SOME THOUGHTS AT THE START OF SHARK SEASON

 

I’ve been a participant in the northeastern shark fishery for a very long time—more than 45 years, if I start counting from my first shark charter out of Rhode Island, about 40 years if I only consider trips where I ran my own boat. 

It's been even longer if I count one outing back in the late 1960s when, after seeing two big sandbar sharks caught by anglers off the southwest Connecticut coast, a friend and I wired the two biggest hooks we could find onto a water ski towrope, nose-hooked a bunker onto each of them, tied a rock to the rope for weight, and began slow-trolling that misbegotten rig off the Greenwich shoreline from a 10 ½-foot plywood skiff.  The idea was that, when we hooked a shark, it would tow us around until it was exhausted, at which point, we would drag the fish up on a local beach.  Unfortunately—or so we thought back then—our enterprise never reached the Nantucket sleighride stage.

The bottom line is that, for most of my life, when I had some free time, there was a very good chance thaat I was somewhere out on the ocean fishing for sharks.

Most of those somewhere have been off Long Island, usually fishing out of Fire Island Inlet, although there were some memorable trips out of Montauk and Rhode Island, as well.

As one might expect, the shark fishery has changed over the years.

The two biggest changes are a general decline in the number of sharks that we find, and in the species mix of the fish that we catch.

In the ‘80s, most people started to chase sharks sometime around the beginning of June, although some began in late May.  The May fishing was notoriously slow; anglers normally caught nothing but bluefish, although a few blue sharks, even fewer threshers, and the occasional mako or white shark would sometimes show up in the slick.

Well before I started fishing for sharks—in the 1950s and ‘60s—Long Island May run of porbeagle sharks, a species related to makos and whites, which are particularly fond of cool water.  The 1971 book Sportfishing for Sharks, by the late Capt. Frank Mundus and writer Bill Wisner, noted that

“In numbers, porbeagles exceed makos and maneaters [a/k/a white sharks], and they appear to have a greater tendency to group more than most other sharks.  In that respect they may be second only to the blues.  When they’re visiting a region, therefore, it’s possible to contact them with frequency.  The Cricket II [Capt. Mundus’ Montauk-based charterboat] has docked with as many as six or eight caught during a single sailing.”

By the time I made my first Montauk shark trip in 1982, such porbeagle abundance was a thing of the past.  Norwegian longliners began to target porbeagles during the 1960s, and quickly drove down their numbers.  Although there is no longer a directed longline fishery for porbeagles in the western Atlantic, the population has been recovering very slowly and remains overfished, although overfishing is no longer occurring.  Where Capt. Mundus sometimes brought six or eight porbeagles back to Montauk in a single trip, fewer than that are now landed on Long Island over the course of an entire season.  The landing of even a single fish is newsworthy.

Thus, by the time I began running my own boat out of Fire Island Inlet, shark season didn’t really get underway until early June, when swarms of blue sharks appeared in local waters.  I usually started to target sharks when surface temperatures rose above 60 degrees, but the blues could tolerate cooler water.  I still recall one June day when I ran out to the 40 fathom line, about 40 miles south of Shinnecock.  The surface temperature was only 55 degrees, and I had my doubts about what we might catch, but we ended up having one of those days when fish hit the baits as soon as the baits hit the water, we ran out of bait and almost out of hooks, and when we were ready to leave, the water beneath the boat looked like some sort of National Geographic special, with a dozen fish cruising around almost close enough to reach out and touch.

We still see blue sharks off of Long Island, and sometimes still run into swarms.  But that happens less than it used to.  My last June trip south of Shinnecock saw only four blue sharks take our baits, in a time and place where I might have expected to catch a dozen or two just a decade ago.  

A 2015 stock assessment found that the blue shark was neither overfished nor experiencing overfishing, but admitted that there was significant uncertainty in the assessment’s results.  While blue sharks don’t support a directed commercial fishery, many are caught and killed as bycatch in pelagic longline fisheries targeting other species, which led the International Commission for the Conservation of Atlantic Tunas to adopt a North Atlantic quota of 39,102 metric tons in 2019.  It was the first blue shark quota ever adopted by ICCAT.  Although such quota represented a meaningful step forward, some conservation organizations believe that it was too high to provide meaningful protection for the blue shark resource.

Then there are makos, the porbeagle’s swift, beautiful, and acrobatic relative.  Even back in the glory days of offshore fishing, when tuna, marlin and swordfish were frequently encountered relatively close to shore, and most sharks were viewed as trash fish, the shortfin mako was revered as a worthy adversary for the blue water angler.  When I started fishing for sharks, most Long Island anglers talked about “going out for makos,” rather than “going shark fishing.”

The first mako of the season usually hit the scales around Memorial Day, and by the first weekend in June, anglers were bringing in quite a few fish.  The last two weeks of June and the first week or two of July were the peak season, with multiple tournaments run out of just about every port between East Rockaway and Montauk.  There was also a steady pick of fish throughout the summer, with makos over 200 pounds regularly caught even in the dog days of August.  In the fall, makos would follow the bluefish, their favorite food, and often appeared in chum slicks through early November.  On most shark trips, we’d see at least one, even if that one was small, and we’d often catch multiple makos in a single day.  Less than ten years ago, we had a 6-mako day fishing just 20 miles ESE of Fire Island Inlet.

Unfortunately, it’s all been downhill since.  A recent ICCAT stock assessment found shortfin makos to be in serious trouble, and late last year, ICCAT prohibited all mako landings.  The National Marine Fisheries Service is completing work on a regulation that will prohibit mako landings in United States waters, which is expected to be released very soon. 

Even so, recovery of the mako stock will probably take 50 years.

That might seem like a long time, but it is far shorter than the time it will take to rebuild dusky sharks, which once were abundant south of Long Island.  During the '80s, small duskies regularly invaded bluefish slicks inside the 20-fathom line.  We caught them while chunking for tuna in the Mud Hole, east of New Jersey.  Truly large duskies—fish over 500 pounds—were far from unknown.  But the fish were--and still are--extremely vulnerable to longlines.  They were killed by bottom longlines set for shark, and they were killed by pelagic longlines targeting swordfish and tuna.  

The population collapsed.

In 2017, the National Marine Fisheries Service finalized a rebuilding plan intended to restore the population by 2107—a full 90 years.  The conservation group Oceana believed that the rebuilding plan won’t get the job done, and challenged it in court.  However, earlier this week, the Federal Court of Appeals for the D.C. Circuit rejected such challenge, finding that NMFS’ rebuilding plan met all of the applicable legal standards. 

Still, no one living today--except a few that are still wearing diapers--will ever see what a healthy dusky shark population looks like. 

At the same time, there's some good news.

The same Sportfishing for Sharks book that I mentioned before states that

“You could go the full route of your shark-hunting career without ever contacting a thresher…It has been our experience that threshers seldom are what could be called abundant.”

That statement might have been true in 1971, but it’s certainly not true today.  Two people I know have already caught threshers this season, and from now into the middle of July, I fully expect to hook up to a thresher any time that I set up a chum slick.  It doesn’t happen on every trip, but it happens often enough that I rarely fish anything lighter than 50-pound line these days; a 4 ½-hour fight with a 400-pound thresher a few years ago convinced me to leave the 30-pound stuff at home.

Part of the reason we’re seeing more threshers is the abundance of baitfish; in recent years, we’ve seen far more menhaden off Long Island than we’ve seen before.  The threshers will follow the menhaden schools right up to the beach; quarter-ton fish have been caught in just 40 feet of water.  We’ve also been getting an influx of chub mackerel, which bring in the threshers.  When the chub mackerel swarm, the odds of hooking a thresher spike.

The population may also be growing, but no one knows for sure, because a stock assessment has never been performed; however, ICCAT considers common threshers to be one of the shark species that is least impacted by pelagic longlines, which is clearly a good thing.  Data is providing mixed signals, and depending on how it is interpreted, provides reason to believe that common thresher abundance remains in decline, has stabilized at relatively low levels, or is slowly increasing. 

Whatever the state of the stock, anglers seem to be seeing more of them.  A recent paper reported that, at one major shark tournament, the proportion of threshers caught increased from 0.1% in 1965 to 4.8% in 1995, then rocketed up to 27.8% in 2004.  Whether that increase reflects a greater abundance of threshers or a decline in the abundance of other species is not completely clear.

The number of sandbar (“brown”) sharks also seems to be on the rise.

There were a lot of them around years ago—enough to reach into western Long Island Sound, and capture my 14-year-old imagination, back in 1968.  We caught a lot of them in the 1980s, too, until they fell victim to bottom longlines and became scarce off Long Island.  But as soon as they were put on the “prohibited species” list, and could no longer be retained by commercial or recreational fishermen, we started to see abundance increase.  Although there probably aren’t yet as many around as there were 40 years ago, few days go by when we don’t catch at least one. 

Another fish that is becoming more abundant is the white shark, although there were always a few swimming off Long Island.  Back in ’82, we were fishing about 30 miles south of Montauk on a calm August day when a 15-foot white shark popped up next to my 20-foot outboard.  It was sobering to think that, at around 2,500 pounds, that fish easily outweighed our boat and all it contained--including us.  Although that shark remains the largest white that I ever saw, I’ve seen a few others that weren’t much smaller.  But recently, we're also seeing quite a few juveniles, little sharks six or so feet long, weighing less than 200 pounds.

That, too, is a good sign.

And then there are the “summer sharks.” 

While we seem to run into fewer tiger sharks than we did years ago, tigers are a “data-poor” species, so we can’t say whether the population is in decline.  Some NMFS data shows a steady decline in both Atlantic commercial tiger shark landings and recreational catch, which seems to suggest that abundance is not what it was.

We’re catching about as many hammerheads, mostly smooth hammerheads, as we ever did, but seeing fewer of them cruising on the surface, probably because we’re rigging and setting out baits a little differently than we used to.  There is no doubt that hammerhead abundance is not what it was, as all three major hammerhead species were hit hard by commercial fishermen who sought their valuable fins, which are sold in China and used to prepare shark fin soup.

The same smaller baits, fished close to the surface, are also attracting spinner sharks, a southern species that is new to Long Island waters.  Even a dozen years ago, catching a spinner shark was rare.  Now, there are drone videos showing large numbers of spinners actively feeding on menhaden schools.  The appearance of spinners is clearly attributable to a warming ocean, but an increasing abundance of bait is also part of the equation.

So, what does it all mean?

The biggest takeaway is the same message that applies to most of our other fisheries.  We shouldn’t take current abundance for granted, and we should turn our backs on old practices, which saw fishermen regularly killing sharks that weren’t wanted for food, such as large tigers, hanging them on a scale, and then dumping them back in the water or trucking to a landfill.  There’s no room in today's increasingly pressured ocean for kill tournaments that offer prizes for fish that end up feeding the flies, rather than the angler who caught it.

It means that we shouldn’t be trapped by the shifting baseline syndrome, which tempts us to view today’s reduced abundance as normal, and forget what healthy shark populations looked like.  It also means that we should acknowledge our responsibility to those not yet born, and do what we can to rebuild depleted shark stocks, even if we won’t be around to enjoy the fruits of our efforts.

But it doesn’t mean that we ought to abandon the fishery.  Instead, we must approach it with respect for the fish, and perhaps even with an eye toward helping researchers with their work through tagging programs, or perhaps by providing a platform that scientists can use to conduct their own studies.

The shark fishery has provided a lot of enjoyment over the years.  As this season starts, it is only right that we, in return, do what we can to ensure it a future.

A HUDSON CANYON MARINE SANCTUARY: HOW WOULD IT IMPACT ANGLERS?

 

Last week, President Biden announced that he was considering designating Hudson Canyon as a National Marine Sanctuary.  That announcement undoubtedly worried many blue water fishermen, who reasonably wondered, “What does that mean for us?”

Right now, the only answer to such question is, “It’s hard to say.”

Hudson Canyon is the largest submarine canyon on the East Coast.  It is essentially the mouth of the Hudson River, as it flowed at the end of the Ice Age, when much of the Earth’s water was tied up in glaciers, and the sea’s level was more than 300 feet lower than it is today.  As the last—the Wisconsian—glacier retreated, roughly 15,000 years ago, the torrent of meltwater flowing down the newly freed river carved a deep cut in the edge of the continental shelf.  

As melting glaciers throughout the world poured more water into the ocean, the sea level rose and created the coastline that we see today.  The Hudson River’s submerged channel remains etched into the bottom; places offshore fishermen know as the “Mud Hole,” “Glory Hole,” “Chicken Canyon,” and the Hudson Canyon itself are merely waypoints that the ancient river passed on its way to an older sea.

Today, Hudson Canyon is a place where nutrient-rich deep-ocean waters collide with the continental shelf, mix with warm surface waters, and create prime feeding conditions for baitfish and, in turn, for pelagic predators such as marlin, tuna, swordfish, and sharks.  It would not be much of an exaggeration to say that Hudson Canyon may be the best-known, and most heavily fished, offshore destination in North America, given its proximity to New York City and to ports from southern New Jersey to eastern Long Island, Connecticut, and even Rhode Island.

Thus, fishermen are right to worry whether a National Marine Sanctuary designation might affect their ability to access Hudson Canyon, and deny them access to that traditional fishing ground.

The good news is that current law permits fishing, including commercial fishing, in national marine sanctuaries.  The bad news is that the same law also allows all fishing to be banned, and permits regulations to prohibit some kinds of fishing while countenancing others.  

Whether and how fishing is regulated in any future Hudson Canyon Marine Sanctuary will depend, in large part, on what such sanctuary is created to protect, and in the comments made and political pressures applied during the designation process.

The Wildlife Conservation Society—the organization that operates the New York Aquarium and the Bronx Zoo, among other enterprises—is the primary advocate for the creation of a Hudson Canyon Marine Sanctuary.  On its webpage, the Society explains,’

“By designating the Hudson Canyon a National Marine Sanctuary, NOAA would be advancing community-led conservation of nationally significant marine wildlife and their habitat, while also providing research and STEM education opportunities.  Sanctuary designation has an opportunity to provide a wide range of benefits for New York and New Jersey residents and for the diversity of marine wildlife in Atlantic waters.  To help protect this ecological treasure, WCS recommends that a Sanctuary Designation

·        Permanently preclude offshore oil, gas, and mineral exploration and development in the canyon

·        Maintain healthy populations of fish and other wildlife

·        Ensure a future for sustainable fisheries under existing regulatory authorities

·        Support the tourism industries that depend on healthy ocean ecosystems

·        Increase federal investment in biological and ecological research and monitoring—including the impacts of climate change on ocean life and resources, and collaborative research with fishing, shipping, and offshore wind industries

·        Identify and protect cultural resources and history

·        Expand opportunities for STEM education, community management, and workforce development, especially for historically under-represented communities

There’s nothing in that list of purposes/benefits that would suggest that angling, or for that matter, any sort of fishing, would be threatened by a marine sanctuary designation.  In fact, the language about maintaining sustainable fisheries “under existing regulatory authorities,” as well as that supporting “tourism industries that depend on healthy ocean ecosystems,” suggest that recreational fishing would continue in the Hudson Canyon National Marine Sanctuary, should such sanctuary ultimately be created.

However, even though the Wildlife Conservation Society kickstarted the designation process, it does not control the process’ outcome.  Just because the Wildlife Conservation Society does not wish to prohibit fishing doesn’t mean that such prohibitions can’t be put in place.  In fact, NOAA’s Office of Marine Sanctuaries describes the “primary goals” of the proposed Hudson Canyon sanctuary somewhat differently than the WCS does, saying

“The primary goals of the proposed national marine sanctuary designation are to 1) support conservation of the area’s marine wildlife, habitats, and maritime cultural resources, 2) work closely with Indigenous Tribes and Nations to identify and raise awareness of Indigenous connections to the area, 3) highlight and promote sustainable uses of the area, 4) expand ocean science and monitoring in, and education and awareness of the area, and 5) provide a platform for collaborative and diverse that support effective and inclusive long-term management of the area.”

One might note that the Wildlife Conservation Society’s references to “sustainable fisheries under existing regulatory authorities” and “tourism industries that depend on healthy ocean ecosystems” do not appear anywhere among the agencies “primary goals,” although optimists can argue that the intent to “highlight and promote sustainable uses of the area” embraces similar themes.

Realists might observe that no-take marine protected areas have long been embraced by elements of academia and the marine conservation community, and that the creation of a Hudson Canyon National Marine Reserve will offer such individuals an opportunity to advocate for a prohibition on any sort of fishing.  While, under certain circumstances, closed areas may provide quantifiable fishery benefits, no one has yet adequately explained how closing a discrete area such as Hudson Canyon to fishing for highly migratory pelagic species, which can and do travel for miles in a single day, following preferred bait and favorable ocean conditions, would provide meaningful benefits to either the fish or to fishermen. 

Even so, a recently published paper recommends that the government

“Establish new highly and fully protected, networked MPAs with better representation of U.S. marine biodiversity, regions, and habitats…Fully and highly protected MPAs are overwhelmingly concentrated in the Central Pacific.  These large MPAs have immense value and should be celebrated.  However, the disproportionate share of MPA stewardship by Pacific Islanders in the U.S. and associated territories should be recognized and rectified by increasing the share of highly and fully protected MPAs in diverse ecosystems elsewhere in the U.S.  This action is imperative, not only to achieve effective protection for biodiversity but to bring the benefits of MPAs within reach of diverse communities.  [emphasis added]”

It’s not difficult to imagine those holding such an opinion viewing the creation of a Hudson Canyon National Marine Sanctuary as the perfect opportunity to create one of their favored “highly and fully protected MPAs”—a place where fishing is very strictly restricted if not fully outlawed--and to “bring the benefits of MPAs within reach of diverse communities,” whether such communities want an MPA or not.

So, again, fishermen need to be wary.

At the same time, fishermen ought to look at other East Coast marine sanctuaries, to get an idea of the range of restrictions that might be imposed. 

Stellwagen Bank National Marine Sanctuary, which lies off the coast of Massachusetts, sits at one end of the spectrum.  Commercial and recreational fishing are both permitted there, although a revised management plan for the sanctuary, now under development, notes that

“Data suggest measurable degradation of habitat quality over the past ten years, primarily due to direct impacts of commercial fishing…In addition to adverse impacts on whales and other important focal species, incidental contact with fishing gear has impacted nearly every maritime heritage resource in SBNMS, reducing their historical, archaeological, scientific, or educational value.”

Such language suggests that additional restrictions on commercial fishing activities might eventually be put in place.  However, nothing in the proposed, revised management plan suggests that recreational fishing activity will be curtailed.  Current recreational fishing activity within the sanctuary is substantial, accounting for about 25% of all recreationally-caught cod in the Gulf of Maine; private boats fishing within its boundaries account for about 117,000 angler-days of fishing activity, and about $6 million in related spending, each season.

If the proposed Hudson Canyon National Marine Sanctuary was managed like Stellwagen Bank, anglers would have nothing to fear.  However, it’s worth noting that the same scientific paper mentioned earlier describes the Stellwagen Bank National Marine Sanctuary as a “minimally protected” area, and notes with apparent disapproval that it allows

“large impacts from human activities like fishing.”

Thus, any attempt to adopt Stellwagen-like management measures for the proposed Hudson Canyon National Marine Sanctuary would probably meet with some degree of opposition from the preservationist wing of the conservation community.

At the other end of the marine sanctuaries spectrum lies the Florida Keys National Marine Sanctuary.  Although the Keys Sanctuary allows angling in some of its waters, it also includes areas where all fishing is prohibited, and other areas where angling is limited to catch-and-release trolling, in order to protect coral reef communities.

Whether fishing is prohibited, and how fishing is regulated, depends on the designations given to specific areas within the Marine Sanctuary, which features five different kinds of “Marine Zones.”  The most exclusive of those zones are the “Ecological Reserves” and “Special Use Areas,” where no fishing of any kind is allowed.  Slightly less restrictive are the “Sanctuary Preservation Areas.”  Fishing is generally prohibited in those areas, too, although four of them do permit catch-and-release trolling; surprisingly, fishing for bait, provided that the fisherman holds the appropriate Sanctuary Permit, is allowed in all of the Preservation Areas.  Finally, there are the “Wildlife Management Areas” and “Existing Management Areas,” all of which allow angling, and often commercial fishing, in some form, although there may be restrictions on the gear used, on vessel speeds and propulsion modes, etc.

Florida Keys Marine Sanctuary-like regulations, if applied to the Hudson Canyon, might or might not be problematic.  Few sport fishermen would care if commercial fishing was restricted, or if certain gear, such as longlines or trawls, were prohibited in order to better protect turtles, marine mammals, or sensitive bottom habitat, although some General Category HMS Permit holders, who claim to be anglers but end up selling their catch, might end up a bit perturbed if commercial harvest was outlawed.

But if all, or even a section, of Hudson Canyon was put off-limits to anglers, either because it was declared a research area (a “Special Use Area,” in the parlance of the Florida Keys Sanctuary) or an Ecological Reserve, recreational fishermen could experience real harm.  Even mandatory catch-and-release in all or part of Hudson Canyon, as in the Florida Keys’ “Sanctuary Preservation Areas,” would be a very tough sell to just about everyone in the canyon tuna fleet.

Right now, it’s impossible to predict what a Hudson Canyon National Marine Sanctuary might look like.

It might look like Stellwagen Bank.  It might look like the Florida Keys.  Given the pressure to create “highly or fully protected” marine protected areas on the East Coast, it might look even worse.

However, given that five years has passed since Hudson Canyon was first nominated as a National Marine Sanctuary, and given that neither the Trump nor the Biden administration has yet derailed the designation effort, there is a very good chance that a Hudson Canyon National Marine Sanctuary will eventually be created.  The offshore angling community is thus well advised to get involved in the designation process now, to best assure that when and if such sanctuary is created, its creation will not do material harm to recreational fishermen.

On June 8, the Office of Marine Sanctuaries announced the beginning of a two-month public scoping period, which is intended to give interested parties an opportunity to provide comment on the proposed marine sanctuary.  As such Office states,

“This is a critical step in NOAA’s consideration to move forward with the process. Should designation proceed, scoping comments also assist NOAA in its future development of sanctuary designation documents, including a draft environmental impact statement, draft management plan, and proposed rulemaking.”

Scoping comments will be accepted through August 8.  They may be submitted in writing, electronically, or at any of the four online and in-person meetings that will be held before the close of the comment period.

More information can be found at https://sanctuaries.noaa.gov/hudson-canyon/.

Anyone who fishes blue water, and leaves from any port between Cape May and Pt. Judith, would be foolish not to make their thoughts known.

MID-ATLANTIC COUNCIL, ASMFC ADOPT MODIFIED "HARVEST CONTROL RULE"

 

Over the past year or so, I have been writing about something that the Mid-Atlantic Fishery Management Council and Atlantic States Marine Fisheries Commission have deemed a “Harvest Control Rule” that would change the way that the recreational bluefish, summer flounder, scup, and black sea bass fisheries will be managed.

The Harvest Control Rule sounds good on paper.  The idea is to expand the criteria currently used to manage recreational fisheries from merely catch and landings estimates derived from the Marine Recreational Information Program, which are compared to the next season’s recreational catch or harvest limits, to things like stock status, biomass trends, and recruitment.  As I’ve noted before, it might even prove beneficial in practice.  The problem is that it is being rushed through the management process, before scientists can determine how its use will impact fish stocks.

The Council’s Scientific and Statistical Committee reviewed the Harvest Control Rule at the request of the Council and ASMFC, and found that it lacked the information needed to determine the impacts of such control rule (which, the SSC determined, wasn’t really a control rule at all, but that’s a separate discussion) on managers’ ability to prevent overfishing or rebuild stocks to, or maintain them at, the biomass target.  

Council staff prepared a memorandum advising against adopting any version of the Harvest Control Rule, noting that doing so would limit the Council’s flexibility to craft management measures, would substantially increase the amount of work needed to craft annual recreational management measures, and probably wouldn’t substantially reduce the need to change regulations from year to year.  As an alternative, staff recommended a set of actions that would reduce interannual variability, address the uncertainty in recreational catch and landings estimates, and generally address the question of uncertainty in the recreational management process.

Despite such concerns, the National Marine Fisheries Service’s Greater Atlantic Region Fisheries Office was intent on seeing the Harvest Control Rule adopted.  On June 3, Michael Pentony, the Regional Administrator, wrote a letter to the Chair of the Mid-Atlantic Council, which attacked the Council staff memo and threatened that, if the Council did not adopt some version of the Harvest Control Rule, that NMFS might do so on its own initiative.  The letter stated, in part:

“…This meeting is the culmination of four years of development, including two Scientific and Statistical Committee (SSC) reviews and the collaborate effort of the Plan Development Team (PDT) and Fishery Management Action Team (FMAT), the recreational reform working group, the Council and Commission, and state and Regional Office staff.  Given the tremendous collective efforts on this action, I was disappointed when I read the Council staff recommendation for, essentially, a status quo approach…

“A consistent theme in the discussion about recreational management over the last few years, from both Council and Board members as well as public comments, is that we should explicitly consider stock status when making determinations about recreational management measures.  This would allow us to better understand the impact that recreational catch is having on the stock, rather than simply comparing uncertain catch estimates to projection-based catch limits.  The current regulations, which the staff recommends remain the same, require us to propose measures that achieve the recreational annual catch limit (ACL), irrespective of stock status…

“The staff recommendation also makes a number of comments about the requirements of the Magnuson-Stevens Fishery Conservation and Management Act, some of which may be misleading to the reader or potentially imply that the alternatives are not legal.  To be clear, neither a recreational harvest limit nor a recreational sector-specific ACL are requirements of the Magnuson-Stevens Act.  While an overall ACL as well as accountability measures are required, these are designated to prevent overfishing at the stock level…Explicitly agreed upon, by the PDT/FMAT and presented at previous Council/Board meetings, was that the target level of recreational removals would be designed to ensure that overfishing does not occur…given the frequent stock assessments, reactive accountability measures, and proactive approach prescribed by the alternatives for setting measures, it is unclear how the new approaches would be in violation of the Act as implied by the Council staff memo…

“While recreational harvest may be projected to exceed an RHL, this does not always, and often has not, resulted in overfishing…

“It is my strong opinion that the Council/Board process and outcomes for 2022 clearly demonstrate that status quo recreational management for these fisheries is not an acceptable way to move forward…The Council staff recommendation is no better than the status quo…The current system is not working, and this is the Council and Board’s opportunity to weigh in on how to improve the process and management of recreational fisheries.  In the absence of meaningful action, NOAA’s National Marine Fisheries Service may be required to make regulatory changes under our own authority…As always, we will continue to improve management while taking into consideration its performance and the needs of our stakeholders.  [emphasis added]”

It was one of the more remarkable letters from a regional administrator that I have seen, in the way that it tried to direct both the Council and ASMFC toward a particular management action, and used the threat of independent NMFS action to do so.  

Having said that, it’s not clear where the authority to take such independent action would come from.

Magnuson-Stevens gives the regional fishery management councils broad discretion to craft fishery management plans, and any amendment to such plans, while placing narrow bounds on the Secretary of Commerce’s (and thus NMFS’) authority to adopt additional or contradictory management measures.  The limits of secretarial authority are spelled out in Section 304 of the statute.

Thus, if a regional fishery management council approves a management plan or amendment to such plan, NMFS must review such plan or amendment, and seek public comment thereon.  Within 30 days after the public comment period ends, NMFS may approve, disapprove, or partially approve the management action; if it fails to do so, such action will be deemed approved and go into effect.  If NMFS disapproves a plan in whole or in part, it must cite the applicable law on which such disapproval is based, explain why the plan is inconsistent with the law, and provide the relevant council with suggestions for conforming the plan to the law.

Magnuson-Stevens does not, however, empower NMFS to substitute its preferred management action for that recommended by the relevant council.

The current method of managing mid-Atlantic recreational fisheries was approved many years ago, so disapproval would not be an option (although NMFS could have disapproved Council staff’s recommendation, had it been adopted by the Council).  It is possible that NMFS could base independent action on Section 304(c)(1)(B) of Magnuson-Stevens, which allows the agency to act if

“the appropriate Council fails to develop and submit to the Secretary, after a reasonable period of time, a fishery management plan for such fishery, or any necessary amendment to such a plan, if such fishery requires conservation and management, [emphasis added]”

although if such independent action was challenged, the agency would have to convince the court that the Harvest Control Rule, or something like it, was a “necessary amendment,” that one or all of the four fisheries, already included in management plans, “requires” additional conservation and management, and that the Harvest Control Rule was a direct and appropriate response to such requirement.  It might be possible to make such a case, but arguing necessity, rather than a mere difference of opinion between NMFS and the Council, could have been a challenge.

Nevertheless, whether the threat was merely a bluff or whether NMFS would have carried it out, NMFS coertion seems to have worked.  

When the time came to vote, a motion to adopt the simplest Control Rule alternative, which would do little more than add consideration of stock status and uncertainty in the data to the current process, and impose a fixed reduction or liberalization in landings rather tailoring such reduction/liberalization to the expected landings (such motion made by New Jersey’s Adam Nowalsky and seconded, not surprisingly, by Michael Pentony) passed easily, with unanimous approval at the ASMFC and only three opposing votes at the Council.

While that wasn’t the ideal outcome, it probably wasn’t as bad as such outcome appeared a few months ago.

First, and most importantly, the motion included a sunset clause.  Unless the Control Rule approach is extended, or replaced by some other methodology, management of all four species will revert to the current process at the end of the 2025 fishing season.  Thus, if the Harvest Control Rule proves to be problematic, it can be abandoned in a couple of years without the need for any affirmative action on the part of managers.

Second, even the approach taken was a modification of one of the original proposals, which will make the Control Rule process somewhat more conservative than it would otherwise have been.

Finally, five of the six models needed to effectively implement the Harvest Control Rule probably will be ready to inform managers ahead of the 2023 season, which will make 2023 specification-setting less of a shot in the dark.  Only one scup model is expected to be unavailable, and given the big increase in recreational scup catch provided by the recently passed reallocation amendment, the delay of that model is unlikely to create any problems.  There will also be no models addressing the bluefish fishery, but given that bluefish are currently under a rebuilding plan, that is not an issue.

So now, we’ll see whether the Harvest Control Rule, at least in its current form, is going to work.

It will certainly achieve its primary objective—allowing anglers to harvest more black sea bass than they would under the current approach--and so reduce the number of complaints received by NMFS and state fishery managers.  But beyond that, nothing is certain.

Overfishing may well become a bigger issue.  Despite Mr. Pentony’s assertion that “it is unclear how the new approaches would be in violation of the Act as implied by the Council staff memo,” an example is easy to provide.  

Consider the black sea bass fishery.

Under the Harvest Control Rule approach adopted last Tuesday, should 2022 recreational harvest exceed the recreational harvest limit by a substantial amount—let’s say 40%, which would fall within historical overages—2023 recreational catch would only be reduced by 10%, because biomass is greater than 150% of the biomass target.  Since the stock-wide annual catch limit is equal to the acceptable biological catch, which in turn is set only about 6.5% below the overfishing limit, if the commercial sector lands its entire quota, and the commercial and recreational sectors both produce the predicted level of dead discards, the remaining, unaddressed recreational overage, if it recurs, would easily drive total catch above both the acceptable biological catch and the overfishing limit.

Such result seems to be in direct conflict with Magnuson-Stevens’ National Standard 1, which states that

“Conservation and management measures shall prevent overfishing while achieving, on a continuing basis, the optimum yield from each fishery for the United States fishing industry.  [emphasis added]”

Given that, the legal concerns in the Council staff memo seem entirely justified.

The other big question is how the Harvest Control Rule will deal with situations where fish stocks are below the biomass target, although not overfished.  

As noted in the SSC’s report to the Council and ASMFC, because both the Council risk policy and the Control Rule consider some of the same values, including stock size compared to target, they tend to reinforce one another, leading to management measures that are too liberal, and increase risk to the stock, when biomass levels are high, while also leading to measures that are unnecessarily restrictive when biomass is somewhere between target and threshold.

Right now, the only stock that falls into that latter category is summer flounder, but if black sea bass and scup stocks continue their steady decline, they can also be expected to also be at or below target in not too many years.  In adopting the Harvest Control Rule, both the Council and ASMFC may have traded higher scup and black sea bass catch in the short term for extended periods of lower catch levels for summer flounder, and perhaps all four species, in the future.

Managers who thought that they were eliminating a cause for stakeholder complaints may find themselves bitterly disappointed.

Still, what’s done is done.

For the sake of the fish, I hope that last Tuesday’s decision was the right one, and that the Harvest Control Rule will move the management process forward, and not cause harm to fish stocks.

Still, I need to be honest.  And honestly, I have my doubts.

 

 

 

 

 

 

 

COUNCIL STAFF, SCIENTISTS ADVISE AGAINST MID-ATLANTIC "HARVEST CONTROL RULE"

For more than two years, the Mid-Atlantic Fishery Management Council (Council) and the Atlantic States Marine Fisheries Commission’s Interstate Fishery Management Program Policy Board (Policy Board) have been working on something they call a “Harvest Control Rule” (Control Rule), which could make very significant changes to the way that the recreational fisheries for bluefish, summer flounder, scup, and black sea bass are managed.

Currently, all four species are managed by the Council and the appropriate Atlantic States Marine Fisheries Commission (ASMFC) species management boards (Management Boards), which have historically compared recent recreational landings with the recreational harvest limit (RHL) for the upcoming year, and set recreational management measures based on whether such recent landings were above, below, or about equal to the next season’s RHL.

Because of unavoidable uncertainty in the recreational landings data, and because angler behavior varies from year to year, the Council and Management Boards have had, at best, indifferent success in keeping recreational landings at or below each year’s RHL. As a result, recreational management measures often change from year to year, even when the biomass of the managed stock shows little change.

The Council and Policy Board began work on the Control Rule in the hope that it would better account for management uncertainty and so avoid annual changes to management measures. The various versions of the Control Rule being considered all consider factors other than the estimated recreational landings and the next year’s RHL, which might include such things as the biomass of the managed stock, whether such biomass is increasing or decreasing, the number of young fish recruiting into the population, and trends in recruitment, which might provide a more nuanced picture of what management measures should be.

The management measures adopted pursuant to the Control Rule would be predetermined, with each set addressing a particular combination of factors. Such predetermined sets of management measures represent a big change from current practice, which sees management measures calculated in direct response to recent landings. While one version of the Control Rule would only require a handful of management measures, others establish complex processes, which might require biologists to devise 52 sets of varying measures to manage a single stock.

The scientists raise many concerns

Yet, while the Council and Policy Board invested a substantial amount of time and effort into determining how management measures would be established, they spent little time determining how such measures might impact the health and stability of managed fish stocks. At a joint meeting of the Council and Policy Board, held on February 6, 2022, both management bodies adopted a motion that read:

Request that the [Council’s Scientific and Statistical Committee] provide a qualitative evaluation, in time for final action at the June 2022 Council/Policy Board meeting, regarding the potential effect of each of the five primary alternatives in the Harvest Control Rule Addendum/Framework on the SSC’s assessment and application of risk and uncertainty in determining the [Acceptable Biological Catch]. The intent is to provide the Council and Policy Board with information to consider the tradeoffs among the different alternatives with respect to the relative risk of overfishing, increasing uncertainty, fishery stability, and the likelihood of reaching/remaining at [the biomass target] for each approach at different biomass levels (e.g., for [a situation where the biomass is below the biomass target, but the stock is not overfished], the relative risk among alternatives is (highest to lowest) E>C>B>A>D).

The Council’s Scientific and Statistical Committee (SSC) created a Harvest Control Rule Subcommittee (Subcommittee), which was instructed to address the motion. In response to the issue raised in the motion’s first sentence, the Subcommittee advised that “The proposed Addendum/Framework is triggered by determination of the [Acceptable Biological Catch], and as such, the actual [Annual Catch Targets] and RHLs are determined only after the ABC has been specified. Consequently, the proposed Addendum/Framework does not affect the structured process the SSC uses to specify the ABC.”

However, the SSC could not provide a clear response to the other issues addressed in the motion. In attempting to do so, it raised a number of serious concerns.

One of the Subcommittee’s comments, which undoubtedly caught some Council and Policy Board members by surprise, was that the so-called “Harvest Control Rule” wasn’t really a “control rule” at all. The SSC noted that

Harvest control rules are quantitative relationships that specify how management endpoints, such as catch, should vary with stock biomass to achieve management objectives…Neither the no action option, nor any of the alternatives described in the Addendum/Framework represent harvest control rules…The proposed alternatives described in the Addendum/Framework are triggers for action only. Specification of how regulations on season length, size limits, and bag limits or other management endpoints would change is missing. Until such details are provided, the performance of the proposed alternatives cannot be determined. [emphasis added]

The Council and Policy Board are thus being asked to adopt a Control Rule, without having any concrete idea of how such Control Rule might affect the health of fish stocks.

The Subcommittee expressed concern that the Control Rule would make it more difficult to manage fish stocks, stating that

 

The sub-committee felt that the proposed alternatives failed to address explicitly the complexity of the problem of specifying a vector of how regulations around season, size, and bag limits would change…The current [Acceptable Biological Catch] process that uses the Council’s risk policy involves control of a single variable, the ABC. However, there are at least three specifications that have to be set simultaneously for the proposed alternatives to be implemented. The sub-committee notes that this increases substantially the complexity and the difficulty of the challenge which the sub-committee believes should be explicitly stated so Council and Commission members have a solid grip on the decision they are being asked to make.

The Subcommittee also noted that, because both the Control Rule and the Council’s risk policy incorporate some of the same information, there was the risk of creating “feedback” that would lead to increased variability in fishery performance. While the Control Rule was intended to reduce such year-to-year variability, and provide for more stable regulations, such feedback would stack “precaution on top of precaution” when a stock’s biomass is below target, resulting in more restrictive management measures than are currently imposed, while increasing risk to the stock by permitting more liberal regulations when fish abundance exceeds the target biomass.

The Subcommittee also noted that, when the SSC currently sets the Acceptable Biological Catch (ABC) for multiple years, it typically assumes that each year’s ABC will be fully caught, but not exceeded. When, as in the case of black sea bass, the ABC is frequently exceeded, the SSC will instead assume that future overages will occur, and so will reduce the ABC in later years. With respect to the Control Rule, “There are structural issues in several of the alternatives…that may lead to increased uncertainty in whether the ABCs may be exceeded, which could lead to the SSC setting lower ABCs than it otherwise would in multi-year specifications.”

Since the ABC governs both the recreational and commercial sectors, setting a lower ABC in response to a Control Rule that solely benefits recreational fishermen could result in commercial fishermen having to accept lower quotas while receiving no countervailing benefits of their own.

In addition, the Subcommittee expressed concern with some of the Control Rule alternatives, which placed management measures in “bins” defined by different levels of, and varying trends in, biomass, recruitment, and other factors. It noted work done by Dr. Paul Rago with respect to such binned management measures, and advised that “Preliminary conclusions from this simulation are that the effects of binning and random recruitment lead to a marked increase in the likelihood that [Overfishing Limits] would be exceeded. Moreover, populations were not rebuilt as frequently as occurred with population-specific optimal fishing mortality rates. Perhaps more importantly, a greater fraction of populations that were previously above [their biomass targets became overfished] when controlled with a binned [Harvest Control Rule].”

The totality of the Subcommittee’s concerns are summed up in the conclusion to its report, which states, in part, that

 

the actual efficacy of the proposed alternatives in the Addendum/Framework is unknown. This uncertainty comes from two sources. First, the actual measures that will be taken in response to any of the triggers identified in the Addendum/Framework are not specified…Until such specificity is provided, quantitative evaluation of the performance of the options is not possible. Second, performance of the discontinuous nature of the options proposed in the Addendum/Framework has not been proven effective in other fisheries nor formally evaluated, to the knowledge of the sub-committee. Preliminary modeling conducted by the sub-committee to evaluate the binning of population states, reliance on various metrics of stock condition and recent catch history, and implications of recruitment variability could result in and increased risk of overfishing and becoming overfished. This suggests that the appearance of precision in the process that leads to regulatory specifications does not necessarily translate into precision in catch performance and compliance. The sub-committee expresses the concern that some of the overly complex, contingent decision-making processes included in the proposed alternatives do not reflect the actual level of control likely achieved in marine recreational fishery management. [emphasis added]

 

Those seem damning comments. Replacing the current approach to recreational fishery management which, although admittedly imperfect, contributed to the successful rebuilding of once badly overfished summer flounder, scup, and black sea bass stocks, with an untested Control Rule of undetermined efficacy, which might lead to increased uncertainty and catch variability, and also increase the chances that even healthy stocks might become overfished, would seem to be an unwise thing to do.

Council staff offers a better alternative

It would seem far better to fix the worst flaws in the existing management process, and that is precisely the course recommended by Council staff.

Julia Beatty headed the Fishery Management Action Team responsible for the Control Rule. In a May 27, 2022 memo addressed to the Chris Moore, the Council’s Executive Director, she recommended against its adoption. In her memo, Ms. Beatty stated that

 

Council staff do not recommend implementation of the Percent Change, Fishery Score, Biological Reference Point, or Biomass Matrix Options…as they reduce the flexibility managers currently have to set measures to prevent overfishing. In addition, the process for setting measures under Options C-E (the binned approaches) would be much more complex than the Council staff recommendation…Also, many details are lacking regarding the process for setting measures under these options…

…measures recommended by the Council must prevent recreational [Annual Catch Limit] overages in order to prevent overfishing and comply with the law…Options B-E will not change the process for setting ACLs and they will not change the requirement to prevent ACL overages. Therefore, Options B-E could require frequent changes in measures unless managers are willing to set more restrictive measures to allow for stability while preventing ACL and RHL overages.

Thus, Ms. Beatty recognized that the Control Rule might neither provide regulatory stability nor allow anglers to maintain even their current level of landings, assuming that stock biomass remains unchanged. As an alternative, her memo proposed meaningful improvements to the current approach to setting management measures.

The staff recommendation is to: 1) set recreational measures for two years at a time, 2) use improved statistical methods for predicting the impact of measures on harvest and discards, and 3) incorporate considerations related to variability and uncertainty in the recreational data…

Council staff do strongly support the use of statistical models such as the Recreational Economic Demand Model and the Recreational Fleet Dynamics Model (both of which are currently in development) to inform the setting of recreational measures. These models will allow for more statistically robust predictions of future harvests and discards under different combinations of measures and different stock sizes. In addition, they will incorporate data other than Marine Recreational Information Program (MRIP) data, such as angler preferences and availability of the stocks to anglers. In addition, Council staff support prioritizing completion of the previously initiated Technical Guidance Document to describe best practices related to identifying and modifying outlier MRIP estimates, using confidence intervals, and guidelines for maintaining status quo measures.

The May 27 memo maps a reasonable way forward, which will allow fishery managers to make needed improvements to the current management process, but does not require them to completely abandon that process in favor of the untested and, given the SSC report and Ms. Beatty’s memo, seemingly dubious Control Rule approach.

Will managers follow the science?

The only remaining issue is whether the Council and Policy Board accept the counsel of Council staff and the SSC.

That is a difficult question to answer. About one-third of the members of both the Council and the Policy Board are state fishery managers. For most of the past decade, those managers have been unfairly criticized and harangued by some elements of the angling community, and in particular by members of the for-hire fleet, for adopting black sea bass management measures that seemed unduly restrictive, given that biomass has been at least double the target level since 2014. Such criticism, which sometimes grew vicious, was leveled by people who had no interest in hearing about increased fishing effort or the mandates of federal law. They only cared about harvesting more fish.

No one likes to be constantly targeted by critics. The Control Rule offers state managers an opportunity to demonstrate that they are trying to improve the management process, and ease the regulatory burden imposed on the for-hire fleet. It’s impossible to predict how many such managers will be seduced by the Control Rule’s promise of a safe harbor, although Council staff’s memo, which warns that the Control Rule may not eliminate the need for frequent regulatory changes, might make at least some of them wonder how safe the promised harbor will be.

In addition, the recreational representatives on both the Council and Policy Board are heavily skewed toward the for-hire sector, either as vessel owners and operators or as persons otherwise connected to the industry. They could find the Control Rule, and its promise of higher black sea bass and scup landings, too attractive to pass up, regardless of what the SSC and Council staff may say. It’s hard to predict whether the likelihood that the Control Rule will lead to more restrictive regulations for less abundant stocks will dampen such members’ enthusiasm.

The Control Rule issue will come up for a vote, at a joint Council/Policy Board meeting, on June 7, 2022. It is then when we’ll learn whether the decisionmakers will heed the advice that they were given, or adopt a Control Rule that could very well leave both fish and fishermen worse off than they were before.

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This essay first appeared in “From the Waterfront,” the blog of the Marine Fish Conservation Network, which can be found at http://conservefish.org/blog/

 

SALTWATER HATCHERIES: DUBIOUS BENEFITS, UNRECOGNIZED RISKS

 

Saltwater fishermen have traditionally been at the mercy of the ocean, and of their own behavior.

Unlike their freshwater counterparts, who often fish in man-made ecosystems, for non-native fish that, in many cases, were spawned not in nature, but in shallow pans on a hatchery rack, saltwater fishermen have long been dependent on native species, on the swings of abundance caused by the success or failure of previous spawns, ocean conditions, and on effective stewardship of marine fish stocks.

But as fishing, climate change, and other stressors impact fish stocks, some people have started to call for saltwater fishery managers to emulate the folks managing inland fisheries, and begin stocking fish to increase abundance without resorting to more restrictive regulations.

That has long been the case in Texas, a state that regularly dumps artificially propagated red drum, spotted seatrout, and southern flounder into its coastal waters, effectively subsidizing recreational overfishing.  Instead of adopting regulations restrictive enough to maintain a sustainable harvest of naturally-spawned fish, Texas freely admits that it employs hatcheries

“to ensure that harvest levels are sustained,”

Instead of adopting management measures better suited to the productivity of local fish stocks, the state boasts that it operates

“one of the most visible marine stock enhancement programs in the world.”

While there’s little doubt that the Texas hatchery program has allowed anglers to ice many more redfish and seatrout than they would have been able to remove from natural populations, there is little clear indication that stocking did the red drum much good.  A 2000 paper published in the Transactions of the American Fisheries Society, written by a scientist with the Texas Department of Fish and Wildlife, observed,

“Previous research that compared red drum length frequencies in stocked versus unstocked estuaries and analyzed the capture rates of fish with chemically marked otoliths indicates that stocked red drum can contribute to wild populations at the local scale, but the results are not definitive.  The data necessary for an accurate estimate of the proportion of hatchery-reared fish remaining in the estuary after several years and their contribution to the red drum population is difficult to obtain and not available currently…Correlations between annual stocking rates and age-0 or age-1 [catch per unit effort] were not significant across estuaries or years, suggesting no population-level effects of consistent annual increases in stocking or interestuary variations in stocking rates.  However, because all estuaries received some hatchery-reared fish during the period of this study, abundance levels of age-0 and age-1 fish in the absence of stocking cannot be inferred.  Therefore, although trends in resource monitoring data did not demonstrate clear stocking effects, release of hatchery-reared fish may still have enhanced red drum populations.  [references omitted]”

 According to an article published in Sport Fishing magazine, DNA testing performed by the State of Texas has found that between 1 and 17 percent of the red drum sampled each year were hatchery fish.  In most years, the proportion of hatchery fish exceeds 4%, which is deemed to be the point where the economic value of the drum caught by anglers breaks even with the expense of artificially rearing the fish, which makes the hatchery program an economic, if not a biological, success.

The same thing can’t be said for the white seabass hatchery established by the State of California.  

Over the past 35 years, California has spent about $40 million to manufacture sea bass, which are then released into the Pacific.  However, probably because the fish suffer very high mortality rates after being released, the stocked fish have had little impact on either the white seabass population or on the fishery.  Yet, while the hatchery has released over 2 million juvenile white sea bass into the wild, a panel of scientists has determined that less than 1% of the fish caught off southern California are of hatchery origin.  The steady increase in biomass is more likely due to a 1990 law that outlawed the use of gillnets in California’s state waters.

Yet, despite the questionable biological benefits of stocking, state management agencies are continuing to move in that direction, in order to provide more fish, and less restrictive regulations, for their anglers.

Thus, beginning in 2014 Mississippi began to release hatchery-raised red snapper into the Gulf of Mexico, as part of a research project being conducted with scientists at a state university that seeks to find ways to increase the availability of snapper to fishermen.  Other Gulf states also maintain or are contemplating hatcheries that will artificially rear popular marine fish species.

As noted by Max Westendorf, the director of Alabama’s Gulf Shores hatchery, the primary purpose of marine hatcheries is to keep fishermen happy, not to maintain fish stocks, which can be done by merely adopting appropriate regulations.

“If you don’t have the hatchery, and let’s say you just do fishing regulations and commercial regulations and fisheries management, you end up kind of just making people mad when you start telling them you can’t [fish].”

So if the primary purpose of marine fish hatcheries is merely to make fishermen happy, and buffer them from the worst impacts of their own harvest, the most important question to ask is whether such hatcheries could do any harm to wild fish stocks.  Such harm could, in theory, come in a variety of forms.  Hatchery fish might cause genetic damage to wild stocks, or they might increase the competition for food, spawning areas, etc.

Are those real threats?

The answer seems to depend on the species involved, and the type of threat being considered.  But recent information coming out of Alaska suggests that introducing too many artificially reared fish into the ocean could impact not only a single species, but an entire ecosystem.

Every year, hatcheries along the northern Pacific Rim—from Japan to Alaska—produce and release about 1.3 billion pink salmon fry; enough survive that about 82 million adult fish return to coastal rivers every other year.  While pinks are the most abundant salmon species, and the hatchery-spawned adults only account for about 15% of returning pink salmon, those 82 million fish are roughly equal to the entire wild sockeye salmon population, and outnumber the wild chum salmon, chinooks, and cohos.

All of those hatchery fish have to feed heavily in order to return to coastal rivers in spawning condition; they can increase their weight by 500% in only four months.  They compete with other salmon species for the available forage, and with species such as sockeye also abundant in Alaskan waters, there may not be enough forage to go around.

It appears that the average size of salmon is falling as a result.  An article in Hakai magazine notes that the size of chinook salmon has dropped by 8% since 1990, while the size of other species has fallen by lesser amounts.

Studies dating back to the 1970s suggest that there is an inverse relationship between the abundance of pink and chum salmon; when the pinks, which peak in abundance every other year, exhibit high numbers, the numbers of chum salmon trend low.  Growth rates of sockeye salmon also seem to wane when pink salmon are abundant.  In a finding that might explain such variations, researchers discovered that when pink salmon were abundant, there was a sharp drop in the abundance of copepods and other large zooplankton, suggesting that the pinks were having a substantial impact on the North Pacific food web.

Such impacts have been linked to declines in the abundance of herring and mackerel, and also on the nesting and survival of seabirds that are dependent on fish that, in turn, need abundant zooplankton to thrive.  It even appears that the abundant pink salmon could be causing an increase in killer whale mortality, and their impact on the food web reduces the numbers of chinook salmon, on which the whales feed.

Hatchery-produced pink salmon are so much a part of Alaska’s commercial salmon fishery—some operations earn a third of their revenues from the hatchery fish—that it is highly unlikely that such production will stop at any time soon, particularly given that scientists are split on the question of whether the hatchery fish are doing real harm.  But in other places, where hatchery fish have not yet been woven into the fabric of local fisheries, it is time to ask whether it is wise to dump thousands, if not millions, of fish into the water each year, merely to give fishermen something to catch.

While hatcheries might provide a logical and valuable response to local catastrophes, such as the impaired river flows that threatensalmon runs in California, or perhaps even the damage that the red tide haswreaked on Florida’s coastal fisheries, they should always be seen as a temporary response, an interim measure intended to support wild populations until natural reproduction can return to more typical levels.

In areas with healthy populations of fish, where recruitment is not an issue, flooding the ocean with man-made fish can lead to problems as easily as to solutions, and should be avoided in favor of regulations that constrain landings to levels that are sustainable in the long term. 

Hatcheries are seductive, as they seem to offer abundant fish without the discipline imposed by stringent regulation.  Yet, in the history of North American fishery management, it is difficult to find an instance, whether in fresh water or salt, where extended periods of stocking have left a native population in better condition than it was in when the stocking began.

That, in itself, should condemn the practice.