TIME TO HELP OUT THE HERRING--AND THEIR PREDATORS

Sometimes it seems that too many people, including fishery managers, forget that fish have to eat.

Thus, we get high-volume fisheries for forage species, the low trophic level fish that feed largely on plankton and, in turn, serve as food for everything else in the sea.  

For far too long, those who manage such fisheries have remained focused only on maintaining the sustainability of the forage fish harvest, and spend too little time focusing on the importance of such forage species to both larger predators and to the fisheries that such predators support.

That is slowly beginning to change.

The Pacific Fishery Management Council has adopted protections for previously unmanaged forage species; the Mid-Atlantic Fishery Management Council has done the same, with an Unmanaged Forage Omnibus Amendment that prevents the creation of new fisheries for many prey species unless there is adequate science to show that any such fishery won’t cause harm further up the food web.

Now, the New England Fishery Management Council is moving forward with its Draft Amendment 8 to the Atlantic Herring Fishery Management Plan, an amendment that, if adopted, would recognize the importance of the already heavily-fished Atlantic herring as a prey species.

As the Draft Amendment notes,

“Atlantic herring have supported an important commercial fishery since the late 19^th century and play a very important role in the ecosystem as forage fish for many predators including marine mammals, larger fish, and seabirds, which support additional commercial, recreational and ecotourism industries…

“The primary purpose of Amendment 8 is to modify the fishery management plan for Atlantic herring fishery by:

1.        Proposing a long-term acceptable biological catch (ABC) control rule for the Atlantic herring fishery that may explicitly account for herring’s role in the ecosystem and to address the biological and ecological requirements of the Atlantic herring resource.

2.       Proposing measures to address potential localized depletion of Atlantic herring to minimize possible detrimental biological impacts on predators of herring and associated socioeconomic impacts on other user groups.”

The second point, addressing potential localized depletion, has always been a contentious issue, whether the target species is herring or some other forage fish.  The point has been raised with respect to menhaden in Chesapeake Bay, and with respect to squid off Massachusetts’ Elizabeth Islands.

With regard to such localized depletion, the Draft Amendment states that

“Localized depletion occurs when harvesting takes more fish than can be replaced either locally or through fish migrating into the catch area within a given time period.”

The Draft Amendment provides additional detail by including a “Council Problem Statement” that says

“Scoping comments for Amendment 8 identified concerns with concentrated, intense commercial fishing for Atlantic herring in specific areas and at certain times that may cause detrimental socioeconomic impacts on other user groups (commercial, recreational, ecotourism) who depend upon adequate local availability of Atlantic herring to support business and recreational interests both at sea and on shore.  The Council intends to further explore these concerns through examination of the best available science on localized depletion, the spatial nature of the fisheries, reported conflicts among users of the resources and the concerns of the herring fishery and other stakeholders.”

In other words, the problem is not a shortage of herring, at least if the current biomass is evaluated on a single-species, rather than on an ecosystem, basis.  Although the stock is managed very aggressively and with a minimum of precaution—the total allowable catch for 2018 is set so high that there is a 50-50 chance that overfishing will occur—the most recent operational stock assessment, conducted in 2015, found that spawning stock biomass was well over the target level, while fishing mortality was well below the overfishing threshold in 2014.

Instead, the problem is an influx of large, mid-water trawlers that come into nearshore waters and remove many thousands of pounds of herring in a single tow, badly depleting the local forage base and causing larger fish, including such recreationally and commercially important species as striped bass, bluefin tuna, and cod, to go elsewhere in search of more abundant forage.  John Pappalardo, executive director of the Cape Cod Commercial Fishermen’s Alliance, noted

“Our guys are not fishing the way they did 12 years ago around the Cape because those fish aren’t there because the bait isn’t there.  We live in a migratory corridor here.  We depend on the bait to be there.”

A letter being circulated by the Fishermen’s Alliance argues that

“Mid-water trawlers are breaking our local food web by removing millions of pounds of herring and in turn harming everything from cod fishermen to whale boat operators.  The residents of Cape Cod feel the effects of sea and river herring being taken from nearshore waters, are penalized for harvesting, possessing or selling it, yet the industrial fleets are not.

“They can legally catch hundreds of thousands of pounds of river herring that are tossed overboard dead.  Predators (striped bass, cod, tuna) leave our area because they don’t have enough to eat.  We think this is the most important offshore issue facing us now.”

There are thus a lot of voices calling for the New England Council to push the big herring trawlers further offshore.  

On Cape Cod, many towns are supporting an inshore buffer zone where such large boats would not be able to fish; they are doing so not only to protect the Atlantic herring and its predators, but also to protect depleted stocks of river herring, which the trawlers frequently kill as part of their bycatch.

In Rhode Island, anglers are strongly supporting options in the Draft Amendment that would consider Atlantic herring’s role in the ecosystem when setting catch limits, and push the mid-water trawlers at least 25 miles offshore.  

Richard Hittinger, First Vice President of the Rhode Island Saltwater Anglers Association, stated that

“For Rhode Island a 25 mile buffer is important to help prevent localized depletion and user conflicts considering the major role herring plays around Block Island and Cox Ledge as forage fish for striped bass, cod, tuna, whales and other species.”

Conservation groups are also pushing for recognition of Atlantic herring’s importance as a forage fish, and for inshore buffers that exclude the mid-water trawlers.  

The Conservation Law Foundation, Wild Oceans and the National Audubon Society, among others, are asking that the big trawlers be pushed at least 50 miles offshore, to provide an adequate feeding corridor for the herring’s predators.

Not surprisingly, about the only opposition to managing herring as forage fish, and to creating the no-mid-water trawler buffer zone, comes from a group that disingenuously calls itself the “Sustainable Fisheries Coalition,” and describes itself as

“an organization of the Atlantic herring and Atlantic mackerel mid-water trawl and purse seine industry, operating from Maine through New Jersey.  The Coalition was established in 2007 to improve public outreach and education and increase awareness of the economic importance environmental sustainability of the Atlantic herring and Atlantic mackerel fisheries.”

According to Rhode Island Public Radio, the Sustainable Fisheries Coalition

“said in an email the current control rule [which ignores the Atlantic herring’s role in the ecosystem] is better because it allows for more flexibility in setting catch limits,”

and

“opposes any new restrictions because they claim there is no evidence that current regulations are harming herring.”

Of course, that latter comment ignores the whole point of ecosystem-based management—it’s not about not harming the targeted species, but about not harming the entire ecosystem within which the targeted species functions—but it’s about what you can expect from a group that specializes in removing many, many tons of forage fish from the ocean each year.

The very last thing they want anyone thinking about is their impact on the ecosystem…

But for those who believe that the health of the ecosystem matters, time is getting short.  The New England Fishery Management Council will be accepting comments on Draft Amendment 8 through 5:00 p.m. on Monday, June 25. 

Such comments should be addressed to Thomas A. Nies, Executive Director, New England Fishery Management Council, 50 Water Street, Mill 2, Newburyport, MA  01950.  If sent by mail, comments should be sent early enough that they are received by the June 25 deadline.  

Given the uncertainties of mail delivery, it might make more sense to email all comments to comments@nefmc.org, or fax them to 978-465-3116.

To make sure that all comments are sent to the right place, they should state “DEIS for Amendment 8 to the Atlantic Herring FMP” on the message line of all emails or elsewhere on mailed or faxed correspondence.

And if folks are concerned about a healthy ecosystem and forage fish stock, all comments relating to setting an Acceptable Biological Catch control rule should support Alternative 2, which

“would prioritize herring predator forage needs based on limiting fishing mortality to 50% of [fishing mortality at maximum sustainable yield],”

and with respect to potential localized depletion and user conflicts, either Alternative 5 (25-mile buffer) or Alternative 6 (50-mile buffer) to keep the mid-water trawls offshore and better assure that predators in nearshore waters will find enough herring to provide for their forage fish needs.

Of course, the Sustainable Fisheries Coalition—the folks who tow those big mid-water trawls—hope that no one does that sort of thing.

Which should be enough to get you off of your couch and onto your keyboard, to make sure that your comments are heard.