WASHINGTON (Saving Seafood) December 12, 2012 – Yesterday, the offices of Representatives John P. Sarbanes (D-Maryland) and John Carney (D-Delware) sent a “Dear Colleague” letter encouraging their peers in Congress to join them in signing a letter to Robert Beal, Executive Director of the Atlantic States Marine Fisheries Commission (ASMFC), to support new catch restrictions on Atlantic menhaden. Both letters recycle claims of environmental groups, who have been pushing for heavy cuts to menhaden harvests. See our analysis below.
The policies endorsed by the two mid-Atlantic Democrats are opposed by the menhaden reduction and bait industries as well as the United Food and Commercial Workers Union Local 400 and the Maryland State Conference NAACP.
Protect Atlantic Menhaden, Boost East Coast Economies
From: The Honorable John P. Sarbanes
Date: 12/11/2012
PROTECT ATLANTIC MENHADEN TO BOOST OUR COASTAL ECONOMY POST-HURRICANE SANDY
Deadline to sign onto the letter is Thursday, December 13th at noon
Dear Colleague,
Please join us in writing to the Atlantic States Marine Fisheries Commission (ASMFC), an interstate body that manages coastal fisheries, to encourage them to follow through on their commitment to protect and rebuild Atlantic menhaden, a fish that is critical to our East Coast economy and ocean ecosystem. The recent disaster declarations resulting from Hurricane Sandy have added new challenges to the already difficult fiscal crisis, and Congress must respond with solutions that will help our coastal economies and communities recover and grow. Protecting Atlantic menhaden is a simple, budget-neutral and environmentally- friendly way to help stimulate economic growth in East Coast communities, while preserving thousands of jobs that are dependent on a healthy ecosystem.
Known as “the most important fish in the sea,” Atlantic menhaden are an essential food for many species that live in or fly above the Atlantic Ocean, including iconic species such as striped bass, bluefish, osprey, marine mammals and tuna. Their abundance directly impacts the economic health of East Coast economies and communities, where activities such as whale watching, recreational fishing and bird-watching generate billions of dollars annually.
The population of Atlantic menhaden has declined to a historically low level, less than 10% of levels seen in the 1980s, causing significant concern amongst scientists, coastal businesses, fishermen, conservation organizations and other concerned citizens. There is one industrial fishery for menhaden that accounts for the largest fishery by weight on the East Coast, as well as some small operations that catch menhaden for bait. Unfortunately, overfishing of menhaden in state and federal waters has been a longstanding problem, and the ASMFC has not taken advantage of proven management tools, such as catch limits, that would put the species on the road to recovery. Given the longstanding bipartisan support for Congressional oversight of federal efforts to conserve and restore Atlantic fish, wildlife, marine mammals and habitat, the decline of Atlantic menhaden represents a serious concern that must be addressed.
Last year, at the urging of over 90,000 concerned stakeholders, the ASMFC made a historic and near unanimous decision to establish science-based management goals for Atlantic menhaden. For the first time, the ASMFC recognized the overwhelming volume of constituents from New England to Florida that have an interest in a healthy population of menhaden, and took action to set goals in accordance with scientific advice. On December 14th, the ASMFC has the opportunity to implement a plan to achieve the science-based goals established last year. The public has already spoken. Over 115,000 people called on the ASMFC to immediately manage menhaden based on the best available science with proven management tools that will enhance accountability.
Congress must take advantage of budget-neutral, common-sense opportunities that will protect and enhance economic growth in our coastal communities, including those recovering from the tragedy of Hurricane Sandy, while also safeguarding the healthy ecosystems those communities rely on. Please join us in encouraging the ASMFC to follow through on their commitments to finally end overfishing and rebuild Atlantic menhaden to healthy levels, paving the way for economic and ecosystem recovery.
If you would like to sign the letter below to the ASMFC, or if you have any questions, please contact Helena Mastrogianis (Rep. Sarbanes, ext. 5-4016) or Justin German (Rep. Carney, ext. 5-4165).
Sincerely,
John P. Sarbanes (MD-03) John Carney (DE)
Member of Congress Member of Congress
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Mr. Robert E. Beal, Executive Director
Atlantic States Marine Fisheries Commission
1050 North Highland Street, Suite 200A-N
Arlington, VA 22201
Dear Executive Director Beal:
We are writing to request that the Atlantic State Marine Fisheries Commission (ASMFC) end overfishing immediately and rebuild the Atlantic menhaden fish population as soon as possible by establishing a coastwide science-based catch limit and a firm commitment to meeting the rebuilding goals in Amendment 2. In the wake of Hurricane Sandy, our Atlantic states are working together effectively in disaster recovery efforts aimed at restoring coastal businesses and ecosystems. In the same cooperative spirit, the ASMFC should act decisively to address menhaden depletion by passing Amendment 2 with a conservation plan that will quickly and effectively rebuild this resource and secure the extensive economic and ecological benefits it provides to our region.
Atlantic menhaden support billions of dollars of recreational and commercial activity from Florida to Maine. Menhaden are often referred to as “the most important fish in the sea” because they are a critical link in the marine food web and prey for a wide diversity of fish, birds and marine mammals, such as striped bass, bluefish, Atlantic tuna, whales and osprey. Atlantic menhaden supports one industrial fishery and nearly all Atlantic recreational fisheries. According to the National Oceanic Atmospheric Administration’s 2009 Fisheries Economics of the United States, recreational anglers took over 43 million fishing trips along the Atlantic coast in 2009, contributing nearly $11 billion in sales to the U.S. economy, $3.7 billion in value added impacts, while supporting over 90,000 full and part-time jobs. Given the significance of Atlantic menhaden to our recreational and commercial fisheries, as well as our tourism industries, we must avoid additional risks to Atlantic menhaden and focus on rebuilding this economic engine.
Currently, Atlantic menhaden provide only a fraction of their potential benefits because the population has been significantly reduced to less than 10 percent of levels seen in the 1980s. The population is currently subject to overfishing, and has been at or above this threshold for 54 of the past 57 years. Overfishing may continue without an overall limit on the number of menhaden that can be taken from the Atlantic Ocean. Vast quantities of Atlantic menhaden are caught in federal waters, yet the ASMFC has not taken steps to end overfishing in the state waters over which it has jurisdiction, nor made a recommendation that the federal government implement necessary conservation and management measures in federal waters. Specifically, the ASMFC must take decisive steps to end overfishing in accordance with scientific advice, like federally-managed fisheries which require catch limits to end and prevent overfishing.
We commend the ASMFC for responding to more than 90,000 constituent comments in November 2011 by adopting new science-based rebuilding goals in Addendum V and developing Amendment 2 to end overfishing and recover from a historically low level of abundance. The Commission can now ensure that the amendment process it initiated last year with strong public support will result in real changes on the water and in our coastal economies.
The ASMFC’s menhaden decision on December 14th can make a significant and lasting contribution to the success of East Coast state and federal restoration efforts. In Amendment 2, we urge the Commission to manage menhaden based on the best scientific information available, to adopt a coast-wide annual catch limit that can be implemented in 2013, to manage to the target fishing level in as short a time period as possible and to make a firm, time-certain commitment to reaching those target levels, and to reduce catch immediately to end overfishing and rebuild the Atlantic menhaden population. These proactive and common-sense steps will put menhaden on the road to recovery, safeguard a key component of Atlantic Ocean ecosystems, and help sustain and grow our vibrant coastal economies. Thank you for considering our request.
Sincerely,
Analysis: Both letters recycle many of the claims of environmental groups, who have been pushing for heavy cuts to menhaden harvests. These claims are full of half-truths, selective omissions, and misdirection, presenting a biased and ultimately inaccurate portrait of the fishery.
The Representatives’ claim that menhaden biomass has declined to “less than 10% of levels seen in the 1980s” is particularly selective, choosing to exclude most years for which there is available data on menhaden. Over the 50-plus years that data on menhaden biomass has been recorded by the ASMFC, abundance has fluctuated based on the strength of menhaden recruitment (the number of menhaden that are born). Scientists with NOAA’s Chesapeake Bay program have found that menhaden recruitment is negatively impacted by high striped bass populations. The 1980s, the decade cited in the letter , was a period of high menhaden abundance largely because the Atlantic striped bass population had crashed. These top predators only began recovering to today’s high levels in the late 1980s. The current menhaden population is at levels much more typical of times when the overall ecosystem is more healthy than it was in that decade.
Further, the letter claims that overfishing has occurred for 54 of the past 57 years, stating that fishing has been over “this threshold.” The referenced threshold, however, was only adopted last year when the ASMFC initially decided to embark on a more conservative management course for menhaden. Relative to the prior benchmark, the fishery had not been subject to overfishing at all for the decade leading up to 2008, when the threshold was breached by only 0.4%. Applying the new reference point retroactively to claim overfishing was occurring in the past makes as much sense as lowering the speed limit and then presenting drivers with 50 years’ worth of speeding tickets.
Moreover, the menhaden stock is at healthy levels, with more than enough reproductive capacity to sustain itself. Effort in the fishery over the past decade has been at the lowest levels in the entire 50-plus year time series. Over the past decade, catch levels are about half of what they were during the 1990s when other industrial operations of similar size and scope of Omega’s were operating. In fact, at the peak of the fishery in the 1950s, catch levels were nearly three times higher than current levels. As recently as the 1980s, over thirty vessels comparable to today’s fleet were operating in the reduction fishery. Today, Omega operates just eight vessels.
Although the Representatives are quick to fault the commercial fishery for a decline in menhaden, missing from the discussion on biomass is the role of climate and environment, two major influences on recruitment. Here is what the National Oceanic and Atmospheric Administration’s Chesapeake Bay Office says: “menhaden recruitment appears to be independent of fishing mortality and spawning stock biomass, indicating environmental factors may be the defining factor in the production of good year classes. If menhaden recruitment is largely environmentally driven, adoption of the new reference points may not result in better recruitment. However, there is a possibility that the stock may be able to take greater advantage of favorable environmental conditions if a larger percentage of spawning adults remain in the population.” The ASMFC came to a similar conclusion, noting that fluctuations in menhaden abundance may be, “almost entirely driven by non-fishery sources.”
This week’s decision on menhaden harvest cuts is far from the “common sense” opportunity the Representatives claim it is. Although their letter calls for the adoption of “new science-based rebuilding goals,” and management “based on the best scientific information available,” the authors fail to acknowledge that this most recent menhaden science has been one of the main obstacles for the ASMFC in determining the future of menhaden fishing.
Specifically, the model used to conduct the 2012 stock assessment demonstrated a severe “retrospective pattern,” a form of bias that, in this case, dramatically understates the population size and overestimates fishing mortality. Due to these recognized problems, the assessment was regarded by the ASMFC's Menhaden Technical Committee as unfit for management advice. As a result, the ASMFC is now expected to regulate a fishery whose exact status is uncertain.
Enacting regulations based solely on data that is either out of date or scientifically questionable does not serve the goal of good, science-based management, especially when the result will cause definitive economic harm. For instance, in Virginia’s Northern Neck region, where the menhaden reduction fishery is headquartered, the proposed cuts would cause significant job loss and reduced economic activity. A recent economic impact study conducted by the Virginia Institute of Marine Science highlighted the importance of the industry to this rural area of Virginia: the reduction fishery employs almost 300 people directly, and many more indirectly, and contributes more than $80 million in economic output to the Northern Neck. Without the reduction fishery, employment in the region would decrease by 8 percent and economic output by 14 percent. Enacting a new quota now could lead to a bad economic situation, and would not be “budget-neutral,” stimulate “economic growth in East Coast communities,” or preserve “thousands of jobs.”
The menhaden fishery is not seeking an unrestricted harvest. Instead, those who rely on the menhaden resource are asking that any cuts be reasonable, commensurate with the facts, and not based on the extremist rhetoric that has been circulated about the species. They are joined in this request by both the Maryland State Conference of the NAACP and the United Food and Commercial Workers Union Local 400.
Conservation of our marine resources is essential. But good conservation is based on sound science and strikes a balance between the concerns of environmentalists and the needs of fishermen whose livelihoods are at stake. Taking drastic action based on inconclusive evidence helps neither the fish nor the fishermen.