FORAGE FISH IN THE SPOTLIGHT

Forage fish, the small and traditionally abundant species that larger fish, birds and marine mammals prey on, have been getting more attention over the past few years, as both academics and fishery managers recognize that without a reliable abundance of forage, there won’t be a reliable abundance of the larger predatory fish that fuel the most valuable commercial and recreational fisheries.

The first sustained effort to manage forage fish as forage, and not merely as another stock to be harvested, probably occurred at the Atlantic States Marine Fisheries Commission about 20 years ago, and culminated with the adoption of Amendment 1 to the Interstate Fishery Management Plan for Atlantic Menhaden in 2001. 

Prior to that amendment, menhaden management at ASMFC was dominated by representatives of the industrial menhaden fishery, who controlled both the scientific bodies that assessed the health of the menhaden stock and the management board that set annual quotas and other limitations on menhaden landings.  The new Amendment 1 was intended to end the foxes’ long tenure as guardians of the henhouse, and pass management responsibility to a board composed of state fishery managers and other representatives of every state throughout the Atlantic menhaden’s range, a change that substantially diluted, but did not end, the industrial fisheries’ influence over menhaden management.

Eighteen years later, the tension between conservation interests, small-scale menhaden fisheries and the industrial fleet continue, but the playing field has been leveled considerably.  While the industrial fleet still has a greater than ideal influence on menhaden management, forage fish advocates have gained a lot of ground—so much ground, in fact, that scientists are now preparing an “ecological-based” stock assessment that should be completed and presented for peer review before the end of this year. 

Unlike traditional single-species stock assessments, the ecological-based menhaden assessment will gauge the health of the menhaden stock, and the efficacy of management measures, based not only on the stock’s ability to sustain itself at present harvest rates, but also on its ability to fully perform its role in the ecosystem, as one of the most important forage species on the East Coast.

Assuming that such assessment passes peer review, ASMFC’s Atlantic Menhaden Management Board is expected to propose abundance/fecundity and fishing mortality reference points that reflect the menhaden’s important ecological role.  It is very likely that, if such reference points would result in appreciably reduced landings, the industrial fleet will try to block their implementation, and it could even be successful in doing so.  However, the mere fact that ecological reference points are even being considered is a sign of how far forage fish management has progressed in the past two decades.

Of course, the forage fish harvesters aren’t sitting on their haunches waiting to see their landings cut.  Omega Protein, the U.S. affiliate of Cooke Inc. a large Canadian aquaculture company, is trying to buy respectability for its industrial menhaden operations by seeking Marine Stewardship Council certification that such fishery is sustainable. 

The initial report from the Marine Stewardship Council’s consultant, SIA Global, was generally favorable to Omega, advising that

“the assessment team has provisionally recommended that the Atlantic menhaden purse seine fishery is eligible to be certified pursuant to the MSC Principles and Criteria for Sustainable Fishing subject to the Conditions and related corrective actions outlined in this report.  [emphasis added]”

However, it’s notable that all three of the “Conditions and related corrective actions” referred to address menhaden’s ecological roles.  They require that Omega

“provide evidence of the implementation of a harvest strategy that is designed to take into consideration the ecological role of Atlantic menhaden and is responsive to the state of the stock with respect to its role in the U.S. Northwest Atlantic ecosystem,” and

“provide evidence of the implementation of well-defined harvest control rules that take into consideration the historical role of Atlantic menhaden as key low trophic role in the U.S. Northwest Atlantic…”

and that

“There shall be a regular review of the potential effectiveness and practicality of alternative measures to minimize the [unit of assessment]-related mortality of [endangered threatened and protected] species and they are implemented as appropriate…”

Even with those conditions added to the report, a number of angling and conservation organizations are challenging the recommendation of provisional certification, because they understand that the health of forage stocks are important.

Some federal fishery managers have also acknowledged the importance of forage fish.  Both the Pacific Fishery Management Council and the Mid-Atlantic Fishery Management Council have adopted management measures intended to protect the health of unfished and otherwise unmanaged forage fish stocks. 

The problems begin to arise when forage species, such as Atlantic herring or Atlantic mackerel, already support significant directed fisheries.  At that point, as in the case of menhaden, individuals and companies have made significant investments in order to prosecute such fisheries.  Shifting management of such fish from a single-species approach to one that incorporates their forage role in the ecosystem would cause at least some economic dislocation for those involved in the fisheries, and so such interests tend to aggressively oppose ecosystem-based approaches.

A few years ago, an organization known as IFFO (2012) Ltd., which calls itself “the marine ingredients organization,” even provided funding and information to a team of researchers who undertook to demonstrate that today’s industrial fisheries for forage fish do no appreciable harm to marine ecosystems.

Thus, conservation advocates have a difficult job ahead of them when they try to preserve already-fished forage fish stocks.  That became obvious when the Mid-Atlantic Fishery Management Council ran into strong industry opposition to including chub mackerel in its forage fish amendment, due to a recent spike in chub mackerel landings off the U.S. East Coast.  Such industry opposition also manifested itself in the four-year fight to keep large mid-water trawls, which targeted Atlantic herring, at least 12 nautical miles from shore, in order to avoid local depletion of forage fish stocks needed to attract and hold various other fish targeted by a wide array of recreational and commercial fishermen.

While both chub mackerel and Atlantic herring are targeted in directed fisheries, other forage species that are incidentally caught also suffer in the offshore trawl fisheries.  River herring, a term that encompasses both the alewife and the blueback herring, American shad and hickory shad are thought to be victims—collateral damage, if you will—of such industrial fishing efforts.  Populations of all four species have fallen sharply from levels typical in the mid-1900s.

During much of 2015 and 2016, the Mid-Atlantic Fishery Management Council debated managing shad and river herring as part of its Atlantic Mackerel, Squid and Butterfish Fishery Management Plan.  In the end, it declined to do so, but did place caps on shad and river herring bycatch in the Atlantic Mackerel fishery, that result in the directed mackerel fishery being closed once the catch cap is caught.

The New England Fishery Management Council also placed caps on the incidental catch of such species in the Atlantic herring fishery. 

Despite such measures, shad and river herring populations are showing few signs of recovery, leading various conservation groups to conclude that stricter management is needed.  In 2011, the Natural Resources Defense Council submitted a petition to have both species of river herring listed under the Endangered Species Act.  Although that original petition was denied, the lack of much important information led the National Marine Fisheries Service to schedule another review of the stocks’ status, which was just released a few days ago. 

NMFS has again decided against listing either species of river herring under the Endangered Species Act, having determined that the likelihood of extinction for either species, when viewed either across their entire range or with respect to a distinct population segment, is generally low.  The probability that NMFS will adopt any additional measures to protect shad and river herring in federal waters is low, as well.

However, river herring, and forage fish generally, have one additional shot at protection.

Last April, Rep. Debbie Dingell (D-MI) introduced H.R. 2236, the Forage Fish Conservation Act, in the House of Representatives.  So far, the bill has attracted 14 cosponsors, which are almost equally divided between the Democratic and Republican parties, although no companion bill has yet been introduced in the Senate.  

H.R. 2236 would, among other things, require federal fishery managers to consider forage species’ ecological role when determining the optimum yield from each fish stock, and require each regional fishery management council’s Scientific and Statistical Committee to make recommendations to such councils on maintaining an adequate forage fish population.

H.R. 2236 would also prevent the creation of new fisheries for unmanaged forage fish stocks unless and until the relevant regional fishery management council has determined how such new fishery would impact the forage fish stock, has decided whether such stock is in need of conservation and management and, if conservation and management is needed, has developed a fishery management plan.

In addition, H.R. 2236 would require that federal fishery management plans be created for shad and river herring.

It’s difficult to predict the bill’s fate right now.  While it contains some very good and valuable provisions, it will undoubtedly be opposed by fishermen who fear that it will negatively impact existing forage fish fisheries, and so do harm to both individual fishermen and fishing communities.

On the other hand, it is likely to receive support from at least some members of the conservation community, and from recreational and commercial fishermen who believe that, by protecting forage fish stocks, the bill will have a positive impact on the larger fish that they pursue.

Whatever H.R. 2236’s ultimate fate, it’s clear that forage fish are a hot topic in fishery management right now, and there is no sign that such topic will cool off at any time soon.

And, given the importance of forage species, that is a very good thing.