Management & Regulation

July 18, 2012 — NOAA’s National Marine Fisheries Service has apologized to the squid fleet for failing to effectively announce the July 9 closing of directed squid fishing, carried out in the waters off Massachusetts, Rhode Island and New York — a shutdown that fishermen say needlessly cost them time and money.

Based on projections that 90 percent of the Trimester II quota of 5,366 metric tons was taken, the NMFS’ Northeast Regional Office based in Gloucester’s Blackburn Industrial Park issued the closing order on the afternoon of July 6. But instead of notifying the fleet by email or the electronic vessel monitoring system (VMS) that most boats use to give NMFS the required 72 hours notice of a planned trip, the Gloucester office mailed and faxed the announced closing on July 6 to holders of squid permits. The National Oceanic and Atmospheric Administration did not email the announcement until after 8 a.m. July 10 — more than eight hours after the fishery closed.

The inadequate and belated communication of the closing meant wasted time and resources and in some cases lost fishing opportunities for some boats, such as Mark Phillips’ 73-foot Illusion. Phillips said in a telephone interview that he ended a trip after four days of successful fishing about 15 hours from Point Judith, R.I. and 14 hours from Cape May, N.J. and, unaware of the closing, was steaming in to reload with ice and gas for another trip.

Had he known of the closure, Phillips said, he would have remained at sea for a fifth day and maximized his catch. He lives in Greenport, N.Y., but fishes mostly out of New Bedford.

Phillips is a member of Northeast Sector XIII, one of the 13 fishing cooperatives organized by Gloucester’s Northeast Seafood Coalition to participate in the the commodification of the groundfishing industry by NOAA, a system that went into effect in May 2010. Many fishermen, like Phillips, hold permits to fish for other species in addition to groundfish.

“We were all expecting the closure, we just didn’t know when,” Phillips said. “We made business decisions; I would have made a full five-day trip instead of a four-day trip.” He estimated the lost day’s fishing cost him about $10,000 in catch based on the current price of about $1 to $1.10 per pound at the dock for the longfin squid. “It’s the best season we’ve had in a long time,” he added.

“In this day and age of universal, instantaneous communications, it is flat out unacceptable that (NMFS) failed to alert our fishing community about this closure and cause many of them to lose tends of thousands of dollars on a wasted journey,” U.S. Sens. Charles Schumer and Kirstin Gillibrand and Congressman Tim Bishop, all of New York, said in a statement Tuesday.

Also Tuesday, Daniel S. Morris, NMFS’ acting regional administrator in Gloucester, issued a statement of his own.

 

Read the full story in the Gloucester Times 

Read Captain Phillips' letter to Daniel S. Morris, NMFS’ acting regional administrator

 

 

WASHINGTON – July 18, 2012 – Last Friday, the Fisheries Survival Fund (FSF), an industry group that includes the majority of full-time, limited-access scallop permit holders, wrote to Dr. Bill Karp, the newly appointed Director of NOAA’s Northeast Fisheries Science Center, to address serious concerns regarding NOAA’s most recent assessment of the Georges Bank yellowtail flounder stock.

The following information regarding the letter has been provided to Saving Seafood by the Fisheries Survival Fund:

In their letter, referring to the recent Transboundary Resource Assessment Committee (TRAC) meeting that discussed the yellowtail stock, FSF stated, “Despite all of the hard work of the [Georges Bank] yellowtail stock assessment team, those of us at the meeting were presented with a seriously flawed assessment.”

The scallop industry is concerned about yellowtail flounder because yellowtail can inhabit the sea bottom in the same areas as scallops. If scallopers’ yellowtail flounder allocations are reduced to low levels, it will act as a choke species, preventing fisherman from harvesting scallops.

The letter, which was signed by Fisheries Survival Fund legal counsel Drew Minkiewicz and David Frulla, stated that, “…all too often [the center that Mr. Karp now leads] takes the approach of trying to solve an assessment problem by reworking the existing data and using numerous statistical tools.”

After noting that NOAA’s scientists have not been able to resolve the problems in the model without contradicting NOAA’s own prior public statements on the subject, FSF observed, “If the model is not capable of accounting for the unknown aliases, the answer is not to put one’s head down and go forth into that statistical night; rather, it is to accept the limitations of the model and acknowledge the obvious: we are currently in a place that is beyond the capability of the current model, making the model no longer useful for catch advice.”

FSF told NOAA that NOAA Fisheries, formally known as the National Marine Fisheries Service (NMFS), “…needs to redirect its limited resources away from the computer models and towards field research.” They continued, “What we are asking for, and believe the fishing industry and nation deserve, is a defensible process for setting catch quotas and a partner in moving forward to improve our understanding of this critical stock. “

Last May, a new assessment of the Georges Bank yellowtail flounder stock found that the previous assessment was over-optimistic in its estimates, and that the catch limits produced from that assessment resulted in overfishing of this stock. As a result, the total Georges Bank yellowtail harvest was reduced to 540 metric tons for 2012; half of the 2011 catch level.

FSF further asks that NOAA recognize that the current yellowtail assessment is not viable for use as a basis for catch advice. In addition, FSF encourages the use of alternate catch advice methods to set allocations for Georges Bank yellowtail flounder, and implores NOAA to embark upon an expanded biological research program for yellowtail flounder to help try to identify the causes of the model’s flaws, so they can be resolved in a principled way.

FSF did not request any repeal of pre-existing yellowtail catch quota reductions , and is not pressing for a new benchmark assessment at this time. Rather, FSF asks for more reliable science, a more thorough biological research process, and a better assessment model for the basis of yellowtail management. All these steps need to be taken before NOAA embarks on a comprehensive benchmark assessment, or else the next assessment won’t be any better than the last. FSF wrote, “If there are to be cuts in the fishery, so be it, but it must be done in an open and justified manner."

Failure of the 2005 “split series” correction

In 2005, the yellowtail assessment began to show a retrospective pattern, which is an indicator of inaccuracy within a model. To correct for this, the 2009 assessment team split the time series of yellowtail data, meaning that they applied different catchability rates to data collected after 1995, masking from view any of the unknown and potential causes of the retrospective pattern. However, the disappearance of this retrospective pattern was only temporary. It recently re-emerged, indicating that there are deeper problems within the model.

Upon the retrospective pattern’s return this year, the assessment committee tested several ways to correct their model. The team ran three different trials, adjusting the natural mortality rate, catch rate, and both values, attempting to fit the data to the model, and eliminate the retrospective pattern. But in order to do so, they had to adjust these values by as much as four to five times their original figures. The committee considered these values too great to include them as the possible explanations for the retrospective pattern, leaving the cause still unclear.

Despite the admitted presence of a retrospective pattern in the model, and the unknown cause of that pattern, the assessment continues to be used to provide management and catch advice for the fishery. NOAA Fisheries asserts that their adjustments are adequate to fix the unknown underlying problems, directly in contradiction to their own prior statements. FSF points out that assessments marked with retrospective patterns are not acceptable for use in management decisions, citing NOAA’s Chris Legault in a 2008 Retrospective Working Group meeting: “A strong retrospective pattern is grounds to reject an assessment model as an indication of stock status or the basis for management advice.”

FSF asked, “Does NMFS intend to follow its own advice?”

Not asking for “more fish” but for “defensible, empirical findings”

In summary, NOAA Fisheries is asking the industry to assume responsibility for a 50% reduction in quota, on top of a 50% reduction in quota from the previous year, based on flawed techniques that, even by NOAA’s own statements, should be excluded from consideration.

Despite the abundance of problems within the data, TRAC was reluctant to reject the assessment because no alternative method for giving catch advice was available. FSF requests that, until these problems can be eliminated, that catch advice be based on catch data and surveys, rather than the flawed assessment. To act otherwise would invest the future of both the scallop and groundfish fisheries in unreliable and problematic data. That is not in the best interests of either industry, nor of federal management organizations.

FSF asserts that the focus of research must shift from statistical to biological. As it stands, many concerning trends in the yellowtail population still lack a tangible, biological explanation. Although these issues remain unresolved, the agency continues to move forward with a current assessment model that will strike a catastrophic blow to both the yellowtail and scallop fisheries alike.

According to FSF, the scallop industry is committed to maintaining a sustainable stock size of Georges Bank yellowtail flounder, and has demonstrated that pledge through their continued partnership with The University of Massachusetts School for Marine Science and Technology (SMAST) bycatch avoidance system. Working together with SMAST, and in cooperation with NOAA Fisheries and the New England Fisheries Management Council via their Scallop Research Set-Aside Program, great opportunity exists to develop better research programs and more sustainable harvesting practices without relying on arbitrary and mutually detrimental data.

Concluding their letter, FSF offers further and final clarification that their motivation to submit written comments to NOAA is not simply to be permitted to catch more fish from the sea, but, instead, to establish an ongoing effort to replace currently flawed data and models with defensible, empirical findings.

They request that NOAA Fisheries acknowledge that the current Georges Bank yellowtail flounder assessment is not suitable for providing catch advice; provide the public with an objective set of criteria to judge the viability of an assessment; as an interim measure, that NOAA Fisheries and the New England Fisheries Management Council provide catch advice using alternative catch advice strategies that rely on survey and catch indices; and that NOAA Fisheries works with FSF and other interested parties in developing and executing a research program for Georges Bank yellowtail flounder with the goal of creating a credible stock assessment.

 

Read the original FSF letter here 

 

 

July 17, 2012 — A top federal fisheries official on Tuesday apologized to regional fishermen for the abrupt closure last week of the longfin-squid grounds, a move that some Long Islanders said cost them tens of thousands of dollars.

Managers usually provide several days notice of closures, which take place when the allotted quota of a targeted species is reached based on vessel landings reports, but in the case of the squid fishery, most fishermen received notice just hours before the closure.

Daniel S. Morris, acting regional director for the northeast at the National Marine Fisheries Service, in a publicly released letter acknowledged that two primary methods for alerting fishermen of the closure "did not work."

Fishermen such as Mark Phillips of Greenport said they did not receive word until the afternoon of July 9, just hours before the closure, while he had already steamed to the fishing grounds and had loaded his vessel with ice and supplies. He had to return by midnight.

Three Democratic New York lawmakers, Sen. Charles Schumer, Sen. Kirsten Gillibrand, and Rep. Tim Bishop of Southampton, called the agency to task, and demanded that it explore more modern alternatives to communicate with fishermen, and a better system of advance notice.

 

Read the full story on Newsday

 

 

July 17, 2012 — BOSTON (AP) Federal regulators are eliminating restrictions that aim to stop scallop fishermen from snaring sea turtles, saying they're unneeded because rule changes and gear modifications are protecting the reptiles.

The National Oceanic and Atmospheric Administration says it's lifting restrictions the fleet now faces in the mid-Atlantic during May through November, when it's shut out of certain areas because of the risk of running into the migrating turtles. The agency says it will instead monitor fishing and evaluate gear changes, which appear more effective at protecting turtles.

The booming scallop industry has, for instance, developed a dredge that knocks turtles out of its way before the endangered animals get trapped. Also, trawl nets used by scallopers have been modified so there's an escape vent turtles can slip through.

The Fisheries Survival Fund, an industry group, said scallopers worked for nearly a decade to develop the dredge with researcher Ron Smolowitz of the Coonamessett Farm Foundation in Falmouth. It said it appreciates that NOAA recognizes what the group has done to protect turtles.

The New England Fishery Management Council still must pass new regulations to officially lift the current restrictions on the scallop fleet in the mid-Atlantic. Federal officials are aiming to have the changes in place by March 2013, the start of the next fishing year for scallopers.

 

Read the full story from the Associated Press in the Boston Globe

 

 

GLOUCESTER, Mass. – July 16, 2012 — Last week, United States Senators Charles E. Schumer and Kirsten Gillibrand and Congressman Tim Bishop blasted the National Oceanic and Atmospheric Administration (NOAA) for failing to properly notify the Long Island, New York fishing industry that a closure of the squid fishery was imminent, costing local fishermen thousands of dollars in haul preparation costs that cannot be recovered. A week ago Friday, NOAA sent out notification to a limited universe of fishing interests, via fax, notifying them that the 90 percent of the Longfin Squid fishery had been harvested and would be closed the following Monday. Word of the impending closure did not reach many in the industry until days later, after many boats were at sea, having purchased fuel, ice, and provisions for up to five days.

Read the press release from United States Senators Charles E. Schumer and Kirsten Gillibrand and Congressman Tim Bishop

Today, NOAA Fisheries' Northeast Regional Office mailed a letter of apology to affected fishermen.  The apology will be posted to their website tomorrow.

The text of the apology follows:

The longfin squid fishery was closed on July 10 as our catch projections showed that 90% of the Trimester II quota would be caught. We announced the closure on the afternoon of July 6, but two of our primary means for providing the information to industry did not work. I have heard from fishermen that the poor communication caused confusion, inconvenience, and, in some cases, unnecessary expenses. I apologize for the poor communication and am committed to improving.

Typically, when we have time-sensitive news to announce, we place paper copies of the permit holder letter in the mail, air messages over National Weather Service Radio and Coast Guard Broadcast, and email constituents who have opted to receive emails from us at nero.noaa.gov. We do not typically send VMS messages for longfin squid closures because VMS is not required for longfin squid permit holders.

These notification methods are obviously not foolproof, and our communication leading up to the July 10 closure have prompted us to troubleshoot and rethink how we pass time-sensitive information to the fleet. We seek your help. We will investigate the costs and utility of using VMS to notify vessels of longfin squid closures.

We'd also like to hear any ideas you may have for improving our fleet notifications about other time-sensitive actions. Contact the Sustainable Fisheries Division at 978-281-9315 if you have suggestions.

Sincerely,

Daniel S. Morris
Acting Regional Administrator 

 

View the original letter here

 

 

July 14, 2012 — The National Oceanic and Atmospheric Administration has approved the transfer of approximately 332,016 pounds of Georges Bank yellowtail flounder quota from the scallop fleet to New England groundfishermen in an action supported by both groups. The transfer is intended to provide some desperately needed relief to the groundfish fleet. Regulators had reduced its yellowtail quota by 80 percent this year while the scallop fleet took only 31 percent of its assigned yellowtail quota last year.

The Fisheries Survival Fund, a scallop industry group, expressed its appreciation for the move in a letter, dated July 12, to Samuel Rauch, deputy assistant administrator for NOAA's Fisheries Service. However, the letter also emphasized the government agency's need to develop better tools for tracking yellowtail.

"Scallop fishermen currently pay observers to track (yellowtail) bycatch during fishing operations," the letter said, "and yet NOAA Fisheries takes five to six months before the observer data is integrated into the catch estimates."

 

Read the full story in the New Bedford Standard Times

 

 

WASHINGTON – July 13, 2012  – The Fisheries Survival Fund and the Northeast Seafood Coalition, the primary industry groups representing the northeastern scallop and groundfish industries, respectively, have responded to NOAA's announcement that 332,016 pounds of yellowtail quota will be transferred from the scallop industry to the groundfish industry.

The Fisheries Survival Fund stated:

Today, NOAA announced that it will adjust the Georges Bank yellowtail flounder quotas for the scallop and groundfish industries, "to preserve fishing opportunities for both industries." The adjustment will move 332,016 pounds of allowable yellowtail from the commercial scallop industry to the groundfish fishery. As Samuel Rauch, deputy assistant NOAA administrator for NOAA's Fisheries Service stated in today's press release, both the scallop and groundfish industries worked together "to find an effective solution to a very difficult situation."

Yesterday, the Fisheries Survival Fund, whose participants include the majority of full-time, limited-access scallop permit holders, wrote to Mr. Rauch to express appreciation for his efforts regarding Georges Bank yellowtail flounder annual catch limit issues, to outline remaining concerns, and to reaffirm their position on the transfer. 

The letter noted the following:
In its vote to recommend the reallocation, the New England Fishery Management Council also voted in favor of an emergency measure, "indemnifying" scallopers should they exceed their reduced sub-ACL in the 2012 fishing year. Without the indemnification provision, the scallop industry could not support the reallocation.  
Because this major switch in quotas (a reduction of about half of the scallop's previous quota) occurs in the middle of the fishing season, and the allocation changes are not based on in-season data on the amount of yellowtail bycatch, or the location in which the scallop industry operates.        

Before any further changes to annual catch limits and accountability measures are made, better tools for tracking yellowtail bycatch need to be developed and used. Scallop fishermen currently pay observers to track bycatch during fishing operations, and yet NOAA Fisheries takes five to six months before the observer data is integrated into the catch estimates. The scallop fishermen have no reliable way to keep track of their yellowtail bycatch, and a long period of uncertainty before learning of the potential imposition of accountability measures. It is unfair to the fishermen to impose reactive accountability measures without giving the fleet a real time indicator of whether or not they are in accordance with the set quota.       

Other alternatives for accountability measures should be considered, such as the use of a three-year average (as permitted under National Standard 1 Guidelines) for determining when quotas have been exceeded. This method is currently used in many fisheries where the annual catches are highly variable and season data is often unreliable. Under a three year average, the scallop industry could avoid reactive closures if the catch limits were exceeded in only one out of the three years, as long as average remained under the limit.

The letter also emphasizes the importance of the ongoing and highly-successful efforts to develop technology to reduce the incidental bycatch of yellowtail flounder. FSF has been working with NOAA Fisheries and its academic research partners via the Research Set-Aside Program to research and develop operational and gear-related methods to reduce bycatch.  They are also working with the University of Massachusetts School for Marine Science and Technology (SMAST) to expand the bycatch avoidance system that has been producing effective results. These measures should eventually provide a better alternative to the current closure-based accountability measures that cause so much uncertainty and potential loss of scallop optimum yield.

Read the letter from FSF counsel to NOAA Fisheries

The Northeast Seafood Coalition stated:

The Northeast Seafood Coalition ("NSC")-a membership organization that represents 254 small-business entities with 514 permits that operate in the commercial groundfish fishery from Maine to New Jersey-supports today's announcement from the National Oceanic & Atmospheric Administration's National Marine Fisheries Service ("NMFS") to initiate a transfer of approximately 332,016 pounds Georges Bank yellowtail flounder to the commercial groundfish fishery. This action will help to alleviate the severe economic hardship being faced by many NSC members that need yellowtail in order to fish on Georges Bank.

NSC board member and multiple vessel owner Thomas Williams praises the NMFS for recognizing the need for immediate action. "I think it saved the hides of a lot of people. Had [this action] not been made, I don't know that many fishermen could have survived. We know there's an abundance of yellowtail out there, so many that we wouldn't have been able to fish for winter flounder or any flat fish without catching yellowtail. I'm very happy they made this decision. It's critical to our operation," Williams said.

Based on results of a NEFMC requested Georges Bank Yellowtail Working Group and a joint Groundfish and Scallop Committee meeting held in June, it was recommended by the New England Fishery Management Council ("NEFMC") that NMFS utilize existing authority provided in groundfish management plan Framework 47 to immediately transfer 156.9 metric tons ("MT") or 90 percent of the 174.3 MT of GB YT from the Atlantic scallop fishery sub-annual catch limit (ACL) to the groundfish sub-ACL based on revised projections of 2012 GB YT bycatch by the Atlantic scallop fleet. Furthermore, any unused GB YT should be transferred to the groundfish fleet by January 15, as outlined in the existing regulations and based on actual catch from the scallop fleet in fishing year 2012.

The NEFMC motion addressed the oversight made in Framework 47 where the updated projection of GB YT bycatch by the Atlantic scallop fleet did not make it into the final number approved by the Council for the current fishing year 2012.

Furthermore, the Council's motion also requested NMFS initiate an Emergency Action to temporarily relieve the Atlantic scallop fishery from any AM triggered by catch less than 307 MT of yellowtail flounder catch by the scallop fishery that under the current scallop regulations would be required if the sub-ACL is exceeded in 2012. Instead, the pound-for-pound repayment provision of the U.S./Canada agreement could be utilized should the total allowable catch be exceeded for FY 2012.

The NSC appreciates the leadership provided by Council and NOAA leadership to address this crisis. NSC strongly thanks NMFS for their quick action, which will enable groundfish fishermen to make reasonable plans for how to make the best use of what is an extremely small overall ACL for the United States fishery in 2012.

On two separate occasions, in September 2011 and May 2012, the Northeast Seafood Coalition wrote to the NEFMC and NOAA Fisheries Service respectively, urging the reevaluation of estimated Georges Bank yellowtail flounder by-catch in the Atlantic scallop fishery and to adjust sub-allocations of the scallop and groundfish fleets accordingly. NSC staff and leadership have been heavily focused on this critical issue with participation on the Georges Bank Yellowtail Working Group and exchanges with NOAA leadership and the NEFMC to assist in the drafting of the transfer mechanism in FW 47 utilized today.

The following was released by NOAA Fisheries:

WASHINGTON, D.C. – July 13, 2012 — NOAA today announced that it will adjust the 2012 Georges Bank yellowtail flounder quotas for both commercial scallop and groundfish fisheries to preserve fishing opportunities for both industries.

This action – supported by both groups – transfers approximately 332,016 pounds of yellowtail quota from the scallop industry to the groundfish industry. As a result, this year's yellowtail quota for the groundfish fishery will increase by 69 percent to just over 811,301 pounds, allowing additional opportunities to harvest other groundfish stocks. The yellowtail quota for the Atlantic sea scallop fishery will decrease by 49 percent to approximately 346,126 pounds.

Although this is a reduction of yellowtail flounder bycatch quota for the sea scallop fishery, the revised allocation will provide enough yellowtail flounder to account for what is typically harvested by scallop fishermen in a year.

This action was recommended by the New England Fishery Management Council, with input from the Georges Bank yellowtail flounder working group, which includes representatives from the council's scallop and groundfish committees, council staff and NOAA. Environmental community members also expressed support for the adjustment.

"The scallop and groundfish industries and NOAA's Fisheries Service have worked together to find an effective solution to a very difficult situation," said Samuel Rauch, deputy assistant NOAA administrator for NOAA's Fisheries Service. "This transfer would not be possible without cooperation between the two industries. It enables both fisheries to continue to operate, while still protecting the yellowtail resource."

The council also requested that NOAA remove accountability measures for the scallop fishery, which would close certain fishing areas in 2013 if the scallop fishery catches more than its 2012 yellowtail flounder quota. However, the groundfish fishery accountability measures would remain in place to protect the Georges Bank yellowtail flounder stock and prevent overfishing if the overall U.S. yellowtail flounder quota was exceeded during the 2012 fishing year.

NOAA intends to address the council's request for removing accountability measures in a separate rulemaking. As soon as the necessary technical analysis is complete, NOAA will publish a rule in the Federal Register proposing to remove the scallop fishery's accountability measure, as requested by the council.

Read the release from NOAA here.

 

 

The following article was published by the Coastal Conservation Association:

July 2, 2012 – Last week the Atlantic States Marines [sic] Fisheries Commission’s (ASMFC) Stock Assessment Committee and Technical Committee met to finalize the stock assessment update and advice they may give the Board for managing menhaden.

To reset the situation, according to the last benchmark assessment four years ago, the stock was undergoing overfishing, recruitment was at or near an all-time low, and abundance was at an all-time low.  Not a good situation for a species whose primary ecological attribute is its historic, teeming abundance which has made it one of the primary forage species for gamefish like striped bass, bluefish, weakfish, bluefin, king mackerel and many others.

Menhaden has been allowed to decline to this low level using the reference points endorsed by the Technical Committee and the management advice based on those reference points by the Technical Committee.   Simply put, the advice of the Stock Assessment Committee and the Technical Committee has failed the Board and the fishery.

At the last benchmark assessment, independent scientists reviewed the stock assessment and noted what the public has been saying for years:  the stock is in a state of decline.  Yet the management guideposts (reference points) did not signal any problems.  The independent scientists suggested the Management Board adopt new reference points that took into account the historic abundance of menhaden.

So it was not surprising that the Board took the advice of the last peer review and adopted new, more conservative reference points.  They adopted a 15 percent Maximum Spawning Potential (MSP) – which is a spawning stock that is 15 percent of an unfished stock – as the threshold and 30 percent  MSP as the target, all perfectly reasonable, commonly used reference points. At the time it would have taken an estimated 10-15 percent reduction in harvest to meet the threshold of 15 percent MSP, and about twice that to meet the target reference point mortality rate.

The Board asked for a stock assessment update (which would add three more years of data to the last benchmark assessment to see where we are today), and that’s where the current problems start.  The model started acting up when the last three years of data were added.  The Stock Assessment Committee finally came to the conclusion that the results were so questionable that it was not useable for offering management advice. The two Stock Assessment Committee members who argued the hardest for not offering any management advice until the stock assessment was fixed were both employees of the National Marine Fisheries Service (NMFS).

Not to be forgotten in this new intrigue are the facts that this is a stock for which managers have a 55-plus-year time series of data, it is at a low level of abundance, there is evident age truncation, and the fishing mortality rate has been increasing in recent years.

And the Technical Committee can’t offer management advice? Really?

Read the full story from the Coastal Conservation Association.

Analysis: The Coastal Conservation Association, in its article "Menhaden Management Not Passing the Smell Test," alleges that the Stock Assessment Subcommittee and Technical Committee of the Atlantic States Marine Fisheries Commission (ASMFC) are being unnecessarily cautious in the preparation of advice they are developing to eventually be delivered to the full Commission for menhaden management. It criticizes the menhaden Stock Assessment Subcommittee for concluding that they do not have enough information to offer appropriate management advice, based on the unreliability of the current data. The author, Ted Venker, argues that the previous 55 year series of data is sufficient to manage the stock. In doing so, the author understates problems with the current management model, and the uncertainty surrounding the most recent data collected on the fishery.

At the last menhaden Technical Committee meeting, it was observed that the updated assessment showed a retrospective pattern, meaning that the estimates in previous population assessments contradicted the population estimates in the current assessment, and needed to be revised in order to fit the more current data. The appearance of retrospective patterns is a sign that a particular stock assessment model may not be working and that the data being produced is not reliable. To fix a retrospective pattern the assumptions that went into making the model need to be revised. Chris Legault, Chair of the NOAA Retrospective Working Group in their January 2008 Report wrote, "a strong retrospective pattern is grounds to reject an assessment model as an indication of stock status or the basis for management advice."

The appearance of a retrospective pattern is not the only problem with the menhaden update assessment, as the fish abundance indices have also produced contradictory and unreliable data. The menhaden assessment uses two separate indices that are compiled to estimate the total population size: an index of older fish based on fisheries data, and an index estimate of juvenile fish obtained from shallow water sampling. The juvenile abundance index has remained stable over the last few years, while the adult abundance index has been increasing. If the proportion of older fish in the population is increasing, but juveniles are remaining constant, this implies that fewer adult fish are being removed from the water. The assessment asserts the opposite.

According to the assessment, fishing mortality is actually increasing. To explain this inconsistency in the assessment, it is possible that either the calculations for the model used on the indices are inaccurate and producing faulty data, or that the claim that mortality is increasing is incorrect. Having an inaccurate measure of both abundance and mortality makes it difficult to determine if fishing targets are being met, and makes it hard to recommend appropriate catch limits. This problem was recognized by the ASMFC in its reluctance to use this data to formulate management advice.

The appearance of many such issues has raised concerns within the menhaden Stock Assessment Subcommittee. Matt Cieri, a Subcommittee member, stated in their June 15th conference call, "The problem is that we've uncovered major problems with the tool we were planning on using to determine status and do projections." Erik Williams, Chair of the menhaden Technical Committee, also expressed doubt about the usefulness of the data in a May 29th conference call. "We also need to decide whether this is useful for management right now," he said. "Unfortunately, we don't have the time to fully understand what is going on, but we can convey the troubling diagnostics we're looking at." These views were part of the consensus reached by the Subcommittee that the current data might not be reliable enough to serve as the basis for important management decisions.

The article also makes the accusation that May's menhaden Technical Committee meeting included inappropriate participation from industry experts, Drs. Doug Butterworth and Michael Prager, claiming that they, "nearly led the discussion." However, Bob Beal, acting Executive Director of the ASMFC, stated in an interview that their participation did not violate protocol, saying, "My understanding is that they weren't inserting themselves beyond what the chair was allowing at the meeting."

By criticizing the ASMFC for its hesitance to make management decisions based on flawed data and its acceptance of outside advice, Mr. Venker a ignores the goal of the stock assessment process, which is to manage the stock according to the most up-to-date and scientifically sound data. The author advocates managing the species based on unreliable data, which would benefit neither the interests of the fishery, nor the long-term goals of conservationists.

 

 

July 9, 2012 — NOAA Fisheries Service will be holding a series of workshops to gather more information to inform its review of whether river herring species should be listed under the Federal Endangered Species Act.

The second workshop on River Herring Extinction Risk Analysis is being held on Tuesday, July 10, 2012, at the EPA building at 5 Post Office Square, Boston, MA, from 9 am to 4 pm, in The Memorial Hall on the 2nd floor.  To view the agenda please visit our River Herring webpage.  

If you wish to attend the workshop in person please contact the workshop organizer Sarah Laporte (sarah.laporte@noaa.gov) to confirm that space is still available.

To listen to the workshop proceedings via telephone, please use the following call-in information and give this verbal passcode to the operator.

Call in number:  1-888-946-7614
Passcode: River Herring

A corresponding webinar will also be accessible via Join.Me  at  https://join.me/916-548-242

Please note: Adobe Flash is required on a PC or Mac.

Further details about Phone and Audio Participation can be found on the River Herring Page under Webinar Instructions link.