MANAGING MENHADEN: WILL THE ASMFC LIVE UP TO LAST AUGUST'S PROMISE?

 

Two months ago, I wrote about a big step forward in menhaden management that was taken by the Atlantic States Marine Fisheries Commission.  That’s when its Atlantic Menhaden Management Board decided to adopt so-called “ecological reference points” that gauged the health of the menhaden stock, and the size of the menhaden harvest, not merely on whether the landings themselves were sustainable in the long term but, instead, on whether the menhaden biomass was sufficient to provide adequate forage for the predators that typically depend on that species for food.

It was an action that many marine scientists have been recommending for a very long time, not just for menhaden, but for all species of “forage fish,” the low trophic level species that, in their historic abundance, provided food not only for more sought-after and more valuable recreational and commercial fish species, but for seabirds and marine mammals as well.

Because so many different predator species depend, to a greater or lesser degree, on Atlantic menhaden, it was practically impossible for biologists to design a model that accounted for all predator species.  Instead, because striped bass were the fish species most dependent on menhaden, and because a menhaden population that supported striped bass would be adequate to support the other predators, menhaden managers used bass as a proxy, setting the target menhaden biomass at a level that would support a striped bass population at its target abundance, and setting the threshold menhaden biomass at the corresponding level that would support a striped bass population that lay just at the threshold of becoming overfished.

It seemed like a watershed in forage fish management, but as I warned two months ago, the value of the ASMFC’s actions on menhaden can’t really be judged by what the Management Board said it would do, managing menhaden to the new target reference points, but must instead be evaluated according to what the Management Board actually does when the time comes to set new harvest limits for 2021.

On the morning of Tuesday, October 20, the ASMFC’s Atlantic Menhaden Management Board will face that test:  Will it do what it had promised when it adopted the ecological reference points two months ago, and manage menhaden as one of the most important forage fish on the coast?

Or will it go back on its word to the public, ignore the actions that it took late last August, and return to managing menhaden as if it were just another industrial commodity, to be torn from the water, reduced into fish meal and oils, which will be fed to chickens and used as feed in salmon farms—themselves ecologically suspect—on the eastern Canadian coast?

Right now, I want to believe that the Management Board, which unanimously adopted ecological reference points less than ten weeks ago, is committed to that decision, and will set 2021 menhaden landings at a level that has at least a 50 percent probability of constraining such landings to the target level.  

Right now, I’d bet that, in the end, they’ll do the right thing.

But I’ll also admit that if I had to lay any real money on the line, I wouldn’t be particularly comfortable about that wager.

Although the ecological reference points have widespread support among anglers, academics, and the conservation community, there are powerful industry forces that aren’t committed to their use.  For example, after ecological reference points were adopted last August, the Virginia-based Daily Progress reported that

“The commercial fishing industry, which is dominated by Virginia-based Omega Protein, is anxious to ensure that the catch limit for Atlantic menhaden remains at its present level of 216,000 metric tons…

“In a letter sent to the ASMFC July 28, the Menhaden Fisheries Coalition offered support for the ecological reference points ‘provided they are considered and utilized flexibly.’  The members also in the same letter urged the board to consider maintaining the status quo when it comes to catch limits.”

As readers of this blog ought to realize by now, when people talk about “flexibility” in a fisheries management context, what they mean is postponing, ignoring, or otherwise getting around science-based management measures, in order to profit from larger short-term landings while placing the long-term health of fish stock at risk.

That’s certainly true in this case.

The Menhaden Fisheries Coalition reportedly offered support to the ecological reference points.  Yet, in order to have at least a 50 percent probability of not exceeding the ecological reference points’ fishing mortality target, 2021 menhaden harvest could not exceed 176,800 metric tons, which would represent a 40,000 metric ton reduction from the 2020 menhaden catch limit. 

That’s where the flexibility comes in:  The Coalition is willing to support the idea of ecological reference points, so long as no one actually takes such reference points seriously and applies them in a way that might meaningfully constrain landings. 

That’s reflected in the Coalition’s recent comments on the 2021 harvest limit where, in an impressive bit of doubletalk, it says

“The Menhaden Fisheries Coalition has supported and continues to support management of menhaden to maintain both the fishery itself (and those who depend upon it) and the stock’s role in the ecosystem.  More specifically, the Coalition supports the use of current [ecological reference points] fishing mortality rate (F) target, which the Board adopted at the August 2020 meeting.

“The primary issue facing the Board next week is the trade-off in term of foregone allowable catch to marginally increase the certainty with which the target will be achieved.  For example, to get to a 50 percent certainty, it would require nearly a 20 percent cut in menhaden [total annual catch]…we do not believe the benefits of increased certainty outweigh the negative impacts that would result…”

In other words, the Menhaden Fisheries Coalition supports the ecological reference points, so long as no one actually uses them to manage the fishery.

That sort of comment could be expected from a trade association trying to protect its profits, and looking through the comments sent to the Management Board, represents what is clearly a minority view.  

Unfortunately, the notion that managers should ignore the target reference points was the majority view of the ASMFC’s Atlantic Menhaden Advisory Panel, where seven out of the twelve panel members commenting on the issue thought that the Management Board shouldn’t try to constrain 2021 harvest to a level that would have at least a 50 percent chance of keeping fishing mortality within the target.

Such advisors made comments like

“Given the precautionary nature of previous [total annual catch] decisions, which resulted in F below the ERP F target in recent years, a risk of 66% of exceeding the ERP F target will not adversely impact the role menhaden play in the environment.”

That is certainly an odd bit of logic, as the 2021 harvest limit would be based on the current menhaden biomass, which already reflects any benefits bestowed by “previous TAC decisions.” 

And

“It is overly precautionary to set the TAC for menhaden based on the risk of exceeding the ERP F target.  For example, the federal risk policy for setting an acceptable biological catch (ABC) is based on the risk of exceeding the overfishing limit (OFL), a value akin to the ERP F threshold; status quo has a 0% chance of exceeding the F threshold in both years,”

which is remarkable for throwing around a lot of loosely related fisheries management concepts in an attempt to prove a very dubious point.  

If one wants to bring federal fisheries management concepts into the debate, the most obvious candidate for mention—which that commenter clearly ignored—was the concept of “optimum yield,” which is defined in the Magnuson-Stevens Fishery Conservation and Management Act as

“the amount of fish which—will provide the greatest overall benefit to the Nation, particularly with respect to food production and recreational opportunities, and taking into account the protection of marine ecosystems; is prescribed by such on the basis of maximum sustained yield from the fishery, as reduced by any relevant economic, social, or ecological factor; and in the case of an overfished fishery, provides for rebuilding to a level consistent with producing the maximum sustainable yield from such fishery.  [emphasis added; internal formatting omitted]”

In light of that definition, it would seem clear that the ecological reference point fishing mortality target for menhaden, which is intended to protect marine ecosystems, and reduces landings from something closer to maximum sustainable yield to landings optimized to address ecological factors, is very probably equivalent to what “optimum yield” for menhaden would be under the federal management system.  References to ABC and OFL, which are primarily concerned with overfishing in a single-species, rather than ecosystem-based, management model, are irrelevant to the discussion.

Even so, there is a high likelihood that at least some members of the Management Board will prove sympathetic to such arguments, particularly the argument that

“The TAC should remain status quo particularly during this time of economic crisis due to the COVID-19 pandemic.  Additionally, harvest in 2020 will be well below the TAC due to lost fishing opportunity thus providing another buffer to the fishery.”

Various ASMFC management boards have, in the past, been prone to elevate short-term economic concerns above the long-term health of fish stocks, and it isn’t hard to envision some members of the Atlantic Menhaden Management Board swayed by an argument rooted in the real economic hardships caused by COVID-19.  If the majority of the Management Board feels that way, it’s easy to picture them supporting the long-term health of the various Atlantic coastal ecosystems at greater risk in order to increase economic returns to the handful of fishermen involved in the large-scale menhaden harvest.

Hopefully, that won’t occur this time.

Hopefully, the majority of Management Board members, who gave broad support to ecosystem reference points two months ago, will do so again, and set a 2021 harvest limit no higher than the 176,800 metric tons that will provide a 50 percent chance of achieving the management target.

For if they fail to do that, and instead ignore their own recent management actions in order to please the industrial menhaden fleet, they will not only throw away the most promising forage fish management action seen in the United States to date.  They will have broken faith with a public who believed that the ASMFC had taken an important and meaningful action, only to see it ignore the clear provisions of a management plan once again.