CLF ultimately misinterprets FSF's testimony at that hearing, in turn distorting our criticisms of current scallop management.
– FSF did not say management has failed but rather changes are needed to provide flexibility and consistency to meet market demands.
– Industry has proven its stewardship of the resource.
– Maintaining all closures allows the scallops to age and die, providing no benefit to communities.
– Allowing access into some closed areas will introduce more areas into the rotational system allowing a more consistent scallop catch without threatening the sustainability of the scallop fishery.
WASHINGTON — December 4, 2013 — The following was released by the Fisheries Survival Fund:
At a public hearing convened by Massachusetts Senator Elizabeth Warren in early November, scallop fishermen joined other members of the fishing and scientific communities in discussing prospective reforms to the Magnuson-Stevens Fishery Conservation and Management Act. Confronting the potential of expected cuts to next fishing year's scallop catch despite the resource not being overfished, industry representatives from the Fisheries Survival Fund (FSF) called for more flexible management, specifically limited access to currently closed scallop areas on Georges Bank. The Conservation Law Foundation's (CLF) Peter Shelley has criticized these proposals as "short-sighted," ("Scallopers Haul Back a Short-Sighted Vision," 11/7) but he ultimately misinterprets FSF's testimony at that hearing, in turn distorting our criticisms of current scallop management.
Mr. Shelley is quick to allege that the testimony of FSF representatives is contradictory. According to Mr. Shelley, it's inconsistent for us to argue both that the scallop fishery is sustainable, but that it also needs access to new grounds to avoid harvest cuts. However, this does not accurately reflect the point of FSF's testimony, or the nature of our criticisms of current management. The proposals from the industry presented by FSF do not indicate that scallops are overexploited, but rather that the current system is inefficient and creating potentially costly, and ultimately unnecessary, disruptions in the market for scallops.
At issue is whether the currently closed areas of Georges Bank can be fished sustainably. Originally closed in the 1990s, they are home to abundant and untapped scallop populations. According to the industry, current regulations, like these closures, are preventing the fishery from achieving its maximum sustainable yield, one of the objectives of fisheries management under the Magnuson-Stevens Act. Without more flexibility in where the scallop fishery can operate, the industry contends that they will be subject to unnecessary cuts in their allowable catch. But allowing the fleet limited access to these areas would safeguard the fishery's economic future without affecting its long-term sustainability.
The expected harvest cuts are a result of the rotational management system currently employed by the fishery. In this system, scallopers fish in certain designated areas during certain seasons while leaving other areas untouched, giving the scallops there time to mature and reproduce. The way the rotational system is currently managed, a sizeable percentage of the scallop biomass is not considered when estimating yearly catch levels, because they are located in closed areas that are off-limits to the fleet. That is why it is possible to have a significant decrease in the catch level, as anticipated for next year, even if there is currently no indication that scallops are being mismanaged or overfished.
Yearly fluctuations in the availability of scallops may not seem to matter much, but their impacts on the fishery can lead to large economic losses. Producing a marketable product, like Atlantic sea scallops, requires being able to regularly deliver a consistent supply. Significant harvest cuts that result in steep decreases in scallop availability from year to year will decrease the market's demand for them in the long run, meaning that next season's anticipated harvest cuts could be felt for years to come.
While Mr. Shelley asserts that the industry's "stewardship of the last closed areas they were allowed to go into has failed to achieve its promised outcomes," recent scallop management has been mostly successful. The scallop population is considered to be rebuilt, and according to the most recent estimates from the New England Fishery Management Council (NEFMC) they are not overfished. In a recent article in The Boston Globe, NOAA Northeast Regional Administrator John Bullard praised the scallop fleet, saying, "they have become tremendous stewards of this resource."
The overall number of scallops remains high, with the Council's Scallop Plan Development Team (PDT) estimating in October that the total 2014 scallop biomass would be around 133,000 metric tons; for the species to be overfished, biomass would need to fall below 62,000 metric tons. While recruitment on Georges Bank has been relatively low over the past two years, there are promising signs of large numbers of young scallops in some areas. Contrary to Mr. Shelley's claims, overall landings per unit of effort (LPUE, a way of measuring efficiency) are not decreasing, and the PDT actually projects an increase in LPUE for 2014. These are all indications that the scallop fishery is sustainably managed.
Because the prospective cuts are not in response to a larger trend indicating a decline in the scallop population, the scallop industry maintains that they are ultimately unnecessary, and represent a failure of management rather than a failure of conservation. While these cuts in the scallop catch are due to the fact that many of the scallops in the open rotational areas are too young to be harvested, this is not an indication that scallops are overfished. More scallops could be sustainably harvested, but scallopers are prevented from doing so by current regulations.
In our testimony, FSF did not claim that the current management system has failed or that it should be abandoned, but that changes are needed to give the fleet the flexibility and consistency it needs to meet the demands of the market. Maintaining all of the Georges Bank closures simply allows the scallops inside of them to age and die, providing no benefit to the fishery or to fishing communities. Allowing the fleet into some of the closed areas will allow access to more scallops, and introduce more areas into the rotational system. This will result in a more consistent scallop catch without threatening the sustainability of the scallop fishery.
While Mr. Shelley is generally dismissive of the scallop industry's track record on conservation, the industry has long advocated for a sustainable scallop fleet. They have strongly supported the system of rotational areas, and have been in the lead among New England fisheries in funding cooperative research that has greatly improved scientific understanding of both the scallop resource and seafloor habitats. Their advocacy on behalf of opening closed areas is not a break from this tradition, but rather a continuation of it.
The Fisheries Survival Fund (FSF), represents the majority of the full-time Limited Access scallop fleet.
References
Dyer, John, "Scallops giving New Bedford fishermen a welcome break," The Boston Globe, December 1, 2013
Hart, Dvora, "Sea Scallop ABC and Fishery Status Update," Northeast Fishery Science Center
New England Fishery Management Council, "Framework 24 to the Scallop FMP and Framework 49 to the Multispecies FMP," February 2013
New England Fishery Management Council, "Draft Framework 25 to the Scallop FMP," December 2013
New England Fishery Management Council, "Draft Summary of Sea Scallop stock status and fishery"