We should hold off fishing on data-poor forage species
Yes, there are rumors floating around that entrepreneurial New England fishermen are developing small mesh cod-ends, which is the back end of a trawl net that holds all the fish during dragging, designed to catch sand eels. I have no idea whether or not such rumors are true. They certainly may not be, but it’s definitely plausible. Targeting small bottom-of-the-food chain critters like sand eels, if it’s done on a small scale, wouldn’t be terrible I suppose. But, if it turned into a large-scale fishery, like we have with other forage such as herring, mackerel, menhaden etc, it could be absolutely disastrous. I imagine that most readers of this column already understand that everything in the northeast feeds on and to some extent depends on sand eels. Should they get fished hard in my area, again not an unlikely scenario should this rumored fishery gain traction, we likely wouldn’t have a fall run…of anything! I can’t help but think that such a fishery could blow up, on a large scale at any time. And to my knowledge, there currently isn’t anything preventing that from happening.
Perhaps, given what I’ve seen in other fisheries, I’m a little sensitive to this. But it’s not unreasonable to be concerned. It’s a fact that market demand for reduction products made from low trophic level species is increasing rapidly with the proliferation of aquaculture and the need to feed farm-raised fish, usually with some fishmeal product. And today just about everyone and their mother is promoting the health benefits of fish oil/Omega 3 fatty acids, which of course come from such forage fish. Recent constraints on the menhaden fishery could exacerbate the situation as buyers will likely be looking for new sources of “raw matrerial”. Check out this article in the Wall Street Journal. Scary stuff if you give a crap about what the fish we target eat. If you still think this is just paranoia, note that fisheries have indeed developed in other parts of the world on krill (e.g. Antarctic), copepods (e.g. Norway), and, yes, sand eels (e.g. North Sea). It’s not unreasonable to think it will happen here.
This is something NMFS and the Councils need to get out in front of, before it becomes a big problem. It’s a management vacuum that needs to be filled as rapidly as possible before we get ourselves in a situation where large fleets are mowing down schools of sand eels, silversides, even krill, before we have any idea of what a sustainable harvest should look like. Managers would be struggling to figure out how to deal with it, while having no management scenario in place to curb such catches. We could most certainly get into a situation where we are fighting to prove that such fisheries aren’t sustainable during a time when federal resources (read money for science) are contracting not expanding.
What would make a lot of sense here is a complete suspension on the development of new fisheries for forage species, unless and until we have good science. The ecological consequences of removing certain prey species should be addressed before any new fishery is allowed to proceed. It’s a reasonable, proactive and precautionary step given the risk, and it’s not an untested idea. Two Regional Management Councils in the Pacific have done something similar.
The progressive North Pacific Fishery Management Council (NPFMC) amended the Gulf of Alaska and Bering Sea/Aleutian Islands Groundfish FMPs back in 1998, to preclude directed fishing on a suite of forage species. They amended these Fishery Management Plans (FMPs) in 2010 to update these actions by designating these forage species as Ecosystem Component Species (ECS). They also created an Arctic FMP in 2009, the primary purpose of which was to preclude new commercial fisheries in the Arctic Management Area, including for forage species, unless and until robust information was available and deemed sufficient to approve a new fishery.
The Pacific Fishery Management Council (PFMC) has also acted to protect unmanaged forage species.
In 2009, Amendment 12 to the Coastal Pelagic Species FMP was implemented to put in place a harvest prohibition on all species of krill. The PFMC is also actively considering additional protections for all other unmanaged forage species, and in June 2012 adopted an objective of suspending new directed fisheries on unmanaged forage species.
Similar management measures to address what could very well be developing fisheries for critical forage species in our region need to be considered at the Mid Atlantic and New England Councils, sooner rather than later. If it is done now, we are not taking anything away from anyone since fisheries on unmanaged forage haven’t really developed yet. In other words it wouldn’t impact the fishing industry. If we were to wait until such fisheries are developed and then act retrospectively, it would likely cause some economic distress, as investments in gear etc. would have already been made. Subsequently, there would be lots of pressure on the Councils and NMFS from the industry to do nothing. The industry would invoke the usual arguments such as the science isn’t good; we don’t know if there’s really a problem; this would cause them to go out of business; etc.. The burden to prove otherwise would be on NMFS who has made it pretty clear recently that they don’t have the resources to do this analysis. One needn’t look any farther than river herring and shad to see how things would likely play out. Acting now would shift the onus for demonstrating sustainability to the industry that would stand to profit from a public resource. This is far more appropriate than requiring already financially burdened public agencies to retrospectively address a problem.
Of course this sort of precautionary approach to managing forage would fit in with the growing scientific and managerial acceptance of the need to manage forage species to account for predator needs. Addressing unmanaged forage proactively aligns with the growing recognition that we need to be managing according to ecosystem principles, not looking at single species in a vacuum. If you’re an angler, all this is intuitive. The bait has to be there if you want to find the predators. Managing a species like summer flounder, striped bass or bluefin tuna, without managing the “bait”, doesn’t make much sense, but that’s pretty much what we’ve been doing for the last three decades.
Protecting additional forage species is not just a philosophical or theoretical discussion about idealistic management scenarios. Declines in forage fish such as river herring and shad, Pacific sardine, menhaden have and are occurring due in part to overfishing… Yes, there is demonstrated potential for new fisheries to emerge on unmanaged forage species, with increasing market pressures coming from industrial uses such as fishmeal and fish oil. And yes, it is clear that demand is rising for new forage fish products. This potential, in combination with what we know about the ecological importance of these species to well-functioning marine ecosystems, demonstrates that we need to act now.
We were actually well on our way to doing this at the Mid Atlantic Council. Public comment was pretty clear that people wanted to include this as an alternative in the Amendment 15 to the Mackerel, Squid and Butterfish (MSB) FMP Draft Environmental Impact Statement. For more info on what the hell this issue entails see prior blog: River Herring and Shad Lose at the Mid. If you read that blog, you’ll see that the Amendment was derailed. If you didn’t, the short version is that because the Council was considering which species should be included in the MSB FMP,specifically river herring and shad, we had a unique opportunity to also address the emergence of new fisheries on poorly understood and ecologically-vital unmanaged forage species in the same action. Unfortunately the Council voted to not move forward with a DEIS, at least not yet.
So now what? Assuming we don’t revisit Amendment 15 in the near future, this will come up again, likely as its own amendment. I’ll make sure of it. The Mid Atlantic Council should examine the various approaches successfully taken by other regions. We should conduct an ecological and regulatory inventory of the forage base in our region, and design and consider a range of alternatives to prevent new forage fisheries from developing until a robust ecosystem-based management plan is in place.
This is a responsible and common-sense management policy which would be so much easier to put in place now, before financial interests are at stake. There seems to be very few people who oppose it. Other Councils have demonstrated it can be accomplished with broad public support. And perhaps more importantly, it will prevent depletion, rather than leaving managers spinning their wheels trying to fix a problem that didn’t need to become a problem in the first place.