On Forage Fish… Managing the Unmanaged

Are large-scale fisheries for sandeels, silversides, bay anchovies etc. coming to a coast near you?


Photo by Capt. John McMurray

Really, if you fish, at all, this is important… for a very basic reason — If there’s no bait, there’s no fishing. If you spend more than a few days on the water every year, you know this to be the case.

Before I get to all this, you may have noticed I haven’t written a blog in a while.   And yes, we had a recent win on striped bass (Charlie covers that pretty well here: ASMFC ALMOST GETS IT RIGHT WITH STRIPED BASS). The lull is for reasons too complicated to get into here, but we hope to be back up and running full steam by early 2015.

Getting back on point, here’s the short version on where we’re at with “the bait” or what the pointy-heads call “forage”.

Yes, some bait species are currently managed by the Federal Councils or the Atlantic States Marine Fisheries Commission (ASMFC). Most, however, are not. Absolutely, there have been and are issues with the way managed forage species like menhaden, river herring, shad, sea herring, mackerel, squid, butterfish etc, are managed, but they are indeed managed. I want to be very clear here that other forage species such as sand eels, bay anchovies, silversides, halfbeaks etc., are not. And that’s kinda scary.

Here’s why we should all be concerned… The Federal Fishery Management Councils and the states are finally getting smart about the forage species they manage. In other words they are beginning to understand that such bait species need to be managed according to ecosystem needs, or in other words the needs of the predator species that depend on them… instead of just those special interests that seek to harvest as many as possible. Yes, this development was slow in coming, and hasn’t gone far enough fast enough, but it does appear to be happening.

Bay Anchovies 3

Photo by Capt. John McMurray

So what does this mean? It means that the amount of large-scale harvest on those managed forage species is being and will likely continue to be ratcheted down, and rightly so.

We also need to keep in mind the long-in-the-making but fairly recent news of the collapse of codfish in New England. The groundfish fleet is massive. There have been huge reductions in allowable take of cod, and there likely will be even more reductions in the near future. It’s hard to believe those fishermen won’t actively be looking for new markets. In fact there’s already some scuttlebutt about directed   fisheries on forage species that have NO current management or oversight developing in New England.

And let’s also keep in mind all the fisheries in the Mid Atlantic that have been rebuilt as a result of the Magnuson Act’s mandates, and to avoid getting back into a situation where we were before rebuilding, harvest has been kept at a sustainable yet lower level. And, well, on the other side of that coin are all the fisheries the states have allowed to become depleted, and so those fish just aren’t there to catch.

What I’m getting at here is that there a lot of fishermen looking for new sources of income, and well, it makes a lotta sense that strapped fishermen are likely going to be, if they aren’t already, looking at prosecuting new fisheries.

It sure as hell isn’t unreasonable to believe the next frontier is the unmanaged forage species… For a few reasons. Globally, forage fishes are major contributors to marine fisheries, constituting more than 35% of annual landings in recent decades. Most of these landings are converted to meal and oil, and used as feeds in livestock and aquaculture industries, or used as bait (in the U.S., largely for the lobster industry).

I mean really, consider the increasing demand for Omega 3s (as a supplement among other things); the growing aquaculture (fish farming) and livestock industries; the fact that ground down/processed forage fish are used in all sorts of products ranging from fertilizer to lipstick where oily bait-fish are a traditional ingredient; and lastly there’s a hungry lobster industry that’s always looking for new, cheaper sources of bait.

So yeah, the point is there’s a lot of demand out there, and the stage is set for entrepreneurial fishermen to initiate large-scale fisheries on new low-tropic level species (and I just mentioned a few above, there are dozens and dozens of others such as grass-shrimp, krill, you name it… If it swims a market can likely be created). In fact, there are already rumors bouncing around about the development of cod-ends with super-small mesh nets to catch sandeels in New England.


Photo by Capt. John McMurray

Frankly, that really scares me. If I don’t have an abundance of sandeels in Oct and Nov, I pretty much don’t have a fall run. No stripers, no bluefish, no bluefin… Come to think of it, if I don’t have sandeels I don’t have an offshore fishery. Really, every single bluefin and yellowfin I’ve ever caught inside of 100-fathoms is loaded with sandeels. Sandeels are simply what bring these fish into striking distance for me. Without them, you could pretty much count out my entire offshore business in July and Aug. And wow… I guess I depend on them for my late-May and June flats fishery. Without that rush of sandeels there would be no reason for striped bass or bluefish to come up on the flats. This stupid charter fishing business is hard enough as it is with striped bass in the shitter and all. Taking sandeels outta the equation would probably end things pretty quickly for me, and lots of others.

I know I keep focusing on sandeels because it’s the sandeel large-scale fishery rumor that has me a little tweaked. I mean you could pretty much imagine how quickly the dynamics of the sandeel stock would change if one or two companies started removing tens of thousands, perhaps millions of metric tons outta that stock. It would be devastating… I mean, not just for my business, but probably the entire ecosystem. But of course it isn’t just sandeels. Do you really think we’d have a false albacore run if some innovative fishermen developed a way to harvest bay anchovies en-masse? You could forget about those iconic bass blitzes off of Montauk Point. You could forget about people coming to Montauk to fish at all.

And what about silversides. Probably wouldn’t be many fluke coming into the bays, right? And grass-shrimp? Or killies? What about halfbeaks? The possibilities are almost endless. Think it couldn’t happen? There are developing fisheries all over the world for things like krill (e.g the Antarctic) copepods (e.g Norway)… And guess what? There’s a substantial large-scale fishery for sand eels in the North Sea. Click on those links if you don’t believe me.

So why wouldn’t it happen here? The point is it could and likely will. And managers would get caught flat-footed in an ugly situation where we are fighting to prove that such fisheries aren’t sustainable during a time when resources (read, money for science) to study such matters are contracting, not expanding. As it stands today, and as backwards as it sounds, a fishery can open up on a species without any data, any plan, or any oversight in place—and the only way managers would likely get involved would be AFTER a problem develops and is brought to their attention.

What really needs to happen here is we need to get out in front of this thing, before it becomes a big problem and before we get into an impossible situation where large fleets are mowing down schools of sand eels, silversides, even krill, before we have any idea of what a sustainable harvest might look like. Where we’ll be struggling to figure out how to deal with it, while having no management scenario in place to curb such catches.

If we wait until those investments are made and those markets developed, \ there would be pressure on struggling Councils and NMFS to do nothing, because it would be real tough for anyone to prove such fisheries were causing damage to entire ecosystems.   And of course industry would say any reduction would cause them great economic harm etc., and they would be partly correct as industry would presumably have already invested in the gear to prosecute such fisheries. I mean Christ, you can see how this has played out with managed forage fisheries like menhaden and herring.

But enough gloom-and-doom… Let me get to the whole point of writing this blog. There is indeed a tangible opportunity to take some proactive action here.


Photo by Capt. John McMurray

Precisely because stakeholder groups had expressed strong interest in ecosystem-based approaches to fishery management and, in particular, the development of a policy for managing forage fishes, the Mid Atlantic Council, of which I am a member, is currently developing an Ecosystem Approaches to Fisheries Management Guidance Document, which, when completed, is intended to provide guidance to the Council with respect to incorporation of ecosystem considerations.

As part of the development of this guidance document, Council staff has been working on a series of white papers, including a recent Forage Fish White Paper. We saw a first draft of this document at our October Council meeting.   The paper, while still a work in progress, provides recommendations on management approaches that the Council could consider. And, guess what. There’s an entire section on unmanaged forage, including 4 different alternatives on how we might proceed in dealing with the unmanaged forage situation.

The last alternative “Declaring a Moratoria on New Forage Fisheries”, is IMO the best option.   I’m not sure “moratoria” is the right word to use, because it tends to imply it would take those unmanaged bait species completely off the table. That’s not the real meaning of moratoria, though. This option would, logically and proactively “formalize and scrutinize processes leading to development and implementation of the fishery, including need for assessments, determination of effects on existing fisheries” etc… In other words, it would require that any new large-scale fishery on such unmanaged forage be proven sustainable before it could be prosecuted. Seriously, that makes much more sense than letting fisheries develop, then getting caught behind the eight-ball.

If we were to go this way, the Council would view new fisheries on bait fish as having the potential to affect its conservation and management measures if these fisheries had an effect on any Council-managed species or marine mammals, seabirds, sea turtles, or other ESA-listed species for that matter. That seems entirely reasonable given the importance of such unmanaged forage to the ecosystem.

Now, how procedurally would the Council go about doing this? That’s a tougher question than it might seem as there issues here. That said, there is precedent.

The North Pacific Management Council has taken significant precautionary action on their unmanaged forage. They brought a list of unmanaged bait species into the groundfish Fishery Management Plan and prohibited new directed fishing on them. They also created a new fishery management plan that prohibited fishing on most unmanaged forage species in the Arctic.

The Pacific Fishery Management Council brought several krill species into the Coastal Pelagic Species Fishery Management Plans and prohibited all fishing for them. They are also currently working on an unmanaged forage amendment, which will bring a list of unfished, unmanaged forage species into all four of the Council’s fishery management plans as Ecosystem Component Species, with management measures to prohibit new directed fishing absent a rigorous review and a fishery management plan amendment to authorize any new long-term directed fishing.

What’s the correct path for the Mid Atlantic Council? I don’t know yet. Each course of action seems to have its own set of pitfalls. I don’t have the space to go into them here, nor do I think you wanna hear them. The bottom line is that I’m working with some people to try and figure that out.

What is damn important though is that anglers understand the issue, and the urgency, and ultimately provide support for protecting unmanaged forage, however we proceed. I don’t think it’s an overstatement to say that just about every seasonal run of fish we target depends on whether or not, and HOW large-scale fisheries are allowed to develop on unmanaged forage. I’ve kinda made it a personal priority. And all cards down, I kinda wanna see this happen fast.

I greatly suspect there will be some action initiated at the Mid Atlantic Council’s meeting in Baltimore which takes place Dec 9-11. A showing of anglers at that meeting would likely help the Council understand how critical this is for us. So stay tuned for details…


After obtaining an undergraduate degree in Political Science from Loyola College in Maryland, Captain John McMurray served in the US Coast Guard for four years as a small-boat coxswain and marine-fisheries law enforcement officer. He was then recruited to become the first Executive Director of the Coastal Conservation Association New York. He is currently the Director of Grants Programs at the Norcross Wildlife Foundation in New York. He is the owner and primary operator of “One More Cast” Charters. John is a well known and well published outdoor writer, specializing in fisheries conservation issues. In 2006 John was awarded the Coastal Conservation Association New York Friend of Fisheries Conservation Award.

Posted in Conservation
4 comments on “On Forage Fish… Managing the Unmanaged
  1. John,
    Would you allow for harvest of these species in states waters?
    If a moratorium was in place what would be your position on importing some of these species for bait?
    Greg DiDomenico

  2. Greg… Harvest should be allowed anywhere, as long as it’s sustainable (in an ecosystem context, not just in a MSY one). Again, the common sense goal of such a “moratorium” is not to prevent new fisheries from developing, but to mandate a rational process for adding new forage fisheries so that if a new bait fishery develops we can be sure it’s sustainable. But yeah, in state waters, be nice to see the same kind of policy on unmanaged forage for the same reasons. And really, wouldn’t be a bad idea if this became a national policy…
    Re importing bait… I can see what you’re getting at here. I don’t think anyone is advocating for a switch to more foreign bait. And no reasonable person is advocating for a shutdown of herring, menhaden, mackerel etc. fisheries. Just that they be managed sustainably, for abundance, for predators as well as fishermen.

  3. Thanks for the reply John.
    I should have been more specific on my second point and I really did not think you were advocating for a shut down of the managed species.
    I was thinking about sandeels and silversides that are imported for hook and line fishing and potential problems associated with monitoring, if a moratorium were in place or potentially low quotas.

  4. Small-scale fisheries Greg. Done with from the shore with seine nets if I understand correctly. The intent with an unmanaged forage action would be to prevent large-scale harvest (for say reduction) before we know what sort of effect on the ecosystem such fishing would have. I don’t envision such an action increasing what we import, but indeed it’s something to think about should we move forward. Thanks for bringing it up, as I hadn’t really thought about this. Would be something we’d have to figure out.

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