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