

“Our [recreational fishing] community invests in aquatic resource conservation because we know that the future of recreational fishing directly depends on the health of fish populations and their habitat…

“For all anglers, fishing provides a chance to experience a special connection with our marine environment, gain a better appreciation for our country’s natural resources, and practice the conservation ethic that is integral to the sporting community…

“Recreational fishing is founded on conservation, sustainability and opportunity.  Saltwater anglers and the recreational fishing industry that they support are critical to conservation…”

I find it impossible to disagree with those statements, and believe that the great majority of anglers will also concur; they are as true in Maine as they are in Mississippi, and hold as firm in Alaska as they do in Alabama.

The “Vision” report is also correct when it states that

“Currently, federal fisheries managers set catch limits for recreational and commercial fishing at or near maximum sustainable yield.  While this may be an ideal management strategy for commercial fishing, where harvesting the maximum biomass is desired, it is not an effective management tool for saltwater recreational fishing.  Recreational anglers are more focused on abundance and size, structure of the fisheries, and opportunities to get out on the water.”

However, when we get down to the nuts and bolts of what a “national” Recreational Saltwater Fisheries Policy would actually look like, all of that idealistic talk about conservation, sustainability and harvesting fewer fish go straight out the window.

Which makes perfect sense, given that red snapper were “virtually the sole impetus for creating the policy in the first place.”

Today, red snapper are already managed in accord with the precepts of aquatic resource conservation.  Managers are already setting annual quotas that allow for a sustainable harvest.  They are already keeping landings below maximum sustainable yield.

That’s what red snapper anglers are complaining about!

So in the “Vision” report, they set about proposing a “national” Saltwater Recreational Fisheries Policy that will allow them to kill more fish.

They propose doing away with quota-based management, saying

“The NMFS should manage recreational fisheries based on long-term harvest rates, not strictly on poundage-based quotas.  This strategy has been successfully used by fisheries managers in the Atlantic striped bass fishery…”

Perhaps they should have spoken to some Atlantic-coast fishermen before taking the name of the striped bass in vain, and checked how “successfully” that no-quota strategy was working out.

Because right now, the stock is in steady decline, with a population that has probably already slipped beneath the female spawning stock threshold and into “overfished” territory.  Fishing mortality exceeds the target. 

Is that what a “successfully” managed fishery looks like?

Maybe, if you’re a red snapper fisherman, who doesn’t like targets and thresholds.  

But most striped bass fishermen would like to see a national policy that starts rebuilding the stock pretty soon—or, to be a little more accurate, that started rebuilding the stock maybe three years ago.

And they might talk to the folks in New England about the no-quota concept.  For many years, that’s how the New England Fisheries Management Council managed groundfish.  As a result, a lot of stocks are not in good shape.

And yes, they’d say that up there it’s different, because commercials were doing the killing, but let me let you in on a little fact that you might not have considered before—a dead fish doesn’t care who killed it.  Whether commercial codfishermen fished unsustainably in the Gulf of Maine or recreational fishermen fished unsustainably in the Gulf of Mexico, too many fish are now too dead in both of those places.

In the Gulf of Maine, it may be too late to fix things.  Cod stocks are at maybe 3% of target levels, and it’s not impossible that we will all lose the fishery for the rest of our lifetimes.  That’s not a “successfully” managed fishery, either.  Maybe a quota would have helped…

For most of us, on most of the coast, who have gone through the pains of rebuilding and don’t want to go through the Hell of empty oceans again, a national Recreational Saltwater Fisheries Policy means just what the idealistic prologue of the TRCP’s “Vision” suggested.  We want abundance, big fish and sustainable, conservative management.

To get abundance and big fish, we need rebuilt stocks.  In fact, we need stocks that are more than only “rebuilt”—which merely means that they will produce maximum sustainable yield.  We want stocks that are substantially larger than needed to produce MSY, because larger stocks produce larger fish and more frequent “encounters” with anglers. 

But, once again, that’s not what the red snapper folks want their national policy to look like.  They say

“Instead of having a flawed deadline for stocks to be rebuilt…set lower harvest rates that would allow fish stocks to recover gradually while diminishing socioeconomic impacts.”

In other words, push back the day when anglers can enjoy an abundance of bigger fish, so that the red snapper folks can kill a few more fish and the people who sell them tackle and bait can enjoy an abundance of bigger profits.

Again, that won’t go over too big with the striped bass folks, who are already fighting to keep some champions of diminished “socioeconomic impacts” in Chesapeake Bay from amending the management plan to allow a longer phase-in of harvest reductions.

Like other folks all around the coast, they want to see the days of abundance and big fish come soon.

It’s pretty clear that a Recreational Saltwater Fisheries Policy that’s good for the nation—that emphasizes big fish, conservation, abundance and sustainability—won’t please those red snapper folks at all.

They want a bigger kill now, and if they management efforts for anything else, well—let’s just say they won't lose too much sleep.

So you can be pretty sure that the folks who view red snapper as “virtually the sole impetus for creating the policy in the first place” are going to be pushing hard for a policy that’s not in our best interests at all.

Still, as I said at the beginning, having  a national Saltwater Recreational Fisheries Policy is a pretty good idea.

So let’s embrace it, and make it our own.

NMFS will be accepting comments on the policy until September 12, and is making it very easy for anglers to make them.

Just go to the NMFS webpage at http://www.nmfs.noaa.gov/sfa/management/recreational/policy/ .  You can click on a link to make your comments right there.

You can tell NMFS that you want stocks recovered to real abundance as soon as possible, as current law requires; you don’t want rebuilding delayed to some indefinite day in the future, which may never come.

You can tell them that you want stocks managed for a better age and size structure—which means more big fish—even if that means that you can’t take quite as many little ones home.

You can tell them that you support conservation, and sustainable management, because you want your kids and your grandkids and those not yet born to enjoy some good fishing too.

If you tell them things such as that, and if NMFS listens, it won’t make the red snapper people too happy.

But we don’t catch red snapper here on Long Island.  

They don’t catch them up in Lubec, Maine, or Gloucester, Massachusetts or in Belmar, New Jersey.  They don’t catch them out of Indian River, Delaware or Ocean City, Maryland.  They don’t catch them out of Long Beach, California or Portland, Oregon.  Not out of Homer, Alaska or Hilo, Hawaii.

But a national Recreational Saltwater Fisheries Policy needs to suit anglers in all of those places, and not hang them out to dry in favor of a few folks down on the Gulf coast.

So if you want a national policy that works for you instead of against you, you might want to click on the link that I gave you above, and provide your comments RIGHT NOW.

THE RISKS OF "COOPERATIVE" SCIENCE

The United States Senate is making a pretty good effort to reauthorize the Magnuson-Stevens Fishery Conservation and Management Act.

I haven’t had a chance to carefully study the latest draft, which came out about a month ago, or to compare it to the initial draft that was released last spring (when I do, I’ll let you know what I find).  But after a quick read, I noticed that the latest draft eliminates one of the original bill’s flaws, a so-called research program which was nothing more than a poorly camouflaged scheme to let folks kill more South Atlantic red snapper.

Unfortunately, the new draft preserved another section that calls for

“ a report on facilitating greater incorporation of data, analysis, stock assessments, and surveys from nongovernmental sources, including fishermen, fishing communities, universities, and research institutions, into fisheries management decisions.“

It’s another one of those things that looks pretty good at first glance, but falls apart when you examine the details.

Certainly, the biologists at NOAA Fisheries could use a little bit of help.  They have hundreds of stocks to manage, and lack the money and the personnel to get the job done on anything like a comprehensive basis.  The result is that the important stocks get assessed on a semi-regular basis, stocks that are not important to industry (but may have real significance to the ecosystem) go largely ignored and everything else is studied in a sort of hit-or-miss fashion when money and manpower allow.

Even some fairly important species may receive inadequate study.  Black sea bass cause a lot of angst and harsh words in the Mid-Atlantic, but because of their unique life history and stock structure, are a devilishly hard—and expensive—stock to assess.  The last assessment was unanimously rejected by a peer review panel, and the peer-review summary report noted that

“It was suggested that the assessment team continue to consider alternative methods for assessing black sea bass stock status…although achieving a new framework should not be expected in the short term…

“The three models suggested…are a major research task and may require additional data.  We do not anticipate that such models could be produced within an operational assessment framework.“

So it would seem that any help that non-governmental sources could provide, in the form of “cooperative science” could only make things better.

But that’s not necessarily true.

When you talk about “cooperative science,” you’ve got to stop and think about why anyone would want to cooperate in the first place.

When it comes to fishermen and fishing communities, the answer is usually pretty simple—they want to kill more fish (although, to be fair, that’s not always the case; striped bass anglers’ continuing advocacy for science-based harvest reductions are certainly one notable exception).

The essence of science is the use of unbiased data, or at least an effort to identify and account for the bias in whatever data exists.  However, we can be pretty certain that any “data, analysis…and surveys” provided by fishermen and their communities will be anything but bias-free.

Often, that’s not really the fishermen’s fault, it’s just a reflection of who they are and what they do.  Scientists are trained to be objective and skeptical, to search for sources of bias and error, and to seek defensible, repeatable results.  Fishermen are trained to catch fish.  That simple difference outlook places any fisherman-generated data in doubt.

You can see the problem arise just about any time that controversial harvest restrictions (and what harvest restrictions are not controversial?) are proposed.

The scientists will come to the table and argue that their surveys, conducted in the same places with the same gear over an a period of years, are showing far lower catch per unit effort, poor recruitment, decreasing average size or other symptoms of an ailing stock.  They will talk about abundance falling below established indices or long-term averages.

Fishermen will look at them with a sort of bemused look in their eye, and say “There’s lots of fish out there!”  They’ll tell the scientists that they’re not catching fish because the scientists aren’t sampling where the fish happen to be, or that their gear is rigged wrong.  Sometimes, they’ll offer to trawl side-by-side with the survey boats, to prove just how many fish they can catch while the scientists catch just a few.

The concept of year-to-year comparisons, that reject sources of bias, is completely lost on them.  The fishermen’s business is built on bias.  If you don’t catch fish in the first place that you try, you move, and you keep on moving until you’re successful.  If you finally catch in the only place holding fish in a thousand square miles of ocean—well, what does that matter?  The hold is still full, and all is OK..

We see a good example of this in the debate over crashing Gulf of Maine cod.

The fishermen sincerely believe that the stock is still fine, but sincerity is no obstacle to error.

And the last thing that anyone wants is sincerely wrong data ending up in the stock assessment.

At least, that’s the last thing that scientists and conservation advocates want.  The Gloucester Daily Times recently ran an editorial lamenting the fact that no fishermen are on the panel established to peer-review the recent Gulf of Maine cod assessment.  Apparently, trusting that task to unbiased scientists makes them uncomfortable…

Yet those problems exist when fishermen are just being themselves.  Things get worse when they bring in hired guns in the form of consultants—normally academics or former government managers who have set up their own firms—to influence the stock assessment process.

Sometimes, the industry scientists really do have insights that improve the management process.  Commercial fishermen up in New England frequently point to their success in safely increasing sea scallop quotas after their team convinced the Northeast Fisheries Science Center that higher harvest levels were completely sustainable.

The recreational fishing industry in the Mid-Atlantic claims a victory, too, after convincing biologists to lower the target biomass figure for summer flounder.  The industry proved their point—and avoided harvest reductions—by bringing in a biologist to successfully argue that males have a higher natural mortality rate than females, which prevented the population from growing as large as scientists once thought it could.

However, despite all the crowing that took place at the time, that “win” wasn’t as decisive as some in the industry would have us believe.  In fact, the data supporting the higher natural mortality rate appeared fairly weak.  In the end, the three scientists on the peer review panel had no deep conviction about the higher figure at all, with one, Dr. Michael Armstrong of The Center for Fisheries and Aquaculture Science in Suffolk, England writing that

“The specific [fishing mortality] by sex will be a function of the physiological determinants of longevity in males and females as well as the abundance of predators taking different sizes of summer flounder.  The specific value for summer flounder at present cannot be determined from existing data…I do  not have a basis for arguing against the [Southern Demersal Working Group’s] expert judgment in proposing a combined-sex value of M=0.25…  [emphasis added]“

Another reviewer, Dr. Kevin Stokes of The New Zealand Seafood Industry Council in Wellington, New Zealand, said

“Overall, the strength of evidence for the adopted value is not strong but the evidence considered suggested the value was unlikely to be below the previously assumed value of 0.2 and could be higher than the newly assumed value of 0.25.  The [Stock Assessment Review Committee] was in no better position to determine an alternative value and accepted the [Southern Demersal Working Group]-adopted value of 0.25…

“My view is that the use of M=0.25 for assessment, reference point calculation and stock status determination is justifiable, although the strength of evidence…for the specific value is weak.  [emphasis added] “

Those are hardly ringing endorsements, and demonstrate industry-paid scientists’ potential to skew the assessment process.  

They are professionals, with too much integrity to knowingly present bad or falsified data.  However, just like an “expert witness” hired to provide testimony in a courtroom trial, the hired guns for the fishing industry are paid to advance the industry’s cause, which is generally either killing more fish or avoiding harvest reductions.

They do that by either raising biologically plausible alternatives to the current management approach—alternatives such as higher mortality for male summer flounder—or by trying to impeach unfavorable data, challenge stock assessment models and question the methodologies used to survey the stock.

One fairly recent example of that was the pollock assessment, where an expert hired by the commercial fishing industry successfully argued that the reason that no pollock more than eight or nine years old were being caught—either by fishermen or in the scientists’ surveys—was because such fish managed to successfully escape the nets, not because they didn’t exist.  The fishermen’s hired gun managed to convince the stock assessment panel to substantially raise the annual harvest limit, and justified it by the existence of “cryptic” fish—pollock that nobody saw, but nonetheless believed were out there.

Such a faith-based stock assessment even managed to pass peer review, although not without reservation, as the peer review warned that

“There is, however, significant concern over the presumed large and as yet unobserved adult biomass (i.e. cryptic biomass) and the implications for management decisions.  For this reason, the Panel recommends a risk analysis approach…to determination of the consequences of assumptions on this biomass for management.  In addition, the Panel emphasizes the need for research that would confirm (or not) its existence.“

Which leads to the question, “Is it better to take a precautionary approach, and cut harvests to protect the fish that we know are there, or should we increase harvests in the belief that fish that no one—including the fishermen—have ever seen really exist in sufficient numbers to support the population?”

I know what my views are on that, and they’re probably 180 degrees opposed to those of the fishing industry’s hired guns.

And they make me pretty leery of “data” supplied by fishermen, whether recreational or commercial.

That’s probably enough reason not to accept fishermen’s data, but what about data provided by “universities, and research institutions”?

The answer to that probably is “It depends.”

There’s a lot of good work being done in such places by some very bright and dedicated people.  Some are experienced scientists teaching the next generation of fisheries biologists; some are the graduate students themselves, investigating novel questions in fisheries management as they earn their place in academia.  

But researchers are human, and both financial and personal biases can impact the research that’s done.

Competition for grants is formidable, and someone who receives significant and ongoing outside funding—say, from a petroleum company, for a continuing study assessing the impact of oil spills on fish populations—might be reluctant to present findings that clearly show that their funder is causing real harm.  

Studies might even be set up to prove that oil spills are benign.

The same sort of thing happens when researchers work closely with the fishing industry.  They often seem to lose their objectivity.  Instead of conducting unbiased research, they enter into projects best calculated to support the industry’s goals.

One of the biggest examples of that sort of industry-supported research was the so-called “Research Set-Aside Program” conducted by the Mid-Atlantic Fishery Management Council.  

Pursuant to that program, 3% of the annual harvest limit for each council-managed species was set aside, and auctioned off by the National Fisheries Institute, a commercial fishing trade organization.  Fishermen who purchased the fish at auction were allowed to catch them during the closed season, when they would bring a better price and thus make the investment worthwhile.  The money that they paid funded research, most of which (except for the NEAMAP survey of fish abundance) was related to the use of fishing gear.

Unfortunately, a lot of the science that the program produced wasn’t very good, and the program was used by unscrupulous fishermen to hide massive illegal harvests.  As a result, earlier this month, the Mid-Atlantic Council decided to take a long look at the research set-aside program and better determine its worth.

Dr. Richard J. Seagraves, an experienced fisheries scientist who serves as the Council’s Senior Scientist, didn’t mince words.  He noted that

“…while there were projects which produced tangible results that were subsequently incorporated into the Council’s management programs…there were also a number of projects which, after completion, failed to pass peer review and could not be used for science or management purposes.

“The fact that a number of RSA Projects failed scientific review after completion raised major concerns about the process by which RSA Proposals were vetted and the oversight of the projects as they were being conducted…considering the costs associated with administration and enforcement, as well as the value of the RSA quota, it’s probably that the program costs have far outweighed the benefits to the Council and public.”

If a council-sponsored program such as the Mid-Atlantic Council’s RSA program couldn’t pass scientific muster, how much faith can we have in “data, analysis, stock assessments, and surveys from nongovernmental sources, including fishermen, fishing communities, universities, and research institutions” that are subject to no council oversight at all?

America’s fisheries resources are a national treasure.  In order to rebuild them and keep them healthy, more and better science is needed.

But what our fish stocks don’t need is to have management plans diluted and corrupted by shoddy, biased and agenda-driven research that calls itself “science” but cannot stand up to rigorous peer review.

And that’s why the Senate reauthorization bill can use a little more tweaking, to assure that fishery management decisions—and decision-makers—are not led astray by bad information produced by folks with more interest in their own bottom lines than in our fisheries' future.