Next week, will ASMFC heed common sense and on-the-water experience?

Top photo: A striper eating bunker

Last week, I received a brief release from the Menhaden Fisheries Coalition, titled National Wildlife Federation Revives Menhaden Myths with Latest Petition.

The Menhaden Fisheries Coalition describes itself as “a coalition of menhaden fishermen, related businesses, and supporting industries,” and the release was exactly what one would expect such a group to produce—a series of over-simplified and somewhat misleading arguments for avoiding any real and immediate action to conserve menhaden.

The menhaden industry is desperate to sway public opinion, because a very important decision will be made on menhaden – and really, how we move forward with managing all forage fish resources – on Nov 13th and 14th in Baltimore.

At that time, the Atlantic States Marine Fisheries Commission (ASMFC) Menhaden Management Board (the Board) will decide on whether to manage menhaden for their role as prey in the marine environment (aka ecosystem-based management) now, or in several years, or… never, although the latter is unlikely. The Board will also decide on state allocation, which is also noteworthy as the state where the last menhaden reduction industry resides currently gets 85% of the quota.

Menhaden industry profits are directly related to the number of menhaden that it is allowed to kill, so, I do understand the industry’s reasons for trying to derail current conservation efforts. But the conclusions in the release don’t make sense to anyone who fishes, understands marine ecosystems, or, well, anyone who practices common sense and doesn’t have a financial interest in killing hundreds of millions of pounds of menhaden each year.

Let’s start from the beginning.

“Menhaden were not overharvested”

Yes, technically menhaden are not “overfished,” and “overfishing” is not occurring. They never have been according to the latest single-species stock assessment. Yet, from a practical perspective, I find this hard to believe.

It’s difficult to gauge what “historical” menhaden abundance looks like, because, well, we’ve been fishing them so hard for so long.

For well over 100 years, reduction fisheries had existed up and down the coast. By reduction, I mean fisheries that catch menhaden in huge quantities, grinding it up and boiling it down into base products like fish oil, fish meal, etc.

Such low value/high-volume fisheries caught A LOT of fish. So much so that just about all of the reduction businesses were either forced out of town or simply closed down on their own.

Whether most of them shut their doors because the states pushed them out (menhaden reduction plants stink—very badly), or due to lack of fish is, of course, debatable… But it is entirely reasonable to conclude, particularly in the northern regions, at least some closed down because menhaden simply weren’t available in large numbers anymore, or at least not enough to make the high volume/low value thing work. If menhaden were overfished, and there weren’t regular abundant aggregations? Well, you get the point.

Yes, bunker appear to be coming back in some, I’d argue most, areas, almost certainly because of a 20% reduction implemented in 2012. And with that resurgence has come all the associated whales, dolphins, seabirds and, of course, striped bass, bluefish, thresher sharks, etc. Indeed, maybe this is the beginning of a recovery. But given the history of the menhaden fishery, we’re likely not near what a “healthy” menhaden population should look like.

The level of depletion that determines “overfished,” which industry frequently references, is the wrong measure for this forage species because it doesn’t account for predator needs.

So yes, I’d say with some certainty menhaden are and have been “overharvested” for quite some time.

Which leads me to the release’s next assertion:

“Quota cuts have not been responsible for their resurgence”

It’s hard for me to stomach this one. And I think it’s difficult for any reasonable person to assume for one minute that the mandated 20% reduction in 2012, which equates to leaving literally hundreds of millions of bunker in the water, didn’t result in the sort of wide-ranging abundance we’re seeing now.

Industry and some managers like to point to the lack of a “stock recruitment relationship.” That’s a science-y way of saying that biologists can’t determine whether having lots of adults in the water equates to good spawning success and ultimately recruitment (aka fish entering the spawning stock biomass). But really, I mean, come on man… If you leave hundreds of millions of pounds of fish in the water, well, then of course there are hundreds of millions of pounds more fish in the water.

We’re not disputing the conclusion that maybe favorable environmental conditions had something to do with resurgence. But it is no coincidence in my opinion – and I think most people’s opinions – that when the Commission finally got around to putting constraining measures on menhaden, well, they came back.

To say that such a reduction in harvest had nothing to do with the resurgence defies common sense, and generally the only people you will find making such an argument are those pro-harvest folks who think that industry should be able to kill as many as they want, and to hell with the rest of the coast.

Yes, industry is correct that, according to the latest benchmark stock assessment, and the stock assessment update completed this year, that the stock is not overfished, and overfishing isn’t occurring. In fact, the new stock assessment contends that we can increase harvest by another 40% and still not overfish. But let’s be very clear that this is a single species stock assessment. In other words, it determines what we can take out of that stock and still have it replenish itself. What it doesn’t account for is how many need to stay in the water for predators. This is a very important distinction!

I’m pretty sure there are very few people on this planet who feel like a 40% increase on what is already an extraordinarily large menhaden harvest wouldn’t have a significant impact on everything that eats them.

“The menhaden fishery does not heavily impact striped bass”

Uhm… What?!

So, regularly running out with large industrial boats, wrapping huge nets around entire schools of menhaden, and then pumping holds full of millions of pounds (hundreds of millions of pounds aggregate) of menhaden, which is unequivocally THE most important driver of spatial and temporal striped bass abundance, has little effect on striped bass?

This is, quite frankly, ridiculous.

Such an assertion is based on a study, largely funded by industry, which claims that striped bass only eat juvenile menhaden and thus the large-scale removal adults has little effect.

Just about anyone… well no, EVERYONE who fishes striped bass knows that this is completely and utterly not true. Adult menhaden absolutely drive time and area adult (read: large) striped bass bites. Want to catch a fish in the 30 to 50 pound class? Well, then you find the darn bunker schools. There are charter boat captains who make a living fishing on them.

To those of us who striped bass fish, such an assertion is preposterous.

“Menhaden oversight did not begin in 2012”

Well, that’s partially true… It didn’t. There were indeed state restrictions, local land use rules etc., some of which forced local reduction plants to close their doors.

The first fishery management plan (FMP) for Atlantic menhaden was developed in 1981. It was a classic example of the fox guarding the henhouse by both the Atlantic Menhaden Management Board and the Atlantic Menhaden Implementations Subcommittee, which was dominated by the menhaden reduction industry. That original management plan guaranteed “industry executives” as many seats on such bodies as it gave to state fisheries managers.

Menhaden weren’t managed as a public resource; instead they were considered assets belonging to industry, until Amendment 1 to the management plan was adopted 20 years later, in 2001. Even then, no effective constraints were placed on menhaden landings. In 2006, a ceiling was put on Chesapeake Bay reduction harvest. But it accomplished nothing, because it was set so high that industry currently catches only about half of it.

So for all practical purposes, the Commission didn’t really do anything to constrain harvest until 2012 when it put in place the above mentioned 20% reduction on current landings. And, well, low and behold the stock came back in numbers few people had ever seen (because few people are actually over 100 years old). It is absolutely true that this was the first real mandated coastwide reduction on what was basically an unrestricted fishery. So yes, for all intents and purposes the coastal menhaden stock had no real management until then.

The release contends that “NWF surrogates are also wrong characterizing the current debate over menhaden reference points as the menhaden fishery wanting to ‘remove restrictions’ on the species.”

I don’t believe that’s true. Industry has been clear that they want to get back to the pre-2012 levels of harvest, or, in other words, removing that 20% reduction that was put in place back in 2012. In the last two years, they have actually managed to get back another 16% despite cries by the angling and conservation community to stay the course.

According to the release, “Members of the menhaden fishery instead support quotas and reference points for menhaden that are supported by the science produced by the ASMFC, and reflect the healthy state of the menhaden population.” But the disagreement lies in what is “healthy.”

Menhaden are not “the most important fish in the sea”

Of course you are going to say this if you profit from the large-scale extraction of a forage fish that just about EVERYONE agrees is VERY important, and likely THE most important fish in the sea… or in the Mid-Atlantic anyway.

By feeding on phytoplankton—tiny plants that form the foundation of the food web—menhaden basically take sunlight and convert it into food for just about every predator fish, bird and marine mammal on the East Coast.

Those of us who spend time on the water know and understand the menhaden’s importance well, extremely well. Aggregations of bunker (both juvies and adults) dictate seasons. They determine how, when and where we fish, precisely because everything feeds and depends on them.

Sure, those predators eat things like sandeels, bay anchovies, silversides, killies, etc. But we all know that most of the time, it’s the bunker that draw the fish and create the epic feeds that haunt us. And we sure as hell wouldn’t have all these whales, or the whale watching boats, if it weren’t for the bunker.

The point is, to those of us who fish, particularly those of us who are out there pretty much every day, it is not an exaggeration to say that they are indeed THE most important fish in the sea.

Industry can fund all the studies it wants and say whatever it can to deny this fact. But we all know it, because we see it. Regularly. Some of us every darn day!

It all comes together next week

Next week’s meeting of the Menhaden Management Board is pivotal. Not only will the Board decide whether or not to allow an increase in menhaden harvest, but also it likely will determine the future course of forage fish management.

They could listen to and be swayed by a profit-focused industry, or they could heed common sense, and listen to those of us who spend time on the water, and who understand the importance of healthy, abundant aggregations.

For the menhaden, for the predators, for those of us who rely on their occurrence, for the future of fisheries management and the health of coastal ecosystems, let’s hope to God that the Board does the right thing.