Sunday, July 3, 2016


Menhaden management is in a state of flux.

A benchmark stock assessment completed in 2010 and revised in 2011 determined that the stock was neither overfished nor experiencing overfishing, but noted that

“The use of FMED based reference points is of concern.  It appears that the stock has been at low levels of population fecundity for many years and yet the current reference points (and the FMED reference points of previous years) provide a determination of ‘not overfishing’ and ‘not overfished’…”

“Generally low recruitment has occurred since the early 1990s.  The most recent estimate for 2011 (4.03 billion) is the second lowest recruitment value for the entire time series, but is likely to be modified in the future as more data from the cohort are added to the analysis.”
In contrast to the assessment itself, the update found that overfishing was taking place.  It confirmed that, according to the reference points used at that time, the stock was not overfished, but warned that

“there is a technical mismatch between the current overfishing and overfished reference points.  The [Technical Committee] recommends that, given the [Atlantic Menhaden Management] Board has adopted an F15% overfishing definition, a matching overfished definition of SSB15% should be adopted as well.”
Such warning cast significant doubt on the “not overfished” finding.

Late in 2012, the Atlantic States Marine Fisheries Commission adopted Amendment 2 to the Interstate Fishery Management Plan for Atlantic Menhaden, which adopted the recommended SSB15% overfishing threshold, as well as an SSB30% target, and also established means to reduce fishing mortality and thus end overfishing.  The Amendment stated that

“The Atlantic Menhaden Management Board adopted new fishing mortality and spawning stock biomass reference points in response to the 2010 Peer Review Panel’s recommendation to provide greater protection for spawning stock biomass or population fecundity relative to the unfished levels.  The new reference points are intended to be interim benchmarks while the Commission’s Multispecies Technical Committee develops ecological based reference points.  [emphasis added]”
The general expectation was that such ecological based reference points would be substantially more conservative than the new, interim reference points, as the interim reference points were only intended to guarantee the sustainability of the menhaden stock, while the ecological reference points would be designed to keep enough menhaden in the water to not only sustain the stock, but perform the species’ ecological role as forage for a wide variety of species.

In 2015, the management terrain changed again, as a new benchmark stock assessment threw out the reference points just established three years before.  Based on the concept of “domed selectivity,” that is, that the biological sampling that took place captured a higher percentage of some year classes than others, and thus skewed the 2012 reference point calculation, the new reference points were slightly more conservative.  Based on such reference points, the stock appeared to be neither overfished nor experiencing overfishing; not even the target reference points had been breached.

Yet there was still uncertainty, with the new assessment containing the statement that

“The [Technical Committee] noted…that the stock-recruitment relationship observed to date is weak at best; therefore, the current fecundity-based reference points used to identify overfished conditions may not be useful for management of menhaden in general.”
Thus, the best available science leaves managers with a lot that they still need to wonder about.  In such circumstances, and with the concept of ecological based reference points still on the table, that would suggest a reason to move forward with caution, and wait until additional information made the wisest path a bit more apparent.

However, Omega Proteinm by far the largest harvester of Atlantic menhaden, feels differently.  At the February meeting of ASMFC’s Atlantic Menhaden Management Board, Shaun Gehan, an Omega representative, asked the Board to consider increasing the kill

“What I would like to raise or have the board consider at this time at this meeting, would be putting on the agenda for May, 2016 meeting reconsideration of the current year quota.
“As you recall last year at the May meeting this board decided to raise quota 10 percent last year and keep that steady for this year.  Subsequent to that time however, we’ve seen an explosion in recruitment, numbers of menhaden up and down the coast in numbers that people can rarely remember…
“By the May meeting you should have projections.  There’s not much new biological information, maybe the recruitment indices could be updated, but until we have a new stock assessment the projections are going to be very similar to what you saw last year and even with another 10 percent or higher increase this year there is a 0 percent chance of overfishing this stock…  [emphasis added]”
In the end, Omega didn’t get the 2016 harvest increase that it was hoping for.  However, as the time draws near for debate on 2017 harvest levels, there is significant concern that menhaden landings are going to be increased.

It would be unfortunate if that occurred before ASMFC could consider ecosystem-based reference points which, if adopted, might well require that harvest be reduced from current levels.  

At least in the case of menhaden, the target reference points have not been exceeded.  That is not the case with striped bass, where another effort to increase harvest is already going on.

Anglers had observed a sharp decline in striped bass abundance beginning around 2006.  By the fall of 2013, ASMFC’s Striped Bass Management Board had a new stock assessmentthat contained much more conservative reference points, and suggested that, without management changes, the striped bass stock could become overfished as early as 2015. 

At the October 2013 Management Board meeting, a few of the members tried to adopt an immediate reduction in striped bass harvest.  However, it was a losing effort, which met strong opposition from people such as New Jersey’s Tom Fote, who said

“we have decided where a threshold will be and then we’re getting close to that line, but we’re not under that line.  It is not overfished and overfishing is not taking place…”
In other words, the Management Board shouldn’t take steps to avert a crisis, but should only act to reduce harvest after the stock fell to critical levels.

However, such reluctance to adjust harvest levels was nowhere apparent at the December 2105 Management Board meeting.  Charlton Godwin, the Chair of the Striped Bass Technical Committee, summarized the 2015 update of the stock assessment, saying

“If constant catch is maintained from 2015 through 2017, the probability of being below the spawning stock biomass threshold increases to about 0.49 in 2015 and declines slightly thereafter to about 0.40 in 2017.  F is expected to decrease to an average of 0.18 during 2015 and2017; and there is less than a 0.12 probability of exceeding the threshold.”
In other words, there was about a 50-50 chance that the stock would become overfished last year, while fishing mortality would just barely fall to the target level.  The stock had a long way to go before being rebuilt, with spawning stock biomass, at best, just a little above the threshold, and fishing mortality hovering between threshold and target.

But that didn’t stop some Board members from already trying to increase the kill.  Mike Luisi, of the Maryland Department of Natural Resources, stating that

“I can’t sit back and explain to people in my state that we’re just going to hold the line and we’re going to wait until 2019 before any consideration would be given to making corrections given that there was no socioeconomic evaluation of these reductions, fishing mortality was at the target, looking at the latest best available science.

“The spawning stock biomass, while still in some decline, is now between the target and threshold.  It is unacceptable and I would like to make a motion.  [emphasis added]”

His motion was

“to initiate an addendum to reconsider the reduction options in Addendum IV for the 2016 fishing season in the Chesapeake Bay based on the results of the 2015 assessment update and the retrospective projections.”
In other words, he wanted to kill more striped bass.

Tom Fote, who will fight as fiercely as a cornered grizzly when it comes to opposing efforts to adopt harvest reductions, leaps into the fight like a starving wolf when given an opportunity to kill more striped bass.  He endorsed Luisi’s comments, saying

“If we had just really looked at the science, we shouldn’t have done this amendment to this plan.”
However, he fell short of endorsing the motion, because it didn’t include states outside the Chesapeake region; that objection went away soon after, when a Delaware Board member moved to amend the original motion to delete “in the Chesapeake Bay”.

Ultimately, the motion was set aside, but the possibility of a harvest increase hangs above the striped bass stock like the Sword of Damocles, perhaps fated to fall when another update to the stock assessment is released in October.

And that’s the problem with ASMFC; the slightest improvement in the health of a stock is immediately followed by efforts to increase the kill, rather than waiting for the entire recovery to run its course.  That tendency is made far worse by ASMFC’s typical reluctance to adopt meaningful and effective harvest reductions when the scientists say that a stock is in trouble.

Tautog may provide the worst example.  In April 1996, ASMFC released its first tautog management plan, which acknowledged that the species was

“overexploited, and at a low biomass level”
and noted that

“The [Stock Assessment Review Committee] recommended an immediate reduction in fishing mortality (F) to avoid the collapse of the stock.”
Biologists recommended that fishing mortality would have to be reduced to 0.15, which would require states to implement regulations that would reduce landings by an average of 55%.  However, to avoid the socioeconomic impacts of taking such a large reduction in a single year, ASMFC allowed the states to phase in the cuts over a two year period, and only get fishing mortality down to 0.15 by 1999, three years after the plan was adopted.

That permitted delay engendered more delay, as Management Board members found new and creative ways to avoid reducing F to 0.15.  They have been very successful; a stock assessment released in 2015 indicates that tautog remain overfished everywhere, although they may not quite be experiencing overfishing along some sections of coast.

Recently, the southern New England stock of American lobster has threatened to dethrone tautog as the leading example of ASMFC’s ineffectual, precaution-averse style of management.

In 2010, a peer review by independent scientists, in response to the American Lobster Technical Committee’s recommendation that a five-year moratorium be put in place to prevent a collapse of the stock, made it clear that harvest had to be substantially reduced, if not by a moratorium, then by at least a 50 to 75 percent cut in landings.  

“I really think that we need to start somewhere and the 50 and 75 percent, while it might be laudable in terms of saving the resource, it doesn’t leave any industry to have a saved resource to harvest.  I think we have to be practical…
“I know in my state I’m the governor’s representative.  He has already called me and says, oh, you’ve got to find something a little less harsh that doesn’t automatically put everybody in the State of Rhode Island out of the lobster business.  We have a terrible economy.  We’re losing jobs like crazy.  I think my role here as a governor’s appointee is to think about social, economic and biological and try to find a blend of the three…”
Last August, a new stock assessment made it clear that, at the current rate of exploitation, and perhaps without much exploitation at all, the stock is going to collapse, and do so fairly soon.  The Management Board tried to address the issue at its May 2016 meeting, with a motion that said

“the Board shall initiate an Addendum to minimize stock decline by lowering fishing mortality and increasing egg production by a combination of changes to the minimum size, maximum size, closed seasons, closed areas, trap caps and cuts, standardizing regulations throughout the area, and or combination of the above.  Target egg production increase shall not be less than 40% above the level that would otherwise be produced with no additional management.  Final regulations for this step shall be fully phased in within 3 years no later than June 1, 2019.”
That motion was watered down, changing the egg production target from “not less than 40%” to a 20% to 60% range.  It’s not immediately clear why an increase in egg production that exceeds 60% would be a bad thing, but we can suspect that the explanation is the same as the one which deems a 20% increase sufficient:

No one want to cause the lobstermen too much immediate economic distress.

Because that’s how things always work at ASMFC.  Needed conservation measures, which would result in harvest reductions and perhaps rebuild distressed stocks, are discussed at length, and face heated opposition.  There are very few that, in the end, are not watered down.

On the other hand, at the first sign of a stock rebound, harvest increases are immediately proposed, and far too often adopted, even if such increase puts a stock’s recovery at risk.

That demonstrates why those who say that “state managers do a better job than their federal counterparts” are so completely, and irredeemably, wrong.

Because at ASMFC, any stock that goes up in abundance is likely to be fished right back down before too much time passes.  On the other hand, stocks in decline will likely continue to fall.

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