John Sackton’s November 18, 2009 Seafood.com news article entitled NE Council adjusts 3 year herring quota upward over objections of Pew contains several errors and misconceptions about the Pew Environment Group’s work to reform herring management in New England, and we would like to take this opportunity to correct these errors. To start, the Pew Environment Group leads the Herring Alliance (www.herringalliance.org), a broad coalition of local, regional, national and international conservation groups. The mission of the Herring Alliance is to reform the Atlantic herring fishery as follows:
-To establish ecosystem-based catch limits which leave sufficient herring in the ecosystem as forage for other marine predators.
-To spatially and temporally apportion herring trawling using buffer zones and time and area closures which both minimize bycatch and avoid localized depletion to ensure sufficient herring is present when and where they are needed as prey.
-To fully monitor and minimize bycatch of commercially and recreationally important fish stocks Ð including juvenile or spawning Atlantic herring and depleted river herring and groundfish Ð as well as whales, seals, dolphins and porpoises.
Mr. Sackton’s assertion that Pew, along with some inshore river herring fishermen, have been arguing that herring should essentially not be fished at all because it is a forage fish, and therefore should be reserved within the ecosystem for those other fish that eat it, such as cod etc. is wrong on two levels.
First, a wide and diverse group of people within the conservation community, as well as the recreational and commercial fishing industries, are working to limit industrial herring trawling and bring greater accountability to the Atlantic herring fishery. Long before Pew began its herring campaign in 2007, the CHOIR Coalition (www.choircoalition.org), which was formed in 2002 by commercial and recreational fishermen, such as the East Coast Tuna Association and the Recreational Fishing Alliance, was already working to change herring management and to keep midwater trawl ships out of inshore waters.
Second, Pew does support a herring fishery. We support New England’s traditional fixed gear and purse seine fisheries that provided bait to lobstermen and Maine canneries until they were displaced by industrial-scale trawlers from the West Coast and Europe. Our concern is with midwater trawl gear, which we believe to be of a scale that is inconsistent with the rebuilding of groundfish and the health of the Northwest Atlantic ecosystem. We have never said, advocated for, or written that there should be no herring fishery.
In his article, Mr. Sackton indicates that midwater trawlers can fish for herring in groundfish closed areas so long as they have observers. This is not correct. A quick check of the regulations reveals that midwater trawlers are only required to take observers in Closed Area 1, a regulation that has only been in effect since November 1, 2009, less than one month. Midwater trawl ships are not required to have observers in the Western Gulf of Maine closed area, the rolling closures, Closed Area 2, the Nantucket Light Ship Closed Area, or any other closed areas.
The article goes on to state that The irony is that the result of efforts by Pew to curtail herring fishing have fallen mainly on the smaller inshore fishermen and lobstermen in Maine. Most of the proposed changes in monitoring rules will impact purse seiners more than trawlers. This is simply not correct. In truth, the monitoring program currently being developed by the New England Fishery Management Council, known as Amendment 5, contains a wide range of options, none of which impact seiners more than trawlers.
The article argues that the idea of overall maintaining reduced catch levels was neither controversial nor contested. The view of the council standing strong against lobbyists and a rapacious industry is a fantasy useful to Pew. All sides, industry and scientists, agree on the need for reduced harvests. In fact, a different reality becomes clear when you read this excerpt from a letter written by herring industry lawyers to Council Chairman John Pappalardo on November 13, 2009:
The likely upper range of TACs [Total Allowable Catches] suggested by the SSC [Scientific and Statistical Committee] is likely to be 107,900 mt [metric tons]. In order to minimize adverse economic impacts, this should be considered a floor, not a cap.
This letter clearly states that the industry believes that the maximum level set by the council’s SSC should be a floor not a cap. A letter from a Massachusetts congressman on behalf of the industry had similar sentiments, requesting the status quo (145,000 mt) be approved until a new benchmark assessment can be done. In addition, herring industry lobbyists have been in Washington, D.C., at the National Marine Fisheries Service headquarters in Silver Spring, Md., and at Herring Advisory Panel and Herring Oversight Committee meetings with the same requests for the status quo at 145,000 mt until a new benchmark is done.
The actual situation unfolding here is that industry lawyers and lobbyists have fought and continue to fight to have the SSC’s recommendation for Allowable Biological Catch (ABC) act as a floor, thus making the Annual Catch Limit higher than the recommended ABC. The issue is not what we or others might think of this position. It is simply a fact, not a fantasy as Mr. Sackton claims.
Finally, the article refers to a major victory for herring operators and comments that the statement put out by Pew on herring appeared to describe a different meeting. So as not to leave room for any misunderstanding by Mr. Sackton regarding our position, we support using the recommendation for ABC from the council’s science committee. The SSC gave three options for ABC: 90,000 mt, 106,000 mt, and 108,000 mt. The council stayed within the recommendations of its SSC by choosing 106,000 mt. Because the council stayed within the SSC recommendation, Pew issued a press release praising their actions. In no way did we object to the council’s decision.
In closing, it bears mentioning again that Pew supports a herring fishery with comprehensive monitoring, science-based annual catch limits that take into consideration evolving predator needs, and gear types that are in scale with New England’s other fisheries. We hope that these clarifications result in more accurate reporting in the future.
Sincerely,
Peter Baker
Manager
New England Fisheries Campaigns
Pew Environment Group