After spending over 50 years on and around the water, I have realized that without strong fisheries laws and effective conservation measures, the future of salt water fishing, and America's living marine resources, is dim. Yet conservation is given short shrift by national angling organizations and the angling press. I hope that this blog will incite, inform and inspire salt water fishermen to reclaim their traditional role as the leading advocates for the conservation of America's fisheries.
Sunday, June 19, 2016
UTILIZING BYCATCH: THE HIDDEN HAZARD
many years, reducing or eliminating “bycatch,” unwanted fish or other creatures
incidentally caught by fishermen while seeking other species, has been a goal
of fisheries managers.
which are harvested in a fishery, but which are not sold or kept for personal
use, and includes economic discards and regulatory discards. Such term does not
include fish released alive under a recreational catch and release fishery
and management measures shall, to the extent practicable, (A) minimize bycatch
and (B) to the extent bycatch cannot be avoided, minimize the mortality of such
Recently, to further its
efforts to reduce bycatch, NOAA Fisheries issued adraft National Bycatch Reduction Strategy(Strategy), which lists multiple
approaches that the agency plans to take in order to comply with National
Standard 9’s mandates.
Most of those measures make sense. There are too many to list
all of them here. However, among other things, NOAA Fisheries plans to:
whether ‘best practices’ can be developed and applied across managed fisheries
and protected species to improve bycatch estimates as needed for fisheries
to support the development and implementation analyses of species-specific
bycatch reduction measures (e.g., circle hooks, TEDs, and ‘hot spot’ area
closures), and modify those measures as needed.”
understanding of post-release mortality of fishery and protected species
through the implementation of the Action Plan for Fish Release Mortality
Science and current best practices for protected species, respectively.”
It’s hard to argue against any of those efforts.
On the other hand, NOAA Fisheries also intends to
research that explores increased utilization of incidentally caught fish that
would otherwise be discarded,”
efforts to encourage utilization of discards…”
At that point, the agency’s plans enter uncertain and
potentially dangerous territory.
At first hearing, the concept sounds good. All fish sold, even
if caught accidentally, are excluded from the definition of “bycatch,” so
utilization would certainly reduce the amount of bycatch that’s caught, and
most people would probably prefer seeing any fish killed put to use, rather
than merely dumped back into the sea.
However, the key issue isn’t whether economic discards can be
utilized. The most important question is whether such fish should be killed at
By definition, economic
discards are composed of fish that currently have little or no market value.
The species that comprise such bycatch are likely to be little-studied, and are
probably not subject to any federal fisheries management plan. There is a very
high likelihood that the impact of fishing mortality on such bycatch species,
and on the ecosystems in which they function, is unknown. In the case of some
bycatch species (e.g.,alewife,blueback herring,American shad),
fishing mortality may already be greater than the stock can tolerate.
Utilization of such low-value and no-value species would require
the creation of new markets where they can be sold. However, once such markets
exist, fishermen will have an incentive to direct effort on species that they
previously tried to avoid or, at the least, made no effort to seek out. If such
fishermen can find a way to make directed fisheries for such previously
unwanted species profitable, there is a substantial risk that fishing mortality
of such fish will increase. At the same time, there will be no federal
fisheries management plan in place that will allow NOAA Fisheries to determine
whether such increased harvest poses a threat to any of the newly marketable
NOAA should avoid creating such a high-risk situation by
prohibiting, rather than encouraging, the sale of any species not included in a
federal fisheries management plan.
Any effort by NOAA
Fisheries to actively encourage the sale of current economic discards would
also frustrate regional fishery management councils’ plans to protect currently
unmanaged forage fish stocks. For example, theUnmanaged Forage Omnibus
being prepared by theMid-Atlantic Fishery Management
“freeze the footprint” of current forage fish landings by prohibiting the
creation of new fisheries for many unmanaged forage species until NOAA
Fisheries can determine the impact of any such fishery on the health of the
stock and the health of the overall ecosystem. Encouraging the sale of economic
discards, including those species that constitute forage, would hinder such
Instead of seeking ways to utilize economic discards, NOAA
fisheries should be concentrating its efforts on developing gear, regulations
and procedures that meet not only the letter, but also the intent, of National
Standard 9, which is to reduce the harvest of non-target species. Relabeling
bycatch, by creating markets for such low-value, non-target species, arguably
complies with the letter of National Standard 9, but is not in accord with the
conservation imperative, which lies at the heart of Magnuson-Stevens.
While the Strategy contains many well thought out proposals, and
is generally worthy of implementation, NOAA Fisheries should not attempt to
seek or develop markets for fish currently categorized as economic discards, as
the dangers of doing so outweigh any possible conservation benefits. Any such
effort must be held in abeyance unless and until there is enough information
available with respect to the relevant species to assure that creation of
markets for such economic discards will not lead to overfishing or deplete
stocks so badly that they become overfished.
InRomeo and Juliet,
William Shakespeare noted that, “A rose by any other name would smell as
sweet.” In a similar vein, fish killed as bycatch, even if labeled with some
other name, can still do real harm.
Utilizing economic discards is not the right solution to the
bycatch problem. Avoiding such bycatch in the first place is. ---- NOTE: This essay first appeared in "From the Waterfront," the blog of the Marine Fish Conservation Network. "From the Waterfront" may be found at http://www.conservefish.org/blog/